ML18037A315
| ML18037A315 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/17/1980 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Jamarl Cummings NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| Shared Package | |
| ML17053C228 | List: |
| References | |
| NUDOCS 8101140166 | |
| Download: ML18037A315 (8) | |
Text
Docket No. 50-220 888 1I $98 Uloi~it'gg~) i-,ir) pop)A FROM:
SUBJECT:
hli11iam.J. Dircks Executive Director for Operations
RESPONSE
TO OIA'S INQUIRY INTO NRR'S OF SHORT TERM LESSONS LEARNED MEMORANDUM FOR:
James J. Ceanings, Director Office of inspector and Auditor
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IMPLEtfENTATIOH
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C lh rom r%~Vi C7 The subject report pointed out that the Nine Nile Point case indicated that deficiencies could exist in NRC's followup of licensees'mplementation of other. TMI Action Plan requirements.
The actions described below will, we
- believe, assure that no such deficiencies exist.
Controls to Insure Verification of TMI Action Plan Items IE and NRR have agreed upon the steps necessary to assure proper coordination with respect to the many NRR lead items that require IE inspection for pt oper close-out.
These TMI items will be. identified on the NRR master listing and vill further be tracked by the individual offices.
Other items',
such as IE lead items or NRR lead items that do not require IE inspection to verify com-pletion, will be tracked under separate systems by the individual offices.
Work began in July to establish positive controls to 'inspect all of the inspec-table licensee. comnitments in the TMI Action Plan, including Short Term Lessons Learned.(STLL) items and to formalize the inspection requirements.
At this time the IE staff began to develop procedures to insure that none of the inspec-table action plan items were missed.
IE has identified those action plan items imposed on licensees that are currently inspectable, and they have been identified for inspection in IE s manual system in Temporary Instructions (TI).
These instructions have been issued to the Regional Offices to require inspection of each iten.
Those items for future implenentation will likewise be included in similar TIs.
hhile each action plan item will be inspected, sampling will be used within an. individual plan iten when 1005 inspection of that item would be an ineffective resource utilization.
The IE staff has developed a computer tracking system that will identify the action plan item, the TI requiring its inspection, the inspection report in which close-out is accomplished and the date of close-out.
Thus, at any time in the future IE will be able to call up the status of action plan items at any facility for which the items were required.
The Regional Offices are responsible for.
performance and management of ins'pection of these items and the Director, Division of Resident and Regional Reactor Inspection wi 11 monitor. the status of completion.
~eddic veports of the status of completion will be issued to. the Office of the Director, IE.
OFFICE $ s SURNAME DATEP
-8 io i i40>>l'RC FORM 318 I9-76) NRCM 0240 AU.S. GOVERNMENT PRINTING OFFICE: 1979.289.369
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James J. Curmings, OIA 2
It has been agreed that IE will perform some additional work such as post-implementatfon review of selected items from the action plan.
NRR will propose the speciffc ftems where additional IE work seems appropriate.
Once agreement fs reached on specific items, IE will include the work fn inspection procedures and the IE tracking system.
Until agreement is reached on specific items, NRR will retain the review responsibility for specific items Mith regard to OIA's concern about possible.confusion resulting fren NRR's use of site visits for post-implementation review of action plan items, NRR may conduct limited site
'eviews fn selected areas but such visits would not be for the purpose of inspecting implementation Prior to making such visits ft will be assured that all participants (licensee, NRR personnel and inspectors) understand the purpose of the visits.
IE Ffndin s Followfn Recent STLL Cate or A Ins ectfons
.As a result of the Nine Mile Point finding, IE initiated an immediate inspection of STLL items at all licensed power reactors.
The IE staff confirmed licensee implementation of their commitments regarding these items.
No.additional material false statements by licensees were identified.
At several facilities, IE inspection revealed inadequacies in licensee Implementation of STLL items.
These inadequacies included items such as procedure in place but containing minor errors, modifications completed but data package incomplete,. or personnel training incomplete.
These items are being corrected by licensees with appro-priate IE followup, which fn some cases will result in regional enforcement.
Enforcement Action - Nine Nile Point As.a result of the NRC Inspection and Investigation conducted October 8-10, 20-31, November 1, and 18, 1980, a Notice of Yiolatfon and Notice of Proposed Imposition of Civil Penalties fn the amount of Two Hundred Twenty-Five Thousand Dollars was issued on November 26,.1980 to Niagara mohawk Power Corporatfon.
