ML20134K508
| ML20134K508 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/13/1996 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Kenyon B NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| EA-96-034, EA-96-067, EA-96-086, EA-96-106, EA-96-145, EA-96-146, EA-96-183, EA-96-197, EA-96-198, EA-96-331, EA-96-332, EA-96-333, EA-96-34, EA-96-350, EA-96-352, EA-96-67, EA-96-86, NUDOCS 9611190148 | |
| Download: ML20134K508 (5) | |
Text
,
November 13, 1996 EA Nos.96-034, 96-067,96-086 96-106,96-145,96-146 96-183,96-197, 96-198 96-331,96-332, 96-333 96-350,96-352 Mr. Bruce D. Kenyon President and Chief Executive Officer Northeast Nuclear Energy Company P. O. Box 128 Waterford, CT 06385-0128
SUBJECT:
SUGGESTED PRESENTATION FOR THE UPCOMING PRE-DECISIONAL ENFORCEMENT CONFERENCE SCHEDULED FOR DECEMBER 5,1996
Dear Mr. Kenyon:
During eight NRC inspections conducted between October 1995 and August 1996, numerous apparent violations of NRC requirements were identified. The apparent violations, which are summarized in the enclosure that provides a reference to the specific report in which it is documented, are being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. A pre-decisional enforcement conference has been scheduled for December 5,1996, to discuss these apparent violations.
This conference is being held to obtain information to enable the NRC to make an enforcement decision, such as a common understanding of the facts, root causes, missed opportunities to identify the apparent violation sooner, corrective actions, significance of the issues and the need for lasting and effective corrective action. As in all conferences, this conference provides an opportunity for you to point out any errors in our inspection reports and for you to provide any information concerning your perspectives on 1) the severity of the violation (s), 2) the application of the factors that the NRC considers when it determines the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other application of the Enforcement Policy to this case, including the exercise of discretion in accordance with Section Vll.
Given the large number of apparent violations (more than 60), the NRC suggests that you make your presentation at the conference in three parts. During the first part, we suggest that you provide a handout that describes whether you admit or deny the specific violations, points out any errors in the inspection reports, and also covers the causes of the specific violation, any missed opportunities by your staff to identify and correct it sooner, and your corrective actions, taken or planned, including the estimated completion dates. However, during your actual presentation during the conference regarding these specific violations, we suggest that you focus only on any apparent violations that you i
f'EDI I
9611190148 961113 PDR ADOCK 05000245 G
Mr. B. Kenyon 2
take issue with, and provide your rationale for your position. The NRC will use this handout following the pre-decisional enforcement conference to determine what further actions are required regarding the apparent violations.
During the second part, which should be the principal focus of the conference, we suggest that /ou provide sn M-depth presentation and discussion of the root cause and corrective actions, taken or plaoned to address the broader programmatic deficiencies that these
]
violations represent. These broader areas are summarized in the enclosure, along with the apparent violations related to those areas. You will note that the apparent violations in the attachment are grouped by similar root causes or corrective actions. You may choose to i
place the individual apparent violations into other groupings that you consider appropriate.
j During the third part of the conference, you may provide your perspectives on: 1) the j
severity level of the grouped apparent violations; 2) the application of the factors that the J
NRC considers when it determines the amount of a civil penalty that may be assessed in i
accordance with Section VI.B.2 of the Enforcement Policy; and 3) any other application of the Enforcement Policy to this case, including the exercise of discretion in accordance with 1
Section Vll.
1 Please be aware that the attached list does not contain all currently open apparent violations that are being considered for escalated enforcement action. Some issues are still under review by the NRC at this time. You will be receiving correspondence on these 4
j issues at a later date.
If you have questions regarding details of t?.e proposed pre-decisional enforcement conference, please contact Wayne Lanning (610-337-5126) or Jacque Durr (610-337-1 5224).
