ML20132E480
| ML20132E480 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/11/1984 |
| From: | Mark Resner NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | |
| Shared Package | |
| ML20132E314 | List:
|
| References | |
| FOIA-85-419 NUDOCS 8510010096 | |
| Download: ML20132E480 (17) | |
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U.s. NUCLE AR nEGULATonY CoMMi$sloN
- - Of fice et lesseector arsc Aw:. tor o........,,'........ Sept. 25 a:d Oct. 11, 19g l Recort of' Interview James P. O'Reilly, Regional Administrator, Region !!, was interviewed regarding the discrepancies in the Reactnr Operator Training Program at Grand Gulf Nuclear Station (GGNS) as they related to'the restart of GGNS on September 25, 1933. He also was interviewed with respect to a September 23, 1953, meeting between Region 11 and Mississippi Power and Light officials at Region 11. He provided the following information:
O'Reilly proffered the facts as stated in his August 29, 1984, proposed response to Congressman Markey concerning this matter (Exhibit 1).
He also provided infomation beyond what is stated in ha reposed response.
Specifically, he did not recall any discussions with or any other Region 11 staff o'n September 23, 1983, concerning the letter which McGaugby brought to the meeting that. day.
Attachment:
Exhibit 1 ...
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ENCLOSURE ,
. STAFF RESPONSES TO QUISTIONS (QUESTION. 2 ANSVERED FIRST TO FACILITATE UNDERSTANDING)
QUESTION: 2: DID REGION II 0FFICIALS AUTHORIZE A RETURN TO OPERATIONS AND ALLOW CONTINUED OPERATION SUBSEQUENT TO LEARNING THAT THE
- FICATIONS OF GRAND GULF REACTOR OPERATORS VERE PROBABLY
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AND THE OPERATORS POTENTI ALLY UNQUALIFIED?
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ANSWER:
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THE DECISION.TO ALLOW GRAND GULF TO OPERATE BETWEEN SEPTEMBER 25 AND NOVE 1983 WAS BASED 'UPON CAREFUL CONSIDERATION OF KANY FACTORS i
EVALUATIONS OF PLANT AND OPERATOR PERFORKANCE AS OBSERVED SPECIAL INSPECTIONS AT THE GRAND GULF SITE. THESE TYPE EVALU MENTS ARE MADE THROUGHOUT THE LIFE OF CONSTRUCTION AND O I
ANY N.UCLEAR P0n'ER PLANT.
i THE JUDGEMENT OF THE , STAFF HAS CONSISTENTLY EEEN THAT THE OPERATING STA '
ALTHOUGH DEFICIENCIES ,1N THE MANAGEMENT GRAND GULF NUCLEAR STATION IS QUALIFIED.
. .0F THE TRAINING PROGRAM WERE. IDENTIFIED BY REGION II INSPECTION ACTIVIT OVERALL COMPETENCE F THE GRANb GULF OPERATORS HAS BEEN FOUND TO BE AC THESE EVALUATIONS AND JUDGEMENTS WERE KADE BY EXPERIENCED P ACCORDANCE WITH HRC REGULATIONS AND AGENCY POLICIES. AS WILL BE DISCUS JUDGEMENTS FOR GRAND GULF NUCLEAR STATION WERE SUPPORTED B
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CONDUCTED BY INDIVIDUALS FROM NRR, REGION I, REGION II, AND REGION III. THE FOLLOWING DISCUSSION OF THE CHRONOLOGY OF SIGNIFICANT EVENTS RELATING TO 0 LICENSING AND RELATED' INSPECTION AND EVALUATION ACTIVITIES AT GRAND GULF NU STATION SUFFORTS THESE CONCLUSIONS.
IN OCTOBER 1951, THROUGH JANUARY 1982, THE NRC GAVE COLD LICENSE EXAMINATIONS TO 30 OPERATORS AT THE GRAND GULF NUCLEAR STATION. SIXTEEN OPERATORS PASSED 8Xe.INATION AND WERE LICENSED. THIS PASSING RATE WAS LOWER THAN NORMAL FOR l
INITIAL EXAMINATIONS, EUT THE OPERATORS WHO PASSED THE EXAMINATION WERE DETER- .
[IN DECEMBER 1952, NRC MINED TO BE QUALIFIED TO PERFORM LICENSED DUTIES.
PRIOR TO THIS DATE, ALL OPERATOR REGION II ASSUMED OPERATOR LICENSING AUTHORITY. .
LICENSING AUTHORITY AND ACTIVITIES WERE CONTROLLED BY THE OFFICE OF NUCLEA REACTOR REGULATION IN NRC HEADQUARTERS ~ IN WASHINGTON.]
