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> EA-97-576
EA-97-576 - Indian Point 2 (Consolidated
Edison Company of New York, Inc.)
July 6, 1998
EA Nos.: 97-576; 98-028; 98-056; 98-192
Mr. Paul H. Kinkel
Vice President - Nuclear Power
Consolidated Edison Company of New York, Inc.
Indian Point 2 Station
Broadway and Bleakley Avenues
Buchanan, New York 10511
SUBJECT: |
NOTICE OF VIOLATION AND
PROPOSED IMPOSITION OF CIVIL PENALTIES - $110,000 (NRC Inspection
Report Nos. 50-247/97-13; 97-15; and 98-02 and Investigation Report
No. 1-97-038) |
Dear Ms. Kinkel:
This letter refers to three NRC inspections conducted between October
27, 1997, and March 23, 1998, at your Indian Point 2 nuclear facility
for which exit meetings were held on January 23, January 30, and April
23, 1998. This letter also refers to an investigation conducted by the
NRC Office of Investigations (OI) to determine if a technician deliberately
falsified an emergency light surveillance test record. Based on the results
of the inspections and investigation, apparent violations were identified
as described in our letters dated February 10, February 13, February 25,
and May 15, 1998, transmitting the inspection reports and OI synopsis.
On May 6, 1998, Predecisional Enforcement Conferences (conferences) were
conducted with you, and members of your staff, to discuss the violations
identified during the first two inspections and the investigation, their
causes, and your corrective actions. With respect to the apparent violation
described in Inspection Report 98-02, sent to you on May 15, 1998,
the NRC decided that an additional enforcement conference was not needed
to discuss this issue.
Based on the information developed during the inspections and the investigation,
and the information provided during the conferences, seven violations
of NRC requirements are being cited and are described in the enclosed
Notice of Violation and Proposed Imposition of Civil Penalties (Notice).
The violations reflect fundamental performance problems related to conduct
of surveillance test activities, maintenance of accurate records, and
completion of appropriate corrective actions to preclude repetition of
problems at your facility.
The first two violations, which are set forth in Section I of the enclosed
Notice, involve the failure by your staff to perform certain surveillance
testing activities, and creation of inaccurate documents to indicate that
these activities had been performed. Specifically, your internal investigation,
as well as the OI investigation, found that a Nuclear Production Technician
(NPT) falsified surveillance test records. The records indicated that
the NPT had performed inspections of emergency battery lights in the primary
auxiliary building (PAB), as well as a second verification of two steps
in an emergency diesel generator (EDG) surveillance test. Both tests are
required by your license or Technical Specifications (TS). The investigations
revealed that the emergency battery light tests could not have been performed
as required by the test procedure, because the NPT, and another NPT who
was assigned to assist with the emergency light tests, were not in the
PAB for a sufficient period of time to complete the checks of the 33 emergency
lights. In addition, 10 days after the emergency light tests were documented
as completed, several of the emergency lights in the PAB were found to
have low water levels in the battery cells. If the tests had been performed,
this condition would have been identified, and adherence to the test procedure
would have required correction of the degraded conditions. Similarly,
the investigations concluded that the second verification of steps in
the EDG surveillance test could not have been performed because the NPT
did not enter the EDG building on the day that the activities were documented
as having been performed. These record falsifications were considered
deliberate because the evidence shows that the tests were not done, that
the NPT understood the procedures requiring performance of the tests,
and that the NPT knew that the tests were not done and admitted that he
had signed the test records.
While the NRC is concerned with the actions of the NPT in this case, of
even greater concern is the consideration that the emergency battery light
tests may not have been performed in accordance with the procedure on
multiple occasions in the last several years. The OI investigation determined
that it was not uncommon for NPTs to sign records for completion of actions
that they had not personally performed. It also indicated that the NPTs
did not have a clear understanding of their responsibility for adhering
to procedures. It appears that there was an informal attitude toward procedural
adherence among the NPTs. This is troubling as it is consistent with previously
documented procedure adherence problems. At the conference you acknowledged
that, although you had communicated management's expectations regarding
procedural adherence, you had not provided supervisory oversight in the
field to reinforce those expectations. Therefore, considering the significance
that the NRC attributes to deliberate violations of requirements, and
the lack of management attention towards licensed responsibilities that
these violations represent, the violations set forth in Section I of the
Notice are classified in the aggregate as a Severity Level III problem
in accordance with the "General Statement of Policy and Procedure for
NRC Enforcement Actions," NUREG-1600 (Enforcement Policy).
