ML20084L082
| ML20084L082 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 05/04/1984 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 30271, 83-10-#3, OL, OM, NUDOCS 8405140333 | |
| Download: ML20084L082 (7) | |
Text
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Consumels Power
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{0&fOf Vice President - Projects, Engineering and Construction General offices: 1945 West Parnell Road, Jackson, MI 49201 * (517) 788 0453 May 4, 1984 83-10 #3 Mr J G Keppler, Regional Administrator US Nuclear Regulatory Commission Region 111 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND ENERGY CENTER PROJECT DOCKET NOS 50-329 AND 50-330 ENGINEERING / CONSTRUCTION HOLD PROCESS FILE:
0.4.9.82 SERIAL:
30271
References:
J W Cook letters to J G Keppler, Same Subject,
- 1) Serial 26621, dated December 9, 1983
- 2) Serial 28033, dated March 2, 1984 This letter, as were the referenced letters, is an interim 10CFR50.55(e) report concerning the coordination of engineering holds and restrictions. The attachment to this letter describes the concern and summarizes the investigation and corrective action taking place.
Another report, either interim or final, will be sent on or before August 10, 1984.
JWC/AHB/cd
Attachment:
(1) MCAR-74, Interin Report 3, dated April 25, 1984 CC: Document Control Desk, NRC Washington, DC RJCook, NRC Resident Inspector Midland Nuclent Plant DHood, USNRC Office of NRR INPO Records Center 8405140333 840504 9
PDR ADOCK 05000329
'QN S
PDR 7
MIO584-0005A-MP01 r
2 Serial 30271 83-10 #3 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 l
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 Trai1~
5795 North River Road Apt B-125 Rt 3 Boca Raton, FL 33433 Freeland, MI 48623 Mr Fred C Williams Dr 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 i
s MIO584-0005A-MP01
FE 3
Serial 30271 83-10 #3 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 Bernabei 2120 Carter Avenue Government Accountability Project St Paul, MN 55108 1901 Q Street, NW Washington, DC 20009 Mr P Robert Brown Clark, Klein & Beaumont 1600 First Federal Bldg Woodward Ave Detroit, MI 48226 MIO584-0005A-MP01
Attachment to
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I4930S Bechtel Associates Professional Corporation M,3 271 j
I49097
SUBJECT:
Management Corrective Action Report (MCAR) 74 INTERIM REPORT 3 s
l DATE:
April 25, 1984' l
PROJWCT:
Consumers Power Company l
Midland Plant Units 1 and 2 i
Bechtel Job 7220 l
r i
Introduction l
i This report addresses concerns in the method of controlling holds and f
restrictions placed on hardware items, which resulted in the installation of unqualified Essex cables in Midland Units 1 and 2 containment buildings.
l l
t Description of Concern
{
l Project engineering restricted installation of Essex cable with factory l
reworked insulation in the Midland containment buildings.
[Ref:
- TWI, BEBC-4607, 12/18/80 (com 018473)). Contrary to the above, the following nonconformances have been identified [Ref:
Nonconformance Report (NCR)
A-000031:
1.
Two Essex cables from reels with factory reworked insulation were installed in Class 1E circuits inside the Unit 2 reactor containment i
building.
j 2.
Six Essex cables from reels with factory reworked insulation were installed in Class 1E circuits inside the Unit I reactor containment i
j building.
(
l 3.
The possibility exists that other Essex cables with factory reworked l
insulation are installed or were scheduled to be installed in Class l
IE circuits inside the Unit I and/or 2 reactor containment buildings i
(indeterminate condition). A total of 68 Essex cables are involved.
i Further investigation of the problem indicated that the method of i'
initiating, documenting, and executing engineering holds and restrictions on hardware items and subsequent control of these items at the jobsite should be upgraded.
l Historical Backaround As a standard practice, the cable manufacturer (Essex) performed factory J
l insulation rework (repairs to insulation) on cables during fabrication.
l l
The insulation rework can be traced to a cable production run and not to l
l any particular cable or section of cable. The cable from each production run is traceable to specific cable reels.
