ML20078M277
| ML20078M277 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 10/14/1983 |
| 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, 23817, 82-01, 82-1, MCAR-55, NUDOCS 8310250101 | |
| Download: ML20078M277 (14) | |
Text
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4 POW 8r 3,n.so coou k (Ohf0l Vice President - Projects, Engineering J.,
d' and Construction General offices: 1945 West Parnall Road, Jackson, MI 49201 + ($17) 788-0453 October 14, 1983 82-01 #7 PRINCIPAL STAFF LMl f/p ]PRP Mr J G Keppler, Regional Administrator U/RE CE US Nuclear Regulatory Commission t,/ Rt DisiSP Region III E
EA 799 Roosevelt Read MO
( KS en 4 3 Glen Ellyn, IL 60137 IGA DL f
f
[ File fh MIDLAND ENERGY CENTER PROJECT DOCKET NOS 50-329 AND 50-330 DEFICIENCIES IN ELECTRICAL ACCESSORIES ASSOCIATED WITH SAFETY-RELATED MATERIAL REQUISITIONS FILE:
0.4.9.57 SERIAL: 23817
References:
- 1) J W Cook letter to J G Keppler, Main Steam Isolation Valves, Final Report, Serial 17558, Dated July 30, 1982
- 2) Serial 22171, dated April 12, 1983
- 3) Serial 22255, dated July 15, 1983 This letter is a final 10CFR50.55(e) report concerning deficiencies in electrical components in that non-Class 1E devices were wired into Class 1E circuits.
Attachment I describes action now being taken to complete resolution of this problem. All engineering investigation needed to identify procurement document discrepancies has been completed.
Oktw 1N
- E JWC/WRB/cd Attachments: (1) MCAR-55, Revision 1, Final Report, dated September 26, 1983 CC: Document Control Desk, USNRC, Washington, DC RJCook, NRC Resident Inspector, Midland Nuclear Plant DSHood, US NRC INPO Records Center Ohoh$$9 1k OC1083-0004A-MP01
2 Serial 23817 82-01 #7 OM/0L SERVICE LIST Mr Frank J Kelley Atomic Safety & Licensing
' Attorney General of the Appeal Board State of Michigan U S Nuclear Regulatory Commission Ms Carole Steinberg, Esq Washington, DC 20555 Assistant Attorney General Environmental Protection Division Mr C R Stephens (3) 720 Law Building Chief _ Docketing & Services
- Lansing, MI 48913 U S Nuclear Regulatory Commission Office of the Secretary Washington, DC 20555 Mr Myron M Cherry, Esq
. Suite 3700 Ms Mary Sinclair Three~First National Plaza 5711 Summerset Street Chicago, IL 60602 Midland, MI 48640
-Mr Wendell H Marshall Mr William D Paton, Esq RFD 10 Counsel for the NRC Staff
. Midland, MI 48640 U S Nuclear Regulatory Commission Washington, DC 20555 Mr Charles Bechhoefer, Esq Atomic Safety & Licensing Atomic Safety & Licensing Board Panel Board Panel U.S Nuclear Regulatory Commission U S Nuclear Regulatory Commission
-Washington, DC 20555 Washington, DC 20555 Dr Frederick P Cowan Ms Barbara Stamiris 6152 N Verde Trail 5795 North River Road Apt B-125 Rt 3 Boca Raton, FL 33433 Freeland, MI 48623 Mr Fred C Williams Mr Jerry Harbour Isham, Lincoln & Beale Atomic Safety & Licensing 1120 Connecticut Ave, NW, Suite 325 Board Panel
. Washington,lDC 20036 U S Nuclear Regulatory Commission Washington, DC 20555 Mr James E Brunner, Esq Mr M I Miller, Esq Consumers Power Company Isham, Lincoln & Beale 212 West Michigan Avenue Three First National Plaza Jackson, MI 49201 52nd Floor Chicago, IL 60602 Mr D F-Judd Mr John Demeester, Esq Babcock & Wilcox Dow Chemical Building PO Box 1260 Michigan Division Lynchburg, VA.24505 Midland, MI 48640 Mr Steve Gadler, Esq Ms Lynne Bernebei
.2120' Carter Avenue Government Accountability Project
.St Paul,' MN 55108 1901 Q Street, NW Washington, DC 20009 September 6, 1983
'OC1083-0004A-MP01 m
2
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Bechtel Associates Professional Corporation Management Corrective Action Report (MCAR)
Subject:
MCAR 55, Revision 1 Deficiencies in Electrical Accessories Associated With Safety-Related Material Requisitions Final Report Date:
September 26, 1983 Project:
Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220 Description of Deficiency The initial scope of the MCAR 55 included main steam isolation valves (MSIVs) and actuators supplied by Energy Products Group (EPG), a division of Gulf and Western Manufacturing Company under Purchase Order 7220-M-ll8A(Q). Major safety-related electrical components of the MSIV system (the actuators, logic cabinets, and the control panel inserts) were found to be nonconforming to the separation criteria of Regulatory Guide 1.75, Quality Assurance Program, as required by 10 CFR 50 Appendix B, or ANSI 45.2 and the project seismic requirements.
