ML20133E837

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Sanitized Version of Investigation Rept 2-83-037 on 841018- 0210.No Noncompliance Noted.Major Areas Inspected:Possible Deliberate & Willful Matl False Statements Re Reactor & Senior Reactor Operator License Exam Applications
ML20133E837
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 03/05/1984
From: Burch R, Hayes B, Vorse J
NRC OFFICE OF INVESTIGATIONS (OI)
To:
Shared Package
ML20081D396 List:
References
2-83-037, 2-83-37, NUDOCS 8508080034
Download: ML20133E837 (596)
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l GRAND GULF NUCLEAR P0'.lER PLANT POSSIBLE DELIBERATE AtlD WILLFUL MATERIAL FALSE STATEMENTS REGARDING R0 Afl0 SR0

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ce "#D , t UNITED STATES 3 'i . ** NUCLEAR REGULATORY COMMISSION O b,Jk '.- OFFICE OF INVESTIGATIONS FIELD OFFICE. REGION ll NL$NA. EOR iA 3 Date: March 5, 1984 REPORT OF INVESTIGATION TITLE: GRAND GULF NUCLEAR POWER PLANT POSSIBLE DELIBERATE AND WILLFUL MATERIAL FALSE STATEMENTS REGARDING R0 AND SR0 LICENSE EXAMINATION APPLICATIONS SUPPLEMENT: 50-416 CASE NUMBER: 2-83-037 CONTROL 0FFICE: 01:RII STATUS: CLOSED REPORTING 0FFICE: 01:RII '

PERI 0'D OF INVESTIGATION: October 18, 1983 - Febru y 10, 1984 REPORTING INVESTIGATOR: e: _

RobertH.[urch, Investigator Office of Investigations Field Office, Region II REVIEWED BY: e

[mes Yf orse, Directo ' '

Offi of Inves atiO s Field Office, Region II

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APPROVED BY: v . ./A,/ ' / /

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w enB. Hay,es,Dfretorf Office of Investi ations

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Summary This investigation was initiated to determine and document the circum-stances involving possible willful material false statements by Mississippi Power and Light Company (MP&L), hereinafter referred to as the " licensee."

The material false statements were reportedly contained in Reactor Operator (RO) and Senior Reactor Operator (SRO) license examination applications submitted by MP&L in behalf of .NRC license candidates employed at the Grand Gulf (GG) Nuclear Power Plant in Port Gibson, MS. A special GG training assessment by Region II, NRC staff members in February 1983 surfaced operator training file documentation deficiencies in the Control Room Operator Qualification Card (QC) program. These deficiencies had been formally identified by the licensee in a Plant Quality Deficiency Report (PQDR) in January 1983 and involved members of the initial license class.

A subsequent NRC Operational Readiness Inspection in August 1983 disclosed l that the QC documentation issue was unresolved and further reflected that k'nown false and discrepant training information in license examination

) applications regarding QCs had not been corrected by the licensee. In a September 30, 1983 letter and at an October 12, 1983 meeting, the licensee acknowledged that some formal training, including QCs, listed as completed on September 3,1981 (initial) applications had not been accomplished by some applicants. As a result of these disclosures by the licensee a material false statement investigation was commenced, concurrently with a Region II, NRC training assessment of current GG licensed operators to assure they have been adequately trained and are qualified to operate the reactor. Additional information provided during the investigation by the NRC training assessment staff revealed possible coercion by licensee officials towards employees of an education service contractor vendor to unduly accelerate the completion of the QC requirement for four current license candidates.

Applicable regulations and standards disclosed the regulatory requirement for the R0/SR0 license training orogram. The license application is the formal document to the NRC which initiates the licensing process.

A Applicable ANSI /ANS and NRC Regulatory Guide documents set forth guidance

() and criteria for licensee development, implementation and maintenance of an -

2 O operator training program. The Final Safety Analysis Report (FSAR) further )

describes the courses, instructions and requirements associated with this program. The FSAR document requires the licensee to provide to each license candidate a QC which is to be completed prior to licensing.

Applicable GG operations procedures implement the FSAR requirements for the license training, including the QC, and require auditable records of training activities to be maintained by the licensee's training department.

The QC is a document listing plant systems knowledge factors and practical factors and is designed to accomplish and record on-the-job training of license candidates. This document has been extensively revised since its implementation at the GG facility.

The license examination applications submitted to the NRC by the licensee were reviewed to identify those which stated the applicant had completed the QC. A total of 46 applications, involving 33 separate license c,andi-dates, submitted on September 3, 1981 (initial) and on March 30 and May 14, 1982, indicate that the QC requirement was completed by the applicants at v the time the applications were submitted. The applications submitted in March and May 1982 requested re-examinations for unsuccessful candidates during the initial examination or requested examinations for those initial applicants who had been withdrawn prior to the initial ex' amination. A review of all QCs at the MP&L/GG facility on which any effort had been expended by these 33 applicants disclosed there is no record to indicate that 12 of these individuals ever worked on the QC requirement. It was further noted that 13 candidates started but did not complete the QC requirement prior to submission of initial applications and that eight applicants completed only the Systems Knowledge section of the QC revision effective when applications were submitted. A review of applications submitted subsequent to May 14, 1982 disclosed no application entry indicating that applicants had completed the QC requirement. QC records for these latter applicants reflect that a significant number had failed to complete this requirement at the time their license examination applications were submitted to the NRC.

Individual training file entries for current and former operator employees at MP&L/GG, both licensed and non-licensed, comprising the initial and

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subsequent groups of applicants were compared with application entries.

This comparison revealed numerous instances in which the training courses /-

activity reflected in applications could not be verified in the training files. These discrepancies and errors include undocumented and incorrect durations of training activity, incorrect course titles and no documenta-tion to certify that applicants had received training in some courses listed on applications. Discrepant information was most often noted in training courses or activity entitled Rx Physics, Core Thermo and Radcon; Heat Transfer and Fluid Flow; Mitigation of Core Damage; Plant Operations and Operator Qualification Card. License examination application discrepMcies were noted to decrease significantly, in most instances, beginning with those submitted subsequent to May 14, 1982.

During the investigation 33 current and former MP&L/GG licensed and non-licensed operators were interviewed regarding participation in and completion of training activity listed on their license examination appli-cations. Twenty-seven of these operators were members of the September

'Q 1981 and/or March and May 1982 license examination classes. Most all of these applicants noted some discrepancy or false information on their applications and advised they were not given an opportunity by the licensee to review the completed application form before it was submitted to. the NRC. Only three applicants stated they had reviewed their applications prior to submission to the NRC and said the QC entry was added after they had signed and dated this document. One of these applicants stated unequivocally that he noted the QC entry on his application during review and had it removed before signing and dating this document. This same applicant, who was a September 1981 and March and May 1982 candidate for the license examination, advised that an education service contractor employee confided to him that he (contractor employee) had deliberately added the QC entry on all initial (September 1981) license applications to conform with the FSAR requirement, knowing some applicants had not started and/or completed this requirement. The March and May 1982 applications with the QC entry were determined to be copies of those submitted in September 1981. Another of these applicants reported a plant official had exerted undue pressure on the training department in August 1983 to

4 accelerate the completion of QCs for four applicants in order that they could be examined earlier than originally scheduled with the NRC. This applicant advised that training officials also exerted pressure on education service contractor personnel to accelerate the completion of these QCs as directed by the plant official. Most of these 27 initial applicants complair.ad of mismanagement and substandard record keeping practices in the training department, excessive use of education service contractors to perform and conduct license training and the apparent low priority assigned by plant management to the required license training functions. The six applicants who were not affiliated with the initial license class noted fewer errors and discrepancies in their applications but some expressed similar concerns regarding the operation and organization of the MP&L/GG training department. Current and former MP&L/GG officials described adverse training department conditions, inadequate staffing, substandard file and record keeping practices, unintentional neglect of training functions by management, excessive and p frequently unsupervised use of education service contractors to perform license training functions and failure by plant management to conduct adequate application reviews. None of these officials acknowledged personal improprieties regardint training department functions and all denied knowledge of false or discrepant information in R0/SR0 license applications prior to August 1983. These individuals advised that, until this time they regarded the file discrepancies as a licensee failure to document training completed by applicants rather than the failure of applicants to complete some training courses / activity listed on applica-tions. Education service contractor personnel currently assigned to the MP&L/GG training department were interviewed and confirmed application discrepancies and training conditions described by operators and plant officials. Additionally, some of these individuals voiced the opinion that MP&L/GG officials exerted intense pressure on them to accelerate training, including QC completion, for four applicants which violated the spirit and intent of the Plant Administrative Procedure regarding this activity. None of these individuals claimed an awareness of improprieties by licensee officials regarding willful material false statements. An education h

V' service vendor formerly employed at the MP&L/GG facility acknowledged direct involvement in the initial application preparation process but

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denied any improprieties regarding willful material false statements.

Plant operations and training department documentation dated 1978 to 1983, which was examined during the investigation, emphasizes the completion of the QC by personnel in the license training program. Contrary to reports by some initial and subsequent license applicants that they were verbally exempted from the QC requirement, no documentation was cited to support this claim.

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1 Purpose of Investigation The purpose of this investigation was to determine and document the extent of and circumstances involving the possible deliberate and willful material false statements contained in Reactor Operator (RO) and Senior Reactor Operator (SRO) license examination applications. These applications were submitted to the U.S. Nuclear. Regulatory Commission (NRC) during 1981 and 1982 by the Mississippi Power and Light Company's (MP&L), Grand Gulf Nuclear Power Plant (GG), Port Gibson, MS., hereinafter referred to as "the licensee."

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Background

On February 15-17, 1983, a special training assessment was conducted at the MP&L/GG facility by members of the Region II, NRC staff. This training review disclosed that, among other general training deficiencies, the Control Room Operator Qualification Card (QC) program for the reactor operators was not documented in individual operator training files.

According to the training assessment report (Section 3d, page 3) signed on March 10, 1983, some licensed operator training files contained no documen-tation to verify that a QC was completed by these individuals, a condition which was previously identified by the licensee in Plant Quality Deficiency Report (PQDR) No. 7-83 dated January 11, 1983. The inspection report further reflects that the QC documentation issue will be carried as an

" unresolved item" pending completion of a documentation search by the licensee.

p) On August 15-19, 1983 and August 30-September 1,1983, a special safety inspection was conducted at the MP&L/GG facility by members of the Region II, NRC staff. The inspection report, (Section 9c, page 12) signed on September 26, 1983, reflects that the QC training requirement had not been completed by eighteen licensed operators. This report further indicates that the Cold License Operator QC was listed as training received and completed on license applications submitted to the NRC and that these applications contained information known by the licensee to be incorrect;

yet, no attempt was made to correct this information. The report i summarizes that not all required training for the license candidates was actually conducted as stated in the applications submitted to the NRC by the licensee.

On September 30, 1983, the licensee, in response to an NRC request, forwarded a letter to Region II, NRC, advising that some of the R0/SR0 license examination applications submitted on September 3,1981 contained errors. The letter states that these errors, which were the subject of j PQDR 7-83, are the failure of some applicants to complete a QC even though l

it was indicated on their applications they had completed this training v ' requirement. The letter further indicates that other application errors

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V and discrepancies exist, such as the failure of some applicants to ccmplete training courses that are listed on their applications.

l On October 12, 1983, MP&L/GG officials met with Region II, NRC staff  ;

members to discuss the results of the licensee conducted investigation at the GG facility regarding errors and discrepancies in R0/SR0 license examination applications. During the meeting the licensee representatives acknowledged that some of the' formal training courses / activity reflected in the September 1981 (initial) license examination applications had not been completed by these applicants. The discrepancies were identified as incorrect course durations, the failure of some applicants to start and/or complete the QC as indicated in applications and inaccurate descriptions of some courses listed in applications.

On October 18, 1983, in a letter to 01:RII referencing the two previous inspection reports and the October 12, 1983 meeting with the MP&L/GG I officials, James P. O'REILLY, Regional Administrator, Region II, NRC (y , requested investigative assistance to determine and document the circum-stances concerning the submission of false information in R0/SR0 license examination applications. According to the request letter, the incorrect information contained in the NRC license examination applications submitted by the licensee relates to the completion of the QC requirement by license candidates and to the completion and documentation of certain other training courses which are listed in the applications. The request letter advises that, concurrent with the OI investigation, members of the Region II, NRC staff will be conducting a training assessment at the MP&L/GG facility to assure that the presently licensed R0/SR0 personnel are adequately trained and qualified as operators. Additionally, this assess-ment will determine whether deficiencies in the licensee's operator training program and the training department organization which led to the submission of false statements in ' applications have been rectified.

On December 5, 1983, in a memorandum to 01:RII, the Region II, NRC Allega-tion Coordination Section advised that during a portion of the training

(# ) assessment inspection conducted on October 19-21, 1983, it was disclosed that four QCs had been completed in a three day period during August 1983. '~

4 According to this supplemental information memorandum, licensee management insisted upon the accelerated completion of these QCs, over the objections -

of the Quadrex (contractor) personnel who performed the checkouts and signed these documents for each license candidate. The memorandum describes the conditions under which the QCs were completed and indicates possible coercion by licensee officials towards contractor personnel and potential intent to deceive the NRC regarding this training requirement.

It was requested that the circumstances regarding accelerated completion of these QCs be included as part of the initial request for assistance.

A copy of Inspection Report Number 50-416/83-06, with the pertinent section highlighted, is EXHIBIT (1) to this report. A copy of Inspection Report Number 50-416/83-38, with the pertinent section highlighted, is EXHIBIT (2) to this report. A copy of the MP&L/GG letter dated September 30, 1983 is EXHIBIT (3) to this report. A copy of the October 12, 1983 " Meeting Summary" is EXHIBIT (4) to this report. A copy of the Region II, NRC investigation request letter dated October 18, 1983 is EXHIBIT (5) to this iO report. A copy of the December 5, 1983 Region II, NRC supplemental information memorandum, with attachment, is EXHIBIT (6) to this report. '

5 b Applicable Statutes, Regulations and Standards During this investigation a review of applicable statutes, regulations and standards was conducted. This review disclosed the following pertinent information regarding this investigation:

Title 10, Code of Federal Regulations, Section 55, entitled " Operators' Licenses," is pertinent to this investigation. At Section 55.1, entitled

" Purpose," it is stated that:

"The regulations in this part establish procedures and criteria for the issuance of licenses to operators, including senior operators, of facilities licensed pursuant to the Atomic Energy Act of 1954, as amended...."

It is stated at Section 55.3, entitled " License Requirements," that:

"(a) No person may perform the function of an operator as defined in this part except as authorized by a license issued by the Comission; (b) No person may perform the function of a senior operator as defined in this part except as authoriz'e d by a license issued by the Commission."

At Section 55.5, entitled " Communications," it is stated that:

"Except where otherwise specified, all communications and reports concerning the regulations in this part, and applications filed under them should be addressed to the Director of Nuclear Reactor Regulation or the Director of Nuclear Material Safety and Safeguards, as appro-priate. U.S. Nuclear Regulatory Comission, Washington, D.C. 20555.

Communications, reports and applications may be delivered in person at the Commission's office at 1717 H. Street, NW., Washington, D.C. or at 7920 Norfolk Avenue, Bethesda, M.D."

Under the heading " License Applications," at Section 55.10, entitled "

" Contents of Applications," regulations therein are pertinent to this

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d investigation. At subsection (a)(2) it is stated that each application for a license shall contain the following information: "The education and pertinent experience of the applicant, including detailed .information on the extent and nature of responsibility." At Subsection (d) it is stated that "Each application and statement shall contain complete and accurate disclosures as to all matters and things required to be disclosed. All applications and statements, other than the matters required by para-graphs (a)(5), (6), and (7) of this section shall be signed by the applicant.

At Section 55.12, entitled "Re-applications," conditions for filing a new application due to a failed written examination or operating test following the initial and/or subsequent application (s) are set forth.

INVESTIGATOR'S NOTE: As will be described in later report text some applicants for written and/or operating examinations at the MP&L/GG facility filed applications on more than one occasion.

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Under the heading " Modification and Revocation of Licenses," at Section 55.40(b) it is stated that:

"(b) Any license may be revoked, suspended or modified, in whole or in part, for any material false statement in the application or any statement of fact required under section 182 of the Act...."

Under the heading " Enforcement," Section 55.50, entitled " Violations," it is stated that:

"An injunction or other court order may be obtained prohibiting any violation of any provision of the Atomic Energy Act of 1954, as amended, or Title II of the Energy Reorganization Act of 1974, or any ,

regulation or order issued thereunder. A court order may be obtained for the payment of a civil penalty imposed pursuant to section 234 of the Act for violation of section 53, 57, 62, 63, 81, 82, 101, 103, 104,107, or 109 of the Act, or section 206 of the Energy Reorga-C# nization Act of 1974, or any rule, regulation, or order issued -

7 thereunder, or any term, condition, or limitation of any license issued thereunder, or for any violation for which a license may be revoked under section 186 of the Act. Any person who willfully violates any provision of the Act or any regulation or order issued thereunder may be guilty of a crime and, upon conviction, may be punished by fine or imprisonment or both, as provided by law."

The Atomic Energy Act of 1954, as amended, Chapter 16, (Judicial Review and Administrative Procedure), Sections 182 and 186, are relevant to this investigation. Section 182, entitled " License Applications," states at subsection (a) that:

"Each application for a license hereunder shall be in writing and shall specifically state such information as the Comission, by rule or regulation, may determine to be necessary... and the Comission may at any time after the filing of the original application, and before the expiration of the license, require further written statements in order to enable the Commission to determine whether the application should Os be granted or dr.nied or whether a license should be modified or revoked. All applications and statements shall be signed by the applicant or licensee...

