ML20237C709
| ML20237C709 | |
| Person / Time | |
|---|---|
| Issue date: | 12/18/1987 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kross R MEAD CORP. |
| Shared Package | |
| ML20237C710 | List: |
| References | |
| EA-87-215, NUDOCS 8712220092 | |
| Download: ML20237C709 (3) | |
Text
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- .A )(3 lEih DEC 1 8 1987 General Licensee (10 CFR 31.5)
EA 87-215 The Mead Corporation World Headquarters ATTN: Mr. Russell E. Kross, Director Human and Environmental Protection Department Courthouse Plaza Nortneast Dayton, OH 45463 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF' CIVIL PENALTY (NRC INSPECTION REPORT NO. 999-90003/87006)
.This refers to-the inspection conducted during the period August 18 through' October _ 26,-1987, at your Kalamazoo, Michigan facility. The inspection was in response to a licensee reported event regarding loss of static eliminator bars. Subsequently, other static eliminator bars were discovered lost by the' licensee at other_ facilities.within the Mead Corporation and reported to the
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NRC. An enforcement conference, to discuss the events, causes, and corrective actions, was held in the NRC Region III office on November 24, 1987. _
It appears that during the 1979-1987 time frame, you removed and discarded 21-static' eliminators to either scrapyards or landfills in both NRC Agreement 'and Non-Agreement states. Nine of the static eliminators were discarded from-facili. ties in Agreement states and are not the subject of this enforcement action. The twelve static eliminators discarded within NRC jurisdiction were
-also not leak tested as required since 1979. It appears that the root cause 1
of the events stemmed from programmatic weaknesses in the ability of Mead Corporation to maintain control over and leak test those devices.
To emphasize the need to develop and implement a program that ensures proper control over generally licensed devices, as well as the need to leak test such devices at required frequencies, I have been authorized, after consultation
- with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the amount of One Thousand Five Hundred Dollars (51,500) for the violations 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 (1987) (Enforcement Policy),
the violations' described in the enclosed Notice have each been categorized at Severity Level III.
CERTIFIED MAIL RETURN RECEIPT REQUESTED.
'8712220092 871218 d IE GA999 ENVMEADC gh ti 99990003 DCD / , t
a The' Mead Corporation DEC 1 8 1987 The base civil penalty for a Severity Level III violation is $500. The NRC Enforcement Policy allows for escalation or mitigation of a civil penalty under certain circumstances. In this case, escalation of the base civil penalty was considered for the multiple examples of violation of 10 CFR 31.5(c)(8) at each facility; however, this was offset by the unusually prompt and extensive corrective actions taken once you identified the problem.
For these reasons, no adjustment to the base civil penalty is warranted'for the violations.
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 and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
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 enclosure will be placed in the NRC 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, Pub. L' No.95-511.
Sincerely, A. Bert Da s
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalties l
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The' Mead Corporation DEC. l181987 Distribution.
.PDR SECY-JTaylor, DEDO ABDavis, RIII.
' JLieberman, OE
-CAnderson, OE EFlack, OE LChandler, 0GC FIngram, PA Enforcement Coordinators RI, RII, RIII, RIV, RV BHayes, 01 SConnelly, 0IA EJordan, AEOD DNussbaumer, GPSP EA File OE File DCS' RIII' RIII RIII RIII Pa el llo i,;
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