ML20004E397
| ML20004E397 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/1981 |
| From: | Pang J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20004E382 | List: |
| References | |
| NUDOCS 8106120129 | |
| Download: ML20004E397 (1) | |
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Appendix A NOTICE OF VIOLATION
'echnical Associates License No. 04-17473-01E 7051 Eton Avenue Canoga Park, CA 91303 As a result of the inspection conducted on February 12, 1981, and in
-accordance with the Interim Enforcement Policy, 45 FR66754 (October 7, 1980),
the following violation was identified:
- A.
License 04-17473-01E as amended May 2, 1977 requires a statement to accompany Geh source, and that this statement will include the sentence, "It is recommended that the source be handled with tweezers or if handled directly, then held by the edges. The source should not be opened.
If it becomes damaged, it should be wrapp?d and j
discarded.
It may be disposed of in the normal trash".
This statement is also required to comply with 10'CFR32.19(d)(3).
Contrarij to the license as amended per letter of May 2, 1977, the statements that accompany. scurces distributed by the licensee does not include the above statement.
i This is a Severity Level V Violation (Supplement VI).
Pursuant to the provisions of 10 CFR 2.201, Technical Associates is hereby required to submit to this office, within twenty-five days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance vill be achieved.
MAR 101981 dated T4 P~
J. F. PangQ Radiation Specialist Radiation Safety Branch i
l 810 612 0 \\~AT
p,R Rf C o
UNITED STATES
' "g NUCLEAR REGULATORY COMMISSION o
WASHINGTON. D. C. 20555
?,
j#
October 28, 1980 T0:
NRC Licensees, Public Officials, ani Other Interested Citizens
~
The NRC has published in the Federal Register a Proposed General Stateme.,t of Policy and Procedure for Enforcement Actions for comment and interim use (45 FR 66754), and an announcement that the NRC will hold public meetings in early December in or near Chicago, Atlanta, Philadelphia, Dallas, and Oakland (45 FR 69077).
Because of the importance of this policy statement, copies of both notices are enclosed with this letter. This will allow you sufficient time to review the proposed policy and prepare written tomments or make plans to attend one of the public meetings. The NRC is particularly interested in comments responding to a series of questions included in the notice.
The notice of the meetings--which provides dates, times, and locations--lists two sessions per meeting both of which will be open to the public.
In the first session (to be held from 1 p.m. to 5 p.m.), the NRC staff will explain in detail major sections of the proposed policy and the potential impact it may have.
Following the NRC presentation, questions and comments will be ret.ei vec'.
The public will be able to ask questions and express their views about the proposed policy during these meetings, which will be continued in the evening from 7 p.m. to 10 p.m.
Any person planning to make a presentation at one of the meetings is urged to contact the appropriate NRC regional office. The enclosed notice of meeting lists the NRC contacts.
We appreciate any assistance you may provide to assure that interested individuals are aware of the opportunity to participate in the public meeting.
If you have any questions which are not answered by the enclosures, please contact one of the individuals identified in the Federal Register notice.
ud y rp on, r
Office of Enforcement and Investigations Office of Inspection and Enforcement
Enclosures:
1.
Notice of Meetings (45 FR 69077) 2.
Policy Statement (45 FR 66754) c\\[
]
'l/
Y
_ _ _ ~,...
F:dml Regi::t:r / Vol 45. No. 203 / Friday. October 17, 1980 / Notices g;9077 Jan Strasca. NRC Region 111. 799 license activity and t pecifies the NUCLEAR REGULATORY Roosevelt Road. Glen Ellyn. IL 60137, conditions under which each COMMISSION (312) 932-2674:
enforcement sanction available to NRC Clyde Wisner. NRC Region IV. 011 Ryan would be used.
NRC Enforcement Program: Public Plaza Drive. Arlington.TX 70012.(817)
The NRC is specifically seeking Meetings 334-2841:
comment on the following:
AGENcr. Nuclear Regulato'Y James llanchett. NRC Region V.1990 N.
(1)Is the policy fair and equitable?
Commission.
California Blvd.. Walnut Creek, CA (2)la the policy understandable?
94956. (415) M3-3809.
(3) Are the Severity 1.evels ACTION: Notice of public meetings concerning NRC enforcement pobey.
Individuals not making an advance appropriate?
request may register to speak at the (4) Are the different types of activities sOMMARr. On September 4.1980, the meetings. Time for such late. scheduled
- U-enough defined? Should there be Nuclear Regulatory Commission presentations will depend on the time othus?
approved publication of a proposed available. Any further procedural rules (5) Are the distinctions among various general policy statement on enforcement needed for the proper conduct of the types of, licensees shown m, Table 1 actions for public comment and interim meetings will be announced by the app a
use.The interim pohey statement was meetmg chairman.
g 8
published in the Federal Register on II. Conduct of the meeting.-In each of level of enf reement act2ons October 7.1980 (45 FR 66754).
the above cities, public meetings will be appropriate? Should there be others?
This notice announces one. day public held from 1 p.m. to lo p.m. with a recess (7)Is the degree of discretion allowed meetings that are to be held in five from 5 p.m. to 7 p.m or to the extent to Office Directors appropnate? Should locations to obtain and consider public indicated by requests for participation.
be more flexibihty permitted?
'7 comments on the proposed enforcement The purpose of the meeting is to provide policy.
an opportunity for interested persons to g8) Are the levels of civil penalties voice their questions and comments on that require Commission involvement the proposed enforcement policy.
appropriate? Should they be higher?
Meeting Doles ondLocations Each of the meetings will follow the Lower?
He public meetings wi'l be held at same agenda:(1) Registration:(2)
(9) Are the provisions for escalated the following times and places:
introduction and opening NRC remarks; action, set forth in Table 2. appropriate?
Atlanta. Georgia on December 1.1980 in and (3) receipt of comments. Remarks Copics of the enforcement policy may Stadium flotel. 450 Capitol Ave.,
will e nsist of a summary of the be obtained by contacting the Atlanta. Georgia 30312.
enforcement policy and its individuals named above at the NRC Chicago. Illinois on December 2.1980 in implementation. The remainder o' the regional offices.
- Sheraton O'Ifare. Hotel. 6810 time will be available for interested Mannheim Road. Rosemont. Ill.
persons to ask questions and make Transcripts'of the meetings will be filed in the NRC Public Document Room, ece b 418 i llo! day Inn.
