ML15118A074
| ML15118A074 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 02/01/1996 |
| From: | Crlenjak R, Harmon P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15118A073 | List: |
| References | |
| 50-269-96-02, 50-269-96-2, 50-270-96-02, 50-270-96-2, NUDOCS 9602120130 | |
| Download: ML15118A074 (9) | |
See also: IR 05000269/1996002
Text
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0
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
Report Nos.: 50-269/96-02, 50-270/96-02 and 50-287/96-02
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC 28242-0001
Docket Nos.:
50-269, 50-270 and 50-287
License Nos.: DPR-38, DPR-47 and DPR-55
Facility Name: Oconee Units 1, 2 and 3
Inspection Conducted: January 8-25, 1996
Inspectors:
i
F
/ , (
/y,
-fo P. E. Harmon, Senior Resident Inspector
Date Signed
P. G. H
rey, Resident Inspector
A p p r o v e d b y :
_
.1Crln_
_Dt
eS
e
VV
CrlenjAk, Chief0'Daeigd
Reactor Projects Branch 1
SUMMARY
Scope:
This special inspection was conducted to review the circumstances
surrounding a spent fuel assembly being inadvertently left
withdrawn from the Unit 1/2 spent fuel pool rack from December 14,
1995, until January 8, 1996.
Results:
An apparent violation was identified involving the inadequate
control over fuel assembly movement on December 14, 1995, which
resulted in a fuel assembly being left in the fuel handling mast
for over three weeks.
Enclosure 1
9602120130 960202
PDR ADOCK 05000269
REPORT DETAILS
Acronyms used in this report are defined in paragraph 4.0.
1.0
Persons Contacted
Licensee Employees
B. Peele, Station Manager
- E. Burchfield, Regulatory Compliance Manager
D. Coyle, Systems Engineering Manager
- J. Davis, Engineering Manager
T. Coutu, Operations Support Manager
- W. Foster, Safety Assurance Manager
- J. Hampton, Vice President, Oconee Site
- D. Hubbard, Maintenance Superintendent
C. Little, Electrical Systems/Equipment Manager
J. Smith, Regulatory Compliance
G. Rothenberger, Operations Superintendent
- R. Sweigart, Work Control Superintendent
Other licensee employees contacted included technicians,
operators, mechanics, security force members, and staff engineers.
2.0
December 14, 1995, Fuel Handling Event (71707, 62703 and 93702)
2.1
Background
Oconee Units 1 and 2 have a common SFP and Unit 3 has its own separate
SFP. Each SFP is a reinforced concrete pool located in its respective
Auxiliary Building. New and spent fuel assemblies are stored inside
individual storage cells within the pool storage racks. The fuel
storage racks rest on the bottom of the SFP. Spent fuel assemblies are
manipulated within the SFP via a fuel handling bridge equipped with a
fuel handling mechanism and fuel grapple. This bridge spans the SFP and
permits access to any one of the storage rack positions. A description
of the SFPs, the SFP Cooling Systems, and the Fuel Handling System is
described in Chapter 9 of the Oconee FSAR.
A SSF exists at ONS as a standby system for use under extreme emergency
conditions. It is provided as an alternate means to achieve and
maintain hot shutdown conditions for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> on all three units
following postulated fire, sabotage, or flooding events. Loss of all
other station power is assumed for each event. The SSF is designed in
part to maintain a minimum water level above the reactor core and
maintain RCP seal cooling. RCS inventory and seal cooling is provided
by the SSF RCMU pumps (one per unit). The Unit 1 and 2 RCMU pumps take
suction from the shared Unit 1/2 SFP. The Unit 3 RCMU pump takes
suction from the Unit 3 SFP. Each affected unit's RCMU pump draws 29
gpm from its corresponding SFP.
Enclosure 1
- II2
SFP cooling is assumed to be lost at the start of an SSF event. Since
SFP cooling is not available, the temperature of the pool begins to
increase due to decay heat generated by the fuel contained in the pool.
The initial temperature of the pool, the mass of water contained in the
pool, and the rate of decay heat generation will determine how fast the
temperature of the water in the pool increases. The rate of decay heat
generation depends on the amount of fuel burn up that occurred prior to
removing the.fuel from the core, the amount of time the spent fuel has
been subcritical, and the amount of spent fuel contained in the pool.
