ML20205J508

Discusses Insp Rept 50-298/86-28 on 861103-07 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty Based on Failure to Ensure 600-volt Cable & Cable Connectors Qualified

ML20205J508
Person / Time
Site:	Cooper
Issue date:	10/25/1988
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Trevors G NEBRASKA PUBLIC POWER DISTRICT
Shared Package
ML20205J511	List: ML20205J508 ML20205J513
References
EA-88-159, NUDOCS 8810310416
Download: ML20205J508 (5)

See also: IR 05000298/1986028

Text

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UNITED STATES

, g NUCLEAR RESULATERY CSMMISSION

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R 25 588

Docket No. 50-298

EA 88-159

NebraskaPublicPowerDistrict(NPPD)

ATTN: George A. Trevors

Division Manager - Nuclear Support

Post Office Sox 499

Columbus, Nebraska 68601

Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY

(NRCINSPECTIONREPORTNO. 50-298/86-28)

This refers to the NRC inspection conducted November 3-7, 1986, at the Cooper

Nucleu Station (CNS) of activities authorized by NRC License No. DPR-46. The

inspection was conducted by a special environmental qualification (EQ) inspection

team to assess the program implemented at CNS to ensure that electrical equipment

important to safety is qualified according to the requirements of 10 CFR 50.49.

This inspection included examination of NPPD EQ records to verify that they

contained appropriate analyses and documentation to support the EQ of electrical

equipment installed in the plant. A copy of the inspection report was sent to

you by letter dated April 1,1987. The results of the inspection were discussed

on June 20, 1988, during an enforcement conference held in the NRC Region IV

office in Arlington, Texas, Because the inspection report issued in this case

is not as detailed as those the NRC normally supplies to its licensees, a

detailed review of the pertinent issues is included as an enclosure to this

letter.

The violations in Part I of the enclosed Notice of Violation and Proposed

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Imposition of Civil Penalty (Notice) involved the failure to ensure, either by

adequate testing or analysis, that the following equipment was qualified:

(1) Kerite HTK/FR 600 volt cable; (2) Thomas & Betts Sta-kon cable connectors

(splices) to Fenwal/Patel temperature switches; and (3) Scotch 130/70/17 tape

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cable splices to Limitorque motor oper a rs. The NRC analysis of these issues

demonstrates that NPPD clearly should he,e known, prior to the November 30,

1985 deadline for completing your environe atal qualifications program that the

requirements of 10 CFR 50.49 were not met

With regard to the Kerite 600V cable, th reports (December 9,1982 SER and the

November 24, 1982 Franklin Research N ter TER) available on this matter as

well as the March 24, 1984 meeting between NPPD and the NRC provided clear

notice that qualification of this type of cable had not been established.

Further, NPPD clearly would have known that qualification had not been

demonstrated if an a M uate review of the Franklin Research Center test

anomalies, regarding degradation of this type of cable during and af ter LOCA

testing, had been performed. In the case of the Thomas and Betts Sta-kon cable

connectors NPPD clearly should have known that qualification had not been

demonstrated because testing had only established qualification in a steam

environment rather than the full accident environment to which the connectors

would have been subjected. Finally, in the case of the Scotch 130/70/17 tape

cable splices NPPD clearly should have recognized that qualification had not

been demonstrated because the installed splices were over cable with a braided

fiberglass jacket which was not representative of the tested configuration in

which the splices were installed over unjacketed insulated cable.

These violations are an indication to NRC of a need to place greater attention

on ensuring that equipment important to safety will perform its intended

function in harsh environments and that regulatory deadlines are met. Also of

concern to the NRC is the fact that, at the time of the inspection, you were

unable to verify whetner Kerite HTK/FR 600-volt cable, an item on your list.of

electrical equipment important to safety about which the NRC had questions, was

installed in the plant. You later determined that this cable was installed in

the plant. Accordingly, I have been authorized, after consultation with the

Director, Office of Enforcement and the Deputy Executive Director for Regional

Operations, to issue the Notice of Violation and Proposed Imposition of Civil

Penalty (Enclosure 1) in the amount of One Hundred Fif ty Thousand Dollars

($150,000) for the violations dcscribed in the enclosed Notice. In accordance

with the "Modified Enforcemont Policy Relating to 10 CFR 50.49," contained in

Generic Letter 88-07 (Enclosure 3), the violations described in Part I of the

enclosed Notice have been determined to affect a limited number of systems and

components, and therefore are considered to be an EQ Category C problem. The

basa value of a civil penalty for an EQ Category C problem is $75,000,

in determining the civil penalty amount, the NRC considered the four factors

set forth in the "Modified Enforcement Policy Relating to 10 CFR 50.49," for

escalation and mitigation of the base civil penalty amount. These factors

consist of: (1) identification and prompt reporting of the EQ deficiencies by

the licensee (i 50%); (2) best efforts to complete EQ within the deadline

(t 501); (3) corrective actions to result in full compliance (2 505); and

(4) duration of a violation which is significantiy below 100 days (- 501).

With respect to the first factor, all three items were identified by the NRC

and, at the time of the inspection, you did not know whether Kerite cable

was used in the plant. Thus, a 50-percent increase in the base penalty is

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Nebraska Public Power District -3-

wnrranted. With respect to the second factor, no adjustment appears warranted.

We recognize that your program to perform additional testing, replace and

upgrade components, and perform additional analyses on other items was complete

prior to November 30, 1985. However, your best efforts were not applied with

regard to the required analyses to support the qualification of some equipment

and to verify that equipment on your EQ list was or was not used in the plant.

With respect to the third factor, a 50-percent increase is warranted in that,

as of the date of the Enforcement Conference, your corrective actions for one

of these three items had not resulted in full compliance, although the NRC

believes no operability issues now exist with the hardware in your plant. With

respect to the fourth factor, mitigation is inappropriate since these

violations existed in excess of 100 days. In total, a 100 percent increase in

the base civil penalty amount is appropriate.

The violations in Part !! of the Notice of Violation (Enclosure 1) are violations

that were not assessed a civil penalty. Violations A and B are classified at

Severity Level IV because during the inspection or shortly thereafter the

licensee was able to demonstrate that the equipment was qualifiable. With

respect to Part II, Item C, of the Notice, NPPD has taken sufficient corrective

action to demonstrate that full compliance has been achieved. Therefore, no

response to Part II, Item C, of the Notice is required pursuant to the

provisions of Section 2.201 of the NRC's "Rules of Practice," Part 2, Title 10,

Code of Federal Regulations.

You are required to respond to this letter and shouH 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. Af ter reviewing your response to this

Notice, including your proposed corrective actions and the results of future

inspections, the NRC will determine 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 enclosure

will be placed in the NRC Public Document Room.

The responses directed by this letter and the enclosed Notice are not subject

to the clearance procedure of the Office of Management and Budget as required

by the Paperwork Reduction Action of 1980, PL 96-511.

Sincerely,

,-----

( N

Robert D. Martin

Regional Administrator

Enclosures:

See attached

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Nebraska Public Power District -4-

Enclosures:

1. Notice of Violation and Proposed

Imposition of Civil Penalty

2. Addendum to NRC Inspection Report 50-298/86-28

3. Generic Letter 88-07

cc w/ enclosure:

Cooper Nuclear Station

ATTN: Guy Horn Division Manager

of Nuclear Operatious

P.O. Box 98

Brownville, Nebraska 68321

Kansas Radiation Control Program Director

Nebraska Radiation Control Program Director

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E OCT 251988

Nebraska Public Power District -5-

DISTRIBUTION

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