ML19318C307
| ML19318C307 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 06/30/1980 |
| From: | Paton W NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Marshall W MAPLETON INTERVENORS |
| References | |
| NUDOCS 8007010333 | |
| Download: ML19318C307 (2) | |
Text
{{#Wiki_filter:. 8 cD RE% g .A UNITED STATES [% j NUCLEAR REGULATORY COMMISSION j WASHINGTON, D. C. 20555 J '$q.....,o June 30, 1980 Mr. Wendell H. tiarshall President, Mapleton Intervenors Route 10 Midland, Michigan 48640 In the Matter of Consumers Power Company (Midland Plant, Units 1 and 2) Docket Nos. 50-329 & 50-330 (0L Proceeding)
Dear Mr. Marshall:
I have received your letter dated June 17, 1980, postmarked June 22, 1980, addressed to the "U. S. Nuclear Regulatory Commission, Washington, DC 20555." In your letter, you refer to recent publicity in the communications media which you say addressed faulty blueprints involving " wiring to instruments in the containment buildings of Unit 2." You ask for information concerning this matter. I enclose a copy of a letter (with attachments) dated May 22, 1930 from Consumers Power Company to the Director of our Region III Office in Illinois relative to the Midland Nuclear Plant. The attachments to Con-sumers' letter describe inconsistent cross-referencing between B&W and Bechtel numbering systems for B&W-supplied instrument systems on Unit 2. I believe this is the matter to which you refer. Consumers' letter states that another-report will be issued on or before August 22, 1980. We will furnish you a copy of that report. There is another matter that I wish you would address. That involves your status in the Midland operating license proceeding. In recent months, I have discussed this proceeding with Mr. Grant J. Merritt, who has represented you, and with Mr. Steve Gadler (who the Board refers to, at page 19 of its Special Prehearing Conference Order, dated February 23, 1979, as your "other representative"). Please advise whether you intend to represent yourself or have Mr. Merritt or Mr. Gadler represent you. Sincerely, f William D. Paton Counsel for NRC Staff
Enclosure:
As stated cc w/ encl: See attached list 80070gg 3
F cc w/ enc.: Ivan W. Smith, Esq. Mr. Gustave A. Linenberger Dr. Frederick P. Cowan Frank J. Kelley Myron M. Cherry, Esq. Ms. Mary Sinclair Michael I. Miller, Esq. Grant J. Merritt, Esq. Judd L. Bacon, Esq. Mr. Steve Gadler Ms. Carol Gilbert Mr. William A. Thibodeau Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Board Panel Docketing and Service Section e e%-
[/ .A'}C000mi10rS ) / I I DGridi ( _ / James w cook Ol Vtte l' resident, Afidl.snJ Prr> ject / General of fices: 1945 West Parnell Road, Jack,on, Machigan 49201 e (517) 788-0640 May 22, 1980 Mr J G Kepplcr, Regional Director Office of Inspecticn and Enforcement US Nuclear Regalatory Conmission Region III 799 Roosevelt Read Glen Ellyn, IL 60137 MIDLAND NUCLEAR PLANT UNIT No 1, DOCKI"' NO 50-329 UNIT NO 2, DCCKET NO 50-330 NSSS COMPCNENT IDENTI7ICATION 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 situation orig'inaAly reported by a telephone call from G R Eagle, CPCo MPQAD to R Knop, NEC 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 interim or final, vill be issued on or before August 22, 1980. 0%a!.A GRE/1r Attachments:
- 1) Quality Assurance Program, Management Corrective Action Report, MCAR-38, dated March 11, 1980
- 2) Letter "MCAR Component Identification" to L H Curtis, dated March 12, 1980
- 3) MCAR-38, Interim Report #1, dated March 11, 1980 h) MCAR-38, Interim Repert #2, and Cover Letter dated !'ay 16, 1980
( CC: Director of Office of In pection and Enrorcement Att: Mr Victor Stello, USNRC (15) $\\ l Informatien & Pregram Ce rol, USNBC (1) 80 28 0 /,Al
