ML19323F182

Interim Deficiency Rept Re Inconsistent cross-referencing Between B&W & Bechtel Numbering Sys for B&W Supplied Components of Unit 2,resulting in Improper Wiring of B&W Supplied Sys.Cause & Corrective Action Under Consideration

ML19323F182
Person / Time
Site:	Midland
Issue date:	05/22/1980
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
References
NUDOCS 8005280621
Download: ML19323F182 (9)

Text

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'_. CCOSl!m0fS l P03r James W Cook 0k

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Vuce President, AfsJ!and Project General of fices: 1945 West Parnall Road, Jackson, Machigan 49201 *(517) 788 0640 May 22, 1980 Mr J G Keppler, Regional Director Office of Inspection and Enforcement US Nuclear Regulatory Commissicn Region III 799 Roosevelt Rcad Glen Ellyn, IL 60137 MIDLA:iD NUCLEAR PLANT UNIT NO 1, DOCKET NC 50-329 UNIT NO 2, DCCKET No 50-330 NSSS COMPCNE'IT IDENTIFICATION FILE: 0.h.9.39 UFI: 73*10*01, 02400(S) SERIAL: 8987 In accordance with the requirements of 10 CFR 50 55(e), this letter constitutes an interim report concerning a potentially unsafe situatien orig'inally reported by a telephone call from G R Eagle, CPCo MPQAD to R Knop, NRC Regicn III, on May 2, 1980.

The attachments to this letter provide a more complete descriptien of the conditicn, the bacis for initial belief that the conditicn was not reportable (pending input from the USSS supplier), and indicate the status of actions beinC taken.

Another report, either interim or final, vill be issued on or before August 22, 1980.

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• GRE/1r Attachments: 1) Quality Assurance Program, Management Corrective Action Report, MCAR-38, dated March 11, 1980

2) Letter "MCAI 38 - Component Identification" to L H Curtis, dated March  :, 1980

3) MCAR-38, Interim Report #1, dated March 11, 1980 h) MCAR-38, Interim Report #2, and Cover Letter dated May 16, 1980 CC: Director of Office of Inspection and Enforcement b Att: Mr Victor Stello, USNRC (15) I l

Information & Prcgram Centrol, USNRC (1) THIS DOCUMENT CONTAINS 8 00628 0 (p a2.1 , POOR QUALITY PAGES r

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4 OUALITY ASSURA'NCE PROGitAM

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[ MANAGEMENT CORRECTIVE ACTION REPOHI MCAR 1 .

Attachment I l

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. . REPORT NO.

DATE _

March 11,1980 _

7220 O NO.

JOD NO.

l ' DESCRIPTION (IncludinD roferences): inconsistent cross referencing betvcen On Ifarch 10, 1980 the Project Engiticer advised that tens (:CII, ICS , ECCAS ,

B&W and Bechtel nutbering systems for B5U-supplied instrtencnt sysThis inconsistent cross r and NI/nPS) has occurred on Unit 2. Because of the inconsistent wiring, the d inconsistent viring of BLU supplied systems.

ICS and I;III will not function properly and some incorrect indications are dispisye ,

to the operator. .

• RECOMMENDED hCTION (Optional) f 1.

Determine if this atic=aly could have an adverse af fect on the ' safety of operation the plant'. Report to PQAE by March 26, 1980. -

2. Determine cause and procedural corrective actions. '

3.

Deterninc most logical fix to probico.

OOA MANAGEMENT C3 EC: ENGINEERING O CONSTRUCTION REFERRED TO O PROCUREMENT ISSUED BY

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Attachment 2

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Bechtel Power Corporation Inter-office Mennorandum To L.11. Curtis Date. March 12,.1930 .

Subject Midland Plant Units 1 and 2 From J. A. Clenents Bechtcl Job 7220

• PCAD. 38 - COMPONENT -

Of 7220 - Licensinr.

IDENTIFICATION

• Copies to At. Ann Arbor Office .