A LICENSE FOR OPERATION AT LESS THAN 5% POWER WAS ISSUED TO GRAND GULF ON JUNE 16, 1982. FOLLOWING LICENSE ISSUANCE, BUT PRIOR TO FUEL LOADING AND INITIAL CRITICALITY, REGION II CONDUCTED A SERIES OF INSPECTIONS TO CONFIRM THAT THE FACILITY WAS READY TO PROCEED. REGION II CONCLUDED THAT THE FACILITY WAS READ I AND ON AUGUST 18,19B2, GRAND GULF, UNIT 1, ACHIEVED INITIAL CRITICALITY WITHOUT SUBSTANTIVE PROBLEMS. FOUR REGION II PERSONNEL WERE PRESENT DURING THAT i EVOLUTION. .
i FOLLOWING INITIAL CRITICALITY, NONNUCLEAR HEATUP, TESTING, AND EVALUATIONS REVEALED INADEQUACIES IN THE DRYWELL COOLING CAPACITY AND AN EXTENDE OUTAGE WAS BEGUN, PRIMARILY FOR THE PURPOSE OF INSTALLING ADDITIONAL ORYWELL COOLING CAPACITY.
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. l 3 l IN FEERUARY 1953,. REGION 11 CONDUCTED A SPECI AL TRAININ3 ASSESSMENT INSPECTION A SUCH ASSESSMENTS ARE EEIN3 CONDUCTED ON ALL THE GRAND GULF NUCLEAR STATION.
UTILITY TRAININ3 FROGRAMS IN REGION II IN RECO3NITION OF THE IMPORTA PROGRAMS.
THESE ASSESSMENT 5 ARE POSITIVE INITIATIVES OF REGION II, AND REGION II HAS PROPOSED SUCH ASSESSMENTS A5 A NATIONAL PR03 RAM ADDITION T DURING THE SPECI AL GRAND GULF INSPECTION AND ENFORCEMENT AT HEADQUARTERS.
TRAINING ASSESSMENT, REGION II BECAME AWARE OF POTENTI AL TRAINING PROBLEMS WHEN ALL THE SUPPORTING RECORDS FOR PREVIOUS OPERATOR TRAININ3 COULD N THE LICENSEE STATED THAT THEY WERE AWARE OF THIS DEFICIENCY AND SH .
INSPECTOR 5 SEVERALl PLANT QUALITY DEFICIENCY REPORTS (P03R'5) TH THE PQDRS DESCRIBED THE INITIATED BY A MEMBER OF' THE TRAINING STAFF OF MP&L. i PR03LEMS AS MISSIhy OR MISPLACED RECORDS AND COMMITTED TO RESOLVE TH FEERUARY 23, 1953. LICENSEE MANAGEMENT CHARACTERIZED THIS MATTER AS A RECORDS PROBLEM. THE EXPLANATIO'N OF MISSING RECORDS WAS' A CREDIBLE ON WERE NOT READILY RET,RIEVABLE AND THERE HAD BEEN RAPID TURNOVER IN THE LICENSE TRAININ3 OEPARTMENT. NRC ENFORCEMENT POLICY STATES THAT A LICENSEE WILL NOT BE CITED FOR A VIOLATION IN CASES LIKE THIS VHERE THE LICENSEE HAS IDE PR05LEM AND THE STAFF HAS INDICATIONS THAT THE LICENSEE WILL TAKE ACCORDINGLY, THE INSPECTORS APPROPRI ATELY IDENTI-EFFECTIVE CORRECTIVE ACTION.
FIED AND 00CUMENTED THIS MATTER IN AN INSPECTION REPORT A5 AN U THAT REDUIRED STAFF FOLLOWUP.
BETWEEN MAY 19E2 'AND SEPTEMEER 1983, LICR'@ i AM*.liATIONS WERE GIVEN TO CANDIDATES FOR OPERATOR LICENSES BY THE NRL wn J OF 39 CANDID EXAMINATIONS OR REEXAMINATION 5.
THIS PASS RATE IS COMPARABLE TO THAT OBSERVED AT OPERATORS WHO PASSED WERE QUALIFIED TO OTHER FACILITIES FOR SIMILAR EXAMS. ,
PERFORM LICENSED DUTIES.
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4 IN JULY AND AUGUST 1953, REGION 11 CONDUCTED A'REQUALIFICATION PROGRAM AUDIT AT SIX GRAND GULF NUCLEAR STATION IN ACCORDANCE WITH NRC EXAMINER STAN OF THE SEVEN OPERATORS EXAMINED BY THE NRC DURING THIS AUDIT PA NATION. THE LICENSEE REQUALIFICATION PROGRAM WAS FOUND TO BE ACCEPTAB BETWEEN AUGUST 15, 1933, AND SEPTEMBER I,1983, REGION II CONDUCTED A SPECIAL INSPECTION TO CONFIRM THE OVERALL READINESS OF THE GRAND GU ~
MATTERS I'NSPECTED TO RESUME OP_ERATION FOLLOWING THE ONE-YEAR MAINTENANCE OUTAGE.
INCLUDED SURVEILLANCE PROCEDURES, ENFORCEMENT, QUALITY ASSURANCE, FIRE PRO .
TION, SECURITY, STAFFING LEVELS, AND TRAINING. DURING THIS OPERATIONAL REA INSPECTION, INSPECTORS, IN _ F0i. LOWING UP ON THE MISSING RECORDS, FOUND TH OPERATOR QUALIFICATION CARDS HAD NDT BEEN COMPLETED AS HAD OPERATOR LICENSE APPLICATIONS. 'THE QUALIFICATION CARDS LIST EVOLUTIONS ON WHICH .AN OPERATOR WDULD BE CHECKED OFF DUR PROCESS. COMPLETION OF THESE QUALIFICATIONS CARDS 15 NOT A ROUTINE R IN THIS CASE, THE LICENSEE HAD MADE A FORMAL COMMITMENT IN THEIR REQUIREMENT.
