ML20062G874
| ML20062G874 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 08/06/1982 |
| 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, 17565, NUDOCS 8208130215 | |
| Download: ML20062G874 (14) | |
Text
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Consumcr8 Power.
Jonies W Cook C 'SEp Y
Vice President - Projects, Engineering and Construction oeneral offices: 1945 West Parnell Road, Jackson, MI 49201 e (517) #88 04b3 August 6, 1982 81-01 #8 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR PLANT DOCKET NOS 50-329 AND 50-330 UNDERRATED TERMINAL STRIPS ON LIMITORQUE VALVE OPERATORS File:
0.4.9.47 Serial:
17565
Reference:
J W Cook letters to J G Keppler, same subject:
- 1) Serial 11190, dated February 13, 1981
- 2) Serial 11976, dated April 24, 1981
- 3) Serial 12041, dated July 8, 1981
- 4) Serial 13665, dated September 11, 1981
- 5) Serial 14617, dated November 20, 1981 6)
Serial 14690, dated February 12, 1982
- 7) Serial 17503, dated June 4, 1982 This letter, as were the referenced letters, is an interim 50.55(c) report concerning the terminal strip vcitage ratings on Limitorque valve operators. provides a status of the corrective actions in progress to resolve this problem. Attachment 2 is the revised MCAR which identifies additional Limitorque deficiencies, which are still being evaluated for reportability.
If any of the additional deficiencies are determined to be reportable, it is CPCo's intention to continue to use this e:isting 50.55(e) to also track the new items.
Another report, either interim or final, will be sent on or before October 22, 1982.
T W. C, o o K
'VlOO sq JLW/1r Attachments: 1) MCAR 46, Interim Report #8, " Qualification Concerns for Various Componente on Limitorque Valve Operators," dated July 30, 1982 8208130215 820006
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gDRADOCK 05000329 PDR OC0882-0008A-MP01 AtJG 9 1982:UfM
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S2rici 17565-2 81-01 #8 Attachments: 2) MCAR-1, Report No 46 Revision 1, dated July 26, 1982 CC: Document Control Desk, NRC Washington, DC RJCook, NRC Resident Inspector Midland Nuclear Plant CBechhoefer, ASLB Panel RSDecker, ASLB Panel FPCowan, ASLB Panel JHarbour, ASLB Panel AS&L Appeal Panel MMCherry, Esq MSinclair BStamiris CRStephens, USNRC WDPaton, Esq. USNRC FJKelley, Esq Attorney General SilFreeman, Esq Asst Attorney General WHMarshall GJMarritt, Esq. TNK8J e
OC0882-0008A-MP01
Uf3960 Serial 17565 81-01 08 Bechtel Associates Professional Corporation
SUBJECT:
MCAR 46 (issued 1/15/81)
Qualification Concerns for Various Components on Limitorque Valve Operators INTERIM REPORT 8 DATE:
July 30, 1982 PROJECT:
Consumers Power Company Hidland Plant Units 1 and 2 Bechtel Job 7220 Introduction As a result of a new random inspection conducted during June 1982, this MCAR has been expanded from underrated / unqualified terminal strips on Limitorque valve operators to include other qualification concerns regarding other components on the Limitorque operator.
Description of Deficiency The following deficiencies are covered by MCAR 46:
a)
The use of underrated terminal blocks in Limitorque operators b)
The use of' terminal blocks without proper environmental qualifica-tion in Limitorque operators c)
Additional concerns regarding qualification of various Limitorque operator components These concerns are detailed below.
A.
Underrated Terminal Blocks While replacing a damaged terminal block on a Limitorque operator, Bechtel determined that some of the terminal blocks used for the termination of the leads from the 460 V motor were rated less than 460 v. These Limitorque operators, when used on safety-related valves, must function on an emergency core cooling actuation signal (ECCAS ).
In addition to being a personnel safety hazard, the potential exists for a short circuit /flashover, which could render the valves inoperative.
Bechtel Associates ProfessionalCorporation 079444 MCAR 46 Interim Report 8 Page 2 B.
Environmental Qualifiestion During random inspection for underrated terminal blocks, it was discovered that in some cases terminal blocks from manufacturers not covered by existing qualification reports were used.
Limitorque provided the following information on environmental qualification of terminal blocks in its July 31, 1981, letter.
The Buchanan 0524 has been qualified by analysis. To supplement the qualification by analysis, Limitorque is currently running a type test on the Buchanan 0524 terminal block. The Buchanan 0824 terminal blocks are not qualified and must be replaced.
