ML20032C268
| ML20032C268 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/28/1981 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, 14715, 78-10-#12, NUDOCS 8111090573 | |
| Download: ML20032C268 (3) | |
Text
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@ power Consumers Jesnes W Cook C0n1pany vi,, e,,,i,,,, - e,oi,,,, e.,i.,,,i.,
and Co.struction General Offices: 1945 West Parnell Road, Jackson, MI 49201 * (517) 788-o453 October 28, 1981 78-10 #12 N
Mr J G Keppler, Regional Director f
Office of Inspection & Enforcement 8
7 Region III N
US Nuclear Regulatory Commission
. f.- u. OVO 6 799 hoosevelt Road b^
Glen Ellyn, IL 60137
'M@ roes 2 s.
MIDLAND PROJECT -
DOCKET NOS 50-329, 50-330 4
COMPONENT QUALIFICATION TEST DOCUMENTATION RE-REVIEW FILE 0.4.9.22 SERIAL 14715 Reference CP Co letters to J G Keppler; Same Subject;
- 1) Serial Howe-252-78, dated November 26, 1978
- 2) Serial Howe-17-79, dated January 17, 1979
- 3) Serial Howe-79-79, dated March 9, 1979
- 4) Serial Howe-133-79, dated May 4, 1979
- 5) Serial Howe-193-79, dated July 6, 1979
- 6) Serial Howe-265-79, dated September 10, 1979
- 7) Serial Howe-48-80, dated February 29, 1980
- 8) Serial 9126, dated June 13, 1980
- 9) Serial 8829, dated September 19, 1980
- 10) Serial 10074, dated December 5, 1980
- 11) Serial 11523 dated March 25, 1981 The referenced letters were interim 50.55(e) reports. This letter is a final report.
Consumers Power Company (CP Co) initiated a limited effort, in early 1978 to review selected component seismic and environmental qualification documentation. This resulted iri a question as to the adequacy of existing documentation to demonstrate component qualification.
In August, a component qualification re-review program was initiated for all the seismic and environmental qualification test requirements, procedure and reports for the procurements processed by Bechtel. The quantity of discrepancies being identified during the review caused CP Co to inform the NRC on November 13, 1978, of a condition which was potentially reportable under the criteria set forth in 10 CFR 50, Section 55, Paragraph _(e).
The potentially reportable condition was stated to be: The review process which the qualification test l
oc1081-0890a141 NOV 2 1981 I
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documentation was subjected to was found to be deficient in that it permitted continued action on components which may not have qualified to the specification requirements.
The condition became reportable by January 5, 1979 when it was determined that the Foxboro Model E10 Series Pressure Transmitters which were performing a safety-related function, were not capable of meeting the Midland plant seismic and environmental qualification requirements. These transmitters are being replaced with qualified transmitters. To date no other safety-related equipment has been identified as unable to meet Midland seismic and environmental qualification requirements.
Part corrective action, for the Bechtel supplied equipments consisted of a complete re-review of all previously accepted qualification documentation following the procedure attached to Reference 2.
Nonconformance reports were issued on those purchase orders / components which the re-review identified as having inadequate qualification documentation. A similar re-review was performed on B&W supplied equipment.
Process corrective action developed and implemented at Bechtel during 1979-1980 included the below actions:
(a) Engineering personnel responsible for reviewing supplier - submitted seismic and environmental qualification documents were required to attend special training sessions on the subject. These training programs are periodically repeated for new personnel.
(b) A procedure was developed and implemented to describe the process for the review of qualification requirements and data.
(c) A change in procedures to require review of qualification documents by
" Licensing" and " Quality Engineering" groups in addition to the engineering personnel review.
(d)
Implemented the " Qualification Open Action Summary" and " Qualification Test Status Report" tracking systems to insure all equipment is qualified.
Because there were no significant discrepancies between qualification documentation and specification requirements on the B&W supplied equipment, there was no formal process corrective action implemented at B&W.
Additional assurance that ongoing equipment qualification efforts at B&W will meet Midland requirements is being provided by CP Co utilizing a knowledgeable individual to review all qualffication documents.
Subsequent to the initiations of the above actions, we received D F Ross, Jr's letter on " Qualification of Safety-Related Electrical Equipment" dated February 24, 1980. A review of the environmental qualification of safety related electrical equipment against this letter requested the new requirements contained in NUREG-0588 which was issued "for comment" in December 1979 and provide a tabulation of certain environmental qualification information.
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In response to that request, component data summa ry sheets, review checklists and detailed review procedures were developed. A description of this review program and results will be in the November 1981 revision of the Midland FSAR.
The Midland seismic response spectra is being revised. This revision requires a complete re-review of all seismic qualification information which is being documented on a detailed form / checklist. NRC verification of the adequacy of this effort will be provided by the Seismic Qualification Review Team Audit.
In summary this is a final 50.55(e) report on this issue because; (a) Part corrective action has been completed by the complete re-review and ar.y open items are being tracked by open NCR's, Qualification Open Action Summary, Qualification Test Status Report and will be identified in the Qualification Volumes of the FSAR, (b) All discrepancies are being resolved in a manner that does not compromise safety, (c) Modification of administrative procedutea and training to prevent future recurrence were accomplished (d) Additional reviews by CP Co, Bechtel and B&W to further verify adequacy of qualification are still underway for final response to the Ross letter and open seismic issue and (e) the areas involved are scheduled to be audited by the NRC.
JWC/WRB/mo CC Director, Office of Inspection E Enforcement Att Mr Victor Stello, USNRC (15)
Director, Office of Management Information & Program Control, USNRC (1)
R Cook, USNRC Resident Inspector Midland Nuclear Plant (1)
AS&L Appeal Panel CBechhoefer, ASLB MMCherry, Esq FPCowan, ASLB SIIFreeman, Ass't Attorney General FJKelley, Esq, Attorney General RSDecker, ASLB WILMa rshall GJMerritt, Esq, TNK&J WDPaton, Esq, USNRC MSinclair BStamiris CRS'.ephens, USNRC oc1081-0890a141