ML20236M998

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Noncompliance Noted:Inadequate Control & Installation of Purchased Equipment & Inadequate Corrective Actions & Insps

ML20236M998
Person / Time
Site:	Farley
Issue date:	11/03/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236M977	List: IR 05000348/1987011 ML20236M998
References
50-348-87-11, 50-364-87-11, EA-87-142, NUDOCS 8711130365
Download: ML20236M998 (5)

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I NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Alabama Power Company Docket Nos. 50-348 and 50-364 I Joseph M. Farley Nuclear Plant License Nos. NPF-2 and NPF-8 l Units 1 and 2 EA 87-142 I i

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During the Nuclear Regulatory Commission (N.RC) inspections conducted on May 11-22, June 1-5, and June 11-July 10, 1987, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the l Nuclear Regulatory Commission proposes to impose two civil penalties pursuant to l 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 penalties are set forth below: I l

I. Inadequate Control and Installation of Purchased Equin pt A. 10 CFR Part 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, and Services, requires that measures be estab-lished to assure that purchased material, equipment, and services conform to the procurement documents. These measures shall include

( provisions, as appropriate, for source evaluation and selection, j l objective evidence of quality furnished by the contractor or sub-l contractor, and inspection at the source. Documentary evidence that material and equipment conform to the procurement requirements is required to be available at the nuclear power plant prior to installation or use of such material and equipment.

Contrary to the above, at the time of the inspections, the licensee had nine circuit breakers with unconfirmed seismic qualification and

, voltage ratings installed in safety-related motor control centers at l Farley Nuclear Plant Units 1 and 2. The circuit breakers were sold by Satin American Corporation as seismically qualified safety-related l circuit breakers acceptable for installation into 600-V motor control I centers. The vendor provided inadequate justification for seismic and 600-V qualification. No testing or analysis that would qualify the use of these breakers as installed had been done either by the licensee or the vendor. Moreover, although the vendor represented that the circuit breakers were fully qualified for 600-V applications, the licensee should have been alerted to a possible problem since the breakers were still affixed with an Underwriters Laboratories, Inc.

rating of 480-V.

B. 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires that measures be established to assure that applicable regulatory requirements and the design basis for those structures, systems, and components te which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. It also requires that measures be established for the selection and review for suitability of materials, parts, equipment, and processes that are essential to the safety-related functions of structures, systems and components.

8711130365 071103 PDR ADOCKOS0g8 G

Notice of-Violation '

Contrary to the above, the licensee installed a number of commercial' l grade parts at Farley' Nuclear Plant Units 1 and.2- without adequately.

evaluating their suitability for use'in. safety-relatediapplications.

These parts were in use at the time of the inspections indicated above. Specifically:

1. Commercialgrade.circuitbreakersweheinstalledintosafety-related motor control centers =10 and 2U.

2. A commercial grade "Namco". limit' switch was installed as a. .  ;

replacement for safety-related switch.for the accumulatorLtank'- '

isolation valve. 1

3. A commercial grade torque switch was" installed into;a' safety-'

related Limitorque motor actuator. Limitorque.has. stated that _

l although the' safety-related and-commercial-grade. torque switches-l for-outside. containment are.the same,.the switches orderedlas:

safety-related received ' additional quality assurance, checks :at -

Limitorque that were not performed on-the commercial grade switches. There was no-evidence that the licensee made additional, quality assurance checks on the torque switch.

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4. Commercial grade hinge pin. bushings were. installed in safety-related Anchor / Darling tilting disk check' valves;in the auxiliary-feedwater system. j

5. A commercial grade Agastat timing relay (ATR) was-installed'as a replacement.in' safety-related panel #Q2R16B007-B, 600-V load l distribution panel. Additionally, commercial grade'ATRs were d found in other safety-related electrical enclosures including j two ATRs in diesel generator 1oad. sequencer panel #Q2R43E5018-B,- .

and two ATRs in diesel generator relay terminal box #Q1R43E506-B. R g Collectively, these violations have been evaluated as'a Severity; Level III problem (Supplement I).

Cumulative Civil Penalty - $25,000 (assessed equally between the violations).

