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P. Shevaon, Chairman flidland 1 & 2 Subcomittece FR0i1: _Garry G. Young Reactor Engineer SUSJECT: QA PROBLEMS AT MIDLAND UNIT 2 The. attached letter fro'n Consu'aers Power Company identifies a potentially unsafe situation at Midland 2.
The letter states that wiring of the Nuclear-Instrumentation (11), Reactor Protection Systern (RPS), Emergency Core Cooling Actuation System (ECCAS), Non-Nuclear Instrtraentation (NNI), and the Inte-grated Control System (ICS) is inconsistent based on incorrect cross-referencing between Ga'.i and Bechtel numbering systems.
If the situation had not been discovered prior to plant operation, the NNI and ICS would not have functioned properly and control room indication of certain parameters would have been misleading.
This incident identifies one of many quality assurance proble:ns at Midland.
Another problam of fill material under vital structures was identified in the P. Tam to P. Shewnon letter dated May 16, 1980.
Please consider this in your
- evaluation of the need for a Subconraittee meeting on Midland.
Garry Young Reactor Engineer Attach:aent:
Cook to Keppler letter dated May 22, 1930 cc. ACRS Members-ACRS Technical Staff Midland 8408010188 840718 PDR FOIA RICE 84-96 PDR omcc)...... AC R.S.,,,,,
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- A CCIBUm0rS l I (T 2r James w cook i
Vice President. Atidt.snJ Project
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May 22, 1980 Mr J G Keppler, Regional Director Office of Inspection and Enforcement US Nuclear Regulatory Cc::: mission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 MIDLAND NUCLEAR PLANT UNIT NO 1, DOCE" NO 50-329 UNIT i:0 2, DCCKET NO 50-330 NSSS COMFCNE'IT IDENTIFICATION FILE: 0.h.9 39 UFI:
73*10*01, 02h00(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, CFCo MFCAD to R Knop, NRC Regicn III, on May 2, 1980.
The attachments to this letter provide a more complete description of the conditicn, the basis for initial belief that the condition was not reportable (pending input from the NSSS supplier), and indicate the status of actions being taken.
Another report, either interin or final, vill be issued en or before August 22, 1980.
hS M GR.!:/1r Attachments:
- 1) Quality Assurance Program, F.anagement Corrective Action 11, 1980 Repcrt, MCAR-38, dated March Letter "MCAF Component Identification" to L H Curtis, 2) dated March 12, 1980 MCAR-38 Interim Report #1, dated March 11, 1980 3) 16, 1980 h) MCAR-38, Interim Report #2, and Cover Letter dated May O
Director of Office of Inspection and Enforcement CC:
1*r Victor Stello, USNRC (15)
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USNRC (1)
Infdrmation te Progrcm Centrol,
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OUALITS ASSUf1A'NCE PROGRAM
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MANAGEMENT Coll!!ECTIVE ACTION 11EP
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McAn 1 REPORT NO. _
March 11,1980
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DATE _
7220 O NO. _
i g betvcen d that inconcictent cross referenc nt syste NO. _
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)ESCRIPTION (including references):the Projcet Engiticer advise had Bschtel nuchering systems for B&W-supplied instr i ; han the U
This inconsistent cross referenc ngof the inconsistent w krch 10, 190,0 i
MI/RPS) has occurred on Unit 2.
lied systems.d some incorrect indications are Because
>naistant viring of Bfaf suppcad l~NI will not function properly an the cpsrctor.
f ty of operation of RECOMMENDED ACTION (Optional) d have an adverse affect on the sa e
- Detarmine if this aE.cr.nly coulReport.to PQAE by March 26,19ctive ac 80.
Detsmine cause and procedural corre th3 plant'.
blem.
Detcraine most logical fix to pro CL OOA MANAGEMENT O CONSTRUCTION m.',}a s c b~?
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Inter-oflice MennOrandum To L. H. Curtis Date.