Some of the Limitorque operators having Buchanan 0824 type terminal blocks have been used on safety-related valves located inside con-tainment. These operators must function on an ECCAS. The poten-tial exists for a terminal block to fail during its intended service t
life because of aging and radiation effects, which would render the valve inoperable and prevent proper operation of the safety-related system.
C.
Additional Qualification Concerns During June 1982, a random inspection was made of safety-related Limitorque valve operators supplied through various valve manufac-turers and installed inside the reactor building. This inspection resulted in various potential concerns regarding qualification of these Limitorque operators.
Summary of Investigation and Historical Background A.
Underrated Terminal Blocks 1.
The manufacturer's name was the only form of identification found on a damaged terminal block. To order a replacement for the damaged terminal block, it was therefore necessary to measure the block's critical dimensions and compare them with those for blocks listed in Marathon Catalog 10M79. This comparison indicated that the terminal blocks used for the termination of the leads from the 460 V motor could have been rated less than 460 V.
Eighteen Limitorque operators on
079416
~1 079444 Bechtel Associates ProfessionalCorporation MCAR 46 Interim Report 8 Page 3 Bechtel Purchase Order (P.O.) 7220-M-132-AC were inspected and eight were found to have underrated terminal blocks (Marathon 100 Series and Cinch Jones 140 Series). Thus, Bechtel deter-
~
mined that some terminal blocks in Limitorque valve operators may be underrated for their intended function. The other ten operators inspected had Harathon 300 Series terminal blocks which are correctly rated for the intended service. Purchase Order 7220-M-132 is with Henry Pratt Company for the supply of nuclear service butterfly valves.
2.
Representatives from Limitorque and Henry Pratt visited the Midland jobsite on January 31, 1981. After inspecting the terminal blocks, they confirmed the results of Bechtel's investigation.
3.
Random inspection was performed by Limitorque during the week of May 11, 1981, to establish the magnitude of the presence of the underrated terminal blocks in the Limitorque operators.
Limitorque provided Bechtel with detailed reports of its inspection. Af ter review of the inspection reports, Bechtel determined that underrated terminal blocks were not used on any Q-listed purchase orders except P.O. 7220-M-132(Q).
4.
Seven different types of terminal blocks were identified (Buchanan 0222, 0524, and 0824; Marathon 300 Series; Beau 7600; Kulka 622; and General Electric EB-5) during the random inspec-tion referred to in Item 3 above. All seven types are accep-table for 460 V service.
5.
Arrangements were immediately made by Bechtel to inspect any unshipped valves upon receipt at the Midland jobsite for underrated terminal blocks. Inspection results are tabulated in Item B.7 below.
6.
Limitorque/ Henry Pratt submitted the terminal block replace-ment procedure and Certificate of Compliance for the terminal blocks which Bechtel project engineering approved upon review.
The actual replacement of all underrated terminal blocks on Limitorque's Purchase Order 7220-M-132(Q) was undertaken by Bechtel construction personnel under the supervision of Limitorque service engineering during the second week of June 1982. The replacement work is now complete; all operators on P.O. 7220-M-132(Q) were inspected.
M Bechtel Associates ProfessionalCorporation 079444 MCAR 46 Interim Report 8 Page 4 B.
Environmental Qualification 1.
During the random inspection of underrated terminal blocks, referred to in Item A.3 above, Buchanan 0824 terminal blocks were found on three Limitorque operators purchased from Westing-house on P.O. 7220-M-123A for nuclear service stainless steel valves. Voltage rating data submitted by Limitorque for these terminal blocks were found acceptable. However, these terminal blocks are unacceptable because of Limitorque's previously cited finding that these blocks "are not" environmentally qualified and "must be replaced."
2.
According to Limitorque, the use of unqualified terminal block type Buchanan 0824 is limited to P.O. 7220-M-123A(Q)-AC with Westinghouse Electric, based on Westinghouse's specific require-ments. These blocks are not qualified and would require replacement with properly qualified terminal blocks. Based on random inspection results, it was concluded that Buchanan 0824 terminal blocks are not used on any other P.O.
3.
Of the seven terminal blocks listed in Item A.4 above, Limi-torque stated that terminal blocks types Buchanan 0222 Buchanan 0524, Curtis Type L, Marathon 300 Series, and General Electric EB-5 were environmentally qualified for inside contain-ment, but were unable to provide the required qualification documentation.
4.
