IR 05000387/1986021
| ML17156A857 | |
| Person / Time | |
|---|---|
| Site: | Farley, Susquehanna  |
| Issue date: | 09/19/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
| Shared Package | |
| ML17156A858 | List: |
| References | |
| CIVP-A-089, CIVP-A-89, EA-88-143, GL-88-07, GL-88-7, IEIN-83-73, NUDOCS 8810060219 | |
| Download: ML17156A857 (6) | |
Text
p,g gp~~TED 3)151'RIBUTJON DEMONSTRAT10N SYFI'ZM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
~ CESSION NBR:8810060219 DOC.DATE: 88/09/19 NOTARIZED: NO FACIL:50-387 Suscpxehanna Steam Electric Station, Unit 1, Pennsylva 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva AUTH.NAME AUTHOR AFFILIATION RUSSELL,W.T.
Region 1, Ofc of the Director RECIP.NAME RECIPIENT AFFILIATION KEISER,H.W.
Pennsylvania Power
& Light Co.
DOCKET 05000387 05000388 R
RECIPIENT ID CODE/NAME PD1-2 LA THADANI,M COPIES LTTR ENCL
1
1 RECIPIENT ID CODE/NAME PD1-2'D COPIES LTTR ENCL
1 SUBJECT: Discusses insp on 860915-19
& 1117-21
& forwards notice of violation
& proposed imposition of civil penalty.
DISTRIBUTION CODE: IE14D COPIES RECEIVED LTR ENCL SIZE:
TITLE: Enforcement Action Non-2.790-Licensee Response NOTES:LPDR 2 cys Transcripts.
LPDR 2 cys Transcripts.
05000387 /
05000388 h
D D
INTERNAL: AEOD/DOA DEDRO NRR/DREP/EPB
NUDOCS-ABSTRACT OE LIEBERMAN,J RGN1 FILE
1
~
1
1
1
1
1 AEOD/DSP/TPAB NRR/DOEA/EAB 11 NRR/PMAS/ILRB12
LE
REG FAILS
DRSS/EPRPB
1
1
1
1
1
1 EXTERNAL: LPDR NSIC NOTES
2
1
2 NRC PDR
1 J
S TOTAL NUMBER OF COPIES REQUIRED:
LTTR
ENCL
September 19, 1988 Docket Nos.
50-387 and 50-388 License Nos.
NPF-14 and NPF-22 EA 88-143 Pennsylvania Power
& Light Company ATTN:
Mr. Harold W. Keiser Senior Vice President Nuclear 2 North Ninth Street Al 1 entown, Pennsylvania 18101 Gentlemen:
Subject:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC Combined Inspection Reports Nos. 50-387/86-21; 50-388/86-22 and 50-387/86-25; 50-388/86-28)
This refers to the NRC inspections conducted on September 15-19, 1986 and November 17-21, 1986 to review the program for the environmental qualification (EQ) of equipment at Susquehanna, Units 1 and 2.
The inspection reports were sent to you on October 31, 1986 and February 10, 1987, respectively.
During the inspections, violations of NRC requirements which were identified by you, involving the lack of environmental qualification of certain items of electric equipment used in both units, were also reviewed.
On June 30, 1988, an enforce-ment 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.
One of the violations, which is described in Section I of the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice), included the failure to maintain, for certain items of electric equipment, sufficient records 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 Marathon terminal blocks in three motor operated valves at each unit, and Raychem heat shrink tubing splices in four Main Steam Isolation Valves at each unit.
These terminal blocks and splices were used in areas to ensure certain containment functions would operate as intended during postulated accident environmental conditions.
These deficiencies clearly should have been known to you prior to November 30, 1985, which was the deadline for being in compliance with the EQ requirements.
With respect to the Marathon terminal blocks, you clearly should have known of the deficiencies because prior to November 30, 1985, the NRC issued Information Notices (IN) such as IN No. 83-73 which identified potential problems with the use of underrated terminal blocks in Limitorque operators.
Further, a reasonable engineering review clearly would have also identified that the Marathon terminal blocks were not qualified for their required service because the accident profile was not bounded by the tested temperature profile.
QG 8810060219 830919 PDR ADOCK 05000387
PDC OFFICIAL RECORD COPY I
L CP PKG SUSQUEHANNA 9/15 0001.0.
09/15/88
e Pennsylvania Power
& Light Company
"2-With respect to the Raychem splices, you clearly should have known of the deficiencies because you had information from the vendor.
Specifically, you had instructions from Raychem that specified the qualified use range for the heat shrink diameter that was employed and you clearly should have reviewed the design and installation of the splices which would have identified that the heat shrink diameter exceeded the qualified use range.
