ML19280D522
| ML19280D522 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/15/1983 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Pollock M LONG ISLAND LIGHTING CO. |
| Shared Package | |
| ML19280D524 | List: |
| References | |
| EA-83-020, EA-83-20, NUDOCS 8308040183 | |
| Download: ML19280D522 (3) | |
Text
DcS JUL 15 ES3 IE FILE COPY Docket No.
50-322 EA 83-20 Long Island Lighting Company ATTN:
Mr. M. S. Pollock Vice President - Nuclear 175 East Old Country Road Hicksville, NY 11801 Gentlemen:
This refers to the two letters, both dated May 12, 1983, from Long Island Lighting Company in response to the Notice of Violation and Proposed Imposition of Civil Penalty sent to you with our letter dated April 12, 1983.
Our letter and Notice described a violation identified during an NRC inspection conducted between November 30, 1982 and December 31, 1982 of activities at the Shoreham Nuclear Station.
After careful consideration of your response, we have concluded for the reasons given in the enclosed Order and Appendix that the criteria for categorizing severity levels, as defined in the NRC Enforcement Policy (10 CFR 2, Appendix C) were properly applied in classifying the violation at severity level III.
In addition to your request for reclassification of the severity level of the violation, we have also given careful consideration to your request for withdrawal or reduction of the proposed penalty.
We have concluded that a sufficient basis for mitigation of the proposed penalty was not provided in your response.
The significant concern in this case is the fact that individuals and a test group in your organization approved the results of a test performed to confirm a safety system's capability of meeting design safety requirements, when, in fact, official test results indicated that acceptance criteria had not been satisfied.
Specifically, the Test Engineer, Lead Startup Engineer, Startup
~ Manager, and Joint Test Group (JTG) all approved the test results during the preoperational testing review process.
Additionally, an Operational Quality Assurance (0QA) inspector witnessed the test and signed the test documentation.
A second 0QA inspector signed the test documentation accepting the results.
As indicated in our letter of April 12, 1983, we recognize that at the time this violation was identified by the NRC, additional audits / reviews of the completed test results by CQA and the Review of Operations Committee (ROC) had not been performed.
Nonetheless, multiple approvals by independent individuals of test results which oa not satisfy acceptance criteria is of significant concern to the NRC.
We are also concerned about the Test Engineer's use, to determine the acceptability of the test, of additional data taken from the strip chart recorders which was not a part of the approved test procedure nor documented in the test procedure as a change.
Therefore, the violation was properly classified at severity level III.
CERTIFIED MAIL liETURN RECEIPT RE00ESTED 8308040183 830715 PDR ADOCK 05000322 G
2 We have also considered your request that the civil penalty be reduced because of unusually prompt and extensive corrective actions.
Although your actions were appropriate for the circumstances, we do not consider your action in response to this violation, which was identified by the NRC in December 1982, as " unusually prompt and extensive." Therefore, no reduction of the civil penalty is proposed.
Adequate reasons have not been provided by Long Island Lighting Company for not imposing the proposed civil penalty for this violation.
Accordingly, we hereby serve the enclosed Order on Long Island Lighting Company imposing a civil penalty in the amount of Forty Thoussnd Dollars.
We will review the effectiveness of your corrective actions already taken and those proposed during a subsequent inspection.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosure will be place in the NRC's Public Document Room.
Sincerely, e/
oung,<' rector Richard C. D Office of ispection and Enforcement
Enclosures:
1.
Order Imposing a Civil Monetary Penalty 2.
Appendix - Evaluation and Conclusions cc w/ encl:
J. Rivello, Plant Manager J. L. Smith, Manager of Special Projects Director, Power Division Edward M. Barrett, Esq.
Jeffrey L. Futter, Esq.
T. F. Gerecke, Manager, QA Department Shoreham Hearing Service List Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New York
3 bcc w/ enc 1:
Region I Docket Room (with concurrences)
Senior Operations Officer (w/o encls)
DPRP Section Chief B. Bordenick, ELD R. Caruso, DOL, NRR ACRS SECY CA R. DeYoung, IE J. H. Sniezek, IE J. Axelrad, IE J. Allan, RI J. Lieberman, ELD V. Stello, DED/ROGR Enforcement Directors RI, RII, RIII, RIV, RV F. Ingram, PA J. Cummings, DIA B. Hayes, 01 H. Denton, NRR J. Crooks, AE0D G. Klingler, IE J. Taylor, IE E. Jordan, IE C. Thayer, IE IE:ES EA File ED0 Rdg File DCS RI:E&I RI:DPRP RI:DPRP RI:DETP RI:DPRP RI:DETP Holody/nm Higgins McCabe Bettenhausen Greenman T. Martin D.No O N I}g HQ: IE}dO(
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