ML20132E705
| ML20132E705 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/30/1983 |
| From: | MISSISSIPPI POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20132E314 | List:
|
| References | |
| FOIA-85-419 NUDOCS 8510010151 | |
| Download: ML20132E705 (97) | |
Text
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W MIt&iS$1PPI PO'm'ER Aht LICHT CO.9Ah'Y CRAhT CUI.T hTCLEAR STATION CORRECTIVE ACTION PLANS s
FOR OPERA 10R TRAINING PROGRAM NOVDGER 1983 r
0510010151 850923 PDR FOIA REBER85-419 PDR
CRAND CULT NUCLEAR STATION 40RFIC72VE ACTIONS FOR OFERA70R TRAIN 7NC FROGRA.M I
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Certain areas have been identified in the Grand Gulf Nuclear Station (GCNS).
licensed operator training program wherein corrective actions are deeced i
necessary to strengthen the program.
These corrective actions, which include actiens to prevent recurrence, generally fall into'tve categerfest
- 1) operator recertificatien and 2) management centrol.
Each of these eajor categories is addressed in this plan udth specific statements delineating the actions te be i
taken.
VJ&L believes this progra vill correct all identified discrepancies and prevent their recurrence.
Additionally, it is ce=prehensive in nature and vill strengthen other areas wherein ne discrepancies have been identified.
The progra= vill concentrate sanagement attention en operater training and vill enhance the safe operatien of the Grand Gulf Nuclear Statten.
FJ&L is ce==itted i
to pursuing this progra: te completten in an aggressive and dedicated manner.
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A.
Operator Re.certifiestien In order to verify the level of in plant system knowledge, t.o provide inercased levels of plant knowledge and refresh all control room operators' knowledge and experience with systens in' the physical plant, Mississippi Fever and Light Coepany (HT&t) is taking the f ollowing steps:
All NRC licensed operators vill be orally re-exa=ined in the plant on all systems and will perform all practical factors as listed on the Crand Gulf Contrel Room Operator Qualification Card. Health Physics, Emergency Procedures, and Technical Specification aspects vill be covered in these examinations.
All exacinations vill be documented.
Respensibility:
Plant Manager Isti=ated Completten Date:
January 16, 1984 2.
The Control Room Operator Qualification Card has been reviewed for adequacy and re-issued with instructions indicating the levels of knowledge required:and the responsibilities of the examiner.
Responsibility:- Training Superintendent Istinsted Crepletion Date:
Complete 3.
M?&1 is revieving recent requalifica'tien' and NRC Ideense exa= results te 'identif y any individua. veaknesses.
These veaknesses vill be add'essed f or each individual.
Results of this reviev vill be an-slyzed f or reneric weaknesses and any needed corrective actions udll be incorporated into the training program.
Responsibility: Training Superintendent Esticated Co=pletion Date:
December 19, 1983 4.
On completion of the above steps, all licensed operators vill be evaluated and certified by the Operator Training Evaluation Board.
Responsibility:
Assistant Plant Manager - Operations i.
Istimated Cocpletien Date:
January 16, 1984 l
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5.
Examiners perf orcing oral, in-plant re-exaninstiens vill be CCNS SRO's selected by the Plant Manager and the Assistant Plant Manager -
Oper'atiens en the basis of excellence in plant knowledge.
They vill further be endorsed by the Vice President - Nuclear. These individuals vill be certified by the Operator Training Evaluation u
Board after conducting at least two operator evaluations on each syste=.
Examiners vill conduct one-on-one checkouts.
Responsibility:
Plant Manager Estimated Ce=pletion Date: January 16, 1964 6.
The Vice President - Nuclear, the Plant Manager and the Assistant Plant Managers vill personally observe seme of the exa=inations to verify the adequacy of the examining technique and demonstrated levels of knowledge.
Responsibility: Vice President - Nuclear
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Esticated Cc=p1'etion Date: January 16, 1954 7.
Any weaknesse's identified in the exacinatten of licensed operators ddS vill be addressed and corrected on an individual basis.
If a licensed operater should demenstrate any significant weakness, he vill be re=eved frem licensed operator duty and ce=plete a syste: training p'regrac that' addresses the identified weakness.
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Respcesibility:
Plant Manager Isticated Completten Date:
As required.
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Any generic weaknesses identified during the 1 ple:entation of Itts 7 '
I above vill be f actored into training pregrar improvements.
Responsibility:
Training Superintendent Estimated Completion Date: March 19, 1984 9.
Any procedure deficienefes or ieproperly labeled pane.Is identified during the in plant exae1* nations. vill be docueented f or corrections and forwarded to Plant Management (Plant Manager and Assiettnt Plant Managers) for timely resolution.
Responsibility:
Plant Manager Estiested Ce:pletten Date:
January 16, 1954 A3/127svb4
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10.
STAS vill be' interviewed and re-certified by..the Operator Training Examination Board to neet PSAR require =ents.
Responsibility:
Assistant Plant F.anager - Operations w
Estleated Completion Date:
January 2, 1984 11.
The experienced EVR Shift Advisors' knowledge of CGNS systems vill be examined by the Operator Training Exa=ination Board and their quali-fications vill be certified.
Responsibility:
Assistant Plant F.anager - Operations Isti=ated Co:pletion Date: January 16, 1984 11.
FJ&L corperate management vill monitor the progress of these activ-itses and vill utilize the expertise and assistance of experienced training <persennel from the General Electric Co., Arkansas Power &
Light Co. and. Duke Power Co.
This menitoring ef f ort vill include:
a.
Veekly progress meetings vith the Sr. Vice President - Nuclear.
b.
Psficdic progress meetings with the MP&L President.
c.
Assignment of the Vice President,- Nuclear onsite essentially full-time for the duration of the recertification ef fort.
d.
MP&1 Ouality Assurance audit of the progras.
e.
VJLL Safety Review Co==ittee review of the program.
Responsibility:
Sr. Vice President - Euclear Istimated Ce:pletien Date:
January 16, 1984 1
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B.
Manarement Cdstrel In additien to the CCNS Operator Recertification' Progra= described above.
MP&L is taking the felleving steps to etrengthen the canatement and control cf the eperator training prograr..
u 1.
An experienced Crand Gulf Senior Reactor Operater has been assigned to the Training Department as Operations Training Superviser.
Responsibility:
Plant Manager Istimated Ce:pletion Date:
Ceeplete 2.
An Operations Assistant for Training has been assigned to the Operatiens Superintendent for supervisien of in-plant training.
Respensibility: Plant Manager Istimatef 'Cemple, tion Date:
Cer.pl et s-A senior level e' gineering superviser, vhe is ce:pletely independent 3.
n of plant operations, has been assigned as Project Coerdinator to
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oversee',the i=plementation of the operater recertification pertion of this plan.
He reperts to the Assistant Plant Manager - Operations and this effort censtitutes his primary duty.
Re spensibili t y: Vice ? resident - Nuclear Estir.ated Ce:p*erien Date:
Cc:plete j
4 An experienced training support superviser vill be hired to handle adeinistrative r.atters including records. saintenance of training r.aterial, deve3cp=ent of instructien tethniques and other areas.
i Recruiting f or this positien is being actively pursued.
1 Responsibility: Training Superintendent Esticated Ce:pletten Date:
As soon as pessible
~5.
All eterater training sta1f has been eenselidated in one location in l
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the Inergy Services Center.
Re sponsibili ty:
Trair.ing Superintendent Esti sted Ct plet. den Date:
Ce:plets 1
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An in-plant eperations training support center has been established cutsidi the centrol roc:.
Res*pensibility:
Plant Manager s.:
Is.tinated Cc=pletten Date:
Cc:piete 7.
STAS and the experienced Ek'E Shift Advisors vill renain assigned to a particular shift and vill train en the training rotation with that shift as appropriate.
Respensibility:
Plant Manager Istiested Ce:pletion Date:
Ongoing S.
Plant ad inistrative controls vill be reviewed to ensure adequacy of the divisien of responsibility between the Operartens Section and the Training Section. Discrepancies vill be resolved by Plant Manaterent.
Respensibility:
P3' ant Manager Isti=ated Ccep'letion Date:
January 2, 1984 A third ististant Piant Manager has been assigned te handle suppert 9.
functiens, including trair.ing, thereby providing additienal =sr.agerent a t t e nt i er..
Kerpensibility:
Plant Manager Isti=ated Cc:pletion Date:
Ceeplete 10.
A Cerperate Nuclear Eu=an Resource Manager vill be hired to relieve the 7:sining Superintendent of handling outside activities relatir.g te staffinE the training pipeline, INPO and industry cer. tacts and perser.-
nel-related matters.
Recruiting f or this position is being actively pursued.
Respensibility:
Sr. Vice ? resident - Nuclear IstinskedCenp)etionDate:
As soon as possible A3/127sub7
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MISSISSIFFI PO'=*ER AND I.1CHT CO.9 ANT 3
l CRAND CULT NUCLIAR STATION i
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3 CORRICTIVE ACTION FIANS 4
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OFIKATOR TRAININC PRCCRAM NOVDGER 1983
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AGENDA u
o TRAINING ORGANIZATION J. YELVERTON o
ORGANIZATION MODIFICATIONS FO.R RECERTIFICATION J. McGUAGHY o
RECERTIFICATION PROGRAM J.' CROSS o'
iiANDOUTPROGRAM o
OUESTIONS o
SUMMARY
J. RICHARD n
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ASSISTANT PL ANT MANAGER SUPPORT
- 3. W. Ygiverton u
TRAINIPC SUPT.
D. L. R.rit Training Support Security' i
Operations Training Mxlear Instructor Supervisor Training Supervisor Supervisor Supervisor Yeoant A. Grace',
C. l.hamon
- 3. Jones 2 Censultants 5 "Put 1 Consultant Operations Simulator Instructors Suoervisor MP&L M, gne13y 17 Consultants
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PIPE LINE o
SUFFICIENT PERSONNEL IN PIPE LINE TO SUPPORT THE FOLLOWING ANTICIP,ATED NRC EXAM SCHEDULE m
EXPECTED NRC EXAM DATE NO, OF SR0s NO, OF R0s 12/83 1 + 9' 7
2/84 1
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7/84 6 + 9' 8
12/84 8
8 1985
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.16 16 1986 16 16
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- 1'NSTRUCToR CERT 1F1 AT1oN c
ALLOWING, FOR ATTRITION, F AILURES At.'R PROMOTIONS, THE ABOVE EXA..S SHOULD RESULT IN TFE FOLLOU1NG LICENSE STATUS.
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3'2 1984 18 22 40 19E5 24 15 39 1985 29 15 44
- FENDING OL'TCOME OF TRAlranc' REcoF.Ds REVIEW d
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o SRO FOR OPERATION TRAINING SUPERVISOR
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o OPERATIONS ASSISTANT FOR TRAINING
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o PROJECT M4 NAGER ASSIGNED o
TRAINING' SUPPORT SUPERVISOR o-CONSOLID. ATE LOCATION OF OPERAT]ONS TRAINING o
IN-PLANT DPERATIONS TRAINING CENTER o-5TA's AND SHIFT ADVISORS TRAIN WITH SHIFT o
CLEAR UP RESPONSIBILITIES OF TRAINING AND OPERATIONS DEPARTMENTS o
THIRD ASSIS' TANT PLANT MANAGER e
CORPORATE NUCLEAR HUMAN RESOURCE M;, NAGER
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NRC LICENSED OPERATORS i
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Oual Car'd reviewed for (Training Dept. & Operations)
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adequacy C
Operstors Removed
( A?ti - Operations)
Free Shift Duty Self Study with (Training' Instructors)
Assistance frcn Training Instru:ters
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Perfom Simulator (Training Instru= tors)
Pra:tical Factors v
Exa..iners provided with (Training Dept. and Goers:icn Knowledge Verification Forms md instructions Previous exams revie-ed (Training Department) for wea' cesses ard sub-mitted to Exa:niners SRD Exa. miners -
exa.ine.on (Exa iners}
- .ea:h system Plant P.anager anc Assistant Plant Managers to evaluate exa.minations
NRC LICENSED OPERATORS (Cont'd)
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M;nt, to eva.luate progran by training experts frcrn Ibke, AP&L and GE.
Unsatis factory areas (Examinen)
Identified and cbesmented 4
If significant weaknesses are identified, - operator (Re ertification Board) to be rtreoved frcrn program to attend upgrad: training
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thsstisfactory areas corrected
( Ex ar.ine rs )
and examined Qual Card (Examiners)
Signed
,'Oual Card with Knowledge Verification (Program Coordinators)
Forms Submitted to Recertification coard 1
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NRC LICENSED OPERATORS (Cont'd) m Review bowledge verification (Recertification Board)
Tenns and orally exarn as necessary Recertify. cpalified (Recertification Board) operators Recores reviewed to cete.v.ine oeneric (Training Department) weak areas to facter inte Training Prograh 9
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Exa=iner Mz=c:
Date:
. S[STD.'EME /J.T NO.