In any case, SFP temperature will reach the boiling point well before 72
hours elapse. This boiling, in conjunction with the water being removed
by the RCMU pumps, decreases the SFP level.
The licensee does not take
any credit for water which might be returned to the SFP via the RCMU.
system recirculation line, the SSF letdown line, or condensation of
steam in the SFP room.
Based on the thermal hydraulic analysis of the SFP racks and NPSH
requirements of the RCMU pumps, the licensee has determined that the
water level in the SFP should not drop below one foot above the top of
the fuel assemblies in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (reference preliminary calculation
OSC-619). NRC Inspection Report 50-269,270,287/94-31 identified
concerns with the failure of the licensee to fully account for the high
radiation levels (approximately 2,000,000 Roentgens per hour) near the
SFP when the water level drops to one foot above the top of the spent
fuel.
This issue is still under NRC review and is being tracked under
URI 50-269,270,287/94-31-06.
2.2
Fuel Handling Event and Related Issues
On the morning of December 14, 1995, a Reactor Engineer contacted the
Fuel Handling Supervisor to request support in an inspection of a fuel
assembly in the SFP. This inspection was part of an ongoing root cause
investigation into minor damage of a fuel assembly grid strap which had
occurred during the Unit 1 EOC 16 defueling evolution. The request was
initially denied due to the scheduled work load of the Maintenance fuel
handlers. Later that morning, due to a work delay, the fuel handling
supervisor informed the Reactor Engineer that Maintenance could support
the fuel inspection after all.
The Maintenance fuel handler and the
Reactor Engineer briefly discussed the fuel inspection, but no formal
pre-job brief was conducted. The fuel assembly inspection was
essentially viewed and treated as filler or non-scheduled work.
At approximately 1:00 p.m., on December 14, 1995, the fuel handler
raised fuel assembly-NJ05T8 into the refuel bridge mast while the
Reactor Engineer video taped it. At the Reactor Engineer's direction,
the fuel handler moved the fuel assembly to an area in the pool where
the video camera could more effectively view the assembly. This fuel
assembly was then returned to its proper location and lowered back into
the rack. The Reactor Engineer then decided to inspect another assembly
S-
for further comparison of minor scratches on the lower assembly plenum.
Enclosure 1
3
Assembly NJ06E7 was selected. The fuel handler traversed the bridge and
trolley to the SFP rack location for assembly NJ06E7, grappled the
assembly and raised it to within one foot of the top o- The mast. After
raising the assembly into the mast, the fuel handler turned off the
hydraulic pump, which mechanically locks the grapple in the engaged
position. Fuel handlers routinely turn off the hydraulic pump because
of previous experiences with hydraulic line leaks and failures. The
Reactor Engineer informed the fuel handler that his inspection was
complete. The fuel handler then left the bridge to assist the Reactor
Engineer in removing the video camera. The fuel handler and the Reactor
Engineer then reviewed the video tape of the fuel assembly. After
confirming that the video was adequate, the fuel handler returned to the
bridge and secured power to the bridge. Neither individual recognized
that the fuel assembly was still withdrawn in the mast. The activity
was performed without the use of a procedure and at the direction of the
Reactor Engineer, who was performing the video taping and acting as the
independent verifier and spotter.
At approximately 11:00 a.m., on January 8, 1996, the same individual
that had operated the SFP fuel handling bridge on December 14, 1995, was
preparing to use bridge again. The individual turned the power on and
noticed on the bridge control panel that the indicated weight on the
fuel lifting hook was what would be expected when a fuel assembly was
being lifted. He determined that a fuel assembly had been left in the
mast. At that time, he and another fuel handler decided that the bundle
should not be in the mast and lowered it into its position in the rack,
and then notified the fuel handling manager.
On January 8, 1996, at approximately 3:00 p.m., the resident inspectors
were notified of the event. The inspectors reviewed the circumstances
of the two separate fuel handling evolutions. Procedures
OP/O/A/1506/01, Fuel And Component Handling, and OP/O/A/1503/09,
Documentation Of Fuel Assemblies And/Or Component Shuffle Within A Spent
Fuel Pool, were inadequate in that specific steps were not defined to
accomplish raising, repositioning, inspection, and lowering the assembly
back into its proper location in the SFP during the evolution on
December 14, 1995. Therefore, this is being identified as Apparent
Violation 269,270,287/96-02-01, Inadequate Control Over Fuel Assembly
Movement.
