ML17055E592
| ML17055E592 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/17/1989 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Burkhardt L NIAGARA MOHAWK POWER CORP. |
| References | |
| NUDOCS 8903290125 | |
| Download: ML17055E592 (20) | |
See also: IR 05000220/1988010
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION
NBR: 8903290125
DOC. DATE: 89/03/17
NOTARIZED:
NO
FACIL': 50-220 Nine Mile Point Nuclear Stationi Unit ii Niagara
Poee
AUTH. NAME
AUTHOR AFFILIATION
ARTINt T. T.
Region
1
Ofc of the Director
REC IP. NAME
RECIPIENT AFFILIATION
BURKHARDTiL.
Niagara
Mohawk Power Corp.
SUBJECT:
Forwards
synopsis
of Ofc of Investigations
Case
1-88-003 re
investigation
conducted
on 880411-0817
concerning
Insp Rept
50-220/88-10. Enforcement
conference
scheduled
on 890330'er
890310 telcon.
DISTRIBUTION CODE:
IE01D
COPIES
RECEIVED: LTR
ENCL
SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES:
DOCKET 0
05000220
REC IP IENT
ID CODE/NAME
PDi-1
INTERNAL:
AEOD/DEIIB
SHANKMANe S
NRR/DLPG/PEB
11
NRR/DOEA DIR
11
NRR/DREP/RPB
10
NRR/PMAS/ ILRB12
OE '~BE
MANz J
REG FILE
02
EXTERNAL:
LPDR
COPIES
LTTR ENCL
1
1
2
2
1
1
1
1
1
1
1
1
2
2
1
1
1
1
1
1
1
1
1
1
RECIPIENT
lD CODE/NAME
SLOSSONu
M
DEDRO
NRR/DEBT DIR
NRR/DLPG/GAB 10
NRR/DREP/EPB
10
NRR/DRIS DIR 9A
NUDOCS-ABSTRACT
OGC/HDS1
RGN1
FILE
Ol
NRC
COPIES
LTTR ENCL
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
25
ENCL
25
jt
~gS +ECy(
~o
e
0
Cy
+0
++*<<>>
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALEROAD
KING OF PRUSSIA, PENNSYLVANIA19406
.48 i 7 tggg
Docket No. 50-220
Niagara
Mohawk Power Corporation
ATTN:
Mr. Lawrence Burkhardt, III
Executive Yice President
Nuclear Operations
301 Plainfield Road
Syracuse,
Hew York
13212
Gentlemen:
Subject:
REGION I INSPECTION NO. 50-220/88-10
AND
OFFICE
OF INVESTIGATION (OI)
CASE
NO. 1-88-003
In response
to the subject inspection of your licensed operator requalification
program,
the
NRC's
Office of Investigation
(OI)
conducted
an
investigation
between April 11 and August 17,
1988
(Case
No. 1-88-003).
We have attached
the
synopsis
of that
OI report to this letter for your review.
As a result of our
review of these reports,
we have concluded that
an enforcement
conference
with
you in conjunction with the involved licensed operators
is wat ranted.
Our concerns
are threefold:
(1) apparent failure of 39 licensed
operators
to
fully participate
in the
NRC"required requalification
progr'am,
(2)
apparent'ailure
on the part of
13 of those
39 operators
and
two levels of facility
management
to
identify inaccurate
statements
on
the
NRC
required
license
renewal
applications
(HRC Form 398)
submitted for the subject
period and,
(3)
apparent
failure
on
the
part
of facility management
to identify
and
take
effective corrective
action
on the
program
shortcomings
that permitted
items
(1)
and
(2) to occur.
Although the
OI report concluded that the submittals of
the
inaccurate
NRC
Form
398s
were
not willful, we believe that
a significant
breakdown
occurred
in
the
management
oversight
of your
licensed
operator
requalification program.
As discussed
in
a
March 10,
1989,
telephone
conversation
between
you
and
Mr.
Rober t Gallo of my staff,
we plan to conduct
an enforcement
conference
at the
site
on
March 30,
1989.
In that telephone
conversation,
you also
agreed
to
have the
13 involved licensed operators
attend the conference.
At the enforcement
conference,
you,
and the involved licensed operators,
should
be prepared
to discuss
(1) the
NRC staff findings and the safety significance
of the abeve
noted failures,
(2) the specific and underlying causes
and (3) the
actions
taken
or planned
to correct
these.
problems
and the results
achieved.
