EA-97-576 - Indian Point 2 (Consolidated Edison Company of New York, Inc.)

July 6, 1998

EA Nos.: 97-576; 98-028; 98-056; 98-192

Mr. Paul H. Kinkel
Vice President - Nuclear Power
Consolidated Edison Company of New York, Inc.
Indian Point 2 Station
Broadway and Bleakley Avenues
Buchanan, New York 10511

 

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES - $110,000 (NRC Inspection Report Nos. 50-247/97-13; 97-15; and 98-02 and Investigation Report No. 1-97-038)

Dear Ms. Kinkel:

This letter refers to three NRC inspections conducted between October 27, 1997, and March 23, 1998, at your Indian Point 2 nuclear facility for which exit meetings were held on January 23, January 30, and April 23, 1998. This letter also refers to an investigation conducted by the NRC Office of Investigations (OI) to determine if a technician deliberately falsified an emergency light surveillance test record. Based on the results of the inspections and investigation, apparent violations were identified as described in our letters dated February 10, February 13, February 25, and May 15, 1998, transmitting the inspection reports and OI synopsis. On May 6, 1998, Predecisional Enforcement Conferences (conferences) were conducted with you, and members of your staff, to discuss the violations identified during the first two inspections and the investigation, their causes, and your corrective actions. With respect to the apparent violation described in Inspection Report 98-02, sent to you on May 15, 1998, the NRC decided that an additional enforcement conference was not needed to discuss this issue.

Based on the information developed during the inspections and the investigation, and the information provided during the conferences, seven violations of NRC requirements are being cited and are described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties (Notice). The violations reflect fundamental performance problems related to conduct of surveillance test activities, maintenance of accurate records, and completion of appropriate corrective actions to preclude repetition of problems at your facility.

The first two violations, which are set forth in Section I of the enclosed Notice, involve the failure by your staff to perform certain surveillance testing activities, and creation of inaccurate documents to indicate that these activities had been performed. Specifically, your internal investigation, as well as the OI investigation, found that a Nuclear Production Technician (NPT) falsified surveillance test records. The records indicated that the NPT had performed inspections of emergency battery lights in the primary auxiliary building (PAB), as well as a second verification of two steps in an emergency diesel generator (EDG) surveillance test. Both tests are required by your license or Technical Specifications (TS). The investigations revealed that the emergency battery light tests could not have been performed as required by the test procedure, because the NPT, and another NPT who was assigned to assist with the emergency light tests, were not in the PAB for a sufficient period of time to complete the checks of the 33 emergency lights. In addition, 10 days after the emergency light tests were documented as completed, several of the emergency lights in the PAB were found to have low water levels in the battery cells. If the tests had been performed, this condition would have been identified, and adherence to the test procedure would have required correction of the degraded conditions. Similarly, the investigations concluded that the second verification of steps in the EDG surveillance test could not have been performed because the NPT did not enter the EDG building on the day that the activities were documented as having been performed. These record falsifications were considered deliberate because the evidence shows that the tests were not done, that the NPT understood the procedures requiring performance of the tests, and that the NPT knew that the tests were not done and admitted that he had signed the test records.

While the NRC is concerned with the actions of the NPT in this case, of even greater concern is the consideration that the emergency battery light tests may not have been performed in accordance with the procedure on multiple occasions in the last several years. The OI investigation determined that it was not uncommon for NPTs to sign records for completion of actions that they had not personally performed. It also indicated that the NPTs did not have a clear understanding of their responsibility for adhering to procedures. It appears that there was an informal attitude toward procedural adherence among the NPTs. This is troubling as it is consistent with previously documented procedure adherence problems. At the conference you acknowledged that, although you had communicated management's expectations regarding procedural adherence, you had not provided supervisory oversight in the field to reinforce those expectations. Therefore, considering the significance that the NRC attributes to deliberate violations of requirements, and the lack of management attention towards licensed responsibilities that these violations represent, the violations set forth in Section I of the Notice are classified in the aggregate as a Severity Level III problem in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600 (Enforcement Policy).

