ML20127N048

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Brief Supporting 850522 Motion to Reopen Record for Receiving Addl Info Re Criminal Conduct of Licensee.Licensee Alleged to Have Withheld Pertinent Info,Rendering Prior Decisions Incomplete.W/Certificate of Svc
ML20127N048
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 05/22/1985
From: Bradford L
THREE MILE ISLAND ALERT
To:
NRC COMMISSION (OCM)
Shared Package
ML20127N000 List:
References
SP, NUDOCS 8505230423
Download: ML20127N048 (227)


Text

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     .                                                                                                                   1 I

l UNITED STATES OF AMERICA 0$cMETED NUCLEAR REGULATORY COMMISSION "ViRC IN THE MATTER OF: ) '

                                                  )        DOCKET NO. 50-289 5 MY 22 P1:03 METROPOLITAN EDISON COMPANY,          )

et al ) (Restart) , _ . . _ . (Three Mile Island Nuclear ) 'l, TIE

                                                                                                          ~
                                                                                                                '- l-Generating Station, Unit 1)           )

BRM4C" BEFORE THE COMMISSION TMIA'S BRIEF IN SUPPORT OF ITS MOTION TO REOPEN THE RECORD FOR THE PURPOSE OF RECEIVING ADDITIONAL INFORMATION I. BACKGROUND This is a Brief in support of TMIA's Motion for the purpose of considering evidence regarding the criminal conduct.of Licensee. TMI Alert (TMIA) believes that this new evidence is indispensible to consideration of Licensee's integrity. The evidence consists of the following documents:

1. The Of fice of Investigation (OI) Report on the f acts surrounding Licensee's submittal of a material f alse statement to the Nuclear Regulatory Commission (NRC) on August 3, 1979.
2. Evidence of additional cheating on the part of Floyd and Mr. O, which Licensee withheld from the NRC.

This motion is timely filed since the documents which TMIA now seeks to make part of the record were heretofore unavailable. Because these documents were previously unavailable, a full consideration on the record developed in this case was not , possible. The documents will also show that Licensee withheld information pertinent to this case and therefore renders prior decisions incomplete. 8505230423 850522 PDR ADOCK 05000289 Q PDR

s. II. LICENSEE TOOK NO ACTION AGAINST FLOYD AT THE TIME OF THE CHEATING In his report to the Licensing Board, the Special Master 1 concluded that "the Licensee failed to declare a clear policy. against what VV (Floyd) did. If the Licensee had declared such a policy, the Licensee might have prevented the cheating which occurred later on the weekly quizzes and the NRC examination." See SMR at 1237. The Board did not accept this finding of the Special Master, concluding instead that Licensee's reassignment of Floyd to a group charged with investigating the accident constituted a demotion for Floyd. See July 27, 1982 PID at 12286. The OI report contains information which was not provided during the reopened hearing on cheating, and was not before the Board when it made its decision in that proceeding. The new information supports the Special Master's finding, and would have resulted in a different conclusion by the Licensing Board had it been available to that Board. On August 20, 1979, a memo was distributed to TMI-2 department heads stating that Floyd was to be temporarily assigned to the accident investigation documentation group ( AIDG), the memo characterized the move as one which would allow Licensee to make the best use of Floyd's talents and knowledge of the plant. Robert Arnold. testified that it was at his suggestion that Floyd was transferred. He did not consider Floyd's submittal

e o of another operators work to satisfy requalification requirements, to be an_act of cheating and referred to it as " poor judgment" on Floyd 's part. Arnold said that Floyd had demonstrated a weakness in terms of administrative ability on other occasions and his decision to reassign Floyd took that fact into account. See OI Report, 124 at 2. Arnold said that the reassignment was in f act a demotion, h owe ve r, this f act was never documented and the f acts do not support Arnold's assertion. Id. at 3. Thomas L. Hombach, Personnel Director for TMI, said that he would have been informed if personnel were to be disciplined. He has no knowledge of Floyd's being disciplined as a result of the cheating. See U.S. v.. James R. Floyd, Criminal Action No. 8 6-00099, Tr. Vol. I at 110. Floyd himself testified at the reopened hearing that the reassignment was a lateral move. He.had neve r been informed that the move was intended as disciplinary action and he did not believe this to be the case. The Board disagreed with Floyd's statement that he had not been demoted. The Board stated:

         "The fact that VV (Floyd) believes it was not a demotion, or says so, may simply be a manifestation of             ,

his own career aspirations. Or it may be to that he 1 does not want to accept or aamit the significance of his transfer. Under the circumstances, it is likely that most of VV's peers in middle management saw his reassignment as a demotion, or at least an impediment to adva nceme nt. July 27, 1982 PID 12284. I

However, the new informa tion supports Floyd 's claim that

  'he was not demoted. On November 15, 1979 Floyd submitted an application for license with accompanying certification signed by Miller. In this application Floyd lists his job classification as Supervisor Station Operations.

The Novemb'er 15, 1979 application further indicates that the assignment was not permanent and Floyd was justified in his belief that it was not a demotion in response to the cheating incident. More importantly, the new evidence demonstrates that Licensee took no action against Floyd for his cheating, and undermines the Board's conclucion in its July 27, 1982 Partial Initial Decision (PID) at 11280-286. III. THE ADDITIONAL CHEATING OF FLOYD AND MR. O On June 1, 1984, Licensee distributed to the Commission Boards and parties copies of requalification program examinations which Floyd completed in May of 1979. The last page of this examination was written by O, and constitutes another instance of cheating involving Floyd and O. This information was neither produced during the cheating proceeding, nor was it provided to the OI investigatnes. In fact, Licensee withheld this information until May of 1984, when it was produced for the Grand Jury investigation of Floyd 's cheating. The fact that Licensee withheld this additional evidence of cheating f rom the NRC during the Reopened Hearing on Cheating

.4 and during the OI investigation is f urther evidence of Licensee's lack of integrity. Fu rthe rmore, it undermines Licensee 's assertion that in July of 1979 there was no way of knowing about O's willingness to cheat. The examinations were graded during the company 's investigation into the cheating of Floyd and O, both Floyd 's and O's exams were graded by Nelson H. Brown, Administrator of Nuclear Technical Training (Instructor). Under these circumstances it is inconceivable that this additional cheating went unnoticed by the training department. O was interviewed by NRC investigators on July 30, 1981. See Staff Ex. 26 at 42. When he was questioned about the incident involving Floyd, O " appeared dismayed and looked nervous and upset." I d,. At the hearing O denied that he knew that he was helping Floyd complete his make-up exam Tr. 26, 190(0). Floyd was interviewed by telephone that same day, I d,. at 26 at 40. He told the investigators that he had gone to the TMI-l shift supervisor's office to review material in order to complete his examination Id,. He recalled that O "had the same questions and a nswe rs " , implying that O was aware that he was assisting Floyd with his requalification requirements. When Floyd was asked whether he thought that O knew he was helping Floyd with his exam, he said "I do not know what was in his mind . . . Tr. 26, 640 (Floyd). The Special Master stated that ". . . it is difficult to see how Mr. Miller could have accepted (O's) denial." See SMR at

r 6' 1227. And he-concluded that Miller in fact knew that O had knowingly provided assistance to Floyd in the completion of his requalification exam. IV. CONCLUSION The Board's conclusion A.1 of the May 3 decision, the keystone of the Board's overall decision that Licensee's training program is adequate, is skaken by this new information. For this reason, TMIA requests that the record be reopened for the purpose of receiving this new inf o rma tion. Respectfully submitted,

                                              /            1 Dated:    May 22, 1985                tt=
  • Louise Bradforo for Three Mile Island Alert, Inc.

e 1 l

4 UNITED STATES OF AMERICA gat 4EE: NUCLEAR REGULATORY COMMISSION USSRC IN THE MATTER OF: )

                                    )        DOCKET NCS5 sugga A1:05 METROPOLITAN EDISON COMPANY,     )

et al ) (Restart) . (Three Mile Island Nuclear ) 'gF Iggj-yggg,; Generating Station, Unit 1) ) BRANCH BEFORE THE COMMISSION CERTIFICATE OF SERVICE I, LOUISE BRADFORD, hereby certify tihat on the 22nd day of May, 1985, I served true and correct copies of the within TMI A 'S Brief in Support of its Motion to Reopen the Record for the Purpose of Receiving Additional Information in the above-captioned ma tter by hand delivery to the persons and offices on the attached list.

                                                         @^               %

LOUISE BRADFORD g

o

5. .

4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ) - 00CKETE'

                                                                  .         'JSNRC
                                        )
       -METROPOLITAN EDISON COMPANY     )           Docket No. 50-289 SP
                                        )                  Restart (Three Mile Island Nuclear      )                             5 MAY 22 P1 :03 Station, Unit No. 1)           )

GFFici.c: n uez,;,, 00CXETING A SEAviU ' BRANCH SERVICE LIST Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission John H. Buck Washington, D.C. 20555 Atomic Safety & Licensing Appeal Board . Thomas M. Roberts, Commissioner U.S. . Nuclear Regulatory Commissi U.S. Nuclear Kegulatory Commission Washington, D.C. 20555 Washington, D.C.. 20555 Administrative Judge , James K. Asselstine, Commissioner Christine N. Kohl U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appealj Washington, . D.C. 20555 Board U.S. Nuclear Regulatory Commissic Frederick Bernthal, Commissioner Washington, D.C. 20555 U.S. Nuclear Regulatory Commission i Washington, D.C. 20555 Administrative Judge Ivan W. Smi,th, Chairman-Lando W. Zeck, Jr., Commissioner Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commissic Washington,-D.C. .20555 Washington, D.C. 20555 Administrative Judge Administrative Judge Gary J. Edles, Chairman Sheldon J. Wolfe Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory Commissic U.S. Nuclear RegulatorylCommission Washington, D.C. 20555 Washington, D.C. 20555

u  ! l Administrative Judge Deborah B. Bauser Gustave A. Linenberger, Jr. Shaw Pittman, Potts & Trowbridge , Atomic Safety & Licensing Board , 1800 M Street N.W.  ! U.S. Nuclear Regulatory Commission Washington D.C. 20036 Washington, D.C. 20555 ,. Docketing and Service Section (3) Office of the Secretary Mr. and Mrs. Norman Aamodt U.S. Nuclear Regulatory Commission 200 North Church Street Washington, D.C. 20555 Parkesburg, PA 19365 Atomic Safety & Licensing Board Lynne Bernabei, Esq. Panel Government Accountability U.S. Nuclear Regulatory Commission Project Washington, D.C. 20555 .555 Connecticut Avenue

   -                                                 Washington, D.C.       20009 Atomic Safety & Licensing Appeal Board Panel Ellyn R. Weiss, Esq.

arm n, Weiss & Jordan U.S. Nuclear Regulatory Commission 001 5 Street, N.W., Suite Washington, D.C. 20555 , 430 Washington, D.C. 20009 Jack R. Goldberg, Esq. Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l Thomas Y. Au, Esq. Office of Chief Counsel Department of Environmental Resources 505 Executive House . P.O. Box 2357 Harrisburg, PA 17120

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                             .                  l,           y                      .        Enclosure (1)
             .',                                                                 TRAINING ASSIGt!MEili ADillt!!STRATIVE FORT 1 7
3. l.esson/ Course: EevetAen ~ sbn ve Oc v 1
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2. Name: V, V _ _ m. ',
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3. Classification: ( nv
                                                                           ~ '

CATALOG ?!UMSER ~I CdURSE ff00E MODE PREFIXE5 DURATION cl ppITIx Makeup ,. MUp , A HOURS Correspondence - 27 31 32 34 i T LIssort . j 15 ' A TYPE SUBJECT ID 26 gg I ttJ 4 ntAF 00 f t min I 35 cosasTs 3,u fkg B w t m i 6 1 I P 1 2 o'IC I I E ! # 1/ff I E f M M I E fa lu t s i 1 3 .

4. ' Reason for assignment-FSR Requirement Cycle: f Mecture itissed Type d(L Cycle Completion Date: 1M ye l st Not Taken Time Period: 8/.u/vs,d 9/u/7) l < 80% on Test . Type of License'(RO@: YI L '

G. Instructor Assigned: M D. b e Instructions: - 4L. Aa/a.) cl.~u4.1 F-e.n C%w <e ,n n a

'Nm ,L - m.A .1 < d , x n L N(nn N(210t ) 11) CR b W \wes (1141-9)(2 % 2-I. 2 12 o?-/.3h bast e4 07% I"e' d [72.0 2-5 M/AV22 02 - 12) . Aad. Orth :k(ne2-/h)b2di /,2) doss o 4 b e m [ A 2 a 2 - /. 1 ) v~i~,wh2~8Yl - ' YAe_ N/a}M V i J~

6. RETUR:t TO TRAIf!ING DEPARTMENT BY: MS M* '
7. Meth:d of Ecaluation: (Check at least one) 'Y '

a) 1:ritten Test [ Scar : . [y h,h ] l-b) Oral Spot Check ' ~~ l c) Other (Explain)- I

8. l  ! ' - - W. , f ,

Ir.n: .. ' ur',s S ignature '. 0a t :perc u. of aini..-- 'Date X . - - - - _ _ _ - - . . . . _ - . - - . - . . - . . .__.._...-._....-..-___.:Y *I ~ ' # EMERGENCY PROCEDURES TEST n ' ja * ~ ~~ Ih( e CYCLE 5 REQUAL . SROANSNERNLLQUESTIONf '\ .b}* Rf.. . n$ ~ , f . : .... 2 . .. . . . _: " .".- 1M.08.Od$ C S ";iyQ. ^7 . .. Qrod  :: . 'fasit.;.tdi l List.i;+hG=.:1 '.Eb.f;,isy..;;fric .2. . go% . 5 Fin'dicatfohs an- me . e .--WPl...... . . y. ,f '. '

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2. What is your action upon discovery of a stuck control rod in Gp 72,' ' ,,, ,,
3. What gives a motor fault alarm?

.N ,- SRO Ne - i 4. . After verifying a rod as being. stuck what 1s follow-up action? a ', J, o., Draw the asymetric rod runback circuit. ' , S. C

6. On the attached figure (Unit I o'r Unit II control room as applicable) mark the .Ao_

. area that an " operator at the controls" should not normally. leave for routine enerations. - ~ (NOTE: X-license answer 'for ,both units) . - ~ . . SRO .

7. An " Operator at the con is" may leave the routine operations area and.briefly _bT..

enter the nonroutine rations area of the contro om. List (3) three, con.!- .ditions.whic an "O erator at thy con tions area.  ; n. c -w the = =ng= -- routine = opera- . .q . _ --+j- h, & a t' ~ ~ e, .ffL =-"* '~ 8. Briefly explain the purpose o,f CAUTION tags.9_ g__ / y y " _ A a.._

9. Given the following information, calculate the qua'drant power tilt. Use 'the .Aa _

attached d'ata sfieet B&,.,,Copypjg;Lpk r Recorder Detector Recorder Detector - Point Number Reading Point Number Reading 1-1 124 1-16. 124 1 125 1-17 117 . 1-10 125 1-18 119 1-11 125 2-1 124 .

1-12 125 2-2 125 1-13 117 .

2-3 125 , 1-14 118 2-4 124 . 1-15 124 2-5 123 ,p , .s z o

10. a) ty O ' s,

[ l ' I M-- List

1. Symetrical (full) incore system
2. Minimum theincore allowable tilt/ i.valuesAv 5' for:[# p.E( N<

system. L

3. Power range channels.

u 't .- #5 ./ / I,y Y 2 b) E,iplain the required actions if the applica'cle quadrant power tilt limit is h#- exceeded. y ,,.'2;'._. .(Essur.:a that corrective ac; ions da not decreapi 4.) , f, i ; .,,, ~ - . . . ..* ~ _..__..____..__'__,_3._s. . _e _ . .. . . . , _ . . _ _n _Q s_. y i -4 ,; . . -2. - - f , l 11, What .is the required frequency for monitoring: I ,, ( b . b5h")'QuadYanbpowert15t $ '.$ 5 4 ..' Y h .'- . . '- : .* ? ---E? W 3 l .' b) Axial power imbalance, gg; . 4 g4 - .S .

17. Following a loss of feed to both OT .s', fiow should be limited to

' apm. p jIlf; ' '* TP.0 __ f 13. How do jou recover from a dry steam generator 7f##;"/lg4;I . ,j , e U"L go_

14. List th's power s0pplies and location of % for main feedwa .. wu -

.3-15. ,/ ~ 1.d 3 es. a astg s{for unantic:1 pated criticality.54 G- - .. f _y_._ IG. What are tbe indications of boron dilution accident in progress? v, 'a__ Taf*I y *%h .X- L 24.5 ' .~ 312 0 d RJb 17.25 f i 12 M , - Lfs ae- Trwc.el m 2- : . ge io 1.e ep.c.d.< a+ A c~kis %V W37 Cn.u.4% N - sP (ia.o2 -7) C a.io3 '-/.n.) H44 chf=4A f 77 /fi Able . E P (1101 -8R2 303 -L 2 ; 2205 ~L3} cR.hBja:ymn~f 3=;J/u.res FP C 1201 Afa4/A)(22o3-2,1) 1.,ss ef OTsG F d EP C 00S-16)(1102~l.1) Un<*d:cip4s.E Cr)N..yNQ F P (22o3-/./) f ess of Ba% i l 1 =- ~ .: .. . o... . DATA SHEET 1 p,.....T'-Lip. . * . j ,.

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._.,.. , . _ . . l(( . khg ~ ETSOf. .4F.'- . "iVJK0ifkiT' POWER TfLT' T.MIriIi:y:4 D: CORE'upcud ',2j , J . 1) Fill .in the following incere valves: . . s . - Core Axial (Recorder - Detector) Quadrant-Quadrant location Level Point No. Reading Sums ^ XY CIO - 2 (1-11) 12 f XY= W 7 ' XY F13 2 . (1-12) IW . Quad..d. 1;J XY , . E9 6 (2-5) 1P3 1 , XY Gil '6 (1-1) )FY '-

  • i YZ.. . L13
2. (1-13) N '/ yz- $7 T '

YZ' 010 2 (1-14) 1/ [ QuadramV ', YZ Kil - 5* (1-17) //7 2 YZ M9 6 (1-18) / / // ~ ZW 06 . . 2- (1-15) 1>+ Zw= 4e/ 7 . ZW (, L3 2 (1-16) />f , Quad d / >f ZW M7 6 (2-1) 3 / ZW K5 6- (2-2) #?A ' / .XW F3 2 (1-9) !M, _ WX=_ tM d 8j i/ , WX C6 2 (1-10) quadragt 1 WX G5 . 6 (2-3) f 4 WX E7 6 (2-4) i>4 i /@ b9 #

2) Core Total = (WX) + (XY) + (YZ) + (ZW) =
3) Quadrant Average Power (QAVE) = Core Total + 4 = c/ e7 /

0"* " 3 -1 % (100T.):

4) Quadrant Tilt, 5 =

E 'a Quadrant 1 XY Tilt = P 0, old-l" A Quadrant 2 YZ Tilt = - Os O 'f.0 % !  ! k Quadrant 3 ZW Tilt = Hiv/? 3. t ' 6 Quadrant 4 WX Tilt = f a.-e /./,; Y, '.

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..) .: *.. 1 . ....... .:. ,. 2-- -.  :.e . . :~- ., .. .., ... p tiit 5'indii5tions'of' an, asym;e;~tfic roi!.' fault'! " .,. .v_..I-yJ.%ot.,:  ;. e M - .y- ,1 - - ' . . .'. . .. - . s.zs 't.1

. What, is your action upon discovery of a stuck control rod  !?. (/ ,,, f,f .

.. What gives a motor fault alarm? '? .y ,- a.ii. Ac. .V N, . ,. After verifying a rod as being stuck what 1safolicw-up action? 4Y 2 a , ,., j - Fr.:w the asymetric rod runback circuit. /Q- . 24 4 On the attached figure (Unit I or Unit II control room as applicable) mark the .Ao___. area that an " operator at the controls" should not normally. leave for routine wrations. - (NOTE: X-license answer for both units) r;0i  ?. An." Operator at the controls" may leave the routine operations area and briefly 7P___ enter the nonroutine operations area of the control room. List (3) three con- .! .ditions which warrant an " Operator at the controls" to enter the nonroutine opera-tions area. ~ ' Briefly explain the purpose of CAUTION ' tags. 4 0 ._ Given the following information, calculate the quadrant power tilt. Use the $0_ attached data sheet: . Recorder Detector Recorder Detector Point number Reading Point Number Reading 1-1 124 1-16. 124 1-9 125 1-17 117 1-10 125 1-18 119 1-11 125 2-1 124 - l 1-12 125 2-2 125 l 1-13 117 - ~ 2-3 125 .~ - I 1 i 1-14 118 2-4 124 't ' E , o l1-15 124 2-5 123 < 1t ,e SRd e l, 10. a) List the allowable tilt values for: 'Q - V 1. Symmetrical (full incore system. I 2. Minimumincoresys) tem. } 3. Power range channels. - I b) Explain the required actions if the applicable quadrant power tilt limit is h8 . j exceeded. . (assume that corrective actions do not decrease the tilt.) e 'd ' ,- -. 2 . - . l , l r 11.' What is the required frequency for monitoring: ...._i.' 'a)- Quadrant power tilt.. - .- -- -._ __ . ---+- 4.* , .-l . b) Axial power imbalance - .....S l i l 17. Following a loss of feed to both OTSG's', flow should be limited to spm. A I l . . l 3 * ' I .:* P.0 How do you recover from a dry steam generator? .73. go,_ ) l ' . 14. 1.ist th'a power supplies and location of % for main feedwater block valves. 's l 1.G. Name at least two causes for unanticipated criticalit:y. .- a __ l IG. What are the indications of a boron dilution accident in progress? 1,'a.__ ~  ;. Taal T * *h X -- 4. 4 4.5- ~ sno 17.xr ' i - c Rs 12.as-' l . i L % ,,. e Tvve.ed

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.,....~, - . :.v ~ . .. s , ' ' . . 7 ' e .. . f ' DATA SHEET 1 j t ... . . ' ~ T2! *:  ?!T. qdA'DielT POWER TILT :!Muin:UM D:50RE'DETECTdRS 'i J.T.. - ,- j J

1) Fill .in the following incore valves: . .

~ Core Axial (Recorder - Detector) Quadrant.- Quadrant location Level Point No. Reading Sums  ! XY CIO ~ 2 (1-11) /O [ XY= g ' XY F13 2 . (1-12) /S [ . Quadrant I. XY E9 6 (2-5) /,73 1 /- XY- Gil 6 (1-1) /J 4/ > YZ. L13 - 2 (1-13) - //7 . YZ= W/ ' YZ 010 2 (1-14) //f Quadgt' K11 6- 2 YZ (1-17) /./ 9 . (1-18) // 9 - YZ M9 6 ZW 06 . . 2 (1-15) /) t/ ZW= ZW  ; L3 2 (1-16} /) Y , Quadr)an ' ZW M7 6 (2-1) /) 3 ZW KS 6- (2-2) ld [ WX F3 2 (1-9) /.2[ WX= fff WX C6 2 (1-10) /d[ Quadragt WX G5 . 6 (2-3) /l[ 4 i WX E7 6 (2-4) /2Y

2) Core Total = (WX) + (XY) + (YZ) + (ZW) = / 98 9 s

^3) Quadrant Average Power (QAVE) = Core, Totai + 4 = Yf/ v Quadrant Tilt, 5 = 0""

4) -1 X(1005): .

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Enclosure:

01 Report H-82-002 Distribution w/o encl: PDR . LPDR NSIC - SECY CA JTaylor, IE ' JAAxeirad IE

                                        ~'

EHoller, IE , JLieberman, ELD

             .JGoldberg, ELD       _

VStello, DED/ROGR FIngram, PA

      ,~

HDenton, NRR RStark, NRR ~ BHayks,OI SConnelly, OIA

 -            TMurley, RI Enforcement Coordinators RI, RII, RIII, RIV, RV IE:ES File IE:EA File EDO Rdg File                                                                          -.

DCS WTravers, Deputy Program Director TMI Program Office Senior Operations Officer DPRP Section Chief JVVliet, PM, NRR Public. Utility Comission Ms. Mary V. Southard, Co-Chairman Citizens for a Safe Environment T. H. Gerusky, Director Bureau of Radiation Protection Harrisburg, PA 17120 [

                    --        -.                   . . ~ . . - -   . _ , , . _ _

SUMMARY

e In a letter dated August 3,1979, ch' Metropolitan Edison Company (Met Ed) certified to the NRC that a licensed senior reactor operator (SRO) had satis-f actorily completed an accelerated requalification program (ARP) and achieved a score of.99.8%. The letter, which was written by the Station Manager at T,hree Mile Island- (TMI), also provided back 3round information on the SRO's training deficiencies during the 1978-79 requalification year. It reported that the SRO (who was Supervisor of Operations. TMI Unit 2) had been found dificient in four training categories (or' sections) and was required to upgrade them in response to Met Ed Administrative Procedure 1006 (AP-1006). The lett'er explained .that upon retesting in his four deficient areas, the SR0 received'two scores less then 80%. It concluded by stating that he had been required to participate in a specifically tailored program which had enabled him to improve in the areas of demonstrated weakness and achieve the 99.8% grade. During the July 1981 investigation into cheating on operator licensing exami-nations (HQS-81-003),'the licensee advised the NRC that the SRO had obtained assistance in completing two of the four areas on his reexamination. He reportedly received a passing grade in one of the questioned. areas and a failing grade in the other. Since the individual who provided the assistance was one of the principal suspects in the July 1981 investigation, and the licensee indicated that the SRO had been reassigned to nonlicensed duties, the information was considered within the context of that investigation. During the Atomic Safety and Licensing Board (ASLB) Hearings in the Fall of 1981, the licensee's certification of the SRO to the NRC came under scrutiny. In its Partial Initial Decision (PID) concerning TMI Unit 1 (dated July 27 1982), the ASL3 concluded that the licensee's August 3, 1979 letter was "a false-material statement to the NRC." An 01 investigation was subsequent 1y' initiated to determine the circumstances. surrounding the SRO's esreification to-the NRC. Interviews were conducted of personnel in the licensee's Training Department, including those. involved in grading the suspect examination and those who l

               - prepared and administered the special requalification program that followed.

1 s.--

I.

  • The instructor who graded the examination said he recognized the handwriting discrepancies and that after consulting with another instructor, he brought the matter to the attention of the Supervisor of Training. According to the
                       ' Supervisor of Training, he i= mediately reported the problem to the Unit 1 Superintendent and understood that the latter advised the TMI Station Manager.

Interviews were conducted of.TMI management personnel, including those in-volved in the licensee's inquiry into the irregularities on the SRO's examination and those involved in his subsequent certification to the NRC. The Station Manager stated that he first became aware of the problem on July 2,.1979 when he was advised that two sections (of the SRO's exam) were unsatisfactory and one was in someone else's handwriting. He added that he

                  ~ subsequently learned that there were two sections which were partially in the handwriting of someone other than the SRO. According to the' Station Manager,
                                                                         ' ~
                    - he advised his s6pervisor (who was^ Vice ~Piesiident for Nuclear Operations) of
     ,                 the problem; the supervisor subsequently stated that he considered the
  • incident sufficiently serious to warrant reporting it to his supervisor-(who was Vice President for Generation).

i

                     'An interview of the SRO verified that he had sought and obtained assistance in completing his examination. Training personnel said that as a result of the SRO's performance on his examination, he was removed from operations and assigned full time to an accelerated requalification program (ARP).. Although the document which assigned the SRO to the ARP states that he only had two deficient areas, Training personnel involved in the preparation and adminis-tration of the program stated that a third area (one of two in which the SRO had received assistance) was also covered in sufficient depth to demonstrate competence in that area.

l The Station Manager advised that he conducted an inquiry into the handwriting irregularities on the SRO's examination. He said that while the SRO demonstrated poor judgement, he felt there had been no deliberat.a attempt to

                  -deceive; with respect to the individual who had provided the assistance, the l                    Station Manager concluded that' he was not aware of the intended purpose of his aid.-

Interviews with licensee canagement indicated that af ter considering

   ~
                                           <, ,, , -- .-,  y          ,e.-

y_ _ several,possible responses to the SRO's conduct, the decision was made to reassign him to a non-line position. -- - - - The Training Department reported that afte,r the SRO had completed his ARP, a letter was drafted to advise the NRC of this fact. This letter, which was prepared by the Supervisor of Licensed . Training, was written in longhand and

               . forwarded to the Station Manager. The Station Manager reported that he received the letter and had it prepared in typewritten form. He said he noticed that only two deficient sections were referenced in the letter while
              .the SRO had actually studied three due to the " handwriting problem."' He continued that he sent a note to that effect, along with the typewritten draft,,co a co:pany-retained attorney for his review. The attorney, when interviewed, stated that he had no specific recollection of having seen either
            .the note or the draft of the proposed letter to the NRC.
  .           When interviewed, the Supervisor of Administration advised that he put the        -

letter into final' form, but added he could not recall who provided the grades which' appear in it. T'he Station Manager said his review of the draf t letter showed him there could have been a third weak section me~ntioned and that he

            .had made a comment to that effect; having done so, unen the August 3, 1979
            . letter was presented to him, he said he signed it. The Station Manager denied that there was any intent on-his part to submit a document which would
           - knowingly mislead the NRC in the matter of the licensing of the SRO.

Interviews were conducted of those listed on the letter's distribution list. Most stated they did not see or had no recollection of seeing the August 3rd letter before it was sent to the NRC; one individual felt he murt have seen it, but added_that he would not have paid any special attention to the grades , contained in the letter. Interviews were conducted of the NRC Staff, including present and former members of the Operator Licensing Branch (OLB). The present Chief of the OLB, who said he regarded the SRO's actions in submitting another's work in fulfillment of his training obligations-as cheating, explained that because~ '

l l l AP-1006 was instituted in fulfillment of 10 CFR 50.54, the procedure had the effect df a regulation and the licensee's certification letter was therefore a requirement and not a voluntary notification; ~He also said that the infor-mation contained in the licensee's August 3rd letter.was, in his opinion, 3 material to the SRO's continuing to hold or renew his NRC license. An OLS l staff member was asked to review the SRO's accelerated requalification program (ARP). After he had reviewed it, he stated that, in his opinion, the ARP did , not adequately cover the individual's identified weak areas. The former Chief of the OLB stated that had he known what had actually happened relative to the SRO's requalification program, he would have taken some action other than  ; auto =atic' renewal of his license when it came up for renewal in November 1979. ' O e 9 e S e 4 1

0 5'c w SANITIZED VERSION I 3 .,., h NUCLEAR RE U R a j wA SMNG TON. D. C. 20555

       *N;'nh*l.
        \ O l df/fD'EOFINVESTICATIONS DATE: March 21, 1983 REPORT OF INVESTIGATION TITLE:

Three Mile Island Nuclear Generating Station: Allegations Regarding Material False Statement SUPPLEMENTAL: Docket No. 50-289 CASE NLYBER: H-82-002 CONTROL OFFICE: OI:HQ STATUS: CLOSED REPORTING OFFICE: OI:HQ STATUS: CLOS ED PERIOD OF INVESTICATION: September 27, 1982 - December 1, 1982 REPORTING INVESTIGATOR: ( , s, 3 // f.3 te E. Taci, W ior Investigator

  • Div sion of Field Operations Office of Investigations PARTICIPATING PERSOSNEL: Edvard C. Gilbert, Senior Investigator
   "                                 Division of Field Operations Office of Investigations R. Keith Christcpher, Director OI Field Office, RI Office of Investigations REVIEWED BY:                 /       M/       f/ /[ L'/
                                    'Widliam J. Vard, Direct'r'     o                         -

Division of Field Operations Office of Investigation,s

                                         )   ,,    ! h :',        's~        ,,

Roge r., A. Fortuna, A ting Deputy Director Office of ve ai 'ons APPROVED BY: daf Be'n B. Hayes , Wec[or T/f/!PS' Office of Investigations j

                  - PURPOSE.0F INVESTICA7,JN This investigation was undertaken to investigate allegations that a senior member of the licensee's management staff made a material false statement to the NRC. The statement in question concerned the eligibility of a second
                                                         ~

manager to retain his NRC license as Senior Reactor Operator, t

        ^

0 9

  • O E
            '   e W

e-t-

IACT. CRC"53 Curing -he July 195L invas: iga:ic inte chea:ing c: cpera:c: licensing exa:- 2 ~ ~

                 ~
                ~#         ina:1c=s (HQS-51-003), :he licensee ~ advised :he NRC 1ha: cie ~e? the "suspec$s~ ,~ ~ ~

lhadbeeninvolvedinanincide:: 1: 1979 in which he had p crid-ed 'ansvers to an individual ce:ple:ing se:e :akeup cui::es fer Traini:g. Since :he individual (who was identified as Ja:es R. TLCYD Superviser of Opera:icas, !MI Uni: '

2) was reper:edly reassigned to n'en-licensed de:ies and his cer:ifica: ion to the NAC had not.ye: been b cush: in:o cues:1c:, :he issue was ne: direc:ly addressed during :he July 1981 invas:igation.

Duri:s the A:c=1e Saf,e:y and Licensing 3 card (ASL3) Hearings (en IMI-Uni:' 1) in the Fall of 1981, the licensee's certifica:1c cf TLO!D to the NRC ca=a under scrutiny. In his repc : da:ed January 28, 1982, Special Master Gary

                    ~MILECLLIN concluded :ha: sta:e:ents =ade by a =e:bar of the licensee's
                       =anage:en: staff care ince=;1r.:e and inaccurate. Specifically, his cencer:

vas :ha: S:a:1:n Manage: Cary M:iLIR in his le::e: da:ed Augus: 3, 1979 had

                    .cer:ified :o :he NRC cha: FLOYD had satisfae:erily ec=pleted an A2P (accelera:ed requalifica:ica pecgra:) and received a secre cf 99.8%; fur:her,
ht:

M:LLER had a:::ibuted a secre cf 89.1% te FLCYD, kncving tha: :he grade represen:ed :he ec bined effer:s cf TLOYD and

                      *                                                                               {eIn a =e:crandu: dated
                    ..une 23, 1952, Ear:1d R. OINTON, Direc:c: ef :he Cifice of Nuclear Reac:::.

Regula:ics, reques:ed tha: the Office of Invas:1ga:icns (OI) lock in:e Judge

                              . .s. ...,. < s . . . . e .. .

( v . .u. .- i i In 1:s Far:ial ::1:ial Decision (?ID) ccacerning TX: L* i: 1 (dated July 27, 1952), :he ASL3 c::cluded : hat the licensee's Augus: 3, 1979 le::er was "a false za:erial s:a:e en: to the NRC" and recues,:ed :ha: a: invas:igatiet be cenducted into M*LLER's represen:a:ica to :he NRC. :: its

                                                                                                               =e= ora:du: and 0 dar (CLI-82-31) dated Oc:che: 14, 1952, the C:==issi:n agreed vi:h :he ASL3
ha: :here was reasonable cause to inqui:e ft :her in:: :he =a::e and direc:ed CI, which had already cc :enced its investiga:ica, to p cvide 1:s findings, when available, ce :he Office cf Inspection and Enforce =en: (:Z),

l a bh .=G G G wM . e d O

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                                         .         .  .       C2 CONT TED 1 A?30b,RobertC.2                                        ==-

Vice ?residen: (Genera:ict), GPU ~ ~ ~ ~ v Service Ccrporatien. EECKEAK, Dc H.3

  • Chief, Opera:c Licensing Branch, USNEC (Current assign =en:)

EEEKS, Marshall L.' Superviser of Licensed I:aining. 15LAKI, Ernes: L. A :cr ey, Shaw, Pitt:an, ?ct:s & T:cubridge. 30GER, Bruce 3 Operater Licensing Exa:iner, Opera:c Licensing Branch, USNRC. 30LIZ, Dennis J. Ad:inistra:c cf Nuclear Technical

          .' .                                                                      Training (Instrue:cr).

310%N, Nelsen D. Ad inistrater cf Nuclear' Technical

      ~

Trai:ing (Instrue:cr). COLLINS, Paul Ferrer Chief, Operator Licensing 3:anch, USNRC. CE7AS!"iK, Jeseph J. Acting Superviser cf Operatic s, TM! Unit 2 (effec'ive CS/20/7s). FLCY3. Ja es R. SupddE6db: cf Opera:1 cts, IMI Uni: 2 (replaced c: Oc/20/79 by CHWAS!!K).

                    ??.ET E1 : , Edvard T..

s Adr.inistra.cr cf Naclet: Technical Training (!:strecter). EERII N, Jch: G.# f Vice ?:esident for Nuclear C; era:icts, so TM1 Genera:1c C: cup. i. C-ECM3 ACE, The:as L. Persc el Direc:c: fc: IM . - LARYER, Lavrence L. . Manager of Trai:ing. I I M LLER, Gary ?.8 l l S:atic: Manager. Units 1 and 2. ' i 9 9 3_ 0

l PARKER, William H. Supervisor of Administration. TMI. SE .INGER, James 9

                                                           ~~ Unit ~21 Sup'erintendent.         ~~
                                                                                        ~

SPEAKER, Fred 10 < Former Attorney General, Commonwealth of Pennsylvania. { TROEBLIGER, James 3

                ,                                           Acting Area Manager of Human Resources, CPU Nuclear Nuclear Corporation.

ZECEMAN, Richard,W. Supervisor of Training. NOTES: (1) Titles given are generally those provided by the individuals themselves; in some cases they may vary slightly from titles attributed to them by others during the investigation. Unless otherwise indicated, the positions listed are those held by the individuals at the time of events in question (July / August 1979). (2) First line supervisor of HERBEIN. (3) Current position. . (4) No longer employed by Met Ed or GPU. (5) No longer employed by USNRC. (6) Not interviewed during the course of this investigation. (7) First line supervisor of MILLER; no longer employed by GPU Nuclear Corporation. (8) No longer employed by GPU Nuclear Corporation. (9) No longer employed by Met Ed or GPU and not interviewed during the course of this investigation. (10) Conducted GPU probe into subject matter of instant investigation.

EF

NT EV IV CF DENNIS J. ICLIZ '

30_* TZ, curren:ly e ;1cyed by Me: Ed/G?U as the Supervise: ef Si=ula::: :g ingfa: Three Mile Island (IM:), was in:erviewed en Oc:che: igators ?.E._3aci and E.C. Gilber: a :he TMI Ifficing Ces:er. 5, 1982 by Inves:- 3CL!Z said he has been 4=;1oyed-by Me: Ed/G?U since 1968 and :ha: he was assigned as a Ad inistrater August of Nuclear Technical Training (ins: uc:c ) during the ;ely 1979 :L=efra:e. . (A::ach:en: SCLTZ volu :arily ;;cvided a signed, svern sta:emen: 'l 1.) which contains the felleving infc :atica it substance: ICL!Z said :ha: in 1977/78, Uni: Ja=es R. TLCY3 (then Supervisor of Opera:icts , TMI

2) had ::aining deficiencies which resul:ed in his bei.g 'requi:ed to participate in a special per:ica cf the nex:

de explained :ha: cc=pany requalificatien ;;egra=.

      .     .                            the ;: gra= van kneen as Tunda=entals and Sys:e s Reviev (FSR) and that assign =en to it was an au:c=atic process.
             .3 LTI explained that assign =ents f :

p cgra: an 1:dividual par:icipa:ing in the FSR , vould be ;;epared by as ins: rue:c:; if :he individual attended classes, 30LTZ said he. veuld be given a v:it:en exa: which votid include addittenal ques:iens in his weak areas bayend these given to c her class

              =e:bers.

SOLTZ said tha: since TLCY3 did no: attend classes, he was sen:

             =ake-up exa=s which covered nis deficient areas.
He centinued that TLGID did re: urn the =ake-up assign =ents and they vera st * :

to hi= a secend :ize. A::c: ding :o ICLTZ, TLOYD finally sub:itted his TSR =ake-up qui::es in *uly 1979 (A::ach en: 2). 3CLIZ said a: tha :ize, either he c ane:her a ins::ue:er, Edvard R. ??.EDIRICK, disc:vered tha: L a: lets: e ene cf FLCY:'s exa=s c:::ained ansvers in the handuri:ing cfl ,J(thenaShif Sup e rvise:) . 3CLTZ con:inued tha: ei:her he c: FRICE?.10E i==ediate'y re;c :ed . the =atter to Supervise: cf Training ?.ichard W. ZECEMAS. Ac:c: ding to SCLTZ, he fel: TLOY2's C ac:icts cens:1:::ed cheating and :ha: the ext:s sub=1::ed by 7LOY3 cen:ainingi ' handwriting vere unaccep:a':le. He said his recollectica vas,:ha: those in Training who were aware of the ta::e: aise felt that FLOYD vas v:eng. 6 e

BOLTZ said that the decision to assign FLOYD to an accelerated requalification program (ARP) did not involve him an'd opined "that it was probably made in meetings involving higher level management such as Cary MILLER (then Station Manager) and ZECHMAN." He added, however, that he might have contributed to developing some of the ARP work assignments based upon what others decided needed to be covered. BOLTZ said he recalled that FLOYD was removed from all licensed duties and assigned to the. Training Department on a full-time basis. He continued that FLOYD spent "c.uite a bit of time" in his (BOLTZ') office and said that during

                      ~

those meetings Category A (reactor theory) material was discussed. When advised that MILLER had said FLOYD was orally tested on Category A material. BOLTZ opined that he'(MILLER) was referring to "the many discussions FLOYD and

            -[BOLTZ) had in [his) office when [FLOYD] was assigned to Training."
 '           BOLTZ stated that FLOYD was very competent in the area of reactor theory and .

' was one of his (BOLTZ') primary sources when he (BOLTZ) had a question in that area. BOLTZ averred that FLOYD's poor performance in the Category A area was not because he didn't know the material. BOLTZ said that at the conclusion of the ARP, FLOYD passed a comprehensive written examination which he (BOLTZ) prepared, proctored and graded (Attach-ment 3). Upon reviewing the exam for the investigators, BOLTZ identified certain questions which he felt covered or involved Category A material (Questions 2[a] and [b]; 3(a} and [b]; 4(a} and [b]) and opined that he would not have included those areas on the exam if he hadn't been told that they were among FLOYD's weak areas and needed to be covered. BOLTZ, who was not on the distribution list for MILLER's August 3, 1979 certification letter to the NRC (Attachment 4), said he recalled some discus-sion concerning the grades in the letter which took place some time after it had been sent. He said he thought the discussion concerned the way the grades were averaged but added that ha was not sure. e e-- ---- - - - - ,e-- , , - - . . ,, --,.-----# .-- --- - - - - - -v.v,.-- + , -, - - , - , . -

Afier reading :he Augus: 2:d le: der, 3CLIZ said he could effe:

expigna.g ,,

fe: :he 59.1% grade c: Ca:eg ry A which a;;ea:s in the le::e vas fincluded regardless of how i: vas at:1ved at. c:her tha: 1: explain why the le :e caly referred Oc : He also sa'd he eeu;; : Vo vaak areas instead cf the three T1:!3 ac:ually had.