II. Inadequate Corrective Actions and Inspections A. 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Act' ion,. requires ,

that measures be established to assure that conditi'ons adverse,to:

quality, such as fai. lures, defective material and. equipment,.and:

nonconformances are promptly identified and co'rrected. In the case.

of significant conditions. adverse to quality,'m'easures are required  :

to assure-that the cause.of-the. condition'is determined and c'orrec- J tive action is taken to preclude repetition. The identification: of '

the significant condition adverse'to quality, the_cause of the; condition, and the corrective action taken are also required,to be documented'and reported ~to appropriate; levels'of management.

l' L Centrary to the above, the inspectors identified.five instances' where' at:the time of the.; inspections, the licensee had failed to take adequate corrective action:

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l Notice of Violation '

1. A 10 CFR Part 21 notification by the Henry Pratt Company in May 1985 detailed problems with Pratt . valves using Limitorque l operators. This problem was not correctly or completely i dispositioned in that seven valves were determined'to be defective afte" the NRC inspection.

2. A 10 CFR Part 21 notification by the Anchor / Darling Valve Company in June 1985 detailed failures with tilting disk check valve hinge pin bushings. This problem was not completely dispositioned in that only check valves in the Auxiliary Feedwater System were ,

inspected. Other safety-related systems were not inspected.

3. A Colt Industries Service Information Letter (SIL), A-2, dated f February 1985, entitled " Blower Installation," was evaluated by )

the licensee, but not all the corrective actions determined to be appropriate by the Alabama Power Company engineering review were implemented -in that SIL A-2,.which gives service instruc-tions, was never placed in the Colt Industries' Emergency Diesel controlled vendor manual, j

4. Maintenance Work Request Nos. 44439 and 67875, which have j implemented corrective actions to the four control room fire  !

damper electrical circuits to ensure that the circuits would I function as desired, were not completed. )

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5. In April 1986, the licensee identified cracks in a number of cells of the safety-related station batteries. Despite the q fact that NRC Information Notice 84-83 identified that such  !

conditions can be caused by the use of hydrocarbon-based i solvents for cleaning purposes, the licensee had not updated I one of three pertinent electrical' maintenance-procedures to adaress the problem.

B. 10 CFR Part 50, Appendix B, Criterion X, Inspection, as implemented I by Section 17 of the Final Safety Analysis Report and the Joseph M.  ;

Farley Operations Quality Assurance Policy Manual, requires that inspection of activities affecting quality be established and executed to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.

Contrary to the above, on June 2, 1987, both Train B, 125-V Service Water (SW) battery racks, were found to be improperly installed and mounted creating an unanalyzed condition concerning seismic qualifi- .

cation. Specifically, the concrete anchor bolt nuts on all Train B l battery rack anchors were backed off and used as leveling nuts for i the rack, thus providing no preload on the concrete anchors. The battery racks were improperly installed in the SW Train B battery ,

room approximately one year prior to this inspection and remained in j this' unanalyzed condition until it was identified by the NRC inspector 1 on June 2, 1987.

Collectively these violations have been evaluated as a Severity Level III

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problem (Supplement I).

Cumulative Civil Penalty - $25,000 (assessed equally between the. violations).

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Notice of Violation -

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Pursuant to the provisions of 10 CFR 2.201, Alabama Power Company (licensee), is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of 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 reasons for the violation if admitted, ]

(3, the corrective steps that have been taken and the results achieved, 1 (4) the corrective steps that will be taken to avoid further violations, and I (5) the date when full compliance will be achieved. If an adequate reply is l 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 net be taken. Consideration may i be given to extending the response time for good cause shown. Under the i authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be l submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, the licensee may pay the civil penalties by letter to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of  !

the civil penalties proposed above, or may protest imposition of-the civil penalties I in whole or in part by a written answer t.ddressed to the Director, Office of f' Enforcement, U.S. Nuclear Regulatory Commission. Should the licensee fail to.

answer within the time specified, an order imposing the civil penalties 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 answer should be 1 clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the j violations listed in this Notice in whole or in part, (2) demonstrate extenuating i circumstances, (3) show error in this Notice, or (4) show other reasons why the  !

penalty should not be imposed. In addition to protesting the civil penalty, such l answer may request remission or mitigation of the penalties.

i In requesting mitigation of the proposed penalties, the five factors addressed

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in Section V.B of 10 CFR Part 2, Appendix C (1987), should be addressed. Any I written answer in accordance with 10 CFR 2.205 should be set forth separately l from the statement or explanation in reply pursuant to 10 CFR 2.201 but may )

incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing l page and paragraph numbers) to avoid repetition. The attention of the licensee  !

is directed to the other provisions of 10 CFR 2.205, regarding the procedure j 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 penalties, unless compromised, ,

remitted, or mitigated, may be collected by civil actien pursuant to Section j 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, i

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Notice of Violation U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with.a copy to the Regional Administrator, Region II, and the NRC Resident Inspector at Farleye FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED Bh J. NELSON GRACE J. Nelson Grace Regional Administrator Dated at Atlanta, Georgia thiS3fdday of November 1987 l

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