The third violation, which is set forth in Section II of the enclosed Notice, involved your failure to determine the cause and take adequate corrective actions to preclude repetition of a significant condition adverse to quality involving 480 volt (V) safety-related circuit breakers. Specifically, between August 1993 and May 1997, there were multiple instances in which Westinghouse DB-50 480V circuit breakers failed to close on demand. Although you had recently upgraded your root cause analysis process in response to previously identified weaknesses in your corrective action processes, the root cause analysis for the DB-50 breaker failures performed using the new process was inadequate for the following reasons. In May 1997, you assembled a team, and hired contractors with expertise on Westinghouse DB-50 circuit breakers to conduct a root cause analysis, using the upgraded process, of the recurring breaker failures. The root causes identified by the team were not clearly supported by the "as found" condition of the breakers. More importantly, because your root cause analysis focused on restoration of the original design basis of the breakers, and did not consider potential deficiencies in the original design, the analysis did not address all credible failure modes that could have prevented the breakers from closing. As a result, although you initiated corrective actions in July 1997 based on the results of the team's root cause analysis, additional breaker failures occurred in August 1997 and October 1997.

The potential safety consequences of the DB-50 breaker failures are significant because approximately 60 DB-50 breakers are installed at Indian Point 2 and are used to provide power to safety-related loads, including the containment spray pumps, auxiliary boiler feedwater (AFW) pumps, residual heat removal pumps, and safety injection pumps. In many cases, these breakers are relied upon to close automatically, such as in response to a safety injection signal or upon the occurrence of a loss of offsite power. Failure of the breakers to close on demand would require operator action to reset and manually reclose the breaker to restore the equipment to service. Therefore, given the potential safety consequences of the breaker failures, as well as your continuing difficulties in implementing effective corrective action processes, this violation is also classified at Severity Level III in accordance with the Enforcement Policy.

The fourth violation, which is set forth in Section III of the Notice, involved the failure to assure that all testing, required to demonstrate that systems and components will perform satisfactorily in service, as specified in the TSs, was incorporated into surveillance test procedures. In February 1998, you conducted a review of the TS surveillance program which identified approximately 170 discrepancies between the TS testing requirements and the surveillance test procedures. These discrepancies included cases in which: (1) the TS surveillance requirement or TS basis statements did not match the plant design; (2) no surveillance test existed to implement a TS requirement; (3) the surveillance test acceptance criteria were not consistent with the TS, or lacked supporting engineering analysis to document the basis for the criteria; (4) surveillance tests were not performed at the required frequency specified in TS; and (5) inconsistencies existed within TS surveillance requirements. The NRC also identified some additional discrepancies while evaluating your review process. Collectively, these discrepancies represent a programmatic weakness in implementing TS requirements; therefore, this violation is classified at Severity Level III in accordance with the Enforcement Policy.

A base civil penalty in the amount of $55,000 is considered for each Severity Level III violation or problem. Since Indian Point 2 has been the subject of escalated enforcement actions within the last 2 years, ⁽¹⁾ 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 for each of the Severity Level III violations and problem. With respect to the violations in Section I, credit for identification is not warranted. Although you identified the violations during your investigation, that investigation was conducted as a result of NRC identification of the degraded battery conditions. With respect to the violation in Section II, credit for identification is not warranted because the failure to preclude recurrence of the DB-50 breaker failures was self-revealing when the additional breaker failures occurred, and the NRC subsequently identified the deficiencies in your root cause analysis. With respect to the violation in Section III, credit is warranted for identification because the vast majority of the testing discrepancies were identified by your review effort. For all of the violations in Sections I, II, and III, credit is warranted for your corrective actions because those actions were considered prompt and comprehensive. These actions included: (1) review of other surveillance test records to ensure that all required tests had been performed; (2) discussions with plant staff to emphasize management's expectations for procedure adherence and documentation of activities; (3) revisions to the emergency battery light test procedure; (4) development of a NPT training program; (5) additional analysis of the DB-50 breaker failures; (6) implementation and testing of DB-50 breaker design modifications; (7) improvements to your root cause analysis process including training of team members and improved use of industry experience; and (8) testing, procedure revisions, and changes to TSs to address the testing deficiencies. The NRC plans to continue to follow your actions closely to determine the effectiveness of your actions in precluding future problems.

