ML18094A362
| ML18094A362 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 04/21/1989 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18094A361 | List: |
| References | |
| 50-272-86-23, 50-311-86-23, EA-88-238, NUDOCS 8904280230 | |
| Download: ML18094A362 (3) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Public Service Electric and Gas Company Salem Units 1 and 2 Docket No. 50-272; 50-311 License Nos. DPR-70; DPR-75 EA 88-238 During an NRC inspection conducted on August 11-15, 1986, of the licensee's program for environmental qualification (EQ) of equipment, violations of NRC requirements were identified.
In accordance with the 11Modified Enforcement Policy Relating to 10 CFR 50.49, Environmental Qualification of Electrical Equipment Important to Safety of Nuclear Power Plants, 11 attached to Generic Letter 88-07, 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 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 (1) each item of e*lectric equipment important to safety shall be qualified by testing identical or similar equipment under environmental conditions identical or ~imilar to those postulated for an accident, and the qualification based on similarity shall include a supporting analysis to show that the equipment to be qualified is acceptable; and (2) a record of the qualifi-cation shall be maintained in ~n auditable form to permit verification that each item of electrical equipment important to safety is qualified and that the equipment meets the specified performance req~irements under postulated environment"al conditfo"ris.
Contrary to the above, from November 30, 1985 until April 8, 1986, eight solenoid operated valves in the Unit 1 Post Accident Samplying System components important to safety, were not qualified in that the valves did not have the required Conax connectors installed and qualification of the valves without the Conax connectors was not demonstrated.
This violation constitutes an EQ Category C violation.
Civil Penalty - $50,000 (This EQ violation existed in excess of 100 days of plant operation.)
II.
VIOLATION NOT ASSESSED A CIVIL PENALTY 10 CFR 50.49 (f), and (j), respectively, require, that (1) each item of electric equipment important to safety shall be qualified by testing and/or analysis of identical or similar equipment under environmental conditions identical or similar to those postulated for an accident, and the qualification based on similarity shall include a supporting analysis 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 r.eets the specified performance requirements under postulated enviror.~ental conditions.
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OFFICIAL RECORD COPY CP PKG SALEM 88-238 - 0005.0.0 890421 05000272 F'DC
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04/18/89
- Notice of Violation Contrary to the above, at various amounts of time beginning November 30, 1985, components important to safety ~ere not qualified including the following examples:
- 1.
As of May 3, 1986, the qualification of terminal blocks used to terminate eight auxiliary feedwater transmitters was not demonstrated in that the qualified configuration of the associated junction boxes specified Raychem splices.
- 2.
As of April 8, 1986, nineteen (eleven in Unit 1 and eight in Unit 2)
Limitorque motor operated valves inside containment, affecting, among others, the safety injection system, residual heat removal system and Reactor Coolant System, did not have T-Drains installed in the operator housings to prevent moisture accumulation in a harsh environment and qualification of the valve operators without the T-Drains was not demonstrated;
- 3.
As of April 8, 1986, sixteen junction boxes (seven in Unit 1 and 9 in Unit 2) affecting, among others, the Main Steam System and the Main Steam Isolation Valve indication limit switches for both units, did not have properly sealed conduit connectors and qualification of the junction boxes without properly sealed conduit connectors was not demonstrated; and
- 4.
As of August 15, 1986 various Limitorque motor operated valves inside containment did not have gear Ease grease relief valves and qualifi-cation of the valve operators without grease reliefs was not demonstrated.
This is a Severity Level IV vioTafion.
(Supplement -I)
Pursuant to the provisions of 10 CFR 2.201, Public Service Electric and Gas 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 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 OFFICIAL RECORD COPY
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CP PKG SALEM 88-238 - 0006.0.0 04/18/89
II
- Notice of Violation 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 11Answer to a Notice of Violation 11 and may:
(1) deny the violations listed in this Notice in wh6le 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 11Modified Enforcement Policy Relating to 10 CFR 50.49, Environmental Qualifi-cation of Electrical Equipment Important to Safety for Nuclear Power Plants, 11 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 faiiure 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 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 responses to the Direct.or, -Office **af 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 Commission, 475 Allendale Road, King of Prussia, PA, 19406 and a copy to the NRC Resident Inspector, Salem 1 and 2.
FOR THE NUCLEAR REGULATORY COMMISSION
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Regional Administrator Dated at King of Prussia, Pennsylvania this-/.
1 jday of April 1989.
OFFICIAL RECORD COPY CP PKG SALEM 88-238 - 0007.0.0 04/18/89