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Category:Enforcement Action
MONTHYEARIR 05000388/20210122021-03-0404 March 2021 EA-20-131: Susquehanna Steam Electric Station, Unit 2 - NRC Investigation Report No. 1-2020-001 and NRC Inspection Report No. 05000388/2021012 IR 05000387/20190032019-11-12012 November 2019 Integrated Inspection Report 05000387/2019003 and 05000388/2019003 and Independent Spent Fuel Storage Installation Inspection Report 07200028/2019001 ML15173A2972015-06-22022 June 2015 EA-15-022 Susquehanna Final Significance Determination for a White Finding with Assessment Follow-up and Notice of Violation (Inspection Report No. 05000387/2015504 and 05000388/2015504) ML15167A1482015-06-16016 June 2015 EN-15-020, Issuance of Final Significance Determination and Notice of Violation to Susquehanna Nuclear, LLC, Susquehanna Steam Electric Station, Units 1 & 2, (EA-15-022) IR 05000387/20130122013-08-28028 August 2013 NRC Inspection Report 05000387/2013012 and 05000388/2013012; and Notice of Violation IR 05000387/20114032011-03-28028 March 2011 IR 05000387-11-403, 05000388-11-403, on 02/07/2011 - 02/11/2011, Susquehanna Steam Electric Station, Access Control, Protective Strategy Evaluation. (Letter Only) IR 05000387/20100082010-12-16016 December 2010 Final Significance Determination of White Finding, with Assessment Follow-up - Susquehanna Steam Electric Station (NRC Inspection Report No. 05000387/2010008 and 05000388/2010008), Dated December 16, 2010 IR 05000387/20090042010-01-28028 January 2010 EA-09-248, Susquehanna, Notice of Violation (NRC Inspection Report Nos. 05000387/2009004 and 05000388/2009004) ML0908505012009-03-26026 March 2009 EN-09-016 - Order Prohibiting Involvement in NRC-Licensed Activities ML0718303172007-07-0202 July 2007 EA-07-083, Susquehanna Steam Electric Station - NRC Investigation Report No. 1-2006-047 2021-03-04
[Table view] Category:Enforcement Guidance Memorandum
MONTHYEARIR 05000387/20130122013-08-28028 August 2013 NRC Inspection Report 05000387/2013012 and 05000388/2013012; and Notice of Violation 2013-08-28
[Table view] Category:Inspection Report
MONTHYEARIR 05000387/20230042024-02-0707 February 2024 Integrated Inspection Report 05000387/2023004 and 05000388/2023004 IR 05000387/20230102023-12-11011 December 2023 Fire Protection Team Inspection Report 05000387/2023010 and 05000388/2023010 IR 05000387/20230032023-11-0303 November 2023 Integrated Inspection Report 05000387/2023003 and 05000388/2023003 IR 05000387/20233012023-09-20020 September 2023 Initial Operator Licensing Examination Report 05000387/2023301 and 05000388/2023301 IR 05000387/20230052023-08-31031 August 2023 Updated Inspection Plan for Susquehanna Steam Electric Station, Units 1 and 2 (Report 05000387/2023005 and 05000388/2023005) IR 05000387/20230022023-08-0101 August 2023 Integrated Inspection Report 05000387/2023002 and 05000388/2023002 IR 05000387/20234012023-06-0707 June 2023 Security Baseline Inspection Report 05000387/2023401 and 05000388/2023401 IR 05000387/20230012023-05-12012 May 2023 Integrated Inspection Report 05000387/2023001 and 05000388/2023001 IR 05000387/20220062023-03-0101 March 2023 Annual Assessment Letter for Susquehanna Steam Electric Station, Units 1 and 2 (Reports 05000387/2022006 and 05000388/2022006) IR 05000387/20220042023-02-0808 February 2023 Integrated Inspection Report 05000387/2022004 and 05000388/2022004 IR 07200028/20220012022-12-15015 December 2022 Independent Spent Fuel Storage Installation (ISFSI) - NRC Inspection Report No. 07200028/2022001 IR 05000387/20224032022-11-29029 November 2022 Security Baseline Inspection Report 05000387/2022403 and 05000388/2022403 IR 05000387/20225012022-11-28028 November 2022 Emergency Preparedness Biennial Exercise Inspection Report 05000387/2022501 and 05000388/2022501 IR 05000387/20224042022-11-0909 November 2022 Cyber Security Inspection Report 05000387/2022404 and 05000388/2022404 (Cover Letter Only) IR 05000387/20220032022-11-0808 November 2022 Integrated Inspection Report 05000387/2022003 and 05000388/2022003 IR 05000387/20220132022-09-28028 September 2022 Design Basis Assurance Inspection (Teams) Inspection Report 05000387/2022013 and 05000388/2022013 IR 05000387/20220052022-08-31031 August 2022 Updated