The third violation, which is set forth in Section II of the enclosed
Notice, involved your failure to determine the cause and take adequate
corrective actions to preclude repetition of a significant condition adverse
to quality involving 480 volt (V) safety-related circuit breakers. Specifically,
between August 1993 and May 1997, there were multiple instances in which
Westinghouse DB-50 480V circuit breakers failed to close on demand. Although
you had recently upgraded your root cause analysis process in response
to previously identified weaknesses in your corrective action processes,
the root cause analysis for the DB-50 breaker failures performed using
the new process was inadequate for the following reasons. In May 1997,
you assembled a team, and hired contractors with expertise on Westinghouse
DB-50 circuit breakers to conduct a root cause analysis, using the upgraded
process, of the recurring breaker failures. The root causes identified
by the team were not clearly supported by the "as found" condition of
the breakers. More importantly, because your root cause analysis focused
on restoration of the original design basis of the breakers, and did not
consider potential deficiencies in the original design, the analysis did
not address all credible failure modes that could have prevented the breakers
from closing. As a result, although you initiated corrective actions in
July 1997 based on the results of the team's root cause analysis, additional
breaker failures occurred in August 1997 and October 1997.
The potential safety consequences of the DB-50 breaker failures are significant
because approximately 60 DB-50 breakers are installed at Indian Point
2 and are used to provide power to safety-related loads, including the
containment spray pumps, auxiliary boiler feedwater (AFW) pumps, residual
heat removal pumps, and safety injection pumps. In many cases, these breakers
are relied upon to close automatically, such as in response to a safety
injection signal or upon the occurrence of a loss of offsite power. Failure
of the breakers to close on demand would require operator action to reset
and manually reclose the breaker to restore the equipment to service.
Therefore, given the potential safety consequences of the breaker failures,
as well as your continuing difficulties in implementing effective corrective
action processes, this violation is also classified at Severity Level
III in accordance with the Enforcement Policy.
The fourth violation, which is set forth in Section III of the Notice,
involved the failure to assure that all testing, required to demonstrate
that systems and components will perform satisfactorily in service, as
specified in the TSs, was incorporated into surveillance test procedures.
In February 1998, you conducted a review of the TS surveillance program
which identified approximately 170 discrepancies between the TS testing
requirements and the surveillance test procedures. These discrepancies
included cases in which: (1) the TS surveillance requirement or TS basis
statements did not match the plant design; (2) no surveillance test existed
to implement a TS requirement; (3) the surveillance test acceptance criteria
were not consistent with the TS, or lacked supporting engineering analysis
to document the basis for the criteria; (4) surveillance tests were not
performed at the required frequency specified in TS; and (5) inconsistencies
existed within TS surveillance requirements. The NRC also identified some
additional discrepancies while evaluating your review process. Collectively,
these discrepancies represent a programmatic weakness in implementing
TS requirements; therefore, this violation is classified at Severity Level
III in accordance with the Enforcement Policy.
A base civil penalty in the amount of $55,000 is considered for each Severity
Level III violation or problem. Since Indian Point 2 has been the subject
of escalated enforcement actions within the last 2 years,(1)
the NRC considered whether credit was warranted for Identification
and Corrective Action in accordance with the civil penalty assessment
process in Section VI.B.2 of the Enforcement Policy for each of the Severity
Level III violations and problem. With respect to the violations in Section
I, credit for identification is not warranted. Although you identified
the violations during your investigation, that investigation was conducted
as a result of NRC identification of the degraded battery conditions.
