ML20059N109
| ML20059N109 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/21/1990 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20059N110 | List: |
| References | |
| EA-90-092, EA-90-92, NUDOCS 9010100113 | |
| Download: ML20059N109 (5) | |
See also: IR 05000295/1990011
Text
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September 21, 1990
Docket Nos.
50-295 and 50-304
License Nos. DPR-39 and DPR-48
EA 90-092
Commonwealth Edison Company
ATTN: Mr. Cordell Reed
' Senior Vice President
Opus West III
1400_ Opus Place
Downers Grove, Illinois 60515
Gentlemen:
SUBJECT:
(NRCINVESTIGATIONREPORTNO. 3-87-010)
(NRC INSPECTION REPORT NOS. 50-295/87008; 50-304/87010
AND 50-295/90011; 50-304/90013)
This refers to the special safety inspection conducted on April- 15 and 24,1987
of activities at the Zion Nuclear Generating Station, authorized by NRC License
Nos.
DPR-39 and DPR-48. A copy of the report of that inspection
(Nos.50-295/87008;.50-304/87010) was mailed to you on June 2, 1987.
This.also
refers to' an investigation conducted by the NRC Office of Investigations and
the closeout inspection that was conducted from April 24 through May 8,1990
and May 29, 1990. The closeout inspection was to follow up on concerns
regarding the recent performance of a radwaste foreman who falcified a record-
ir, March 1987.
A copy of the investigation report summary and the latter-
inspection report are attached. A violation of NRC requirements was identified
during the course of the inspections and investigation.
The_ opportunity to:
meet and consider this issue in an enforcement conference was discussed with
Mr. T. Maiman of your staff and it was agreed that an enforcement conference
regarding this matter was not necessary.
On March 14, 1987, a radwaste foreman signed a checklist . indicating that he had
performed two verifications required by technical specifications governing the
radwaste release, when in fact, he had not performed either:of the required
verifications. One verification required that the foreman personally see that
the discharge valves were properly lined up prior to start of the discharge
operation; the other required that he personally check to see that the
monitoring instruments were working p'
3erly and, if not, that' he take samples
of the discharge. The radwaste foremah asserted that he had received verbal
affirmation from the operating equipment attendant.that the valves were
properly lined up and, therefore, felt that he had not violated prescribed
procedures. The radwaste foreman claimed to have no recollection of training
-he received with_ regard to management verification. However, the 01
investigation disclosed that the radwaste foreman'had received training _on two -
separate occasions (one as recent as two weeks prior to this event) that-
addressed the issue of failure to perform verifications properly.
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September 21, 1990
The staff recognizes that the resultant unmonitored releases were fortuitously
- within regulatory limits.
However, i squirements are established for a specific
purpose and a foreman who believes that he need not perform the tasks required
of him is inexcusable.
Besides the trust placed in a foreman due to his
supervisory position, a foreman sets the standards of conduct for his
subordinates.
It is unacceptable for a supervisor to deliberately not perform
an assigned task and then falsify the record of that assignment.
The NRC considered several factors in determining the severity level-of this-
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willful violation. Although there was no economic advantage gained as a result
'
of this violation and the technical safety significance of the underlying event
,
was minimal, the individual involved was in a supervisory position and the
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individual had received training two weeks prior to the event regarding dual
verification. Therefores considering the foreman's position, his prior
training, and the fact that the NRC considers record falsification a
.
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significant regulatory concern, this violation has been categorized at Severity
Leve III.
.
'
In accordance with the " General Statement of Policy and Procedure for NRC
Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C (1987), a
civil penalty is considered for a Severity Level III violation. However, after
consultation with the Director, Office of Enforcement, the Deputy Executive
Director for Nuclear Reactor Regulation, Regional Operations, and Research, and
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the Commission, I have decided that a civil penalty will not be proposed in
2
this casa because you promptly identified the violation and reported 'it to the
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NRC. Further, the disciplinary actions taken by the Commonwealth Edi, ,.
Company by suspending the foreman's employment for three days without pay and
the instituting of a requirement for dual verification of valve positions were
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taken into consideration.
Also, the apparent satisfactory performance by the
i
radwaste foreman subsequent to his return to work from the suspension wcs
considered.
!
The fact that a civil penalty is not being proposed for this violation should
not diminish the importance of this matter. As'previously stated, docement
falsification cannot be excused in the nuclear industry.
In fact, if this
violation were to occur today, the NRC would consider issuing an order;to
remove the individual from licensed activities. . However, the NRC recognizes
that considerable time has passed since this' violation' occurred and that
actions have been taken to correct the identified violation and to prevent-
recurrence. Nevertheless, despite the apparent good behavior of this
individual since the time the violation occurred, you are required to respond
to this letter.
Specifically, you are to provide the NRC with your formal
basis for concluding you currently have confidence in the individual's
,
activities, giver, the record falsification,
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In accordance with 10 CFR 2.790 of the NRC's Rules of Practice, a copy of
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this letter and its enclosure will be placed in the NRC Public Document Room,
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September 21, 1990
The response directe:-
'his letter and the enclosed Notice are not subject
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to the clearance prot- J . . of the Office of Management and Budget as required
by the Paperwork Reduc dan Act of 1980, Pub.L. No.96-511.
Sincerely,
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A. Bert Davis-
Regional Administrator
Enclosures:
1.
2.
Inspection Reports-
No. 50-295/90011;
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No. 50-304/90013
'
3.
Synopsis of 01 Report
3-87-010
cc w/ enclosures:
M. Wallace, Vice President,
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PWR Operations
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'. Kovach, Nuclear
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Licensing Manager
T. Joyce, Station Manager
DCD/DCB (RIDS)
OC/LFDCB
Resident inspectors, Byron,
Braidwood, Zion
Richard Hubbard
J. W. McCaffrey, Chief, Public
Utilities Division
Mayor, City of Zion
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Chandu Patel, Project
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Manager, NRR
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Robert Ne-1 ann, Office of Public
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Counse. State of Illinois Center
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Commonwealth Edison Company
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September 21, 1990
The response directed by this letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub.L. No.96-511.
Sincerely,
4
A. Bert Davis
Regional Administrator
Enclosures:
1.
2.
Inspection Reports
,
No. 50-295/90011;
No. 50-304/90013
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3.
Synopsis of 01 Report
1
3-87-010
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cc w/ enclosures:
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M. Wallace, Vice President,
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PWR Operations
T. Kovach, Nuclear
Licensing Manager
T. Joyce, Station Manager
DCD/DCB (RIDS)
,
'
OC/LFDCB
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Resident Inspectors, Byron,
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Braidwood, Zion
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Richard Hubbard
J. W. McCaffrey, Chief. Public
Utilities Division
Mayor, City of Zion
Chandu Patel, Project
Manager, NRR
Robert Newmann, Office of Public
Counsel, State of Illinois Center
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