Limitorque presently has no specific plans for an environmental testing of the remaining terminal block types Kulka 622 and Beau 7600 for outside containment use.
5.
Environmental qualification documentation for terminal block types specified in Items B.3 and B.4 above was received on July 7, 1982. Bechtel is currently reviewing this documentation.
6.
Bechtel field engineering has generated Nonconformance Report (NCR) 3780 against valves 2MO-llli, 2MO-1101B, and 2M0-1120B purchased from Westinghouse Electric on P.O. 7220-M-123A(Q)-
AC, Items 4.2, 5.4, and 5.8, respectively. This NCR was initiated at the request of project engineering because of the presence of an unqualified terminal block, Buchanan 0824.
i e
m
079416 1
079444 Bechtel Associates Professional Corporation MCAR 46 Interim Report 8 Page 5 7.
The following 18 operators were to be inspe'ted upon receipt c
from the vendors at the jobsite for the presence of noncon-forming terminal blocks. The statas is as follows:
Terminal Block (TB)/
P.O. Number Item (Quantity)
Remarks 7220-J-255A(Q) 23(8)
TB Kulka 622 7220-M-117(Q) 5.1(1 )
Under investigation 7220-M-117(Q) 5.2(1)
(Valves converted to 7220-M-117(Q) 5.3(1) manual type; operators 7220-M-117(Q) 5.4(1) have been surplused) 7220-M-168(Q) 1.5(1)
TB Buchanan 0222 7220-M-398(Q) 1.1(1)
TB Kulka 622 7220-M-398(Q) 1.2(1)
TB Kulka 622 7220-M-398(Q) 3.1(1)
TB Kulka 622 7220-M-398(Q) 3.2(1)
TB Kulka 622 7220-M-398(Q) 3.3(1)
TB Kulka 622 All operators listed above are located outside ccntainment.
The terminal blocks' voltage ratings are acceptable. However, environmental acceptability is pending review and acceptability of the Limitorque qualification documentation described in Item B.5 above.
C.
Additional Qualification Concerns 1.
The motor nameplate on some Limitorque operators installed inside the containment lists a 40C ambient certification. The specified reactor building ambient temperature is 50C.
2.
The motor on some Limitorque operators located inside containment lists the insulation as Class B, which according to industry standards is good for an ambient temperature of only 40C. The specified reactor building ambient temperature is 50C.
3.
No identification was evident on wiring internal to the Limi-torque operators. It is not presently known whether this wiring is qualified for the service conditions.
l t
Bechtel Associates ProfessionalCorporation 079444 MCAR 46 Interim Report 8 Page 6 4.
Various orientations of installed operators were observed.
It has not been verified in Limitorque's original qualification report that the operators are qualified for all installed orientations.
5.
Drain plugs on operators were observed to be both in place and removed. Orientation of the operators did not always result in the drain holes being at the lowest point of the installed operator. It is not presently known whether the existence of the drain plug or the orientation of the drain hole is essen-tial to proper operation of the operator or is in conformance with the qualification tests for the operator.
6.
Various Limitorque operator limit switch gear frames were observed to be made of a white metal. It is not presently known whether these gear frames are made of aluminum, a material not qualified for the service conditions.
7.
Information obtained from purchase order files and QVDP files l
does not agree with the installed components.
8.
It is presently not known whether space heaters are qualified or required to be qualified.
Safety Implications and Reportability Seven of the eight valve operators having underrated terminal blocks are located in the component cooling water and service water systems and are used on safety-related valves. These must function on an emergency core cooling actuation signal. The potential exists for a short circuit /flashover which could render the valves inoperative.
Based on the potential safety concerns, this item was considered reportable. This deficiency was reported by Consumer. Power Company on January 14, 1981, to R. Sutfin, R. Cook, and R. Knop of the Office of Inspection and Enforcement, Region III, U.S. Nuclear Regulatory Commission, as a reportable deficiency for Midland Plant Units 1 and 2 in accordance with 10 CFR 50.55(e).
l e794iG Bechtel Associates Professional Corporation 0 7 9 45{)frI' Report 8 Page 7 Probable Cause A.
Underrated Terminal Block According t0 Limitorque, it does not stock Marathon 100 Series terminal blocks. However, Limitorque believes (according to its January 21, 1981, letter) that when its field service engineer visited the Midland jobsite in November 1977 to increase the number of points on the terminal blocks for 66 operators (P.O. 7220-M-132),
he may have procured the subject terminal blocks locally. Limitorque further explained that an additional 20 terminal blocks (140 Series, manufactured by Cinch Jones) were shipped to Midland, to make up for quantities damaged in an earlier shipment. These blocks are similar to Marathon Series 100 blocks and may have been used by the Limitorque service engineer to terminate the 460 V motor leads.