The scope of MCAR 55 was expanded as a result of project's commitment to review safety-related material requisitions for similar nonconformances. A review of four additional equipment packages
[M-125C(Q) nuclear stainless steel valves 150 through 400 pound ratings 2-1/2-inch and larger, M-149(Q) air handling units, M-150(Q) air filtering units, and M-154(Q) HVAC isolation valves) that include electrical accessories has revealed that some non-Class lE devices have been wired into Class lE circuits.
Summary of Investigation and Historical Background Investigation and historical background of MSIV deficiencies were summarized in the final report on original MCAR 55, issued July 28, 1982 (see Attachment 1). As a result of MCAR 55, further review was conducted for selected safety-related material requisitions. Contacts with four equipment package vendors and review of available documentation confirmed that some non-Class lE devices have been wired into Class lE circuits.
Analysis of Safety Implication A detailed analysis of safety implication was performed for the MSIVs in the final report on original MCAR 55 (see Attachment 1). Detailed l
analysis for each purchased item of the four additional equipment packages has been included in MCAR 55, Rev 1, review. Potential safety l
concerns exist for some of these systems to perform their safety
I2S64o Bechtel Associates Professional Corporation MCAR 55, Revision 1 i
i29622 Final Report i
Page 2 l
function as described in applicable FSAR sections because the integrity of the Class lE power and control circuits may be degraded by the inclusion of non-Class IE devices if not properly isolated.
Probable Cause the cause of MSIV deficiencies was described in the final report on original MCAR 55 (see Attachment 1).
Investigation of why some non-Class lE devices have been wired into Class lE circuits indicated the following:
a.
Some material requisitions for safety-related equipment did not directly reference the requirements of Regulatory Guide 1.75 and IEEE-384 regarding identification and separation of the Class 1E and non-Class lE functions and devices.
b.
Some vendors provided non-Class lE devices for functions which they understood to be nonsafety-related.
c.
Vendor documents frequently did not distinguish between Class lE and non-Class lE functions and devices.
d.-
Electrical schemes and control logics for this cquipment were usually l
developed on the assumption that the electrical accessories provided as part of safety-related material are Class lE.
Corrective Action Recommended Corrective Actions 1 through 6 associated with the original issue of MCAR 55 related to the MSIVs were completed (see Attachment 1).
The following actions resolve the expanded scope of MCAR 55, (Actions 7 through 10).
1.
Actions 7 and 8:
1.1 Guidelines and a checklist have been developed for review of eafety-related material requisition requirements and vendor design adequacy. All safety-related material requisitions that include procurement of electrical components and accessories (see ) have been reviewed in accordance with the guidelines and checklist. The review included the following:
a.
Review of safety-related material requisitions and specifications to ensure that equipment and accessories are properly specified to meet the project commitment of Regulatory Guides 1.89 (IEEE Standard 323), 1.100 (IEEE Standard 344), and 1.75 (IEEE Standard 384), as applicable.
l
. ~
129646 m
Bechtel Associates Professional Corporation l2ggg7 MCAR 55, Revision 1 Final Meport Page 3 b.
Based on the results of the review of Item a, a review of l
vendor electrical design (those designs where both Class lE and non-Class lE components may be present) for adequacy and clarity based on system functional requirements was conducted.
c.
Bechtel electrical design (those designs where both Class lE and non-Class IE components ara used in vendor design) interface with vendor electrical design.
d.
Identified inconsistencies.
