ML20078M551
| ML20078M551 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/07/1994 |
| From: | Kraft E COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ESK-94-077, ESK-94-77, NUDOCS 9412020207 | |
| Download: ML20078M551 (5) | |
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Commonwrith Edison ound cities Nuclear Power station 22710 206 Avenue North cordova, Illinois 61242 l
Telephone 309/654-2241 ESK-94-077 November 7,1994 Director, Office of Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:
Document Control Desk
Subject:
Quad Cities Power Station Units 1 and 2; l
NRC Docket Number 50-254 and 50-265; NRC Inspection Report Numbers 50-254(265)/94018
Reference:
John B. Martin letter to M. Wallace dated October 12,1994, transmitting Notice of Violation and Proposed imposition of Cin Penalty - $80,000 (Severity Level 11)
Enclosed is Commonwealth Edison's (Comed) response to the Notice of Violation transmitted with the referenced letter. The NOV cited two violations, involving: 1) the failure to suspend the Operation's Manager's unescorted access to the protected area after determining that his fitness may be questionable and 2) the failure to implement for-cause testing as soon as possible after receiving credible information that the Operations Manager wa under the influence of alcohol.
These violations have been classified in the aggregate as a Severity Level ll problem, and assessed a civil penalty of $80,000. Comed's response and payment of the civil penalty is attached.
We appreciate the NRC's acknowledgement of Quad Cities corrective actions for these violations. As pointed out in your NOV, we had not included revising the fitness-for-duty procedure to provide additional emphasis that removal from unescorted access and testing within one hour were required when credible information is received that an individual's fitness may be questionable. That commitment is being made by this letter. Quad Cities' Administrative Procedure (QCAP) 890-7 will be revised by November 12,1994.
Furthermore, to ensure that management's expectations regarding fitness-for-duty are fully understood cad properly implemented by all personnel working at Quad training on af/ AM Y Cities, the station manager and/or myself provided supplemental FFD,L aspects of the FFD program.
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' Director, Office of Enforcement U. S. Nuclear Regulatory Commission Page 2 If there are any questions or comments concerning this letter, please refer them to Nick Chrissotimos, Regulatory Assurance at (309) 654-2241, ext 3100.
Respectfully, E. S. Kraf t,.b.
Site Vice President Quad Cities Station Attachment cc:
J. Martin, Regional Administrator, Rlli R. Pulsifer, Project Manager, NRR C. Miller, Senior Resident inspector, Quad Cities l
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' VIOLATION 50-254/265-94018; During an NRC inspection conducted from May 2 through. August 29,1994 violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:
A.
10 CFR 26.27(b)(1) requires, in part, that those workers whose fitness 4
may be questionable be removed from activities within the scope of this part.
Contrary to the above, from 9:50 p.m. on April 23,1994, until 1:08 a.m. on April 24,1994, the licensee failed to remove the Operations Manager from licensed activities in that he was still permitted unescorted access to the protected area even though two individuals had reported to the Shift Engineer the smell of alcohol on the breath of the Operations Manager. (01012)
B.
10 CFR 26.24(a)(3) requires, in part, that the licensee implement testing for cause as soon as possible after receiving credible information that an individual is abusing alcohol.
Quad Cities procedure QCAP 890-7, Section D.Z(d) states that "for cause testing" should be accomplished by management within one (1) hour.
Contrary to the above, the licensee did not implement testing for cause ae soon as possible af ter receiving credible information that the Operations Manager, who was unescorted in the protected area, had abused alcohol. The credible information was initially received at about 9:50 p.m. on April 23,1994 and testing for cause was not conducted until about 1:15 a.rn, on April 24, 1994.(01022)
This is a Severity Level 11 problem (Supplement Vil).
Civil Penalty - $80,000.
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REASONS FOR THE VIOLATION:
.i Comed acknowledges the above violation. The cause for the violations'was a failure f
to follow the Quad Cities Station Fitness for Duty (FFD) procedure (QCAP 890-7).
j Com 'buting factors to the event were:
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- 1) The Shift Engineer did not consult the entire procedure during the event.
- 2) The Shift Engineer was misled by the Operations Manager in that he stated he had consumed only one beer.
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- 3) The Shift Engineer's assessment that the Operations Manager was not a threat to plant safety was based upon observations and misleading statements provided by the Operations Manager.
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- 4) Operational conditions ano ; vents created distractions for the Shift Engineer, including a Unit 2 transforms transient and recovery, a medical emergency, including the possible declaration of an Unusual Event based on the medical emergency, and the need to provide a thorough shift turnover to the on-coming shif t.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED _t The following immediate and near term actions have been taken:
- 1) The Operations Manager was immediately denied access and subsequently was removed from the position and resigned from the company.
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- 2) Quad Cities personnel, including licensed shift personnel, received supplementai FFD training from the Site V.P. and/or the Station Manager on all aspects of the FF0 program, with emphasis on:
l a) for-cause test determination b) response to odor of alcohol c) escort requirements d) time requirements for testing 6 instruction for reporting to work
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- 3) The Shif t Engineer was counselled by the Station Manager. The Shift Engineer l
subsequently reviewed the FFD Policy and Lessons-Learned from the event with all other Shift Engineers.
- 4) FFD Training was reviewed for adequacy and was determined to be satisfactory.
' CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:
The Chief Nuclear Officer has communicated this event in writing to all Nuclear Division employees, with emphasis on FFD expectations. This communication and expectations has been incorporated into the station FFD training.
The station will revise procedure QCAP 890-7 by November 12,1994. This revision will place emphasis on the requirement to remove unescorted access of an individual j'
whose fitness is determined questionable, until the concern has been satisfactorily resolved. The revision will also clarify the requirement to begin a for-cause test within one hour of the time the determination is made to conduct a test.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be met with the completion of the above reference revision to procedure QCAP 890-7 by November 12,1994.
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