I ose ofik enforcement 171711 Street NW., Washington, DC Midtown.1311 Walnut Street.19107 policy.-Ue enforcement authority of 0555. and at the regional offices.
Irving. Texas on December 9.1980 in the Nuclear Regulatory Commission is Dated at Dethenda Md this 14th day of Holiday Inn-South. 444 W. Airport drawn from the Atomic Energy Act of October 1980.
Freeway. 75061.
1954 as amended. and the Energy Dudley Thompson.
Oakland. Califorr, a December 11 Reorganization Act of 1974. NRC 1980 in tl e flyatt nouse. 455 requires licent7 comphance with Dwcror. Off,ce of Enfomement and liegenberger Road. 94621.
regulatory requirements and takes In u stworions. Office orinspection and En'omemcef.
SUPPLEMENTARY INFORMATION:
orcemed acdon to losW I. Publicporticipation.-Any improvement in licensee performance l Dnc e sus Filed to e-am o es eml individual may make a written or oral when noncompliance is identified.
rcement acuons a aMe to E request to NRC for an opportunity to be include notices of viola @tions, orders scheduled to speak at one of the m
4 en5%8.s W n 8
,jg ga*
meetings. Each request must state (1) the identity of the speaker. (2) the length of perations. revokmg licenses or the presentation (not to exceed 15 requiring cease and desist actions and minutes). (3) organization (s) the speaker imposition of civil penalties (fines). In June 980. Pub. L 9G-295 amended the represents. and (4) a r. tailing address At mi nugy Act m raise the cnd daytime telephone number through ma mc puta%om m to which the speaker may be contacted.
- I' Requests to speak should be made at least five days in advance of the d to $.
meetings to any of the following:
The proposed policy explains how Karl Abraham. NRC Region I. 631 Park NRC intends to use these enforcement Avenue. King of Prussia. PA 19406 authorities in matters involving public (215) 337-5330; health and safety, the common defense Kenneth Clark, NRC Region 11.101 and security, and the environment.The Marietta Street. Atlanta, GA 30303 policy categorizes all violations in terms (404) 221-4503 of six levels of severity for each type of I
l b
1
i i
1 66754 Feder11 Regist:r / Vol. 45 No.196 / Tursday,0ctobir 7,1980 / Propos:d Rules NUCLEAR REGULATORY eliminated the provision limiting the
" meticulous attention to detail" 'and COMMISSION total civil penalties payable in any 30-
"high standard of compliance" 'will be day period to $25,000.
achieved. Furthermore, licensees who 10 CFR Part 2 The proposed statement of general cannot achieve and maintain adequate policy set out below (Appendix C to Part levels of protection will not be permitted Proposed General Statement of Policy
- 2) explains how the Commission will to operate."
- and Procedure for Enforcement utilize its various enforcement Actions authorities. Tne Commission is H. ega amewmk AGENCY: Nuclear Regulatory particularly interested in comments on The Commission's enforcement Commission.
the use of Table 2 (see Section IV. F).
jurisdiction is drawn essentially from the Atomic Energy Act of 1954, as ACTION: Proposed general statement of Appendix C-General Policy and amended (sections 161,188. and 234) policy.
Procedure for NRC Enforcement Actions and the Energy Reorganizaiton Act
SUMMARY
- The U.S. Nuclear Regulatory ne foH wing statement of general (sections 200 and 223).
l Commission (NRC) has under pohey and procedure explains the Section101 of the Atomic Energy Act l
consideration ths following staff.
pohcies and procedures to be followed authonzes NRC to conduct inspections proposed policy statement on by the U.S. Nuclear Regulatory and issue any orders that may be enforcement policies and procedures.
Commission and its staff in initiating necessary or desirable to promote the Th '
d I.
enf rcement actions and by presiding common defense and security or to intended to nfo censees an the officers, the Atomic Safety and protect health or to minimize danger to public of the bases for taking various Ucensing Appeal Boards, and the life or property. Section 188 authorizes enforcement actions. It is intended that Commission in reviewing these actions.
NRC to revoke licenses under certain this policy, as finally adopted, be This statement is applicable to circumstances (e.g., for material false codified as Appendix C to Part 2 of Title enf reement m matters involving the statements, in response to conditions to of the Code of Federal Regulations.
public health and safety, the common that would have warranted refusal of a Pending final adoption of the policy, the defense and security, and the license on an original application, for a envir nment.'
licensee *s failure to build or operate a Proposed Ceneral Statement of Policy facility in accordance with the terms of will be used as guidance to the NRC I. Introduction and Purpose staff in taking enforcement actions.
The goals of the NRC's enforcement of a Co ss n eg lation) lio ver.
DATE: Comments are due on or before program are:
licensees must be given an opportunity December 31,1980.
-to ensure " compliance with NRC to demonstrate or achieve compliance ADDRESSES: Send comments and regulations and license conditions"; s before a license may be revoked or suggestions to:Secretaryof the
-to obtain " prompt correction of suspended (except in cases of Commission, U.S. Nuclear Regulatory licensee weaknesses"; a willfulness or those in which the public Commission, Washington. D.C. 20555.
-to deter " future non' compliance health, interest, or safety require attention: Docketing and Service Branch.
through strong enforcement otherwise). Section 234 authorizes NRC Copies of comments may be examined measures";
- and to inipose civil penalties for the in the U.S. Nuclear Regulatory
-to encourage improvement of licensee violation of certain specified licensing Commission Public Document Room, performance, thus enhancing the provisions of the Act, rules, orders, and 171711 Street, N.W. Washington, D.C.
degree of proteciton of public health license terms implementing these FOR FURTHER INFORMATION CONTACT:
and safety, common defense and ptovisions, cnd violations for which Dudley Thompson, Executive OIYicer for security, and the environment.
licenses can be revoked.