1.2 A list identifying all safety-related equipment / instruments is being developed as project Drawing 7220-L-100(Q), and will be issued Rev.0 in accordance with engineering production schedule EPS-5010.
2.
Action 9:
Based on the results of the review of Item 1 above, a corrective action plan has been developed (see Attachment 3) to ensure that safety-related design uses only Class lE devices / equipment or provides equipment isolation as required. Attachment 3 identifies purchase orders having inconsistencies and requiring corrective actions. The following deficiencies are not included in Attachment 3 for the reason stated.
a.
Deficiencies identified on Quality Action Request (QAR) M-74 for Purchase Orders M-125C, M-149, M-150, and M-154 have been corrected except for M-150.
b.
Limitorque actuators provided on safety-related valve orders identified on MCAR 46 as having qualification and documentation problems are being resolved on MCAR 46.
c.
Qualification related deficiencies are being investigated for adequate qualification and documentation as a part of the current seismic and environmental qualification effort for all safety-related equipment.
Engineering production schedule (EPS-1017) for MCAR 55, Revision 1 activities will be revised by October 21, 1983 to include corrective action plan identified in Attachment 3.
3.
Action 10:
The review discussed above is documented and is auditable.
129646 Bechtel Associates Professional Corporation 129622 MCAR 55, Revision 1 Final Report Page 4 As a result of MCAR 55 and to preclude non-Class lE components wired into Class lE circuits all disciplines have been made aware of the probable causes of MCAR 55 problems and have been advised to consider them when preparing safety-related material requisitions that include procurement of electrical components and accessories, reviewing vendor prints, and performing Bechtel electrical interface design.
Reportability The final report on MCAR 55, issued July 28, 1982, committed to the further reviews of equipment not covered in either MCAR 55 or MCAR 46.
On March 11, 1983, Mr. W.R. Bird of Consumers Power Company notified Mr. R. Gardner of the Nhc that deficiencies in electrical accessories / devices associated with other equipment had been identified.
Submitted by: M _(' [ M k T.G. Ballweg Mechanical Group Supervisor
$G.'Kovach 4 Electrical Group Supervisor Approved by:
E.M. Hughes Project Engineer' k'
Concurred by-fM.T. Fravel Chief Mechanical Engineer i
E.H. Smith V
Engineering Manager O r M.A. Dietric W Project Quality Assurance Engineer TGB/SP/lb(M) 032305s/9
129646 Bechtel Associates Professional Corporation MCAR 55, Revision 1 129622 vin,1 Report Page 5 Attachments:
1.
Original MCAR 55 Final Report Issued July 28, 1982 2.
Material Requisitions Reviewed for MCAR 55, Revision 1 Concerns 3.
MCAR 55, Revision 1 Corrective Action Plan 4
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to MCAR 55, Revision 1 Final Report l29622 lggg g
Management Corrective Action Raport (NCAR)
SUBJECT:
MCAR 55 (Issued 1/15/82)
Deficiencies in Electrical Components Associated with MSIV Actuators, Imgic Cabinets, and Control Panel lasarts FINAL REPORT DATE:
July 28, 1982 FROJECT:
Consumers Power Company Midland Plant Units 1 and 2 Sechtel Job 7220 1
Description of Deficiency Main steam isolation valves (MSIVs) and actuaturs 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 were provided with off-the-shelf consercial grade items Recent review of the MSIV actuator design and without seismic qualification.
accessories also revealed that certain components of the hydraulic actuator, that must operate in order for the MSIV to perform its safety function, are not in accordance with the applicable IEEE standards and Regulatory Guide i
1.75 requirements.
The major safety-related electrical components of the MSIV system are the Details of actuators, the logic cabinets, and the control panel inserts.
the nonconformances and deficiencies identified are as follows:
A.
Actuator 1.
The separation criteria of Regulatory Guide 1.75 were not met.
2.
The electrical components listed below wer2 not procured by EPG as Class 1E nor in accordance with a quality assurance program meeting the requirements of 40 CFR 50, Appendix B or ANSI N45.2.
a.
Wiring b.
Trip solenoids c.
Limit switches f
i
~
MCAR 55 Final Report J29646 Date: July 28, 1982IIbb2/
Fage 2 3.
Logic Cabinets 1.
The cabinets and their components are not seismically qualified.
2.
The separation criteria of Regulatory Guide 1.75 were not met.
3.
The electrical cosponents were not procured by EPG as Class 1E nor 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.