At Section 186, entitled " Revocation," subsection (a) states that:

"Any license may be revoked for any material false statement in the application or any statement of fact required under section 182, or because of conditions revealed by such application or statement of fact or any report, record, or inspection or other means which would warrant the Comission to refuse to grant a license on an original application...."

A February 7, 1983 Office of General Counsel, U.S. Nuclear Regulatory Comission memorandum to the Comissioners entitled " Civil Penalties for '

Material False Statements-Comission Authority and Policy," contains )

coments relative to a material false statement. At Section III of this IG document it is stated that a "[ material false statement] is undefined in '~-

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V the Atomic Energy Act except to the extent that section 186(a) requires that such a statement must be in an [ application or any statement of fact required under section 182]."

Title 18, United States Code, Chapter 47 (Fraud and False Statements),

Section 1001 " Statements or entries generally" is pertinent to this inves-tigation. It is stated that:

"Whoever, in any matter within the jurisdiction of any department or agency of the United States knowingly and willfully falsifies, conceals or covers up by any trick, scheme, or device a material fact, or makes any false, fictitious or fraudulent statements or representa-tions, or makes or uses any false writing or document knowing the same to contain any false, fictitious or fraudulent statement or entry, shall be fined not more than 510,000 or imprisoned not more than five years or both."

O ANSI /ANS-3.1-1978 (Revision of N18.1-1971), American National Standard for Selection and Training of Nuclear Power Plant Personnel, contains guidance for developing, implementing and maintaining an operator training program.

Section 5.1 of this document states that "A training program and schedule shall be established for each nuclear power plant to initially develop and maintain an organization fully qualified to be responsible for operation, maintenance, and technical aspects of the nuclear power plant involved."

Section 5.2 contains guidance for Cold License training of operations personnel. Section 5.6, " Documentation" states that "Auditable records of the qualifications, experience, training, retraining and operator requali-fication program examinations for each member of the plant organization covered by this standard shall be maintained for as long as a person performs work in job categories described in this standard."

Regulatory Guide 1.8 entitled, " Personnel Selection and Training," under Section C, " Regulatory Position" states that:

"The criteria for the selection and training of nuclear power plant u' personnel contained in ANSI N18.1-1971, " Selection and Training of -

9 Nuclear Power Plant Personnel," are generally acceptable and provide an adequate basis for the selection and training of nuclear power 4 plant personnel...."

Copies of all applicable regulations cited in this section of the investi-gation report are being retained in the case file at 01:RII.

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10 Applicable Licensee Commitments and Procedures A review of applicable reports and procedural documents relative to licensee commitments and requirements was conducted pursuant to this investigation. This review disclosed the following materials which are deemed pertinent:

The MP&L/GG Final Safety Analysis Report (FSAR) Revision 47, Section 13.2, entitled " Training" describes the courses, instructions and requirements associated with the Licensed Operator Training Program. At subsec-tion 13.2.1.1.5.3 entitled, "In-Plant Training" it is stated that "Each license candidate shall spend a period of time on shift in a training 4

status under the direct supervision and guidance of the licensed control room operator. The objective of this training period is for each candidate to gain experience in the routine operation of a nuclear power plant." It i is further stated in this subsection at paragraph (a) that " prior to

, initial criticality... each candidate is provided with a control room

, V operator qualification card which contains kncwledge factors and practical factors to be accomplished / discussed while in an on-shift training status.

The candidate's performance while on shift is monitored by the shift supervisor who shall provide an evaluation of the candidate's operating abilities at the conclusion of this training phase." At paragraph (b) of this subsection it is stated that "After initial plant criticality, each license candidate shall spend at least 3 months on shift in a training status in the GGNS control room. During this period, the candidate shall carry out the duties of a control room operator under the direct super-vision and guidance of the licensed control room operator. The candidate's performance is monitored by the shift supervisor who shall provide an evaluation of the candidate upon the conclusion of this training phase.

Each student is provided with a control room operator qualification card which lists the knowledge factors and practical factors to be discussed /-

, accomplished while in this (on-shift) training." At section 13.2.5, entitled " Training Records," it is stated that " Records of plant personnel i

qualifications will be maintained on each member of the plant staff. Each

( member of the plant staff will have a qualification and training folder .. >

maintained by the Training Superintendent. The training folder contains a

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resume of the person's qualifications, records of training programs, training courses completed, lectures attended, and drill participation."

At section 13.2.6, entitled " Documentation" it is stated that " Adequate records will be maintained in accordance with 10 CFR 55 to document the participation of all licensed personnel in the initial training and requalification programs."

INVESTIGATOR'S NOTE: Revision 47 of the MP&L/GG FSAR was effective when the license examination applications were submitted to the NRC by the licensee on September 3, 1981 and on March 30 and May 14, 1983.

MP&L/GG Plant Operations Manual, Volume 01, Section 04, Administrative Procedure 01-S-04-1, Revision 0 dated November 14, 1980 (effective when September 30, 1981 applications were submitted) and Revision 1 dated February 24, 1982 (effective when the March 30 and May 14, 1982 applica-tions were submitted) lists the requirements and establishes training

( courses which satisfy prerequisites for the NRC license examination. At v subsection 6.2.5(d) entitled, " Operating Practices Training" the control room training requirements are set forth. The text of

-Section 13.2.1.1.5.3, FSAR, as stated above, is repeated in its entirety at this subsection of the administrative procedure. At subsection 6.5, entitled " Records," it is stated that "the training and operational experience received in the Licensed Operator Training and Qualification Program shall be recorded and maintained in accordance with" Plant Administrative Procedure 01-5-04-14, Training Records.

MP&L/GG Plant Operations Manual, Volume 1, Section 04, Administrative Procedure 01-5-04-14, Revision 2, dated April 10, 1981 sets forth require-ments for the maintenance of training records. According to this procedure, "each member" of the GG facility "will have an auditable record of his... training." It is further stated that the individual training record will provide " certification that each plant staff member has been provided the required training...." This procedure identifies the Training Supervisor as the individual " responsible for ensuring that all necessary

, entries are made in the Training Records." _

12 The MP&L/GG Plant Operations Manual, Volume 1 Section 3, Administrative Procedures 01-S-03-1 and 01-S-03-2 which discuss the GG Ouality Program and the Plant Quality Deficiency Reports, respectively, are pertinent to this investigation. The former procedure subjects the Training Department to the provisions of the MP&L Quality Assurance Manual. It identifies the PQDR as the applicable document to resolve safety related deficiencies discovered in non-material related activities (training). The latter procedure delineates responsibilities regarding the preparation, issuance and resolution of PQDRs. At section 6.3 entitled, " Disposition," it is stated that " timely disposition is required by the Operational QA Program" and a " Corrective Action Completion Date" of 30 days or less is assigned to each PQDR.

INVESTIGATOR'S NOTE: PQDR Number 7-83 dated January 11, 1983, which is pertinent to this investigation and will be discussed in detail under the " Explanation of Pertinent Licensee Documents" section of this report, did not have " CORRECTIVE ACTION" completed until

( September 8,1983. On September 30, 1983, Region II, NRC issued a Notice of Violation to MP&L for failure to comply with the requirement of GG Administrative Procedure 01-S-03-2 regarding disposition of PQDRs.

Copies of all of the reports and licensee procedures referenced in this section of the investigation report are being retained in the case file at 01:RII.

13 O Discussion of the Control Room Operator Qualification Card The Grand Gulf Nuclear Station Control Room Operator Qualification Card (QC) is a document designed to accomplish on-the-job training of licensed and non-licensed operator candidates. The current QC contains a listing of systems knowledge factors and practical factors, the accomplishment of which is to demonstrate that an operator can perform the required reactor functions, manipulations and evolutions. The completion of the QC is a pre-NRC license examination commitment (as set forth in the FSAR) for licensed operators and senior operators, and a licensee imposed pre-certi-fication requirement for non-licensed operators. The QC was referred to as a Cold License Operator Qualification Card for earlier license candidates at the GG facility. By definition, a " Cold License" is an operator license issued by the NRC as a result of successful completion of the written and oral examinations prior to the initial core loading of the reactor.

INVESTIGATOR'S NOTE: According to Region II, NRC records, initial D core loading at the GG facility commenced on July 1,1982 and initial criticality was achieved on August 18, 1982.

The signature and date blocks on the QC, located adjacent to the identi-fication of each system, sub-system or evolution, is completed for the applicant after his/her successful demonstration of knowledge to an individual already familiar with those systems and who has been designated by the licensee to conduct the " checkouts." The QC document is described in and is an attachment to a Plant Administrative Procedure, which is a section of the Plant Operations Manual. The purpose and requirements of this Administrative Procedure, Number 01-5-04-1, Revision 0 and Revision 1, and attached QC, have been explained in the previous section of the investigation report.

During the investigation, it was disclosed through interviews and/or MP&L/GG permanent records that the QC was developed in 1977-1978 by a former MP&L/GG Training Department official who reportedly borrowed the idea from the U.S. Navy. The current version of the QC is a product of numerous revisions, changes and modifications since its inception at the GG

14 D facility. Copies of the revised administrative procedure, containing QC revisions, were requested from the licensee and based upon this documen-tation a chronology of the evolution of the procedure and QC is set forth as follows:

(1) A 21 page document entitled "GGNS Cold License Operator Quali-fication Card," is claimed by the Training Superintendent to be the first QC implemented at the facility. The licensee was unable to locate all 21 pages of the original OC in their training records or central files. No administrative procedure describing the purpose and requirement of this QC was provided by the Training Superintendent.

(2) Administrative Procedure 01-S-04-Temp-1, dated September 20 and November 21, 1978 entitled " Grand Gulf Nuclear Station, Initial Operator (Cold License) Qualification Card," was pro *vided.

According to the Training Superintendent this procedure was O promulgated to define and implement "the training program to be used for initial (" Cold") operator training," in fulfillment of the requirements established in the FSAR. Attachment II to this procedure is the GGNS Cold License (Initial) Operator Qualifi-cation Card. Attachment VII is the GG Senior Reactor Operator (Limited) Qualification Card.

(3) An Administrative Procedure document entitled " Operator Cold License Training and Qualification Program," issued as Temporary Directive 01-5-04-Temp-2 dated October 3, 1979 revised the

" Temp-1" version of this procedure. The " Cold License Operator Qualification Card" was unaffected by the revision of this procedure.

(4) Temporary Directive 01-5-04-Temp-3 dated June 27, 1980 revised the " Temp-2" version of the procedure and the QC. Attachment I, the " Grand Gulf Nuclear Station Initial Operator (Cold License)

Qualification Card, contains substantial revisions and additions.

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6 (5) On November 14, 1980, Plant Administrative Procedure 01-S-04-1, Revision 0 became a permanent GG procedure. The " Control Room Operator Qualification Card" is Attachment V to this procedure.

The style, format and content of the QC was again substantially revised as additional systems, subsystems and plant evolutions were completed during the construction of the facility. A section of the QC, entitled " Practical Factors," was added; however, a parenthetical notation indicates the contents of this section would be implemented at a later date.

INVESTIGATOR'S NOTE: This revision of the QC was in effect u

when the initial " Cold License" examination applications were submitted to the NRC on September 3, 1981.

(6) On February 24, 1982, Plant Administrative Procedure 01-S-04-1, Revision 1 was implemented . Attachment II to this revised procedure is the " Control Room Operator Qualification Card." The format and content of the QC was unchanged from the previous revision and the " Practical Factors" section contained the identical notation.

INVESTIGATOR'S NOTE: This revision of the QC was in effect when the license examination applications of March 30 and May 14, 1982 were submitted to the NRC.

(7) On August 28, 1982, Plant Administrative Procedure 01-S-04-1, Revision 2 was issued. Attachment II to this revised procedure is the " Control Room Operator Qualification Card." Modifications and revisions in the form of added systems and subsystems were made on the revised QC, The text of the " Practical Factors" section of the QC was added with the issuance of Revision 2. As stated in the heading of the Practical Factors section, operators are required to demonstrate a practical understanding and working knowledge of plant systems by walkthrough performance and O discussion or actual performance of surveillance procedures and i instructions. -

1 1

- - > -- - ,- ~- m--.,- n..-- ,,-,w , , , ,, - _ . , -.,,,,.,_,,.m. . , - , , , , , , , , , , , . , - , _ . . , - , , _ , , - , - - - , . . _ . . , - , , , , , , . _ , , - - , . ,

\

16 T

L (8) On September 13, 1983, Plant Administrative Procedure 01-S-04-1, Revision 4 was implemented. The QC was removed as an attachment to this procedure; however, another MP&L/GG Plant Administrative Procedure was implemented on August 11, 1983 to continue the requirement of the Control Room Operator Qualification Card for documenting the comp.letion of training " specific to the License Operator Training Program."

(9) The Plant Operations Manual, Volume 14, Section 02, Plant Administrative Procedure 14-S-02-6, Revision 0 indicates this procedure was issued on August 11, 1983. Attachment II is entitled " Grand Gulf Nuclear Station Control Room Operator Qualification Card." Revision 1 of this procedure was issued on October 17, 1983 and. Revision 2 was issued on November 9, 1983.

Copies of the revisions of Administrative Procedures 01-5-04-1 and 14-S-02-6, are being retained in the case file at OI:RII.

o.

v .-

, 17 1

i Discussion of License Examination Apolication Forms

The application form used by MP&L/GG for all license candidates on
September 3,1981 and on March 30, May 14 and October 8,1982 is a plant specific form (old) developed by a former MP&L/GG Training Department Superintendent. The NRC, under cover of a February 24, 1983 generic

! memorandum, implemented a standard (new) license examination application i

form (NRC Form 398) for use by all R0/SR0 license applicants nationwide.

The MP&L/GG plant specific application form is a three page document, the first of which requests only personal applicant data in Items 1 through 6.

Page two contains only the captioned headings, under Items 7 and 8, of

" Formal Training" and " Experience" respectively. Page three contains only the captioned heading " Previous Operating Licenses" under Item 9, and a i space for the signature of the applicant and the date the application is

! signed. The old form is structured in sections and is organized to allow for the reporting of general training information at the discretion of the

licensee. The new form is more specific in its reporting requirements and contains a certification statement not reflected on the MP&L/GG originated form. This statement certifies that the applicant "has or will have

^

completed by the time of examination all the required training and has learned to operate the controls in a competent and safe manner...."

According to MP&L/GG training department officials, the listing of courses and/or. training activity on the old form implied completion at the time the application was submitted, unless a specific notation beside each course indicated otherwise. Blank copies of the old and nes style applications l are EXHIBITS (7) and (8) to this report.

l l Dw

18 g]l xm_/

Review of License Examination Acolications Pursuant to this investigation, all R0 and SRO license examination applications submitted to the NRC by MP&L/GG were reviewed. This review was conducted for the purpose of identifying applications which indicated ,

that license candidates had completed the QC requirement at the time the license examination application was submitted to the NRC. According to licensee and Region II NRC documentation, R0/SR0 license examination applications were submitted to the NRC by MP&L/GG on the following dates:

(1) September 3, 1981 (initial applicants)

(2) March 30, 1982 (initial re-submissions)

(3) May 14, 1982 (some initial re-submissions)

(4) October 8, 1982 (5) March 3, 1983 (6) May 25, 1983 (7) August 10, 1983 9.% (8) September 1, 1983 (9) October 24, 1983 Although the old application form was last utilized by the licensee with the applications submitted to the NRC on October 8, 1982, the Formal Training entry " Cold License Operator Qualification Card" does not appear in applications submitted after May 14, 1982. As revealed by this review of license examination applications, 34 initial R0/SR0 applications were submitted by MP&L/GG on September 3,1981. The transmittal letter from MP&L/GG to the Operator Licensing Branch, NRC, Washington, OC, states that the " personal applications... for each applicant... includes education, formal training, and experience." Of the 34 initial applications, 33 contain the entry " Cold License Operator Qualification Card" under the Formal Trainirg section. The only application in which this entry does not appear is that of license candidate George H. LEE.

t i i Nj

19 O In a March 30, 1982 transmittal letter to the NRC, Washington, DC, the licensee re-submitted nine of the initial 34 applications, formally reque: ting re-examinations for R0/SRO license candidates at the GG facility. Of these nine applications only LEE!s re-application did not contain the " Cold License Operator Qualification Card" entry under the Formal Training section.

On May 14, 1982, the licensee formally applied to the NRC, Washington, DC, for the re-examination of four initial candidates and for the examination of two initial applicants who were withdrawn prior to taking the first examination. Of these six applications, five contained the " Cold License Operator Qualification Card" entry under the Formal Training section of the application. Again, only the second re-application of LEE failed to contain this entry. In summary, a total of 49 applications for initial applicants requesting the R0/SR0 license examination were submitted to the NRC on September 3, 1981 and on March 30 and May 14, 1982, utilizing the old style form. Forty-six (46) of these applications contained the Formal O Training entry " Cold License Operator Qualification Card." No applications containing this entry were submitted after May 14, 1982 and the QC entry was nut reflected on any applications utilizing the new style form.

Copies of the September 3, 1981, March 30, 1982 and May 14, 1982 MP&L/GG transmittal letters to the NRC, with applications containing the " Cold License Operator Qualification Card" entry are EXHIBITS (9), (10) and (11) to this report.

INVESTIGATOR'S NOTE: Each of the referenced transmittal letters from MP&L to the NRC are signed by James P. MCGAUGHY, Vice President, Nuclear. A statement in each letter indicates that the applicant's training has been reviewed for conformance to 10 CFR 55.

O .

