ML20132E812
| ML20132E812 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 08/18/1984 |
| From: | Mark Resner NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | |
| Shared Package | |
| ML20132E314 | List:
|
| References | |
| FOIA-85-419 NUDOCS 8510010176 | |
| Download: ML20132E812 (6) | |
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U. . .ducLE AR REGULATORY Commission Of fice et inspector and Av:hter
,.. c . . .. i, .. .A. .... Au ra st 18, 1984 Report of Ir.terview Division of Reactor Eafety (DRS),
Division of Reactor Projects forner iuclear negu atory Comission (NRC), was23, interviewed 1953, (DRP), Region 2 , U.S.
relative to the facts and 'circunstances concerning a September neeting at Region II between Mississippi Power and Light (MP&L) and Region officials. He was also interviewed with respect to the facts and circum-
- stances pertaining to discrepancies in Reactor25,Operator 1983. (R related course of events which led to a restart of GGNS on September He provided the following infomation:
23, 1983, Generally, the meeting between Region II and MP&L on September concerned Agastat Relays and was characterized as a management mee opposed to an enforcement mee. ting.
conducting' management and enforcement meetings with the licensee, to remind the licensee of the necessity to submit accurate and factual infomation to NRC. He noted that .NRC's enforcement policy regarding Material False Statements (MFS) is; routinely meetings involving corporate l.discusseevel personnel such as the Se -
meeting. -
23, 1983, meeting was to The thrust of Region II actions at the Septenber identify opportunity.
potential safety problems and to have them resolved NRC's increasing concern about the problems associated with reactor operator licensing examinationHeapplications, they did not consid recently asked the Office of Investiga-actions are routinely practiced.
tions (01) investigator who handled this matter if he believec Region II's l 23, 1983, meeting ccepromised or hindered the 01 i actions at investigation.the SeptemberThe 01 investigator denied that Region II's actions com-promised the investigation.
The events at the September 23, 1953, meeting concerning an MP&L letter addressing discrepahcies in the Reactor Operator Tr '
meetings. Events relating to the .presentatien by 19, MP&L of thebetween 1983, meeting letter concer
, discrepancies in ROTP were precipitated by an AugustAt that meeting, Re
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per se, the licensee had comitted in their Final Safety' Analysis Repert (FSAR) to complete qualification cards. Consequently, their actions, or lack cf action in that regard was considered to be a deviation and potentially an MFS, Region II.. officials further advised the .lic'ensee that if Regicn II had known when the applications for the reactor operator examinations were sub-mitted that MP&L had not accomplished the training as described in the FSAR, the cperator exans would not have been conducted until the training had been
. completed. Region II also reminded the licensee that in a accordance with NRC enforcerent policy, en MFS is a potential c;ivil penalty matter and they must devote prompt management attention (investigate) to determine the nature, scope, and cause of the discrepancies with the qualification cards as well as any other training deficiencies of licensed operators at GGNS.
Concerning the reliance of Region II upon the licensee to provide further details (an investigation) about the discrepancies on the cualification cards i when Region II was considering the actions by the licensee or lack of actions to be a potential MFS, he noted that based on the information available at that time Region II did not believe MP&L management intentionally submitted the false applications. He learned from his conversations with James McGaugby, Vic'e President, Nuclear, MP&L, concerning this matter, that .
McGaugby signed the MP&L letter transmitting the false applications to NRC without verifying the information. McGaughy relied on his staff in this ,
matter. Therefore, Region II believed that if they brought this problem to McGaughy's attentien it would properly and promptly be resolved. He noted that wtien the overall MP&L training program for R0s and SR0s became suspect, it was incumbent on MP&L to investigate and report any deficiencies .to
' NRC as well as take'necessary corrective actions. -
Digressing to the August 19, 1983, meeting, he recalled that towards the close of the meeting, Region II advised McGaugby that they wished to again promptly meet with MP&L to review the results of MP&L's investigation into the licensed operator training discrepancies. McGaugby advised Region II that he would give the matter prompt attention, however, based on the findings of Region II's February 15 through 17, 1983, assessnent and follow up inspection at GGNS, he had concluded that the situation was not that serious.
Digressing to the September 23, 1983, meeting, he recalled that as an after-thought to the meeting, McGaugby mentioned that he had a letter concerning MP&L's correction of the record regarding qualification cards for R0s and SR0s at GGNS which had been prepared for submittal to Region II. Region II officials then advise.d McGauchy that the issue of the operator cualification cards was currently being discussed in Region 11 and that it was now being considered an MFS as opposed to a deviation as it had been described at the Aucust 19, 1983, meeting. 'McGaugby said that in view of the significance that was currently being noteo by . Region II (primarilyM Richard Lewis, Director, DRP, and David Verrell1, Chief, Reactor Projects Branch #1, DRP) on the issue concerning the qualification cards, he wanted to be absolutely certain that the information provided to him by his staff was correct.
