IR 05000245/1987017
| ML20245D535 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/21/1989 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mroczka E NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML20245D537 | List: |
| References | |
| EA-88-254, NUDOCS 8905010036 | |
| Download: ML20245D535 (5) | |
Text
--
.
_ ___.
_
__
. _ - _ _.
D QS
!
.
...
..
.
,
i April 21, 1989 Docket Nos. 50-245 and 50-336 License Nos. DPR-21 and DPR-65 i
EA 88-254 Northeast Nuclear Energy Company ATTN: Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations Group Post Office Box 270 Hartford, Connecticut 06141-0270 Gentlemen:
50-338/[87-15; Subject: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIV PENAlT (NRC Combined Inspection Reports Nos. $0-245/87-17
and 50-245/88-14; 50-336/88-20; and 50-245/85-30; and 50 336/85-35)
This refers to the NRC inspections conducted on November 18-22, 1985, July 15-17, 1986 and August 16-19, 1988 to review the program for the envi-ronmental qualification (EQ) of equipment at Millstone Units 1 and 2.
The inspection reports were sent to you on April 15, 1986, November 19, 1987 and October 14, 1988, respectively.
During the inspections, violations of NRC requirements which were identified by your staff involving the lack of quali-fication of certain items of electric equipment used in both units, were also reviewed. On November 9, 1988, an enforcement conference was conducted with you and members of your staff to discuss the significance and extent of the violations, causes of the violations, and the corrective actions taken or planned.
Further, the enforcement considerations set forth in Generic Letter 88-07 were also considered.
One of the violations, which is described in Section I of the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice), consists of examples of failura to maintain, for certain items of electric equipment, a file of documentation to demonstrate that the items were qualified to perform their intended function (s) during the postulated environmental conditions.
These items, which were identified by your staff, included PE/PVC cables, General Electric EB-5 terminal blocks, Honeywell microswitches and 3M Scotch-
'.tk wire nuts associated with the Standby Gas Treatment System (SGTS) in Unit'l and Ideal, Model 748, wire nuts on the termination of one ASCO solenoid valve which controls the atmospheric steam dump valve on Unit 2.
The SGTS components are required to operate in a high radiation environment during postulateo accident conditions.
The items were unqualified in that the SGTS component; were never tested for the harsh environment nor the material analyzed to determine its ability to withstand high radiation without substantial degradation.
Further, the documentation in the qualification file did not support qualification of the Ideal, Model 74B, wire nuts for operability in a high energy line break (HELB) environment of 320F peak temperature.
OFFICIAL RECORD COPY CP PKG MILL 4/17 - 0001.0.0
/d 8905010036 890421 04/18/89 PDR ADOCK 05000245 Q
FDC E
\\
\\
l E___ _ -- -
-
- - -
-
-
-
L J
_ _ _ _ _
- - _ - _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ _ _ - _ _ _ _.
_. _.
_ _ _ _ _ _ - _
'
.
.
.
Northeast Nuclear Energy Company-2-These deficiencies clearly should have been known to you prior to November 30, 1985. With respect to the SGTS components, you clearly should have known of these deficiencies because the high radiation field associated with the internal filter was a design feature of the original equipment and should have been a consideration for material selection.
The basis for the NRC staff's acceptance of the qualification of the SGTS, which was described in your various submittals, was our understanding based on those submittals, that the modifications made to the reactor building isolated the SGTS from the LOCA and HELB environments.
In the staff's view such harsh environments clearly include radiation considerations.
The fact that a data table supplied in one of the submittals contained information that conflicted with the statements the NRC staff relied on in accepting the SGTS does not alter our conclusion.
In fact, the existence of the conflicting infor-mation supports the NRC staff's position that you clearly should have known of the deficiencies.
It is understandable that an NRC reviewer might not identify the problem of the conflicting data given the general statements previously made, while the document preparer should have identified the problem because the data conflicted with his conclusion.
With respect to the Ideal wire nuts (Model 74B), you clearly should have known of the deficiency because the associated solenoid valves were required to be environmentally qualified and in order to maintain that qualification replace-ment parts should have been verified as acceptable for the environment in which they are to be used.
Further, given that the associated solenoid valves were specifically replaced for EQ considerations in the 1979-80 time period it is reasonable to expect that replacement instructions would have assured quahfication of the valves and interfaces were maintained.
The NRC staff considered your argument that the installation of the unqualified wire nuts is a maintenance procedure problem rather than an EQ deficiency.
It is the NRC staff's position that EQ is not solely an engineering function.
Rather, when the failure to properly install or maintain a piece of equipment can adversely affect the equipment's qualification, an EQ deficiency exists.
While a flawed procedure was the reason that unqualified wire nuts were installed in this particular instance, the fact the procedure was not properly reviewed with respect to EQ makes this an EQ deficiency.
Further, it was reasonable to expect that a licensee would perform field verification for electrical equipment, including the SGTS components and the Ideal Model 74B wire nut terminations for the ASCO solenoid valve, to assure proper qualification and installation.