20 Review of Individual Operator Qualification Cards During this investigation, verbal and written requests for copies of all individual operator QCs at the MP&L/GG facility were made to Douglas Leon HUNT, Training Department Superintendent. HUNT, in responding to this request, advised he had directed a thorough search of the training files and records and the MP&L/GG central files and that all of the individual operator QCs (active and inactive) on which any accomplishments had been documented were being provided. All of the QC documentation was reviewed and categorized to determine whether the licensee had complied with the FSAR and plant procedures regarding this training require int. Applica-tions were grouped according to the dates they were submi- id to the NRC and the QC for each applicant, if one was provided by the Iv;ensee, was examined to determine its current status. The following information was determined from this analysis:

September 3, 1981 Applicants

- 8 applicants had completed the correct QC revision, System Knowledge only, No Practical Factors.

- No QC record located for 12 applicants.

- 6 Applicants had started the proper QC revision but did not complete it.

- 7 Applicants had started a superceded revision of a QC but did not complete it.

- 1 Applicant subsequently completed a later revision of a QC, March 30, 1982 Apolicants

- 3 Applicants had completed a superceded revision of a QC, System Knowledge Section only, No Practical Factors.

l'

21 O

I

- No QC record located for 4 applicants.

1 Applicant had started a. superceded revision of QC but did not complete it.

1 Applicant subsequently completed a later revision of a QC.

May 14, 1983 Applicants 3 Applicants had completed a superceded revision of a QC, System Knowledge Section only, No Practical Factors.

- No QC record located for 2 applicants.

2 Applicants had started superceded revisions of a QC but did not complete them.

- 2 Applicants subsequently started but did not complete a later revision of a QC.

- 3 Applicants subsequently completed a later revision of a QC.

INVESTIGATOR'S NOTE: Only six of these candidates were initial applicants and only five (LEE the exception) had the QC entry on their applications.

October 8, 1982 Applicants'

- 2 Applicants had completed the effective QC revision.

- No QC record located for 3 applicants.

- 1 Applicant had started the effective QC revision but did not complete it. ,

e s

gg b - 2 Applicants had started superceded revisions of a QC but did not complete them. ,

- 1 Applicant had completed a superceded revision of a QC.

March 3, 1983 Aoplicants

- 1 Applicant had completed the effective revision of a QC, May 25, 1983, Applicants

- 6 Applicants had completed the effective revision of a QC.

August 10, 1983 Applicants

- 4 Applicants had completed the effective revision of a QC.

Q - 2 Applicants had started but did not completed superceded revisions of a QC.

September 1, 1983 Apolicants

- 4 Applicants had completed the effective revision of a QC.

- 2 Applicants had started but did not complete superceded revisions of a QC, October 24, 1983 Aoplicants

- 2 Applicants had completed a superceded revision of a QC,

- 4 Applicants had started but did not complete a superceded revision of a QC.

\ -

23 I

A chart of the results of the QC and license examination application analysis was prepared on December 14, 1983 to display the information sumarized herein. This chart identifies all applicants and their current employment and license status, the style of application form used, the applications with the QC entry and the current QC status for each appli-cant. A " Key" page of the chart identifies coded entries. A copy of this chart is EXHIBIT (12) to this report.

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24

\ Comparison of Acolication and Training Record Entries A comparison of Formal Training entries contained in the applications of the initial applicants and of current operators (licensed and unlicensed) with data contained on " Individual Training History" sheets in their

! MP&L/GG training file was conducted. This task was initially completed by 1

Lawrence Edward KOKAJKO, Senior Service Engineer, Quadrex Corporation, Tulsa Oklahoma', a GG facility contractor. The licensee had previously initiated this activity based upon a commitment made during the October 12, 1 1982 meeting with Region II, NRC staff members. A sampling of the work i completed by K0KAJK0 was conducted to ensure the reliability of the results achieved by'this individual. The information contained herein represents the results of K0KAJK0's efforts, except in those instances in which 01 sampling was conducted (as noted by an asterisk). The name of each initial applicant whose application and training file was compared is listed, under which the discrepancies between these two record sources is noted.

ANDERSON, Donald R.

1- the 7 day Plant Operations Course (P0C) is documented as 5 days only t

2- the three application entries regarding SR0 training at Quad Cities are undocumented I

3- the 13 day POC is documented as 10 days only 4- the 1 week Mitigation of Core Damage (MCD) is documented as 32' hours 5- QC is undocumented

  • BEARDEN, William C.

1- the 3 day Heat Transfer-Fluid Flow Course (HT-FF) is v undocumented --

l 25 P

2- the 6 day Rx Physics, Core Thermo, Radcon course is not documented 3- the 3 week HT-FF Course is documented as 6 weeks 4- the 13 day POC was documented as 12 days only j 5- QC is undocumented

  • BENEFIELD, Keith W.

1- the 13 day P0C is documented as 12 days only 2- the 6 day Rx Physics, Core Thermo, Radcon course is documented as 3 distinct 2 day courses 3- QC is undocumented BYRD, Lawrence R.

1- the 13 day P0C is documented as 12 days only 2- the 3 day HT-FF course is undocumented i

3- the 6 day Rx Physics, Core Thermo, Radcon course is undocumented l

l 4- QC is undocumented CADE, Walter C.

1- the 7 and 13 day P0Cs are documented as one 15 day course

- 2- the 1 week MCD course is documented as a days only

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

26 3- the 3 day HT-FF course is undocumented 4- the 6 day Rx Physics, Core Thermo, Radcon course is documented as a 5 day course 5- QC is documented as N/A as of 6/9/82 CRESAP, Charles E.

1- the 7 and 13 day POCs are documented as one 15 day course 2- the 6 day Rx Physics, Core Thermo, Radcon course is undocumented 3- the 3 day HT-FF course is undocumented 4- the 1 week MCD is documented as a days only O 5- QC is documented N/A as' of 6/8/82 DOTTER, Jay F.

1- the 13 week Perry Simulator Course is undocumented as

" duration" 2- the 13 day POC is documented as 12 days only 3- the 6 day Rx Physics, Core Thermo, Radcon course is

, documented as 3 distinct 2 day courses 4- the I week MCD course is documented as 4 days only 5- QC is undocumented O -

27 FRAZIER, John B.

1- the 13 day P0C is documented as 12 days only 2- the 6 day Rx Physics, Core Thermo, Radcon course is

! undocumented i

3- the 7 day POC; applicant failed final exam, no evidence of make-up examination 1

4- the 5 day POC is undocumented 5- the 1 week MCD, applicant failed, no evidence of make-up examination 6- QC is documented as incomplete as of 7/14/83 GORDON, William K.

1- the 7 and 13 day P0Cs are documented as one 15 day course 2- the 6 day Rx Physics, Core Thermo, Radcon course is undocumented 3- the 3 day HT-FF course is undocumented 4- the 1 week MCD is documented as 4 days only 5- QC is documented N/A as of 6/8/82 HALL, Errol K.

1- the 7 and 13 day P0Cs are documented as one 15 day course N

1

- . - - - - , -, . , , - . . - - . .~.-,n_,., , . - , , - -- - - - . - - - . , - . - - - , . , . , . . - - , . . . - - - - n,,-, , , - - - . ----

28 2- the 6 day Rx Physics, Core Thermo, Radcon course is undocumented 3- the 3 day HT-FF course is undocumented 4- QC is undocumented HICKS, Charles V.

i 1- the 13 day P0C is documented as 12 days the 6 day Rx Physics, Core Thermo, Radcon course is 2-undocumented 3- the 3 day HT-FF course is undocumented 4- the 1 day Fire Brigade Training is documented as 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> only 5- QC is undocumented

  • HOTHAM,~Andrea D.

1- the 6 day Rx Physics, Core Thermo, Radcon course is documented as 2 day Radcon only 2- the 10 Reactor Criticals is undocumented 3- the 1 week Station Nuclear Engineer Course is undocumented 4- the 12 week Operator Training Course is undocumented 5- the 22 week Instructor Training Program is undocumented i A Q ._.

l i

29  ;

l 6- the 12 week Installation and Service Engine.ering Program training is undocumented i

7- QC is undocumented JACOBSON, Ronald K.

1- the 7 and 13 day POCs are documented as one 15 day course 2- the 6 day Rx Physics, Core Thermo, Radcon course is undocumented 3- the 3 day HT-FF course is undocumented 4- QC is documented as N/A as of 3/17/83 JOHNSON, Gilbert A.

1- the 8 week Grand Gulf Technology is undocumented 2- the 12 week Operator Training Course is undocumented 3- the Reactor Training at Dairyland is undocumented 4- the Operator Retraining at Vermont Yankee is undocumented 5- the SR0 Training at Vermont Ysnkee is undocumented 6- tha 7 and 13 day POCs are undocumented 7- the 6 day Rx Physics, Core Thermo, Radcon is documented as 5 days ,

, = =

30 0 8- the 3 day HT-FF course is undocumented 9- the 1 week MCD is documented as 4 days only 10 - QC is undocumented KEETON, Roy G.

1- the 13 days POC is documented as 12 days only 2- the 6 day Rx Physics, Core Thermo, Radcon course is undocumented 3- the 1 week MCD course is documented as 4 days only 4- QC is undocumented

  • LEE, George H.

No discrepancies noted between the application and his training file.

LEWIS, Billy G.

1- the 7 and 13 day POCs are documented as one 15 day course 2- the 6 day Rx Physics, Core Thermo, Radcon course in undocumented 3- failed week 10 of the 12 week Cold License Training Program.

No evidence of a make-up examination 4- QC is documented as incomplete as of 7/14/83 i

. - - - _. - = , . - _- . - . - - -

31 LHAMON, Gary D.

1- the 1 day Quality Assurance course is documented as a i hour course 2- QC is undocumented i MANBY, John F.

1- the 13 day P0C is documented as 12 days only i

2- the 1 week MCD course is documented as 4 days only 3- QC is documented N/A as of 6/10/82 MCDONALD, James K.

1- the 7 and 13 day POCs are documented as one 15 day course 2- the 6 day Rx Physics, Core Thermo,_ Radcon course is undocumented fl .i 3- the 3 day HT-FF course is undocumented i

, 4- QC is documented incomplete as of 7/14/83 ii a

MCMILLIN, George L.

i l 1- the 7 and 13 day POCs are documented as one 15 day course i

2- the 1 week MCD course is documented as incomplete

{

1

.L l 3- the 3 day HT-FF course is undocumented d ..

'!,a

_m- - - , - .._______ __ _ . , . . , _ _ _ , _ . . , . -. _,.-.. , .-- ,. .- _ ,. ,-.----

32 4- the 6 day Rx Physics, Core Thermo, Radcon course is undocumented 5- QC is documented incomplete as of 7/14/83

  • MILLER, Lee R.

i I 1- the 3 week HT-FF course documented as two separate 3 week courses 2- the 7 day P0C is documented as 5 days only 3- the 13 day POC is documented as 10 days only 4- the 6 day Rx Physics, Core Thermo, Radcon course is undocumented 5- the 3 day HT-FF course is undocumented 6- QC is documented incomplete as of 7/14/83

  • MOULDER, Larry B.

1- the 7 and 13 day P0Cs are documented as one 15 day course 2- the 6 day Rx Physics, Core Thermo, Radcon course is undocumented 3- the 3 day HT-FF is undocumented 4- QC is undocumented PERRYMAN, Richard L.

1- the 13 day POC is documented as 12 days only

/ ._

33 2- the 6 day Rx Physics, Core Thermo, Radcon course is documented as 2 days each for Rx Physics and Core Thermo, no Radcon documented 3- the 3 day HT-FF course is undocumented 4- QC is undocumented POWELL, David M.

1- the 21/2 day Fire Brigade Training documented as 2 days only 2- the 7 and 13 day P0Cs are documented as one 15 day course 3- the 6 day Rx Physics, Core Thermo, Radcon course is p documented as 2 days Radcon only 4- QC is documented N/A as of 6/8/82 POWERS, Rocer N.

1- the 2 week Perry Refresher training is undocumented 2- the 13 day P0C is documented as 12 days only 3- the 6 day Rx Physics, Core Thermo, Radcon course is not documented 4- the 1 week MCD is documented as 4 days only 5- QC is undocumented RICE, Clark M.

i \

[

1- the 2 week Perry Refresher training is undocumented --

'l

~ - - - - ~ - - - ---,.-en-- m m-v.,.- ,.-,.v. .,,-,_y. . _ , . - , . , , - , , , _ - . ,m,

34 I

(v/

2- the 7 and 13 day P0Cs are documented as one 15 day course 3- the 6 day Rx Physics, Core Thermo, Radcon course is documented as 2 days each for Rx Physics and Core Thermo, no Radcon documented 4- the 3 day HT-FF course is undocumented 1

5- the Plant Hatch training courses are undocumented 6- QC is undocumented 4

ROBERTSON, James L.

1- the 7 and 13 day P0Cs are documented as one 15 day course 2- the 6 day Rx Physics, Core Thermo, Radcon course is

' undocumented 3- the 5 month Introduction to Nuclear Power is documented as 4 1/2 months a

4- QC is undocumented RUSSELL, Wayne A.

1- the 7 and 13 day POCs are documented as one 15 day course 2- the 6 day Rx Physics, Core Thermo, Radeon course is t '

undocumented 3- the 3 day HT-FF course is undocumented 4- QC is undocumented n.

v .

l

35

SHELLY, William M. i 1- the 7 and 13 day P0Cs are documented as one 15 day course l

2- the 5 day POC is undocumented 3- the 6 day Rx Physics, Core Thermo, Radcon course is undocumented 4- QC is undocumented STAFFORD, Clark D.

1- the 7 and 13 day POCs are documented as one 15 day course 2- the 6 day Rx Physics, Core Thermo, Radcon course is undocumented 3- QC is undocumented WARNER, John B.

1- the 7 and 13 day POCs are documented as one 15 day course f

l 2- the 6 day Rx Physics, Core Thermo, Radcon course is l undocumented l 3- the 1 week MCD is documented as 4 days only 1

4- QC is documented N/A as of 6/9/82 l

L I

    • e i

36

[ m WHALEY, Paul M.

1- length of Perry Simulator course not documented 2- the 7 day P0C is documented as 5 days only 3- the 13 day Rx Physics, Core Thermo, Radcon course is documented as 2 days Radcon only

. 4- QC is undocumented WHITE, James L.

1- the 7 and 13 day POCs are documented as one 15 day course i

2- the - 6 day Rx Physics, Core Thermo, Radcon course is undocumented 3- the 3 day HT-FF course is undocumented 4- QC is documented N/A as of 6/9/82 A comparison of the re-submitted applications with training files for applicable applicants disclosed that many of the same discrepancies present in initial applications were repeated in a subsequent application.

EXHIBIT (12) to this report identifies operators (and employme't status) who had license applications re-submitted in their behalf by the licensee.

The comparison of the application entries with training file entries for applicants subsequent to the initial class was completed using the same guidelines employed for the initial license candidates. The name of each applicant is listed and discrepancies between the application and the training file is reflected beneath each name. The application dates and employment status for these individuals is also reflected in EXHIBIT (12).

The QC entry is not listed on any of these applications, h

j ..

I

37 1 . (n

, ~

BOTTEMILLER, Charles A.

1- the 1 week MCD course is documented as 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> 2- the 14 day Simulator Refresher Training is documented as 13 days BREWER, Paul W.

No discrepancies noted between application and training file.

BURRIS, Steve A.

No discrepancies noted between application and training file.

CUPIT, Billy R.

1- the 2 week Pre-Simulator course is undocumented 1

  • DORSETT, Michael A.

l 1- the 12 week GGT-Cold License Training is undocumented for weeks 3, 9, 11 and 12 2- the 3 week HT-FF course is undocumented EHRHARDT, Karl F.

i 1- the 12 day Simulator Refresher course is documented as being accomplished in 10 days 2- the 5 week Self Study is undocumented l

38 ELLIS, Mickey L. i 1- the Certified R0 Perry Simulator entry is undocumented; applicant did not certify, did not complete course 2- the 3 week HT-FF course is documented as incomplete 3- the 5 day Rx Startup is documented as 3 days only with 6 Startups 4- the 5 week GG Systems Review; the 3 week Rx Physics, Core Thermo and Heat Transfer; the 2 week Admin Requirements course; and the 2 day MCD course are documented as incomplete INVESTIGATOR'S NOTE: This applicant was withdrawn from the examination due to incompleted courses. Another application was C\ subsequently submitted for him and no discrepancies were noted between the second application and his training file.

ELLSAESSER, Charles W.

No discrepancies were noted between application and training file.

FRANCO, Samuel F.

No discrepancies were noted between application and training file.

  • HERRING, Homer (n) l' - failed cycle 1 of the 12 week Cold License Training, no evidence of make-up examination j ._

39 b

J 2- the 6 week HT-FF course is documented as 3 weeks only 3- the 2 day Radiation Worker I and II courses are documented separately as 4 distinct courses of 1, 3 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Credit By Examination 4- the 3 week Rx Physics and Heat Transfer review is undocumented 5- the 2 week Administrative Procedure and Plant Operating Procedure Review is undocumented 6- the 2 day MCD course is undocumented HOLCOMBE, Terry H.

No discrepancies were noted between application and training file.

]

HUMPHRIES, Stephen W.

1- the 12 day Simulator Refresher Training is documented as only 10 days 2- the 5 week Supervised Self Study is undocumented t

MCDOWELL, Michael D.

j No discrepancies were noted between application and training file.

l 4

MCINTYRE, Thomas 0.

1- the 12 day Simulator Refresher Training is documented as

  1. only 10 days ~~

i

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40 l O 2- the 5 week Supervised Self Study is undocumented l

MCKNIGHT, Huohie E.

No discrepancies were noted between application and training file.

