EA-97-055 - Surry 1 & 2 (Virginia Electric & Power Co.)

August 29, 1997

EA 97-055

Virginia Electric and Power Company
ATTN: Mr. J. P. O'Hanlon
Senior Vice President-Nuclear
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, Virginia 23060

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -$55,000 (NRC Inspection Report 50-280/97-01 and 50-281/97-01)

Dear Mr. O'Hanlon:

This refers to the inspection conducted between January 13 and 17, 1997, at Virginia Electric and Power Company's (Virginia Power) Surry facility. The inspection included a review of your implementation of the requirements of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" [the Maintenance Rule]. The results of the inspection were formally transmitted to you by letter dated February 20, 1997. An open predecisional enforcement conference was conducted in the Region II office on March 11, 1997, with you and members of your staff to discuss the apparent violations, the root causes, and corrective actions to preclude recurrence. A summary of the conference was sent to you by letter dated March 17, 1997.

Based on the information developed during the inspection and, after evaluation of the information that you provided during the conference, the NRC has determined that violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) and the circumstances surrounding them are described in detail in the subject inspection report.

The violations set forth in the Notice include a serious failure to implement key aspects of the Maintenance Rule. These violations, collectively, represent a programmatic breakdown in the development and implementation of Virginia Power's program to ensure compliance with the regulatory requirements of the Maintenance Rule. Escalated enforcement is warranted due to the significant regulatory concern with the common underlying root causes of the violations. The root causes included: (1) poor management oversight and control of the Maintenance Rule program development and implementation; (2) ineffective turnover of plans developed in the Virginia Power corporate offices; and (3) the failure to correct deficiencies, found as a result of Virginia Power audits and self-assessments during program development and implementation.

The violations in the Notice are directly related to the failure to meet the requirements of the Maintenance Rule. Violation A involved the failure to include the emergency switch gear heating ventilation and air conditioning system in a program to monitor its performance against established goals, as required by 10 CFR 50.65(a)(1). Violation B included seven examples of failures to demonstrate that the performance or condition of structures, systems, and components (SSC) within the scope of 10 CFR 50.65 had been effectively controlled through the performance of appropriate preventive maintenance, such that the SSC would remain capable of performing its intended function. Three procedural violations, Violations C.(1), C.(2) and C.(3), were identified that indicated a significant failure to procedurally establish and implement maintenance rule procedures.

The Commission determined that the Maintenance Rule was necessary to ensure that licensees evaluate the effectiveness of maintenance to minimize the likelihood of failure of safety-significant equipment that could initiate or adversely affect a transient or accident. Even though the final rule was issued in July 1991, it did not become effective until July 1996. Within this five year period, the NRC staff and industry were provided the first two years to develop implementation and inspection guidance. The following three years were to permit licensees to implement the requirements such that by July 10, 1996, all requirements would be satisfied. Full compliance with the maintenance rule by this date is a requirement set forth in 10 CFR 50.65(c).

During the five years of guidance development and implementation, the staff and the industry worked towards a common goal of assuring that licensees had good implementation guidance and clearly understood the manner in which NRC would inspect implementation, once the rule became effective. This was accomplished through multiple public workshops and a pilot inspection program. Results from these activities were documented and shared with the industry so that licensees would have sufficient time prior to the July 10, 1996, effective date of the rule to develop and implement their programs and processes.

In general, Surry has a good performance record in the maintenance area and significant upgrades in the material condition of the plant were noted in the last systematic assessment of licensee performance report, issued on November 8, 1996, and during the inspection that was the subject of this enforcement action. The NRC also acknowledges that Virginia Power had taken significant steps to replace plant equipment found to be unreliable, such as the emergency service water pumps. Nevertheless, the NRC concludes that your actions taken to implement the Maintenance Rule had a number of significant weaknesses, and measures to meet all Rule requirements had not been fully integrated into the appropriate programs at Surry. Thus, the failure to implement the requirements of the Maintenance Rule is considered to be a significant regulatory concern. It is important to note that the maintenance rule sets forth requirements for monitoring the effectiveness of maintenance and not for performing maintenance. Surry did not have adequate measures in place to monitor the results of maintenance to assure plant SSCs remain capable of performing their intended functions. Appropriate performance trending, effective cause determinations and risk insights were not incorporated into maintenance monitoring activities to reasonably assure that plant equipment degradation or problems are identified and corrected before they result in significant failures or place the plant in undesirable and risk-significant configurations.