             " hen 1: vas ;cin:ed cc: to IOL:: :ha:

Ad=1:is::a:ive ?::cedure 1005 (A?-1006) calls fer epen c: clesed beek vri::en ext:s c TSR areas and that the exa:s are to be given either in class or c shif , SOL:Z said that he c:es'dered an ca-shif: exa: :o be the equivale:: cf a take-he:e exa=. He explained tha: be:h were given c: the heter systa=, withou: any prec:c: being present. 3CL I said : hat "we veuld have no objectics" if se:ecte vanced to ecuplete the ex a: he:e., bu: added tha: they ceuld no: direct anyone to do so withcu: :he unic requiring pay fer bargaining unit :e:be:s. 30*_T* vas sheen a~ce;y cf a ee:::ar.du: frc: IICEMAN :: TLOYD dated July 1 1974 (A::ach:en: 5). The dect ent, which 30LTI said he c uld to: recall having seen befcre, asks that TLOY3 rede his 751 assign =ent for Categcry A

he reques: ef X:LLIR. .301:Z s:a:ed :ha: he c uld :: explain the ra:1 :a'e behind X *. LIE's reques: :ha:

FLCYO rede his Ca:eg:ry A assign =en: and added tha: he did ::: kt:v if :he verk vas ever cc:;1e:ed by ?~ 0Y3. 20*!",: ld :..e invas: ga: cts tha: ne was :: aware cf any pressure c: reques: en;edi:e FLOYO :h:cugh his ARP because his license was needed and added

         ..a.
         .. . .. .      .u.e .es. c.a
                               .   .      u... ss r.. . . . , e 2. . . . . g e , .-. .n. s,
                                                                                            .as    .. ..<
                                                                                                   .. .... a. e.a <__   <.e se.a ...
                                                                                                                         . . . .        <es subsequan: :: his Al?.                                                                                                      ....

25"I57"CA! E'S NOTI: A': a cepy of TLCY3's Category A FSR qui:.the cenclusion of. he in:arviev, 30L

                                                                                                 ~he ext =, which included v::k as well as tha: cf TLOYD, received a grade of 59.1%. 30L;; das~"" 2 asked caly        :c reviev FLCY3's      verkthe   c exa:              to see if :he 59 ': se::e did, in f ae:, reflec:'
he test.
                           ' ;u:, FLOYD vould have received                         ICL! ' arev'evgrade cfindi:::ed 54.2%. :ha:          vi:h:::

This same request a;; ears wastha: subsecuently =ade of ane:her ins::ue:::, Nelsen 3RG"h*.

                                        .                                                                                                 I:
1y the questic s ac:cally cc:;leted by TLOYO.3C*!Z zisunders: cod :

1.f ques: ten'ng was direc:ed :crards de:ernining if TLOYO's c: rec:The investig ansvers, 59.!: grade. when :aken alene, vould have bee: sufficient :o achieve :he Whe 3RC7N reviewed :he exa=, he said :ha: TLOYD veuld have fa:'.ed vi:heu: the it;ut f:c: C O

                    .N . r..1r_ _~ Oe rD. r_ 3 p.. :. :.._rg e: t CK -

7:edarick, currently a: ployed by Me:-Id as Superviser cf Non-licensed - Training, was interviewed c: Oc:eber'5,~1982 by Invas:1ga:c s P.I. Iaci and I. C. ' Cilb er: a: the Three Mile Island (TMI) Training Cen:er. FRI;II :K said he has been e:picyed by Me:-Id since 1973 and that he was a ::aining ins: rue:er during the July-Augus: 1979 :1:sfra:e. FRIDIRICK velun:arily

                  ;;cvided a signed, svern sta:e en: (A::achten:
6) which cc :ains the fc_*
  • cving infer:atica in subs:ance:

l l 1 t

                 ?AI IIICK related that en or abou: July 2, 1979 he received Ja=es R. FLOYD's

(: hen Supervisor of Operatic:s, IXI Uni: 2) Funda:en:als and'Systa:s Review - (TSR) ext:ina:icns for gradi:g (A::ach=en: 2). de centinued that while

            ~

grading the exa=1:a:1cus, he noted tha: the handwri:ing differed on :ve cf t h e:. .

               ~

FRI:IRICK said he was fc=iliar with FLCTD's handwri:ing and ne: iced

    .            ; hat parts of eve cf :he'exa:s appeared to have been vri::en by TLOYD while c:her par:s appeared to be in a differen: handeri:ing. According :o                               -

7EI;II CK, he suspec:ed :ha: the seccad handwri:ing was tha: of (then a Shif: Supervise ). lf FRICIRICK said he : hen ven: to see anc her ., ins::ue:c:, Oennis J. ICLTZ, who verified :ha: :he secc:d handwriting en :he ext:ina:icas balenged to v' Acccediag ce TF.IDIE CK, he aisu vent :e see Richa:e k*. IICEMAS (tne Supervise: cf Training) cencerning ILOYD's exa:isa:1 ens. FKIIII:CK reccun:ed

' :: IICEF.AN appeared cencerned and asked hi: :: finish grading all :he exar.ina:1: s. FEI;IRICK sta:ed : hat while he graded all :he tests and 9

recc:ded the~fac: : hat TLOYD had sub=1::ed the:.: 7:aining, he did =ct ec: sider these exa:s which cc=:ained :ve differen: handwri:ings as acceptably i . fulfilling FLOYD's ::aining chliga:icas. He ec :inued :ha: upcn c: ple: ten cf

he grading, he turned :he exa s ever :e ZICEMAN vhc teld hi: :ha: he veuld
             " handle it f:c: there." FRIDIRICK said tha: :his represen:ed the end of his invclve=en: in the ca::er.

1

I When f asked if he regarded FLOYD's actions as cheating, FREDERICK replied in l the affirmative and said it was for that" reason ~he_ b.iongh.. - . . . . . . .

    .                             of ZEC11 MAN t it to the~ attention - -. -

D

      -(.

__ es e

                  ' 9
          '           *     .c                                                                                       p
  • 6 9

e w 9-

                                                                       -                                     I
   .      ' INTERVIEN OF NELSON D. BROW          ,

BROW, c arrently employed by Met Ed/GPU as Supervisor of Licensed Operator - Training at Three Mile Island (TMI), was -interviewed on October 5,1982 by Investigators P.E. Baci and E.C. Gilbert at the TMI Training Center. BROW said,that he held the position of Administrator of Nuclear Technical Training j I (instructor) "during the period of the FLOYD incident in July 1979." BROWN-voluntarily provided a signed, sworn statement (Attachment 7) which contains the following information in substance: BROW said that as a result of examinations given in.'1977 and 1978, James R. FLOYD (then Supervisor. of Operations. TMI Unit 2) was found to be deficione in certain categories as defined in company-Administrative Procedure 1006 (AP-1006 is int tded as Attachment 8). According to BROW, FLOYD was obliged ed participar a. training program which was structured to cover areas of demonstrated weakness.

  • INVESTICATOR'S NOTE: This special training was knowd as Fundamentals and
               . Systems Review (FSR) .

BROW said he recalled at least_ two of FLOYD's weak areas and identified them

           .as Categories A/M (reactor theory) and K (fuel handling and core parameters).                    ,

He continued that several months after the TMI accident,.it was determined

           .that FLOYD had not returned the examinations (Attachment 2) associated with his training program and he (FLOYD) was so notified.
  • BROW said that when FLOYD did submit his examinations, he (BROW), another instructor, Dennis J. BOLTZ, or someone else discovered that part of the material submitted was not in FLOYD's handwriting. According to BROW, he was "very surprised and shocked that FLOYD would have obtained help from ,

someone else." He opined -that FLOYD "probably obtained assistance because he lacked the time to complete the work himself" and added that it was " difficult  ;

            .for,(him] to classify this incident as cheating since FLOYD could have comple-                  f ted the questions himself had he devoted the time." BROW stated, however,                       l i

that he " consider (ed] (FLOYD's] actions unethical and unacceptable and (faltj I they were quite properly brought to the attention of appropriate supervisorf  ; i personnel." 1

IRC'4; vas shewn cepies cf T;OYD's accelerated requalifica:ien p g:g: (Agy) and :he ec=prehensive ext:ina:ics given at tha'conclusien (A::ach en: 3). IRCUN said that 1:e:s (1) and (2) en the AEP and questiens 2,3 and 4 en the exa= ei: hor related ec c: required an understanding of reae:c theery (Cate-gory A/E). After reviewing the AE? and ext: vich the investiga:::s, IRCWN said he fel: ":ha: their successful cc ;1stics represen:s an adequate de::n-s::a:ic cf cc:;etence in the area of reac:c: theery." 3RCVN, who was not en the distributien list for MILLIR's (Gary P. MILLER, then S:a:ica Manager, Units 1 and 2) Augus: 3, 1979 certifica:icn let:e to the NRC (At:ach=en: 4), stated that ha first saw the letter subsequent to the Fall 1981 Eearings (IMI Restar: Hearings, Atetic Safety and Licensing Beard, Eanrisburg, Pennsylva:ia) and was sur;;ised that only two of TLCYD's three vaak areas ve:e identified. 3RCWN said he also questioned the validity of listing :he 89.1% secre in tjie le::e: since 1: re; esen:ed the joint efferts

   'ef,TLCYD and                                                                                           .
           .a . ..
                .....S-. .iun e ..N...n - :   -.
C,.'D vas requ, red ec train and be exa:ined in a
:a1 of feu: ?SR sections. FLCYD received :ve passing (8C: c: abeve) and vo f ailing grades c his FSR qui::es. One passing grade (89.1% cc Categcry A c: Reac:c: Theory) and one failing grade (64 en Category H c:

upcn he Tual suizissien Eandling cf * >"hg. wc:k.e Parace:ers) After 3RCWN were hadeach based provided his in par: to the sta:e:en: knvas: iga:c:s, he was asked to review TLOYD's Categery A FSR qui: c assess whe:he FLOYD's cc::ect ansvers, when censidered alene and witheu: lb inpu:, v uld have been sufficien: := achieve :he 89.1% grade. - 3.:.;WN said :ha: TLCY3 veuld have f ailed vi:h::: :he inpu: f :: -- 4 e

In I?X:I'J CT MARSEALL L. 3EIRS IIIRS, va's interviewed en Oc:ober 1 and 4,1982 by Investigators P.I. 3aci and -~~ "

                                                                            ~

I.C. Gilbert at the NRC Office c Three~ Mile Island (!MI).' '3IIRS, who was e: ployed by Met Id/GPU as Superviser of Licensed Trair.ing during the July-Augus: 1979 ti=efra=e, has since left the Cc=pany's e=pley. IIIRS volun:::tly previded a signed, svern sta:e=en: (A::ach en: 9) which cen:ains the felieving infer =a:1cn in subs:ance: III?.S said that shortly af ter Ja:es R. FLCYD (: hen Supervise: cf Opera:icns, TM! Uni: 2) sub=it:ed his FSR (Funda=en:als and Systa=s Review) exa=s (A::ach=en: 2) for grading in July 1979, either Idvard R. FR DIRICK c: Dennis J. 30LTZ (then Ad=inis::aters of Nuclear Technical Traini:s c: "instrue:ers")

     ,      .: eld h1= of sc=e apparent i=proprie:ies in FLOYD's quizzes. 3IIRS centinued that his recollection was that at least one of FLCYD's exa=s appeared to have Eeen vri::en in ye diffe en: handv=itings.,

A:::: ding :o 3EIRS, he van: to see Supervisor cf Training Richard 'J. ZICEMAN and discussed the situatien vi h ht=. He added that he also discussed :he pr:ble: with the Statien Manager, Ca'y P. MILLIR, al heugh he said he could n:: re:e=ber if this occurred during a =ee:ing, via telephens c be:h. IIIRS said that because TLCYD had :ve c: =:re~ areas en the FST. quizzes in which he se :ed less then 80%, he was re=:ved f: = all licensed duties and placed is an accelera:ed requalifica:icn pr:gra= (A::ach:en: 3). Acc: ding to III?.S :he accelera:ed requalifica:icn pregra (AR2) c vered all cf FLCYD'.s

           .veak areas and was prepared by 30LTZ, Nelsen D. 3RC*a3 (ane:her ins::ue:c:) and hi:self.       3EIRS said FLOYD passed a cc:prehensive vri::en exa=ina:ica (A::ach=ent 3) a: the cenclusien of the ARJ vhi:h covered all of his deficies:

areas, including Category A. IIIES explained tha: Categ::y A vas a se::1:n en FLCT3's ?SR exa= en which he received a grade of 89.1%; h vever, he added :ha: this grade was par:ially based upen the sub=issien of ar.svers p;cvided by u N. e

                                                          - 12 .
      .. _           .-     = . . . - - . . . - . -     - --   - - - . . .

b

c T . INVES!! GATOR'S NOTE: his FSK exa:s which vere par:ially cc:pleted byt?LOYOac:uallyhad-tr b 0:e ei :3 gue~ sec:icas grade received a failing gra_de of 64: While the c:her vas~ assigned a '~~ of 89.1%. areas is.his . Since FLOYD vas -clearly require'd' io ~ address f ailing received with Cassistance and hev tha:a :en ien generally fccused en :he p deficiet: area was addressed. IIIRS:vas sheva a cepy of a ====:andu: da ed July 6, 1979 fre: IICEMAN te TLO?D (A::ach:ent 10). IIIRS said he did =c: k cv vho'had drafted the me:::. andu=, which discussed FLCYD's ARP, and could effer no expla:ation as to why 1: caly addressed the :vo (FSR) areas in which TLCTU had scored less the 50%. IIIRS said again.cha: he, IICEMAN, IOL Z and IROWN all had input i-

               " drawing up the AR? f or TLOYD."

IIIRS vas sheen a copy of a seccad =e=crandu: f c: ZICEMAN te FLOYD, dated July 11, 1979 (A::ach=ent 5). IIIRS acksceledged that he was the author cf this de:::en: bu: said he could ne: re:e:bar who had asked hi:

       , , 15IRSsaid:ha: th s'                                                              to   prepa:e 1:.
 "                                       =e=o vas "chvicusly written at the request of MILLIR al:heugh (he could ne:) reme=ber whe:her he personally asked (hi=) te write J
             .t . E9 INVIS!!OATOR'S NCTI: The July 11,1979 =e:crandu= referenced "!M79-18" and s: aced that in addition t: the assign =en:s made as part of 7LOY 's A32, FLOYD vas also requested te rede :he Category A FSR assign =en:. The ze:::andu: centinued tha: the ext vas a:: ached fe FLOYD 's use and cen:luded by saying tha: this ex::a v :k vas "a: the reques cf G.?.

M *.LII to insu:e validi:y.cf this see:1:n of FSR." 1: sheuld be :::ed

2:
                             "!M79-18" *::s sp;2:en:ly an in::: rect rafarenes since :he d::c:an:

Rad :::hing te de vi:h TLOYD, his ISR ext:s c his AR?. The 1:ves: iga:ict did to: reveal any writ:en reques: asking :ha: FLOYD rede his,Categ: y A ISR assignment.fr:: M:*LIR :o :aining IIIRS said he ceuld =c: re=e:bar if "a fer:al =e:c f::= M LLIA vas respcasible fe: generating the 7/11/79 =e o to TLOYD" and added : hat he did "no: know if

         .?LOTO ever redid the Catagery A FSR assign =en: as reques:ed." IIIRS said he ceuld not explain MILLER's ra:icnale in asking FLCYD to red: Categcry A unles's i: .vas jus:-:o tie up "Icese ends."

IIIRS advised the investigators that he was author of a handwritten draf:, da:e:* July 26, 1979, f:c: MILLER to Paul COLL NS cf :he NRC (A::ach:ent 11). He cc :inued that ner= ally :he~ individual in charge cf ::aining (ZICEMAS) 4 e

would prepara such letters, but. added. that ZECEMAN was himself in _ training at------- the ' time so the task fell to him-4-According'to' BEERS,~ the~ intent of the letter was to advise the NRC that FLOYD has successfully completed the ARP. He acknowledged, however, that' the July 26th handwritten draft, the July 27, 1979 typewritten draf t (Attachment 12) and the August 3, 1979 letter (Attachment 4) sent to the NRC all v.ated that FLOYD was put in the ARP because he received two scores below 80%. He said it was unfortunate that the letters, especially the final letter (which BEERS said he did not prepare), did not state that FLOYD had received a total of three scores less then 80%. BEERS said that he did not see the final letter (August 3,1979) before it vent out but added that if he had, the cited grades would have been

            " irrelevant in light of the fact that the ARP covered all (of FLOYD's]
          , deficient areas." When asked why the August-3rd letter only addressed two
    ,      deficient areas, BEERS proffered the explanation that Administrative Procedure 1006 (Attachment 8) called for the ARP when two or = ore grades were below 80%
  • and that the letter was explaining to the reader that two such scores require participation in an ARP.
                  -INTERVIEW OF RICHARD W. ZECHMAN      _ _      ,_ _ _ _ _            1 ZEChMAN,currentlyemployedasTecEn'icianTrainingManageratThreeMile
                 - Island, (TMI) was interviewed on October 5,1982 by Investigators P.E. Baci and E.C. Cilbert.at the TMI Training Center. .ZECHMAN said he has been employed by~ Met Ed since 1969 and that he held the position of Supervisor of Training during the July-August 1979 timeframe.

ZECEMAN voluntarily provided a signed, sworn statement (Attach' ment

13) which contains the following infor-mation in substance:

ZECEMAN said that as a result of grades received on two company examinations

                .during 1977 and 1978, James R. FLOYD (then Supervisor of Operations, TMI Unit
           . 2) was' required to participate in a special training program known as Funda-mentals and Systems Review (FSR). He continued that the requirement was contained in Administrative Procedure 1006 (AP-1006) a company procedure instituted in co'apliance with NRC regulations (Attachment 8).

According to ZECHMAN,.FLOYD was required to train in a total of four FSR sections. ZECEMAN said that performance-on FSR assignments is determined by

                " written evaluation quizzes" which may be " administered in either closed or open book format and as classroom or on-shift exams."

ZECEMAN stated that in early July 1979, Marshall BEERS (described by ZECEMAN

 *     '       as Group Supervisor, Training) advised him that FLOYD had scored less than 80%
          " on two sections of his (FLOYD's) FSR exams (Attachment                         2). to According ZECEMAN, this meant that FLOYD would have to be removed from operations and assigned full time to an accelerated requalification program (ARP).

{ ZECHMAN said that at about the same time, he learned that all of FLOYD's written quizzes were not in the same handwriting. He said his recollection was that Edward R. FREDERICK (then an instructor or Administrator of Nucle Technical Training) discovered the discrepancy in the handwriting and reported it to BEERS; BEERS then advised him. ZECEMAN said he immediately reported the matter to James SEELINGER (Unit 1 Superintendent) and it was his (ZECEMAN's) understanding that SEELINGER then advised Station Manager Gary P. MILLER. l

Acce: ding :: II!EMAN, his nex: re :llectics was of a :elephene ccaversa:ica vi:h M!L* 'o Il in which MI*'IR :old hi= he was aware cf :he ?LCYD incide:: and vas :aking full respensibili:y for :he'invas: iga:ics. He added tha: MILLII la:e: ec fir =ed the suspiciens ceneersing the :vo differen: hat .. sc< 1 g,^e_- FLOYD's exa=s and said that TLOYD had obtained se e ansvers f :: _

                                                                                                            ]O v

M ZI:EMAN s:a:ed :ha: he prepared a ce:crandu: to F*0!D, dated July 6, 1979, which described :he accelera:ed ::aining pr:gra: (A?J) which had been prepared for FLOYD by 3IIRS (A::ach:en: 10). He centinued :ha: the =e:crandu: cu: lined the assign =ents, discussicus and vri::en exa:ina:10: which veuld be required of TLO'iD. ZICEMAN said that in re: respect, it was regre:able that his July 6:h ce:6:andu: culy addressed the fact that TLOYD received less than 8C: c: two TSR requalifica:1c qui::es. He acksculedged tha: :he le::e did ac: explici:1y s:a:e tha: TLCYD's qui: c Category A, in which he received a grade cf 89.1% was also unacceptable because he (FLOYD) had sub=1::ed se=eene else's

                  .                                                                                            =

v0:K.

N"I!!!CATCR'S NOTE: As =entiened earlier, FLOYD vas required te ::at:

and be ext:ined in a total of f:ur FSR secticas. TLOYD received :ve passing (80* cr abeve) and :ve failing grades c: his TSR qui::es. One passing grade (89.1* :: CA:egcry A cr Reac:c: Theery) a:d c e failing grade (64* c Ca:escry H c: Tuel Han(LLEs.and Cere Para:e:ers) were each based in par: upe :he sub:issi:: o f- verk. CW TIC'-:M*.T des:ribsd a ^::etin- he at:t:ded in M:* LII'm Office c

.sbeu: Ju_'y 9,
           '979.            Accc: ding :o ZICEMlN, :he =ee:ing vas a:: ended by hi=se*f, MIL *_IR and Th::as L. ECM3 ACE (:he: Fe:sennel Direc::: f:r IM:). He ec :inued tha: he was
;:esen: f: :he whole ti=e but said he was teld :ha: TLCY3 was being relieved ef his epera:Lenal esponsibilities and assigned :e !:at:ing en a full :i e basis until he finished :he (AES) p cgra: and passed a: exa: c the veai. areas identified. ZICEMAN said tha: ":hese included the :ve 751 see:1: s in which he scored less than 80* and :he ene he sub:i::ed using s::e ef( ,

CJ

        =a:erial."

ZICEMAN vas asked te explain :he ra:10: ale behind a ze:::andus he see: :o O F'CYD c: July 11, 1979 (A::ach:en: 5). The =e:::andu: asked tha: TLCYD rede s e 4

his Category A assign =ent at the request of Gary MILLER. ZECHMAN said he ! c5uld not recall whether his memorandum was the resu request but added that he believed it came from MILLER by way of BEERS . ZECHMAN stated that he did not know whether or not FLOYD ever complet d e and

                   . returned the assignment provided to him via the July lith memorandum.

said that, in retrospect, ZECHMAN the July lith memorandum made no sense because AP-1006 did not: call for an individual to redo deficient FSR sections; rather it.provided that he be assigned to an ARP. , He continued that since FLOYD's Category A FSR quiz was a deficient area and he (FLOYD)eenhad already b assigned to an ARP, having FLOYD redo the Category A assignment would have

             -     served no useful purpose and he, ZECh3AN, could not explain MILLER's reason for asking that FLOYD do so.
               - ZECHMAN stated 'that he regarded FLOYD's actions in Csubmitting                                                     answers on the FSR exams as cheating; further, he said that Section A as                                                   m sub ted byit '

FLOYD on his FSR exam was completedly unacceptable, both to him and the Training Department. ZECHMAN was shown a copy of a letter dated August 3, 1979 from to Gary MILLE the NRC which certified FLOYD's satisfactory rating upon completion of his ARP (Attachment 4). l INVESTICATOR'S NOTE: 1 Administrative Procedure 1006.This certification letter was required by Met Ed provides that Specifically, Section 2.6 of AP-1006 an equivalent "whenorthe written license oral holder examination and is(2) (1) able to satisfactoril y pass satisfactory certification of his rating responsibilities is sent added)." (emphasis to the NRC, he shall resume his on-shift ZECHMAN said he could not explain why MILLER attributed theon89 1% grade ( the Categery A FSR quiz) to FLOYD since "it was well known that achieved that grade by himself." FLOYD had not ZECHMAN also said he could not explain why MILLER only identified two areas of weakness in his August 3rd letter n whe FLOYD had a total of three. ZECHMAN told the investigators that he did not see MILLER's August 3rd letter befo're it was sent to the NRC. 'AccorNngtoZECEMAN,hewassurehewould have remembered MILLER's letter, "especially the part about FLOYD only having two weak areas." He continued that he recalled reading the letter in detail only after it had become an issue with the Atomic Safety and Licensing Board (ASLB). k" hen asked if AP-1006 permitted "take-home" exams, ZECEMAN said that the procedure called for FSR quizzes to "be,given in the classroom or on shif t." He continued that they have usually been given on the honor system and that he was not aware of any problem concerning them until the FLOYD incident occurred in 1979. ZECHMAN added that he had since heard that some operators had taken the exams he:e. lihen ZECHMAN was* asked to co= ment on MILLER's testimony that FLOYD had been

    .             orally reer.asined (on Section A} by the Training Department (before Special
  • Master Gary MILE 0LLIN, ASLB, TMI Unit 1 Restart Hearings, November 17, 1981; page 24, 434-lines 20-21), he said MILLER probably based that statement upon a hasty conversation he (MILLER) had had with BEERS, Dennis J. BOLIZ (then an instructor or Administrator of Nuclear Technical Training) and himself prior.

to MILLER's 1981 testimony before the Special Master. ZECEMAN said it was his belief that MILLER was told of " oral discussions on reactor theory" that he and BOLTZ had had with FLOYD. He continued that in addition "to what we believe was oral questioning" that took place between BR0k'N (Nelson BROWN, then an instructor or Administrator of Nuclear Technical Training) and FLOYD

              , on the subject of suberitical multiplication, which according to ZECEMAN is Category A caterial, FLOYD successfully passed a written test at the conclusion of his ARP (Attachment 3) which covered all of his deficient areas, including Category A.

ZECHMAN said that no record of the discussions with_ FLOYD on Category A was maintained but pointed out to the investigators those portions of the ARP and final exam which he felt both covered and demonstrated FLOYD's understanding of Category A material.

ZECEMAN said that when FLOYD completed his ARP on or about July 23. 1979, his exak was graded by BOLTZ, reviewed by (Manager of Training) Lawrence'L. LAWYER ~ and himself and then forwarded to MILLER for certification. He continued that shortly afterwards, MILLER telephoned and thanked him "for getting FLOYD squared away." ZECHMAN said MILLER told him he (MILLER) would take care of both the follevup en the NRC as well as any further actions concerning FLOYD. I According to ZECEMAN, he had no further involvement with "the FLOYD matter and the next thing [he] heard was the news from the ' grapevine' that FLOYD had been rea,ssigned." ZECEMAN stated that prior to the Restart Hearings he had no contact with John G. HER3EIN (then Vice President for Operations, TMI Generation Group) concerning the FLOYD issue.

          -                                 He continued that he did "not know what part
   *         (HER3EIN] played, if any, in the decision to send the August 3, 1979 letter to the NRC."

ZECHFMN concluded by saying that no one, including Gary MILLER - - asked him, directly or indirectly, to shortcut, circumvent or otherwise interfere with the AP-1006 training requirements for FLOYD, because his license was needed or for any other reason. l l

INTERVIEW OF LAWRENCE L. LAWYERi g__c _ =.~emem&&:W't '"- ~~ ""

 ~

LAhYERwas'interviewedonOctober ~18, 1982 by Investigators P.E. Baci and R.K. Christopher at General Public Utilitics (GPU) Headquarters, Parsippany, N.J. LAWYER, who was employed at Three Mile Island (TMI) as the Manager of Training during the July-August 1979 timeframe, voluntarily provided a signud, sworn s'tatement (Attach =ent 14) which contains the following information in substance: LAWYER said that sometime after July 1, 1979, Richard W. ZECEMAN (then Supervisor of Training) came to him while he (LAWYER) was working nights and told him of a problem concerning James R. FLOYD (then Supervisor of Operations, IMI Unit 2). As an aside, LAWYER explained that training was not his (LAWYER's) primary function at that time and that he had other duties as

              ; well.

According to LAWYER, ZECEMAN said that one of the exams (Attachment 2) FLOYD i had taken as part of his F3R-(Fundamentals and Systems Review) " package" contained handwriting other than FLOYD's. He continued that ZECEMAN indicated he was going to notify line management of the problem although he (LAWYER)

               'didn't know to whom he went. Other than having been shown one problem exam by ZECEMAN, LAWYER said he was not familiar with FLOYD's training situation- in 1979 as it related to the number of weak FSR areas he had to redo.-

LAWYER said he felt he must have seen the certification letter dated August 3, 1979 sent by Gary MILLER (then Station Manager, Units 1 and 2) to the NRC

              '(Attachment-4). He added that he would not have paid any special attention to.the grades in the letter, but would have assumed that ZECHMAN would have inserted the appropriate grades. LAWYER said that if he had seen the passing grade "on the one problem exam [he'd] have assumed that the issue had been resolved."

Concerning the certification letter, either in draft (Attachments 11 and 12) or final form (Attachment 4), LAWYER said he would have relied upon ZECEMAN to tell him if there was any problem with the way it was written. He added that )

there was no intent on his "part to be a party to any inaccurate

                                                            ~

representation to the NRC concerning either'the grades on his (FLOYD's) exams or his qualifications to hold an NRC license." LAWYER said he "never met with or discussed the exam question or qualification / certification issue with Gary MILLER, Jim FLOYD or Jack HERBEIN ' (John G. HERBEIN. then Vice President for Nuclear Operations. TMI Generation Group)." He recalled however, that in February of 1981 or 1982, he was

 '         contacted by HER3EIN and asked if he had taken any of the records concerning FLOYD's examination when he (LAWYER) was transferred from TMI. L told HER3EIN that he had not.

LAWYER was shown a copy of a memorandum from ZECHMAN to FLOYD dated July 11 1979 (Attachment 5). In the memorandum, FLOYD.was asked to redo the Category A part of his FSR assignment to ensure its validity. LAWYER said he did not know the rationale behind the request since "it wouldn't have changed the ~ requirement that he cover that area in the ARP [ accelerated requalification program)." LAWYER concluded by stating that "with benefit of hindsight, having been told that FLOYD asked someone else to complete work for hi= which he then submitted in fulfill =ent of a training requirement, (he] would have to say that such conduct would constitute cheating in the generally accepted use of that word." e _ , - - .- - -- - - - - - - - - - ~ ' ' ~ ~ ~ ~ ~ '

l INEIECIV OF JEIS R. ?LOYD FLOYD, ,curren:1y assigned :c the Saf ety. Reviev,Gr.oup _a:,Three Mile, Island -_. . - .- . (TMI), was interviewed by Invas:1gaters I.C. Gilber: and ?.I. Baci en Oc:eber 7, 1982 at the NRC Office en Three f.ile Island. TLOYD, who was Supervisc: of-Operatices, IMI Unit 2, during the June-August 1979 ti=efrane, stated that he has.been e= ployed by Me:-Id since 1965. TLOY3 voluntarily p cvided a signed, svor$ stata=en: (A::ach=en: 15) which centains the felleving infer: :ic in substance: FLOY3 s:sted that i==ediately prior to scing en vaca:ien in late June c early July 1979, he sub=1::ed sc=a TSR (Funda=entals and Sys:e=s Review) ext =ina-tions to the Training Depar:=ent (A::ach=ent 2). Upon his return to verk en July 9,1979, FLOY3 said he rece ved a ncte f:c= Cary ?. MILLIR (then Sta ic: l {anagerc Units 1 and 2) which indicated thac MILLER vanced to see hi=. FLOY3 cet:inued that he i==ediately vent to MILLIR's office where he had a meeting vi:h MILLIR, Richard W. ZECEMAN (then Supervisor of Training) and The:as L.. - ECMIACH (: hen Persennel Direc:c: for Th2).

 .           Accc ding to FLOY3, he was ecnfren:ed with the f ac: that sc=e of the FSR r

ext ina:ic: =a:erial sub=i::ed by hi= cen:ained ane:her individual's i hand ri:ing. TLCY3 stated tha: he "readily ad:it:ed" tha,: the c:her hand-g> vri:ing was that o. u - and teld MILLIR tha: he had no: a::e:Ip:ed to " defraud anyene" but tha: he had ne: had suffi-

            "dien :i=e to ec=ple:e the exa=s hi=self.        TLOYD continued tha: MIL *IR =cid hi= his cendue: vas unaccep:able and that he vas being relieved f:c: all licensed activi:y and assigned to the Training Depa::=ent until he had sa:isf ac:crily ec=placed all training requirener.:s :o reselve his weak areas.

A1:heugh FLOYD said he had no specific reccliec:ic cf an undated =e:crandu:' l add:essed to hi= fre: MILLIR (A::achmen: 16), he added :ha: he assu=ed he had received and read :he ce=orandu: which critici:ed hi= for exercising pec: l judgenent. Si=ilarly, FLOY3 said he could no: recall having received c: read ! :ve Ee:cranda addressed to hi= f:c: ZICEMAN, dated July 6 and July 11, '979, 1 I l l 1 L

k respec.tively (Attachments 10 and 5). FLOYD acknowledged having recently read

              ~
                 'the' July 6, 1979 memorandum which' outlined the a'ccelerated training pro prepared for him, but added that this was only af ter the issues of his requalification and certification had been raised.

He continued that areas 1 and 2 of this memorandum pertained to Category A (reactor theory) and could also be applicable to Category H (fuel handling and core parameters). With respect to the July 11, 1979 L memorandum which requested that he redo th e FSR' assignment for Category A, FLOYD also acknowledged having read it recently. FLOYD said that he could not specifically recall whe~ther he had been requested to redo the Category- A assignment but assumed that he did it since it was requested. He added that it might hele h'in memorv if he co"1 A see the exam in question but that a copy has not been located.

   ~
           ~ FLOYD_ stated tha~c to the best of his knowledge he satisfactorily complete training requirements in the accelerated requalification program (ARP)                              .             He added that he could not recall whether or not he had any " sic down" sessions with training personnel to determine if all' sections or categories had been covered.

FLOYD said he took a written exam (Attachment 3) at the conclusio of the ARP and achieved a score et 99.e4. ne continued that he could not - specifically recall whether the examination covered Category A caterial. 4 When shown a copy of the examination, FLOYD identified several questions which he felt covered Category A material and stated that by achieving a score of 99.8%. that he had demonstrated his knowledge of that area. I FLOYD indicated that he was aware of the letter dated August 3, 1979 which MILLER sent to the NRC (Attachment 4). He said he received a copy of MILLER's , letter, which certified that he (FLOYD) had satisfactorily completed the ARP and obtained a score of 99.8%, after it had been sent to the NRC. FLOYD averred that he never saw a draf t of the letter before it was sent out and said that when he finally did see the letter, the possible anomoly of the 89.1% grade would not have been apparent to him since he felt the Training Department was responsible for both the conduct of the ARP and maintaining records.

                  ,                                 e                                -r

' ~ INVESTICATOR'S NOTE: FLOYD'S reference was'to one of fosr'FSR grades ~~ ' attributed to him in MILLER'S August 3, 1979 letter. Two of these grades,'89.1% and 64%, were partially based upon the input FLOYD received from .c FLOYD said he could only assume that.the inclusion of the 89.1% was a clerical error made by the Training Department or a coincidence. FLOYD stated that at about the same time he took his ARP exam, he was reassigned from his position as Supervisor of Operations to an ad hoc committee for the Accident Assessment Group. He added that he did not conside.r the transfer a punitive measure at the time but has subsequently learned that it was intended to be punitive in nature. e o I

                                                  - 24    .                .

INTERVIEW OF THOMAS L. HOMBACH On Octo,ber.6, 1982, HOMBACH was , interviewed by Investigators E.C. Gilbert and P.E. Baci at the NRC Office at Three Mile Island (TMI). HOMBACH,.who:was . c; employed by Met Ed as Personnel Director for TMI during the July-August 1979 timeframe, was advised of the purpose of the interview. HOMBACH said he had recently been advised by GPU Nuclear President, Robert C. ARNOLD, that he (HOMBACH) would be contacted by Fred SPEAKER (former Pennsyl-vania Attorney General) regarding the James R. FLOYD (former Supervisor of Operations TMI Unit 2) exam matter. HOMBACH said he made a conscious decision at the time to rely only upon his personal recollection of events rather than contacting knowledgeable individuals and reviewing pertinent documents and records. For this reason, he said he was only able to impart general information on the FLOYD issue to both SPEAKER and the NRC. HOMBACH said that his knowledge of the FLOYD problem was limited to that gained through his attendance at a meeting in Gary P. MILLER's (then Station , Manager, Units 1 and 2) office in July or August 1979. He recalled that (Supervisor of Training) Richard ZECHMAN, MILLER, FLOYD and he were present and explained that he was there in his capacity as Personnel Director for TMI. HOM3ACH said that FLOYD was confronted with the discrepancies in handwriting ' on his exams and did not deny that some of the material was not his. HOM3ACH I recalled that FLOYD's excuse for his actions was that he lacked suf ficient ti=e to complete the exams himself. He said that MILLER admonished FLOYD for inappropriate and unacceptable conduct but added that the incident was not characterized as cheating durp, d e,_ meeting. HOM3ACH could not recall whether the need for additional training was dis-  ; h cussed although he said that the need to have FLOYD retested was mentioned.- He advised the investigators that with the exception of general discussions with MILLER, he did not recall participating in any subsequent meetings or decisions regarding the matter. A Results of Interview covering the interview of HOMBACH was prepared by Investigator Gilbert and is included as Attachment (17).

                                                    - 2$ -
                           .o ... . =
               . .. . . . ;;,.      -. . C t Cr.3.v. 3. . .v.t?.?.?R i
                                                                          /

c: Cc:che: 29, 1952, . M:*~IR vas in:erviewed, under ca:h, by NRC ::ves:1gacers F.I.,Ia'ci and E.C. Gilber: a:

he'NRC* 0ffices ,*Ia chisdiPMafyliEC~f:"*
  • M:LLIR's request, his perscnal a::crney, X . Michael'~'4. MAUIIN, was presen:

during the entire interview. MILLIR, who is curren: 1y e:;1cyed by Ma::epel. 1:an Idisen (Ma: a: Id) as Direc:or of Special P cjec:s, Genera:ica, sta:ad that the time cf the incident involving Ja=as R. TLCYD (then Superviso cf C; era:icts, Uni:

2) and his TSR (Tunda:en:als and Sys:a:s Review) ext:s in July 1979, he (MILLIR) held the positien of Three Mile Island Sta ica Man fer bc:h Uni:s One and Ivo (TM:-l and TMI-2) .

MILLIR said :ha: he received his firs: indica:ica of a pro'le: b with TLOYD's exa=s f:cm Ja:es SIILINCIA (then Uni: 1 Superin:enden:) on July 2, 1979. Accc: ding to MILLIR, SIILINCIA called hi= and said tha: .. ansvers fc TLOY3 had sub:itted fcur :akeu; exa=s that sa=a day; two vara reper:edly unsa:isf ac-

    .        Ecry.andcnewasinsc=seneelse'shandwriting.

ne MI'.LIR added that neither h.e SIILINGER had seen the exa:s at :his pein: and that ha subsequen:1y learned :ha: there vare ac:: ally evo areas er exa:s which vara pa::ially in

he hande:1:ing cf se: ::e c:her than TLOY3.

M:*LIA said :ht: he notified his supervisc:, Jchn G. EIRII N (then Vi:e

           ?:asiden: fc: Nuclear C; art:1cns, IMI Generatie: C::up , via a ph::a c:nversa-o
i:n a..d a handsrt::en .c:a da:ed Jaly 3.1973 (A::ach=an: ;E ).

Z:*LIk sa.d

          '..e  cculd ne:

recall the specifig verds cf his c:nversa:ica vi:h EIEII;N, but indica:ed :he substance was that he (MILLIR) sh::1d ;;ccaad with the ra:ui:e-cents cf :he ad:ints::a:ive precedure (cca:arning TLOY3's training) and

  • hha: he shcul'd also invas: irate the handwritint.questiens.

He added that_ i t while the decisien to invas: iga:e the handeri:ing f rsue vas HER3I:N's,1: vas _ based en his race ==anda:icn. i Ac:c ding to MILLI?., his inquiry discicsed that TLOY3 had ch: tined assistance f:::CA lin ec=ple:ing several cf his ISR qui:zes. {

         ":'.LIR said while 7LOYD's ..::ic .s re;;esen:ed ;ce; judge:en: , he (K;'.'.IR) fait

( they did act ecasti:u:e a delibera:e at:e:;: :o deceive; therefore, he did ::: t i -. - - - - l i b

charae:a:1:a 7;0Y3's ccaduct as cheating. With respect te indica:ed he accep:ed his __ O Ittgg

                             -          -                              Jexplanatic: tha: ha did no: kne.-ingly.

l cceplete an exam for TLOYD. _ g ,. ~ c~ ~. ,- ' '

                                                                                           '..i         --         - - - -

M:LLIR bu: af:a recalled that ha initially rece==anded a ena-vaak suspension fo , vaeks. conferring vi:h EIR3EIN, the ;;cpesed suspensien was extended Ecbar: MILLIR said his raccliec:ica was that EIRII;N's 1::edia:a superviser t;. C. AKSOLD (:han Vice Presiden: ,

                                                                                                                                         )
                     !                                                        -Ganara:icn, GPU Service Cc:;cratice),

regarded the TLOYD incident as =cra of a superviscry p;chla:

         ,, T                                                                                          and van:ad the:

(MILLIR/EiR3I!N) :o censider a differen: actien. I

          ,        ,. fp;;a: level cen ac:                                                  MILLIR, who said tha: his                      ?

c :carning :ha TLOY3 =a: tar was EIR3IIN, added tha:

            '      u hichcugh the fir.a1 decision to :*. assign TLOY3 vas agreed upon b                                              '

i but

                   -   ..' EIR3IIN and himself, he personally had had no dialegue with A3 SOLD cha briefing of ARNOLD :o EIR3EIN.

v l MILLIR said that, in his epitien, TLOY3's raassign=en: had an adversa i en his (TLOYD's) caras: vi:h the ec=pany. He explained tha: TLOYD vas a a$;1cyeewhowas:a:cvadf:c a line positic,n. He said while there was nc l i==ediata financial 1: pac: :ssulting fec= the teva, ha fal: that TLOY3's cng-:ar= ca:aar c;;c : unities vara reduced as a result of his reassign =es: . M:LLIR acknculadged that while TLOY3 was given a latter of ad:enish:en: (A::a:h:en:

16) fe; his ";cer judge: ant," ha (M LLIR) was avara cf no decu:as:

which di:ce:ly linked TLOY3's rectaig:= ant : i . J his .cticas en the 737. qui:aes. 3y abeu: July 10, 1979, MILLER said ha had pa senally lecked at TLOY 's exams and de:arcined that thera vers :vo sectict.s helev 20% and a :hird see: ten,'. which was aheva 80%, but which had no: been ec:;1a:ed by TLOY3 alena. Ha cen:inued :ha: upcn seeing ZICEMAN's = esc:stdu: (A::ach=an: te T*.CY3, dated July 6,1979 10), which discusses TlCYD's Accelera:ad Requalifica:1cn ?:cg:t=' (AR?), he focused en the epening s:sta:en: which said TLCY3 had received :ve g;ades helev 60% en his TSR qui::es. Accc: ding :c MILLIR, he knew thera was a

hird see:1cn (:he 89.1% c Catescry A section) which had :c ha :edene because of :he " handwriting" p;chle:, ar.d ha recallad having called Supervise: cf T:aining Richard V. IICKMAS cn the phena and :alling hi: se have Ca:escry A
                                                           . .                                                                                    l i

o e

redone as well. According to MILLER, the memorandum from ZECHMAN to FLOYD

 '                   dat9d July 11, 1979 (Attachment-5);was ZECHMAN's'way of " completing-t}:e
  • requirement [he] imposed." The memorandum ~r'eportedly transmitted a copy of the Category A FSR assignment and requested that FLOYD redo the exam "at the request of G.P. MILLER to insure validity of this section of (thej FSR."

MILLER indicated chat he never gave much thought to the specifics of how FLOYD would address'the third weak area. He averred that he was merely pointing out

         '          to the Training Department that there was a third area which needed to be cov red. He continued that having since looked at the matter in detail, he now realizes that redoing the Category A FSR assignment was not the proper way to remedy,FLOYD's third area of weakness. According to MILLER, he was aware that
               - AP-1006 (Ad=inistrative Procedure 1006; Attachment 8) required a written notification to the NRC once FLOYD had complaced his program. MILLER said
           *     -that since the Training Depart =ent was also aware of the notification require-ment, they drafted a letter to the NRC and forwarded it to him. He said thah the first draf t, dated July 26, 1979, was handwritten and prepared by the Supervisor of Licensed Training, Marshall L. BEERS (Attachment 11).