1 SAPP, Michael D.

1- the 10 week Reactor Training course is undocumented 2- the 12 week BWR Systems course is undocumented 3- the 12 week Balance of Plant course is undocumented 4- the 2 week Technical Specification course is undocumented 5- the 1 week Thermohydraulics course is undocumented 6- the 2 day Health Physics course is undocumented 7- the 7 day Simulator Certification course is undocumented 8- the 1 week MCD course is undocumented 9- the 1 week HT-FF course is undocumented 10 - the 5 week GG Systems course is undocumented 11 - the 5 day Amin. Requirements course is undocumented 12 - the 1 day RWI and GET course is documented as an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> GET course only 13 - the 1 day RWII course is documented as a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> course only ~~-

_ . - - . - . - - - - . ~ - . . . _ _ - _ .. .-..- - .. -._____.- - . ..

41 1

INVESTIGATOR'S NOTE: This applicant is no longer employed by the licensee.

WALKER, Kenneth L.

No discrepancies were noted between application and training file.

It was noted during the reviews of individual training files that not all j of the training courses and activities documented therein appear on the i applications of the license candidates. A complete copy of the training I file for each current operator and individual training history sheets for I

former operators, as provided by the licensee, are being retained in the case file at 01:RII.

O i

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1 1

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42 n

v Interview of Initial License Candidates During the investigation both current and former NRC license examination candidates of the MP&L/GG f acility were interviewed regarding the completion of QCs and other training activity reflected on their applica-

~

tions. The applicants identified below, all members of the initial " Cold License" class, each had the entry Cold License Operator Qualif.ication Card on the September 3,1981 application for the R0/SR0 license examination.

The letters "C" and "F" beside each name designates " current" or "former" employee of the license.

BEARDEN, William Clay (F)

BENEFIELD, Keith William (F)

BYRD, Lawrence Robert (F)

CADE, Walter Charles (C)

CRESAP, Charles Edgar (C)

FRAZIER, John Burke

(' (C)

( GORDON, William Keith (C)

HALL, Errol Keith (C)

HICKS, Charles Vincent (C)

HOTHAM, Andrea Dee (F) _

JACOBSON, Ronald Keith (C)

JOHNSON, Gilbert Alan (F)

KEETON, Roy Green (C)

LEWIS, Billy George (C)

LHAMON, Gary Duane (C)

MANBY, John Forrest (C)

MCDONALD, James Kelly (C)

MCMILLIN, George Lewis (C)

MILLER, Lee Roy (F)

MOULDER, Larry Sevan (C)

POWERS, Roger Noklin (F)

ROBERTSON, James Lee (C) g RUSSELL, Wayne Allison (C)

SHELLY, William Michael (C) .-,

,w7 _ - . _ - ._, _. -

-T - - - . . - -

43

\

STAFFORD, Clark Daniel (C)

WHITE, James Lamar (C)

.:y, alk + _

He acknowled,yed signing and dating the third page of the NRC license examination application but stated he did not see the complete application when he signed it, stated that the QC entry is incorrect. He stated he was never issued a QC at the MP&L/GG facility and that he was told by a former Operations Superintendent during his pre-employment interview that he would not be required to work on a QC. I advised that other license candidates at MP&L/GG, including i 5 , did not have QCs issued to them. ,

I A 9 -

CN s

He reviewed his NRC license examination application and acknowledged he signed and dated the third page but said he did not see the completed document before it was transmitted to the NRC.

9 '

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, He further acknowledged that he worked on his QC but never completed this document due to shift time constraints and because no definite procedures were provided by the licensee, said he would have corrected these discrepancies in his application if he had been given the opportunity to review it before it was submitted to the NRC. He stated he reviewed his individual training file at MP&L/GG and noted that this record failed to document some of the training listed on his application. He said he kept no personal records to verify the training he received because he assumed this was the responsi-bility of the MP&L/GG training department.

o V .-

.. a 44 j s

- i He stated he was enrolled in the Licensed Operator Training Program upon his arrival at the MP&L/GG facility. j described initial GG training and operations department officials as  ;

unorganized, inconsistent, inexperienced and lacking knowledge regarding -

training required by operators to prepare them for the NRC license examination. He also stated that, in his opinion, these licensee officials delegated too much operator training responsibilities to vendors and they failed to take an active supervisory role in this activity.

! advised that he was issued a QC in " ,fwhich he did not complete as no written procedures or guidance policy for completing this document was provided to him. He said that the licensee officials in the MP&L/GG Operations Department reper.tedly failed to insist upon the completion of this document and therefore minimal effort was devoted to the QC. He said some SRO candidates, including I were never issued a QC. advised that MP&L/GG training officials also failed to properly record the trai'ning completed by license candidates and it was therefore impossible to rely upon the individual operator training files to verify training. He said that due to frequent changes in training, management personnel, reliance upon contractors and limited personal and fiscal resources in this department the 't raining program, in his opinion, was given low priority and received little attention.

, advised that his license examination application to the NRC, as well as those of other initial applicants was most likely prepared by RTS (vendor) employee Terry MOUNTAIN. He stated he signed and dated the third page of his application in good faith and without seeing the remaining portions of this document.

saw his complete application for the first time. stated he also noted inconsistencies in his individual training file, including absence of any documentation reflecting he completed some courses listed in his applica-

/ tion. "

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46 p) i v'

PQDR 5-73 addresses the absence of training file documentation to support required training courses reported as -

completed by some operator personnel, a topic which is covered by the investigation. PQDR 6-73 concerns emergency diesel generator operations training by licensed and non-licensed personnel. PQDR 8-73 is similar to PQDR 5-73 in that it relates to training file documentation of SR0 instruction on the basis for plant technical procedures. These latter two PQDRs do not relate to the purpose of the investigation, f l He reviewed his application and acknowledged that he had signed and dated the third page but could not recall seeing the complete application. He stated

( he noted no incorrect data under Formal Training except that he never

\

completed the QC as reflected therein.

l He acknowledged signing and dating the third page of his application but said he does not recall seeing the complete application. stated he could not recall the durations of all courses listed in the Formal Training section but assumed the licensee kept accurate records and reported correct information on his behalf when his application was submitted to the NRC.

He stated he was issued a QC by the licensee and he recalled completing all except advised that, in his opinion, the MP&L/GG operator training program was deficient in both instructional and administrative resources.

O All three operators acknowledged signing and dating page kh three of their application, were unable to recall

47

(

seeing this completed document before it was submitted to the NRC in September 1981. They all stated that a training department official, possibly a vendor employee, brought their applications to them for signature and indicated some urgency in having them completed and forwarded to the NRC. reviewed his application and advised he did not recall taking the -

advised he noted no discrepancies under the Formal Training section of his application except that he had not completed his OC. ~ stated that his initial application to the NRC appears to contain only one discrepancy which is the Oc entry. He said he did not complete this requirement and this entry must have been added to his application after he signed it since he does not recall seeing it on the complete application when he signed and dated it. j contains the QC entry which is also incorrect since he had not completed this document at that time. Both f- s x complained of inadequate training records management by

/

(v) the licensee and further expressed concerns that the MP&L/GG operator training program was mismanaged and improperly staffed when he received training in also advised that, in~

his opinion the instructors, who were mostly vendor employees, were .

unprepared to teach and were only marginally familiar with the course material they were presenting, that it was not staffed properly to accomplish objectives and the licensee relied too heavily upon education service vendors and contractors to instruct and develop courses in the license training program. reviewed application to the NRC and advised that did not attend the listed on application. advised that was never issued a QC and saidll never

/'~'t worked on this aspect of Cold License training. stated """ read and j V reviewed application in its entirety and is certain the QC entry under-

48

,/ 7

\

v) the Formal Training section was not on application when signed it, did not see application again until about October 1983 and it was at this time noted the QC entry, identified MP&L/GG employee LEE and/or a former contractor employee of RTS Corporation working at the GG facility, as the individual (s) responsible for preparing the

~

license examination applications for the initial candidates. ~

stated that former MP&L/GG training department employee discovered documentation and record keeping problems in operator training files about October 1982 and verbally informed the Training Superintendent of these deficiencies, said eventually identified these training record discrepancies regarding QCs in a PQDR after verbally informing the MP&L/GG Plant Manager of these

' said these records problems were

~

deficiencies in December 1982.

initially presented to MP&L/GG officials as missing or misplaced documen-tation rather than the failure of a license candidate to complete a

, particular requirement. According to Plant Manager MCC0Y attempted to shield MP&L corporate officials from the training problems at the GG facility. said that MP&L/GG Training Superintendent HUNT sometimes procrastinated in his actions to inform the NRC of mistakes made in license

! examination applications for fear the licensee would be viewed as incompetent and unreliable in plant operations, further advised that MCC0Y placed a sense of urgency and a feeling of pressure on some training matters and stated the August 1983 accelerated completion of QCs directed by MCC0Y for license candidates MCDOWELL, BURRIS, WALKER and ELLSAESSER is an example, said MCC0Y arbitrarily ordered the accelerated completion of training, including QCs, for these individuals and to pressure Quadrex employees to obtain the necessary QC signatures. advised that it was never intended by MCC0Y that the QC completions be accomplished in any illegal manner; however, the time allotted for this process was insufficient and the manner in which the training had to be accelerated was unfair to the trainees.

concluded that was unaware that false statements were willfully submitted to the NRC and said is not aware of willful attempts to

(' conceal false information from the NRC.

( --

49

( I NJ' Both sources reviewed the third page of their application and acknowledged they had signed and dated it. These individuals advised that the portion of the application which listed formal training completed was not presented to them when they signed these docu-ments. stated he was issued a QC but said he did not complete this document as indicated in his application. recalled that he completed his QC; stated he has not seen this document in a very long time; and furthermore , noted no discrepancies in his application.

believe the licensee has not maintained adequate training records to verify their achievements. He also stated that these same operators are of the opinion that the NRC is penalizing them for inefficiencies of the licensee.

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reviewed his license examination application and acknowledged that he signed and dated the third page. He said he did not see pages one and two before they were submitted to the NRC. He stated the courses listed under the Formal Training Section of his applica-tion were completed cn a " Credit By Examination" (CBE) basis rather than class attendance. He further advised he never worked on a QC while at the MP&L/GG facility because a memorandum between the training and operations departments excused him and other supervisors from this requirement.

advised that the QC program never received proper attention while he was employed at the MP&L/GG facility and its completion was not emphasized by management.

M advised that he did not see his complete license examination application He submitted to the NRC by the licensee, although he signed and dated page g'~' three of this document. advised that he did not recall taking the

( ) _, course and further said he -

50 t /

'd questioned the durations of some courses listed on his application. He advised that he completed the QC requirement as indicated on the appli-cation; however, the licensee has no record to verify that this document was completed. advised he and other operators are concerned that the licensee has failed to properly maintain and manage training files and records. He also advised that no licensee documentation exists which ~

exempted license candidates from comoleting the QC since this is an FSAR commitment.

He reviewed his application and acknowledged signing and dating the third page of this document. He said he did not review the completed application prior to its submission to the NRC. He advised that his application contains only one discrepancy which is the QC entry under Formal Training and said he started but never completed this training activity, (p) and v '

advised that he signed and dated his license examination application without reviewing the completed document. He said that Plant Manager MCC0Y informed him and other operators about mid October 1983 that the NRC was investigating inaccuracies and discrepancies in the license applications of' the initial GG license class. He said MCC0Y offered to provide legal counsel and any other company assistance to any operator who felt this protection was needed, advised that this discussion evolved 'nto a session in which it was determined that the deficiencies in the applica-tions resulted from deficiencies in individual training files.

stated he then reviewed his complete application for the first time and said he noted that some training courses listed in his application were misleading because they were not taught separately but as one presentation.

He cited the listed on his application, which were presented as one course, as an example of misleading informa-tion. He stated he also recalled that the 'p, m -

(d\\

said he was

51 issued a QC but never expended any time or effort on this document because he was told by someone, name not recalled, that he did not have to complete this training requirement. He stated he did not authorize the QC entry to '

be placed on his application and he would have insisted that this and other incorrect information be removed if he had reviewed his application before it was submitted to the NRC, advised he suspected that ~

added this entry to applications of initial applicants or either he knew who was responsible for doing so.

concluded that operator training has not always been assigned the priority it should have received at the MP&L/GG facility. He advised that although training conditions have improved, there still remains some confusion, lack of organization and mismanagement in the training department.

All three individuals acknowledged they had

, signed and dated the third page of their license examination applications I

but they did not review the completed application before it was forwarded

[ to the NRC. upon interview, reviewed his application, noted no discrepancies and advised he completed his QC before his application was submitted to the NRC. reviewed his application and pointed out l several discrepancies contained therein. He advised that the also advised that he did not complete the QC as indicated in his application. He said management of training records has been a perpetual problem at MP&L/GG and the training records clerk or other training official had misplaced verifying documentation. He said vendors and contractor personnel assigned to the training department do not appear to have the proper interest and attitude regarding records and they are sometimes negligent in performing both cle:sroom duties and administra-tive responsibilities. concluded that operator morale has suffered now that they are aware of the deficiencies in the training records caused by lack of management controls. Iadvised that he g doubted the duration of some courses listed on his application but said he - -

52 O

did not maintain the necessary records to dispute this information. He advised he was issued a QC but never completed this document, either before or after taking the NRC license examination.

M:

He said the signatures appear to be his and that the second page (training history)

He stated he did not see completed application before it was submitted to the NRC. advised he questioned the duration of some courses reflected on his application and further stated he did not recall a l He advised he completed his QC,  !

n V) He advised he signed and dated page three but did not see the complete license examination application to the NRC. He stated he signed it "in blind faith" that the licensee had ensured all entries were correct and properly" documented in training files. He O'tated he recalls all Formal Training listed on his application except the QC, He said he never had a QC.and stated he was told by John RICHARDS,0N, Michael ANASHANSLEY and Gilbert JOHNSON, fomer MP&L/GG Training and Operations officials that he was exempt from this requirement. He said he never saw a memorandum which exempted him from the QC requirement, although each of these individuals advised they were placing a memorandum to this effect in his training file, advised he would never have signed his application if he had known l the QC entry was contained therein.

l l

o, ,

U acknowledged his signature but advised that he did not recall signing and- .

53

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dating page three of his NRC license examination application. He said he did not see the complete document before it was submitted.

He reviewed the Formal Training Section of the application and stated the only discrepancy noted is the entry which indicates he completed his QC. @ advised he did not complete a QC, although he said he worked on this document while at the GG facility. .

Each of these individuals reviewed a copy of the application submitted to the NRC in their behalf by the licensee and they each acknowledged their signatures on page three of this document.

Only recalled seeing the completed application prior to its submission to the NRC. advised that, contrary to their applications, they never worked on a QC because they were verbally informed by former Operations Superintendent JOHNSON that they g] were not required to complete this document. They said JOHNSON told them

( ) he would document their files accordingly, although each advised they have never seen any exempting documentation, advised that he was issued a QC but said he did not complete this requirement. All of these operators stated they assumed that the MP&L/GG Training Department was ,

maintaining accurate information on courses and requirements completed and therefore they did not maintain their own records. All stated that the QC entry is a false entry on their applications and I stated he believes this entry was added after he signed his application.

All of these individuals expressed concerns, variously, regarding inattentiveness to detail by training department officials, unprepared instructors teaching training courses, insufficient training staff, general lack of organization in the department, a breakdown in coordinating the assignment of trainees l to the required courses and a failure to maintain accurate and complete documentation to verify that trainees have completed a required course or activity.

I l

i 54 k

He advised

that he could not recall seeing his license examinatior application at the time he signed and dated the third page. He advised that he noted no inaccuracies in his application and said he completed the QC issued to him,

, volunteered that the .

MP&L/GG Training Department "looks good on paper but it leaves much to be desired." He stated that, in his opinion, GG officials have relied too heavily upon vendors and contractors in the training department and these individuals do not have the concern and interest of the training function that licensee employees would have. He stated he believes that the licensee has been negligent in record keeping requirements associated with operator training and the qualifications of some instructors is marginal.

{ and all other operators claimed no knowledge of willful false state-ments by the licensee or of attempts to conceal false information that was submitted to the NRC.

O 9

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.. . .- . . - . - . - - _ . . = _ - . . _. . _, . - _ - . _- --

55 f

Interview of Other MP&L/GG Operator Personnel The personnel identified in this section of the investigation report are j all current operators at the MP&L/GG facility. Their license examination applications were submitted to the NRC at various times, as indicated in EXHIBIT (12), after the initial group of applicants, utilizing both the old and the new application forms. The following individuals were interviewed:

EHRHARDT, Karl F.

. HERRING, Homer (n)

HOLCOMBE, Terry H.

i HUMPHRIES, Stephen W.

MCINTYRE, Thomas 0.

MCKNIGHT, Hughie E.

EHRHARDT was interviewed on November 9,1983 and advised his application

. was submitted to the NRC on September 30, 1982. He stated he reviewed his l application in its entirety before it was submitted and to his knowledge all of the information contained therein is correct. He said he did not l maintain records of his training at MP&L/GG since he assumed the training l

i department was responsible for maintaining accurate and complete records.

He advised that he had completed all required courses and activities, including the Control Room Operator Qualification Card, before he received his license in March 1983.

+

  • HERRING was interviewed on December 13, 1983 and advised that he did not

! review his application before it was submitted to the NRC. He stated he

did not participate in the preparation of his application nor did he know which courses are listed under the " Formal Training" section of this

, document. HERRING advised that he has never completed his QC, although one was issued to him by the MP&L/GG Operations Department.