OUALITY ASSURAl4CG PROGitAM [' MANAGEMEMT CORilECTIVE ACTION REPOll! Att,achment 1 MCAR4 " * * * * ~ REPORT NO. f ilarch 11, 1980 DATE 7220 O NO. JOD NO. l ' DESCRIPTION (includinD references): between the Project Engidecr advised that inconsistent cross referencingCCII, ICS, EC On Ifarch 10, 1980 B6V and Bechtel nuchering systems for BLU-supplied instrument systemsThis inconsistent c tnd NI/RPS) has occurred on Unit 2. Because of the inconsistent viring, the inconsistent viring of BLU supplied systems. ICS and ImI will not function properly and so=c incorrect indications are displayed to the operator. 'RECO;.1 MENDED kCTION (Op!!onal) Determine if this ad.c=aly cocid have an adverse affect on the ' safety of operation 1. the plant'. Report to PQAZ by ifarch 26, 1980. Determine cause and procedural corrective actions. 2. Deterninc most logical fix to problem. 3. OOA MANAGEMENT C CC:ENGINEENNG O CONSTRUCTION REFERf'.ED TO O PROCUREMENT ~ W ^ ISSUED BY Pio eCt OA Entneet Cy*O s I NOTIFIED CUENT REPORTABLE DEFIC!ENOY I see loM J.ClemnM. L.Cvrii) oste O YES Project uanaget 3(NO i:.d Her 12 So l S .,,v Kctm. 3 0 lll CAUSE c-CORRECTIVE ACTICN TAKEN ~ AUTHORIZED BY ADDmONAl.D!SintDVDON AS APPROPRIATE FORMAL. REPORT TO CUENT ST AttOARD o:SIntDUTION p,go t.ee.= E nw. um acta (l! Sect. ion 11 App.gics) cvnso O.ue,4cen swurcienc' sten u cs..or o. tro A t.O par'ocurt* ut N t 'Urrtitn OUAUTY MCA ca in paNaorn CoasM HtJCICt8 u A'* AGt R o p.*Gi n reno):,nvE t t\\OJ CCr.Sttt vA'oACLR p p o.unoctnce.ta CORRECTIVE ACTIO.1 IMPLEMENTED ess rCtts e . u .c.tn AAo e f*OJCC1 Cef stalk %$ e tan ACCR tuviejoes 4 n0cyntes.t.f unn Ato rtWteit ut tef tec4ACUt rnOJIWCO'ioutr t pare e stok%H N Lut.mapesa 06v 3.us's tittic'JAtity ucn AAo 6s4 OF Cos.%tnutto 4 VEnlFIED DY _ Proicct OA Ene; beet
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an g 2 ~ ( ~ BechteiPowerCorporation ~ Inter-office Mer.norandum To L. H. Curtis Date. March 12,,1930 Subject Midland Plant Units 1 and 2 From J. A. Clc:nents Bechtel Job 7220 1: CAD. 38 - COMPOND:T Of 7220 - Licensinr. IDR:TIFICATION Cop;es to At-Ann Arbor Office. J. I'. Anderson V. J. Manta ~ ~ D,. R. Anderson R. L. Rixford File 0534, LG-13.4 L. A. Dreisbach M. O. Rothuell E. M. Hughes J. N. Vance B. P. Kononcez }i. E. Velastegui Comm Log The purposc o'f this IO:I is to docu=ent the safety-related basis to be used in conjunction with a "signiffcancy" study, to be done by others, to determine if the subject deficiency is reportabl.c under 10 CTR 50, Subsection 50.55(c). [ CONCLUSI0"- This deficiency, were it to have renai ned uncorrected, could \\ not have af fected adversely the safety of ope: ationis of tEic Midland Plant at anytiac throughout the lifetite of the plant. _B/ SIS : The component identification problem involyces inconsistent cross-referencing between BEti and Bechtel nu= bering syster=s for EL!i supplied components in both the primary and secondary system:s of Unit 2. This. inconsistent cross-referencing resulted in inconsis: tent viring of the following Unit 2 B6if-supplied instrument systens: Nuclear instrucentation/ reactor protection system (In/RPS) Emergency core cooling actuation systen (ECCAS) + Non-nuclear instru entation (In:I) ~ Integrated control system (ICS) The analysis completed to date on the ELI?-supplied c:ngineered safety featurcs actuation systems, i.e., the MI/RPS and ECCAS, have indicated that their safety-related functions would not have been de.?.raded by the component numbering problem. These safety systens diepend upon a . 2-out-of-4 coincidence logic to initia te their safet.y functions.
- Thus, they are unaf fected by the orcter in which the, input signals are wired.
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[ Bechtel Power orporation. Inter-office Mccorandun March 12, 1980 Page 2 There are two probic$s associated with the non-safety related systems, i.c., the NMI and ICS, due to the conponent numbering probic:2: 1. The 10iI and ICS vill not function proper 3y. They are wired r
- that' feedwater is controlled as a function of sa=e steam generator secondary side parameters (stca: generator pressure and Icycl, feedvater flow and temperature) and opposite seca= generator pricary side parameters (RCS flow) instead of the same steam generator primary and secondary side parameters.