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Co==ents fer S or U Unsz tis f a c t ory 1.O EQU1PM %T 1.1 Purpose 1.2 Flos-Fath 1.3 Nor=al Para =eters 1.4 Cc=ponents 1.5 Syste= 3ehavior and Respo'nse 2.0 1ESIT.UMINTATION 2.1 Detector 2.5 Malfunctica 2.3 Cen!rol 7.ce= Indicatien g
2.4 Local Indication i
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WEEKLY PROGRESS MEETINGS t
o PROGRESS MEETING WITH MPEL PRESIDENT
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o VP - NUCLEAR ONSITE o
OA, AUDIT r
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u MISSISSI??I PO*'IR Ah7 I"GET CO.SAh7 GRAht GULT NUCI. EAR S'.'ATION CORRECTIVE ACTION PLANS FOR OFIRATOR TPJ.IXING PR00?J.M NOWMEF. 3 953 e
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CRAND CL*LT NUCLD.R STATION C6 ERECTIVE ACTIONS FOR OPERATOR TRAINING PROGRAM M
Certain areas have been identified -in the Grand Gulf Fuclear Statien (CGSS).
Iicensed cperater training progra: wherein cerrective actions are deemed
'necessary to strengthen the progran.
These corrective acticns, which include actions to prevent recurrence, generally fall into two categories:
- 1) operater recertification and 2) manage =ent centrol.
Each of these major categories is addressed in this plan v.th specific statements delineating the actions to be taken.
MP&L believes this progra= vill correct all identiff ed discrepancies and prevent their recurrence.
Additionally, it is ce=prehensive in nature and e.11 strengthen ether areas wherein no discrepancies have been identified.
The progra= vill cencentrate manaEement attention en operator training and vill
~
enhance the safe operation of the Grand Gulf Nuclear Station.
MP&L is ce==itted to pursuing this progra= to conpletion in an aggressive and dedicated manner.
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A3/127sub2
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A.
Onerater Rec'ertificatien In order to verify the level of in plant syste= knowledge, to provide increased' levels of plant knowledge and refresh all control roem operators' knowledge and experience with systems in the physical plant, Mississippi Power and. Light Company (MP&L) is taking the following steps:
u 1.
All ERC licensed operators vill be orally re-examined in the plant on all syste=s and vill perform all practical factors as listed on the Grand Gulf Control Room Operator Qualification Card.
Eealth Physics, E=ergency Procedures, and Technical Specification aspects vill be covered in these examinations. - All exacinations vill be documented.
Respensibility:
Plant Manager Esti=ated Completten Date:
January 16, 1984 2.
The Control Roem Operator Qualification Card has been reviewed for 3
adeouacy and 're-issued with instructions indicating the levels of knowledge requir.ed and the responsibilities of the exaciner.
i Responsibility:.. Training Superintendent
^
Esti=ated Completion Date:
Complete
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3.
My41 is reviewing recent requalificatdon and NRC license exa= results
~
to identify any individual weaknesses. "These veaknesses vill be addressed for each individual.
Results of this reviev vill be an-alyzed f or generic weaknesses and any needed cerrective actions vill be incorporated into the training progra=.
Responsibility:
Training Superintendent Esti=ated Completion Date:
December 19, 1983 4.
On completion of the above steps, a13 licensed operaters vill be evaluated and certified by the Operator Training Evaluation Ecard.
Responsibility:
Assistant Plant Manager - Operations r,.
Esti=ated Completion Date,:' January 16, 1984 A3/127sub3
5.
Exa=iners performing cral. in-plant re-examinattens vill be GCNS SEO's selected by the Plant Manager and the Assistant Plant Manager -
Operatiens en the basis of excellence in plant knovJedge.
They vill further be endorsed by the Vice President - Nuclear.
These individuals vill be certified by the. Operator Training Evaluation Board after conducting at least two operater evaluations on each u
s y s't e=.
Exa=iners vill cenduct one-on-ene checkouts.
l Responsibility:
Plant Manager
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Esti=ated Cc=pletion Date:
January 16, 1984 6.
The Vice President - Fuclear, the Plant Manager and the Assistant Plant Managers vill personally observe seme of the exa=inattens to verify the adequacy.cf the exa=ining technique and de=enstrated levels of knowledge.
Responsibility: Vice President - Nuclear Estimated Co pletten Date:
January 16, 1984 7.
Any weaknesses identified in the exa=ination of Ideensed operaters viT1 be addressed and corrected on an individual basis.
If a licensed operatdY should de=enstrate any significant weakness, he vill be re=oved fre= license'd operator duty and ce=plete a systen training prbgra= that addresses the identified weakness.
Resp ensib'111ty:
Plant Manager Esti=ated Cc=pletion Date:
As required.
B.
Any generic weaknesses identified during the implementatien of Ite: 7' above vill be f actored into training progra= improve =ents.
Respensibility: _ Training Superintendent Esti=ated Cc=pletion Date: March 19, 1984 Any procedu're deficiencies er improperly labeled pane's identified 9.
during the in-plant exr=inations vill be document ed f e: cerrectiens and f orwarded te'P2 ant Ma'nagenent (Plant Manager and Art:stant Plant Managers) for timely resolution.
Respensitiitty:
Plant Manager Esta=sted Ce:pletion Date:
January 16, 1954 l
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10.
STAS vil) be interviewed and re-certified by. the Operator Training Exa:ination Board to meet TSAR requirements.
Respensibility:
Assistant,P1 ant Manager - Operations M
Isti=ated Ce=7 etion Date:
January 2, 1984 1
11.
The experienced 3WR Shift Advisors' knowledge of CCNS systems vill be examined by the Operator Training Examination _3eard and their quali-fications vill be certified.
Responsibility:
Assistant Plant Manager - Operations Istiested Cc=pletten Date:
January 16, 1984 12..
M?&L corporate r.anage=ent vill monitor the progress of these activ-ities and vill utilize the expertise and assistance of experienced training p'ersennel f rem the General E3 ectric Co., Arkansas Power &
Light Co.' and Duke Power Co.
This monitoring effort vill-include:
Veekly progress teetings with the Sr. Vice President - Nuclear, a.
b.
Pe-iodic progress meetings with the MP&L President.
c.
As signment of the Vice President - Nuclear onsite essentia11
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7 full-rice f er the duration of the recertificatien effort.
Mh&LCualityAssuranceaudit d.
of the program,
M?&L Saf ety Review Cc==ittee review of the progra=.
e.
Respensibility:
Sr. Vice President - Euclear Esticated Cc=pletion Date:
January 16. 198&
A3/l:7sub5
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5.
Mana ge nt Centrol In addition'to the CCNS Operator Recertification Progra: described above.
MP&L is taking the folleving steps to strengthen the management end control of the ep'erator training program.
~
1.
w An. experienced Crand Gulf Senior Reactor Operator has been assigned to the Training Departeent as Operations Training Supervisor.
Responsibility:
Plant Manager Isti=ated Cc=pletion Date:
Co=plete 2.
An Operatiens Assistant for Training has been assigned to the Operations Superintendent for supervision of in-plant training.
Responsibility:
P} ant Manager Istimated Ceupletion Date:
Complete a
3.
A senior level engineering supervisor, who is ce=pletely independent of plant operations, has been assigned as Project Coerdinator te eversee the'i=ple=entation of the operator recertification pertion of this plan.
He reports to the Assistant Plant Manager - Operatiens and this effort constitutes his pri=ary duty.
Responsibility: Vice President - Nuclear' Istinated Co:pletion Date:
Cc:plete 4
An experienced training supp' ort superviser vill be hired to handle ad=inistrative earters including records, maintenance ef training material, development of instruction technicues and other areas.
Recruiting f or this position is being actively pursued.
Responsibility:
Training Superintendent Istimated Ceepletion Date:
As soon as pessible 5.
All oper'ator traininF staf f has been conselidated in one locatier. in the Inergy Services Centes.
Responsibility:
Training Superintendent Istimated Completion Date:
Ce:plete A3/127svb6
6.
An in plant operations training support center has been established cursido'the control roo=.
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Respo'nsibility:
Plant Manager Estinated Cc=pletion Date:
Co=plete s
7.
STAS and the experienced BVR Shif t Advisors vill re=ain assigned to a
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particular shift and vill train ~cn the training rotation with that shift as appropriate.
Responsibility:
Plant Manager Esti=ated Cc=p3etien Date:
Ong oing 8.
Plant ad=inistrative controls vill be reviewed to ensure adequacy of the divisien of responsibility between the Operations Section and the Training.Section.
Discrepancies vill be resolved by Plant Managenent.
Respensibili,t'y:
Plant Manager Esti=sted Cc=p1'etten Date:
Jar.uary 2, 1984 9.
A third Assistant Plant Manager has been assigned to handle support functiens, including training. thereb'y previding addittenal =anagenent attention.
Respensibility:
Plant Manage:
Esti=ated Cc=pletten Late:
Cenplete 10.
A Cerperate Nuclear Eu=an Resource Manager vill be hired to relieve the Training Superintendent of handling eurside activities relating to staffing the training pipeline, INPO and ' industry contacts and person-nel-related =strers.
Recruiting for this positien is being actively pursued.
Responsibility:
Sr. Vice President - Nuclear Isti=sted Cenpleiden Date,-
As socn as pessible i
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, P' ANALYSIS INTRCDUCTION On October 19, 1984 Sharon Connelly, Director,-Office of i
3 Inspector and Auditor (OIA), forwarded to the Commission OIA's report on how Region II (R II) handled problems of falsification of reactor operator license qualifications at Missicsippi Power &
l Light's (MP&L) Grand Gulf (GG) facility (OIA Report).
The Cc= mission had requested CIA's investigation to respond to two issues raised in Congressman Edward Markey's letter dated July 27, 1984 (Attachment I of OIA Report) which resulted from his review of the Office cf Investigation's - (OI) report of March 5, 1984 on the GG matter (OI Report).
The issues are:
l i
(1)
Did R II unnecessarily or inappropriately share information with the licensee?
(2)
Did R II authorize a return to operations or allow continued operation after learning that the qualifica-tions of reactor operators were probably.. falsified and
'the operators potentially unqualified?
l O!A answered the first question affirmatively.
OIA never explic-itly stated a conclusion on the second question, but noted R II's l
knowledge of the GG operators'. licensing status and_the events s
which led to the. removal of four operators from their duties.
By i
letter from Chairman Palladino, the Co= mission sent the OIA I
report to Congressman Markey along with comments from OI and the Executive Director for Operations (EDO).
EDO enclosed separate.
31 v.
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cc==ents frc= R'II*
The ec==ents evidenced a lack of consensus P
among the offices on -the conclusions of -the report.
The Commis-sien then ec==itted to do its cwn review and to respond o
Mr. Markey.
The Chairman directed that OGC review the record and i
prepose for Cc= mission consideration an appropriate response to the Ccngressman.
OGC has reviewed the record. compiled by OIA and OI, as well as the related office ce==ents and correspondence.. Our discussion of these materials is~provided in three parts.
Part I is a.
gelective synopsis of the facts to help in understanding the issues.
In Parts II'and III we evaluated the two issues using criteria that appear to us reasonable for that purpose.
OGC's study of the questions on this basis leads ~it tentatively to conclude thht the answer to.both questions is yes.
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General Factual Svneosis i
In January, 1983, while on an extended outage after a brief period of criticality pursuant to a icw pcwer license, MP&L identified deficiencies in its. documentation of Operator License qualifications.
These deficiencies were recorded in a Plant I
{
Quality Deficiency Report (PQDR).
Such reports are to be 1A chronology of salient events is attached for the ce==ission's convenience (Attachment 1).
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I resolved within 30 days.
R II said it became aware of the deficiencies in February, 1983 in a special GG training assess-ment -- a rare event in NRC history.
The problem centered on missing and ince plete qualifications cards (QC) to which MP&L l
had ec==itted itself to verify reactor operator training.
The deficiencies were carried as an " unresolved item" with apparently g.eneral acceptance of the view that because there were many 1
=issing docu=ents the deficiencies were themselves paper defi-ciencies and not, actual training problems.
According to R II's March 10, 1983 inspection report (March report), MP&L was to have
)
resolved the matter within 30 days.-
I The March report, which appears as Exhibit 1 of the OI Report, f
reflected other training problems and failures.
For example, despite requirements to provide training on facility changes,
"[i]n some instances first knowl' edge of system changes occurred when the operators tried to operate the systems and discovered the changes."
No training had been conducted on over 200 I
outstanding modification and design change packages.
OI Report, Exhibit 1, p. 5.
The March report also recorded other areas of I
For example, instructors were unfamiliar with'GG concern.
systems and could not relate specific examples to aid the students.
The March report notes.that "close supervision /
auditing of contracted training will be necessary to ensure a consistent high level of training is achieved."
OI Report
4
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Exhibit 1, pp.'l-2.
Significant problems in requalification F
training were also cited.
Id., p.
4.
On' August 12, 1983, according to R II official R II agreed during a management meeting to advance the examina-tien date for four operators to September 26 by pestpening ext =ination fer another licensee.
This was apparently necessary to acec==cdate a scheduled Septe=ber 2f restart by assuring there would be sufficien.t operators licensed to conduct operations thereafter.
MP&L had' requested the change and had " assured Rogion II that the candidates would cc=plete their training in an acceptable manner prior to September 26."
OI Report Exhibit 6, p.
3.
Notwithstanding sc=e individual views that reflected in'-
creasing awareness of =cre significant problems after the March repert, R II is not otherwise reported to have given the matter any further crganized consideration until August 15-19, 1983.
