ML20195H430

Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $75,000

ML20195H430
Person / Time
Site:	Braidwood
Issue date:	11/23/1988
From:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Oconnor J COMMONWEALTH EDISON CO.
Shared Package
ML20195H433	List: ML20195H430 ML20195H439
References
EA-88-198, GL-88-07, GL-88-7, NUDOCS 8811300400
Download: ML20195H430 (4)

Text

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NOV 231983 Docket Nos. 50-456 and 50-457 Licenses Nos. NPF-72 and NPF-77 EA 88-198 Comonwealth Edison Company ATTN: Mr. James J. O'Connor President Post Office Box 767 Chicago, Illinois 6Cf90 Gentlemen:

SUBJECT:

NOTICE OF VIOLATION AND PROPOS$j IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORTS NO.50-456S M05(DRS) AND NO. 50-457/88006(DRS))

This refers to an NRC inspection conducted during the period February 29 through May 4, 1988 of activities authorized by NRC Operating Licenses Nos.

NPF-72 and No. NPF-77 at the Braidwoed Station, Units 1 and 2. The inspection focused on the implementation of requirements for assuring environmental qualification (EQ) of electrical equipment and identified violations of NRC regulatory requirements. The details are presented in the subject inspection report which was sent to you by letter dated May 27, 1988. An enforcement conference was held in the NRC Region III office between Messrs. T. J. Maiman, A. B. Davis, and others of our respective staffs on August 17, 1988, during which the violations, their root causes, and your corrective actions were discussed. Additionally, the NRC staff has reviewed and considered the information contained in the various submittals, concerning EQ at the Braidwood Station, that have been made by Commonwealth Edison Company since the enforcement conference.

The violations described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) resulted from the failure of Braidwood Station engineering and maintenance personnel to ensure that electrical equip-ment important to safety was: (1) qualified for its intended service by

testing and/or analysis, (2) installed in the configuration qualified by test and/or analysis, and (3) maintained to preserve its qualification. It appears that the root cause of these violations was the failure to implement adequate management and programmatic controls that would: (1) assure that equipment was properly qualified, (2) verify that equipment was properly installed in the field, and (3) assure coordination between your maintenance and engineering staffs so that maintenance would be performed on equipment in a manner that would preserve its qualification. The programmatic nature of these violations and the failure of management control systems are cause for significant concern.

As a result, two of the violations involving multiple examples have been categorized in the aggregate as a Severity Level III problem.

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Commonwealth Edison Company 2 NOV 2 31988 F

I In addition, two Severity Level IV violations are contained in the enclosed '

Notice. The first of these two violations relates directly to the plant EQ program but is not included as a part of the above problem. Based on the information that was available to you concerning the qualification of Bunker Ramo electrical penetrations, the NRC staff has concluded that the fsilure to recognize the qualification deficiencies associated with the electrical penetration is not significant enough to warrant inclusion in the escalated action. The second of these violations does not relate directly to your EQ program. Rather, it involved the improper installation of compon9nts that may have affected their ability to perform under various ciremtonces.

To emphasize the importance of implementing adequate management and  !

programmatic controls to ensure the initial and continuing qualification of 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 violations described in Section I of the enclosed Notice.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988) (Enforcement Policy),

the violations described in Section I in the enclosed Notice have been categorized in the aggregate as a Severity Level III problem. The base value of a civil penalty for a Severity Level III problem is $50,000. The .

escalation and mitigation factors in the Enforcement Policy were considered l l and the base civil penalty has been increased by 50 percent because the corrective actions to prevent recurrence were not timely. Specifically, for the identified violations, the NRC prompted the licensee into taking the necessary corrective actions.

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

Policy set forth in 10 CFR Part 2, Appendix C (1988). Because Braidwood, Units 1 and 2 were granted operating licenses after the November 30, 1985 EQ deadline, the Modified Enforcement Policy Relating to 10 CFR 50.49,

, "Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants" (Generic Letter 88-07) was not applicable.

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, the NRC will determine whether further NRC enforcement action is necessary to ensure

compliance with NRC regulatory requirements.

l 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 enclosure will be placed in the NRC Public Document Room.

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Commonwealth Edison Company 3 MV 2 31988 The responses directed by this letter and the accompan.yIng Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely.

Original signed by

1. Bert Davia A. Bert Davis Regional Administrator

Enclosures:

1. Notice of Violation and Proposed Imposition of Civil Penalty

2. Inspection Reports No. 50-456/88005(DRS);

No. 50-457/88006(DRS) cc w/ enclosures:

C. Reed, Senior Vice President T. J. Maiman, Vice President, PWR Operations H. Bliss, Nuclear Licensing Manager S. Hunsader, Nuclear Licensing Administrator M. Lohmann, Project Construction and Startup Superintendent R. E. Querto, Station Manager P. L. Barnes, Regulatory Assurance Supervisor Licensing Fee Management Branch Resident Inspector, RIII Braidwood Resident Inspector, RIII Byron D. W. Cassel, Jr. , Esq.

Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division H. S. Taylor, Quality Assurance Division OE OGC OE:D DEDRO

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J. M. Taylor, DEORO J. Lieberman, OE L. Chandler, OGC T. Murley, NRR RAO:RIII PAO:RIII SLO:RIII l-M. Stahulak, RIII i Enforcement Coordinators  :

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