With respect to the violation in Section II, credit for identification
is not warranted because the failure to preclude recurrence of the DB-50
breaker failures was self-revealing when the additional breaker failures
occurred, and the NRC subsequently identified the deficiencies in your
root cause analysis. With respect to the violation in Section III, credit
is warranted for identification because the vast majority of the testing
discrepancies were identified by your review effort. For all of the violations
in Sections I, II, and III, credit is warranted for your corrective actions
because those actions were considered prompt and comprehensive. These
actions included: (1) review of other surveillance test records to ensure
that all required tests had been performed; (2) discussions with plant
staff to emphasize management's expectations for procedure adherence and
documentation of activities; (3) revisions to the emergency battery light
test procedure; (4) development of a NPT training program; (5) additional
analysis of the DB-50 breaker failures; (6) implementation and testing
of DB-50 breaker design modifications; (7) improvements to your root cause
analysis process including training of team members and improved use of
industry experience; and (8) testing, procedure revisions, and changes
to TSs to address the testing deficiencies. The NRC plans to continue
to follow your actions closely to determine the effectiveness of your
actions in precluding future problems.
Based on the above, separate $55,000 civil penalties are warranted for
the Severity Level III problem in Section I and the Severity Level III
violation in Section II of the enclosed Notice. Therefore, to emphasize
the importance of (1) performing activities in accordance with procedures
and accurately documenting such performance, and (2) preventing recurrence
of problems at the facility, I have been authorized, after consultation
with the Office of Enforcement, to issue the enclosed Notice of Violation
and Proposed Imposition of Civil Penalties in the cumulative amount of
$110,000 for the violations in Sections I and II of the Notice. No civil
penalty is warranted for the violation in Section III of the Notice.
Three other violations identified during the inspections have been classified
individually at Severity Level IV and are set forth in Section IV of the
enclosed Notice. These violations involved the failure to take prompt
corrective actions for identified deficiencies in the post accident containment
vent (PACV) and hydrogen recombiner systems and an inadequate procedure
for operation of the PACV system.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response. As provided
for in the enclosed Notice, you are required to include a description
of the reasons for the violations, if admitted, and your corrective action.
This description should address the actions taken following identification
and the long term comprehensive actions taken or that will be taken to
prevent recurrence. Your response should be submitted under oath or affirmation
and may reference or include previous docketed correspondence if the correspondence
adequately addresses the required response. In addition, if you dispute
any of the enclosed violations or their severity levels, you should describe
the basis for the dispute in your response. The NRC will use your response,
in part, to determine whether further enforcement action is necessary
to ensure compliance with regulatory requirements.
With respect to the violation set forth in Section III of the enclosed
Notice, based on the information developed during the inspection, the
NRC had sufficient information to conclude that a civil penalty is not
warranted; therefore, this action is being issued without holding a predecisional
enforcement conference. If the NRC is satisfied with your response to
this violation, you will be notified that this enforcement action is completed.
However, if your corrective action, as documented in your required response,
is not sufficiently prompt and comprehensive such that a civil penalty
may be warranted, we may telephone you or schedule a predecisional enforcement
conference with you. Further, you may request that an enforcement conference
be held to discuss this violation, in which case, please advise Mr. John
Rogge at (610) 337-5146 within seven days of the date of this letter.
In the absence of such a request but where matters are disputed, we may
also elect to hold an enforcement conference. In the event that a conference
is to be held, it will be scheduled at least two weeks after receiving
the written response to the Notice. Following review of any disputes and
the record of the conference, if held, a decision will be made to modify,
withdraw, or affirm the Notice and, if warranted, issue a civil penalty.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy
of this letter, its enclosure, and your response will be placed in the
NRC Public Document Room (PDR).
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Sincerely, |
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Original
Signed by |
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Hubert
J. Miller
Regional Administrator |
Docket No. 50-247
License No. DPR-26
Enclosure: Notice of Violation Proposed Imposition of Civil Penalties
NOTICE OF VIOLATION AND
PROPOSED IMPOSITION OF CIVIL PENALTIES
Consolidated Edison Company
of New York, Inc.
