ML17157A442
| ML17157A442 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/27/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17157A441 | List: |
| References | |
| EA-90-156, NUDOCS 9012030084 | |
| Download: ML17157A442 (6) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Pennsylvania Power and Light Susquehanna Steam Electric Station Units 1 and 2
Docket Nos.
50-387; 50-388 License Nos.
NPF-14; NPF-22 EA 90"156 During an NRC inspection conducted on August 13 - September 7,
1990, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, Enforcement Policy,
( 1990) the Nuclear Regulatory Commission proposes to impose a civil 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 parti-cular violations-and associated civil penalty are set forth below:
I.
VIOLATION ASSESSED A CIVIL PENALTY 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures be established to assure that conditions adverse to
- quality, such as nonconformances, are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and that corrective action is taken to preclude repetition.
The corrective action taken shall be documented and reported to appropriate levels of manage-ment.
10 CFR 50.49(f) requires, in part, that each item of electrical equipment important to safety must be qualified by appropriate testing,
- analysis, or a combination thereof.
Contrary to the above, the licensee identified, in 1988, conditions adverse to quality associated with the environmental qualification (EQ) of equipment (as described in a.
and b. below), but failed to take effective corrective action, as of August 31, 1990.
The Licensee's Nonconformance Report No.
(NCR) 88-0181, dated March 24, 1988 identified 21 motor actuators at Units 1 and 2
equipped with 250 Vdc Reliance motors which were not subjected to adequate Limitorque qualification testing.
The licensee's evaluation of this nonconformance was inadequate in that it identified a similarity analysis which compared Reliance 125 Vdc with Reliance 480 Vac motors, but did not show the applicability of the similarity analysis to the 250 Vdc motors.
b.
The Licensee's NCR No. 88-0520, dated July ll, 1988, identified 31 motor actuators at Units 1 and 2 operated with 250 Vdc control power which is twice as much as the 125 Vdc control power used in the Limitorque qualification testing for these motors.
The evaluation of this nonconformance was inadequate in that it partially relied on a
OFFICIAL RECORD COPY SUSQUEHANNA OPTION 2
0007.0.0 11/27/90
Notice of Violati on test report that included no pre-accident aging or radiation 'consi-derations, it failed to consider expected moisture intrusion and it failed to account for low resistance readings recorded for the torque
- switches, even at 120 Vdc.
This is a Severity Level III violation (Supplement I).
Civil Penalty - $25,000.
II.
VIOLATIONS NOT ASSESSED A CIVIL PENALTY A.
10 CFR 50.49(a) requires each holder of a license to operate a
nuclear power plant to establish a program for qualifying electric equipment identified in 10 CFR 50.49(b).
10 CFR 50.49(b) defines electric equipment important to safety and includes:
(1) safety-related electric equipment, i.e.,
equipment relied upon to remain functional during and following design basis events; and (2) nonsafety-related electric equipment whose fai lure under postulated environmental conditions could prevent satisfactory accomplishment of the functions of safety-related equipment.
10 CFR 50.49(f) requires that each item of electric equipment impor-tant to safety be qualified by testing and/or analysis under postu-lated environmental conditions.
Contrary to the above, as of July 19, 1990 for Division 1, and July 21, 1990 for Division 2, certain items of electric equipment impor-tant to safety,
- namely, the polyurethane damper actuator seals for the ITT NH90 dampers for the Standby Gas Treatment System (SGTS) and the direct expansion (Dx) switchgear room cooling system, were not environmentally qualified.
The seals were not environmentally qualified because they had been in service for a period of time exceeding that for which the seals were originally qualified.
This is a Severity Level IV violation. 'Supplement I)
B.
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions or procedures and shall be accomplished in accordance with these instructions or procedures.
Licensee Procedure OPS-5, entitled "Deficiency Control System,"
.Revision 4, dated May 18,
- 1988, Section
- 5. 1 states, in part, that the licensee's deficiency control system is designed to promptly report and correct conditions identified as adverse to quality.
OFFICIAL RECORD COPY SUSQUEHANNA OPTION 2 0008.0. 0 11/26/90
Licensee Procedure OPS-12, entitled "Administrative Control of Plant Operation,"
Revision 3, dated May 18, 1988, Section 5.5.8, states, in part, that in cases where required documentary evidence is not available, then the associated equipment and material must be considered non-conforming in accordance with OPS-5, Deficiency Control System.
Licensee Procedure EPM-QA-122, Rev. 0, dated December 29,
- 1989,
, Section
- 3. 1. 1 defines an engineering deficiency to include conditions adverse to quality, or nonconformances whose impact on plant equip-ment and hardware, is not known and requires further analysis.
- Further, Section 5.2. 1 of this procedure requires that each engineer-ing discrepancy shall be documented on an Engineering Discrepancy Report.
Contrary to the above,
- when, on June 29, 1990, the licensee was informed of environmental qualification discrepancies related to polyurethane damper actuator seals for the ITT NH90 dampers referenced in Violation II.A, an engineering discrepancy report was not completed to assure resolution of this discrepancy until August 1, 1990.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Pennsylvania Power 6 Light Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalty (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (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 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'he 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 addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil 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 OFFICIAL RECORD COPY SUSQUEHANNA OPTION 2 - 0009.0.0 11/26/90
J E
1 r
Notice of Vio l at ion Notice of Violation" and may:
( 1) deny 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, in whole or in part, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty,.the factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1990) should be addressed.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statements 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 determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C.
2282c.
The response noted above (Reply to 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, D.C.
20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region I, and a copy to the NRC Resident Inspector at the facility which is the subject to this Notice.
FOR THE NUCLEAR REGULATORY COMMISSION Thomas T. Martin Regional Administrator Dated at King of Prussia, Pennsylvania this day of November 1990 OFFICIAL RECORD COPY SUSQUEHANNA OPTION 2 - 0010.0.0 11/26/90