IR 05000416/1983045

Insp Rept 50-416/83-45 on 830815-19.Results Provide Bases for Multiple Violations Cited in Escalated Enforcement Action 84-23.Major Areas Inspected:Review of Training Records for NRC Licensed Operators

ML20128M473
Person / Time
Site:	Grand Gulf
Issue date:	06/03/1985
From:	Hehl C, Julian C, Verrelli D, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128M454	List: IR 05000416/1983045 ML20128M451
References
50-416-83-45, EA-84-023, EA-84-23, NUDOCS 8507110744
Download: ML20128M473 (5)

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p ;to UNITED STATES o NUCLEAR REGULATORY COMMISSION

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Report No.: 50-416/83-45 Licensee: Mississippi Power and Light Company Jackson, MS 39205 Docket No.: 50-416 License No.: NPF-13 Facility Name: Grand Gulf 1

Inspection Conducted: August 15-19,198/

Inspectors: O- 9 [/ N I

= C. A. JdMan Date Signed C %n &

C. W. Hehl Os/gs ~

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L. J. ats n U d /' 2 / 8 5 Date Signed Approved by: /l/' M7 b -

4 I D.M'.Vfrelli,BranchChief Datie Signed Divisiofi of Reactor Projects SUMMARY Scope: This special, announced inspection involved 18 inspector-hours onsite in the area of reviewing training records for NRC licensed operator Results: The results of this inspection along with those documented in the Office of Investigations Reports 2-83-037 and 2-84-005, and NRC Inspection Report 416/84-07, provide the bases for the multiple violations cited in Escalated Enforcement Action (EA) 84-23 which was transmitted to MP&L on June 3,198 l 8507110744 850605 PDR ADOCM 05000416 U PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• J. B. Richard, Senior Vice President, Nuclear

• J. P. McGaughy, Vice President, Nuclear

• C. K. McCoy, Plant Manager

• D. C. Hunt, Manager, Training Department Other licensee employees contacted included numerous corporate officials,

. engineers, operators, and office personne NRC Resident Inspector

• A. Wagner, Senior Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on August 19, 1983, with those persons indicated in paragraph 1 above. The licensee acknowledged his understanding of the inspection finding Since that exit interview, numerous meetings were held between NRC and MP&L on the inspection topic At each meeting, the NRC stressed the seriousness of these matter . Licensee Action on Previous Unresolved Items (Closed) Unresolved Item (416/83-38-11): This unresolved item has been escalated to a violation (EA 84-23-2) as discussed in paragraph 5. The previous item number is therefore administratively close (Closed) Unresolved Item (416/84-07-04): This unresolved item has been escalated to a violation ( EA 84-23-4). The previous item number is therefore administratively close . Unresolved Items Unresolved items were not identified during this inspectio . Training Documentation Deficiencies In January 1983, GGNS training department initiated several Plant Quality Deficiency Reports (PQDRs) identifying existing documentation deficiencies associated with the training records for several licensed operators and senior operator The apparent deficiencies and the existence of the associated PQDRs were documented during the February 1983 NRC Training Assessment as noted in Inspection Report 50-416/83-0 During that

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inspection, licensee representatives portrayed the matter to the NRC inspec-tors as a documentation problem. In that report, the documentation deficiencies were left as an unresolved item (416/83-06-01), pending com-pletion of the licensee's documentation search. Inspector followup on this unresolved item during the week of August 19, 1983, determined that the licensee's documentation search had been complete The licensee's documentation search determined that for PQDRs 5-83, 6-83, and 7-83, which identified deficiencies regarding training commitments made in the facility Final Safety Analysis Report (FSAR) and plant administrative procedure 01-S-04-1, all training identified as completed on the individual NRC license applications had not been accomplished. PQDR 5-83 indicated that the training records of one individual showed no completion date for a course entitled " Heat and Thermo Review" and that the training record of a second individual showed no completion date for courses entitled, "GG Tech",

" Plant Operation Casualty Response", " Operator Practices Training", and

" Simulator Refresher". All of these courses were to be completed prior to taking the NRC exam per MP&L Letter AECM-81/002. PQDR 5-83 also stated that training for other individuals on courses not listed on the license appli-cation, but part of the training program, had not been completed. PQDR 5-83 stated that the missing training could be satisfied by other training and nuclear navy trainin In the case of PQDR 6-83, all persons lacking training in diesel operation have subsequently been given that training. In the case of PQDR 7-83, which identified deficiencies in control room qualification card documentation, it was determined that this training had not been completed by eighteen licensed personnel. Although completion of the control room qualification card is not an NRC prelicense training requirement, it is a commitment in GGNS FSAR Section 13.2.1.1. Details of these deficiencies are provided in the following discussio Subsequent revier revealed the following. The licensee's letter AECM-81/002 submitted applications for 34 NRC license candidates. This letter stated,