Based on the above, separate $55,000 civil penalties are warranted for the Severity Level III problem in Section I and the Severity Level III violation in Section II of the enclosed Notice. Therefore, to emphasize the importance of (1) performing activities in accordance with procedures and accurately documenting such performance, and (2) preventing recurrence of problems at the facility, I have been authorized, after consultation with the Office of Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the cumulative amount of $110,000 for the violations in Sections I and II of the Notice. No civil penalty is warranted for the violation in Section III of the Notice.

Three other violations identified during the inspections have been classified individually at Severity Level IV and are set forth in Section IV of the enclosed Notice. These violations involved the failure to take prompt corrective actions for identified deficiencies in the post accident containment vent (PACV) and hydrogen recombiner systems and an inadequate procedure for operation of the PACV system.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. As provided for in the enclosed Notice, you are required to include a description of the reasons for the violations, if admitted, and your corrective action. This description should address the actions taken following identification and the long term comprehensive actions taken or that will be taken to prevent recurrence. Your response should be submitted under oath or affirmation and may reference or include previous docketed correspondence if the correspondence adequately addresses the required response. In addition, if you dispute any of the enclosed violations or their severity levels, you should describe the basis for the dispute in your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

With respect to the violation set forth in Section III of the enclosed Notice, based on the information developed during the inspection, the NRC had sufficient information to conclude that a civil penalty is not warranted; therefore, this action is being issued without holding a predecisional enforcement conference. If the NRC is satisfied with your response to this violation, you will be notified that this enforcement action is completed. However, if your corrective action, as documented in your required response, is not sufficiently prompt and comprehensive such that a civil penalty may be warranted, we may telephone you or schedule a predecisional enforcement conference with you. Further, you may request that an enforcement conference be held to discuss this violation, in which case, please advise Mr. John Rogge at (610) 337-5146 within seven days of the date of this letter. In the absence of such a request but where matters are disputed, we may also elect to hold an enforcement conference. In the event that a conference is to be held, it will be scheduled at least two weeks after receiving the written response to the Notice. Following review of any disputes and the record of the conference, if held, a decision will be made to modify, withdraw, or affirm the Notice and, if warranted, issue a civil penalty.

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 (PDR).

 

	Sincerely,
	Original Signed by
	Hubert J. Miller Regional Administrator

Docket No. 50-247
License No. DPR-26

Enclosure: Notice of Violation Proposed Imposition of Civil Penalties

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NOTICE OF VIOLATION
AND
PROPOSED IMPOSITION OF CIVIL PENALTIES

Consolidated Edison Company of New York, Inc. Indian Point 2 Nuclear Generating Station

Docket No. 50-247 License No. DPR-26 EA Nos.: 97-576; 98-028; 98-056; 98-192

During NRC inspections conducted between October 27, 1997 and March 23, 1998, for which exit meetings were held on November 14, 1997, and January 23, January 30, and April 23, 1998, and during an investigation conducted by the NRC Office of Investigations (OI) from September 25, 1997, until January 22, 1998, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the Nuclear Regulatory Commission proposes to impose civil penalties 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 penalties are set forth below:

I.	VIOLATIONS RELATED TO INACCURATE INFORMATION 10 CFR 50.9 requires, in part, that information required by the Commission's regulations to be maintained by the licensee shall be complete and accurate in all material respects. Technical Specification Section 6.8.1 requires written procedures be implemented covering activities referenced in Regulatory (Safety) Guide 1.33, November 1972. Appendix A of Regulatory Guide 1.33, recommends, in part, written procedures for performance of surveillance tests and for record retention. Station Administrative Order (SAO)-521, "Records Management Program," provides instructions for the identification and storage of completed records. Section 4.1 of SAO-521, requires, in part, that quality assurance records be maintained in accordance with ANSI N45.2.9-1994, "Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants." Appendix A, Section A.6.1 of this document, specifies retention of records dealing with periodic checks, inspections, and calibrations performed to verify surveillance requirements are being met.
	A.	Consolidated Edison surveillance test PT-M49B, "Appendix R Emergency Lighting (Nuclear)," provides instructions for monthly checks of the emergency battery lighting required by the NRC-approved fire protection program required by License Condition 2.K. PT-M49B provides instructions for inspections of 33 emergency battery lights in the primary auxiliary building (PAB) and requires signatures for completion/performance of all procedure steps. Contrary to the above, on August 8, 1997, the emergency battery lights in the PAB were not tested in accordance with PT-M49B, yet records were created that indicated that the lights had been tested. Specifically, a Nuclear Production Technician (NPT) signed that he had completed all of the checks required by PT-M49B. However, on August 8, 1997, the NPT was only in the PAB for a period of 15 minutes and the other NPT assigned to assist with the checks was only in the PAB for a period of 17 minutes; it is not possible to complete all the checks of the 33 emergency battery lights in a period of 32 minutes. These records were material because they indicate whether certain required safety activities had been completed. (01013)
	B.	Consolidated Edison surveillance test PT-W1, "Emergency Diesel Generator," establishes a weekly surveillance test of the emergency diesel generator auxiliaries. Steps 3.4.1 and 3.5.2 of PT-W1 require double verification that the steps have been performed and require that the double verification be documented. Contrary to the above, on August 8, 1997, the double verifications of steps 3.4.1 and 3.5.2 of PT-W1, which involved checks of the diesel generator compressor, were not performed, yet records were created that indicated that the second verifications had been performed. An NPT signed the data sheet indicating that he had performed the second verification of the steps; however, the NPT did not enter the emergency diesel generator building on August 8, 1997. Therefore, he could not have performed the second verifications. These records were material because they indicate certain required safety activities had been completed when in fact they had not been completed. (01023)
	These violations represent a Severity Level III problem. (Supplement VII). Civil Penalty - $55,000.
II.	VIOLATION RELATED TO DB50 BREAKERS 10 CFR Part 50 Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, deficiencies, and deviations, defective material and equipment are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. Contrary to the above, between August 1993 and October 14, 1997, the licensee failed to determine the cause and take corrective action to preclude repetition of a significant condition adverse to quality involving failures of safety-related electrical breakers. Specifically, a root cause analysis performed in June 1997 to address multiple recurring failures of Westinghouse DB-50 breakers (that occurred between August 1993 and May 1997) was inadequate in that the analysis did not address all credible failure modes that could have prevented the breakers from closing. For example, the analysis did not address inadequate weight on the trip bar as a credible failure mode. In addition, the identified causes (malfunctioning amptectors and binding of the operating mechanisms due to accumulated dust, dirt, and lubricant) were not supported by the facts (e.g., there was little evidence of dust and hardened lubricant), and it was later determined that these factors were not significant contributors to the failures. As a result, corrective actions taken in July 1997 failed to preclude repetition of failures of DB-50 circuit breakers on August 13 and October 14, 1997. The failure of these breakers is considered a significant condition adverse to quality because it could prevent safety-related equipment from starting during an accident. (02013)
	This violation is classified at Severity Level III (Supplement I). Civil Penalty - $55,000.
III.	VIOLATION RELATED TO TECHNICAL SPECIFICATION SURVEILLANCE TESTING 10 CFR Part 50, Appendix B, Criterion XI, "Test Control," requires, in part, that a test program be established to assure that all testing required to demonstrate that systems and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Contrary to the above, prior to January 1998, the Technical Specification (TS) surveillance test program did not assure that all testing required to demonstrate that systems and components will perform satisfactorily in service as specified in the plant technical specifications was incorporated into test procedures. Examples of deficiencies in the surveillance test program included:
	1)	No surveillance test existed to assure that the requirements of TS 4.4.D.2.b, governing service water in-leakage into containment in the event of a loss of fan cooler unit integrity, were met;