Operations Support, Office ofInspection The Atomic Energy Act (Chapter 18) and Enforcement U.S. Nuclear To help achieve these goals, the also authorizes NRC to obtain Regulatory Commission, Washington, enf rcement program will emphasize injunctions in response to violations of D.C. 20555 (301-72-8487).
prompt and vigorous enforcement the Act (or any reguation or order issued when dealing with persons 'who are under the authority of the Act). In SUPPLEMENTARY INFORMATION:The unable or unwilling to cmply with NRC addition, the Act provides for varying criteria used b the Commission's staff j
requirements and,in an case,will levels of criminal penalties (i.e
to determine enforcement action and
" assure that a licensee will not benefit nd imprisonment) for categories of noncompliance (referred to by violating NRC regulations." 'It is the
[l[fu v o tons herefrom as" Criteria ) were first C
i
's i tent that it published on October 17,1972 (37 FR enf e ent pr gram be marked by "an (2) Any other section of the Act or any 21962) These Criteria were gg s ive e f rcement strategy that regulation or order prescr'. bed or issued subsequently modified on january 3' stronger under section 65 r subsections 161b.,
1975 (40 FR 820) and on December 1,
,n c
nt easures nd en,o m oaan 1979 (44 FR 77135). Since late 1979, the implementation that assures "that (3) The requirements set forth in the Commission has been considering the
!i e 18 m re expensive than
" "" *E ".",'aThese pol cies am Act concerning the receipt, tampering, publication of a comprehensive mp lance statement of enforcement policy Added fnten e and disclosure of Restricted Data and 888um 8 e " 0888rY trespass upon Commission installations.
urgency for the development of such a policy statement has arisen from the
' Antitrust enforcement matters will be dealt with also establishes crimmal penalties pendency, and now the enactment and on a ca.e-by. case basis.
approval of Pub. L 96-295 (approved
Tiscal Years 1942-1986 Policy. Pf anning and June 30.1980), that among other things, Pmgram Guidance (PPPC)", at para II A.3 D.
'In the AfatterofX Ray Engineering Co 1 AEC amended section 234 of the Atomic
- /d. at para ll.B.21.
Ess. 55s (1900).
.fa
,,, is, sg,,,,,,7 pga,f;, 7,,,;,, tas,,,,,,;,,,
Energy Act to raise the maximum civil eld, ai para it.A.3 b.
Inc : AEC 423. 4r.8. (1964).
penalty from $5.000 to $100.000 and
- /d. at para !!.D.2.1
'PPPC, at para II.A.2.a.
Federal Register / Vrl. 45 N1190 / Tu:sd y. Octob r 7,1980 / Propos:d Rul:s 66755 cpplicable to certain individuals of a of NRC requirements; for example, when The NRC expects licensees and firm constructing or supplying the a safety problem not previously covered applicants to provide full, complete, components of any intilization facility by a requirement is discovered. NRC timely, and accurate information and licensed under section 103 or tol[b).
imposes civil penalties, however only reports. Accordingly, unless otherwise Those individuals include any director, on the basis of a violation of an existing categorized in the Supplements, the c flicer, or employee of such firms. Under requirement.
severity level of a violation involving the failure to make a required report to the section,it would be a criminal III. Severity of Violations effense if any of these individuals "by the NRC will be based upon the cct or omission, in connection with such Regulatory requirements have varying significance of and the circumstances construction or supply, knowingly and degrees of safety, safeguards, or surrounding the matter not reported. The willfully violates or causes to be environmental significance. This policy severity level assigned to material false violated, any section of this Act (i.e the statement categorizes all violations in statements may be Severity Level 1. !! or show Atomic Energy Act of 1954, as amended) terms of six levels of severity to,ty Level 111. depending on the circumstances cny rule, regulation, or order issued their relative importance. Severi surrounding the statement. Similarly, thereunder, or any license condition.
I has been assigned to violations that failure to make a required Part 21 report which violation results, or if undetected are the most sigmficant; Seventy Level may be assigned Severity Level I,11 c.r could have resulted,in a significant VI violations are the least significant.
- gig, g y ic component g Severity L.evels I,11. and111 comprise
,""acili y violations that are of significant IV. Enforcement Actions regulatory concern. In general.
This section describes the A basic component"is defined in s alations that are included in these enforcement sanctions available to NRC section 223 generally along the lines of 8 venty categories involve actual or and specifies the conditions under the definition in 10 CFR Part 21. Part 21 h'igh potential impact on the pubhc.
which each is to be used.The basic implements section 200 of the Energy Severity Level /V violations include sanctions are notices of violation, civil Reorganization Act of 1974. Section 200 degradation of engineered systems or penalties, orders of various types, and (f the Energy Reorganization Act cuthorizes NRC to impose a civil management control systems designed the less formal enforcement. mechanisms to assure proper plant construction or to such as bulletins and immediate action penalty in an amount equal to that detect, prevent, or mitigate an event, letters.
cuthorized by section 234 of the Atomic 0 u h se port t a$se o s nif a A. Notice of Violation
,,,e ves are kno safety de et i license c ncern, they are the sort of violations A Notice of Violation is a written facilities or activities. Section 206 has an that,ifleft uncorrected, could lead to notice setting forth one or more cpproach similar to section 223, but matters of significant concern. Severity violations of a legally binding section 200 does not provide for criminal Level V covers other less serious requirement. The notice requires the penalties and is not as limited in scope vi lations that are of other than minor licensee to provide a written statement.
es is the language in section 223."
c neern.SeverityLevel VIdefines normally under oath, describing All alleged or suspected criminal vi lations oat are of minor concem.
corrective actions taken (or planned).
violations of the Atomic Energy Act are Decause of the considerable the results achieved, the date when full
'nvestigated by the Federal Bureau of differences in the types of activities compliance will be achieved, and Inve.stigation of the Department of regulated by the NRC, violations of corrective action to prevent r=currence.
y regulatory requirements have been NRC uses the notice of violation as ommission hss implemented the scaled according to their relative the standard method for formally,
e snforcement provisions of the Atomic importance within each of the following recording the existence of a violation.
Energy Act and the Energy seven areas:
The notice may be the only enforcement Reorganization Act by regulations set (1) Reactor Operations (Supplement I),
cction taken or it may be used as a bas,s i
r in 10 C Part 2 i 2
(2) Facility Construction (Supplement for other enforcement actions, such as II).
civil penalties and orders. Because the 10 CFR 2.201 governs the issuance og (3) Safeguards (Supplement III)-
Commission wants to " encourage and notices of violation. Sections 2.202 and (4)licalth Physics 10 CFR 20 support licensee init!ative for self-2.204 of Title 10 set forth procedures for, (Supplement IV)-
identification and correction of respectively.
(5) Transportation (Supplement V),
problems'" " NRC will not generally (1) orders to show cause why b. censes (6) Fuel Cycle Operations issue notices of violation for a violation I
should not be amended, suspended, or (Supplement VI), and that meets all of the four following tests:
revoked or why such other action as (7) Materials Operations (Supplement (1) It was identified by the licensee, j
may be proper should not be taken, and y11)-
(2) It fits in Severity Level V or VI.
l (2) orders modifying hcenses.