Sincerely, ORIGINAL SIGNED BY:
W. KANE Hubert J. Miller Regional Administrator Docket Nos. 50-245 50-336 50-423
Mr. B. Kenyon 3
i cc w/ encl:
T. C. Feigenbaum, Executive Vice President - Chief Nuclear Officer J. McElwain, Unit 1 Recovery Officer M. Bowling, Jr., Unit 2 Recovery Officer J. Cowan, Unit 3 Recovery Officer j
L. M. Cuoco, Esquire Senior Vice President, Nuclear Safety and Oversight Vice President, Reengineering Vice President, Nuclear Technical Services j
F. C. Rothen, Vice President, Maintenance Services J. R. Egan, Esquire V. Juliano, Waterford Library J. Buckingham, Department of Public Utility Control S. B. Comley, We The People State of Connecticut St.O Designee 1
l I
i l
l i
__ =
Mr.B.Kenyon 4
i Distribution w/ encl:
Region i Docket Room (with concurrences)
W. Lanning, Deputy Director of Inspections, SPO, Rl M. Kalamon, RI, SPO NRC Resident inspector Nuclear Safety Information Center (NSIC)
PUBLIC D. Screnci, PAO OE (2) 1 Distribution w/enci (VIA E-MAIL):
D. Screnci, PAO N. Sheehan, Field-Public Affairs Officer, RI J. Anderson, PM, SPO, NRR W. Dean, OEDO P. McKee, Director, Deputy Director of Licensing, SPO, NRR G. Imbro, Deputy Director of ICAVP Oversight L. Plisco, Chief, SPO, NRR 1
V. Rooney, PM, SPO, NRR D. Mcdonald, SPM, SPO, NRR M. Callahan, OCA i
R. Correia, NRR R. Frahm, Jr., NRR inspection Program Branch (IPAS) l 4
4 1
DOCUMENT NAME: G:\\ BRANCH 6\\ MSENFCON.JPD To receive a copy of this document. indicate in the boa: *C" = Copy without attachment / enclosure
'E" = Copy with attachment / enclosure "N" = No copy i
OFFICE Rl/SPO C Rl/SPO_
Rl/SPO Rl/EO HQ/OE HQ/OE.
NAME RUrban plyL JDurr 'M WLanningM DHolody Qlf JLieberman BLett#'fe DATE 11/7/96 "
11/g/96 11/ff96 6 11/g/96 11/ f/96 11/12/96
'~
u E= HRn=
OFFICE RIQf f NAME H@'
4 DATE 11/0/09 OFFICIAL RECORD COPY
APPARENT VIOLATIONS TO BE DISCUSSED AT THE MILLSTONE PRE-DECISIONAL ENFORCEMENT CONFERENCE Technical Soecifications 10 CFR 50.59 Items Failure to follow Technical Specifications.
Failure to properly make changes in the EA 96-086 eel 336/95-44-05 facility.
EA 96-106 eel 245/96-01-01 EA 96-197 eel 245/96-04-04 EA 96-034 245/96-03-01 EA 96-197 eel 245/96-04-03 10 CFR 50.9(a)
EA 96-198 eel 423/96-201-02 eel 336/96-201-03 Failure to provide complete and accurate eel 423/96-201-04 information.
eel 423/96-201-05 eel 423/96-201-06 EA 96-183 eel 336/96-05-11 eel 423/96-201-07 eel 423/96-201-08 10 CFR 50.71(e)
EA 96-332 eel 336/96-06-05 Failure to update the Final Safety Analysis 10 CFR 50.73(a)
Report.
Failure to provide proper event reports.
EA 96-145 eel 245/95-82-20 EA 96-198 eel 423/96-201-01 EA 96-197 Ei e 245/96-04-01 10 CFR 50 Accendix B, Criterion 11 10 CFR 50 Accendix B Criterion Ill Actions contrary to the QA Program.
Failure to properly implement design control measures.
EA 96-145 eel 245/95-82-12 EA 96-145 eel 245/95-82-03 10 CFR 50 Aooendix B Criterion V eel 245/95-82-04 eel 245/95-82-08 Failure to establish procedures appropriate eel 245/95-82-09 to the circumstances.
eel 245/96-82-10 eel 245/95-82-11 EA 96-198 eel 423/96-201-18 eel 245/95-82-14 eel 245/95-82-18 10 CFR 50 Accendix B, Criterion XI eel 245/95-82-19 EA 96-146 eel 423/96-06-15 Failure to conduct proper testing of EA 96-198 eel 336/96-201-09 equipment.
eel 423/96-201-09 eel 336/96-201-11 EA 96-183 eel 336/96-05-09 eel 336/96-201-12 EA 96-198 eel 423/96-201-32 eel 423/96-201-15 eel 423/96-201-33 eel 336/96-201-31 eel 423/96-201-34 eel 423/96-201-35 eel 423/96-201-37 eel 423/96-201-39 eel 336/96-201-41 EA 96-352 URI 245/96-01-05
10 CFR 50 Anoendix B, Criterion XV/XVI 10 CFR 50 Anoendix B. Criterion XVI Failure to properly process Failure to take prompt and effective nonconforming materials.
corrective actions.
EA 96-067 URI 245/95-44-01 EA 96 350 eel 245/96-06-04 EA 96-197 eel 336/96-04-05 10 CFR 50 Aooendix B, Criterion XVll EA 96-198 eel 42 /96 3 Failure to maintain records.
I 336/96-201-20 eel 423/96-201-21
'4 EA 96-198 eel 423/96-201-10 eel 423/96-201-23 eel 423/96-201-24 eel 336/96-201-25 eel 423/96-201-26 eel 423/96-201-27 eel 336/96-201-29 eel 423/96-201-29 eel 336/96-201-30 eel 336/96-201-36 EA 96-331 eel 336/96-06-11 EA 96-333 eel 336/96-06-12 i
i l
.