McGaugby removed the letter from his briefcase to demonstrate theIIfact of its existence and then put the letter back in his briefcase. Region officials
+ 4+ was a good oresent at the meeting agreed to his proposal and indicated + -
To idea in consideration of the seriousness of the matter. er nor did they recollection, Region 11 personnel present did not read the le make such a request from MP&L. He noted that MP&L representatives did not
offer or refuse begion 11 representatives thatthaLater, he believed MP&L in the hadhallway, been sand bagged" by NRC about the seriousness of the qualification cards i issue because previous discussions between.MP&L and NRC had not represented this matter as a potential MFS. He recalled that this meeting was held in Lewis' office at Region II.
An October 3,1983, documented sumary of the September 23, 1983, meeting (Exhibit 1) does not indicate the discussions and actions relative to the MP&L letter in question. Sec.ause, as previously alluded to, events regarding the latter occurred after the femal meeting had adjourned. The October t 983.
su=ary was written by _W, a former Region II ' ~ ~
assigned to GGNS.
' Generally, with respect to the discrepancies in ROTP and the related course of events at GGNS which led to the restart of GGNS on September 25, 1983, the magnitude of the problems regarding the training progressed over a period of time. Initially, Region II believed that the deficiencies were a matter of missing documentatinn resulting from poor file naintenance by MP&L. As time prcgressed from Region II's initial training assessment of RO and SRO training in February 1983 to a second~ training assessment conducted in November 1983, the prcblems associated with the training program expanded. They included not only missing documentation, but also indications that some of the P0s may not have had all of-the. required training as described by MP&L in the RO exam applications. .- .
More specifically, during a training assessment inspection 50-416/83-Ob conducted from February 15 through 17, 1983, Region 11 first became aware that all of the supporting records for previous licensed operator training could not be located. MP&L advised Region II that they were aware of the missing documentation and showed Region 11 a number of MP&L Plant Quality Deficiency Reports (PQDR) documenting the problem. The PQDR characterized the problem as missing or misplaced documents. MP&L comitted to Region 11 that they would resolve the problem by February 23, 1983. Region II gave credence to the licensee's explanation because the records were in a state of disarray. In accordance with NRC practice, because MP&L had identified the problem in the PQ3R and had comitted to resolve the problem Region II considered the matter to be an unresolved inspection item pending a further review of the licensee's actions in a follow up NRC inspection. He is aware that resulting discussions within Region II involving James P. O'Reilly Recional Admini r+r John 01shinski, Director, DRS, M Operations Branch (03) DRS, and Albert Gibson, Chief, OB,.DRS, explored the possibility that MP&L made an MFS with respect to the discrepancies in the operator training. It was resolved from these dis-cussions that based on the,information known at that time, it could not be concluded that MP&L made an MFS.
l The unresolved item concerning the missing documentation was next reviewed by Region II during an Operational Readiness Inspection (50-416/83-38) from August 15 through September 1, 1983. Concerning a six month delay in follow-ing up on this matter, he noted that the safety significance of this problem I was negligible in that the reactor (GGNS) was in a state of cold shutdown for a maintenance outage since August 18, 1982, and was not expected to restart for approximately six to nine months. He explained that Region II had issued l
.s a Ccnfimation [8 Action (CCA) letter on October 20, 'IgS2, in ccnnection with the shutcown, and i.t prevented MP&L from restarting GGN5 without Region II's concurrence. Also, Region II's work loed included activities associated with other reactors that were operational and required nore attention than GGNS which, as noted, was in a state of cold shutdown.
During this cperational readiness inspection, Region 11 found that the pur-ported nissing documentation concerning RO and SRO training could not be located and that some of the training had been abbreviated. The focus of the inspection was then on incomplete RO qualification ~ cards because of the discrepancies in them concerning previous applications for operator licensing examinations to NRC. The failu.e by MP&L in this regard was censidered a deviation by Region II and so stated to MF&L manecement during an exit con-ference on August 19, 1983. At that meeting, he advised the licensee that when they found that the information previou @ sly submitted to N -
correct, it was incumbent upon them to assure its accuracy. He further
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advised then that this matter could be consid2 red by NRC as an MFS. Ine MP&L representatives present were Jack Richard, Senior Vice President, Nuclear, and .
James McGaughy, V. ice President, Nuclear, and they verba'.ly comitted to Regien 11 that they woul.d correct the record by way of a femal letter to NRC.
During the weeks folloding the exit conference, Region 11 discussed the inspection findings thoroughly and again entertained the possibility that the
. licensee comitted an.EFS in this matter. There was some discussion as to whether or not..the matter should be referred to the Office of Investigations (OI), NRC, for a femal investigation.
On September 23, 1983, as described above, there was a meeting at' Region II between MP&L and.NRC.
On October 4,1983, MP&L and NRC representatives met at the Region II offices to discuss cther issues concerning GGNS. At the conclusion of the meeting, the licensee advised Region 11 that they wished to update the NRC about progress in their investigation concerning the deficiencies in the licensed operator training program. They infomed NEC that in addition to the problems of inconplete cualification cards, it was possible that some of the R0s had not received some of their training because no record of some of the training couic be found. Region 11 advised the licensee of _ their increasing concern with the problems regarding ROTP.
