ML20056B372

Forwards Order Imposing Civil Monetary Penalty in Amount of $450,000 Re Violations,Per 870914-18,1102-06 & 16-21 Insps. Violations Include Failure to Demonstrate Splice Qualification & Failure to Maintain Environ Qualification

ML20056B372
Person / Time
Site:	Farley
Issue date:	08/21/1990
From:	Sniezek J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Hairston W ALABAMA POWER CO.
Shared Package
ML20056B373	List: ML20056B372 ML20056B379
References
CIVP-S-003, CIVP-S-3, EA-88-040, EA-88-40, NUDOCS 9008280194
Download: ML20056B372 (2)

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%,,,,,/ AUG 2 1 1990 Docket Nos. 50-348 and 50-364 License Nos. NPF-2 and NPF-8 J EA 88-40 Alabama Power Company ATTN: Mr. W. G. Hairston, III Senior Vice President 40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Gentlemen:

SUBJECT:

ORDER IMPOSING A CIVIL MONETARY PENALTY (FARLEY)

This refers to your letter dated November 14, 1988, in response to the Notice of Violation and Proposed Imposition of Civil Penalty (Notice) sent to you by our letter dated August 15, 1988. Our letter and Notice described one

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Environmental Qualification (EQ) Category A problem regarding the environmental qualification of electrical equipment important to safety. This problem involved failure to identify numerous tape splices in electrical circuits as requiring environmental qualification or failure to demonstrate those splices' qualification, failure to establish qualification for States and General Electric terminal blocks in instrument circuits, failure to establish qualifi-cation for moisture intrusion seals on the reactor head vent solenoid valves and limit switches (both inside and outside containment), failure to maintain environmental qualification of containment sump level transmitters, and multiple qualification deficiencies in valve operators. These violations were extensive, affecting many systems and components, and indicated a programmatic breakdown in your EQ program. To emphasize the need to ensure qualification of electricai equipment important to safety, a civil penalty of Four Hundred Fifty Thousand Dollars ($450,000) was proposed.

The NRC staff has reviewed your response in which you denied all but two of the violations and protested the imposition of a civil penalty. In your response you argued that (1) the " Modified Enforcement Policy Relating to 10 CFR 50.49, Environse.ntal Qualification (EQ) of Electrical Equipment Important to Safety for Nuclear Power Plants" (Modified Policy) is legally deficient; (2) the Notice fails to apply the Modified Policy properly; (3) the NRC staff failed to esta-blish that you clearly should have known about the EQ violations prior to Noventer 30, 1985; (4) the NRC staff incorrectly classified the violatiQns as significant; and (5) the Notice does not appropriately apply the mitigation and escalation factors.

Af ter careful consideration of your response to the Notice of Violation and Proposed Imposition of Civil Penalty, the NRC staff concludes, for the reasons given in Appendix A to the enclosed Order Imposing Civil Monetary Penalty, that 5hh  ?

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Alabama Power Company ~  ;* (1)' the Modified Enforcement Policy is not legally deficient; (2) the NRC' staff applied the Modified Policy properly; (3) the NRC staff established that you clearly should have known about the EQ violations prior to November 30, 1985; (4) the NRC staff. correctly classified the violations as significant; and (5) the NRC staff appropriately applied the mitigation and escalation factors-

, in the Notice. Accordingly, the NRC staff hereby serves the enclosed Order on Alabama Power Company imposing a civil monetary penalty in the amount of Four Hundred Fifty Thousand Dollars ($450,000). -i After careful consideration of your response to Violation II, for which a civil  :

penalty was not proposed, the NRC staff has withdrawn the example related to l CAR 1251. The violation as such will be modified in our records to reflect '

the deletion of.the example dealing with CAR 1251.

In accordance with Section 2.790 of the NRC's " Rule of Practice " Part 2, Title 10, Code of Federal Regulations, a' copy of this letter and the enclosure will be placed in t1e NRC's Public Document Room. i Sincerely, Jm@ 4 James H. Sniezek eputy Executive Director for i (NuclearReactorRegulation, Regional Operations, and-Research

Enclosure:

' Order. Imposing a Civil Monetary Penalty with Appendices i

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