IR 05000413/1988007

Discusses Insp Repts 50-413/88-07 & 50-414/88-07 on 880201-05 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty

ML20195B711
Person / Time
Site:	Catawba
Issue date:	10/24/1988
From:	Ernst M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Tucker H DUKE POWER CO.
Shared Package
ML20195B713	List: IR 05000413/1988007 ML20195B716
References
EA-88-132, NUDOCS 8811020163
Download: ML20195B711 (5)

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OCT 241988 Docket Nos. 50-413 and 50-414 License Nos. NPF-35 and NPF-52 EA 88-132 Duke Power Company ATTN: Mr. H. B. Tucker, Vice President Nuclear Production Departmr't 422 South Church Street Charlotte, NC 28242 Gentlemen:

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT N05. 50-413/88-07 AND 50-414/88-07)

This refers to the Nuclear Regulatory Commission (NRC) inspection conducted at both the Catawba Nuclear Station, Units 1 and 2, and the Duke Power Company (DPC) Design Offices in Charlotte, NC, during the period February 1-5, 1988. The inspection included a review of the program for the environ-mental qualification (EQ) of electrical equipment under 10 CFR 50.49.

During the inspection, violations of NRC requirements were identified involving the lack of environmental qualification for cert. tin components of electrical equipment in isolated systems in both units. The inspection also included a review of the circumsty:es surrounding your identification of the unqualified wide range Reactor Coolant System (RCS) hot and cold leg resistance temperature detectors (RTD), which were unqualified because they were not installed in accordance with the tested configuration. The report documenting this inspection was sent to you by letter dated May 4, 1988. As a result of this inspection, a significant failure to comply with regulatory requirements was identified, and accordingly, NRC concerns relating to the inspection were discussed in an Enforcement Conference held on July 1, 1988.

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l The letter summarizing this Conference was sent to you on July 25, 1988.

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The violations described in the enclosed Notice of Violation and Proposed

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Imposition of Civil Penalty (Notice) involved the failure to comply with the requirements of 10 CFR 50.49 for both units. Unit 1 is subject to the

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"Modified Enforcement Policy Relating to 10 CFR 50.49. Environmental Quali-fication of Electrical Equipment Important to Safety for Nuclear Power Plants " contained in NRC Generic Letter 88-07. Unit 2, by virtue of its being licensed after the November 30, 1985, deadline for EQ compliance, is suh.iect to the normal Enforcement Policy of 10 CFR Part 2, Appendix C.

The duali g of Enforcement Policy notwithstanding, a single Notice of Violation and Proposed Imposition of Civil Penalty is appropriate in this case because of the similarity of the violations for both units; equitability in applying the Enforcement Policies in this case is achieved by addressing the overall i

l EQ program at the Catawba Nuclear Station; and, in fairness, it is appro-l priate to assess the EQ problem at the facility as a whole.

l 8811020163 881024 PDR ADOCK 05 COO 413 Q

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OCT 2 41988

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Duke Power Company,

The violations described in Section I of the enclosed Notice included the failure to properly install the RCS hot and cold lag wida range RTDs in accordance wfth the tested configuration; failure to adequately evaluate the qualification of non-safety valve operators installed inside Unit 1 contain-ment in the Containment Air Return and Hydrogen-Skimmer System (VX); and fit ally, failure to ensure that valve operators on both units had function-ing T-drains installed similar to the qualified test ccnfiguration.

The unqualified RTD configuration resulted from a breakdown in your design interface controis to properly translate design specifications for EQ equipment into installation instructions for the craft and your failure to perform adequate walkdowns of EQ equipment. The lack of functioning T-drains on some Limitorque valve operators can also be attributed to your failure to perform adequate walkdowns. The violation involving the instal-lation of non-safety valve operators into the Hydrogen Skimer System resulted from an inadequate engineering evaluation which failed to consider all the facets of proof necessary to qualify a component to the requirements of the EQ rule.

The NRC believes that Duke Power Company clearly should have known about the environmental qualification deficiencies identified above for Unit 1, and clearly would have discovered the problems had an adequate level of atten-tion been applied to the environmental qualifica'. ion program requirements which included design interface control and fie',d verification inspections.

The issue regarding the submerged RTD install? cions should have been dis-covered in 1984 when questions were raised by NRR concerning the capability of the RTDs to function while submerged. Not only is the need to install functional T-drains on the inside containment actuators required by the test report for the actuators, but it should be a routine practice to have all actuators fully functional...oreover, DPC was informed in 1984 that valve operators in the VX system did not meet their specifications and were not qualified for installation inside containment.