Inspection Plan for Susquehanna Steam Electric Station, Units 1 and 2 (Report 05000387/2022005 and 05000388/2022005) IR 05000387/20220102022-08-11011 August 2022 Biennial Problem Identification and Resolution Inspection Report 05000387/2022010 and 05000388/2022010 IR 05000387/20224012022-08-11011 August 2022 Material Control and Accounting Program Inspection Report 05000387/2022401 and 05000388/2022401 (Cover Letter Only) IR 05000387/20220022022-08-0404 August 2022 Integrated Inspection Report 05000387/2022002 and 05000388/2022002 IR 05000387/20220012022-05-0909 May 2022 Integrated Inspection Report 05000387/2022001 and 05000388/2022001 IR 05000387/20220112022-03-0707 March 2022 Post-Approval Site Inspection for License Renewal - Phase 2 Inspection Report 05000387/2022011 IR 05000387/20210062022-03-0202 March 2022 Annual Assessment Letter for Susquehanna Steam Electric Station, Units 1 and 2 (Reports 05000387/2021006 and 05000388/2021006) IR 05000387/20224022022-02-16016 February 2022 Security Baseline Inspection Report 05000387/2022402 and 05000388/2022402 IR 05000387/20214032022-02-11011 February 2022 Cyber Security Problem Identification and Resolution Inspection Report 05000387/2021403 and 05000388/2021403 (Cover Letter Only) IR 05000387/20210042022-02-11011 February 2022 Integrated Inspection Report 05000387/2021004 and 05000388/2021004 IR 05000387/20210102021-12-13013 December 2021 Design Basis Assurance Inspection (Programs) Inspection Report 05000387/2021010 and 05000388/2021010 IR 05000387/20210112021-11-0404 November 2021 Temporary Instruction 2515/194 Inspection Report 05000387/2021011 and 05000388/2021011 IR 05000387/20210032021-11-0303 November 2021 Integrated Inspection Report 05000387/2021003 and 05000388/2021003 IR 05000387/20214012021-10-25025 October 2021 Security Baseline Inspection Report 05000387/2021401 and 05000388/2021401 IR 05000387/20214022021-09-23023 September 2021 Security Baseline Inspection Report 05000387/2021402 and 05000388/2021402 IR 05000387/20213012021-09-17017 September 2021 Initial Operator Licensing Examination Report 05000387/2021301 and 05000388/2021301 IR 05000387/20210052021-09-0101 September 2021 Updated Inspection Plan for the Susquehanna Steam Electric Station, Units 1 and 2 (Report 05000387/2021005 and 05000388/2021005) ML21224A2402021-08-24024 August 2021 Security Baseline Inspection Report Cover Letter 2021 FOF IR 05000387/20210022021-08-0404 August 2021 Integrated Inspection Report 05000387/2021002 and 05000388/2021002 IR 05000387/20210012021-05-0505 May 2021 Integrated Inspection Report 05000387/2021001 and 05000388/2021001 IR 05000388/20210122021-03-0404 March 2021 EA-20-131: Susquehanna Steam Electric Station, Unit 2 - NRC Investigation Report No. 1-2020-001 and NRC Inspection Report No. 05000388/2021012 IR 05000387/20200062021-03-0303 March 2021 Annual Assessment Letter for Susquehanna Steam Electric Station, Units 1 and 2 (Reports 05000387/2020006 and 05000388/2020006) IR 05000387/20204032021-02-10010 February 2021 Cyber Security Problem Identification and Resolution Inspection Report 05000387/2020403 and 05000388/2020403 (Cover Letter Only) IR 05000387/20200042021-02-0808 February 2021 Integrated Inspection Report 05000387/2020004 and 05000388/2020004 IR 05000387/20205012020-11-18018 November 2020 Emergency Preparedness Biennial Exercise Inspection Report 05000387/2020501 and 05000388/2020501 IR 05000387/20200032020-11-0505 November 2020 Integrated Inspection Report 05000387/2020003 and 05000388/2020003 IR 05000387/20200122020-10-27027 October 2020 Triennial Fire Protection Inspection Report 05000387/2020012 and 05000388/2020012 IR 05000387/20200052020-08-31031 August 2020 Updated Inspection Plan (Inspection Reports 05000387/2020005 and 05000388/2020005) IR 05000387/20200112020-08-18018 August 2020 Biennial Problem Identification and Resolution Inspection Report 05000387/2020011 and 05000388/2020011 IR 05000387/20200022020-08-11011 August 2020 Integrated Inspection Report 05000387/2020002 and 05000388/2020002 IR 05000387/20204012020-07-0202 July 2020 Security Baseline Inspection Report 05000387/2020401 and 05000388/2020401 IR 05000387/20200012020-05-0505 May 2020 Integrated Inspection Report 05000387/2020001 and 05000388/2020001 IR 05000387/20190062020-03-0303 March 2020 Annual Assessment Letter for Susquehanna Steam Electric Station, Units 1 and 2 (Report 05000387/2019006 and 05000388/2019006) IR 05000387/20200102020-02-21021 February 2020 Temporary Instruction 2515/194 Inspection Report 05000387/2020010 and 05000388/2020010 2024-02-07