The control panel inserts and their components are not seismically qualified.
i 2.
The separation criteria of Regulatory Guide 1.75 were not met.
3.
The electrical components were not procured by EPG as Class 1E nor in accordance with a quality assurance program meeting the requirements of 10 CFR 50, Appendix B or ANSI N45.2.
Summary of Investigation and Historical Background Bechtel became aware of possible inadequacies in the MSIVs by Consumers Power Company Nonconformance Report M?O1?970?O64, an unsolicited proposal for modification from EPG dated April 1,1980, and a review of environmental i
l qualification data.
l Contsets with the vendor, review of available documentation, and inspection of the installed hardware at the jobsite confirmed the deficiencies des-cribed above.
Analysis of Safety Implication 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 thct are required for transmission of the Mc'IS, tripping the latch mechanism, closing the valve, and maintaining s,ht shut-off, must be capable of performing 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 func-tion as described in the FSAn.
MCAR 55 129646 Final rept Date: July 28, 1982 Page 3 129622 Probable Cause The original MSIV design specification was prepared with the intention of purchasir-g 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 criteris for such items were not included in the technical specification. However, EPG offered the panel inserts and logic cabinets in their proposal as addi-tional items as an incentive to market their unique and innovative ball valve design for MSIV service. During the course of procurement, a failure to address the full safety-related requirements of the design resulted in the described condition.
This closes Action Item 6 of MCAR 55.
j Corrective Action 1.
Purchase Order 7220-M-238(Q), Main Steam Isolation Valve Electrical Modifications, has been issued to procure materir,1s that would cor-Tect the deficiencies and nonconformances that sere identified in the existing electrical equipment. This purchase order has been placed with EPG. The scope of work to be covered is summarized below. The corrective actions satisfy the requirements of Items 1 and 2 of MCAR 55.
A.
Actuator 1.
Seismically and environmentally qualified EA-180 NAMCO l
limit switches, essential mounting brackets, wiring, and flexible conduit will replace existing components. Modifi-cation of the actuator will bring it into compliance with the seismic requirements of 7220-M-236(Q) and the separation criteria of Regulatory Guide 1.75.
2.
Seismie qualification of the actuator trip solenoids and solenoid valves will be obtained.
B.
Logic Cabinets 1.
Provide four (4) new logic cabinets to meet the seismic and environmental qualification requirements and separation criteria as defined in Specificatien 7220-M-238(Q). Only one Class 1E channel will be contained in each cabinet.
C.
Control Panel Inserts 1.
Modify or replace four (4) control panel inserts to meet the seismic and environmental qualification requirements and criteria as defined in 7220-M-238(Q).
l i
129646 MCAR 55 Final Report 9622 Date: July 28, 1982 Page 4 2.
All MSIV Class 1E electrical component deficiencies have been added to the Qualification Open Action Summary dated March 11, 1982. This action satisfies Corrective Action 3 of MCAR 55.
3.
The main steam isolation valve specification, 7220?Ht118A, identified the qualification requirements for the valve and ac tuator. However, the vendor supplied logic cabinets and con?
trol panel inserts were not supplied in accordance with a recog-nized qualification program; a fact which was not detected by the MCAR 25 rareview. Specification 7220?M?238(Q) was prepared to correct the deficiencies and nonconformances that exist in the MSIV electrical equipment.
The scope of MCAR 25 did not require review of the specification to determine adequacy of imposed qualification requirements. It reviewed the specification requirements against the FSAR (e.g.
safety, Seismic Category I, adequacy of qualification reports to specification requirements).
Review of Q? listed equipment specifications in preparation for NRC audits of seismic and environmental qualifications will ensure that unresolved problems are identified. This process coupled with tracking of all NCRs in accordance with EDP 4.61 provides assurance that acceptable qualifications will be provided. The above closes the recossended Action Item 4 of MCAR 55.
l 4.
Investigation of all Q-listed valve orders on the Midland project i
revealed that electrical components associated with logic cabinets and control panel inserts that were specified with inadequate quali?
fication requirements were unique to Purchase Order 7220?M-118A(Q) only.
