ML17202G678
| ML17202G678 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/01/1989 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202G677 | List: |
| References | |
| 50-237-87-03, 50-237-87-3, 50-249-87-03, 50-249-87-3, EA-87-051, EA-87-51, NUDOCS 8911090152 | |
| Download: ML17202G678 (3) | |
Text
Commonwealth Edison Company Dresden, Units 2 and 3 NOTICE OF VIOLATION Docket Nos. 50-237; 50-249 Licenses No. DPR-19; DPR-25 EA 87-51 During an NRC inspection conducted during the period December 8, 1986 through January 13, 1987, and an NRC investigation conducted during the period September 29, 1987 through June 23, 1989, a'viol~tion of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR Part 2, Appendix C {1989), the violation is listed below:
Technical Specification 6.2 requires that detailed plant operating procedures, including applicable checkoff lists, for Offsite Dose Calculation Manual (ODCM) implementation be prepared, approved, and adhered to. Section 8-.2.3 of the -
Dresden ODCM states that administrative and procedural controls to ensure proper control of liquid radwaste releases are documented in Dresden Operating and Administrative Procedures. Dresden Operating Procedure DOP 2000-28 "Radioactive Waste Discharge to the River" implements the ODCM specified controls by requiring, among others, that valve lineups be performed for each release, that the shift supervisor or his designee verify the valve lineups, and that effluent monitor sample flow be verified 15 minutes after initiation of the release.
A.
Contrary to the above, on January 5, 1987, procedure DOP 2000-28 was not adhered to for a liquid radwaste release in that the radwaste foreman, designated by the shift supervisor, did not perform valve lineup verifications for Checklists 6 Section A, 9, and 11 of the procedure," although the radwaste foreman signed the checklists indica,ti.ng that the verifications were performed.
This.is a Severity Level IV violation (Supplement I).
B.
Contrary to the above, on January 5, 1987, procedure DOP 2000-28 was not adhered to for a planned liquid radwaste release in that the*
operator performing the valve lineup checklists failed to properly position two valves, failed to read and comply with a temporary procedure change concerning proper positioning of a third valve, and failed to perform a procedural step which requires effluent monitor
- sample flow verification 15 minutes after initiating the radwaste release.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Conmonwealth Edison Company is hereby required to submit a written statement or explanation to t~is Office within 30 days of the date of the letter transmitting this Notice. This reply should include for each violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the Notice of Violation corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be 8911090152 891101 PDR ADOCK 05000237 Q
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achieved.
Where good cause is shown, consideration will be given to extending the response time.
Dated a~len Ellyn, Illinois this I
day of ~cteber 1989 t.l< v*rn4.
FOR THE NUCLEAR REGULATORY COMMISSION A. Bert Davis Regional Administrator
SYNOPSIS After reviewin*g staff inspection results forwarded to the* NRC Office of Investigations (NRC:OI) from the NRC Region III Regional Administrator on April 27, 1987, NRC:OI self-initiated an investigation at the Dresden Nuclear Power Station on September 29, 1987.
The decision to self-initiate evolved from allegations that a radwaste foreman willfully failed to perform required independent valve position verifications wnile signing the checklists that he had done so.
It was also discovered that since similar incidents of falsification of verification records were alleged at two other Corrmonwealth Edison Company (CECo) facilities, there allegedly could have been management involvement in.training, approving, or authorizing the falsification of verification records.
The first allegation involved a radwaste foreman who had signed procedure checklists indicating that he had performed independent valve position verifications during a radwaste release on January 5, 1987, when, in fact, he had not verified the valve position lineup. The inexperienced 8-operator, who was responsible for positiOning the valves, believed that the valves were in the correct position and failed to position three valves correctly. The radwaste foreman admitted that he knew that he was required to independently verify the valve lineup perfonned by the 8-operator, but because he was having personal problems, used careless disregard by not verifyfog the lineup. He had assumed that the B-operator should have been able to properly perform the lineup.
The second allegation involved CECo management involvement in the training, approving, or authorizing the falsification of verification records. The radwaste foreman stated that he had never been instructed or trained. by CECo management that it was allowable to bypass any technical specification procedure or any station operati_ng procedure. There was no indication that other operators or radwaste foremen have ever failed to perform the required valve lineup verifications.
The NRC:OI investigation concluded that the radwaste foreman used careless disregard when he knowingly failed to perform the required independent verification of the B-operator's valve lineup, even though the radwaste release appeared to be proceeding without any problem. The allegation of CECo management involvement was not substantiated
- Case No. 3-87-016 1