ML15336A696
| ML15336A696 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/02/2015 |
| From: | Michael Scott Division Reactor Projects I |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Juan Ayala | |
| References | |
| 1-2014-029, EA-15-087 | |
| Download: ML15336A696 (4) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 December 2, 2015 EA-15-087 Mr. Bryan C. Hanson Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
NRC INVESTIGATION REPORT NO. 1-2014-029
Dear Mr. Hanson:
This letter refers to the subject investigation by the U.S. Nuclear Regulatory Commission (NRC)
Office of Investigations (OI) conducted at your Limerick Generating Station (LGS). The investigation, which was completed on April 10, 2015, was conducted to determine whether a Radiation Protection Supervisor (RPS) deliberately failed to follow licensee procedures pertaining to the possession and/or use of illegal drugs at LGS. Additionally, the investigation also evaluated whether the RPS deliberately failed to report the use of prescription medication as required by Exelon procedures.
Based on the evidence gathered during the OI investigation, the NRC concluded that the RPS did not deliberately fail to report the use of prescription medication as required by procedure. Nor was evidence found that he deliberately failed to follow licensee procedures pertaining to the possession and/or use of prescription/illegal drugs at LGS.
In accordance with Exelon procedure, SY-AA-102-206, Reporting Use of Medication, revision 7, individuals were required, in part, to report the use of prescription medication to their supervisor if they believed the prescription may impair their alertness, judgment, or any other ability to safely perform their job duties. On February 7, 2014, the procedure was revised to revision 8 and required individuals to report the use of prescription medication upon receiving any prescription that indicates taking the medication may affect their ability to perform their job duties. During the 2012 and 2013 timeframe, the RPS was prescribed medication, including an antibiotic and a pain medication, for two major illnesses. The RPS reported the use of the antibiotic because it was taken while at work, but did not report the use of pain medication because it was not taken at work and he did not believe it would have an impact on his ability to perform the job. The RPS was also prescribed antibiotics and pain medication in 2013 following another surgery, but he did not report the use of the medication because the medication was not taken at times that he believed would impact his ability to perform the job. Because the RPS had completed his annual refresher training on January 24, 2014, prior to revision 8 being implemented, the NRC concluded that the RPS understanding of requirements for reporting of prescription medication taken in 2012 and 2013 was consistent with revision 7 of the procedure, the latest version of the procedure of which he was likely aware.
After reviewing the specific circumstances regarding this issue, the NRC concluded that no violation of regulatory requirements occurred. However, NRC notes that other individuals, in addition to the RPS, lacked a clear understanding of Exelon Procedure, SY-AA-102-206, Reporting Use of Medication which may be indicative of a training issue.
You are not required to respond to this letter. However, should you choose to respond, your response should be sent to the U.S. Nuclear Regulatory Commission, ATTN: Regional Administrator, Region I, 2100 Renaissance Boulevard, Suite 100, King of Prussia, PA 19406, and marked Open by Addressee Only, within 30 days of the date of this letter, with a copy to the NRC Senior Resident Inspector at LGS. If Security Related Information is necessary to provide an acceptable response, please mark your entire response Security-Related Information in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room and from the NRCs Agency-wide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. However, the material enclosed herewith contains Security-Related Information in accordance with 10 CFR 2.390(d)(1), and its disclosure to unauthorized individuals could present a security vulnerability. Therefore, the material in the enclosure will not be made available electronically for public inspection in the NRC Public Document Room or from ADAMS.
Should you have any questions regarding this letter, please contact Mr. Daniel L. Schroeder at 610-337-5262.
Sincerely,
/RA/
Michael L. Scott, Director Division of Reactor Projects Docket Nos.
50-352, 50-353 License Nos. NPF-39, NPF-85 cc w/encl: Distribution via ListServ
After reviewing the specific circumstances regarding this issue, the NRC concluded that no violation of regulatory requirements occurred. However, NRC notes that other individuals, in addition to the RPS, lacked a clear understanding of Exelon Procedure, SY-AA-102-206, Reporting Use of Medication which may be indicative of a training issue.
You are not required to respond to this letter. However, should you choose to respond, your response should be sent to the U.S. Nuclear Regulatory Commission, ATTN: Regional Administrator, Region I, 2100 Renaissance Boulevard, Suite 100, King of Prussia, PA 19406, and marked Open by Addressee Only, within 30 days of the date of this letter, with a copy to the NRC Senior Resident Inspector at LGS. If Security Related Information is necessary to provide an acceptable response, please mark your entire response Security-Related Information in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room and from the NRCs Agency-wide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. However, the material enclosed herewith contains Security-Related Information in accordance with 10 CFR 2.390(d)(1), and its disclosure to unauthorized individuals could present a security vulnerability.