[Table view] Category:Letter
MONTHYEARIR 05000387/20230042024-02-0707 February 2024 Integrated Inspection Report 05000387/2023004 and 05000388/2023004 PLA-8096, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2024-01-0404 January 2024 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval PLA-8077, Emergency Plan Revision 67 (PLA-8077)2023-12-27027 December 2023 Emergency Plan Revision 67 (PLA-8077) IR 05000387/20230102023-12-11011 December 2023 Fire Protection Team Inspection Report 05000387/2023010 and 05000388/2023010 PLA-8089, Submittal of Revision to Inservice Testing Program Plan2023-12-0505 December 2023 Submittal of Revision to Inservice Testing Program Plan PLA-8084, Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.22023-11-29029 November 2023 Application to Revise Technical Specifications to Adopt TSTF-568, Revise Applicability of BWR TS 3.6.2.5 and TS 3.6.3.2 ML23345A0682023-11-28028 November 2023 Technical Specification Bases, Manual PLA-8091, Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091)2023-11-0808 November 2023 Response to Request for Additional Information Regarding Proposed Relief Request for the Fifth 10-Year Inseervice Inspection Interval (PLA-8091) IR 05000387/20230032023-11-0303 November 2023 Integrated Inspection Report 05000387/2023003 and 05000388/2023003 PLA-8082, Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program2023-11-0202 November 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program ML23291A1132023-10-12012 October 2023 Submittal of Revision 71 to Updated Final Safety Analysis Report and Revision 25 to Fire Protection Review Report ML23279A0612023-10-0505 October 2023 Paragon Energy Solutions LLC, Part 21 Final Report Re Potential Defect with Eaton Jd and Hjd Series Molded Case Circuit Breakers (Mccbs) ML23277A0412023-10-0505 October 2023 Notification of Commercial Grade Dedication Inspection (05000387/2024011 and 05000388/2024011) and Request for Information IR 05000387/20233012023-09-20020 September 2023 Initial Operator Licensing Examination Report 05000387/2023301 and 05000388/2023301 ML23254A0242023-09-0606 September 2023 Paragon Energy Solutions LLC, Potential Defect with Eaton Jd and Hjd Series Molded Case Circuit Breakers (Mccbs) IR 05000387/20230052023-08-31031 August 2023 Updated Inspection Plan for Susquehanna Steam Electric Station, Units 1 and 2 (Report 05000387/2023005 and 05000388/2023005) ML23228A1952023-08-21021 August 2023 Summary of August 10, 2023, Public Observation Meeting Re. Proposed Alternative PLA-8080, Proposed Relief for Valve 251130 (PLA-8080)2023-08-14014 August 2023 Proposed Relief for Valve 251130 (PLA-8080) PLA-8074, Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval2023-08-0303 August 2023 Proposed Relief Request for the Fifth 10-Year Inservice Test Program Interval IR 05000387/20230022023-08-0101 August 2023 Integrated Inspection Report 05000387/2023002 and 05000388/2023002 ML23195A1852023-07-27027 July 2023 Correction to Technical Specifications Page 3.3-73 in Amendment No. 265 PLA-8076, Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076)2023-07-20020 July 2023 Unit 2 - 21st Refueling Outage Owner'S Activity Report (PLA-8076) ML23201A0152023-07-20020 July 2023 Operator Licensing Examination Approval ML23200A1012023-07-19019 July 2023 Notification of Conduct of a Fire Protection Team Inspection ML23193A0062023-07-12012 July 2023 Requalification Program Inspection PLA-8078, Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-80782023-07-0505 July 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report, Revision 1, PLA-8078 ML23163A1012023-06-12012 June 2023 10 CFR 50.46 Annual Report (Pla 8065) PLA-8054, Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence2023-06-0808 June 2023 Proposed Amendment to Licenses NPF-14 and NPF-22: Remove Control Rod Operability Separation Criteria and Replace Reference to Banked Position Withdrawal Sequence with the Analyzed Rod Position