Indian Point 2 Nuclear Generating Station |
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Docket No. 50-247
License No. DPR-26
EA Nos.: 97-576; 98-028; 98-056; 98-192 |
During NRC inspections conducted between
October 27, 1997 and March 23, 1998, for which exit meetings were held
on November 14, 1997, and January 23, January 30, and April 23, 1998,
and during an investigation conducted by the NRC Office of Investigations
(OI) from September 25, 1997, until January 22, 1998, violations of NRC
requirements were identified. In accordance with the "General Statement
of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the
Nuclear Regulatory Commission proposes to impose civil penalties 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 violations and associated
civil penalties are set forth below:
I. |
VIOLATIONS
RELATED TO INACCURATE INFORMATION
10 CFR 50.9 requires, in part, that information required by the
Commission's regulations to be maintained by the licensee shall be
complete and accurate in all material respects.
Technical Specification Section 6.8.1 requires written procedures
be implemented covering activities referenced in Regulatory (Safety)
Guide 1.33, November 1972. Appendix A of Regulatory Guide 1.33, recommends,
in part, written procedures for performance of surveillance tests
and for record retention.
Station Administrative Order (SAO)-521, "Records Management Program,"
provides instructions for the identification and storage of completed
records. Section 4.1 of SAO-521, requires, in part, that quality assurance
records be maintained in accordance with ANSI N45.2.9-1994, "Requirements
for Collection, Storage, and Maintenance of Quality Assurance Records
for Nuclear Power Plants." Appendix A, Section A.6.1 of this document,
specifies retention of records dealing with periodic checks, inspections,
and calibrations performed to verify surveillance requirements are
being met.
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A. |
Consolidated
Edison surveillance test PT-M49B, "Appendix R Emergency Lighting (Nuclear),"
provides instructions for monthly checks of the emergency battery
lighting required by the NRC-approved fire protection program required
by License Condition 2.K. PT-M49B provides instructions for inspections
of 33 emergency battery lights in the primary auxiliary building (PAB)
and requires signatures for completion/performance of all procedure
steps.
Contrary to the above, on August 8, 1997, the emergency
battery lights in the PAB were not tested in accordance with PT-M49B,
yet records were created that indicated that the lights had been tested.
Specifically, a Nuclear Production Technician (NPT) signed that he
had completed all of the checks required by PT-M49B. However, on August 8, 1997,
the NPT was only in the PAB for a period of 15 minutes and the other
NPT assigned to assist with the checks was only in the PAB for a period
of 17 minutes; it is not possible to complete all the checks of the
33 emergency battery lights in a period of 32 minutes. These records
were material because they indicate whether certain required safety
activities had been completed. (01013)
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B. |
Consolidated Edison surveillance
test PT-W1, "Emergency Diesel Generator," establishes a weekly surveillance
test of the emergency diesel generator auxiliaries. Steps 3.4.1 and
3.5.2 of PT-W1 require double verification that the steps have been
performed and require that the double verification be documented.
Contrary to the above, on August 8, 1997, the double verifications
of steps 3.4.1 and 3.5.2 of PT-W1, which involved checks of the diesel
generator compressor, were not performed, yet records were created
that indicated that the second verifications had been performed. An
NPT signed the data sheet indicating that he had performed the second
verification of the steps; however, the NPT did not enter the emergency
diesel generator building on August 8, 1997. Therefore, he could not
have performed the second verifications. These records were material
because they indicate certain required safety activities had been
completed when in fact they had not been completed. (01023)
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These violations represent
a Severity Level III problem. (Supplement VII).
Civil Penalty - $55,000.
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II. |
VIOLATION RELATED TO
DB50 BREAKERS
10 CFR Part 50 Appendix B, Criterion XVI, "Corrective Action," requires,
in part, that measures shall be established to assure that conditions
adverse to quality, such as failures, deficiencies, and deviations,
defective material and equipment are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures
shall assure that the cause of the condition is determined and corrective
action taken to preclude repetition.