} HOLCOMBE was interviewed on November 8,1983 and advised that he recalled I

no problems or discrepancies regarding his application. He stated he had 3

completed all course and activity requirements, including the QC, prior to

\J the time he received his license. ~~-

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56 O

kf' HUMPHRIES was interviewed on November 9,1983 and advised he did not recall reviewing his application prior to submission to the NRC. He said he recently reviewed his application at the request of the operations depart-ment superintendent. He stated he noted only one discrepancy in his application which is the training listed as the 12 day Simulator Refresher Training course. HUMPHRIES advised that this should have been recorded as a 10 day course only. He advised that he did not complete a QC, although one was issued to him when he was assigned to a shift in 1979. He said he was told that he did not have to complete this document and therefore never worked on it. He said he took the NRC examination and passed it so MP&L/GG facility management made the decision he would be exempted from retroactive completion of the QC requirement. He advised he does not recall who made the decision or who told him he was exempted from this activity. HUMPHRIES advised that the current feeling among operators is that the licensee has not been responsive to operator training needs and requirements of the candidates and they have failed to maintain accurate records to document all of the training the operators have actually received.

O-t 1 MCINTYRE was interviewed on November 9, 1983 and advised he did not recall seeing his application before it was submitted to the NRC. He said he subsequently reviewed it and noted only one discrepancy which is a 10 day Simulator Course listed as a 12 day course. MCINTYRE advised he first took the NRC license examination in December 1982 and his QC was not complete at that time. He said he was re-examined in April 1983 at which time his QC was completed.

MCKNIGHT was interviewed on November 9,1983 and advised he noted no discrepancies in his application prior to it being submitted to the NRC.

He said he completed all of the training activity listed on his application and also the QC requirement prior to receiving his license.

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59 Interview of Current and Former Licensee Officials T

i Interviews of current and former MP&L/GG training, operations and corporate officials were conducted. The folicwing individuals were interviewed:

John Edward CUSTER, Jr. (former employee)

Douglas Leon HUNT.(current employee)

Charles Kenneth MCC0Y (current employee)

James Porter MCGAUGHY, Jr. (current employee) 4 Jerry Wayne YELVERTON (current employee)

Thomas EDISON REAVES (current employee)

CUSTER was interviewed on November 15, 1983 at the Shoreham Nuclear Power Plant, Shoreham, New York. He advised that he was employed at the MP&L/GG facility from July 1980 to November 1982. He said he served as the Training Superintendent from July 1980 to January 1982. CUSTER advised that Plant Manager MCC0Y hired him to develop, implement and/or procure V through consultants all of the training services and programs at the GG facility, including those for operator training. He identified the consul-tants utilized during his tenure as RTS, General Electric and Quadrex, Inc.

He advised that RTS first became involved in operator trainirg at the GG facility about July 1981 and employee Terry MOUNTAIN was tne primary

, individual associated with this activity. He said MOUNTAIN was knowledge-able in training matters and for this reason he was delegated significant responsibilities in the Cold License training program. CUSTER advised that because of MOUNTAIN's previous experience with NRC license examination applications he was additionally delegated the responsibility of preparing the initial 34 applications for R0/SR0 license examinations. CUSTER stated he personally researched the regulations to determine the types of information required in the application and said he and MOUNTAIN designed the application form to accommodate this information. CUSTER stated that he also attempted to implement and develop a system to organize and maintain the voluminous operator training files and records. He described individual license candidate files as being in complete disarray and totally undocumented at the time he became the Training Superintendent. He i advised that MOUNTAIN, utilizing the unorganized individual operator files,

i

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60 a

Q was directed to compile a list of courses / training activities completed by the 34 initial applicants and entered this information under Item 7,

" Formal Training," on each of the applications. CUSTER recalled that licensee employee LEE, who was an Acting Supervisor in the MP&L/GG Training Department, possibly assisted MOUNTAIN with application preparations.

m e

CUSTER advised, after rev'iewing copies of the 34 initial license examination applications, that the Cold License Operator Qualification Card entry on 33 of the 34 initial applications was probably added after he approved these documents for submission to the NRC. He identified license candidates with this application entry who had never i

received and/or worked on a QC.

l.

He advised that he never prepared or saw an MP&L/GG memorandum exempting any applicant from the QC requirement. CUSTER stated that he

/O believed the QC entry was placed on the initial applications by an individual, who knew this requirement had not been

completed by most applicants. CUSTER concluded that he is responsible for the failure of some applicants to complete their QCs but he was not respon-sible for this entry being placed in the initial applications. CUSTER's signed, sworn statement is EXHIBIT (22) to this report.

HUNT was interviewed in his office at the MP&L/GG Training Department on l November 30 and on December 7 (telephonically) and 15, 1983. HUNT advised that he has been employed at the GG facility since January 1978 and said he has served as the Training Department Superintendent since February 1982.

HUNT cited long standing training department problems at the GG facility, ,

including the lack of adequate instructional and administrative resources, inadequate management and supervision of the department and an, apparent inability by the company to develop and implement a total training program, including operator training. He advised he was hired in his present job to a

eliminate-these deficiencies. He described the condition of training files and records when he assumed his present job as unorganized and in disarray, g HUNT advised that his first indication of inadequate and missing training s 4

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l 61 course / activity documentation in the operator files was about mid 1982 wnen l former employee BYRD verbally identified these problems to him. He said BYRD described these discrepancies as missing documentation problems rather than as the failure of candidates to begin or complete a license exami-nation requirement or training course. HUNT advised he failed to respond imediately to BYRD's training record concerns because BYRD had not formally identified the extent of his concerns in proper documentation and because BYRD was a " chronic complainer." HUNT advised that he also failed to perform an immediate independent assessment of BYRD's concerns until they were documented by PQDR in January 1983. HUNT advised that BYRD also informed training' department officials LEE and HOTHAM of individual training record problems but neither of these individuals pursued his complaints because of personality conflicts and philosophical differences in training management. He said BYRD's concerns addressed missing documen-tation to verify QC completion by some license examination applicants.

HUNT advised he personally supervised a review of operator training files and other training records during early 1983 in an attempt to locate QC and

[]

V other missing documentation. He stated he informed an NRC Training Assessment group in February 1983 that records discrepancies pertained to documentation of QCs completed by license examination applicants rather than the failure of applicants to complete this requirement. He advised that he continued to search for missing QCs after the NRC review and he prepared an April 13, 1983 memorandum (IPC-83/1548) to the file reflecting that some QCs for licensed applicants could not be located. He advised he should have, at that time, informed the NRC that some QCs could not be located; however, since these applicants had already received their licenses ne did not consider it necessary to do so. HUNT stated that LEE had earlier informed him that some initial applicants had been exempted from the QC requirement and that a memorandum had been placed in their files. HUNT advised that the OC completion issue surfaced again in August 1983 when a Region II, NRC officia.1 commented during an exit conference l

with Plant Manager MCC0Y that the PQDR regarding QC documentation had not

! been closed in a timely manner. HUNT stated this comment prompted MCC0Y to l

resurrect the QC issue and to consider the possibility of material false l

statements in the initial applications. He advised that a review of all ~

! license examination applications submitted to the NRC by MP&L/GG was

_ .. -_ .-_. ._ ~ _ _ _ . - _ __ - _ - -

62 O ordered by MP&L Vice President MCGAUGHY in September 1983. HUNT advised that some applications with the QC entry, which were submitted to the NRC on more than one occasion, were duplicated from the initial application.

He advised that former Training Superintendent CUSTER or his delegate was responsible for completing initial applications. HUNT denied any personal improprieties regarding false information in applications but acknowledged I that he or other MP&L/GG officials were remiss in not promptly pursuing reported discrepancies and informing the NRC of this matter. A copy of HUNT's Results of Interview is EXHIBIT (23) to this report.

MCC0Y was interviewed on November 21, 1983 and related he was the Plant Manager at the GG facility from 1978 to November 21, 1983, when he became the Special Assistant to the Senior Vice President. MCC0Y acknowledged that the Plant Manager is responsible for all GG activities but advised he delegated training duties to a Training Department Superintendent. MCC0Y advised that Training Department Superintendent CUSTER was responsible for preparing the 34 initial license examination applications submitted on September 3, 1981. He said he, did not personally verify the accuracy of the data contained in these applications since he delegated this responsi-bility to CUSTER. He advised he became aware that some of the initial applications contained false information relating to the completion of a Cold License Operator Qualification Card about August 1983. He acknow-ledged that he was apprised of documentation problems associated with QCs in early 1983 but clarified that he then understood those problems to be missing and/or lost documentation to verify completion of this requirement by operators. MCC0Y said he has been aware since 1978 of the FSAR commit-ment that all license candidates complete a QC and he said he has never exempted any candidate from this requirement. MCC0Y stated that MP&L/GG officials " screwed up" by failing to keep accurate and complete operator training records and by failing to conduct thorough reviews and verify application entries against training record information. He acknowledged that he delegated too much responsibility in the training department without providing adequate supervision. MCC0Y denied any personal improprieties regarding false entries in license examination applications.

He said MP&L/GG officials did an " unacceptable" job in preparing these applications due to inexperienced personnel in the training department,

63 NJ failure to adequately review applications and because of excessive utilization of contractors for this activity. A copy of MCC0Y's signed, sworn statement is EXHIBIT (24) and a copy of the Results of Interview is EXHIBIT (25) to this report.

MCGAUGHY was interviewed on November 22, 1983 and advised he is Vice President, Nuclear, with MP&L. He said the GG Plant Manager reports directly to him and stated he (MCGAUGHY) is responsible at the corporate level for the operation of the facility. MCGAUGHY advised that he recalled a July or August 1981 telephone call from the GG site regarding submission of the initial applications to the NRC. He said he cautioned the caller to make certain all FSAR commitments were completed when applications were forwarded to him for corporate review. He stated he did not specifically mention QCs but had these in mind when he issued his precautionary remark.

MCGAUGHY adyised that he personally performed a cursory review of the initial license examination applications and the training file for each applicant. He advised that he did not verify the information contained in C/ applications since he assumed the Training Superintendent or the Plant Manager had performed this task. MCGAUGHY advised that after he signed the NRC transmittal letter dated September 3, 1981, all applications were returned to the GG facility for mailing. MCGAUGHY stated that in early 1983 he became aware of some general record keeping problems as a result of a PQDR and an NRC Training Assessment report. He advised he did not begin to learn the details of these problems until August 1983 when, in a conver-sation with Region II, NRC official Caudie JULIAN, he was asked about the QC documentation issue. He said JULIAN informed him that some of the initial license candidates had not been issued a QC, cor.trary to the entry contained in their applications. He advised that he made additional inquiries regarding the content of license examination applie:ations and found additional errors and discrepancies, all of which were reported to the NRC in October 1983. MCGAUGHY acknowledged that MP&L/GG officials failed to prepare applications properly and said they did not document records adequately to verify that the informdtion contained in these applications was accurate and complete. He cited inexperience and lack of facility management's involvement in the review process as the reasons for the false application information. MCGAUGHY advised he is not aware of any

64 4

I J MP&L/GG document or procedure which exempted any license candidate from the QC requirement. He advised that about October 1983 an RTS employee Terry MOUNTAIN, formerly employed at the GG facility, told the MP&L l

Corporate QA Manager that LEE instructed him (MOUNTAIN) to put the QC entry on all applications but said MOUNTAIN later retracted this comment.

MCGAUGHY denied any knowledge of or personal improprieties regarding submission of false information to the NRC. He stated that the majority of the QC entries on the applications are false and that the individual responsible for this was aware that some candidates had never been issued a QC, A copy of MCGAUGHY's Results of Interview is EXHIBIT (26) to this report.

YELVERTON was interviewed on December 15, 1983 at the GG facility and stated he has been employed with MP&L since December 1979. He advised that he served as the site QA manager until October 1983 when he became the Assistant Plant Manager. YELVERTON advised he first became involved with application discrepancies when the Training Department Superintendent asked U/ for an independent audit of training files and records in 1983. He said this audit was not a QC review but one designed to verify the contents of PQDR 7-83, which identified lack of QC documentation in operator training files. YELVERTON advised that he was not directly involved with the'se documentation and training records problems again until he became the GG Assistant Plant Manager. YELVERTON advised that, in his opinion, the prevalent feeling at the GG facility has been to qualify reactor operators "at all cost." He said upper management at the site created a " pressure cooker" atmosphere to accomplish training necessary to achieve this objective. He stated that this attitude and these conditions have changed with the replacement of MCC0Y as the Plant Manager. YELVERTON further advised that as the Assistant Plant Manager he has been delegated the responsibilities of identifying all training department problems and discrepancies and of taking the necessary remedial measures to ensure that all operators are properly certified, their files and records correctly j documented and training commitments achieved prior to licensing. He said he is of the impression that the MP&L/GG training department staff has not until recently been aware of all the training commitments and requirements and this has created the problems which exist there at the present time.

65 O

YELVERTON stated he does not believe that the submission of false license examination application information was done deliberately to expedite the issuance of licenses. He said that he is of the opinion that neither HUNT nor MCC0Y recognized material false statements in the applications and neither recognized the significance of the QC issue after it was surfaced as a documentation problem. YELVERTON advised that the licensee's attempts to resolve internally the training record and file problems and discre-pancies without timely NRC involvement was obviously a mistake and an example of poor judgment by facility management. YELVERTON concluded that MP&L/GG management concedes they have made serious errors in judgment and that they are willing to accept the consequences of these mistakes.

REAVES was interviewed on February 9 and 10, 1984 and advised he is corporate Quality Assurance Manager. He stated he was directed by the Senior Vice President to convene an investigation of initial license examination application discrepancies for those operations personnel currently employed at the MP&L/GG facility. REAVES advised that his s investigation disclosed numerous errors, discrepancies and false entries in the initial license examination applications. He identified these applica-tions problems as no record to support completion of training for some applicants, including the QC, and incorrect training course information in applications. He stated that most current operator employees acknowledged some error or inconsistency between applications and training files. He said they attributed these discrepancies to the fact they did not see or failed to carefully review their applications before they were submitted to the NRC. He said operators complained variously regarding the substandard quality of the training effort, inadequate record keeping practices and mismanagement in the training department. REAVES advised that initial applicant HOTHAM, who is no longer employed at the GG facility and former training superintendent CUSTER offered that the QC entry had been added after the review process. REAVES advised that RTS contractor employee MOUNTAIN, formerly at the GG facility, first stated and then retracted that he was told to place the QC entry on all initial applications. He said MOUNTAIN was unable to recall who told him to place this entry on initial applications. REA ES advised that he learned during his investigation that U some initial operators were supposedly exempted, in writing, from the QC '~

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t 66 requirement but said he did not locate any documentation to support this claim. He stated he did review certain MP&L/GG documents which designated certain shift supervisors as qualified to sign other QCs and from these j memoranda he deducted they must have been exempted. He stated that he did not identify any evidence of willful wrong doing by MP&L/GG personnel nor did he determine how erroneous information, such as the QC entries, were l placed on initial applications. A copy of REAVES' Results of I terview is i

EXHIBIT (27) to this report.

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67 v Interviews of Contractor Personnel During the investigation it was determined that personnel employed at the GG facility by the Quadrex Corporation, Tulsa, OK., were aware of infor-mation pertinent to this investigation. Two of the Quadrex employees interviewed were assigned to audit and analyze operator training files and -

records in the training department and the remaining three were involved in the " accelerated" completion of QCs for four license candidates. The following Quadrex personnel were interviewed:

Lawrence Edward KOKAJK0 Steven Lewis OSWALD Billie Gene JONES Gary K-Don ADKINS James Herbert MCDONALD m)

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All of these Quadrex individuals advised that the candidates were examined and quizzed as a group, rather than individually, regarding the QC contents, either in a classroom or in the simulator. They said a plant "walkthrough" was not accomplished due to time limitations imposed by the licensee. They advised that the conditions and circumstances under which these QCs were completed violated both the spirit and intent of this requirement. They advised that they felt a sense h of direct pressure from the licensee to complete these QCs and each stated they believed that their failure to follow the directions of licensee officials could jeopardize the Quadrex contract. They stated that the accelerated completion of the four QCs was a " joke" and a " farce" and that the manner in which the QCs were completed also violated the administrative ~

procedure regarding completion of the QC. All interviewees stated they had administered all parts of the QC to the four candidates and that they felt comfortable and satisfied that the applicants could operate the plant systems safely and satisfactorily. Each reiterated that they would not have participated in the accelerated QC completion effort if they had not felt pressured and coerced by the licensee to perform this activity.

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70 v Interview of Gerald Richard MOUNTAIN MOUNTAIN was interviewed on November 14, 1983 at his office in Canton, CT.

He advised he is Vice President and Director of Field Service for Resource Technical Services (RTS), Toledo, OH. He said he was employed by RTS at the MP&L/GG facility from July 1981 to January 1982. MOUNTAIN advised that his responsibilities with the licensee during this period included class-room instructing, developing and implementing various operator training courses and programs for R0/SR0 candidates and compiling training information for the initial license examination applications. MOUNTAIN advised he completed a handwritten draft application for each initial applicant and presented the draft to MP&L/GG Training Department Super-intendent CUSTER. MOUNTAIN said he obtained all Formal Training entries in l applications from individual operator training files. He stated he does not recall placing the QC entry in the initial applications but if he did so the information came directly from each applicant's training record.

MOUNTAIN advised that applicants were frequently reminded to complete their j QCs and said he is not aware that any candidates were exempted from this FSAR requirement. MOUNTAIN advised he did not know why only the applica-tion of LEE among the initial group failed to contain the QC entry. He said not all courses listed on the initial applications were complete at the time they were submitted; however, the licensee intended for these courses to be completed before the examination was administered. MOUNTAIN advised that he never became involved in the very complex system of keeping operator training records while at the GG facility. He advised that the initial license examination applications were hurriedly prepared and were not reviewed to verify the accuracy of the information contained therein.

He also said the training department was understaffed and the clerical personnel were inefficient and untrained during his tenure at the MP&L/GG facility. A copy of MOUNTAIN's Result of Interview is EXHIBIT (30) to this report.