This violation demonstrates that sufficient attention was not provided to the EQ program at Millstone, as evidenced by the inadequate engineering review of the SGTS and inadequate Quality Control of these activities.
Accordingly, I have been authorized, after consultation with the Director of Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards, and Operations Support to issue a proposed civil penalty in the amount of Fifty Thousand Dollars (550,000) for Violation I described in the enclosed Notice.
In accordance with the " Modified Enforcement Policy Relating to 10 CFR 50.49," (Modified Policy) contained in Generic Letter 88-07 l
(Enclosure 2), Violation I has been determined to be small and to have affected
'
a few systems and components, and therefore is considered to be an EQ Category C violation. The base value of a civil peralty for an EQ Category C violation is $75,000.
!
0FFICIAL RECORD COPY CP PKG MILL 4/17 - 0002.0.0
04/1E/89 I
-
.
.
.
Northeast Nuclear Energy Company-3-In determining the civil penalty amount, the NRC considered the four factors set forth in the Modified Policy, for escalation and mitigation of the base civil penalty amount. These factors consist of (1) identification and prompt reporting of the EQ deficiencies ( 50%); (2) best efforts to complete EQ within the deadline ( 50%); (3) corrective actions to result in full compliance ( 50%);
and (4) duration of a violation which is significantly below 100 days (-50%).
With respect to the first factor, 50% mitigation is appropriate since both examples were identified by your staff. With respect to the second factor, no mitigation is appropriate because your failure to identify and establish qualification files for the Standby Gas Treatment System represents a signi-ficant oversight in your control of engineering activities affecting EQ that was not identified and corrected until an independent reverification program disclosed it after the EQ deadline.
Further,Section II of the enclosed Notice documents a number of other less significant EQ violations which existed at the time of the EQ deadline and therefore, given the total number of environ-mental qualification violationr set forth in the enclosed Notice, it is clear that the best efforts were not exhibited prior to the EQ deadline to ensure compliance with the requirements. With respect to the third factor, 50%
mitigation is appropriate since comprehensive corrective actions were taken, once the violation was identified. With respect to the fourth factor, mitiga-tion is inappropriate since these EQ violations existed in excess of 100 days.
Therefore, on balance, 100% reduction of the base civil penalty amount would be appropriate.
However, in accordance with Section IV.8 of the Modified Policy, the minimum $50,000 civil penalty is being assessed. Although the policy permits full mitigation under certain conditions, full mitigation is inappro-priate here because of your lack of best efforts to complete EQ within the deadline.
In addition to the violation assessed a civil penalty,Section II of the enclosed Notice contains two less significant violations.
Since the NRC finds that the items discussed in Violation II.A were shown to be qualified or qualifiable during the inspection or shortly thereafter classification of the violation at Severity Level IV is appropriate.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
l s
0FFICIAL RECORD COPY CP PKG MILL 4/17 - 0003.0.0 04/18/89
.
.
_
_
_ _ _ _ _ _ _ _.
_ _ _ _ _ _ -
_
_ _ _ _ _ _ _. __
_
I
.-
.-
.
,
Northeast Nuclear Energy Company 4-i
-
The responses directed by this-letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget, otherwise required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Sincerely, ORIGINAL SIG!50 ev JAMES M. ALLAN
,
g r William T. Russell l
Regional Administrator Enclosures:
1.
Notice of Violation and Proposed Imposition of Civil Penalty 2.
Generic Letter 88-07 cc v/ encl:
W. D. Romberg, Vice. President, Nuclear Operations S. E. Scace, Station Superintendent D. O. Nordquist, Director of Quality Services R. M. ' Kacich, Manager, Generation Facilities Licensing Gerald Garfield, Esquire Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
!
l 0FFICIAL RECORD COPY CP PKG MILL 4/17 - 0004.0.0
,
04/18/89 l
l l
_ _ - _ - - _ _ -
.
.
.
U Northeast Nuclear Energy Company DISTRIBUTION:
_
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
DRP Section Chief Robert J. Bores, DRSS PDR LPDR SECY CA HThompson, DEDS JMTaylor, DEDR JLieberman, OE-WTRussell, RI LChandler, 0GC TMurley, NRR JPartlow, NRR Enforcement Coordinators RI, RII, RIII, RIV, RV Resident Inspector FIngram, GPA/PA BHayes, OI EJordan, AEDO JLuehman, OE DE:Chron OE:EA DCS State of Connecticut rih 8S RI:E0 Mk RI:DRS RI:DRS DRP Holody/pmb/mjh Anderson Durr
/sfz7/,y ane 1/ /89 1/!P/89 1//7/89 1/15/89 1/$89 if W
QE GC RI:RC
,, F
- ian s sel'1 M1 gia Chandler Gutierrez,F*(k I
1/ /89
89
.j/2/ /89
/89
89 C
f _ f, g
Lieberman TayTUT L
Twdse
{L<..i',v)
1/ /89
,lL_BJ p q{ ta
]))l 0FFICIAL RECORD COPY CP PKG MILL 4/17 - 0005.0.0 04/18/89
_ _ _