Contrary to the above, between August 1993 and October 14, 1997, the
licensee failed to determine the cause and take corrective action
to preclude repetition of a significant condition adverse to quality
involving failures of safety-related electrical breakers. Specifically,
a root cause analysis performed in June 1997 to address multiple recurring
failures of Westinghouse DB-50 breakers (that occurred between August
1993 and May 1997) was inadequate in that the analysis did not address
all credible failure modes that could have prevented the breakers
from closing. For example, the analysis did not address inadequate
weight on the trip bar as a credible failure mode. In addition, the
identified causes (malfunctioning amptectors and binding of the operating
mechanisms due to accumulated dust, dirt, and lubricant) were not
supported by the facts (e.g., there was little evidence of dust and
hardened lubricant), and it was later determined that these factors
were not significant contributors to the failures. As a result, corrective
actions taken in July 1997 failed to preclude repetition of failures
of DB-50 circuit breakers on August 13 and October 14, 1997. The failure
of these breakers is considered a significant condition adverse to
quality because it could prevent safety-related equipment from starting
during an accident. (02013)
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This violation is classified
at Severity Level III (Supplement I).
Civil Penalty - $55,000.
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III. |
VIOLATION RELATED TO
TECHNICAL SPECIFICATION SURVEILLANCE TESTING
10 CFR Part 50, Appendix B, Criterion XI, "Test Control," requires,
in part, that a test program be established to assure that all testing
required to demonstrate that systems and components will perform satisfactorily
in service is identified and performed in accordance with written
test procedures which incorporate the requirements and acceptance
limits contained in applicable design documents.
Contrary to the above, prior to January 1998, the Technical Specification
(TS) surveillance test program did not assure that all testing required
to demonstrate that systems and components will perform satisfactorily
in service as specified in the plant technical specifications was
incorporated into test procedures. Examples of deficiencies in the
surveillance test program included:
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1) |
No surveillance test existed
to assure that the requirements of TS 4.4.D.2.b, governing service
water in-leakage into containment in the event of a loss of fan cooler
unit integrity, were met;
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2) |
No surveillance test existed
to verify that the steam generator blowdown valves isolate during
an automatic initiation of auxiliary feedwater as required by TS Table
4.1-1, Item 30;
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3) |
No procedural requirements
existed to calibrate the service water inlet temperature monitoring
system prior to service water temperature exceeding 80 degrees F,
as required by TS Table 4.1-1, Item 45; and
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4) |
Surveillance procedure
PT-V16 only required a differential pressure of greater than 100 psid
while performing leak testing across certain reactor coolant system
pressure isolation valves, although TS 4.16.A.5, requires that a minimum
differential pressure of 150 psid across the valves being tested.
(03013)
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This violation is classified
at Severity Level III (Supplement I).
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IV. |
VIOLATIONS RELATED TO
CONTAINMENT ATMOSPHERE CONTROL
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A. |
10 CFR Part 50 Appendix
B, Criterion XVI, in part, requires that measures shall be established
to assure that conditions adverse to quality, such as failures, malfunctions,
deficiencies, deviations, defective material and equipment are promptly
identified and corrected.
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1. |
Contrary to
the above, as of December 31, 1997, measures were not established
to assure that conditions adverse to quality identified in work orders
on the Post Accident Containment Venting System (PACVS) were promptly
corrected. Specifically, on October 19, 1993, work order 93-67432
identified that a flow meter (FM-1249) indicated incorrectly, and
on February 1, 1995, work order 95-75719 identified that
flow integrator (FZ-1249) was not responding to input signals. This
equipment is needed to permit the proper operation of the system as
directed in its associated system operating procedure (SOP). However,
these deficiencies were not corrected as of December 31, 1997. (04014)
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2. |
Contrary to the above,
as of December 31, 1997, measures were not established to assure that
conditions adverse to quality identified in work orders on the hydrogen
recombiners were evaluated and either promptly corrected or adequately
compensated for until corrective actions could be effected. Specifically,
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a. |
On October 22, 1994, work
order 94-74545 identified that repair/replacement of the 21 hydrogen
recombiner RC-1A ratio control was needed.
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b. |
On October 23, 1996, work order 96-86886
identified that the 22 hydrogen recombiner hydrogen pressure gauge
(PI)-5B was pegged high.
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c. |
On April 8, 1997, work order 97-90343
identified that the 22 hydrogen recombiner low pressure alarm was
not working as a result of its associated pressure switch being broken.