	2)	No surveillance test existed to verify that the steam generator blowdown valves isolate during an automatic initiation of auxiliary feedwater as required by TS Table 4.1-1, Item 30;
	3)	No procedural requirements existed to calibrate the service water inlet temperature monitoring system prior to service water temperature exceeding 80 degrees F, as required by TS Table 4.1-1, Item 45; and
	4)	Surveillance procedure PT-V16 only required a differential pressure of greater than 100 psid while performing leak testing across certain reactor coolant system pressure isolation valves, although TS 4.16.A.5, requires that a minimum differential pressure of 150 psid across the valves being tested. (03013)
	This violation is classified at Severity Level III (Supplement I).
IV.	VIOLATIONS RELATED TO CONTAINMENT ATMOSPHERE CONTROL
	A.	10 CFR Part 50 Appendix B, Criterion XVI, in part, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment are promptly identified and corrected.
		1.	Contrary to the above, as of December 31, 1997, measures were not established to assure that conditions adverse to quality identified in work orders on the Post Accident Containment Venting System (PACVS) were promptly corrected. Specifically, on October 19, 1993, work order 93-67432 identified that a flow meter (FM-1249) indicated incorrectly, and on February 1, 1995, work order 95-75719 identified that flow integrator (FZ-1249) was not responding to input signals. This equipment is needed to permit the proper operation of the system as directed in its associated system operating procedure (SOP). However, these deficiencies were not corrected as of December 31, 1997. (04014)
		2.	Contrary to the above, as of December 31, 1997, measures were not established to assure that conditions adverse to quality identified in work orders on the hydrogen recombiners were evaluated and either promptly corrected or adequately compensated for until corrective actions could be effected. Specifically,
			a.	On October 22, 1994, work order 94-74545 identified that repair/replacement of the 21 hydrogen recombiner RC-1A ratio control was needed.
			b.	On October 23, 1996, work order 96-86886 identified that the 22 hydrogen recombiner hydrogen pressure gauge (PI)-5B was pegged high.
			c.	On April 8, 1997, work order 97-90343 identified that the 22 hydrogen recombiner low pressure alarm was not working as a result of its associated pressure switch being broken.
			These deficiencies could have impacted the operability of safety-related equipment required to be operable in accordance with Technical Specifications. However, these deficiencies were not corrected as of December 31, 1997. (05014) This violation is classified at Severity Level IV (Supplement I).
	B.	TS 6.8.1 requires that written procedures be established covering activities referenced in Regulatory (Safety) Guide 1.33, November 1972. Appendix A of Regulatory (Safety) Guide 1.33 recommends written procedures that govern operation of safety-related systems including containment cleanup systems. An example of a procedure to operate a containment cleanup system is System Operating Procedure (SOP) 10.9.2, "Post Accident Vent System Operation." Contrary to the above, until corrected by revision on October 20, 1997, SOP 10.9.2 was inadequate because it did not reflect the proper containment pressure for system operation. The technical specification basis for the post-accident containment vent system (PACVS) states that a minimum internal containment pressure of 2.14 psig is required for the system to operate properly. The Updated Final Safety Analysis Report, section 6.8.2.2, states that the PACVS requires a differential pressure between the containment and the outside atmosphere in order to permit venting and that this is based on a pressure of 2.14 psig in the containment. However, step 2.6 of SOP 10.9.2 stated that the minimum containment pressure for proper operation of the PACVS was 0.5 psig. Also, steps 4.1.9, 4.2.1, and 4.2.2, referenced the incorrect pressure value of 0.5 psig. (06014) This violation is classified Severity Level IV (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Consolidated Edison Company of New York, Inc. (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 receipt of this Notice of Violation and Proposed Imposition of Civil Penalties (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 to 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 penalties 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 penalties proposed above, or may protest imposition of the civil penalties, 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 penalties will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may: (1) deny the violations 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 penalties should not be imposed. In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.

In requesting mitigation of the proposed penalties, 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 that 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: Mark Satorius, Deputy 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 I, and a copy to the NRC Senior 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, proprietary, or safeguards 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 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.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.

Dated at King of Prussia, Pennsylvania
this 6th day of July 1998

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¹ e.g., A Notice of Violation and Proposed Imposition of Civil Penalties in the amount of $110,000 was issued on October 7, 1997 (EA 97-367), and a Notice of Violation and Proposed Imposition of Civil Penalties in the amount of $205,000 was issued on May 27, 1997 (EAs 96-509, 97-031, 97-113, and 97-191). Both of these actions included violations for failure to identify and correct problems at the facility.