At that time it conducted a special safety inspection in anticipa-Ihllllh said that NRC staff members did " low tien of restart.
key" the qualifications card issue (because the licensee pre-sented it as missing documentation) and did not follow up until August.
OI Report pp. 75-76..'
1 I
In advance of restart, R II focused on MP&L's failure to close the unresolved matter in a timely fashion.
R II was then also undergoing a change in its appraisal of the seriousness of the
=atter, =cving toward the positien that it finally adopted, that'
~
5 g&
MP&L had made material false statements (appearing in some quctations as "MfS").
Scme information was given to the licensee about this change en September 23 and pessibly also on August 19
-- how much er to what extent is described or. recollected differently by those involved.
MP&L Vice President McGaughy told CIA interviewers that at an August 19, 1983 exit conference, of R II advised him during the meeting'that the deficiencies concerning the qualifi-catien cards were considered a deviation by NRC and that MP&L naeded to follcw up on the deviation with a letter stating what actions MP&L would take to correct it.
recitation of the same event adds that the licensee was then told that its behavicr could poten^ially be a material false statenent.2-gn R II enforcement panel met Septe=ber 20 and concluded that enforcement action for material false statements should be taken.
A decisien en wi11 fulness was deferred.
OIA Report at 9.
Within four' days, by September 23, R II had essentially decided to seek an OI investigation to support enforcenent decisions on material false statements.
TI, gave CIA l
2 O'Reilly, administrato* m#
James P.
version.
prepared testimony which agreed with reflects that O'Reilly provided very little OIA's report O!A l
personal recollection directly to its investigater.
l Report, Attachment 8.
6 7
On Septe=ber 23 Mh&L officials met with R II' officials in Atlanta F to discuss Aga' stat relay failures "and other topics of current I
interest."
Depending on which account is believed, at or,after the meeting, Vice President McGaughy displayed or disclosed a draft letter prepared for NRC on the qualification card matter.
Either of his own volition or at an R II official's suggestion, McGaughy retained the draft.
MP&L did not supply a written response on the qualification cards problem until after startup.
That response, dated Septa =ber 30, differed significantly from i
the MP&L draft response displayed on September 23 and ultimately provided to NRC at OIA's request during the ccurse of its review.
t R II allowed the scheduled September 25 restart, and on the i.
following day signed the special safety inspection report. The
~
reporu reccgnized that control room QC training requirements had -
not been completed by -18 licensed operators, but that license
' applications submitted to URC falsely listed such training as received and cc=pleted.
Moreover, the licensee knew that the applications contained incorrect information but had made no effort to correct it.
OI Exhibit 2 at 12.
The enforcement natter was resclved in f avor of a civil penalty \\
against MP&L for willful material false statements.
- However, Mr. Markey's.two questions focus on the events of late August and September with respect to actions taken and not taken by NRC's Region II.
His second question asks in addition, about why
.. -. _,. _. - ~ _ _
e 7
Regien II allowed the plant to centinue to cperate and thus F
~
involves the appropriateness of Region II's failure to shut the plantdcwnasitsofficialslearnedmoreinOctoberand},ater about.the lapses in MP&L's training system.
Mr. Markey suggests that those lapses had er should have had implications for NRC's confidence in the actual qualificatiens of reactor operators.
We turn new to examine Mr. Markey's questiens separately.
II.
ISSUE 1 -- Did R II Unnecessarily or Inapp cpriately Share Infor=ation with the Licensee A.
OIA's Findines and Cenclusions CIA's investigation found:
(1) one R II official did advise MP&L officials en August 19 that discrepancies with operator training records were considered to be a deviation and could potentially be censtrued as material false statements; (2) on September 20 there were discussions in R II at which a decisien was made to refer the matter as a material false statement to OI; (3) on Septe=her 23, 1983 at least one R II official told an MP&L vice president that the discrepancies were now being considered to be a material fal'se statement; (4) the OI believed that once there were thoughts of referral to o enere should have been no further discussion of the material false statenents between R II and the licensee unless there were health and safety concerns involved (which he believed was not the case based on at least one statement to him by an R II official);
(5) the OI believed _that the disclosure b'y R II caused the objective ou one investigation to be made known prematurely to MP&L, resulted in an elenent of preparedness by l
/
S certain MP&L of'ficials, and to that extent compromised the investigation; (6) R II believed then and believes now that their
~
actions in sharing information were not improper (moreover, they contend that their actions represent common practice and..are an appropriate avoidance of trickery).
1 4
OIA concluded:
"Given'the facts and circumstances of the September 23, 1983 disclosure, and absent any apparent exigen-cies, CIA believes that the disclosure was not appropriate without first coordinating with OI".
(OIA noted that R II has received guidance concerning the handling of a material false statement but that it lacked specific. direction on what co==unications to the licensee are appropriate when handling any material false statement matter being referred to OI.)3 B.
Other NRC offices' Positions It did so while making clear 0]endorsedtheconclusionsofOIA.
that OI recognized the need for a balance between the "necessary interface from regional staffs to licensees" and the protection of OI investigations from compromise.
OI recognized as well that i= mediate health and safety concerns take priority over investi-gations and inspections.
f 3 Congressman Markey believes from his review of the OI report that the disclosure was hannful in that it led MP=,u,
to refuse to transmit a letter prepared for R II sta..,.
=
4 9
The E00 disagreed with OIA and concluded that Question 1 must be F
answered in the negative " based en (his} review of Recion II's co=ments."
[E=phasis provided.]
EDO supported his conelusion
' solely by statements that "the ecmmunication on September 23, 1984, with the licensee, was deemed appropriate by R II as part of its operational and safety responsibilities" and that OIA incorrectly concludes that there was only minimal safety ccncern.
On the latter point, the EDO stated:
One particular point in the CIA report that requires cc= ment is the statement that the issues were only of minimal safety concern.
Thic is simply not correct.
The ecmpetence, training, and qualification of opera-ters, including the integrity or safety sensitivity of
=anagers who direct their activities, are real safety questions.
Whenever there are such concerns,.such matters must be taken seriously and handled en a
~
priority basis as they were in this instance.
R II said that obviously the licensee had been aware before the R II " disclosure" that the situation involved a potential material false statement; that OIA misquoted a R II official for the preposition that health and safety considerations were
=inimal, whereas, the opposite was true and thus the problem had high NRC safety priority; that, in effect, the problem was o
historical and the facts were essentially fixed and the documents largely in our possession; and that OI never earlier mentioned i
l any concern about R II's "ccmpromise" of its investigation and in j
essence, had no such concern nor any basis for it.
I
~
1 10 J
,e 1
i C.
Criteria for Decision It is undisputed that the material false statement deter ination was cc==unicated by R II to MP&L on' September 23.
Thus the real
~
whether question to be answered is not factual, but judgmental:
that ce=munication was unnecessarily or inappropriately made.
i The answer will depend on whether the communication served or disserved the interests of the public welfare and the regulatory role of the agency' and whether it contravened any current policy.
There are no published criteria for this judgment, but the nature of discussion by the involved offices reveals criteria that they i
believe are relevant.
In large measure from its consideration.cf the respenses of other offices, OGC has' derived-the following f actors which it believes are relevant to this determination:
(1)
Was the staff communication necessary or was it reasonably believed to be necessary for health and safety actior i
at that plant?
(2)
Was the communication in violation of or in
~
compliance with any agency rule, policy or~ practice?
(3)
Was it reasonable to believe that it would have-the effect of likely ccmpromising the investigation?
(4)
Did harm flow ffom disclosure?
(5)
If not short term health and safety, what was the purpose and the nature of-the co=munication?
of these consideraticns, the first would be dispositive if health j
and safety required the disclosure.
If the decision on the i
health and safety factor does not dispose of the issue, the
=
..e 11 Ccmmission will need to determine what weight to give the other r
facters.
D.
Analvsis of Issue I 1.
Additional Facts Relevant to Issue Sofore discussing individual criteria, we detail the varying accounts of the events of Friday, September 23, 1983.
(a)
As~ Presented by OI Vice President McGaughy's interview with OI included no mention He does of the draft letter or the Septenber 23 disclosure.
appear to acknowledge some advice from Julian that facts about Qualifications Cards (QC) were contrary to representations made in license applications.4 4Vice President McGaughy told OI that "in early 1983 he became aware of some gener'ai record keeping problems, (but that] he did not beg'in to learn the details of these 1983 when, in a conversation with problems until August
' he was asked about the CC documentation issue.
some of the initial He sai tnat g informed him that license candidates nad not been issued a QC, contrary to the He advised that he entry contained in their applications.
made additional inquiries regarding the cor. tent of license l
examination applications and found additional errors and l
discrepancies, all m# which wa e reported to the NRC in October 1983."
.c 12 In @ account to the OI investigator he disclosed that the R II chief engineer g"recogni::ed the potentiality of material false statements by the licensee regarding the QC issue," but
" viewed" it as "a deviatien" and so informed the licensee M says that at that time he also said the in August 1983.
NRC could view the QC entry as a material false state =ent.
@ instructed the licensee to notify NRC in writing regarding
(':'he unsigned, draf t letter that Vice President
' the matter.
McGaughy brought to the Septe=ber 23 discussion appears to have been prepared to satisfy th'at instruction.)
1983 he informed the g stated that "about late August Regicnal Administrator of the circumstances of the QC issue as he He said the possibility of material false statements knew them.
was discussed at the Regional Administrator's briefing and some consideration was given to an OI investigation; however, no firm decisien was made at that time."
(Althcugh unclear, this appears to refer to some earlier date than an enforcement panel meeting on September 20.)
According to the OI's account of M statement, on September i
1 23 the next discussien of.the QC issue took place with the and McGaughy was advised that the matter was being
- licensee, regarded as one involving material false statements and therefore
% said Vice President McGaughy had an mere sericus.
l
..e r
13 i
unsigned letter frem MP&L cn this occasien which addressed training recc d discrepancies; however, McGaughy stated, accord-ing tc5llllll( that since the NRC was censidering material false
. state =ents he wanted to make sure all application discre'[ancies 1
were ecvered before he. presented the letter to the NRC.
He said that the licensee felt it had "been misled regarding the sericusness of the issue, and intended to conduct an investigation of the matter before responding to NRC."
OI's Exhibits and Investigator's Note reflect a perceived peculi-arity in M identification of a draft letter date'd October 1983,,which is OI exhibit 44,6 as the September 23 draft letter.
said that MP&L " acknowledged errors and discrepancies in the initial application, including the QC entries, in a September 30, 1983 letter and again during an Oct.
12 meeting.
The OI Report includes the blicwing description of exhibits :
EXHIBIT (44) is a copy of an unissued MP&L/GG letter dated October, 1983.
This document references the MP&L/GG September 30, 1983 letter to the NRC identifying license examination application discrepancies.
It is stated in this letter that MP&L/GG has performed a complete review of operator training files for currently licensed RO/SRO personnel and that deficiencies and discrepancies noted between applications and training files relate to incorrect duration of some courses listed on applications, missing documentation to certify courses listed en applications and ince=plete or missing QCs for "the majority of licensed personnel."
INVESTIGATOR'S NOTE:
According to this letter was personally shown to him by McGAUGEY in September 1983 and -
[ Footnote Continued]'
l
l 14
~
Exhibit 44 references a September 30 letter which was apparently P
dated and signed a week after September 23 when the draft was displayed.
(b)
As presented by OIA OIA gave censiderable attention to the September 23 letter
~
incident.
The accounts that appear in OIA's report are more olaborate and remain conflicting.
By OIA's account, Vice President McGaughy recalled that M and probably O'Reilly read the draf t letter and M subsequent 1'y advised McGaughy to review it carefully.
McGaughy recalls that on Septe=ber 23 he and.another KP&L official met with R II officials in Atlanta.
After the meetine adiourned he advisedjllllll(that he had a draft letter addressing the deficiencies with the QCs for reactor operators which he had been
[Footncte Continued) i==ediately withdrawn whe.7 he (MCGAUGEY) was informed that the NRC was considering a,pplication discrepancies regarding QCs as material false statements.
IXHIBIT (45), a copy of a November 1, 1983 letter from MP&L/GG to Region II NRC, which addresses in detail the three categories of deficiencies and discrepancie-identified in the unissued October 1983 letter.
According to this letter the three categories of dis'.crepancies are:
incerrect course durations listed in applications, missing -
documentauien to verify training listed in applications and incomplete or missing GCs for some license applicants.
CI Repert, at 84-85.
e 15 f
told about at the August 19 conference.
Hesaidthatjd5kN00said he was glad that he brought the matter up because it was under discussion.
He said that % took the letter from him and he b511eved that M brought the letter to Mr..O'Reilly to
' discuss it with him. Wreturned shortly thereaf ter and advised him that although R II had originally considered the matter a deviation it was now considering the =atter in the sense
' that MP&L provided incorrect information to NRC.
"In his (McGaughy's) mind,Che knew that this meant the possibility of a material false statemer.'t."
McGaughy said that further advised him that MP&L should review theit letter carefully and make sure it was on point because NRC was taking a closer look at the matter.
llllllalso told him that his August 19, 1983 advice that it was to be considered as a deviatien may not have been correct.
