ML20154S265

Discusses Safety Insp Repts 50-461/87-26 & 50-461/88-10 on 870817-1013 & 880225-0331 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $75,000. Violation Re Use of Inappropriate Design Specs

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: ML20154S265 ML20154S295
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

Text

}. .' 7 , ,

i EE lY

I

JUN 1 1988 1

i

@

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

.

,

NRC requirements. Two of these examples were identified as Potentially i

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.

l 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.

'

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

i

you for a potential generic problem. Your failure to take prompt and effective

i corrective actions is of regulatory concern. We request that your response

describe your actions to preclude similar corrective action failures.

l CERTIFIED MAIL L

RETURN RECEIPT REQUESTED

3806090020 880601

PDR ADOCK 05000461

.

,,

DCD , _ _ _ ,, __ , _, _, __ __ _

_ _ _ _ _ _ ___ __ _ _

. - . . _ _ - ____ - __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.; *,- . ..

.e

Illinois Power Company 2 JW 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 ,

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

i 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

i Notice 84-57, a previous NRC violation (50-461/87026-03(b)) and your own

'

Nonconforming Material Report written on September 16, 1986 and the multiple

l examples found for each violation involving numerous safety-related systems.

The enforcement action being taken in this case is based on the normal enforcement

.

policy of 10 CFR Part 2, Appendix C (1988). Because Clinton Nuclear Station

! was granted an operating license after the November 30, 1985 EQ deadline, the

, enforcement policy for EQ violations for operating reactors, provided in

Generic Letter 88-07, was not censidered applicable.

!

- _ .

-

., *: . .

.-

Illinois Power Company 3 IN

-

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. Notice of Violation

and Proposed Impcsition

! of Civil Penalty

l

2 In;pection Reports

No. 50-461/87026(DRS);

No. 50-461/88010(DRS)

I

cc w/ enclosures:

Licensing Fee Management Branch

l Resident Inspector, RIII

! Roy Wight, Manager

l Nuclear Facility Safety

l 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

'

OE III O- 0

WSafano A vis L ler rman r

0 5/24/88 / V/u/88 M/88 f 988

RIlhh

CAnd(rson

I

Mi ler

RI

J

r

.e

RIIhh

CPapediello

RIII

ABDay s

5/p/88 ,

5/f 88 5 2}/88 5/JE/88

547/88

c-, --. - _ . . ,. - .. . - - - -.

.,

c ,

. . /, *.~.

.

. .

g?'

,

u .

' Illinois Power Company 4 JUN 1 1988'

{b-

Distribution (Cont'd)

,

David Rosenblatt, Governor's ,

'

Office of Consumer Services

SECi  :

CA. -

'

'0GPA

J. - M. Taylor, . 0E0!:0 ' >

J. Lieberman, OE

J. Stafano, OE

L.' Chandler,-OGC

T. Murley, NRR

Project Manager, NRR

RAO:RIII

,

PAO:RIII

SLO:RIII.

M. Stahulak, RIII *

Enforcement Coordinators,

RI, RII, RIV, and RV

-

.

:

,

r

1

l

l

l

'

,

i

a

I

r