Detailed guidance is provided in (3) It was reported, if required, and l
Immediately effective ordering actiens Supplements I-VII for determining the (4)It was or will be corrected within a must be based on a findmg that the appropriate severity Icvel for violations reasonable time.
i public health, interest. or safety requires in each of these seven areas oflicensed Licensees are not ordinarily cited for auch actions, or that the basis for the activities. Violations not specifically violations resulting from matters not i
action was a willful violation.
Identified by a severity level will be within the control of the licensee.
l Section 2.205 sets forth procedures for placed at the level best suited to the including its employees, that could not casessing civil penalties.
significance of the particular matter.
have been reasonably foreseen, such as.
Corrective enforcement actions may Similarly. licensed activities not directly equipment failures that are not the result be taken in the absence of any violation covered by one of the above listed seven of personnel error or inadequate design.
areas: e.g., export license activities; will procedures, quality assurance.
l aihe precedms descriptions are summanes of be placed in the activity area most 6I rtaE. he.$tDErds the et tu$s suitable in light of the particular
- TY azao Policy. Planning. and Program he should be consulted.
violation involved.
Guidance." pare !! D.z.a.
i l
i
66756 Feder:I Register / Vol. 45, Nm,196 / Tuisd y, October 7,1980 / Propos:d Rules fabrication, testing, maintenance, or noncompliance, how the problem was forth in Table 1.These distinctions are communications.
Identified, the financialimpact on the made primarily on the basis of potential A notice of violation may be issued to licensee of a given penalty, the good public consequences.1.icensee classes a licensed operator when a failure to faith of the licensee, the licensee's prior toward the top of the table are penalized comply with an operator's license enforcement history and whether the more heavily because their operations contributes directly to violations of violation was willful.
generally involve greater nuclear Severity Levels I, II, or Ill In general,'
NRC imposes different levels of materialinventories and greater whenever a licensed operator is issued a penalties on different classes of potential consequences to the health notice of violation, the facility licensee licensees.The base values of civil -
and safety of the public as well as also receives a notice of violation. For penalties ordinarily imposed are set licensee employees.
egregious single violations by licensed Tem t.-Base N Ponabas operators, or recurring operator involvement in Severity level 1. II, or !!!
violations, suspension or revocation of se nty i.w.as moinons the operator's license will be
'rp" *"c*"'"*
8
'V V
considered.
R CivilPenalty Pow.t r. acus Oh Shn.ws aumed wm Cmgary I mm.
nat for sat.gu.rd purpos.s arm s80.000 s00.000 s40.000 sis,000 s5 000 A Civi/Penaltyis a monetary penalty Tesi eacws u - om su n=,== ear us.guara pur.
for violation of(a) certain specified pf,",,", *',*,,c,,,,,c,,,,,,, y _
$ $ 7"
["
licensing provisions of the Atomic As om., ac.n
.na p.r.on. e,.a io c% r
- s. coo s.o00 4.000 i.soo 500 Energy Act or supplementary Commission rules or orders, (b) any A secondary factor considered in provide an incentive to licensees to find requirement for which a license may be Table lis the ability of various classes and correct problems on their own.
revoked, or (c) reporting requirements of licensees to pay the civil penalties.:
under section 200 of the Energy is not the Commission's intention that Civil penalties may be increased as Reorganization Act.
the economic impact of a civil penalty much as 25 percent of the amounts Civil penalties are generally imposed be such that it puts a licensee out of shown in Table lif the licensee could in the following situations: '8 business or adversely affects a reasonably have been expected to have (1) Severity I.evel I, II, or III violations licensee's ability to safely conduct taken effective preventive measures. For have occurred:
licensed activities. The deterrent effect example, cases in which a licensee had (2) Severity Level IV and V violations of NRC penalties is best served when knowledge of a problem as a result of a have occurred that are similar to the amounts of such penalties take into prior NRC inspection or licensee audit, violations discussed in a previous account a licensee's " ability to pay." As or issuance of an order, bulletin, enforcement conference, and for which a general rule, the licensee classes circular, information notice, generic -
the enforcement conference was toward the top of Table 1 represent letter, notice of violation, or other ineffective in achieving the required larger firms, whereas those toward the means, and still failed to comply despite corrective action: 58 bottom tend to be smaller. When such prior warning, the additive factor (3) There are knowing and determining the amounts of civil will apply. Particularly egregious cases, violations of the reportm.g penalties for licensees for whom the including cases involving willfulness, conscious 88 requirements of section 200 of the table does not accurately reflect the may result in penalties up to the Energy Reorganization Act; or (4) Willful violations of requirements ability to pay, NRC will consider statutory maximum. On the other hand, f r those cases in which the NRC have occurred.
necessary increases or decreases on a c neludes that the licensee deserves In determining the amount of a civil case.by. case basis.
,,3 g
,,8ood faith," a penalty to be applied, the Commission The dollar values shown in Table 1 civil penalty may be reduced by as believes the gravity of the violation are those normally imposed for much as 25 percent of the adjusted involved (i.e., severity level) is of violations at the severity levels and for values resulting from reductions,if any, paramount concern. However, when the types of licensees indicated. Because making this determination, NRC also the NRC considers the potential for an g[en igation based on "self g
ic tio *
considers the duration of the event to be of similar seriousness as the occurrence of the event l'self, the civil The " good faith" reduction will only
= orders may be in :ed in ties of. or in addition penalty amounts for Severity Level I and be applied if, in addition to meeting the to. civil penalt9s for these same situations.
!! violations are intentionally the same.
requirements for the 50 percent "In apl tng this guidance. NRC normally
}{owever,in addition to civil pendities, TeduClion. the licensee bas taken 3
- "jr"o'mtN dSe 'o"f". siinsI '"ioYo'r an Order is generally issued for Severity extraordinarily prompt and
,c thin two years, whichever is greater. NRC also considers I.evel ! Vioh.* ions.
Comprehensive corrective action.
the licensee's success in dealms with previously if, prior to NRC discovery, a licensee identified concems. Enforcement conferences an' identifies, corrects, and (where required)
In the case of violations at Severity d
[""*$,'l,"$",yl$'/"n7, jf,fii",' '"i y reports a violation in a timely fashbn.