- Moreover, McGaughy said he had not intended to submit the letter at that time because it had not been reviewed by either his i==ediate supervisor or the MP&L legal staff.
i l
CIA reported that McGaughy "re,c'alled that the draft letter listed l
the names of the individual operators involved with the cualifi-I cations card issue and MP&L did not want to unnecessarily place
[their) names.
in the public domain.
He indicated that for I
16 s'
these reasons the draft letter was revised and a final letter was F
issued en September 30, 1983."7 OIA Report', Interview at 2.
% account of the Septe:.ber 23 =eeting is semewhat different.
He refers to discussions aji the meeting.
Nonetheless it should be noted that several other NRC officials do not recall thcm, nor do they appear in the notes of the meeting which were Later in the circulated and placed in the Public Document Roc =.
interview write-up the following account is recorded:
recalled that! as an af terthought to the meeting, McGaughy mentioned that he had a letter concerning MP&L's correction of the record regarding qualification cards for Ros and SROs at GGNS which had been prepared'for submittal to Region II.
Region II cfficials then advised McGaughy that the issue of the cperator qualification cards was currently being discussed in Region II and that it was new being'to a considered a material false statement as opposed deviation as it had been described at the August 19, 1983 meeting.
McGaughy said that in view of the sienificance that was currentiv being noted by Region II' (primarily M Richard i,ewis, Director, DRP, and David Verrelli, Chief, Reactor Projects Branch fl, DRP) on the issue concernine the cualification cards, he wanted to be absolutelv certain that the information crovided to him by his staff was correct.
McGaughy removed the letter frcm his briefcase to demonstrate the fact of its existence and then put the letter back in his briefcase.
Regicn II officials present at the meeting agreed to his propesal and indicated that it 7The draft discussed here is apparently that displayed Ee later apparently mistakenly identified OI to Ixhici 44 as the displayed draft.
See suora page 14.
8The meeting agenda and other correspondence state interest" would be repeatedly that "other topics of current addressed.
See OIA Report Exhibits to Attachment 7.
- Yet, i'
the meeting summary records no other topics discussed than,
the one specifically designated in advance.
l l
17
,,a was a good idea in censideration of the seriousness of the =atter.
To @ reccliection', Region II persennel present dic not read the letter nor did they
=ake such a request frc= MP&L.
He noted that MP&L representatives did not offer or refuse Region II l
rep'resentatives the opportunity to read the Mette-Later, in the hallway, McGaughy advised him that he believed MP&L had been " sand bagged" by NRC about the sericusness of the qualification cards issue because previous discussions between MP&L and NRC had not represented this matter as a potential material false statements.
He recalled that this meeting was held in Lewis' office at Region II.
OIA Repert, Attach =ent 7 at 2-3.
(E=phasis provided).
d 1Elllll focusds en Vice' President McGaughy's concern whether McGauchv's staff had provided him with correct infor=ation rather than an interest in higher MP&L review, and in detail relates McGaughy's cisplay of the le,tter.
Mr. O'Reilly's prepared schmission states that "during a meeting.
in Atlanta en September 23, 1983, Region II Management Officials infor ed licensee management" that they were considering whether the incorrect operator licenses constituted a material false Mr. O'Reilly also provided one specific piece of statement.
" live" information:
"Specifically, he did not recall any discussiens withM or any, 'other 'R II staf f on September 23,
- 1983, racerning the letter which McGaughy brought to the meeting that day."
OIA Report Attachment 8.
I
18 Nddres,singtheCriteria 2.
P Criterien I.
Was the staff.com=unication en Septe=ber 23 regarding the material false state =ent decision necessary fer health and safety reasons?
Scth the EDO and R II Administrator take the position that the cc==unication was appropriate in light of health and safety The EDO did not provide any specific support for his reasons.
assertion.
R II Administr'ator exp'lained the high safety priority and the seriousness of the issues mainly by asserting that emerging facts cau' sed Region II to force MP&L into "further and deeper inve'stigatiens into their problems en a priority basis in order to provide infor=ation to the Region to make necessa'ry safety judg=ents and. decisions."
He did not explain why it was l
necessary specifically to alert the licensee to consideration of the matter as a =aterial f alse statement af ter there was a likelihood of an OI investigation.
Indeed, R II's Administrator may well be correct in his expressed belief that licensees in his region are very conscious of material false statements and would have been aware of that aspect.*without being told.
But, if that was the case, it would seem less necessary to spell out the material false statements question for the licensee.
This is all the more true if E had informed the licensee of an material false statement possibility on August 19 as he related to OI and CIA.
In that light it is also difficult to understand why MP&L's
.e 19
,aa f
i McGaughy would have felt that they were " sandbagged" by the a ma'terial false statement action, aslIIIllll reported j
change to f
to OIA.
See suora at 17.
a view that health and
.Moreover, numerous censiderations support cafety reasons did not require divulging specifically en September 23 that NRC was censidering enforcement action for 1
=aterial false state =ents.
First and p_erhaps mos't important the reactor was not then operating and were heaith and safety censiderations perceived to 1
bo of high seriousness ~ and top priority it would have been possible to' delay startup.
To the contrary, by permitting R II appeared to make the asst =ption that even though
- startup, there were known deficiencies in training, no short term health and safety issues were at stake.
1 John Michael Puckett, Director of R II's Enforcement and l
Investigative Cecrdination staff, told the OIA interviewer that i
the issue of a possible I'
in a mid-March meeting held at Region II, material false statement was d,iscusse'd and it was resolved that there was not enough infor=ation available for such a decision.
Were the matter of high health and safety significance, it is i
to understand why it was left on a back burner until difficult l
~... -,. _ -. _ ~. _ _.,. _ _. _ - _. _. -
____.,...m
_. _ - _. _ _. _ _ _.. - - -. - ~.,. -, _.. _ _.,. _ ~. _ _. _,.
20 restart was i==inent.9 Mr. Puckett's interview suggests that P
CIA's interpretation was ccrrect that short term health and safety censiderations did not warrant the disclosure.
Albert F. Gibsen, who according to the interview report described hi=self as the " individual to provide input at the Regicnal level with respect to the ce=petence of licensed cperators" at GG,
~
said he could not recall being specifically asked by R II about the cc=petence of. licensed operators at GG.
As we shall discuss more fully below with respect to Issue II, R II's expressed his concerns in Septe=her cd 1983 that perhaps licensed operators at GG were not ready for operations; however, he did not indicate that th'is cencern elicited actions on the part of R II.
- M does not recall anycne in R II asking him to review or verify the
.1 ce=petence of reacter operaters and senior reactor operators as a result of the information learned about training deficiencies.
He appeared to confirm the lack of serious health and safety See also M statement regarding "a six month delav in following up."
OIA Repcrt Attachment 7 at 3.
had explained to OI that R II "did not react ggressively to this problem because the licensee presented, it as missing documentation rather than the failure of applicants to complete QCs."
OI Report at 76.
21 cencern so lcng as the plant did not exceed SS.
He said that in P
Seete=her he. learned that sc=e of the GG licensed operators may net have ec=pleted all of the required training.
His discussion of that informatica did not indicate that it was ce==unicated to or received by him in a fashion that suggested high shcre term health and safety interest.
R II's willingness en August 12 to advance the examination date for fcur GG cperatcrs to September 26, en MP&L's assurance that the candidates would complete their training in an acceptable fashion by Septe=ber 26, at the least. suggests sc=e question about R II's activity in view of their growing doubts about the
\\
t truthfulness of M?&L assertions regarding training.
OI interviews conducted in Octcber with the training contracter, Quadrex, were able to produce information that Quadrex had recc=: ended that sc=e applicants be withdrawn as not. ready but 0
that MP&L had not done so.
Further support for the hypothesis that a health-and-safety-based need was not the moving force for R II's disclosure can be found in the meeting agenda for the peptember 23 meeting and the subsequently issued meeting notes.
Operator license 10Quadrex employees assured R II that they would not have siened the cards if the individuals were " totally unsafe and inccmpetent." g interview, OI Report,
22 qualification was not mentioned as a topic then under r
consideration 'in the meeting which was called to deal with health and safety factors related to the restart of reactor ope ations.
The tcpic was discussed with reference to the draft letter apparently as an afterthought and possibly only after the meeting.
t i
Even though we have raised some questions that were not resolved by the OIA report / in sum it appears that there is sufficient 1
basis to conclude that short term health and safety reasons were l
not sufficient to require R II to ccmmunicate the material'. false I
statement decision to the licensee.
criterion II.
Was the disclosure in ecmpliance' with "or in violation of any agency rule, policy or practice?
OIA and OI, who both believe that the disclosure was inap-propriate, acknowledge that there is currently neither a formal rule nor guidance that would govern staff decisions about disclosure of information related to wrongdoing which might cubsequently be the subject of.OI investigations.
Moreover, here there was no question of divulging the fruits of an OI investigation because none had yet begun.
Thus R II was' divulging only information which it had developed.
J
23 as There is also general agree =ent that agency policy and practice would require that health and safety censiderations govern.
Thus, if R II believed -- whether rightly or wrongly -- that its a'ticns were required for safety, the disclosure would have been c
' censistent with NRC policy.
The dif ficulty here is that outside of R II's efficials state =ents of belief, there is no objective
=easure ether than examining other actions taken by R II to
' determine whether they appear consistent with a belief that health and safety, required this action.
While it is the Cc==ission itself that'=ust make this judg=ent, we think en the basis of the discussicn about health.and safety suora that the balance tips agains't R II's having such a belief.
Ecwever, it appears that agency practice may well permit f'reer ec==unication between region st'aff and the licensees than seems desirable in this instance with the advantage of hindsight.. Even the CI who ec=plained about ec=prc=ise acknowledged that.cc==unications between region staffs and licensees are typically =cre cpen than he would find appropriate.
R II goes beyond its contenticn' that'it is "cc= men practice, when conducting management er enforcement meetings with the licensee, to remind the licensee of the necessity to s=bmit accurate and factual informatien to NRC" and advocates a pro-cc==unication policy.
R II believes it is inappropriate to use " entrap =ent" or
" stealth" to trick a licensee into.=aking additional material i
24 false statements or continuing in unsatisfactory performance for
~
the. purpose of. supporting potential enforcement actions.
OGC l
concurs with the latter principle espoused by R II, but has i
difficulty understanding its relevance to this matter.
"It could I
hardly be dee=ed trickery not to have advised MP&L that a i
material false statement investigation would be underway and therefore MP&L should adhere to the truth.
Moreover, R II has not explained why it is not sufficient to remind the licensee of the' necessity to submit accurate information without discus' sing the imminence of a material false statement enforcement. action.
With special reference to the t
letter brought to R II on September 23, it would appear that R II's more general earlier warnings had availed little.
A's we chall discuss below, changes were made before submitting the i
draft which possibly avoided any additional or continuing material false statement, but it is troubling that so long as the licensee believed only a " deviation" was at issue it may have been prepared to submit some highly questionable explanations.
1 4
On balance OGC finds that this. criterion tips in R II's favor in light of the uncertainty of the guidance on the communications.
i i
.. ~. ~ _,
~~
25 n
l Criterien IIIs Whether it was reasonable to believe that disclosure of consideration of material false statements would ccmprcmise the investigation.
In his post-OIA Report memorandum, Mr. O'Reilly defended R II's disclosure by pointing cut that once an OI investigator arrives at a site or talks to a licensee employee, responsible officials of the licensee will soon know what is going on.
In that way he believed the elem,ent of preparedness that the OI Investigater caid he sensed in some 'of the interviews could be explained.
He thought this was especially true given that the interviewees who appeared to be prepared were interviewed after some 30-odd other interviews had been conducted.
What Mr. O'Reilly states has considerable merit.
This is particularly so in this case where he believed the matter at issue related in large degree to documents already in NRC files in a matter over a year old where the facts were " essentially fixed."
O'Reilly memo, Nov. 5, 1984 at 2.
Indeed, OI investigators apparently openly attended a meeting on October 12, 1983 between R II and MP&L.
According to M Region II advised MP&L that OI was in attendance at the meeting because of the expanding scope and the training discrepancies and Region II's heightened concern about the problem.
The licensee was also informed that during the preceding week Regien II had discussed with
26 OI the pos'sibility of regular or formal OI inves-tigation of this matter.
If a licensee notification of a possible material false statement invesuigation were considered to comprcmise the subseque,n.t inquiry, it is difficult to see how those investigators would collaborate in this by attending the meeting.
Their willingness to attend the meeting, as well as to undertake the' investigation at a later time, suggests that in the circumstances of this case there was no perceived prejudice to the investigation back in 1983.
On the other hand, there are factors which tend in the opposite directicn.
.The bounds of wrongdoing may not be known with assurance prior to the start of an investigation.11 This s.hould temper the confidence one has that the documents of interest are already in N*.C's possession.
Furthermore, even conceding that much of the advantage of surprise is lost when there are many interviews to be conducted at one location, it would seem that an NRC official should reasonably avoid giving up every advantage attendant on surprise or short notice as would be done by provid-ing notice of the intended investigation weeks before it is officially requested.
11Indeed, here this soon proved not to be the case.