On October 12, 1953, MP&L again met with NRC at Region 11 to discuss MP&L's investigation of the discrepanlies with ROTP. Region II had reouested that investigators froni OI attend that meet James Y. Vorse, Director. OI, Atlanta Field Office..an of his (Vorse's) staff attended the meeting. Region 11 advised that I was in attendance at that meeting because of the expanding scope with the training discrepancies and Region II's
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heightened cencern about the. problem. The licensee was also informed that during the preceding week Region II had discussed with OI the possibility of requesting a femal 01 investigation of this matter. On the following day Region II management met and decided to recuest a femal investication by 01.
On October 17, 1983, Region 11 verbally requested thaMr M 01, and Vorse begin an investigation of this matter. This verbal request was followed by a femal letter of request dated October 18, 1983,
l a* a From Octcber 3,1 thrcuch November 4,1983, Region 11 chnducted another Training Assessment Inspectten (50-416/83-53) of R0s and SRos at GGNS. The, purpose of the inspection was to detemine what corrective measure by MP&L had been taken to preclude future errors in licensed RO applications and also to verify that all previously licensed ce~ possessed sufficient knowledge to safely operate the reactor. He noted that as a result of the inspection, it was fcund that four licensed cperator candidates examined in September 1953 fer SRO licer.ses had been rushed thrcuch their training. For example, one cf the qualification cards had over 100 sign offs on oral examination of knowl-edce en reactor systems accomplished in one day. This raised serious questions in Regien II about the adequacy of training at GGNS. Only portions of the normal NRC simulator and plant walk through examinations had been given to 13 operaters. Three licensed operators, upon questioning by members of the NRC inspecticn team, exhibited inadequate knowledge of the plant. Ten opera-tors examined by the NRC inspection team were deemed to be fully adequate.
Three licensed cperators who exhibited inadequate knowledge of the plant were rem:ved from their respective duties on November 4,1983, following the exit MP&L sub u quently documen+.ed these interview between MP&L and Regien II.
acticns by way of 'a November 10, 1983, letter to Region II, Because low power testing had almost been completed, and based on Recion II's observations of the licensed operators at the plant, GGNS was permitted to operate until November 8,1953, when the plant was taken to a cold shutdown. He noted tha't on November 7.1983, fomer Comissioner Victor Gilinsky visited GGNS and toured the facility with Lewis, O'Reilly, and himself. Prior to the Co nis-siener's tour of the plant, he was briefed by Region II (O'Reilly, Lewis, and
@) concerning the discrepancies with ROTP, and the fact that .some licensed cperators had been removed from their duties as a result of Region It's training assessment / inspection. Gilinsky expressed his concurrence with Recien II's actions regarding ROTP at GGNS, Although cold shutdown of GGNS was effected by HRC through a verbal agreement with MP&L on November 4,1983, stipulating MP&L would be allowed to operate at five percent power or less for two more days (this actually proved to be four days) in order to complete low power testing, the C0A letter of December 5, 1933, regarding this action does not state that GGNS should not be operated.
Hewever, it did specify certain conditions to include that MP&L would complete a recertification of the training program for the operating staft at GGNS prior to exceeding five percent power. He also noted that there was a meeting held in Region II on November 14 and 18,1953, between NRC and MF&L wherein MP&L described the recertification program that they had co citted to for the GGNS cperating staff. The December 5,1983, COA letter to MP&L confirms those
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comi o.ents . ..
i With respect to the December 5, $983, C0A letter, he S; recalls dis-
- cussions with Region II management (he does not recall wno the discussions l
- were with) wherein the questi'on was asked if the operation of GGNS should be prohibited until such time that the com.itments, specifically, the recerti-fication of the operator training program identified in the COA letter were l fulfilled. He noted that despite the fact no formal rpstriction was placed on :
GGNS with respect to it operating below five percent power, the recertifica- l tion of ROTP restricted operator manpower which resulted in insufficient availability of licensed operators to meet the technical specifications Heof' shift manning requirements. Therefore, the plant could not operate. l recalled that he had draf ted a version to the December 5,1983, COA wherein it
specifically stated that GGNS shall not be restarted urtil licensed operator recertification was completed. This draf t letter was discussed at various levels of management in Region 11 and a decision on its finalization was never reached. Instead, the December 5,198*i, COA letter stated prior to exceeding five percerit power". . . The issuance of the letter was delayed until December 5,1983, because Region 11 staff resources were involved in other activities concerning GGNS.
In February 1984, MP&L completed the recertitication of the licensed operators at GGNS. NRC has subsecuently conducted walk through and simulator examina-tions for all operators scheduled to perfom operator duties at GGNS. The purpose of the examinations was to verify the adecuacy of MP&L's recertifica-tion. As a result o6f these'* examinations, NRC considers the licensed operators at GGNS to be fully trained and competent.
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