According to Limitorque's July 1, 1982 letter, the root cause for the presence of' underrated terminal blocks was the lack of adequate training for a newly employed field service engineer.
B.
Unqualified Terminal Block According to Limitorque's July 1, 1982, letter, Buchanan 0824 ter-minal blocks have not been tested for environmental qualification.
These terminal blocks were furnished with actuators built in 1974 to the specific requirements of an individual valve manufacturer.
However, the terminal blocks were considered qualified by analysis at the time they were supplied. The Buchanan 0824 uses nylon construction, which is unacceptable in today's acelear industry.
It is Limitorque's opinion that this terminal block would pass a nuclear qualification test; however, because of the stigma attached to the use of nylon in this application, the terminal block would still be considered unacceptable.
C.
Additional Qualification Concerns The additional concerns addressed above are still being defined.
A discussion on the probable causes of these concerns will be covered in a future interim report.
..79416 7
c 079444 I
Bechtel Associates Professional Corporation MCAR 46 Interim Report 8 Page 8 Corrective Action A.
Underrated Terminal E:ocks During Limitorque's June 1982 inspection / replacement trip to the Midland jobsite, all underrated terminal blocks were replaced by correctly rated Marathon 300 Series terminal blocks on operators purchased on P.O. 7220-M-132(Q). Thus, this deficiency will be considered completely resolved, pending receipt and acceptance of a report covering the inspection / replacement activities. A formal report is expected to be in by July 30, 1982.
B.
Unqualified Terminal Blocks 1.
Bechtel project engineering is to complete its review of the terminal block qualification documentation recently submitted by Limitorque by August 6, 1982.
2.
Bechtel project engineering is to provide procurement with specifics for further inspection and replacement for unquali-fled terminal blocks by August 13, 1982. This will include terminal blocks on all Limitorque operators located inside containment, outside containment in harsh environments, and those purchased on P.O. 7220-M-123A(Q).
3.
Bechtel project engineering is to disposition NCR 3780 by August 20, 1982.
4.
Procurement is to arrange with valve manufacturers /Limitorque/
Bechtel construction by August 20, 1982, for inspection and replacement of unqualified terminal blocks in Limitorque operators in accordance with input provided by project engi-neering in Item A.2 above.
C.
Additional Qualification Concerns An evaluation is presently being conducted to determine whether the identified concerns could adversely affect operation of the Limitorque operators. Part of this evaluation will include a determination of the Limitorque operators having tie particular concern. Based on the results of this evaluation, further required actions will be reported in future interim reports.
7 I B 4'l.
079444 Bechtel Assor.Ites Professional Corporation MCAR 46 Interim Report 8 Page 9
/NIA </ [q Submitted by:
/
A$8
'T. Ballweg 6
d Mechanical Group
'V" Supervisor Approved by:
W E.M. Hugheh Ann Arbor Project Engineer Concurrence by:
1 M. Fravel Chief Mechanical Engineer j
Concurrence by:
[
N E. Smith' Engineering Manager Concurrence b :
M.A. Dietrich Project Quality Assurance Engineer i
QUALITY ASSURANCE PROGRAM 079444 MANAGEMENT CORRECTIVE ACTION REPORT
[,t[
6!
y MCAR1 81-01 #8 46 Rev 1 REPORT NO.:
7220 uly 26, 1982 JOB NO.:
0 NO.:
DATE:
l DESCRIPTION * (Including References):
I This MCAR has been revised to reflect additional deficiencies discovered during a random inspection at Midland site on Limitorque valve operators. These deficienciesarerelatedtoequipmentqualificationandaredetailedinSectionB:g below.
(continued) f RECOMMENDED ACTION * (Optional):
Project Engineering:
- 1. Identify the purchase orders, quantity, purchase order item numbers, and location of all Limitorque Operators used in safety-related systems.
(continued)
REFERRED TO:
DI Engineering O Construction O OA Management O
NOTE: The addition l W iE*e"ncies identi-7!2A /b2-fied in this revision are being ISSUED BY:
I
' ' * * ' ^ * " ' ' *
- evaluated for reportability.
f#f l
anuaq 14, i m ll REPORTABLE DEFICIENCY:
l NOTIFIED CUENT:
one 00YES
/s/ J.A. Rutgers January 15', 1981 O NO l
Pm aiu-=e-one i
Ill CAUSE:
CORRECTIVE ACTION TAKEN:
AUTHORIZED BY:
om.