An additional issue of concern to the NRC is the weakness with your process for performing assessments for determining the overall effect on the performance of safety functions when removing equipment from service for maintenance. Your staff indicated that the intent of these assessments was to ensure that the plant is not placed in risk-significant configurations. However, several instances were identified where you underestimated the risk associated with certain plant configurations established for the performance of maintenance. Several weaknesses were found that contributed to this problem. Your probabalistic risk assessment (PRA) specialists were not actively involved in the decision process for taking equipment out-of-service. The matrix used for risk assessment included only 12 of the 44 PRA risk significant systems. Plant personnel (e.g., operators and maintenance schedulers) assigned to assess plant risk mistakenly believed that the matrix included all PRA risk significant SSCs. In addition, the functional equipment groups used by schedulers did not reflect PRA risk insights. Also, required management approval for a high risk plant configuration was not obtained as required by procedure and was therefore identified as Violation II.C.(3) in the Notice.

Therefore, these violations are classified in the aggregate in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity Level III problem.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level III problem occurring on or continuing after November 12, 1996 (61 Federal Register 53554). Because your facility has been the subject of escalated enforcement actions within the last two years¹, the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy.

With regard to the factor of Identification, the NRC has determined that overall, credit for identification is warranted for this Severity Level III problem because your staff did identify, through the performance of many audits and self-assessments, that your implementation of the Maintenance Rule was not sufficient to comply with the requirements of the Rule.

As to the factor of Corrective Action, your corrective actions for the Maintenance Rule violations, when finally taken, were judged to be comprehensive. After the Maintenance Rule program problems were identified in January 1997, Virginia Power established a dedicated recovery team to revalidate and revise, as necessary, the Maintenance Rule program for both Surry and the North Anna facility. In addition: (1) other similar licensee programs are being examined to ensure that weaknesses are not present; (2) deficiency reports will be written on all conditions adverse to quality, including those identified by individuals in the Virginia Power corporate offices; (3) recent self-assessments will be reviewed to ensure deficiencies are captured in the corrective action program; and (4) steps are being taken to ensure thorough understanding of Maintenance Rule requirements by both Virginia Power management and staff.

Notwithstanding your comprehensive corrective actions taken to address the Maintenance Rule violations, your actions were not considered prompt. Your staff failed to take prompt corrective actions following a number of audit and self-assessment findings that indicated that violations of the Maintenance Rule existed at your facility. Findings, in the assessment that was issued in April 1996, included weaknesses in: (1) the programmatic controls of Maintenance Rule scoping, (2) recording of SSCs data, (3) performing evaluations for goal setting, (4) monitoring corrective actions, (5) use of industry events, and (6) trending of Maintenance Preventable Functional Failures (MPFF). Had you taken prompt effective corrective actions, you could have been in compliance by the effective date of the rule. Your April 1996 assessment concluded that your Maintenance Pilot Program did not meet all regulatory requirements of the Maintenance Rule. Your followup reviews, issued after the date of Maintenance Rule implementation, performed on July 10, 1996, August 21, 1996, and October 16, 1996, noted that many of the discrepancies identified in previous assessments remained uncorrected. Your Maintenance Rule Team Report, issued January 14, 1997, further confirmed the failure to implement the Maintenance Rule adequately. That latter assessment was comprehensive and critical because it found significant deficiencies continued from earlier assessments and identified that corrective actions for previous self-assessments had not been promptly implemented. As discussed at the predecisional enforcement conference, your review of this matter revealed that you failed to enter significant conditions adverse to quality, identified during self-assessments of the Maintenance Rule program, into your corrective action program. This process deficiency contributed to your management's inadequate resolution of these conditions and resulted in the failure to meet the requirements of the Maintenance Rule. In view of the delay in taking effective corrective actions once your staff identified the failure to meet the Maintenance Rule, credit is not warranted for corrective action.

