ML11292A039
| ML11292A039 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/17/2011 |
| From: | Kristin Davis - No Known Affiliation |
| To: | NRC/OE |
| Gulla G | |
| References | |
| IA-09-014 | |
| Download: ML11292A039 (4) | |
Text
October 17, 201 I Director, Offic(' of Enforcement U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 RE: Keith W. Davis Docket :-.Jo.t......
License No.*S**** (termin<lted)
IA-09-014 On April 1, 2009 1 \\yas issued an Order Prohibiting Involvement in NRC-Licensed Activities.
I am requesting the Director, Office of Enforcement to reJax and/or rescind the conditions of the confirmatory order based upon demonstration of good cause.
- 1) Jnformation regarding the reasons fen: prior vio1ations of NRC.Jequirements!
A. 1 failed to report an arrest on June 19,2006 as required by Susquehanna Steam Electric Station procedures and the terms and conditions of mv SRO license. I violated NRC requirements by 'willfully failing to report my arrest to SSES management.
- 1. The facts of the originating event are detailed in the NRC 01 investigation.
- 2. I failed to apply the same standards and reasoning to this event that I applied to reactor operational issues and t'vents. I allowed myself to rely on the specific wording and failed to realize or understand the intent.l failed to apply the requirements intelligently and conservatively',
- 3. 1 focust'd on not highlighting the event instead of ensuring compliance by bringing it to light and discussing with the management team to enable other's opinions and thoughts.
- 4. I eroded public confidence in nuclear po\\*ver, tht' NRC, and SSES by operating in the control room, under my SRO license, while unresolved issues about my trustworthiness existed.
B. 1 failed to respond to the Confirmatory Order issued November 26, 2007.
- 1. It was my belief when attending the ADR meeting, that, when 1 described the events in person, the NRC would agree no violation existed. I was surprised to learn at the ADR meeting that that,vas not a possible outcome. At the ADR meeting, it,vas explained to me the purpose was for me to offer actions the NRC would find acceptable as an option to enforcement. I was unprepared and left scrambling to come up with actions.
- 2. I agreed to p~~rform the actions as described in the Confirmatory Order. I agreed to the issuancE' of a level III violation. ] signed a \\-",'aiver of my right to request a hearing.
- 3. I attempted to write the required documents agreed to dt the ADR se\\'eral times. I was unable to produce desired results, 1 belie\\'(=' mainly because 1did not yet understand tht.'
lessons il'arned, because I was in denial.
C. I failed to notify the NRC in writing explaining my position and reasons for not complying with the Confirmatory Order.
- 1. I was of the opinion that because I no longer held a SRO Licen::.e and no longer worked in the nuclear industry that I was no longer subject to the jurisdiction of the commission.
10CFR2,.202(a) states "The Commissilm may institute a proceeding to modify, suspend, or revo,ke a license or to take such other action as may be proper by serving on the licensee or other person subject to the jurisdiction of the Commission.."
- 2. On October 2008, during my discussions with NRC 01 I \\-vas requested to call the ~'RC RI senior enforcement specialist, which I did that same day. The NRC Rl senior enforcement specialist advised me to send a letter to NRC RI regional administrator explaining my position. These discussions did not change my opinion at that time. I could not see any purpose or requirement in performing this t;uggested action.
- 2) Actions taken to prevent recurrence of the viQ~tions.
A, Understand the consequences.
I) I worked in nuclear p<l\\\\'er for 26 years. I was adept at applying the NRC regut;)tions for Commercia.l :;\\l'udear Puwer Plant Operations efficiently and correctly. I was very good at operating nuclear power plants and was respected by those who knew me.
- 2) 1 have been barred from nuclear power, realistically, since July 2(J06 \\\\'I1('n my security clearance was revoked. 1have suffered personally, professionally, and financially.l was unemployed for 21 months prior to being banned from the nuclear industry for an add itional 3 years.
- 3) Professional outcast. I have approached various people for support and have bp.cn denied based on a fear of reprisal either directly or indirectly, and the impact that vvould have on them professionally and financially.
- 4) It is entirely possible that even if the NRC agrees to relax and/or rescind the conditions of the conJirmatory order I may never have the opportunity to \\-vork in nuclear power again.
B. Actions related to the root event, the nUl.
- 1) Counseling, driver license suspension, probation, community st~n'ice, high risk car insu rance, fines and costs are the actions to prevent recurrence done ei ther by me or required of me by others.
- 2) The fact that this singular event: over 5 years ago, has not been repeated is a testanwnt to the success of these actions.
C. Actions to Prevent Recurrence I) Having grown up in nuclear power plant operations for 26 years, when confronted with
.J hum.Jn performance short coming one rC'.Jches for their human performance tools to prt'vent recurrence, however, this event is not a matter of turning the wrong s\\,dtch or reading the wrong gauge or failing to communicate or understand a direction. This event involves a ~nior Reactor Operator failing to uphold the public confidence in nuclear power because he failed to follcnv the l'\\RC regulations, as dli:fined by Susquehanna Steam Electric plant's procedures, My failure was thinking these events are not similar, I treated my event different than a plant operational event. 1failed to have a peer check an indt'pendent verification, fuiled to intelligently apply the procedure direction, failed to involve my supervision and management for problem sO];,'ing and decision making; and most important, 1 failed to understand the hazards and repercussions of my actions or inactions.. This event was not intentional on my part, but it was willfuL I knew better, I had alarms going off in my head I chose to ignore, I had all the indications but failed to take the appropriate action.
- 2) r commit to utilizing the human performance tools and approach personal issues as r would plant issues. r"vill apply the same conservative decision making skiJls I utilize in dealing with plant issues to my own issues. 1 will not ever compromise public safety nor mitigate public trust in nuclear power by my actions.
- 3) My ability and willingness to carry out the2P~ecial trust and confidencehLthe NRC plM~d it!
m~ as a Hcensed Qp~rator.
A. I was an electrician doing start up and test, a non licensed nuclear plant operator; a reilctor operator and finally a Senior Reactor Operator. I understand the impact of not being open and honest in communicating issues or events which may be issues. I \\vill not only comply with the rules and regulations but will continually strive to understand, and remain cognizant, of the intent of those rules and regulations,
- 4) My ability,",!!td wi1Jingl1ess~ toabide by all fitness-for~duty and other license requiI~Illen~
and conditions.
A. J have always had a profound respect for the regulations involved around the opemtion of a commercial nuclear power plant. rmade a significant error in judgment, interpretation and application and I have learned. I wiH conduct myself in a manner that nuclear power operation deserves. I will always be aware of the consequences when actions are not in the best interest of the public safety and confidence in nuclear power.
A. I would like to publically thank the NH.C This event has changed my life. Prior to this event I defined myself by my abilities. My divorce, the DDt being stripped of my security clearance, SRO license termination, termination of employment and finally prohibition from working in the nuclear industry forced me to re-evaluate my life. I made significant errors, suffered significant penalties, but learned significant lessons. Now I define myself by my actions and realize my abilities are the product of god given gifts focused and directed by myself and others. What I do with those gifts is what defines me now. 1 realize now how
\\vrong I was and my life as a whole has changed for the better.
Sincerely Keith W. Davis