INVESTIGATOR'S NOTE: Throughout the course of the interview with MOUNTAIN, he behaved in an indifferent and perfunctory manner. He

, frequently made critical and sarcastic remarks about the NRC and the ..

licensee, oftr.n in a disruptive manner. He repeatedly questioned the

i 71 i

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necessity for the NRC to pursue the QC issue at the GG facility. He

belittled the investigation effort and the emphasis being placed upon j the issue of incomplete QCs. In the opinion of the reporting
investigator, MOUNTAIN was less than candid regarding his knowledge of
and participation in the placing of the QC entry in 33 of the 34 initial applications. Finally, MOUNTAIN very vehemently declined to i

q provide a signed, sworn statement, stating that it would have an

adverse affect upon his company throughout the nuclear industry for him to do so.

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Interview of John Charles BELL BELL was interviewed on December 15, 1983 at the GG facility. He stated he has been employed with MP&L/GG since November 1980. He advised he served

as a Senior Quality Assurance (QA) Representative until August 1983 when he enrolled in the License Training Program. BELL recalled thc.t about March or April 1983, Training Superintendent HUNT requested that the site QA department conduct an audit of the operator training records. He said he personally conducted the audit, looking at all MP&L/GG licensed operator training files to make certain all operator training was doct.mented and to determine whether all training requirements had been completed by these individuals. He said the audit was a very informal one and was never reduced to a written report, although a two page handwritten summary was prepared for HUNT. He stated that this audit disclosed that QCs for 24 licensed operators were missing and some training files lacked adequate documentation to verify the completion of training courses. BELL advised that, except to answer a few questions for HUNT several months after he

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73 O Interview of Clerical Personnel Interviews of MP&L/GG Training Department clerical personnel were conducted in an effort to obtain amplifying information regarding the preparation and submission of the initial license examination applications. The following clerical employees were interviewed:

Deloris (n) MIMS Anita Sue HERRING MIMS, interviewed on November 12, 1983, advised she has been employed as a typist in the MP&L/GG Training Department since September 1980. She advised that, in addition to typing duties, she has also filed records and annotated training documents. MIMS reviewed the 34 initial license

. examination applications and the NRC transmittal letter and advised that she recalled typing all of these from rough drafts provided to her by former Training Superintendent CUSTER. She said she could not recall if

( the QC entry was on the rough draft provided by CUSTER or whether this entry was added later by LEE or MOUNTAIN. She said that the formal training information on applications was constantly changed on the initial applications to add or delete entries. She said she did not know the rationale for these changes. She advised that the rough drafts were destroyed when the applications were finalized. MIMS claimed no additional information pertinent to this investigation.

HERRING, interviewed on December 13, 1983, advised she has been employed at j the MP&L/GG facility from June 1980 to October 1983 when she was placed on maternity leave. She described her clerical duties in the Training Depart-ment as routine, commenting that she became involved during September 1980 with setting up individual training files for the license candidates. She said that prior to this date there were no individual training history sheets on which to record the training received by the applicants. She

! said she obtained individual training information from the volumes of unorganized course completion sheets and course materials and entered this

,. data onto the history sheets. She stated that procedures for maintaining ,_

this information were also being developed and implemented as she was I

74 O entering the data into the files. HERRING advised that no procedures for preserving and maintaining training information existed prior to this time, even though operator training was being conducted on a regular basis. She advised that she was the only records clerk in the department at the time and it was impossible for her to perform all of the administrative require-ments and to maintain operator training files and records. HERRING advised that when the first license examinations applications were submitted to the NRC, no QCs had been turned in to the training department to be recorded on the individual operator training history sheets. HERRING advised that, in her opinion, training records mismanagement and insufficient administrative staffing in the department has created the present chaotic records problems.

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Interview of Region II, NRC Staff The Region II, NRC staff members involved in MP&L/GG licensing activities, previous training assessments / inspections and current operator re-certifi-cation reviews were interviewed to obtain information pertinent to the investigation. The following individuals were interviewed:

Caudie A. JULIAN, Section Chief Charles William HEHL, Reactor Engineer John Francis MUNRO, Licensing Examiner JULIAN was contacted at various times throughout the course of the inves-tigation. He advised that he did not participate in the GG training assessment conducted by Region II, NRC staff members during February 1983 but said he has knowledge of this activity based upon subsequent discussions with the participants. He said that the February 1983 p) inspection was conducted to determine the adequacy of the GG training program with specific emphasis on their reactor operator training activity.

He said that during the inspection a staff member noted five PQDRs that addressed deficiencies relating to the training program. JULIAN advised that it was disclosed during the training assessment that some of the training courses / activity listed in the initial license examination appli-cations could not be verified from the applicants' training files. He said the significant discrepancy noted was the absence of documentation to substantiate that candidates had completed a QC which is a FSAR require-ment. JULIAN said that the licensee informed staff members that QCs had been completed by initial applicants but that they had either not been turned in for credit or they had been turned in but not recorded in the applicant's training files. JULIAN said that, based upon this explanation by the licensee, the matter was left open as an Unresolved Item in the inspection report. . JULIAN explained that an Unresolved Item is one that has the potential for a violation or a deviation but sufficient information is lacking to make a decision. He advised that upon completion of the Training Assessment exercise in February 1983 the NRC staff members did

" low key" the QC issue and they "did not give the licensee the flavor that U this could be a material false statement problem." He said that the NRC

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76 O did not react aggressively to this problem because the licensee presented it as missing documentation rather than the failure of applicants to complete the QCs. JULIAN advised that there was no followup action regarding the QC issue until August 1983 when Region II, NRC staff members conducted an Operational Readiness Inspection (ORI) at the facility. He explained that the purpose of the ORI was to determine whether MP&L/GG had corrected previously noted discrepancies in surveillance procedures before achieving reactor criticality. He said during the ORI, staff member HEHL inquired about the Unresolved Item regarding QC documentation. He said it was determined that the licensee had not closed the PQDR regarding QC documentation even though procedures require a 30 day corrective action statement. JULIAN stated that HEHL recognized the potentiality of material false statements by the licensee regarding the QC issue but said he (JULIAN) viewed it as a deviatico frc- the FSAR and so informed the licensee at the exit conference attended by GG plant management. He said he also told the licensee that the NRC could view the QC entry in appli-cations as material false statements since they were unable to document V completion of this requirement. JULIAN said he also instructed the licensee to notify the NRC in writing regarding any initial application errors and deficiencies which included the entry indicating QCs had been completed by the applicants. He stated that about late August 1983 he informed the Regional Administrator of the circumstances of the QC issue as he knew them. He said the possibility of material false statements was ,

discussed at the Regional Administrator briefing and some consideration was given to referring the matter to 01; however, no firm decision was made at that time. JULIAN said the next discussion of the QC issue with the licensee occurred about September 23, 1983 at the Region II, NRC office.

He said on this occasion MCGAUGHY was advised that the NRC now considered application discrepancies concerning QC completion to be more serious than a deviation from procedure and that this matter was being regarded as material false statements. He said MCGAUGHY had an unsigned letter from MP&L on this occasion which addressed training record discrepancies; however, he (MCGAUGHY) stated that since the NRC was considering material false statements he wanted to make sure all application discrepancies were

( covered before he presented the letter to the NRC. JULIAN advised that MCGAUGHY told him he felt he had been misled regarding the seriousness of

77 O

s the QC issue and that the licensee intended to conduct an investigation of the matter before responding to the NRC. JULIAN said that MP&L/GG officials acknowledged errors and discrepancies in the initial applica-tions, including the QC entries, in a September 30, 1983 letter and again during an October 12, 1983 meeting in the Region II, NRC office. JULIAN concluded that since this meeting he has been ir.volved with the operator re-certification program at the GG facility to ensure licensed personnel have been adequately trained to operate the reactor.

HEHL was contacted and interviewed at various times during the investi-gation. He advised he served as a member of the Region II, NRC Training Assessment group which reviewed the MP&L/GG training program in February 1983. He said the group was directed to determine that the overall training program was adequate. He said the thrust of this inspection effort was directed at the licensed and non-licensed operator training program. HEHL advised that after the entrance conference, the NRC grgup adjourned to the MP&L/GG Training Department where Training Superintendent N HUNT advised that there were some documentation problems associated with ir.dividual operator training files. He said HUNT informed the group that he was in the process of organizing files and fully identifying the discrepancies which had been documente'd by a PQOR. He said that NRC staff member MUNR0 learned simultaneously from licensee employee BYRD that it was possible some training listed on initial license examination applications had not been completed as stated. HEHL said that the purpose of the Training Assessment review was to determine the adequacy of operator training rather than to look at specific problems or deficiencies. He said for this reason the Training Assessment group did not look at specific deficiencies or inaccuracies in training files. He said that they did cite the QC issue as an Unresolved Item in the inspection report since HUNT explained that this requirement had been completed by all initial appli-cants but was not documented in training files. He said HUNT told the Training Assessment group that the license applicants were turning in completed QCs so that they could be credited with this activity in their individual training files. HEHL advised HUNT did not suggest at the time O, that the QC issue was more than the failure to document the completion of

~

this requirement by the applicants. HEHL said that it appeared the

78 licensee was actively identifying and resolving the problem and there was no reason to suspect that any MP&L/GG official had willfully provided false information to the NRC. HEHL advised that his next contact with the licensee regarding the QC issue was during the ORI activity at the GG facility in July and August 1983. He said during this occasion he reviewed an MP&L/GG memorandum (IPC-83-1548) from HUNT to the file. He said the memorandum addressed PQDR 7-83 and an unsuccessful effort by the licensee to locate QCs for some licensed operators. HEHL stated he questioned HUNT regarding the memorandum and the status of this PQDR. He said HUNT told him the reason the PQDR had not been closed was because the licensee had

! not completed the QC search effort. HEHL advised that members of the NRC l

l inspection group then began to suspect that the QC issue was more than just a failure to document the completion of this requirement by applicants. He advised that the Regional Administrator, Region II, NRC was apprised of the application discrepancies, including the QC issue, upon their return from the ORI activity at the GG facility. He said this matter and other train-O f' ing discrepancies were also the topic of several Region II, NRC enforcement h panels. HEHL advised that he is currently involved with the operator re-certification effort which is being conducted at the GG facility.

MUNR0 advised that he first administered R0/SR0 license examinations at the GG facility in about July 1982, while assigned to the Operator Licensing Branch, NRC, Washington, DC. He said he became acquainted with licensee employee BYRD on this occasion. MUNR0 advised that he has talked with BYRD telephonically and personally since July 1982 regarding licensing matters and applications for NRC license examination. MUNR0 advised that he has

( also spoken with MP&L/GG Training Superintendent HUNT regarding applica-tions. He said on one occasion in about late 1982 he and HUNT conversed telephonically regarding an inadvertent omission from the application of current operator BOTTEMILLER. He said HUNT told him that the particular training course completed by BOTTEMILLER was done so on a Credit By Examination (CBE) basis rather than by classroom participation. He said HUNT told him BOTTEMILLER's second application contained the CBE notation, whereas the first one did not contain this notation. MUNR0 stated that, based upon the explanation from HUNT, he did not consider this to be more than a typographical error, a common occurrence in applications from

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{G utilities throughout the country. MUNRO advised that he participated in the February 1983 training assessment activity at the GG facility. He stated that while involved in the training assessment, he reviewed PQDR 7-83 concerning QC documentation which had been prepared by BYRD on January 11, 1983. He advised he discussed this PQDR with BYRD who expressed the opinion that some license examination applicants identified in the PQDR may not have completed the QC requirement. MUNR0 advised that he reviewed several applications which were submitted to the NRC in l

September 1981 and noted that the entry Cold License Operator Qualification l Card was typically listed on each. MUNR0 advised that it became apparent j to him that th'e licensee had possibly submitted false statements to the NRC and said he discussed this with the group leader Donald R. QUICK. He said that following his discussion with QUICK (no longer employed by the NRC)

I and acting upon guidance he received the QC issue was to be appropriately regarded as an Unresolved Item since the licensee (HUNT) was already processing the PQDR in accordance with established procedure. MUNR0 advised that the exit briefing for the training assessment activity, attended by NRC staff members and MP&L/GG management, addressed the PQDR regarding QC documentation. MUNR0 said he advised Plant Manager MCC0Y that QCs may not have been completed by some of the September 1981 applicants even though applications reflected this requirement had been completed.

MUNR0 advised that upon their return to Region II, NRC, members of the training assessment group briefed Regional Administrator O'REILLY. He said HEHL presented the findings to the assembled staff and discussed the QC documentation issue as related by the licensee. MUNR0 said he commented at l the briefing that it was possible some of the September 1981 license l candidates may not have completed certain FSAR reouirements with regard to l training, including the Cold License Operator Qualification Card, even l though their applications reflected this activity was completed. MUNR0 said he again understood from the meeting comments that the QC documen-tation issue would be tracked as an Unresolved Item. He said he was not personally involved in this matter again until August 1983 when he visited the GG facility to conduct requalification examinations. He advised that a Region II, NRC training inspection team was also at the GG site. He said a

( ) member of this inspection team asked him about the QC documentation issue and the PQDR which addressed this deficiency. MUNR0 advised that, although

80 he was not involved in the August 1983 training inspection effort, he presumed that the reason for this inquiry regarding the PQDR was to dispose of the Unresolved Item from the February 1983 training assessment. MUNR0 concluded that, with the exception of the telephone conversation with HUNT regarding BOTTEMILLER's application, he received no notification from any MP&L/GG officials regarding incorrect application information.

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i 81 Review of RTS Contract Inasmuch as RTS Corporation provided training personnel to the MP&L/GG facility during 1981 and 1982, a copy of the contract with this contractor was obtained. The contract between RTS and Middle South Energy, Inc., in effect when the initial license examination applications were prepared and submitted is dated July 1, 1981. According to the contract, the services to be performed by RTS shall be described and set forth from time and time in separate work orders issued pursuant to the terms of the contract.

According to Work Order Number 1, dated July 1, 1981, RTS is directed to provide instructional personnel and specialists, including one Senior Training Specialist, to assist the GG training organization by providing classroom instruction or through course development. According to CUSTER and HUNT, RTS employee MOUNTAIN was employed at the MP&L/GG facility under this contract to develop the initial license examination application form and to compile applicant training data for inclusion on these applications.

A copy of the Agreement between RTS and Middle South Energy, Inc., with O pertinent work orders and MP&L/GG purchase orders attached, is EXHIBIT (31) to this report, s -.

82 V Explanation of Pertinent Licensee Documents During the investigation, numerous licensee documents from the training and operations departments and from the central file room were provided by MP&L/GG officials and vendor employees. These documents were reviewed and, if found relevant, retained for inclusion in the investigation report. An -

explanation and description of these relevant documents, along with any pertinent licensee comments which were made at the time they were presented, will be set forth in this section of the report.

EXHIBIT (32) is a copy of GG memorandum PMI-78/1298 dated December 6, 1978 regarding Operator Qualification Requirements through March 31, 1979. This memorandum states that personnel authorized to conduct plant operations in support of the Pre-operational and Acceptance Test Programs must complete the indicated sections of the GGNS Initial Operator Qualification Card.

I I EXHIBIT (33) is a copy of a March 30, 1979 GG memorandum regarding completion of qualifications in accordance with PMI-78/1298 and PMI-79/406, (which revised the initial memorandum). This document states that opera-tors JACOBSON, BENEFIELD, CADE, LEWIS and BYRD (all members of the initial license application group) and others had completed required sections of their QCs and are " qualified" to perform operational activities. This memorandum also identifies other operators who had not completed their QCs.

The QC reviews disclosed that only JACOBSON had completed the entire QC when initial applications were submitted on September 3, 1981.

EXHIBIT (34) is a copy of PQDR 15-80 dated March 21, 1980 which addresses a deficiency regarding the failure of operators, including shift supervisors, to complete a QC prior to performing or directing the performance of operations of permanent plant equipment. The " Corrective Action" statement reflects that QCs "have been or will be issued to Shift Supervisors. The

/^N t I procedure states that operations during pre-op and acceptance testing must

'V be done by operators signed off on the the system. No formal pre-op or

83 s

acceptance test (s) have been completed by operators who have not been l qualified on the system. We will continue this practice." This statement is signed by a former MP&L/GG operations superintendent and concurrence is indicated by the signature of Plant Manager MCC0Y on May 8, 1980.

According to current MP&L/GG managers HUNT and YELVERTON, this " Corrective

! Action" statement is a commitment by the licensee that all operators will complete the QC requirement and that no operator will be excused from this activity for any reason. YELVERTON advised that this document ruled out any legitimate exemption of operators from this commitment.

EXHIBIT (35) is a copy of a GG memorandum dated September 30, 1980 which states that the systems portion of the QCs for MILLER and HICXS (initial license candidates) have been completed. This document further states they are " qualified" to function as shift supervisors. Examination of QCs disclosed that only MILLER had completed a QC, less the Practical Factors

! section, when the initial applications were submitted on September 3,1981.

i A superceded version of a QC started by HICKS has not been completed.

> EXHIBIT (36) is a copy of a GG memorandum dated February 26, 1981 regarding the designation of operator RUSSELL to sign QCs. RUSSELL was one of twelve initial candidates in which no QC record was located.

EXHIBIT (37) is a GG Operations Department memorandum dated March 27, 1981 setting forth the minimum requirements for completing portions of the QC, The memorandum is addressed to " Operations Personnel" and contains no comments which exempt operators from completing the applicable sections of the QC, EXHIBIT (38) is GG Operations Department memorandum IPC-81/497 dated April 2,1981, which identifies eleven operator personnel authorized to sign off specified areas of the QC. Although this document authorizes personnel to sign QCs it contains no comment which exempt any operators I

from completing this requirement. All eleven operators authorized to sign

> QCs are members of the initial license examination group and seven of these

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are among those for which no QC could be located by the licensee. _,

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4 84 J

EXHIBIT (39) is GG memorandum IPC-81/618 dated May 27, 1981 regarding the designation of personnel to sign various sections of the QC for Control Room Operators and non-licensed operators. Most of the personnel authorized to sign QCs are members of the initial license examination group. Among the initial personnel identified and authorized to sign control room operator QCs, eight of these had no QC on record at MP&L/GG.

