NG-88-3744, Responds to Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Corrective Actions:Util Has Taken Steps to Preclude Future Installation of Unqualified Butt Splices in Circuits,Per 10CFR50.49

Responds to Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Corrective Actions:Util Has Taken Steps to Preclude Future Installation of Unqualified Butt Splices in Circuits,Per 10CFR50.49

ML20206M245
Person / Time
Site:	Duane Arnold
Issue date:	11/21/1988
From:	Rothert W IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	Lieberman J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE)
References
EA-87-083, EA-87-83, NG-88-3744, NUDOCS 8811300502
Download: ML20206M245 (6)

Text

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10 CFR 2.201 Towa Electric Light and Power Company November 21, 1988 NG-88-3744 Mr. James Lieberman, Director Office of Enforcement U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Reply to Notice of Violation and Proposed Imposition of Civil Penalty (EA 87-G3)

File: A-102, A-64

Dear Mr. Lieberman:

This letter is being submitted pursuant to 10 CFR 2.201 and a letter from Mr.

A. Bert Davis, US NRC Region III Regional Administrator, to Mr. Lee Liu, President and Chief Executive Officer, Iowa Electric Light and Power Company, dated October 21, 1988. Specifically, we are required to submit, by November 21, 1988, a reply to a Notice of Violation and P.oposed Imposition of Civil Penalty. This letter and the attachments constitute the required reply.

Pursuant to the requirements of 10 CFR 2.201(a), Attachment 1 to this letter, "Reply to a Notice of Violation," provides our (1) admission of the alleged violation, (2) the reasons for the violation, (3) the corrective steps that have been taken and the results achieved, (4) corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved.

Iowa Electric recogniv.s the serious nature of the violation identified in the Notice. As Mr. Davis' letter acknowledges, Iowa Electric exerted its best ef forts to complete the Environmental Qualification Program within the deadline established by the NRC and, upon learning that nylon-insulated butt splices had failed undar test conditions directly applicable to the Ouane Arnold Energy Center (DAEC), identified and reported the presence of similar splicos at the DAEC and took prompt and extensive corrective action. This information was discussed during our enforcement conferences on June 29 and July 24, 1987 and was considered in tir. Davis' letter. We do not believe that it is in the best 0011300502 001121 PDR ADOCK 05000331 O PNU Y[L-i;eneral Of] ice

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.Mr. J. Lioborman

. NG-88-3744 Page.2 interest of the owners of the DAEC to pursue this matter further. We, therefore, will not submit a response pursuant to the provisions of 10 CFR 2.205 protesting the Civil Penalty. We enclose a copy of our check in the amount of

$EO,000, payable to the Treasurer of the United States, which was previously submitted.

This response, consisting of this letter and attachment, is true and accurate to the best of my knowledge and belief.

IOW ELECTRIC LIGHT D POWER COMPAPY By u tu nu "

W11'11am C. R'otherT Manager, Nuclear Olvision Subscribed and Swor to Before Mo on this- day of _ , 1983.

/w/h Jauw ,

NogyPublicinandFortheState of Iowa WCR/NKP/pjl l

Attachments: (1) Reply to a Notice of Violation (2) Copy of Check No. 185991 i cc: N. Peterson f R. McGaughy I' L. Root L. Liu  !

J. R. Hall (NRC-NRR)  :

A. Bert Davis (Region III)  !

NRC Resident Office '

Commitment Control No. 880398

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• Attachment I to NG-88-3744 Page 1 of 3 REPLY TO A NOTICE OF VIOLATIDtf

1. NRC DESCRIPTION OF VIOLATION During an NRC inspection conducted on April 13-29, 1987, a violation of NRC requirements was identified. In accordance with the Modified Enforcement Policy Relating to 10 CFR 50.49, "Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants," attached to Generic Letter 88-07, the Nuclear .'egulatory 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 ane associated civil penalty are set forth below:

10 CFR 50.49(f) requires each item of electrical equipment important to safety to be environmentally qualified by testing and/or analysis.

10 CFR 50.49(k) specifies that requalification of electric equipment important to safety is not required if the Commission has previously required qualification in accordance with "Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors," November 1979 (00R Guidelines).

DOR Guidelines, Section 5.2.2, states that type tests should only be considered Vdlid for equipment identical in design and material construction to the test specimen and any deviations should be evaluated as part of the qualification documentation.

Contrary to the above, from November 30, 1985 to December 9,1986, the licensee operated the plant with unqualified electrical equipment important to safety as evider.ced by the following examples:

a. AMP nylon-insulated butt splices, used in some items of electrical equipment important to safety, were not environmentally qualified by adequate type testing. While a type test wa: done, the tested splices were not demonstrated to be identical to the installed AMP splices in that the manufacturer and the formulation of the tested splices were not specified. Further, the testing relied on by the licensee did not simulate the combined degrading effects of radiation and steam that would be encountered by the installed splices during +cident conditions,

b. AMP KYNAR butt splices, used in numerous items of electrical equipment importent to safety, were not environmentally qualified by appropriate testing and/or analysis in that the tested configuration did not simulate the cc.. figuration of the splices installed in the plant.

