IR 05000114/2012011
| ML20215M944 | |
| Person / Time | |
|---|---|
| Site: | Crystal River, 05000114  |
| Issue date: | 10/23/1986 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Wilgus W FLORIDA POWER CORP. |
| Shared Package | |
| ML20215M945 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 EA-86-037, EA-86-37, NUDOCS 8611040005 | |
| Download: ML20215M944 (4) | |
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OCT 231986 Docket No. 50-302 License No. DPR-72 EA 86-37 gF1'da Power Corporation m TN: Mr. Walter S. Wilgus Vice President Nuclear Operations P. O. Box 14042, M.A.C. C-2-M St. Petersburg, FL 33733 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY AND NOTICE OF DEVIATION (NRC INSFECTION REPORT NOS. 50-302/85-01 AND 50-302/85-22; NRC INVESTIGATION REPORT NO. 2-85-004)
This refers to the inspections and investigation conducted during the period January 14, 1985 through December 11, 1985.
As a result of these inspections and investigation, several violations in the administration of licensed operator training and requalification training and in the documentation of this training were identified.
The results of requalification examinations admin-istered-to Crystal River licensed operators by the NRC on March 5, 1985, were consistent with the inspection findings to the extent that they indicated licensed operator requalification training had been ineffective and unsatisfac-tory.
Over 70 percent of the individuals administered the examination failed.
The results of the inspections and investigation were discussed on January 28, 1986, during an Enforcement Conference held in the NRC Region II Office with you and members of your staff.
The nature and number of deficiencies identified by the NRC indicate inadequate management control of, and attention to, the area of licensed operator training and retraining.
This lack of management control and attention was evidenced by deficiencies in the conduct and documentation of training and testing, the failure to implement commitments to the Commission, inaccuracies in the documentation of training on license applications, and the failure to adequately evaluate individual trainees' performance prior to licensing.
The inadequate management attention was further evidenced by Florida Power Corporation (FPC)
training supervision's apparent lack of awareness of applicable requirements and commitments as contained in Title 10 of the Code of Federal Regulations,.
NUREG 0737, the Final Safety Analysis Report (FSAP,), letters to the Commission, and FPC procedures.
Additionally, there appears to have been a widespread misconception that the conduct and documentation of reactor operator (RO) and senior reactor operator (SRO) training were not quality related activities, requiring attention to detail.
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Florida Power Corporation
OCT 2326 Violation A in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty addresses the reduction in scope and subsequent failure to implement the Licensed Operator Requalification Program.
Numerous procedural revisions within the Training Department led to the omission of requalification training' commitments, and the conduct of a requalification program unlike that contained in Amendments 35 and 4? of the FSAR which had been approved by the NRC.
The reductions in program scope were never submitted to the NRC for approval as required.
Of particular concern was an NRC requirement, as a condition of acceptance of the original requalification program, that licensed operators achieve a passing grade of 80 percent on requalification' lecture examinations or be provided with remedial training and re-examined.
This requirement was procedurally deleted and licensed personnel were allowed to fail multiple lecture examinations on safety related material with no corrective action or retest.
The negative impact of this failure to resolve training deficiencies as they were identified became more evident when 70 percent of the individuals taking the NRC requalification examinations in March 1985 failed.
Other examples of the failure to implement the approved requalification training program are also included in j
the Notice of Violation.
License renewal applications submitted during this period continued to certify that all requalification training had been
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successfully completed with no deficiencies listed.
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Additionally, Violation B addresses procedural deficiencies including failure to establish and implement adequate training procedures.
FPC had made several hundred commitments in the area of training.
Despite a computerized commitment
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j tracking system, FPC failed to establish and implement adequate controls over the revisions of Training Department procedures and programs.
Numerous procedural revisions resulted in the omission of many commitments to the NRC.
In addition, commitments made to resolve previously cited training violations were-negated by subsequent licensee actions.
Violation C addresses the failure to maintain adequate training records and to detect record deficiencies during
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QA training audits.
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To emphasize the need for FPC to maintain adequate management control over the training and retraining of licensed operators, and to assure that operator training is conducted according to commitments in the FSAR and approved programs, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Eighty Thousand Dollars ($80,000) for the violations described in the enclosed Notice.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986) (Enforcement Policy), the violations have been categorized as a Severity Level II problem.
The base civil penalty for a Severity Level II violation or problem is Eighty Thousand Dollars ($80,000).
The escalation and mitigation factors in the Enforcement Policy were considered, and no adjustment of the base civil penalty amount has been deemed appropriate.
As a result of the inspections and investigation, the staff also determined that a number of R0 and SR0 license and license renewal applications submitted between 1932 and 1984 contained inaccurate information.
The NRC requires extraordinary care be taken to assure information provided in R0 and SR0 license applications i
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Florida Power Corporation
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is complete and accurate.
FPC did not vigorously implement a program to accurately document the training given R0 and SR0 candidates, adequately
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verify the information prior to its submittal to the NRC, or provide for checking that training it had told the NRC would be completed by a specific date had in fact been completed by that date.
You are expected to take all actions necessary to ensure that in the future all communications with the
NRC'are complete and accurate in all significant respects.
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The inspection findings also indicate the failure to' implement commitments made regarding training requirements derived from NUREG 0737.
This matter is l
discussed in the enclosed Notice of Deviation.
You are required to respond to the enclosed Notices and you should follow the instructions specified therein 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 actions, the NRC will determine whether further NRC cnforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's " Rules of Piactice," Part 2,
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Title 10, Code of Federal Regulations, a copy of this letter and the enclosure will be placed in the NRC's Puolic Document Room.
The responses directed by this letter and accompanying Notice are not subject to the clearance procedurcs of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
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Should you have any questions concerning this letter, we will be glad to discuss them with.you.
Sincerely, l
(Original Signed by Roger D. Walker)
J. Nelson Grace Regional Administrator
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Enclosures:
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Notice of Violation and Proposed i
Imposition of Civil Penalty 2.
Notice of Deviation cc w/encls:
P. F. McKee, Nuclear Plant Manager R. Widdell, Manager
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Nuclear Operations Licensing
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and Fuel Management
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Florida Power Corporr:, ion
0CT 2 31986
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