ML20245D540

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violation Noted:Certain Environ Qualification Files Failed to Include Required Documentation

ML20245D540
Person / Time
Site:	Millstone
Issue date:	04/21/1989
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20245D537	List: IR 05000245/1987017 ML20245D540
References
EA-88-254, NUDOCS 8905010038
Download: ML20245D540 (4)

Text

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Northeast Nuclear Energy Company- Cocket Nos. 50-245 and 50-336 Millstone 1 and 2 License Nos. DPR-21 and DPR-65 EA 88-254 During NRC inspections conducted on November 18-22, 1985, July 15-17, 1987 and August 16-19, 1988, the NRC reviewed the licensee's program for environmental qualification (EQ) of equipment, as well as the circumstances associated with EQ deficiencies identified by the licensee in 1986-1987. In accordance with the " Modified Enforcement Policy Relating to 10 CFR 50.49, Environmental Qualification of Electrical Equipment Important to Safety of ."uclear Power Plants," contained in Generic Letter 88-07, the Nuclear Regulatary Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The parti-cular violations and associated civil penalty are set forth below:

I. VIOLATION ASSESSED A CIVIL PENALTY 10 CFR 50.49 (f), and (j), respectively, require, that (1) each item of electric equipment important to safety shall be qualified by testing and/or analysis of identical or similar equipment, and the qualification based on similarity shall include a supporting analysis to show that the equipment to be qualified is acceptable; and (2) a record of the qualifi-cation shall be maintained in an auditable form to permit verification that each item of electrical equipment important to safety is qualified and that the equipment meets the specified performance requirements under postulated environmental conditions.

Contrary to the above, as of November 30, 1985, certain environmental qualification files did not include the required documentation to demon-strate environmental qualification, as evidenced by the following examples.

1. On June 5, 1987, it was disclosed that the qualification of the PE/PVC cables, GE EB-5 terminal blocks, Honeywell microswitches and 3M " Scotch lock" wirenuts used in the Standby Gas Treatment System at Unit I had not been established under certain environmental conditions in that documentation did not exist to support qualification of I

these components for operation in a high radiation environment; and

2. On September 20, 1986, it was discovered that the qualification of a Ideal Model 74B wirenuts, used for the electrical termination of one ASCO solenoid valve which controls an atmospheric steam dump valve at Unit 2 had not been established under certain environmental condi-tions in that documentation did not exist to support qualification of the wirenuts for operation in an High Energy Line Break (HELB) environment under accident conditions.

This violation constitutes an EQ Category C violation.

Civil Penalty - 550,000 (This EQ violation existed in excess of 100 days l of plant operation).

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Notice'of Violation - 2'-

II. VIOLATIONS NOT ASSESSED A CIVIL PENALTY A. 10 CFR 50.49(d)(f) and (j) respectively require that (1) the licensee shall prepare a list of electrical equipment important to safety covered by this section; (2) qualification of each item of electrical equipment be based on testing or experience with identical equipment or with similar equipment with supporting analysis to show that the equipment is acceptable; and (3) a record of the qualification shall be maintained in an auditable form to permit verification that each item important to safety is qualified and that the equipment meets the specified performance requirements under postulated environmental conditions.

Contrary to the above, these requirements were not met as evidenced by the following examples:

1. between November 30, 1985 and June 5, 1987, the qualification of six Crane Teledyne Motor Operated Valves located outside the Drywell in Unit'l and required to function for a LOCA was not established in that documentation did not support qualification of the valves for operation in a harsh radiation environment.

2. between November 30, 1985 and June 5,.1987, the qualification of six electrical penetration terminations located in the reactor building outside the drywell in Unit I was not estab-lished in that documentation did not demonstrate qualification of the terminations for operation under postulated accident environmental conditions.

3. between November 30, 1985 and September 20, 1986, the qualifica-tion of terminations for containment spray pumps P-43A and P-43B located in the ESF rooms outside containment in Unit 2 was not l

' established in that documentation did not support qualification of the terminations for operation in a harsh environment.

4. between November 30, 1985 and September 20, 1986, the qualifica-l tion of six Raychem splices, used for connecting the field cable to the Conax seals associated with the Rosemount transmitters in Unit 2 was not established in that the installed cable seal I

length of one and one-half (11) inches was less than the tested 3

cable seal length of two (2) inches.

5. between November 30, 1985 and September 20, 1986, the Enclosure l

Building Filtration System Fan Motor Terminations in Unit 2, electrical equipment important to safety, were not on the EQ Master List, and so qualification was not established for these terminations.

6. between November 30, 1985 and September 20, 1986, the quali-fication of splices used in twelve Limitorque valve operators l in Unit 2 was not established in that documentation did not support qualification of these splices for operation under postulated accident environmental conditions.

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. Notice of Violation - 9 i s .

'7. between November 30, 1985 and September 20, 1986, the qualif .

cation of the motor terminations of two auxiliary feedpumps and

. two switchgear room fans in Unit 2 was not established in that'

! documentation did not support qualification of the termination for operation under postulated accident environment conditions

8. .between November 30, 1985 and September 20, 1986, the qualifica-tion of eight solenoid operated valves used in the MSIV rooms in Unit 2 was not established in that documentation did not support

.' qualification of the valves for operation under postulated

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accident environmental conditions.

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9. between November 30, 1985 and September 20, 1986 the qualification 1 of 6 Limitorque motor operators located inside the containment and used on isolation valves, was not established in that the operators did not have the required T-drains' installed.

This is a Severity Level IV violation. (Supplements)

B. 10 CFR 50, Appendix B, Criterion III states, in part, that measures for the identification and control of design revisions affecting 1 quality shall be accomplished in accordance with instructions and procedures.

Contrary to the above, as of November 22, 1985, the requirements of licensee procedure GE-EQ-1, for maintaining EQ documentation files,

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I were not properly implemented in that numerous unsigned and undated markups and corrections were found in.various System Component Evaluation Worksheets (SCEW) which are critical to documentation of component qualification.

This is a Severity Level V violation (Supplement I).

i Pursuant to the provisions of 10 CFR 2.201, Northeast Nuclear Energy Company .!

Company (Licensee) is hereby required to submit a written statement of (

explanation to the Director,' 0ffice of Enforcement, .S. Nuclear Regulatory l 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 alleged violation: (1) admission or denial of the alleged violation, j (2) the reasons for the violation if admitted, (3) the corrective steps that 1 have been taken and the results achieved, (4) the corrective steps that will 1 be taken to avoid further violations, and (5) the date when full compliance was or'will be achieved. If an adequate reply is not received within the time i specified in this Notice, an order may be issued to show cause why the license 1 should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be 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 penalty by letter to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or j

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Notice of Violation money order payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the licensee fail to answer within the time specified, an order imposing the civil penalty 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 clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating 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 answer may request remission or mitigation of the penalty.

In requesting mitigation of the prcposed penalty, the mitigation factors in the

" Modified Enforcement Policy Relating to 10 CFR 50.49, Environmental Qualifi-cation of Electrical Equipment Important to Safety for Nuclear Power Plants,"

contained in Generic Letter 88-07, should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately 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 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 for imposing a civil penalty.

Upon failure to pay any civil penalty due which subsequently has been deter-mined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 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, U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, a copy to the Regional Administrator, U. S. Nuclear Regulatory Commission, 475 Allendale Road, King of Prussia, PA, 19406 and a copy to the NRC Senior Resident Inspector at Millstone.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGM SWD "

n Jk,@ K N (j d e William T. Russell Regional Administrator Dated at King of Prussia, Pennsylvania thisdj day of April 1989.

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