ML20196A135

Responds to NRC 880922 Notice of Violation & Proposed Imposition of Civil Penalty Re Equipment Qualification of Electrical Equipment Deficiencies.Corrective Actions: Limitorque SMB-00 Installed & Fully Qualified

ML20196A135
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/01/1988
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8812050270
Download: ML20196A135 (4)

Text

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Consumers Power Kenneth W Berry ym thrector Nwirer lkemveg General Offas- 1945 West Pernell Roed. Jooson. MI 49201 e 1517) 788-1636 December 1. 1988 Nuclear Regulatory Commission Document Control Desk Washington DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

REPLY TO NOTICE OF VIOLATION FOR ENVIRONMENTAL QUALIFICATION DEFICIENCIES By letter dated September 22, 1988, the Nuclear Regulatory Commission transmitted a Notice of Violation and Proposed Ieposition of Civil Penalty regarding environmental qualification of electrical equipment deficiencies for Big Rock Point Plant. In accordance with 10 CFR 2.201, a "Reply to a Notice of Violation" is provided herein.

DESCRIPTION OF VIOLATION 10 CFR 50.49(f) requires each item of electrical equipment important to safety to be environmentally qualified by testing and/or analysis.

10 CFR 50.49(k) t.srcifies that requalification of electric equipment important to safety is not required if the Commission has previously required qualifica-tion in accordance with "Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors," November 1979 (DOR Cuidelines).

DOR Cuidelines. Section 5.2.2. states that type tests should only be considered valid for equipment identical in design and material construction to the test specimen and any deviations should be evaluated as part of the qualification documentation.

Contrary to the above Consumers Power Company failed to qualify equipeent important to safety by appropriate testing and/or analysis as evidenced by the following examples:

1. Limitorque Motor Actuator HD-7068 an item of electrical equipment important to safety, was recoved from service af ter 13 years of operation and was subjected to a Loss of Coolant Accident (LOCA) test on April 23, 1975.

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Nucider Regulatory Commission 2 Big Rock Point Plant Reply to Violation for Envir Qual Def December 1. 1988 This actuator was then reinstalled and returned to service in the contain-ment spray system without being qualified by testing and/or analysis to evaluate aging and degradation due to the LOCA test. This condition existed from November 30, 1985 until February 13. 1987, at which time Limitorque Motor Actuator MO-7068 was replaced.

2. Butyl rubber and polyethylene insulated cables, items of electrical equipment important to safety, which had not been environmentally qualified by testing and/or analysis, were installed in various Class IE circuits inside containment. This condition existed from November 30, 1985 until June 30, 1987, at which time the unqualified cables were replaced.

REPLY Consumers Prver Company acknowledges that the facts as stated in the violation are substantially correct.

REASON FOR VIOLATION

1. LIMITORQUE MOTOR ACTUATOR MO-7068 Consumers Power Company utilized extensive resources in an effort to comply with the EEQ regulations. However. EEQ. like other upgrade efforts (eg. 10CFR50 Appendix R. TMI Action Items), evoPsed over c long time period, allowing program managers, both Consuners Power Com.sany and NRC, to change during program development and corpliance review. Decisions or compliance interpretations that were agreed upon at one stage eay have been changed or modified by individuals involved during later time periods.

In the c2se of EEQ. program development and NRC review were ongoing for many years prior to the November 30, 1985 deadline. Region bastd inspect-ions did not commence until 1986.

The first time the issue (re-installation of tested unit) dealing with the qualification of Limitorque Actuator M0-7068 was raised was during the 1986 Region inspection. NRC staff knew during earlier program audits and Franklin Research Institute reviews that the valve had been tested, inspected, refurbished (where needed) and returned to service, but did not raise a concern. Had NRC staf f raised a concert, with returning the operator to service following testing during earlier program reviews and audits, the issue may have been resolved or the operator replaced prior to November 30. 1985. Consumers Power assumed. in the absence of notification to the contrary, that the operator was qualified for its intended service.