Levels L 11. or IIL the amounts shown f ri viot.iions that are considered prosrammatic irather.he civil pena!ty will be reduced by as Table 1 may be imposed for each than isolated) concerns-much as 50 percent of the amounts violation. llowever, to emphasize the ni$b shed t y [cci n Niof the r shown in Table L This policy will focus on the specific event (s) or,
~ ' '
problem (s) of concern, the cumulative Reoronization Act.
"Willf al violations inc!.Je those invol ing "These factors are denved from the Conference total for all violations reled to a carcien a.3resard of requirements.
Report on the FY so NRC Authonzation Ddt specific event or problem will generally
Federal Register / Vol. 45, No.190 / Tuesday Octob:r 7,1980 / Propos:d Rules 66757 be the amount shown in Table 1. "If the (b) To stop facility construction when (1) Enforcement Conferences are violations involve more than one (i) further work could preclude or meetings held by NRC with licensee specific event or problem, civil penalties significantly hinder the identification management to discuss safety, may be assessed for each specific event and correction of an improperly safeg sards or environmental problems, er problem.The failure to make a constructed safety related system or licensee compliance with regulatory required report of an event a problem is component, or (ii) the licensee's quality require ments, a licensee's proposed considered as a separate event.
assurance program implementation is corrective measures (including A greater civil penalty is imposed if a not adequate and effective to provide schedules for implementation), and violation continues for more than one confidence that construction activities enforcement options available to the day. Each of such violation may are being properly carried out:
NRC.
constitute a separate violation for the (c) When the licensee has not (2) Bulletins, Circulors. Information purpose of computing the applicable responded adequately to other Notices and Generic Letters are written civil penalty. A continuing Severity III.
enforcement action:
notifications to groups of licensees IV or V violation which exceeds the (d) When the licensee interferes with identifying specific problems and calling maximum civil penalty for a single the conduct of an inspection or for or recommending specific actions on violation of the next higher seve.ity investigation: or their part. Responses to these level must be approved by the (e) For any reason not mentioned notifications may be required to be Commission, e.g., a continuing Seven.ty above for which license revocation is under oath or affirmation.
Level!!! violation for a reactor legally authorized.
(3) Notices ofDeviation are written cxceeding $100.000 must be approved by Suspensions may apply to all or part notices describing a licensee's or a the Comm,ssion. A continuing Severity of the hcensed activity. Ordinarily, a vendor's failure to satisfy an informal i
Level 1 or 11 violation which exceeds licensed activity is not suspended (nor is commitment or failure to conform to the three times the maximum civil penalty a suspension prolonged) for failure to provisicns of applicable codes, for a single Severity I violation, i.e.,
comply with requirements where such standards, guides, or accepted industry
$300.000, must be approved by the failure is not willful and adequate practices. The commitment, code, Commission. Civil penalties in excess of correction action has been taken.
standard, practice or guide involved has the limits for each type, of license will The policies governing immediately not made a legally binding requirement.
require specific Commission approvalin effective suspension orders and orders but it is a type of activity that a class of (coordanm with guidance set forth in to show cause are the same as those licensees has been encouraged to section V below.
previously described above for license follow.The notice of deviation requests C Orders modification orders.
the licensee or vendor to provide a An Onferis a written NRC directive (3) Revocotion Orders may be used:
written explanation or statement to modify, suspend, or revoke a license:
(a) When a licensee is unable or describing corrective steps taken, the to cease and desist from a given practice unwilling to comply with NRC results achieved (or corrective steps that or activity; or to take such other action requirements, are planned), and the date when es may be proper (see 10 CFR 2.202 and (b) When a licensee refuses to correct corrective action will be completed.
a violation.
{4)Immediate Action Letters (IALs) 2,2m),
(1)I.icense Afodification Orders are (c) When a licensee does not respond are letters confirn.ing a licensee's issued when some change in the conduct to a notice of violation, agreement to take certain actions to of a licensed activity is necessary.
(d) When a licensee does not pay a remove concerns about health and These orders are made effective fee required by to CFR Part 170, or safety, safeguards, or the environment.
immediately, without prior opportunity (e) For any other reason for revoking a E. Referrals to Department offustice for hearing, whenever it is determined license under section 180 of the Atom,c i
that the public health, interest, or safety Energy Act (e.g., any condition which Alleged or suspecti.d criminal so requires. or when the order is would warrant refusal of a license on an violations of the Atomic Energy Act l
responding to a violation involving original application).
(and of other relevant Federal laws) are willfulness. Otherwise, a prior (4) Cease and Desist Orders are referred to the Department of Justice for opportunity for a hearing on the typically used to stop an unauthorized investigat:on and consideration of modification is afforded. For cases in activity that has continued despite possible piosecution. Referral to the which the NRC believes a basis could notification by NRC that such activity is Department of Justice does not preclude reasonably exist for not modifying the unauthorized.
the NRC from taking other enforcement acti n under this General Statement of license as proposed, the licensee will D. OtherEnforcement Actions Policy. llowever, such actions will be i
ordinarily be afforded an opportunity to show cause why the license should not In addition to the formal enforcement coordinated with the Department of I
be modified in the proposed manner.
mechanismt of notice of violations. civil justice to the extent practicable.
(2) Suspension Ordere may be used:
penalties, and orders, NRC also uses F Escalation of Enforcemen: Sanctions (a)To remove a threat to the pubhc inwrmal mechanisms, such as health and safety, conimon defense and enforcement conferences, bulletins, NRC considers violations of Severity security, or the environment; circulars, information notices, generic Levels I, !!, or Ill to be very serious. If letters. notices of deviation, and repetitive serious violations occur, NRC "All violations associated with a particular event immediate aClion letters as part of its will consider issuing orders in catenon at the sa*""""Y enforcement and regulatory programs.
conjunction with civil penalties to
{r pgem w casociated with the event. might otherwise have NRC expects licensees to adh re achieve immediate corrective actions
[
9 been categorized at a lower seventy levelle a the scrupulously to any informal Mhgations and to deter further recurrence of l
failure to post a radiacon warnms sign. which and commitments resulting froin these serious violations. NRC carefully ji processes and will not hesitate to issue considers the circumstances of each wou c son ed s vny v viotai,on it it coninbuted to an actual overe= posur, appropriate orders to make sure that case in selecting and applying the nceedma 5 remst expectation is realized.