OFFICIAL RECORD
COPY
<gvl
gqgza.9o
C>S
xR
fi
'Niagara
Mohawk Power Corporation
Thank you for your attention to this matter.
Sincerely,
Original Signs:!
~",".
ThQiHc".8 T.
Vla'"'- 0
Thomas
T. Hartin, Director
Division of Reactor Safety
Enclosure:
Office of Investigation
Case
No. 1-88-003 Synopsis
cc w/encl:
C.
V. Mangan, Senior Vice President
D. Palmer, Acting Manager, Quality Assurance
W. Hansen,
Manager,
Corporate Quality Assurance
R.
G. Smith, Unit 2 Superintendent,
Operations
C.
Beckham,
Manager,
Nuclear Quality Assurance
Operations
R.
B. Abbott, Unit 2,.Station
Superintendent
J. Perry, Director, Nine Mile Point Unit
1 Restart
Task Force
K. Dahlberg,
Unit
1 Station Superintendent
R. Randall, Unit
1 Superintendent,
Operations
J. Willis, General
Station Superintendent
C. Terry, Vice President
Nuclear
Engineering
and Licensing
J.
F. Warden,
New York Consumer Pro'tection
Branch
Connor
& Wetterhahn
Troy B. Conner, Jr.,
Esquire
Gary D. Wilson, Senior Attojney.
John
W. Keib, Esquire
Director,
Power
Division,
Department
of Public
Service,
State
of
New
York
State of New York, Department of Law
Licensing Project Manager,
Public Document
Room (PDR)
Local Public Document
Room (LPDR)
Nuclear Safety Information Center
(NSIC)
NRC Resident
Inspector
State of New York
bcc w/encl:
Region I Docket
Room (with concurrences)
DRP Section Chief
Robert J.
DRSS
B. Clayton,
RI: DRSMQ
Sisco/djh
3/t0/89
RI:DRS
Cont
3t/lf/8
~/ ('p~VVp
OFFICIAL
Rj
RS
1flo
M rtsn
3/V@89
gyp'>> 3//7/89
RECORD
COPY
OI CASE 88-003
0001.1.0
03/16/89
Attachment I
SYNOPSIS
Operations
Engineers
from the
NRC, Region I, conducted
three inspections of
the reactor operator requalification training program at the Nine Nile Point
Huc ear Station, Unit 1 (Ht1P-1), Scriba,
New York, in February,
triarch,
a
d
April 1988.
The first inspection identified several
discrepancies
in the
documertation of operator requalification training.
The second
inspection
disclosed that portions of classroom
and simulator training required
by the
in-house Nuclear Training Procedure
(NTP-ll) which implemented
had
not been
completed
by 39 operators
who had submitted license
renewal applications
to the
NRC between
Hay 1987 and March 1988.
The last inspection in April 1988
revealed that the operators
made-up
the missed
classes
and the licensee
completed most of the remedial action necessary
to prevent the recurrence of
documentation
problems
and training deficiencies.
Mhen the Region I staff became
aware of the missed training at HIP in
February 1988, they questioned
the truthfulness of the operators'Personal
Qualifications Statement - Licensee"
(HRC Form 398).
Hore specifically, the
staff questioned
the validity of the number of weeks listed
on
some
398s under
"Training - Requalification," Section 12(6).
On April I, 1988, the Office of Investigations
(OI) was asked to determine if
the reactor operators,
who sought renewal of their
NRC licenses,
executed
material false statements
when they submitted
398s that may have been inaccurate.
OI was also asked to ascertain if the Superintendent
of Training and the
former General
Superintendent
of Nuclear Generation
knew that
some operators
had missed training sessions
when they certified to the
NRC that the operators'
398s were correct.
OI's investig&ion, conducted
between April 11"and August 17', 1988,
included
examination of training records,
interviews of operators,
quality assurance
(QA) people, clerks, training managers,
station superintendents,
operations
personnel,
and senior management.
Several
operators
claimed they forgot that
they had missed
a session
or two"of required training when they signed their
398s which were prepared
by a third party.
The operators
said .they relied on
the preparer of their 398 to insert
co> rect information thereon
and never
intentionally signed
an inaccurate or false document.
The preparers
of the
398s said they only counted the total number of training hours
and never
attempted'to identify missed sessions.
The preparers
stated that all 398s
sent to'he
NRC contained
information that they alone inserted.