For example problems related to training were expanded by a subsequent awareness of the inordinately speedy and
-concentrated ratings session of the qualifications of (Footnote Continued)
~
5 27 Thus while we cannot say that it was totally unreasonable to assume there would be no compromise, and it appears that R II r
could fairly assume that compromise was not a significant factor in'this case, we come down on the side that R II would hav'e been Nonetheless, wise to assume it was reasonable to be concerned.
in light of ambiguous guidance, we would grant this factor in favor of the Regicn.
Obviously, some direction for future occasions is warranted.
a Did harm flow from the disclosure?
l Criterion IV.
The only harm alleged by NRC personnel was the. possibility that disclosure had led to " preparedness" of some MP&L management that I
However, Congressman may have compromised the investigation.
Markey also alleged harm in that the disclosure prevented NRC
~
frem receiving the explanatory document that was prepared for it.
,(1)
Earm to the Investigation i
The OI~ investigator's allegation cf harm to the investigation came late.in the course of events -- well after the' OI report was In addition to R II's point that management would in l
submitted.
i
[ Footnote Continued]
operators who were to take the September 26 examinat that training.
~
4 I
28 i
I any case have known of the investigation frem the other r
{
interviews OI'was conducting on site, Mr. O'Reilly relies heavily and not unreascnably on OI's failure to complain earlier.
In this centext he notes OI explicitly expressed satisfaction with the coeperation between it and the region.
OI's participation in a meeting in advance of the investigation also signals a lack of concern that this case was subject to ecmpromise simply by advance notice.
i Ultinately, this investigation led to enforcement for willful material false statements.
So it could also be argued that even l
if there was a questionable ec= premise, in the end it caused no a
harm.
But, en the other hand, taking enforcement action does not assure that the entire extent of the underlying problems h'as been discovered.
Here the alleged prepared state of seme officials
)
could arguably have impeded fact gathering on how widespread 4
through manage =ent was an awareness of the falsity of MP&L's I
otatements.
i (2) Harm from preventing NRC from receiving the document.
The effect that the disclosure of possible material false l
statement enforcement acticn had en the letter that was, at a j
minimum, displayed to a R II official on September 23 is possibly i
f 1
,----------,-----.-.n....,---m-,n-,
,.,- - - -, -.. - ~, - -,,.,,,.. -
.,n-
,r
-.~.e
.~
i
~
29 9
the'most difficu'lt* matter to resolve.
The accounts of the r
l surrounding events are in conflict, and the significance, if any, of the event has received little or no attention in agency investigatory reports.
The matter, however, raises a generic I
l
' issue of the propriety of the regional officials participating in sessions to. prepare documents for licensees to submit to those very officials or other members of the agency.
Here, the 1
question must be answered whether this nucleus of events resulted in harm and if so,, what the nature of it was.
4
?
12 f
on ec=parisen of the September 30 letter and its draft it is a
i==ediately apparent that Mr. McGaughy was correct when he stated l
that individual names were removed.
However, there were some i
cther deletions that may be significant:
l I
j (1) on page 2 of draft with respect to the first error, i
j that applications implied that cold operator license quali-f fication cards had been completed, the draft had explained:
"The I
i J
i i
1 5
12OIA's exhibits of the draft letter and the submitted Sept. JO letter are attached to this paper as attachments 2 and 3.
OI's exhibit 44, allegedly identified by Julian as the draft letter shown him by McGaughy in September, 1983 l
and then withdrawn, presumably on the September 23 occasion i
under discussion, is attachment 4.
We also attach MP&L's l
Nov. 1 letter'of which exhibit 44 is obviously the draft.
(Attachment 5).
r
L l
30 i
1 ee i
f apparent cause of this error was the inexperience of the training r
staff at that time which led to. poor tracking for completion of i
cualification cards."
i l
That sentence was deleted.
l t
(2) Also on page 2, with respect to errors where it had h,
been represented that various operators had certain training, the draft had explained:
"The apparent cause for these errors is again attributed to the inexperience of the training staff in documenting training records."
i t.'
That sentence was deleted.
1 I
(3) Also on page 2Lof the draft, it was stated:
"A thorough.
review of all license holders training records was cenducted and no additional discrepancies noted."
Y 4
That sentence was deleted.
i l
j Without the disclosure that NR,C was considering the operator j
qualifications matter as involving material false statements, the i
licensee may have' submitted the original letter as drafted.
If i
the disclosure may well have avoided additional false so, statements to NRC.
McGaughy implies that his supervisor's and i.
legal adviser's review could have altered the letter even withcut i
,e 31 One can only speculate whether they would have R II's alert.
cdited out the later deleted statements even had they believed, as the drafter had, that the letter was si= ply explaining what had been done about a deviation.13 In any event, it,is d'ifficult not to conclude at a =ini=um that the drafter had included false statements.
Cne shculd keep in mind the timing -- restart was to occur Septe=ber 25, oper'ator examinations on an expedited schedule were
=arked for.Septe=ber'26.
Indisputably, MP&L had incentive to keep matters on track.
Beyond this'it is difficult to know what significance to attach to the dif ferences in accouts. M inf ormed the lice:isee to recpend in writing to seme of the operator problems en August 19, only a few days after a decision had been cade to expedite some of the MP&L examinations to acco=modate the imminent startup.
He apparently made no special efforts to get that writing before startup or the examinations.
In fact, it was his action in disclosing the MFS that apparently caused the writing not to ccme lk1thoughllllllsaystheletter in until after these events.
13One can also speculate whether MP&L would have sent for NRC review such a letter without supervisory and legal i
But arguably the lack of concurrence would concurrence.
preserve the supervisor and legal counsel from the taint of prior knowledge of any attempted caterial false statement.
32 opisode tock pl' ace at a meeting, no one else recalls the events
~
(except O' Reil.ly in a prepared statement), let alone recalling them asllll((6 does.
(Apparently no investigator asked O'.Reilly 1
directly for his recollection of these events).
In this" light it in hard to knew what to make of M identifying the October draft of the MP&L November 1 letter as the draft he was shown in Septe=ber by McGaughy.
The identification is all the more
. strange in juxtapositen with g statement that he had not
,.The OI investigator's note see=s to be identi-(
read the letter.
fying his awareness of the: strangeness of lllllllllidenti-fication.
However, this awareness is never mentioned up front in the report.
See sucra, n. 6.)
O'Reilly's strong statement about the inappropriateness of' stealth, entrap =ent and such trickery is more understendable if we believe McGaughy's account that. E took the 1etter to
~
O'Reilly and presume that he read it.
Under the circumstances of that date O'Reilly would have realized the import of MP&L's subscribing to such a document and might well have been concerned that it would be perceived as trickery to let MP&L submit it.
This would particularly be true if he was accustcmed to counsel-ing MP&L on what was acceptable to NRC and if that was the purpose of MP&L's bringing the letter to the meeting.
If for the purposes of analysis, we were to assume that R II's disclosure either intentionally or inadvertently prevented MP&L -
l 33 frem increasing its offense, was there any harm?
Mr. O'Reilly's P
i statements suggest that his analysis would provide "no" for an answer, and would conclude that cautioning MP&L against submittal of the letter in light of pending material false statement' issues 2 :
would be no more than advising them of the importance of 4
7 i
submitting accurate statements.
But that cannot be correct.
It i
is one thing to give general warnings about the need for accuracy I
and even advice that scrupulo'us care must be given to certain types of submittals.
It may be yet another thing when one sees
~
ambiguous or inadvertent error to caution clarity.
However, it i
seems quite a different matter to participate in preparing documents that you have required to explain to you the
~
i i.
unacceptable events that have transpired.
While it is difficult to articulate, it may be that the danger is that it will l
encourage lying.
This may occur because if the licensee doesn't.
know how much the recipient of its letter knows, the licensee will be more concerned that his lie will be recognized as such, i
than.if the proposed recipient typically' advises the licensee to cccrect in advance of submission the matters the recipient knows f
or suspects are untrue.
In the latter event the licensee will i
have less concern that additional untruths will be recognized.
f Alternatively stated, the deterrence purpose in assessing any i
material false statement penalty suffers when the licensee can count on the judge to step in and prevent the submittal that i
~
would be recognized as false and would draw the penalty.
.___.__,,_._,,.._,,,_._._,,,._,______.m,__.
34 Accordingly, OGC would find that harm is shewn under this facter.
Criterien v.
If not health and safety, what was the purpose and the nature of the communication?
i Beth OI and CIA appear to conclude that R II's disclosure did not have a health and safety purpose, as that has been defined in the i
j context of this discussion.
OGC believes they are correct as
(
shown in our discussion of the first criterion.
Yet, neither investigation appeared in'any way to pursue an answer to the question of. purpose.
In the case of OI, the question may have been beyond the se' ope of its assignment.
In the case of OIA, the question ap' pears to be central to the issues before it; yet, from the interview reports, it appears that it was never asked.
One reason for this could be that it was so generally acknowledged to be agency practice for this kind of disclosure to take place that i
it was unnecessary to ask.
O'Reilly's statements regarding the openness of his practice would tend to support this view.-
But that support is undercut by~the insistence on the nearly unexplained assertion that high priority health and safety I
l concerns required the disclosure.
It is also undercut by the lack of any contemporaneous record of the advice given at the time of disclosure and the obvious emission of discussion of the disclosure from the Sept. 23 meeting notes.
i
,n
-r-r,---
35 There are numer'ous courses of action which could have provided a regulatcry reason for the disclosure.
For example, were R II to "
decide to delay startup they might have had a reason to explain that the decision was due to concerns about operator triining by virtue of recently adopted beliefs that there had been material Or if R II had decided not to proceed with false statements.
additional operator examinations in light of understandable doubts about whether MP&L had met its commitment that the operators would be adequately trained, R II might have referred Given to material false stata=ent in explaining that decision.
that MP&L had been earlier told of at least a possib'ility of MFS consideration, and'given that R II was not planning to alter the course of startup etc., the facts as presented do not reveal a safety purpose for the disclosure.
Thus, we fail to discern a significant purpose to the cem=unication.
We believe it was most likely incidental information communicated in the course of the open flow described as " agency practice."
Conclusion on Issue 1 As we have. tentatively rated the factors, we conclude that the answer to the first question is that R II unnecessarily shared information with the licensee.
However, this sharing was not clearly inappropriate in light of agency practice, policy or lack thereof, and the circumstances of this case.
36 III. ISSUE O
-- Did R II authorize a return to operations cr allow continued operation after learning that the qualifications of reactor operators were probably falsified and the operator's potentially unqualified?
i A.
CIA's findines and conclusions OIA's response to,this issue is reprinted below in its entirety:
The investigation showed that subsequent to the initial training assessment by Region II in February 1983, the extent of the' discrepancies in the training program became. apparent to Region II over approximately a nine to ten' month period.
From the information developed by Region II during this period, the discrepancies in the training program indicated the problem was management and ad=inistration of the licensee's operator training program as opposed to the competence of the-individual licensed operators.
Although there were varying
. degrees to the severity-of the discrepancies in the training program, Region II knew that the operators involved had been examined and licensed by NRC and believed there was no basis for suspension or revoca-tion of their licenses.
CIA noted that Region II officials t'old the licensee on August 19, 1983, that if Region II knew the training for reactor operator license candidates committed to in the licensee's Final Safety Analysis Report had not been accomplished, the operator exams would not have been conducted until the training had been completed.
OIA also noted that NUREG-1021, " Operator Licensing Examiner Standards,"
which sets forth the eligibility requirements for reactor operator and senior reactor operator license.
candidates includes training prerequisites.
At the time of the September-25, 1983, restart of GGNS, Region II believed that the operators were competent.
However, during a second Region II training assessment conducted from October 31 through November 4,
- 1983, j
Region II concluded that three licensed operators were deficient in their knowledge of the plant.
In
37
~
addition, another licensed eperator had discrepancies in his training records.
Consequently, on Nove=ber 4, 1983, Region II effected the removal of these four operators frem their respective duties.
Finally, the problems identified with the licensed.
operator training culminated with Region.II requiring a recertification by MP&L of the training program.for the cperating staff at GGNS.
B.
Other NRC Offices' Position en CIA Reoort OI did not co= ment on this issue.
EDO's only co==ent on this
",.. the facts as stated by OIA clearly support a issue stated:
negative conclusion.*
'R II does not address this issue directly,
'nor do any of R II's cc=ments in its memorandum seem to speak to this issue.
Chis is perhaps because R II interprets the CIA respense as supporting R II and responding no to the question.
However, Mr. O'Reilly references R II's report, which is the
. prepared testimony that he gave the OIA investigator and which is an exhibit attached to Attachment 8 of the OIA report.
We attach it here for the Cc= mission's convenience..
C.
What is the Question and what did CIA's Resocnse Slenifv?
Before we proceed any further'we think it useful to elaborate briefly on the nature of the question.
The issue as stated contains two questions.
The first is:
Did R II officials authorize a return to operations, and/or allow continued operation, subsequent to learning that the qualifications of GG-
~
(
~
i.
e 38 To that question, it reactor operators were probably falsified?
4 appears from generally agreed facts that the answer is y'es.1 The second question is did R II officials authorize a reYurn to operations and/or allow continued operation subsequent to learning that the operators were potentially unqualified.
Mr.
Markey's letter makes it clear that he cannot understand how R II could have allowed GG to operate after determining that the adequacy of operator training was at best unknown and quite possibly inadequate.
