ML20248A419

Responds to 881020 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $150,000.Believes That Facts Surrounding Violation Do Not Warrant Civil Penalty.Request for Hearing Will Not Be Sought.Payment of $75,000 Fee Encl

ML20248A419
Person / Time
Site:	Quad Cities
Issue date:	06/02/1989
From:	Delgeorge L COMMONWEALTH EDISON CO.
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE)
References
0148T, 148T, EA-87-082, EA-87-82, NUDOCS 8906080126
Download: ML20248A419 (2)

Text

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') Commonwealth Edison 72 West Adams Street Chicago, Illinois

</ Address Reply to. Post OificiBTx 767-

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'b/ Chicago, Illinois 60690 - 0767 June 2, 1989 Mr. James Lieberman, Director Office of Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Quad Cities Nuclear Power Station Units 1 and 2 Response to Order Imposing a Civil Monetary Penalty - Enforcement Action 87-82 FRC Docket No. 50-254 and 50-265 References (a): A.B. Davis letter to J.J. O'Connor dated October 20, 1988 (b): L.O. De1 George letter to J. Lieberman dated November 21, 1988 (c): H.L. Thompson, Jr. letter to J.J. O'Connor )

dated May 3, 1987.

Mr. Lieberman:

Reference (a) transmitted the Notice of Violation and proposed Imposition of Civil Penalty involving a failure to provide documentation of adequate testing and/or analysis, as specified in 10 CFR 50.49, to support the j environmental qualification of AMP nylon-insulated butt splices which were  ;

used in a number of important to safety applications. A civil penalty of one  !

hundred fifty thousand dollars ($150,000) was proposed for the violation.

In Reference (b), Commonwealth Edison admitted that we were unable to demonstrate that the AMP splices were environmentally qualified based on the test results conducted at CECO *s initiative in December, 1986. At that time )

we documented the bases for our belief that the documentation on file was I adeguate to demonstrate that the AMP splices were properly qualified in accordance with DOR guidelines by type testing and analysis. Commonwealth Edison requested reconsideration of the civil penalty on this and other bases discussed in Reference (b).

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J. Lieberman June 2, 1989 Reference (c) denied the request for reconsideration, however; the Staff reduced the civil penalty by fifty percent (50%) due to the inappropriate application of the escalation factor for identification and reporting. While Commonwealth Edison believes that the flets surrounding the violation do not warrant the civil penalty, we nonetheless have elected not to request a hearing on this matter. Accordingly, enclosed please find a check for $75,000 in payment of the fine.

Very truly yours, g) . -

L. O. De1 George Assistant Vice President 1m Enclosure cc: A.B. Davis - Regional Administrator, RIII T.M. Ross - Project Manager, NRR Quad Cities Senior Resident Inspector 0148T/11-12

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