The preparers
also emphasized
that they never falsified a 398 and that no operator ever
asked
them to inflate the number of weeks listed in Section
12(6).
Operations
and training personnel
at
NHP said that the Station Superintendents
for HHP.-l and
NHP-2 were notified when'operators
missed training sessions.
However, because
of poor record-keeping,
certain skipped classes
were not
identified until an internal audit was conducted
in earlv March 1988.
A
consultant to the Niagara
Hohawk Power Corporation
(HMPC), who was part of a
Safety
Review
& Audit Board,
informed
a licensee
representative
in April 1987
that training records
were disorganized
but
HMPC took no apparent action to
correct the problem.
Case
Ho.
1-88-003
Several
licensee
employees
questioned
whether "continuous training," the most
frequently missed
session,
was required for requalification.
Nevertheless,
licensee
personnel
acknowledged
that it should
have
b'een
completed
since it
was part of the requalification program which had been
approved
by the
NRC.
The Superintendent
of Training said that when
he signed
a 398,
he believed
that the operator's
training was either complete or up-to-date.
He stated
some
398s were submitted
in the middle of the requalification year at which
time he
knew further training was necessary.
He claimed that
HRC regulations
fail to address
those
instances
when 398s are submitted to the
HRC during the
middle of a requalification period.
He denied that
he ever intentionally
signed
an inaccurate
398.
The retired Vice President for Nuclear Generation
and the former General
Superintendent
of Nuclear Generation
stated that they relied upon the integrity
of the operators
and the proficiency of subordinate
reviewers to ensure that
all 398s were correct when they signed
them.
They claimed to be unaware of
any missed training until after the first NRC inspection in February
1988.
The testimony
and documents
acquired during this investigation yielded no
conclusive evidence that any
NHPC employee submitted
a material false
statement
to the
NRC.
In a few cases,
the Superintendent
of Training
knew
that certain classes
were missed but he believed that they would be made-up.
However, the
NRC inspections,
HNPC's internal audit,
and this investigation
revealed that
a significant amount of operator training was not completed
by
the end of the requalification period ending February
22, 1988, because of .
poor managemerrt controls.
Case
No.
1-88-003
ACCEMRATED
DISTRIBUTE ON
DEMONSTRATION
SYSTEM
REGULATORej:NFORMATZON DISTRIBUTION +TEM (RIDE)
ACCESSION NBR:8903290125
DOC.DATE: 89/03/17
NOTARIZED: NO
DOCKET ¹
FACIL:50-220 Nine Mile Point Nuclear Station, Unit 1, Niagara
Powe
05000220
AUTH.NAME
AUTHOR AFFILIATION
RTIN;T.T.
Region 1, Ofc of the Director
ECIP.NAME
RECIPIENT AFFILIATION
BURKHARDT,L.
Niagara
Mohawk Power Corp.
SUBJECT:
Forwards synopsis of Insp 50-220/88-10
& OI Case
1-88-003.
Enforcement
conference
requested.
DISTRIBUTION CODE:
ZEOZD
COPIES
RECEIVED:LTR
I
ENCL
(
SIZE'
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES:
RECIPIENT
ID CODE/NAME
PD1-1
INTERNAL: ACRS
AEOD/DEIIB
SHANKMANFS
NRR/DLPQ/PEB 11
NRR/DOEA DIR 11
NRR/DRE~RPB
10
NRR PMAS/ILRB12
~
L
BE
NFJ
EG F
02
RNAL: LPDR
COPIES
LTTR ENCL
1
1
2
2
1
1
1
1
1
1
1
1
2
2
1
1
1
1
1
1
1
1
1
1
RECIPIENT
ID CODE/NAME
SLOSSONFM
DEDRO
NRR/DEST DIR
NRR/DLPQ/QAB 10
NRR/DREP/EPB
10
NRR/DRIS DIR 9A
NUDOCS-ABSTRACT
OGC/HDS1
RGN1
FILE
01
NRC PDR
COPIES
LTTR ENCL
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
R
I
NCTE 'IO ALL "RIDS"
RECIPZERIS'ZEASE
HELP US 'IQ REDUCE HASTE! ~CZ 'IHE DOQ3NEÃZ (XÃIBDLDESK,
ROCN Pl-37
(EXT. 20079) K) EZZKQQZB YOUR MME FBCH DISTRIBVPIQN
LISTS FOR DOCUMEKIS YOU DGNFT NEZD!
