ML20079H162
| ML20079H162 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/16/1984 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 2665, 83-15-1, MCAR-1, MCAR-79, NUDOCS 8401230344 | |
| Download: ML20079H162 (6) | |
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Consumers Power James W Cook Vice President - Projects, Engineering and Construction General offices: 1945 West ParneH Road, Jackson, MI 49201 * (517) 788-0453 January 16, 1984 83-15 #1 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER PROJECT DOCKET NOS 50-329 AND 50-330 NON-SEISMICALLY SUPPORTED C0!!PONENT COOLING WATER PIPING SYSTEM FILE:
0.4.9.87 SERIAL:
26665 On December 16, 1983, Consumers Power Company notified your staff of a potential 10CFR50.55(e) condition involving the attachment of non-Q/non-seismic piping to the component cooling water system.
This letter is an interim 10CFR50.55(e) report. The attachments to this letter describe the concern and summarize the investigation and corrective action taking place.
Another report, either interim or final, will be sent on or before April 20, 1984.
JWC/AHB/lr Attachments:
(1) MCAR-1, Report No 79, dated December 19, 1983 (2) MCAR-79, Interim Report 1, dated January 9, 1984 CC: Document Control Desk, NRC Washington, DC RJCook, NRC Resident Inspector Midland Nuclear Plant DHood, USNRC Office of NRR INPO Records Center 8401230344 840116 PDR ADDCK 05000329 JAN 18 @
OC0184-0031A-MP 1
2 Serial 26665 83-15 #1 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 Nuclea. Regulatory Commission Washington, DC 20555 Mr Charles Bechhoefer, Esq
)
Atomic Safety & Licensing Atomic Safety & Licensing I
Board Panel Board Panel f
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, DC 20036 U S Noclear 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 Cadler, Esq Ms Lynne Bernabei 2120 Carter Avenue Government Accountability Project St Paul, MN 55108 1901 Q Street, NW Washington, DC 20009 OC0184-0031A-MP01
l37660 ittechment _
O serie1 266c5 83-15 #1 l'
I QUALITY ASSURANCE PROGRAM jt p MANAGEMENT CORRECTIVE ACTION REPORT MCAR 1 REPORT NO.
79 g.
JOB NO. 7220 Q NO.
DATE 12/19/83 l* DESCRIPTION (including references):
A potential deficiency has been identified concerning non-Q piping connected to Q-list equipment. Specifically, a condition exists where non-Q/non-seismically supported component cooling water piping is connected to Q-listed letdown coolers in the reactor building, as follows:
(continued)
- RECOMMENDED ACTION (Optional) 1)
Perform an invaluation to determine what impact this condition would have on the safety of operations at Midland if left uncorrected.
2)
If, as a result of Item 1) above, the effected hardware is found to be nonconforming, initiate proper controls in accordance with project procedures for nonconforming items.
(continued)
REFERRED TO EXENGINEERING O CONSTRUCTION O OA MANAGEMENT O
bN
/M/'7/I3 O PROCUREMENT ISSUED Y
/ ate
- This condition was reported to the NRC by the
. Project OA Eng,r.pr D
client as a potential 10 CFR-50.55(e) on 12/16/83.
s 11 REPORTABL E DEFICIENCY NO F
0 NO
- DI YES
/
8 3 Project Managar [
' Dat6 111 CAUSE CORRECTIVE ACTION TAKEN AUTHORIZED BY Date STANDARD DlSTRIBUTON ADDITONAL DISTRIBUTON - AS APPROPRIATE DMSON OA MANAGER ENGtNEERING MANAGER FORMALREPORT TO CLIENT MANAGER OF OA BPC PROJECT ENGINEER (if Section11 Applies)
Date GPD OA MANAGER OE SUPERVISOR Ct ASTRUCTON MANAGER D OA M NAG R PROJ SUPT /PROJ CONSTR MANAGER PROJECT MANAGER CHIEF CONSTR OC ENGINEER CLIENT CORRECTIVE ACTION IMPLEMENTED DIVISON PROCURENT MGR PROJ PROCUREMENT MGR PROCUREMENT SUPF' LIER QUALITY MGR AND DIV SUPPLIER QUAT.!TY MGR VERIFIED BY Project QA Engineer Date
- Describe in space provided and attach reference document.
