ML20245G151
| ML20245G151 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/10/1989 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Corbin McNeil PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20245G154 | List: |
| References | |
| NUDOCS 8908150232 | |
| Download: ML20245G151 (5) | |
See also: IR 05000352/1989011
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Aug'ust 10, 1989
Docket Nos. '50-352
50-353
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License Nos. NPF-39
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CPPR-107
EA 89-126
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Philadelphia' Electric Company
' ATTN: Mr. C. A. McNeill, Jr.
Executive Vice President
Nuclear-
-Correspondence Control Desk
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P. O. Box-7520-
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Philadelphia, PA 19101
Gentlemen:
Subject: NOTICE OF VIOLATION AND PROP 0kED IMPOSITION OF CIVIL PENALTY-
$75,000
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(NRC. Inspection Report-No. 50-352/89-11 and 50-353/89-17)
This refers to the NRC emergency preparedness inspection conducted during
May 22-26, 1989 and June 7,1989 at the Limerick Nuclear Generating Station.
During the inspection,'the report of which was sent to you on June 21, 1989,
violations of NRC requirements were identified. On July ~ 6, .1989, an enforce-
ment conference was conducted with you and members of your staff to discuss
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the violations, their causes and'your corrective actions.
The-violations,.which are described in the enclosed Notice of Violation
and Proposed Imposition of Civil Penalty, includei
(1) the inability of the
operations staff to effectively utilize the Emergency Action Level (EAL) Event
Classification guides to properly escalate emergency classifications and make
appropriate Protective Action Recommendations (PARS) which would be, required
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in the event of-an emergency; and (2) failure to promptly correct deficiencies
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in the emergency preparedness program which were identified during previous
Nuclear-Quality Assurance (NQA) audits.
The.first violation was identified when NRC inspectors conducted walk-through
scenario drills, including postulated equipment failures and changes to key
plant parameters, so as to observe operator actions and ascertain the
effectiveness of operator training.
Five control room shifts (including each
Shift Superintendent who is the Interim Emergency Director during an emergency
until your emergency response organization is activated) were evaluated with
respect to their ability to:
(1) recognize initiating conditions requiring
entry into the emergency plan; (2) classify events utilizing the EALs; and
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(3) escalate emergency classification levels and make appropriate PARS. As
a result of these walk-through drills, the NRC determined that four out of
the five potential Emergency Directors tested were unable to adequately
escalate emergency classifications or make appropriate PARS during a fast
breaking severe accident. This indicates that the training provided to
these individuals was ineffective in assuring that the Interim Emergency
Directors will be able to properly assess initiating conditions and make
correct protective action recommendations.
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Although you implemented immediate corrective actions by conducting remedial
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emergency response training, the inability of the Interim Emergency Directors
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to properly classify events and make appropriate PARS at the time of the
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previous inspection represents a significant regulatory concern.
During a
fast breaking accident, these individuals would have the primary emergency
control responsibilities for classifying events and making the appropriate
recommendations to protect the public until your response organization is
fully activated. The NRC recognizes that your corrective actions have been
effective as verified during a special inspection conducted by the NRC from
July 17-20, 1989.
The second violation involved the failure to correct deficiencies in the
emergency preparedness program that were identified during a Nuclear Quality
Assurance (NQA) audit conducted in 1988.
Specifically, the audit, which
received extensive management distribution, identified significant staffing
and training problems as well as a lack of sufficient management and adminis-
trative controls over the emergency preparedness program to ensure the quality
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and readiness of the program.
Furthermore, the audit findings were consistent
with findings from NQA audits conducted in 1986 and 1987 for which the NRC
issued a Notice of Violation in February 1988 for failure to adequately
address similar identified deficiencies (IR 50-352/88-01).
Notwithstanding
these program weaknesses, these deficiencies continued to exist at the time
of the NRC inspection in May 1989.
The NRC is particularly concerned about the lack of aggressive management
action to correct these deficiencies that were identified during three
successive NQA audits.