EXHIBIT (40) is a copy of GG memorandum IPC-82/2011 dated February 19, 1982 addressed to operations personnel. This document addresses the completion of applicable portions of the operator QCs consistent with plant systems that have been completed. The memorandum contains no comments which exempt any operator from this requirement.

EXHIBIT (41) is a copy of a GG file memorandum dated October 13, 1982.

This memorandum was prepared and signed by BYRD and initialed by Training Superintendent HUNT. The contents of this document reflect that a Control Room Shift Supervisor is not requiring students to complete their QCs.

O According to the memorandum, the failure to complete QCs is one reason operators are deficient in knowledge of control room operations.

EXHIBIT (42) is a copy of PQDR Number 7-83, with related documents, dated January 11, 1983. This document states the FSAR and a GG Plant Administra-tive Procedure both require that a QC be completed during the on-shift training period for each license candidate and that there is no documen-tation in training records that operator QCs have been completed for some applicants. A copy of an April 13, 1983 GG file memorandum, IPC-83/1548, in response to PQDR 7-83 is attached. This memorandum states that a review of training files for 28 currently licensed operators disclosed only 10 QCs were documented in individual files. It is further stated that QC completion was inadvertently omitted from the check list used by training to certify that license candidates have completed this requirement prior to submission of applications to the NRC. This memorandum states that members of- the first and second license class who did not work on or complete QCs will not be required to do so since "no one was licensed and thus qualified to sign off the cards." The operations personnel who are exempt from (f _

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retroactive completion of the QC requirement are listed in an attachment to PQDR 7-83.

INVESTIGATOR'S NOTE: It appears that the statement in IPC 83/1548 regarding no operators being " qualified" to sign QCs is contradictory of earlier memoranda statements which designate and authorize operator personnel to sign these documents. For example, EXHIBITS (33), (35),

(36), (38) and (39) address the qualifications of certain operators and authorize them to sign QCs based upon their training and partici-pation in plant operations. Eight of the 18 personnel retroactively exempted from the QC requirement are members of the initial license group who had no record of QC participation.

EXHIBIT (43) is a copy of a GG memorandum dated January 31, 1983. This memorandum, originated by HUNT and addressed to license holders solicits the help of these individuals to account for and turn in OCs to the train-ing department. A handwritten note by BEARDEN on a copy of this memorandum (j indicates he was never issued a QC and that "a memo existed at one time" which exempted ROBERTSON, MOULDER and RUSSELL from this requirement. This note further reads that "all other supervisors were issued qual cards and worked on them."

INVESTIGATOR'S NOTE: Based upon the review of QC documents provided by HUNT, there was no evidence in MP&L/GG files that 12 initial candidates had worked on QCs. It was further revealed during inter-views of MCC0Y, HUNT, YELVERTON and KOKAJK0 that no official memorandum exists in licensee files which exempted any candidate from the QC requirement.

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 R0/SRO personnel and that defi-O, ciencies and discrepancies noted between applications and training files

\M relate to incorrect duration of some courses listed on applications,

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missing documentation to verify courses listed on applications and incomplete or missing QCs for "the majority of licensed personnel." This letter further states that the QC in effect at the time initial applica-tions were submitted "did not include a Practical Factors Section as required by the FSAR." Attached to this letter are pages containing duplicate " Formal Training" entries from individual applications of currently licensed operators with a corresponding sheet which reflects the discrepancies noted between the applications and training files.

INVESTIGATOR'S NOTE: According to JULIAN, this letter was personally shown to him by MCGAUGHY in September 1983 and immediately withdrawn when he (MCGAUGHY) was informed that the NRC was considering applica-tion discrepancies regarding QCs as material false statements. The information displayed in the attachment to the letter regarding application and training file discrepancies appears to be the result of K0KAJK0's audit of this documentation.

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\,_ / EXHIBIT (45) is 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 discrepancies identified in the unissued October 1983 letter. According to this letter the three categories of discrepancies are; incorrect course durations listed in applications, missing documenta-tion to verify training listed in applications and incomplete or missing QCs for some license applicants.

EXHIBIT (46) is a copy of MP&L/GG " Summary Report" of License Application

, Discrepancies, PMI-83/13776 dated February 10, 1984. Attachments to the report are licensee generated memoranda, MP&L/GG Quality Assurance docu-ments and plant correspondence relative to the investigation of the license applications errors and discrepancies by the MP&L Quality Assurance Manager. The report summarizes these activities and identifies license application and training issues discussed with current licensed operators at the GG facility. According to the report, errors and discrepancies in applications resulted from inadequate staffing levels, failure to maintain O adequate training records and frequent personnel changes in the Training g'j and Operations Departments. The report failed to identify culpability

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\9 regarding false entries in the initial license applications. It addresses -

i- possible rationale for the failure of some currently licensed shift  ;

4 l supervisors to complete QCs and cites reasoning to support the licensee's  !

} i i position that all currently licensed personnel are qualified to operate the l 2

reactor.

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88 Liaison With The Reauestor Throughout the course of the investigation, the Regional Administrator, Region II, NRC and/or members of his staff were briefed regarding the progress of the investigation.

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Status of Investigation Inasmuch as all significant investigative activities have been completed, the status of this investigation is CLOSED.

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('Dl Exhibits (1). Inspection Report Number 50-416/83-06, dated 3/10/83 (2). Inspection Report Number 50-416/83-38, dated 9/26/83 (3). MP&L/GG letter to NRC, AECM-83/0629, dated 9/30/83 (4). Meeting Sunnary of 10/12/83 meeting with MP&L/GG officials (5). Region II, NRC Investigation request memorandum, dated 10/18/83 (6). Region II, NRC Supplemental Information memorandum, dated 12/5/83 (7). MP&L/GG License Examination Application Form (8). NRC Form 398, Personal Qualification Statement-Licensee (9). MP&L/GG letter to NRC, AECM-81/002, dated 9/3/81, with 34 license examination applications attached (10). MP&L/GG letter to NRC, AECM-82/120, dated 3/30/82, with 9 license examination applications attached (11). MP&L/GG letter to NRC, AECM-82/215, dated 5/14/82, with 6 license examination applications attached A (12). Analysis Chart, dated 12/14/83 h (13).

(14).

(15). -

(16). ,

(17).

5 (18).

.(19). j (20).

(21).

(22). Sworn Statement of John E. CUSTER, dated 11/15/83 (23). Results of Interview of Douglas L. HUNT, 12/15/83 (24). Sworn Statement of Charles K. MCC0Y, dated 11/30/83 (25). Results of Interview of Charles K. MCC0Y, dated 11/21/83 (26). Results of Interview of James P. MCGAUGHY, dated 11/22/83 (27). Results of Interview of Thomas E. REAVES, dated 2/10/84 (28).

(29).

2 O (30). Results of Interview of Gerald R. MOUNTAIN, dated 11/14/83 (31). Copy of RTS and Middle South Energy, Inc. service contract, dated 7/1/81 (32). MP&L/GG memorandum PMI-78/1298, dated 12/6/78 (33). MP&L/GG memorandum dated 3/30/79 (34). MP&L/GG PQDR 15-80, dated 3/21/80 i

(35). MP&L/GG memorandum dated 9/30/80 (36). MP&L/GG memorandum dated 2/26/81 (37). MP&L/GG memorandum dated 3/27/81 (38). MP&L/GG memorandum IPC-81/497, dated 4/2/81 (39). MP&L/GG memorandum IPC-81/618, dated 5/27/81 (40). MP&L/GG memorandum IPC-82/204, dated 2/19/82 (41). MP&L/GG memorandum dated 10/13/82 (42). MP&L/GG PQDR 7-83, with attachment, dated 1/11/83 (43). MP&L/GG memorandum dated 1/31/83 (44). MP&L/GG unissued letter to NRC, dated 10/83

.m (45). MP&L/GG letter to NRC, AECM-83/0681, dated 11/1/83 (46). MP&L/GG " Summary Report" of License Application Discrepancies, PMI-83/13776, dated 2/10/84, with attachments

UNITED STATES .

- [p aseg3o, NUCLEAR REGULATCRY CCMMISSICN

! , j AEG3CN 11 3 e tot hW4eTTA 37. M.W. SUITE 3100

,  ! ATLANTA. GEORGIA 30305

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3 Recor: Nos. : 50-415/83-06 and 50-417/83-03 Licensee: Mississicci Power and Lignt Comaany i Jackson, MS 39205 Occket Nos. : 50-416 and 50-417 License Nos.: NPF-13 and CPPR-119 Facility Name: Grand Gulf 1 and 2 l

Training Assessment at Grand Gulf site near Por Gibson, Mississicci l Inscectors: 06J 3/7/dU

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Cate 51gnec 6uW $ J/7AJ Date Signec M. E. Casnatt b S .V7NJ R. L. Ancerson Catt Signec Accreved cy: d /. #

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0. T. Quicx, Section Chif9,' P[fea' iici aranen Ofte signec No. lA, Division of Pdoject anc Resident Programs sky 53 F. 5. Cantre1i , Secti5n Kalif 7 ate 51gnec Project Branen No.18 Division of Project and Resicent Programs SUWARY Training assessment concucted on Fecruary '5-17,1983 .

Areas Reviewed This scocial training assessment involved 104 inscector-neurs on site in ne areas of licensec and non-licensed operator training anc recualification crograms, on-snift/real-time training, . raining on moci fication s anc cesign enanges, shift tecnnical acvisor and simulator training programs. Accitionally, One progress of the system description and lesson clan rewrite crograms were reviewec. ._

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\ ' Results Curing the course of :nis training assessment, one violation was icentiffec in one of the areas evaluated (f ailure to concuct training of facility cesign changes, paragraon 5).

An apparent deviation was found in one area and several areas not soecifi-cally acdressed by regulatory requirements generated concerns. These items are discussed in :ne report details.

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RE:CRT OETAILS

1. Persons Contacted Licensee E.mployees

'A. O. Hotham, Simulator Supervi sor

  • 0. L. Hunt, Nuclear Training Superintendent

'C. R. Huteninson, Nuclear Succor Manager

'S. G. Jones, Cuacrex Training Uni: Manager (Consultant) l

'G. H. Lee, Training Sucervisor

'C. K. McCoy, Plant Manager

'J. W. Yelverton, Site Quality Assurance Manager R. G. <eeton, Coerations Superintendent Other licensee employees contacted incluced licensed and non-licensed ocerators, operator candidates in training and training staff personnel .

" Attended exit interview

2. Exit Interview The scope and findings of this training assessment were summari:ec on Fecruary 17, 1983, with those persons indicated in Paragracn 1 acove. The licensee acknowledged the assessment findings.
3. Licensed and Non-Licensed Operator Training
a. C1.ssroom Training In recent months, the operator training crograms nave uncergone sucstantial changes. Some of these enanges resultec frem an immediate .

nee: for training increased numoers of operations corsonnel to meet projected licensed operator neecs. In an effort to colster its training staff to meet these training neecs, MP&L nas recently contracted wtth a consultant to conduct licensec coerator training at Grand Gulf. The contract provices for classroom instruction anc lesson clan develocment work during the next three years.

Utili:ation of' contract instructors nas begun anc one hour of a twelve nour presentation on Tecnnical Scecifications was coservec by a memcer of the assesscent team. The class was comoosed of five reac:ce coerator candidates and one shift tecnnical acvi sor cancicate. The following coservations are those of tne assessment team ou :ney mirror comments sucm1 ted by tne students on :neir cost-training evaluation forms.

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The instructor was unsure of the level of Tecnnical Scecifica:icn knowledge required of a reactor ocerator.

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- The instructor was unf amiliar witn Grand Gulf systems, anc :nere-fore could not relate specific examoles to aic :ne stucents' uncerstanding.

- No formal lesson plan was utili:ed. The material was resented by the instructor reading tne Tecnnical Specifications.

A review of evaluation forms from other contracted training sessions were markedly different from the aoove. But, as evicenced by.:ne acove comments, close supervision / auditing of contracted training will be necessary to ensure a consi-stant high level of training is acnievec.

The licensee has assigned a memcer of the plant staff to monitor training presented by contract instructors, but he is acditionally responsible for imolementing a sucstantial numoer of c ner programs.

This licensee representative was not present curing ne instruction attended by the assessment team.

b. Simulator Training The Grand Gulf site-specific simulator, wnich has just recently become operational, appears to be providing useful operator training. The simulator is currently being utili:ed for training the operators on startuo test procedures. A very positive program practice of allowing auxiliary operators (A0s) and nuclear coerators Level B (NCBs) to participate along with the licensed coerators was noted. The only problem area identified during the asses'sment of simulator training was the scheduling of people to the simulator. The numoer of licensed coerators fluctuates to the extent :nat, at times, :ne simulator instructor is overloaded (nine stucents).

l c. Training Materials The licensed operator training crogram lesson plans reviewec during nis assessment were in need of revision anc ungrading. he licensee l

indicated that they are aware of ne neec for improvement in :ni s area, l

and that lesson plan development work is part of :ne ::ntract services

! to be proviced. No lesson plan revisions were avaiiacie 'or eview by l

the assessment team.

System cascriptions are curren .ly :eing revisec ancer ::n:ract with General ' Electric ~ Company. Cf :ne a::coxima ely- seventy system cascriptions identified for revi sion, twelve nac been evised. reviewed and approved at the time of this assessment. An assessment team review of the twelve approved system cascri tions icentif'ec errors *nicn indicated lack of adecuate tecnnical eview. Intervd ews witn :ne l O training staff determined that :ne licensee is es:cnsi:le 'or :ne

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technical review anc that these system cescrictions aticeivec :neir N technical review by non-licensed memoers of ne training staff. At 1 present, there are no plans for licensec :ersonne1 to :artici ate in )

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this review process. This apoarent program ceficiency .vas ciscussed witn licensee management at :ne exit interview.

d. Cualification Card Program On- ne-joo training of licensed and non-licensed ocerator candidates is accomolished by a qualification card program. The qualification carcs incorocrate a listing of knowledge factors and practical factors, tne

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accomolishment of wnich is to demonstrate that an individual can perform required functions. Completion of the cualification card is a pre-NRC . licensing exam commitment (F5AR) for licensed coerators and senior operators, and a licensee imposed pre-certification reautrement for non-licensed operators. The cualification program establisned at Grand Gulf appears capable of performing its intended function, but preolems in the program implementation exist.

(1) In the past, the qualification card crogram has not been structured. Trainees have been basically handed the carcs and told to find a cualified coerator and learn wnat he does. The lack of structured isolementation is furtner comocunded by the availability of qualified personnel to concuct system eneckouts and walkdowns. Interviews with candidates, presently qualified operators and personnel designated to conduct the system eneckouts

\ indicate that time is just not availaale to parform these-checkouts, especially on dayshift.

Discussions with the training department concerning these program deficiencies revealed that recently, for the A0 class, the assigned classroom instructor has been scending time in the plant with his students conducting system walkcowns; and occasionally, an instructor has been orovided to concuct enecxouts for licensec and non-licensed coerator trainees on snift. The licensee indicated an awareness that additional resources need to be committed to this area.

(2) Another deficient area of the qualification card program is I documentation. As noted above, completion of the cualification card is a NRC pre-license exam commitment (FSAR, Chacter 13.2) for both reactor operator anc senior reactor coerator candicates. A review of licensed ocerator training recorcs determinec :nat :nis documentation is incomplete for some coerators. This documenta-

tion deficiency has been icentified by the licensee anc a Plant l Quality Deficiency Report (PCOR) was written on January 11, 1983.

The PCOR requires resolution of this issue by Feoruary 23, 1983.

The training department is currently working to resolve this

, matter. This documentation issue will be carried as an unresolved item pending completion of :ne licensee's cocumentation seartn l

(416/83-06-01).

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e. Fifth Week Training Coerating decartment snift senecules are arranged suen :na: every fif tn week is a week cesignated for training. Until :ne recent availability of ne Grand Gulf simulator, very little training had :een concuctec during nis week. Currently, this week is utilized for ne simulator training as discussed in paragraph b. Starting in April, licensed coerator recualification training will be incorporated into this training week.
f. Requalification Training The status of the licensed opera:ce recualification training program is tenuous at best, in nat, the program has not been implemented. Two

. program imolementation outlines have been prepared, but neither one has oeen approved by plant management. A program was begun in Septemcer 1982, ut only a minimal persion (General Emoleyee Training, Fire Brigade Training and Radiation Protection Training) was accomolf sned.

A second program, which is scheceled to begin in April 1983, is still in an early developmental stage, i .e. , specific lecture topics and instructor assignments. Requalification lesson plans were not yet available for review. This lack of p ogram detail may have been a contributing factor to the marginal success of the first crogram attempt. The present lack of any requali fication training is particularly acute in light of the sucstantial numcer of design enanges and modifications that have occurred since the initiation of the current plant outage, and that there has been virtually no plant systems or procedure training conducted during tne past year.

4 Review of Training Audits The training cepartment presently has five outstanding PCORs witn recuirec response cases of eoruary 23, 1983. These recorts were written :y :ne training caparuent and are being tracked by the site cuality assurance organi:ati on. The generic proolem area identified by :nese recorts is a lack of cocumentation to support acc:mpiisnment of all the requirements of FSAR, Chapter 13.2 (Training), and the licensee's crocacures for licensed ocerator training. In some instances certain recuirements of FSAR 13.2 listec as accomolishec on incivicual ocerator license acclications, lack succor.ive cocumentation. At :ne time of this assessment, resolution of nese cocumentation proclems had not yet occurrec. As notec in caragracn 3.d acove, this cocumentation issue is being carriec as an unresolved item.

