ML20247K719
| ML20247K719 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/30/1998 |
| From: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Sullivan R AFFILIATION NOT ASSIGNED |
| References | |
| IA-98-17, NUDOCS 9805220190 | |
| Download: ML20247K719 (4) | |
Text
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UNITED STATES
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o#a 475 ALLENDALE ROAD KING oF PRUsslA, PENNSYLVANIA 19406-1415
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March 30, 1998 lA 98-17 Mr. Ray Sullivan HOME ADDRESS DELETED UNDER 2.790
SUBJECT:
Missed Tests and inaccurate Records
Dear Mr. Sullivan:
This letter is in reference to information provided to the NRC by PECO Energy which identified that records you prepared involving several local leak rate tests (LLRT) conducted at Peach Bottom were inaccurate. In one instance, during the performance of "ST/LLRT 20.07E.02:
LLRT "B" Containment Atmospheric Dilution (CAD) Analyzer Isolation Valves" test conducted around August 20,1996, you signed for the independent verification of the initial testing conditions for several valves, but did not enter the room to perform the verification. The second instance was during the performance of "ST-M-014-626-2: Core Spray Loop B Primary Coolant Pressure isolation Valves Leakage Test" conducted around September 18,1996,in which you signed for having completed a prerequisite step that verified a relief valve, set for 1100 psig, was installed on a pressure test rig; however, the relief valve had not been installed.
The NRC Office of Investigations discussed these issues with you on July 14,1997. In that discussion, you admitted that you did sign a document, which would lead a reader to believe that you had installed a relief valve on the LLRT test rig. You stated that you verified the valve to be located in a cabinet on the Unit 3 turbine deck, signed the document, and intended to pass on to the next shift that the valve needed to be installed. You also stated that you signed another document verifying that the calibration of a test gauge was current, when it was not.
Based on your testimony and the information provided by PECO Energy, we are concerned that you signed documentation to indicate that an activity was performed, when in fact, the activity was not performed. Such behavior is clearly unacceptable in the nuclear industry, is a violation of NRC requirements, and cannot be tolerated. NRC and its licensees must be able to rely on nuclear industry workers to properly perform the duties assigned to assure compliance with requirements, as well as to maintain complete and accurate records of these actions. However, given that the licensee has taken action against you (termination of employment) and after consideration of all the circumstances of this case, the NRC has decided not to take any further action on this matter.
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9805220190 980330 PDR ADOCK 05000171 3
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Mr. Ray Sullivan 2
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You should be aware that NRC regulations allow the issuance of civil sanctions directly against unlicensed persons who, through their deliberate misconduct, cause licensees to be in violation of NRC requirements. Deliberate Misconduct, as set ' orth in 10 CFR 50.5 (enclosed),
includes, an intentional act or omission that the person knows would cause a licensee to be in violation of any rule or regulation or other NRC requirement, or any term, condition, or limitation of the license. The deliberate misconduct rule also addresses the deliberate submission to the NRC or a licensee, of information that the person knows to be incornpfete or inaccurate in some respect material to the NRC. An Order may also be issued to an individual to prevent his or her engaging in licensed activities at all NRC licensed facilities. A violation of this regulation may also lead to criminal prosecution.
Should you be involved in nuclear activities in the future, we expect that you will properly carry out yo"r responsibilities in accordance with requirements of the Commission and assure that records you prepare are complete and accurate. Failure to meet the Commission's requirements in the future may result in enforcement action against you.
You are rAot required to respond to this letter. However, if you choose to provide a response, please provide it to me within 30 days of the date of this letter at U.S. Nuclear Regulatory Commission, Region 1,475 Allendale Road, King of Prussia, PA 19406.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, records or documents compiled for enforcement purposes are placed in the NRC Public Document Room (PDR). A copy of this letter with your address removed, and your response, if you choose to submit one, will be placed in the PDR 45 days after the date of this letter (unless you provide sufficient basis to withdraw this letter). At that time, a copy also will be provided to PECO Energy.
If you have any questions concerning this letter, please coritect Mr. James Lieberman at (301)415-2741.
Sincerely,
/
Hubert J. Miller Regional Administrator
Enclosure:
Deliberate Misconduct Rule
l DISTRIBUTION W/O Enci and W/Home Address Removed:
- Hold for 45 days and verify through the Director, Office of Enforcement, for placement in l
the PDR l
- PUBLIC l
SECY l
CA LCallan, EDO AThadani, DEDE JLieberman, OE HMiller, RI FDavis, OGC SCollins, NRR RZimmerman, NRR Enforcement Coordinators RI, Ril, Rlli, RIV BBeecher, GPA/PA GCaputo, 01 DBangart, OSP HBell, OlG TMartin, AEOD DScrenci, PAO-RI NSheehan, PAO-Ri OE:Chron OE:lA
- NUDOCS
- Nuclear Safety Information Center (NSIC) i 920
E ENCLOSURE PART 50 DOMESTIC UCENSING OF PRODUCTION AND UTluZATION FACluTIES
$ 80.5 Douberate adeconduct.
> (a) Any licensee, applicant for a license, employee of a licensee or applicant; or any contractor (including a supplier or consultant), subcontractor, employee of a contractor or subcontractor of anylicensee or applicant for a license,'who knowingly provides to any licensee, applicant, contractor, or subcontractor, any components, equipment, materials, or other goods or services that relate to a licensee's or applicant's activities in this part, may not:
(1)Engagein deliberate misconduct that causes or would have caused,if not detected, a liosases or op cent to be in violation of any rule, on,or order; or any term, tion, or g limitationof anylicenseissuedbythe
. r a-.nt ia=; or E
(2) Delibentely submit to the NRC, a g licensee, an applicant, or a licensee's or applicant's contractor or subcontractor, 16 formation that the person submitting the information knows to be incomplete or inaccurate in'some respect material to the NRC.
(b) A person who violates paragraph (a)(1) or (a)(2) of this section may be subject'to enforcement action in accordance with the proceduresin to CPR part 2.subpart B.
(a)(1) de misconduct by a person means an intentional act or omission that the person knows:
(1)Would cause alicensee or applicant to be h violation of any rule, regulation, or order; or any term, condition, or limitation, of any license issued by the Commission;or (2) Constitutes a violation of a requirement, procedure, instruction, contract, purchase order, or policy of a licensee, applicant, contractor, or subcontractor.
6 1
l l
504a (next pase is S7)
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