ML20087A809
| ML20087A809 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 03/02/1984 |
| From: | Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 28033, 83-10-#2, OL, OM, NUDOCS 8403080222 | |
| Download: ML20087A809 (6) | |
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Colv.ETED uw" James W cook s*
'84 MR -7 A10:43 v'a ~>de=< - Ni"". N ~d s and Construction General offices: 1945 West Parnali Road, Jackson, MI 492,01 y,G f 78 45[3 7
3 RANCH March 2, 1984 83-10 #2 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 CLASS 1E CABLE FACTORY REWORK FILE:
0.4.9.82 SERIAL:
28033
Reference:
J W Cook letter to J G Kappler, Same Subject, Serial 26621, dated December 9, 1983 This letter, as was the referenced letter, is an interim 10CFR50.55(e) report concerning the coordination of engineering holds and restrictions. The attachment to this letter describes the concern and summarize the l
investigation and corrective action taking place.
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Another report, either interim or final, will be sent on or before May 4, l
1984.
l JWC/AHB/lr
Attachment:
(1) MCAR-74, Interim Report 2, dated February 17, 1984 7
CC: Document Control Desk, NRC Washington, DC kp a t cu RJCook, NRC Resident Inspector
/
Midland Nuclear Plant DHood, USNRC Office of NRR Y
h INFO Records Center 8403060222 840302 PDR ADOCK 05000329 S
PDR OC0284-0045A-MP01 U )y A-
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2 Serial 28033 83-10 #2 OM/0L SERVICE LIST Mr Frank J Kelley Atomic Safety & Licensing Attorney General of the Appeal Board State of Michigan U S Nuclear Regul9 tory 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 Ccean Ms Barbara Stamiris 6152 N Verde Trail 5795 North River Road Apt B-125 Rt 3 Boca Raton, FL 33433 Freeland, MI 48623 l
Mr Fred C Williams Dr Jerry' Harbour l
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 3 runner, Esq Mr M I Miller, Esq Consumers Power Company Isham, Lincoln & Boale 212 West Michigan Avenue Three First National Plaza l
Jackson, MI 49201 52nd Floor Chicago, IL 60602 Mr D F Judd Mr John Demeester, Esq l
Babcock & Wilcox Dow Chemical Building l
PO Box 1260 Michigan Division l
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 OCO284-0045A-HF01
Seri"1: 28 33 1 431 S '+
Bechtel Associates Professional Corporation 143{agementCorrectiveActionReport(MCAR)
T6 Ba 74 SU8 JECT:
g INTERIM REPORT 2 DATE:
February 17, 1984 PROJECT:
Midland Plant Units 1 and 2 Consumers Power Company Bechtel Job 7220 Introduction This report addresses concerns in the method of controlling holds and l
restrictions placed on hardware items, which resulted in the installation of unqualified Essex cables in Midland Units 1 and 2 containment buildings.
Descriotion of Concern Project engineering restricted installation of Essex cable with factory reworked insulation in the Midland containment buildings.
(Ref:
TWZ.
BEBC-4607, 12/18/80 (com 018473)]. Contrary to the above, the following nonconformances have been identified [Ref: Nonconformance Report (NCR)
A-00003]:
1.
Two Essex cables from reels with factory reworked insulation were installed in Class 1E circuits inside the Unit 2 reactor containment building.
2.
Six Issez cables from reels with factory reworked insulation were installed in Class 1E circuits inside the Unit 1 reactor containment building.
3.
The possibility exists that other Essex cables with factory reworked insulation are installed or were scheduled to be installed in Class 1E circuits inside the Unit 1 and/or 2 reactor containment buildings (indeterminate condition). A total of 68 Essez cables are involved.
Further investigation of the problem indicated that the method of initiating, documenting, and executing engineering holds and restrictions on hardware items and subsequent control of these items at the jobsite should be upgraded.