AAPD-0161
1 o
O 137660
~
MCAR 79 Page 2 Description (continued):
Unit Line Line Equipment Equipmant Reference Number Number Class Number Class Document Unit 1 6" 1HBD-448 thru 451 Non-Q 1E-57A&B Q
H-616SH5(Q)
Unit 2 6" 2HBD-448 thru 451 Non-Q 2E-57A&B Q
H-617SHl(Q)
Assuming a worst case condition, the possibility exists that the non-seismically supported component cooling lines connected to the letdown coolers could fail during a seismic event. If this piping were to collapse during an earthquake, significant loads would be transferred through the coolers and into the equipment support structure, possibly causing failure of the supports and collapse of the coolers. This occurence would result in a subsequent failure of the safety related piping connected to the ecclers, thereby possibly causing a breach of the reactor coolant pressure boundary.
I Recommended Action (continued):
3)
Perform a review to determine if similar conditions exist where non-Q systems are connected to safety related equipment.
4)
If deficiencies are identified from item 3) above, perform an evaluation to determine the impact on safety of operations, initiate proper controls for any hardware nonconformances in accordance with project NCR procedures.
5)
Determine root cause of the design deficiency and provide corrective action to preclude recurrence.
6)
Issue initial report, interim or final, by 1/3/83.
~
f Serial 26665 f39455 83-5 #1 Bechtel Associates Professional Corporation I3946i
SUBJECT:
MCAR 79 INTERIM REPORT 1 DATE:
January 9, 1984 PROJECT:
Midland Plant Units 1 and 2 Consumers Power Company-Bechtel Job 7220 Introduction This report provides the status and course of corrective action required by Management Corrective' Action Report (MCAR) 79.
Description of Deficiency A condition exists where non-Q/nonseismically supported component cooling water (CCW) piping is connected to Q-listed letdown coolers in the reactor building.
The following lines are involved in this deficiency:
Equip-ment Reference Unit Line Line Class Equipment Class Document (7220-)
1 6"-1HBD-448 through Non-Q 1E-57A&B Q
H-616, Sh 2 451 2 6"-2HBD-448 through Non-Q 28-57A&B Q
H-617, Sh 4 451 Historical Backgroug During a design review and site walkdown, it was discovered that the CCW piping connected to the letdown coolers was not seismically supported and could impose unacceptable loading on the coolers.
Ana1Ysis of Safety Implications Assuming the worst case, the cooler supports could fail, causing subsequent failure of the letdown line, a component of the reactor coolant boundary. Based on this assumption, the condition is reportable under 10 CFR 50.55(e).
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n-
,i Bechtel Associates Professional Corporation NCAR 79 139455 I3946I INTERIM REPORT 1 Page 1 Probable cause The probable cause was failure to ensure compliance with equipment vendor nozzle load limitations at the interface between the non-Q-listed, noncritical, subcontractor (ITT Grinnell)-analyzed piping system and the Q-listed equipment nozzles.
Corrective Action 1.
If, as a result of the review, the affected hardware is found to be nonconforming, initiate proper controls in accordance with project procedures for nonconforming iters. A nonconformance report is being issued to be attached to the affected coolers.
2.
Perform a review to determine if similar conditions exist where non-Q-listed systems are connected to safety-related equipment and table corrective actions as required, based on findings.
3.
Action (s) to preclude recurrence will be finalized in a later report..
Reportability This deficiency was reported to the NRC by Consumers Power Company as a potential violation of 10 CFR 50.55(e) on December 16, 1983.
Su itted by:
>r E.B. Poser
- rog, Project Engine ing Manager
/
Approved by.
gg,
M.H. Smith Engineering Manager concurrence by:
-fp r M.A. Dietricy Project Quality Assurance Engineer l
0514u