2. 10LYETHYLENE (PE) AND BUTYL RUBBER (BR) CABLES The issue use of similarity analysis in cable qualification was slightly different than the MOV because Consumera Power believed similarity analysis OC1188-0224-NLO2

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Nucicer R2gulctory Commiscion 3 Big Rock Point Plant i Reply to Violation for Envir Qual Def December 1, 1988 was the only viable method to demonstrate acceptability. The age of BRP did not permit testing since identical cable types were no longer manufactured ;

and thus not available. Obtaining sa=ples from the plant large enough, and encompassing all variations necessary, to accomplish the required tests was also determinti not to be a viable option. Thus, in response to the June 1984 NRC audit CDCo proposed a resolution to the concerns with the three cable types identified. One of the cable types was replaced during 1985 and the remainirl two were qualified by similarity which is permitted per 10CFR50.49(f)(2) and the DOR Cuidelines. This required purchasing of test reports at a cost of $50,000. These issues and proposed resolution were addressed in the NRC Safety Evaluation dated November 15, 1985 and found acceptable.

However, during the inspection in 1986 the approach outlined to the NRC in 1984 and discussed in the Safety Evaluation was determined to be unaccept-able. The conclusion of the inspectors was that similarity could not be established between cables produced by different manufacturers, a restrict-fon not raised by previous NRC reviewers.

CORRECTIVE STEPS TAKEN/RESUI.TS ACHIEVED

1. LIMITORQUE MOTOR ACTUATOR MO-7068 As discussed in Consumers Power letter dated September 26, 1986, a commit-ment was made to replace the operator during the 1987 Refueling Outage.

The new operator A Limitorque SMB-00 was installed during this outage and was fully qualified for inside containment conditions per Limitorque Report 600456,

2. POLYETHYLENE (PE AND BUTYL RUBBER (BR) CABLES For PE and BR insulated EEQ related cables outside centainment, a consultant evaluated the formulation of each cable insulation type and the variation between the known manufacturers of Big Rock Point's cable. The evaluation demonstrated that materials, manufacturing processes, and fabrication of the cables are similar and will not affect the cables functional capabili-ties. This information established the line for similarity to cables which were qualified for environmental conditions which envelope Big Rock Point. These similarity analyses were submitted by letter dated June 2, 1987 to the NRC. By letter dated June 12, 1987 (RIII-CAL-87-008A), NRR and Region III accepted this documentation.

All PE and BR insulated EEQ related cables inside containment were replaced in accordance with plant modification TC-610. The new cable installation was the subject of a special safety inspection (50-155/87015 (DRS)) on June 3-4, 1987. The insnection reviewed installation procedures, qualifi-cation reports for the new cable, and inprocess activities related to the replacceent effort. No violattens of NRC requirements were observed during this special safety inspection.

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1 Nucloor R:guletory Commission 4 Big Rock Point Plant Reply to Violation for Envir Qual Def December 1, 1988 CORRECTIVE STEPS TO AVOID FURTHER VIOLATIONS Consumers Power Company has established all necessary administrative controls to implement a program to maintain the environmental qualification of electrical equipment, as required by 10 CTR50.49(a). This program was evaluated in NRC F Inspection Report 86013, which stated "... the inspectors determined that the  !

licensee had established an adequate EQ program in compliance with..10CFR50.49."

DATE(S) VHEN FULL COMPLIANCE WAS ACHIEVED i

1. LIMITORQUE MOTOR ACTUATOR MO-7068 Full ccapliance to 10CFR50.49 for this item was achieved by completion of the above actions prior to startup on March 7, 1987. No further corrective  ;

, actions are required regarding this issue.  !

i 1 2. POLYETHYLENE (PE) AND BUTYL RUBBER (BR) CABLES l

! Tull compliance to 10CFR50.49 for this item was achieved on June 18, 1987  :

when the new cable was placed into service. No further action is required l for this iten. ,

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<jf),_,;/s(*Gl$**);tl Kenneth W Berry l l Director Nuclear Licensing {

1 CC Administrator. Region 111, NRC l NRC Resident Inspector - Big Rock Point (

Director. Office of Enforcement. NRC -

Deputy Exec Dir. Regional Operations. NRC 4

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