ML20043D766
| ML20043D766 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/04/1990 |
| From: | Galle D COMMONWEALTH EDISON CO. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| Shared Package | |
| ML20043D767 | List: |
| References | |
| EA-90-031, EA-90-032, EA-90-31, EA-90-32, NUDOCS 9006110152 | |
| Download: ML20043D766 (4) | |
Text
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Commonwoolth E:" son 1400 Opus PI:ce Downers Grov), Illinois 60615 t
June 4, 1990 Mr. James Lieberman Of flee of Enf orcemtent U.fi. Nuclear Regulatory Cormnission Washington, D.C.
20555 Subject In the Matter of R.L. Dickheiber, License No. SOP-2365-8 Docket No. 55-5043. EA 90-031 and in the Matter of Coimnonwealth Edisoa, Quad Cities Nuclear Power Station.
Docket Nos. 50-254 and 50-265. License Nos. DPR-29 and DPR-30 and EA 90-032 Referencet (a) J.1.ieberman to Cordell Hered letter dated Mety 1, 1990.
(b) C.R. Lef stein to J. Liebetman letter dated April 13, 1990.
Mr. Lieberman:
This is in response to the reference (a) letter which states, in part, as follows:
"On April 13, 1990 Mr. R.L. Dickberber submitted his answer to the above orders issued to Convuonwenith Edison Company and to Mr.
Dickheiber.
The etnif is in the process of considering his answer.
As part of our review it would be helpful to obtain Commonwealth Edison Company's views on Mr. Dickherber's performance in the past and why we should have confl'ence in his performance in the future."-
Attachment A provides the information requested.
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I In addition, reference (a) requested that Commonwealth Edison provide its views on the adequacy of the Company's controls for work hours in light of the information contained in reference (b). This information has been provided to the Region 111 Administrator, as requested, and the information is herewith attached for your information. Also enclosed for completeness of this submittal is a copy of Mr. Dickherber's clarification, to statements contained in his April 13, 1990 response, dated June 1, 1990.
If your staf f has any questions or conenents to this submittal, please refer them to Ms. Rita Stols at (708)-515-7283.
I Very truly yours, ca s t. (Ma bihu Dennis Calle Vice l' resident BWR Operations cci A. Bert Davis, Regional Administrator, RIII J. Zwolinski, Assistant Director, NRR
- h. Olshan, Project Manager. NRR W.Schafer, Branch Chief Region III J. Illnd, ficction Chief, Region 111 Senior Resident Inspector, Quad Cities
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6 ATTACRMENT A C0!HONWEALTil EDISON'S VIEW ON R. DICKHERBER Mra_Dickhe rber_' alas 13n riormance Commonwealth Edison's review of Mr. Dickherber's performance over the last twenty-five (25) years showed that, except for the October 17, 1989 event, Mr.
Dickherber has more than met management's expectations for acceptable and satisfactory personnel performance. To exceed expectations for a Fuel Handling Foreman, the Foreman must not only possess the qualities required to maintain an NRC SRO Limited license, but also the individual must be creative and innovativo in the implementation of_his/her responsibilities and the resolution of problems.
Furthermore, the Fuel llandling Foreman must offectively interface with other Commonwealth Edison Departments and Stations, vendors and utilities.
Mr. Dickherber, in his fifteen (15) year career as Fuel Handling Foreman, has been effective in implementing his duties.
lie has demonstrated dedication in the performance of his duties and management considered him to be highly reliable and dependable.
Since the inception of the formal Personnel Performance Review (PPR) system in 1987, Mr. Dickherber has been rated by his superiors in the category of " exceptional performance" in 1987 and 1988.
llis performance rating declined in 1989, due solely to the October 17 event.
Until the October 17, 1989 event, Mr. Dickherber had not been involved in any situations which indicated a willful disregard for procedures or otherwise called his integrity into question.
In fact, throughout his career he was considered a trustworthy and loyal employee.
Finally, throughout his career, Mr. Dickherber has contributed to the success of Quad Cities Station and provided many innovative suggestions and problem solutions that have been successfully adopted.
Mra_Dickherber's. Statements A careful review was conducted of Mr. Dickherber's response dated April 13, 1990.
The response reflects Mr. Dickherber's successful fifteen (15) year career as a Fuel llandling Foreman and his dedication to improving the activities for which he was responsible. Mr. Dickherber's factual statements are consistent with his achievements and his effective implementation of the Fuel Handling Foreman's responsibilities. Commonwealth Edison does recognize that Mr. Dickherber's presentation of the factual information contains some magnification associated with a strong sense of pride in his accomplishments and achievements.
Independent of these embellishments, our review of sections I.B through I.D showed that, the factual bases were correct, with the exception of the claimed reduction in radiation exposures and hours worked.
The records showed I
that the average radiation exposure per Fuel llandling worker did decrease by 48% from 1976 to 1977, however, they did not decrease as much as stated by Mr.
i Dickherber between 1974 and 1977.
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Furthermore, with regard to Section II.C of the response, Commonwealth Edison has performtd an extensive review of various time-keeping records. Our review demonstrates that the records generated from the protected area ingress and egress security computer do not support Mr. Dickherber's statements regarding the amount of hours worked. These discrepancies have been brought to Mr.
Dickherber and his attorney's attention and they have clarified these statements in correspondence to the NRC dated June 1, 1990.
In that clarification, Mr. Dickherber stated that his erroneous statements regarding work hours and radiation exposure arose from an over reliance on memory _and were not intended to mislead the NRC. Commonwealth Edison does not question the sincerity of Mr. Dickherber's explanation, but has considered the need to take these factual discrepancies into account in determining how to proceed with Mr. Dickherber's future status as discussed below.
MruMckherber'.s.Juture Commonwealth Edison realizes that the event which occurred on October 17, 1989 was totally inconsistent with expectations which have been established
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and implemented for the conduct of personnel in our Nuclear Operations area specifically, as well as the entire nuclear industry in general. Accordingly, j
following our internal investigation of the event, appropriate disciplinary j
actions which clearly communicated the uuacceptability of Mr. Dickherber's judgement were initiated. Those actions were consistent with our approach to discipline for personnel arrors and the sanctions imposed were also consistent with our view of the seriousness of this event.
Mr. Dickherber's record of employment for the last twenty-five years prior to this incident shows that he was a person of trustworthiness and integrity.
Although the October 17, 1989 event and the subsequent response to the NKC's request for information detracts from the company's confidence in Mr. Dickherber, we believe that his total record indicates that, with an appropriate staged program of evaluation and inareasing levels of responsibility, he can be returned to useful work in the highly regulated environment of a nuclear power plant. To substantiate this belief, and before embarking on a remediation progam, we intend to have an independent evaluation performed by our medical department. This independent evaluation will address i
medical concerns noted by Mr. Dickherber in his earlier response.
Positive results will be a first step in restoring our confidence in Mr. Dickherber, in a manner consistent with the Company Policy to provide a safe work environment and to promote high standards of employe health, 1
Given these favorable results Commonwealth Edison intends to submit a remediation plan for the Commission's review and concurrence.
In no event, however, do we intend, to seek approval to return Mr. Dickherber to activities f
which require an NRC license.
In summary, confidence in Mr. Dickherber's performance in the future for l
non-licensed duties can be based upon his demonstrated record of good past performance, his learning experience f rom this incident, a medical evaluation leading to a remediation program, and the successful completion of that remediation program. These factors should provide the necessary confidence that both Commonwealth Edison and the Commission need in reestablishing Mr.
i Dickherber's integrity and trustworthiness, so that he can assume non-licensed duties within a nuclear power plant environment.
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