ML20081D440

Interim Deficiency Rept Re safety-related Electrical Equipment Not Meeting Project Requirements.Initially Reported on 821230.Bechtel Task Force Established to Investigate & Resolve Mcar 66.Next Rept by 831230

ML20081D440
Person / Time
Site:	Midland
Issue date:	09/30/1983
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, 23809, 82-16-#6, 82-16-#66, NUDOCS 8311010188
Download: ML20081D440 (14)

Text

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Consurners POWBr wc.

{Q Vice President - Projects, Engineering and Construction General Offices: 1945 West ParneH Flood, Jackson, MI 49201 e (517) 788 0453 September 30, 1983 82-16 #6 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region III l

799 Roosevelt Road l

Glen Ellyn, IL 60137 MIDLAND NUCLEAR C0 GENERATION PLANT -

DOCKET NOS 50-329 AND 50-330 POTENTIAL 50.55(e) REPORT CONCERNING PROCURED ELECTRICAL EQUIPMENT FILE:

0.4.9.72 SERIAL:

23809

References:

J W Cook letters to J G Keppler, Same Subject (1) Serial 19130, dated December 30, 1982 (2) Serial 20716, dated February 25, 1983 (3) Serial 22197, dated May 13, 1983 (4) Serial 22241, dated June 29, 1983 (5) Serial 23769, dated August 12, 1983 This letter, as were the referenced letters, is an interim report on a potential 50.55(e) condition concerning delivered, safety-related electrical equipment not meeting project requirements. Attachment A provides a description of the problem and the overall corrective actions to resolve this issue.

As discussed in Attachment A, Bechtel Project Engineering has concluded that none of the nonconforming conditions specifically identified would have had an impact on the safety of operations.

In addition, a joint Consumers Power Company /Bechtel Task Force has recommended several corrective actions to ensure that nonconformances of this type do not continue to appear at the jobsite.

Consumers Power Company believes that the Midland Project Quality system has been effective in documenting existing supplier-caused nonconformances.

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8311010188 830930 gDRADOCK 05000329 Tg}

PDR OC0983-0040A-MP01

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4 Serial 23809 82-16 #6 However, corrective actions will be monitored, in the near term, to ensure adequacy and to confirm that nonconformances are being properly identified.

Another letter, either interim or final, will be sent on or before December 30, 1983.

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JWC/WRB/cd Attachment A: MCAR-66, Final Report, dated September 14, 1983 CC: Document Control Desk, NRC Washington, DC RJCook, NRC Resident Inspector Midland Nuclear Plant DSpood, US NRC INP0 Records Center i

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OC0983-0040A-MP01 l

3 Serial 23809 82-16 #6 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 i

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, DC 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 4

Jackson, MI 49201 52nd Floor j

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 l

Mr Steve Cadler, Esq Ms Lynne Bernebei j

2120 Carter Avenue Government Accountability Project St Paul, MN 55108 1901 Q Street, NW Washington, DC'20009 September 6, 1983 OC0983-0040A-MP01 i

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Attachment A Bechtel Associates Professional Corporation l}g Cg CICAR 66 (issued December 30, 1982)

')eficiencies Associated with Wbrkmanship Conditions on Electrical Control Panels and Cabinets Supplied by Yarious Vendors FINAL REPORT DATE:

September 14, 1983 PROJECT: Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220 Introduction This report provides the final status and course of corrective action required pursuant to MCAR 66.

Description of Deficiency Unacceptable workmanship conditions, such as insufficient solder, broken wire strands, damaged wire insulation, leads pulling from lugs, loose identification tags and markers, use of improper wire lugs, and improper crimping have been identified on electrical control panels and cabinets supplied by various vendors.

Probable Cause A task force was established at the request of Midland project management te review the findings resulting in NCAR 66 and to develop recommended plans of action to avoid recurrence of the problems.

Based on the results of the review, the root cause has been determined to be a failure to directly address workmanship in the purchase order documents, failure of the suppliers to have and/or implement documented standards for electrical wiring, and inadequate verification that procedures were in place and implemented in the supplier's facility.

Summary of Investiaation and Historical Backaround Thirty-seven discrepancy reports (nonconformance reports (NCRs) and quality action requests (QARs)) have been written on electrical equipment as a result of MPQAD overinspections using Consumers Power Company Project Inspection Plan 01-E-7B.

See Attachment 3 for a f

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9 Bechtel Associates Professional Corporation NCAR 66 FINAL Mgrq 4 9 12 8 3 8 6 Page 2 list and description of the NCRs/QARs associated with this NCAR.