The factory rework was subjected to all required production testing, but was not subjected to l
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Bechtel Associates Professional Corporation t
l I49097 l
MCAR 74 Interim Report 3 i
i Page 2 t
)
Class 1E loss-of-coolant accident (LOCA) quellfication testing. As a result, project engineering restricted installation of Esser cable from L
reels traceable to production runs containing factory-reworked insulation l
for Class II circuits from use inside the Midland containment buildings.
Contrary to this restriction, cables suspected of containing factory l
lasulation rework were discovered during MPQAD review of cables installed in Units 1 and 2 containment buildings, resulting in issuance of NCR l
A-00003. Based on the NCR, Safety Concern and Reportability Evaluation (SCRE) 100 was issued to evaluate the cable deficiency for reportability. The condition was subsequently reported to the NRC.
l l
Analysis of safety Implications i
A safety analysis on the eight cables originally identified on NCR A-00003 has been completed.
It was determined that the eight cables I
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 LOCA and/or main steam line break.
It was concluded that even if the subject cables did contain factory insulation f
rework, they could remain functional throughout the plant's design life j
for all design basis events. However, because an environmental t
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 l
I operations of the Midland plant.
[
Root Cause i
i i
Investigation indicates:
i 1.
Controls and procedures for issuing and enforcing project engineering's holds (including restrictions) should be upgraded.
l 2.
The condition necessitating the specific cable hold was not recognized as requiring a nonconformance report and associated hold j
tags.
)
Corrective Action 1.
A review was performed to determine whether additional corrective i
action was required to prevent further installation of Essex cable l
I i
suspected of containing factory-reworked insulation in the t
containments. Based on the following, it was determined that no l
additio,a1 action was required:
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Bechtel Associates Professional Corporation I4909I' i
MCAR 74 Interim Report 3 Page 3 i
a.
Factory-reworked insulation was prohibited on all Class 1E Essez cable purchased after August 18, 1980.
b.
All cable from reels supplied to the Midland project that l
contained Essex cable suspected of having factory-reworked insulation has been expended.
i 2.
Sixty-eight Essex cables have been identified for use in Class IE j
circuits in Midland Units 1 and 2 containment buildings. The cables installed or pending installation have been examined to determine the I
manufacturing date code, quarter code, and footage marker.
This l
Information has been sent to Essex to determine whether any of the cables originated from production runs containing factory reworked l
Insulation. This evaluation by Essex is continuing and the results f
will be included in the next report.
l
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3.
Any cables suspected of containing factory reworked insulation from f
Item 1 above will be replaced. This action will be tracked on NCR f
A-00003 and completed in accordance with the Construction Completion l
Program.
4.
A review to determine the status of all engineering holds has been completed. The results are being evaluated to determine whether any i
nonconforming conditions exist.
Issuance of NCRs will follow if I
required.
This activity is scheduled to be completed by May 14, 1984.
l 5.
Holds still in effect via memoranda, TWIs, or hold forms have been f
incorporated into the related design documents. All future holds f
will be implemented by design change only.
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6.
Engineering and construction procedures related to the hold process are being reviewed and revised as necessary. Procedures related to l
the review are Project Engineering Procedures 4.49.0, 4.49.1, 4.47.1, f
5.16.1, 4.61.1, and 4.46.1; associated Engineering Department i
Procedure Instructions / Manager of Engineering Directives; and Field l
l Procedures FPD-5.000, 1.000, and 9.910.
Completion of this activity is scheduled for July 5, 1984.
7.
An engineering training bulletin will be issued to instruct
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appropriate personnel on revised and new procedures concerning j
initiation, documentation, and control of engineering holds.
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1 Bechtel Associates Professional Corporation 97 0S i
NCAR 74 Interim Esport 3 Page.4 i
r Reportability This concern was reported to the NRC by Consumers Power Company as potentially reportable on November 10, 1983.
Submitted by:
E.B. Forer Project Engineering Manager Approved b : e R.L. Castleberry ChiefElectr{calEngine I
l Approved by:
W E.H. Smith Engineering Manager Concurrer.ce by:
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/ drM.A. Dietrigh Project Quality Assurance Engineer L
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