According to KILLER, he wrote a note to his secretary on the second page of the handwritten draft instructing her to type a note to Ernest BLAKE, an attorney retained by the licensee. MILLER said a copy of the note was also to so.co John HER3EIN and Villiam H. PARKER (then Supervisor of Administration).

               "In the note, MILLER said that while he "only reference (d] two sections in the cakeup, [FLOYDj actually studied three due to the handwriting problem."

According to MILLER, his secretary put the note and handwritten draf t in typewritten form, dated July 27, 1979, and sent them to BLAKE, HERBEIN, PARKER and himself (Attachment 12). i MILLER said it was his belief that PARKER was the individual who inserted the grades in the final letter, dated August L 1979 (Attach ent 4). He centinued that the basis for this opinion was the initials which ase m ed en the bottom i 1 of the letter (WdP:LCW). He explained that WHP vas PARKER and ICW

                                                       ~
                                                                ~     ^                                                                                           2.

wa secr&tary that PARKER got to type 7tieITin'a Tl'et Ar N

                                                                                      -                               ~

MILLER was asked if it was normally his practice to submit the draf t of a certification letter to corporate counsel for review. He replied that in the July 1979 timeframe, most correspondence he sent out wase reviewed by attorneys "because of. the number of litigations and the number a of items Three Mile Island was involved in following the TMI-2 accident " . Referring to the August 3, 1979 letter, MILLER said it was his recollection th at HERSEIN had had BLAKE involved "in this event" early in his (MILLE "to make sure of [his) submissions" and to "cov er any area that (hel might not cover." _ He added that he (MILLER) had notes in his files that

                -(he] had talked to BLAKE at least once during the set of events." indicate Q Given this background, MILLER said that submitting this particular letter for BLAKE's r'aview didn't sees that unusual to him.         ,

MILLER was asked why, since he had earlier acknowledged awareness that had had a total of three weak areas, he only referenced two in his August letter to the NRC. He responded that the letter was draf ted for him by Training, and that his review of the handwritten and typewritten draf ts (J 26 and 27, 1979) mentioned"; showed him that there "could have been a third section however, he said he couldn't answer why the third weak section didn't get carried through to the August 3rd letter. According to MILLER, he "made the ce==ent (regarding the third weak section] and when the letter was given to (him) August 3rd, (he) signed the letter." ",'- - MILLER was asked if BEERS was given any instructio'ns to include the third section in the letter. MILLER said that he " thought by (his) note that he did that." He added that he wasn't talking to BEERS at that time; rather, he was dealing with PARKER. The investig.itors pointed out that his (MILLER's) note vas directed to BLAKE and not to PARKER. MILLER replied that he "would have assumed that PARKER vould have followed up on what (ha) wrote." He added that

             "(ha) took the time to read the letter and expected (PARKER) to finalize                                                                   .

it " MILLER said that the purpose of his note to BLAKE vas:

1) to have his review

i l i

he la::ar; and 1) to ':all ?AEXI?.,:o finali:o :he 1e::ar.
ha le:::: c Au'gus: That he *as gi.,e-3, 1979, he didn't ask "h:v cc:a (his] v::ds ve:a:':

inse7:e'd in tha letter." Es een:indsd ~:ha: "[he]-vas"::1dihe7e: a::e;:able :o sign, and (ha) krav :ha: Trainir.; had received :his draf:....that John (EIR3IIN) had, (he] knev tha: everybedp"had reviaved 1." A::c: ding to M!LLIR, "[he). jus: signed the Augus: 2:d le::er." Sit:a M1L'i?. said he called 4::an:1c

o the third sec:1:n in the d af: la::er, he was asked why 1: did :: ap; ear significa:: to hi: in the fi:a1 le:::: which vas signed and sen: :: :he NIC.

[he).da; ended c hi: He replied tha: "Wh a: (he} sava 1: :c 1111 ?Ayy.Ig

o resolve anyhedy's cen:en:s, and when (?A?J.IR) stuck 1:

1: f:::: ,cf (hi=] c Augus: 3rd, (he] ;;chably did =ct :eview i: :o any great ex:en: because tha two versus th:aa vasn': cri:ical in (his] =ind. F.a: vas in the backs: und of the 1e::ar." The invas: iga:c:s ;cin:ed cu: :o M**.*.I?. ir.velva:en: I :ht: :he :e:::d cf his (M*L*.IK's) vi:h :he 710YD issue included separate :ee:ings vi:hg=Jako==us, TLCTO, :::ve:sa:icas vi:5 and/c :a::s c: :ctes :o HIK3EIN, ILAXI and

e;;esan:a:ives cf :he 7:aining Ee;ar::e'::.
              ;:in:ing cu: c ::aining that they needed :o c:ve Eis inv:1ve:e:: also included
he :hird vaak area ha:ausa cf :ha s:-called "handv:iting" ;;:ble: and revievir. the d:sf: ca::ifica:1::

is::a: 1: sufficies: de: ail :o :aalt:e :ha: c 'y vo se:: tens cf :ha cakau; va:a rafarar.:ad whe: 7*.0Y: su;;esedly had studied th:st. It al*y, :he 1 :1-dwn:

                      . ..:.::ad d: in; a :ala:ively b:.af :1:afra:a (Ju'>-Augus: 1i75) a:J vas unusaal in :ht: 1: involved the cer.due: et a se-ic: su;arvis::y ef fi:ia.' vish a his:::y :! =anagasse: deficier.cies.
             *r. vtav cf :he ateve, XILLIR vas asked why ha didn': have the final 'st: :

rev:1::en. He s:a:ad :ha: "(he] teck the :1:a 1: 1979 a:::gs: r.:: an awful

            *:: :f h:.:s in the day -- and :his vas :: a raf e: ; :i'e=, tu: .he:                                                       *
k :he
i:a att ic:ked in:o :he in:1 der.: ;;a::y hard because c! :he fac: that 1:

inv: ved a seni : su;arviser." He con tr.uad :ha: ":h::vgh :his thing (he) saw  ;

ht: :he:a vara :hree see: tens : hat (TLCY3) had :o v::k ca. The 7:si:1:3 te;a;?:::: had :he res;ensibility :o :ake sure (710Y:] did : hat. When I
         .              .         . e e == sens em e.no -                 *=" *                *                              " " * * * "

l t - _ _ _ _ _ . _ . _ _ _ _ _ _

                          .!M LLIR) sav :he 1e::e: (he} sav :he sa=a thing.Vhen it gc:
                                                                                                                                                      ;esei.,.,g
                         , cf [hin), [he) vas :cid :c sign the le::er; i: vas ekay." Ac                                                                              .;.,tg, c,

M:;*=IR, the to:al nu=her cf anciEcEs"shd1the~-Ediv'idual~. ,--, -. ..cc din.g;:c, .-- , backs:cund. gridesvere all He added that "the tht:3 this le::er dids: is in the fir para- I g a;h itk=ev M:;;IR) certified tha:. that (TiOY3) had deze a ec:; ehe sive pres:a: . (Is,

                                              - -.        (We] k:ev it personally.

(hi.s] =ind, =ino: The c:her ce=:ents were, in qualified, and he was." cc:=en:s to the issue of whether or he (TLCY3) vas M LLIA said he cculdn': ansva: the ques:ic: vhen 1: ca=a to ht=, why he didn't rev:1:e the 1.- e:  ! effice

                        *a::e:

and he had already given his cc:=ents whe . vas accep:able c sign. s and said che jualsinvolvedand::us: MILLIA said that "cg: of trus: in their verkahility - ne: for the indivi , vc:haht'i:y - (ha) signed it." , their integrity bu: :heti~

cday, bu: 1: veul'dn ': He added that [he) eculd write it differe::1y change the first -parag:a;h which s,ays Mr. TLCY3 pas a ec:;;ehensive ;;:gra=, tad this (vas) the ne:ifica:ica of : hat " .

M:L*.IR

7. estar:

vas asked :c tr.;1ain the basis' up:n which hethetestified 'S!! (at

ainingEsa:1.gs)

De; art: ::. : hat TLOY? vas certified hated c an e:a1 yenacitatica He explained tha: :he 1: :evievi:g the docu:en:a:1cn he

                   ;:ssessed ;;ter :o tes:1fying, he hi:self had had a questic as ::s hev T tes:ing had been a::c ;11shed.
                 . a f t.1:is::a:                                      Accc ding to MILLIA, he sent his 1::: :he a::er. 1ve assistan:, Merrill SEAITIA, to the T:sining Depate::sn:                                                                 ic:k SEATTI?.. ;;cvided MIL *IK vi:h a :ve page handv:1::en :::e whi-h cu: lined the inf:::stien ha chtained f:c: ::sining (A::ach                                                                                                   ,
en: 19).' he unda:ed .::e, whi:h was reportedly based en infor:stica ;;cvided b said that TLCT3 had sc: , -
4'sc said tha retaken the $ectiet A reexas as M*LLIK had dire TLOY3 vas "cra*1y qui::ed and ques:1 cts en See:1:n A
erial vare given in :he vri::en reext:

of the failed O exa:s." Tinally, the ac:a (si:) tu: said that "the 59.1% en See:1cn A vas the ext: in ,,,,,Jg handv:i :1g 1 the ::a:erent cence::ing 99.87. cvara'.1 c: ccvered." * :eexa: : an: Se:: ten A van u I (

                                                                                                                                                                  . .. ==

MILLER stated that the foregoing represented more than he knew at the time he wroth the August 3, 1979 certification letter. He said that in 1981, the (SKAFFEA) note was a sufficient basis for him to be satisfied that FLOYD had - been orally examined (on Section A). MILLER said he knew his requirements (to redo the Section A FSR quis) had not been met and he asked why. According to MILLER, the response from Training came through SKAFFER's note and said, in effect, that they (Training) felt he was qualified on Section A because of the oral testing plus the questions on the comprehensive exas. MILLER said he could not explain why no record of any oral testing of FLOYD appears to exist. He added ,that there had been a lot of people going through TMI records at that time, especially in the area of training. While he offered that as a possible

          ~

explanation, he said that any records would have been in the Training Depart-ment and he had no way of finding or controlling them. ii1LLER'was asked 'if there was ever any intent on his part "to submit a document to the tiMC which would knowingly mislead the agency in the matter of the

  • licensing of FLOYD. He was also asked if there was ever any conversation or agreement between any of the individuals involved with the FLOYD issue to mislead the NRC in any way so that FLOYD could keep his license or because the licensee needed his license. To both questions, HILLER replied in the nega-tive.

A transcript of the interview of HILLER is being maintained at Headquarters.

         "NRC Office of Investigations.

o d

                                                                                                  +

INTERVIEW OF WILLIAM H. PARER PARKER, currently employed by GPU Nuclear. Corporation (CPUNC) as Manager of Facilities, was interviewed on October 18, 1982 by P.E. Baci and R.K. Christopher at GPUNC Headquarters, Parsippany, N.J. PARKER said that he was Supervisor of Administration at Three Mile Island (TMI) during the July-August 19f9 timeframe. PARKER, who said he was then acting in support of station Manager Gary P. MILLER, voluntarily provided a signed, sworn statement (Attach-ment 20) which contains the following information in substance: PARKER said that MILLER came to him in 1979 and asked him to draft a let admonishins Ja-== "

                                        "P Uhen Supervisor of Operations. TMI Unit 2) for hls Tetions on the FSR (Tundamentals and Systems Review) examinations. He continued that MILLER probably made him aware that FLOYD "had turned in an exam paper with handwriting other than his own," but said he did not recall
 ..    ..       MILLER's having made him aware of the facts at the time. According to PARKER;    '

MILLER probably gave him an outline of what he proposed to say and he (PARXIR)

                "p'ut it in fom."

PAAKER said that af ter he had completed the final draf t, it was approved by

              ' John C. HER3EIN (Vice President for Operations TMI Generation Group), signed by MILLER and personally delivered by him (PARXER) to FLOYD (Attachment 16).

PARIER said his next inval""-^^" "nk *h* me innua van to take the draf t of a_ letter prepared by the Supervisor of Licensed Training, Marshall L. 8EERS,

              .and "put it in emennemnh fo m."

He explained that the letter was intended.co certify that FLOYD had successfully completed his Accelerated Requalification Program (ARP), improved in his weak areas and attained the required proficien-cy. PARX!R acknowledged having seen a memorandum dated July 27, 1979 from MILLER to Attorney Ernest BLAXE (Attachment 12). PARXER said he was " unaware" of MILLER's meaning in the July 27th memorandum in which he (MILLER) " admits to referencing only two sections despite FLOYD's apparently having studied three sections."

                     !          He added that he also could not " explain why the third section relating to the handwriting probles was not addressed."

PARKER said that until the day of the interview, he did not believe he "was aware that the 89.1 grade on Section A was the section.containing handwriting o'ther than yLOTD's." PARKIR, who earlier had said he was not involved in any nestings in which the specifics of cheating were discussed, added that he was never involved in any discussions prior to the mailing of the certification letter with respect to the accuracy of FLOYD's represented qualifications or whether be not he should be certified as qualified for a license. PARKIR' stated that "to _ene ever indicated that the 89.1 score should be represented as valid or used to deceive the NRC." Ma eeneinuad ehme ha uma

              . not involved with the request to Training to have TLOYD rado the Category A

.* aissignment and opined that MILLER dicn't view TLOYD's conduct as cheating in. the classical sense that one perceives chasting to be based on need (sic)of the individual to pass." r 8 e 4 0 4 4 0

INTERVIEW OF ERNEST L. BLAKE On November 12, 1982, BLAKE was telephonically interviewed by ~~~ Investigator F. E. Baci. BLAXE, who is an attorney with Shaw, Pittman, Potts & Trowbridge, a Washington, D.C. law firm. representing the licensee, was asked to describe his knowledge of the July 1979 incident involving James R. FLOYD (then Superintendent of Operations, Unit 2)'and his subsequent certification to the NRC. BLAKE said he was at Three Mile Island (TMI) at the time, involved in the various investigations of the TMI-2 accident. 9 BLAKE stated that although he had haard of the problem involving TLOYD's exams back in 1979, he could not recall how the matter was first brought to his attention. According to SLAKE, he recalled that he had been 7 )

                   ~ concerned over the impact that TLOYD's failure to attend certain
  • training sessions might have had upon the accident investigations being <
 ..        ..       -_ conducted at that time.
  • BLAKE said that TLOYD's actions.-

had raised the possibility in his mind that others might also have failed to attend training sessions, and further, that given both TLOYD's lack of attendance at the training sessions and the problems concerning his makeup exams, he (BLAKE) was concerned that TLOYD might not have baan _ appropriately licensed at the time of the accident. According to BLAKE, he had no recollection of a note addressed to him

                 'from Cary P. MILLER dated July 27, 1979 (AttacSment 12). He said while it was possible that he had seen the note as well as the draf t certification letter (Attachment 12) purportedly forwarded to him for review, he could not recall having seen them. BLAKE also said he could not recall whether it was common practice at the time to submit training correspondence to him or other Company attorneys for review.

BLAXE said that if he had been involved in any discussions concerning TLOYD's certification in the July 1979 ti:sframe, he would have remembered such involvement. He felt that given the nature of the controversy surrounding TLOYD, he would have noted or othervise docu:ented any involvement

on his part. BLAKE stated that he had checked his files and could find no I i documentation concerning any discussion of the FLOYD certification nor could he find a copy of either MILLER's note or the draf t certification letter. I . 6 j

                    .   .                                                   to   '.        e I                          e s                       + . - '

s F e 0 0 O e

                  ...-....... c. .. x c.
                     ..             _     2... _n_.g
            . KI;.II;N, curren:17 a p*:yed as Vice ?:ssidan: fe:
                                                                 .              1:a:1:n C; era:icas with
               ?INI* SIC, Neva:ba a subsidiary of General Public Utili:iss (070), was in:erviewed 4, 1951 a:                                                                            en the Thraa Mile Island (!M:) 7:aining Faci *ity by    .
igators P.I. 3aci and I.C. Gilbert. ,
                                                                                                               .es -

XII3I!N che said he has tean e rt.;..e.a

                                                                                                          -     e by G?" Ce ;anies since 1967, was re;:ssanted during the in:::viev                                 g y ;g ,3 3, 1*.'I;;S, an a::: ney vi h Isha=, Linecin and Beale.
i=efra:e During the J. gly _Agg. : ;979 HIE 3I N said he held the position of Vice Presidan: f:: N.;.1 2 C; ara:icns, TMI Canara:icn G: cup.

HIE 3IIN said :ha: sesa:1:a in July 1979, 5:a-1:n Manager (Uni:s I and 2) Gary

             ?. M:*.LIR inferned hi= : hat Ja:as R. TLCY3 (: hen Superintandant L*nt:                                                                                                     s, of C;
2) had sub::::ed a training assign =ent,
             ;                                                            par: cf which a;;aared to be i-
             ~he handv:iting cf ancther individual. Acc:: ding to EIE1EIN , he it.s::ue:ed M, * '_IE :s "1:ck fu::ha: at all :he fac:s."

KIE3I!N said M:L*.IK's inquiry deter =ir.ed :ha: .

                                                                          ?LOY3 had ehtained hande-1::en L, a. sus:s
                 ~
::aining assign =tn: questi: s f::

a shif: su;arviser idan:ified as

           ~

tining 3 apart:an:He cen:inued in fulfill:en:: hat TLCYD had sui:1::ed :hasa ansva:s to :he t. cf ;ar: cf his (7* e-CY- 's) : aining :equire-

en:s. XIIII N said tha: af:a: M:**IR =at with TLOY3, __,[]):dre;asentatives f := :he 7:

41:1:.g Ospar::en:, he de:er ined : hat whila 7;CY3's a::1cns e; e - sr.::al,"excep:1:nal* y ;:c: judge:an:," there vas, ::. M~L.*IK's c;inica, no

        , deli *:e:a:e a::a:;: :o deceive en TLCY3's ;a;:.

A:::: ding :: EIF.II:N, ha censidered tha ?.* 0Y3 incif en: i sufficiently seri:Es to va::an: re;c::ing i:

c his (EIK3IIN's) superviser, se he advised 7.:te:: C.

I M":* 3 ( han Vice ? esidan: - Genera:icn, ??U Service C::;c a:i:n) cf the !  ;;:h*a: and kept hi: a;;;ised cf the sta:us cf M**.*IA's inquiries..

  • KI?.II!N said he and MIL *.I?. discussed the vari us disciplinary :tasu:es : hat ceuld be :aken in resp:nse :: TLCY3's actions.

He indi:a:ed :he: M:* *.IR and he inE:ialir rec:n= ended giving TLOY3 tire c!! vi:h:u: ;ay hu: :ht: AI! :' 3 fav::ed reassigt.ir.g TLCY3. KIEZI N said A130*.3's posi:1:n en TLOYO vas

ul:ir.a:aly ':aken.and TL ?3 vas su}sequan:1y reassigned f:c: his ; s: in c;aratiens t: the Acciden: Invas iga icn Task ?c :e. M:* *. A agreed tha:

                   .                                                                                                                    Es added that he and "Ji:h respec                                                          1:g, raprasa::ad an a;;;c;;ia:a res; :sa :o FLOY;'s c ndu: .

ak tot, ==,'HIR3I N said ha ves satisfied :ha: :he ad:::ishnen: - given as suffician; and . :ha: - decisien n:: :o disciplina h1=. ha (EIEZI!N) vas not involved in :he Acd:: ding to HIE 3IIN, M!L*.Il indicated tha: ?LOYD vas ::

aining to =aka up his deficient areas. receive additi:nal EIE3I!N axplained that sin:a : hey needed an 'adequa:a nu:bar cf licensed persennel in the cen ::1 :o== a sure of :he fu:ure a:::1:ics :a:a. he and MILLIR falt 1:veuld be vise to giva TLOY6 the c;;c:: unity to p: ;s:1y cc :act his deficiencias and : sta in an licensed capacity.

Acce: ding te EIE3IIN, M**.*.IR la:a

eld his T*CY3 had =ade up his defician; a:aas and tha: he' MILLIR~. vas scing to send a la::a:
o :he NRO. EIE3I N said ha c uld n:: .

are be " exactly hev it teek place, but (ha] suggestad to M**.*.IR :: he decided en his eva := clea: the 1e::a: vi:h (: heir] legal g::u;." Et centinued :ha: ":his was to in:ura.:ha: :he lat:e: vas all righ in view cf

he circu:s:ancas sur:cunding TLOY ': deficiencias." MIEZI!N said i: vas his assu:;:1:n ":he Legal Iapa:::en: had n: ;;:blan vi:h :he la::a: sinta (ha) nava haard any :::a th: : 1:."

EI?.21:S vas shev a nusher of docu:an:s rela:ad :o :he ins:an: investiga:1:n and ashad wht:her he had saan the befe:a. ~he firs: such d::::en vas a c:;y

f a handwri::en neta f::: M1*.LIR to hi=, da:ed July 3,1979 (A :ach:en: 11).

NIF.II*N said whi's ha did recall discussing :he.situa:1:n and issues vi h M:*LIK, he could no: recall having seen :he ne:a a: tha tira. tha: He cc :en:ad avan though :he nc:a was addressed :: his, he didn't aivays have :ize ::

ad.all his ail a: tha: ti a.

HIE 31*S added :ha: ha eculd n:: " a: ail the s;e:ifies of :he infer:atica centained in MILLIA's handwri::en =a:c." *th an asked hev he inte:;;a:ad M:*.'.IA's cc :en: a

he be::c: of :ha no:a , EIE3I S said he fel: the ;;oble !J' *.'.IK vas ref erring ::"vas :ha: cf exce;:1:na.*ly
     ;::: judge:ent en :he par: ef yLOYD."

4 4

h27. I N vas sh:.. a c:;y cf a =e== andu: da:ed July 6, 1979 f c: IIC".v.ui

           .e., . .. , (.3...a
                                                ._.. . r.).                 .

c... .. .. ..a. .e

                                                                                            . . . g .. o .u..r.:.:. .r.r   .s , s.e to
                                                                                                                                   .. d'>.. .  ... see              .'.e
ha: :i=e. He explained :ha: the =escrandu:

2e:::andu a:

t:

cen:ai:ed 1:fc :a:ica (a dese:1p. c' TLOYD's accelera:ed requalificatien pr:gra:) c' a :ype ac :-- ally fc varded to hi=. KI?lI N as she*.. a ce;y c' a =e:::andu: da:ed July 10, 1979, fre: gt::.yq; . v.:*'.*.IF. (A::achsen: 21). He said he recalled having see: the ce:::asdu ., which re; esented a su==ary o' :he aves:s assccia:ed vi:h 7* 01D's pt::1cipa-.

1:: in :he 1977/73 requalifica:ic: ; :gra:, c:1y as a :esult cf the taquiry c:: ducted hv Fred S?IATIR. .
                        .u..o. :..
                                 . (.e. .,.,.s.. s. .r.. S N C. ..:. : .......N   = :.: :. .

c c du e: e d b y vas ref erri:3 to the in'ves: iga:icn being

                        ,. .                                '.:..:=.,,e      Cc ::: veal:h                     cf'?t           sylvania Attorney General 7:ed
                        .::.s.:....

s.. .:.

                                                                . , as as cc:s, der, was re;c        .
e,..,y selec e,.

c 2.. . . , r

                                                                                                                                                                           ,.,y C.U
:s
                             ... . . . . . s .    .
                                                         .c..

se ., . , . h e . .e.m. . J s .. .. ., a.

                                                                         .... .                                     . .e    . .. .. .o ave ., d a. y s ,.as .

EI?2I!S vas shet-. a c:py c' a =e:::a.du: '::= IIC:-2'.C* :o FI.CD, dated July 11, [979, which :eques:ed tha- ?.* 0D rede his FSR assign =en:. 'c: Ca:egory A (A::ach en: 5). **i:h regard :o :his :e==:andu:, EI?2EIN said he va's ::: . aware c .' .- - ..". .. ' . .a . .d . .. s a: - -. "."... .*. ? '. .. , ." 0 ". a . . d <. .?. " *. .

                                                                                                                               ..t.", c-. ... . e . ..< ..g
                                                                                                                                                       .           :. .os. D ' s deft:1en:1es and :he c::: active actie: to be taken. He cen:inued tha: while 1: =ade sense :ht:

such c:: unica:1:ss v:u.*d have e curred to insure 7"0D

       ...a.e.s...a. . e r....
        . . .       . . . . .               .       .....a._. .e...a.e
                                                                     .                     ,., .s a ..      2 c ..ec.e.          .a.u..as a e .a.s a..e..          . . .a.eas,          s..e 3...          . . . .                     ..

ru . . v .m, g ..r. . . . ...a s . . a . .. . s . . e d s ....... e s.A.<ss.---- d3 - 1<,S caa v r - .v d *8 ..a..a..a

                                                                                                                                                  ***-a               **
                                                                                                                                                                                    ... ... .a.... -. .a s
        .g      g...g ..             2    .\g         g.g.*24----          .                                 4             d ... ... %d. Ly gw         . ..                r                    g5..d.g.g..g
                                                                                   --- -                         .e
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                                                                                                                                                            *"%g --g-~~-6
                                                                                                       -                                                                . n.d..
                                                                                                                                *r** "-                .
   ,   .e.a..e .. e..         . . . .

u.?.: T *.". "as S'...-... a ccr.v c*' aa """s -' 6 --" e d e-a"'"

                                                                                                                                                    --      ~#~--      v  * ?
                                                                                                                                                                - -- "---         '" '*a-ad-
      . . . *..      .., .:=:      ... ( A ....a %... e.            . . . 6 2 )' . .u. e 4. . . 2. 4 a..e d .L..a   .       . %.. e .3
                                                                                                                                ..         . e e.%.... %..a..e. s e en .u..e  .
      .e
      . . . .   ..g. . . >..._
                           . .       g. .. %...      g     .4
                                                           ..
  • c.# . .. e **

1.. .* .# d. e .. *. k. U *. " .k.. a *. b.. e V a s ..*. *. s ". . e . .. e s a .. k.. e a.. s .a .. , g .e t gas. a... .. g.. . . u. . , .o., . .. u.. g y.t . ...s. . . . . y . ~, s...,,.o.g.a ..s ... .. s.... . . .. . . u.. e .. e a . a . ,. . W

                                                             =mm.                                                                                                                            . . . .

in:1 dent involving and . ..  ; ne '.:nba: - a:;1:yed by C?C;C). KI?lI*.5 said :he July 27:h =e:::anfu: re; esen:ed

       .....v.-*s
     .s.-          A           ...<.e...
                                ....           ., c ..e..s .... ....... u..s.s .. 1 s.ss.3....t5 o.. . C . .u.. e .v n. .')
                                                                                                                                                         .o . c .< d e. ..

9

                                                                                                       -    39-
                                                                                                                                                                        * *=- * -                  * * - * - -
                                                                                                                                                                                                          ---ews-e-
                -According to HER3EIN, while he and MILLER were in daily contact regarding a numbdr'of things, including the FLOYD incident, he could not recall whether there was ever any meeting or discussion devoted exclusively to that issue.

HERBEIN said he'could not recall the number of areas in which FLOYD was deficient, what they were, or whether _ they overlapped. He said that all he

               .could recall was that'there were differences in handwriting and FLOYD had' turned in someone else's work. HERBEIN continued that he "certainly (fele]

that FLOYD could not be assigned a grade based on the work he submitted that was completely by someone else." HERBEIN said while he did not know, he assumed t, hat FLOYD's accelerated training program included all of his deficient areas. He said that "in recordance with the procedures, (he] assu=ed.at the time that (FLOYD] vould have been ratested in all deficienc areas to insure that he was qualified."

      .         HERBEIN was shown a copy of a note dated July 27, 1979 from MILLER to Attorney Ernest BLAKE (Attachment 12). The note transmitted a copy of a draf t letter
  • from MILLER to the NRC, also dated July 27, 1979, which was also shown to HERSEIN (Attach ent 12). HER3EIN said he didn't recall having seen either the note to ELAKE or the draf t of the letter to the NRC. After reviewing the documents, he opined that MILLER had forwarded the draft letter to BLAKE for 1egal review as he (HER3EIN) had mentioned earlier. HER3EIN said he couldn't explain MILLER's co= ment that he (MILLER) "only reference [d] two sections in the cakeup" and that FLOYD "actually studied 3 sections due to the handwriting
            ' problem." He also said he could not " explain why the draf t letter only refers to two vaak areas rather than three."

HERBEIN said while he was included on the distribution list of MILLER's letter to Paul COLLINS (then Chief, Operator Licensing Branch, USSRC) dated August 3 L979 (Attachment 4) he didn't recall having seen the letter before it was sent and felt he wouldn't have attached any particular significance to the specifics of the letter if he had. He continued that while he was generally f aciliar with the circunstances surrounding the TLOYD incident, he was not L

cenynrsant with all the details and the score of 89.1% listed for FLOYD on Category A would not have held any special meaning for him. HER3EIN stated that " cheating is a very subjective term" and would involve 4

                    " deliberate attempt to deceive."

According to HERBEIN MILLER's inquiry did not surface a deliberate attempt on FLOYD's part to deceive and conclude

   '                FLOYD's conduct represented " exceptionally poor judgement."

l HERBEIN said he "placed_a great deal of confidence in MILLER's determination" a d n that he (HERBEIN) also considered FLOYD's conduct to represent " exceptional judgement" rather than a deliberate attempt to deceive and falsify. HER5EIN acknowledged that there may have been weaknesses in the trainin

                ~

program'and administrative procedures, that copies of the certification letter may not have been read by all those on the distribution list and that he now knows that the 89.1% score referenced in the letter was not He correcti

          ~~

stated, however,fehat "[he did] not feel there was ever any attempt to deceiv, the NRC by either MILLER or (himself}." He continued that he strongly dis-agreed with this " accusation" in the Partial Initial Decision (of the Atomic Safety and Licensing Board).

  • HER3EIN said he did not regard his reassignment to his current postion (at PENELEC) as being adverse in nature and opined that MILLER's recent reassig cent represented a lateral move.

A copy of HERSEIN's signed statement is included as Attachment (23).

                    - v.~. .-: .". .. = ",. C .= .=. ". .* .*.*. *. C . l.'.N  3
                                                                                                                              #                                                                                                                                      1 AENCLT, ?:esiden:, G?U "celear Cc:pera:ic: (CF'J"C), vas in:erviewed in hia                                                                                                                                                                       l efficp a': Three Mile Island TMI) c: Oc:che: 7, 1982 by ! ves:igaters E.C.

Gilber: and P.E. 3aci. AINCLD said tha: in July 1979 he was Vice Presiden: (Generatien) of the GPU Service Cc:pera:1cn. A:: : ding ec AEN 10,

he sub=issi:n cf sakeup ::aising ext:s by .'a:es R. ?;;rg

( ... -s. e .. .e .r _ . e - . e. . .s . c.e c , e . a . . .' - .. s , ~. ".' ". . .' . v'..'.

                                                                                                                                  .                                    .' ) . *.. .' .. .' ". .' e d. v...e v::4 c,e ~*"""

0 L Iwas the ::s: recen: cf several ins:an:es in which w 710TO had ext:cised ;cer judge =es:. Accordingly, AENGLD said FLOYD vas re ved f:c= his pesi:ica as Supervise: cf Opera:i::s, which required as NRC c; era:: 's lice:se, and reassigned c :he A::1 den: Investiga:Lon G cup. Al"C*.3 said :ha: :o :he best cf his re::llec:1

                                                                                                                                                                                  , FLOYD's ini:ial reassign =en:

Las :aly intended to

  • e te:;crary and =anage:::: ;; bably veuld have used 7;CY: in the cent :1 :::= in a ideensed capaci:y a: a 'u:::e da e. H e - -- - - --
        ,        eI:;1ained :ha: yidTD vas a :echnically adequa:e cc:::cl ree: supervise: vhese
aining and experience as a senter reac::: c;e a::: (TRO) vare valuable to 4

the :::pany. He c:::1::ed, hevever, tha: TLOY3 has never been used in a

                 *i:ensed capa:ity cubsequen: :c the e,xt=ina:1c: in:id er.:.                                                                                                                       He advised :ha:

a -h: ugh TLC'it's $10 license fe "ni: 2 vas never reveked, 1: did lapse (da:e unkn:vn) and i: vas n : re:eved. .~. n...e..- n. s ... .,. ., ,, .s... . a... ..g.. .<.s..,...

                                                                                           ...              .u..s .e.g.a..             ..... .z.1s.g..c.
                                                                                                                                                                                      " . . .' . . a .. sa c '. ' e....-..1.*.*",
          ,     res;::.sible f:: :he ce::ifica:1:n of cpera::: licenses. He said tha: ;;i:: :e r
he AS*.3 (A:::1: Sa'e:y and Licensing 3:ard) lestar: Hearings, he (AEN0*. )

as ::: avare cf the cer:1 fica:1er. require:ents. IS"ISTICATOR'S NCTI: ARNCLO clarified this pei:: during a rein:erview c: N:ve:he: 9, 19c2. He explained tha: while he was avare cf :he

                            .. e g....        . . <. . e. e n. . .c.         o
                                                                                   '. .' - a .- ". a .' c a - . .' .' .' . a . .' .~ n . .' .' .' . e..                                                                       ._ e '..":".
                                                                                                                                                                                                                            . s                .. .r. e . a . - .

he was act : hen f a:iliar vi:h :he require:en: :: :::i'y :he NIC vhen at 4 c; era:c: had been receved f::= licensed d :1es, pla:ed in ar. accelera:ed requalifica:ica ;;:gra: and : hen re: : ed to du:y. He fu::her ex;;ained,

ha: un:11 re:ently, he had been under the ':;:essien :ha: :he cer:ift:4:ica le:: : a: the cen:e: c' :he c: ::: vers) vas :he bi-annual ce::ifica:ic refer:v< :o aheve.

1 t . g g g g mm e g. g g M . MM . . I 4

                                                                                                                                                                                                        .__._,,__y___

ARNOLD stated ther when ha initicily brought the FLOYD incident t o the attention of Investigators Gilbert and Baci in July 1981, he was not the, August 3, 1979 certification letter (Attachment 4) f aware of Further, he said that to the best of his knowledge, he had nevrom Met-Ed this letter. er read or seen INVESTIGATOR's NOTE: investigation conducted by Former Pennsylvania AttARNOLD sa SPEAKER, but added it was "not in such a way that orney General Fred (he) could read it." ARNOLD remarked that information concerning the FLOYD issue wa l deve'oped during the ASLB hearings. s not fully

                         .of  the ASLB, the Company did not regardempt deceive Company personnel.

FLOYD's to ac

                 ,    ,;what it' regarded as an independent investiARNOLD continued th gation of the entire issue and was using former Pennsylvania Attorney General Fred SPEAKER,
                       ,any bias.

an outsid er_, to avoid

                      ' available, would net support the findiARNOLD s,expressed                       when ngs and/or conclusibus of the Special *
 .                      Master     and the Partial Initial Decision (PID) with respect false statement.                                                       material to any
   ,,                                        Further, he remarked that he would not consider any
     -                 additional personnel action until he had the benefit of the results the SPEAKER and the NRC investigations.                                    of both 4.

e

i l

                       ...s.--_.,--".
                       ... . . . . . .              ..                       C.   .T.C ". ...". C . a' .'.NCl3
                                                                                                                /

Cn Neva:ba 9,1982, A?3C*.3 was rain:arvieved by Invas: iga::: ? . I . 3 a c t t.,

                       ;JSCL3'.s cffica en Three Mile Island (TMI). ;JSOL3 velu :arily ;; vided a                                                                                                                        ,

signed, svern state:ent (A::ach:::: 24) which c:::ains :he felleving i:fc::a-ics in substance:

  • I: vas IJSC*3's . recollac:1:n :ha: :ha ;;:i'a= . vith Ja=es R. F 0D's exa=s was ini:ially brough: := his at:en:ica by John EI?lI;N (then Vica ?:asida:: fe:

Nuclear 0;araticas, IMI Generatica C: cup) se a:i=a during the firs: Ove weeks cf July 1979. I.c:::di.g :: A350~3, EI?lI!N advised hi= tha: T CD had ch-

                                                                                               &r           -

tained assis:an:c f: = _ in cc rla:1=I

                       =akaup assign =es:s which he (7LCD) was required to ce=;1ste as part of tha requalifica:ic: ;; gra=.

IJSC*.3 sa'd ha a:s:barad having discussed :he T*_CD =a::e: vi:h EI?lI;N c

                .        :hree c: four c::asi::s.                                                      He cc :inued tha: ha recalled EI?lIIN and Gary P.

M:L*.IR (:han 5:a:icn Manager, Cri:s 1 and 2) f avered a suspensics f:c: verk a*s a Ess; nse :o 710D's ac:icts and tha- he,1530*3, disagraad. He a>:;1ained

ha: a suspensi:n veuld hava heen a;; :;: data had I*C D 's acti: s c :he ext =s .

been an iscla:ed in:ident, bu: since 1: vas ::ly :he la:es: such inciden: in a ext:;1as cf ;::: judgeman:, IJSOLD f el: v::k his:::y cen: tining c:he reassign =en: vas :he ;::per respensa. -

                                                                                                                                      .                 t*

t ... he IJ5CL3 said ha van:ed TLCD reassig .ed, ha added :ht: ha saw n: reasc.

                          ..           .243 . ,_, . , ., ., .'. v '.. '. _ a s a s e ... ' . . . a a. - . .- . c , a . a . . . ( *.. . ) s..' .. a . '. . s. v ' .. .. . ". a . '.

have had need f:: kn:vledgeable licensed pe:p* e in the subseque .: ::::hs. .

                        /JS**.3 recalled : hat ha unders::cd 710D vas ::.have baan given a la::a: cf re;;t:and in cenjune:ics vi:h h's reassig .:en: but added tha: they had :::

haan able :o ic:a:e any d::::en:atic tha: li .ked ?*.CC 's :a:: val :c his re:::d ef ; :: perf:r:an=a as a canager. A1:h: ugh JJSCLD said h's ; in: cf cen:ac: vas EI?lI;N and tha: he ceuld ne: re:a*.*aver having discussed :he TLOD ca::a: vi:h MIL *.IR, he said ha was general

  • y ava:e of :he direc:icn M*LLIR} s 1.quiry in:o :he incide .: had :aken.

11 4

                                "e also indi:a:ed :ha: in effect, he (A. ENCL 2) =ade the ft al decisic
he reassign =en: cf TLCY2. (./ as to
  • ARNOLO said :ha: vi:h respec: :e 1 WP"Mur he was
                               ;;e; grad to accept MILLIR's and HIIII!N's judge:en:

exa: issue. cen:erning his rele in.:he A.SC*3 said that while he had been inv:lved in :he devel:;=en: ft:a:ic: ef the requali-

                                   ,            ;;egra: for c;eraters during the 1973/74 had been away f:::                                                                                     ti e f:ste, by =id.1979 he -

it for several years and did:'t recall all the specift: de:sils ef :he ;;cgra= ad inistratica. He cent':ued tha: ;;ier :o the sygArzg invas: iga-ics, he had :heugh: tha: Augus: 3 ,1979 (A::achmen: 4) vasthe se called "certifica:ica a certificatics f: lette:" cf t re: eval cf 7;oy;'s license; he said that' he now k:cvs tha:

he le::e advise [theNRCtha-TLOYD
                          'had        ;::ble=s          in :he Cc=pany re::aining p: gra: and that he vas assigned                                                                                          t passed         an                                                                                                                                                 o and accelerated requalfication ;;cgra=.

l recollectic AENOLD s:a:ed he had no

                              ~                        hat he k:ev a: the :i=e tha: te ; crazy disqualifica:ic: for unsa:isfae: cry pe-for:ance in the re::aining ;:egra: required actifica:ic
he NRC upc re::: ing as c; era:c . :o-A55010 ; iced tha: :o lice: sed duties.

l EERIIIN's ::ansfer to FINILIC vas a la:eral ==ve a:d ] not a de:::i:: and added tha: there vas no . element of dissa':isfacti:n vi:h IIRII~N's j b perf::=an:e which resul:ed in his reassign =en:. of be:h EI?.IIIN and MI~.LIR, the even:s a He said tha: in the case

he :'=e =f and sub:ecuen: c the a::iden: had i:;ac:ed u;:
                        .... . . . ..          .. . . ,s
                                           . sc..a.   . c.s
heir utili:ati : by the Cc=;any; fu::her, he fel:

c .,... _ a. . < .. g u. .. c . s. ...., e

                                                                                                        .a.. e . . . . . c . ...u. e e.
                                                                                                           ... .....                                 . . _. ,.      . . .,. . . a.... ... e _. o
              ,, individuals (K!;~_IR/EIF.IIIN) were best achieved by :hei: reassignmen:.

{ {

                     'fi:hres;ec: :e :he Augus: 3,1979 let:e: hich MILLIR sen: to :he N?.C,                                                                                                  -

4 A NC"_3 said tha: MILLIR had 5een : eld tha: in :p.e C::pany's judge:ent, his

                    ";erfer:ance was unsatisfac ::y in previding tha:
                   . . . . a       .e..s..    . . .o v..n._..R da.ed .a......s.                                             cer:ificati:n to the NRC."
                                                                                 ... . le., .i e. :..3 (c....c _e. . .n , ,, - . . :

_...s

                   -hat "give                     [his) knevledge cf circe:s:ances a:
                                                                                                                                                                         .......as   .
ht: zize, [he] should have been ze:e diligen: in providing assurances :o (hi:self! as ::
he accuracy of the inf:::ation in :he cer:ification."
                                                                .         . _ . . .       --.LS-i .   .

INVESTICATOR's NOTE: intervie s. It is unlikely that the instant ARNOLD appeared candid and forthcoming during both investigation would have

                           ' been undertaken or that the Co= mission (or Special Master) would have                                                                                                                                ~

become aware of the FLOYD issue had-ARNOLD not volunteered both the information July 1981 cheating and supporting investigation. documentation to the investigators during the Se - h , 'e , 'j

             ,                                 9                 *                                        *                                              .
                                                                                                                                                                                                        . c..

o t G g4 E'

                                                                                                                                         -\                                 N     , ' <           ;                      g         ,

e t

  • e e
  • s 9

__ .__-._a__ _ _ . _ - _ - - - - - - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - " - - " " " - - - - - - - - - " ---

REVIEW OF PERSONNEL AND pal'AOLL RECORDS On October 7, 1982, James TROE3 LIGER, Acting Area Manager GPU ources, of Human R uclear Corp., made available personnel and payroll records to NRC Investigators Peter E. Baci and Edward C. Gilbert. The records revealed that James R. FLOYD was on vacation from July 2 through July 6,1979. Records contained August 17, 1979a letter from MILLER to department heads and superintende e which announced that effective August 20, 1979, Joseph J. CHWASTYK vould assume the duties of Supervisor of Operations 2 (FLOYD's previous position) . or Unit -A A copy of this letter is appended as Attachment (26). Records also contained a request dated October 4 , 1979 that CHWASTYK's 15, 1979. promotion to Supervisor of Station Operations be effecti ve November Payroll records disclosed FLOYD's job title was changed on Septe=ber "Operati 1,1979 from Supervisor of Station Operations to Supervisor nt o ons throughout to conform Med-Ed/GPU. to a new common job title system which was being adopt Payroll records also revealed there was no change in FLOYD's salary during calendar Year 1979. TROEBLICER pointed out that . although FLOYD has subsequently received periodic salary increases

                                                                         .          , he has              not been ent'itled to the monthly and yearly bonuses paid to Senior Reactor Operators (SRO).