At approximately 6:00 a.m., on January 9, the inspectors reviewed the
SPOC manager's log and noted that the event had not been documented and
the SPOC manager was not aware of the incident. The inspectors then
reviewed the control room operator's log and learned that the event had
not been logged, and the control room operators (ROs and SROs) were not
aware of the event.
On the evening of January 8, 1996, the licensee initiated a SEIT to
review the incident. The team exited on January 12, 1996, with several
Enclosure 1
4
preliminary findings and concerns. The SEIT concluded that there were
two principal root causes for the event:
- The fuel bridge operator did not apply appropriate self-checking
measures during the December 14, 1995, fuel manipulation
- Management had not clearly defined expectations for formality in
all aspects of the fuel handling process
Other SEIT findings included:
- The event was improperly scheduled and planned
- Clear lines of responsibility were not defined
- Procedures were inadequate and were not followed
- The pre-job briefing was inadequate
- There was no written guidance for the evolution.
In addition, the team identified that the plant response to the event
was inadequate in that the assembly was lowered back into the fuel
storage rack without notification to supervision, plant management, or
the control room; notification to the NRC residents was not timely, and
the 10CFR 50.72 notification made on January 9, 1996, should have been
made earlier.
2.3
Corrective Actions
The licensee suspended all fuel handling activities until the evaluation
and recommendations from the SEIT have been formalized and corrective
actions implemented.
2.4
Recent History of Fuel Handling Errors
Under Enforcement Action 94-104 (dated August 4, 1994) the licensee was
cited for fuel handling activities when a fuel bundle was placed in the
wrong position in the reactor vessel on May 25, 1994. That citation
resulted in a civil penalty in the amount of $15,000.00 (fifteen
thousand dollars). It was the fourth citation in four years for failure
to maintain adequate control of fuel assemblies in the SFP and the
Reactor Vessel during core offload and reload activities. Also cited in
Enforcement Action 94-104 was a second violation involving the movement
of fuel assemblies to different locations within the reactor core
without a procedure.
The licensee's response to the second violation recognized that the
cause for that violation was in part due to an insufficient awareness
Enclosure 1
5
that ANY fuel movement required detailed instructions. However, the
corrective actions were limited to requiring procedures for the
placement of fuel irn the core.
2.5
Significance of the Event
The licensee evaluated an accident scenario involving the SSF where
water was supplied from the SFP. The evaluation concluded that pool
inventory could be depleted to where the thrice burned assembly
suspended in the mast, could be uncovered. The licensee evaluation also
concluded that after the assembly was uncovered, the 10 CFR, Part 100
limits could be exceeded at the site boundary. Due to this evaluation,
the licensee made a 10 CFR 50.72, 1-hour notification on January 9,
1996.
Subsequently, the licensee performed a more detailed evaluation and
determined that the 10 CFR, Part 100 limits would not have been
exceeded. The design basis event assumes that water in the SFP could be
lowered to within 1 foot above the top of the stored spent fuel.
Rough
calculations concluded that radiation levels in the SFP could reach
approximately 900,000 Roentgens per hour during the event. The licensee
has calculated that an increase of 4 percent in radiation levels above
the design basis would occur as a result of the suspended assembly being
out of the water when the borated water level was dropped to one foot
above the stored fuel.
The most recent licensee analysis also indicated
that the fuel clad of the specific fuel assembly involved in the event
would not be breached upon being uncovered. However, a different
assembly might in fact have experienced clad failure, which would result
in release of the fuel assembly gap activity.
3.0
Exit Interview
The inspection scope and findings were summarized on January 25, 1996,
with those persons indicated by an asterisk in paragraph 1. The
inspectors described the areas inspected and discussed in detail the
inspection results. A listing of inspection findings is provided.
Proprietary information is not contained in this report. Dissenting
comments were not received from the licensee.
Item Number
Status
Description and Reference
Apparent Violation
OPEN
Inadequate Control Over Fuel
269,270,287/96-02-01
Assembly Movement (paragraph 2.2).