sanction (s) appropriate to the case in 1
f i
i 667$8 Federcl Regist;r / Vol.15. No.196 / Tuesday, October 7,1000 / Proposed Rules accordance with the criteria described exercises judgment and discretion in able to perform its intended function in sections IV.B and IV.C. above, determining the severity level of the under certain conditions (such as not Examples of enforcement actions that violations and the appropriate operable unless offsite power is (could)(will normally) be taken for enforcement sanctions, including the available);
Severity Level 1. II, or !!! violations are decision to impose a civil penalty and
- 3. Release of radioactivity offsite set forth in Tab!e 2.' The actual the amount of such penalty, consistent greater than the Technical Specification progression to bb un ed ir a particular with the general principles of this limit *: or case will depend on the circumstances.
statement of policy and the technical
- 4. Violation of 10 CFR 50.59 such that i
- "E Tabte 2.-Examples of Progresskwr of Escalat-The Commission will be provided D. Severity IV-Violations involvmg:
w ten no@cadon of all enforcement
- 1. Inadequate review or the failure to Same Acevity Area under the Same Lkense actions involving civil penalties or make a review in accordance with to orders. The Commission will be CFR 50.59 or 10 CFR 21, that does not
%mb., on ws., mean. *om m aat. as in.
sp iam msg in.aggy 2 rears consulted prior to taking enforcement result in a severity levelI. IL or 111 i
action in the following situations (unless violation:
woon the urgency of the situation dictates
- 2. Any license limit, not covered by 1st 2d 3d immediate 8Clion):
Severity Levels I,IL or Ill being I
a+b a+b+c d
t a
a+b a+b+c (1) An action affecting facility exceeded:
operations that requires balancing the
- 3. Failure to meet requirements not
- +*
public health and safety and common covered in Severity Levels I, IL or 111.
j!
,c,,,,,,,,
gg gagegggg defense and security implications of not that measureably degrades the safety of
'I w.,,u. can
,. camp.nc..e m. am.cese operating the facility with the potential operations, incident response, or the M *4 T,""g",,6p'% *W"g"*g radiological or other hazards associated environment; or f
6 cease. as awoonata, with facility operation: "
- 4. Failure to make a required Licensee (2) Proposals to impose civil penalties Event Report when the reported matter Normally the progression of in amounts greater Gian the maximum itself does not constitute a violation.
enforcement actions for repetitive values set forth in section IV.B; E. Severity V-Other violations, such violations will be based on vio!ations (3) Any proposed enforcement action as failure to follow procedures, that under a single license. When more than which the Commissior. asks to be have other than minor safety or one facility is covered by a single consulted on: or environmental significance.
license, the normal progression will be (4) Any action an Office Luector F. Severity VI-Violations that have based on repetitive violations at an believes warrants Commission minor safety or environmental individual facility and not on repetitive involvement.
significance.
Supplement L-Severity Categories Supplement IL-Severity Categories Io er i shoul be no that inder some circumstances; e.g where there is Reactor Operations Facility Construction common control over some facet of.
A. Severity 1-Violations involving:
A. Severity I-Violations involving all facility operations; repetitive violations
- 1. A Safety Limit, as defined in the or part of a structure or system that is may be charged even though the second Technical Specifications, being completed in such a manner that it violation occurred at a different facility exceeded; would not have satisfied its intended and/or under a different license. For
- 2. A system designed to prevent or safety related purpose.
example, a physical security violation at mitigate a serious safety event not being B. Severity ll-Violations involving:
i Unit 2 of a dual unit plant that repeats able to perform its intended safety
- 1. A significant deficiency in quality an earlier violation at Unit 1 nught be function when actually called upon to assurance program implementation considered repetitive.
work; related to more than one work activity V. Responsibilities
- 3. An accidental criticality; or (e.g., structural, piping. electrical,
- 4. Release of radioactivity offsite foundations), as shown by multiple The Director. Office of Inspection and greater than ten (10) times the Technical program implementation violations that Enforcement, as the pnncipal Specification limit.'
were not identified and corrected until enforcement officer of the Commission.
B. Severity II-Violations involving:
after installation (i.e., completion) and has been delegated the authority to
- 1. A system designed to prevent or inspection by the quality assurance /
issue notices of violati ns, civil mitigate serious safety events not being quality control check points that are penalties, and orders. The Director able to perform its intended safety relied upon to identify sdch violations; function;
- 2. Release of radita.:tivity offsite
- 2. All or part of a structure or system Sect on o e e er 1 Re st e otice the grecter than five (5) times the Technical that is completed in such a mariner that comminion is traerested a commenta conceming the policy for the use of Table 2.
Specification limit.*
it could have an adverse affect on the "The Directors of the Offices of Nuclear Reactor C. Severity ill-Violations involving:
safety of operations
'd
$r'"gN'h,,e eI"be e efst d
- 1. A Technical Specification Limiting C. Severity III-Violations involving-n ar Condition for Operation bemg exceeded
- 1. Lack of quality assurance program authonty. but it is expected that normal use of this authonty by NRR and NMSS will be confined to where the appropriate Action Statement implementation related to a single work actions necessary in the interest of tha public health was not satisfied; activity (e.g., structural. piping' and sa:ety but not to those involving a violation of
- 2. A system designed to prevent or cle trical, or foundations) as shown by any nistins neminment. sunderly. u is npected raiti ate a serious safety event not being multiple program implementation E
that IE wd! normally confine use of its authonty to actions based on violations of existina violations that were not identified and reouirements. The Director. Office of
- -FY a:'s6 Policy. Plannirs. and Program CorTCCMg gy more tgan one quag;Q A mmistratson, has been delegated the authority to Cuidance." para II.ud.
issue orders where L.ensees violate Comnussion
- This does not apply to it' mancous release assurance / quality control checkpoint reuglations by nonpsyment of hcense fees.
limit.
relied upon to identify such violations; i
Federal Regl t;r / Vol. 45. No.190 / Tu'sday, October 7,1980 / Proposed Rules 66759
- 2. Preoperational test program implementation in which the violations
- 1. Failure to provide protection or result in falling to confi:e the design control of access into the protected area;
- 3. Release of radioactive material to
- 2. Failure to provide protection or an unrestricted area in excess of 5 times safety requirements of the structure or control of access to a vital area or the limits of to CFR 20.106; system: or material access area:
- 4. Failure to make an immediate
- 3. Failure to make a required 10 CFR 50.55(e) report.
