ML19340D397

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Final Deficiency Rept,Originally Reported by 801119 Telcon, Re Violations of Separation Criteria in Power Generation Control Complex.Final Separation Insp Will Be Documented for Each Panel Containing safety-related Components
ML19340D397
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 12/17/1980
From: Kemper J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
10CFR-050.55E, 10CFR-50.55E, SDR-19-1, NUDOCS 8012300527
Download: ML19340D397 (5)


Text

. ,CW PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 DEC 171980 JOHN S. KEMPER vict sessioswr

. . . . . . . . . . ..........c Mr. Soyce Crice, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement. Region I i 631 Park Avenue  !

King of Prussia, PA 19406 ,

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SUBJECT:

Sienificant Deficiency Report No.19 Final Report for Violations of Separation Criteria in the FGCC Lincrick Generating Station, Units 1 & 2 'l NRC Construction Fernit Nos. GPPR-106,107 ~1 s i RE72REFC2: Telecon of Novembe.r 19. 1030

9. R. tialters (PECO) to J. "attia (NRC)

FILE: CUAL 2-10-2 (SER plo)

Ocar :'r. Grier:

Attached is our final report on the above subject deficiency which was reported to the USTRC per the referenced telecon in accordance with 10C79.5 0.55 (e) .

.If there are any questions on the =atter we vould be pleased to discuss them with yeo.

Sincerely,

$~/d 1 7

Attachnent Copy to: Director of Inspection and Inforcement [

United States Nuclear Rc2ulatory Cennission h' ash ing ton, D.C. 2C555 3o/7 s

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8012300547 3

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I FINAL REPORT-i VIOLATIONS OF SEPARATION CRITERIA IN THE POWER GENERATION CONTROL COMPLEX i

LIMERICK GENERATING STATION UNITS 1 AND 2

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i PHILADELPHIA ELECTRIC COMPANY I)ECEMBER, 1980 .

SDR-19-1.

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TABLE OF CONTENTS 1.0 Introduction 2.0 Description of Problem 3.0 Analysis of Safety Iciplications 4.0 Corrective Action Taken 5.0 Conclusions l

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SDR-19-2 i

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1.0 Introduction The Limerick Generating Station Power Generation Control Complex (PCCC) was purchased from General Electric Company as part of Nuclear Steam Supply System contract. The PGCC is comprised of the main control room consoles and vertical control boards as well as the panels containing the control logic for the safety-related and non safety-related T'snt systems.

Violations of the Project requirements regarding separation of safety-related internal panel wiring have been identified in several PGCC panels and it has been determined that plant safety could have been compromised under certain conditions had these separation violations gone undetected.

In compliance with 10CFR 50.55(e), this Final Report is issued to describe the deficiencies, analyze their safety implications, and describe the action taken to correct them. .

This significant deficiency was reported' via telecon to the USNRC, Region I on November 19, 1980.

2.0 Description of Problem During visits to the General Electric Company PGCC fabrication facility, Philadelphia Electric Company (PECO) engineering personnel observed violations of Project separation criteria in Limerick safety-related PGCC panels which were under construction. Separation as required by the connection diagrams was not being consistently provided for internal panel wiring.

The Project separation criteria for internal panel wiring of the PGCC are implemented through the use of notes on these connection diagrams.

The noted violations were discussed with General Electric Company. As part of the resolution of these violations, it was agreed that corrections suuld be Laplemented by General Electric field personnel af ter delivery to Limerick via Field Disposition Instructions (FDI) .

Af ter receipt of the PGCC panels at Limerick, PECO QA personnel identified I several instances of violations of the Project separation criteria while inspecting the internal wiring of several panels. Several of these violations were in addition to those previously identified at the factory.

Although General Electric had not yet completed field modifications to the PGCC panels prior to the PECO QA inspections, PECO has concluded that nu:erous changes to the panels will be required to achieve compliance with the Project separation criteria and, thernfore, this is considered to be a Significant Deficiency. Based on the extent of the violations observed both in the factory and at the site, it is concluded that this deficiency can be attributed to a lack of adequate instruction of the factory viring personnel and a breakdown of the factory QC inspection prog ram.

SDR-19-3 i

4 3.0 Analysis of Safety Implication Because of the multiplicity of wires and panels involved with this deficiency, it is not feasible to identify individual safety implications.

However, if these conditions had gone undetected, safety could have been compromised by the unanalyzed failure of a safety-related system.

The inadequate separation of internal panel wiring could lead to an unanalyzed failure of a safety- related system due to the propogation of a failure to that system from a redundant safety-related system or from a non safety-related system.

4.0 Correcti?e Action Taken Based on the inspections that have been performed to date on the safety-related panels and consoles, it is. apparent that a complete re-inspection of each panel is required tn verify that all separation violations have been identified and corrected. General Electric Company has been informed by letter of the PECO position that all PGCC panels containing safety-related components must be re-inspected for compliance with the Project separation criteria.

Because of the large amount of field work yet to be performed on the PGCC panels, final separation inspections will be performed upon completion of the field re-work on each panel.

General Electric Company has been requested by letter to submit a schedule for the issuance and implementation of the FDI's required to correct the separation deficiencies.

The final separati6n inspection will be documented for each PGCC panel containing safety-related components and will be performed prior to the panel beiog released for system pre-operational testing.

5.0 Conclusions The corrective actions described above will correct and eliminate violations of Project separation criteria within the PGCC panels prior to loading fuel for each unit.

EFS:rs SDR-19-4

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