ML20129J622

Discusses IE Insp During Aug-Sept 1983 & on 831018-840509 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty.Operator Training & Recertification Program Not in Compliance W/Fsar Commitments

ML20129J622
Person / Time
Site:	Grand Gulf
Issue date:	06/03/1985
From:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Cavanaugh W MISSISSIPPI POWER & LIGHT CO.
Shared Package
ML20126G602	List: ML20126G599 ML20129J622
References
EA-84-023, EA-84-23, NUDOCS 8506100141
Download: ML20129J622 (4)

Text

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'h ~ NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 4*****/ JUN 0 319$5 Docket No. 50-416 LEA 84 - Mississippi Power and Light Company

-ATTN: William'Cavanaugh, III President:

P. O. Box-1640

. Jackson, MS -39205-Gentlemen:

Discrepancies in documentation of operator training were identified during a

.special training assessment conducted in February 1983 and a special safety inspection conducted by Region II during August and September 1983. The Region II staff evaluated these inspections and concluded-that these discrepan-cies were not limited to documentation errors. At Region II's request, the

.0ffice of Investigations conducted investigations (Office of Investigations Report No. 2-83-037, March 5, 1984 and Report No. 2-84-005, July 13, 1984) during the period October 18, 1983 through May 9, 1984. The investigation included a-review of the circumstances surrounding the submittal of false and undocumented infonnation on operator license applications. As a result of these inspections and the investigation efforts, significant failures to comply with NRC regulatory requirements were identified.

The inspection and investigation findings demonstrate that the program for

_~ training Reactor Operators (R0s) and Senior Reactor Operators (SR0s) at the Grand

, Gulf facility had not been established in accordance with commitments made in the Final Safety Analysis Report (FSAR) and as required by NRC regulations. The investi-gation also determined that 46 applications for SR0 and R0 licenses, containing certification by Mississippi Power and Light Company (MP&L) that each individual

' applicant had completed required training or courses of instruction, contained material false statements. The information provided was false in that the-amount of training actually completed was less than that described in the

-operator-license applications. The information was material because had the complete and accurate information been known to the NRC, the applicants would not have been permitted to participate in the NRC licensing examination and, consequently, would not have received licenses. In addition, even after MP&L officials became aware in 1982 that false information had been submitted, they failed to notify the NRC or to correct the submittals. This constitutes a separate material false statement by omission.

CERTIFIED MAIL RETURN RECEIPT REQUESTED B506100141 e50603 PDR ADOCK 05000416 9 PDR-

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i Mississippi Power and Light Company n ,

Item 1 in the Notice of Violation and Proposed Imposition of Civil Penalties

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addresses the training program inadequacies. In this case, you had'not established 4' an' effective -program for assuring commitments made in the FSAR were implemented in the operator license trai~ning program. Specifically, MP&L delegated control of the training program to a contractor and did not exercise adequate oversight

-of training activities. This contributed directly to your failure to meet your commitment for. comprehensive and adequate training of operator license candidates.

Items 2 and 3 of the enclos'ed Notice concern the material false statements.

The NRC requires extraordinary care be taken to assure information provided in applications is complete and accurate. MP&L did not adequately verify the

information prior to its submittal to the NRC, vigorously implement a program ,

to. identify and document the false information after being informed of its existence by a licensee employee, or inform the NRC that false information had been submitted once it became aware that the submittals contained false information.

Item 4 of the Notice addresses a procedural violation involving failure of

_a mechanical maintenance supervisor to correctly complete a practical factors b , book for a mechanic. The cause of this. violation was that inadequate instructions on how to accomplish the tasks were provided to supervisors responsible for i following the trocedures.

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. To emphasize the need for MP&L to assure that the operator training program meets the commitments stated in the FSAR, and that certifications in operator license l applications are ar. curate and complete, I have been authorized, after consulta- i tion with the Connission, to issue the enclosed Notice of Violation and Proposed Imposition 'of Chil Penalties in the amount of Five Hundred Thousand Dollars

, ($500,000) for five_of the violations described in the enclosed Notice. Four 4 of the violations have been categorized at Severity Level II in accordance with 1; the NRC Enforcement Policy, 10 CFR Part 2, Appendix C. These were serious violations and positive corrective actions were not taken until the NRC became 1: involved. The violations occurred-in careless disregard for NRC requirements.