't. Failure to provide protection or notification as required by 10 CFR control of access to the transport vehicle 20.403(a)(i) and 10 CFR 20.403(a)(2):
D. Severity IV-Violations involving:
or the SNhl being transported; or
- 5. A radiation levelin an unrestricted
- 1. Failure to follow one or more
- 4. Failure to establish or maintain area that exceeds 50 millirem / hour for a Quality Assurance Criteria not safeguards systems one hour period; amounting to Severity Level 1.11. or 111 detect the unauthon, designed or used to 0. Disposal oflicensed material in violations; or zed removal of Category 11 SNh! from areas of quantities or concentration a excess of
- 2. Inaricquate review of the failure to make a review in accordance with 10 authorized use or storage.
5 times the limits of 10 CFR A303 or CFR Part 2L D. Severity IV-Violations ins >lving:
20.304: or
- 1. Failure to establish or maintain
- 7. Exposure of a worker in restricted E. Severity V-Other violations, such safeguards systems designed or areas in excess of 5 times the limits of 10 as failure to follow procedures. that employed to detect the unauthorized CFR 20.103.
have other than minor safety or removal of Category 111 SNM from areas C. Severity Ill-Violations involving:
environmental significance.
of authorized use or storage:
- 1. Exposure of a worker to levels in F. Severity VI-Violations that have minor safety or environmental
- 2. Failure of the security organization excess of those specified in 10 CFR significance.
to follow procedures to cope with actual 20.101 or 20.104:
security incidents that are not covered
- 2. A radiation levelin an unrestricted Supplement IIL-Seven.ty Categories by Severity Levels I.11. or III; area that exceeds 5 millirem / hour for a i
Safeguards *
- 3. Fa lure of corporate or site security one hour period:
management to provide adequate
- 3. Failure to make a 24. hour A. Severity I-Violations involving:
direction or supervision of the security notification as required by 10 CFR
- 1. Actual entry of an unauthorized pr gram that do not result in Seventy 20.403(b) or an immediate notification Individualinto a vital area or material I*"I I* II* or HI violations; or access area from outside the protected
- 4. Inadequate miew or the failure to required by 10 CFR 20.402(a);
area that was undetected at the time of make a review in ac ordance with 10
- 4. Substantial potential for an CFR Part 21.
exposure or release in excess of 10 CFR detual theft, loss or diversion of E. Severity V-Other violations, such 20 where such exposure or release does special nuclear material (SNhij or an act s failure to follow procedures or an not occur (e.g., entry into high radiation of radiological sabotafy: report an actual approved security plan, that have other area without having performed an e or
- 3. Failure to prompt than minor safeguards significance.
adequate survey, operation of a radiation facility with a nonfunctioning cr attempted theft or diversion of SNht
- * *"Y
. u ns that have a
interlock system):
cr an act of radiological sabotage, min r safeguards sigmficance.
- 5. Release of radioactive material to B. Severity II-Viola tions involving:
Supplement IV.-Severity Categories an unrestricted area in excess of the
- 1. Dreakdown of security systems fyjg py,,,,,g (pg pg,g gg hmM M GR 2M designed or used to prevent any y
unauthorized individual from entering a
. A. Severity I-Violations involving:
covered in Severity Levels I orII:
G. Disposal of licensed material not vital area or material access area from
- 1. Exposure of a worker in excess of cutside the protected area such that 25 rems of radiation to the whoe body,
- 7. Exposure of a worker in restricted cccess could have been gained without 150 rems to the skin of the whole body, areas in excess of the limits of10 CFR s
detection:
20.103; or or 375 rems to the feet, ankles, hands, or
- 2. Failure to operate the central (or forearms-
- 8. Release for unrestricted use of sIcondary) alarm station:
- 2. Exposure of a member of the public contaminated material or equipment
- 3. Failure to respond to unauthorized in excess of o.5 rems of radiation:
substantially in excess of NRC or or unanticipated security alarm
- 3. Release of radioactive material to license limits or the failure to cnnucciations; an unrestricted area in excess of 10 decontaminate plant areas as required.
- 4. Failure to establish or maintain times the limits of 10 CFR 20.100; D. Severity IV-Vicla tions involving:
s1feguards systems designed or
- 4. A radiation levelin an unrestricted
- 1. Failure to follow requirements (e g..
Gmployed to prevent or detect the area that exceeds 100 millfrem/ hour for inadequate survey, incomplete unauthorized removal of Category I a one-hour period:
dosimetry, improper postingl not SNh1 from areas of authorized use or
- 5. Disposal oflicensed material in covered in Severity Levels I. II, or III.
storage: or quanthics or concer:trations in excess of that substantially reduces the margin of
- 5. Dreakdown of transportation 10 times the limits of to CFR 20.303 or sg,
security systems designed or employed 2a304: or radiation levelin an unrestricted to prevent the theft, loss, or diversion of G. Exposure of a worker in restricted area such that an individual may receive SNh1 or acts of radiological sabotage.
areas in excess of to times the limits of g
g, C. Severity Ill-Violations involving:
10 R2 l period or 100 millirem in any seven D
e ity f---Violations involving.
consecutive days:
EnEo a[ntY...
- 1. Exposure d a workerin excess of 5
- 3. Failure to make a 30-day more n octmty such as a shipper (to CfR 7320t and a rems of radiation to the whole body,30 notification required by 10 CFR 2a405:
cerrter(10 CfR m20s). W hen a violation of such a rems to the skin of the whole body, or 75 or reg Jrement occurs, enforcement scuan wiu be rems to the feet, ankles, heruls, or directed agamst the re spons.ble hcensee whkh forems-
- 4. Inadequate review or failure to g
make a review in accordance with 10 ender the circumstances of the case may be one or
- 2. Exposure of a member of the public CFR Part 21.
4 more of the beenms involved.
In excess of 0.1 rems of radiation:
E. Severity V-Violations involving:
.l
1 66760 Federal Register / V:1. 45. Nr.196 / Tuesday October 7,1980 / Proposed Rules I
- 1. Failute to make a followup written Severity Level I. II. or III violations: that
- 1. A technically unqualified or j
reporJ as required by 10 CFR 20.402(b).
reduces the margin of safety; or unauthorized person conducting a 20.408. and 20.409: or
- 3. Inadequate review or failure to licensed activity that results in radiation
- 2. Any other matter. including failure make a review in accordance with to levels, contamination levels, or releases to follow procedures, that has other than CFR Part 21.
that exceed to times the limits specified i
minor safety or environmental E. Severity V-Other violations. such in the license; significance.
as failure to follow procedures, that
- 2. Use of unauthorized equipment that F. Severity VI-Violations that have have other than minor safety or results in radiation levels.
minor safety or environmental environmental significance.
contamination levels. or releases th.st significance:
F. Severity VI-Violatiom, that have exceed to times the limits specified in the I cense:
Supplement V Severity Categories ny aafety or environment, ;
Transportation materials requiring a license, that results Supplement VI Seven.ty Categon.es in radiation levels. contamination levels.