Several discrepancy reports do not concern workmanship and are not addressed in the scope of this NCAR. The various discrepancies of all NCRs/QARs were corrected via the normal NCR/QAR tracking process.

Analysis of Safety InD11 Cations The NCRs/QARs associated with this NCAR have been analyzed for impact on the safety of operations at the Midland plant. No safety l

impact was identified.

Corrective Action A task force was established by Bechtel to investigate and resolve NCAR 66.

The task force has completed its activities and has provided project engineering with several recommendations to be applied to future purchase orders containing Class 1E, shop-fabricated or shop-installed electrical / electronic equipment.

See Attachment 1 for the task force charter syllabus and recommendations. The following is the status of corrective actions initiated or completed.

a.

Safety Evaluation of Identified Conditions An investigation to summarize the deficiencies as noted on each of the NCRs/QARs has been completed and is included in this report as Attachment 2.

Safety evaluation of identified conditions is included in Attachment 3 and the Analysis of Safety Implications section above.

b.

Rvaluation of Requirements and Vendor Programs 1.

For all future purchase orders and, on a case-by-case basis, exist 8ng purchase orders, specific contractual clauses via specification 7220-C-23(Q) (General Requirements for Supplier Quality Assurance Program) will be included to require that the vendor provide workmanship standards for project engineering approval that cover the supplier's scope of work. Specification 7220-C-23(Q) was revised via Specification Changes Notice 2 (issued July 22, 1983).

Inclusion of this requirement into applicable purchase orders has been reemphasized to all disciplines.

In addition, project engineering will ensure that all discipline purchase orders that include electrical components will also include a specification or other similar means to identify Bechtel electrical requirements.

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Bechtel Associates ProfessionalCorporation NCAR 66 r1Mu. m PonT i28386 l28449 Page 3 2.

The task force has reviewed supplier submittals to determine whether workmanship was addressed in their programs. As a result of this review, the followirg actions were initiated. All new Midland purchases that contain electrical components now use Procurement Supplier Quality Department Training Manual TS-408, Inspection Guidelines for Electrical Terminations (previously ECG-103, Guide for Compression Type Wire Connectors), or an equivalent procedure to define electrical requirements. All new Midland purchases that involve supplier wiring invoke the supplier quality training manuals as acceptance criteria if the supplier has no equivalent criteria implemented. This point was stressed to the manufacturers represented at the electrical commodities workmanship workshop held in the Bechtel San Francisco offices in June 1983.

3.

The task force has reviewed the project records for evidence of supplier's implementation of its workmanship programs.

As a result of that review, the following corrective action will be initiated for future purchase orders. The quality requirements have been expanded to require verification that supplier and subsupplier workmanship procedures are implemented, c.

Evaluation of Bechtel Programs 1.

MPQAD has reviewed the receipt inspection program and has concluded that for the equipment in question, the control of vendor workmanship is beat controlled by source inspection.

As recently revised for Midland, the receiving program, as a supplement to source inspection, is adequate and no further action is required. Source inspection has been revised as detailed in Corrective Action Sections b.1, b.2, b.3, and c.2.

2.

MPQAD has increased participation in vendor surveillance and l

issued project inspection plans for Vendor Source Inspection l

7220-E-24 (Overinspection of Vendor-Supplied Printed Circuit Board Assemblies, issued February 21, 1983)'and E-25 (Overinspection of Vendor-Supplied Electrical Equipment / Components, issued February 18. 1983). These inspection plans will ensure that MPQAD, supplier quality representative (SQR), and supplier inspection requirements are compatible.

The supplier quality department has developed several inspection criteria guidelines and training sessions, e.g.,

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Bechtel Associates Professional Corporation bkh PORT I28386 Page 4 a guide for compression type connectors, electrical testing, electrical codes and standards, and electrical commodities.

The improved training program also includes preparation of comprehensive training manuals on wiring processes. In i

addition, the SQRs are placed in vendor shops according to j

their training, background experience, and complexity of the i

procured equipment. The SQR surveillance has been increased as necessary. Bechtel will ensure that acceptance criteria and all necessary special instructions to the SQR are provided. It has been reemphasized to all disciplines that for the applicable purchase orders that include electrical components, the acceptance criteria, appropriate witness and hold points, and all necessary special instructions to the supplier quality representative must be provided (

Reference:

Engineering Department Procedure (EDP) 4.55, Section 4.7].

d.

Final Inspection Bechtel has observed a recent increase in the quantity of loose terminations on vendor equipment and believes that this was partly due to the overinspection criteria, which required a firm pull on the termination. The action taken as described in Item c.2 to ensure compatability of inspection requirements will contribute to resolving this concern.

In addition QAR J-0001 has been issued to ensure that compatible criteria are used for field inspections.