I Nist'orical Backaround l
l As a standard practice, the cable manufacturer (Essex) performed factory
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insulation rework (repairs to insulation) on cables during fabrication.
I The insulatica rework can be traced to a cable production run and not to any particular cable or section of cable. The cable from each production run is traceable to specific cable reels. The factory rework was l
subjected tu all required production testing, but was not subjected to class II loss-of-coolant l
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I43134 Bechtel Associates Professional Corporation 143276 MCAR 74-Interim Report 2 l
page 2 accident qualificatior, testing. As a result, project engineering restricted installation of Essez cable from reels traceable to production runs containing factory-reworked insulation for class 1E circuits from use inside the Midland containment buildings. Contrary to this
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restriction, cables suspected of containing factory insulation rework l
were discovered during MPQAD review of cables installed in Units 1 and 2 containment buildings, resulting in issuance of NCE A-00003.
Based on the NCR, Safety Concern and Reportability Evaluation (SgtE) 100 was issued to evaluate the cable deficiency for reportability. The condition was subsequently reported, l
Analysis of Safety Implications l
A safety analysis on the eight cables originally identified on NCR l
A-00003 has been completed. It was determined that the eight cables included class 1E circuits for t.he 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 l
l line break. It was concluded that even if the subject cables did contain
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factory insulation rework, they could remain functional throughout the i
plant's design life for all design basis events. However, because in j
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 3rft uncorrected, could have adversely affected the safety of operations of the Midland plant.
Root Cause l
Investigation indicates:
1.
Controls and procedures for issuing and enforcing project i
engineering's holds should be upgraded.
2.
The condition necessitating the specific cable hold was not recognized as requiring a nonconformance report and associated hold i
tags.
I Corrective Action t
1.
Sixty-eight Essex cables have been identified for use in Class IE circuits in Midland Units 1 and 2 containsment buildings. The cables installed or pending installation have been examined to determine the manufacturing date code, quarter code, and footage marker. This 0527u l
n 143134 Bechtel Associates Professional Corporation I4)276
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Interim Report 2 Page 3 informa?.lon has been sent to Essex to determine whether any of the cables originated from production runs containing factory reworked 4
insulation. This activity is scheduled to be completed by March 16, 1984.
l 2.
Any ce51es suspected of containing factory reworked insulation from Item 1 above will be replaced. This action will be tracked on NCR A-00003 and completed in accordance with the construction completion Program.
3.
A review to determine the status of open engineering holds /and or restrictions placed on hardware via memoranda IWXs, or hole forms has been completed. The results are being evaluated to determine if say acaconforming conditions exist. Issuance of NCRs will follow if required. This activity is scheduled to be completed by i
March 12, 1984.
4.
Holds in effect from Item 3 above will be incorporated into the related design documents. This activity is scheduled to be completed by February 24, 1984.
5.
A plan to review holds implemented by " design document revision" for nonconforming conditions is being developed. The scheduled completion date is February 25, 1984.
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6.
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 has been l
performed. Engineering and construction procedures revisions will be completed by March 23, 1984. Procurement and QA/QC procedures need l
no revision.
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7.
Appropriate responsible personnel have.been notified by memorandum that all holds to design documents are to be made by document revision. Formal instruction to appropriate personnel on revised or j
new procedures concernins' initiation, documentation, and control of engineering holds placed on, hardware items wb1 be conducted upon completion'of Item 6.
l Reportability This concern was reported'to the NRC by Consumers Power Cccpany on l
November 10,;1983.
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Bechtel Associates Professional Corporation NCAE 74 143134 143276 Interim Report 2 Page 4 O
Su tted by:
_kN erth N
E.B. Poser Project Engineering Manager Approved by:
F E.L. Castleberry ChiefElectrfcalEngineer Approved by:
E.H. Smith "
Engineering Manager Concurrence by:
.[,r M.A. Districh Project Quality Assurance Engineer M
RCH/TJS/Imm l
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