Therefore, the material in the enclosure will not be made available electronically for public inspection in the NRC Public Document Room or from ADAMS.
Should you have any questions regarding this letter, please contact Mr. Daniel L. Schroeder at 610 337-5262.
Sincerely,
/RA/
Michael L. Scott, Director Division of Reactor Projects Docket Nos.
50-352, 50-353 License Nos. NPF-39, NPF-85 cc w/encl:
Distribution via ListServ ML15336A696 DOCUMENT NAME:S:\\Enf-allg\\Enforcement\\Proposed-Actions\\Region1\\Limerick Prescrip Meds no vio EA-15-087.docx X
SUNSI Review/ CJC*
X Non-Sensitive Sensitive X
Publicly Available Non-Publicly Available OFFICE RI/ORA RI/ORA RI/DRP RI/DRS RI/DRS RI/RC NAME C Crisden/CJC* N Warnek/NSW*
D Schroeder/DLS*
R McKinley/DBE for via email*
R Lorson/GXS for via email*
P Jehle/PAJ via email*
DATE 11/17/15 11/18/15 11/18/15 11/19/15 11/23/15 11/18/15 OFFICE RI/ORA OGC OE RI/DRP NAME B Bickett R Carpenter/RC via email*
R Carpenter/RC via email*
M Scott DATE 11/24/15 11/24/15 12/2/15
- see previous concurrence OFFICIAL RECORD
Letter to B. Hanson from M. Scott dated December 2, 2015 D. Dorman, RA D. Lew, DRA M. Scott, DRP J. Colaccino, DRP R. Lorson, DRS G. Suber, DRS D. Schroeder, DRP S. Barber, DRP R. McKinley, DRS J. Bream, DRS D. Caron, DRS D. Screnci / N. Sheehan, PAO B. Klukan, ORA B. Bickett, ORA M. McLaughlin / C. Crisden, ORA S. Rutenkroger, LGS SRI M. Fannon, LGS RI D. Bearde, RI N. McNamara / D. Tifft, RI Enforcement Coordinators RII, RIII, RIV (D. Gamberoni, R. Skokowski, M. Hay)
R. Carpenter, OGC L. Casey, NRR C. Parker, NRR S. Coker, NSIR J. Teator, OI M. Holmes, OI R1DRPMailResource R1 OE Files (with concurrences)
RidsNrrPMLimerick Resource RidsNrrDorlLpl1-2 Resource RidsNRRPMLimerick Resource RidsOEMailCenter Resource ROPreportsResource@nrc.gov
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406-2713 December 2, 2015 EA-15-087 Mr. Bryan C. Hanson Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
NRC INVESTIGATION REPORT NO. 1-2014-029
Dear Mr. Hanson:
This letter refers to the subject investigation by the U.S. Nuclear Regulatory Commission (NRC)
Office of Investigations (OI) conducted at your Limerick Generating Station (LGS). The investigation, which was completed on April 10, 2015, was conducted to determine whether a Radiation Protection Supervisor (RPS) deliberately failed to follow licensee procedures pertaining to the possession and/or use of illegal drugs at LGS. Additionally, the investigation also evaluated whether the RPS deliberately failed to report the use of prescription medication as required by Exelon procedures.
Based on the evidence gathered during the OI investigation, the NRC concluded that the RPS did not deliberately fail to report the use of prescription medication as required by procedure. Nor was evidence found that he deliberately failed to follow licensee procedures pertaining to the possession and/or use of prescription/illegal drugs at LGS.
In accordance with Exelon procedure, SY-AA-102-206, Reporting Use of Medication, revision 7, individuals were required, in part, to report the use of prescription medication to their supervisor if they believed the prescription may impair their alertness, judgment, or any other ability to safely perform their job duties. On February 7, 2014, the procedure was revised to revision 8 and required individuals to report the use of prescription medication upon receiving any prescription that indicates taking the medication may affect their ability to perform their job duties. During the 2012 and 2013 timeframe, the RPS was prescribed medication, including an antibiotic and a pain medication, for two major illnesses. The RPS reported the use of the antibiotic because it was taken while at work, but did not report the use of pain medication because it was not taken at work and he did not believe it would have an impact on his ability to perform the job. The RPS was also prescribed antibiotics and pain medication in 2013 following another surgery, but he did not report the use of the medication because the medication was not taken at times that he believed would impact his ability to perform the job. Because the RPS had completed his annual refresher training on January 24, 2014, prior to revision 8 being implemented, the NRC concluded that the RPS understanding of requirements for reporting of prescription medication taken in 2012 and 2013 was consistent with revision 7 of the procedure, the latest version of the procedure of which he was likely aware.
After reviewing the specific circumstances regarding this issue, the NRC concluded that no violation of regulatory requirements occurred. However, NRC notes that other individuals, in addition to the RPS, lacked a clear understanding of Exelon Procedure, SY-AA-102-206, Reporting Use of Medication which may be indicative of a training issue.