Further, programmatic weaknesses in the emergency
preparedness area were identified during previous NRC inspections as well
as in the most recent SALP report. The NRC recognizes that prior to 1987,
the emergency preparedness program at Limerick has historically been good
as evidenced by two successive Category 1 SALP ratings.
However, the failure
to take prompt actions to correct these identified deficiencies has resulted
in a significant decrease in the effectiveness of the emergency preparedness
program, as evidenced by a SALP 2 rating during the last period compared
to prior SALP 1 ratings.
These weaknesses were clearly illustrated by the
first violation involving the inability of the Interim Emergency Directors
to properly classify events due to inadequate training.
The NRC recognizes that, subsequent to the May 1989 inspection, a detailed
root cause analysis was performed and thr.t you have increased management
oversight of this program and have made programmatic and organizational
changes, to ensure the adequate implementation of the emergency plan.
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Nonetheless, to emphasize the importance of maintaining increased and
improved management oversight and control of the emergency preparedness
program at both the corporate and site levels, I have been authorized,
after consultation with the Director, Office of Enforcement, and the Deputy
Executive Director for Nuclear Materials Safety, Safeguards and Operations
Support, to issue the enclosed Notice of Violation and Proposed Imposition
of Civil Penalty (Notice) in the amount of Seventy-Five Thousand Dollars
($75,000) for the violations described in the enclosed Notice.
In accord-
ance with the " General Statement cf Policy and Procedure for NRC Enforcement
Actions," 10 CFR Part 2, Appendix C, 53 Fed. Reg. 40019 (October 13,1988)
(Enforcement Policy), the violations described in the enclosed Notice have
been categorized in the aggregate as a Severity Level III problem to focus
on our underlying concern, namely, a lack of effective management oversight
and involvement in the emergency preparedness program.
The base civil penalty for a Severity Level III problem is $50,000.
The
escalation and mitigation factors set forth in the policy were considered
and the following adjustments to the base civil penalty were made:
(1) the
violations were identified by the NRC and therefore, escalation of the base
civil penalty amount by 50% is warranted; (2) once the problems were identi-
fied to senior management, your immediate short term corrective actions for
the violations, as set forth in your letter to the NRC dated May 26, 1989,
as well as the detailed root cause analysis and long term corrective action
plan presented at the conference, were considered prompt and extensive and
therefore, 50% mitigation of the penalty amount is warranted; (3) as discussed
earlier, prior notice of the violation involving failure to correct deficien-
cies was provided in three successive NQA audits as well as in NRC inspection
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findings, therefore, 50% escalation of the base civil penalty amount for this
factor is warranted.
Further escalation of the civil penalty was considered
for this factor, but was not taken due to your good overall performance in
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other functional areas. The other escalation and mitigation factors set
forth in the policy were considered and no further adjustment was considered
appropriate. Therefore, on balance, the base civil penalty amount has been
increased by 50%.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence. After reviewing your response to this
Notice, including your proposed corrective actions and the results of future
inspections, the NRC will determine whether further NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC Public Document Room.
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-The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Sincerely,.
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Original Signed By
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WILLIAM T. RUSSELL
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William T. Russell
Regional Administrator
Enclosure: Notice of Violation and Proposed
Imposition of Civil Penalty
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cc w/ encl:
J. S. Kemper, Sr., Senior Vice President - Nuclear Construction
G. M. Leitch, Vice President - Limerick Generating Station
S. J. Kowalski, Vice President - Nuclear Engineering
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D. R. Helwig, General Manager - Nuclear Services
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M. J. McCormick, Jr., Manager - Limerick Generating Station
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W. T. Ullrich, Manager - Limerick Unit 2 Startup
A. S. MacAinsh, Manager - Limerick Quality Division
G. A. Hunger, Jr. , Director - Licensing Section
T. B. Conner, Jr. , Esquire
E. J. Bradley, Esquire, Assistant General Counsel
H. D. Honan, Branch Head - Nuclear Engineering Licensing
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
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Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
Section Chief, DRP
Monte Conner (SALP Reports Only)
PA0 (2) SALP Reports Only
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