FINAL SAFETY ANALYSIS REPORT TO USE QUALIFICATION CARDS AND, THEREFORE, WA REQUIRED TO DO 50. THE LICENSEE ALSO STATED THAT APPAREN COURSES HAD BEEN SHORTENED (E.G., A FIVE-DAY COURSE CONDUCTED IN FOUR A DAYS). THE INSPECTORS INFORMED PLANT MANAGEMENT THAT FAILURE
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TRAINING WAS CONTRARY TO COMMITMENTS THE UTILITY HAD MAD FAILURE TO MEET SUCH A COMMITMENT.COULD BE CITED AS A DEV THE INSPECTORS FURTHER INFORMED PLANT MANAGE-WITH NRC ENFORCEMENT PRDCEDURES.
MENT THAT THE OVERSTATEMENT OF COMPLETED OPERATOR T
! APPLICATIONS COULD BE CONSIDERED AS A MATERIAL FALSE STATEMENT.
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, 5 DURING A MEETING IN ATLANTA ON SEPTEMBER 23, 1983, REGION 11 MANAGEMENT INFORMED LICENS.EE MANAGEMENT THAT , AFTER FURTHER REVIEW, THE TRAINING ISSUE WOULD NOT EE CITED AS A DEVIATION FROM COMMITMENTS, AS PREVIOUSL IN THE EXIT INTERVIEW, IN THAT WE WOULD EVALUATE OUR INFORMATION TO DE THE STAFF THE INCORRECT APPLICATIONS CONSTITUTED A MATERI AL FALSE STA STATED THAT THE LICENSEE MUST DEVOTE PROMPT KANAGEMEN THEIR DETAILED INVESTIGATION OF THE NATURE, SCOPE, AND CAUSE OF THE FAILU LICENSED OPERATORS TO COMPLETE QUALIFICATION CARDS AND T THE NRC STATED THAT THEY WISHED TO MEET TRAINING COMMITMENTS MADE TO THE NRC.
AGAIN PROM TLY WITH THE. LICENSEE TO REVIEW THE RESULTS O THE ABOVE PROELEMS, AS VIEWED AT THAT TIME, WERE HISTORIC IN NATURE AN TO ACTIVITIES THAT OCCURRED WEL[L OVER A YEAR EARLIER. T LACK OF OVERSIT,E BY UTILITY MANAGEMENT OF THE GRAND GULF OPERATOR T PROGRAM; HOWEVER, IT MUST BE NOTED THAT THE RESULTS OF NRC EXAMINAT CONTINUING OBSERVATIONS ON SITE PROVIDED HIGH ASSURAN QUALIFIED TO PERFORM LICENSED DUTIES.
THE STATEMENT THAT "BY AUGUST 1983, AND CERTAINLY NO LATER THAN SEPT 19E3, REGION II WAS AWARE OF THE ERR 0NECJS OPERATOR TRAINING RECO REASON TO SUSPECT,THE COMPETENCE OF GRAND GULF'S OPERATORS" IS MI THE ERR 0kEOUS TRAINING RECORDS BECAME KNOWN TO THE NRC, OVER IMPLICATIONS.
2 AS TO THE COMPETENCE OF THE GRAND GULF OPERATORS, THE EXTENDED PERIOD OF TIME.
NRC HAD SUBSTANTIAL REASON TO BELIEVE THE OPERATORS AS DISCUSSED PREVIOUSLY, THE OPERATORS HAD PASSED NRC THEIR LICENSED DUTIES.
LICENSING EXAMINATIONS AND THE REQUALIFICATION EXAMI AUGUST 1983. THESE RESULTS ARE EVIDENCE THAT THE PERSONNEL WE
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PERFORM LICENSED DUTIES, AND THE REQUALIFICATION PR03MM' AU AEILITY OF THE LICENSED OPERATORS TO RETAIN APPR IN ADDITION, MOST OF THE OPERATORS TO WHICH THIS ISSUE PERFORM LICENSED DUTIES.
NRC INSPECTIONS SINCE THAT APPLIED HAD EEEN LICENSED SINCE EARLY AND MID 1982.
TIME HAD RESULTED IN THE CONTINUING OBSERVATI AS FOR THE FAILURE TO COMPLETE THE THE LICENSED OPERATORS IN THE CONTROL ROOM.
QUALIFICATION CARDS, NRC CONTINUES TO BELIEVE THAT THE QU HOWEVER, THE ,
SIGNIFICANT ISSUE AS THE PROPOSED ENFORCEMENT ACTIO '
COMPLETION OF OUALIFICATION CARDS SHOULD BE PUT IN THE PROPER CONT AND HAS NOT BEEN, A REGULATORY REQUIREMENT, QUALIFICATION CARDS IS NOT NOW, ALTHOUGH THE NRC DOES EELIEVE THAT ESTABLISH
.IN THIS SPECIFIC CASE, THE SYSTEMS IN TRAINING. PROGRAMS IS A GOOD PRACTICE. .
