ML19249E729
| ML19249E729 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/07/1979 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Arenal A SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| NUDOCS 7910020297 | |
| Download: ML19249E729 (1) | |
Text
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UNITED S FATES 8h
( [','o NUCLEAR REGULATORY COMMISSION C-5 cAk'!I6((E nEGION V
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WALNUT CREEK, CALIFORNI A 94596 September 7, 1979 Docket flos. 50-206 50-361 50-362 Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Attention:
f4r. A. Arenal Vice President, Advanced Engineering Gentlemen:
This Information i;otice is being reissued to correct a word emission and a punctuation error that, when taken together, completely changed the intent of a statement.
The changed stateir.ent is underlined in the test of the Information i'otice.
It is requested that the facility licensee provide copies of this In-formation Notice to all NRC licensed individuals at the facility.
i'o specific response is requested at this time.
If you have questions regarding this matter, please contact the Director of the appropriate NRC Regional Office.
Sincerely, l5 I cllk R. H. Engelken Director
Enclosure:
IE Information Notice No. 79-20, Revision 1 cc w/ enclosure:
J. ii. Curran, SCE J. T. Head, SCE J. H. Drake, SCE 1072 IN 8
7910020 g' i O
SSIlls: 6870 Accession No:
7908220108 J UNITED STATES NUCLEAR REGULATORY COMi1ISSION b
0FFICE OF INSPECTION AND ENFORCEllEf!T WASHIrlGTON, D.C. 20555 Septenber 7, B79 IE Inforation t'otice No. 79-20 Rev. 1 llRC ENFORCEi1ENT POLICY - NRC LICEllSED INDIVIDUALS
Background:
In the past, flRC licensed individuals have been cited by the NRC for failure to comply with the conditions of their licenses.
These items of noncompliance can generally be characterized as serious or repeated failures to follow reactor opccating procedures.
Trio recent events involving the radiation overexposure of NRC licensed individuals through their violation of utility procedures, facility Technical Specifications and the Code of Federal Regulations have raised questions about the exercise of their responsibilities.
The purpoce of this Information Notice is two-fold:
(1) To remind the NRC licensed individuals of their responsibilities, not only in the proper operation of the facility controls, but in compliance with the facility administrative procedures, and (2) To sumarize the enforcement sanctions available to the NRC for use against licensed individuals.
Description of Circumstances:
1.
Responsibilities Facility licensees are charged with the responsibility to design, construct and operate their plants in accordance with NRC requirements to assure that public health and safety are protected.
The role of flRC licensed individuals is no less important in the overall Regulatory scheme.
The NRC recognizes that timely actions by NRC licensed indivi-duals are an important part of safety.
Reliance on these actions is a part of the defense-in-depth concept.
Specifically, the NRC requires that:
(1) Only licensed operators are p*mitted to ranipulate the controls that directly affect reactivity ('.0 CFR 50.54 (i))
(2) Licensed operators are required to be present at the controls at all times during the operation of the facility (10 CFR 50.54 (k))
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IE Infomation Notice No. 79-20 Rev.1 September 7, 1979 Page 2 of 3 (3) Operation of mechanisms and apparatus other than controls which may indirectly affect the power level or reactivity of a reactor shail only be accomplished with the knowledge and consent of an operator licensed in accordance with Part 55 (10 CFR 50.54 (j))
(4) Licensed senior operators are required to be present at the facility during specified conditions, and available or on call at other times during operation (10 CFR 50.54 (m))
(5) The flRC licensed individual shall observe all applicable rules, regulatiers a-d Orders c# the Ccrission, whether or not stated in the license (10 CFR 55.31(d))
The above requires the f RC licensed individual to comply with the requirements pertaining to the operation of the facility and nanipule. ion of its controls and to comply with radiation safety procedures implementing 10 CFR 20.
IIRC policy for the responsibility for safe operation of NRC licensed facilities continues to be as follows:
(1) The facility licensee is responsible for assuring that the facility is operated within the requirements of the license, Technical Specifica-tions, rules, regulations, and Orders of the NRC and for the actions of their employees.
(2) fiRC licensed individuals are responsible for taking timely and proper actions so as not to create or cause a hazard to " safe opera-tion of the facility" (i.e. actions or activities, including failure to take action, related to the facility which could have an adverse affect on the health and safety of the public, plant workers or the individuals).
2.
Enforcement Sanctions On December 31, 1974, the then AEC sent a letter to all facility licensees containing the criteria for determining enforcement action and the categories of noncompliance with AEC regulatory requirements.
Those criteria and categories are applicable to fiRC licensed individuals as well as facility licensees.
Paragraph 55.40(b) of Title 10 of the Code of Federal Regulations prescribes that tiRC issued operator licenses ray be revoked, suspended or modified for failure to observe any terms or conditions of any rule, regulation or Order of the Commission, or any conduct determined to be a hazard to safe operation of the facility. These would generally involve serious items of noncompliance where: (1) the individuals' action clearly demonstrate inatt ention to duties or disregard for requirements including technical specificatons and operating procedures; (2) the !!RC licensed individual fails to take a reouired action or takes an iridejiciident actfUri mat results in significant acfGal or potential safety consequences; or T3Fthere is repefitive noncompl1T5ce with regulatory requffEifents.
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IE.Information llotice fio. 79-20 Rev.1 September 7, 1979 Page 3 of 3 Examples of situations which could result in violations include:
(1) floting a serious violation of procedural requirements and not taking corrective action.
(2) Unauthorized bypassing of required reactor safety systems (3) Defeating alarms which have serious safety significance (4) Unauthorized abandoning of reactor controls (5) Knowingly taking actions that violate T5 Limiting Conditions for Operation The examples listed above involve the failure of an i;RC licensed individual to follow procedures and adhere to controls.
These are violations of flRC require-ments.
In the past the fiRC has issued flotices of Violation, as provided for in 10 CFR 2.201, and suspended, modified or revoked the license, as provided for in 10 CFR 55.40 (b), of f!RC licensed individuals.
The issuance of civil monetary penalties, as provided for in 10 CFR 2.205 and 10 CFR 55.50, or charges, as provided for in 10 CFR 55.50, have not been previously c
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- u. ed aga unt fiRC licensed individuals but nay be used if the circunstances warrant such action.
The Comission will continue to nonitor the performance of t;RC licensed individuals and will continue to take the appropriate enforcement action against flRC licensed individuals, f!o written response to this Information tiotice is required.
If you have questions regarding this matter, please contact the Director of the appro-priate flRC Regional Office.
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