Specifically, the tested spitees were not tested in contact with each other or their surrounding grounded metal housing.

This is an EQ Category B violation.

Cumulative civil penalty - $50,000 (assessed equally between the examples).

1

1 Attachment 1 to 14G-88-3744 Page 2 of 3 cII. IOWA ELECTRIC REPLY 1 6dmission of the Violation - '

Iowa Electric Light and Power Company (IE) admits that the electrical equipment identified in the Notice did not meet requirements for environmental qualification.

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. 2. The Reasons for the Violation

a. AMP Nylon-Insulated Butt Splices IE had determined that these splices r,et environmental qualification i

requirements, based on documented reports of tests performed _in 1971 and i

industry-accepted methods of an=1ysis in accordance with the D0R

, gufdelines. However, in Decembwr 1986 IE was informed of the results L; >

of environmental testing of these splices performed by another utility.

The tests demonstrated that the splices did not meet environmental qualification requirements. IE has concluded that the test report and analyses previously rolled upon were not adequate to demonstrate environmental qualification. Th9 combined effects of temperature,

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i pressure, humidity, radiation and thermal aging were not adequately

) accounted for in the original testing and analyses,

b. AMP KYNAR Butt Splices IE had dctermined that those splices met environmental qualification requirements, based on AMP qualification test report (110-11004) and i

analysis in accordance with the 10 CFR 50.49. The AMP test report indicated that environmental testing accounted for the most severe temperature, pressure, humidity, radiation, and thermal a,ing conditions

. expected at the DAEC. The text of the test report stated the splices i

were tested in an enclosure similar to those used at the 0/EC and that

circuit testing was performed while the splices were in contact with a conductor (lead shot). IE concluded that the tested configuration adequately simulated the installed configuration at the DAE';. In l December 1986, the NRC advised IE that the AMP test report did not appear i

to document qualification testing of KYNAR splices in a configuration similar to the installed configuration. In November 1987 splices of this

{ type failed in environmental qualification tests conducted by another

uttitty. In those tests the splices were in enntact with nach other or j the grouNed metal housing and they failed, therefore, IE's similarity j analys's of the t",t report was inadequate.

3. The Corrective Steos That Have Been Taken and the _Resulb Achieqd On December 9, 1986, IE ascertained that the nylon-insulated butt splices had failed under test conditions directly applicable to DAEC. A plant shutdown was immediately initiated to repair the affected splicas. These repairs consisted of wrapping of all butt splices, regardless of manufacturer or insulating material, which could oc subjected to a steam J

, Attachment 1 to NG-88-3744 Page 3 of 3 environment under accident conditions. During the next refueling outage, all remaining butt splices within the sce u of the DAEC Equipment Qualification (EQ) program were sis.. d repaired. The splices were wrapped with qualified tape, using qualified procedures and properly trained personnel.

In addition, qualification documentation for other similarly qualified equipment was reviewed for adequacy. No deficiencies were noted. .

4. Corrective Steos Thal Will Be Taken te Avoid Further Violations .

As described above, this violation has en completely corrected. Iowa Electric has also taken administrative m ps to preclude the future installation of unqualified butt splices at the OAEC in circuits to which the requirements of 10 CFR 50.49 apply. Maintenance procedures govern the installation and repair of all splices within the scope of the EQ program to assure that splices are environmentally qualified.

Furthermore, IE is engaged in a number of activities to provide additional f assurance that other plant equipment at the DAEC is properly qualified and to monitor industry-wide sources that provide information that could affe-t the status of qualified equipment at the DAEC. Iowa Electric receives anJ evaluates Institute of Nuclear Power Operations (INPO) Significant Event '

Reports and Significant Operating Event Reports; General Electric Servico Advice Letters, Service Information Letters and Technical Information Letters; and NRC Generic Letters, Bulletins and Information Notices.  !

Information from any of the listed sources relating to equipment qualification is reviewed to Msure that the potential impact on the Equipment Qualification progri at the DAEC is addressed and documented. '

Iowa Electric participates in industry groups that provide information  !

relating to environmental qualification issues. Examples include the  !

Boiling Water Reactor Owners' Group, the Nuclear Utility Group on Equipment  ;

Qualification, and the Electric Power Research Institute Equipment t Qualification Advisory Group. Information obtained from meetings and/or j reports of these groups is provided to appropriate members of the Iowa <

Electric staff and is reviewed for applicability to equipment installed at i the DAEC. Iowa Electric recognizes that the maintenance of equipment '

qualification is a continuing ef fort and has in place a number of programs designed to keep abreast of developments in the area Iowa Electric believes that these programs will help prevent equipment qualification violations in the future.

5. Du d hen Full Como11ance=Wil!_be Achieved Iowa Electric was in full compliance as of June 28, 1987, the date of startup from the Cycle 8/9 Refueling Outage.

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