" outlines of training courses conducted for personnel in the Licensed Operator Program are included in Enclosure (4). Each applicant will have completed this program through training or experience before the examina-tion". The license applications attached to AECM-81/002 listed the Cold License Operator Qualification Card as formal trainin A memorandum to file from the Training Superintendent, numbered IPC 83/1448, was discovered in the training files of several licensed operators. The memo referenced PQDR 7-83 and described an MP&L review of licensed operators' training records conducted to determine the extent of missing and/or incomplete qualification card documentation. The memo stated " review indicated that of 28 licensed personnel, only 10 qualification cards were documented in the training records". The letter also stated " completion of the qual cards was inadvertently left off the checklist used by the training staff to check that all training requirements have been met prior to

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submitting license exam applications to the NRC". The memo concluded: the first 1wo cold license classes should be exempt from the qual card since no i n.ensed individuals were available to sign off the cards; and the remaining operators in question had completed NRC exams and had been . license Eighteen individuals were listed as exempt from the qual card completion. All of these individuals had current NRC license After discussing this matter with Region II management in a meeting on October 12, 1983, MP&L conducted a thorough audit of the training records, including a completely independent audit by Quality Assurance. The results

= of that audit are documented in MP&L's letter AECM-83/0681 to Region I The nature of the discrepancies were as follows:

Several formal training courses were not as long as was stated on the original application. There was no evidence that material was deleted from these courses, so presumably all the subject items were addresse Several applications listed training courses taken for which no record could be foun In all such cases, the item was resolved by retesting the individual, conducting additional training, or by demonstrating that equivalent training had been given in the past for which adequate records exis For the majority of licensed personnel, qualification cards were not done or were only partially completed. There was apparently a widely held under-standing among plant personnel that the original " cold license" operators did not have to have qual cards. The FSAR, however, clearly states it as a commitment for all license applicant In January 1983, by initiation of these PQDRs, the licensee placed, in written form, the fact the operator license examination applications were

! not totally correct and that not all training was conducted for the applicants. These documents were reviewed by plant management. In February 1983, the NRC became aware of these discrepancies, but the matter was portrayed as a missing records problem. In August, during followup on

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this unresolved item, the NRC inspectors were informed that the item involved more than missing records and that required training was not conducte Between February and August, the licensee took no action to inform the NRC of the recognition of incomplete training and took no action to correct the erroneous submittals made earlier. The placing of the memo in the training files was apparently the only action taken to correct the record The licensee's corrective action, initiated in response to these PQDRs, included the establishment of a checklist as a part of the implementing

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procedure for licensed operator trainin This checklist specifies all I

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required training and provides means of documenting proper reviews and evaluations prior to submitting license application CFR 55.10(a)(6) states that license applications must contain " details on courses of instruction administered by the facility licensee, number of course hours, number of hours of training, and nature of training received at the facility". 10 CFR 55.10(d) states that "each application and state- i ment shall contain complete and accurate disclosure as to all matters and things required to be disclosed". This review indicates that the licensee did not assure complete and accurate disclosure of a portion of the training progra In addition, had this deficiency been disclosed, the NRC would have required that the additional training be completed prior to examination. As reported in Inspection Report 416/82-45, "NRC Systematic Assessment of Licensee Performance", a total of 36 candidates were examined for reactor operator (RO) and senior reactor operator (SRO) licenses during the period of July 1, 1981 through August 30, 1982. The passing rate for the first attempt was 55% for SR0 candidates, and 38% for RO candidate Eleven candidates were retested with a passing rate of 83% for SR0s and 100% for R0s. This failure rate indicates that additional training was necessary for a significant portion of the candidate This review indicated that the licensee made multiple Material False Statements on the subject license applications. Furthermore, when the licensee became aware of these matters, action was not taken to identify and correct the false information, nor to notify the NR Enforcement action was directed to MP&L in Mr. James M. Taylor's letter of June 3, 1985

.(EA 84-23).

From November 1983 through February 1984, the licensee conducted a formal Licensed Operator Recertification Program to examine operators, conduct additional training, and certify their competence. The NRC subsequently reexamined all operators and allowed only those who passed to return to duty.