TO COMPLETE QUALIFICATION CARDS AND WAS LICENSEE MADE A FORMkl COMMITMENT THEREFORE REQUIRED TO.D0 SO. [ REGION II REVIEWED AVAILABLE FINAL SAF IN ONLY ONE OTHER CASE WAS THE COMPLET REPORTS FOR THIRTEEN OTHER LICENSEES.
OF QUALIFICATION CARDS A. COMMITMENT.)
THE STATEMENT THAT HAD THE NRC KNOWN THAT TH FALSIFIED, NOT ONLY WOULD THE OPERATORS NOT HAVE BEEN LI POWER LICENSE ITSELF WOULD NOT HAVE BEEN ISSUED, ALSO N 28, 1983, MEMORANDUM FROM THIS STATEMENT WAS .MORE FULLY EXPLAINED IN A DECEMEER THE EXECUTIVE DIRECTOR OF' OPERATIONS., WILLIAM J. DIRCKS, VICTOR GILINSKY. THE NRC WOULD NOT HAVE ISSUED OPERATOR L THAT TRAINING INDICATED ON THE APPLICATION O IF THE OPERATOR LICENSES HAD NOT BEEN FULLY COMPLETED AND HAD BEEN FALSIFIED.
WERE NOT ISSUED, THEN THE UTILITY WOULD NOT HAVE HAD T LICENSED OPERATORS REQUIRED FOR OPERATION, AND THE
7 IT- S'HOULD ALSO BE NOTED THAT-CONSIDERED THE ISSUANCE OF A LOW POWER LICENSE.
SINCE THE QUALIFICATION CARDS ARE NOT A REGULATORY REQUIREMENT, BJT WERE A LICENSEE COMMITMENT, THE LICENSEE COULD HAVE REQUESTED DELETION OF THAT COMMITMENT PENDING NRC APPROVAL.
1 THE STAFF PURSUED THIS PATTER VIGOROUSLY. ON OCTOBER 4, 1983, REGION II MET WITH THE LICENSEE FANAGEMENT ON ANOTHER MATTER AND RECEIVED AN UPDATE ON OF THE LICENSEE'S INVESTIGATION OF THE OPERATOR TRAINING RECORDS. THE DESCRIEED THEIR FINDINGS TO DATE AND REVEALED, FOR THE FIRST TIME, THAT IN ADDITION TO INCOsPLETE QUALIFICATION CARDS AND SHORTENED TRAINING FSAR SAYS A COURSE WILL BE FIVE DAYS; RECORDS SHOW IT WAS COMPLETED IN (EXAMPLE:
FOUR AND A HALF DAYS), SOME TRAINING COURSES MAY NOT HAVE BEEN CONDUCTED SINCE IN SOME CASES SUPPORTING DOCUMENTATION COULD NOT BE FOUND. THE STAFF ON OCTOBER 12, 1983, REGION II MET WITH INCREASING CONCERN, OVER THESE MATTERS.
LICENSEE OFFICIALS TO DISCUSS THE RESULTS OF THE LICENSEE'S INVESTIGA MATTER. TWO OFFICE OF INVESTIGATION INVESTIGATORS ATTENDED THIS MEETING A j SPECIFIC REQUEST OF REGION II. SUBSEQUENT TO THIS MEETING, REGION II REQUESTED A FORMAL INVESTIGATION OF THIS PATTER BY THE OFFICE OF INVESTIGATION.
ON OCTOBER 31, 1953, THROUGH NOVEMBER 4, 1953, REGION II CONDUCTED ANDTHER THE
, SPECIAL TRAINING ASSESSMENT INSPECTION AT GRAND GULF NUCLEAR STATIO
- PURPOSE OF THE INSPECTION WAS TO, DETERMINE IF ADEQUATE CORRECTIVE ACTIONS WERE B'EING TAKEN TO CORRECT IDENTIFIED DEFICIENCIES, AND TO PAKE ANOTHER EVALUATIO THE ADEQUACY OF OPERATORS' KNOWLEDGE. DURING THIS INSPECTION, WALK-THROUGH T EVALUATIONS WERE CONDUCTED FOR THIRTEEN LICENSED OPERATORS ON TEN OF THE OPERATORS WERE JUDGED TO BE QUALIFIED TO PERFORM LIC THREE OPERATORS WERE IDENTIFIED AS BEING DEFICIENT IN KNOWLEDGE
8 REMOVED FROM LICENSED DUTIES. THIS INSPECTION ALSO REVEALED THAT THE QUA TION CARDS FOR FOUR *0THER INDIVIDUALS WHO HAD EEEN EXAMINED IN SEPTEME HAD BEEN RUSHED THROUGH AND WERE INADEQUATE. ONLY ONE OF THESE INDIVIDU RECEIVED A LICENSE AT THAT POINT IN TIME, AND HE WAS REMOVED FROM LICENSED THUS A TOTAL OF DUTIES. THE OTHER THREE OPERATORS WERE NOT ISSUED A LICENSE.
FOUR INDIVIDUALS WERE REMOVED FROM DUTIES ON NOVEMBER 4, 1983. AS AGREED BETWEEN THE LICENSEE AND REGION II, DURING THE EXIT INTERVIEV, THE LICENSEE DOCUMENTED THIS AGREEMENT BY A LETTER OF NOVEMBER 10, 1983, TO REGION II.