He noted that SR0s currently receive a bonus of $285 per conth and an additional $2,000 per year if they have held an SRO license fo four years. - e S l l l 47 - 1 l O  % v--+r . , _ . .

INTERVIEW OF NRC LICENSING PERSONNEL On detober 26, 1982, Don H. BECKHAM was interviewed by Investigator P.~~E. Baci at the NRC Offices in Bethesda, Maryland. BECKHAM, who is Chief of the Operator Licensing Branch (OL3), Office of Nuclear Reactor Regulation (NRR) , has been employed by the NRC since 1976. BECKEAM, who stated that he regarded (former Superintendent of Operations, TMI Unit' 2) James R. FLOYD's actions in submitting another's work in fulfill ent of his training obligations as cheating, was asked to review a letter from for=er TMI Station Manager, Gary P. MILLER to Paul COLLINS, BECKHAM's it=ed-iate predecessor as Chief, OLB/NRR. In the letter (Attachment 4), dated

          ~

August 3, 1979, MILLER certified to the NRC that in accordance with TMI Ad=inistrative Procedure 1006 (Attachment 8), James R. FLOYD completed an

            , accelerated requalification program (ARP) and achieved a score of 99.8%. The letter ~also prov'ided background infor=ation on FLOYD's training status during r
 "            the 1978/79 requalification year and stated.that he (FLOYD) was deficient in' t              four category sections, including Section A or Principles of Reactor Theory.

The letter centinued that FLOYD vas required to upgrade the weak areas and that on ratesting, he (FLOYD) received scores of 89.1%, 75.6%, 80.5% and 64% on Sections A.E,G and H, respectively. The letter finished by stating that since FLOYD received two scores less than 80% (emphasis added), a specifically i tailored program (ARP) was instituted which enabled FLOYD to improve in his veak areas and achieve the score of 99.8%. BECKHAM explained that 10 CFR 50.54 provides that:

                       "Within three (3) conths after the issuance of an operating license, the licensee shall have in effect an operator requalification progras which shall, as a mini =us, caet the require =ents of Appendix A of Part 55..."

He continued that the ad:inistrative procedure cited in MILLER's letter ! (AP-1006) outlined the Met-Ed Operator Requalification Progra: and was insti-tuted as a direct result of an SRC require:ent. BECKHAM said that NRR reviews

and approves the program description for all such procedures and that the Office of Inspection and Enforcement '(IE) reviews their implementation. He added that NRA (OLB) also conducts audits of the various requalification programs but conceded that limited resources prevented this from being more chan a mini =al effort (21 audits were conducted within the past year -- each audit less than one man day). BECKHAM explained that because AP41006 was instituted in fulfillment of 10 CFR 50.54, the procedure had the effect of a regulation; therefore, the certifica-tion of FiOYD's satisfactory rating (in the ARP) in MILLER's letter was a requirement and not a voluntary notification by the licensee.

            -BECKHAM opined that AP-1006 appeared to require that the-licensee merely
             -provide certification of the license holder's satisfactory rating on the ARP and not the background infor=ation contained in the letter; however, he felt that since that infor=ation was included, it should have been accurate and        -

truthful. BECKHAM stated that the foundation of an effective regulatory pr'ogram is based upon the agency's ability to trust and rely upon the accuracy of the infor=ation it receives from licensees. 3ECKRAM advised that 10 CFR 55.40(b) provides that:

                               "Any license may be revoked, suspended or codified, in whole or in part, for any caterial false state:ent in the application or any statement of fact required under section 182 of the (Atomic Energy) Act, or because of conditions. revealed by such application or state =ent                     l of fact or any report, record, inspection or other means which would warrant the Commission to refuse to grant a license or an original application, or for violation of, or failure to observe any of the ter=s or conditions of the Act, or the license or of any rule, regulation.

Order of the Co==ission or any conduct deter =ined by the Co= mission to be a hazard to safe operation of the facility." , 49 - _ _ , _ , _ _ . - - - m - * - * *s' '"'"*** ' " " ~ ~~

He noted that the renewal of FLOYD's Senior Operators License (for TMI) was regeested (in writing, by FLOYD) on November 15, 1979. SECKHAM'said that FLOYD's application (Attachment 27) stated that "during the effective term of [his} license [he had] satisfactorily completed the Metropolitan Edison Operator Requalification Program." BECKHAM continued that FLOYD's application was accompanied by a certification from MILLER (Attachment 27), also dated November 15, 1979, which said that FLOYD had " discharged his duties in a competent and safe manner during his current license period." According to BECKEAM, the NRC would have relied upon the additional information earlier

              .provided, in MILLER's August 3,1979 letter when it censidered whether to renew FLOYD's license.
           ~ BECKHAM said that if the information contained in the August 3, 1979 letter
            . was false or inaccurate, as it appeared to be, the KRC would not have known:

(1) that FLOYD had received three scores (on his FSR quizzes) less than 80% instead of the two mentioned in the letter; (2) that FLOYD had a total of three areas of demonstrated weakness and therefore whether or not he had received additional training in the third area; (3) that FLOYD had submitted another's work in fulfill:ent of his training obligations; and (4) that FLOYD had not, as stated in his renewal application, satisfactorily completed the Met-Ed Requalification Program and that he had not, as stated by MILLER in his November 15, 1979 certification, discharged his license respcasibilities in a competent and safe canner.  ! BECKHAM said that if the SRC had been aware of the above, FLOYD's license i cight have been revoked, suspended or modified under the provisions of 10 CFR 55.40 (b), cited earlier. I

INVESTICATOR's NOTE: A review of FLOYD's docket revealed FLOYD's licens t was withdrawn on November 29, 1982. Although there is no record in OLB of any written or telephonic requests for the withdrawal of FLOYD's license, has request BECKHAM advised that such action is not normally taken unless a been received. BECKKAM was advised that FLOYD, MILLER cnd various representatives of the li'censee's Training Department had asserted that FLOYD's ARP (Attachment 3)

                    . covered all of his weak areas, including Category A, and that FLOYD had
                    . demonstrated his proficiency at the conclusion of the ARP by successfully passing a comprehensive written exam (Attachment 3).

He was also told that , FLOYD was allegedly tested orally by members of the Training Department although no record of any such oral exams was located. At the request of the reporting investigator, BECKEAM provided a copy of . JLOYD's ARP and his comprehensive exam (with answer key) .'o Bruce BOGER of the

                   - OLB.
                                 . According to BECKEAM, B0GER was the most knowledgeable NRC individual concerning the Met-Ed Requalification Program. BOCER reviewed the                                                                    '

afore=entioned material and stated, in a note dat.ed October 7,1982, that "in < his opinion the accelerated requal exam [did] not adequately reexamine [the) areas of weakness identified in Categories A,E, G, and H." He gave his reasons as follows:

                                      "(1)       There are no questions relating to Cat. E; (2)      There is only one question relating to Cat. G (No. 6);

(3) The shutdown margin calculation (No. 3) is essentially the same as the reactivity balance calculation perfor=ed as part of the accelerated training program. The same initial-conditions were used on both calculations, so the same points on the reactivity graphs were used. Therefore, I question whether knowledge of the subject i. matter required in Cat. A has been de enstrated." t

) . 1 Su==arizing the coc=ents of Messrs. BECKHAM and BOGER: (1) , 4 BOGER stated that, in his opinion, FLOYD's ARP did not adequately cover his (FLOYD's) areas of demonstrated , weakness; (2) BECKEAM felt that MILLER misrepresented the total ' nu bar of FLOYD's weak areas in his August 3,1979 letter;

                                   .(3)

BECKKAM stated that the licensee had made a false statement, in that MILLER's letter attributed grades to FLOYD which he himself had not earned; and finally.

                  ,'            , (4)

BECKEAM stated that, in his opinion, the information contained in

                                         . MILLER's letter was material to FLOYD's continuing to hold or renew his NRC senior operator's license.

4 e As indicated earlier, BECKHAM stated that he regarded FLOYD's actions on his FSR quizzes as cheating. BECKHAM's supervisor, Hugh L. YHOMPSON, Director of the Division of Human Factors Safety, NRR, essentially shared'BECKHAM's view of FLOYD's actions in a letter to the Secretary.of the NRC, dated Nove=ber 11, 1982, in which he stated that "I wish to clearly state that it is the staff's

           '     position that an individual has cheated when he or she submits an answer.

prepared by another. individual, as his own to any examination questien." i 5 9

INTERVIEW OF PAUL F. COLLINS On De,cember 10, 1982 COLLINS was telephonically interviewed by Investigator P. E. Baci. COLLINS, who has since lef t the employ of the NRC, was Chief of the Operator Licensing Branch (OLB), Office of Nuclear Reactor Regulation (NRR), during the timeframe of the incident involving James R. FLOYD. He sa'id that while, he could not recall the August 3,1979 letter from (former Station Manager) Gary MILLER (Attachment 4), he did not doubt that it had been sent. COLLINS said that he recalled having reviewed FLOYD's docket and that while MILLER's August 3rd letter did not come to mind, he remembered the renewal application which said FLOYD had completed everything in the Operator Requalific'ation Program. _ COLLINS ' acknowledged that while the NRC did not initially require the licensee to submit a certification following satisfactory completion of an accelerated requalification program, once the licensee had committed to it in its adminis-trative procedures (Attachment 8) he felt they should comply. He stated that. the significance of MILLER's letter would have been to al' art him to FLOYD's deficient areas. . COLLINS said that if MILLER's letter had accurately described how FLOYD had had a total of three weak areas due to the cheating incident on his FSR exams, he would then have expected some indication of proposed remedial action in the 1,e_e t e r . If there had been no proposed remedial action in the letter, COLLINS said he would have contacted the licensee to find out what corrective measures they intended to take concerning FLOYD's third weak area. In either case,

            , COLLINS centinued that he (COLLINS) would have made a note to himself on MILLER's letter to check that all deficiencies had been corrected when FLOYD next came up for license renewal.

COLLINS acknowledged that MILLER's August 3, 1979 letter centained false i information with respect to the total number of weak areas and the grades attributed to FLOYD. He stated that had he known what had actually happened i relative to FLOYD's requalification program, he would have taken some action other than automatic renewal of his (FLOYD's) license. He continued

that if FLOYD had not corrected the third weak area, i.e. the one not ident-ified 'to the NRC, then both his November 15, 1979 renewal application and MILLER's accompanying certification (Attachment 27) would have been false statements since FLOYD represented that he had satisfactorily completed (emphasis added) the Requalification Program and MILLER had certified that FLOYD had discharged his license responsibilities in a competent and safe manner. COLLINS advised that in a letter dated December 9,1977 (Attachment 28), Met-Ed v.as told by the NRC that the language in license renewal applications should be specific concerning an applicant's participation in the requalification program. The letter explained that the term " satisfactorily

           ~

completed," when used in connection with the requalification program, means

             ~ that "a licensee has been administered the annual examinations and has participated in 'the lecture series, as required, that he has participated in the on-the-job training; has been evaluated by supervision regarding his perfor=ance during abnor=al and emergency situations; and has participated in all the other portions of the approved qualification program."

Os l i l

STATUS OF INVESTIGATION As no further investigative effort is anticipated, this investigation is considered CLOSED. er 9 0 8e o e e e 5 t 55 -

g ATTAC*dMENTS (1) Copy of Statement of D. J. B0k.TZ/0ctober 6,1982.- (2) Copies of four FSR examinations for J. R. FLOYD . (3) Copy of Accelerated Training (or Requalification) Program for J. R. FLOYD with Examination and Answer Key. (4) Copy of Letter from C. P. MILLER to P. COLLINS / August 3, 1979, (5) Copy of Draf t and Final Memorandum (w/ referenced memo attached) from R. W. ZECHMAN to J. R. FLOYD/ July 11, 1979.

                                                                                         ~

(6) Copy of Statement of E. R. FREDERICR/ October 5,1982. (7). Copy of Statement of N. D. BROWN / October 7,1982. (8) Copy of Metropolitan Edison Administrative Procedure 1006/ April 11, 1977.

                 ~

(9) . Copy of State =ent of M. L. BEIRS/ October 6,1982.

   ,*               (10) Copy of Me=orandum (v/ attach =ent) from R. W. ZECHMAN to J. R. FLOY3/ July 6, 1979.

(11) Copy of Handwritten Draf t Letter from G. P. MILLER to P. COLLINS / July 26, 1979. (12) Copy of Note (w/attachcent) from G. P. MILLER to E. BLAKE/ July 27, 1979. (13) Copy of Statement of R. W. ZECHMAN/ October 1,1982.

          , ,      (14) Copy of Statement of L. L. LAWYER / October 18, 1982.

(15) Copy of Stata=ent of J. R. FLOYD/ October 7,1982. (16) Copy of Me:orandum from G. P. MILLER to J. R. FLOYD/ Undated.

                .(17) Copy of Results of Interview of T. L. HOM3ACH/ October 6, 1982.

(18) Copy of Handwritten Note fres G. P. MILLER to J. G. HERBEIN/ July 3,1979. (19) Copy of Handwritten Note frc: M. SHAFFER to G. P. MILLER / Undated. (20) Copy of State:ent of V. H. PARKER / October 18, 1982. I i l r

                                                                                                      ...m.w-,m~-'
                                          ._. _.     =-         .-     .            -    _ _ _ . -

(21) Copy of Memorandum from R. W. ZECHMAN to G. P. MILLER / July 10, 1979. (22) Copy of Unsigned Memorandum (w/ attachments) fror. G. P. MILLER to J. G. HEREEIN/ July 27, 1979. (23) Copy of Statement of J. G. HEREEIN/ December 27, 1982. (24) Copy of Statement of R. C. ARNOLD / December 1, 1982. (25) Copy of Letter from R. C ARNOLD to G. P. MILLER / August 19, 1982. (26) Copy of 17, August hemorandum 1979. from G. P. MILLER to Department Heads / (27) Copy of Letter (w/ attachment) from J. R. FLOYD to P. COLLINS / November 15, 1979. (28)

               .          Copy of Letter from P. COLLINS to J. G. HER3EIN/ December 9, 1977.

O 9

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L.

Page 1 cf 5 r Place: TMI Training Cen:er

          .                                                                                                                     Ca:e:     10/6/82 STATEMENT                                                 '

I, CENNIS J. 50LTZ, hereby rake the fellowing voluntary statemen: : :e:er E, Saci, who Cc=ission. Regulatory has identified himself to me as an Investign:ce with the U.S. Nucle Investiga:cr Bact has written this stateren for me. This stater.en: su =ari:es the infer:atien which provided :c tiRC Invas tgaters !aci and Edwarc C. Gilber; during an interview held a:the TMI Training Center en 10/5/82. I currently am employed by Me: Ed/GFil as the Supervis,cr cf Simulater Training at TMI. I have been with the Ceepany since

       * -1958 and was assigned as an Administrat:r cf Nuclear Technical Training                                                                                       ne     a:
fee Jim FLOYD submitted his FSR cui::es in July 1979. The investiga:cr asked me to re::un: cy involverent in the grading cf FLOYD'S FSR qui:zes and the -

cevele::en and administration of the Accelerated Requalificatic, Program to wnich he was assigned. I have read the .0artial Initial De:isien (FIC) cf the Atomic Safe y and Li:ensing Scard as 't c:n= erns the 1579 in:icen: invciving Jim FLCYO anc _ C

             ~                               i :s way cf backgruent I hal;ed ..rita and gra::a 5::: the .977 :r:ss.
       .1.i:ensing exam and the recualificatien exam wnich FLOYD ::ck in ebruary 1978.

I keen

na: as a result of these exams, FLOYO was recuired to.;artici:a:e in.a s:e:ial ::r:icn :f :ne next company rec;alifica:f en pr: gram known as Fundamentals and Systems Review (FSR) in fcur areas cf de :nstra ed weakness.

The assignment to the FSR program was an autcma-ic pr: cess anc w:ule ;r:: ably have been made by the Training Grcup Supervisor, Dan G000 MAN. The actual assignments would be prepared for the individual by an instruc :r. If the 9 l i indSicual attended classes, he would be given a wrt::en exam which :ncludec ac:iti:nal cuestiens in his weak areas teycnd tha: wnien was given :: ::rer class mem:ers. If he did not attend classes, as was the case with FLOYD, he l Attachment i L

F Page 2*of.5 w:uld be sent make-up exams covering his areas of weakness.

               ~                                                                 Although I cannet recall -he da:es, FLOYD was sent some make-up work assignments because lack cf class attendance; he did not return these so they were sent to him e again.                                                                             .

In July 1979, Jim FLOYD submitted his F5R make-up quizzes. I cannot recall whether it was re or Ed FRE0ERICK who first discovered it, but there was a';reblem concerning FLOYD's exams. i Siecifically the pr:blem, which was immediately re;ce se :: management, was that at least one of the exams O c:ntained answers in the handwritine cf *

                                                  ~

m 9n additen to that of FLOYD. I am n : sure whe:her I had FREDERICK go :: the Supervisor cf Training, Dick IECHM*N, er whether I went nyself. In any event, I felt that F.' 0YO's acti:ns c:::s:ituted eneating6 and that the exams he submitted c:n:aining answers wri :en :/ _ -pre unac:e; able. I recall tha: the reaction cf c hers in Tratr.in; who were aware cf this matter was also tha: FLOYD was wr:ng.

:erning the accelerated requalifica: Ten pr: gram (ARF), the decisi:n ::

assign FLOYO :: -his program did net invcive me; it was :r:ba ly made in

                            ~

mee:ings involvfng higher level' management such as Gary FILLER and IEORMAN.

     'a'hile ! did not not participate in the decision to assign FLOY to the AP.?, I may have contributed to developing some of the werk assigr.ments based u;:n what others cecided needed to be covered.

Mr. Saci showed me" a letter dated 7/6/79 from ZE:HMAN to The FLOYD.meme, wnien I did not originally see until after it had c:me cut in sm:eth, lis:ed FLOY"'s required assignments for :ne ARP. It aise listed several areas in wnich I was supposed to work with him t,o help overccme certain deficiencies.

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  • 7_

s. f Page 3*of 5 As I recall, FLOYD was removed frem all licensed duties and assigned to the Training Dept. on a full-time basis. I know he spent quite a bit of time in my office and feel that during that time, we discussed the Category A or Reactor Theory material. FLOYO is very competent in this area and was one of my primary sources whenever I needed information concerning a question on reactor theory. In fact, FLOYO taught me a lot of what I know concern'ing

               ' reactor theory. :I am convinced that his poor performance in the Category A area was not because he didn't know the material.
  • At the conclusion.of the ARP, FLOYD took and passed a comprehensive written exam which was prepared, practored and graded by me. I reviewed a copy of the final exam provided by Mr. Baci and told him that Category A material was covered in a number of questions. For example, Questions 2(a) and (b) involves source fuel detector geometry and is included in Category A (or
             . reactor theory) material. Questions 3(a)and(b)and4(a)and(b)alsodeal with Cat. A material.         I cannot recall if I was given any guidelines in pre-paring the test but I don't believe I would have included those areas (Cat. A) on the exam if I wasn't told by someone that they were among FLOYD's weak areas which needed to be covered.

Mr. Baci showed me the 8/3/79 certification letter to the NRC by MILLER. I recall some discussion concerning the grades in the letter which took place some time after it had gone out. I think it had something to do with the way the grades were averaged, but I am not sure. I can offer no explanation for the

v r i . e "Page 4#*of 5 L' L l gra'de cf 29.1% fer Cat. A which a;; ears en the letter c:ner than it was put down as FLOYO's secre, regardless of how it was arrived at. At Mr. Eaci's

           - recuest, ! quickly reviewed FLOYD's Cat. A FSR cuiz to see what grace he have receivec leaving out,      % input.
                                         ,,,,            I did-this to see if perna;s the 89.1%

score did in fact represent only FLOYD's work en the test. Without "' Jnput, it appeared FLOYO would have received a score of 84.2%. I cannet e_xplain why the- 89.15 se:re was inicuded in the 8/3/79 letter if it did, as it

          .a;; ears, incluce ,,,,, w rk. This wculd nc: have been ac:; rate since FLOYO did.

not re'ceive the grade on his own. I also cannet :nplain why the letter refers [

cnly,2 *eak areas ir. stead Of the 3 he had when ycu include the Categ:ry A area.

Further, if this was net a weak area, I cannet explain why it was c:vered On :ne final ARP exam. Mr. 3a:1 ;;intec cut that Acmin. Precadare 1306 calls for an c;en or i ,, eleste t:0k wrt::en exam to be given en FSR areas. The exam is :: he given either ir-class er en-shift. He asked me if I c:nsiderec an cr-shift exam :: be e:uivalent :: a take-heme exam and I said that I cid since they were 5 n given en the honor system, without any proc Or present. We coulc never di e:: anycre tc take this type cf exam at home since the unien wcuid then ask :nat bar;aining unit members be paid; however, if somecne wanted :c take it (the ex hcme to complete, we would have no objection since essentially the same condition w:uld 9- evail. Mr. Baci told me that Gary MILLER had said :nat FLOY3 was tested crally on tne Cat. A material. I know that the material was c:vered in his ARP pr: gram i

  • L

Page 5 of 5 and on the final exam; the only oral testing I can think of would be the many discussions FLOYO and I had in my office when he was assigned to Training. These discussions, which I mentioned earlier, covered some Cat. A material. In e fact, I r' member one such discussion in which we talked about a negative reactor, period following very small reactivity insertions (less than a B

          ~ fraction).

I believe FLOYO even called someone at Penn State about this. I was shown a memo dated 7/11/79 from ZECHMAN to FLOYO which aske to redo his FSR assignment for Category A at the request of G. P. MILLER. I - hadn't seen this memo before that ! can recall nor can I explain the rationale for asking FLOYD to redo the FSR Cat. A work. Since he was both given and ' tested on Cat. A material in his ARP, I cannot explain why Mr. MILLER would have asked him to redo it. I don't know whether or not FLOYO ever redid the Cat. A section and handed it in as requested. Mr. Baci asked me if I was aware of any pressure or requests to expedite FLOYD through his ARP because his ifcense was needed. I told him that I was

         .not aware of any such pressure.        To the best of my knowledge, . Jim FLOYO was not etilized in licensed duties subsequent to the ARP.-

I have read the foregoing statement consisting of 6 handwritten pages. I' have made and initialed any necessary corrections and have signed my name in ink in the margin of each page. I swear that the foregoing statement is true and correct. Signed on 10/6/82 at 12:09 PM. Signature: /s/ Dennis J. Boltz Subscribed and sworn to before r,e this 6th day of October,1982, at TMI Training Center. Investigator: /s/ Peter E. Baci i Witness: /s/ E. C. Gilbert l 1 ' l

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O J 6. RETURN TO TRAIllItiG DEPARTMElli8 BY:_ W3 7l 7. liethod of Evaluation: Check at least one) a) liritten Test Score: 89, / $ b) 0 al Spot Check c) Other (Explain): B-

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N r  ? $ Ins 1(sd6 tor's Si ture ' Date ' Supervisor of Training ' Da te Attachment 2

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R0 12.5 Pts CATEGORY.A (A,H) PRINCIPLES OF REACTOR THEORY g 0

                  - R0 ANSWERS
  • SRO ANSUERS h*
                                                                                      / I        '

UllMARKED R0 Afl0 SRO AtiSWERS i

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                                  .                                                         1 0      1.       a.      Explain the tenn Decay Heat (1.0)
                - b.      How and why does its effect vary over time after a rdactor trip from full power? (1.0)                                                                         .

0 2. A suberitical reactor has a count rate of 30 cps for X,ff of 0.95. What is the count rate for Xeff of 0.987 Show all assumptions and work. (1.0) *

3. Assume your reactor is critical at 800 cps on the source range. The operator with-draws a control rod 35. Assume each percent withdrawal adds 0.06% 4k/k.
a. Whatwillbetheresultingperiod?(2.0)
b. Sketch thechart resulting power trace on the recorder pacer (Figure A-1). Assume on inch / min speed. Use attached chart paper. ('i.0)
          ...c.          Assume a reactor trip occurred 010 5cps.' Sketch and explain the response on the SRit. (1.0)
4. ' a. If 1% excess reactivity'is added to a reactor that is critical, the resulting stable positive period is very short. Explain in detail why resultsthe in aaddition ofnegative long stable 1% negative period. reactivity 1.0) (to a critical reactor
b. For the case of adding 1% positive reactivity, would the reactor be considered prompt or super critical? Explain (1.0) l
5. Assune the reactor tripped from 100% power.

a. Plot the resulting Xenon curve for 100 hours after the trip. (0,5) b. Using a dash line plot Xenon if the reactor was started up eight hours after the trip and raised to 50% power. (1.0) c. . Discuss the problems on startup 8 hours after a trip. (1.0)

                                           ,                                                                           l

r 6. The of Moderator cor.e Temperature life. Explain Coefficient is known to be most negative at e the reason for this condition. the effe necessar,ct on each of the applicable factors in the 6 factor formula. Includ y to define each of the 6 factors.) (2.0) (Itisnot 0

7. .

For Is thisthe attached reactor Figure shutdown, A-2, critical, or calculate supercritical?each (1.0)of the factors in the 4 es O g O es e O a G E O e e 9 e 6

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( . b,<0u e [M nil 10. 'n6Y YR.

3. Classification: (U 1 or. Ops u-Tt -
                                                  \

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4. Reason for' assignment-
                   /                                                             -

r SFSR Requirement Cycle: D

            . Lecture flissed Type                                                 Cycle Co.mpletion Date:              / W .9 .':? W Test flot Taken
                      ,                                                            Time Period:)_j'W M ~7:57 - / /f ?.'eC ?f t('80% on Test                                                      Type of License (RO/SRO): 52.0 M--C E       Instructor Assigned:                   d ef.               t)fdd-                              Instructions:      -
           &:,La A a l k J A 6 < J                                                         c .e.              e u s d . 6 , .-                      .
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6. RETURil TO TRAIllIllG DEPARTliEllT BY: _ / N E/$ N
7. Method of Evaluation: (Check at least one) a) t!ritten Test V Score:

b) Oral Spot Check ! c) Other (Explain):

8. h InstrTet'or's Signatur(c,)

w_ r ~)h?( ,

                                                                 ' Da'tel              Supervisor of Training                                     'Date
                    ~.
                  .                                                                                          SRO 10.0 pts CATEGORY H (K)

FUEL HANDLING AND CORE PARAMETERS [

  • SRO ONLY ANSWER
01. What are two (2) reasons for having end voids in the fuel rods? (1.0) 0 2. Describe the physical differnnees between Control Rod assemblies and Axial Power
                           -Shaping Rod assemblies.

(IncludeDriveMechanisms) (2.0) o 3. The following data was taken during the loading of a reactor core.

                    -                                                                                             Estimate the number of fuel elements required for a critical mass and show how you arrived at this number.                       (2.0) l                                                                                                                              '

HUMBER OF ELEMENTS ADDED COUNT RATE (Cos) 0 100 40 121 20 139

                      ..                                        20                               161 10                               175 10-                              180 10                               200 o 4. a. Ilhat is a " reactivity anomaly"? (1.0)
b. .

Describe the method ,used ,to determine if a " reactivity anomaly" exists. (1.0)

c. What action (s) must be taken if a " reactivity anomaly" occurs? (1.0)
  • 5.

During a reactor refueling an irradiated fuel assembly gets stuck in the "A" Transfe tube when the fuel transfer system East system, fails. Describe the actions required to remove the stuck assembly. (2.0) ~

1 l l

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CATEGORY E _ j-SAFETY AND EMERGENCY SYSTEMS E

                                                                                                                             !        0 0

RO only answers SR0 only answers-UNMARKED RO and SR0 answers

                                                                                                                           })                                 t L
1. List the conditions that wil cause a rea.ctor setpoints. (Assume at 10
                          ? __ - O +.oe)*r**           =~4 (2.

v4,0)o j--a 3d

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  /                .

During thiee (3) pump operation the anti-reverse rotation t"',c! *= +5'? #d'e

k. #)agtoggpumpaiggribpt Je rj systy..f(2.0 ,.yj 3.

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                                                                                                       *+ w & nOY.                                       f Following char.ged.            a loss of all four (4) reactor coolant pumps the OTSG feed lineup is(t
,e          [           a.

Describe the lineup (a sketch may be used). (1.0)4-4pMc. rw 7., .~a.  ; 9 r (Describe the reason for the lineup change. (1.0)c, 1 . - # A d -A

  • 4 4 1t, - p 1L.7 4 .
., 5 3
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associated with ufpose~ th rapd.of the rea,ctor coolant system pressur n m =,e decay)~c heat removal system. (1.0)/W&- ~=/f a u s.

                      -tomplete the following table for the Emergency Core Cooling Systems. (2.0) 5YSTE!1 DESIGN FLOW

_ SOURCES.0F WATER HPI .s s

  • ype--/ m B'< S !' - P ^ f LPI J'8'~ # 7 Reactor Building Spray asW')MN f.sveg ,

sist -(4 Y

  • i List tppjpr cess radiati n onitor '

_ M*AG17 A'. A ff ., /*d(2,phich A will rttstop A / flo'w when in High Alarm. (2.0)

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1. *csson/ Course:
                                  ,                                  ,,                                          Employee I;o.

Cor.pletion 1 Dote

2. flama: d. - O'/ Idi3:%i42. o. 'OAY Y 2
3. Classification: bu od. QF COURSE i;@ E PREFIXES CATALOG t!Ul!BER ,.
                                                                                                             "3__"                       -

DUPATI0tt fla$:eup - MVP cl ggg, pp2rIx

  • 22 34 Correspor.dence - CCS LESSCT 27 31 15 A TYPE SUBJECT ID 26 ,
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                                 .: 1 11 CtEt i
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l 35 CO?tMD TS 9I

          ..IIIIi11I IIt iII IIffIliIII
4. Reason for assin.want- .

NRRequirement Cycla:

               ' Lecture !!issed Type                                                             Cycle Completion Date:                     / .47.4 -79 Test Not Taken                      '

Tir.e Period: ###4Mi. 07. L / .D.:P!.M V 80f,on Test Type of License (P.0/SRO):

5. Instructor Assigned: 6./7./ru$ fd Instructions:. -
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6. RETUR!l TO TPAlllIllG DEPARTMENT BY: / Y.Y 7 .' h3Ak 1
7.  !!athed of Evaluation: (Check at least one) a) 1fritten Test Score:

b) Oral Spot Check c) Other (Explain):

8. hA $

Instrutfor's Signatur(.,) i 2 3f21

                                                                                ' D3te /                 Supervisor of Training y
                                                                                                                                                                    'Catu

a.

                     ,isExelain in detail how an ion,ization chamber can detect uncharged.                                                                                                 amm y &JM U.5) /M #'d
                                                         ?/

f L' . Mradiation M , which m&r de-- ? n * & ~ b. Is an 1onization chamber sensitive to the energy of the incid(nt gama [ , radiation?

r Explain wg or why not. (0,5)4 L
                         ,es.- ?G 'n         u #:}?M:s       -4 m      -L           -f/= 'i r- -,%            w- A 'i s
                                        ;xL.:-                                                        !., 4 /                         .-

-

  • 6.  : n-D  %
                     # efinef"Sul y, d%pergfon                    J
                                   ~5H>zard"4          wiTh r                            to radioaq)fy isotopes. (10)                                                 '

2 bc. f N f b* f "',- *]A # espec-?? D ~ . #Sme* ^' Canorrespiratory why why not. protection credit be claimqd for submersion Explain

                                                                                                                                           **h*

a ha ards? f*M (0.5) y g e T z)M yg .,4.,4 , e

                                   * , 'S
7. a.

o What ( 0. 5)isfthe

                                 /,J Technical 4 ,,g          Specification lig r Reactor Coolant System Activity?

_ ; *f A 13 4 foy~ wg 2. Illhat(0,5)p^d4-/W' actions are' r.guired - by v4 technicald4 - specifications o j

                                                       ^ Tsk
                                                           ~ Q4o % c.cs. s/ 1 red 4 A M'                                  -

p hat is the

                               & basis for this limit? (0,5) g h . y g g / p oT5C.

vA.s =s ' b Ip ,--- ,W: ~/p A_:f p t 9 4

                                                                ~ ' " ~ ~ ~ " ' ' ' * - - -             _ , - _ _ _ _ _ _

RO 9.0 pts SRO T5 0 pts CATEGORY G (G&I) - RADIATION C0tlTROL AND SAFETY O RO answers

  • f, SRO answers UNMARKED All answer I1
                                                                                            / I              .

0 1. Djscribethe reductfon Ha,n p N-16

                       , o ..' -~ gs                             ..s r and
                                                                        ., p ps hazard to plant personnel. (1.0) g h      .2.       a,                                              1 e 4.u <.
                              ' List the Quality Factors for the following types of radiation.
1. Fast Neutrons (0.1) k '- n _ - '- -i  %
11. Beta (0.1) jy
  • iii. Thermal Neutrons (0.1)/0 k iv. Alpha (0.1) y/ .

dow goare the= Quality r_ , Factors e w A related to biological damage? (0.6) r,. z T-our protective clothi I. 'After yourselfproperly for contaminan removing [s anc find the soles 07 frisk at a step-off your shoe apparently from the set-off pad. . hat should be your imediate actions? (1.0) ~ ~ [cogmgtstootherWhat s precautions h should be taken to g on your way to the decon area? (0.5,

                  /.' What   the contamination limits must be met to permit wearing these shoes to leave
                      ' -           ,cgn, trol access point? Be specific
                                           ' gio.ro ypo              pr two &n(0,5)   n-4         4 4 * 't ~&-

4. After working on a small radioactive fitting for two hours you discover that your pocket at one foot. dosimeter is off scale. A survey indicates that the fitting reads 800 mr/hr fitting, You estimate that your average working distance was two feet frem the

a. Estimate your dose. (1.5) M d M k *
  • b.

How much additional dose are you permitted to receive this quarter? Justify

  /,

ny f _

                                        .1   , .   .'s h , , J.A .A L S " '-

e' ,i TRAI:li!!G ASSIFJ:ME :T AC.'!!.'.f STD.ATI'!E F.%'t

1. .esson Course
                                   .W G .:2:'.-3t,h>>...%.o .!b?.. .!u. 0
                                                         .-                               Employaa ilo.           CcmpletiETa te 4              P, 9                             14
2. Ila:aa: QUO L -

Y 8INI L - f t0. ' DAY Y P. , l '

3. Clcssification:__ S O4 M " - N 4 5 l '

CATALOG Ntit13ER ' CollRSE _ lite PREFIXES ct DURATION HOURS I  !!!keup - 14UP A Correspondence - CCS 27 31 32 3 T LEss0:! 15 A TYPE SUBJECT ID 25 7, ,ff,g /.ft'v g 9 (N 5 49 41 f i 0101 l . 35 COMMENTS nI

       . .It tilt 1I III iit iIIIIIIiii
4. ~ Reason for assignment-MSR Requirer.ient
                                                               ~

Cyc14 : I Lecture llissed Type Cycle Ccmpletion Date: /d/M/?,79 Test flot Taken Time Period:/M#~'- 7e? - /.4 e w.~/ "P g <' 807, on Test- Jype of Licensa (?.0/SRO): 5 Instructor Assigned: C. (7. /I) f 80 Instructions:. .

             .C .;f hr.a t* *. $ 1.ts.? $ h ,e ,e..G !'                        m, . ;- $ . s no.'b l .s%.               .#....0h  .
               *. .'* :f.L d.$lf !;1 #.-l b.                    .
6. RETURil TO TRAlllIl!G DEPARTItEllT BY: /r~/? ~79
7. Itethod of Evaluation: (Check at least one) a) Written Test / Score: .

b) Oral Spot Check c) Other (Explain):

8. hYAo&

Instruct'or'sSignatu&

                                     =                       , "7h19
                                                            ' date'               Supervisor of Training                        'Date
                    #              E
+- .
        .N J. R. FLOYO                                            Riticops[/

ACCELERATED TRAINING PROGRAM Assign. Instructor g Grade .Q3,ts, Sienature rh p b b T. Viewed NET Module #3, Unit 12 I - ' ip, and ampleted Questions 12.3 -

g. l A
  • 5dhay
2. Read Reactivity Balance Unit I/II and completed Reactivity Balance.
                                                                                                                     'e'
                                                                                                                      .)                                       / /

7/M/7[

                                                                                                                                                                              ! //' /-

M/

        "+                                                                                                                                                                                                       -w'--
        * *8f                                Review the fellowing with Instruct-ij 4 %Y-3. or '
                                       ./ a) stuck. fuel assembly in transfer                                                                                                            7'             'Y tube.                                                   S                                 7/iibi        ..

di &% ~ os C

              '                        / b)                 System ' response to failed RCP
                                                                                                                                                               /../                 .f.

anti-rotation device. ,3 7//// M. /J didd - ,

                                                                                                                                                         ~7!8 7f
                                                                                                                                                                                                                         ~

s (H yst r. . f 4. discussed h Read Unit I/II ICS Procedure dd. response UT3G line)-up c upon ,h failure of 4-RCPs. '~ d -r['//77/,-

                                                                                                                                                            '//                 -{/ J
                                                                                                                                                                                .                                  4,-
                                                                                                                                                                                                                   /
              .      .            5.        Review a11 Rad Monitors in both                                         O W/g,                                                j Units I/II and submitted descrip-
                                                                                                                        ' 'I * ./           *W                  j, /., c, 4

tive ifst. . o f -)fm

Completed comprehensive written i f 6. -

exam.

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O REACTIVITY BALANCE PROCEDURE REVIEW OP 2103-1.9 CALCULATIONS: A. Reactfvity 8414nce at Power 6 ((gy

                        'l.        Core Age = 300 EFPD                    '

Boron = 610 PPM ,

                         ',        Rods = 6/7 9 905, 8 0 38%

Power = 505 Tave = 582' F ,

                    ~

Equilibrium Conditions for Xenon, Samarium

2. Core Age = 100 EFPD -

8eron = 1100 PPM ,

                ,                 Rods = 6/7 8 905, 8 0 385
  • Power = 1005 -

Tave = 582'F -

 )                                                              ,           '

Xenon at Equilibrium ,

                              , Samarium at Equilibriun Assianment:
1. '

Perform a reactivity balance calculation using information given above. 2. Based upon the results of the calculation, describe action required, if any. e . 6 J(' e

4 a
                              ) h,.A % .

2103-1.9 Revision 1 N ' ' 09/08/77

      -                                                                   ENCLOSURE 1:. REACTIVITY CALCULATION PART I:
1. Reference Conditions:

(Circla appropriate reference conditions). ' fReactivitySalanc]e. Shutdown Estimated Power ' Marcin Critical Position I T Average 5829F i 532'F 532'F -

    .                                        Average NI Power                     1005 -                                        05                    Os Control Rod                                                                               *
          '                                  Position                             1001 1001                   1005
          ,                      2.          Actual Unit Status.                                                       -

A. Taye 4~ C 'F.. DIS .

8. Average NI Power (O ' /d 5FP:

W NI-5 _5FP

,s              .

w.' - NI-6 <0 _5FP p NI-7 A %FP l00 NI-8 d 5FP -

                    ~     -

C. Core 2 ed EFPD. '

                                        ' D.
                       ,                          Boron Concentration                          G/0             ppm.        //d # '

E. Rod Position: Group 1-4 /0 / 5WD Group 5 B"5 COM D W BE i

                                                                          /-o        %WD                             '-
  • Group 6/7 4
                                                                             #0     _%WD .                          J' Group 8                    aY       %WD                            -

y,gT[: All positive (+) and negative (-) reactivity valves will be taken frem'the figures. $ 3. FuelExcessReactivity(Fig.8/1A)- M.O

y -
                                                                                                                                              '~
                                                                                                                                                 %4K/K f/0, / 7o+ 1fff' M
                                                                                                         .                                                                                      I 22.0                                                - . _ _ _ _ . - - - - _ - _ .
                                                                                                                                                                                       ~~~~

2103-1.9 Revision 3

4. Control Rod Reactivity:

A. k i

                                          ,          Groups 1-7 (Ffg. 2/2A/28/$) -0.oW fak/k               -d dN E#

v E: For shutdown Margin a== =e 0% withdrawn for Groups -7.

3. '

Group 8 (APSR) (Fg. 4A h - t ut., _tak/k

                                                                                                                               ""*D         3 C.
                                 ,                  Total Reactivity of Rods (Gp 1-8) 4a+46=

8

                                                                                                   -I.,

tak/k. -8' d Do'.s

5. Boron Reactivity (Fig 5) -l. . /.,

tak/k.-it,[vj[ J y A. , Baron Ratio (Depletion) (Fig. 5A)_O MAf#M ' z. p 8. Effective Baron Worth 6. 5 x 5Ae -r_. a a sax /K /v.9 f* - II* ' Xenon Reactivity: [6 e A. For Reactivity Balance at Power use Figure h # u I  : B. For Shutdown Margin use Figure 6A (if at equilibrium) or 1 Section 4.4 for transient conditions. C. 7,rs 9 For ECP see Section 4.4 TC. n W %Ak/k 0 ~1* 10 7. Reactivity associated with tempe ature change: A. /

   )                                              Reactivity coefficient (Fig 7Ah 0< 73 '7 3 54k/k/ 8 F. -d 8I'A g 8.

Reactivity due to tianperature change - -

                                                                                                                        - sa ,'

(7a) X (Tave - Reference Condition) - C 54k/k O O NOTE:

                    .                                         For shutdown margin when the reactor is at power,
             '                                               use 014k/k for temperature change reactivity.
8.

Reactivity associated with power change:

                          ,             A.
                                                ' Reactivity due to operating below 1005 FE COM MA UE                                   -

(F,{g. 8) f d,3T tak/k O ' B.

                                                                                                 /%U 1ak/k /J/#

For SOM or ECP use 054k/k o g. Samarium Buildup after Shutdown time since shutdown days (Fig. 9) (For SOM, ECP only)

                                                                                                 /k [ EAk/k gy N '              C 50TE:

I Insure that the correct signs have been recorded from figures. ' j 10. Stuck Rod Criterta l A. For Shutdown margin use +3.915aK t' A ' / l 5. For At Power Balance or ECP use 0%Ak/k O TA4/4 O

2103-1.9 5 Revision 3 09/22/78 *

11. Net Reactivity (p):

G ' , yt,. c ,

 !v                                     p (net) = p (fuel) + p (rods) + p(boron) + p (xe) + p (temp)

{ power) + p (sm) + p (stuckrod). . Add the values recorded for the following steps: p (11)t*6= 0p (3) - e<fi + p (4) + p (5) + p (6) + p (7) + p (8) + p (9)

                                                                                                   .-C. ax eMSSI (10)              er*. b                ,
                                                                                                                                  &          perg-5'             mk            0
                                                                                                    .u. t /        8              e
                                                        + par:$1'                                   . Ile1 1
  • M
  • c ,o o "*% q g 9 f g
                                                                                                                                                                    -2D p (net) = fv.J t tak/k '"

p

                    ,             *3:                         Refer to Limits and P utions section 2.0.
e. M A.
   .h i #*               , H . if                                    Shutdown Ma j
                          . p,                           '
                                                                                            '/ n. p (not) must be more negative than:-
                                                                    -25&K/
   .-                    . N '1                            -

enXeff61(T53.1.1.1.a) - i X/K when Xeff 9,4 w J#M* 8. 71(TS3.1.1.1.b)

r+ q The reactivity balance must be within + 0.55 ak/k ( ,

or + 0.85 Ak/k (transient). s Calculat by:

  '")?f                                                                                                        '/:/#Nf gg Approved by:

Uperator '

                                                                                             ~

Oate/ time

                                                                                                                                          /Mo.