Limitorque actuators provided on Q-listed valve orders identified on MCAR 46 as having qualification and documentation problems are being resolved on MCAR 46 to satisfy FSAR commitments. Actuators and electrical components on orders not identified on MCAR 4Q are being identified and investigated for adequate qualifications and document tation as a part of the current seismic and environmental qualifica?
tion effort for all safetyrrelated equipment. Each of these efforts will result in reports which will be incorporated in or referenced in l
the FSAR. This closes Action Item 5 of MCAR 55.
All necessary corrective actions related to this MCAR have now been established, and have either been completed or entered into the nor?
mal engineering release tracking system.
l
-, _ _ _ _. _. -. - _ _ ~ _. _ _. _ _ _ _ - - _ _. _ _
MCAR 55 Final Report l290kO Date: July 28, 1982
$S00??
Fase 5 Reportability Based on the deficiencies that exist in the equipment and the magnitude of the effort required to make the necessary repairs, we determined that the subject of this MCAR is reportable within the requirements of 10 CFR 50.55(e). The NRC has been duly notified.
Submitted by:
Q f T.G. Ballweg Mechanical Group Supervisor Approved by
/ J A} O.
E.h. Hughes (
Project Engineer Concurrence by:
MfT. fravel E
Mechanical Discipline Chief
/
Concurrence by:
. M-ib
.H. Smith Engineering Manager Concurrence by:
l y g,A. Dietrich Project Quality Assurance Engineer TGB/JOA/am(M) l l
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. to l2$622 MCAR 55, Revision 1 Final Report i29646 Material Requisitions Reviewed for MCAR 55, Revision 1 Concerns Architectural Civil Control Systems Electrical Mechanical Nuclear None C-24 J-201 E-6 M-14 M-54 C-50B J-202 E-7 M-18 M-56 J-204 E-ll M-19 M-93 J-205 E-13 M-20 M-374 J-207 E-19 M-52 J-229 E-20 M-53 J-233 E-34 M-75 J-244 E-45 M-92 J-245 E-49 M-117 J-249 E-51B M-118B J-255A E-205 M-120 J-755E M-123A J-256 M-123B J-258 M-123C J-275A M-125A J-275B M-125B J-278 M-125C J-281 M-127B J-284 M-129A J-297 M-129B M-331 M-132 M-134 M-146 M-149 M-150 M-151 M-154 M-157 M-163 M-168 M-169 M-180 M-224 M-347 i
M-349 M-398 1
032305s/9
Attcchment 3 to MCAR 55, Rev 1 Final Report MCAR 55, Revision 1 Corrective Action Plan P.O.
Equipment D?scription Description of Deficiencies Quantity Corrective Action Remarks M-19 Emergency Diesel Cenerator Unqualified thermoswitch 4
Provide ESFAS D-G start Fuel Oil Transfer Pumps (motor thermal cut-out) signal to override ther-(lP-78A, B and 2P-78A, B) wired Class 1E mal cut-out [CPCo Letter 9/30/80 (com 12942)],
or modify circuits.
eo M-75 Service Water Pumps Unqualified motor space 5
Provide isolator or ao (OP-75A, B, C, D, E) heaters wired Class lE disconnect space heater co wiring.
rs) ea M-180 Service Water Self-Unqualified motor space 5
Provide isolator or Cleaning Strainers heaters wired Class 1E disconnect space heater (OF-75A, B, C, D, E) wiring.
M-123C Nuclear Stainless Steel Unqualified motor (Rotork) 4 Provide isolator or Valves 600-Pound Rating space heaters wired Class lE disconnect space heater and Higher, 2-1/2-inch wiring.
and Larger (IMO-1058, es3 ao 1059, and 2MO-ll58, 1159) co M-169 Hydrogen Recombiners Unqualified thermocouples 12 Qualify thermocouples to em (lVE-54A, B and Wired Class 1E Class IE, or modify C7) circuits.
2VE-54A, B)
M-150 Air Filtering Units
- 1. Two non-Class 1E instru-6 There are three options: Only two non-(OVM-78A, B; OVM-79A, B; ment systems sharing the
- 1. Rearrange Class IE Class lE and OVM-94A, B) same power supply with and non-Class lE one Class lE two Class lE instrument devfces within the instrument systems.
same panel with systems
- 2. No separation provided for proper separation involved for non-Class lE instrument and modify wiring.
OVM-79A, B.
systems.
- 2. Separate Class lE and non-Class lE devices into two panels and modify wiring.
- 3. Qualify non-Class IE devices to Class lE.
032305s/9