ML17180A688
| ML17180A688 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/21/1994 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Wallace M COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17180A689 | List: |
| References | |
| EA-93-182, NUDOCS 9404270043 | |
| Download: ML17180A688 (4) | |
See also: IR 05000237/1992033
Text
UNITED STATE~
NUCLEAR REGULATORY COMMISSION
REGION Ill
801 WARRENVILLE ROAD
LISLE, ILLINOIS 60532-4351
Docket Nos.
50-237 and 50-249
License Nos.
EA 93-182
Commonwealth Edison Company
ATTN:
Mr. Michael Wallace
Vice President and
Chief Nuclear Officer
Executive Towers West III
1400 Opus Place, Suite 300
Downers Grove,
Illinoi~ 60515
Dear Mr. Wallace:
SUBJECT:
April 21, 1994
(NRC INSPECTION REPORT No. 50-237/92033; 50-249/92033; AND*NRC
INVESTIGATION REPORT NO.- 3-92-055R)
This refers to the special inspection conducted from November 30, 1992, to
December 4, 1992, at the Dresden Nuclear Station. The report documenting this
inspection was sent to you by letter dated September*9, 1993.
An enforcement
conference was held on September 16, 1993, and a report summarizing the
conference was sent to yo*u by letter dated September 28, 1993.
This also
refers to the investigation conducted by the U.S. Nuclear.Regulatory
Commission's Office of Investigations (01); a copy of the synopsis of the 01
report is enclosed.
On September 18, 1992, a nuclear station operator (NSO) who was operating
Dresden Unit 2 mispositioned a control rod while moving rods to balance the
power in the reactor core.
Plant procedures required that th~ mispositioned
rod be driven fully into the core and no further control rod movements be made
until the situation is evaluated by an upper management representative. Plant
procedures also required that the NSO record the mispositioned rod in the
control room log books and report the mispositioned rod to the Unit Operating
Engineer or the Operations Duty Supervisor.
The qualified nuclear engineer
(QNE) on duty observed the error and informed the NSO.
The NSO, however, did
not drive the mispositioned rod into the core but continued to move other
control rods at the direction of the QNE, an unlicensed individual, without
the knowledge or approval of the shift control room engineer (SCRE, who is the
senior licensed operator in the Dresden control room who has overall
responsibility for supervising operation of the plant during the shift) and.
without an evaluation of the situation by an upper management representative,
in violation of numerous Dresden plant procedures and .NRC requirements.
Shortly thereafter, the five personnel in the control room at the time of the
event (the SCRE, the NSO, the QNE, and two nuclear engineer trainees) agreed
to conceal the event from Dresden management.
In furtherance of this attempt
to conceal the event, the rod mispositioning was not recorded in the control
room log, a Dresden Form 14-14C was falsified, and the event was not reported
9404270043 940421 ;
ADDCK 05000237
G
Commonwealth Edison Company
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to plant management, in violation of Dresden Technical Specifications and NRC
requirements, including 10 CFR 50.9, "Complete~ess and Accuracy of
Information."
The NRC recognizes that rod balancing is a routine evolution at power reactors
to even the power distribution in the reactor core and that the safety
.significance of the event itself turned out to be minimal in this particular
case. Reactivity changes and rod mispositioning can be of substantial safety
significance, however.
Thus, NRC regulations require that activities that can
affect the reactivity of the reactor core be conducted by trained and
qualified personnel under the supervision of a senior licensed operator and in
accordance with approved procedures.
We are aware that Dresden management was
unaware of the event, does not condone the failure to .follow procedures, and
does not tolerate wrongdoing by its employees.
This was evidenced by the
actions Dresden management took when it became aware of the event.
However,
we are concerned that an environment existed in which the individuals involved
in the September 18, 1992 event believed that the failure to report the
incident was acceptable conduct. Other problems, if not reported, could lead
to safety challenges. Therefore, it is vitallj important for Dresden
management to clarify its expectations that problems mu.st be reported so their
root causes can be determined and appropriate corr~ctive actions can be
implemented to prevent recurrence.
Two violations are described in the enclosed Notice of Violation and relate to
Dresden's failure to identify and take effective corrective actions for a rod
mispositioning event that occurred on April 10, 1992 and for failure to follow
required response procedures for a rod mispositioning event-that occurred on
September 18, 1992.
The two violations are categorized in the aggregate as a
Severity Level III problem in accordance with the "Statement of Policy and
Procedure for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2,
Appendix C.
In accordance with the Enforcement Policy, ordinarily we would propose a civil
penalty for a Severity Level III problem and, in fact, we considered proposing
a civil penalty in this case. .However, after consultation with the Director,
Office of Enforcement, and the Deputy Executive Director for Reactor
Regulation, Regional Operations, and Research (DEDR), I have exercised
discretion pursuant to Section VII.8(6) of the Enforcement Policy and have
decided that a civil penalty will not be proposed in this case because of your
identification of the problem and your substantial ~orrective actions,
including the decisive disciplinary action that you took against the
individuals who were involved in wrongdoing in this matter.
The decision not
to propose a civil penalty in this c~se also takes account of the fact that
additional, separate enforcement actions are being issued directly to the
individuals responsible for the violations, some of whom were plant operators
licensed by the NRC.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice of Violation (Notice) when preparing your
response.
In your response, you should document the specific actions taken
and any additional actions you plan to prevent recurrence. After reviewing
Commonwealth Edison Company
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your response to this Notice, including your proposed corrective actions and
the results of future inspections, the NRC will determine whether further NRC
enforcement action is necessary to ensure compliance with NRC regulatory
requirements.
In addition to the enclosed Notice of Violation, the NRC is also issuing
Orders to the three licensed operators and letters of reprimand to the
trainees involved in this incident.
In accordance with- 10 CFR 2.790 of the NRC~s "Rules of Practice~" a copy of
this letter and its enclo~ures will be placed in the NRC Public Document Room~
The responses directed by this letter and the enclosed Notice are not subject
to th~ £learance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Enclosures:
1.
2. *Synopsis of 0 I Report
cc w/enclosures:
DCD/DCB (RIDS)
.
M. Lyster, Site Vice President
L. DelGeorge, Vice President, *
Nuclear Oversight and Regulatory
Services
G. Spedl, Station
Manager
J. Shields, Regulatory Assurance
Supervisor
D~ Farrar, Nuclear Regulatory
Services Manager
OC/LFDCB
Richard Hubbard
Nathan Schloss, Economist,
Public Utilities Division
David Tang Wee
Kenneth G. Pierce
Sean G. Mi 11 er
George J. Piccard
John P. Marotto
Sincerely,
c;
ma~~~*
foh{( ~- Martin .
{)
Regional Administrator
Commonwealth Edison Company
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DISTRIBUTION
SECY
CA
JTaylor, EDO
JMilhoan, DEDR
JLieberman, OE
LChandler, OGC
JGoldberg, OGC
WRussell, NRR
LReyes, NRR
Enforcement Coordinators
RI, RII, RIV, RV
Resident Inspectors LaSalle,
Dresden, Quad Cities
Licensing Project Manager, NRR
Fingram, GPA/PA
DWi 11 i ams, OIG
BHayes, OI
EJordan, AEOD
RRosano, OE
RCrl enj ak, DRS
SStein, SRS
EA File (2)
State of Illinois
Chairman, Illinois Commerce
Commission
RAO:RII I
SLO:RIII
PAO:RIII