IR 05000255/1990035
| ML18057A668 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 12/12/1990 |
| From: | Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057A663 | List: |
| References | |
| 50-255-90-35, NUDOCS 9012270141 | |
| Download: ML18057A668 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/90035(DRSS)
Docket No. 50-255 Licensee:
Consumers Power Company 1945 West Parnall Road Jackson, MI 49201 License No. DPR-20 Meeting Location:
NRC Region III Office, Glen Ellyn, Illinois Meeting Conducted:
November 15, 1990 Type of Meeting:
Enforcement Conference Approved By:
Lt)~ 't;,__,Qj)
William Snell, Chief Radiological Controls and Emergency Preparedness Section Meeting Summary Meeting on November 15, 1990 (Report No. 50-255/90035(DRSS))
12../iz...bo Date Areas Discussed:
An enforcement conference was conducted to discuss the licensee 1 s apparent willful failure to observe high radiation access control requirements, falsification of chemistry quality control sample records, apparent breakdowns in General Employee Training program implementation and failure to maintain accurate training and qualification record Results:
One Severity Level IV violation was identified for a failure to meet technical specifications requirements for high radiation area access contro Two violations, failure to obtain waivers for training as required by plant procedures and failure to maintain accurate records of training and qualification, met the criteria for exercise of discretion of Section V. of Appendix C to Part 2; therefore, Notices of Violation were not issue Based upon additional information provided at the enforcement conference, it was determined that the fourth apparent violation, failure to provide indoctrination and training to contract instructors, had not occurred.
9012270141 901213 PDR ADOCK 05000255 Q
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DETAILS Meeting Attendees Consumers Power Company J. Bacon, Assistant General Counsel F. Buckman, President and C~ief Operating Officer K. Haas, Radiological Services Manager J. Hanson, Operations Superintendent D. Hice, Chemistry Superintendent D. Hoffman, Vice President NOD D. Joo*s, Vice President ESS J. Kuemin, Licensing Administrator H. Robichaud, Vice President Human Resources D. Rogers, Training Administrator G. Slade, Plant Beneral Manager D. VandeWalle, Safety and Licensing Director Others D. Eldridge, Private Citizen Nuclear Regulatory Commission W. Axelson, Deputy Director, Division of Radiation Safety and Safeguards B. Berson, Regional Counsel
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B. Clayton, Chief, Reactor Projects Branch 2 L. Greger, Chief, Reactor Programs Branch J. Heller, Senior Resident Inspector, Palisades B. Holiman, Project Manager, NRR J. House, Radiation.Specialist B. Jorgensen, Acting Chief, Projects Section 2A P. Lougheed, Enforcement Coordinator A. Markley, Radiation Specialist C. Paperiello, Deputy Regional Administrator R. Pedersen, Enforcement Specialist, OE C. Pederson, Director, Enforcement and Investigation R. Rosano, Senior Enforcement Specialist, OE M. Schumacher, Chief, Radiological Controls and Chemistry Section Sn~ll, Chief, Radiological Controls and Emergency Preparedness Section Enforcement Conference Details As a result of apparent violations of NRC regulatory requirements, an enforcement conference was held-in the NRC Region III Office on November 15, 199 The preliminary findings, which were the bases for the apparent violations, were documented in Inspection Reports No /90019(DRSS) (dated October 5, 1990), 50-255/90028(DRSS) (dated November 9~ 1990) and 50-255/90030(DRSS) (dated November 9, 1990).. The attendees at this enforcement conference are listed in Section 1 abov *
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i The NRC Region III staff surranarized the inspection findings, apparent violations of regulatory requirements, and other regulatory and management concern The specific issues discussed by the Region III staff included the following: Falsification of quality assurance* sample analyses results by a chemistry technician for sample analyses that he had not performe Failure to comply with technical specification requirements for high radiation area access control c. * Failure to provide the practical factor portion of General Employee Training (GET) for personnel authorized access to the radiological controlled area (RCA). Failure to mairitairi accurate records for the practical factbr portion of GET and prequalification examination result * Inadequate evaluation of inatcurate training record Failure to provide adequate indoctrination arid training to contract
- training instructor *
The NRC Region III staff presented several generic concerns that resulted from collective consideration of the aforementioned specific issue These included concerns regarding the reasonable reliance by the NRC upon the integrity of records maintained by the licensee and reliance by the*
NRC upon licensee personnel to perform required task The primary reason for the enforcement conference was to obtain additional information from the licensee regarding the apparent violations in order to determine if regulatory violatfons had occur.red and to assess the safety significance of the incident a.*
Falsification of Chemistry QA Sample Results Regarding the falsification of chemistry quality assurance sample results, the licensee presented a description of the laboratory quality assurance program, the sequence of events, corrective actions taken, and the root causes of the falsification of sample result The licensee's presentation did not deviate significantly from the incident description discussed in Inspection Report N /90030(DRSS).
