ML17201Q447
| ML17201Q447 | |
| Person / Time | |
|---|---|
| Site: | Dresden |
| Issue date: | 05/03/1989 |
| From: | Thompson H NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Oconnor J COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17201Q448 | List: |
| References | |
| EA-87-081, EA-87-81, NUDOCS 8905080151 | |
| Download: ML17201Q447 (2) | |
Text
-,,
UNITED STATES NUCLEAR REGULATORY'COMMISSION Docket No.
LicE:nse No.
EA 87-81 50-249 DPR-25 Commonwealth Ed1son Company ATTN:
Mr. James J. O'Connor President Post Office Box 767 Chicago, Illinois 60690 Gentlemen:
WASHINGTON, D. C. 20555 MAY 0 3 1989
SUBJECT:
ORDER IMPOSING CIVIL MONETARY PENALTY (DRESDEN)
This refers to your letters dated June 28 and July 1, 1988, in response to the Notice of Violation and Proposed Imposition of Civil Penalty (Notice) sent to you by our letter dated April 29, 1988.
Our letter and Notice describe one violation of environmental qualification requirements identified by the NRC.
To emphasize the importance of environmental qualification of electrical equip-ment important to safety, a civil penalty of One Hundred Fifty Thousand Dollars
($150,000) was proposed.
In your response, you admitted that, based on testing performed during December 1986, the AMP splices involved in the violation were not environmentally quali-fied; however, you did not agree that the documentation of qualification was inadequate to demonstrate qualification.
In addition, if the NRC concluded the violation occurred, you requested mitigation of the proposed civil penalty based on the initial treatment of the issue by the NRC as a minor problem, your actions taken to test the splices, the implementation of a monitoring program for iden-tification of splice degradation, and an error in the NRC staff's determination of the lerigth of time the plant operated with unqualified splices. Further, you question the fairness of the NRC's policy to not consider operab1hty arguments in assessing the safety significance of a violation.
After consideration of your response, we have concluded, for the reasons given in the Appendix attache::d to the enclosed Order Imposing Civ i1 Monetary Pena 1 ty, that you did not provide sufficient basis for withdrawal of the violation or for mitigation of the proposed ~ivil penalty. Accordingly, we hereby strve the enclosed Order on Co111T10nw~alth Edison Company imposing a civil monetary penalty in the amount of One Hundred Fifty Thousand Dollars ($150,000).
We w111 review the effectiveness of your corrective actions during a subsequent inspection.
8905080151 890503 PDR ADOCK 05000249 Q
Conunonwealth Ed1son Company In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, T1tle 10, Code of Federal Regulations, a copy of this letter and the enclosures will b~ placed in the NRC's Public Document Room.
Sincerely,
~~:~
~~~ Executive D1re~or Nuclear Materials Safety, Safeguards, and Operations Support
Enclosure:
Order Imposing Civil Mon~tary Penalty with Appendix cc w/encl:
Cordell Re~d, Senior Vice President H. Bliss, Nuclear Licensing Manager J. Eenigenburg, Plant Manager Richard Hubbard J. w. Mccaffrey, Chief, Public Utilities Division
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