ML20210S428

Responds to NRC Re Violations Noted in Ofc of Investigation Repts 1-96-006 & 1-96-033.Corrective Actions: Primary Chemistry Manager & Chemist Resigned,Counseled Chemistry Technician & Formed Task Force to Study Integrity

ML20210S428
Person / Time
Site:	Limerick
Issue date:	09/04/1997
From:	Walter MacFarland PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
EA-97-050, EA-97-115, EA-97-50, NUDOCS 9709100171
Download: ML20210S428 (7)

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4 ( An ( v l'l CD / y vu L n t .ua i 19404 0920 e 01 71 063 Pagne 1800 072 2285 #8320 10 CFR 2.201 September 4,1997 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 )

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Director, Office of Enforcement U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555 4

SUBJECT:

Limerick Generating Station, Units 1 and 2 Reply to a Notice of Violation and Payment of Civil Penalty NRC Office of Investigation Report Nos. 1-96-006 and 1-96-033 Enforcement Actions97-050 and 97-115 Attached is PECO Energy Company's reply to a Notice of Violation for Limerick Generating Station (LGS), Units 1 and 2, that was contained in your letter dated August 5,1997. The Notice concerned instances of falsification of information required to be kept by PECO Energy in accordance with the requirements of 10CFR50.9. The attachment to this letter provides a restatement of the violation followed by our reply. A check in the amount of $80,000 for payment of the civil g penalty is enclosed. Y Although several incidents of record falsification were identified at LGS, a $/;

thorough investigation determined that these were independent cases. The '

incidents were not indicative of a generic concern regarding a willingness to misrepresent activities. Neither were the incidents indicative of the culture at \

LGS with respect to the integrity of station personnel and their willingness to i raise issues of concern PECO Energy emphasizes employee behaviors that reflect important core values including integrity, openness, trust and respect.

Management continually relies on the integrity and trustworthiness of station 9709100171 PDR 970904

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l Do,ck,et Nos. 50-352 and 50 353

' September 4,1997 Page 2 1

personnel to perform their assigned duties, and to raise issues of concern. Both cited issues were identified by station emp;oyees. The corrective actions were prompt and appropriately comprehensive based on the nature of the issues.

Additionally, there were no plant safety consequences stemming from these incidents.

PECO Energy is o#J md,@o ensure that an open culture continues to exist at all of its facilities. A4 pcxA a letter from the Senior Vice President of Nuclear Operations will be issued n ull PECO Nuclear personnel reemphasizing that the company's standard for Operational Excellence is based on each Individual living to the core values described above, in addition, this letter will reemphasize that no one is expected to compromise their values for any reason, and that anyone who believes their values may be compromised should raise such a concern to management's attention.

If you have any questions or require additional information, please contact us.

Very truly yours, (t f (, D ,

Attachment cc: H. J. Miller, Administrator, Region I, USNRC w/ attachment N. S. Perry, USNRC Senior Resident inspector, LGS i

Attachment Do'cket N'os'. 50 352 and 50-353 September 4,1997 Page 1 of 5 Roolv to a Notice of Violation Restatement of the Violation As a result of investigations conducted by the NRC Office of Investigations, and PECO Energy company, violations of NRC requirements were Identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

NUREG 1600, 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 01 CFR 2.205, the particular violations and associated civil penalty are set  ;

forth below:

10 CFR 50.9 requires, in part, that Information required by the Commission's regulations or license conditions to be maintained by the licensee shall be compete and accurate in all material respects.

Technical Specification (TS) 6.10.2.d requires, in part, that records of surveillance activities required by TSs be retained for at least 5 years.

1. Contrary to the above, a record of a TS surveillance activity required to be maintained by the licensee at Limerick, was not complete and accurate in all material respects. Specifically, on February 7,1996, while a Reactor Enclosure Cooling Water (RECW) radiation monitor was inoperable, the licensee was required, in accordance with TS 3.3.7.1, ACTION 72, to '

obtain and analyze at least one grab sample from the RECW system at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. On that date, the sample needed to be taken by 11:00 a.m. to meet the requirement. Although the sample was not taken until 12:15 p.m. on that date (approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes after the time it was due), the record of the RECW Surveillance Test (ST : 0926-570-1, "Inop Reactor Enclosure Cooling Water Rad Mon Grab l Sampling and Analysis"), signed by a chemistry technician and the chemist (as chemistry supervision), was inaccurate because: (1) page i one of attachment 1 of the test record indicated that the time of the sample was 11:00 a.m., and (2) the attached computer printout of the Gamma Spectrum Analysis (required by step 4,3.1 of the surveillance test) also indicated that the sample was taken at 11:00 a.m.. This record was material because it provides evidence as to whether the licensee met the grab sample requirements. (01012) i

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Attachment Do'cket Nos'. 50 352 and 50-353 September 4,1997

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2. Contrary to the above, certain surveillance records required to be  ;

maintained by the licensee at Limerick, were not complete and accurate in  !

all material respects. Specifically, on three occasions between April 3, 1995 and June 28,1995, the records for fire protection surveillance tests required by.TS 4.7.6.2.c and TS 4.7.6.5.a were not accurate in that certain fire hose and sprinkler system inspections were recorded as '

having been completed, even though plant security data indicates that the technician was not present in the vicinity of the equipment to perform the >

inspection. These records were material because they provide evidence as to whether the licensee met the fire protection surveillance  !

requirements. (01022)

This Is a Severity Level ll problem. (Supplement Vil)

Civil Penalty - $80,000. ,

REPLY Admission of the Violation PECO Energy acknowledges the violations.