The licensee also presented information that the event was licensee identified, that this was an isolated incident and that no nuclear safety significance existed; that this was a split sample program onl *
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. Failure to Comply With High Radiation Access Controls Concerning the failure to comply with technical specification requirements for high radiation area access controls, the licensee presented a sequence of events, immediate actions taken by the licensee, corrective actions.taken, and the root cause of the even The licensee's presentation did not deviate significantly
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from the incident description discussed in Inspection Report
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No. 50-255/90019(DRSS).
The licensee's immediate actions included removal of the individuals from the RCA and convening a Management Review Boar The licensee's corrective actions included:
(1) Counseling of the auxiliary operator per the corporate disciplinary action polic *
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(2)
Plating a letter i~ the personnel file of the pl~nt sup~ort supervisor that emphasized the seriousness of the event and the potential for dismissal if further violations occu (3)
Discussion of the event with operations department personne (4)
Revised the drum fill processing sheet to require notification of health physics prior t~ processin The licensee identified the root cause of the event as a disregard of administrative requirements for* expediency of wor The licensee also presented information that this event was licensee identified
- and that there was little potential for overexposure due. to knowledge of radiation levels in the are Apparent Training P~ogram Violations Regarding the apparent violations in the training program, the licensee presented the organization charts for both the plant *
training program and the Steam Generator Replacement Project (SGRP) staff, a sequence of events, root causes, corrective actions, and an evaluation of the safety significanc The licensee also presented subject matter summaries for contract. radiation safety technician training, GET, and SGRP contract radiation* safety technician training~ Failure to Pr'ovi de Practical Factor. GET With respect to the failure to provide the practical factors portion of GET for personnel who were authorized ~ccess to the RCA, the licensee identified the root cause as an instructor who inappropriately 11waived 11 technicians from the dress out requirements. This failure was presumably based on the assumption that th_e technicians could satisfactorily perform the practical factors and testing was not required~ The licensee's corrective actions to prevent recurrence included reviewing the incident with both contract and Palisades instructors, emphasizing the consequences of records falsificatio The licensee presented information that the event had no impact on plant safety and no adverse radiological consequence The licensee indicated that all technicians involved had previous experience in donning and removing protective clothing and that most other -
facilities would waive these personnel from dress out requirement Second, each technician was required to don and remove protective clothing as part of the On-the-Job (OJT) training program and that each technician had successfully ~ompleted dress out. The licensee also presented the following mitigating factors:
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(1)
Consumers Power Company identified the problem and promptly reported the event to the Resident Inspecto (2)
The event was promptly investigated and qualifications revoked-despite the impact upon the outage preparation (3)
The event was. not one that could easily be prevented nor was it indicative of a breakdown in manag-emen (4)
The initial selection process for the contract instructor included a review of performance at other utilities *. _ The instructor's performance prior to this event ~as excellen Failure to M~intain Accurate Records Concerning the failure to maintain accurate records for the practical factor portion of GET and for prequalification examination results, the licensee identified the root causes of the event as
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follows:
(1)
The instructor inappropriately "waived" technicians from the dress out requirements.
. (2)
The cause for inaccurate prequalification examinations was that the completed answer sheets were altere (3)
Four factors that contributed to the grading errors were an
_oversized gradin~ template; an exam question sequence, that was offset by only one or two questions, may have a 11 owed the wrong template to be used; poor quality grading templates; and inattention to detail by the instructo The licensee indicated that the following corrective actions would be taken to prevent recurrence. First, the Nuclear Training Department has been charged with overseeing training record *
preparation and prcicessing, testing protocol, exam gradirig and exam security for contract Radiological Services Technicians~ Second, the SGRP Quality Assurance has completed a follow-up surveillance to ensure the corrective action for the grading errors was adequate~
The licensee indicated that the final class packages and training records were reviewed and found to be satisfactor The licensee present~d information that this had no impact on plant safety and no adverse radiological consequence The licensee indicated that all technicians had satisfactorily completed OJT, thereby demonstrating their competence on the job. Subsequent reviews of the technicians' work did not identify any performance deficiencies and that all technicians who had failed the qualification exam had passed the retest~* The licensee presented the following mitigating factors:
(1)
Consumers Power identified the problem and promptly reported it to the Resident Inspecto.. J t
(2)
The event was promptly investigated and the technicians qualifications were revoke (3)
The violation was corrected by tutoring and retesting all technicians failing the qualification exa (4). The Radiological Safety Technician qualification process includes both classroom and OJ All technicians failing the
. qualification exams satisfactorily completed OJ (5)
Reviews have been performed of the affected technicians' work with no problems identifie *
(6) All other work performed by the. instructor has been. verified with no additional inditation of problems... Inadequate Evaluation of Records Falsification Regarding the inadequate evaluation of the falsification of records by a contract training instructor, the licensee presented the following information:
(1)
The failure to conduct practical factors training and the subsequent falsification of training records are not directly related to the alteration of exams.