BASED ON THE RESULTS OF THE MANt EXAMINATIONS AND EVALUATIONS PERFORMED, AND ON OUR CONTINUING OBSERVATION OF SATISFACTORY PERFORMANCE IN THE CONTROL ROOM, THE STAFF'S JUDGEMENT WAS THAT OPERATOR LICENSE SUSPENSION OR REVOCATION WA WARRANTED. HOWEVER, BASED ON THE KNOWLEDGE THAT CERTAIN TRAINING HAD NOT BEEN FULLY COMPLETED AND THAT SERIOUS QUESTIONS EXISTED RELATING TO RECORDS, THE STAFF'S JUDGEM5NT WAS THAT ADDITIONAL ACTIONS TO CERTIFY THE TRAINING AND AS KNOWLEDGE LEVEL OF ALL OPERATORS WAS REQUIRED BEFORE PROCEEDING FURTHER.
DISCUSSED PREVIOUSLY, OPERATORS WITH DEFICIENT KNOWLEDGE LEVEL AND THOSE WITH RUSHED-THROUGH QUALIFICATION CARDS WERE REMOVED FROM DUTIES. ON NOVEMBE NOVEMBER 18, 1983, THE NRC MET WITH THE LICENSEE TO ENSURE THAT A PROGRAM WAS INITIATED TO REVERIFY THE OPERATORS' KNOWLEDGE LEVEL FOR THOSE AREAS IN AS A SUPPORTIVE TRAINING . DOCUMENTATION COULD NOT SUPPORT SUCH A CONCLUSION.
RESULT OF THESE MEETINGS, THE LICENSEE DEVELOPED AN EXTENSIVE RECERTIFICATION THE PROGRAM WHICH BEGAN IN NOVEMBER 1983, AND WAS COMPLETED IN FEBRUARY 1954.
DECEMBER 5,1983, CONFIRMATION OF ACTION LETTER CONFIRMED THE AGREEMENT WITH THE LICENSEE TO COMPLETE THIS PROGRAM AND RECONFIRMED THE VERBAL COMMITM NOVEMBER 4,1983, AND THE WRITTEN COMMITMENT OF NOVEMBER 10, 1983, THAT CERTAIN OPERATORS HAD BEEN REMOVED FROM DUTIES. ,
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9 AS A PART OF THE RECERTIFICATION PROGRAM, THE LICENSEE EXAMINED ALL LICENSED OPERATORS ON EACH SYSTEM. ON THE QUALIFICATION CARD (EE SYSTEM 5). LICENSEE MANAGEMENT, REPRESENTATIVES FROM OTHER UTILITIES AND FROM THE FEACTOR VENDDR, AS WELL AS NRC, MDNITORED THIS EXAMINATION PROCESS. OPERATORS WHD WERE WEAK WERE RETRAINED AND REEXAMINED. UPDN SUCCESSFUL COMPLETION OF THESE EXAMINATIONS, THE CANDIDATES AND THEIR RECORDS WERE EVALUATED BY AN OPERATOR TRAINING Et ALUATION COMMITTEE COMPRISED OF PLANT MANAGEMENT. THE LICENSEE ALSO REVIEWED TRAINING AND EXAMINATIONS OF THE SHIFT TECHNICAL ADVISORS AND SHIFT ADVISORS WHO ARE NDi LICENSED. . THE SHIFT TECHNICAL ADVISORS AND SHIFT ADVISORS WERE PROVIDED TRAINING AS NECESSARY AND WERE ALSO CERTIFIED BY THE OPERATOR TRAINING EVALUATION ,
COMMITTEE.
UPON COMPLETION OF THIS PROGRAM, THE NRC REEXAMINED THE TWENTY-SIX LICENSED OPERATORS WHO COMPLETED THIS PROGRAM. TWENTY-THREE OPERATORS SUCCESSFULLY PASSED THE NRC EXAMINATION.
IN ADDITION TO THE TRAINING OF OPERATORS, THE LICENSEE MADE SUBSTANTIVE CHANGES IN THE MANAGEMENT RESOURCES DEVOTED TO TRAINING TO ENSURE THAT FUTURE TRAINING IS COMPLETE AND CONDUCTED IN A QUALITY MANNER.
IN
SUMMARY
, REGION II PAID CLOSE ATTENTION TO THE LICENSING, TRAINING, AND PERFORMANCE OF OPERATOR'S AT THE GRAND GULF NUCLEAR STATION. SPECIAL INITIATIVES
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AND ADDITIONAL INSPECTIONS WERE CONDUCTED THROUGHOUT THE PERIOD IN VHICH GRAND GULF PREPARED FOR AND CONDUCTED LOW POWER TESTING. EXPERIENCED INSPECTORS AND i
- EXPERIENCED EXAMINERS FROM DIFFERENT OFFICES OF THE AGENCY, AT THE REQUEST OF REGION II, WERE UTILIZED TO ASSESS THE COMPETENCE OF THE GRAND GULF OPERATORS.