In addition, an immediately effective license modification was imposed removing the former Nine Mile Point Site Superintendent. from involvement fn nuclear activities for the Corporation and requiring improved controls for the flow of information upward through the management chain; also issued was an Order to Show. Cause, by January 5,
- 1981, why the Executive Yfce-Presfdent should not also be removed from involvement fn nuclear activities.
These actions were. taken based on a material false statemIent submitted by the licensee under oath on= January 22, 1980.in response to the NRC Order of January 2, 1980.
The requirements of the January 2'Order concerned Category A items covered in.NUREG 0578; Item 2.1.8.b was described by the licensee fn its response as having been completed December 31; 1979 when, in fact, it was not completed until after an NRC inspection fn October 1980; The former Site Superintendent was aware that action on Item 2.1.8.b was not completed on January 22, 1980 and that the licensee's letter to I'(RC stated that work was complete.
He did not provide this fnformatfon to higher management.
The Executive Vice-Presfdent signed the flawed letter, under oath, without adequate verification of fts correctness.
OFFICE/ i.
SURNAME
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DATE P.
NRC FORM 318 {9.76) NRCM 0240
'0 U.S. GOVERNMENT PRINTING OFFICE: 1979.289.369
James J.
- Cumnings, OIA 3
The licensee was thus in noncompliance with the January 2, 1980 Order for 232 days from January 31, 1980 until October 8, 1980.
This enforcement action follows our enforcement procedures in existence at that time, and the penalty
$ s limited to $25,000 for each 30 day period.
Otherwise, the cumulative amount of the penalty would have been.$ 1,165,000 rather than the proposed
$225,000.
{Signed) V/llliamJ. Dircks Wi 1 1 4 am.J. Dircks Executive Director for 'Operations Distribution
'W. J. Dircks, EDO K. Cornell, EDO T. A. Rehm, EDO H. R. Denton, NRR H. K. Shapar, ELD V. Stello,
.IE R.
C.
E. Bryan, IE G. Ertter (EDO 9876)
B. Matosko, IE (Hll-2356-H06)
IE Files IE Reading PDEA Reading (C. DeLiso),
IE PDB Chron (J. Miller), IE Central Files J.
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NRC FORM 318 t9.76) NRCM 0240 0 U.S. GOVERNMENT PRINTING OFFICE: 1979-289-369
FROM; OIA: CUI'SINGS TO:
The Commission DATES ACTION CONTROL COMPL DEADLINE 2/5/80 ACKNOWLEDGMENT INTERIM REPLY I
FINALREPLY FI LE LOCATION
- z.sN-Ho(
CONTROL NO.- 09,"")75 DATE OF DOCUMENT 1'I 12 80 PRFPARE FOR SIGNATURE OF:
Q CHAIRMAN EXECUTIVE DIRECTOR OTHER:
OIA IN(UIRY INTO NRR'S.'IMPLEMENTATION OF SHORT TERM LESSONS LEARNED CATEGORY A RE(UIREMENTS CLASSIFIED DATA DOCUMENT/COPY NO.
NUMBER OF PAGES
+'OSTAL REGISTRY NO.
CLASSIFICATION CATEGORY Q
NSI QRD Q FRD DESCRIPTION LETTER Q MEMO Q REPORT Q OTHER g~ ~~y:k~
Prepare memo to OIA (in coordination w/NRR) for EDO signature responding to the OIA report.
Memo should address enforcement action on Nine Mile Point, cleanup of short term lessons learned inspections, and any lack of clarity in other Action Plan inspections.
PRIORITY ASSIGNED TO:
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.o ted@
DATE INFORMATIONROUTING Tres,woa Cornell Rehm" Denton CK w~~
LEGALREVIEW ASSIGNED TO:
DATE Q
FINAL '
COPY NO LEGAL OBJECTIONS NOTIFY:
Q EDO ADMIN4CORRES BR EXT.
COMMENTS, NOTIFY:
EXT.
JCAE NOTIFICATION RECOMMENDED:
0 YES Q
NO O V 23+
(21-75)
EXECUTIVE DIRECTOR F R OPERATIONS PRINCIPAL CORRESPONDENCE CONTROL OO NOT REAIOYE THIS COPY
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