It is clear that a program

for environmental qualification of electrical equipment should include, as

a fundamental element, a comprehensive as-built field inspection program to verify that equipment was installed in the configuration in which it was tested for qualification.

Such was not the case for the RCS RTDs in Unit I where the RTD wires were not qualified for submergence in the installed configuration and the problem was not discovered during your review of the installation.

Finally, Duke Power Company had available information such as IE Circuler 79-05, several IE Notices such as 79-03 and 83-72, and j

NUREG-0588, "Interim Staff Position on Environmental Qualification of

Safety-Related Electrical Equipment," which addressed the need to environ-mentally qualify such items as moisture intrusion seals, moter operators,

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transmitters, and other safety-related electrical equipment for harsh i

environments.

It is evident that Duke Power Company has taken an overall aggressive

approach to EQ and that considerable corporate-wide effort has been applied i

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00T 2 41988 Duke Power Company,

to the program; however, there were specific program partions which were deficient as evidenced by these violations. The oromnt corrective action which addressed the specific problems was quickly applied to other DPC

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stations and this is indicative of active management involvement.

To emphasize the importance of environmental cualification of electrical equipment at the Catawba Nuclear Station, Units 1 and 2, and that regulatory deadlines are met I have been authorized, after consultation with the Deputy Executive Director for Regional Operations, and the Director, Office of Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dollars ($50,000) for the violations described in Section I of the enclosed Notice.

In accordance vIth the "Modifhd Enforcement Policy Relatin 50.49," contained in NRC Generi. Letter 38-07 (Enclosure 2)g to 10 CFR

, the violations described in Section I of the c

'osed Motice have been determined to be an isolated problem, having af s ed a limited number of systems and components, and therefore is considered to be an EQ Category C problem.

The base amount of a c'vil penalty for an EQ category C problem 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) corrective actions to result in full compliance ( 50%); and (4) duration of violation which is significantly below 100 days (-50%).

The escalation and mitigation factors were considered as follows:

No escalation or mitigation was applied for identification and prompt reporting after considering botn the fact that the licensee and the NRC each iden-tified one of the two violations for which proper corrective actions were taken, and the fact that although the licensee identified the third violation, it was not properly corrected.

Fifty percent mitigation was applied for best effsets to complete EQ within the deadline. Duke Power Company has been sensitive to EQ requirements and generally maintained a high degree of attention to the EQ program.

Twenty-five percent mitigation was applied for corrective actions to result in full compliance.

Specifi-cally, Duke Power Company initiated shutdown to undertake immediate correc-tive action on the RCS RTDs.

Further, the corrective actions included extensive training enhancements which were incorporated into the station EQ program which should help to preclude similar problems in the future.

However, these efforts were partially offset by the fact that two Limitorque motor operated valves without functioning T-drains were installed in the Unit 1 VX system, after the deadline, to correct Violation I.B.

With respect to the fourth factor in the Modified Enforcement Policy, mitigation is inappropriate since these EQ violations, with the exception of Violation I.B. existed in excess of 100 days for Unit 1.

The application of the mitigation factors reduced the civil penalty to the minimum $50,000 as provided by Generic Letter 88-07 for significant EQ failure l..

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Duke Power Company,

00T 2 4 588 The first violation described in Section II of the enclosed Notice involved hydrogen skimmer fan motors in Unit 2, which were not installed ir, accord-ance with the tested configuration, in that the breather drains were not installed. This violation was categorized as a Severity. Level IV in accord-ance with 10 CFR Part 2, Appendix C.

The second violation involved an-inadequate EQ file for the Unit 1 Hydrogen Recombiner tape splices which was categorized as a Severity Level V violation because prior to the end of the inspection the equipment was shown to, in fact, be qualifiable.

l You are required to respond to this letter and should follow the instruc-tions 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 NP.C 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 enclosures will be placed in the NRC Public Document Room.

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l The responses directed by this letter and its enclosures are not subject to l

the clearance procedures of the Office of Management and Budget as required l

by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.

Should you have any questions concerning this letter, please contact us.

Sincerely, ORIGINAL SIGNED fly M. L ERNST Malcolm L. Ernst Acting Regional Administrator Enclosures:

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Notice of Violation and Proposed Imposition of Civil Penalty 2.

Generic Letter 88-07 cc w/encis:

T. B. Owen, Station Manager State of South Carolina

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Duke Power Company.

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