Due to the inconsistent viring of the NNI, control room indication 2. displays labeled as steam generator A (or B) are not all t:enitoring the sa=e secan generator. The first prob'len, involving the ICS, has been addressed by BM? in their responses to NRC questions 031.37 and 232.3. Specifically, the response "There has been no analysis perfor=ed which to 031.37 states, in part, identifies f ailure codes of the ICS that ecuse an abnormal condition out-side of acceptnble linits precisely because cuch failures are not important to safety." Also, TS/JL Subsection 15.0.2, Single-Failure Philosophy, .( Ltates, in part, "No ICS or operator action is required for reactor protection." These statc=cnts need to be reconfirmed by DC? in light of the current situation. The second problem, involving control room indications, could lead to confusion of the control roo= operators even though the indications are non-safety related. However, as stated in FSAR Subsection 15.0.2, "No All accidents ICS or operator action is required for reactor protection. . Operator arc analy::ed without itecdiate ICS or operator action. ~ action for maintaining hot shutdown conditions or for initiating cool-down to cold shutdown conditions is assu=ed only when adequate time and instruencnt indications are availabic to the operator." Therefore, no operator action has been assu=ed based upon non-safety related instrumentation. This position also cust be confitned by BC?. k'c are continuing to rescarch this issue and uill document any additional IOM before 3/26/80. information and/or BC1's concurrence in a subsequent /.a.G wM Prepared by: J. A. Clements Licensint> Group Supervisor Concurrence by: _ft ,C-- [ J.:!. Anderssd[ (, Control Systens Croup Supervisor v g d 4 % ~ e.
- J. M. Vance Chief NucIcar T.ngineer f
009906 SULJECT: MCAR #38 (component l>3ntification), dated March 11, 1980 Interim Report #1 Date: April 1, 1980 Project: Consumers Power Coopany 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-referencing between B&W and Bechtel numbering systems for syste=s (Non-Nuclear Instrumentation (NNI), Integrated B&W-supplied instrument Control Systems (ICS), Emergency Core Cooling Actuation System (ECCAS), and Nucicar Instrumentation and Reactor Protection System (NI/RPS) } and other com-ponents has occurred on Unit 2. This inconsistent cross-referencing has If the inconsistent resulted in it. consistent wiring of B&W-supplied systems. the ICS and NNI viring were to remain uncorrected, it can be postulated that vould not function properly and that so=c incorrect indications would be dis- [ The following is a preliminary response to the recom-played to the operator. mended actions of MCAR 38: Determinc if this situation could have had an adverse affect on the 1. safety of operatien 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 outential for reportability of this matter under 10 cra 50.55(c) sa. discussed with B&W. Subject to further B&W D&W tentatively agrcEd"with Bechtel's preliminary conclusions
- revicw, that the systcas involved that provide safety functions (ECCAS and NI/RPS) would accomplish their functions under existing conditions.
Based on the information available at that time, B&W could not conclude that the incorrect labels on control room displays would 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(e) is scheduled to be submitted r to Bechtel by April 18, 1980. Our present position on reportability under 10 CFR 50.55(e) is that the situation does not presently appear to be reportable.
- However, will be reviewed based on the B&W evaluation and any
(. this positio-further resuits of project investigation. 1 L . m_j e n
I 006003 Determine cause -and procedural corrective actions. 2. The most probable cause apperts to be some misinterpretation by design personnel regarding the system of cross-referencing between 2. No the B&W and Bechtel component numbering system for Unit specific procedural corrective actions have been identified to date; however, some may be determined as described below under " Corrective Action." Determine remedial actions. 3. and the best Several alternative solu. ions are under consideration, solut Action." Probable Cause_ f probable Refer to item 2 under " Description of Discrepancy" for discussion o cause. Corrective Action " Component A multi-discipline Midland prcject task group (referred to as theion of Numbering Task Group" or CNTC) has been formed to coordinate resolut ( The CNTG will act as a the issue addressed in MCAR 38 and related matters.the issue (s), and to plan,
- schedule, steering group to completely define implementation of remedial actions.
