ML20154B126
| ML20154B126 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, 05503096  |
| Issue date: | 09/06/1988 |
| From: | Pfender F PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| EA-88-077, EA-88-77, NUDOCS 8809130237 | |
| Download: ML20154B126 (4) | |
Text
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DCJ September 6, 1988 i
i Director, Office of Enforcement U.S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555 Ret Frank J.
Pfender, Jr.
Docket No. 55-3096 License.No. SOP-2621 EA 88-77
Dear Sir:
"*tJECT :
REPLY TO NOTICE OF VIOLATIOM on August 9, 1988, I was officially notified that I would be charged with a Severity Level II Violation and a proposed civil penalty of $1,000.00.
The proposed violation and penalty result-t ed from behavjor which subjected me to an enforcement conference on March 30, 1988.
This is my explanation of my conduct, as required pursuant to 10 C.F.R. S 2.201.
The Notice of Violation which I received indicated that contrary to the provisions of my license I violated Peach Bottom Atcmic Power Station Administrative Procedure A-7 entitled "Shift operations".
This Procedure provided that while I was on duty I was to remain alert and attentive to the control Room instrumen-tation and to refrain from engaging in distracting activities.
4 Because I was a Senior Licensed Operator, I was to ensure that all those under my command obeyed Administrative Procedure A-7.
i Instead of carrying out this charge, I read non-technical material while I was on duty and I permitted my shift to read.
l As stated in the Notice of Violation this activity occurred mainly on the midnight shift, but also on some afternoon shifts.
I In addition to reading, I played a hand-held golf game and allowed my shif t members to do the same.
I also allowed indi-viduals to play a computer video game in my presence.
I permit-I ted operators to lean back and close their eyes while they wero I
on my shift, and I did the same thing in my office.
I I must take the blame for my actions as well as those of my operatcrs because I was in charge of the shift.
I rationalized j
1 the breaking of Administrative Procedure A-7, because I did it 1
only after shift activf. ties were finished, when the plant was quiet.
For example, I read and let others read to pass the time on the midnight shift, rather than finding something better for
{
them to do.
I never proper 1 - understood the significance of 1
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a PVC
Director Office of Enforcement e
September 6, 1988 Page 3 violating an Administrative Procedure; worse yet, I gave mixed signals to my crew as to what type of behavior was acceptable.
I expected my crew to read and follow Administrative Procedure A-7, yet I broke it myself and I never held meetings to tell my shift how they should behave.
My greatest failing as a Shift Superintendent was that I stressed the technical side of my
- job, only.
I emphasized compliance with procedures concerning starting the
- reactor, shutting it down and maintaining it in a safe status.
I did not stress the significance of proper control room behavior.
I fully understand now that by violating an Administrative Procedure myself, my shift could only assume that I did not consider it important.
This was a serious failure on my part.
I currently am engaged in Electrical Preventive Maintenance.
My job requires me to coordinate with the shift, the removal of circuit breakers for offsite overhaul.
I suggest the particular breakers involved, and discuss with outage planning and the Shift Manager the switching required.
Final approval is granted by the Shift M.inager.
Through this assigt.n.ent, I have seen a remarkable change in the operators.
Operators keep procedures in front of them now at all times.
They will not do any task I request without a procedure.
In fact, each operator confirms that what I 4
have asked him to do is covered by a procedure and his supervisor comes in and confirms this, too.
There is double verification for all tasks.
I anticipate that I will be asked to delay my request for retirement and accept the Electrical Supervisor position in the Operations Department.
If this transpires, I have several goals.
First.
never again will our electrical equipment (breakers, valves, motors, etc.) be permitted to deteriorate to the extent that they have over the past thirteen years.
Second, it is my intention to create an Electrical Operating Group composed of the best plant operators who will be dedicated to electrical problema only and third, I wish to train the best and most experienced member of the group as my eventual replacement.
I believe a group of this kind will increase the liklihood of safe, reliable operations and decrease unexpected transients, isolations and scrams due to electrical ignorance.
In conclusion, I wish to state that I have not taken this matter lightly.
I lost the job and respect that I worked for over the last 35 years.
I have not fully recovered from the humiliation of tnis experience, but I want to put it behind me and become once more a valued member of the Operations Depart-
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Director, Office of Enforcement September 6, 1988 Page 3 ment.
I do value the opportunity of being permitted to remain at y
Peach Bottom and getting on with the work that I so dearly love.
Respectfully submitted, r. f.
s
Enclosure:
$1,000.00 Penalty cc:
Regional Administrator U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Per.nsylvania 19406 i
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AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA 6
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COUNTY OF L
.l Before me, a Notaty Public, personally appeared Frank J.
Pfender, Jr., who being duly.aworn according to law deposes ~and says that the statements made in his Reply to Notice of Violation s
are true and correct to the best of his information, knowledge f
and belief.
Sworn to and subscribed to before me this
'I day of
, 1988.
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