The violations described in this Notice demonstrate that sufficient attention was not provided to the EQ program at Susquehanna, as evidenced by inadequate engineering review, inadequate consideration of vendor installation informa-tion, and inadequate Quality Control of these activities.
Further, after you identified the deficiencies in the Marathon terminal blocks, Models 300 and 6000 in June, 1986, adequate corrective actions were not then taken in that this series of the terminal blocks was replaced with the Series 1600 Marathon terminal blocks which were also unqualified.
These terminal blocks were subsequently replaced on September 30, 1986 and October 15, 1986 for Units
and 2, respectively.
Accordingly, I have been authorized, after consultation with the Director of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Enclosure 1) in the amount of Fifty Thousand Dollars ($50,000) for the violation described in the enclosed Notice.
In accordance with the
"Modified Enforcement Policy Relating to
CFR 50.49," contained in Generic Letter 88-07 (Enclosure 2), the violation described in the enclosed Notice has been determined 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 penalty for an EQ Category C violation is $75,000.
In determining the civil penalty amount, the NRC considered the four factors set forth in the "Modified Enforcement Policy Relating to 10 CFR 50.49", 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) cor rective 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 because both issues were identified by your staff and properly evaluated against applicable reporting requirements.
With respect to the second factor, 25% mitigation is appropriate because your efforts to enlist the support of several different external groups with equipment qualification expertise (to assist in setting up your equipment qualification program, and to audit and upgrade your program in a timely manner), reflect best efforts to complete the equipment qualification program within the deadline.
However, during the NRC inspections it was apparent that a substantial amount of the work to upgrade the plant EQ files had been performed after the November 30, 1985 deadline and therefore full mitigation for this factor is not appropriate.
With respect to the third factor, 25% escalation is appropriate because adequate corrective actions were not taken for the terminal block deficiency when it was initially identified in June 1986.
As described above, when you discovered the unqualified terminal blocks you replaced them with other terminal blocks that were later also determined to be unqualified.
OFFICIAL RECORD COPY CP PKG SUSQUEHANNA 9/15 " 0002.0.0 09/15/88
Pennsylvania Power
& Light Company-3-With respect to the fourth factor, mitigation is inappropriate since these Eg violations existed in excess of 100 days.
Therefore, on balance, 50% reduction to the base civil penalty amount is appropriate.
However, in accordance with Section IV.B of the enclosure to Generic Letter 88-07, the minimum $50,000 civil penalty is being assessed.
Although the policy permits full mitigation under certain conditions, full mitigation is inappropriate in this case again because your corrective actions for the initial deficiency with the Marathon terminal blocks was inadequate'ou 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.
. 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.
Enclosures:
~
Notice of Violation and Proposed Imposition of Civil Penalty 2.
Sincerely, QRiGINi'(L MONER 8~
If@/jES M. PiLl Ql~
William T. Russell Regional Administrator cc w/encls:
A.
R. Sabol, Manager, Nuclear guality Assurance E. A. Heckman, Licensing Group Supervisor R.
G.
Bryam, Superintendent of Plant-SSES H.
W. Hirst, Manager, Joint Generation Projects Department R. J.
Benich, Services Project Manager, General Electric Company B. A. Snapp, Esquire, Assistant Corporate Counsel H.
D. Woodeshick, Special Office of the President J.
C. Tilton, III, Allegheny Electric Cooperative, Inc.
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Pennsylvania OFFICIAL RECORD COPY CP PKG SUSQUEHANNA 9/15 0003.0.0 09/15/88
Pennsylvania Power
& Light Company bcc w/encl:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
DRP Section Chief Robert J.
Bores, DRSS SECY J. Taylor, DEDO J.
Lieberman, OE W. Russell, RI T. Murley, NRR
, D. Holody, RI J. Wiggins, RI L. Chandler, OGC T. Martin, DEDRO Enforcement Officers, RII-III Enforcement Officers, RIV-RV F.
Ingram, PA J.
Bradburne, CA E. Jordon, AEOD B. Hayes, OI S. Connelly, OIA D. Nussbaumer, SLITP
.J.
Luehman, OE OE FILES (3 copies
+ ltr hd)
EDO Rdg File DCS RI: EO Holody/sh/tlm Q/ 8,'f88 ez~
c.g RI: MRS Anderson
/6/>>/88 RI: DRA e~~
Al 1 an 6/
/88 RI:DRS Durr
if/4'7/88 RI:RA Russell 8/
/88 RI:
Johnston 6/ZS'/88 E
Miral gi a
/88 f/l /88 OGC Chandler 6/
/88
- OE Lieberman 6/
/SS DEDRO Tayl or 6/
/8 OFFICIAL RECORD COP CP PKG SUSQUEHANN
/15 - 0004.0.0 09/15/88 w~~~
< i~j<<
8E ~- <//I'