ML20154A288

Responds to NRC Re Violation of Plant Administrative Procedure A-7, Shift Operations. Corrective Actions:Author Assumes Responsibility for Violation & Conducts Weekly Shift Meetings W/Other Operators

ML20154A288
Person / Time
Site:	Peach Bottom
Issue date:	08/28/1988
From:	Hart R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE)
References
EA-88-014, EA-88-14, NUDOCS 8809120140
Download: ML20154A288 (4)

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August 28, 1988 Director, Office of Enforcement U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Mashington, D.C.

20555 Ret Russell S. Hart Docket No. 55-5913 License No. OP-10329-1 EA 88-14

SUBJECT:

REPLY TO NOTICE OF VIOLATION On August 9, 1988 I lear.ted that I would be subject to a Severity Level III Violation and a proposed civil penalty of

$500.00.

I am subject to this enforcement action because I violated Peach Bottom Administrative Procedure A-7 entitled "Shift Operations".

I am charged with being inattentive to instrumentation, during the 11:00 p.m. to the 7:00 a.m. shift and allowing myself to be distracted by activities that were specifically banned under Administrative Procedure A-7.

As I acknowledged during any enforcement conference on March 2,

1988, I violated the terms of my license because I was inat-tentive, at times, while at the controls of Units 2 and 3.

I riever slept on duty, but I did let my attention drif t which meant I was not focusing exclusively on my duties.

On occasion, I assumed a relaxed posture with my head back and arms behind my head.

This posture could have given others the perception that I was inattentive.

While I was on duty, I

read non-technical inuterial.

I played a golf game on one occasion and during another period I played music on a tape recorder, which I had brought into the Control Room.

I violated Procedure A-7 because I let myself get in a rut.

I allowed my mental state to affect my job performance to the point where I lost my perspective of the seriousness of my responsibilities.

Because I allowed myself to become disillu-sioned, I began not to care how I appeared while I was at the controls at Peach Bottom.

I thought I could get away with breaking certain rules, because I would not really be inattentive if, for example, I played a golf game at the reactor console.

I failed to consider how important complete attention to and control of the reactor, as shown through procedural compliance, was to the health and safety of the public.

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1 Director, Office of Enforcement August 28, 1988 Page 2 After shutdown, there was no question in anyone's mind what the rules and regulations were because management stated that rules were going to be stringently enforced no matter who broke them.

We all understood that.

I also came to see that if there wore over an accident at Peach Bottom it probably would not be based upon plant design.

It would probably be from inattention; so, only I and the other operators could prevent that.

The only l

way to prevent a problem was to regain total control over the reactor by giving it 100% of our attention.

Lapses, such as I experienced, could never happen again.

As part of my immediate corrective action, I resolved that I must never again get into the mental state where I was not enthused about my performance as a reactor operator.

I made the determination to get all I could out of my PPE training, and I found it to be extremely valuable.

PFE training taught me how to be persistent about my own ideas, yet at the same time learn to accept things that I could not change.

I realized that I had to use other people to compensate for my shortcomings and I was shown how to appreciate their abilities.

This all came into focus for me when I had to examine how I gave directions to others.

Before, I did not care if someone could not understand j

my directions.

I figured that it was his problem.

It has been brought home to me that it is my responsibility to make sure everyone always understands my directione.

I made an important attitude change in the way I stood shift by perceiving that I needed to monitor the reactor to catch things happening before an alarm went off.

I must rely on myself

)

and the other operators to keep equipment operating safely, just j

in case something might fail.

To help myself do this and show my support for others, I brief my relief operator thoroughly on what has happened, what is going on and what is anticipated to be going on with the reactor.

Before, my attitude was "you are on your own, my shift is over."

I have been further helped in my new awareness of the need for procedural compliance by our practice of having weekly shift meetingo.

At these meetings we operators discuss among ourselves what we should or should not do.

The Shift Managers get back to us with their ideas on how to follow the letter of the procedures.

The company has given us its commitment to etraightening out our procedures, and agreeing that if we find something wrong, we need go no further until it is corrected for uc.

The most significant corrective action J have taken is to assume responsibility not only for my actions, but for the actions of the other operators.

Before, if I

saw improper behavior, I thought it was none of my business.

To me, it was management's job to correct people who were out of line in the

6 Director, Office of Enforcement August 28, 1988 Page 3 Control Room.

Now, I know that I must take the responsibility to correct a violation of the procedures, even if it means that I i

must bring it higher, to someone in authority's attention.

For the

future, I

understand that because the Nuclear j

Regulatory Commission has entrusted to me the operation of Peach Bottom Atomic Power Station's Units 2 and 3,

I, in turn, am responsible for the health and safety of the general public.

It is Jm responsibility to see that the reactors are operating 4

safely.

I am dedicated to doing the job right.

If something goes wrong it is my responsibility to correct it.

I know I have r

to continue to work hard to keep this attitude instilled in me and in my co-workers, in return for your willingness to let me i

keep my license.

Respectfully submitted, i

J//h$

$4ussell S.

Hart cc:

Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road L

King of Prussia, Pennsylvania 19406 1

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AFFIt' WIT COMMONWEALTl! OF PENNSYLVANIA SS:

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COUNTY OF Bafare me, a Notary Public, personally appaared Russell S.

Ilart, who being duly sworn according to law deposes and says that the statements made in his Reply to Notice of Violation are true and correct to the best of his information, knowledge and belief.

Sworn to and subscribed to before me this day of 1988.

0l D.hf Wf X LA i.1 Notary Public (SEAL)

My commission expires o.nis c wtwa. war rueb6 runon teamtr. LAncera conff~

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