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Bechtel Associates ProfessionalCorporation NCAR 66 128449 FINAL REPORT l2ggg6 Page 5 Reportability This condition was reported to the NRC by Consumers Power Company as potentially reportable on December 3, 1982.

A case-by-case analysis of all the nonconformances has revealed no impact on the safety of operations at the Midland plant.

Submitted by L

J.G. Kovach l Cognizant Group Supervisor Approved by:

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<f E.M. Hughes h Project Engineer L'

Concurrence b :

R.L. C&Etleberry

- Cognizant Discipline Chief Concurrence by:

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Lt E.H. Smith Engineering Manager Concurrence by:

for M.A. Dietrich/

Project Quality Assurance Engineer Attachments:

1.

MCAR 66 Task Force Charter Syllabus and Recommendations l

2.

Sussnary of Deficiencies for NCAR 66 3.

Sussnary of NCRs/QARs for NCAR 66 i

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. to MCAR 66, Final Report Page 1 of 2 128449 128386 TASK FORCE CRARTER Charter 1.

Review the findings from NPQAD's (Plan 01-R-78) overinspections of electrical control panels and cabinets, and develop recommended plans of action for the Midland project and other divisional departments to avoid recurrence on future Midland plant purchase orders (

Reference:

NCAR 66, Recommended Action Items B.2, B.3, C.1, and C.2).

2.

Review and concur with project engineering dispositions so that there is a consistent approach used to correct problems on existing hardware and to revent problems on future work.

Based on that review, the task force will produce a checklist to summarize the deficiencies for each purchase order.

Project engineering, in support of the task force, will review each NCR and QAR and summarize the deficiencies noted on individual checklists for each purchase order (

Reference:

NCAR 66, Recommended Action Items A.1 and A.2).

3.

Develop a list of considerations to be used in evaluating the individual purchase orders. The task force will then review each purchase order affected by this MCAR 66, against the evaluation checklist (Step 2) and summarize the strengths and weaknesses of each purchase order (

Reference:

NCAR 66, Recommended Action Items B.1 and B.2).

4.

Identify the root causes of the workmanship deficiencies and develop plans for corrective action (

Reference:

NCAR 66, Recommended Action Items B.2, B.3, C.1, and C.2).

5.

Prepare a summary of corrective actions for individual purchase orders under Plan 01-R-7B where there will be future releasec or where there is time in the fabrication process on existing items to implement changes. The Midland project will review, concur with/ resolve, and implement the corrective actions

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Reference:

MCAR 66. Reccessended Action Items B.2, 8.3, and C.2).

6.

Develop a list of generic actions for purchase orders based on attributes other than those covered by Plan 01-R-7B.

This list will be developed principally from the purchase order checklist and problem summary. The Midland project will implement the generic actions (

Reference:

HCAR 66. Recommended Action Item C.2).

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' to MCAR 66, 4

Final Report i

Page 2 of 2 g

' I28449 Recommendations t

l For project action on the following task force recoassendations, refer to the NCAR 66, final report Corrective Action sections noted in parentheses.

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Include a specific requirement in the purchase order for the supplier to have and implement workmanship standards (Corrective Action b.1).

2.

Verify that the supplier QA manual addresses commitment to workmanship (corrective Action b.1).

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3.

Expand SQR surveillance and/or audit requirements to include verification that supplier procedures related to workmanship exist and are being implemented (corrective Action b.1).

4.

Ensure that all mechanical and other discipline purchase orders that include electrical components also include a specification or other means that identify Bechtel electrical requirements (Corrective Action b.1).

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5.

Verify that the supplier addresses control of subsupplier i

design criteria in its QA manual (Corrective Action b.1).

6.

Verify that the supplier has passed requirements for workmanship and special instructions to its subsuppliers j

(Corrective Actions b.1 and b.3).

7.

Verify that the supplier has complied with its commitment to

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audit subsuppliers (Corrective Action b.3).

8.

Ensure that the acceptance criteria, witness and hold points, and all necessary special instructions to the SQR are provided l

(Corrective Action c.2).

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9.

Evaluate the necessity for increased SQR and MPQAD surveillance

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(Corrective Action c.2).

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Implement a training program for SQRs involved in orders that relate to electrical workmanship (corrective Action c.2).

11.

Ensure that MPQAD SQR, and supplier inspection requirements i

are compatible (Corrective Action c.2).

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Attachmen9 2 to ICAR 66, Final Report Sl20ERY OF DEFICIEleCIES FOR MCAR 66(l)

[284k Deficiency IICR/04t Af fected Tvoe of Deficionev(2) a.

