ML20247Q179

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $100,000.Noncompliance noted:safety-related Motor Control Ctrs in Auxiliary Bldg Had Not Been Demonstrated to Be Qualified for Environ Conditions

ML20247Q179
Person / Time
Site:	Crystal River
Issue date:	09/13/1989
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247Q177	List: IR 05000302/1989009 ML20247Q179
References
EA-89-118, NUDOCS 8909280123
Download: ML20247Q179 (4)

Text

_ _- -. _ _ - .. --- . _

NOTICE OF VIOLATION AND PROPOSED IMPOSITIDT0F CIVIL PENALTY Florida Power Corporation Docket No. 50-302 Crystal River License No. DPR-72 '

EA 89-118 4

During the Nuclear Regulatory Commission (NRC) inspection conducted on April 24-28, 1989, violations of NRC requirements were identified. -In accor-dance with the General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the Nuclear Regulatory 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 particular violation'and associated civil penalty are set forth below:

A'. 10 CFR 50.49(a) requires each holder of a license for operation of a nuclear power plant to establish a program for qualifying electric equipmentidentifiedin10CFR50.49(b).

10 CFR 50.49(b) defines equipment important to safety and includes:

(1) Safety-related electric equipment, i.e., equipment relied upon to remain functional during and following design basis events. l (2) Certain post-accident monitoring equipment.

10 CFR 50.49(d) requires the licensee to prepare a list of electric equipment important to safety covered by this section.

10 CF 50.49(f) requires that each item of electric equipment important to safety shall be qualified by testing and/or analysis under postulated environmental conditions.

10 CFR 50.49(j) requires that a record of qualification for the electric equipment important to safety, as identified on the Master List, be maintained in an auditable form for the entire period during which the covered item is installed in the nuclear power plant. 3 Contrary to the above, from November 30, 1985 the licensee failed to comply with the above EQ requirements as evidenced by the following violations:

1. On December 9,1988 it was discovered that certain safety-related motor control centers in the Auxiliary Building had not been demonstrated to be qualified for the environmental conditions resulting from a postulated auxiliary steam line crack.

2. On December 16, 1988 it was identified that valve motor operators FWV-14 and 15 and WDV-406 contained tape splices and the licensee could not demonstrate qualification for the valve motor operators in that the licensee did not have a record of qualification for the tape splices.

$, ANh f O

I

. .. l L

Notice'of Violation l

3. As of April 24, 1989 the licensee did not have a record of qualification for Kerite tape' splices such as the one used .in electrical penetration EPA-412.

,. 4. As.of April 24, 1989 three GEMS Containment Sump Level transmitters l (WD 303-LT-A&B and WD '302-LT-B) were found to be in a configuration i

other than the tested configuration in that the associated junction l boxes were not filled with silicone oil. The licensee did not have L analysis ~ to demonstrate the acceptability of the installed condition.

5. The record of qualification for certain ASCO solenoid valves such as those used in the Main Steam Isolation Valves was deficient in that it did not adequately support a 40-year qualified life for the solenoid valves when considering the effects of elevated localized temperatures from the hot process piping.

6. Electrical penetration EPA-128, which contains the cables for required post accident monitoring temperature elements AH-536, 537, 538 and 539-TE, was not on the master list of electric equipment important to safety.

7. The four Limitorque valve motor operators associated with valves RCV-11, CAV 1, 3, and 4, respectively were installed inside contain- ,

ment without functioning T-drains and grease reliefs. Qualification l of these operators was based upon a tested configuration which included functioning T-drains and grease reliefs; however, the licensee did not have analysis to demonstrate the acceptability of the installed configuration.

8. Weidmuller terminal blocks were not properly qualified for use inside containment in'that the qualification documentation did not contain insulation resistance values taken during the accident profile testing and did not contain analysis to demonstrate the acceptability of the installation of these terminal blocks in junction boxes, which differed from those tested, in that the installed boxes hao no weep holes.

9. Valve RC-11 was found installed in a configuration other than the tested configuration and the licensee did not have analysis to demonstrate the acceptability of the installed configuration.

Specifically, the valve was found with degraded grease in gear box and cracked wiring insulation.

10. Transmitters RC-163 ALT, RC-163 BLT, RC-164 ALT, RC-164 BLT, RC-14A delta PT 1-3, RC-14B delta PT 1-3, SP-31 LT, SP-32 LT, SP-21 LT, SP-22 LT, SP-23 LT and SP-24 LT were installed in configurations other than the tested configuration and the licensee did not have i analysis to demonstrate the acceptability of the installed configurations. Specifically, the transmitters were installed below the design basis accident flood level but the associated cables and splices had not been qualified for submergence.

4 Notice of Violation 11. Eleven butt splices on Main Steam pressure transmitters MS-106 PT, thru MS-113 PT and Emergency Feedwater Flow Transmitters EF-24 FT thru EF-26 FT were found installed with Raychem WCSF-115 sleeves

.instead of the required WCSF-070 sleeves and the licensee did not have analysis to demonstrate the acceptability of the installed configuration.

B. 10 CFR Part.50 Appendix B Criterion V requires in part, that activities affecting quality be prescribed by documented procedures appropriate to the circumstances. ,

Contrary to the above, procedures MP-405 and PM-133 were not appropriate for the circumstances in which they were used in that.they lacked suffi-cient detail to ensure the qualified status of certain equipment required by 10 CFR 50.49 was maintained. Specifically, MP-405 did not properly consider vendor bend radius limitations for cebles and PM-133 did not properly consider vendor requirements for bearing lubrication.

This is a Severity Level III Problem (Supplement I).

Cumulative Civil Penalty - $100,000 (Equally assessed among the 12 violations).

Pursuant.to the provisions of 10 CFR 2.201, Florida Power Corporation (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 (1) admission or denial of each violation, (2) the reasons for the violation if admitted, (3) the corrective steps 'that havebeentakenandtheresultsachieved,(4)thecorrectivestepswhichwill be taken to avoid further violations,.and (5) the date when full compliance will

- be achieved. If an adequate reply is 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 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.

l 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 addressed 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 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, l such answer should be clearly marked as an " Answer to a Notice of Violation" l 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 l of the penalty.

Notice of Violation In requesting mitigation of the proposed penalty, the factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1989), 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 i 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 the penalty due, which has been subsequently determined 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. 2282.

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, with a copy to the Regional Administrator, Region II and a copy to the NRC Resident Inspector, Crystal River Nuclear Plant.

FOR THE NUCLEAR REGULATORY COMMISSION Original signed by SDEbneter Stewart D. Ebneter Regional Administrator Dated at Atlanta, Georgia this/34fbay of September 1989 s

_ __-_---___ _ -_____ _____ _ _- _ _ - _ _