ML20082V296
| ML20082V296 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 12/09/1983 |
| 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, 26621, 83-10-#1, MCAR-1, NUDOCS 8312200063 | |
| Download: ML20082V296 (7) | |
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e Consumers Power James W Cook Vice President - Projects, Engineering and Construction General Offices: 1945 West Pernell Road, Jackson, MI 49201 e (517) 78&O453 December 9, 1983 83-10 #1 Mr J C Keppler, Regional Administrator
.US Nuclear Regulatory Commission Region III 799. Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER PROJECT I
DOCKET NOS 50-329 AND 50-330 CLASS 1E CABLE FACTORY REWORK FILE:
0.4.9.82 SERIAL:
26621 November 10, 1983, Consumers Power Company notified your staff of a potential 10CFR50.55(e) condition involving the coordination of engineering holds and restrictions with the construction effort at the Midland jobsite.
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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 March 2, 1984.
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Attachments:
(1) MCAR-1, Report No 74, Revision 1, dated November 29, 1983 (2) MCAR-74, Interim Report 1, dated November 30, 1983.
.CC: Document Control Desk, NRC Washington, DC RJCook, NRC Resident Inspector Midland Nuclear Plant DHood, USNRC Office of NRR INPO Records Center 8312200063 831209 f
gDRADOCK 05000329 I\\
PDR OC1283-0010A-MP01-DEC 151983
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2 Serial 26621 83-10 #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 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 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 OC1283-0010A-MP01 l
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Serial 26621 83-10 #1 QUALITY ASSURANCE PROGRAM MANAGEMENT CORRECTIVE ACTION REPORT 74 I3596i MCAR-1 REPORT NO.
11/29/83Rev[lk ho, 7220 0 NO.
DATE l* DESCRIPTION (including references):
An engineering restriction was placed on ESSEX cable with f actory rework for use inside the Midland Unit I and 2 reactor containment buildings (Ref: BEBC-TWX-4607/com 18473, dated 12/18/BO). Contrary to the above, the following nonconformances have been identifled (Ref NCR-A-000031:
(continued on page 2)
- RECOMMENDED ACTION (Optional) 1)
Perform In-depth review to Identify all ESSEX cables with factory rework Installed in Class IE circuits inside the Midland Unit I and/or 2 reactor containment buildings.
2)
Document findings from Il above on NCR and determine Impact on the safety of operations et Midland.
- 3) Take appropriate remedlet action (s) based on detailed findings from 1) and 23 above.
(continued on page 2)
REFERRED TO G ENGINEERING G CONSTRUCTION O QA MANAG MENT O
OA'o D f/ 2 9 - 83 O PROCUREMENT ISSUED BY _
This deficiency was reported to the NRC by Consumers for ProjectOAEng@
Date Power Company as potentially reportable on 11/10/83.
11 REPORTABLE DEFICIENCY NOTIFIED CUE O NO
@ YES MI Profs 6TManager Date ill CAUSE CORRECTIVE ACTION TAKEN AUTHORIZED BY Date STANDARD DISTRIBUTON ADDITONAL DISTRIBUTON - AS APPROPRIATE DMSON QA MANAGER ENGINEERING MANAGER FORMAL REPORTTO CLIENT MANAGER OF OA BPC PROJECT ENGINEER (if Sectionll Applies)
De#
GPD - QA MANAGER OE SUPERVISOR LAPD QA MANAGER SFPD OA MANAGER CONSTRUCTON MANAGER PROJECT MANAGER PFDJ SUPT /PROJ CONSTR MANAGER CUENT CHEF CONSTR OC ENGINEER CORRECTIVE ACTION IMPLEMENTED DMSON PROCURENT MGR PROJ PROCUREMENT MGR PROCUREMENT SUPPLER QUALITY MGR AND DN SUPPUER QUAUTY MGR VERIFIED BY Project OA Engneer Date
' Describe in space provided and attach reference docurnent.
AAPD-0161
Management Corrective Act on Report Report No. 74, Revision i Page 2 13596i DESCRIPTION (continued):
- 1) Two (2) ESSEX cables with factory rework were Installed In Class IE circults inside the Unit 2 reactor contaltunent building.
2)
Six (6) ESSEX cables with factory rework were installed in Class IE circuits Inside the Unit I re.:ctor containment building.
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- 3) The possibility exists that other ESSEX cables with factory rework (in addition to those identifled in 1) and 2) above) are Installed in Class IE circuits inside the Unit I and/or 2 reactor containment buildings (Indeterminate condif fon).
Furtl*3r Investigation of the problem Indicates that a programmatic deficiency exists in the method of Initiating and documenting engineering holds and/or restrletions on hardware Items and l
subsequent control of these items at the jobsite.
RECOeOOED ACTION (continued):
- 4) Perform In-depth review to determine status of other engineering holds
- and/or restrictions placed on hardware items at Midland to determine the extent, if any, that nonconformance reports should have been erItten.
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5)
If, as a result of item 4) above, hardware deficiencies are noted, document on NCR and determine Impact on the safety of operations at Midland.
- 6) Take appropriate remedial ac+1on(s) based on detailed findings from 4) and 5) above.
- 7) Review engineering, construction, procurement, and QA/QC procedures related to initlation, documentation and control of holds end/or restrictions placed on hardware Items and revise or laplement new procedures as necessary.
