ML20073B681

Responds to NRC Re Violations Noted in Insp Repts 50-277/94-15 & 50-278/94-15.Corrective Actions:Medical Procedure MDI/N2 Revised on 940902 to Include Specific Instruction for Medical Personnel to Notify of Any Changes

ML20073B681
Person / Time
Site:	Peach Bottom
Issue date:	09/15/1994
From:	Rainey G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CCN-94-14150, NUDOCS 9409220176
Download: ML20073B681 (5)

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Peach Bottom Atomic Power Station

_1 IECO ENERGY ;rg";gce-Delta. PA 17314-9739 717 456 7014 September 15,1994 Docket Nos. 50-277 50-278 Ucense Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Peach Bottom Atomic Power Station Units 2 & 3 Response to Notice of Violation (Combined Inspection Report No.

50-277 & 50-278/94-15 And 50-352 & 50-353/94-19)

Gentlemen:

In response to your letter dated August 18,1994, which transmitted the Notice of Violation concerning the referenced inspection report, we submit the attached response. The subject report concerned a Senior Reactor Operator Umited to fuel handling (LSRO) combined examination for Peach Bottom and Umerick Generating Stations that was conducted August 1-5, 1994.

If you have any questions or desire additional information,- do not hesitate to contact us.

t Geraid R. Rainey /

Vice President Peach Bottom Atomic Power Station Attachment CCN #94 .4150 220031 ,

9409220176 940915 PDR '

i G ADOCK 05000277E

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i cc: R. A. Burricelli, Public Service Electric & Gas: i R. R. Janati, Commonwealth of Pennsylania T. T. Martin, US NRC, Administrator, Region 1  :

W. L Schmidt, US NRC, Senior Resident inspector l H. C. Schwemm, VP - Atlantic Electric l R. l. McLean, State of Maryland l A. F. Krby ill, DelMarVa Power -

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bec: J. A. Bernstein 63C-7, Chesterbrook Commitment Coordinator 62A-1, Chesterbrook Correspondence Control Program 61B-3, Chesterbrook D. M. Smith 63C-3, Chesterbrook J. B. Cotton 53A-1, Chesterbrook W. H. Smith 62C-3, Chesterbrook J. Doering, Jr. 63C-5, Chesterbrook E. J. Cullen S23-1, Main Office A. A. Fulvio SMB4-6, Peach Bottom G. A. Hunger 62A-1, Chesterbrook M. C. Kray 62A-1, Chesterbrook C. J. McDermott S13-1, Main Office G. R. Rainey SMB4-9, Peach Bottom J.T.Robb 61C-1, Chesterbrook R. K. Smith A4-5S, Peach Bottom 1

RESPONSE TO NOTICE OF VIOLATION Restatement of Violation '

10 CFR 55.25 requires that if a licensed operator develops a physical condition that causes the operator to fail to meet the medical qualification requirements, the facility shall notify the Commission within 30 days of learning of the diagnosis.

Contrary to the above, PECO Energy (the facility) did not notify the Commission within 30 days of learning of a licensed operator with a physical condition that caused the operator to fail to meet the medical qualifications. Specifically, on December 13,1991, a medical examination of a licensed reactor operator identified that the operator's vision did not meet medical qualification limits without corrective lenses, and the facility notified the Commission of the diagnosis on July 14,1994, as part of license renewal.

This is a Severity Level IV violation (Supplement I).

Reason for the Violation Medical personnel understood the requirements relative to visual acuity for licensed operators and that the use of corrective lenses effectively addressed visual-deficiencies. There was confusion on the part of medical personnel, however, whether an update notification to the NRC was required for an operator license when a condition arose concerning the need for corrective lenses. NRC Form-396's, " Certification of medical examination by facility licensee" were accurately completed and placed in file, but medical personnel did not consider the need for corrective lenses to be significant enough to require that notification be made to the NRC. Although there was NRC guidance on licensed operator medical requirements, it was unclear to PECO Energy personnel that a condition for which the use of corrective lenses is required was also a condition that required a 30 day notification to be made to the NRC. As a result, medical procedures did not clearly identify the need for a 30 day notification to the NRC when the use of corrective lenses was required for licensed operators to meet medical standards.

At the time of this violation there was no single station procedure that provided overall control of interfaces, responsibilities and accountability relative to licensed operator medical requirements. Guidance information was either fragmented or in draft form, and there was not an adequate management tool to ensure that proper interfaces occurred and that required notifications were made. Since most of the activities related to licensed operator medical requirements were accomplished by experienced personnel, the perceived need for an overall control document was limited. In addition, due to the lack of a control process, self-assessment in this area was weak. As a result, process problems and weaknesses were not self-identified and corrected.

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The Corrective Steos That Have Been Taken and the Results Achieved ,

Medical procedure, MDl/N-2 " Procedure for the Medical Evaluation of Personnel -

Requiring Nuclear Power Plant Operator Licenses ( RO, SRO, LSRO) for the  :

Nuclear Division and the Certification Thereof" was revised September 2,1994, to ,

include specific instruction for medical personnel to notify the Experience Assessment Group, Senior Manager of Operations or Manager Reactor Services of any changes in licensed operator medical conditions that would require -

submittal of a revised NRC Form-396 to the NRC. In addition, appropriate personnel in the areas of Operations, Training, Medical and Experience Assessment have been notified of NRC requirements for submittal of changes to operator's licenses.

l An audit of facility licensed operator files, including LSRO's and former licensed operators, was conducted both at Peach Bottom and Limerick Generating Stations. Results of these audits indicated that most of the records reviewed were -

consistent with NRC requirements, however, oversights were identified at both facilities where the 30 day change notification had not been made. NRC Form-  ;

396's were completed and forwarded to the NRC to update corrective lens  ;

restrictions for licensed operators where previous NRC notification or license renewals had not been made. i The Corrective Steos that Will Be Taken to Avoid Further Violations A Nuclear Group procedure is currently under development to properly delineate areas of responsibility and accountability for operator licenses, clarity on corrective lens issues and NRC Form-396 requirements, and 10 CFR 50.74 submittals to the NRC. This procedure will be completed and implemented by December 31,1994.

As a result of this procedure and the delineation of responsibility, appropriate ,

groups will better assess the process and their contributions to it as part of the plant self-assessment process.

Date When Full Comoliance Was Achieved Full compliance was achieved September 2,1994, when audit identified discrepancies at Peach Bottom and Limerick were corrected by submittal of updated NRC Form-396's to the NRC. ,

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