ML20086T351
| ML20086T351 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 02/24/1984 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 28014, 83-06-#3, 83-6-#3, MCAR-70, NUDOCS 8403060272 | |
| Download: ML20086T351 (7) | |
Text
[L Consumers Power i Presid - Projects, Engineering and Construction oeneral offices: 1945 West Pernali Road, Jackson, MI 49201 * (517) 788-0453 February 24, 1984 83-06 #3
.J G Keppler, Regional Administrator
.US Nuclear Regulatory Commission PRINCIPA!! STAFF Region III
/deSPRP 799 Roosevelt Road Glen Ellyn, IL 60137 RC ysg MIDLAND ENERGY CENTER PROJECT A
DOCKET NOS 50-329 AND 50-330 Ng
- I ELECTRICAL RACEWAY SYSTEM NONCONFORMANCES
'* lIb FILE:
0.4.9.78 SERIAL:
28014
Reference:
J W Cook letter to J G Keppler, same subject:
(1) Serial 23770, dated August 29 -1983 (2) Serial 23834, dated October 28, 1983 This letter, as was the referenced letter, is an interim 10CFR50.55(e) report concerning nonconformances in Electrical Raceway Systems.
Althcugh Bechtel Project Engineering has determined that deficiencies which have a significant impact on plant safety are not likely to exist, Consumers Power Company will make a final judgement uhen results from the construction completion program become available. As described in Enclosure 1, none of the original discrepancies or any results of further engineering review, was
' determined'to have an adverse effect on the safety of plant operation'.
Another report, either interim or final, will be sent on or before June 8, 1984.
h JWC/WRB/cd
Enclosure:
- 1) MCAR-70, Revised Final Report, dated February 7, 1984 CC: Document Control Desk, NRC PHood, NRC Office of NRR
. Washington, DC RJCook, NRC Resident Inspector INFO Records Center Midland Nuclear Plant 9403060272 840224 1
gDR ADOCK O M OC0284-0027A-MP01 DR 1
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Serial 28014 83-06 #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, E9q 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 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 Brenner, 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 OC0284-0027A-MP01
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Bechtel Associates Professional Corporation
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142096
SUBJECT:
MCAR 70 Electrical, Raceway and Raceway Supports l
REVISED FINAL REPORT DATE:
February 7, 1984 PROJECT:
Consumers Power Company Midland Plant Units 1 and 2 Bechtel Job 7220
. Introduction This provides the status and the course of corrective action required by Management Corrective Action Report (MCAR) 70.
Descriotion of Concerns NCAR 70 concerns nonconformance reports t,n electrical racewty and raceway supports. These fall into three categories:
1.
Raceway and raceway supports not installed in accordance with the design documents 2.
Design drawings fsr cable tray and cable tray supports that are not l
specific or complete l
3.
Raceway and raceway supports previously inspected and accepted by l
quality control that have been subsequently found not conforming to j
the design documents These concerns have been addressed by Nonconformance Report.
l NCR-M01-9-3-033, Safety Concern and Reportability Evaluations, SCRE 78, and Consumers Power Company Management Corrective Action Report, MCAR/R DN-2.
Additional concerns (i.e., definition of symbols, lack of dimensions, lack of angle callouts, etc) have been addressed by the Midland Project Quality Assurance Department (MPQAD) in quality action requests for 7220-E-600(Q) series electrical raceway drawings.
i Investinative Bsekaround This concern was identified during an overinspection by the Midland Project Quality Assurance Department (MPQAD) of electrical raceway and raceway supports in the auxiliary building.
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t41977 Bechtel Associates Professional Corporation 142096 NCAR 70 Revised Final Report Page 2 Analysis of Safety Innlications A safety evaluation was performed for the cases identified in SCRE 78, and specifically to investigate the conditions identified in
.l NCR-M01-9-3-033 and NCAR/R DN-2.
Engineering evaluated the electrical raceway and raceway support discrepancies. Calculations were performed to evaluate the structural adequacy of the existing conditions. In all cases, the raceway and raceway supports were shown to have margins sufficient ':o ensure adequacy and no conditions were found that would affect the safe operations of the Midland plant.
