ML20154B069

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Responds to NRC Re Violation Noted Against License SOP-3622-3.Admits Violation of Administrative Procedure A-7 Over Extended Period of Time & Failure to Exercise Control & Command Responsibility as Supervisor
ML20154B069
Person / Time
Site: Peach Bottom, 05503217  Constellation icon.png
Issue date: 09/07/1988
From: Woodrow D
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE)
References
EA-88-030, EA-88-30, NUDOCS 8809130199
Download: ML20154B069 (5)


Text

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September 7, 1988 1

i Director, Office of Enforcement U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C.

20555 Ret David S. Woodrow l

Docket No. 55-3217 License No. SOP-3622-3 EA 88-30 l

Dear Sir l

SUBJECT:

REPLY TO NOTICE OF VIOLATION j

On August 9, 1988, I was served with a Notice of i

i Violation, Severity Level II, and Proposed Imposition of l

Civil Penalty in the amount of $800.00, because I par-ticipated in the inattentive behavior which required the Nuclear Regulatory Commission to suspend operation of the l

Peach Bottom reactors on March 31, 1987.

This Reply l

consists of my admission of my violation of Peach Bottom l

Administrative Procedure No. A-7, the reasons for my l

violation, the immediate corrective steps that have been taken, the corrective steps that have been taken to avoid l

further violations, and the date when full compliance will be achieved.

l As 1 admitted during my enforcement conference on l

l February 17, 1988 in Aberdeer Maryland, I had engaged in a t

violation of Administrative tocedure A-7 over an extended I

period of time and I failed to exercise the control and command responsibilities expected of a shift supervisor.

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I read non-job related material while I was on duty, I also put my feet up, and closed my eyes.

I allowed those I supervised to engage in this behavior and to play a golf game in my presence.

Although I knew this type of conduct was prohibited by the Administrative Procedure, I engaged in it because I r

had a lackadaisical attitude.

I also had the short-sighted I

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Director, Office of Enforcement September 7, 1988 Page 2

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attitude that automatic safety systems would take care of any incidents that might arise in the Plant.

l Since the shutdown order, I have come into compliance with Administrative Precedure A-7, because I understand 4

fully that my job is directly on the line if I do not comply with it and enforce it.

If I had directed the operators, prior to March 31, 1987, to stop violating Administrative Procedure A-7, I think they would have temporarily, but they knew I did not have the authority to discipline them in a manner that would prevent the resumption of this activity, r

Now, I can give an oral warning, or turn a more serious matter, such as a procedural violation, over to management.

One of the steps I have taken to prevent future vio-lations of Administrative Procedure A-7 is to observe ray men better by watching for any signs of bad behavior or any attitude problem.

To do this, I take more walks around the Control Room, and I have the men make more rounds while they

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are on duty.

I have asked my team members to let me know if they have any problems with other employees so that we can

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handle these problems correctly, and not with a disturbing confrontation.

If a man should have a bad day before coming to work and not obtain his needed rest, I tell my team members I would like to know that before the shift begins so that we can watch out for each other.

If I know this, I can i

obtain him a relief so that he can get some fresh air, or walk away from the consolo for awhile.

I will also visit l

with him more during the shift, and I will alert the other operators to be extra watchful of him to see that he does I

not assume a relaxed position.

I also told my team members l

that I would not condone any unprofessional behavior, and I

that I would report any improper actions to the attention of management.

We understand that because we have lost our reputations we must work twice as hard to prove to the NRC, PEco, and the public that we will perform our jobs in a proper, conscientious, and ptsfessional manner.

t Another corrective action I have taken, primarily because of a shortcoming that vns brought to my attention during my enforcement conference, is to become better l

l acquainted with activities at other nuclear power plants.

l Prior to shutdown, I had never talked to an operator from another nuclear plant, other than ones who had left the j

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Director, Office of Enforcement September 7, 1988 Page 3 employment of Philadelphia Electric Company.

I was very pleased to be selected to visit a Canadian Nuclear Power Plant, which had a distinguished service record.

I was assigned to look for pointers on a number of operational topics including shift scheduling, promotions and training.

The tour was a real eye opener, and in my recently completed report to my employer I recommended the expansion of the number of individuals manning the Control Room, and the need to include more individuals for emergency electrical and maintenance work.

I suggested moving from six teams to eight teams to cut down on the amount of night work and to accommodate personal scheduling changes.

The experience of this trip encouraged me to keep working on my promotional goals becoming involved in planning Operations' activities.

The final corrective activity I have successfully completed is my adjustment to the Shift Manager mode of operation, and my building of a strong operating team.

My Shift Manager is extremely vupportive.

We hold conferences together to plan work for the shift, and we ask for comments and input from the rest of the team.

My Shift Manager never bypasses me; also, my operators know that I will either act on their concerns or explain why I cannot.

I know that we set a fine example for the rest of the Plant, because others have approached me asking to join our team.

In conclusion, I would like to state that I am in full compliance with Administrative Procedure A-7, which I understand is a part of my license requirements, and I have taken the steps outlined ebove to ensure that my conduct and the conduct of the operators assigned to me will not jeopar-dize the health and safety of the general public.

There is better communication now among the operators, a better attitude towards our jobs as well as towards the other departments upon whom we must rely, and a strong desire to show that we can perform our duties in a professional manner.

I wish to thank you for giving me the opportunity

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Director, Office of Enforcement September 7, 1988 Page 4 to continuo as a licensed Shift Supervisor at Peach Bottom Atomic Power Station.

Rospectfully submitted, b wic

$$5ed<ns David S. Woodrow Enclosuro:

$800.00 Penalty 4

cc:

Reginoal Administrator U.S. Nuclear Regulatory Commission j

Region I l

475 Allendale Road King of Prussia, PA 19406

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AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA

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Before me, a Notary Public, personally appeared DAVID S. WOODROW, 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 f day of W I fh

, 1988.

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