J. P. Anderson V. J. Manta -

D,. R. Anderson R. L. Rixford File 0534, LG-13.4 L. A. Dreisbach M. O. Rothwell E. M. Ilughes J. N. Vance B. P. l'ononcez

!!. E. Velastegui *

, Comm Log The purpose'o'f this 10:1 is to doce=ent the safety-related basis to be used in conjunc tion with a "significancy" study, to be done by others, to determine if the subject deficiency is reportablic under 10 CFR 50,

. Subsection 50.55(c) .

CONCLUSION: This deficiency, were it to have retai ned uncorrected, could not have af fected adversely the safety of operation:s of tFte Midland Plant at anytime throughout the lifeti=c of the plant.

BASIS: The component identification problem involves inconsistent cross-referencing between BEN and Bechtel numbering systec:s for r,EN supplied coeponents in both the primary and secondary systems of Unit 2. This ^

inconsistent cross-referencing resulted in inconsis tent viring of the following Unit 2 B6W-supplied instrument systems: *

+ Nuclear instrucentation/ reactor protection s'astem ('I/RPS)

• Emergency core cooling actuation system (ECClaS)

• Non-nuclear instru=entation (NNI) .

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• Integrated control system (ICS)

• The analysis completed to date on the B4N-supplied engineered safety  :

featurcs actuation systems, i.e., the MI/RPS and ECCAS, have indicated l that their safety-related functions would not have been de.o.raded by the l component numbering problem. These safety systens c".epend upon a 2-out-of-4 coincidence logic to initia te their safet.y functions. Thus, they are unaf fected by the order in which the, input signals a re wired.

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Bechtel Power' orporation.

Inter-office Memorandun

• March 12, 1980 Page 2 There are two problems associated with the non-safety related systems, i.e., the imI and ICS, due to the conponent numbering problem:

1. The IC'I and ICS will not function properly. They arc wired so that'

• feedwater is controlled as a function of sace steam generator secondary side parameters (stcaa generator pressure and Icvel, feedvater -

flow and temperature) and opposite seca= generator primary side paraccters (RCS flow) instead of the same steam generator pricary and secondary side parameters. ,

2. Due to the inconsistent wiring of the NNI, control room indication displays labeled as steam generator A (or B) are not all monitoring the sa=c secam generator.

The first prob'lem, involving the ICS, has been addressed by 35W in their Specifically, the response responses to NRC questions 031.37 and 232.3."There has been no analysis perfor=ed whic to 031.37 states, in part, identifics f ailure nodes of the ICS that cause an abnormal condition out-sid2 of acceptable linits precisely because such failures are not important to safety." Also, FSAR Subsection 15.0.2, Single-Failure Philosophy, states, in part, "No ICS or operator action is required for reactor protection." These state =ents need to be reconfirmed by BMJ in light of the current situation.

The second probica, involving control room indications, could lead to confusion of the control roon operators even though the indications are non-safety related. However, as stated in FSAR Subsection 15.0.2, "No ICS or operator action is required for reactor protection. .All accidents Operator arc analyzed without irrediate ICS or operator action.

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action for maintaining hot shutdown conditions or for initiating cool-down to cold shutdo n conditions is assu=cd only when adequate time and instrument indications are availabic to the operator." Therefore, no operator action has been assumed based upon non-safety related instrumentation.

This position also cust be confirmed by BMJ.

We are continuing to rescarch this issue and will document any additional information and/or BM1's concurrer a in a subsequent IOM before 3/26/80.

Prepared by:

.a. C -

J. A. Clements Licensing Group Supervisor Concurrence by: j f%

• J.:1. Andersp(I

• Control Systcus Group Supervisor,

- g.d 42L%&. .

J. N. Vance Chief Nuclear Engineer .

Attachment 3 008906 identification), dated March 11, 1980

SUBJECT:

HCAR #38 (component Interim Report #1 Date: April 1, 1980 Project: Consumers Power Company Midland Plant Units 1 & 2 Bechtel Job 7220 Introduction This report is submitted regarding the interim status and actions taken pursuant to MCAR #38.

