ML20235N187
| ML20235N187 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/22/1989 |
| From: | Delgeorge L COMMONWEALTH EDISON CO. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 5553K, EA-88-161, NUDOCS 8903010090 | |
| Download: ML20235N187 (2) | |
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, E {\\ i);[ One First Nation".1 Plart, Chicago, Illinois
. Commonwealth Edison -
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a Address Reply to: Pow Offic) Box 767
'L/ Chicago, Illinois 60690 - 0767
-l February 22, 1989 Mr. James Lieberman Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Quad Cities Station Units 1 and 2 Response to Order Imposing a Civil Monetary Penalty -
Enforcement Action 88-161 NRC Dockets 50-254 and 50-265 References (a): Letter from J.M. Taylor to J.J. O'Connor dated September 15, 1988.
(b):
Letter from L. De1 George to J. Lieberman dated October 17, 1988 (c):
Letter from J.M. Taylor to J.J. O'Connor dated January 23, 1989, Imposing a Civil Monetary Penalty
Dear Mr. Lieberman:
Reference (a) transmitted a Notice of Violation which described events involving; (1) the continued operation of Unit 2 for approximately six months while the 1/2 Emergency Diesel Generator was incapable of automatically performing its intended safety function due to an undetected failure in the circuitry of the automatic start relay, and (2) the failure to perform a safety evaluation for various grounds which existed on the 125 Volt DC Battery system.
Civil penalties in the cumulative amount of one hundred and twenty-five thousand dollars ($125,000) were proposed for the two violations.
Reference (b) admitted the first violation and transmitted a check for seventy-five thousand dollars ($75,000).
Reference (b) also acknowledged the second violation but requested reconsideration of the proposed fifty thousand dollar ($50,000) penalty on the basis that; (1) it partially duplicated the penalty for the first violation, and (2) the NRC inappropriately applied the mitigation factors in 10 CFR Part 2, Appendix C, Section V.B.
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Mr. J. Lleberman February 21, 1989 4
Reference (c) denied the request for reconsideration and imposed the civil penalty.
Additionally, Reference (c), as well as the attached Appendix, indicated that upon review, a determination was made that Commonwealth Edison's corrective actions were not entirely responsive to the NRC's concerns.
Specifically, there appears to be concern regarding our interim policy for dealing with electrical grounds. This policy was presented at the June 24, 1988 enforcement conference, further documented in Reference (b), and has been the subject of recent extensive discussions between ourselves, the NRC Region III and NRC NRR.
We are pleased to have an opportunity to meet with representatives of NRC Region III and NRR on March 1, 1989 for further discussion of our Interim Grounds Policy and its adequacy.
Edison believes this meeting will a]Inw an opportunity for your staff to better understand the extensiveness of our program for dealing with grounds. While Edison believes that levying an additional fifty-thousand dollar ($50,000) civil pennity was unnecessary, we nonetheless have elected not to request a hearing on this matter.
Accordingly, enclosed please find a check for fifty-thousand dollars ($50,000) in payment of the fine.
Please direct any questions regarding this transmittal to the Nuclear Licensing Deparbnent.
Very truly yours, 6
L.O. De1 George Assistant Vice President Imb
Enclosure:
$50,000 Check cc A. Bert Davis - Regional Administrator, Region III T. Ross - Project Manager, NRR Quad Cities Senior Resident Inspector 5553K
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