Cut, nicked, broken strands 3, 9, 10, 11, 12, 15, W

28, 29, 34, 37 b.

Strands outside lug barrel l l, 12, 15, M W

c.

Underslae/Irw rwt type wiring 5, 8, 31 W/E d.

Unidentified wiring 8, 31 E

e.

Minimen bond radius violation 9, 25 W/E f.

Conductor not terminated 2

W g.

Conductor pulled out of termination 2, 4, 7, 15, 19, 34, 36 W

h.

Conductor outside wireuey/ support 5, 7, 23, 31 W/E problem I.

Conductor insulation inside lug barrel 15 W

j. Conductor Insulation damaged 17, 24, 33 W

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Conductor not visible past lug barrel 19 W

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Loose terminations ll, 12, 13, 15, 17, W

18, 19, 25, 27, 34, 35, 36, 37 m.

More than two lugs on a terminal 5, 10, 22 E

n.

Class IE and non-Class lE apparently 5

E on same terminal o.

Color code violations 5, 7, 8, 16, 31, 33 E

p.

6-inch separation violations I, 5, 15, 35 E

q.

Lugs applied without proper tools 9, 13 W

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li.cerrwt size lugs /Ir.cerrwt type 5, 8, 10, 11, 13 W/E lugs or terminations 14, 21, 23, 28, 29, 31, 35 i

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Excessive / inadequate solder in lugs 15, 35 W

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Terulnal block ID missing / incorrect 5, 7, 8, 31, 34 W/E u.

Terminal block barrier alssing/ broken 28, 29, 32, 34 W

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Missing / inadequate Inspection crlisrla 6, 7 E

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Appearance /wortueenship 5, 7, 9, 16, 17, 25, 35 W

(83 (2) Only worlueenship deficiencies are included in the scope of MCAR 66.

W = worlueenship E = engineering s,s, Mb

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ATTAC M 3 rv NCAR 66. FINAL REPORT g

StNetARY OF NCR'S/QAR'S CC CJ Worketmehlp Reeposelble Purchase Purchase Discrepancy Disciplinet order order Indes Number safety 10 CFR 50.55(e)

MCR/QAE Number Comment (7720-)

Vendor

[see Attachment 2) tapact Resortability Bemerke 1)

N01-9-1-097 Control Systeme J-201(Q) alagnetico pose NA NA Not a workstaohly deficiency - esperation removed from NCAR 64 scope 2)

N01-9-1-114 Electrical E-stb (Q) solid state F. C Wo No - See CPCo the workassehty d'.ecrepancy was reputred and controle. Inc.

NCE Block 17 sattefactorily relmspected.

N CD I

3)

N01-9-1-095 B&W A

No No Evaluated by CPCo p

4)

N01-9-0-075 Control systems J-201(Q) Magnetice C

No No - See CPCo Toador followed proper procedures; M ulpment WCR Block 17 was 100E setlef actortsy laspected Espore shipment; dispoelttoa le to rettshton and use as is.

5)

N01-9-1-075 Inschaalcal N-18(Q)

Delaval N, W No No - 34e CPCo Not all of the NCR portalas to NCAR 64.

Some NCE alock 17 items were given a dispoelttom of "use as le."

Ftr leased to correct discrepeacles.

6)

N01-9-0-064 Nechaalcal b 118&tQ) Esv Nome NA NA Not a worknaaeht) deficiency - removed from

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IeCAR 64 ocope (selenic analysts report re9strod) 7)

ti31-9-O-064 Nechaalcal N-118&(Q) EST C, N W No No - See CPCo Not all of the NCE portales to MCAR 64; scoe NCE Stock 17 discrepancies were deelga related; deelga-critecto not completely ideutified 8)

N01-9-0-044 Nechaalcal N-169(Q) Westlaghouse C, 3 No No - See CPCo Documentattes and laspection criteria NCE alock 17 9eestlose 9)

N01-9-1-004 Electrical E-51B(Q) Solid State A. E, Q. W No No - See CPCo some reterstaattone were required.

Controle. Inc.

NCE Block 17

10) 1801-9-0-063 Electrical E-11(Q)

Solid State A. R No No - See CPCo D1eposition le to "use as le."