C
D
S
TOTAL NUMBER OF COPIES
REQUIRED:
LTTR
25
ENCL
25
March 17,
1989
Docket No.
50-220
Niagara
Mohawk Power Corporation
ATTN:
Mr. Lawrence Burkhardt, III
Executive Vice President
. Nuclear Operations
301 Plainfield Road
Syracuse,
13212
Gentlemen:
Subject:
REGION I .INSPECTION
NO. 50-220/88-10
AND
OFFICE
OF INVESTIGATION (OI) CASE
NO. 1-88-003
In response
to the subject inspection of your licensed operator requalification
program,
the
NRC's
Office of Investigation
(OI)
conducted
an
investigation
between April 11 and August 17,
)988 (Case
No. 1-88-003).
>le have attached
the
synopsis
of that
OI report to this letter for your review.
As
a result of our
review of these
reports,
we have concluded
that
an
enforcement
conference
with
you in conjunction with the involved licensed
operators
is warranted.
Our concerns
are threefold:
( 1) apparent
failure of 39 licensed
operators
to
fully participate
in the
NRC '-required
requalification
program,
(2)
apparent
failure
on
the part of
13 of those
39 operators
and
two levels of facility
management
to
identify
inaccurate
statements
on
the
NRC
required
license
renewal
applications
(NRC
Form 398)
submitted for the subject
period
and, (3)
apparent
failure
on
the
part
of facility management
to identify
and
take
effective corrective
action
on
the
program'hortcomings
that permitted
items
.
( 1) and (2) to 'occur.
Although the OI report
concluded
that the submittals
of
the
inaccurate
NRC
Form 398s
were not willful, we believe that
a significant
breakdown
occurred
in
the
management
oversight
of your
licensed
operator
requalification
program.
As discussed
in
a
March 10,
1989,
telephone
conversation
between
you
and
Mr.
Robert Gallo of my staff,- we plan to conduct
an
enforcement
conference
at the
site
on
March
30,
1989.
In that
telephone
conversation,
you also
agreed
to
have the
13 involved licensed operators
attend
the conference.
At the enforcement
conference,
you,
and the involved licensed operators,
should
be
prepared
to discuss
(1) the
NRC staff findings
and the safety significance
of the above
noted failures, (2) the specific
and underlying causes
and (3) the
actions
taken
or
planned
to correct
these
problems
and the results
achieved.
8903290125
890317
ADQCK 05000220
8
PNU
Niagara
Mohawk Power Corporation
Thank you for your attention to this matter.
Sincerely,
Original Signed
By.
Iomas J.
Ma~'homas
T. Mar'Hh, Director
Division of Reactor Safety
Enclosure:
Office of Investigation
Case
No. 1-88-003 Synopsis
cc w/encl:
C.
V. Mangan,
Senior Vice President
D. Palmer,
Acting Manager, Quality Assurance
W. Hansen,
Manager,
Corporate Quality Assurance
R.
G. Smith, Unit 2 Superintendent,
Operations
C.
Beckham,
Manager,
Nuclear Quality Assurance
Operations
R.
B. Abbott, Unit 2 Station Superintendent
J.
Perry, Director,
Nine. Mile Point Unit
1 Restart
Task Force
K. Dahlberg, Unit
1 Station Superintendent
R. Randall,
Unit
1 Superintendent,
Operations
J. Willis, General
Station Superintendent
C. Terry, Vice President
Nuclear Engineering
and Licensing
J.
F. Warden,
New York Consumer Protection
Branch
Connor 5 Wetterhahn
Troy B. Conner, Jr.,
Esquire
Gary
D. Wilson, Senior Attorney
John
W. Keib, Esquire-
Director,
Power
Division,
Department
of Public
Service,
Sta
State of New York, Department of Law
Licensing Project Manager,
Public Document
Room (PDR)
Local Public Document
Room (LPDR)
Nuclear Safety Information Center
(NSIC)
NRC Resident
Inspector
State of New York
te
of
New
York
bcc w/encl:
Region I Docket
Room (with concurrences)
DRP Section Chief
Robert J.
DRSS
B. Clayton,
3/cr'y
RI: DRS( "g
Sisco/djh
3/
/89
RI:DRS
.