Therefore, to emphasize the importance of full compliance with 10 CFR 50.65, the Maintenance Rule, the need for vigorous management oversight to ensure that prompt corrective actions are initiated to address significant conditions adverse to quality, and in consideration of your previous escalated enforcement actions, I have been authorized, after consultation with the Commission, to issue the enclosed Notice in the base amount of $55,000 for the Severity Level III problem.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. In particular, since your program to implement the Maintenance Rule was a corporate one, similar deficiencies likely exist at the North Anna facility. Although not specifically the subject of this enforcement action, the NRC expects that future inspection activities at North Anna will provide the NRC an opportunity to examine the complete scope and effectiveness of your corrective actions in correcting any deficiencies that may exist.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room.

Should you have any questions concerning this letter, please contact us.

Sincerely, Original Signed by Luis A. Reyes Regional Administrator

Docket Nos. 50-280, 50-281
License Nos. DPR-32, DPR-37

Enclosure: Notice of Violation and Proposed Imposition of Civil Penalty

cc w/encl:
J.M. McCaroley, Manager
Nuclear Licensing & Operations Support
Virginia Electric & Power Company
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA 23060

David A. Christian, Manager
Surry Power Station
Virginia Electric & Power Company
5570 Hog Island Road
Surry, VA 23883

W. R. Matthews, Manager
North Anna Power Station
P. O. Box 402
Mineral, VA 23117

Chairman
Surry County Board of Supervisors
P. O. Box 130
Dendron, VA 23839

Dr. W. T. Lough
Virginia State Corporation Commission
Division of Energy Regulation
P. O. Box 1197
Richmond, VA 23209

Michael W. Maupin
Hunton and Williams
Riverfront Plaza, East Tower
951 E. Byrd Street
Richmond, VA 23219

State Health Commissioner
Office of the Commissioner
Virginia Department of Health
P. O. Box 2448
Richmond, VA 23218

Attorney General
Supreme Court Building
900 East Main Street
Richmond, VA 23219

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NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTY

Virginia Electric and Power Company Docket Nos. 50-280 and 50-281 Surry Power Station License Nos. DPR-32 and DPR-37 EA 97-055

During an NRC inspection conducted between January 13 and 17, 1997, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the NRC proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:

A. 10 CFR 50.65(a)(1) requires, in part, that the holders of an operating license shall monitor the performance or condition of structures, systems, or components (SSCs) within the scope of the rule as defined by 10 CFR 50.65(b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that such structures, systems, and components, are capable of fulfilling their intended functions. Such goals shall be established commensurate with safety. When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken.

Contrary to 10 CFR 50.65(a)(1), as of January 13, 1997, the licensee failed to monitor the performance and establish goals commensurate with safety for the emergency switch gear heating ventilation and air conditioning system, as required by 10 CFR 50.65(a)(1), in a manner sufficient to provide reasonable assurance that such a structure, system, and component, was capable of fulfilling its intended functions. The emergency switch gear heating ventilation and air conditioning system is a system required in order for the facility to shut down the reactor and maintain it in a safe shutdown condition. (01013)

B. 10 CFR 50.65(a)(1) requires, in part, the holders of an operating license shall monitor the performance or condition of SSCs, as defined by 10 CFR 50.65(b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that such structures, systems, and components are capable of fulfilling their intended functions. When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken.

10 CFR 50.65(a)(2) requires, in part, that monitoring as specified in 10 CFR 50.65 Section (a)(1) is not required where it has been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance, such that the structure, system, or component remains capable of performing its intended function.

Contrary to 10 CFR 50.65(a)(2), as of July 10, 1996, the time that the licensee elected to not monitor the performance or condition of certain SSCs against licensee-established goals pursuant to the requirements of Section (a)(1), the licensee failed to demonstrate that the performance or condition of SSCs within the scope of 10 CFR 50.65 had been effectively controlled through the performance of appropriate preventive maintenance, as evidenced by the following examples, each of which would constitute a separate violation:

(1) The licensee failed to demonstrate that the performance of the risk-significant, direct current power, emergency switch gear heating, ventilation and air conditioning (chillers), and service water systems, and the non-risk-significant emergency lighting and condensate polishing systems, had been effectively controlled through the performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2). Specifically, the licensee failed to evaluate the appropriateness of the performance of preventive maintenance on these systems prior to placing these SSCs under Section (a)(2). The evaluation of the appropriateness of the preventive maintenance system failures was not adequate because it failed to consider system failures prior to July 10, 1996. Without an evaluation of the appropriateness of preventive maintenance performed on these systems prior to July 10, 1996, the licensee was unable to demonstrate that the performance or condition of these systems were effectively controlled through the performance of appropriate preventive maintenance, such that the SSCs remain capable of performing their intended functions.