March.12,. 1930 Subject Midland Plant Units 1 and 2 From J. A. Clenents Bechtel Job 7220 of 722n - Licensinr.
PCAD. 38 - COMPO!!DIT IDE! TIFICATION Ann Arbor Office.
At-Copies l'>
J. P. Anderson V. J. Manta D,. R. Anderson R. L. Rixford File 0534, LC-13.4 L. A. Dreisbach M. O. Rochuell
- 2. M. Hughes J. N. Vance B. P. Kononcez M. E. Velastegui Comm Log The purposc of this IOli is to docu=ent the safety-related basis to bc
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used in cor. junction with a "significancy" study, to be done by others, to determine if the subject deficiency is reportabl,c under 10 CTR 50, Subsection 50.55(c).
CONCLUSIO:!: This deficiency, were it to have recai-ned uncorrected, could not have af fected adversely the safety of operationis of t!be Midland Plant at anytime throughout the lif eti=c of the plant.
The component identification problem involvces inconsistent cross-B ASIS:
referencing between BEN and Bechtel numbering systerns for I;LU supplied This components in both the primary and secondary systems of 17nic 2.
inconsistent cross-referencing resulted in inconsist cnt wiring of the following Unit 2 B&W-supplied instru=ent systens:
. Nucicar instrumentation / reactor protection sy7 stem (III/RPS)
- Energency core cooling actuation system (ECCluS)
- Non-nucicar instru=entation (ImI)
- Integrated control system (ICS)
The analysis co=pleted to date on the ELV-supplied engineered safety the NI/ PTS and ECCAS, have indicated featurcs actuation systc=s, i.e.,
that their safety-related functions would not have been degraded by the component numberinr. probico. These saf ety systens c"cpend upon a
- Thus, 2-out-of-4 coincidance logic to initiate their safet.y functions.
they are unaf fected by the order in which the, input signals arc vired.
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Bechtel Power' Corporation f
,p Inter-office Mccorandun March 12, 1980 Page 2
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There are two probicms associated with the non-safety reisted systems, i.e., the NHI and ICS, due to the conponent numbering problem:
The UNI and ICS vill not function properly. They are wired so that' feedwater is controlled as a function of same steam generator 1.
secondary side paraceters (secam generator pressure and Icvel, feedwater flow and temperature) and opposite seca= generator primary side parameters (RCS flow) instead of the same secan generator pricary and secondary side parameters.
Due to the inconsistent viring of the NNI, contrel room indication
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displays labeled as steam generator A (or B) are not all monitoring 2.
the sa=e secar. generator.
The first p. rob'lem, involving the ICS, has been addressed by 35U in their Specifically, the response responses to NRC questions 031.37 and 232.3.
h to 031.37 states, in part, "There has been no analysis pe important side of acceptable limits precisely because such failures are r.otA
,co safety."
"No ICS or operator action is required for reactor These state =cnts need to be reconfirmed by BLW in light of states, in part, protection."
the current situation.
The second probica, involving control room indications, could lead to confusion of the control room operators even though the indications are However, as stated in FSAR Subscetion 15.0.2, "No All accidents non-safety related.
ICS or operator action is required for reactor protection.
. Operator arc'analy cd without iemediate ICS or operator action.
action for caintaining hot shutdown conditions or for ini Therefore, no instrument indications are available to the operator."
i operator action has been assumed based upon non-safety related instrume This position also =ust be confirmed by DLU.
We are continuing to rescarch this issue and will document any additional
- s information and/or B&W's concurrence in a subsequent IOM before 3/26/80
.a.0L M Prepared by:
J. A. Clements Licensing Group Supervisor
[ 3.it. Anderspd _,e Concurrence by:
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Control Systcias Croup Supervisor V
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- J. N.
Vance Chief Nuclear T.ngineer 1
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'[ 1 Attachm:nt 3 006906 d March 11, 1980 MCAR #38 (component identification), date
SUBJECT:
? ?tarim Report [1 I
April' 1,.1980 I
Dsts:
Consumers. Power Company Midland Plant Units 1 & 2 Frajict:
Bechtel Job 7220 Ivtreduction interim status and actions taken
'This, report is submitted regarding the
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pursuant to MCAR #38.