BMI g $hN 5A1 t foreman Date/ time RETURN TO NUCLEAR INEEA I \b'~ b#

                                                                                                                                                            ~

av~ e p nr,, > cA-

l. W. 5[

yp / A bp WA ,- . . w' p*

                                                                                                                                                              ,r           ,

L).

                                                                                                                                                              .:/c c                 .

1 e {- 24.n

9 r , 1103-15 Revisfon 21

    ,                           15.,3.1.4.                                                                         04/11/78                   ]

calculattenal Method Ourino Power'0eeration -

                                                     ,(not)=a(fuel)+o(rods)+a(boren)+o(xenon)+a                                              !

(temp)+a(power) gg: .

                                ~                                 Use Table #1 to aid in computation.
                                    ' 1.                                                                    8[g7                             i Excess reactivity associated with the fuel.
a. Core age /t d . //

_EFFO.

b. Excess reactivity of Fuel
                                                                                                +

14k/k (Figure 1) 2.,

                                  '               Reactivity of rods inserted in core.
a. Reactivity of Groups'1 - 7 tak/k (Figure 3) b.

Reactivity of Group 8 (Figure 48) - ' tak/k

c. Total reactivity of Group 1 - 8 (2.4)+(2.b) *
3. _ tak/k Use Figure 58 to determine the reactivity associated with 'd th
                                            ' present boron concentration.

If the computer is operational, have an assistant go to the performance panel and call for Print Point #852. Check to see the baron concentration printed is the actual current conce in ppms. If it is not, have the corrected' concentration inserted. '

                                               >(                                                           9 J

s, 4.0

1103-15 Revision 22 06/09/78 a. Scron Concentration opm 5 - h *

                                           '.b
                                                ~

Soron Reactivity Wcrth 14K/K 4 Reactivity Associated with Xenon A good...

                                                      ' approximation of equilibrium Xenon worths can be obtained
                   . ..                     for various power levels from Figure 6.

However, to use this graph 33,',' ['.' without applying any correction factors, no power change may have taken place in the last 40 hours. If the reactor power has changed in the last 40 hours, the Xenon reactivity worth is difficult to calculate accurately by hand. Therefore, if this situation arises, do not attempt a reactivity balance calculation until the plant has been at one power level for

                                          % han.              -
a. Xenon Reactivity Worth. .

(Figure 6) - 14K/4

)                                        b.      Reactivity due to Equilibrium Xenon at 1005 F.P.

(Figure 6A) Tak/k

c. Reactivity due to difference from 100s Equilibrium Xenon (4.a-4.'b)+ 14K/X NOTE:

Reactivity due to difference form 1005 equilibrium xenon' is used because the Fuel Reactivity curve used as the reference condition is based on 1005 equilibrium xenon. l e 0 8 44 5.0 ,

f..g, ' f , , MtP15 - Revision 13 05/22/78 5'.

                                                      ' Reactivity Associated with change in nuiderator temperat:Me                                                                                                              -
a. Baron concentration ppm B .

Y!.Y5re coefficient of reactivity (Figure 75) * '

                                                         .                     -                                                                       i                              sang
c. Present Tay

_ . o r .

                                  ,                   d.

Reactivity Associated with moderator temperature . change ' (5.b)(Tay-579'F)

                        '                                                                                                                              1-                            sayK
8. , Reactivity associated with change in power (from 1001 FP)
a. Core age EFF0 . * *
b. Present power level . ..

1 FP -

c. Reactivity due to oportting below 1005 FP.
                                                             . (Present Power , doppler. co-efficient)(Present Power-locs)+                                                                      SAVK h Reactivity due to difference from 1001 Full Power is used                                                                                                                '
                      .                      .s                      becesse the Fuel Reactivity curve used as the referenca 2,.

condition is based on 1001 Full Power.-

7. Net Reactivity
  • p (Net) = , (fuel) + e (rods) + e (boren) + o.(Xenon) ( + e ' temp) + s (pow p (net) = (1.b) + (2.c) + (3'.h) + (4.b) + (5.d) + (8.c) .

p(net)= EX/K , Jggi, The abovai sua. should be zero 10.51 (steady state xenon) .. . or10.454X/K (transient xenon) (see limitations and pre-cautions - Section 15.3.1.2) , . .

                                                                       ,                                                                                                                                 e i                                    '
                                                                                                                                   .          4   8
                                                                                                      . 4.0               .
                                                                                                                                                                                    ,                                   ' eeW8
                                                                                                                              -                                                                                                      1 i

e

               ,,             ,                                                                                               1103-15 REACTIVITY           8ALANCE DURING POWER                          N 'i "OPERATIO 0                                                                    /O9/78
  '                               Tay1.e'l - Ref Cond_579 F,1005FP, Eg Xe, No Control Rods                                .

CAUTION: 1.a Coreage__IdO USE THE 579'F FUEL CURVE AND THE 579'F RCO EFPO b Excess Reactivity due to fuel (fig ) F*,- MST COPY AVAILABLI 2.a Reactivity.of Rods Gp 1-7 (Ffg. 3) - o.e4

                                                                                                                            + _ **                 RK/K b                                                                 ux/x Ms '                         -

Reactivity of Group 8 (Fig. 44) - _ ** $$ L tax /K c Total Reactivity of Rods Gp 1-4 ' 3.a Beren Concentration // d d ' sps B ~

                                                                                                                          .' f' N :- uWX   '

b Reactivity due to Baron Concentration (Ffg. 58) M - 4.a Xenon Reactivity (Fig 4) - M

                                                                                    ,2, p.
                                                                                                                       = /J # ax/X                1
                 -                                                                                 s4x/x b Reactivity due to Equilibrius                                                                                  ,

Xenon at 1005 F.P. (Fig. 6A)' '" M c ' 1ak/k'F . S Reactivitydifferencefroml005Eq.Xe.(4.a-4.b) +00b 5.a _ tax /x ' Temperature coefficient (Fig. 73 "" 0' 8 8 8 14x/x F b Present Tay M'F ' P c Reactivity due to temperature change ' *e,tA (5.a)(5.b-579) .

                        '6. 4 Present Power Level /.'0 sFP C OA3                       tar /K b

Reactivity due te Operating below 1005 FP Present Pcwor Fig. 4( (Present do ppler co-efficient) x Power

  • 1005FP) ,, + _O ux/K 7

Net Reactivity a a (net) a p (fuel) + a (boron) + a (Xe) + .g

,          ,,,,41                 *
                                             )
  • 8 (E'"'d
          . i 3,',"                                                         h ,4 '.                                                           '
               o (net) = (htr) + (3,4) + (.L4) + (4rtr) + (5:e) + (4str) 69,/73
                                                                                                                 +               =

i l _54X/K  !

       ~~ l );              ,' Refer to Limitations and Precautions 15.3.1.2          '

t

                          ,9                                                                                                                               i j f.n )

Calculatfons performed by _ ' Date/ Time _ RETURN TO NUCLEAA ENGINEER Approved by

  • Date/ Time 76 -

M'

REACTOR OPIRMICN

12. Fuel Leading and Startup (centinued) j IR. F/or .

7d

   'N                                    suit shows a prediction of.between 209 and 210 bundles needed e  ritica
                   \ ,' be         a
                                                                                                     ~

actor. The 1/M plot tends to Aatten cut a bit as 'we' add fuel,

      \                     R              fuel added to the outer edge of the core is not worth quite as i 4:        el added to the center.

(Fuel assembly worth is propertiorial to Sux J j ' vel just as control red worth varies with aux level.) e .t1_ 4.kl. 12 .3 -1. You have a 49-fuel-element core. The source and locaticas are showet. Number the core map to show in what y order you would Icad it to critical. Explain your selection. g(f ;p

  • ayl.y) '
                                                                                                 .k n = # & A.

10$ 3 . h.

                                                                          ~

f

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I. m Wf#M' C b - ' A L '2 v4 se tt.) . ' DETICTOM 2 6 .'l 9 8 .' At J'i DETE OR 1

                                                    %   ;4  %  "'

t/ 11 4 v.) W af *.' .tr yc w C$Wk & b9l

  • db '

c'a,bl4or 4.hade,A

                                                    .!? W                                                              ;

ldfe4 ****h / ' Ii 478 12.3-5 m

a ' EC"JOR OPERAT CN 7g5 12 . Fuel f.cading and Startup (continued) s ' 12 . 3- 2,, , ' The following data as taken from detecter 1 while the core was being loaded. ' do you prodlet the critical condition to be ?fecm th Eund1e Number

                   ~

Neutren Count an ta (Coun % 'Per Second)

                      ,              10                                        !< 0 348 11 347 ve ts/ 7 12                                          3,ff7 347                              ,

13 : -

                                                          ..          348 0*T4Y 14                       -
                                                               ,      351 #' O '                         .

15 358 4'4 7k 18 35 7 eId 9 . 17

         ,                                                            345 v M T 18                                 4gg v. f'M-
  • 0' ,

4 g 0 ??7 AVAIU l 21 ' ,e 435 a,44 9 32 ' ( 550 0 424 . 23 . g7 y ,$~ l 24 g g g,,c,, c - 25 g g 0,391 28 - gg4 .r, 9 9 - 27 880 .N >~J I 28 8 2 8 0 . V isf . 29 910 8.fJJ 30 1000 J. 5 y', 31 #' A 1110 32 13 20 u, .u, s 33 1320 v. 4 A 34 2085 # ' ' N0 , Y34 J :- f, d f*,

  • 876 19 sa
                                                                        /ak-        M
   ~

REACICR OPI?JCION - [#.f.

     .                     12 .
       ,                          Fuel Leading asui Startup (centinued) m              -

e e s 9 9 9 e 0 9 8

                       .                      O e

9 e 9 9 .

                                         .                         =,.

j .., . e s O. sm COM AVAluBE .

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e e e e i I t 8W C0H AVAllAKE 4 l 9 ' t == 4

         /      .
        .             . RIACiOR OPEMUON                                                                          .

I'2. Fuel Lcading and Startup (continued) .

                               '.                                                Unit 12 - Fuel Leading and Star:up Quiz       ,

Name: $.0 $l"/ Cate 'Jok'pn Score: O .

1. DefLne h

hhhd a .- Subcritical multiplication .b et a-c * . ' ~ ' ~ 5 p,e L%py _ 'T L kr, y+ JfJL ~,~_n_~'~ 1: _,- f-i

b. ' Normalization fketer .,2t/.+ = s ~.+..- n
                                                                                                                                                    . ,M y4 c _ JQ L -, ,, !                      I      W          X,;y      ==    '  =u-y w h .~. U L , g .                    g ._ , _         ~

y' m

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i. :
  'g' .
c. 1/M plot a. / - .7 w+ , _ - MM A F ^ = =' (5)
                                                                    ~ ,~ 3% .Ja qA9, ;
2. In the echtse of a reactor startup, the neutron ecunt tr.ta dcuhles. -

What does this mean to you as the operator? $Ms.d#-- 60)

                             .    $$A G t.'. on, q'),452.2 7 J ; -                                  lpa.vM*V
3. a. :Qtue of,Talse)DA JJ- from the source can be The neutrons neglected tf the reactor is operatic 7 at power.

g (5)

b. D< plain your answer. (15)
                                                                         %u
                                                                     ~a49,2p
                                                                                                       */ p y-s."a, 2%             9
                                                                                                                                                            <4 f, ,yk. x n a/L ch / A JLA                                                                .
                                                                           ; w 'p ~ ~ . , d 4 f ,. f 2                                           'f s

h ava r., .

                 ~

REACTOR OPERATION

12. Fuel Leading and Startu; (centinued)
4. N r$a two methods of predicting the c:tical condition. when starting

( up a reacter. ,.

a. A. fas. ' W~ Nb -o_9<.</.**'? W (5)
                           .b .            IltA        EWY                                                             .

{5)

5. A reacter shows a neutron ecunt rata cf 1000 counts per second when k eff is 0.92. What will the count rate be when keff is-E- ff,.S5,,3,,,, (10)
                                    .y i L >~~w, g , I -d' 3,          1 -< u g.Ko 1

4 v

s-ku .
                                                                                                                         .e
                                           -                j= ^*
  • i so c p*s,, ., t .
                                             -       jopa S Y '-),.s @ ~

1

o. o = -

l l .. c. t&oo ~- 6v [ 1 . l

b. 0.98 '

(10) s, cs sol' W,. s u,, Y s . .(~ l uI i.

REACTOR OPEFATION

12. Fuel Leading and Startup (continued) m .

r 1, 6. A reacter has a neutron source that produces 120 neut cas per second.

a. If the neutron inst:t=tentation shcws a count rate of 1500 cps, what is the suberitical multiplicatien? A+ = ,ya- (5)
                                                                                                -4. = ..%

l a, {J -M.h .a .

=0 -
                                                                                                                                                      " & c.
                                                                                                                            . ' ~ :). Q . ;1*'                                                    ,

M _ ,3 .m - v.- -

b. I' the.reacter abeve has a ner=alization facter of 0.25 what is k,g? g,9( kj
                                                                                                                          .. .                                                                                                            ~

(10 G '- r ._./D . a ccS O _ ,!

                                                                                                                                        *I.
                                                                                                                                                                                                                                 ,.,n>>

Goes :. wed

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               .                                                    ACCILIRATED REQUALITICATION TRADTCIG PRCGRef I;q3 FOR J. R. FLOYD
                                     ~

JULT 1979 [ MIN POINTS  % 40 MAX. PODITS 80 50 100 [ CRADE .h L-Name e pt

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{ l. 4ith tha aid of a sketch (required) describe how the RCP Marlin Clutch wor'cs. (10)

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            ~.                           .

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                .2.         a)

Calculate 1/m the ' number plots for.,both of fuel(required). detectors assemblies required for a critical nass based en

                                                    ...~....

(5). < b) Isthegeometh.forthedatasatisfactory? Why? (5).

3. ..

From the condition given, calculate the core shutdown margins. ITsa_tfI-II reactivity balance CF, and tha attached calculation sheets. . Show all woric. ,

u:

a) Core Age - 300 IFPD . 4 , Baron 610 PPM

  • Reds - 6/7 6,90%, 8 @ 38: "
                      *p          Power - 50             1.

k Tave - 582cF .. Equilibrium Zenon & Samarium (3)

      -M                   b) Core Age - 100 EFPD Baron - 1100 PPM Reds - 6/7 @ 90%, 8 9 38%

Power - 100%~ Tave - 5820F-. . Equilibrium Ianon & Samarium (3) , 4.~~During a. core loading,'a CR of 300 cps is recorded when K = 0.9. [ a) What is the C1 when E.= 0.957 (2) f b) What will be the K at 900 ~ eps? (2) 5

         / 5.

I.T the event that the fuel storage pool was inadvertantly filled with unborated [ water, would this pose a criticality problem? Explain your answer. (For both type of spent fuel racks) (4) 6. Complete TMI-I the attached tables concerning accidental releases of radioactivity fron and TMI-II. i i

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          '~     '.

2103-1.9 Revision 1 q f .' 09/08/77 < ENCLOSURE 1:

       ~                                                                     REACTIVITY CALCULATI'ON PART I:

1. Reference Conditions: (.Cire,le appropriate reference conditions). Reactivity Salancef Situtdc,wn Estimated at Power i Marcin / Critical TAverage Position 582"F . 532 F

                               ~

532'F Average ~NI Pcwer 100% 0% 0%

  • Control Rod
                   ,                  Position                   100%                               j 100%    i     100%
2. Actual Unit Status. . ,

A. Tave f P 2-F.. B. Average HI Power A ' -

                                                                                %FP:

HI-5 _%FP

   ^..

v) ' NI-6 TFP NI-7 ZFP . HI-8 %FP C. Core 2a c

               .                                              EFPD.                                                      .
0. .

Baron Concentration SId opm. 2 E. . Rod Position: Group 1-4 /M T4 Group 5- /#8 %WD \ Group 6/7 99 TR Group 8 .39 TdD NOTE _: All positive (.+) and negative (-) reactivity valves will be taken frca the figures. 3. Fuel Excess Reactivity (Fig. 1/1A)~ -f IP, 33 .j %AK/K 22.0

                                                                                                                                          \
                .                                                  BEST Copy Agy                     n%d 2
        '                                                                                            09/22/78                             i
4. Control Rod Reactivity:
                                                                                            /                                             l
                                   .<, A.          Groups 1-7 (Fig. 2/2A/23/3) -- Te O "ak/k G                                                                  ,
   ,_                                              NOTE:      For shutdown Margin assume      ithdrawn for Groups 1-7.
8. Group 8 (APSR) (Fg. 4A/48) - a,3 3 %ak/k g C. Total Reactivity of Rods (Gp 1-8) 4a+4b= '- 4, f 7 %4k/k.
5. Baron Reactivity (Fig 5) -7,4 S %ak/k.

A. Scron Ratio (Depletion) (Fig. SA) d. 9 V2 7 # B. Effective Boron Worth 5 x' 5A=_._t,,t,5 gax/K

6. Xenon Reactivity:
                                         'A . . For Reactivity Balance at Powe'r u::s Figure 63.

_,,ff B. ...- For Shutdown Margin use Figure 6A (if at equilibrium) or - ., s-d -

              ,                                   Section 4.4 for transient conditions.                  [            ,_02'A T C.       For ECP see Section 4.4                   - 28          Kak/k      2 ' f
7. Reac'tivity associated with temperature change:

Reactivity coef.ficient (Fig. 7A/B)

n. A.
      ).                                                                             .      .
                                                                                                         %ak/k/.0F.     . . . . -       .
8. Reactivity due to temperature change .

St*

  • SW (7a) X (Tave - Reference Condition) O %ak/k N

NOTE: For shutdown margin when the reactor is at power, use 0%Ak/k for temperature change reactivity. ! , 8. Reactivity associated with power change: l- , A. Reactivity due to operating below 100". FP (Fig. 8) %ak/k B. For SOM or ECP use 0%ak/k ~

                                                                                                      /

O %Ak/k ' l 9. Samarium Buildup after Shutdown time since shutdown .' days (Fig. g) (For 50M, ECP only) O Sak/k HOTE: Insure that the correct signs have been recorded from figures. '

10. StucX Rod Criteri.a i_)

A. For Shutdown margin use +3.91m,fs l B. For At Power Balance or ECF use Osak/k byRI X "ak/k

2103-1.9

       ,                                                                                          Revision 3 09/22/78
11. Net Reactivity (p):

{ r - p (net) = p (fuel) + p (reds) + p(boren) + p (xe) + p (temp) + p (power) + p (sm) + p (stuck red). Add the values recorded for the following steps: p (11) = p (3) + p (4) + p (5) + p (6) + p (7) + p (8) + p (9) + p (10) f*l% 43 - 1.ft - k W - 2. tf a 0 0 +s.4/ Hass -ss7 p (net) = -2.f3 %4k/k

  • 37.77
             *M

_ g ,g3 NOTE: Refer to Limits and Precautions section 2.0. A. Shutdown Margin, p (nat),'must be more negative than:-

         *                                       -234K/K when Keff >jl (TS 3.1.1.1.a)                                  f'
                                                 -1%4K/K wheg Keff < 1 (TS 3.1.1.1.b)

B. i

                          '                      The reactivity balance must be within + 0.5% ak/k (steady st O

or+-O.8%ak/k'(transient). Calculated by: M 1/as/71 a No - Tperatof Date/ time - Approved by: Shift Foreman - Date/ time

            ~

RETURN TO NUCLEAR ENGINEER e 9 J' 24.0

               '.                                                                                     2103-1.9 Revision 3           \

09/22/78  !

 .m
11. Net Reactivity (p):
                         #                                                            f ffhk
                               . p (net) = p (fuel) + p (rods) + p(boren) + p (xe) + p (temp) + p (power) + p (sm) + p         (stuck red).

Add the values recorded for the following steps: p (11) tis".f$

                                       = p (3)~ +4*p4(4)    7 -+11,14 p (5)-2.10   + p (6) + p (7) + p (8) + p (9) + p
                                                                                            <>    d      g th". $f                                                                                                        + 3, 9 /
 . S,4 } - - *4          9'1 (10)

II .16

 *II
2. , L. /

p (net) = -4 4 7 %Ak/k

                 ' Y '17' NOTE:

Refer to Limits and Precautions section 2.0. A. Shutdown Margin, p (net), must be more negative than:-

                                                -2%4K/X when Keff $1 (TS 3.1.1.1.a)
                                                -1%aK/X when     :' Xeff < 1 (TS 3.1.1.1.b)

B. The reactivity balance must be within + 0.5% ak/k (steady s-

  '                                             or+0.8%ak/k(transient).

Calculated by:

                                        ' Operator                                r [:n.3 /11  or/T Date/ time Approved by:

Shift Foreman Date/ time RETURN TO NUCLEAR ENGINEER 24.0 __- . _-

2103-1.3

4. Control Red Reactivity: hh& [
                                                                                                          /2 A.

Groups 1-7 (Fig. 2/2A/2S/3) - 4,0 Y %ak/k 1:0TE: For shutdcwn Margin assume 0% awn for Groups 1-7. B. Group 8 (APSR) (Fg. 4A/48) - a,3 3 ak/k C.

                        .                     Total Raactivity of Rods (Gp l-8) 4a+4b= - f. 9 7 %ak/k.
5. Baron Reactivity (Fig 5) -t2.ff %ak/k. -

A. Boron Ratio (Depletion) (Fig. EA) #' 9 M 6, B. Effective Scron Worth 3' 5 x 5A= -il. n gax/x-ldS9

6. Xenon Reactivity:

A. For Reactivity Balance'at Pcwer use Figure 63. B. For Shutdown Margin use Figure 6A (if at equilibrium) or Section 4.4 for transient conditionsr- - - - ~ ~~ ~ _ _ _ _ _ _ - - C. For ECP see Section 4.4 -

                                                                                            -2.78          %ak/k
7. Reactivity associated wit temperature change:

A. Reactivity coefficient (Fig 7A/B) 1

  *                                                                                                        %ak/k/ F.

B. Reactivity due to temperature change ! V (7a)'X (Tave - Reference Condition) O sak/k NOTE: i . For shutdown margin when the reactor is at power, t use 0%Ak/k for temperature change reactivity.

8. Reactivity associated with pcwer change:

A. Reactivity due to operating below 100 FP

(Fig.8) %Ak/k B.

For SDM' or ECF use 0%ak/k [ O

                                                                                                          %ak/k
                  . 9.          Samarium Buildup aftar Shutdown time since shutdown days (Fig. 9) (For SDM, ECP only)               d_       %Ak/k NOTE:

Insure that tne correct signs have been recorded from figures. '

10. Stuck Red Criteria -

J A. For Shutdown margin use +3.91baK,fK / B. ' For At Power Balance or ECP usa Otk/k f 54/ -;ak/h __.

h hhhk 2103;1.g

           ,                              calcu1&tional method may be used to determine the0 shutdcwn                                                argin m$99 0 if the reactor is critical and it is desired to determine hcw much suberitica1 the reactor will be if it is shutdewn or to calculate shutdown margin if the reactor is alredy sh'utdcwn.                                        If the reactor
                           .                                                                                   8 is at power. Tay will drop to 545 F as soon as the reactor trips; Tav is then reduced to 532'F.                                In order to be conservative,, it is assumed that Tay will drop imediately to 5328F.
                                       . NOTE:                    Obtain Enclosure 1 for c:mputation.

4.2.1 The reference ccnditions for the shutdown margin are 8 532 F, 0% FP, 2155 psig, no Xenon and no control rods. Verify that the curves used are for these referrenced conditions. 4.2.2 Obtain the folicwing unit status: ~ a) The average reactor ecolant temperature, TAV, can be obtained from the digital display window on the U Contrc1 Roca center censoie. ' b) The out-of-core (MI) pcwer level can be obtained from the control room center console. Average NI-5,6,7 & 8 to determine the power level, %.

                     ,                                          c). Core age can be calculated by obtaining ecmputer
  • printout #32 and =ultiplying the "STU this cyc1'e Best Estimate (X109 )" by 4.404 d) Obtain the intest baron concentration from the Reactor Coolant Chemstry Analysis.

NOTE: Check the CR0 log to verify that no major boren c:ncentration changes have been made since the analysis. , ./

                                            '                                              8.0
               '                                                              2103-1.9
   '                                                                         Revision 3          .

09/22/78 e) Obtain the Control Red group position, from' their

                            '        '                                                                         i indicators on the control room center console.

4.2.3 Determine the fuel excess rec.ctivity from the " Shutdown i Margin" curve on Figure 1. - 4.2.4 Determine the reactivity worth of ALL control rods insertad in the core: a) Obtain reactivity worth from Figure 2A assuming all rods in groups 1-7 are inserted. b) The worth of the Axial Power Shaping Rods, group 8, can be found on Figure 4A. c) Add the value obtained for group 1-7 and group 8 for the total red worth. ~ 4.2.5 . Use the 532"F curve on Figure 5, multiply the value by the j, I ..s boron depletion' worth from Figure SA to determine the react associated with the borea concentration of the reactor coolant. 4.2.6 See section 4.4 for Xenon reactivity worth calculations. NOTE: If calculating SOM while at power, and no power change has taken, place in the last 40 hours use Figure 6A. NOTE: If the reactor has been shutdown for more than 90 hours, Xenon reactivity will be negligible. 4.2.7 Calculate the correction factor associated with reactor

     .                                 coolant temperature change from 532 F as follows:

a) Obtain the temperature ceefficient of reactivity'frem Figure 7A (this value is taken to 102 g 3 gjg p,7 0F ). ' ~ 9.0

2103-1.9 80@ *

                                  '.                    b)     Subtract 532*F frem the recorded actual RC average v

temperature. Multiply the difference in taperature (*F) by the coefficient obtained in 4.2.7 (a). NOTE:' If the reacto.- is at power, then the reactivity worth' for temperature change =

                                                                ,    ,    0% AX/K.

4.2.8 The doppler power reactivity worth is equal td 0% AX/X, since the reactor will be shutdcwn. 4.2.9 Detennine the reactivity worth of samarium (buildup) . after shutdown frem Figure S.

               .                                       NOTE:        The power leyel prior to shutdewn must be kncwn for calculation.

4.2.10 TecRhical Spect[icattons require shutdown margin calculation - .O includa.the most reactive control rod stuck cut of the C , core Gnost reactive rod is wceth 3.9.% aX/X). NOTE: Shutdown margin by definition always assumes a red is stuck at the 100% positten, i.e. O[ Even 11 all reds are inserted, you must assu=e one

                        ,                                    rod is at full out position.

Ql If rods are cocked you assume that one will ren:atn at full out posttien in the event cocked rods are - i tripped. 1 -

                                                   .iO t

I If at power and reactor trips the rod worth inserted is considered based on one rod reaining at full out position. 4.2.11 Total the reactivtty worths frem steps 4.2.3, 4.2.4c,

,,                                                    4.2.5, 4.2.6, 4.2.7, 4.2.9 and 4.2.10 to obtain the net V

reactivity for the shutdown margin. 10.0

            *'                                                                                                              2103-1.9 Revision 3 09/22/78          t i

NOTE: n The net reactivity must be.more negative than: l

                                                                 -2% aK/K when Kaff > 1 (Tech Spec 3.1.1.1.a) or
                                                                 -15 AK/K when Kaff < 1              (Tech Spec. 3.1.1.1.b).'              i 4.2.12                                                                                        ;

Sign off the appropriate blanks on Enclosure 1 and-send to the Nuclear Engineer. NOTE: Part II is not applicable for the Shutdown Margin. . 4.3 Estimation of Critical Rod Position.

                                    'The totai core reactivity can be calculated from a set of initial condition. While shutdown this net reactivity worth for the core
                                                                                            ~   ~

will be negative. Therefore, positive reactivity from rod withdraw and ,deboration are required to obtain p (net = 0.

                       -                                              :'                                    The critical red group positions are determined by solving the reactivity balance 5

equation for net reactivity. The net reactivity.in this case is the . positive reactivity to bi inserted by sequential red group withdrawal in order to obtain criticality. The reactivity for the desired red position is then determined. If the reactivity added by the red withdrawal does not equal - p(net) it will be necessary to deborate to achieve criticality.

                                                  '                  The change in baron concentration is determined by solving the following equation:

p(. net) + A P (red withdrawal-) + ap (boren) = 0 where p (net) is the amount by which the reactor is shutdown. NOTE: This is not shutdown margin as defined in paragraph 4.2 ap (reds) is the reactivity added by red withdrawal to the estimated (desired) critical position. ap (boron) is the reactihity addad by deborating to the required boron concentration. '

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2103-1.9 0~ - - Revision 1 os/0a/77 I ENCLOSURE 1:

  • REACTI'.'ITY CALCULATION  !

PART I: -

1. Reference Conditions:

(Circio apropriate reference conditions). ' Reactivity Ealance Shutdown Estimated at Power Marcin Critical ' Position ' T Average 582*F 532'F 532*F . verage NI Power 100E, 01 0%

                 -                 Control Rod Position                                                                         100%                                   100%         1005
      ,                 2.         Actual Unit Status.
  • 582 A. Tav. ar.. -

a O B. Average HI Pcwer SO %FF; 85ycopy;y,I*,'y NI-5 30 ZFP . e t-

,)                                                             NI-6                                        50     %FP NI-7                                        56 %FP                                                         '

NI-8 SB %FP

                                                                                                         & EFPD.

C. Core - D. Baron Concentration btO ppm. E. Rod Position: \ e Group 1-4 l00 'DID l Group 5 1oOswD Group 6/7 TO ntD Group 8 M D1D ! NOTE: All positive (+) and negative (-) reactivity valves will be taken frem the figures. g

3. Fuc1 Excess Reactivity (Fig. 1/1A) ) Y[2,3 faK/K use s sa. .,, e. . -

22.0 i

g r jMj 2103-1.9

      .                                                                                         Revision 3                  9. 2 4.-       Control Rod Reactivity:                                         09/22/78 g

q .A. Groups 1-7(Fig.2h28/3 - 9.le4 %ak/k j NOTE: For shutdown Margin assw:e Q,yithdrawn for Groups 1-7. 8.' Group 8(APSR)(Fg.h4Bf '3 3 fak/ .' C. Total Reactivity of Rods (Gp 1-8) 4a+4b=,-9.91%4k/k. 5. Boron Reactigigg5) ~71 'ak/h. g, i A. Baron tio De lation)(Fig.5A 90 i . W23 [

                                                                                                         '~

g

8. Effective Baron Worth 5 x 5f= .(,9 sax /K
6. Xenon Resctivity:

A. For Reactivity Salance at Power use Figure 68. .

8. For Shutdown Margin use Figura 6AJ(if at equilibrium) or Section 4.4 for transient co..ditions. - -

C. For ECP see Section A.4 - 2.l[a "%ak/'d, .

7. Reactivity associated'with temperature change:

A. Reactivity coefficient (Fig 7A/8)

  • M/A 1ak/k/*F. ~

4

8. Reactivity due to temperature change (7a)X(Tave-ReferenceCondition) [ C sak/k NOTE: For shutdown marefn vehen the reacte- <e e e~.,*. .

! , use Otak/k for te- eratu-* c*ce r= activity.

8. Reactivity associated with power change:
A. Reactivity due to operating halow 100
FP (Fig.a) 9/A sak/k
8. For 50:4 or ECP use 05akik l

( .C %4k/k

9. Samarium Buildup after Shutdown tima since shutdov.n Q days (Fig. 9) (For 50:1, ECP only) O tak/h O "o't: 2a=#r that th corr ct sis => ^^v h a r cord e rr==

figures. -

10. Stuck Rod Critoria .

A. For Shutdown margin u'sc +3.91"G/;' _ _?.

w.

                             .                                                                                              2103-1.s Revision 3 f!      3;(

09/22/78 O i i,. Net atactivity (p):

                                      '                                                 E C#Y MAdm p (net) = p (fuel) + p (rods) + p(boron) + p (xe) + p (temp) + p                                                 ,

(power) + p (sm) + p (stuckred). Add the values recorded forg following steps:

f. .) A d* 8- L m P s. .3% g4, p (11) =H2.3 o.(3),+,p ,l- 9 97 (4) + p (5) +- pp.(6) + p ( ) + p (8) + p (9) + p

_f /.9 e e. . g,3 g p (nat) =,-2/ol %Ak/k

                                                                                                  *~

NOTE: Refer to Limits and Precautions section 2.0. A. Shutdown Margin, p (nat), c:ust be more negative than- ~

                                                                 -254K/K when Keff fl (T5 3.1.1.1.a)                                     -
                                                                 -154K/K whed Keff < 1 (T5 3.1.1.1.b) 8.
     '                                                           The reactivity balance cust be within + 0.55 ak/k (steady s or + 0.85.ak/k (transient).

Calculated by: Operator Cate/ time

Approved by
-

Shift Foreman Date/ ti. a ~ i RETURN TO NUCLEAR ENGINE,ER \ . Q,J y4lue o.s ewh m &ol,J thP = TM SpM: O i4 I

sess. R If: _O 00N k}kN)fG skon'T o9/08/77 ENCLOSURE 1: REACTI'.*ITY CALCUI.ATION ' PART I: ,

1. Reference Conditions:

(Cire,lo ap;ropriate reference conditions). '

                                   '                      Reactivity Balance Shutdown                                                       Estimated              '
                                               ,          at Power                                                       Marcin             Critical             '

Position l T Average 582 F 532'F - 532*F Average NI Power 100% 0% 0% Control Rod Position 100% 100% 1005

        ,                  2. Actual Unit Status.                                                                                     '

A. Tave E $ 2, 'F.

                                                                                                                                                       ~',

B. Average HI Power l'C O sF:: m NI-5 100 %FP j NI-6 100 %FP . NI-7 f 00 %FP , NI-8 ) OD %FP - C. Core 100 EFPD. - D. Baron Concentration it00 ppm.

                     .           E. Rod Position:

Group 1-4 10 0 20

Group 5 toO %WO Group G/7 9O %WD Group 8 3$ UlD 1
0TE:

Allpositive(+)andnegative(-)reactivityvalves , will be taken frc= the figures. j 3. r O FuciExcessReactivity(Figh1A) t/ 5.55 nx/K j V5C SDm em

                                                   @ iAO S.F9D 22.0 _ _ _ _ _ _

G 4 i-2 s on 3

  • 4' C#Ypg Control Rod Reactivity: Osf22/7a Q , 'A.

f Groups 1-7(Fig.2h2B/3) 0N %ak/k/ NOTE: For shutdewn Itargin assume 05* withdrawn for Groups 1-7. B. Group 8(APSR)(Fg.4A/48) -- 0 33 %Ak/k C. Total Reactivity of Rods (Gp 1-8) 4a+4b= -9.Q%Ak/k.

5. 12.55 Sik/k.

BaronReactivjggfQ) A. Boron Ratio (Degi,og (Fig. SA) O.937] - g B ._ Effective Baron Wo th I 5 x 5Ak.ii.% tax /K

6. Xenon Reactivity:
             ,.                A.       For Reactivity Balance at Power use Figure 68.

B. in For Shutdownt06Marg %%use

e. Eicure 6A (if at equilibrium) or .

Section 4.4 for transient conditions. - C. For ECP see Section 4.4 - g. [ ~ 2.'70 fak/k .-

7. Reactivity associated with temperature change:

,_) A. Reactivity coeffici,ent (Fig 7A/B) ' AJ/A %Ak/k/0 F, B. Reactivity due to temperature change 4 (7a) X (Tave - Reference Conditien) NOTE: fo %ak/k For shutdown margin when the reactor is at' cewer, f use 0%Ak/k for temperature change reactivity. 8. Reactivity associated with power change: A. Reactivity due to operating below 100% FP ' (Fig.8) N/A -c%ak/k g

8. For 504 or ECP Nse 0%4k/k hO fak/k
9. Samarium Buildup after Shutdown ti=a since shutdown O days (Fig.9)(For50:1,ECPonly) O %ak/k Q MOTE:

Insure that the correct signs have been recorded from figurcs. J .

10. Stuck Rod Criteria A. For Shutdown margin u'se +3.91!!1.s/K O 3
                                                                                                                                 +~

2103-1.9. Revision 3 AN J... 11.f Net Reactivity (p): kff 09/22/78

 )                         p (net) = p (fuel) + p (rods) + p(boren) + p (xe) + p (temp) + p (power) + p (sm) + p          (stuck red).
                       '   Add the values recorded for,ge follcwing steps:

g I41  ?.as 6s~ Ye '%P  %  %  %,% p (11) = p (3) + p (4) + p (5) + p (6) + p (7) + p (8) + p (g) + p

                                    +t5 55 -9 91 - i t .H. - 2.7                 o      o                            ,_, g. _ + 3,3 i p  (net) =-4 97 %Ak/:M NOTE:      Refer to Limits and Precr:tions section 2.0.

A. Shutdown Margin, p (nat), c:ust be more negative than: *

                                            -g4K/K when Kaff il (TS 3.1.1.1.a)                                                    -
                                            -15aK/K wheh Kaff < 1 (TS 3.1.1.1.b)

O B. The reactivity bala ce c:ust be within 10.5% t.k/k (steady s m - v' or 10.85. Ak/k (transient). Calculated by: Operator Date/ time

              ..      Approved by:

Shift Foreman Date/ time RETURN TO NUCLEAR ENGINEER Q ,y W lves O.5 tack m &eded S4er = To b l 5 pe.d. i MS O - J  :.

m 4. h. ' N COPY AlAllnig

  '~

CR2 I"El - 3 CRj 1-K2 CR2 . CRj (1-K7 ) 3cn (1-0.9)

                                                                                                    .                                 (1-0.95)                           - -
                                                                                                     ,      1-K2           -
                                                                                                  =

300(o,j) =

                                                                                                                               ;(300)(2) " 600 ens             a mN-oS s-         ..:.

g, CR 2 1-X)- CRi 1-X~ 2 900 1.09 766 1-X2

                                                                                                                                                                     ~

3(1-K2 = 0.T' _ - l 3-3K2 = 0.1 - __ . l

                                                              .    . __.    ..      ;        3K         = 3-0.1    -

2 . . ... 1 3K2 = 2.9 . .. X2 = 0.967 Jpb m e (-o.s) m e D I J

I

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Criticality ical systems in the using fuelgeometrically storage andsafe handling system will be crevented by phys-configurations. The fuel storage racks have a 21 1/8 inch center-to-center distance in both directions. This spacing is adequate to maintain a Kaff of less than 0.90 even if flooded with non-borated water. ~ i

00)  ;

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                                               , .                                                     Fest Cnf n E:a 433                                       i f.t.ddletean. Pen 9sylvania 17C57                        ,

717 544-:041 August 3, 1979

                                                                                .                                                                     ~

Mr.-Paul F. Collins U. S.~ Nuclear Regulatory Conmission - Office-of Nuclear Regulations .. k*ashington, D.C. 2-555

Dear Mr. Collins:

Re: James R. Floyd (SOP-2051-3) In accordance 1006, with Three Mile Island Administrative Procedure herebyMetropolitan certify the Edison Operator Requalification Program, I satisfactory rating of Mr. Floyd, based upon his _ completion of an accelerated requalification program in which he achieved a score of 99.8. - - By way of background during,the 1978-79 requalification year, Mr.-Floyd was found to be deficient in four category sections:

  • t Section A: Principles of Reactor Theory
                        .Section E:                   . Safety and Emergency Systems Section C:                   Radiation Control 9 Section H :- Tuel Handling and Core Parameters As a consequence response      to                        he was required to upgrade these areas in received          the Administrative          Procedure 1006 and, on retesting, following grades:

Section A: 89.1- - Section E. : 75.5 Section G: 80.5 Section H: 64 Since he received two scores less than 80f, a specifically tailored program was instituted which enabled him to improve in the areas of demonstrated weakness and to attain the level of proficiency indicated by the test score in paragraph 1 above. Sincerely.

                                                                       . P. Miller Station Manager CPM /k'HP /l ev cc:        M. L.        Beers J .- R. Floyd J. G. Herbein L. L.       Lawyer                    .

R. W. Zechman Attachment 4 f.'etrcce!:an Ed son Comoany is a t.'amoer o' t*e Gi .e a:Pu$he U:.'.:.es Sys:em

s.Q.JNp n ./; &m-A nm ~ TELf,R'] C 75 : 3. R. ?! } hk 3f n, in 1

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E t0-2.d % _ e c. c. e. w n w. . I BIST COPY AVAILABLE i i v - Attachment 5

    . _ - .          . . - -                      _.-.--_ .-- .-                        _ . - . _ . ,         -.         - -           =- -. _ _      _ _ ,

ucr i METROPOLITAN . EDISON COMPANY- sow;, a;,c.,,,i Jun, ,\;J~ J,, ymM4 e-subject ACCELERATED TRAINING PROGRAM; ADDENDUM Location TMI J. R. FLOYD Dam To .  ; July 11, 1979 l I RE: TM79-18 l 1 In addition.to the assignments made as part of your Accelerated Training Program, you are requested to re-do FSR assigment for Category A. This exam is attached for your use. to insure validity of this section of FSR.This extra work is at the request of G.P. Miller

                                                         $ W. Er / =
             ~

R. M. Zechman Supervisor of Training RWZ/drg Attachment - cc: G. P.' Miller . O e e s 9 INTER-OFFICE MEMORANDUM

iner9sg=

                                                                           -/-

METROPOl.lTAN EDISON CO M PA N Y := o, o . ,. u,,u,,,, c.. ,,,,, t . Miest SINULATOR STARTUP CERTIFICATION Tl1I Nuclear Statfor Location Middletown, Pa. To Date January 22, 1979 STARTUP CERTIFICATION PARTICIPAfRS The following personnel are scheduled to attend the B&W simulator in Lynchburg, Virginia for startup certification per the following schedule: Feb.12 - Feb.16 & Feb. 19 - Feb. 23

             *C - M. P. Kandig                                         *C - D. A. Smith J. C. Herman                                                 D. B. Mayhue
           - Feb 26 - itarch 2                         &

tiarch 5 - March 9

             *C - J.11. Garrison                               *S-C - J. A. Brumer M. D. Phillippe                                             L. P. Germer C. F. Mell                                      .
                                                                                                *S - single room *C - car Arrangements are being made for hotel accomodations and rental cars. Purchase orders Roxanne for those assigned rental cars will be sent to you. You should see advance checks.

Taylor at least two weeks prior to your departure to arrange for cash motel, ceals.andThe fueladvance amount for the rental car. will include a sufficient amount to cover For those who have not taken the Mock NRC written exam, the Unit II personnel will take their exam with the licensed personnel taking the annual requal exam. Unit I personnel will take their Mock NRC written exam following their return from the siculator tenatatively March 13, 1979.

             -I request that the above listed trainees be removed from shift work as of Feb. 12, 1979 and remain off shift until their completion of the NRC exam.

I also request that the Shift Suoervisor insure that each triinee's Hock NRC oral be administered prior to his trainee 9-month program end date. Forms will be sent to the S/S for documentation of the orals. Nef &% ' M. L. Beers Group Supervisor - Tech. Trng. MLB/drg cc: G. P. Miller R. W. Zechman K. M. Tennis R. B. Taylor N. D. Brown D. J. Boltz ' Shift Supervisors INTER-OFFICE MEMORANDUM

Fage 1 of 2 i Place: TMI Training Center Date: 10/E/82

                            .                       STATEMENT E. Baci, who has icentified himself'to me as an Investiga Nuclear Regulatory C'cmmission.
           .for me.                             Investigater Baci has written this statement This statement ' summarizes the information which I provided to NRC Investigat' ors Baci and Edward C. Gilbert during an interview held at the TMI Training, Center en 10/5/82. I am currently employed by Met Ed as the
     * ~Su;erviser cf Non-licensed Training and have been with the Company since 1973.