AAPO OtSTheuTtoN PRoJ DtSTRieUTION oTHER DISTRIBUTION uGR or construction cN Er coNsTR oc ENGR uGR or on. TPo FORMAL REPORT TO CUENT uGR or ENGmEER G curNT GPo on uGR (If Sectionll Applies) o==
WGR or PROCUREMENT ProCE LAPo oA MGR MGR or PROJ OPERATIONS PROJECT CoNSTR MGR SFPo - QA MGR uGR or ovauTv ASSURANCE PRoact ENGaEER CORRECTIVE ACTION IMPLEMENTED CONSTRUCTION MGR PROJECT WGR ENGhEERING WGR PROJ PROCUREMENT WGR suPPuER ouaufv uGR sTE uGR oE SUPERVISOR VERIFIED BY
'Desenbe in space provided and attach reference document.
Pmpact oA Engmeer oste a4Po oooo Section Number Page of
1 MCIR 46 Rev 1 O[hkkk
' July 26, 1982 Pega 2 of 3 I DESCRIFTION (continued)
A) During the wiring installation of a Henry Pratt Butterfly Valve actuated by a Limitorque Operator, the Marathon terminal strip on the operator broke. Measurement of the strip and comparison with the dimensions on the Marathon catalog led to the suspicion that the terminal strips were underrated.
Investigative action disclosed that 8 of the 18 operators on the M-132 Purchase Order had 100 Series Marathon Terminal Blocks rated at 250 volts for use in a 460 Solts supply circuit. The remaining 10 Operators had 300 Series Marathon Terminal Blocks which are currently rated at 300 volts by the manufacturer, but were presumably rated at 600 volts at time of initial fabrication of the valve operator.
Since 8 of the 18 operators checked have underrated terminal strips, the potential for a short circuit or flash-over exists.
Since 7 of these valves are installed in safety-related systems and considered active, this condition has been reported by the Consumers Power Company to the NRC under 10 CFR 50.55(e).
B) Additional Deficiencies i
1.
The motor nameplate on some Limitorque operatoars installed inside the containment lists a 40C ambient certification. The specified reactor building ambient temperature is 50C.
j i
2.
The motor on some Limitorque opertors located inside containment
)
lists the insulation as Class B, which according to industry standards is good for an ambient temperature of only 40C. The specified reactor building ambient temperature is 50C.
3.
No identification was evident on wiring internal to the Limitorque operators.
It is not presently known whether this wiring is qualified for the service conditions.
4.
Various orientations of installed operators were observed.
It has not been verified in Limitorque's original qualification report that the operators are qualified for all installed orientations.
(
5.
Drain plugs on operators were observed to be both in place and l
removed. Orientation of the operators did not always result in
(
the drain holes being at the lowest point of the insta'lled i
operator.
It is not presently known whether the existence of the drain plug or the orientation of the drain hole is essential to proper operation of the operator or is in conformance with the qualification tests for the operator.
I L
,-', MCAR 46 Rev 1 July 26, 1982 Page 3 of 3 6.VariousLimitohe3shlakorlimitswitchgearframeswereobserved F
to be made of a white metal.
It is not presently known whether l
these-gear frames are made of aluminum, a material not qualified
[
for the service conditions.
- 7. Information obtained from purchase order files amd QVDP files does not agree with the installed components.
- 8. It is presently not known whether space heaters are qualified or required to be qualified.
RECOMMENDED ACTION (continued) 2.
Prepare, schedule, and implement an inspection plan to check the terminal strips on operators identified in Action (1).
Identify all underrated terminal strips.
3.
Determine the correceive action required to rectify the discrepancies identified.
Plan a schedule of implementation.
Project Procurement:
4.
Procurement Supplier Qualiry is to identify any open Purchase Orders for valves with Limitorque Operators and take appropriate action so that no operators are shipped to the jobsite without verification of terminal strip ratings by the cognizant SQRs.
5.
Remind the concerned vendors that if they submit a 10 CFR 21 report, they must notify project as required under the terms of the contract.
Project Engineering and Procurement:
6.
Coordinate and issue the first interim report by February 6, 1981.
7.
Project engineering to evaluate the additional deficiencien and their effects on plant safety.
8.
Project engineering tc, identify all deficient valve operators and take the appropriate actions necessary to correct the deficiencies and preclude recurrence.