Reasons for the Violationg The cause of the violations was cognitive personnel error, in the first case, a Chemistry Technician.was aware of the assignment to obtain and analyze the RECW system fluid sample but did not pay sufficient atte_ntion to obtain the sample by the set time. The Technician and a former Chemist, at the direction of a former Primary Chemistry Manager, deliberately falsified the record of the time the grab sample was taken from the RECW system. The Primary Chemistry Manager also pressured the

. Technician and Chemist to lie about their actions to security personnel investigating the matter, in the second case, a fire protection Technical Assistant deliberately failed to perform fire hose station and sprinkler system visual inspection surveillance tests, yet i falsified the surveillance test documents to indicate the tests were performed.

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Attachment  !

Docket Nos'. 50 352 and 50-353 I September 4,1997 Page 3 of 5

_C_orrective Actions Taken and Results Achieved Chernistry As indicated in LER 1-96-005, the results of the sample analysis indicated that there was no RECW system contamination, and therefore, there were no plant safety consequences as a result of the late analysis.

Based on the results of the PECO Energy's independent internal investigation, unescorted access was suspended for both the Primary Chemistry Manager and the Chemist on the next working day.

As a result of this incident, the Primary Chemistry Manager and the Chemist were suspended with the intent to terminate, and both subsequently resigned from PECO Energy.

The Chemistry Technician initially identified the late sample, was coerced by the Primary Chemistry Manager to falsify and provide a fabricated account of the events, and subsequently revealed the true facts concerning the event. As a result, the Technician was counselod and the individual's security access was reinstated.

Subsequent to the start of the independent internal investigation, the Limerick Vice President convened a task force of five individuals from outside the Limerick organization to determine the overall integrity of the Chemistry function at Limerick.

The results of the task force indicated that PECO Energy Core Values, such as integrity, openness, trust and respect, were important to chemistry personnel. In addition, the results indicated that Chemistry personnel were not reluctant to raise nuclear safety issues.

Fire Protection After admission of intentional falsification, the individual's unescorted access was suspended, and the individual was appropriately disciplined, including suspension of employment.

The applicable surveillance test (ST) procedures were re-performed. The ST procedures were all completed satisfactorily indicating that the affected Fire Protection equipment was operable. Therefore, there were no plant safety consequences as a result of the failure to perform the inspections.

Attachment Do'cket Nos'. 50-352 and 50-353 September 4,1997 Page 4 of 5 Management expectations regarding personal integrity were reinforced to all members of the Fire Protection Group.

Corrective Actions to Avoid Future Noncomollance Chemistry A Chemistry ati-hands meeting was conducted to discuss the event as well as management's expectations on completeness and accuracy of information required by l the NRC.

Expectations on personal integrity were reinforced with Chemistry Supervision.

A Read and Sign on personal integrity was issued to Chemistry personnel.

The site Directors were briefed on the issue.

The opportunities for Chemistry organization improvements identified by the Chemistry Task Force were addressed.

Fire Protection Based on the findings within the Fire Protection Group, management expectations for-personal integrity were reinforced to all rnembers of the Site Support Division, in addition, because of both the Chemistry and Fire Protection issues, the Limerick Vice President issued a letter to all site personnel regarding personal integrity.

Site wide Actions Because of both the Chemistry and the Fire Protection incidents, the independent investigation was expanded to include other onsite groups. Some discrepancies were identified, were further investigated, and were addressed by line management. These discrepancies were considered to be associated with poor work practices. Based on .

the results of the assessment, management concluded there was no generic concern regarding falsification of records,

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Att,achment Docket Nos. 50-352 and 50 353

- September 4,1997 Page 5 of 5 h addition, group meetings were held with all site personnel. At th6se meetings, the l Vice President and other senior managers discussed the expectations of truthfulness l and integrity, Nuclear Group Actions A letter from the Senior Vice President of Nuclear Operations will be issued to all PECO Nuclear personnel reemphasizing that the company's standard for Operational Excellence is based on each individual living to such core values as integrity, accountability, openness, trust, and respect, in addition, this letter will reemphasize that no ons is expected to compromise their values for any reason, and that anyone who believes their values may be compromised should raise such a concern to management's attention.

Date When Full Comollance was Achieved With respect to the Chemistry event, full compliance was achieved on February 7, 1996, when the Unit i RECW fluid sample was obtained and analyzed, and determined not to be contaminated. With respect to the Fire Protection events, full compliance was achieved by August 27,1996, when all of the applicable inspections had been performed and the fire protection equipment was found to be operable.

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