I have been asked ;o recount my knowledge of an incident involving Jim FLOYD wr.ich occurred shertly af ter I reported to ey new assignment as an instructor

  • in the Training Des:. around June of 1979.

As an instruct:r, I routinely received training exams in the ecmpany mail which were sen; in for grading. On or ab:u 7/2/79, I received Jim'FLOYD's FSR exams;.t: the best of my recollec: fen, I graded all four exams. Whfie graci..; '.he exams, ' r.oticed tht the handwriting diffared on two cf them. I was familiar witn FLOYD's handwriting and knew that par:s cf two of the exams a; earec to have teen written by him; parts cf the same tw: exams were in a C . Eif#eren; handwriting,which!. suspected to be that ofa W

                                                                  .                    I went to c

see Denny SOLTZ, another instrue:or in Training who was a friend f ,,___, and ne verified that the second handwriting on the exams was tra cf,,,,,,,,,, I also wer.t to see Dick ZECHMAN concerning the exams. As I recall, IECHMAN shook his head and appeared concerned and asked me to cceplete grading all the exams. While I graded the txams and reccrded the fact that FLOYD had submit ed b them to Training, I did not censider the exams which were in bc:h his and ,,,,, Attachment 6 L--

 '                ~

Page 2'of 2 writing as acceptably fulfilling FLOYD's training requirements. When asked by Mr. Baci, I told.htm that I regarded FLOYD's actions in this matter to be cheat-ing; this was the reason that I brought it to the attention of ZECHMAN. When I completed grading the exams, I turned them over to Z' ECHMAN who said he would handle it from there. That was the end of my involvement in this matter. I have read the foregoing statement consisting of 2 handwritten pages. I have made and initialed:any necessary corrections and have signed my name in ink in the margin of each page. I swear that the foregoing statement is true and correct. Signed on 10/5/82 at 1153. . Signature:, ,

                                       /s/ E. R. Frederick Subscribed and sworn to before me this 5th day of Oct.1982, at TMI Training Center.

INVESTIGATOR: /s/ Peter E. Baci l WITNESS: /s/ Edward C. Gilbert e I

l l 9 Page l'of 3 Place: . East Hanover TWP, PA Date: 10/7/82 STATEMENT I, NELSON 0. BROWN, hereby make the following voluntary statement to Peter E. i Baci, who has identified himself to me as an Investigator with the U.S. Nuclear Regulatory Commission. Investigator Baci has written this statement for me. This statement sunnarizes the information which I provided to NRC

             . InvestIigators Baci and Edward C. Gilbert during an interview at the TMI Training Center on 10/5/82. I am currently employed by Met Ed/GPU as the SupervisorofLicensedOperatorTraining(Unit 1);duringtheperiodofthe FLOYO incident in July 1979, I held the position of Administrator of Nuclear Technical Training (Instructor).

As a result of examinations given in 1977 and 1978, it was identified that James R. FLOYD was deficient in certain categories as defined in Administrative Procedure (AP) 1006. He was therefore obliged to participate in a training program with an exam at the completion of the training period.

       ' " The assigned training program and exam were structured to cover areas of
           ,     demonstrated weakness. This included at least 2 areas that I recall, Category A/H (Reactor Theory) and Category K (Fuel Handling and Core Parameters).

1 Several months after the accident, it was determined that FLOYD had not returned the required examination material and he was so notified; he

         .      eventually submitted the exams.

Sonsone, either BOLTZ, me or someone else, discovered that some of the

                                                                                          ~

exam material submitted by FLOYD was not in his handwriting. I was very ._ surprised and shocked that FLOYD would have obtained help from someone else since he was and still is smart enough to answer the questions himself. In Attachment 7

. Page 2'of 3 my. opinion, he probably obtained. assistance because he lacked the time to complete the work himself. It is difficult for me to classify this incident as cheating since FLOYD could have ccm:leted the cuestions himself had he devoted the time; however, I certainly consider his actions unethical and unacceptable and feel t

                                            ' hat they wergite properly breucht to th. ate.ntion of apprc'priate supervisory narsonnel.

Mr. Baci showed me a copy of both the Accelerated Requalification Program

     ,       ~(ARP) and the ecmprehensive exam given to FLOYD at the conclusion.               With respect to the ARP, both item (1) [ reactivity balance) and item (2) are rela:ec to reactor theory (Cat. A/H). With respect to the ARP exam, cuestions rxm:ers 2, 3 & 4 require an understanding of reacter theory (Cat. A/H).                After reviewing both the ARP and the ccmprehensive exam, I feel that their successful completion represents an adequate demenstratien of ccm;etence in the area cf.                     -

react;f theory. Mr. Eaci next showed me a copy of a letter frem Gary MILLER te Paul COLLINS a: the NRC, dated 8/3/79. I told Mr. Saci that I had firs seen this' letter subsequent to the Fall 1981 Hearings and was surprised at seme of the centents. Specifically, 3 areas of weakness rather than two shculd have icentified, the third being Category A/H or reacter theory. I question the validity of listing the 89.1% score in the letter since it represented the jcint

                   'a' forts of both Jim FLOYD and W

O

                               %=       .       . . . .         .

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1 Mi,

                                                                                                                                         ?.svis!zn.2 f
  • C'/11/77 (f) Horcal and Ear;ency 0;erating precebras ~

(g) Radiation Centro) and Safety - For Senior Operators the FSR Program will also include: i (h) Reactor Theory (1)- Radioactive Material Handling, Dis;csal, and" Hazards (j) Specific Operating Characteristics

                                                     . (k) Fuel Handling and Core Paracaters (1)

Administrative Procedures. Conditions, and Lim tc.tfens - Perforcance of FSR assignments will be determined through ,.ritten evaluation quizzes. 'These quizzes will*be specifically dire

  • _toward ~RO or SRO knowledge requirements.

The quizzes may be adv.f nistered in either the closed book, o_r 6,~ '

                                                                                                %qk . format, as classroca or on .

shift quizzes.. *

                                                                                                                                                  ~

A satisfactory grade on the FSR evaluatien quiz will be 80' . If a

  • grade below 8,0% is achieved by a license holder, a deficiency is ,

assigned and the license h' older will be assigned an accelerated

  • requalification program as par,'Section 2.6. -

2.3 On-the-job-training ' . During the two-year term of his license, each licensed operator shall participate in on-the-job-training which has the folic.ving ' goals: -

                                                                              ~

(a) Each 1 ensed reactor nperator or sanfor operator shall partici; ate in a minimum of 10 reactivity manipulations as defined in this section of the requalification program. * ' (b) - Each ifcensed reactor operator or senior operator s' hall partici;ite-as appropriate, in a;pitcable surveillance testing, systsm - checkout and equipment operation based on licens*e level and

                                                        , relevance to the area of ifcense responsibility.               .'

t

7. 0 .

i .. . 1:~5

                                                                -                                                                         Revisin:: 2 C?/11/77 g

(c) Each licensed reactor operat:r or sent:r operator shall review

                                    -                     procedure changes, unit codifications, technical spejification                                            -

changes, reportable occurrences and incidents eitherion-the- -

                                ~                       '

job or during sessions' of the OR Lecture Series. Each licensed reactor operator shall manipulate the unit controls , to effect reasonable reactivity changes. Each licensed s'enfer . reactor operator,shall either manipulate or direct the manipulation

                                    .-        .cf the unit centrols to effect reasonable reactivity changes.

Reactivity manipulations which demonstrate skill and or familiarity

                                             .with reactivity control systems and which are' credited to meeting
                                                                                                                                      ~                         '
         '.                          ,         on-the-job-training will include, but are not limited to:                                               .
1. Power change of greater tha'n lot full power with the reactor,
                                ,                        control statiory in manual.                       '.,                      ,
                                           , 2.          Control rod manipulation from suberitical condition to point                                             ,

of adding nuclear heat. .

3. Scratiert and deboration maneuvers involving control red mani- ,
                                                     ' pulation..                                                      -
                                                                                                       ~
4. T'urbine startup and shutdown. ,
5. Reactor trips and subsequent actions. .

The participation of licensed personnel in the on-the-job program - will be reviewed quarterly by appropriate supervisors to insure

                                          . that operators participate in a variety of evolutions.                                 If diversity                     .

of operations is lacking, specific assignments may be made to ensure wide operator experience. Included in the folloEing Ifst are examples of additional o;erations which may be considered in this category. These samples are not to , he considered for reactivity manipulation credit.

       ~                 -                         .                                            g,n                                            ..
                                                                             -e.<,

1 { .. - . .

                                                                                                                                .           Ic:s p.cei:i:. 2 04/11/77

.  !. 1. Surveillance Testin; Including:

a. Containment spray System  ; .
                               .            b.      Safety Injecticn                                                                                         -

f

                                                                                                                                   =
                    .                      c.       E=argency Diesel Generators                                                                                                    .

d.- Chemical Addition System -

     .                            2.       Mar'.eup and Purification System 0;eration                                           *
3. Decay Heat Removal System Operation
                                 ,4 .      Feedwater System Oper'ation                 -
                              ' 5.
           ,,                              Reactor Ccolant System
6. Turbine Valve Testing .
7. Pressurizer Operation ' .
8. 'Incore Monitoring System Operation
9. Control Room Calculations Including:
a. Heat Balance
b. . Quadrant Tilt / Imbalance / Rod Withdrawai Index ,
c. Reactivity Balance .. '.
                                                                                                                                               ~
10. Portable HP Instrument Use.
    ~'            '                                                                                                   .

Licensed personnel, whose job assignments are not directly related '

         ,                      to unit operations will actively participate in control roca cperation                                                            '

an average of 4 hours per month. During this period these licensed . personnel will participate in whatever activities are in progress. A s.fmulator may be used in meeting the requirements of this secticn. , The use of a ~ s,imulator to meet the on-the-job training section of the program must be reviewed by the NRC prior to implementatien. ,- The folicwing standards apply to the evaluatien of on-the-feb performance:

                                                                                                                                          .                                .           c 9.0 4
                                                                                          ,__,           , , ,                                               ' " ^ ^ " "

10C5 ' P.evisien 2 04/11/77

                                                         ' l .-         Quarterly review cf operations partici;2 tion will be made by
                                                                    'the appre;riate supervisors. The review must indicate a diversity of experience.                        If this is not demc .strat(d, the
  • operator will be scheduled for additienal operating experier.ce.
2. Quarterly review of reactivity control manipulation (RO) or -

direction (SP.0) must show ' satisfactory pregress tc.:ard the mi.nimum of 10 operations as defined in this section. If

         ~
                                                                  . satisfactory progress is not indicated, an c;erator will-be assigned additienal centrol recm operat.icns or may accorpiisa the required reactivity changes on a simulater.
                                                                                                                                                                                                                                  ~
3. Annuhl review of licensed personnel whose job assignments are -

not directly related to unit operatiens must show a minimum of 48 hours of unit operation assignments per year. If this is not complete, personnel will be assigned to active control

                                                            *                                                                                                                                              ~

room duty until the time is made up. A simulater may be used to ccmplete control room time. 2.4 Annual Evaluation Examination N - Evaluations will be conducted on an annual basis as fo11cus: . (a) An annual written evaluation examination will[te given to all , licensed operators and senior operators prior to the cc pletion -

                                                                                                                          ~*

of, each annual cycle. (b) An annual oral evaluation will be administered to all licensed operators and senior operators prior to completica of each annual cycle.

  • The annual written evaluation examination will be administered to all licensed personnel as set forth in the following guidelines:

10.0

                                       .-, . . . _ _ . _         _ _ . , , _ _ _ _ _ . , . , . _ - _ . _ _ .               . . , - _ , , , _ _ _ , _ _ , . . _     ,._,__.s.           _ , _ . , . . - - .         , _ _               --,

e

             ~ "
  • 105
                                                                                                                                                  -                                                           F.svist:n 2 C'/11/77
1. The examinaticn will simulate the examination n:r. ally administared
                                                                                                                                                                        ~~

by the Nuclear Regulatory Ccmission. .

2. .R'eact:r Operaters will take Sections A through G of th examinatien while the Senior Reactor Operators will take Sections H through .

L and'answar selected questions in Sections A thr: ugh G. -

3. The examination, exanin tien answers"and a' grading key will be - ,

prepared in advance. .

4. The examinatien results will be used to identify specific FSR lecture series topics to be covered by each licensed individual during the sub. sequent annua 1 requalificatian program cycle. ,
                                          .           5.         The examination will be administered and graded by a member of                                                                                                   -
                                                               ,the station technical staff, station minagement staff, training                                                          ,

department supervisor, or consultant. ,

   -                                                 6.         The persons responsible for the preparation of the examinati.cns                                                                                    ,

and answers will be given credit for passing the examination. The annual cralj evaluation examinat.icn, using a checklisti will b'e edministered to all'licansad pars:nnal. The oral examina. tion wi1T coverthefollowinga[eas: - (a) ' Action in event 'of abnormal conditions - . (b) Action in event of emergency c:nditions -

           ~

(c) Response to unit transients ,

                                                    . (d)         Instrumentation signal interpretation                                                                                                                 ,       ,

(e) Procedure modification (f) Unit modifications (g) Technical specifications (h) Emergency plans -

                                                                                                                                                . 11.0     .

9 S

                     - - -        r--         .       . ,.      . . . . , , . . . . . . , , , . , , _ . , , . , _ _ , , , , , , . _ _ , _ _                    , , . _
  • 1005
                                                                                                                           ?stisi:n 2
                                 '                      -                                                                       0*/11/77 S
                                           .The .following standards apply to t.a           annual evaluatien examinatices:
1. ' A ifcense holder who scores higher than 60: in all sec' fens of .
                                   -            'the annual written evaluatica will not be required to participate in the FSR program.              ,
2. If a license holder scores less than 500 on any sections of -

the ar.nual written examinatien, the license holder will at[end the FSR crocram related to failed sections.

3. If a license holder scored belcw S0% in two or core sections of the annual. written examination, the license holder will be given an oral examination and evaluatien by the Superviser of
                 .                               Operations, Supervisor of Training, or. other suitable qualified .-

persens designated by the Unit Superintende'nt. This examinar. will, based on the.results of his examination, eake a recem-

                                                                    ~

mendation in writing to the Unit Superintendent, that the . Operator either - (1) be relieved of his responsibilities and enter an accelerated training program or (2) be permitted to remain en shift while participating in the appropriate requalifi-cation FSR program with suitable tutorial assistance. ' '

4. An unsatisfactory evaluatien en the annual oral examination will require that discussjens of deficiencies, take place between the license holder and either the Supervisor of Operations, Supervisor of Training, or other suitable qualified person designated by the Unit Superinte.kdent. A.second oral evaluatien examination will be administered. If performance is again unsatisfactory, the license holder will be relieved of responsi-bilities and placed into an accelcrated requalificatien program. ,
                                                                        -               12.0                      ,
                           ~
                      ,.     .     ..                                                                                                                                                                          l 1:05                                l F.evisi:n 2                         i
                                                                            .                                                                                              C4/11/77
5. -If an indivical receives a grada of less th:n 70C cverall en
                                        -               ' the annual- examination it will be mandatory that (1) he be
                                 ,                         relieved of his~ licensed duties and (2) enter an accel) rated requalification program. Upon (1) successfully passing a     _

second written and oral examination and (2) certificatien of - satisfactory rating being sent to the .tiRC, the individual will -

                               .                          be returned to his licensed duties.

2.5'.Reccrds' Records of licensed personnel'herformance on all written evaluation

                                                 'examinaticns and quizzes shall be available for itRC examination for the two annual requalification cycles prior to ifcense renewal                                                                               .

application. These records shall include: ,

1. Examination and quiz questions
2. Answer sheets and grade keys
3. Examination papers and work sheets' R'ecords of partigipation in all GR lecture and FSR programs will be available for I;RC review for the two annual raqualification cycles .

prior to license renewal application.. These records shall include: .

               .                                  1.   . Attendance Records                                                                                                                             .
2. OR Lecture Content -
3. FSR A'ssignment
4. Absences and I.!akeup Sessions . ,
5. -AssignmentCheckoffLksts
6. Occument Review lists - ,
                                       .          Records of annual oral evaluation examinations shall be made available for fiRC review fon the two annual requalification cycles prior to                                                                                      }
                                                 . license renewal application.                                                                                                              ,

1 13.0

                                                                                                                                                    )
                                                ~
                                                                                                          .e.evishn 2 t       .

C'li;/77 l l

                                   . Records of all on-the-jeb activities ' 5:all s    be available for f.F.C
                                  -review for the tso annual requalification cycles prior to license renewal applications. These records sha11' include:                                            ,
1. Reactivity Control Manipulation
 .                                  2. Equipment Operation                                                                    -
3. - _ Simulator Participation .

A summary record 'will be maintained on each license holder for the duration of his empic>r.ent. 2.6 , Accelerated Requalification Program * . An operator who does not clear deficiencies assicned due to performance

                                                                                                                              ~
                                  -below standards on eith'er the annual kritten or oral evaluatiens _

will be relieved of respcnsibilities and enter a full time accelerated; requalification program. . The program duration and content will be dictated by ti.e natur'e of the deficiency. Program duration will be det'armined by individual performance. J. hen the license holder is (1) able to satisfactorily . pass an equivalent writte. or cret examination and (2) ccrtification of his satisfactory rating is'sent to the NRC, he shall resume his , _on-shift responsibilities. During the period of accelerated requalifi-cation, attendance at the OR lecture series is required. If the license holder is off-shif t for more than 4 months, Section 2.7 dealing with lengthy absences applies. 2.7 Four Month Absence Program . If a licensed person has not actively' carried out the functions of - his li, cense for a period in excess of four months he 'shall: - (a) Review all material presented or scheduled to have been presented , in the OR lecture series for the period of inactivity. - 14.0 -

r .

                                                           ,                                            1005 Ravist:n 2
                                                                                                    '04/11/77
                               , (b) 8e given an oral examiraticn en the applicable Sectico of the LOR lecture series an~d current unit status.                          .
                             . If-performance on the cra1' evaluation is unsatisfactory, the individual will be placed~in an Accelerated Requalification Program in accordance with Section 2.6.

Upon. receipt of a satisfactory rating the licensed persen shall be

  • certified by the Superviser of Operations, Supervisor of Training '

or other suitably qualified persen designated by the Unit Superintendent. The certification of satisfactory rating will be transmitted to the , 11RC and only after at:roval by the fiRC shall the operater be returned to normal licensed duties. - 2.8 Newly Licensed Opar~ators -

                              ?!awly licensed operators, v;en receipt of their license, shall                 -

enter the program and. participate in the annual program cycle. ^ New operators receiving their flRC license less than six conths prior to the annual-evaluation exa:Ination will be required to l attend tne appropriate OR and FSR Frograms but will be excused frc \ . taking the current annual evaluation, examination. Hewever, he will - be responsible for taking all other annual evaluation examinations. l .

          -3.0

[ RESPONSIBII.ITIES - RE00ALIFICATI0ft PROGUM ADMINISTD.ATI0tl - 3.1 The Supervisor of Training and his staff are respensible for: *

1. -Assigning instructors for the 09 lecture series. . .
2. Determining FSR assignments for individus1 operators.

3. Maintaining and , reviewing all record,s. - 4

                                   ' Assigning deficiencies, determining appespriate action to clear deficiencies and c'learing deficiencies upon satisfactory'                                                  .

cc pietion of assigned ' action. ' "

                                                                  . 15.0                                   -                                 -

L

~

                         ~                                                                   '
                                                                                                                  * :5
                                                             .                                                    Etvisic- 2 C;/11/77                t 5.. Arranging accelerated regalification programs as esy be
                               -         necessary.                                                                                            .
6. Defining oral evaluation procedures.  !

7 .' Scheduling necessary simulator time.

8. Prepare license applications for lic'ense renebal. .

3.2 The Supervisor of Operattens, Supervisor of Training, or other

                                                                              ~

suitably qualified person designated by the Unit Superintendant is

                                 ' responsible for:
1. Evaluation of on-ths-job performance of all lica.nse holders. . .
2. Meeting with license holders who receive unsatisfactory annual
                                                                                                                                  ~

evaluation exa:nination grades. ,

3. Certifying operater qualific'ation.when returning fr m a four month absence frca operation. ,,
4. Constructing annual written evaluation examination, answers and grade key. .
                             .      5. Grading of the annus) written examination.

1 e f' - 16.0 . O .

  • e .

9

p Page 1 of 5 Place: Three Mile Island Date: Oct. 6, 1982 STATEMENT I, MARSHALL L. BEERS, hereby make the following voluntary statement to Peter E. Baci,Regulatory Nuclear who has identified himself to me as an Investigator with the U.S. Consission. for.me. Investigator Baci has written this statement TMs statement sununarizes the infonnation which I provided to NRC Investigators Baci and Edward C. Gilbert during interviews held at the NRC Office at Three Mile Island on Oct.1st and 4th,1982. I have been. asked by the investigators to reconstruct the sequence of events leading to the certification of' James FLOYO to the NRC by Gary MILLER in his letter of 8/3/79. To the best of my recollection; these events, which took place while I was employed as Supe ~rvisor of Licensed Training, occurred as described below, i Shortly after Jim FLOYD had submitted his FSR quizzes for grading, someone in Training - either Ed FREDERICK or Denny BOLTZ - came to me and told me that there appeared to be some improprieties regarding the exams; specifically, I recall that at least one of the exams appears to have been written in two different handwritings. I don't recall which category it was, although after

        ,   being presented with documents during the interview, I see that it was Category A (Principles of Reactor Theory) and Category H (Fuel Handling and Core Parameters).

I went to see Dick ZECHMAN, who was then Supervisor of Training, and discussed the situation with him. I also discussed the problem with the Station Manager, Gary MILLER, although I cannot remember if our discussions occurred during a telephone conversation, a meeting, or perhaps both. I know that as a result of his having two or more areas on the FSR quizzes on which Attachment 9

t Page 2'of 5 he ' scored less than SO: that he was removed from all Itcensed duties and placed in an accelerated training program (as required by Administrative Preced The accelerated requalificatic,n program (ARP) for FLOYO was made up 50LTZ, Nelsen BROWN and myself. FLOYO was assigned to Training on a full-tim basis un,til he ccepleted the ARP, at the conclusion of which he was given, and

        ' passed, a cceprehensive written examination on all'his identified weak areas.

These included Sections ! and H, en each of which he received a score of less than 80%, and on Section A, the section en which he was assigned a grade of 89.~1% but which was based upcn the partial submission of answers provided by m"

                                                                                        ~

During the interview, in reviewing the c:mprehensive exam given te FLOYO at the cenclusien of his ARF,.I noticed that it also in:luded material on Section G (

      ,Radiatien Centrcl), which FLOYO had cassed and was therefere not ebliced to t.ae.

Mr. Saci shewed me a memo from IECEMAN TO FLOYO dated 7/5/79 c:rcerning the ARP. As I indicated earlier, ZECHMAN, BOLTZ, SRCWN and I all had in;ut in crawing up the ARP for FLOYO. 'I don't knew who specifically drafted tne 7/5/79 memo. Mr. Baci asked me why it only addresses tne two areas in which FLOYO secred less than 80: and I told him I didn't knew the answer. Mr. Baci next shewed me another meco frem ZECHMAN to FLOYD, this cce dated 7/11/79. I examined this memo and a handwritten draft. I ::ld Mr. Saci that I was the auther altheugh I cannot remember who it was who asked me to prepare it. It was obvicusly written at the recuest cf MILLER althcugn I cannot remember whether he personally askee me to write it. I examined the e

                      . _ > _ _ _ _ . ____       _ . o   -

Page 3 o.f 5 referenced document (TM 79-18) and feel that it must be a mistake since coes not pertain to the subject of the memo. I told Mr. Baci that I cannet remember whether er not a formal memo from MILLER was responsible for generating the 7/11/79 memo to FLOYD. I also do not knew if FLOYO ever recie

      -    the Category A FSR assignment as requested in the memo nor can I explain the rationale for asking him go do so unless it was just to tie up " loose ends."

ee When the FLOYO ' matter became an issue approximately one year ago, I went ever to Training and met with ZECHMAN, ECLTZ, Karen TENNIS, and Jchn WILSCN. WILS'CN was not actually present; he was speaking with us via the s:eaker-;hene. The pur;cse of the meti:ing was to try and determine how the F. CYD ca::er had been handled. TENNIS put together a package of documents " asscciated with tne FLOYD issue: I can't recall if :.g 7/11/79 memo was ;ar: cf :he ;ackage er if the questien of FLOYD's reccing the Categ:ry A F5R cu : ever ca e u:. I feel, h: wever, that if FLOYD had red:re the cui: tha: 7ENN:5 - wcult have tr:luded it in the package. Again, :: recc Ca:ege y A is to ": icy to the rec:rd" since the cceprehensive ARP ext: included Categ:ry A. F . Eaci asked me to cc:;are the questiens en FLOYO's Fin Category A Cui: with ta:se en the c:::rehensive ARP exam. While the f:rrer has more cuestiens en Ca:e;:ry A, the latter has questiens whien require an equal depth of understanding f :he material. Mr. Saci next shewed me a draft letter dated 7/26/79 fecm M:L'ER :o . PaulCOLLINS(NRR/NRC).

           '                                   ;*:cid Mr. Bact : Mat the handwritten craf: was ;re;ared by te.

The ner:al practice was that the individual in charge cf Training wcuid

      ;re;are such letters, bu: ZECHMAN was himself in training at the time se ! wr::e D

l Page 4.of 5 l the letter. The intent of the letter was to say that FLOYD had successfully l completed the ARP. The handwritten draft, dated 7/26/79, the typewritten draft, dated 7/27/79, and the final letter sent to the NRC, dated 8/3/79, all state that FLOYD was put in a specifically tailored program to enable him to improve in the areas of demonstrated weakness. They also stated that he was put in the special program because he had received two scores on the FSR quizzes which were below 80%.' AP 1006 calls for the special ARP when two or more scores are belcw 80%. I believe it is unfortunate that the letters, especially the final letter, do , ryt say that he received three scores less than 80% instead of addressing only 3he fact that_two such scores require participation in the ARP. In any event, FLOYD was required to participate in an ARP which covered all of his demonstrated weak areas, including Category A, and he did successfully pass a comprehensive i exam on all the material. Mr. Baci asked me if other letters concerning individuals in ARP's also addressed only the two minimum areas requiring their participation in a special training or if they addressed all areas of we'akness. I told him that FLOYD's case was the first of its kind and I don't know if others have occurred since I left Training. I al,so told Mr. Baci that I don't recall having seen the final letter befora it went out; but I feel that even if I had, tne grades cited in the letter were irrelevant in light of the fact that the ARP covered all the deficient areas. Finally, I am not aware of any oral examination given to FLOYD on Category A; this would have been unnecessary since he received a comprehensive written exam at the conclusion of the ARP O y , y g , . .

Page 5'of 5 which included Category A as well as the other weak areas on his FSR program. I have read the foregoing statement consisting of 5 handwritten pages. I have made and initialed any necessary corrections and have signed my name in ink in the margin of each page. I swear that the foregoing statement is true and correct. Signed on 10/6/82 at 1335. Signature: /s/ Marshall L. Beers Subscribed and sworn to before me this 6th day of Oct.1982, at Three Mile Island. INVESTIGATOR: /s/ Peter E. Baci , WITNESS: /s/ Edward C. Gilbert O mmw_ .

Tli79-98

           .: . -                                                                            '36%

E D I S O N C O M P A N Y s% . o ,.. ,. ui,;., c. METROPOLITAN ,,,,, TMI Nuclear Station Sdiect ACCELERATED TRAINING PROGRAM Location Middletown, Pa. Data ,' July 6, 1979 To- J. R. FLOYD - Unfortunately, you have received less than 80% on two (2) FSR Requalification Quizzes. Per Procedure 1006 " Met-Ed Operator Requalification Program", Section 2.2 & 2.6, you will be relieved of your responsibilities and enter a full time accelerated training program effective July 3,1979. Your accelerated training program includes the following assignments, dis-cussions, and written examination:

                 ~
1. View NET video tape module #3, Unit 12 and complete questions
                                 #12.3-1 and #12.3-2 relating to Fuel Leading and 1/M Plots. Return completed questions to the Training-Department for grading. The Training Department Instructor will deterinine if answers are either Sat or Unsat.                                                              .
2. Read Reactivity Balance Procedure #1103-15 and #2103-1.9 and complete reactivity balance problem enclosed. Return completec assignment to the Training Department for grading. The Training Department Instructor will determine if solution is Sat or Unsat.
3. Meet with D. Boltz or N. Brown (at a time convenient to all con-cerned) to discuss the following areas: .

a) Actions required if stuck fuel assembly in transfer tube. (D.Boltz) b) System response due to failure of RCP anti-rotation device. (N. Brown) Reasons for bypass line around DHR system cooler. (D. Boltz) c)

4. Read ICS Procedures, Unit I/II in reference to the response 'to a loss of 4-RCPs and OTSG line up and discuss with D. Boltz.
5. Review all Radiation Monitors in both Units I & II. List each and describe the purpose of each. Submit descriptive list to D. Boltz.

Instructors will determine if Sat or Unsat.

6. Take comprehensive written examination covering items 1 through 5 above. (When convenient to all concerned.) (Passing grade - 80%)

Please note that all Unsat assignments will be returned for correction. Also, your return to duty will require us, per procedure, to sent the NRC a certifi-cation of your satisfactory rating. The completion of each item should be signed off by the instructor on the attached form. Should you have any questions concerning this matter olease call me at INTER-OFFICE MEMORANDUM Attachment 10

J. R. Floyd. ._

                                                    -2   .

July 6, 1979 exten$,fon#313. G h " ! -- - R. W. Zechman Supervisor of Training  ; RWhdrg Attachment cc: J. L. Seelinger F.'A. McCormick M. L. Beers D. J.' Boltz N. D. Brown L..L. Lawyer

               .          G. P. Miller O

6 a _ _ _ _ - _ . - _ . _ _ _ ___m

J. R. FLOYD ACCELERATED TRAINING PROGRAM Assign. . Instructor Subject Grade Date .Sienature l .

1. Viewed NET Module #3, Unit 12, and completed Questions 12.3 -

1, 2.

2. Read Reactivity Balance Unit I/II l-and completed Reactivity Balance.

3.' Review the following with Instruct-

                               -or:    -

! a) Stuck fuel assembly in transfer . I tube. ti) System response to failed RCP I anti-rotation device. _ r c) Reason for bypass line around I DHR system cooler.

4. Read Unit I/II ICS Procedure and discussed response OTSG line-up upon failure of 4-RCPs.
5. Review all Rad Monitors in both Units I/II and submitted descrip-tive list.

I 6. Completed comprehensive written L exam. 9

 .;.    *i *                                  .    ,
                                                                                      ^ ~ ~ - ~     - -

REACTIVITY BALANCE PROCEDURE REVIEW l OP 2103-1.9 cal.CULATIONS: A. Reactivity Balance at Power -

1. Core Age = 300 EFPD Boron = 610 PPM Rods = 6/7 9 905, 8 9 38%

Power = 50% ' 8 Tave = 582 F ,

                       . Equilibrium Ccnditions for Xenon, Samarium
2. Core Age = 100 EFPD Boron = 1100 PPM Rods = 6/7 9 90%, 8 9 38% ,

Power = 100% Tave = 582'F Xenon at Equilibrium Samarium at Equilibrium Assignment:

       - -    1. Perfonn a reactivity balance calculation using information given above.
2. Based upon the results of- the calculation, describe action required, if any.

1 e

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G.. P. Mt LLER J' ~T ' ~ ~ ~ " '

             ,                                   . . July 27,1979                           5/$.'.[hk h6p M V7s   -- '
                     .                                                                        mv ls        ik) an . n,-   -

To: E. Blake , Priof.to rny submission, please reyfew. E, I only reference two sections in the make up. N'e actually studied 3 sections due to the handwriting problem. Thank you,

                                               ,e.Pndia-ludL G. P. Miller GPM:cak cc:     J. G. ~ Herbein                         -

W. H. Parker - ~ G; P. Miller , 9

   *e.

t e P Attachment 12

                -                                                  .           ^        ,  5 h*

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                                         /                                                             - *I 11l     y                     ;
                                                                           " ' - ~ 

f/ttropofian Edisc3 Con pany f , Post Office Box 480 u.am iown. Penn*Wons 17057 717 9444o41

                     ~

July 27, 1979 Mr. Paul F. Collins . U. S. Nuclear Regulatory Comission ) Office of.Huclear Regulations Washington, d. C. 2-555

Dear Mr. Collins:

'             During the 1978-79 Requalification had FSR program requirements on four (4) year at THI, Mr. J. R. Floyd (50P-2051-3) category sections. These requirements were a result of a score less than 80% in 3 sections of the                                       1977-78 Requalification Exarr and I section of 1977 cross-license Exam, the sections of the FSR program are:                                                                                                                                       identifi Section G; Radiation Control and Safety, Section H, Fuel H                                                                          .

Procedure (AP-1006). Action was taken to upgrade the licensee per our Requalifica licnesee for the deficient sections. Written evaluation quizzes were assigned to be compl Section A , Section E~ The results of the.qut grades were as follows: -

                                                             , Section G                     , and Section H of these         section   grades were unsatisfactory (less than 80%), furtherSince                                              two corrective            actio was     necessary.

accelerated requalification program 1006 2.6. per APMr. Floyd was relieved of his The program was tailored spect-ments of the requalification program we are notifying you completed satisfactorily and Mr. Floyd has been returned to his normal duties. Sincerely,

              -                                                    G. P. Miller Station Manager I

GPM:M}B:cak Attachment i cc: R. W. Zechman  ; L. L. Lawyer J. R. F1oyd M. L. Beers File 313 J. G. Herbein G. P. Miller l l l Mertc;;o'.:an Ec son Com:29ps a Member of tee Gene a: Pu:: : U 't es Sn:em

e ~

                                                  ~
                                                                                            ~

JULY 26, 1979 -l-- .1 i~ I~

                        . . I herby certify that James k. Floyd has satisfied all deficiencies identified by the Requalification Pr.ogram E through Accelerated Retraini.ng, and is capa51e of operating safely and proficiently under the provisions of his license.      -                                                            -
                                                                                                    ..s
                                                                                                                                               ~
                                                               ~L. L. Lawyer                  -

Manager of Training P. ' Miller

                                                                                                               ~

G'. l Station Manager 5 e {. l

Page-1*of 9 Place: THI Training Center Date: Oct 1,1982 STATEMENT I, RICHARD W. ZECHMAN, hereby make the following voluntary statement to Peter

         'E. Baci, who has. identified himself to me as an Investigator with the U.S.

Nuclear Regulatory Comission. Investigator'Baci has written this statement for me. This statement summarizes the information-which I provided to Investigators Baci and R. Keith Christopher-during an interview on 29 Sept.1982 at the

        -TMI Training Facility.           I have been employed by Met Ed since the Fall of 1969 and currently hold the position of Technician Training Manager at TMI.                    I have
   .       been asked by the investigators to reconstruct the sequence of events involving
                                                                                                                     ~

Jim FLOYD's certification to the NRC by Gary MILLER. To the best of my recol-

         'lection, these events, some of which took place while I was Supervisor of Train-ing,~ occurred as described below.

l l In August 1977, James R.- FLOYD (also known as Jim Floyd) held a TMI-1 senior operator's license and took a Company given cross-licensing exam for.TMI-2, a test which he passe'd but on several sections of which he scored less than

       ,80%.         Because of an NRC-required administrative procedure'(Admin. Procedure 1006), FLOYD had to participate in a special portion of the next Company requalification program known as Fundamentals and Systems Review (FSR) in those areas in which he scored less than 80%.         In February 1978, FLOYD took h.is TMI-1 operator's requalification exam. As was the case with the cross license exam, FLOYD passed the test but failed to score the required 80% on a number of areas. One of the weak areas was also a weak area on the cross license exam. . All told, as of February 1978, FLOYD was required to- train in a
        ~ total of four FSR sections due to his performance on the 1977 cross license Attachment 13

I i

                                                       /                                                               .,                         \

Pa,ge~2'ef 9 \ { I

                                                                                                                                        -         t and 1978 recualification exams.

fulfill his'FSR cbligations included:The four sections c FLC Radiation Control and Safety; (K)(H) Fuel Handli(A/H (E) Safety and Emergency Procedures ng and Core Parameters; and, these FLOYD had to complete is determined b. Perform quizzes,-according to AP-1006, may be administered The iy

              - cpen back format and as classrcem er en-shift exams n either                    .

In early July ef 1979, Marshall EEERS (Grcu; Supe and said that FLOYD had scored less than 80% in two arrv ccepletirg in the FSR program. eas or secticns he was This cean: fre c;eratiens and placed in a full tim that FLOYD would have to be remo At abcut he same tice, it had also been icentifi de accele e written qui:zes were not all in the same ha dthat ene er mere cf FLOYD's

r. writing. .

fcunc LP.is and cid SEERS, who in turn told As! recall,EdFRE;EdICK me.

       " I inmediately went tc Jim SEILINGER                 n:             (UUpon      t receiving this in' creation, circumstances te nim.                                     1, Separintenden:) and re; cried all tr.e Gary ?.- MILLER, and-advised                                    on.

him cf the situat anager, a call frc: MILLER in which he said that he was awareScte ti . full _ responsibility fer the investigation of :ne incident and taking concerning the two different handwritings gn FLOYO's () ms and said that FLOYD had ch < ained scme cf the answers frcm 9R""~' O

                          - ~,   -.,       . - -...      _ . - -              - - - . . - - - _            --  ..

i Page 3 of 9-On July 6,1979 I prepared a meme to FLOYO c ncerning the ac:elerated training

      ;r:gra=. The mem described the accelerated pr: gram whien EEEP.5 had ;repared fer #LOYD and cu: lined the assignments, discussiens and written examination which would be required. Unfortunately, the cpening paragraph of the meme only cdresses the fact -hat FLOYD received less than 80% en two FSR recualification qgi::es; it dcas not explicitly state that his cuiz en Categ:ry A, in which he_

received ca grade of 89.1%, was also unacceptable because of the fact that he subjttedsomeneelse'swork. Nonetheless, the accelerated program prepared for FLOYD by Training covered the Category A material. In retrespect, it is regrettable that :his issue was not directly mentioned in the memo, but I can - state that FLOYD's initial exam en Categ:ry A was in ne way acce; able t: me ar.d he was recuired to cover that r.aterial and be tested en it as part cf the ac:alera:ed recualification program. c'y nej: recollection of this issue is of a mee:ing in M*LLER's effice en or "ascut July 9, 1979. I believe Tem HOMSACH was there fr:m Pers:nnel; I, myself, as cnly :P.ere part ef .the time. I was told that FLOYO was being relieved cf nis cpera:fonal res;ensibilities and being assigned to Training en a full-time basis until he finished the pr: gram and passed tne exam en the weak areas icentified. These included the two F5R sect,iens in which he scered less than u 50% and the one he submitted using some of ,,(([) material. Mr. Eaci asked me if I conf 5dered Mr. FLOYC's actions in submitting scme Of H!T:' answers en his (FLOYD's) exam to be cheating. teid him abselutely - thert'is no question but that such c nduct is cheating. Further, I told him u . . . . .. . . - - . .. e e -, , - - - - - - - . w - ,_,m,. - - ,e-m.-- -. - - - . - - - , ,v- , , ,,

1 s --e l

                    .Page 4*of 9                              -     ~~                                                   !
                           !                                                                                             \

tha: Secticn A, as originally submit $ed by FLOYD cn his F5R exam, wa ur.ac:e;;asle to me and the Training Dept. , I told him aise tha: FLOY; was re. cuired to cover related Section A material in the accelera:ed ;regram and was tested en the material prior to the August 3,1979 recertificati n letter being sent'to the NRC. I have been shown MILLER's 8/3/79 letter and cannot explain why he attributed

                                                                                                                  ~

the 89.1% grade to Mr. FLOYD since it was well known that FLOYD had net achieved that grade by hi.self. I also cannet explain why MILLER enly identified two areas of weakness when FLOYD had a t:tal of three. MILLER should have known tr.is and that FLOYD have covered all three areas in the accelerated recualif'ica:icn program. The only 89.1% grade I know of was the Ta ene FLOYO get using some of

                                                      $ ork; o

it was not FLOYD's grade en any c:her

              -cral er written exam asse:iated with this incident including the ene en the a:: ele n:ec recual. program.

l "r. Ea i cid me that MILLER testified that he cid nc

          . .                                                                          censider FLOY 's a::icns :: be cheating and further, that no one in the Licer.see's Training
             .gr:us disagreed with him. That is simply net true; I censidered FLOYD's
            . actions to be cheating.           I have also been told that tne Aug. 3,1979 le::er Aas circulated in draft form to everyone on tTe distributien list ,                     and further.  , that according to MILLER, these persens were specifically aware of the fa :s and did not disagree with its contents. Speaking for myself, tha
            ' is nc: true; I did not see the letter-before-1: want~ cut ~nce did I agree witn its contents after I finally did see it. I am sure I would have remembered L ..

Pager5 of 9 it, especially the part about FLOYD.only having two weak. areas. I recall

                 . reading this letter in detail only after it had become an issue with the ASLB.

Mr. Baci asked me if I ur.derstood AP-1006 to permit "take-home" exams'. I know that 1006 says FSR quizzes should be given in the classroom or on shift. They have usua'lly been given on the honor system and I was not aware of any problem

                -involving them until the FLOYD incident occurred in 1979.                                  I have since heard that some operators had taken them home.

The investigators showed me a copy of a memo from me to FLOY9 dated July 11, - 1979. The memo asks FLOYD to redo the FSR assignment for' Category A and states that this extra work is at the request of G. P. MILLER to insure the validity of this section of the FSR. I cannot recall whether this memo was ' , precipitate,d by a written or oral request although I believe that it came from MILLER by way of BEERS. I do not know whether or not FLOYD ever completed and

               . returned the assignment which was attached to the memo. .In retrospect, I agree that this memo makes no sense for several reasons.                              First, the Category
             *A quiz originally submitted by FLOYD was certainly a deficient area since he                                                          '

had cheated on it, submitting someone else's work as his own. AP 1006 does not call for ' individuals to redo the deficient FSR sections; it requires that l

              ~t hey be assigned to the accelerated requalification program. Second, FLOYD had already been assigned to this program;                      I, myself, had signed the memo assigning FLOYD to the program effective July 3, 1979. Thus, having FLOYD redo
             - the' Category A section on the FSR would have served no useful purpose and I
             .cannot explain Mr. MILLER's motivation or reason for asking that he do so.
                               ,      . _ . , - , . . - . , , , . - +-.--n.  .  . ,.-.., -,           , , ,

Fagef6*of 9 I cannet explain FLOYD's m: ives for cheating on the FSR quiz :tner than t: say he was indifferent er even lazy.concerning the fulfill ent of his writ en training requirements. He was and is an extremely bright anc ca;able man, cuite capable of passing the F5R cuizzes on his own, if he had ap: lied himself and aken his time in preparing written answers. As a matter of fact, FLOYD scored rather high en the Category A section of the requalification exam he

     .- . took in 1979; this exam was given about-four months prior t his turning in the FSR quizzes which are the cause of so much cencern.