In the sense that if operators are not correctly qualified they must be pot'entially unqualified, R II knew that they were potentially unqualified when it permitted restart and continued operations.
S R II said it believed the operators were qualified -- based
- Yet, on examination and observation.
So, the heart of this question is whether the probability of falsified qualifications and.any information put R II on notice that the other known relevant operators could potentially'b, unqualified in a oractical sense.
Any reservation would be based on the word 14 It is barely possible that word exaggerates "probably."
But R II's position before OI conducted its investigation.
more likely R II did then think that qualifications were falsified, as evidenced by their advice to MP&L that R II,
(Footnote Continued)
~
39 The question may b'e taken ene step further to ask not only
~
whether it put R II on notice but whether it reasonably should have done so.
CIA's memorandum appears to challenge the Read in that context, R II position and implies at least a qualified affirmative answer In essence OIA is contradicting the position that to Issue II.
NRC examination and licensing was sufficient assurance that the operators were qu,alified where the NRC program required certain training as,well.
OIA' notes both that R II officials admitted that they would not have permitted.the examinations to be conducted had they'known that the training was not completed and that NUREG 1021 is clear that passing the examination is not M o r e' o v e r,
enough and that training prerequisites are required.
OIA juxtaposes to the information that R II believed on September 25, 1983 that the operators were competent, the information that in a training assessment conducted only a month later R II was i.e.,
able.to find three licensed operators who were incompetent, deficient in their knowledge of the plant.
These operators then 4
I had to be removed along with another operator who had discrepancies in his training, record.
Finally OIA stated -- in oblique contradiction to the high level of assurance R II claimed i
l l
[ Footnote Continued) would proceed on the basis of material false statements, and OI was to investigate the extent of involvement and whether the material false statement was willful.
40
~
with respect to'the operators' ccmpetence, that R II later determined that a total recertification of the training ' program was needed.
Because it.is a matter of judgment, not fact, OIA lef t it to the Cc==ission to conclude whether the status"of cperator qualifications should have prevented the startup or later caused a shutdown.
D.
Criteria for Decision In determining whether R II's response to the operator qualifications problem was reasonable, the following factors appear to us to merit consideration:
(1)
What was the safety significance of the decision involved?
(2)
What facts were known?
(3)
Did the actions taken reflect reasonable consideration of NRC rules, regulations, and requirements?
e w
,-m
,,s 1.
Safet*y significance F
O'ur discussion cf Issue 1 addressed whether there was a* health and safety reason that required disclosure of NRC's intent to go Here forward with enforcement based on material false statment.
va address a different =atter which is the health and safety
. significance of the underlying matter to the cperation of the OGC fully supports the assessment of EDO and R II that reac cr.
the =atter of cperate'r' license qualification is of high safety significance.
The IDO phrased it'this way:
The cc petence, training and qualification cf cpera-ters, including the integrity or safety sensitivity of managers who direct their activities, are real safety questions.
Whenever there are such cencerns, such matters =ust be taken seriously and handled en a priority. basis...
Accordingly this factor is not disputed and we conclude that the underiv. ine. matter ree.uired serious and c. rioritv treat =ent.
2.
What facts were k,nevn?
According to the OI Report, a former empicyee of MP&L informed O!
at an interview that in addition to notifying MP&L training and cperations officials regarding training discrepancies, he also
[
l l
informed R II employee of these problems in December 7 This infor=ation is nowhere confirmed in 1982.
42 the repcrt so far ts we have been able to determine, nor is it elsewhere explicitly denied.
AlsoaccordingtotheOIReport,k$!!![tcidtheinvestig$ tor about his participation'in the February 1983 training assessment activity.
At that time he discussed with a fermer GG e=ployee, the same man who claims to have given he: infor=atien in Dece=ber
- - 1982, MP&L's legging.cf the PQDRs that related to license.
examinatien applicants.
Munro said then that en his review of severalapplications,'ipb'ecameapparenttohimthatthelicensee had pcssibly sub'=itted ' f alse statements to the NRC, and he discussed this with the group leader; ^+v+ MET -w.% ' 4m received guidance that the matter was to be carried as an unresolved ite=.
Later, en his ieturn to the R II headquarters,M was a=cng those who briefed the Regiona1 Administrator, O'Reilly. M said he co==ented at that briefing that sc=e candidates may not have cc=pleted _ FSAR requirements and that this was so even though their applications showed that the activity was cc=pleted.1lll(l[ said that he understcod frc= that meeting as well that the matter would be
~ tracked as an unresolved item.[
At the time the March 10, 1983 NRC training assessment report was signed, NRC was at the least already en notice thOt the January 11, 1983 PCDR was not resolved.
It is possible that R II staf f -
=e=bers, individually er collectively, were aware of the
4 43-possibility of' falsification, but certainly, it was known that the licensee.had made no attempt to correct the questioned information on the applications.
Further, no training had been cenducted on over 200 design change packages.
And othef' training
~
related problems had been noted.
In addition, R II knew it was dealing with a facility where there had been a lower than normal pass rate on one large group of operator examinations.
OIA Report Attachment 8, Exhibit 1 at 2.
The fail rate could have been sufficient to render suspect the GG training and certification program where.there were other indicators of possible problems, The matter was next tangentially raised in August when the licensee requested speedup of the examination date.
Apparently
~
' knowing that the candidates were not yet qualified, Region II sought, received and relied on verbal commitments that the qualifications would be fully =et before the examinations.
After that came-the August 15 through 19 inspection.
The report of that inspection was not issued until September 26, a day after We believe it-is fair to assume that Region officials startup.
were fully cognizant of the.information in that inspection report by.the 25th,-where the final concurrence and sign off came only a day later.
Accordingly, it must be considered that at startup R II knew the amount and duration of training that had been
44 misrepresented,. nsofar as it was kncwn in that report, and that licensed cperators were therefere deficient in training, other relevant information relates to the August inspection period.
jjll) a R II reactor engineer, related that he was at the facility in July and August, 1983.
At that time he questioned an MP&L cfficial about the status of the PQDR and was told that the reason it had not been. closed was because the licensee had not ec pleted.the search effort. E said that at that time members of the NRC inspection group began to suspect that the matter was
=cre than just a failure to document the completion of require-ments by applicants.
Moreover, he advised that these matters were discussed with the Regional Administrator on their return from the GG facility, presumably in late August.
1 sum qgllllgtoldinterviewersthatduringtheoperationalreadiness inspection f c= August 15 to September 1, they had found that "sc=e of the training had been abbreviated."
He was thus' acknowledging that he knew at'that time that false representa-tiens had been made regarding the extent of the training given.
Ancther R II empicyee, Gibson, provided a safety rationale for neither revoking nor suspending operators' licenses.
Gibson
j l
45 informed CIA that he would have spoken up if he believed that the
~
cperators were not cc=petent.
He said he had "no strong l
evidence" to indicate ince petence, and since there was fuel in the reacter, he thought it was prudent not to suspend or~ revoke.
Other R II personnel alluded to the relationship of fuel in tia reactor to a suspension or revocation decision.
An interview report with Beckham indicated that real consideration was given to suspension or gevocation and that among the decision factors was the fact that fuel /would require attention of licensed operators even while i'n cold shutdown.
Re also made the point that to off-load irradiated fuel would have required direct supervisien by licensed operators.
We do not know whether fewer operaters would have been required and whether there would have been sufficient operators for that kind of staffing had revocations taken place.
R II officials may have faced a Echsen's choice, either to blink their eyes at possible operator lack of qualification or reduce the level of safety by revoking licenses and thus reducing the complenent of available licensed cperators when fuel was in the reactor.
In late September, in discussions related to the September 25 restart,jllllhexpressedconcernsthatperhapstheoperatorswere not ready.
(OIA Report at 11).
He could not pinpoint the deficiencies at that time but apparently had an overall uneasiness.
On October 4, 1983 Region II's Administrator says 1
46 that R II learned"for the first time that sc=e required training-may not have been conducted at all, apparently in contradistinction to substantially abbreviated training.
During i
a Region II training assessment from October 31 through" November 4, 1983, three licensed operators were found to be deficient in their knowledge of the plant and were removed.
In addition another licensed operator was removed because of discrepancies in his training records.
The qualifications of 4 1
of those who had taken the September 26-exams had been completed in a highly unsatisfactory' manner.
On Nove=ber 11, there was a meeting between R II and MP&L On regarding the overall qualifications of operators at GG.
November 18 the licensee agreed to a complete recertification of the training program for the operating staff.
By this time low power testing had been completed.
3.
Did the actions taka.n in the reported factual situations reflect reasonable consideration of NRC rules, regulations and requirements?
Resolution of PQDRs R II's original decision to permit the licensee to resolve the problem that it had itself identified is consistent with NRC enforcement policy.
However, the record is clear that the
i 47 licensee and Region II were both aware that a PQDR should be resolved within 30 days.
TheMarchrepo$trevealedthatthis problem did not stand in isolation but that there were other significant training problems.
Thus, it is questionable whether R II was reasonable in maintaining such a " low key" approach that it did nothing until-August to require resolution of the PQDR.
It is not possible to answer from the record why the PQDR was c11 owed to remain open until September 30 and how R II could continue to believe the training problem was only a documentation question after it was hot resolved in a timely fashion.
Excedition of operators' Examinations From what we discern, additional operators were essential to MP&L's plans for operation after the September 25 scheduled restart.
Nothing suggests that staff's scheduling the examinations in advance of qualification of the applicants bent the rules or practice.
But R II's trust was questionable where it already had substantial reason to know that MP&L has been short-changing the training program.
l
48
\\
l
)
Rescense to Operator Traininc Deficiencv i
i P
(a) Possibility of license revocation and shutdown To respond to the operator training deficiencies, revocation of operators' licenses or the applicant's license to operate were possible under the ' Atomic Energy Act and NRC rules.
10 CFR 55.10 sets forth the requirements for applications for operator licenses.
(Throughout th[s paper we have used the term operator licenses to include senior operator licenses).
Included in the information required pursuant to that section are both information on the education and pertinent experience and the i
details of courses of instruction and training at the facility.
Applications are to be complete and accurate and. signed by the applicant.
See 55.10 (a) (1),. (6) and 7 (d).
Section 55.40 (1) of the same part permits, but does not require revocation, suspension or modification, in whole or in part, fort any material false statement in the application.
Among many_ alternatives that were legally available to R II was revocation of the operators licenses or suspension of those licenses until the qualifications and abilities of the operators could be verified.
Revocation of the operators licenses might have made continued operations an impossibility because reactors may not be operated by unlicensed operators for safety reasons.
e*
(b ),
Testing R II's reasons for not revoking licenses In permitting cperator licensees to retain their licence's R II relied on "the results of the many examinations and evaluations perfor=ed, and on [R II's] co'ntinuing observation of satisfactory performance in the control room."
O'Reilly statement, OIA Report.
This reliance could be read to eviscerate any separate require =ent for experience and training.
In our view this was an inappropriate responsecto.a serious and high priority safety Moreover, theNe is nothing on the record to document the-matter.
nature or standards of R II's evaluations and observations.
The discovery v.ery shortly after restart of several unqualified operators whose removal was required,-would tend to show that R II's reliance had been misplaced.
It is also worthy of note that after recertification training from November to February, 1984, three of 26 operators tested did not pass.
CIA Report at 9.-
This was in addition to 4 already removed for lack of knowledge and 3 who were permitted to take the exam on September 26 but were later found to have serious problems in the manner of completion-of qualification ca,rd re,quirements.
Two had actually failed the September 26 exam.
As related above, another decision factor was apparently the need for licensed operators because there was fuel in the reactor.
Nonetheless it does not appear whether suspension of the-
50 a-operators in que's'tien would have reduced operator staffing levels 8
below NRC requirements, or caused any actual safety problem that was more serious than retention of the operators with questionable qualifications.
The question remains whether safety I
is served by permitting the questionably qualified to remain on 15 duty.
I There was a suggestion that R II had some concerns about the unfairness to operators of revoking their licenses where they had apparently relied on the licensee, at the licensee's direction, It should be noted that to fill in'the'ir cards after signing.
suspension until the matter was sorted out could in large part l
As signers they should have softened the blow for the operators.
be expected to bear some responsibility for misrepresentations.
Otherwise, NRC is sending a signal that a signature on an application has no significance.16 While revocation and suspension are discretionary, we 15 believe that unless the fuel problem admitted no other solution, in a serious and high priority safety matter a need for strict conformity with NRC regulations should have been better perceived l
by R II.
In addition to the discrepancies discussed throughout'this 16 paper, OI discovered that statements of qualification were signed j
by the operater license applicants in advance of the completion l
of the statements of training, in effect rendering the signature,-
a nullity as a guarantee of accuracy.
j e'
51 i
/
Far frcm demonstrating R II's high level of. adherence to.NRC i
regulations and procedures because of sesicusness and priority of the problem, the OIA Report reveals on the part of R II a willingness to temporize in apparent subordination of the matter to the restart scheduling requirements of the licensee.17 The' doubts and reservations about ec=petence that appear in many of the interview reports and the-nature of the subsequent
~
discoveries and subsequently imposed safety requirements that followed se close on the Septenber 25 restart date support this position.
