ML20138L884

Forwards Insp Repts 50-338/85-30 & 50-339/85-30 on 851022 & Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $20,000 Based on Falsification of QA Records for Painting Activities in Containment Bldgs

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: IR 05000338/1985030 ML20138L884 ML20138L924
References
EA-85-068, EA-85-68, NUDOCS 8512200092
Download: ML20138L884 (3)

See also: IR 05000338/1985030

Text

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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,

'< Nuclear Operations

P. O. Box 26666 '

Richmond, VA 23261

"

Gentlemen: '

'5UBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY

- (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

s (QA) records for painting activities involving the ventilation ring ductwork of

x the contaihment buildings of Units 1 and 2. These activities were conducted

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

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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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