81 Ensure that procedures addressed in item 7) above aro Integrated to provide adequate continuity / compatibility between organizations responsible for laplementing subject procedures.
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- 9) Provide formal Instruction to appropriate personnel on procedures for initiation, documentation and control of engineering holds and/or restrictions placed on hardware Items.
- 10) Determine root cause of problem and take appropriate corrective action (s) to prevent recurrence.
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- 11) Issue report, either Interle or final, by November 25, 1983.
The term ' Hold / Restriction,' as referenced in this report, refers to those directions NOTE:
- t Initiated by engineering to restrain constructica and/or procurement from performing activities on issued designs. This term does not apply to those ' holds' shown on engineering drawings or specifications to designate incomplete design.
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1361a3 serin 1 26621 z
ebZ:5 Manage nt Corrective Action (MCAR) 74 INTERIM REPORT 1 Date:
November 30, 1983 Project:
Midland Plant Units 1 and 2 Consumers Power Company Bechtel Job 7220 INTRODUCTION This report addresses deficiencies in the method of controlling holds and restrictions placed on hardware items, which resulted in the installation of unqualified Essex cables in Midland Units 1 and 2 containment buildings.
DESCRIPTION OF DEFICIENCY Project engineering restricted installation of Essex cable with factory reworked insulation in the Midland containment buildings. [Ref: TWX, BEBC-4607, 12/18/80 (Com 018473)].
Contrary to the above, the following nonconformances have been identified (Ref: NCR A-00003):
1.
Two Essex cables f rom reels with factory reworked insulation were installed in Class 1E circuits inside the Unit 2 reactor containment building.
2.
Six Essex cables f rom reels with factory reworked insulation were installed in Class 1E circuits inside the Unit i reactor containment building.
3.
The possibility exists that other Essex cables with factory reworked insulation (in addition to those identified in 1 and 2 above) are installed in Class IE circuits inside the Unit 1 and/or 2 reactor containment buildings (indeterminate condition).
Further investigation of the problem indicates that a programmatic
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deficiency exists in the method of initiating, documenting, and executing engineering holds and restrictions on hardware items and subsequent control of these items at the jobsite.
HISTORICAL BACKGROUND The cable deficiency was discovered during a MPQAD review of cables installed in Units 1 and 2 containment buildings, resulting in issuance of NCR A-00003. Based on the NCR, a safety concern and reportability evaluation (SCRE) 100 was issued to evaluate the cable deficiency for reportability.
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I MCAR 74 136175 Interim Report 1 Page 2 I36l53 ANALYSIS OF SAFETY IMPLICATIONS A safety analysis on the eight cables identified on NCR A-00003 has been completed. It was determined that the eight cables included Class 1E circuits for the decay heat return letdown valves and the reactor building recirculating air cooling unit fans required to function in the event of a loss-of-coolant accident and/or main steam line break. It was concluded that because an environmental qualification was not performed on subject cable containing factory reworked insulation for inside containment, the reliability of this cable relative to all design bases was rendered indeterminate and, therefore, if left uncorrected, could have adversely affected the safety of operations of the Midland plant.
i PROBABLE CAUSE l
Preliminary investigation indicates:
1.
Lack of adequate controls and procedures on issuing and enforcing project engineering's holds.
2.
The condition necessitating the specific cable hold was not recognized as requiring a nonconformance report.
CORRECTIVE ACTION 1.
An in-depth review is being conducted to identify cable installed in the containments for Units 1 and 2 for Class IE circuits that may i
have come from subject Essex reels. Additional findings, if discovered, will be documented on NCR A-00003, t
2.
Remedial corrective action will be determined once the review in 1 l
above has been completed. Forecast date fcr completion is December l
30, 1983.
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3.
A review to determine status of other engineering holds and/or restrictions placed on hardware items is in progress. A plan for completion of this ectivity will be issued by December 30, 1983. Any related hardware which is found to be nonconforming will be documented on a NCR, corrective action implemented, and safety impact determined.
4.
A review of engineering, construction, procurement, and QA/QC procedures relating to initiation, documentation, and execution of holds and/or restrictions placed on hardware items is being performed, with a scheduled completion date of December 30, 1983.
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a MCAR 74 Interim Report 1 Page 3 I36I53 I36I75 5.
Formal instruction to appropriate M rsonnel on revised or new procedures concerning initiation, documentation, and control of engineering holds and/or restrictions placed on hardware items will be conducted by January 30, 1984 6.
Investigation into the root cause, and assignment of appropriate corrective action, is in progress. Completion is scheduled for January 30, 1984.
REPORTABILITY This deficiency was reported to NRC by Consumers Power Company on November 10, 1983.
Submitted by:
[I
.,se R.C. HdMar [/
Project Quality Engineer Approved by:
'E.B. Poser Project Engineering Manager Concurrence byh J.G. Kovach
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l Electrical Croup Supervisor Concurrence by: [J h[dM 1.L. Castlebe r g
Chie,f, El ctri I:usineer N
Concurrence by:
'V E.H. Smith En ineerin Manager
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Concurrence by:
./
w W. Nielson Construction Coordinator Concurrence by:
[A
-f e M.A.Dietrip Project Quality Assurance Engineer i
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