• Description of Discrepancy Inconsistent cross-ref erencing between B&W and Bechtel numbering systems for B&W-supplied instrument systc=s (Non-Nuclear Instrumentation (NNI), Integrated Control Systems (ICS), Eccrgency Core Cooling Actuation System (ECCAS), and Nuc1 car Instrumentation and Reactor Protection System (N1/RPS)] and other com-This inconsistent cross-referencing has ponents has occurred on Unit 2. If the inconsistent resulted in ir. consistent wiring of B&W-supplied systems.that the ICS and NNI it can be postulated wiring were to remain uncorrected, indications would be dis-would not function properly and that some incorrect The following is a preli=inary response to the recom-played to the operator.

mended actions of MCAR 38:

1. Determine if this situation could have had an adverse affect on the safety of operation of the plant.

Ecchtel evaluation to date of the numbering inconsistency has indicated that the deficiency, were it to have remained uncorrected, would probably not have affected adversely the safety of operations of the Midland Plant.

On March 20, 1980, the potential for reportability of this Subject matterE&W to further under 10 CFR 50.55(c) was discussed with B&W.

review, B&W tentatively agreed"with BechteJ 's preliminary conclusions that the systcas involved that provide safety functions (ECCAS and HI/RPS) would accomplish their functions under existing conditions.

Based on the information available at that time, B&W could not labels on control room displays would conclude that the incorrect not have adversely affected the safety of operations of the plant.

The B&W response letter as to the safety aspect of reportability of this matter under 10 CFR 50.55(c) is scheduled to be submitted to Bechtel by April 18, 1980.

Our present position on reportability under 10 CFR 50.55(e) is that However, the situation does not presently appear to be reportabic.

this position will be reviewed based on the B&W evaluation and any further results of project investigation.

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00690G 2.

Determine cause and procedural corrective actions.

by The most probabic cause appears Unit 2.to No be some misinte the B&W and Bechtel ccoponent numbering system for fied to specific procedural corrective actions ha.ve been identid

" Corrective Action."

3. Determine remedial actions.

and the best i

Several alternative solutions are under consideration, solu

- Action."

Probable Cause i f probable Refer to item 2 under " Description of Discrepancy" for discuss on o cause.

Corrective Action task group (referred to as the " Component i f A multi-discipline Midland projectNumberingThe Task CNTG Group" will actorasCNTC) a has bee schedule, the issue addressed in MCAR 38 and related matters. l As steering grnup to completely define the issue (s), and to p an,and cause monitor, report, part of their activities, the CNTG will determine the cause o

- inconsistency.

Safety Implication f safety Refer to item 1 under " Description as It should be noted that, of Discrepancy" a practical catter, it is believed for discussion d prior to o

fuel implication.

that this iten could not have gone undetected and uncorrecteand system checkouts that load. This is because of the numerous component will be made prior to fuel load.

Forecast Date of Corrective Action 16, 1980.

is scheduled to be issued by liay The next interim report Submitted by: N, m Approved by:

Concurrence by: ./ / Ch^, . t

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s-MAC/pjh G

Attachm:nt h Bechtel Power Corporation 777 East Eisenhower Parkway .,

Annareer.u.cnsan 008234 us#Avaress: P.O. Box 1000, Ann Arbor. Michigan 48100 May 16, 1980 BLC-9277 Conseners Power Company 1945 West Parnall Road Jackson, Michigan 49201 Attention: Mr. J.W. Cook Vice President Midland Project

Subject:

Midland Plant Units 1 and 2 .

Consumers Power Company Bechtel Job 7220

• - MCAR 38 Interim Report 2 Attached for your information and use is MCAR 38, Component Identification, Interim Report 2.

In a change from Interim Report 1, we now conclude that the subject issue. is probably reportabic under 10 CFR 50.55(e). Censu=crs Power Cocpany uns notified of this position by telephone on May 2,1980 (confirced in BLC-9260, dated May 13, 1980).

The next interim report is scheduled to be issued by .

