ML20072F985
| ML20072F985 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 08/15/1994 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9408240153 | |
| Download: ML20072F985 (3) | |
Text
D Csmm:nw:alth Edis n C / Byron Nuclear Station i
Of 4450 North German Church Road Byron. Illinois 61010 August 15,1994 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention:
Document Control Desk
Subject:
Byron Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report No. 50-454/94014 NRC Docket Numbers 50-454
Reference:
G. Grant letter to Mr. Graesser dated July 14,1994, transtnitting NRC Inspection Report 50-454/94014 Enclosed is Commonwealth Edison Company's response to the Notice of Violation (NOV) which was transmitted with the referenced letter and Inspection Report. The NOV cited a Severity Level IV violation requiring a written response. CECO's response is provided in the attachment.
If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441 ext.2280.
Respectfully,
/
U K. Graesser Site Vice President Byron Nuclear Power Station Attachment (s) cc:
J. B. Martin, NRC Regional Administrator - Rill G. F. Dick, Byron Project Manager - NRR H. Peterson, Senior Resident inspector, Byron B. L Jorgensen, Reactor Projects Chief - Rlli D. L Farrar, Nuclear Regulatory Services Manager, Downers Grove I
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i ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 454/94014 VIOLATION (454(455)/94014-01)
During an NRC inspection conducted on June 20 - 24,1994, a violation of NRC requirements was brought to the attention of the NRC and examined. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1994) the violation is listed below:
10 CFR Part 50.54(l) states, in part, that "The licensee shall designate individuals to be responsible for directing the licensed activities of licensed operators. These individuals shall be licensed as senior operators pursuant to Part 55 of this chapter."
Contrary to the above, during the period from April 1,1994 to June 15,1994, the licensee designated a senior operator, licensed pursuant to 10 CFR Part 55, to direct licensed activities when that person had not met the requirements for maintaining an active license in accordance with 10 CFR Part 55.53(f).
This is a Severity Level IV Violation (Supplement l}
REASON FOR THE VIOLATION:
A Station Quality Verification (SQV) audit discovered two incidents where a Shift Supervisor's qualification requirements to maintain his Senior Reactor Operator (SRO) license active had not been met while he had performed SRO duties.
The Shift Supervisor, who was involved, was an "off-shift license" assigned to the Operating Department's procedure writers group at the time. Historically, these people were responsible for tracking their own hours worked to ensure the requirements were met.
As the end of the first quarter approached, the SRO's recollection of the exact number of shifts worked was unclear. He had been on shift for about the first two weeks of the year.
He thought that he had worked the required five twelve hour shifts in the quarter to maintain his license current. In actuality he had worked four twelve hour shifts and a portion of a fifth. Since the requirements for hours on shift had not been met, the Shift Supervisor's license became inactive on April first (the start of the second quarter).
On April sixth, and again on April twenty second, the SRO accepted duties for a position for which his qualifications had expired and worked on shift, as a shift Supervisor, in a capacity requiring an active SRO license.
During both shifts in question there was a Shift Engineer (SE), Shift Control Room Engineer (SCRE), and another Shift Supervisor on shift, for a total of three SROs which meets the requirements of Section 6 of the Technical Specifications.
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At no time during the two shifts did a transient occur that required the inactive SRO
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to direct licensed operator's actions.
The Station Control Room Engineer (SCRE) was always available to backup the inactive SRO in the SCRE's capability as Shift Technical Advisor (STA).
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
As an immediate corrective action the individual was removed from active licensed duties.
The individual's name was removed from the list of active licensed operators. As a follow-up, a discussion was held with the Operations Manager to re-enforce the personal responsibility to maintain the requirements of an SRO license.
Operating Department Policy # 400-12 was revised to address the tracking of "off shift licenses" An active status log for off-shift individuals is being kept in the shift engineer schedule book in the Shift Engineer (SE) Office. The active status individuals are responsible for updating this book. Operations management will review the book the first week of each month and forward a copy of the log to each individual to insure they are aware of the number of shifts worked in that quarter. In addition, operations management will review the status of these individuals 3 to 4 days prior to the end of each quarter via an operating quarterly surveillance. If an individual has not met his requirements, he will be notified as soon as possible and not be allowed to provide shift coverage (the next quarter) until his " Active" Status can be verified acceptable.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION:
A broad review of the tracking for different license conditions will be conducted to determine what improvements are required. This review will include, but not be limited to, time on shift, medical conditions, training qualifications, and limited SRO status. This review and the implementation of its findings will be tracked by NTS # 454-200-94-01200-
- 01. The expected completion date of the review is 09/01/94 with full implementation by-10/01/94.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
On 06/06/94, after Station Management was notified by SQV, the individual in question was removed from active licensed duties. Additionally, on 06/21/94, Byron Operating Department Policy Statement No. 400-12,
Subject:
Operator's License-Active, was revised to include only names of active licensed operators.
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