l THESE EFFORTS WENT FAR BEYOND NRC PROGRAM REQUIREMENTS. THE OPERATORS AT GRAND
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10 GULF NUCLEAR STATION ARE, AND WERE, QUALIFIED TO PERFORM LICENSED DUTIES. THEIR SATISFACTORY PERFORMANCE OURING L0w' POWER TESTIN3 IS CREDIBLE EVIDENCE OF THIS FACT. THE RECERTIFICATION PROGRAM HAS REVERIFIED TO THE LICENSEE THE IMPORTANCE OF THE TRAINING PROGRAM AND OF TRAINING COMMITMENTS PADE TO THE NRC. THE ACTIONS OF NRC REGION II WERE AGGRESSIVE AND CORRECT, PARTICULARLY WEN ONE RECOGNIZES THE INFORMATION AVAILABLE AND THE PLANT STATUS AT DIFFERENT TIMES DURING THIS 1
PERIOD. THE DILIGENCE 0.F REGION II IS DIRECTLY RESPONSIBLE FOR IDENTIFYING ALL
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THESE DEFICIENCIES AND IN SEEING THAT THESE DEFICIENCIES AND THEIR ROOT CAUSES WERE CORRECTED IN AN APPROPRIATE PANNER. ,
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11 QUESTION 1: "DID REGION II 0FFICIALS UNNECESSARILY AND/OR INAPPROPRIATELY SHARE INFORMATION WITH THE LICENSEE"?
(MP&L, REGARDING THE POSSIBILITY OF QUALIFICA-TION CARD ISSUE BEING CONSIDERED A MATERIAL FALSE STATEMENT.)
ANSWER THE STAFF STRONGLY SUPPORTS THE POSITION THAT NO IMPROPER ACTION WAS TAKEN B REGION II IN THIS MATTER. THE CONTENTION THAT IT IS UNNECESSARY AND/OR INAPPRO PRIATE TO DISCUSS WITH A LIICENSEE THE POTENTIAL SIGNIFICANCE OF MATERIAL FAL IT IS COMMON PRACTICE FOR REGION II, STATEMENTS (MFS) TO THE NRC IS INCORRECT.
VHEN CONDUCTING MANAGEMENT OR ENFORCEMENT MEETINGS WITH LICENSEE MANAGEMENT, TO REMIND THE LICENSEE OF THE NRC'S INSISTENCE THAT THE SUBMITTAL OF INFORMATIO ALSO, THE ENFORCEMENT POLICY REGARDING THE NRC MUST BE ACCURATE AND FACTUAL.
MFS IS ROUTINELY DISCUSSED DURING ENFORCEMENT MEETINGS AND AT OTHER SCHE MEETINGS WITH CORPORATE LEVEL PERSONNEL.
ADDITIONALLY, NRC INSPECTION ACTIVITIES AND THE PRESENTATION OF INSPECTION FINDINGS ARE CONDUCTED IN AN OPEN, CANDID AND STRAIGHT-FORWARD MANNER. IT IS NOT APPROPRIATE FOR THE NRC TO USE ENTRAPMENT OR STEALTH TO TRICK THE LICENS MAKING ADDITIONAL MFS OR. TO ALLOW THE LICENSEE TO CONTINUE IN UNSATISFAC PERFORMANCE IN SAFETY-RELATED ACTIVITIES MERELY FOR THE SAKE OF ENHANC POTENTIAL FUTURE ENFORCEMENT ACTION. THE PRIMARY THRUST OF REGION II A WAS TO IDENTIFY POTENTIAL SAFETY PROBLEMS AND GET THEM FIXED PROPERLY AS POSSIBLE. TOWARD THAT GOAL, IT IS APPROPRIATE TO BE CANDID WITH THE LICENSEE.
ALSO, IT IS IMPORTANT TO RECOGNIZE THAT IN THIS KATTER, WHEN REGION II WAS
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) DISCUSSING THIS KATTER WITH MP&L IN LATE 1953, THAT THIS MATTER WAS THEN THE REACTOR. OPERATOR EXAMINATION REQUESTS CONSIDERED TO BE AN OLD ISSUE.
CONTAINING INACCURATE TRAINING INFORMATION WERE SUEMITT i IN ADDITION TO THE ABOVE, WE NOTE 1981, AND WERE PART OF NRC'S OFFICIAL RECORDS.
THAT IN REVIEWING THIS QUESTION, REGION II ASKED THE 01 INVESTIGATOR WHO l
PERFORMED THE WORK IF REGION II CONVERSATIONS, OR INDEED ANY OF THE EXT i
REGION II ACTIVITIES IN THIS AREA COMPROMISED OR HINDERED HI l
ANY WAY. THE ANSWER TO THAT QUESTION WAS AN EMPHATIC NO ,
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TO SUPPORT THE ABOVE' POSITION, THE FOLLOWING DETAILED DESCRIPTION OF TH
'f DURING A TRAINING ASSESSMENT INSPECTIOM 0F EVENTS IS OFFERED BY REGION II.
(50-416/83-D6) 0F FEBRUARY 15-17, 1983, REGION 11 FIRST BECAME AWARE O TRAINING PROBLEMS WHEN ALL THE SUPPORTING RECORDS FOR PR '
COULD NOT BE LOCATED. THE LICENSEE STATED THAT THEY WERE AWARE OF THIS DEFICIENCY AND SHOWED THE INSPECTORS SEVERAL PLANT QUAL THE i (PQDR'S) THAT HAD BEEN INITIATED BY A MEMBER OF THE TRAI PQDRS DESCRIBED THE PROBLEMS AS MISSING OR MISPLACED RESOLVE THIS PATTER BY FEBRUARY 23, 1983. LICENSEE PANAGEMENT CHARACTERIZED THIS i
J MATTER AS A RECORDS PROBLEM.
