PLA-7838, Reply to Notice of Violation: EA-19-050 (PLA-7838)

Reply to Notice of Violation: EA-19-050 (PLA-7838)

ML20035G116
Person / Time
Site:	Susquehanna
Issue date:	02/04/2020
From:	Cimorelli K Susquehanna, Talen Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-19-050, PLA-7838
Download: ML20035G116 (4)

Text

Kevin Cimorelli Susquehanna Nuclear, LLC Site Vice President 769 Salem Boulevard Berwick, PA 18603 TALEN~

ENERGY Tel. 570.542.3795 Fax 570.542.1504 Kevin.Cimorelli@TalenEnergy.com FEB 0 4 2020 U.S. Nuclear Regulatory Commission 10 CFR2.201 ATTN: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION REPLY TO NOTICE OF VIOLATION: EA-19-050 Docl\:et No. 50-387 PLA-7838 50-388

Reference:

I. NRC Letter, DanielS. Collins (NRC) to Brad Berryman (Susquehanna), Susquehanna Steam Electric Station -NRC Investigation Report No. 1-2018-011 and Notice of Violation, dated Janumy 7, 2020 (ADAMS Accession No. ML20007D652).

In Reference 1, the Nuclear Regulatory Commission (NRC) issued Notice of Violation (NOV) EA-19-050, which requires a reply from Susquehanna Nuclear, LLC (Susquehanna).

The Enclosure to this letter contains Susquehanna's response.

This letter contains no new regulatory commitments.

Should you have any questions regarding this submittal, please contact Ms. Me lisa Krick, Manager- Nuclear Regulatory Affairs, at (570) 542-1818.

Enclosure:

Reply to Notice of Violation: EA-19-050 Copy: Regional Administrator, Region I Ms. S. Goetz, NRC Project Manager Ms. L. H. Micewski, NRC Sr. Resident Inspector Mr. M. Shields, PA DEP/BRP

Enclosure to PLA-7838 Reply to Notice of Violation: EA-19-050

Enclosure to PLA-783 8 Reply to NOV: EA-19-050 The following is Susquehanna's reply to NOV EA-19-050:

Description/Timeline of the Issue:

The violation involved a contract individual who worked at Susquehanna Steam Electric Station (SSES) and provided inaccurate information about past and current substance abuse on applications for unescorted access authorization. The following is a timeline of key events related to the NOV.

Time Activity January 14, 2017 The individual returned an electronic personal history questionnaire (EPHQ) indicating no past or current substance abuse issues.

January 24,2017 The individual was granted unescorted access to SSES for outage activities.

January 31,2018 The individual returned an EPHQ indicating no past or current substance abuse Issues.

February 5, 2018 The individual was granted unescorted access toSSES for outage activities.

April19, 2018 Based on various information obtained and events that occurred, the individual was interviewed by Site Access and Corporate Security personnel.

During the interview, the individual admitted to having abused prescription medications without a prescription. The falsification of the EPHQ was implicit in this confession.

The individual's plant access was administratively withdrawn while the investigation continued.

May 15,2018 The individual's access at SSES was terminated and a Personnel Access Data System (PADS) entry was made indicating that the individual had been denied access at S SES.

January 7, 2020 NOV EA-19-050 was received from the NRC.

January 14, 2020 NOV EA-19-050, the associated Susquehanna condition report, and a note regarding the individual's falsification of information was included in the individual's Susquehanna access file.

Reason for the Violation:

A contract individual provided inaccurate information that was material to the NRC about past and current substance abuse on applications for unescorted access authorization, thereby creating a false record that was used by Susquehanna to grant unescorted access toSSES.

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Enclosure to PLA-7838 Reply to NOV: EA-19-050 Corrective Steps Taken and Results Achieved:

The individual's unescorted access was terminated and a PADS entry on the terminated access was made on May 15, 2018. Additional information was added to the individual's access file on January 14, 2020. These actions restored full compliance.

Enhancement actions taken to deter similar behaviors included, but are not limited to, the following:

1. An article entitled "Act with integrity, comply with procedures and regulations: Willful Misconduct/Records Falsification and Nuclear Safety Culture" was published in the Daily Leadership Alignment Package (DLAP). The DLAP is used to communicate messages to individuals and departments to encourage station alignment. This article described the significant consequences associated with willful misconduct, both for the plant and for the individual involved in wrongdoing.

2. A second article entitled "Willful Misconduct/Record Falsification Series for SSES: What Does Your Signature Mean? was published in the DLAP describing that an individual's signature on a document means the individual is endorsing the document as correct and complete.

Corrective Steps that Will Be Taken:

No additional corrective actions are required.

As an enhancement action, Susquehanna plans to issue a DLAP article on willful misconduct, using the circumstances of this NOV as an example, prior to the upcoming refueling outage.

Date When Full Compliance Will Be Achieved:

Full compliance has been achieved.

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