Sequence IR 05000387/20234012023-06-0707 June 2023 Security Baseline Inspection Report 05000387/2023401 and 05000388/2023401 PLA-8073, Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval2023-06-0101 June 2023 Proposed Relief Request for the Fifth 10-Year Inservice Inspection Interval PLA-8064, Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064)2023-05-17017 May 2023 Response to NRC Regulatory Issue Summary 2023-01 (PLA-8064) ML23132A3212023-05-17017 May 2023 Associated Independent Spent Fuel Storage Installation - Issuance of Amendment Nos. 285 and 269 Related to Order Approving Transfer of Licenses PLA-8067, Notification of Completion of Emergence from Bankruptcy (PLA-8067)2023-05-17017 May 2023 Notification of Completion of Emergence from Bankruptcy (PLA-8067) IR 05000387/20230012023-05-12012 May 2023 Integrated Inspection Report 05000387/2023001 and 05000388/2023001 PLA-8066, Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-80662023-05-0808 May 2023 Notification of Planned Closing Date and Information Identified in March 30, 2023 Order, PLA-8066 PLA-8053, Radiation Exposure Information and Reporting System2023-04-27027 April 2023 Radiation Exposure Information and Reporting System PLA-8058, Annual Radiological Environmental Operating Report (PLA-8058)2023-04-26026 April 2023 Annual Radiological Environmental Operating Report (PLA-8058) PLA-8041, Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041)2023-04-25025 April 2023 Radioactive Effluent Release Report and Offsite Dose Calculation Manual (PLA-8041) PLA-8047, 2022 Annual Environmental Operating Report (Nonradiological), PLA-80472023-04-19019 April 2023 2022 Annual Environmental Operating Report (Nonradiological), PLA-8047 PLA-8062, Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-80622023-04-11011 April 2023 Supplement to Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 252F007B, PLA-8062 PLA-8061, Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-80612023-04-10010 April 2023 Relief Request 4RR-10 Relief from Code Seal Weld Requirement for Valve 25F007B, PLA-8061 ML23090A2302023-03-31031 March 2023 NRC Decommissioning Funding Status Report PLA-8049 PLA-8060, Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060)2023-03-30030 March 2023 Submittal of Unit 2 Cycle 22 Core Operating Limits Report (PLA-8060) ML23095A0572023-03-29029 March 2023 NRC Decommissioning Funding Status Report December 31, 2022 PLA-8057, Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-80572023-03-15015 March 2023 Application for Order Approving Indirect Transfer of Control of Licenses and Approving Conforming License Amendments- Supplemental Information, PLA-8057 ML23065A1962023-03-0202 March 2023 EN 56387 Paragon - Part 21 Report Re Defect Identified in Automatic Transfer Switch Pn: NLI-ATS480A400X1 IR 05000387/20220062023-03-0101 March 2023 Annual Assessment Letter for Susquehanna Steam Electric Station, Units 1 and 2 (Reports 05000387/2022006 and 05000388/2022006) PLA-8052, (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums2023-02-13013 February 2023 (Sses), Proof of Financial Protection and Guarantee of Payment of Deferred Premiums IR 05000387/20220042023-02-0808 February 2023 Integrated Inspection Report 05000387/2022004 and 05000388/2022004 ML23010A0882023-01-15015 January 2023 Summary of Regulatory Audit in Support of License Amendment Request to Revise Control Rod Technical Specifications 2024-02-07
[Table view] Category:Notice of Violation
MONTHYEARIA-20-025, NRC Office of Investigation Report 1-2019-013 and Notice of Violation2020-03-12012 March 2020 IA-20-025 NRC Office of Investigation Report 1-2019-013 and Notice of Violation ML15173A2972015-06-22022 June 2015 EA-15-022 Susquehanna Final Significance Determination for a White Finding with Assessment Follow-up and Notice of Violation (Inspection Report No. 05000387/2015504 and 05000388/2015504) IR 05000387/20140092014-08-0101 August 2014 IR 05000387-14-009 and 05000388-14-009, and Notice of Violation, June 2-6, 2014 and June 16-20, 2014, Susquehanna Steam Electric Station, NRC Problem Identification and Resolution IR 05000387/20130132013-09-25025 September 2013 NRC Investigation Reports 1-2012-012, 1-2012-043, 1-2011-030, and NRC Inspection Report 05000387-13-013 & 05000388-13-013; and Notice of Violation IR 05000387/20130122013-08-28028 August 2013 NRC Inspection Report 05000387/2013012 and 05000388/2013012; and Notice of Violation ML1200603002012-01-0606 January 2012 IA-11-055 G. Rinehart, Notice of Violation (NRC Office of Investigation Report No. 1-2010-055) PLA-6791, Reply to Notice of Violation, EA-11-244, PLA-67912011-12-0808 December 2011 Reply to Notice of Violation, EA-11-244, PLA-6791 IR 05000387/20110042011-11-0808 November 2011 IR 05000387-11-004, 05000388-11-004; on 07-01-11 - 9-30-11; Susquehanna Steam Electric Station - NRC Integrated Inspection Report and Notice of Violation IR 05000387/20090042010-01-28028 January 2010 EA-09-248, Susquehanna, Notice of Violation (NRC Inspection Report Nos. 05000387/2009004 and 05000388/2009004) 2020-03-12
[Table view] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ust 28, 2013
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION - NRC INSPECTION REPORT 05000387/2013012 AND 05000388/2013012; AND NOTICE OF VIOLATION
Dear Mr. Rausch:
This letter provides you the NRC enforcement decision for the apparent violations documented in Inspection Report 05000387/2013008 and 05000388/2013008, issued to PPL Susquehanna LLCs (PPLs) Susquehanna Steam Electric Station (SSES) on June 17, 2013 (ML13168A020)1.
The apparent violations, associated with licensed reactor operator medical examinations and related NRC reporting requirements, were discussed with SSES representatives at an inspection exit meeting on May 22, 2013, and documented in the subject inspection report. The report also included a cross-cutting aspect assigned to a Green Reactor Oversight Process (ROP) finding associated with one of the apparent violations.
The June 17, 2013, NRC letter transmitting the inspection report also: (1) notified you that two of the apparent violations were being considered for escalated enforcement in accordance with the NRC Enforcement Policy; (2) noted that the report included the associated Green ROP finding for PPL not implementing effective corrective actions to prevent the recurrence of one of the violations; and (3) provided you with the opportunity to address these apparent violations by either attending a pre-decisional enforcement conference or by providing a written response before we made our final enforcement decision. In a letter dated July 17, 2013 (ML13199A179),
PPL provided a response which acknowledged the violations, but also expressed disagreement with the cross-cutting aspect assigned to the Green ROP finding.
Based on the information developed during the inspection and the information that you provided in your July 17, 2013, letter, the NRC has determined that violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the subject inspection report and in the NRCs June 17, 2013, letter.
Designation in parentheses refers to an Agency-wide Documents Access and Management System (ADAMS) accession number. Documents referenced in this letter are publicly-available using the accession number in ADAMS. The first violation involved multiple occurrences between August 2007 and June 2012, in which PPL: (a) did not restrict licensed reactor operators from performing licensed duties when they had disqualifying medical conditions; and (b) did not properly notify the NRC after learning of changes in licensed reactor operator medical conditions that involved permanent disabilities/illnesses. Specifically, four licensed reactor operators at SSES developed disqualifying medical conditions that were not properly evaluated by PPL staff. PPL did not restrict the operators from performing licensed duties or obtain NRC approval (by requesting conditioned licenses) for the operators to continue to perform licensed duties. Additionally, the NRC identified eight instances in which PPL did not notify the NRC within 30 days of learning of changes in licensed operator medical conditions that involved permanent disabilities/illnesses.
This resulted in the operators performing licensed operator duties without their licenses being properly amended to add requirements to accommodate the medical conditions (such as requiring an operator to wear prescribed corrective lenses if (s)he did not meet the minimum vision requirements).