A separate review, which to date has included more than 90% of the cable tray supports, has identified no safety concerns and no conditions more severe than the nonconformances identified above. This is due to conservatisms in design and analytical techniques. As a part cf the construction completion program (CCP), the status of Q raceway and supports will be assessed to ensure that as-constructed conditions are in accordance with the design requirements. Nonconforming conditions will be documented on nonconformance reports and evaluated in accordance with the Consumers Power Company program to control and disposition NCRs.
l Probable cause j
1.
Construction Nonconformances supports were not installed exactly in accordance with the design.
l This was due to congestion, which created many constructibility problems, and to the practice of attaching conduits to cable tray supports without informing project engineering.
l Engineering approval wrs not obtained before changing the support l
configuration nor was clarification obtained when questions arose on drawings.
2.
Engineering I
Dimensions not considered critical or needed for installation of raceways are not shown on raceway drawings. Althouga this was the practice, a statement to this effect was not included in Drawing 7220-E-42(Q), Conduit and Tray Notes Symbols, and Details.
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s 141977 Bechtel Associates Professional Corporation 142096
.cAE 70 l
Revised Final Report Page 3 Some cable tray support drawings did not have all details necessary to meet the design requirements.
3.
Quality control Inspection procedures were not followed.
i Corrective Action 1.
Construction The CCp provides for assessment of seismic Q raceway and supports for compliance with current design documents. The program requires that applicable field procedures and instructions be reviewed and revised as necessary. The program also provides for training of personnel to ensure that assessment activities are performed according to the latest design / procedural revisions. This program was approved on i
October 6, 1983.
2.
Engineering All cable tray support drawings [7220-E-700(Q) series) were reviewed l-for specificity and completeness. Of the 2.710 supports reviewed, I
drawings of 490 supports were changed. Where approved calculations I
did not support the drawing revisions, the support was placed on hold. In addition to placing holds on drawings, a system has been implemented to track the holds and the calculation status of each cable tray support. The drawing changes made were of three types:
to supply missing information, to clarify inconsistencies between section views, and to provide general clarification of some supports, project engineering has resolvAd the additional MPQAD concerns by completing the following corrective actions (completed 11-30-83):
a) The following note was added to Drawing 7220-E-42(Q).
l Cable tray locating dimensions on the 7220-E-600(Q) drawings are not shown unless deemed necessary by project engineering. Cable tray installation shall i
conform to all applicable locating dimensions as specified in the following project documents:
7220-E-42(Q), E-42B(Q), E-47(Q), E-600(Q) series, and E-700(Q) series, b) Additional symbols and descriptions were added on Drawing 7220-E-42(Q).
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Revised Final Report Page 4 c) Two notes were added to Drawing 7220-E-42B(Q). One note specified the maximum allowable cantilever lengths for tray ends; the other note provided the tray-fitting-to-support maximum dimension requirements.
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d) The following note was added to Drawing' 7220-E-706(Q):
Cable tray seismic support centerline-to-centerline spacing shall not exceed 8'-0" as measured along the centerline of the tray.
3.
Quality control The Quality Verification Program, which is part of the CCP, and the quality control inspection process provide verification of the acceptable quality for raceway and supports. These programs also provide for the necessary procedural revisions and recertification of quality control personnel.
Actions to Preclude Recurrence The CCP ensures that all future activities related to construction and inspection of seismic Q raceway and supports will be performed in accordance with the design requirements and applicable procedures and instructions.
l l
Design personnel have been formally directed to provide the additional detail on the engineering drawings.
Rooortability The condition was reported to the NRC on July 29, 1983.
The safety of operation of the Midland plant is not affected for the specific cases analyzed.
Due to the conservatisms in the design and l
analytical techniques, no safety concern has been identified.
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Bechtel Associates Professional Corporation mesm 70 141977
!42096 Revised Final Esport Page 5 a
Submitted by: /[
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g E.B'. Poser Project Engineering Manager Approved b -
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T.E. Johnson Chief Civil Engineer Approved by:
R.L. C'astleberry Chief Electrical Engineer
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b Approved by:
,M E.H. Smhth ~
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Engineering Manager l N Concurrence by:
XJ n e M.A. DietricM Project Quality Assurance Engineer
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