While I cannet explain scme of the apparent discrepancies which exist with rescec: to this issue, especially cencerning Mr. MILLER's Aug 3,1979 le :er the NRC, I can state that FLOYD's performance en -he Categ:ry A F5R qui: was regarded as chea:ing and therefore unacceptable :: the Training Dep . Furthee, that FLOYD was required to partici ate in the accelerated repualifi-catica pr: gram for all the' weak areas which were identi'ied thrcugh the F5R

         'cui::es, includtrg the two areas in which he sc: red less than 50% and :ne Cate-

_ we --

         ,g:ry A area in whien he submitted scme cf                   . 5a:erial. I can a- es;'

the fact that he completed all of the werk in the training package and suc-cessfully passed a written test which covered all the deficient areas, including

       -Ca egcry A.

This ' exam, which was proctered and graded by :eenis 50LTZ, seculd

       -have been the basis for FLOYD's certificatien since he received a core of 99.8 I can also attest to FLOYO's c mpe:ence in the Categ:ry A area since 30LTI and
                  ~

I had discussions with him during his assigned week in which he demonstrated an uncerstanding of the material. However, no written rec:rd cf these discussiens was maintained. O

l Page 7 of 9

                    .I have been told that MILLER has stated that the Training Dept. orally -

examined FLOYD and determined FLOYD's adequate knowledge of Category A. MILLER was most likely referring to the hasty conversation we had with him prior to his testimony before the Special Matter in which BEERS, 80LTZ and myself were quickly trying to recall and reconstruct the events of three years past. I believe we told MILLER of the oral discussions on reactor theory that BOLTI and I had with FLOYD. In addition to what we believe was oral questioning that took place between FLOYD and BROWN during his accelerated program on the subject of fuel handling, suberitical-multiplication and reactivity balance, it should be noted that FLOYD in his accelerated assignment . incorrectly answered

                -the question on subcritical multiplication and had to be reassigned additional
              - problems which he then successsfully completed. Since FLOYD had demonstrated a                                                             i weakness in the area of suberitical multiplication, which is Cat. A material -

this area was included as part of the final accel. program exam he took and passed on 7/23/79. I have provided the NRC investigators with copies of the program and exam especially made for and taken by FLOYD and have marked those portions which pertain to Category A. I realize, however, that this does not explain the inconsistencies in the Aug. 3, 1979 certification letter. When FLOYD successfully completed the accelerated program on or about 7/23/79, his exam was graded by BOLTZ, reviewed by myself and L. L. LAWYER (Manager of . Training) and forwarded to MILLER for certification. Shortly afterwards, I received a call from MILLER thanking me for getting FLOYD squared away and 4 e i 1

t

  ^

Page 8'of 9 - ' telling me that he, MILLER, would take care of both the followup to the NRC and any further actions concerning Mr. FLOYD. That was the end of my association with the FLOYD matter and the next thing I heard was the news from the " grapevine" that FLOYD had been reassigned. One other document concerning the incident was shown to me by the investigators. This was a memo written by me to MILLER. Dated July 10, 1979, after my July 9th meeting in his office, the memo is a summary of FLOYD's participation in the 1977/78 requalification program. It identifies, among other things, that FLOYD scored , less than 80% on FSR Categories E and H quizzes and that answers to Categories A and K (H) were written by someone other than FLOYD. I told the investigators that prior to .the hearings I had no contact with Jack HERBEIN concerning the FLOYD issue and do not know what part he played, if any,-in the decision to send the Aug. 3, 1979 letter to the NRC. I also told

                .them that no one, including Gary MILLER, asked me, either directly or indirectly, to shortcut, circumvent or otherwise interfere with the AP-1006 training require-ments for FLOYD because they needed his license or for any other reason.

I have read the foregoing statement consisting of 10 handwritten pages. I i

Page'9'of 9 have made and initialed any necessary corrections and have signed signed my name in ink in the margin of each page. I swear that the foregoing statement is true and correct. Signed on 10/1/82 at 0959. SIGNATURE: /s/ RICHARD W. ZECHMAN Subscribed TMI Trainingand sworn to before me this 1st day of Oct.,1982, at Center. INVESTIGATOR: /s/ Peter E. Baci .

                 . WITNESS:   /s/ Edward J. Brown O

a. t

  • 4 9

6

l I l Page l'of 3 Place: Parsippany, N. J. Date: 10/18/82 STATEMENT I,' LAWRENCE L. LAWYER, hereby make the following voluntary statement to Peter

                   - E. Baci, Regulatory Nuclear            who has identified Comission.himself _ to me as an Investigator with the U.S.

for-me.

  • Investigator Baci has written this statement This statement summarizes the information I provided to Investigators
                   .Baci and R. Keith Christopher at GPU HQS on 10/18/82.                 It relates to my       '

knowledge of the' events leading up to the certif.fcation of James FLOYD to the NRC on 8/3/79. At that time, I was assigned to TMI as Manager of Training and most likely reported to Jack HERBEIN. Training was not yet my primary , function and I,had other duties as well. Sometime after-7/1/79, Dick ZECHMAN came to me while I was working nights and told me that on one exam FLOYD had taken as part of his FSR package, the handwriting was not that of FLOYD.

                  - ZECHMAN indicated that he was going to notify line management of the problem"~

although I don't know specifically who he went to,

         ,                  The next contact I recall on this issue was about February of 1981 or 1982 - I can't remember which - when Jack HERSEIN asked me if-I had taken any of the records with me pertinent to FLOYD's examinations when.I was transferred to INPO-in Georgia.               I told him that I had not.

I was not familiar with FLOYD's situation back in 1979 as it applies to the number of weak areas he had to redo for the FSR. I knew he had at least one area because of the exam ZECHMAN had shown me. When I saw the certifi-cation letter of 8/3/79, as I feel I must have, I would not have paid any l .special_ attention to the grades, assuming that ZECHMAN would have put in L

the appropriate grades. If I had seen the passing grade on the one problem i

exam I'd have assumed that the issue had been resolved. Attachment 14

Page 2 of 3

             ~

With benefit of hindsight, having been told that FLOYD asked someone else . to complete work for him which he then submitted in fulfillment of a training requirement, I would have to.say that such conduct would constitute cheating-in the generally accepted use of that word. I never met with or discussed the i exam question or qualification / certification issue with Gary MILLER, Jim FLOYD

       ~ or Jack HERBEIN. 'As far as seeing the certification letter, either in draf t or final form, I would have relied upon Dick ZECHMAN to tell me if there was any problem with the way it was written.

I cannot recall having seen a memo from ZECHMAN to FLOYD dated 7/6/79 concerning FLOYD's ARP assignments. In reviewing it however, certain parts of it seem to address the Category A or reactor theory area. These are the first and second assignments.- Mr. Baci has shown me a copy of a memo from ZECHMAN to FLOYD, dated

   .-    7/11/79, in which FLOYD is asked to redo the Category A part of his FSR assign-ment to ensure its validity.        I don't know the rationale for this request since
      . it wouldn't have changed the requirement that he cover that area in the ARP.

Concerning the 8/3/79 certification letter, signed by Gary MILLER, there was no intent on my part to be a party to any inaccurate representation to the

      !NRC concerning either the grades on his (FLOYD's) exams or his qualifications to hold an NRC license.

I have read the foregoing statement consisting of three handwritten j

                                                                                                )

Page '3'of '3 _pages. I have made and initialed any necessary corrections and have signed my name in ink.in the margin of each page. I swear that the foregoing statement is true and correct. Signed on 10/18/82 at 1:30. .

                              . Signature: /s/ Lawrence L. Lawyer Subscribed and usworn to before me this 18th day of Oct.1982, at Parsippany, N. J.
                             ' Investigator: /s/ Peter E. Baci 10/18/82 1:32 P.M.
                          . Witness: /s/ R. Keith Christopher    -

10/18/82 1:32 P.M.

               .                         Investigator, U.S. NRC O

4 L

 ~
                                                                                                     .-m
                   ,        ?ggs,1 of 5 Place: Three Mile Island Date:           October 7, 1982 STATEMENT
                         *I, JAMES R. FLOYD, hereby make the following voluntary statement to Edward C.
                       . Gilbert Nuclear who           has identified Regulatory Commission.                   himself 'to me as an Investigator with the U.S.

Investigator Gilbert-has written this statement for me. This statement summarizes.the information which,I provided to

Investigatora Gilbert and Peter E. Baci during an interview on 5 October 1982 at th'a TMI NRC Office. I have been employed by Met-Ed since 1965 and I am
                      ' currently assigned to the Safety Review Group. The investigators have asked
          .             me to reconstruct the sequence of events which occurred subsequent to my submittal of my TSR exams to the Training Department in July 1979.

Since I had scored less then 80% in various sections of the cross-licensing exams and the annual requalification exam, I was required to receive FSR training. Therefore, I received a training package of exams which I had to complete and return to the Training Department. Since I have received several of these training packages, I cannot recall how many sections

            ~                               ~

this one consisted of or the specific questions and/or answers. Mr. Baci has told me there were four sections. I would like to point out that I consider "on shift" and "take home" exams to be identic la , i.e., they are not monitored. I submitted the examination material during the later part of June or the first part of July 1979 and then went on a one oc two-week vacation. When I i returned to work on Monday, July 9, 1979, there was a note on my desk l indicating Gary MILLER wanted to see me. I immediately went to his office and I had a meeting with MILLER, Tom HOMBACH, and Dick ZECHMAN. I was confronted 4 1 4 Attachment 15 j

  . - - -    -          ,_. _,__,_,---r          .,    , . , . - _ , , _ . . _ . - , , ,         _ _ _ __           . , _ _ - . . . - . . , _                 , . . . . . , _ . - - , - -
                        ? age.2 of 5 1

1 I vi h the fact that sc=e of :he TSR 1xa=inatic: =aterial I had turned is r centai:ed another individual's handwriting. I readily ad=1::ed tha: :his was 1W 7 vri:ing. I told Mr. Miller that this was not an a::::p: c: =y par: to defraud anyese but ra:her tha: I didn't have sufficient :1=e to ec:;1e: :he exa=s =yself. Mr. MILlIR :old =e I was being re: ved f c= all licensed i ac:1vity and reassigned to the Training Depart ent until I had satisfae:::ily 1 ce=pleted all training require =e::s :o rese.lve :he areas in which I had

            -                                                                                                             i
                      ~de:::s::ated weaknesses.

Mr. Zaci showed =e a copy cf a =e=o :o =e f c: Mr. ZZCMMAN da:ed July 6, . -1979cc:erning=7placeIan: in c the Accelera:ed !: tining Pregra= and - identifyingthe:::erialto$ecovered. '~n ile I casnet specifically recall

eceiving and reading :his =e=o, I de : t dispu:e : hat I did. E vever, I have s

read.this eene recen:ly since :he issues cf =y requalificarica and [. cer:ift:atics have bee: raised. Areas /31 zud #2 ef this t l'

                                                                                            =e== per:at      to
l. Cz:e;::y A (rear.:::

t ' decry) and : hey could 'ee ep;'.1:sble ':e Ca:egory E. r i Mr. 3aci aisc showed =a a copy of ane:her =e=o ec ce f:c: Mr. ZICEMM da:ed .*uly 11, '979. A1:heugh I can::: specifically reca'.1 receiving and ' 1 reading this =e= , I do not dispute : hat I did. Eevever, I have' read this i re:: ==:e recently. I also ca::o: specifically ree:11ee: whe:her c: ac: I vas  !

equested to re-do the ySR assign =es: for Ca:eg: y A as requested in the =e: .' l
                  - I assu:e I did it since 1: vas requested. If I could see the Ca:egory A exa=                           l

{ l vhich was at: ached to the =e=c I think 1: vould help =y =e= cry. 1 t l

                   'Jef:'::unat ely a ecpy of this exa= has tot been loca:ed.

I may also have c:=;1e:ed this ext: by means of an oral review. I l b o l

I Pase.3 of 5 Mr. Baci showed me a copy of an undated memo from Mr. MILLER to me - wherein I 'vas criticized for exercising poor judgement. I assume I received and read this meno although I have no specific recollection of it. I probably received it shortly after the meeting I attended in Mr. MILLER's office in early July 1979. , To the best of my knowledge I satisfactorily completed all training

         . ,                requiiements in the Accelerated Requalification Program (ARP).                                        However, I cannot recall whether or not I had " sit down" sessions with training department personnel to determine if all necessary sections / categories had been covered. I did take a written exam and achieved a score of 99.8%.                                            I
                      -cannot specifically recall whether. Category A material was covered in this written exam.                           I may have taken other written or oral exams during the ARP but I cannot recall any. Mr. Baci showed me a copy of my ARP exam. After reviewing this exam, I identified the following questions containing Category A material: #4 (sub-critical multiplication), #11 (reactivity balance) and f1A (Category A and H).                          Overlapping of categories existed in the exam questions and answers. I would like to point out that by achieving a score of
                                                                                                                              ~

99.8 on this exam I demonst'ated r my knowledge of Category A. Subsequently, Mr. MILLER vrote a letter to Paul COLLINS of the NRC, dated August 3, 1979, certifying that I had satisfactorily ccepleted the ARP and 1 obtained a score of 99.8. I did receive a copy of this letter after it had been sent. I have reviewed a copy of this letter provided by Mr. Baci'and I told Mr. Baci I saw nothing wrong or misleading on its face. However, the l G

             - ,,,-----4e,,           -c,-,-,,---e-,---,m--,,,,                  ,. w- , , - m--, g-v w a --- w,- , - - e--   y   w          , ,   ,
      -              Pahe,4of5                                                              '
                    . letter may contain an error with respect to the 89.1% score attributed to me for Category A.         When I told Mr. Baci that I saw nothing wrong or misleading
                   .on the face of.teh letter, I meant that the letter looked internally consistent, except, perhaps, for the 89.1% score.          I did not mean, and do not mean to suggest, that, if the letter contains an errer, there is nothing wrong with an erroneous letter being sent to the NRC. These comments are applicable
                                   ~

to my thoughts on October 5, 1982. When I first saw the letter after it was sent to the NRC:in 1979 the possible anolomy (sic) of the 89.1% wuold not have been apparent to me since the Training Department is responsible for preparing and-conducting the ARP and associated exams and maintaining records. Therefore, I rely on the procedures and documented test scores. The initials on Mr. MILLER's letter indicate it was actually authored by William H. PARKER. j l Mr. Baci told me that according to Mr. MILLER a draft copy of this letter was l, sent to all individuals listed on the distribution, including me; however, I

          ~~
never saw'the draft copy. Mr. Baci pointed out the score of 89.1 attributed l l

, to me for Category A. I can only assume this was either a clerical error made l l c by the Training Department or a coincidence.

                          .At approximately the time I took the above exam (three weeks before or after) I was reassigned from Supervisor of Operations or the Training
i. . Department to an Ad Hoe Committe/ task force for the Accident Assessment Group.

E A memo assigning Joe-CHWASTYK as the Acting Supervisor of Operations was distributed although I have not been able to locate a copy of it. I know this memo was circulated since it was'importanc co notify the staff'of this'

                                                                      ~                                    ~

l l l reassignment.

Pese,'S of 5 At the time I did not consider this transfer a punitive measure. As a '1 result of thd Partial Initial Decision, if not before, I ahva learned that it was intended to be punitive in nature. Mr. Miller did tell me at the time of the exam incident that my conduct was unacceptable. . I never discussed my reassignment with Mr. ARN01.D. In my opinion, a more complete and precise version of the above events is contained in my testimony before Special Master MILHOLLIN any my interviev with Mr. Fred SPEAKER. Mr. SPEAKER's interview was taken at the behest of CPU Nuclear. I voluntarily appeared for all three of these interviews. \ f ( I have read the foregoing statement consisting of five handwritten pages. I have made and initialized any necessary corrections and have signed my name in ink in the margin of each page. I swear that the foregoing statement is true and correct. Signed on 10-7-82 at 1316. Signature: /s/ James R. Floyd " Subscribed and sworn to me before me this 7th day of Oct., 1982, at Three Mile Island. Investigator: /s/ Edward C. Gilbert Witness: /s/ Peter E. Baci 8

Title:

Invesi:igator I

                                                                                                                                                                                                             )
                                                                                                                                                                                                             )

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t. . tieto vn, Pennsylv.nia 17057
                               .                                                                  717 944 4041 To: J. R. Floyd Subjec't:            Failure to Comply with Licensed Operator Training Requirer)ents You have been counselled for your recent conduct during the 1978-1979 Requalification year. You exercised and demonstrated exceptionally poor judgement i              in the manner you chose to complete the assignments specifically designed to remedy those areas in which you had a demonstrated deficiency. More importantly.

your actions indicate a disregard for the system of administering examinations, and for the importance of training as a part of the responsibilities of a licensed = operator. 1 . l A copy of this letter has been placed in your personnel file with the ex-

pectation that there is recognition on your part and that there will be no recurrence of this or similar type behavior.
                                                             .   . Miller GPM:cak cc:        J. G. Herbein Personnel File A-Attachment 16
                                        ' e: coo an e so, co m> :s a />m:e c' t*c Grex Puu.: U :u S,r:m

l i I i hI ~ I m g -

                                 -   RESULTS OF INTERVIEW WITH T. L. HOMBACH AS RECORDED BY INVESTIGATOR E. C. GILBERT ON 6 0CTOBER, 1982

[ Thomas L. HOMBACH, Administration Manager, Met Ed/GPU, was interviewed by NRC " s investigators Edward C. Gilbert and Peter E. Baci at Three Mile Island (TMI) l on 6 October.1982. He was advised the interview was being conducted to { ascertain the circumstances surrounding James R. FLOYD's submittal of f Fundamentals and Systems Review (FSR) exams in July 1979. ? - E - [ HOMBACH remarked that several weeks ago he had received a letter from Robert [ E . ARNOLD, President, GPU Nuclear, notifying him that he would be contacted by a [ company representative, Fred SPEAXER, who was conducting an investigation of - [ the matter for the company. He can'tinued that at this time he made a conscious decision that he would rely on his personal recollection of events f rather than preparing himself by. contacting knowledgeable individuals and i i reviewing pertinent documents and records. Therefore, he conceded that he was [ i only able to impart general information to Mr. SPEAXER and the NRC

              .  .. investigators.

i E [ ' HOMBACH stated that his knowledge of and participation in the incident was limited to his attendance at a meeting in Gary MILLER's office in July or August 1979 when the examination improprieties were discussed with FLOYD. He h 1 recalled that Richard ZECHMAN, MILLER, FLOYD and he (HOMBACH) were present. p He noted that his presence at the meeting was based upon his position at the time as Personnel Director for TNI. E

HOMBACH related that when FLOYD was confronted with the handwriting discrepancies appearing in the exams he br, s imitted, he did not deny that Attachment 17

some of the material was not his. Further, HOMSACH advised that "0 " was tidentified as the other party. Hcwever, he could ne: -ecall whether Floyg Om had volunteered W name or whether. it had initially been mentioned by MILLER cr ZECHMAN. l As he recalled, FLOYD's excuse fer his actiens was that he lacked sufficien: time to cceplete the exams himself. HOMEACH stated tha: :he incicent was nct described as " cheating" during the meeting. He did recall that MILLER adm:nished FLOYO by remarking that his c nduct was ina::r :riate ar.d unacceptable and that it would not be tolerated again. He could not recall specific disciplinary actien being discussed with FLOYD at the

            . . meeting. HOMSACH could not recall whether FLOYD's demonstrated areas of weakness recuiring additional training were indicated during the meeting.                            He did rec:llect that the nec~e'ssity of FLOYD being " ret'ested" was tentioned.

When cueried regarcing FLOYO's reactien to the discicsure and confrenta:fon, n u.v. . . .x n cbserved that FLOY3 was n:: pa,rticularly c:ncerned er u; set. He n::ed, hcwever, that FLOYD is no: an emotional individual by nature. l MCMEACH advised that with tne excepti:n of Senerai discussions (s:ecifics nc

          ,              recalled) wi:h M:LLER concerning the incicen:, he d:es ne: recall parti: ipa:.

i .; in ary subse: ant reetings or decisi:ns regar ing the matter. :n :nis

               . regard, he was r.:: involved in any disciplinary reasures which                                  were pre:: sed er initiated. He did not know whether a letter of reprimar.d hac been ;'. aced in FLOYD's persennel file.

MC.v.5ACH pointed cut that he w:.ld ncr ally have i cecided the appr:priate disciplinary action; however, during the period

                                              * " * =         w=....      -

l=-.. . . . . . .

follo~ wing the accident, this responsibility was assumed by higher levels of management. He noted that subsequent to the meeting, FLOYD was no longer working in a licensed operator capacity. He could offer no additional perti-nent information. I l L Reported by: /s/ E. C. Gilbert E. C. Gilbert, Senior Investigator l O t 9 7.,*.*<,-[,.h._...'__. .

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   /        ' Page 3'of 3
                 . I have read the foregoing statement consisting of 3 handwritten pages. I have made and initialed any necessary corrections and have signed my name in ink in the margin of_each page. I swear that the foregoing statement is true and correct. Signed on-10/7/82 at 11:06.

Signature: /s/ Nelson D. Brown

                  ' Subscribed and sworn to before me this 7th day of Oct.1982.

at E. Hanover TWP, PENNA. . Investigator: /s/ Peter E. Baci Witness: /s/ Edward C. Gilbert O t a i to I l i e

                                                                                      . . - = =
 ~                 "

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                                                                                                                                                                                  ~

E 3.:01.lTA:t E3I50*: C~E:.ATOR RE.',191.lFICAT10ft FF.C tA:t C0hTROL_D COPY Date R e fis;en

                                                                                                                             "@NES   pa:r_-              D::,                       g e,;p Pee           b'. .               Revision                Ps:e 1.0       04/11/77                    2                 26.0                                                                 51.Q 2.0       C4/11/77                    2                 27.0                                                                 52.0 3.0       04/11/77                    2                 28.0                                                                53.0 4.0       04/11/77                    2                 20.0             e                                                   54.0 5.0       04/11/77                    2                 30.0                                 ,

55.0 6.0 04/11/77 2 31.0 -- 56.0 ' 7.0 04/11/77- 2 32.0 57.0 S.O 04/11/77 , 2 33.0 ' SS'0 9.0 04/11/77 2 3'4.0 59.0 ' 10.0 04/11/77 2 35.0 . 60,0 11.0 04/11/77 2 3G.0 1 - 61.0

     '12.0         04/11/77                    2                 37.0                                                                  62.0 13.0        04/11/77                    2                 38.0                                                                  63.0 14.0        04/11/77              .

2 30.0 64.0 15.0 04/11/77 - 2 40.0 G 5.0

      'l 5.0       04/11/77                     2                41.0                                                                  G6.0 17.0                                                      42.0                                                                  67.0                                    .

1 S.0 - 43.0 68.0 10.0 44,o 69.0 20.0 45.0 70.0 21.0 46.0 71.0 22.0 47.0 72.0 23.0 43.0 . 73.0 24.0 49,0 - 74,0 25.0 50.0 75.0 Uni: - Unit 2 Staff Recor. n,tn s .'6::rovsl i s 1 Staff R:': Approv:1 I m/. enrJsDate A :r: val - A pproval I Cate Ccinitfat O!;/. i$ d Cc; if t..t'pf.}::: Unit 2 OP.r:Recc.- rnands A;;rcv:1 Unit 1/GSC Re::.-Inends Apcrovat

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  • u.) D a te .'.!. " ~ Y
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         /           Chsi:r .:n cf TO F.C                                             [j         [ , Chs;rr .:n el F0%

PORC commen:s of - i ...!.:d:d

                                                                   .                          I' ORC ccm .ar :: cf                                                      _i.:!ad:d

(: fate) M!t!! Ey - v .... Cs _ _ _ Da:e A A . 1'

                                                                                           *1.;;.r:.~i J.-lNN.?5h.oCa:'.?!                 ~ ~ ~ ~
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A ~ - " ~ Approvsi hY{ li'W'D  :~ n.. A/**")/ j n } ,.. c . a , ^ i<

                                                                                                                                   .,                                        ,ato .._.        .

7.';r. 0:2,u. ., .. g ,,g ,,, .j., p ,.g ,.,.,3 .,. g.,. 3 Ov,i.ty A=2.2 ce Attachment 8

Revisidn 2

u. v 04/11/77.

THREE MILE ISL'.'.3 !;;;* EAR . STATIO.*i

                                                 .       ACMIllISTPATIVE .R: E::RE #1005                                                     -
                                 ~; Metropolitan Edison Operator'Re:;ualification Program                                                                    ,

CAUTIO.'t:, Prior to changing att' ached procedure - FSAR submittal r.ust be - made since Admin.1006 has been submitted as a portien of the FSAR. -

                                         .                       Table of Centents Pace 1.0 GErlERAL                        -
                                                     ,                                                                               2.0                                     '
            -1.1       Purpose
                                                                                           .                                         2.0 l.2 ,5cepe                                            .-                                                        -

2.0 . 1.3 ' Program Schedule ' 2.0 2.0 REQUIREMENTS ~ - 4.0 2.1 Operational Review (OR) Lecture Series - 4.0 2.2 Fundamentals and System Review (FSR) Pregram 6.0 2.3 On-The-Job-Training - 7.0 2.4 Annual Evaluation Examination , ,

                                                                                                                . -.              10. 0
          .2.5        Records                                                                                                                                          ~
                                                                    -                                                    *~13.0 2.6 Accelerated Requalification Program
  • 14.0 -

2.7 -Four Month Absence Program . 14.0 -

        ~

2.8 fleuly Licensed Operator 15.0 3.0 RESPO.'ISIBILITIES -

                                                                               ,                                               15.0 3.1 Supervisor of Training and His Staff                                                                        '

15.0 3.2 ' Operations Supervisor, Suparvisor of Training, or Other Suitable Qualified Person Designated by the Station

                   ' Superintendent                                                     '

16.0 g .

                           ,                                                 1.0 '                                                 *
                                                                                                              .  ,                                                            t
                                                                                       -                                                                                                          ~

r . . i- .. . 2

.: ) . ..
                                   .                                                                                                                                                                  'C05 Eni:ic.. 2                                       .

C'/11/77

                                                   .                     THREE MILE IS'J 10 i;UC' AR STATION                                                                                                                                                      .
                                                                         . ADMINISTRATI'/E pAOCE "RE #1006                                                                                                               ,               ,
                                                                                                                                            ~
                                           -             Metropolitan Edison Operator Requalification Program                                                             -

1.0 GENE?.;L . . 1.1 Purpose - The Metropolitan Edison Requalification Program, as set forth in this docud:ent, applies to the Three Mile Island Nuclear Generating Station. All licensed personnel will participate in the' applicable ,

                                 . portion of the requalification program. The basis of the requalifi-cation program is,the need to maintain operator competence and
                                                                                                                                                                 ~
  ,1                 '.              proficiency in the quest for continued safe operation. The guidelines'                                                                                                                                                              ,

for the requalification program are found 'in.10CFR55 Appendix A. In addition, the implementation of this program conforms to 10CFR50.

          .' 1.2 ^ Sco;-: s                                                                 -                                                                         -
                                                               ....- ~.                                         ._
                                                                                                                                                                                              .       .c The'following section of the requalification program covers:                                 -
                            .                    .           Program Schedule                                      -

7-~~- II. Pre-planned

  • Lectures
                                                                                                                                        . : :,                                   .         JN h                                      ,..
                                                                                                                                                       ..               i. .: ,                       ... . ..c                                       .,

III. On-the-job-training - IV. Annual Evaluation Examination . V. Records -

                                                             .                      ..                                                                                    ..                                            ,                     ....f..

VI. Accelerated Requalification Program , E VII. Four Month Absence Program - *;~? . VIII. Newly Lic.cnted Oparators .' IX. ' Requalification Program Administration .

                                                                                                    .                                                                                                                                              . ; . .r. -

1.3 Program Schedule

                                                                                                                                                                                                                                                      ' C. . -
                                 .The requalification program described herein will be implemented at                                                                                                                                      ,

a specified date within 90 days aftar receipt of an operatin's. . . .. -

                                                                            ..                                       2.0.s                                                                                  ..                                                         ,

s c ,-

                                                                                .                                                    .                                                               ,,          ,                                             ~
                                                                                                                                                                                                             -).-                                      .
                                                                                                                               . ...,                 .~                 .

9 .

                                                            ~

1C05 F.cvision 2 01/11/77

                                              't.[ license. March 1, and subsequent a .niversaries of this date, will '

be considered to be the star' ting dat of each annual cycle of ,

                                               .          requalification program operation.       .
                                                                                                                    ,          j                         .

The I'etro;olitan Edi' son Requalification Program consists of four interrelated segments which run concurrently. These segments are:

1) Operational Raview l.ecture Series (OR) -

2), Fundamentals and System Review Program (FSR)

3) On-the-job-training
4) Annual Evaluation Examinations The OR Series is a classroom lecture presentation 'which provides ,

lthe licensed personnel with the details of operational information - related 'to the Three Mile Island Station. As part of the OR Series, FSR topics'are selected in

                                                                            ~
                                                        ' selected FSR topics are presented.
             .                                          areas where annual operator and senior $perator written examinations indicate that' emphasis in scope and depth of coveraga is needed.
                                                    , OR lectures are scheduled for a minimum of 60 hours per ye'ar.

On-the-job-trainino is designed to insure that all licensed personnel'

                                         ~

operate reactor controis and participat,e in major plant evolutions.

                                     .-                Records of all on-shift performance are maintaine'd and periodically reviewed by supervisory personnel. The ' annual evaluation examinations simulate the written and oral examinations administered by the .

lluelear Regulatory Comission. Performance on these annual evaluation examinations determine the extenk; of the FSR program during the , following twelve month requalification period. Each license holder w'ill complete all OR and FSR requirements on an .

    .-                                                 annual cycle. The On-the-job-training is conducted throughcut the -

two year term of the individual's license. All required on-the-i p . ' l ... , , job-training will be completed prior to licansa renewal. 3.0 ..

   - '-    '                                                                                                                              1C05               -

Favisica 2 0*/11/77 e A statement of Requalification pr:; ram participation will be submittsd-with each license re. esal applicatic'n. The requalificati,cn program is designed with fixed performance standards and specifi(d remedial .

                                 ;              actions. The procram results and records are fully auditable.                                                            .

2.0 REOUIF.E!!ENTS . . 2.1 Operational Review (OR) Lectures Series . During each year, personnel shall attend the Operational p.eview (OR)LectureSeriesenthefollcwingbasis:

                                              '(a) Licensed station administrative and technical persennel will I   participate in the OR Lecture Series as either students or instructors, except to the extent that their normal duties                                                  .

preclude the need for spect'ffe retraining in particular

                                                                                                                                                             ~
                                                                      '                                                               ~

areas. . (b) OR Lecture Series attendance is required o'f all licensed operators and senior operators who are normally on' shift . assignments. , The following* topics shall be covered as a minimum during the CR , Lecture Series eacn yeir: (a) Reportable Occurrences *

           .                                   (b) ijnf t ibdifications                           .

(c) Operating History and Problems - (d) Procedure Changes . - (e) Abnormal and Emergency Procedure Review

                                            '(f) Technical Specifications (g) !!ajor Operational Evoluttens (such as refueling)
     .                                        (h) Applicable portions of Title 10, Chapter I, Code of Federal Regulations                                                      ,             .

4.0 . e a

1005 Revision 2 (i) FSR Program Material 04/11/77 Additional topics which may be presented include: (but are-not limited to) * (a) Operational Q/A . . i (b) Standing Orders (c) . 0;erating Experiences - Reactor Safety and other per

                                                             ,              publications                                                                                                          .

Lectures shall be held on a continuing basis and consist of minimum of 60 scheduled hours per requalification pregram The program for each session .will be determined by unit or projected operati.ons. ' Records of the topics

  • covered in eac session will be maintained-by'the Training Department.

Attendance of all licensed personnel will be reccrded.

    .t  ,           ,

Absences will be made y by reviewing lecture materials and/or discussions with ' supervisory personnel or the tebhnical staff. Periodic evaluatien quizzes covering the content of the OR lecture series will be administered. .

                                                '                                              The auttzes may be administered in either the e.losed
                                                        , book or_open book format, as class room, or on-shift If -quizzes.
                                            '           'an uhsatisfactory grade (less than 20';) is received, makeup s
                 .                                     iwith assigned instructor.s kill be conducted.

The makeup session '

                                                     . w                                                                                                                                                           ,
                                                       , ill conclude when an oral evaluation is satisfactorily completed.
                                                  '     The centent of the quiz will be different for f.0 and SRO license holders and will reflect.the topic areas and degrees of respo                                                                               '

needed by the license ' holder.

                                                                                                                      ~ Examples of the ~ materials to be used p ,.

during the OR lecture series are: 5.0

  • p O e e. ' s
                                                                                                                                                                                                                          \

v ~ m, ,,,,s. , ,------,y -.. ,, . , _ ~ . - . - .-,,-.v, =,

l

 .,           ,                                                                                                      ICC6 I.alis$on 2 f                                                                                    'C"/11/77 (a) Unit Records and Legs                     .

(b) Pertinent Cc=unications to and frem the i;RC ' (c) Unit Procedures and Changes . (d) Test Results * (e) Applicable Training Program Materials ' 2.2 Fundamentals and System Review (FSR) Program -

  • During each year, licensed personnel shall participate in the FundamentalsandSystemsReview'(FSR)PrograEbasedenthairanc.ual wcitten examination scoras as identified in Sectier$ IV .- Evaluations.

The FSR Program may consist of pre-planned lecture serias, s,alf study assignments, possible tutorial sessions with designated . technical instructors and evaluation quizzes. The study assigneants and pre-planned lectures will be in keeping with the license level of the individual ifcense holder. Individual _ study assign =ents, films, and video tapes will consist of no more tha'n 50". of the FSR' ~ Program. .

          .. .                           Pre-planned FSP. lectures shall, be scheduled in those areas where                     . . ,
                                     ' annual operator and senior operator written examinations indicate                               '
  • hat emphasis in scope and depth of coverage is needed. ,

Any or all'of the following topics may be included in a particular year's FSR Program: . (a) Principles of Operation (b) Features of Facility Design

                 .                      (c) General Operating Characteristics (d)     Instrumentation and Control (e) Safety and Emergency Systems Including Unit / Station Protec:icn                                    ,

Systems 6.0 j 1

                  .,       y Page'1 of 3                               --

Place: Parsippany, NH Date: 10/18/82 STATEMENT-I, William H. PARKER, hereby make the following voluntary statement to Peter E. Baci, who has identified himself to me as an Investigator with the U. S. Nuclear _ Regulatory Connission. ' J I am currently Manager of Facilities, GPUNC at Parsippany. At the time of the incident ' involving Jim FLOYD, I was the Supervisor of Administration at TMI acting in suppport of Gary MILLER. 1 first became involved with the Floyd t ( incident when asked by Gary MILLER to put together a letter admonishing Jim FLOYD for his actions on the FSR examination. I probably was made aware that Jim had turned in an exam paper with handwriting other than his own.

                                          ~

I do not - t. specifically recall that Gary made me aware of the facts int the time. Probably

. Gary gave me.an outline of what he proposed to say and I put it in form. As I recall, the letter was thought by Jack Herbein to be too Navy oriented in terms of a letter of admonition as opposed to the final draft which took Jim .
l. to task for. failing to meet accepable standards of conduct. After I had
            . . completed the final draft, it was approved by Jack HERBEIN, signed by Gary j      .

MILLER, and personally delivered to Jim FLOYD by me. At this time, I was

                ,' unaware of the NRC requirements for licensing or requalification or the specific grade requirements.            I was not involved in any meeting with anyone where the specifics of cheating was discussed. My next involvement was to take the draft of the letter prepared by Marshall BEERS and to put it in                                      l paragraph form. This letter was to certify that FLOYD had successfully completed his accelerated Requalification Program and that he had improved in the areas of demonstrated weakness and had attained the required proficiency.-

l I have seen the July 27, 1979 memo from Gary MILLER to Ernie BLAKE wherein he l I l ! Attachment 20 i

pagar2,of 3 admits to referencing only. two sections despite FLOYD's apparently having

              . studied three sections. I am unaware of what this reference may mean nor can I explain why. the third section relating to the handwriting problem was not a'd dressed.

When I received the initial draft there were no test scores written and I cannot recall who gave me the scores preparatory to completing the final version of the letter. -I' don't believe that unti1 today, I was aware that the 89.1 grade on section A was the section containing handwriting other than FLOYD's. Prior to the mailing of the letter to the NRC I was never-involved in any discussions with respect to the accuracy of FLOYD's ' represented qualifications or whether or not FLOYD should be certified as qualified for a license. No one ever indicated that the 89.1 score should be represented as valid or used in an attempt to deceive the NRC. I was not involved with request to Training to have FLOYO re-do the Category A assignment. I don't believe that Gary MILLER viewed FLOYD's conduct as

            . cheating in the classical sense that one perceives cheating to be based on need of the individual to pass. FLOYO didn't need to cheat - he is just
            ' adverse to administrative requirements.
            .I have read the oregoing statement consisting of six handwritten pages.            I ye e a  e e
                                                                                ---n-

[;. t

  • t' Page'3 of 3 have made and initialed any necessary corrections and have signed my name in ink in the margin of each page. I swear that the foregoing statement is true and correct. Signed on 10/18/61 at 1625.

SIGNATURE: Original signed by W. H. Parker Subscribed and sworn to before me this 18th day of October

  • 1982, at Parsippany, NJ.

INVESTIGATOR: Orignal signed by Peter E. Baci 10/18/82 WITNESS: Original signed by R. keith Christopher Investigator 10/18/82 1626 O O 9 O f

                                            "CO.FIDENTVAL"                               a m es.

METROPOLITAN EDISON C O M P A N Y s...#.,, , c . ..,..,u,.,,,c,,,,,, THI Nuclear Station subject JIM FLOYD'S PARTICIPATION IN THE 1977/1978 Location- Middletown, Pa. REQUALIFICATION PROGRAM - Date ' July 10, 1979 To- G. P. MILLER

           .                                                                           9 The following is a summary of the events associated with Jim Floyd's participation in the 1977/1978 Requalification Program:
1. Jim'Floyd took the 1977/1978 Requalification Examination in March 1978.

He received less than 80% in Sections: (A/H) - Principles of Reactor Theory - 60.4% . 0 ,,7 (G/I) - Radiation Control and Safety - 55.6% (K)(H)- Fuel Handling and Core Parameters - 70% hpgu#g\'t

l. cA* o ff fu g#

(E) .- Safety and Emergency Procedures - 74.8"g pr# lA

                                                                                                                ~

A_s a result: ((l .

                     !a)    Requal Procedure 1006 (copy enclosed) requires that he atten                  u     f the FSR Lecture and receive written quizzes in those areas in                  ??.o which he received 'ess than 80% on the Annual Requalification N Examination.
2. Since he could not attend lectures, he was sent FSR assignment packages.

and quizzes covering areas A/H, G/I, K and E. ~ NOTE: 1) He was sent the FSR assignments in January 1979 to complete. Not returned.

2) He was sent a second set of FSR assignments in March 1979 to cocplete.
3) Hewasnotifiedseveraltimesbytelephoneandinpersontoj get the assignments in prior to July 1, 1979.
4) Received completed FSR assignments and quizzes on Monday,,

July 2, 1979.

5) The cover speet clearly indicated that it was an FSR assignment.
6) All licensed personnel were sent a copy of the Requalification Procedure 1006, on May 14, 1979, to read and to become familiar with, per M. Ross's letter of May 14, 1979 (cover letter enclosed).

Therefore, he should have been aware of the requirements of the { FSR and OR Sections of the Requalification Program. ,

3. He received less than 80% on both the FSR Cateoories E and H cuizzes. Plus, it was identified by the Instructors that the answers to Catecorfes A and K (H) were written by someone other than Jim Floyd.

Attachment 21 INTER-OFFICE MEf.'OR ANDUM l

   ~-
       ?                                            . . .                                .

G. P. itiller July 10,-1979 i

  • a') Requalification Procedure 1006 indicates that a grade of less than 807, on an FSR assignment will require that the individual be assigned to an Accelerated Requalification Program.

b) Accelerated Recualification Program requires thatE an individ al

                                  .will be:

4

1) Relieved of responsibilities and enter a fulltime requalification program.

2). The duration to be determined by the nature of the deficiency and ability to pass an equivalent written and oral examination.

3) K letter of. certification indicating satisfactory completion of the Accelerated Training Program by Jim Floyd must be sent to the NRC prior to his return to duty. -
4. . Effective July .3,1979 Jim Floyd was assigned to ccmplete an Accelerated
        -            Training Program (copy enclosed).
            -5.      Further, Jim Floyd also received less than 80f, on the following procedure quizzes in the OR portion of the Requalification Program:

, P 2202-1.10 - Shutdown from Outside the Control Rocm EP 2202-2.1 - Station Blackout EP 2202-2.5 - Station Blackout Without Diesels Grade 71'.2%I'EP2202-2.3 - Loss of Instrument and Service Air EP 2201-2.1 - Load Rejection QP2203-2.3 - Steam Supply System Rupture

             ,                        [AP1028-OperatorControls
                                      'AP 1037 - Ca'ution Tags
                                      .EP 1203-7 & 2103-1.1 - Hand Calculations of Tilt & Imbalance Grade 68.6% / EP 1202-8, 2203-1.2 & 1.3 - CR0 Failures EP 1202-26A/B & 2202-2.2 - Loss of OTSG Feed EP 1203-10 & 2202-1.2 - Unanticipated Criticality EP 2203-1.1 - " Loss of Baron NOTE:     Per Procedure 1006 (copy enclosed) he will be required to attend make-up session with the assigned instructors
                                                '(not identified as yet) and will be required to pass an oral examination ccvering the abcve procedures.
            '6.      To the best of our kncale p this is the first time this particular sit.::icn has oc:urril it.           *S
                                                          . . R:;alification Prcy    at TMI.

t 1

                                                                                         -q G. P. Miller                                           July 10, 1979
         - Should you have any further questions concerning this letter, please call me at Ext. #313.

Y 6V

  • R. W. Zechman SupervisorofT, gaining RWZ/drg
         - Enclosures cc:       M. l.. Beers        .

46 - 0 9 5 e t es t 9 e 9

                                                                                                                     ~ ~~

T se: J G.~Herbein -

                                                                                       -T-                                          -             -

Sybject:. TMI Sta-icn - Mr. J. R. Flcyd License ' 4 Snc!cscres: f -

                                                                                                                                  ~

E (1) Meeting with G. P. Mill Zechman follcw-up memo er and R. W. Zechman en 7-5-79 and R. W. m (2) v

                            .                 Meeting with G. P. Miller M. J. Ress andi en 7-7-79 (3) Meeting with G. P. Miller, J. R Zech an-(; art time) en 7-9-79               . Ficyd, T. L. Mc bach and R. W.

I. 'IN','SST!GATION On 7-2-79, I was notified by J. L. Seelinger that'J. R en two of his fcur make up hand-in ext criteria. sections, that were below the minimum Systems)*and a 64: Specifically, a.75.6 on the Category E Section -(Safety p c;Additienally, hat - the handwriting theon the Category Training Department H Secticn had (Fuel Handling raised a questien and Core as tParame o the pessibility en two of tne examir,aticns did not appear to be Mr. Floyd's.