Evaluation of Issue II As the previous discussion reveals, the matter of operator training merited serious consideration and priority.
R II's extended " low key" treatment of the matter apparently placed them in a position where serious consideration could not be accomplished within the time frame that had been established for However the OI Report, and our review, was limited to the 17 two issues raised in Mr. Markey's letter.
This limited-scope review did not, and could not, take into account other actions by R II to promote safety at the GG facility.
Thus we cannot express any opinion on the overall performance of R II in protecting public health and safety.
In this connection, we note that we are aware of other investigations or inspections related to GG but have given them no consideration this analysis.
52 the startup.
R II seemed to take a permissive attitude in order to permit startup and to let its uncovering of the facts and request for an OI investigation lag behind operations.
Attach =ents:
1.
Chronology 2.
OIA exhibit of draft of MP&L's Sept. 30 letter 3.
MP&L Sept. 30 letter as submitted 4.
OI Exhibit 44, MP&L draft letter 5.
MP&L letter of Nov. 1 6.
Region II's Report as it appears in OIA Report 1
m 6
i I
i.
w
.g
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CHRONOLOGY F
June 16, 1982 Lcw power (5%) licensa'is' sued for Grand Gulf.
August 18, 1982 Plant went critical for a very short time then began a 13-=cnth outage January, 1983 Licensee formally identified qualifica-tien operator training file docu=enta-tion deficiencies in a Plant Qualify Deficiency Report (PQDR) (OI Report)
February, 1983 Special GG training assessment by Region II (R II) " surfaced" operator training file documentation deficiencies (OI Report)
March 10, 1983 Training assessment report was signed.
The report reflects that the QC documen-tatien issue will be carried as an
" unresolved itam" pending completion of a documentation search by the licensee (OI).
Unresolved items are to be resolved within 30 days (OIA)
August 12, 1983 According to llllll$ during a management meeting on RIA, an agreement was made to advance the exam date for 4 licensees to September 26 by postponing exams for another licensee.
MP&L had requested the change and had " assured RII that the candidates would complete their training in an acceptable fashion by Sept.
26."
August 15-19,1983 R II conducted special safety inspection August 19, 1983 Exit interview - E tells MP&L problem will be treated as deviation.
Aucust 30-5ept. 11, 1983 R II conducted second part of special safety inspection.
eO 2
Enforcement panel conference - decided Sepcember 20 to pursue enfercement for MFS, willfulness was at issue.
September 23 MP&L - RII meeting in Atlanta told MP&L it would be MFS, prepared "draf t-letter" retained by MP&L.
Sept. 25, 1983 Lew power restart Sept. 26,.1983 Special safety inspection signed --
" reflects that QC training requirement had not been completed by 18 licensed operators.
Report further indicates that the-Cold License Operator QC was listed as training received and complet-ed en license applications submitted to NRC and these applications contained in or known by the licensee to be incer-rect, but which licensee made no effort to correct" (OI)
Sept. 30, 1983 MP&L Letter (final of draft displayed Sept. 23) -- licensee acknowledged that scoe formal training including QCs, listed as completed on Sept. 3, 1981 initial application.had not been -
accomplished by scme applicants.
Oct. 12, 1983 GG officials met with Region 2 to discuss results of the licensee conducted investigation.
i Oct. 18, 1983 O'Reilly formally recuested investigative assistance frcm CI l
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E:.*3 IOT: Grs.:.d Gulf 22:let. Sta. tics U:iss 1 a. d 2 Lockets Nos. 50116 s.:1 50 117 Refar=== AI:bSi/0'2
. File CT65/026c/02T2/0 72 A;;11. i==n for Opera.t=rs a=d
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Seni=r Opers.tcrs's 1. ice =ses g,,
1: th.e lies:se a;-Aies.ti== les:er to Mr. h.ul C:1.11:a, subjett title A;;11:r,10. f:r C;ers.:.=r's a.si Semier Ope.st=r's 1.1:::ses, M:"LS1/002 ds.t ed Septe=her 3,
- 1951, two errors vere =sde is the e=lesed.
a.;;11.:1cas f=r sc=e of the lize=se es..dida.tes.
- les e cr =rs were'
~,.c g d:::===.ed i= a== rds.:ce with ' * -t prc=einres.
Os fi st. arr=r sy;ites is h:1scure(2) line ite= seve, 70.=m1 ' re.1:
1:g, vtich i=;iied tha.: c=1d license cpe.i. er gealifies. tic: cards ta.d.,
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been c =jletard.
X?ilt s review i dicates ths.: the perse=e1 listed belov i-l did not===;1 eta a. g.= ' fies.ics card s.s 1-41:s.,ed is senti:= seve cf s-
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y?al hs reviewed this err:r in deta,11 a..i ha.s deter =ined ths.: it is either necessary nce ;rsctiele to require the a.beve listed perscanel :.:
retreactively ce=;1ete a gas.lifica. tion ca-d a.
snis time.
Sis deter-zir.s.1== is bas ed c their sue: css ful c.c=71c 10: cf the 1 itie.1 tra.ining e
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', R C.c9 '54 14:21 rF*.4. rd r"' W SER PORT C 25CN t'3.
P.C2 M!ssicCIPPI PCNm 4: 1.13HT C.OMPANY D'-
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pr=grs.= s.=d subserae:t li=e:si=g, successful c==;:leti== cf the yes,rly re caz.lificAtic: progra.=, s.=d er;erience gs.1:cd c: the ;1s.=. st=:e 1951.
S e s.;;srs=
cAuse cf.his errer vs.s the berperience of h e t. ai.=1 g sts.fr at thAt -*-- v:ich led T.o p :r tracki:q !=r ce=;;:le:ic: cf gas 11ri cati== cards.
Se Trs.ising B*.a.ff ha.: ' ' tie.ed per=s.ne=t c r.e::1ve s= tic: to preve.=:
sn-occurre::es.
A rev tra.1=ing bs.:-2::1c:, lict: sed 0;erater Tr=
- d g Progra.= !.=;1 - -,s. tic =, 11-S-C2-6, ha.a been iazued.
2.is pro cedu o spet.ifies the methat to be used by es.ch lice:.se castide.e to c=s
,.let e ne q alifict:1== ca.rd.
In s.id h h=, h alac specifies the recaired
===;1et'.c period.
Se i=strue:1:s also ;,..
- 1gs.tes a nev chectsheet f=r ce trs.1=1:s s s.ff's use.
Sis checisheet.
- --'udes a
11:e he= ths.: v' " pr= vide d= u=ents. tic: tha.: the TAlificati== ca.rds a.=d ret.: ired t.rs.i=i=; vaa c==;1sted s.=d s= e=:ry =a.de is the a;;r=;ris.t.e, trs.1 ':s se ri.
Se see::d' error a;;1ies to Inclosure (2) line i+
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bg, which i=;11es tis.
c=14 lies:se ca.:did e.e ha.d re-a d ved a St.:sfer s.=1 Se. o P.eview Cou.se a=d ths.
ca.=dida..e la.d recsived the fellevi:g training:
25 days Pla:t 0;ers.-ic: C:urses
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6 days P.as.:ter Physics, Core S er==, s.si P.a.dcos.
did atte=d the c=urse specifically T.itled Ees..
Tra.=sf er a.=d Ser=.s P.eviev.
E=vever, he received a
'hr
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- tysics,
==re ther=c, rad e = =, hes.t transfer a=1 fluid f1:V 1y his
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p ps.rtici;s. tie: 6 a 11. day Pres' -s's. tor course 1: July 196 s. d a. S day Whiget*;:= cf C re ' = Age c=urse 6 Sep e=ber 1931 a
did not for=4117 sit fer de ah=ve listed c=urses.
!=
eperaticus instructor, he vs.s 6volved 6 :.es.ching his s.a sig:=est as a es.ch cf these coarses.
N o apps.re:S cau.se for these err =rs is agai: attribu ed i.e the 1:ex.
[
perience of the tra.intag s;.s.fr 1: docu=e:.bg tra.ining records.
Se Trsising Sta.ff ha.s i:h is.,ed M.=a:e : corr:::1ye actie: to prevent, s '
- 1.
occurre: es.
?rc:edure 1L-S-02-6 ha.s ben: issued sed provides a.
checilist to 1 clude a 11:e ite= ths.-
required trai=ing !ct license ec=;1e,ed a=d a;;re;ris.te a:tries =a.de 1: the tra.ici=g a;;11cs.::s vss
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re cord.
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A thorough review of s.11 license h=1ders i,rs.1 i:g recerf.s vs.s c==du::,ed
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a,nd - r.: a.d,ditions.1 disere;4::1e vere :
,ed.
Se.vm ite=s discussed s.bove have been revieved by :.he Pia.. Staff a=d 1: has been deter =issi th.s.t these h e=s ha.ve ce i=,.e. ;, oc the ss.fe ope.
ratic. of Grs.=d Gcif Nucles.r Stati==.
a.C.es 's.: :4:c;f EnRL GGrdgA..LKWxns'e-ssmre.
m A2:CM-MissicstPPI PowTR Q LIGHT COMPANY Pa.g e 3
" is 1:fer=stics is being provided in order to clear dis = reps.::1.s 2.1:e se ay;11c.a.01er.s' a.f.
betwee: whs.: vss,. eriginany suh=1 :ed is the Ms.
is acte. ally d=c=ented in the individca.1 tra.ir.isg rec:
cz Siseerely, 1
i J. F. M:Gaus!:7
.,w./:* I/=n cc: Mr. J. 3. Richard Mr. G. 3. ':ay1=r/
Mr. R. 3. M:Gehee Mr. T. 3. Cc =er Mr. Richard C. DeYe==g, Direcser Cffi:e of 1: spec-ics & 2:: force =er.
U. S. h :.l e s.: Regulat=ry Cc -4ssic:
Wa.shi:g==, 0.0.
2D555 M. J. P. O'?.cilly, Regiosa.1 Ad=icistrater Cffice =f 1:spe: ies & Ir.f=reenem U. 5. heles.: Regulatory C=
issi=n Regian ::7 101 Ms.rietta ts., 3.v., Scise 3100
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21arta., Ge=rgia. 30303
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M. Desa.1d Seelham l
C;ers.:=r License 3ra, h Divisic: cf Reacter Lice =sirg U. 5. hcita. Eegulatcry Cc-4 asie:
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t!.S. Euclear Regulatory Commission
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R.egion 11 N.
101 tarietta St., N.V., Suite 2900
'M3 Atlanta, Georgia 303C3 Attention:
Mr. Bruce Wilson
Dear Mr. Wilson:
SU1 JECT: orand Gulf Nuclear St.ation Units I and 2 Docket Wes. 50-416 and 50-417 License No. NFT-13
Reference:
AEQI-81/002 g
Tile: 0765/0260/0272/00$2 Applications for Operator's and
. :ty -
Senior Operator's Licenses AECE-E3/0629
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In the lisense application letter to Mr. Paul Collins, subjee,t title Application for operator's and Senior Cperator's Licenses, Arct-81/DC2 dated September 3,1981, errors were made in the enclosed
', c applications for some of the license candidates. These errors were discovered by E?&L's training staif upon review of t.be applications, N
af ter which tix the trairing stati initiated a Flant Quality Deficiency Report (@R, 7-83) to track the matter to resolution. The PQCat was brought to.t.he attention of XRC sentatives during a special
~~
training assessment conducted by and his team on m
Tebruary 15-17, 1983, and was carried as an unresolved item in the KRC's c2 report (50-416/83-06 and 50-417/83-03). The unresolved item itas 1.ater discussed with the NRC's while the XRO's operatiocal readiness review was in progress.
k The errors, which were the subject of the PQDR, were that some of the perseenel listed in Enclosure I to the referenced letter did not l
complete a Cold License Operator Qualification Card, although it was 2
indicated that they had completed the qualification card in their f*
liee'nse applications Iten 7 of Inclosure 2 to the same letter. MP&L j [,
has reviewed in detail the circumstances which resulted in these errors, and has determined that it is neither necessary nor practical to require
,j ;i the operators, who had not cocpleted a qualification card, to de so at s
L this tis.e.
This determination is based on the fact that these people
[
have successfully completed the initial tr.sining program, have received j
their licenses, have successfully coepleted the yearly requalificatica 1
prestan, and have gained operational experience at the plant since 1981.
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BEE 1 Member Middle South Utilities System gr
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N training cta5I kan initiated Mrmanest ccerectiw cettes taA new troimiag instr i
prevent oimilar occurrences in.the future Licensed Operator Trsiaing Program Impl-taties,14-8-C2-4, has beca i
issued,, Th.is precedure specifies the method to be maed by occh liewaas
%=.4 candidate ta complete the qualificaties card.. la eddities, it alae um N instructies alae g
specifies, the required completi*e period.
This presulasses a new checksheet for the training staff's mae.c M.
qualificat.ien cards and the required traiaing wre com r
E7, g3 the training has been completed.
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Parthermore, during its investigation of the arrers, which were the B,.
AECH-81/Oc2, for certain of the applicanta.
subject of the pQuR, MPE determined that other errors had been made is the list of formal training, item 7 et the Application, Eaclosure 2 to
These additional errors were that the license applications for some of the applicants indicated that a specific training course had been successfully completed by the t.
applicant, when is fact, the course had not been completed, but it a
appears that in each case the subject mattar of the coe.rse had been MFC successfully eevered by other training receiwd by the applicaat.
