ML20024H567
| ML20024H567 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 05/30/1991 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20024H565 | List: |
| References | |
| EA-91-042, EA-91-42, NUDOCS 9106050038 | |
| Download: ML20024H567 (3) | |
Text
. _ - _ _ _ _ _ _ _ _ _ _ _ _.. _ _ _ _ _ _ _ _ _ -
I i
N011CE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Yankee Atomic Electric Company Docket No. 50-29 Yankee Nuclear Power Station License No. OPR-3 EA 91-042 During an NRC inspection conducted between February 20, 1991 and March 25, 1991, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2.
Appendix C (1990), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205.
The particular violations and associated civil penalty are set forth below:
A.
10 CFR Part 50, Appendi.. B, Criterion }l, " Quality Assurance Program "
requires, in part, that the Quality Assurance Program crovide for training of personnel performing activities af fecting quality as necessary to assure that suitable proficiency is achieved and maintained.
The Yankee Atomic Electric Company's Quality Assurance Program, Revision 19A,Section VII B.3.b. states that the plant shall be responsible for the evaluation of purchased services during and/or af ter completion of the service.
Contrary to the above, the licensee's Quality Assurance Program did not provide for adequate training of the electrical personnel who installed the electrical connections on three Emergency Diesel Ger,erators (EDGs) in September 1990 nor did it adequately evaluate their services.
This is evidenced by the f ailure of EDG-1 to start during a surveillance test on January 2,1991 due to improper electrical connections, and the 92 nonconforming wire connections subsequently identified.
B.
10.CFR Part 50, Appendix B, Criterion X, " Inspection," requires, in part, that a program for inspection of activities affecting quality be established and executed to verify conformance with the documented inst ructions, procedures, and drawings for accomplishing the activity.
Contrary to the above, in September 1990, the licensee did not establish and execute an adequate quality control inspection program to ensure quality installation of the replacement EDGs, specifically the installation of the electrical connections associated with these EDGs.
The program was inadequate in that the EDG replacement was subjected to random surveillance and not mandatory inspection points, nor did the development of the insrec-tion activities identify the appropriate attributes requiring inspection.
This is a Severity Level 111 problem (Supplement 1).
Cumulative Civil Penalty - 550,000 (assessed equally among the two violations) 0FFICIAL RECORD COPY EA 91-042 5/24 - 0009.0.0 05/24/91 9106050030 910530 PDR ADOCK 05000029 0
pm
~.
J Pursuant to the provisions of 10 CFR 2.201, Yankee Atomic Electric Company is hereby required to submit a written statement or explanation to the Director.
Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalty (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid l
further violations, and (5) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause sFown.
Under the authority of.Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201~, the Licensee may pay the civil penalty by letter addressed to the Director, Of fice of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draf t, money order, or elsttronic transfer payable to the Treasurer of the United States in the amount of *he civil penalty proposed above, or may protest imposition of the civil penaity in whole or in-part, b/ a written answer. addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.
Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, i r, whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may:
(1) deny the violations listed in thit Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty in whcle or in part, such answer may request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1990), should be addressed.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2,201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to tho other provisior.s of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has been determined-
.in accordance with the applicable provisions of 10 CFR 2.205, thir matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant.to Section 234c of the Act, 42 U.S.C. 2282(c).
OFFICIAL RECORD COPY EA 91-042 5/24 - 0010.0.0 05/24/91
f t-Notice of Violation 3
The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and Anv.<er to a Notice of Violation) should be addressed to:
Director, Of fice of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region 1, 475 Allendale Road, King of Prussia, Pennsylvania 19406 and a copy to the NRC Senior Reactor inspector, Yankee Nuclear Power Station.
FOR 1HE NUCLEAR REGULATORY COMMISSION Original Simd By:
Thomas T. Martin Thomas T. Martin Regional Administrator Dated at King of Prussia, Pennsylvania this y"'
day of May 1991 l
l OFFICIAL RCCORD CDPy-EA 9)-ogg 5,p4 ' 00)),0,0 05/2A/93
_ _., _... _. _. _ -. _ -