4.0
End-Of-Cycle
Fuel Assembly
Final Safety Analysis Report
GPM
Gallons Per Minute
Enclosure 1
6
Net Positive Suction Head
NI
Nuclear Instrument
Oconee Site Calculation
RCMU
Reactor Coolant Makeup
Reactor Coolant Pump
Reactor Operator
SEIT
Significant Event Investigation Team
Single Point Of Contact
Senior Reactor Operator
Spent Fuel Pool
SSF
Standby Shutdown Facility
Unresolved Item
Enclosure 1
34386
Federal Register / Vol. 60. No. 126 / Friday, June 30, 1995 / Notices
factors in arriving at the appropriate
isnothold,thelicenseewillnormally
isamatterof publicrecordsuchasan
severity level will be dependent on the
be requested to provide a written
adjudicatory decision by the
circumstances of the violation.
r
an inspection report, if
Department of Labor. in addition. with
However, if a licensee refuses to correct
issued, as to the licensee's views on the
the approval of the Executive Director
a minor violation within a reasonable
apparent violations and their root
for Operations, conferences will not be
time such that it willfully continues, the causes and a description of planned or
open to the public wher good cause has
violation should be categorized at least
implemented corrective action.
been shown after balancing the benefit
at a Severity Level IV.
During the predecisional enforcement
of the public observation against the
D. ioltins
f Rpotin Reuiemul-conference, the licensee, vendor, or
potential impact on the agency's
D. Violations of Reporting Requirementsbe
given an
in a particular case.
The NRC expects licensees to provide
opportunity to provide information
As soon as it is determined that a
complete, accurate, and timely
consistent with the purpose of the
conference will be opento public
information and reports. Accordingly,
conference, including an explanation to
observation, the NRC will notify the
unless otherwise categorized in the
the NRC of the immediate corrective
licensee that the conference will be
Supplements, the severity level of a
actions (if any) that wer taken
open to public observation as part of the
violation involving the failure to make
following identification of the potential
agency's trial program Consistent with
a required report to the NRC will be
violation or nonconformance and the
the agency's policy on open meetings
based upon the significance of and the
longterm comprehensive actions that
"Staff Meetings Open to Public."
circumstances surrounding the matter
were taken or will be taken to prevent
published September 20,1994(59 FR
that should have been reported.
rerence. Licensees, vendors, or other
48340). the NRC intends to announce
However, the severity level of an
persos will be told when a meeting is
open conferences normally at least 10
untimely report, in contrast to no report, a predsional enforcement conference.
working days in advance of conferences
may be reduced depending on the
A predecisional enforcement
through (1) notices posted in the Public
circumstances surrounding the matter.
conference is a meeting between the
Document Room. (2) a toil-free
A licensee will not normally be cited for
NRC and the licensee. Conferences are
telephone recording at 800-952-674.
a failure to report a condition or event
normally held in the regional offices
and (3) a toll-free electronic bulletin
unless the licensee was actually aware
and ar not normally open to public
board at 800-452-0678. In addition, the
of the condition or event that it failed
observation. However, a trial program is
NRC will also issue a press relse and
to report. A licensee will, on the other
being conducted to opn approximately
notify appropriate State liaison officers
hand, normally be cited for a failure to
25 percent of all eligible conferences for
that a predecisional enforcement
report a condition or event if the
public observation. i.e., every fourth
conference has been scheduled end that
licensee knew of the information to be
eligible conference involving one of
It is open to public observation.
reported, but did not recognize that it
three categories of licensees (reactor,
The public attending open
was required to make a report.
hospital, and other materials licensees)
conferences under the trial
may
V. pedeisnnalEnfrceentwill be open to the public. Confernces
observe but not participate inth
V. Predecisional Enforcement
cneec.i
sntdta
h
ups
Coferenes
will not normally be open to the public
cneec.I
sntdta
h ups
f te fr
action being
of conducting open conferces under
Whenever the NRC has learned of the
contemplated:
the trial program is not to maximi
existence of a potential violation for
which escalated enforcement action
(1) Would be taken against an
public attendance, but rather to
whih ecaltedenorcmen acio
individual, or if the action, though not
determine whether providing the public
appears to be warranted, or r
ng
taken against an individual. turns
with opportunities to be informed of
nonconformance on the part of a
whether an individual has cmmitted
NRC activities is compatible with the
vendor, the NRC may provide an
doig
NRC's ability to exercise its regulatory
opotniyfor a predecisional
2
op -ortiuty
confe renc ithna
(2
fInves
inificant personnel
and safety responsibilities. Therefore.