THE EXPLANATION OF MISSING RECORDS WAS A CREDIB ONE SINCE THE RECORDS WERE NOT READILY RETRIEVABLE AND NRC ENFORCEMENT POLICY STATES TURNOVER IN THE LICEN'5EE'S TRAINING DEPARTMENT.
THAT A LICENSEE WILL NOT BE CITED FOR A VIOLATION IN CAS LICENSEE HAS IDENTIFI.ED A PROBLEM AND THE STAFF HAS IND ACCORDINGLY, THE INSPECTORS i
E VILL TAKE' PROMPT AND EFFECTIVE CORRECTIVE ACTION.
i APPROPRIATELY IDENTIFIED AND DOCUMENTED THIS PATTER IN I UNRESOLVED ITEM THAT REQUIRED STAFF FOLLOWUP. .
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! THE UNRESOLVED . ITEM. WAS NEXT EXAMINED IN AN OPERATIONAL READINESS TEAM INSPEC-I TION 50-4I6/83-38 CONDUCTED BY SIX INSPECTORS INCLUDING TWO RESIDENT INSPECTORS
' FROM OTHER SITES DURING THE PERIOD OF AUGUST IS THROUGH SEPTEMEER I, 1983. THIS SPECIAL INSPECTION WAS CONDUCTED TO EVALUATE THE OVERALL FACILITY READINESS TO l
RESUME OPERATION FOLLOWING A ONE-YEAR MAINTENANCE OUTAGE. DUPING THIS OPERATIONAL READINESS INSPECTION, INSPECTORS, IN FOLLOWING UP ON THE MISSING f
RECORDS, FOUND THAT OPERATOR QUALIFICATION CARDS HAD NOT BEEN COMPLETED AS HAD BEEN INDICATED ON OPERATOR LICENSE APPLICATIONS. THE QUALIFICATION CARDS LIST i VARIOUS SYSTEMS AND EVOLUTIONS ON WHICH AN OPERATOR WDULD BE CHECKED OFF DURING THE QUALIFICATION PROCESS. COMPLETION OF THESE QUALIFICATION CARDS IS NOT A ROUTINE REGULATORY REQUIREMENT. IN THIS CASE, THE LICENSEE HAD MADE A FORMAL' COMMITMENT IN THEIR FINAL SAFETY ANALYSIS REPORT TO USE QUALIFICATION CARDS AND, THEREFORE, WAS REQUIRED TO 00 50. THE LICENSEE ALSO STATED THAT APPARENTLY SOME
! 0F THE TRAINING. COURSES HAD EEEN SHORTENED (E.G. , A FIVE-DAY COURSE CONDUCTED IN FOUR AND A HALF DAYS). THE INSPECTORS INFORMED PLANT MANAGEMENT THAT FAILURE TO 1 CONDUCT THIS TRAINING WAS CONTRARY TO COMMITMENTS THE UTILITY HAD MADE TO THE NRC AND THAT FAILURE TO MEET SUCH A COMMITMENT COULD BE CITED AS 'A DEVIATION IN l
ACCORDANCE WITH NRC ENFORCEMENT PROCEDURES. THE INSPECTORS FURTHER INFORMED PLANT MANAGEMENT THAT THE OVERSTATEMENT OF COMPLETED OPERATOR TRAINING ON l INDIVIDUAL LICENSE APPLICATIONS COULD BE CONSIDERED AS A MATERIAL FALSE STATEMENT.
- i l REGION II MANAGEMENT EXTENSIVELY DISCUSSED THE INSPECTION FINDINGS' INTERNALLY AND REVIEWED THE FILE INFORMATION DURING THE FOLLOWING WEEKS. THIS MATTER RECEIVED
! CLOSE ATTENTION IN PARALLEL WITH NUMEROUS OTHER TECHNICAL ISSUES THAT NEEDED RESOLUTION PRIOR TO REGION II CONCURRENCE WITH THE STARTUP OF GRAND GULF.
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,. 14 j DURING A MEETING' IN ATLANTA ON SEPTEMBER 23, 1983, REGION II MANAGEMENT OFFICIALS 4
- 3NFORMED LICENSEE MANAGEMENT THAT, AFTER FURTHER REVIEW, THE TRAINING RECORD l'
i 8SSUE WOULD NOT BE CITED AS A DEVIATION FROM COMMITMENTS, AS PREVIOUSLY DESCRIBED
' IN THE EXIT. INTERVIEW, IN THAT WE WOULD EVALUATE OUR INFORMATION TO DETERMINE IF j
THE STAFF THE INCORRECT APPLICATIONS CONSTITUTED A VATERIAL FALSE STATEMENT.
t STATED THAT THE LICENSEE MUST DEVOTE PROMPT MANAGEMENT ATTENTION TO COMPLETE THEIR DETAILED INVESTIGATION OF THE NATURE, SCOPE, AND CAUSE OF THE FAILURE OF LICENSED OPERATORS TO COMPLETE QUALIFICATION CARDS AND TO FULLY COMPLETE OTHER TRAINING COMMITMENTS MADE TO THE NRC. THE NRC STATED THAT THEY WISHED TO MEET ,
AGAIN PROMPTLY WITH,THE LICENSEE TO REVIEW THE RESULTS OF THEIR INVESTIGATION.
