ML18153A087
| ML18153A087 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/18/1996 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Allen R AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML18153A088 | List: |
| References | |
| IA-96-065, IA-96-65, NUDOCS 9610310067 | |
| Download: ML18153A087 (3) | |
See also: IR 05000280/1995020
Text
IA 96-065
Mr. Robert C. Allen
[HOME ADDRESS DELETED
UNDER 10 CFR 2.790]
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
October 18. 1996
SUBJECT:
(NRC Inspection Report Nos. 50-280. 281/95-20 and Office of
Investigations Report No. 2-95-029)
Dear Mr. A 11 en:
This letter refers to an inspection conducted on September 14 through
October 4. 1995. as well as an NRC Office of Investigations (DI) investigation
completed on June 28. 1996.
During these reviews. the NRC examined the facts
and circumstances surrounding your conduct of licensed activities at Virginia
Electric and Power Company's (VEPCO) Surry Power Station on September 13.
1995.
You were informed of our initial findings and provided copies of the
applicable inspection report and synopsis of the DI investigation report by
letter of August 16. 1996.
You were also provided an opportunity to respond
in writing to the apparent violation or request a predecisional enforcement
conference to discuss the apparent violation. the root cause. and the
corrective actions to preclude recurrence.
By letter dated August 29. 1996.
you requested a conference. A closed. transcribed conference was conducted on
October 2. 1996. at the Region II office in Atlanta. Georgia.
A list of
conference attendees and a copy of NRC presentation materials are enclosed.
Based on the information developed during the inspection and investigation as
well as the information that you provided during the conference. the NRC has
determined that your actions on September 13. 1995. constituted a violation of
your NRC Senior Reactor Operator's license. Specifically. your license
required that you observe the operating procedures of the Surry Power Station:
however. on September 13. 1995. you deliberately did not adhere to plant
procedures for the venting of the Unit 1 pressurizer relief tank (PRT).
On
this date. you were the Supervisor of Shift Operations providing oversight of
control room shift operations. After becoming aware that the reactor coolant
system pressure was higher than that which would permit performance of certain
outage-related critical path activities. you instructed operations personnel
to establish a second vent path for the PRT. contrary to plant procedures.
without first obtaining the proper approval to do so Ci .e .. a Procedure Action
Request).
In particular. you were knowledgeable of the procedural
requirements. yet you deliberately allowed the venting to proceed knowing that
valve No. l-RC-HCV-1549 was not closed and a polyethylene hose was not
connected from valve No. l-RC-ICV-5025. as required. This resulted in
simultaneous vent paths. one of which bypassed the process vent system causing
an unmonitored. ground-level release.
In addition. you failed to obtain the
proper release permit for the ground-level release.
The NRC concluded .
however. that your failure in this regard was inadvertent.
You were cognizant
of the radiological and industrial safety implications of the release when it
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R. Allen
2
was initiated. through review of the PRT elevated release permit and
discussion with shift health physics supervision.
During the conference. you admitted that you were aware of the valve position
and polyethylene hose requirements; however. you indicated that the failure to
obtain the proper gaseous release permit was unintentional.
You attributed
the violation to a serious error in judgement resulting from self-imposed
pressure to maintain the outage schedule and an extremely heavy workload of
outage activities.
You further stated that you intended to formally request a
change to the procedure to allow the procedure deviations. but did not. and
that the violation was not premeditated or conducted with the intent to avoid
compliance.
As a result of these actions you received substantial
disciplinary action. including termination of your NRC license on December 28.
1995. at VEPCO's request.
In addition. you were required to participate in a
performance remediation plan.
As an NRC-licensed senior reactor operator. the NRC conferred upon you its
confidence that you would assure that the Surry Power Station would be
operated safely and in accordance with all regulatory requirements.
In
addition. the NRC places a high value on the standards set by plant management
for the conduct of plant operations.
As the Supervisor of Shift Operations on
September 13. 1995. you were in a position to direct and coordinate the
activities of other operations personnel.
Your actions did not adhere to
these standards and also undermined the trust inherent in your position to
ensure public health and safety.
In addition to violating your NRC license.
your actions were contrary to the provisions of 10 CFR 50.5. Deliberate
Misconduct. and VEPCO was subject to escalated enforcement as a result of your
actions. A copy of this enforcement action was provided to you in our August
16. 1996 letter.
Given the significance of your actions. after consultation with the Director.
Office of Enforcement. and the Deputy Executive Director for Nuclear Reactor
Regulation. Regional Operations. and Research. the NRC has decided to issue
the enclosed Notice of Violation (Notice) to you based on your deliberate
violation of plant operating procedures.
In accordance with the "General
Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement
Policy), NUREG-1600. the violation has been classified at Severity Level III.
In determining the sanction against you. the NRC gave considerable weight to
the fact that you fully cooperated with NRC's investigation. showed remorse
and accepted full responsibility for your errors. and were placed in a
performance remediation program by VEPCO.
However. should there be evidence
of similar conduct on your part in the future. you may be subject to further
enforcement action that could possibly include an order prohibiting your
involvement in NRC-licensed activities for up to five years.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response. you should document the specific actions taken and any additional
actions you plan to prevent recurrence.
R. Allen
3
In accordance with Section 2. 790 of the NRC's "Rules of Practice." Part 2.
, Title 10. Code of Federal Regulations. records or documents compiled for
enforcement purposes are placed in the NRC Public Document Room (PDR).
A copy
of this letter. with your address removed. and your response will be placed in
the PDR.
To the extent possible. your response should not include any
personal privacy. proprietary. or safeguards information so that it can be
placed in the PDR without redaction.
Also. a copy of this enforcement action
will also be provided to the licensee.
Questions concerning this Notice may be addressed to Mr. Thomas Peebles.
Chief. Operator Licensing Branch at 404-331-5541.
Docket No. 55-6236
License No. SOP-4301-4
CERTIFIED MAIL NO. P 343 386 352
RETURN RECEIPT REQUESTED
Enclosures:
1.
2.
3.
Conference Attendees
NRC Presentation Materials
cc w/enclosures [HOME ADDRESS DELETED]:
David A. Christian. Manager
Surry Power Station
Virginia Electric and Power Company
5570 Hog Island Road
Surry. VA 23883