IR 05000237/1986015
| ML17199G450 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/23/1987 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Oconnor J COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17199G471 | List: |
| References | |
| EA-87-026, EA-87-26, NUDOCS 8704280576 | |
| Download: ML17199G450 (4) | |
Text
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Docket Nos. 50-237; 50-249 Licenses No. DPR-19; DPR-25 EA 87-26 Commonwealth Edison Company ATTN:
Mr. James J. O'Connor President Post Office Box 767 Chicago, IL 60690 Gentlemen:
APR 2 3 1887 SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORTS NO. 50-249/86009, 50-249/86012 AND 50-237/86015, AND 50-249/86017)
This refers to three NRC safety inspections that were conducted by personnel from the Office of Inspection and Enforcement, Region III, and consultants, of activities at Dresden Nuclear Power Station authorized by NRC Licenses No. DPR-19 and No. DPR-2 During the inspections, numerous violations of NRC requirements were identifie The subject Inspection Reports No. 50-249/
86009, 50-249/86012, and 50-237/86015, and 50-249/86017 were sent to you on t/ 1 May 29, October 17, and June 30, 1986, respectivel An enforcement conference was held on February 26, 1987 with you and your staff to discuss the inspection findings and your corrective action The inspections were conducted between December 2, 1985-July 16, 1986, and took place at the Dresden Station, your corporate offices, and the offices of contractors responsible for engineering activities related to facility modifi-cations at Dresde The inspections were part of a trial NRC program that was implemented to examine the adequacy of licensee management and control of modifications performed during scheduled major plant outage The purpose of the inspections was to examine, on a sampling basis, the detailed design and engineering that was required to support modifications as well as the installa-tion and testing of plant modifications accomplished during the October 1985 to July 1986 outage at Dresden, Unit The violations in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) are considered significant because, when evaluated collectively, they identify a major weakness in the modification area and include:
(1) design change control, (2) installation of equipment, (3) proce-dures and instructions, (4) QA/QC overview of modification activities ;
(5) corrective action implementation, and (6) control of testin These violations demonstrate a need for licensee management involvement in the plant CERTIFIED MAIL RETURN RECEIPT REQUESTED 8704280576-870423------- -,
PDR ADOCK 05000237
G PDR
, I
Commonwealth Edison Company
APR 2 3 1987 modification area to ensure that adequate controls are available and being implemente The violations listed in the Notice are representative of the approximately 90 violations that were identified in the inspection report Although only selected examples of the violations were presented in the Notice in the interest of clarity, you are required to respond in the manner described in this letter and Notice to each of the violations and deficiencies set forth in both the Notice and inspection report To emphasize the need for licensee management to remain actively involved in implementing effective modifications and corrective action programs, I have been authorized, after consultation with the Director, Office of Enforcement and Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Twenty-Five Thousand Dollars ($25,000) for the violations described in the enclosed Notic In accordance with the 11General Statement of Policy and Procedure for NRC Enforcement Action, 11 10 CFR Part 2, Appendix C (1987)
(Enforcement Policy), the violation has been categorized in the aggregate as a Severity Level III proble The escalation and mitigation factors in the Enforcement Policy were considere The base value of a civil penalty for a Severity Level III violation or problem is $50,00 The NRC Enforcement Policy allows for reduction of a civil penalty under certain circumstance In this case, the base civil penalty is reduced by 50 percent because of the unusually prompt and extensive corrective actions being taken to prevent reoccurrence and upgrade the overall modification process and management control You are required to respond to the enclosed Notice and should follow the instructions specified in the enclosed Notice when preparing your respons Your response should be directed at the following three area First, ycu should confirm the completeness of the actions taken to correct the violations cited in the Notice as well as additional examples of similar violations described in the subject inspection report Second, you should address how you have changed or strengthened the implementing procedures to preclude similar violations in these subject areas in the futur Third, you should describe the steps you have taken to ensure that continuing attention by management will be provided to prevent recurrence of these kinds of failure We note that you have, in some cases, already addressed these concerns in previous correspondenc Therefore, in your response you may reference previous submittals where appropriat After reviewing your response to the Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with 10 CFR 2.790 of the NRC's 11 Rules of Practice, 11 Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room.
' I
Commonwealth Edison Company
APR 2 3 1987 The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51 Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/enclosure:
D. L. Farrar, Director of Nuclear Licensing J. Eenigenburg, Plant Manager DCS/RSB (RIDS)
Licensing Fee Management Branch Resident Inspector, RIII Richard Hubbard J. W. McCaffrey, Chief, Public Utilities Division RIII No~s/jaw q~1\\i1
Sincerely, A. Bert Davis Regional Administrator
Commonwealth Edison Company DISTRIBUTION:
SECY J. Taylor, DEDRO J. Lieberman, OE A. B. Davis, RIII J. Goldberg, OGC Enforcement Directors, RII-III Enforcement Officers, RIV-V T. Murley, NRR F. Ingram, PA J. Bradburne, CA E. Jordan, AEOD B. Hayes, DI S. Connelly, DIA P. Robinson, OE R. Cunningham, NMSS D. Nussbaumer, OGP/SP OE File (3 copies + ltrhd)
APR 2 3 1987
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