B&W and Bechtel numbering system Description of Discrepaner Inctnsistent cross-referencing between ling Actuation System (ECCAS), and l
B&W-supplied instrument systems (Non-Nuc ear )] and other com-Control Systems (ICS), Emergency Core Coo tor Protection System (NI/RPSThis incons Nuclear Instrumentation and Reac p:nents has occurred on Unit 1.
plied-systems.be postulated that the ICS and reculted in inconcistent wiring of B&W-sup dis-e incorrect indications would be wiring were to remain uncorrect.ed, it can is a preliminary response to the recom-would not function properly and that som i
lplcyed to the operator. The follow ng mended actions of MCAR 38:
had an adverse affect on the Determine'if this situation could have safety of operation of the plant.
ing inconsistency has indicated 1.
l have remained uncorrected, would probab y b
Bechtel evaluation to date of the num er of operations of the Midland that the deficisacy, were it tonot have affected adversely th ft rtability of this matterSubject to further Plant.
the potential for repo d with B&W.l's preliminary conclusions On March 20, 1980, under 10 CTR 50.55(e) was discussefunctions (ECCAS and review, B&W tentatively agreed"with Bechtesystcas in i
s lish their functions'under existing condit on.
h t time, B&W could not that the Based on the information available at t aontrol room dispinys would
.NI/RPS) would accomp conclude that the incorrect labels on cof operations of the plant.
ct of reportability not have adversely affected the safetyThe B&W resp of this matter under 10 CFR 50.55 e 18, 1980.
to Bechtel by April d r 10 CFR 50.55(e) is that
- However, Our present position on reportability un ear to be reportabic.aluation and the situation does not presently appewill be reviewed based on the B investigation.
this position further results of project
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actions.
Determine cause and procedural correct ve isinterpretation by
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The most probable cause appears to be some mof cross-referencing be
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No ing system for Unit 2.
design personnel regarding the system have been identified to b
the BW and Bechtel component num er ibed below under specific procedural corrective actionsdate; houever, so
" Corrective Action.",*
Determine remedial actions.
ideration, and the best 3.
Several alt'e'rnative solutions are under consd below unde solution will be determined as describe Action."
bable prrbable Cause,.
of Discrepancy" for discussion of pro i
Refer to item 2 under "Descript on ccuse.
formed to coordinate resolution o Corrective Action A sulti-discipline Midland project task grou The CNTG will act as a Numbering Task Group" or CNTC) has been
- schedule, d related matters.-issue (s), and to plan,f remedia the issue addressed in McAR 38 an As h
steering group t6 completely define t eand cause complete implemen monitor, report, p;rt of their activities, the CNTG w
-inconsistency.
Safety Impliention repancy* for discussion of safety lieved as a practical matter, it is be i
Refer to item 1 under " Description of D sc to fuel It should be noted that, undetected and uncorrected priorheckouts that implication.that this item could not have goneof the numerous component and syst This is because d
t:111 be made prior to fuel loa.
load.
of Corrective Action 16, 1980.
Forecast Date be issued by Hay The next interim report is scheduled t'oN.,[
hw Submitted by:
Approved by:
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Concurrence by:
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warm,weniaan 8106 men Aseen P.O. 80s 1000, Ann Arbor, Michigan 4 008234 May 16, 1980 5
BLC-9277~
Consumers Power Company 1945 West Parnall Roa'd 49201 Jackson, Michigan
.Mr.J.W.dook Attention: Vice President Midland Project Midland Plant Units 1 and 2
Subject:
Consumers Power Company Bechtel Job 7220 HCAR 38 Interim Report 2 d use is MCAR 38, Co:ponent
- Att. ached for your information anIdentification, Interim Rep conclude that the subject In a change from Interin Report 1, we nowFR 50.55(e).