I tr ns o ta ion re en sin ing:
Fue/ Cycle Opemtions
{r releases hat excee 10 times the
- 1. Radiation exposure of a member of A. Severity I-Violations involving:
- 4. Failure to perform required surveys, the public in excess of 0.5 rems of
- 1. A nuclear criticality accident; or tests or evaluations. or to institute r:diation: or
- 2. A system designed to prevent or required safety precautions that results
- 2. Loss of package integrity resulting mitigate a serious safety event not being in radiation levels, contamination levels.
in surface contamination or external operable when actually required to or releases that exceed to times the I
r;diation levels in excess of ten (10) perform its design function.
limits specified in the license: or tim s the NRC or Department of B. Severity II-Violations involving:
- 5. A system designed to prevent or Tr<nsportation (DOT) limits.
- 1. A system designed to prevent or mitigate a serious safety event not being B. Severity ll-Violations of NRC mitigate a serious safety event being operable when actually required to tr:nsportation requirements involving:
inoperative; perform its design function.
- 1. Loss of package integrity resultmg
- 2. Conduct of activities not authorized B. Severity II-Violations involving:
in surface contamination or external by the license that have a significant
- 1. A technically unqualified or r:diation levels in excess of NRC or safety implication: or unauthorized person conducting a DOT requirements:
- 3. Failure to make an immediate or licensed activity thattesults in radiation
- 2. Surface contamination or external prompt report required to be made by levels, contaminatioa levels. or releases r2 diation levels in excess of three times telephone or other electronic means.
in excess oflicense hmits:
NRC or DOT limits that did not result C. Severity III-Violations involving-
- 2. Possession or use of unauthorized from a breach of package integrity; or
- 1. A degraded system designed to equipment or material in the conduct of
- 3. Failure to make required initial prevent or mitigate a serious safety licensed activities that results in notifications associated with Severity event (e.g., confinement barriers or radiation levels, contammation levels, or Level I or Il violations.
criticality controls); or releases that exceed limits specified in C. Severity III-Violations of NRC
- 2. Operation with a technically the license.
tr msportation requirements involving:
unqualified or unauthorized person
- 3. Failure to perform required surveys.
- 1. Breach of package integrity; resulting in a reduced margin of safety.
tests, or evaluations that results ;n
- 2. Surface contamination or external D. Severity IV-Violations involving:
radiation levels, contamination levela, or i
radiation levels in excess of, but less
- 1. Inadequate review or the failure to releases that exceed the limits specified thin a factor of three above NRC or review activities in accordance with 10 in the license.
DOT requirements, that did not result CFR Part 21 or management reviews
- 4. Failure to make required initial from a breach of package integnty; required by the license that are not notifications associated with Severity
- 3. Any noncompliance with labelling, performed or are performed LevelI or II violations: or placarding, shipping paper, packaging, inadequately but that do not result in a
- 5. A system designed to prevent or loiding. or other requirements that could Severity Level I II. or III violation:
mitigate a serious safety event being reasonably result in the following-
- e. Improper identification of the type.
- 2. Any operatica limit not covered by inoperative.
Severity Level I, h. or Ill violations C. Severity III-Violations involving:
qu:ntity, or form of material; being exceeded:
- 1. Failure tc control access to licensed
- b. Failure of the carrier or recipient t cxtrcise adequate controls: or
- 3. Failure to follow requirements not materials for radiation purposes as
- c. Substantial potential for personnel covered in Severity LevelI. II or III specified by NRC requirements;
- 2. Possession or use of unauthorized cxposure or contamination; or violations. that reduces the margin of sar equipment or materials in the conduct of
- 4. Failure to make required initial licensee activities; 4 Fai re to make a required 30-day notification associated with Severity
- 3. Procurement of radioactive material Le
((g9 hu an use where such use is not e ty V - iolations of NRC everity ther o t s uch transportation requirements involving:
- 1. Any noncompliance involving have oeer 6an minor ufdy w
- 4. Conduct oflicensad activities by a j
e iro al signincame.
techmcally unqualified or unauthorized pickage selection or preparation requirements which does not result in a F. Severity VI-Vio!Mions GM hae person:
bre.ch of packare integrity or surface rnin r a fety r envir nmental
- 5. Failure to make required initial contamination or e ternal radiation sigmncance.
notifications associated with Severity Level Ill violations: or 1:vels in excess of NRC or DOT Supplement VII.-Severity Categories
- 6. Degradation of a system designed to requirements.
- 2. Failure to follow procedures: or Afaterials Operations present or mitigate a serious safety event.
1 inadequate procedures, not covered in A. Severity I-Violations involving:
D. Severity IV-Viola tions involving:
l
f Federal Register / Vol. 45 N2.190 / Tursd:y. Oct:bir 7,1980 / Propos:d Rul:s 66761 1.F;ilure ta f;11:w thulrements n:t covired in SevIrf ty Levil I. II. cr III violations that reduce the margin of
=
safety (e.g., failure to determine that a radiographic source is fully retracted after an exposure):
- 2. Failure to maintain patients containing cobalt-60, cesium-137, or iridium 192 implants hospitalized, to conduct required leakage or contamination tests, or use of improperly calibrated equipment: or
- 3. Inadequate review or the failure to review activities in accordance with to CFR Part 21 or management reviews required by the license that are either not performed or not performed adequately but that do not result in a Severity Level I, IL or III viola tion.
E. Severity V--Other violations, such as fauure to follow procedures,%at have other than minor safety or environmental significance.
F. Severity VI-Violations that have Ininor safety or environmental significance.
Dated at Bethesda. AfD, this 1st day of October 1980.
For the Nuclear Regulatory Cc:nmission.
Victor Stello, Jr Director. Office ofInspection and Enfon ement.
tFR Doc. 80-m80 Nf to+at a 45 ml s Limo coos isoo-os-as
_