=The fifth violation has been characterized as a Severity Level I violation

.because it was a knowing failure to correct previously submitted false information.

;The base civil penalty for a Severity Level II violation was $64,000 at the time these violations occurred. The-base civil penalty for a Severity Level I violation was $80,000 at the time these violations occurred. In considering the appropriate amount for the penalty to be proposed for the items in the Notice, several factors were taken into consideration

1) the duration of the violations was lengthy; 2) there were multiple examples of the violations; and 3) even after the NRC's training assessment identified training program deficiencies in January 1983, the licensee failed.to correct them as evidenced by the fact that four operator candidates were rushed through qualification card sign-offs in September 1983 in a manner which could not have determined if the candidates were, in fact, adequately conversant with the material. 'Accordingly, I have determined that each of the three submittals of false infonnation, and the false statement by

[ omission,-is a separate violation and should be assessed a separate civil penalty

of $100,000. The violation involving the training program inadequacies also warrants the full penalty permitted for a single violation of $100,000. The resultant total penalty is $500,000. The violation involving the mechanical k

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Mississippi Power and Light Company maintenance practical factors books has been categorized as a Severity Level IV violation and no civil penalty has been proposed.

Management meetings to discuss these matters were held in the Region II Office on September 23, October 12, November 11, and November 18, 1983. As a result of these meetings, MP&L committed to conduct a review of the previous training of all licensed operators, Shift Technical Advisors, and on-shift Operations Advisors. Certain operators were removed from licensed duties until they could be retrained and retested. These commitments were confirmed by letter dated December 5, 1983.

As a result of these commitments, MP&L examined each operator on each of 68 systems listed on the Grand Gulf licensed operator qualification card. These examinations were monitored by MP&L management, representatives of two other utilities, the Nuclear Steam Supply System vendor, and the NRC. At the completion of this examination process, the records of the operators were reviewed by a Grand Gulf recertification board consisting of plant management. The board examined operator training records, the results of the examinations, and conducted additional oral examinations as necessary. Out of twenty-seven individuals examined by the board, one was found to be unqualified and three needed training. Region II conducted licensed operator recertification and walk through examinations in February 1984 after each licensed operator had undergone the MP&L examinations. The results of the independent NRC recertification examination were that twenty-three of the twenty-six operators passed. The three who failed have been removed from licensed duties. These actions provide reasonable assurance that operators presently at the controls of the facility have met NRC requirements for training.

You are required to respond to the enclosed Notice and you should follow the instructions specified therein when preparing your response. Your response should specifically address your plans to ensure that in addition to the specific actions described above, the following programmatic actions are taken: 1) the establishment of an effective management program for the timely detection and correction of problems which could lead to violations of regulatory requirements;

2) the assurance that all submittals to the NRC, particularly in operator license applications, are complete, accurate, and contain full disclosure of required information; and 3) assurance that all personnel, licensee or contractor, are aware of the extent of their authority and responsibility for matters related to safe operation of the Grand Gulf facility. The NRC will closely monitor MP&L's corrective actions and failure to carry them out may lead to further enforcement action.

t As noted above, numerous inspections involving these matters have been conducted by the NRC and also several management meetings and Enforcement Conferences have been held which concerned these issues. Written commitments have been made and

. actions taken by MP&L as a result of these meetings and inspection reports. In your response to the enclosed Notice of Violation and Proposed Imposition of Civil Penalties, appropriate reference to these previous submittals (by page or paragraph number as appropriate) is acceptable.

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I Mississippi Power and Light Company In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," Part 2, "

r Title 10, Code of Federal Regulations, a copy of this letter and the enclosure will be placed in the NRC's Public Document Room.

The responses directed by this letter and accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, ames M. Taylor sf irector Office of Inspection and Enforcement

Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalties cc w/ encl:

J. E. Cross, Plant Manager Ralph T. Lally, Manager of Quality Middle South Utilities. Inc.

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