enforcement conferencethe
NRC has requested
brs of the public will be allowed
licensee, vendor. or other person before
that the individual(s) involved be
access to the NRC regional offices to
taking enforcement action. The purpos
present at the conference
attend open enforcement confrencs In
of the conference is to obtain
(3) Is based on the findings of an NRC
ordance with the "Standard
information that will assist the NRC la
Office of Investi
reprt- or
operating Procedures For Providing
determining the appropriate -
-
(4) Involves
formation.
Security Support For NRC Hearings And
enforcement acon, such s: (1) A-
Privacy Act information, or information
Meetings, published November 1,1991
commn ndrsanin of facts. rookt
rceue
~monundrstadin of act. r t,1
whichb couldi be considered proprietarr'
(58 FR 55). Thesepodus
Baisses and
sed opportunities
addion con
es
not.
provide th visitors may
associated withiheapparent violations.
ormaly beN
'
lic 1f:
i
that sign
(2) a common
Of
(
-
n
i
ub
, etc., not larger than 8"
corrective action taken or planned, and
mlsdmlnistrations or
permitted. and that disruptive persons
(3) a common understanding of the
and the conference cannot be conducted
may be removed.
significance of issues and the need for
without disclosing the exposed
Members of the public at
g
lasting comprehensive corrective action.
individual's name; or
coferences will be reminded that (1
If the NRC concludes that it has
(6) The conference will be conducted
the apparent violations discussed at
sufficient information to make an
by telephone or the conference will be
predecisional enforcement conferences
informed enforcement decision, a
conducted at a relatively small
are subject to further review and may be
conference will not normally be held
licensee's facility.
subject to change prior to any resulting
unless the licensee requests it. However,
Notwithstanding meeting any of these
enforcement action and (2) the
an opportunity for a conference will
criteria, a conference may still be open
statements of views Or expressions Of
normally be provided before issuing an
if the conference involves issues related
opinion made by NRC employees at
order based on a violation of the rule on
to an ongoing adjudiatory proceeding
predecisional enforcement conferenceS,
Deliberate Misconduct or a civil penalty
with one or more intervenors or where
or the lac thereof, are not intended to
to an unlicensed person. If a conference
the evidentiary ba s for the conference
represent final eteriations or belie
8
Enclosure 2
Federal Register / Vol. 60, No. 126 / Friday, June 30, 1995 / Notices
34387
Persons attending open conferences will to be under oath. Normally, responses
management involvement in licensed
be provided an opportunity to submit
under oath will be required only in
activities and a decrease in protection of
written comments concerning the trial
connection with Severity Level I. U. or
the public health and safety.
program anonymously to the regional
III violations or orders.
office. These comments will be
The NRC uses the Notice of Violation
subsequeatly forwarded to the Director
as the usual method for formalizing the
The NRC imposes different levels of
of the Office of Enforcement for review
existence of a violation. Issuance of a
penalties for different severity level
and consideration.
Notice of Violation is normally the only
violations and different classes of
When needed to protect the public
enforcement action taken, except in
liconsees vendors and other persons.
health and safety or common defense
cases where the criteriafor issuance of
Tables IA and lB show the base civil
and security, escalated enforcement
civil penalties and orders, as set forth in
penalties for various reactor, fuel cycle.
action, such as the issuance of an
Sections VLB and VI.C. respectively, are materials and vendor programs. (Cvil
immediately effective order, will be
met. However, special circumstances
penalties issued to individuals ar
taken before the conference. In these
regarding the violation findings may
determined on a case-by-cas basi
The
cases, a conference may be held after the warrant discretion being exercised such
ructure of these tables generally takes
escalated enforcement action is taken.
