ML20138L884
| ML20138L884 | |
| Person / Time | |
|---|---|
| Site: | North Anna |
| Issue date: | 12/13/1985 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML20138L888 | List: |
| References | |
| EA-85-068, EA-85-68, NUDOCS 8512200092 | |
| Download: ML20138L884 (3) | |
See also: IR 05000338/1985030
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DEC 131985
Docket Nos. 50-338 and 50-339
License Nos. NFP-4 and NPF-7
EA 85-68
jV'rginia Electric and Power Company
VATTN:
Mr. W. L. Stewart, Vice President,
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Nuclear Operations
P. O. Box 26666
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Richmond, VA 23261
Gentlemen:
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'5UBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
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(NRC INSPECTION REPORT NOS. 50-338/85-30 AND 50-339/85-30;
0FFICE OF INVESTIGATIONS REPORT NO. 2-84-015)
This refers to the investigation conducted by the Office of Investigations (OI)
of activities authorized by NRC Operating License Nos. NPF-4 and NPF-7 for the
North Anna facility.- The OI report,.a redacted version of which was sent to you
on August 29, 1985, concluded that there was falsification of quality assurance
(QA) records for painting activities involving the ventilation ring ductwork of
s
the contaihment buildings of Units 1 and 2.
These activities were conducted
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during December 1982 - January 1983, for Unit 1 and April - May 1983, for Unit 2.
The finding yas discussed with those members of your staff identified in the
enclosed irspection report and at the enforcement conference held in the
NRC Region II Office on October 22, 1985.
Enforcement action for the violation was delayed by the need to conduct an
investigation, to review and provide you a copy of the results of that
investigation, and to assess your corrective actions once the matter became
known to you. .Notwithstanding the amount of time that has elapsed,
enforcement
action is being taken now because of the significance of any violation involving
falsification of qtulity assurance records.
As explained in the enclosed Notice of Violction and Proposed Imposition of
Civil Penalty, the violation involved the falsification of records pertaining
to safety-related work performed as part of two maintenance activities in the
Units 1 and 2 reactor containment buildings.
This falsification was particularly
significant because later inspections indicated that the safety-related work
was, in fact, deficient.
Tha issues invowing the actual deficiencies in the
application of unqualified protective coatings were addressed in NRC Inspection
Report Nos. 50-338/84-30 and 50-339/84-30 which was issued on October 9, 1984.
To emphasize the importance of having accurate documentation for safety-related
work, I have been authorized, after consultation with the Director, Office of
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
8512200092 851213
PLH
ADOCK 05000338
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Virginia Electric and Power Company
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Inspection and Enforcement, to issue the enclosed Notice of Violation and
Proposed Imposition of Civil Penalty in the amount of Twenty Thousand Dollars
($20,000) for the violation described in the enclosed Notice.
In accordance
with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (Enforcement Policy), the violation described in the
enclosed Notice has been categorized as a Severity Level III violation. The
base civil penalty for a Severity Level III violation under the Enforcement
Policy in effect at the time the violation occurred was $40,030.
However,
after considering the circumstances of this case and your corrective actions
once you became aware of the falsified records as a result of the 01 Report,
we propose to mitigate the civil penalty by 50 percent.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your response,
you should document the specific actions taken and any additional actions you
plan to prevent recurrence.
After reviewing your response to this Notice,
including your proposed corrective actions, the NRC will determine whether
further NRC enforcement action is necessary to ensure compliance with NRC
regulatory requirements.
You are requested to confirm in your response the commitment made during the
enforcement conference held on October 22, 1985. The details of this commitment
are discussed in the enclosed inspection report.
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 its enclosures
will be placed in the NRC's Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to
the clearance procedures of the Office of Management and Budget as required by
the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this letter, we wil.1 be glad to discuss
them with you.
Sincerely,
ORIGINAL SIGNED BY
' JOHN A. OLSHINSKl
J. Nelson Grace
Regional Administrator
Enclosures:
1.
Notice of Violation and Proposed
Imposition of Civil Penalty
2.
Inspection Report Nos. 50-338/85-30
and 50-339/85-30
fcw/encls:
. W. Harrell, Station Manager
. J. Hardwick, Jr. , Manager -
Nuclear Programs and Licensing
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