                                                              ~
              .    ~My acticns on this' item are detailed below:

A. Initial above. discussions with J. L. Seelinger, Unit 1 Superintendent

                                                                                                                               , as noted 3.

j . .jeeting with Mr. Zechman en 7-5-79. SeeEnclosure(1). This meeting also l C. included the formal definitien

  • C of the required license =akeu .

Meeting with M. J. Acss and _7 en 7-7-79.

3. See Enclosure (2).

Meeting wit h J. R. ricyd, T. , Ieeienclosure(3). L.. Mc: bach ar.d R. W . Zecn=an (paru time) en .7-9-)g. o !' !I. . E7*LL'ATION A..- To ec ;1y with TMI Adninistrative and Training Requirs:ents . R. Flcyd ::stJ be the required notifications be made.; laced in an accelerated

             '3.                                                                                                                              .

ascertain that Licensed personnel have been an of the program especially in the area of lecture attencance and in tim of refresher training in identified weak areas. n C. V furtcer identified in cur precedures.The, cecific requiremen i D. ~ - . ---- , Senior site management cust be notified as seen begi: as practical when to identify this type of problem with licensed persennel. must take ;csitive follow action to preclude these kir.ds of problemsSite Manag m . . . . . . l . . . . . .

   -:-                                                                                                     Attachment 22 e    e.
                              , , ~ ,
                    ..:;;; :                 . ~ . .*' Stati:n - J.-R, Fi y: LicSnSe July 27,1979                                                         :                     -
                                                                                    ~^

II. _ EVALUATICN (c:ntinued) E.. ,individual Th'e performance of take-hece ex'a:inatient by any other : nan -he is not an acceptable er valid practice. q III. RECOMMehDATIONS

  • T A.

Issue an accelerated training pregra: for J. R. Ficyd t0 c::;lete. Acticn: C:::leted B. Review and c:eplete action to insure that the requalification pro:ra: recuires pr =pt upgrading of identified weak areas and,that lecture attendance meetithe intent of the program. Action: C. Rev.ise administrative pr:cedures to detail examination requirements. Action: R. W. Zech an D. Revise the ac inistrative requirements to :ut a process in place for

                                     'of site this management type.              to assure attentien and early action in situatiens                                         .

Acticn: R. W. Zechman/G. P. Miller E. invg ment in this situatien is unacceptable. He-ever, T resy en nis be]ing a persen of un;yestiened integrity and that there was any malfeasince on his part. I rec:=:end that no action be takenfor need relative actien.to him as I believe this investigaticn has ace::;11shed any F. J. R. Floyd sh uld be disciplined for his perfermance in this . atter. My recc=:endatien is that he be given ene week ti=e eff withcut pay (his other Cc::an file. y benefits to be centinued) anc na- -his letter be placed in his I base this en the fact that this investiga:icn reveals his acticas to be cutside the program limits but the implemen:atien of the progra by the Statien requires substantive improvement. G. P. Miller GPM:cak

  • 1 l

l 1 4

E::CL OS ;F.E (! ) MEETING: , G. P. Miller /R. W. Zechman 7/5/79 Subjec't:, J. R. Floyd License Exam A. . HISTORY ' [, 1977 and 1978 Dual SRO License Examinations - Mr Floyd received grades of

                 .less than 80% on four exam sections. This resulted in a requirement for classes or  reading assignments followed by completion of a hand-in test for each category involved.

These makeup exams were recently handed in and subsequent grading indicates resu of less than 80% for categories on Fuel Handling / Core Parameters, Safety and Emergency Systems and Reactor Theory.

              'Two Floyd's of the
                           . exams appear to be in handwriting of an individual other than Mr.

B. PROGRAM

                              ~

Administrative procedures required that J. R. Floyd-be removed from duty, assigned to an accelerated program and that he be re-examined in the deficient areas. .

           >1G. P. Miller writing           to take the appropriate action to investigate and resolve the hand-question.

R. W. Zechman to issue a memo to J. R. Floyd detailing the specific program for-maintaining his license and including the required notifications (attached here). R. W. Zechman to provide G. P. Miller with specific wording of Administrative procedures which required the above actions. e t I

                              - menees am em - . emme ensus ese e a y sus % . - -.
                                                                                                                    . o ..s    .s ..

METROPOLITAN ED ISON COW A N Y . s .., &c. ., j, '. L,,ges.ga _ TMI Nuclear Stati

 .                Miect          ACCELERATED TRAINING PROGRAM                                       Location Middletown, Pa.

Date July 6, 1979 Tr J. R. FLOYD

                   ~
                               .                                                                                                      l Unfortunately, you have received less than 80% on two (2) FSR Requalification                                      j Quizzes. Per Procedure 1006                  " Met-Ed Operator Requalification Program",

Section 2.2 & 2.6, you will be. relieved of your responsibilities and enter a full time accelerated training program effective July 3,1979. Your accelerated training program includes the following assig.nments, dis- . cussions, and written examination:.

                         .l . View NET video taos module #3, Unit 12 and complete questions
               -                  fl2.3-1 and #12.3-2 relating to Fuel Loading and 1/M Plots. Return completed questions to the Training Department for grading. The Training Department Instructor will detennine if answers are either Sat or Unsat..
2. Read Reactivity Balance Procedure #1103-15 and #2103-1.9 and complete reactivity balance problem enclosed. Return completed assignment to the Training Department for grading. The Training Department Instructor will detennine if solution is Sat or Unsat.
3. Meet with D. Boltz or N. Brown (at a time convenient to all con-cerned) to discuss the following areas; a) Actions required if stuck fuel assembly in transfer tube. '

(D. Boltz)

         ,                       b)    System response due to. failure of RCP anti-rotation device.

(N. Brown) c) Reasons for bypass line around CHR system cooler. (D. Boltz) t

4. Read ICS Procedures Uitit I/II in reference to the response to a loss of 4-RCPs and OTSG line up and discuss with D..Boltz.
5. Review all Radiation Monitors in both Units I & II. List each and describe the purpose of each. Submit descriptive list to D. Boltz.

Instructors will determine if Sat or Unsat.

6. Take comprehensive written examination covering items 1 through 5 above. (When convenient to all concerned.) (Passing grade - 80%)

Please note that all Unsat assignments will be returned for correction. Also, your return to duty will require us, per procedure, to sent the NRC a certifi-cation of your satisfactory rating. The completion of each item should be signed off by the instructor on the attached fonn. Should you have any questions concerning this matter, please call me at INTER-OFFICE MEMORANDUM

F . .. ..

                                                           ~ ~ ^ ~ ~~

extension !313.

                     -                                   ~                   ~
                                       ~

d</. 7 -

                               ~

R. W. Zechman .- Supervisor of Training  ;, RWZ/drg Attachment . cc: J. L. Seelinger

  • F. A. McCormick M. L. Beers D. J. Boltz N. D. Brown
     .                                 L. L. Lawyer G. P. Miller

)

t

                 .                                        -                                                                1 J. R. FLOYD                   ^                 ~ ~

ACCELERATED, TRAINING PROGRAM '

                          '   '                                                                                            l
                                                            ,            Assign.                -Instructor Subject
                              -                                          Grade     Date         .Sicnature t
1. Viewed NET Module #3, Unit 12.

and completed Questions 12.3 - 1, 2.

2. Read Reactivity- Balance Unit I/IT and completed Reactivity Balance.
3. ' Review the following with Instruct-or:

a) Stuck fuel assembly in transfer

               .                     tube.

b) System response to failed RCP anti-rotation device. c) Reason for bypass line around

  • DHR, system cooler.
4. Read Unit I/II ICS Procedure and discussed response OTSG line-up upon failure of 4-RCPs.
5. Review alt Rad Monitors in both Units I/II and submitted descrip-tive list.
6. Completed comprehensive written exam.

e 9 e . .. . - M MM- N . e- e ee 6.m _ m e me . **# I

                        ~

REACTIVITkBALtiCEPP.0CIDUP.EREVI'EFMIbNbrJ- E- = = , OP 2103-1.9 CA1.CULATIONS: A. Reactivity Balance at Power i

1. Core Age = 300 EFPD
                     ~                                                                  '

Baron = 610 PPM Rods = 6/7 8 905, 8 9 385 . Power = 50% Tave = 582' F  %

                                          ' Equilibrium Conditions for Xenon, Samarium
2. Core Age = 100 EFPD Boron = 1100 PPM .

Rods = _6/7 0 901, 8 9 38% Power = 1005 . Tave =.582'F , Xenon at Equilibrium Samarium at Equilibrium Assignment: '

1. Perfonn a reactivity balance calculation using infonnation given above.
               .. 2. Based upon the results of the calculation, describe action required, if any.
                                                                                                                                  )
                                                                 .----. --. .. _ . .. .       . . . .   . . _ - . .     . . . 1
                               -.      .    ..c.,.~..  .. ,.:15 an:                                                                             b "c....
             ~' ,~~~...

g K-r ecyd License Examinjticns * - ext ina':icns being in handwriting resemblingtG. . cense P. Miller questiens. T G. P. Mille that he*be open, frank and henest en

                                 '                                                                  this ite: anc      :: s::et: relate the C                                                                                                    ;

Were the exams - - - 5 tha they -ere on e:en tf him.mr.dwriting? after reviesing nen stated  ! Cid M.. i e he was n _:: kn:wingly c:::lete the exams f:r Mr. Ficyd? ~ . aware that he was answering Mr. r, - Flcyd :c write up sc e inf:rmatien forestions

                     -                                                        screwhich  qu:yd's          exams, _ne naFstated Jim gave him.:een recuested by Didn't                      ~

d_ L ldid not rec gnize been dish:" nest en any examinations being less than honest. n he had been given as an exam,C statec that he had net and that  ? v r been er wculd he censider 5 and inat tnere w:uld be an evaluatien

     .situatien.
all involved measures for :ne cf thei E

f - E I il5 5 E w

                                                                                                                                             +

EE p

                                                                                                            . . . .       _ _ . _ .          y 6                                                                                                            5
 -.~           ___
                                              -_-                                                                                            a
                                                                        ~ ~ -              --     ,

[

MIE 3 G: . . .. -

                                                                                                        . = -

G. 7. Miller, J. R. Ficyd, T. L. H : tach, 'R. W. Ze:r. an (;ar: 5.: ject: a time)~ ~~~~ J. R. Ficyd Li:ense Exams . L G. F. Miller c;ened the centing by inferming Mr. Ficyd of the actic[tah:: date. brief description of the' identified these items frc:Principa?ly., testings.

                                                                                                                    ~ andthe   a      meeti
sid Mr. Ficyd that I had cirec questions for him to res;:nd At sais and ; int, reac: I ;to.

Cid Jim agree tha: wi:h the license recualifica:icn program?the subject exams were these he hande - Mr. Ficyd stated these were the exams he handed in. Jimfens. sec: was Additicnally,.the informe'd thatrehe had grades cf less than the minimum exam criteria e sented to Jim in a fermal memo.quirements to c:::ence full-time training were pre-Mr. fashion.Ficyd agreed.that the program wculd be c:c;1eted by him in a timely G. P. Milh and that stated that two of the exams were in hand writin ether than Jim's [nad stated the answers were c:epleted by Jim stated that these were in C it in directly to cc=;lete the Muired cuestions."Eriting and in fac time and was abcut to go en vacaticti,that he was s::ewhat ;ress the assignments in the mcst expediticus fasnien.so he was a::e:pting to c::;lete reeded to c::;lete a nunter of cuesti:ns and that he askedJim___. saidI:o t 4h t he provic,e s: e inf0mation to him. O G. P.and en=s Millertiia: stated the prceram that this was not an acceptable methed of ec=:leting these-werk. Further, the ti5e pr: intent was that it be the assicned individual's cwn blem, was in G. P. Miller's ci:inien, caused by Mr. Ficyd's delinquency in previcusly cc ;leting these recuirements in a timely fashi:n cver a time period since last year's exa ir.ations . Jim stated that he did not see a significance in this item and that

             'he    made no atte ;; to disguise it and in fact, had directly handed the exam in without any modification.

tne werk, he had cc pleted the requirements,He felt by cc ;leting and studying i evaluate the item and that he would be informed It was of ac icn further stated Management. that there was a femal report being prepared and forwarded to c Jim ackncwledged that he r derstcod.

                                                                                  . . . . . . . . . - . . - .-                            =

Page 1,;cf'9 Place: Three Mile Island STATEMENT l I, Jchn G. HEREEIN, hereby make the fellowing vcluntary s atement c Peter E. Eaci and Edward C. Gilbert, who have identified themselves to re as investigaters with the U.S. Nuclear Regulatcry Cc=missien. Investigater Eaci has typed this statement for me. I am currently employed as the Vice President for Station 0;eratiens for PENELEC, a subsidiary of General Public Utilities (GPU). Altneugh I . assumed my current ;csition en 1 April 1982, I have been er;1cyed by GPU Cc ;anies since 1967. The investigators have exclained that - l the purpcse of their investigation is to determine the facts concerning Janes R. FLOY3's actiens en his 1979 FSR examina:icns and his subsequent certi#ica-icn c the NRC by Gary P. MILLER in a letter dated 3 August 1979. A my request,. Mr. James B. EURSS, an atterney with Isha=, Linccin and Eeale, represented ee 1 { curii.g -he s ir. tar.iew wi th the NRC investigators. l I i Scre-ice in July 1979, Gary MILLER contacced me and inferred me na- Jares FLCY2 had submittet a training assignment, part of which,a;; eared te be in the har.d-writing of another individual. I instrue:ed MILLER, who was my subercina e, c icek further at all the facts. MILLER subsecuently conductec an inquiry whic.~ determined that FLOYD ..- had ebtained handwritten answers to training assignment questiens frem a_

                                                               ~

jand that FLOYD hac 9 then saceitted these answers to the Training Decar =en- in fulfillmen cf ;ar: cf nis training assignments. After MILLER met with FLOY3, A C ir. anc recre-Atta,chment 23

Page 2.of 9 sentatives from the Training Department, MILLER determined that while FLOYD's

                ~

actions represented exceptionally poor judgement, he (MILLER) felt that there was no. deliberate attempt to deceive on the part of FLOYD. I was concerned at that time regarding FLOYD's action and the exceptionally poor judgement it repre-sented. I notified my supervisor, Bob ARNOLD, of the FLOYD incident and kept' him apprised of the status of MILLER's inquiries. Since ARNOLD was my supervisor,

          -I felt a responsibility to keep him apprised of significant events and I con-sidered the FLOYD incident sufficiently serious to warrant reporting it to
    .       Mr.' ARNOLD.

4 MILLER and I discussed the various disciplinary measures that could be taken

                                 ~

in response to FLOYD's actions. MILLER initially recomended giving FLOYD time off without pay and I agreed; however, when I discussed this with ARNOLD,' ' h'e favored reassigning FLOYD. ARNOLD's position concerning FLOYD was ultimately taken and MILLER and I agreed that it was appropriate action for FLOYD's conduct. FLOYD was subsequently reassigned from his post in operations to the Accident

         , Investigation Task Force.      It was my understanding from MILLER that FLOYD was to receive additional training to make up his' deficient areas. MILLER told me that l-         FLOYD had made up the deficient areas and that he, MILLER, was going to send a letter to the NRC.       I cannot recall exactly how it took place, but I suggested to MILLER or he decided on his own to clear the letter with our legal group.

This was to insure that the letter was all right in view of the circumstances surrounding FLOYD's deficiencies. I assumed the Legal Department had no problem with the letter since I never heard any more about it. 4e,, qun'

E I Pagd 3.of 9 As I recall, the issue concerning the certification of FLOYO to the NRC first came to light during either the NRC investigation into cheating or during the subsequent hearings held by the Special Master. W'en h I read that portion of the Partial Initial Decision which discussed the incident involving FLOYO and accused MILLER and myself of a deliberate attempt to deceive the NRC, I strongly and totally disagreed with the assessment. I have read parts of the _ report ' prepared by the Special Master and parts of the Partial Initial Decis of the Board. I wish to state that in my opinion, there was no intent on the part of MILLER to' deceive the NRC. While there appear to be inaccuracies in the 3 August 1979 letter which HILLER sent to the NRC, I believe tI1at these inaccuracies probably o'ccurred due to administrative oversights or mistakes . I would also say that I never did anything or intended to do anything that might deceive the NRC concerning the certification of FLOYD. Mr. Bact showed me a copy of a handwritten memo from MILLER to me dated 3 I

       ~
         " July 1979 I cannot recall seeing this at the time; however, I do recall discussing the situation and the issues with MILLER.         Even though the hand-i written note appears to be addressed to me, I didn't always have time to read.

all my mail at that time and I don't recall seeing or reading this document at the time. I cannot recall the specifics of the information contained in MILLER's handwritten memo. I will say that MILLER and I both considered the incident to be_ serious and to represent exceptionally poor judgement on FLOYD's I part. cannot recall whether or not we discussed the significance of the fact that ' FLOYD's name on his answer sheet was printed as opposed to being signed. 4

Page 4 of 9 -- ^ - ~ ' MILLER and I did discuss the need to retain FLOYD's license. We needed an adequate number of licensed personnel in the control room and were not sure of the future attrition rate; we therefore felt it would be wise to give FLOYD the opportunity to properly correct his deficiencies so that we would keep him in a licensed capacity. It seemed sensible to have as many properly licensed individuals as possible. Although FLOYD displayed very poor _ judgement, he was

       -qualified by way of training, background and experience and we felt it was pru-dent to maintain FLOYD in a licensed capacity if he properly corrected his deficiencies. .Mr. Baci asked me if I had any idea what the coment by MILLER at the bottom of the note was intended to mean. The comment reads:          " If the exam which is not in proper handscript develops to a problem I will have an additional problem and will get to you".      It is my interpretation that the problem which MILLER was referring to was that of extremely poor judgement on the part of FLOYD.          ?

Regarding the characterization of FLOYD's actions, I told the' investigators that

                                                                                  ~
                                                                                          ~

I consider FLOYD's conduct to represent exceptionally poor judgement rather than a deliberate attempt to deceive and falsify. This is based on MILLER's

      , determination that it was not a deliberate attempt to deceive.

In my opinion t

a. deliberate attempt to deceive would be cheating. Cheating is a very subjective L- tem. I placed a great deal of confidence in' MILLER's determination. MILLER didn't surface a deliberate attempt to deceive and felt that FLOYD's actions represented exceptionally poor judgement. I accepted his assessment of the O situation.

i Mr.-Baci next showed me a copy ~of a memorandum dated 10 July-1979,' from R.: W.

l l

         "Pagepof9 1
                  .                                                                                                                                 .j ZECMMAN, who was Superviser of Training at that time.

The memcrancum .was to G. P, - M'LLER and re; resented a summary of the events associated with FLOYC's ;artici-pa[ien'inthe 1977/1978 requalification program. I do not recall having seen the mem:randum at that time. I just recall having seen it as' a result of the inquiry conducted by lir. SPEAKER. Mr. Baci next showed me a copy of a memcrandum to FLOYD fr:m ZECHMAN dated 11 July 1979. This memorandum requests that FLOYD rede his FSR assignment for Categcry A. I:was not aware of c:mmunications among Miller, FLOYD and

                          ~
                                                                                                                                              ~

IECMMAN regarding FLOYD's deficiencies and the corrective action to be taken.

            ~

It makes sense that such c:=munications w:uld have occurred. This would have

                                                         ~
      ' insured that FLOYD understood the program requirements and was required to ccrrect his deficier.: areas.           I was not involved in tne details of FLOYO's                                               2 training nor was I a. ware cf the specific recuirements which were imposed upon him by the Training Lepartment.
      .}r.Eacir.extsnewedmeaecpyofamemorandum, unsigned,fromMILLER't: ne dated 27 July 1979. I told the investigat:rs that I may have seen that memo-randum at the time cf the incident; however, I am net sure.                                       I,do recall having seen -

it at:the time of the investigation inte the cheating y anc - tuum,. This memorandum represented MILLER's writeup c ncerning his inquiries

     .into_the FLOYD incident. MILLER and I were in daily c:ntact regarding a numser                                                                  I cf things, including this incident. I cannet recal'1 whether there was ever. any Cm                                         l 1

ceeting or discussien which was devoted exclusively to the FLOYJ/,,,,,lincicent.

                                                                                                                                            ~

I 'cannet recall the number of areas in which FLOYD was deficient, what they

s. . . . _ ..
                             .                                                                                                                        I

Page 6'of 9. "" 4 were, cr'whether they everlapped. Al1 I can recall is tha: there were ciffer. ences in handwriting and that FLOYD turned in sc eene else's werk. I tcld ne investigators that I certainly feel tha: FLOYD ceuld not be assigned a grace based on the work he submitted that was ccepleted by somecne else. I den't know whether the accelerated training program in which FLOYD participated included all the deficient areas. At the time, I assumed that it did. In accordance with the procedures, I assumed at the time that he would have

                 ~been retested in all deficient areas to insure that he was qualified.
                                                   ~'
       *                         $1             -

Concerning. involvement in this incident, I was aware that MILLER had ~ T sccken te . ,,,during h.is incuiry.

                                    -                          I was ne invclved in the decision not
c discipline'.asms W

! I was.nex shown a ccpy of a meme from ZECHMAN to FLOYD dated 6 July '979.

               . ine ce%:, whien cescribes the acceleratec training pregram in which Mr. FLCYD
                .was tc ;articipate, was net seen by me at that tfee.

This type cf infermatien wcu'c nc: ncr= ally have been ferwarded to me.

I .as next shown a copy of a nete from MILLER to Ernie ELAXE dated 27 July 1979.

d$. ' This note transmitted a draft copy of the certifica icn ie::er, aise da:ec 27 July

. -1979, to Mr. BLAXE for review. I don't recall having seen this draft ie
:er nor de I recall having seen the note te Mr. BLAKE.

9 I assume that MILLER fcrwarded the craft letter to SLAKE for his legal review as we had ciscussec earlier. I cannct. explain MILLER's ccament in the neie'tc SLAKE which states: "I*cnly'~~ ~~

             . _           .   .      . . ~                            . .  . - -              - ...- -

t.

l i + . Page 7 of 9 reference two sections in the make-up. He actually studied 3 sections due to the handwriting problem." I also cannot explain why the draft letter only. refers to two weak areas rather than three. Although I don't recall having seen either the 27 July ~ note or the 27 July draft letter, I note that I am on the distri-. bution for both and it is possible that I did see them at that time. The investigators next showe,d me a copy of a letter to Paul COLLINS from

  • - MILLER. dated 3 August 1979. While I note that I am again on the distribution, I don't recall seeing this memorandum before it went out. I don't think I would have attached any particular significance to the specifics of this memo-randum. I was generally familiar with the circumstances surrounding the FLOYD
'              incident, however, I was not conversant with all the details and the score of 4

89.1% listed for FLOYD on Category A would not have held any special meaning foFL me. I can only soeculate as to who may have filled in the blanks in the above

             ~ m'entioned draft letter or placed the scores on the final letter. I cannot say where those scores came from. The investigators asked me to read the 3 August After letter and to' provide them with my understanding of its meaning.

reading the letter, I told the' investigators that I would interp. ret the letter as stating that FLOYD had two deficient areas which had been corrected. In summary, I told the investigators that there may have been weaknesses in the training program and administrative procedures. I also told them that I now know the 89.1% score referenced in the letter was not correct. Copies of the I.do.not i. letter may not have been read by alluthose on the distribution list. . . . . _ .

                                                                ~~
                   .p,g,g.df9                                          '~

feel there was ever any attempt to deceive the NRC by either MILLER or myse . I strergly disagree with this accusatien in the Partial Initial Decisien, I fe,] that a mistake was made regarding the 89.1% secre which was referenced in th letter submitted _ to the NRC but there was no attempt te deceive or be dish with the'NRC. While it was generally known that FLOYD had been reassigned to the Accident

                 = Investigation Group, I don't feel it was necessary for everyone to know the specific reascns.
        .                                            The professionals in the' organization would ar/d                   ~~

prcbably did understand that FLOYD's transfer represented a negative career move. I beit. eve I explained to FLOYD why he was being reassigned at the time, a I cannot swear to this. I believe we ciscussed his reassignment one day while : was standing en the back-perch of my trailer. The investigaters. advised me that

              .FLdYD hac not considered his reassignment c be an adverse acticn un testified before the Special Master in 1981. Considering the c;tions cf a work fuspensien er a reassignment, in my opinien the reassignmen; was a much mere                                    '
             -severe ;enalty.

The long term results cf being taken cut cf an in-line mana;e-ment pcsition would be potentially more damaging to FLOYD's career than a suspen-

            - sien from work.

I cannot speak for how FLOYD may have construed the relative severity of the two disciplinary / administrative optiens; hewever, I feel that the action taken in FLOYD's case was adequate. Based upen MILLER's findings and his statenent that there was no dishonesty on the cart of' % . I feit a: the

          - time that the admonishmen given te                           was sufficient.                .
   .s
                                                                                                          - ..,m..-w.-

F Page 9'of 9 The investigators asked me if my reassignment to my current position was regarde by me as being adverse in nature. I told them that I did not regard it as an adverse action and that press releases prepared at the time of my reassignment

 .        specifically said that it was not an adverse action. The investigators asked me whether the recent reassignment of MILLER represented an adverse action and I told them that I feel MILLER's reass!gnment was lateral in nature.

I have read the foregoing statement consisting of 9 typed pages. .I have made and initialed any. necessary corrections and have _ signed my name in ink in the

   ,      margin of each page.

I declare under~ penalty of perjury that the foregoing statement is true and correct to the best of my present recollection.

  • Signed on Dec. 27, 1982 at 1615 (date) (time)

SIGNATURE: /s/

        .                                 JOHN G. HERBEIN WITNESS:                 /s/

NAME: Maryann CORNELIUS i _ _ . . _ . - - ^'

s -- i Page l'of 6 - t Place: Three Mile Island Date: Decem:er 1, 1982 SfATEMENT Eac'i, who has identified himself to me as an Investiga cr Nuclear Regulatory Cermission. for me. Investigator Baci has typed this statement This statement summarizes the informatien which I provided to Investigator Baci durin'g an. interview held in my office at Three Mile Isiand on 9 Novembe 1982. A.t the time of the incident involving James FLOYD and his submission cf

          ' ' makeup training exams in July 1979, I was serving as Vice Presiden of the GPU Service. Corp. and was functionally assigned as-head of TMI-2 re cperations.

While this was a transition period, organization wise, as a practical ~ catter,' Gary MILLER reported directly to Jchn HEREEIN and he in turn reported directly to me. To the best of =y recollectien, the issue of FLOYD's FSR exams first came , a :ent;:n during tne first er second week of July 1979. I scoke with hERBEIN -

          - either face-to-face       Ca- er en the phone - and he told me that FLOYD had g:::en assistance fr:m                   Y
              ,                        "M in c:=pleting make-up assignrents wnich FLCYD was -

re:;uired :: do :: remain current in the retraining pr gram. I did not see the exams at that time and saw them for the first time las: week when they were included as an attachment t: the SPEAKER re;:rt. The SPEAXER re: Ort documents the resuits of an investigation into the FLOYD issue which was C:mpany f initiated and conducted by an outside consultant. As I recall, HERSEIN and I dis:ussed the FLOYD problem 3 or 4 times. The first time, he notified me of p .=: wna: had happened and said he was checking it cut.

                                                                                                                .L The secondL ime; HEREEIN r ~          -~

Attachment 24

Fage 2 cf 6 ~ =- : r Ca . re:erted'that MILLER 0 had spcken to beth.,_,, and FLOYD, een de-that it had termined that while 9 provided the answers to FLOY0, he did net knew what it was f:r. This was acce:ted by MILLER and not challenged by HEREEIN . FLOY3's ace:unt was thet he only thcught it was necessary to be familiar w . material and that it did net count how he did He it. reportedly tele MILLER that he hadn't tried to disguise the fact that he submitted so meone else's work. HEREEIN said MILLER very much disagreed with FLOYD's judgemen but felt he was being truthful. n this matter I don't recall whether it was during the same conversation uent one,' or a subs but HEREEIN indicated that he and MILLER felt a week's u e an suspensio adecuate resper.se to FLOYO's conduct. I disagreed. I felt that FLOYO hac exercised peer judgement and that there had been a prior history of suc examples cf peer managerial or superviscry judgement. I also felt that FLOYO shcu'd =c remc.4a f.:m his pcsitien hnd teid HET.hEIN and 1:

          ..the matter.                                                           ILLER to cecer. sider HEREEIN4  . subsequently came back and propcsed a two                              n; week su he war.ted to keep FLOYD in his pcsition because he felt-FLOY3                         y kn *'e:;-

was v able c:ncerning the plant and precedures. , We discussed the matter furtner but my position remained unchanged and I still felt that FLOYO e. I be reassig wculd add, however, that I saw ne reason to discualify him as a seni-r reac Or cperator since we might well have had need for knowledgable, licensed the c: ming months. FLOYD wasn't reassigned on the basis cf an isolated incident , but rather for a dem:nstrar.d history of peor judgement . pernaps if the exam incicent had been the only ene, I T.ight have agreed that a one or t wo week ~ i

                                        . . . . .       ,'                                                                         .i
                                                                                          -..n.                         m._   .,+

e Page .3 of 6 [e m

                                                                            ., 3 suspension.would have $een appropriat'e; but it was only the last su in a work history centaining other examples of poor judgement and I felt that reh.oving him was the proper action to take.

t- ItwismyunderstandingatthetimethatFLOYOwouldbegivenaletterof t reprimand and this would have been appropriate for what I perceived as a failure i

                 -to support the training program; however, I don't believe FLOYD's reassignment i:                was ever documented as resulting from his record of poor perfor=ance as a manager.
         .        I would normally be involved in, or at least aware of, any disciplinary action involving a supervisor or any exempt personnel.                    I don't always become aware of such action ahead cf time when it involves hourly people.                     It is our practice to discuss disciplinary action involving supervisory or exempt personnel among senior management.

This ensures consistancy and fairness, both ~to the indi-

       .      -viduti and the company.

( - i I never discussed the FLOYD issue directly with MILLER; all of my conversations

              .cn -he subject were with Jack HERSEIN.
                                                                                                 .                         ~

h - To the test of my knowledge, FLOYD never again worked in an operational capacity

             - after 2 July 1979. I believe it was about the second week in August 1979 that the paperwork was issued which formally effected his reassignment to the Accident Investication Group. With respect ton              Ch
                       ,-                                          w
                                                                        . I was prepared to accept HERBEIN's t

and M!LLER's-judgement concerning his involvement in the exam issue. l '~

Page'4 of 6 In 1973/74, I had been involved in the development of the requalification program for operators. By mid-1979 however, I had been away from it for several. years and wasn't familiar with the mechanics of the program, nor was I familiar with the individual training history of FLOYD. Prior to SPEAKER's report, I had thought that the 3 August 1979 letter was a certification prior

   ~' to the expiration of FLOYD's license. I now know that the letter actually says that FLOYO had problems with his requalification program, that he wa~ put through and passed an accelerated requalification program and that he             .

successfully completed the program. Until a week ago, I did not realize what specific requirement the letter was fulfilling. I did not see the letter in draft or final form before it went out and did not read it until about a week ago. I saw it during the SPEAKER investigation, but not in.such a way that I could read it. As a matter of fact, I had no knowledge that there was even a need for such a letter to go out.

   . I told Mr. Baci that HERBEIN'.s reassignment to PENNELEC was, in my opinion, one of a lateral nature and not a demotion. There was no element of dissatis-faction with HERBEIN's performance which resulted in his reassignment. There was recognition from the Company's standpoint, however, that we had a potential for future events creating a situation in which the Company was handicapped in its ability to deal with the situation and where others with whom we have to interact could be handicapped because of the focus on Jack HERBEIN in past acci--             ,

i dent investigations and reviews. - There was also -recognition that from'HERBEIN s' i

                                                                                              ~

l 1 _ _ - . . - - _ - . - --- J' ~--

Page'5.of 6: ,, _ .~ -
                                                            ~ ' -- y 4
             '     viewpoint, his opportunities for advancement within nuclear activitie
                  ~ ad.versely affected by the above.

I have strong confidence that HERBEIN is a capable and dedicated invididual who can contribute much . We to the C

      '           needed his centributiof in large fossil plant operations and felt that th chances of optimizing both the Company's and HERBEIN's interes realized by his' reassignment.~
                - Although MILLER's experience base is not as great as HERBEIN's, th
        .        situation basically holds true for him.

MILLER is a good, competent, journey- . man manager who services the Company wishes to retain. As with HERBEIN, the events at the time of. an'd subsequent to the accident have impacted' upon' h utilizstion by the Company.

          '                                     Also as with HERBEIN, the chances of optimizing both the interests of both the Company and the individual were best ac                                '

by his. reassignment. For the record however, there were certain aspects of

          ~

operations at TMI for which Gary MILLER.was responsible with which we w dissatisfied. i

                                . These involved conditions which existed before the accident, but which were identified subsequently by the various investigations and rev                         .

i These included such things as control of operations on shift, maintenanc l; ! activities and diligence in ensuring training activities were adequately carried out. ! The above were considered and entered into the decisio MILLER was reassigned within the nuclear corporation. MILLER's scope of responsi-

          . bility in his position as head of start-up was clearly much His                .

less sub-sequent move to MET-Ed however, represented a lateral reassignment and w a par with the position he held as head of start! up.~~ ~ ~ ~ " ' l \ . l l k

                                                                                                                                                  -t l

l Page 6*of 6 MICLER was told of the above, both orally and in a letter dated 19 August-1982. He was also told that the Company regarded his oversignt of the FLOYO recertification to be lacking and that it was dissatisfied with the letter of

         .3 August'1979 which he sent to the NRC.

I told Mr. Baci that I felt that the' 3 August letter was inaccurate concerning both the 89.1% exam score and the fact that only two instead of three weak areas are mentioned. While I agree that the letter is inaccurate. I don't believe MILLER intentionally included false or misleading information to knowingly deceive the NRC.

        .I have read the foregoing statement consisting of 6 typed pages. I have made and intialed any necessary corrections and have signed my 'nane in ink in the margin of each page. I swear that the foregoing statement is true and correct. Signed on                             at                                .

(date) (time)

SIGNATURE:

ROBERT C. ARNOLD Subscribed and sworn to before me this day of , 198_ , a~t . INVESTIGATOR: PETER E. BACI WITNESS: NAME: e . 4

                       ,.e-    ,,~         .%-,---,-,-,,py2,----.,-r--,          ,vy-----yv, ,-w fyryw.      n---g-        ,-c.           y   --

s--

n. - 2.3 _

GFU Nuclear----+ == : _ _ _ - = h U N b N kh I. h M 9 M b ~5 s any, ew Je sey 07054 201 263-6500 TELEX 136-482 Writer's Direct Dial Numcer: August 19, 1982 Mr. G. P. Miller

        .R. D. 12 - Box 425 Fairview Road Columbia, Pennsylvania 17512

Dear Gary:

                                                                ~

Subject:

Transfer to Operating Company This letter is to document discussions that have been ongoing between you and Company i manage:nent since about mid-1981. During the recent ASLB hearing on the NRC licensing examination. cheating incident and related investigations, it became clear that your August 3,1979, letter to the NRC l certifying 'the status of Mr. VV in the Company's training program was incorrect as l to'the basis for the certification. Your letter was for the purpose of supporting the renewal of Mr. VV's NRC Senior Reactor Operator license. I met with you and told you of the Company's judgment that your performance was unsatisfactory in providing l that certification to the NRC. The Company believes that given your knowledge of 3 the circumstances at that time, you should have been more diligent in providing assurances to yourself as to the accuracy of the infomation in the certification. I have also informed you that the Company will be conducting a full investigation of all of the circumstances under which that certification was provided. The Com-party understands that you believe the steps you took at the time of the letter to provide assurance of the accuracy of the contents were appropriate and reasonable. The Company will review its judgment in this matter upon completion of its investi-gation. The Company investigation.will be carried out and any appropriate action taken regardless of whether or not the NRC staff conducts a similar investigation as recomended by the ASLB (see paragraph 2312 of the ASLB Partial Initial Decis-ion). During discussions with you, it has been recognized that because of your respori-bilities prior to and at the time of the THI-II accident, reviews of the various issues raised as to the Company's performance in that time period frequently in-

     -volved specific discussion of your performance and role in the conduct of TMI activities. As described to you, while the Company has new insights into activi-ties at TMI as a result of the accident that has caused us to be critical of the way in which some of the activities were supervised and administered, we also recognized many strengths in the management of DtI activities for which much of the credit goes to you.                                     --

GPU Nuclear is a part of the General Public Utilities Syster.: Attachment 25

1 Mr.G.P. hiller ~ Page 2-August 19, 1982 L In reviewing the total situation, the Company had concluded that it is unlikely that we directwill responsibility consider you forfor assignment to senior positions in GPUNC where you would have plant operations. In view of this, we have discussed with j you over the _last several months our interest in assigning you to one of the GPU operating companies where your skills and talents are needed and your own professional interests will also be served. l transfer for the first half of 1983.We had tentatively discussed the timing of such a j I Believe the constraint on your utilization , recommended by the TMI-Unit I ASLB Las set fortH in paragraph 2319 of their Partial Initial Decision dated July 27,1982) i assignment during the restart of Unit 1.makes it impractical to continue your present i We will Be, therefore, transferring you to either Metropolitan Edison Company cr. Pennsylvania Electric Company, reporting at the Vice President level, effective October 1,1982. We will be finaltzing the position with you during the next few weeks. Very truly yours, . l

                                                               . C. old President slm cc: J. F. Wilson, Esq.
       . T. L. Myers R; F. Wilson t

I i I

                         .            : 1.    . ::. '.+ .
                                                                                                     , , . .e . m e -          ,      ,f %-  ** - '" ~
                     --METROPOt.lTAN= EDISON COMPXNY.1,'s4,#,,,;i o,;ai~,;g-n.

u snJ 5; ul,', ~ '- ^ Subject SUPERVISOR OF OPERATIONS - ACTING FOR' UNIT II 1.oestion TMI Nuclear Station

                                                                                           -                                      Middletcwn, Pa.170!

Date 17 August 1979

To DEPARTMENT HEADS SUPERINTENDENTS -

i . Effective August 20, 1979, J. J. Chwa'styk will assume the daties of Supervisor of Operations. - Acting fon Unit II. In this cuicity Joe will be responsible for day to. day supervision and tech'ical

                 .-               direction of the Unit II Operations Department. J. J. Chuastyk i

j wil.1 ieport to J. Logan in the performance of these duties. Site (Unit I *and II) operations departmdnt administrative policy i such as union matters.and personnel changes will be under the cognizance of M. J. Ross, Supervisor of Operations - Unit I, who will be the senior site operations supervisor.

                                                                        ,                      v f}
                                                       '           ~                              G. P. MILLER
  • l Station Manage
                               ,GPM:JLS:amt cc:     J. J. Colitz
  • J. G. Herbein L. L. Lawyer ".

G. P. Miller l-4 Q .b QW v%A, LN (h 4g Nq d % e4 %4., DM l . u2Cs A h LT-%.nt,-wet. . e \ . r . 1 INTER-OFFICE MEMORANDUM Attachment 26 t j

l. .
           ,,,.                               *          ~
                                                                                                  ^
                                                                                                       , NRC 79-59
                                                                  ;__ y _ -          u :: ::= --                                        _.

Middfatown. Pennsyivania 17o57 717 944-4o41

                                                                            %e Mr. Paul F. Collins U.S. Nuclear Regulatory Conmission                                      15 November 79 Office of Nuclear Reactor Regulation Wa'shington, D.C. 20555

Dear Mr. Collins:

                    ~

Pleas's License. consider this letter as my application for renewal of my Senior Operato information is given:In accordance with Section 55.33 of Regulation 10CFR55, t

1. Name: James R. Floyd -

Address: 10 Floyd Drive . Middletown, PA 17057

2. Citizenship: Citizen of the U.S.A. by birth.

3. Present Classification Supervisor Station Operations - Nuclear, Metropolitan Edison Company, Three Mile Island Nuclear Station, Unit II, Middletown. PA.

                        '4. , License Serial Number: Senior Operator, Serial Number SOP 2051-3.
5. Experience:

plant operations in accordance with my license duties.During the te

6. Approximate Number of Operating Hours: 100 Hours. .

7. Requalification satisfactorily com Program: Durin'g the effective tenn of my license I have

                             'ification Program.pleted the Metropolitan Edison Company Operator Requal-
8. Medical Examination results sent under separate cover.

Sincerely you s,

                                                          ~

[. JRF/clh Enclosure , l Attachment 27 Meropoman Ed on Comcany a a Memoer of me General Putic Wirres System

         .                                                                                                                                   l
                 .                 .l              -
                                                          .                                  ~

LICENSEE CERTIFICATION DATE: November 15. 1979 This is to certify that James R.- Floyd has discharged his license responsibilities in a competent and safe manner during his current license period. n

             ~

( , ger Su port Services t 1

                                         ?

i

           ..o     .,                                   -

j'"'***. UsesTED sTATss E.'[iii.N U W ' '

                             .             NUCLEAR REGULATOR COMMIS$10N                ' ' - ~~'        " ' " "

was oroa.o.c. names - ~ ~ -

                                                                                                                     ~
               %.....#                                               DEC  9 B77 Occkat No. 50-289 Metropolitan Edison Company                                                                              :

Three Mile Island Nuclear Plant '1 ATTN: Mr. J. G. Harbain, Station Superintandant , P. O. Box 480 I Middletown, Pennsylvanta 17057  ! 1 Gentlemen:  !

         ~                                                           .                                                        l The purpose of this letter is to provide guidance regarding the information required on operator and senior operator license renewal applications relating to participation in the operator requalification program. We have found that vagueness or incompleteness -in-these applications has, at-times, caused delay in their processing.            '

Section 55.33(a)(4) of 10 CFR Part 55 requires that the applicant provide "A statement that -during the effective term of his current license the

               ' applicant has satisfactorily completed the requalification program for the facility for which operator or senior operator license renewal is sought."
                " Satisfactorily completed" means that the licensee has been administered                                    '

the annual examinations and has participated in the lecture series, as required, that he has participated in the on-the-job training; has been evaluated by supervision regarding his performance during abnormal and emergency situations; and has participated in all the other portions of the approved requalification program. Section 55.JJ(a)(4) was worded in this manner to preclude the need for the applicant to furnish the details of his participation in the program in his application for 1icense renewal, since it was expected that he

       ,       would be participating in the program as subnitted by the facility 1icensee and approved by the NRC.

Attachment 28 l l l

                  -~
                                 .                                  , --.          .                      n In order to avoid this office having .to request additional information in
conjunction with renewal applications, we request that individuals who have l- coupleted all portions of the program use the term " satisfactorily completed -

the requalTlication program," in the renewal applications. Terms such as

                         " actively engaged,"
  • engaged in," " participating-in," should not be used to indicate complete participation.

I If the applicant has not completed all portions of the program, those portions not completed should be enumerated in the application for license renewal. In addition, facility management should indicate what action has been taken, or is to be taken, to ccupensate for the nonparticipation.- We recognize that exigencies may arise that cause an operator to miss participation in some i aspect (s) of the program and r.hese will not necessarily bar renewal of the , ( license without reexamination. However, all such events must be identified s

           .-           and justified.                                                 .

Based on our evaluation of this information, and the other information required -- - by Section SS.33(a), we will be better able to make the determination to >- ' renew the license with or without reexamination. - - Sincerely, _

                                                                                              / y fl.a,
                                                                                                              '      n Paul F. Collins, Chief l:                                                                                  Operator Licensing Branch

! Division of. Project Management l- . i l l l

                                                                                                                         '"~

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