S
Conte/
~
G
1
o
3/1 7/89
3/
/89
R
.DRS
M rtin
3//7/89
SYNOPSIS
Operations
Engineers
from the
NRC, Region I, conducted
three inspections
of
the reactor operator requalification training program at the Nine Mile Point
Nuclear Station, Unit 1 (NMP-l), Scriba,
New York, in February,
March,
and
April 1988.
The first inspection identified several
discrepancies
in the
documertation of operator requalification training.
The second
inspection
disclosed that portions of classroom
and simulator training required
by the
in-house Nuclear Training Procedure
(NTP-11) which implemented
had
not been
completed
by 39 operators
who had submitted license
renewal applications
to the
NRC between
May 1987
and March 1988.
The last inspection
in April 1988
revealed that the operators
made-up
the missed classes
and the licensee
completed
most of the remedial action necessary
to prevent the recurrence of
documentation
problems
and training deficiencies.
When the Region I staff became
aware of the missed training at
NMP in
February
1988, they questioned
the truthfulness of the operators'Personal
qualifications Statement - Licensee"
(NRC Form 398).
More specifically, the
staff questioned
the validity of the number of weeks listed
on
some
398s under
"Training - Requalification," Section 12(6).
On April 1, 1988, the Office of Investigations
(OI) was asked to determine if
the reactor operators,
who sought
renewal of their
NRC licenses,
executed
material false statements
when they submitted
398s that may have
been inaccurate.
OI was also
asked to ascertain if the Superintendent
of Training and the
former General
Superintendent
of Nuclear Generation
knew that
some operators
had missed training sessions
when they certified to the
NRC that the
operators'98s
were correct.
OI's investigation,
conducted
between April ll and August 17, 1988,
included
examination of training records,
interviews of operators,
quality assurance
(gA) people, clerks, training managers,
station superintendents,
operations
personnel,
and senior management.
Several
operators
claimed they forgot that
they had missed
a session
or two of required training when they signed their
398s which were prepared
by a third party.
The operators
said they relied on
the preparer of their
398 to insert correct information thereon
and never
intentionally signed
an inaccurate
or false document.
The preparers of'he
398s said they only counted the total
number of training hours
and never
.
attempted
to identify missed
sessions.
The preparers
stated that all 398s
sent to the
NRC contained
information that they alone inserted.
The preparers
also emphasized
that they never falsified a 398 and that
no operator
ever
asked
them to inflate the number of weeks listed in Section 12(6).
Operations
and training personnel
at
NMP said that the Station Superintendents
for NMP-1 and
NMP-2 were notified when'operators
missed training sessions.
However, because
of poor record-keeping,
certain skipped classes
were not
identified until an internal audit was conducted
in early March 1988.
A
consultant to the Niagara
Mohawk Power Corporation
(NMPC), who was part of a-
Safety
Review
5 Audit Board,
informed
a licensee
representative
in April 1987
that training records
were disorganized
but
NMPC took no apparent
action to
correct the problem.
Case
No.
1-88-003
Several
licensee
employees
questioned
whether "continuous training," the most
frequently missed
session,
was required for requalification.
Nevertheless,
licensee
personnel
acknowledged
that it should
have been
completed
since it
was part of the requalification program which had been
approved
by the
NRC.
The Superintendent
of Training said that when
he signed
a 398,
he believed
that the operator's
training was either complete or up-to-date.
He stated
some
398s were submitted in the middle of the requalification year at which
time he
knew further training was necessary.
He claimed that
NRC regulations
fail to address
those
instances
when 398s are submitted to the
NRC during the
middle of a requalification period.
He denied that he ever intentionally
signed
an inaccurate
398.
The retired Vice President for Nuclear Generation
and the former General
'uperintendent
of Nuclear Generation
stated that they relied upon the integrity
of the operators
and the proficiency of subordinate
reviewers to ensure that
all 398s were correct when they signed
them.
They claimed to be unaware of
any missed training until after the first NRC inspection in February
1988.
The testimony
and documents
acquired during this investigation yielded no
conclusive
evidence that any
NNPC employee
submitted
a material false
statement
to the
NRC.
In a few cases,
the Superintendent
of Training
knew
that certain classes
were missed but he believed that they would be made-up.
However, the
NRC inspections,
NNPC's internal audit,
and this investigation
revealed that
a significant amount of operator training was not completed
by
the end of the requalification period ending February
22, 1988,
because
of
poor management
controls.
Case
No.
1-88-003
I
~