ML20040G767
| ML20040G767 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/04/1982 |
| 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, 14682-82-01, 14682-82-1, NUDOCS 8202160446 | |
| Download: ML20040G767 (7) | |
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s Consumers power James W Cook CDMpBHY Vice President - Projects, Engineering and Construction
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82-01 #1 General offices: 1945 West Parnall Rome, Jacksw. MI 49201 * (517) 78& O453 February h, 1982 i, N.
Mr J G Keppler, Regional Administrator d \\Al/qc
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US Nuclear Regulatory Commission p'y' l'e Region III
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MAIN STEAM ISOLATION VALVES FILE:
0.h.9 57 SERIAL:
1h683
/ QT'(f This letter is an interim 50 55(e) report concerning deficiencies in electrical components associated with main steam isolation valve actuators, logic cabinets and control panel inserts. This condition was reported January 5 to R C Knop of URC Region III.
Attachments 1 and 2 provide a description of the deficiencies and the status of the planned corrective actions.
Another report, either interim or final, vill be sent on or before April 1, 1982.
WRB/1r CC:
Document Control Desk, NRC Washington, DC (1)
RJCook, NRC Resident Inspector Midland Nuclear Plant (1)
Attachments:
(1) Bechtel Management Corrective Action Report MCAR-1, Report No 55, dated January 15, 1982 (2) Bechtel MCAR-55, Interim Report 1, dated January 26, 1982 gg B ON P202160446 820204 PDR ADOCK 05000329
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.,_ Serial 14683 CC: CBechhoefer, ASLB Panel r-RSDecker, ASIS Panel FPCowan, ASLB Panel JHarbour, ASLB Panel
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AS&L Appeal Panel
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M4 Cherry, Esq
- MSinclair BStamiris CRStephens, USNRC WDPaton, Esq, USNRC FJKelley, Esq, Attorney Gen SIL'reeman, Esq, Asst Attorney Gen WHMarshall GJMerritt, Esq, THK&J Great Lakes QA Managers w
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OUALITY ASSURANCE PROGRAM senal 1%d3 e2-01 #1 MANAGEMENT CORRECTIVE ACTl2N REPORT Pega 1 cf 2 55670 MCAR1 REPORT NO.:
55 7220 JOB NO.:
O flO.:
DATE:
January 15, 1982 i DESCRIPTION * (including References):
Main Steam Isolation Valves (MSIVs) were supplied by Fluid Systems Division (FSD) of Gulf C. Western Manufacturing Company under Purchase Order 7220-M-118A(Q) issued 8/22/74. The design for the electrical components associated with these valves does not appear to conform to the channel separation criteria in Reg. Guide 1.75 to the extent required by the FSAR; also, satisfactory seismic qualification reports i. ave not been submitted for these electrical components. The electrical components of concern associated with the MSIV were identified as follows:
(continued)
RECOMMENDED ACTION * (Optional):
1)
Take the appropriate corrective action to make the design and the hardware confo to the requirements of Regulatory Guide 1.75 and IEEE standard as committed in FSAR.
2)
Obtain the required equipment seismic qualifications.
3)
Add the above mentioned Class lE electrical components associated with the MSIVs to the Qualification Test Status Report (QTSR) as outstanding items to be quali-fled.
(continued)
REFERRED TO:
I Engineering O Construction O QA Management O
O Procurement l!I Ob ISSUED BY:
Pro,.cio4 Eng
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I Potentially ll REPORTABLE DEFICIENCY:
l Reportable NOTIFIED CUENT:
January 6' 1982 l
O NO 50YES f
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I Ill CAUSE:
CORRECTIVE ACTION TAKEN:
t AUTHORIZED BY:
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t,APO DISTRIBUTm PROJ DISTR.BUTION OTHER DISTRIBUTION MGR or construction cuiEr coNsin oc ENoR uGR or ca. TPo FORMAL REPORT TO CLIENT uGR or ENGn.E ERno cufNT oPo. on uGR (If Section11 Applies) oa MGR OF PROCUREMENT PFoCE LAPO oA MGR MGR cF PROJ OPERATIONS PROJcOT CONSTR MGR SFPD. oA MGR uGR or ovauf, assUR*NcE PROJECT ENGmEER CORRECTIVE ACTION IMPLEMENTED CONSTRUCTION MGR PRGJECT MGR ENGINEERING MGR PROJ PROCUREMENT MGR SUPPUER oVAUTY MGR SITE MGR oE SUPERVISOR VERIFIED BY
- Descnt>e in spaco provided and attach reference document.
Pro,.ci on Eng.i.,
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a*Po ooos Section Number Page of
055670 reg 2 cf 2 MCAR-55
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DESCRIPTION (continued) 1)
Actuator, limit switches and wiring 2)
Actuator terminal box and conduits 3)
Safety-related actuator solenoid valve 4)
All components and wiring of the logic cabinets and control panel inserts, except for the pressure transducer digital readout.
Appendix Al to Specification 7220-M118A(Q), Para 1.19.20 states:
The equipment included in this specification shall be designed, built, tested, and shall conform in accordance with the latest applicable AGMA, ANSI, ASTM, IEEE, and NEMA Standards.
RECOMMENDED ACTION (continued) 4)
Determine why qualification for the electrical components was not detected by MCAR 25 re-review. Add to the QTSR any other deficien-cies pertinent to equipment qualification identified on NCRs.
