ML20195G782

Responds to NRC Re Violations Noted in Insp Repts 50-254/86-21,50-254/87-11,50-265/86-21 & 50-265/87-11 & Proposed Imposition of Civil Penalty in Amount of $150,000. Corrective Actions:Amp Splices Repaired & Installed

ML20195G782
Person / Time
Site:	Quad Cities
Issue date:	11/21/1988
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	Lieberman J NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE)
References
NUDOCS 8811300037
Download: ML20195G782 (4)

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, Commonwealth Edison

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Address Reply tx Post Offc; Box 7C w/ Chego, libros 60690 0767 tiovember 21, 1988 Mr. James Lieberman, Director Office of Enforcement U.S. tiuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk Re: Quad Cities Station, Units 1 and 2 Reply to tiotice of Violation Report tio s . 50-254/86021; 50-254/87011; 50-265/86021; 50-265/87011 tJRC Docket tios . 50-254 and 50-265 Reference (a): October 20, 1988 A. B. Davis Lotter to J. J. O'Connor (b): tiovember 21, 1988 L. O. DelGeorge Letter to J. Lieberman (c) June 28, 1988 P. Steptoe Letter to J. L iebe rina n ,

L. O. DelGeorge Letter to A. B. Davis, and accompanying I. M. Johnson, M. S. Turbak, V. floonan and R. LaGrange and J. Abel AffIdavJts

Dear Mr. 1. i e be rma n :

This is Commonwealth Edison's reply to the 110tice of violation concerning the environmental qualltication of AMP nylon-insulated butt splices at Quad Cities, Units 1 and 2. Soe Reforonco (a). An accompanying letter from Commonwealth Edison's lawyers, Sidley 6 Austin, constitutes CECO's Answer to the proposed imposition of a $150,000 civil penalty in this matter This Reply and the Sidley & Austin Answer are complete, with the exception of a supplemental affidavit from Philip Holtzman which G811300037 88112'1 7R mDe -g ,

% 'A Mr. James Lieberman, Director tiovember 21, 1988 Page 2 will be submitted in the near future. This matter was discussed by you and Ms. Irene M. Johnson (CECO) in a flovember 18, 1988 telephone conversation and found to be acceptable.

bj;LEGED VIOLATTCti.

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

10 CPR 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 Evaluation Environmental Qualification of Class lE Electrical Equipment in Operating Reactors," flovember 1979 (DOR Guidelines).

DOR Guidelines, Section 5.2.2, states that type tests should only be considered valid 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 flovember 30, 1985 until December 6, 1986, AMP nylon-insulated butt splices, used in numerous items of electrical equipment imoortant to safety, were not properly environmentally qualified in accordance with DOR Guidelines by type testing. While a type test was done, the tested splicos were not demonstrated to be identical to the installed AMP splicos and this deviation was not evaluated as part of the documentation in the qualification file.

1. Admissinq_or Denial of t lle_A_lAtgmL V i o l a t i_o n t Commonwealth Edison admits that it was unable to demonstrate that the AMP splices were environmentally qualified, based on the results of testing conducted at CI:Co's initiative in December 1986. it does not agree that the documentation in its ffles as of December 6, 1986 was inadequate to demonstrate that the AMP splices

, 4 Mr. James Lieberman, Director November 21, 1988 Page 3 were properly qualified in accordance with the DOR Guidelines by type testing and analysis. However, the Company believes that this documentation issue has been superceded by the December 1986 test results and further argument as to the adequacy of documentation would not be useful or constructive.

2. Reasons for the Allocod_ violation.

The violation occurred due to the unexpected failure of the December 1986 tests to confirm the environmental qualification of the AMP splices based on type testing and analysis. There is a possibility that the December 1986 tests, which were conducted in accordance with Category I requirements, were more severe than the old

, G.E. tests which formed the basis for CECO's environmental qualification judgment. In addition, as in the case of Dresden, Unit 3 (see Reference (c)), it appears that certain irformation related to the old G.E. tests was not documented by G.E. in its test records and therefore was not considered by CECO or its consultants prior to receiving the December 1986 test results.

3. Corrective Actions Taken and Results Achieved.

On its own initiative, Commonwealth Edison shut down Quad Cities Unit 1 for five days. Quad Cities Unit 2 was in a refueling outage, Commonwealth Edison made appropriate repairs to the affected splices with qualified tape, using approved procedures and properly trained personr.el. Region III personnel witnessed these repairs.

4. Corn;gtive SJ Aps ighop___to Avoid _Dtr_ttar ViolaMpBL.

On its own initiative, Commonwealth Ediron repaired or replaced the AMP splices already instal}9d in Dresden and Quad Cities in DecemL9r, 1986, and took further administrative steps to prerent future installation of splices in EQ circuits.

o Mr. James Lieberrnan, Director tJovember 21, 1988 Page 4

5. Date when Full Compliance Was Ac}1 1eved.

Corrective actions with respect to AMP splices already installed were complete as of December 1986 when Quad Cities Units 1 and 2 returned to operatit N.

Respectfully submitted, kt A Louis O. DelGeorge Assistant Vice President cca A. B. Davis Quad Cities Resident Inspector J3lR8A26.WP