Censumers issue is probably reportable under 10 C i
by telephone on Power Company was notified of this posit onMay 13, 1980).
May 2, 1980 (confirmed in BLC-9260, dated be issued by The next interim report is scheduled to August 1, 1980.
7 y yo Very John A. Rutge.
er Project Man i
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JAR /P1R/kb MCAR 38 Interim Repdtt 2
Attachment:
W.R. Bird w/a cc:
G.S. Keeley w/s B.V. Marguglio w/a p201%0 i
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. Resp'once Requested:
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HCAR #38 (Component Identification) dated March 11, 1980 SUBJCCT:
INTERDi REPORT #2 -
008234 Pr; ject: Consumers Power Company Midland Plant Units 1 & 2 Bechtel Job 7220 Introduction This report is submitted r,egarding the interim status and actions p :ition that the issue addressed in MCAR #38 is probably reportable under to UCAR #38.
10 CPR 50.5)(c).
D^rcription of Discrepanev I :onsistent cross-referencing has occurred ou Unit 2 betwee (NNI), Integrated Control Systems (ICS), Emergency Core Cooling Actuation System (ECCAS), and Nuclear Instrumentation and Reactor Protection Sy If the -inconsistent wiring were to remain cther components.
l wiring of B&U-supplied systems. uncorrected, it can be postulated that the ICS and NNI w cnd that come inectreet indications would be dioplayed to the operator.
Status and Actions Taken The Midland Project Component Numbering Task Group (CNTG) is coordinating resolu The scope of the Midland numbering problem is currently cf the subject issue.
bring studied, and information is being solicited from other utilities.
B&W has indicated that they could not support the preliminary conclusion,e,xpressed the deficiency, were it to have remained uacorrected, ia Interim Report #1 (that w:uld probably not have affected adversely the safety of operations of the The Midlend plant) because the deficiency would invalidate the safe cnalyses.
A revised safety analysic postulating that the deficiency r main uncorrected until cause a bona fide plant operation might determine that the condition would notHouever, this w safety problem.
process, particularly since remedial action is now in progress.
Safety implientions Eaced on the expressed concern that the, inconsistencies could result in inappropriate cperntor action which could adversely affect the safety of plant operations, we conclude thst the deficiency probably should be classed within the " adverse to cafety" requirement of 10 CTR 50.55(e).
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g Cttrsetive Action The CNTG will determine the 33 corrective actio.n has been determined at this time.l ation is completed an prcierredsolutiontobegigenengedastheevau esrrsetive action is defined [h fdture reports.
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~ Dita on Which-the' Corrective Action will be Taken i n by July 1,1980, and fg I
Prclininary planning indicates a completion of evaluat o coepiction of impicmentation by January 1,1981.
Rtportability l de that the subject-Bas:d on the - safety implications stated above, we conc u This is due to the d2ficiency is probably reportable under 10 CFR 50.55(e).
to safety" requirement fcer that the deficiency will be classed within the " adverse i the "significant cf.10 CFR 50.55(e) g it has been determined to be with n d2ficiency in final design" requirement.
Additional Information define the issue (s), and to l
l Th2 CNTG will act as a steering group to complete yand cause. complete implementat plan, schedule, monitor, report,Several alternative solutions are under considera will be determined and implemented.
cetions.
se of the numbering relution
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As part of their activities, the CNTC will determine the cauThe m tion by design pcyconnel regarding the. system of cross-referencing inconsistency.
l Eschtel componant numbering system for Unit 2.
is believed that this Nowevet, it-should be noted that, as a practieni matter, itt d prior to fue Thi: is item eculd not have gone undetected and uncorrec e h t will be made prior to b:cause of the numerous component and system checkouts t a fuel inad.
August 1,1980.
The next interim report is scheduled to be issued by 4
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4 Submitted by: [/
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.H. Anderson 4
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Approved by:
F L.R.'Curtis Concurrence by:
it.D. Ba',iley
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Concurrence by:
L. A. Dre s.lasch '
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