ML17156A859
| ML17156A859 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/19/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156A858 | List: |
| References | |
| EA-88-143, GL-88-07, GL-88-7, NUDOCS 8810060222 | |
| Download: ML17156A859 (4) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Pennsylvania Power and Light Company Susquehanna Units 1 and 2
Docket Nos.
50-387 and 50-388 License Nos.
NPF-14 and NPF-22 EA 88-143 During NRC inspections conducted on September 15-19, 1986 and November 17-21, 1986, of the licensee's program for environmental qualification (EQ) of equip-ment, violations of NRC requirements were identified.
In accordance with the "Modified Enforcement Policy Relating to 10 CFR 50.49, Environmental Qualifi-cation of Electrical Equipment Important to Safety of Nuclear Power Plants,"
contained in Generic Letter 88-07, the Nuclear Regulatory Commission proposes to impose a civi 1 penalty pursuant to Section 234 of the Atomic Energy Act of
- 1954, as amended (Act), 42 U.S.C.
- 2282, and 10 CFR 2.205.
The particular violations and associated civil penalty are set forth below:
I.
VIOLATION ASSESSED A CIVIL PENALTY 10 CFR 50.49 (f), and (j), respectively, require that, in part, (1) each item of electric equipment important to safety shall be qualified by testing of identical or similar equipment with supporting analysis where appropriate to show that the equipment to be qualified is acceptable; and (2) a record of the qualification shall be maintained in an auditable form to permit verification that each item of electrical equipment important to safety is qualified and that the equipment meets the specified performance requirements under postulated environmental conditions.
Contrary to the above, prior to November 30, 1985, the following items were not demonstrated to be environmentally qualified:
1.
The qualification of the three Marathon 300 and 6000 series terminal blocks in limitorque valve operators at each of the two units was not established under certain environmental conditions in that the accident temperature profile was not bounded by the tested temperature profile, nor did analysis of the test data show that these terminal blocks were acceptable.
This condition was identified on June 17, 1986.
2.
The qualification of four Raychem splices in each unit, used in Main Steam Isolation Valve solenoid pigtail leads, had not been established under certain environmental conditions in that no qualification data existed to support qualification of the small heat shrink sleeving as used in the bolted'plices'his condition was identified in August 1986.
This violation constitutes an EQ category C violation.
Civil Penalty
$50,000 (This EQ violation existed in excess of 100 days of plant operation).
OFFICIAL RECORD COPY CP PKG SUSQUEHANNA 9/15 " 0005.0.0 09/15/88 88l0060222 880919 PDR ADOCK 050003'-::7 Q
VIOLATIONS NOT ASSESSED A CIVIL PENALTY A.
10 CFR 50.49(f) requires that qualification of each item of electrical equipment important to safety shall be qualified by testing of identical or similar equipment with supporting analysis where appropriate to show that the equipment to be qualified is acceptable.
Contrary to the above, prior to an NRC inspection on November 17,
- 1986, 1.
the qualification of Valcor high temperature wires was not established.
The qualification was based on questionable test data (unrealistically high insulation resistance measurements during simulated LOCA test).
Subsequently, interim qualification of these wires was established before the end of the inspection using additional data.
2.
the qualification of Target Rock Solenoid valves was not established in that a difference existed between the valves tested and the valves installed, and there was no supporting similarity analysis in the qualification file provided.
An adequate similarity analysis was provided before completion of the inspection.
Because qualification was established before the end of the inspection for both examples above, this is a Severity Level IV violation.
(Supplement I)
B.
10 CFR 50, Appendix B, Criterion V states, in part, that activities affecting quality shall be accomplished in accordance with instruc-tions and procedures.
Procedure DC 151.0 and Memorandum SS-2129k, dated March 20,
- 1986, specify instructions for accomplishing activities affecting quality and require that Replacement Item Equivalency Evaluations (RIEE) be incorporated into applicable EQ binders via a Binder Change Notice (BCN)
Contrary to the above, as of November 17, 1986 the completed RIEE had not been incorporated into the applicable EQ binders, via BCN, to reflect that the installed Rosemount model 1153 transmitters were equivalent to the specified Rosemount 1151 transmitters.
This is a Severity Level V violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Pennsylvania Power and Light Company (Licensee) is hereby required to submit a written statement of explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice.
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for OFFICIAL RECORD COPY CP PKG SUSQUEHANNA 9/15 - 0006.0.0 09/15/88
Notice of Violation each alleged violation:'1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results
- achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance was or will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken, Consideration may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act, 42 U.S.C.
2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, the licensee may pay the civil penalty by letter to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of the civi 1 penalty proposed
- above, or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.
Should the licensee fail to answer within the time specified, an order imposing the civil penalty will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may:
( 1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the mitigation factors in the "Modified Enforcement Policy Relating to 10 CFR 50.49, Environmental Qualifi-cation of Electrical Equipment Important to Safety for Nuclear Power Plants,"
contained in Generic Letter 88-07, should be addressed.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition.
The attention of the licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has been deter-mined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the pen'alty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C.
2282c.
The responses to the Director, Office of Enforcement, noted above (Reply to a
Notice of Violation, letter with payment of civil penalty, and answer to a Notice of Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC
- 20555, a copy to the Regional Administrator, U.
S. Nuclear Regulatory OFFICIAL RECORD COPY CP PKG SUSQUEHANNA 9/15 0007.0.0 09/15/88
Notice of Violation Commission, 475 Allendale Road, King of Prussia, PA, 19406 and a copy to the NRC Resident Inspector, Susquehanna 1 and 2.
FOR THE NUCLEAR REGULATORY COMMISSION OMI")L <],",,i","~.:i Jg~."!Il)5 p pi i,nqi
'William T. Russell Regional Administrator Dated ag King of Prussia, Pennsylvania thisgq~ay of September 1988 OFFICIAL RECORD COPY CP PKG SUSQUEHANNA 9/15 - 0008.0.0 09/15/88