IR 05000387/1990017
| ML17157A440 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/27/1990 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
| Shared Package | |
| ML17157A441 | List: |
| References | |
| EA-90-156, NUDOCS 9012030081 | |
| Download: ML17157A440 (6) | |
Text
November 27, 1990 Docket Nos.
50-387; 50-388 License Nos.
NPF-14; NPF-22 EA 90-156 Pennsylvania Power and Light Company ATTN:
Mr. Harold W. Keiser Senior Vice President - Nuclear 2 North Ninth Street Al 1 entown, Pennsyl vani a 18101 Gentlemen:
Subject:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
$25,000 (NRC Special Inspection Report Nos. 50-387/90-17; and 50-388/90-17)
This letter refers to the NRC safety inspection conducted on August 13-September 7,
1990, at the Susquehanna Steam Electric Station, which was forwarded to you on September 14, 1990.
The inspection was conducted following a management meeting held with members of your staff in the Region I office on August 10, 1990, to discuss the circumstances associated with (as well as the technical significance of) certain environmental qualification deficiencies identified by your staff.
During the NRC inspection, violations of NRC requirements were identified.
On October 4, 1990, an enforcement conference was conducted with Mr.
R.
G.
Byram and other members of your staff to discuss the violations, their causes, and your corrective actions.
The violations are described in the enclosed Notice.
One of the violations (set forth in Section I of the Notice) involved the failure to perform an adequate evaluation and promptly correct conditions adverse to quality associated with the environmental qualification (E(}) of 52
, Limitorque valve actuators.
The specific concerns, which were identified by your staff and documented in two Nonconformance Reports (NCR) issued in March and July 1988, respectively, involved the lack of adequate qualification testing for the actuators.
Your initial evaluations of those concerns did not result in corrective actions on a schedule commensurate with the importance of these discrepancies.
At the enforcement conference, your staff informed the NRC that the actuators were qualifiable and a qualification analysis would be available to the NRC Region I Office by November 15, 1990.
On November 15, you informed Region I that you completed the analysis and the 'items were found to be qualified.
Nonetheless, given the number of actuators affected and the uncertainty that existed concerning their qualification, the NRC is concerned with the length of time that had passed without resolution of these issues.
The NRC recognizes that Pennsylvania Power and Light Company has developed an aggressive and comprehensive plan to implement the changes necessary for resolving deficiencies in a timely manner.
These actions, delineated in PP8L Nuclear Department Policy Letter No.90-003, dated August 13, 1990, communi-cates standards of performance for identification, control and closure of OFFICIAL RECORD COPY yoi20;.00.= l. <rOi127 PEER AK)OCV 0: cjgo;:.p7 I?
F'DC SUSQUEHANNA OPTION
0001.0.0 11/26/90
Pennsylvania Power 5 Light Company
deficiencies.
Nonetheless, this violation represents a significant regulatory concern because it resulted in operation of the facility with a large number of safety-related motor operated valves of indeterminate'quality for an extended period of time.
Therefore, this violation has been categorized as a Severity Level III violation in accordance with the "General Statement of Policy and
'rocedure for NRC Enforcement Actions,"
CFR Part 2, Appendix C, (1990)
~
Accordingly, to emphasize the importance of implementing adequate management and programmatic controls to ensure that identified discrepancies are appro-priately evaluated and corrected, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor, Regulation, Regional Operations, and Research to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty, in the amount of $25,000.
The base civil penalty for a Severity Level III violation is $50,000.
The escalation and mitigation factors in the Enforcement Policy were considered as described below.
The civil penalty was escalated by 50% for NRC identification.
Even though you initiated two NCRs in 1988 that identified the lack of qualification testing, the NRC identified your failure to adequately evaluate those components and take timely corrective action.
A 50% mitigation of the base civil penalty is warranted for your corrective actions subsequent to the NRC inspection.
In addition, the overall past performance at Susquehanna has been good, as evidenced by Category 1 ratings in most areas during the last several Systematic Assessments of Licensee Performance (SALP),
and a recognition in the last SALP that you had an effective method of dealing with plant problems and other operational occurrences.
Therefore, 50% mitigation of the base civil penalty on this factor is warranted.
Full 100% mitigation on this factor is not warranted since a $50,000 civil penalty was issued to you on September 19, 1988 for violations of EQ requirements at Susquehanna that were identified in 1986.
The other escalation and mitigation factors were considered, and no adjustment is warranted.
Two other violations of NRC requirements (involving requirements for qualifi-cation of certain polyurethane seals)
are set forth in Section II of the enclosed Notice.
The NRC recognizes that the safety significance of the violations was low since the seals were unqualified for a short period and because failure of the component during an accident could have been mitigated by prudent operator/accident management actions.
Therefore, these violations have been classified at Severity Level IV in accordance with 10 CFR Part 2, Appendix C.
Nonetheless, the NRC emphasizes that any similar violations of this nature in the future may result in more significant enforcement action.
You are required to respond to this letter and the enclosed Notice, and should follow the instructions 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 take to prevent recurrence.
After reviewing your response to this Notice, including your proposed corrective actions and OFFICIAL RECORD COPY SUSQUEHANNA OPTION 2 " 0002.0.0 11/26/90
Pennsylvania Power 5 Light Company
the results of future inspections, the NRC will determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In addition to your response to the violations, you should also provide this office,'y November 30, 1990, your analysis to verify the environmental qualification of the Limitorque actuators described in Section I-of the enclosed Notice.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of this letter and its enclosure will be placed in the NRC's Public Document Room.
The responses directed by this letter and the enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub.
L.96-511.
Sincerely, Thomas T. Martin Regional Administrator Enclosure:
Notice of Violation cc w/encl:
R.
G. Byram, Vice President, Nuclear Operations A.
R. Sabol, Manager, Nuclear Quality Assurance
.
J.
M. Kenny, Licensing Group Supervisor H.
G. Stanley, Superintendent of Plant-SSES S.
B. Ungerer, Manager, Joint Generation Projects Department J.
D. Decker, Nuclear Services Manager, General Electric Co.
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 SUSQUEHANNA OPTION 2 " 0005.0.0 11/26/90
Pennsylvania Power 5 Light Company
bcc w/encl:
PDR LPDR SECY CA J.
Sniezek, DEDO J.
Lieberman, OE
" T ~ Martin, RI D.
Hol ody, RI J. Goldberg, OGC T. Murley, NRR J. Partlow, NRR Enforcement Coordinators RI, RII, RIII, RIV, RV Resident Inspector F.
Ingram, GOA/PA B. Hayes, OI D. Williams, OIG E. Jordan, AEOD W. Troskoski, OE P. Swetland, RI OE:Chron OE:EA DCS RI:DRS Anderson 11/
/90 RI:DRA Kane
.
11/
/90 RI: DRS Dur r 11/
/90 RI: DRS Hodges 11/>~//90 ehl 11/+090 RI: RC ll/ /90 Troskoski 11/
/90 RI T artin 11/~/90 OE:D
'EDO JLieberman JSniezek 11/
/90 11/
/90 pP on ii ~j SUSQUEHANNA OPTION 2 0006.0.0 11/23/90