(2) The licensee failed to demonstrate that the performance of the non-risk-significant radiation monitors had been effectively controlled through the performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2). Specifically, the licensee failed to adequately evaluate the appropriateness of the performance of preventive maintenance on the radiation monitors prior to placing these SSCs under Section (a)(2). The evaluation of the appropriateness of the preventive maintenance was not adequate because it had failed to identify that maintenance performed on the system had not prevented excessive inoperability and unavailability of the radiation monitors such that the monitors may not have been capable of performing their intended function of either (1) alerting the licensee that radiological set points had been exceeded, or (2) initiating an automatic safety system actuation.

(3) The licensee failed to demonstrate that the performance of the risk-significant reactor protection system (RPS) and the safety injection actuation system (SIAS) were being effectively controlled through the performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2). Specifically, the licensee failed to demonstrate it had established adequate measures to evaluate the effectiveness of preventive maintenance on these risk significant SSCs prior to placing these SSCs under Section (a)(2) in that it used a standard that would allow up to three maintenance preventible functional failures (MPFF) per operating cycle. Allowing three MPFFs for the risk-significant RPS and SIAS would not demonstrate that the performance of the SSCs were being effectively controlled through appropriate preventive maintenance.

(4) The licensee failed to demonstrate that the performance of the risk-significant component cooling water pumps and the instrument air compressor had been effectively controlled through the performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2). Specifically, the licensee failed to establish any measure to evaluate the appropriateness of the performance of preventive maintenance on the component cooling water pumps and the instrument air compressor prior to placing these SSCs under Section (a)(2). Measures to evaluate the appropriateness of the preventive maintenance were necessary to demonstrate that the performance or condition of the components were being effectively controlled through appropriate preventive maintenance such that the component cooling water pumps and the instrument air compressor remain capable of performing their intended function.

(5) The licensee failed to demonstrate that the performance of the risk-significant reactor coolant system code safety valves had been effectively controlled through the performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2). Specifically, the licensee had failed to establish adequate measures to evaluate the appropriateness of the performance of preventive maintenance on the reactor coolant system code safety valves prior to placing these SSCs under Section (a)(2). The measures used in the evaluation of the appropriateness of the preventive maintenance were not adequate because they failed to consider set point drift of the valves. Measures for the evaluation of set point drift were necessary because, if preventive maintenance fails to preclude change to the set point of the reactor coolant system code safety valves, the valves may not be capable of performing their intended function of protecting the reactor coolant system from over pressurizing and failing.

(6) The licensee failed to demonstrate that the performance of the risk-significant emergency service water system had been effectively controlled through the performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2). Specifically, the licensee failed to adequately evaluate the appropriateness of the performance of preventive maintenance on this system prior to placing this SSC under Section (a)(2). The evaluation of the appropriateness of the preventive maintenance system failures was not adequate because it failed to consider failures of periodic tests for system operability prior to July 10, 1996. Without an evaluation of the appropriateness of preventive maintenance performed on this system prior to July 10, 1996, the licensee was unable to demonstrate that the performance of the system was effectively controlled through the performance of appropriate preventive maintenance, such that this SSC remains capable of performing its intended function.