E-19(Q)

Controle. Inc NCE Block 17 E-Ste(Q)

11) N01-9-0-071 Electrical 3-205(Q) ITE A, B, L. R No No - See CPCo All discrepancleo corrected and lect Block 17 relaspected

12) QAR F-010 Electrical E-205(Q) ITE A. B. L 18e No sono as IBCS 301-9 4 071

13) N01-9-1-024 leechaalcal Is-150(Q) Nine safety L. Q. R No No - See CPCo All discrepeacles corrected and NCE elock 17 relaspected 0427u i

SINERAFT OF NCR'S/QAR's (Coattneed)

N G

Workmanship Respoesthle purchase Purchase Discrepancy C.D Diselpline/

Order order Inden Number Safety 10 CFR 50.55(e) m NCE/043 Number Compaar (7220-)

vendor isee Attachment 2)

Impact Reportability-Remarks ve

14) QAR SD-332 Control systems J-207(Q) Several E

No No Not a workmanship discrepeecy (control J-275(Q) systems), but an laspection probles J-201(Q)

(mechnetcal); vendors used lasslated lage J-284(Q)

Electrical E-6(Q)

E-7(Q)

N Nechaalcal N-18(Q) g N-150(Q)

N-169(Q)

.W'

15) N01-9-1-128 Control systems J-201(Q) Magnetics A

3. C. 1. L. 3 No No - See CPCo Same problem as N01-9-0-075 C.f")

NCR alock 17

16) N01-9-1-136 Nechselcal N-10(Q)

Delevel W

No No - See CPCo Original purchase order did act require the NCR Block 17 Ilsted as discrepeacles; DCP lessed to repair discrepaneles

17) N01-9-1-129 Control Systems J-201(Q) Nagnetics J. L. W No No - fee CPCo Fleid to rework fleid desage and retighten NCR Block 17 loose vendor teralsettoes i

18)

N01-9-1-140 Electrical E-7(Q)

ITE L

Wo No - see CPCo Repale loose teralastleas.

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NCE alock 17

19) N01-9-1-142 Electrical E-7(Q)

ITE C. E. L No No - See CPCo Repair loose teralastloss.

NCR alock 17

20) QAR 30-342 NA NA NA NA NA NA Canceled, this QAR was written for unacceptable meterial certifications for ASme section III pipe supports

21) QAR F-007 Electrical E-7(Q)

ITE None NA NA Dispoelttoa le to "use as is"; removed from NCAR 66 scope

22) N01-9-0-067 Nechaalcal N-150(Q) Mlae Safety Nome NA NA pesoved from NCAR 64 scope

23) QAR F-070 Electrical E-51B(Q) Solid State None NA NA Disposition is to "use as is"; removed free Controls. Inc.

NCAR 66 scope

24) N01-6-1-043 Electrical E-7(Q)

ITE None NA NA Destga consideratloa not lacluded la the scope of NCAR 66

25) QAR F-114 Electrical E-19(Q)

Solid State E. L. W No No Discrepancies were repatred.

Controls. Inc.

26) N01-9-1-120 NA NA NA NA NA NA Conceled 10/20/81; IICAR 50 addresses the itsee on this NCR s

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SUIRIARY OF NCE*5/0&R*s (Contisued)

Workmanship l

Besponsible Purchsee Purchase Discrepancy Disciplinet Order Order lades Number Safety 10 CFR 50.55(e)

[

NCR/048 Number Compaan (7220-)

Vendor (see Attachment 2) _ laeoct Reportability Remarks N

l CD

27) N01-9-1-139 Rioctrical R-7(Q)

ITE L

No No - See CPCo

( a.)

NCE Block 17 g

O

28) 8801-9-1-150 S&W A. R. U No No Evaluated by CPCo

29) QAR F-133 NA NA NA NA NA NA Canceled 12/23/81; NCE Ps00-9-1-150 wettten to replace this QAR

30) N01-9-1-137 NA NA NA NA NA NA Canceled 11/30/81; QAR F-133/NCR N01-9-1-150 weltten to replace this NCR

31) 1101-9-1-151 Nechaalcal N-169(Q) Westlighouse C. D. N. O. R. T No No - See CPCo NCE alock 17 N

32) 3101-9-2-082 S&W U

To be evaluated by CPCo g

33) N01-9-2-150 control systems /-275(Q) Titro J. O. W No No Reference SCRE 66 e

34) 3001-9-2-139 Isochaalce.1

$1B Delaval A.L.C.U No No m

35) Is01-9-2-173 Isochaalr61 81-14 Terry Turbine / L. R. S No No - See CPCo W111emette

36) 1801-9-3-089 Control sisteme J-284(Q) Comelp L. B. C No No - 8e* CPCo OPea; added to IICAR 66 la sceordance with NCR Block 24 CPCo serial 20749 (3/30/43); vendor will repair discrepancies.

37) 1801-9-3-094 Control systems J-202(Q) Marlo A. L Wo No - See CPCO Open; added to sh:AR 66 la accordance with leCR Block 24 CPCo serial 20749 (3/30/83); vendor will repair discrepancies.

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