The second violation involved PPLs submittal of information to the NRC that was not complete and accurate in all material respects. Specifically, between 2010 and 2011, PPL submitted three licensed operator renewal applications and one initial license application, each of which certified the medical fitness of the applicants and that no restricting license conditions were necessary. However, the applicants, in fact, each had medical conditions that did not meet the minimum standards of 10 CFR 55.33(a)(1) and, therefore, required specific license conditions in order to perform licensed activities. Based, in part, on this inaccurate information, the NRC issued the licenses without the required restricting license conditions.
The NRC has concluded that both violations occurred as a result of PPLs failure to: (1) oversee the licensed operator medical examination process; (2) train staff on the applicable NRC requirements; and (3) implement an effective licensed operator medical program that maintained awareness of NRC and industry guidance. Specifically, when PPLs Medical Review Officer (MRO) assumed the position in 2007, he was not provided turnover or training from PPL regarding licensed operator medical requirements. The PPL MRO relied upon exams that were performed by a physician and his staff at a local hospital. Similarly, the physician that performed the exams at the local hospital had not been trained on, nor had knowledge of, the applicable NRC requirements. Accordingly, these violations have been categorized collectively as a SL III problem to emphasize the importance of providing suitable training, oversight, and focus on licensed operator medical requirements.
In accordance with the NRC Enforcement Policy, a base civil penalty in the amount of $70,000 is considered for a Severity Level III problem. Because PPL has not been the subject of escalated traditional enforcement action within the last two years, the NRC considered whether credit was warranted for Corrective Action in accordance with the civil penalty assessment process in Section 2.3.4 of the Enforcement Policy. The NRC has concluded that credit is warranted for PPLs corrective actions. Specifically, PPL: (1) trained the MRO and the site nurse on the specific requirements; (2) revised the site implementing procedure to include requirements for the MRO and nurse to receive annual refresher training and to attend an industry conference; and (3) hired a contract company with specialized knowledge of the NRC requirements in this area, to temporarily oversee its licensed operator medical program.
Therefore, to encourage prompt and comprehensive correction of violations, and in recognition of the absence of previous escalated traditional enforcement action, I have been authorized, after consultation with the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty. The NRC has concluded that information regarding: (1) the reasons for the violations; (2) the actions planned or already taken to correct the violations and prevent recurrence; and (3) the date when full compliance was achieved, is already adequately addressed on the docket in Inspection Report 05000387/2013008 and 05000388/2013008, the NRC letter dated June 17, 2013, the PPL letter dated July 17, 2013, and in this letter. Therefore, you are not required to respond to this Notice. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
The NRC evaluated PPLs disagreement with the Problem Identification and Resolution -
Evaluation P.1(c) cross-cutting aspect (CCA) assigned to the Green ROP finding for the lack of effective corrective actions to prevent the recurrence of this issue following the issuance of similar violations in 2009 and 2011. In part, PPL stated that Human Performance - Decision Making H.1(b) would be a more appropriate CCA, due to PPLs failure to take prompt actions to restrict affected operators from licensed duties. Although the NRC acknowledges that non-conservative decision-making was a factor, we maintain that PPLs failure to appropriately evaluate the issue was the most significant contributing cause.
PPL also indicated that the issue was not indicative of current performance because of improvements to PPLs condition report procedure, which governs the performance of root cause evaluations. While the NRC did not fully agree with the basis provided in your letter, we did consider that NRC Inspection Manual Chapter 0612, Power Reactor Inspection Reports, Section 03.15 states that, in some rare or unusual cases, other considerations can be applied to determine if a CCA is reflective of current performance. As one example, a CCA can be considered to not reflect current performance if the performance characteristic has been corrected or eliminated (i.e., the performance deficiency would not likely occur today under similar circumstances due to changes made to licensee programs and processes). The NRC acknowledges that, during the time period between identification of this most recent issue until the inspection exit and ultimate report issuance, PPL made significant process and procedure changes associated with medical examinations and reporting (beyond changes to the referenced condition report procedure) previously described in this letter. As such, the stated performance deficiency (PPLs failure to implement adequate corrective actions to prevent this recurrence) was no longer considered indicative of current performance. As a result, the NRC has concluded that a CCA should not be assigned to the Green finding.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room and in the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, 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 information, 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 2.390(b) to support a request for withholding confidential commercial or financial information).
The NRC also includes significant enforcement actions on its Web site at (http://www.nrc.gov/reading-rm/doc-collections/enforcement/actions/).
Sincerely,
/RA/
William M. Dean Regional Administrator Docket Nos. 50-387; 50-388 License Nos. NPF-14; NPF-22 Enclosure: Notice of Violation cc w/enclosure: Distribution via ListServ