(2)
The initial investigation reviewed all GET records for the potential falsification and found no evidence other than the verbal *statements of the technician (3)
The same technicians did not identify any wrongdoing regarding written examinati.ons in the GET program or Technician trat~ing progra (4).At the ti~e of the investigation, none of the exam alterations had taken plac (5)
Responsiveness to the records falsif1cation was noted as a strength in the inspection report of October 5, 199 Failure to Provide Adequate* Indoctrination and Training to Instructors Concerning the failure to provide adequate indoctrination and training to contract instructors, the licensee indicated that the events were not a result of the instructor's lack of knowledge or lack of p~ocedural guidance; rather, the eve~t was a result of an instructor who made a decision to violate procedural requirements.
. The licens~e indicated that the instructor knew that authority to grant waivers was not the instructor's and that management would not approve any waivers of dress out requirement The licensee presented the following information regarding the training and indoctrination of contract instructors:
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(1)
(2)
(3)
(4)
(5)
The certification process for instructors requires that they first complete the class as a student or sit through and observe the clas The instructor must then perform an internship with a cert1fied instructor or conduct a performance demonstration with a supervisor or a certified instructo Instructors are given current copies of the lesson materials and shown how to process the class record Each of the forms they must complete have directions included with the form such that referral to the procedures is not require Other areas of the procedures are not covered-since they apply to the development of programs and lesson plans, training evaluation, procedure dev~lopment, and student transcript Discussion with Former Instructor During the enforcement conference, the former instructor was in attendance and was questioned on several occasion The former instructor acknowledged that the technicians had not received the practical factors portio~ of GET and that the instructor h~d signed the records indicating that this training had been give However, the former instructor stated that these forms had been signed in
- order to 11wa i ve" the students from performance of dress ou The instructor indicated that there was no attem~t or ~ntent to deliberately not perform a required tas The former instructor acknowledged being co.nfronted by the licensee regarding the
.requirements to perform practical factor training. The fonner instructor stated she had lied to the licensee indicating a knowledge of the requirements to perform practical factor.trainin This item was new information to the licensee and to the NRC Region III staf Generic Concerns Regarding the generic concerns presented by the NRC Region III management, the licensee's presiding official addressed these in his surrmary statement The licensee stated that Consumers Power Company was concerned about the recent failures discussed in this enforcement conferenc The licensee indicated that the presence of Consumers Power Company management was indicative of the level of concern fel The licensee indicated that there would be no toleration for willful violations nor record falsifications by contractor or licensee personnel. The licensee also indicated that these events were licensee identified and that.actions taken by the licensee would preclude recurrence of these event The licensee requested that the NRC exercise care in determining appropriate action with respect to the individuals involved in these violation The licensee indicated that the former instructor probably panicke *.. --'::""r7*
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when confronted by the licensee and made serious error~ in judgement *
With respect to the licensee 1 s chemistry technician and operations personnel, -the licensee stated that their disciplinary system had dealt effectively with the individuals involve Enforcement Actions One of the four apparent violatio~s that was identified during the inspections has subsequently been determined to b~ a violation for which a Notice of Violqtion is being issued. This involves the failure to meet technical specification requirements regarding high radiation area entry contro One apparent violation, failure to maintain accurate records of training and qualification, met the criteria -for-the exercise of discretion of Section V.G.1 of Appendi~ C to 10 CFR Part 2; therefore,
-a Notice of Violation will not be issued for that violatio One apparent violation, failure to provide general employee training to workers who were subsequently authorized access to the radiologically controlled area, was reviewed for appropriateness based on additional information that was provided at the enforcement conference. This apparent violation is now characterized as a failure to obtain waivers of training as required by plant procedures.-
Since the criteria for the exercise of discretion of Section V.G.1 of Appendix C to 10 CFR Part 2 were met, a _Notice of Viol~tion will not be issued for this violatio The fourth apparent violation, failure to provide indoctrination and training to contract irist~uctors, was reevaluate Based on the additional information provided at the enforcement conference regarding the nature of the training program for the contract instructors, it was determined that a violation had not occurre *
No violations were identified regarding the apparent falsification of proficiency testing records by a chemistry technician.
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