ML20153G485

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Noncompliance Noted:Failure to Have Woodard Speed Sensors,Vulkene Wire Not Installed in Valve Actuators & Wire Not Tested for Qualification

ML20153G485
Person / Time
Site:	Brunswick
Issue date:	05/05/1988
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20153G479	List: ML20153G475 ML20153G485
References
EA-87-165, NUDOCS 8805110247
Download: ML20153G485 (4)

Text

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NOTICE OF VIOLATION AND PROPOSED IMPOSITIDT 0F CIVIL PENALTY Carolina Power & Light Company Docket Nos. 50-325, 50-324 Brunswick Steam Electric Plant License Nos. DPR-71, DPR-62 Units 1 and 2 EA 87-165 During the Nuclear Regulatory Commission (NRC) inspection conducted on July 6-10, 1987, violations of NRC requirements were identified. In accordance with the "Modified Enforcement Policy Relating to 10 CFR 50.49, Environmental Qualifica-tion of Electrical Equipment Inportant to Safety for Nuclear Power Plants,"

contained in 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 cet forth below:

10 CFR 50.49(d), (f), and (j), respectively, require, in part, that: (1) a list of electric equipment important to safety be prepared, and informa-tion concerning performance specifications, electrical characteristics and postulated environmental conditions for this equipment be maintained in a qualification file, (2) each item of electric equipment important to safety shall be qualified by testing of, or experience with, identical or similar equipment, and qualifications shall include a supporting analysis to show that the equipment to be qualified is acceptable, and (3) a record of the qualification of the electric equipment shall be maintained in a qualification file in an auditable form to permit verification that the required equipment is qualified and that the equipment meets the specified performance requirements under postulated environmental conditions.

Contrary to the above:

1. From November 30, 1985 to October 18, 1986, for Unit 1, and from June 15, 1986 to October 21, 1986, for Unit 2, the licensee did not have: (1) the Woodward speed sensors for the High Pressure Coolant Injection (HPCI)systemonthelistofelectricequipmentimportant to safety (Master List of qualified equipment), (2) the speed sensors for HPCI turbines tested for qualification, and (3) documentation to verify qualification of the speed sensors in an auditable form.

2. From November 30, 1985 to September 1986, for Unit 2, the licensee did not have: (1) the Vulkene wire installed by the licensee, in valve actuators required to be environmentally qualified, on the Master List of qualified equipment, (2) the wire tested for qualification, and (3) documentation to verify qualification of the wire in an auditable form.

3. From November 30, 1985, to July 1987, for Unit 1, the licensee did not have: (1) the Whitney-Blake wire installed by the licensee, in valve actuators required to be environmentally qualified, on the Master List of qualified equipment, (2) the wire tested for qualification, and l

(3) documentation to verify qualification of the wire in an auditable form.

o h 247 880505 OCK 05000324 DCD

Notice of Violation 4. From November 30, 1985 to November 21, 1986, for Units 1 and 2, the licensee did not have: (1) the control relays for the Standby Gas Treatment (SBGT) skid on the Master List of qualified equipment, (2) the relays tested for qualification, and (3) documentation to verify qualification of the relays in an auditable form.

5. From November 30, 1985 to March 10, 1987, for Unit 1, the licensee did not have: (1) Kulka terminal blocks, for components required to be environmentally qualified, on the Master List of qualified equipment, (2) the terminal block tested for qualification, and (3) documentation to verify qualification of the terminal block.

6. From November 30, 1985 to July 7, 1987, for Unit 2, the licensee did not have: (1) Cinch terminal blocks, for components required to be environmentally qualified, on the Master List of qualified equipment, L (2) the terminal blocks tested for qualification, and (3) documentation to verify qualification of the terminal blocks.

7. From November 30, 1985 to March 11, 1987, for Unit 1, the licensee i did not have: (1) unidentified teflon-type wire (used on the SBGT skid) on the Master List of qualified equipment, (2) the unidentified teflon-type wire tested for qualification, and (3) documentation to verify qualification of the unidentified teflon-type wire.

8. From November 30, 1985 to July 1987, for Units 1 and 2, the licensee did not have: (1) documentation to verify that qualification of the HPCI condensate float switches was not required or (2) the HPCI ,

condensate float switches on the Master List of qualified equipment

• with documentation of qualification in an auditable form.

9. From November 30, 1985 to October 1987, for Units 1 and 2, the licensee did not nave documentation to verify qualification of the fop owing items used in Limitorque Motor Operators: Allen-Bradley nylon terminal '

blocks, GE phenolic terminal block, and electrical butt splices.

, Additionally, various motor operators contained Collier PVC wire

installed by the licensee for which qualification documentation was i not &vailable.

This is an EQ Category B problem.  ;

Civil Penalty - $50,000 (The facility operated in excess of 100 days in violation of EQ requirements.) l Pursuant to the provisions of 10 CFR 2.201, Carolina Power & Light Company 4 (Licensee) is hereby required to submit a written statement or explanation to '

the Director, Office of Enforcement, Nuclear Regulatory Commission, within 30 days of the date of the letter transmitting this 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 violation, (2) the reason for L

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(m Notice of Violation the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps whid W il be taken to avoid further violations, and (5) the date when full complia ne will be achived.

Where good cause is shown, consideration will be given to extending the response time. 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. Uneer the authority of Section 182 of the Act, U.S.C. 2232, thi, response shall be submitted under oath or affirmation.

Within the same time as provided for 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 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 an answer should be clearly marked as an "Answer to a Notice of Violation" and may: (1) deny the violation of this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show r error in this Notice; or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty, such an answer may i request remission or mitigation of the penalty.

In requestinc mitigation of the proposed penalty, the factors addressed in the "Medified Enforcement Policy Relating to 10 CFR 50.49, Environmental Qualifica-tion of Electrical Equipaent Important to Safety for Nuclear Power Plants,"

l 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 by specific reference (e.g., citing page and paragraph +

l 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 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,

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Notice of Violation U.S. Nuclear Regulatory Comnission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region II, U.S. Nuclear Regulatory Commission, and a copy to the NRC Resident Inspector at the Brunswick Steam Electric Plant.

FOR THE NUCLEAR REGULATORY COMMISSION Originsi signed by J. flelson Gnce J. Nelson Grace Regional Administrator Dated at Atlanta, Georgia this s'#rday of May 1988

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