THE MP&L VICE PRESIDENT STATED THAT HE WOULD GIVE THE MATTER PROMPT ATTENTION.
HE STATED THAT BASED ON THE FIND'INGS OF THE NRC INSPECTIONS CONDUCTED ON FEBRUARY 15-17, AND AUGUST 15-SEPTEMBER I,1983 (INSPECTION REPORTS 83-06 AND
] 83-38) HE HAD NOT CONSIDERED THE SITUATION TO BE THAT SERIOUS. HE STATED HAD WITH HIM A DOCUMENT THAT HAD BEEN PREPARED FOR SUBMITTAL TO THE NRC TO I CORRECT THE RECORD ON THE QUALIFICATION CARD MATTER BUT, IN VIEW OF THE SIGNIFI-
.i CANCE PLACED ON THESE ISSUES BY THE NRC, HE WANTED TO MAKE ABSOLUTELY CERTAIN THAT.THE INFORMATION PROVIDED TO HIM BY HIS STAFF WAS CORRECT. THE STATEM PAGE 2 0F CONGRESSMAN MARKEY'S LETTER MISREPRESENTS THE FACTS BY STATING 1
VICE PRESIDENT REFUSED TO TURN OVER INFORMATION AND POSSIBLE EVIDENCE. SUC
- NOT THE CASE. THE MEETIN'G THEN CONCLUDED WITH THE LICENSEE AGAIN STATING THAT PROMPT ACTION WOULD EE TAKEN. ,
f
! THE STAFF PURSUED THIS MATTER VIGOROUSLY. ON OCTOBER 4, 1983, REGION 11 MET WITH
! THE LICENSEE MANAGEMENT ON ANOTHER MATTER AND RECEIVED AN UPDATE ON TH l OF THE LICENSEE'S INVESTIGATION OF THE OPERATOR TRAINING RECORDS. THE i
e
d * . IS THAT IN D REVEALED, FOR THE FIRST TIME RTENED TRAINING COURSE DESCRIBED THEIR' FINDINGS ADDITION TO (EXAMPLE:
FSAR SAYS A COURSE WILL BE FIVE DAYS FOUR AND A HALF DAYS), SOME THE STAFF C STATED THE D NDT BETRAINING FOUND.
SOME CASES SUPPORTING MP&L HAD SUBMITTED A LETTER DOCUMENTATION G C THESE MATTERS.
INCREASING CONCERN OVER RATOR TRAINING DISCREPANCIE 30, 1983, CONCERNING THE OPE THE LETTER STATED 3 .
SEPTEMBER E NRC OF THESE MATTERS.
THEIR COMMITTMENT TO DEFICIENCIES FORMALLY INFORM ON PREVI T l
IN
SUMMARY
THAT <THERE HADTHEBEEN LETTER FURTHER TRAI THAT PASSING THE NRC' EX'AM AND SUBSEQ THE' NRC TO TAKE FURTHER ACTION TAKEN WITH TO PREVENT RESPECT RECURRE TO STATED THAT CORRECTIVE ACTION HAD BEE ,
j .
STATED THAT WE DISAGREED WITH THE MP l
OETAILED INVESTIGATION BY MP&L MUST ,
REGION II AS 500N AS POSSIBLE.
REGION II MET WITH L ICENSEE OFFICIALS T ON OCTOBER 12, 1983, IS MATTER.
TWD OFFICE OF INVE l
OF THE LICENSEE'S INVESTIGATION THE SPECIFIC REQUES OF TH INVESTIGATORS ATTENDED 11 MANAGEMENT MET THE THIS MEETIN f FOLLOWING THE MEETING WITH MP&L, REGION Y REl '
1 DISCUSSED THE TRAINING ISSUES AND VERBALL '
DE GATION OF THE TRAINING ISSUES. REGION HACTE, W f 17, 1983, AND URGED I
ON MONDAY, OCTOBER EQUESTING AN INVES l f
THE FORMAL LETTER FROM REGION II TO BUT BY THAT DATE, 01 WA l
OCTOBER 18, 1983, l
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15 2N CONCLUSION, THE SIAFF SUPPORTS THE POSITION THAT REGION II ACTED PROPE J
BASED ON THE INFORMATION AVAILABLE TO THE NRC AT THE TIME, AND DID NOT WE FEEL UNNECESSARILY OR INAPPROPRIATELY SHARE INFORMATION WITH TH THAT THE NRC IN THE INTEREST OF SAFETY MUST CONTINUE TO, CONDUCT OPEN AN WHEN LICENSEE PERFORMANCE IN SAFETY-RELATED CONVERSATIONS WITH THE LICENSEE.
i ACTIVITIES IS OF CONCERN, THE NRC MUST PROMPTLY INFORM THE LICENSEE OF TH CONCERN, INDEPENDENT OF POTENTIAL OR POSSIBLE FUTURE ENFORCEMENT ACTION. ,
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