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These
deficiencies could have impacted the operability of safety-related
equipment required to be operable in accordance with Technical Specifications.
However, these deficiencies were not corrected as of December 31,
1997. (05014)
This violation is classified at Severity Level IV (Supplement I).
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B. |
TS 6.8.1 requires that
written procedures be established covering activities referenced in
Regulatory (Safety) Guide 1.33, November 1972. Appendix A of Regulatory
(Safety) Guide 1.33 recommends written procedures that govern operation
of safety-related systems including containment cleanup systems. An
example of a procedure to operate a containment cleanup system is
System Operating Procedure (SOP) 10.9.2, "Post Accident Vent System
Operation."
Contrary to the above, until corrected by revision on October 20,
1997, SOP 10.9.2 was inadequate because it did not reflect the proper
containment pressure for system operation. The technical specification
basis for the post-accident containment vent system (PACVS) states
that a minimum internal containment pressure of 2.14 psig is required
for the system to operate properly. The Updated Final Safety Analysis
Report, section 6.8.2.2, states that the PACVS requires a differential
pressure between the containment and the outside atmosphere in order
to permit venting and that this is based on a pressure of 2.14 psig
in the containment. However, step 2.6 of SOP 10.9.2 stated that the
minimum containment pressure for proper operation of the PACVS was
0.5 psig. Also, steps 4.1.9, 4.2.1, and 4.2.2, referenced the incorrect
pressure value of 0.5 psig. (06014)
This violation is classified Severity
Level IV (Supplement I).
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Pursuant to the provisions of 10 CFR 2.201,
Consolidated Edison Company of New York, Inc. (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
receipt of this Notice of Violation and Proposed Imposition of Civil Penalties
(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, (2) the reasons for the violation
if admitted, and if denied, the reasons why, (3) the corrective steps
that have been taken and the results achieved, (4) the corrective steps
that will 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 or a Demand for Information
may be issued as to 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.
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
addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, with a check, draft, money order, or electronic transfer 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, 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 penalties will
be issued. Should the Licensee elect to file an answer in accordance with
10 CFR 2.205 protesting the civil penalties, 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 penalties should not be
imposed. In addition to protesting the civil penalties in whole or in
part, such answer may request remission or mitigation of the penalties.
In requesting mitigation of the proposed penalties, the factors addressed
in Section VI.B.2 of the Enforcement Policy 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 that 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 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 response noted above (Reply to Notice of Violation, letter with payment
of civil penalty, and Answer to a Notice of Violation) should be addressed
to: Mark Satorius, Deputy Director, Office of Enforcement, U.S. Nuclear
Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville,
MD 20852-2738, with a copy to the Regional Administrator, U.S. Nuclear
Regulatory Commission, Region I, and a copy to the NRC Senior Resident
Inspector at the facility that is the subject of this Notice.
Because your response will be placed in the NRC Public Document Room (PDR),
to the extent possible, it should not include any personal privacy, proprietary,
or safeguards information so that it can be placed in the PDR without
redaction. If personal privacy, proprietary, or safeguards information
is necessary to provide an acceptable response, then please provide a
bracketed copy of your response that identifies the information that should
be protected and a redacted copy of your response that deletes such information.
If you request withholding of such material, you must specifically
identify the portions of your response that you seek to have withheld
and provide in detail the bases for your claim of withholding (e.g., explain
why the disclosure of information will create an unwarranted invasion
of personal privacy or provide the information required by 10 CFR 2.790(b)
to support a request for withholding confidential or financial information).
If safeguards information is necessary to provide an acceptable response,
please provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice
within two working days.
Dated at King of Prussia, Pennsylvania
this 6th day of July 1998
1. e.g., A Notice of Violation and Proposed
Imposition of Civil Penalties in the amount of $110,000 was issued on
October 7, 1997 (EA 97-367), and a Notice of Violation and Proposed Imposition
of Civil Penalties in the amount of $205,000 was issued on May 27, 1997
(EAs 96-509, 97-031, 97-113, and 97-191). Both of these actions included
violations for failure to identify and correct problems at the facility.
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