C PmN is eeotissing its detailed review of each application, which has bees submitted to the 10tc, and of the ' upporting training records to werity
- ~l-s the accuracy of each submittal. MPE will submit to year office a t>>
complete wrification of each applicant's records, identifying and~j F- -E*-
resolving each discrepancy by October 21, 1983.
Bg De training staff has initiated permanent corrective action to Procedure 14-5-02-4 has been issued and prevent similar occurrences.provides.a checklist to include line itema ve hires training for license applicants has been completed and ret
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appropriate entries to be made in the training records af ter training, '.-
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' courses have been completed.
ye The discrepancies discussed above have been reviewed by the plant staff and it has been determined that these items have no impact en the
- o This letter is being U
safe operation of Crand Culf Nuclear Station.
provided in order to notify you of discrepancies between
~
documented in the. individual training records.
MPE appreciates the importance of this matter and since the time 31@
vban the errors in the Applications were first di_ covered, it has given
,[ !j additional management direction to the preparation of Operator and l3 Senior operator License Applications and has established procedures to 1
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ensure that these types of errors do not occur in the future.
}&
Sincerely, l
n s*
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Mr. J. 3. 3.1ch.srd M r. R. 3. RicC,e kee.
Kr. T.1. Commer Mr. G. 3. Taylor Er. Rich.ard C. DeToung, Directer Off4cs of Inspection & T.aforcement g
U.S. Nuclear Regs1 story Commission E shington, D.C.
2C555 f*
Kr. J. F. O'Reilly, Regional Administrator U.S. Nuclear Regulatory Commission Region II 201 Mariett.s St., N.W., Suite 2900 Atlanta, Georgia 303C3 Mr. Donald neckham y
Operstar License Branch eE Division ef Raaeter 1.1eamatag h
U.S. Nuclear 'ILegdstory thf seios Washington, D.C.
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Er. T. I. Closinger Mt. T. E. Reaves Mr. C. E. McGey Er. J. W. Telvertan Er. A. E. Smith Mr. A. C. Wagner-Mr. C. C. Eayes Er. E. D. Nous ton -
Er. J. F. Pinto Er. L. F. Daughtery Er. E. D. Archdeacon Er. L. F. Dale Er. A. C. Pearson (2)
Er. A. 8. McCurdy Er. D. L. Bunt (GGS) y Er. J. C. Cesare Eiddle South Services Eme. lear Activit.ies O
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Melping B uilc' Mississippi P. O. B O X 16 4 0. J A C K S O N, MIS SIS SIP PI 3S205
.r a ucs e. u e v. a October
,1983 U. S. Nuclear Regulatory Coussission Region II 101 Mariet:a screet, N. V.
Suite 2900 Atlanta, Georgia 30'303 Attention:
Mr. J. P. O'Reilly, Regional Ad=inis::stor
Dear Mr. O'Reilly:
Grand Gulf Nuclear Station SU3 JECT:
Unit 1
~~.
License No. NFT-13 Docket No. 50-416 Applica: ions for Operators and Senior Operators License AECM-83/
Mississippi Power Light Company notified you by
- letter, AICM-83/0629, dated September 30, 1983, of errors made in - previously sub=i::ed applications for Operator's and Senior Reactor Operator's Licenses. This subject was also discus sed with you in your Atlanta offi'ce en Oc:ober 12, 1983.
This let'ter s
--ar'izes the problems dis-
~
cussed a=d our proposed actions to resolve this matter.
MP&l, performed a ensplete review of training recorda for all cur-at Cra=d restly licensed Reactor Operators and Senior Reactor Operators Gulf, and identified discrepancies between the license application and the training records.
A co=plete list of identified proble=s associated vi:h each application is enclosed- (Enclosure 1).
The discrepancies can be categorized into three general problem areas:
not as long as indi-(1) Training duration (length of course) was cared on the application.
The following discrepancies were
. identified in this area:
i (a)
Several applications listed one week of Mitigation of Core Da= age which was actually only four days long.
Letter AECM-81/330, dat ed August 28, 1981, from MP&L to.'
Harold Denton, comitted to 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of Mitigation of Core Da= age.. Although only thirty-two hours.of docu=ent-s ed training was given in this module, mudh of the matersal norm:11y covered in the Mitigation of Core
MISSISSIPPI POWER & LIGHT COMPANY J. P. O'Reilly,.
Page 2 ArCM-83/
in other courses.
n e eight week Damage Course is taught irieludes modules Grand Culf Technology or Systems Course ceutron monitoring and vessel instru=entation.
.on fu el,
Individual courses in Heat Transfer and Fluid Flow, E=er-and Chapter 15 of the TSAE are taught gency Procedures, in individual course and are major topies in the Mitiga-Af ter completing the above tion of Core Damage Course.
a major portion of the' Mitigation of Core noted courses, is a repeat and can be covered in a short Damage CourseA review was conducted of the course material time span. for this four-day course and substantiated that and exams the material was adequately covered.
No further action.
is deemed necessary for this discrepancy.
ne present course is given over a two week period.
(b)
Several applications listed a thirteen. day Plant Opera-tiods Course addressing the FSAR, IOI's and EPP's and a seven day. Plant Operation's Course addressing Technical bined fifteen day 5pecifications which was given as a com course.. ne thirteen days specified were actually taught and the seven day, course was taught in five in een days The course was placed in the Training Records as a days.
The duration of these courses were fif teen day course.
adequate and 'the required material was covered in the shorter courses.
No further action is deemed necessary for th'ese courses.
(c)
Several applications listed a twelve day simulator re-accomplished in ten days.
the dates fresher, but was the training was to be accomplished was shown on the that as 11/12-11/23/82.
These applications were application scheduled submitted in October 1982, indicating this was Only ten days of training was trai=ing to be complaced.
ne two week simulator refresher was of ade-
~
performed. length, thus no further action is proposed on this quate issued.
(d)
Several applications listed a 13 day Plant Operations ne twelve day course Course which was actually 12 days.
no action adequately covered, the required material ' thus for this ite= is deemed necessary.
One application listed a fourteen day si=ulator refresher (e) training course which the records indicate was thirteen satisfactorily completed and the The course was days.
No fur-application should have indicated thirteen days.
ther action is deemed necessary for this ites.
nis application also noted a one week Mitigation of Care (3runswick, Cp6L), but the training records indi-Da= age care 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of training was received.
No further justified in item action is required for this it e=
as (la). above.
De material covered ner the exam was re-at CP&L.
viewed as this course vas
-_. ~ _ _ _ - -
J.P.CRemy MISSISSIPPI POWER & LIGHT COMPANY Page 3 AICx-83/
l s application listed a one day QA Indoctrination Course (f)
On' which only lasted one hour.
his was an error in the application as the training records clearly indicate the one hou'
- course, nis mat erial can be satisfactorily addressed in this time frame; thus, no additional, actions are deemed necessary.
(g)
Three applications listed a six week East Transfer and Fluid Tiow Course.
A three week course was entered twice in these applicants training records, and when the appli-i cation was prepared, the duplicate courses were shown on the application as s h weeks.
De Training Records for j
these individuals have been corrected.
The three week course adequately address this material, and no further a.ction is deemed necessary for this item.
(2)
Docu:sentation does not exist to substantiate certain training listed on the applications.
ne following discrepancies were identified in this area:
(a)
Several applications listed a six day Reactor Physics, Core Thermo and Radeon Course.
There are no records that document this course.
Each of these applicants had other training in each of these subjects.
Both the MP&L and NRC exams test this area.
Due to these two factors, no additional training is deemed necessat7 to address this training.
(b)
Several applications listed a three day Heat Transfer and Fluid Flow Course, yet doessme= tait on does not substan-tiate this trianing.
Each of these applicants had other training which adeguately addresses this material.
nis material it also well-covered on MP&L and NRC exa=s:
thus, no further training is deemed necessary.
(c)
One applicant listed a five day.Eitigation of Core Damage Course.
His training records indicate he attended a total of four days but did not take the exa=.
This applicant will be required to review the material and pass an exam covering the course material.
(d)
One applicant listed a twelve week Cold License Training Course /Crand Gulf Technology on three different applica-tions.
ne training records indicate that he did not ob-I tain a passing grade on week 10 of this course. Prior to a
his third application, he did satisf actorily complace l
twenty-one week License Operator Izan Preparation Course vhich covered this nac erial.
No.further training is,-
deemed necessary.'
(e)
One applicant listed a seve= day Plant Operations Course
\\'-
covering Technical Specifications and a five day Plant
f
.7. F. O'Railly MISSISSIPPI P WER Ak LIGHT CMPANY l --
Page 4 AZQi-33/
l Operations Course covering Technical Specification on his original applicatien in September 1981.
He did. not pass e
' the exam en the seven day course and there is no record j
of attendance for the five day course.
He did not pass j
hi's NRC exam, and submitted another application in October 1982, which eliminated the seven day and five day courses.
There is no record of this applicant being
.l trained in the Tech Specs.
He will be required to review this material and satisf actorily pass an exam.
(f)
One application listed a twelve week Grand Gulf Tech-nology - Cold License Training Course.
There are no re-cords to verify week 11 or 12, and week 9 is incomplet e.
This same application listed a three week Eeat Transfer and Tiuid Tiow Course, but there are no records to verify this.
This training material ves covered in a lat er tvesty-one' week License operator Exam Pr'eparati6n Cours's, which he a~atisfactorily completed.
No further action is deemed necessary for this discrepancy.
(g)
One application siisted a two week pre-simulator course, record to verify this.
This applicant but there is no f ailed the NRC exam.
Another. application has been sub-I mitted for this applicant to take the RRC exam in December 1983.
He has successfully passed a two and one-half week simulator refresher course since the first application.
No further action is deemed necessary for this discrepancy.
(h)
Several applicaticus listed self study retraining or re-performed after views.
This self study retraining was the individuals had failed the NRC exam.
These in-dividuals had already coEpleted all r'equired training to take the NRC exam thus, no further training was required.
This study was to meet the individuals needs. No records are maintained for this type study.
This is considered satisfactory but is documented in this report due to the entry on the application.
(i)
One applicant lised several courses on his application that he was given* credit for teaching rather than taking.
j There was no notation on the application to this fact.
His training records will.be updated to indicate this.
Credit for teaching is considered adequate, and no fur-ther action is deemed. necessary.
(j)
One application that was submitted in 1982 had several proble= sreas.
MPEL withdrew this application at that time due to the individual's training not being complete, and he was r.o t given a NEC exam.
No further action is deemed necessary for this item.
a
Y* I*
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MISS1551PPI POWER & LIGHT COMPANY Page 5 AIC'.-83 /
(3)
For tis ajority of licensed personnel, Qualification Cards required by the were not completed, or cannot be located, as r
TSAR and as i=dicated on the license applications.
In addi-completed during this tion, the Qualification Cards that were time fr'a=e did not include a Practical Factors sections as re-4 quired by the TSAE.
he Practical Tactors Section portion of the Qual Card has been established for each licensed operator.
Records of cour-placed surveillances were reviewed and for those surveillances that had been performed by, or under the direction of a li-censed operator, that operator's Qual Card was signed off as satisf actorily completing that practical factor.
The Opera-tion's Superintendent has authorized specific Senior gaaetor This Operators to sign off the additional practical factors.
authoriation was based on the 510's past experience and/or ex-postire to the surveillance procedure.
Each licensed" opera' tor is in the process of completing this practical factors section prior to full power licensing.
The Enowledge Factors portion of the Qual Card is presently being reviewed.
Where documented training exists to sub stan-tiate the Knowledge Factor has been previously reviewed in other trai=ing, his Qual Card vill be updated and credit taken for this previous training.
Where areas exist that training-cannot be substantiated, then the Knowledge Tactor portion vill be satisfactorily complaced.
The majority of the problems noted in this report are the result of traini=g record problems that occurred prior to and during 1981.
There has been a vast improvement in the training records since that time.
The NRC application form, has helped to, eliminate application errors.
For future applications, the preparer vill sign a cover sheet stati:ig that the records have been reviewed to substantiate the training-listed on the application.
The Operation's Training Supervisor or Training Superintendent will independently verify the information and sign a s.=ilar seatament.
ne investigation and identification of these problems was perfe -
i ed by our Training Department.
.T. have requested our Quality Assurance completely. independent review of these records organization perform a
for added assurance that every problem has been identified.
This audic is in progress and should be completed during the week of October 24, 1983.
I hope that this information will re solve your concerns of this problem.
Yours truly, 1 s, JW/ C&JJF. /shb M
s w ssunt m
o J. P. O'Railly MISSISSIPP! PCWER & UGHT COMPANY Page 6 AICM-33/
1 Mr. J. 3. Richard cc:
Mr. 1. 3..McGhee Mr. T. 3. Conner Mr. Richard C. DeYoung, Director Office of Inspec: ion & Enforcemen:
U. S. Nelear Regula:ory comunission Washingto=, D.C.
20555 Mr. C. 3. Taylor South Miss. Elec:ric Power As sn.
P. O. Box 1589 Eat:iesburg, MS 39401 G
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