As and cause complete f the numbering monitor, report, part of their activities, the CNTG will determine the cause o inconsistency. Safety Implication _ f safety Refer to item 1 under " Description of Discrepancy" for diccussion oas a practi It should be noted that, d prior to fuel that this item could not have gone undetected and uncorrecteThis implication. load. will be made prior to fuel load. Forecast Date of Corrective Action is scheduled to be issued by liay 16, 1980. Tne next interim report Submitted by: N, m Approved by: /
- Obl,
[fts Concurrence by: ./ ( HAC/pjh O
Attcchm:nt 14 ~ Bechtel Power Corporation 777 East Eisenhower Parkway t._, 008234 Ann Arbor, Michigan pes Aseen P.O. Bon 1000. Ann Arbor, Michigan 4810G May 16, 1980 BLC-9277 Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 Attention: Mr. J.N. Cook Vice President Midland Project
Subject:
Midland Plant Units 1 and 2 Consumers Power Co=pany Bechtel Job 7220 MCAR 38 Interim Report 2 Attached for your infor=ation and use is MCAR 38, Co:ponent (. Identification, Interim Report 2. In a change from Interim Report 1, we now conclude that the subject issue is probably reportabic under 10 CPR 50.55(e). Consurers Power Company was notified of this position by telephone on May 2, 1980 (r.onfirmed in BLC-9260, dated May 13, 1980). The next interim report is scheduled to be issued by i August 1, 1980.
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.i f 49 {#?# # John A. Rutge's Project Man er JAR /RLR/kb Attachrnent : MCAR 38 Interim Report 2 cc: W.R. Bird w/a C.S. Reeley w/a B.U. Marguglio w/a T>TG@$ N h5, n u d G e MA'/ 20 WBO ~ b-Response Rcquested: No i
SUBJCCT: HCAR !38 (Component Identification) dated March 11, 1980 ( INTERIH P.EPORT d2 008234 Project: Consumers Power Company Midland Plant Units 1 & 2 Bechtel Job 7220 p 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 reportable under 10 CFR 50.55(e). Dercription of Discrepancy Inconsintent cross-referencing has occurred on Unit 2 between B&W and Bechtel numbering systems for B&W-supplied instrument systems (Non-Nucicar Instrumentation (NNI), Integrated Control Systems (ICS), Emergency Core Cooling Actuation System (ECCAS), and Nuclear Instrumentation and Reactor Protection System (NI/RPS)] and other componente. This inconsistent cross-referencing has resulted in inconsistent wiring of B&U-supplied systems. If the inconsistent wiring were to recain uncorrected, it can be postulated that the ICS and NNT would not function properly and that ceme incerrect 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 probics is currently being studied, and information is being solicited from other utilitics. B&W has indicated that they could not suppo rt the preliminary conclusion, expressed in Interim Report #1 (that the deficiency, were it to have rc=ained uncorrected, would probably not have affected adversely the safety of operations of the The Midlcnd plant) because the deficiency would invalidate the safety analyses. 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 plant operation might determine that the condition would not cause a bona fide safety prob 1cm. Rouever, this would be an unnecessarily costly and tire-consuming process, particularly since remedial action is now in progress. Safety Implientions Based on the expressed concern that the_ inconsistencies could result in inappropriate the saf'ty of plant operations, we operntor action which could adversely affect e concInde thst the deficiency probably should be classed within the " adverse to safet* requirement of 10 CPR 50.55(e). l e
strective Action The CNTG will determine the no corrective action has been determined at this time. d proper preferred solution to bc[}igeriented as the evaluation is completed an cerrective action is deflncd Ih fdture reports. d Date on Which the Corrective Action will be Taken Preliminary planning indicates a completion of evaluation by July 1,1980, and completion of impic=cntation by January 1,1981. I Reportability Based on the saf ety implications stated above, we conclude that the subjectThis is due to deficiency is probably reportable under 10 CFR 50.55(c). fact that th of 10 CFR 50.55(c) AND it has been determined to be within the "significant deficiency in final design" requirement. Additional Information The CNTG will act as a steering group to completely define the issue (s), and to and cause. complete impicmentation of remedial and the preferred schedule, monitor, report, Several alternative solutions are under consideration,
- plan, actions.
rolution ulli be determined and implemented. to part of their activities, the CNTG will determine the cause of th ( design perconnel regarding the system of cross-referencing between the BW and inconsistency. The most Bechtel compon2nt numbering system for Unit 2. Iloweve(*, it chould be noted that, as a practical matter, it is believed that this Thie is . item could not have gone undetected and uncorrected prior to fuel load. The next interim report is scheduled to be issued by August 1,1980. Submitted by: / /d c [.M. Anderson M# M G 4 Approved by: (/ f L.H.'Curtis I Concurrence by: K.D. Ba',iley i L Concurrence by: [I L. A. Dref1 bach ' tmc/pjn i .}}