(7) The licensee failed to demonstrate that the performance of standby functions of the electro-hydraulic control system, bearing cooling system, boric acid transfer pumps (emergency boration mode), auxiliary building heating, ventilation and cooling system, and the control room emergency ventilation system had been effectively controlled through performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2). Specifically, the licensee failed to establish any measures to evaluate the appropriateness of the performance of preventive maintenance on these SSCs prior to placing these SSCs under Section (a)(2). Without any measures to evaluate these standby functions, the licensee was unable to demonstrate that the performance or condition of these SSCs were effectively controlled through the performance of appropriate preventive maintenance, such that these SSCs remain capable of performing their intended function. (01023)

C. Technical Specification (TS) 6.4, Unit Operating Procedures, states in Part A.7, that detailed written procedures with appropriate checkoff lists and instructions shall be provided for preventive or corrective maintenance operations which could have an effect on the safety of the reactor. Part D of TS 6.4 states that all procedures described in Specification 6.4.A shall be followed.

Virginia Power Station Administrative Procedure VPAP-0815, Maintenance Rule Program, Revision 3, and VPAP-2001, Station Planning and Scheduling, were established to provide instructions for preventive and corrective maintenance operations.

(1) VPAP-0815, Revision 3, included the screening criteria for cause determinations of Maintenance Preventable Functional Failures (MPFF), an activity which could have an effect on the safety of the reactor. Section 4.11 of VPAP-0815 included a requirement that a SSC within the scope of the Rule must experience a failure which resulted in a loss of risk-significant or standby train function and/or loss of a non-risk-significant system function that affected plant level monitoring criteria prior to screening for a MPFF.

Contrary to the above, as of January 13, 1997, the instructions provided in Virginia Power Station Administrative Procedure VPAP-0815, Revision 3, were not appropriate, in that VPAP-0815 did not prescribe adequate instructions regarding cause determinations for MPFFs in the main feedwater, chemical and volume control, and radiation monitoring systems. Specifically, Section 4.11 of VPAP-0815 did not provide instructions to allow for screening of MPFFs for a SSC within the scope of the Rule without experiencing a failure which resulted in a loss of risk-significant or standby train function and/or loss of a non-risk-significant system function that affected plant level monitoring criteria. During the inspection, examples of MPFFs were identified for the main feedwater, chemical and volume control, and radiation monitoring systems which had not been identified by the licensee due to this procedure inadequacy. Limiting the screening of functional failures to failures that actually cause plant transients does not provide assurance that the main feedwater system, the chemical and volume control system, and the radiation monitoring system remain capable of performing their intended function thereby affecting the safety of the reactor. (01033)

(2) VPAP-0815, Revision 3, Section 5.12, requires the Maintenance Rule Working Group to develop, review, and approve performance criteria for risk significant and Maintenance Rule structures, systems, and components.

Contrary to the above, the licensee failed to follow VPAP-0815 in that the performance criteria for the reactor protection system, a system where performance has an effect on the safety of the reactor, was changed on January 16, 1997 without approval of the Maintenance Rule Working Group as required by Section 5.12 of VPAP-0815. (01043)

(3) VPAP-2001, Revision 3, Section 6.7.2, requires that the approval of the Assistant Station Manager Operations and Maintenance be obtained whenever two or more risk-significant systems or components are to be unavailable which are not addressed in the site matrix for removing equipment from service during on line operations.

Contrary to the above, the licensee failed to obtain approval from the Assistant Station Manager Operations and Maintenance on October 17, 1996, when one pressurizer power operated relief valve was blocked and an instrument air compressor was unavailable (both risk-significant components whose removal from service would have an effect on the safety of the reactor and not addressed in the site matrix) as required by Section 6.7.2 of VPAP-2001. (01053)

These violations represent a Severity Level III problem (Supplement I).
Civil Penalty - $55,000

Pursuant to the provisions of 10 CFR 2.201, Virginia Electric and Power Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalty (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or the cumulative amount of the civil penalties if more than one civil penalty is proposed, or may protest imposition of the civil penalty in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may: (1) deny the violation(s) listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalty, the factors addressed in Section VI.B.2 of the Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.

Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.

The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to: James Lieberman, Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region II and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Atlanta, Georgia
this 29th day of August 1997

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^1. On August 16, 1996, a Severity Level III problem was issued related to the operability of containment hydrogen analyzers (EA 96-231). On November 22, 1995, a Severity Level III problem was issued related to multiple violations associated with the September 1995 unplanned reduction in reactor vessel water level (EA 95-223).