August 1, 1980.

/Q & f  ?-

John A. Rutge's Project Man er JAR /PJ R/kb

Attachment:

MCAR 38 Interim Repdtt 2 cc: U.R. Bird w/a G.S. Rec 1cy v/a B.V. Marguglio w/a ,, ,

MAY 20 WBO 5

Response Requested: No

SUBJCCT: HCAR #38 (Component Identification) dated March 11, 1980 .

INTCRIM REPORT #2 '

008234 Project: Consumers Power Company Midland Plant Units 1 & 2 Bechtel Job 7220 Introduction This report is submitted regarding the interim status and actions taken pursuant to MCAR #38. A change from Interim Report #1 (dated April 1,1980) is the current position that the issue addressed in MCAR #38 is probably reportabic under 10 CFR 50.55(c).

Dercription of Discrepancv Inconsistent cross-referencing has occurred on Unit 2 between B&W and Bechtel '

numbering systems for B&W-supplied instrument systems (Non-Nuclear Instrumentation (NNI). Integrated Control Systems (ICS), Emergency Core Cooling Actuation System (ECCAS), and Nuclear Instrumentation and Reactor Protection System (NI/RPS)] and other components. This inconsistent cross-referencing has resulted in inconsistent wiring of B&U-supplied systems. If the inconsistent wiring were to remain uncorrected, it can be postulated that the ICS and NNI would not function properly and that some incorrect indications would be displayed to the operator.

Status and Actions Taken The Midland Project Component Numbering Task Group (CNTG) is coordinating resolution of the subject issue. The scope of the Midland numbering problem is currently being studied, and information is being solicited from other utilities. .

B&W has indicated that they could not support the preliminary conclusion , expressed in Interim Report #1 (that the deficiency, were it to have remained uncorrected, would probably not have affected adversely the safety of operations of the Midland plant) because the deficiency would invalidate the safety analyses. The as-constructed plant would differ from the plant design assumptions of the safety analyses.

A revised safety analysis postulating that the deficiency remain uncorrected until plane a 'eration might detarmine that the condition would not cause a bona fide safety problem. Houever, this would be an unnecessarily costly and time-consuming process, particularly since remedial action is now in progress.

Saf'ety Implications Based on the crpressed concern that the, inconsistencies could result in inappropriate

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operator action which could adversely affect the safety of plant operations, we conclude t.hst the deficiency probably should be classed within the " adverse to safety" requirement of 10 CPR 50.55(e).

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,,-- t Corrective Action The CNTG will determine the d and proper No corrective action has been determined at this time.

preferred solution to bc0fMetw"ted 3 aa the evaluation is c *p ete corrective action is definect [n fdture reports.

Date on Ubich the Corrective Action will be Taken 80, and Preliminary planning indicates a completion of evaluation by July 1,19 completion of implementation by January 1,1981. .

l Reportability_

Based on the safety implications stated above, we conclude This isthat duethe subject to the deficiency is probably reportable under 10 CFR 50.55(e). fact that "significant of 10 CFR 50.55(c) AhT_ it has been determined to be within the deficiency in final design" requirement.

Additional Information d to

()

The CNTG will act as a steering group to completely define the issue s , anan and the preferred plan, schedule, monitor, report, actions.

Several alternative solutions are under consideration, '

rolution will be determined and implemented.

As part of their activities, the CNTG will detcruine the dcause of inconsistency.

design perconnel regarding the system of cross-referencing between the Bt.U an Bechtel component numbering system for Unit 2.

this as a practical matter, it is believed that Thic is Howevet,it chould be noted that, item could not have gone undetected and uncorrected prior to fuel load. ,

because of the numerous component and system checkouts that will be made prior to . . .

fuel load.

The next interim report is scheduled to be issued by August 1, 1980.

c Submitted by: / /d

.M. Anderson Approved by: M# M 9 L.H.'Curtis #

Concurrence by:

K.D. Ba',iley J

- Concurrence by: [I _

)

L. A. Drefsbach '

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