ML20154S265
| ML20154S265 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/01/1988 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Gerstner W ILLINOIS POWER CO. |
| Shared Package | |
| ML20154S270 | List: |
| References | |
| EA-88-090, EA-88-90, GL-88-07, GL-88-7, IEIN-84-57, IEIN-85-039, IEIN-85-39, NUDOCS 8806090020 | |
| Download: ML20154S265 (4) | |
See also: IR 05000461/1987026
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JUN
1 1988
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Docket No. 50-461
License No. NPF-62
EA 88-90
Illinois Power Company
ATTN:
Mr. W. C. Gerstner
Executive Vice President
500 South 27th Street
Decatur, IL 62525
Gentlemen:
SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
(l!RC INSPECTION REPORTS N0. 50-461/87026(DRS) AND NO. 50-461/88010(DRS))
This refers to the special safety inspections conducted during the periods of
August 17 through October 13, 1987 and February 25 through March 31, 1988, of
activities at the Clinton Nuclear Station authorized by NRC License No. NPF-62.
These inspections reviewad implementation of the requirements for assuring
environmental qualification (EQ) of electrical equipment. As a result of
- hese inspections, certain o' your activities appear to be in violation of
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NRC requirements. Two of these examples were identified as Potentially
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Enforceable / Unresolved Items in NRC Inspection Report No. 50-461/87026(DRS)
sent to you by letter dated November 6,1987. A third example was licensee
identified and discussed in NRC Inspection Report No. 50-461/88010(DRS) sent
to you by letter dated April 20, 1988.
An enforcement conference was held in
the Region III office on March 31, 1988 between you and other members of your
staff, and Dr. C. J. Paperiello and other members of the NRC staff during which
the violations, their root causes and your corrective actions were discussed.
The violation described in.the enclosed Notice of Violation and Proposed
Imposition of Civil Penalty (Notice) concerns the failure on the part of the
engineering staff to appropriately translate the design specifications for
electrical equipment important to safety into installation directions and to
ensure that the installed configuration was the same as the tested configuration.
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These failures caused equipment to De installed which differed from the tested
(qualified) configuration.
The unqualified junction boxes, AMP KYNAR butt
splices and Thomas and Betts nylon wire caps had been installed since the
beginning of plant operations and represented significant equipment problems
which could have led to equipment failures during postulated accident conditions
in nume:ous systems important to safety.
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Your ncncanformance report (issued September 16,1986) and NRC violation 50-461/
87026-036(DRS) (issued November 6, 1987) relating to corrosion due to the absence
of drainage openings in one electrical equipment junction box should have alerted
you for a potential generic problem. Your failure to take prompt and effective
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corrective actions is of regulatory concern. We request that your response
describe your actions to preclude similar corrective action failures.
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CERTIFIED MAIL
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RETURN RECEIPT REQUESTED
3806090020 880601
ADOCK 05000461
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Illinois Power Company
2
1 1988
~ During the enforcement conference, you stated that your methodology for
testing butt splices and wire caps was consistent with industry practice.
IE Information Notice No. 85-39, "Auditability of Electrical Equipment
Qualification Records at Licensee's Facilities," states, in part, that an
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EQ test report, in and of itself, does not completely support a determination
that equipment is qualified and that similarity of the tested configuration to
that installed configuration in the plant must be established. Additional
information such as an evaluation of the adequacy of the test conditions may
be needbd.
For example,10 CFR 50.49(k) endorses NUREG-0588, which requires
meeting IEEE Standard 323-1974, "IEEE Standard fo Qualifying Class IE Equipment
for Nuclear Power Generating Stations," that provides that equipment specifications
-and test plans should include, as applicable, the mounting and connection method ~
and configuration. As such, equipment should be mounted, positioned, and connected
in a manner that simulates its expected installation unless an analysis can be
performed and justified to show the equipmert's performance would nut be altered
'by other means of mounting and connection. Analytical data should contain the
specific features, postulated failure modes or the failure effects to be analyzed.
Standard 323-1974 supports our position that the equipment should be tested
under the most adverse conditions it would experience throughout its expected
life.
The installed configuration for the wire caps and butt splices did not
prevent them from being in contact with each other or surrounding grounded
metal.
Therefore, these devices should have been tested in contact with ground
since that is a possible configuration and failure mode.
To emphasize the importance of adequate engineering control of installation
instructions to ensure qualification of electrical equipment important to
safety, I have been authorized, after consultation with the Director, Office
of Enforcement, and the Deputy Executive Director for Regional Operations,
to issue the enclosed Notice of Violation and Proposed Imposition of Civil
Penalty in the amount of Seventy-Five Thousand Dollars ($75,000) for the
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violation described in the enclosed Notice.
In accordance with the "General
Statement of Policy and Procedure fo. NRC Enforcement Actions," 10 CFR, Part 2,
Appendix C (1988) (Enforcement Policy), the violation described in the
enclosed Notice has been categorized at a Severity Level III. The escalation
and mitigation factors in the Enforcement Policy were considered and the base
civil penalty amount has been increased by 50*4.
Your prompt and extensive
corrective action once the problem was identified to you is offset by the prior
notices you have had concerning the junction boxes in the form of IE Information Notice 84-57, a previous NRC violation (50-461/87026-03(b)) and your own
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Nonconforming Material Report written on September 16, 1986 and the multiple
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examples found for each violation involving numerous safety-related systems.
The enforcement action being taken in this case is based on the normal enforcement
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policy of 10 CFR Part 2, Appendix C (1988).
Because Clinton Nuclear Station
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was granted an operating license after the November 30, 1985 EQ deadline, the
enforcement policy for EQ violations for operating reactors, provided in
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Generic Letter 88-07, was not censidered applicable.
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Illinois Power Company
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You are-required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence. After reviewing your response to this
Notice, including your proposed corrective actions and the results of future
inspections, the NRC_will datermine whether.further NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its
enclosures will be placed in the NRC Public Document Room.
The responses directed by this letter and the encl'osed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Sincerely,
Driginal signed by
,B. Bart Davis
A. Bert Davi<
Regional Admir.istrator
Enclosures:
1.
and Proposed Impcsition
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of Civil Penalty
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2
In;pection Reports
No. 50-461/87026(DRS);
No. 50-461/88010(DRS)
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cc w/ enclosures:
Licensing Fee Management Branch
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Resident Inspector, RIII
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Roy Wight, Manager
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Nuclear Facility Safety
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Mark Jason, Assistant
Attorney General,
Environmental D.N.nl fM et sion
Richard Hubbard
J. W. McCaffrey, Chief, Puol k
Utilities Division
H. S. Taylor, Quality Assurance
Division
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' Illinois Power Company
4
JUN
1 1988'
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Distribution (Cont'd)
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David Rosenblatt, Governor's
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Office of Consumer Services
SECi
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J. - M. Taylor, . 0E0!:0
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J. Lieberman, OE
J. Stafano, OE
L.' Chandler,-OGC
T. Murley, NRR
Project Manager, NRR
RAO:RIII
PAO:RIII
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SLO:RIII.
M. Stahulak, RIII
Enforcement Coordinators,
RI, RII, RIV, and RV
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