You are not required to respond to this letter. However, should you choose to respond, your response should be sent to the U.S. Nuclear Regulatory Commission, ATTN: Regional Administrator, Region I, 2100 Renaissance Boulevard, Suite 100, King of Prussia, PA 19406, and marked Open by Addressee Only, within 30 days of the date of this letter, with a copy to the NRC Senior Resident Inspector at LGS. If Security Related Information is necessary to provide an acceptable response, please mark your entire response Security-Related Information in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room and from the NRCs Agency-wide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. However, the material enclosed herewith contains Security-Related Information in accordance with 10 CFR 2.390(d)(1), and its disclosure to unauthorized individuals could present a security vulnerability. Therefore, the material in the enclosure will not be made available electronically for public inspection in the NRC Public Document Room or from ADAMS.
Should you have any questions regarding this letter, please contact Mr. Daniel L. Schroeder at 610-337-5262.
Sincerely,
/RA/
Michael L. Scott, Director Division of Reactor Projects Docket Nos.
50-352, 50-353 License Nos. NPF-39, NPF-85 cc w/encl: Distribution via ListServ
After reviewing the specific circumstances regarding this issue, the NRC concluded that no violation of regulatory requirements occurred. However, NRC notes that other individuals, in addition to the RPS, lacked a clear understanding of Exelon Procedure, SY-AA-102-206, Reporting Use of Medication which may be indicative of a training issue.
You are not required to respond to this letter. However, should you choose to respond, your response should be sent to the U.S. Nuclear Regulatory Commission, ATTN: Regional Administrator, Region I, 2100 Renaissance Boulevard, Suite 100, King of Prussia, PA 19406, and marked Open by Addressee Only, within 30 days of the date of this letter, with a copy to the NRC Senior Resident Inspector at LGS. If Security Related Information is necessary to provide an acceptable response, please mark your entire response Security-Related Information in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR 2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit requirements for your response.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room and from the NRCs Agency-wide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. However, the material enclosed herewith contains Security-Related Information in accordance with 10 CFR 2.390(d)(1), and its disclosure to unauthorized individuals could present a security vulnerability.
Therefore, the material in the enclosure will not be made available electronically for public inspection in the NRC Public Document Room or from ADAMS.
Should you have any questions regarding this letter, please contact Mr. Daniel L. Schroeder at 610 337-5262.
Sincerely,
/RA/
Michael L. Scott, Director Division of Reactor Projects Docket Nos.
50-352, 50-353 License Nos. NPF-39, NPF-85 cc w/encl:
Distribution via ListServ ML15336A696 DOCUMENT NAME:S:\\Enf-allg\\Enforcement\\Proposed-Actions\\Region1\\Limerick Prescrip Meds no vio EA-15-087.docx X
SUNSI Review/ CJC*
X Non-Sensitive Sensitive X
Publicly Available Non-Publicly Available OFFICE RI/ORA RI/ORA RI/DRP RI/DRS RI/DRS RI/RC NAME C Crisden/CJC* N Warnek/NSW*
D Schroeder/DLS*
R McKinley/DBE for via email*
R Lorson/GXS for via email*
P Jehle/PAJ via email*
DATE 11/17/15 11/18/15 11/18/15 11/19/15 11/23/15 11/18/15 OFFICE RI/ORA OGC OE RI/DRP NAME B Bickett R Carpenter/RC via email*
R Carpenter/RC via email*
M Scott DATE 11/24/15 11/24/15 12/2/15
- see previous concurrence OFFICIAL RECORD
Letter to B. Hanson from M. Scott dated December 2, 2015 D. Dorman, RA D. Lew, DRA M. Scott, DRP J. Colaccino, DRP R. Lorson, DRS G. Suber, DRS D. Schroeder, DRP S. Barber, DRP R. McKinley, DRS J. Bream, DRS D. Caron, DRS D. Screnci / N. Sheehan, PAO B. Klukan, ORA B. Bickett, ORA M. McLaughlin / C. Crisden, ORA S. Rutenkroger, LGS SRI M. Fannon, LGS RI D. Bearde, RI N. McNamara / D. Tifft, RI Enforcement Coordinators RII, RIII, RIV (D. Gamberoni, R. Skokowski, M. Hay)
R. Carpenter, OGC L. Casey, NRR C. Parker, NRR S. Coker, NSIR J. Teator, OI M. Holmes, OI R1DRPMailResource R1 OE Files (with concurrences)
RidsNrrPMLimerick Resource RidsNrrDorlLpl1-2 Resource RidsNRRPMLimerick Resource RidsOEMailCenter Resource ROPreportsResource@nrc.gov