that the NRC refrains from issuing a
into account the gravity of the violation
Notice of Violation. (See Section VI.B
consideration and the
VI. Efoment Actions
- litigation of Enforcement Sanctions.") abattoayv
This section describes the
In addtion, licensees are not ordinarily
c
pi as a
oa
enforcement sanctions available to the
cited for violations resulting frmgreaternucea
material
NRC and specifies the conditions under
matters not within their control, such as
inventories and greter potential
which each may be used. The basic
equipment failures that were not
conences to the public and licensee
enforcement sanctions are Notices of
avoidable by reasonable licensee quality
empoees receive higher civil
Violation, civil penalties. and orders of
assurance measures or management
penalties. Regarding the secondary
various types. As discussed further in
controls. Generally, however, licensees
factor of ability of various classes of
Section VLD. related administrative
are held responsible for the acts of their
licensees to pay the civil penalties. it is
actions such as Notices of
employees. Accordingly, this policy
not the NRCs intention that the
Nonconformance. Notices of Deviation,
should not be construed to excuse
economic impact of a civil penalty be so
Confirmatory Action Letters. Letters of
personnel errors.
severe that It puts a licensee out of
Reprimand,' and Demands for
B
ii
eat
uies(res
ahrta ii
Infomation e used to supplement the
B. Civil Penaltybis
d rhe thn
i
enforcement program. In selecting the
A civil penalty is a monetary penalty
pente mise whene
ites
enforcement sanctions or administrative
that may be imposed for violation of (1)
or
termnate licensed aiviti
actions, the NRC will consider
certain specified licensing provisions of
o adely affct licensee aiity
enforcement actions taken by other
the Atomic Energy Act or
tely condct ofcensed activties
Federal or State regulatory bodies
supplementary NRC rules or orders; (2)
Te deterent ffect
of
tie
having concurrent jurisdiction, such as
any requirement for which a license
best
e wnth amnt
o he
in transportation matters. Usually.
may be revoked: or (3) reporting
penlti to
aaon iene
whenever a violation of NRC
requirements under section 206 of the
amilit o
p
ntiin
the
requirements of more than a minor
Energy Reorganization Act. Civil
aou of cii pales
relcnsee
concern is identified, enforcement
penalties are designed to deter future
fo
hom
the
ables
o
f the
action is taken. The nature and extent of
violations both by the involved licensee
ailiy t
he rvity of th
the enforcement action is intended to
as well as by other licensees conducting violan h
e
NR
der
a
reflect the seriousness of the violation
similar activities and to emphasize the
cay
ase
as
a
involved. For the vast majority of
need for licensees to identify violationsdbs
ray
fia
violations, a Notice of Violation or a
and take prompt comprehensivehli
ee
n m
onse
Notice of Nonconformance is the normal corrective action, .ship,
te
ill
ner
action.
Civil penalties em considered for
Paetan r
aotie o
f volationSeverity
Level m violations. In addition.
A. Notice of V1olatfoa
civil penalties will normally be assessed
civil penalty. Howeve, where a licensee
A Notice of Violation is a written
for Severity Ievel I and U violations and
notice setting forth one or more
knowing and conscious violations of the will normally be required to address
violations of a legally binding
reporting requirements of section 206 of
why it has
rescuos to safely
requirement. The Notice of Violation
the Energy Reorganization Act.
licensed
ctiie a
p
normally requires the recipient to
Civil penalties are used to encourage
provide a written statement describing
prompt identification and prompt and
2 Civil Pealty
ummt
(1) the reasons for the violation or, if
comprehensive correction of violations.
contested, the basis for disputing the
to emphasize compliance in a manner
Inan effort to
violation: (2) corrective steps that have
that deters future violations, and to
ia
been taken and the results achieved; (3) serve to focus licensees' attention on
requirmentsand(2)
prm
corrective steps that will be taken to
violations of significant regulatory
self-Identification of problems and root
prevent recurrence: and (4) the date
concern.
causes and prompt and comprehensive
when full compliance will be achieved.
Although management involvement,
correction ofviolatios, the NRC
The NRC may waive all or portions of
direct or indirect. in a violation may
reviews each proposed civil penalty on
a written response to the extent relevant
lead to an increase in the civil penalty,
itsownmeritsand.after
informaton as aldy been provided
the lack of management involvement
relevant circumstances,
ad
to the NRC in writing or documented in
may not be used to mitigate a civil
basecivl penalties
an NRC inspection report. The NRC may palty. Allowing mitigation in the
and lB for severity Level!. U, and M
require responses to Notices of Violation
lrcae
could encourage the l
of
violations as described below.
9
Enclosure 2