5)
Engineering shall determine what other purchases this specifica-tion or similar valve specifications for electrically operated Q-listed valves were used in which associated electrical components were purchased with the valves. Engineering shall review the identi-fied purchases to ensure that the seismic qualification documentation and electrical separation requirements satisfy the FSAR commitments, and take appropriate corrective action as required.
6)
In order to preclude recurrence, Engineering shall determine, identify and define the root cause of this problem.
7)
Engineering to issue interim report by January 26, 1982.
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3 057009 057202 seria 1ac83 4
82-01 #1
SUBJECT:
MCAR 55 (Issued 1/15/82)
Deficiencies in Electrical Components Associated with MSIV Actuators, Logic Cabinets, and Control Panel Insercs INTERIM REPORT 1 DATE:
January 26, 1982 PROJECT:
Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220 Description of Discrepancy Main steam isolation valves (MSIVs) and actuators were supplied by Energy Products Group (EPG), a division of Gulf and Western Manufacturing Company, under Purchase Order 7220-M-118A(Q). The logic cabinets and control panel inserts were vendor supplied units not covered in detail by the valve specification, and are currently of f-the-shelf commercial grade items with-out seismic qualification. Recent review of the MSIV actuator design and accessories also revealed that certain components of the hydraulic actuator, that must operate in order for the MSIV to perform its safety function, may not be in accordance with the applicable IEEE standards and Regulatory Guide 1.75 requirements.
Bechtel became aware of possible inadequacies in the MSIVs by Consumers Power Company Nonconformance Report M-01-9-0-064, and an unsolicited proposal for modification from EPG dated April 1, 1980, and a review of environmental qualification data.
. The major safety-related electrical components of the MSIV system are the actuators, the logic cabinets, and the control panel inserts. Detailssof the potential nonconformances and deficiencies currently identified are as follows:
A.
Actuator 1.
It is not certain if the separation criteria of Regulatory Guide 1.75 was achieved as physical inspection for separation has not yet occurred.
2.
It is not certain that the essential electrical components listed below were designed and procured by EPG as Class lE and in accord-ance with a quality assurance program meeting the requirements of 10 CFR 50 Appendix B or ANSI N45.2.
a.
Trip solenoids and wiring b.
Trip solenoid valves c.
Limit switches d.
Position switches for the solenoid valvca
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Logic Cabinets 1.
Existing documentation does not substantiate that the cabinets are seismically qualified.
2.
The separation criteria of Regulatory. Guide 1.75 was not achieved.
3.
It is noti certain that essential electrical components' were designed and procured by EPG as Class 1E and in accordance with a quality assurance program meeting the requirements of 10 CFR 50 Appendix B or ANSI N45.2.
C.
Control Panel Inserts 1.
Existing documentation does not substantiate that the panel inserts
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are seismically qualified.
2.
The separation criteria of Regulatory Guide 1.75 was not achieved.
3.
It is not certain that essential electrical components were designed and procured by EPG as Class lE and in accordance with a quality assurance program meeting the requirements of 10 CFR 50 Appendix B or ANSI N45.2.
Potential Safety Problem The safety function of the actuator and associated electrical components is to provide emergency closure of the MSIV upon receipt of either a Channel A or
-Channel B main steam line isolation signal (MSLIS). All electrical components that are required for transmission of the MSLIS, tripping the latch mechanism, closing the valve, and maintaining tight shut-off, must be' capable of perform-ing the safety function during or af ter a seismic event.. A potential safety problem exists if failure of any of the components results in failure of the MSIV to perform its safety function as described in the FSAR.
Investigation / Corrective Action The following actions have been initiated or completed to resolve this situation.
1.
The probable cause of the problem has been identified. The original MSIV design specification was prepared with the intention of purchasing only valves and power operators. Logic cabinets and control panel inserts were not contemplated when the original specifications were prepared and issued for bid; and therefore, design requirements and criteria for such items were not included in the technical specification. However, EPG l
offered the panel inserts and logie cabinets in their proposal as addi-i tional items as an incentive to market their unique and innovative ball valve design for MSIV_ service.
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'2.
Action.is being initiated to either confirm or modify the design and the hardware to conform to the requirements of the applicable regulatory.
i guides and IEEE standards. Components requiring Class 1E and seismic qualification have been identified. A specification addenda that includes the applicable IEEE standards and regulatory guides is in internal review.
When the full scope of work has been established, action to implement will be taken.
3.
The electrical components that are determined to require quelification will be added to the qualification open action summary (QOAS)'as out-j standing items which require qualification prior to plant completion.
4.
Response to this corrective action will be addressed in the next report.
5.
Electric-hydraulic operators were purchased on 7220-M-118B for feedwater isolation and auxiliary-feedwater cross-connect service. Extensive environmental and electrical qualification was performed on these operators.
These valves do not have free standing or separate electrical components.
'The seismic qualification documentation and electrical requirements satisfy the FSAR commitments. Determination of need to examine similar specifica-tions is under review and will be discussed in the next report.
6.
See Corrective Action Number 1 for probable cause.
Reportability Consumers Power Company verbally informed D. Knop, USNRC Region III represen-tative, that the MSIV deficiencies were a potentially reportable 50.55(e) concern on January 5, 1982. Bechtel is now separately performing an evaluation to determine if the items involved are actually reportable.
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