In Septemcer of 1981, CE3 Corocration acministered NRC style comorenensive written and oral examinations to all licansed operator cancicates as committec to in the FSAR, Section 13.2.1.1.6. Based on :ne examination results, :Me :3AR recuires nat an evaluation be mace of :ne cancicate's  ;

weaknesses and a training program be ceveloced to correct : nose weaknesses. 1 l Otner than the evaluations anc recommendations mace ey CES regarcing :ne examination results, no dedumentec individual evaluations of eacn

\ candidate's weaknesses was accomplisned. A generic retraining outline was ,

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\ deveicoed for the candicates to ac:cmolish on snift as .ime oermittee, but no documentation exists to incicate that this generic e: raining was ac:cmolisnec. The licensee indicatec :nat ne CES exam acministerec in Sectemoer 1981 was cetermined no: to se an effective tool for evaluating a candicate's weaknesses; nence, ne cevelopment of :ne generic retraining outline. The inscector notes :nat no attemot to acminister a meaningful second exam Was made.

5. Training on Procedural Changes, Design Changes and Significan: Events A required reacing crogram is the method utili:ed to orovice training on procecural enanges and significant incustry and Gra.1d Gulf events. The estaciished crogram is administared by the training caparuent and takes :ne form of weekly seminars. The seminar sackages are preparec :y the training deparuent and forwarced to the acclicable work groua sucervisor wne is resconsible for conducting the seminar and returning :ne recuirec documenta-tion. Interviews with the coerating decarment personnel determinec that the program is not effective for :ne following reasons.

- Generally, except on the tack snifts, time is not availaole for conducting seminar type training. Instead, the pacXages are circulated to be read by the indivicual .

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Material' incorporated into the recuirec reacing cackages needs to be

( screened to eliminate all except essential information. Briefing or sununary sheets are needed to reduce one volume of material cresented in the packages.

- Dissemination of pertinent information is not occuring in a timely l manner. The information is montns cic :y :ne time it is circulatec.

l No tracking system nas been establisned to ensure that all cersonnel wno neec :ne information get it.

Facility modification and design enange training is an FSAR =cmmitment and required by Grand Gulf procedures. For cesign enanges affecting ocerations, the Operations sucerintendent is resconsible for :ne initial training of his corsonnel. The Training Superintancent is resconsible for reviewing :esign enanges for i ncorocrati ert of acerceriate enanges into :ne training materi al s. Assessment team interviews witn coera:ces anc clan: f aff corsonnel determinec :na a suestantial numoer of cian: mocifications nave caen comcleted witnout the required training. In some instances, 'frs

knowledge of system cnanges oc
urred wnen :ne coera:ces tried to ocerate :ne I systems and di scovered the enanges.

At oresent, :nere exists in excess of 700 outstancing mocification anc cesign O :nange sacxages on wnich training nas not :een :encucted. Of : curse, no:

nese enanges will require formal training, out even a review of :nese I (*/s all cackages Oy the affected clant section and the training deoarment to estaclish training requirements has yet to Oe done. This item was =rougnt i

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( :o the attention of ne licensee at the exit interview and ne licensee l

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6 c:mmitted to conducting the necessary training orier to restart of :ne 1 facility. This failure to concuct training on enanges to :ne facilt:y design for licensec coerators and senior acerators is a violatier of Tecnnical Scecification 6.4.1 (416/83-06-02).

6. Shift Technical Advisor Training The shift technical adviser (STA) training program is established by Administrative Procedure 01-5-04-7. The program concucted coes not accurately reflect the STA program c:mmitted to in the FSAR. An examole is the instruction in Administrative Controls: the FSAR indicates four weeks of instruction; Procedure 01-5-04-7 says it will be 1-4 weeks; in actuality, five days were given. This is a deviat.icn from commitments contained in the FSAR, Sec-ion 13.2.1.2.10 (416/83-06-03). All the cresently certified STAS at Grand Gulf are affected my this apparent deviation.

The shift technical advisor cetraining program is also an FSAR c:mmitment and a reouirement of procedure 01-5-04-07. The retraining crogram wnich is to commence within 90 days of issuance of the plant coerating license has not yet caen developed. As required by 3*ccecure 01-5-04-7, retraining is required annually and prior to resuming resocnsibilities of the position following an extenced period (4 months or more) of not actively performing the functions of an STA. An interview with : certified STA has determined that none of the STAS have functioned in that capacity in the last six months. Therefore, all the STAS will require retraining prior to assuming those duties. This retraining requirement was discussed with the licensee at one exit interview.

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asen . uMITeD STAT 1s

F *o NUCLEAR REGULATORY COMMIS$1CN

, n ReQloN il

  • g 101 AAAAleTTA STMeeT,N.W.

. I ATLANTA. GEORGIA 30303

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Recor: No.: 50-416/83-38 Licensee: Mi ssi ssippi Power and Light Comoany Jacksort, MS 39205 Docket No.: 50-416 License No.: NPG-13

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acility Name: Grand Gulf 1 Inspection at Grand Gulf site near Port Gibson, Mississicci Inspeczors: $ *k' Y s Y !-

C. A. Juliarf/ Date Signec

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G. A. Seltsfu I Date Signec Xa UL +124 /1s g W. J. Orcers Cata S(gnec 2O vak- e/zdss L. g. Garner Cats Sitnea C A - %2- . Ac:- /2.!/5:

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  • t/ Cate Signec X a adt.-- rksh2 L. J. atson Cate 5fgnea Aoprovec by: N/ d A i 4/.Il O. A. Jerrelli, Branen Chief Oate Signec Division of Project and Resident Programs

SUMMARY

Insoection on August 15 - A.ugust 19, 1983 anc Augus: 30 - Sectemoer 1, 1983 I Areas Insoected This soecial, announced inscection involved 308 insoector-cours on site in :ne areas of operational reaciness including licensee action on crevious enforcement q j matters, surveillance procacure review, moce recuirec surveillances, enange o-

'd moce procecures, fire protection, training, One Quality Assurance Auci Program, licensee action on oreviously icenti fiec inspection fincings, c::mmi t.ments

\ inclucec in Operations Ennancement Program, security , Tecnnical Soeci fication review and staffing level review.

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Results Of ne twelve areas inspected, no violations or ceviations were icentified in ten areas; four violations were found in two areas, (paragraon 10, failure to crecare incicent recort and report missed surveillance, failure to correct conditions adverse to cuality icentified in P00Rs, and failure to issue audit report witnin required time frame; and paragrach 3, failure to post fire waren).

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REPORT DETAILS

1. Persons Contacted Licensee Employees at Grand Gulf Site "J. 3. Ricnard, Senior Vice President, Nuclear

'J. P. McGaugny, Vice President, Nuclear

'C. K. McCoy, Plant Manager

'J. E. Cross, Assistant Plant Manager

'T. E. Reaves, Manager, Quality Assurance

'P. R. Hughes, Regulatory Comoliance Supervisor "L. .:. Daugntery, Plant Comoliance

'R. G. Keeton, Ocerations Superintancent

'C. R. Huteninson, Nuclear Support Manager

'J. D. Sailey, Plant Quality

  • 0. C. Hunt, Manager, Training Decartman:

SJ. F. Pinto, Manager, Nuclear Plant Engineering "J. C. Racerts, Startuo Suoervisor "S. M. Feith, Coerations CA Manager

'G. A. Zinke, Technical Engineering Supervisor

'A. S. McCurcy, Technical Superintendent Licensee Emulayees at Jackson, Mississipoi J. Fowler, Engineering Assistant, Nuclear Safety and Licensing G. Cesare, Manager, Nuclear Licensing Otner licensee emolayees contacted inclucec engineers, tecnnicians, coera:ces, mecnanics, security force memoers, anc office oersonnel .

NRC Personnel "R. C. Lewis, Director, Division of Project anc Resicen Pr grams (OPRP), RII "T. H. Novak, Assistant Director for Licensing, Division of Licensing, NRR

'O. S. Brinkman, Section Leader, STS Section, SSPB, Division of Licensing, NRR

'A. Wagner, Senior Resicen: Insoec:ce "Attenced exit interview

2. ExidInterview The insoection scoce and findings were summari:ec on August 15, Augus: 19,

~s anc Sectemoer 1. 1983, witn : nose eersons incicatec in caragraan i acove.

t ) The licensee acknowlecgec :ne insoection fincings. :incings icentifiec in s *~

nis recort incluce:

l IFI 116/83-38-01, Philoscony Occument on Logic Train Testing.

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IFI 416/83-38-02, Quality of Reference Drawings.

IFI 416/83-38-03, Inclusion of See:1on XI into Surveillance Program.

Unresolved Item 416/83-38-04, Valve Lineups for Local Leak Rate Testing IFI 416/83-38-05, Veri fication of Identification of Active Tecnnical Specification Surveillances in Each Mode.

IFI 416/83-38-06, update Cornuter Data Base for New and Deletsc Surveillance Procedures IFI 416/83-38-07, Selection of Surveillance Procecures to be Performec Prior to Heatuo.

IFI 416/83-38-08, Logging System for Annunciators IFI 416/83-38-09, Incormoration of Tecnnical Soecification Surveillances in Coerating Procedures Violation 416/83-38-10, Breach of Fire Rated Assemelies.

Unresolved 416/83-38-11, Incorrect Information Included in Application for Coerator License Examinations.

Violation 416/83-38-12, Failure to Precare IR and Recor: Missed Surveillance Violation 416/83-38-13, Inadeouate Corrective Action for PCORs Violation 416/83-38-14, Failure to Issue Auci: wi:nin TS Recuirec Time Frames.

IFI 416/83-38-15, Clarify Responsibilities for Ini:1ation of IR.

IFI 416/83-38-16, Erroneous Reference in Corrective Action Procecure.

IFI 416/83-38-17, Procedure Imolementation Wording.

IFI 416/83-38-18, Setcoint Verification Curing unctional Tests.

3. Licensee Action on Previous Enforcement Matters (Closec) Violation (416/83-22-01) Failure to Provice Bases for Cetermination
nat DCPs Did Not Involve An Unreviewec Safety question. MP&L's -escanse cated Augus 8, 1983, is consicerec accectacle my Region II. The insoector x reviewed Procacure 01-304, "Cerformance and 3-ecaration of Cesign Change s

) ?ackages", Revision 6, catec August 15, 1983. Accisional clard fication nas A- / ~ been crevided for comaletion of 10 CFR 50.59 reviews. The insoector'aiso reviewec recorcs of class attencance for 55 NPE cersonnel . This training x was concuctec to assure personnel familiarity witn Procecure 01-304

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(Closed) Deviation (416/82-78-02) Reference licensee's letter AECM-33/0165 of Maren 11, 1983. The inspector verified that training on :ne crocacure for " Conduct of Maintenance Activities" was c:moleted for maintenance section personnel on March 8,1983. The deviation is closec.

(Closed) Violation (416/83-06-02) Training of Operators on Design Changes.

The inspector reviewed training for licensed operators on cesign enange packages as discussed in paragraph 9.b. This item is closed.

(Closed) Unresolved Item (416/83-06-01) This item was sucerceced as discussed in paragraph 9.c. The item is therefore closed.

4. Unresolved Items Unresolved items are matters about wnich more information is recuirec :o cetermine wnether they are acceptable or may involve violations or caviations. Two new unresolved items identified during :nis inspection are discussed in paragraphs 5 and 9.c.
5. Surveillance Procedure Review

</^ The Confirmation of Action (CCA) letter dated Octocer 20, 1982, reouf res

( * . :nat actions be taken to ensure all surveillance procacures are tecnnically adecuate and establish an effective program c incorcorate, c:ntrol anc implement regulatory requirements. . These actions are to include tecnnical specification surveillance, ASME See:1on XI Code anc 10 CFR 50 Accencix J requirements.

Basically, the. licensee divided the facility's surveillance procacures into two groups:

1)  : nose procecures whien, upon tecnnical review, cic not warrant rewrite prior to power ascension; and
2) those procedures wnich, upon technical review, cic recuire rewrite prior oc power ascension.

The procedures in both grouos were to be reissuec with a Revision 20 identification, to icentify this new generation of procacures.

l A review of :ne technical adequacy of surveillance crocacures, wnien implement technical specifications, was performed by examining :rocacures:

1) wnich had been reviewed and issuee but not yet cerformec; 2) wnica nac caen issued and successfully performed; and 3) wnicn nac :een issued anc l

were observec while being cerformed. Of the samole insmectac, no tecnnical l ceficiency was founc in those procacures wnien hac teen successfully lf l

completec in :ne field.

whicn were deemed as requiring accitional review However, potential proolem areas anc coservattens y :ne NRC are casignatec

  • as inspector followup items (IFI) in the inspection catails provicec :elow.

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a. Testing of Actuation Logic Selected portions of the reactor protection system (RPS), ne nign pressure core spray (HPCS) system, the nuclear steam sucoly snutoff l system and the low pressure core spray ( LPCS) system logics were discussed with the procedure writers to ensure that a method nad been established to: 1) identify components which require actuation;
2) complete the logic testing from sensor to actuation devices; and
3) incorporate this information in surveillanca procacures. The method in use appears workable. To completely test the legic recuires performance of instrument and control (I&C) procecures from the sensor to some point in the circuit and then tasting of actuation devices by operation procacures in such a manner that the same point (cenoted as an interface coint) is tasted again. The procacure group is currently preparing a philosophy document, which is to incluce these interface points and a cross reference between procacures for each logic train.

Comolation of tne philosophy document will be tracked as IFI 416/83-38-01.

In addition to the above, portions of the following procedures were reviewed against crawings for proper logic testing as well as adequate acceptance critaria:

Procedure No. Revision No.

06-IC-1821-R-0005 20 06-OP-1C71-M-0001 20 06-IC-1017-R-1002 4 06-IU1821-R-0022 2 06-0P-1C11-R-0011 20 06-0P-1C41-M-0001 13 06-IC-1821-R-0008 20 06-IC-1821-R-0004 13 06-0P-1017-M-0015 11 06-IC-1821-R-0009 20 06-IC-1821-R-0008 20 06-OP-1975-R-0003 20

b. Quality of Referenca Orawings .

Revision 20 is :ne cesignation for procecures wnich nave teen otally revised and reissuec as a result of tne COA effort. Crawings were examined in the control roc;n, the tecnnical succort grouc office and One maintenance snoo. In trach area, recucec si:e crints were avail-able. The recrocuction cuality of these were suen :nat several logic f- s prints were illegible. This nad accarently seen icentifiec cy CA seve.al montns earlier anc steos are in orogress to provice reacaole

('s-;). prints in tne control room. The cuality of :ne crints in :ne c ner areas need to be evaluatec and aporopriate action taKen. This is !~I x 416/83-38-02.

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l c. Review of Technical Specification Recuirements The following procedures whien had been satisfactorily performec were revi ewed for conformance between acceptance criteria anc tecnnical specification requi rements, for overall technical acequacy and verification that the technical specification requirement was met:

Procedure No. Revision No. Date Comoleted 06-IC-1E31-M-0028 2 07/12/83 06-CP-1C11-M-0008 20 06/25/83 06-IC-1E30-R-0001 20 07/30/83 06-IC-SC8E-0-1004 20 06/26/83 06-IC-1E31-M-0013 3 07/06/83 06-IC-1E30-M-0001 20 08/04/83 06-IC-1821-M-1001 5 06/29/83 06-IC-1E12-R-0002 20 07/12/83 06-IC-1530-M-0002 20 08/09/83 l 06-IC-1E33-R-1002 20 08/16/83 l No preolems were identified.

d. Review of Temporary Change Notice (TCN) l Of the six surveillances the inscec ces were able to witness, three l were Revision 20 procacures and tnree were not. Of the six survei l-l lances, five either failec or required a change to tne procacure. The surveillances were:

p-ocacure No. Ti tl e 06-0P-1E61-5-0002 Rev. 10 Primary Containment Hydrogen Recemoiner Operacility 06-CP-1017-M-0015 Rev. 11 Main Steam Line Rac Monitor .:/T 06-CP-1017-M-0003 Rev. 20 SSW System Raciation Monitor /T 06-OP-1G33-0-0001 Rev. 11 RWCU Valve Ocerability 06-IC-1521-R-0008 Rev. 20 Reactor Vessel Level Calibration 06-IC-1E51-R-1002 Rev. 20 Containment /Orywell Di f ferential Pressure The latter two required TCNs to be issuec to cor ect :rocecure deficiencies. As a result of this c7sertation anc conversations wi:n tecnnician's cerforming the newly issu.a Revision 20 crocecures, 1:

Secame apparent that many Revision 20 pr.:ecures requirec TCNs.

s Thus, an aucit was conducted of c:ccleted procecures to determine na tyoe of TCNs were necessary to allow the recently rewri tten , reviewee l 'v)' anc acoroved Revi sion 20 procacures to be successfully =erformec.

Fourteen TCNs issuec on :ne following eign: procecures were reviewec:

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'Ig-Procedure No. TCN No. TCN Dates 06-OP-1P75-M-0002 3 07/27/83 06-OP-1P75-M-0001 2 07/27/83 i 06-IC-lM71-R-0001 5, 6 08/03/83, 08/04/83 I 06-IC-1E21-R-0004 4 06/30/83 06-IC-1E21-R-0001 9 07/14/83 06-IC-1C61-R-1002 3 08/08/83 06-IC-1C71-R-0001 6, 7 08/11/83, 08/16/83 06-IC-1321-R-0008 5,6,7,8,9 08/08/83, 08/09/83, 08/10/83, 08/13/83, 08/16/83 The insoectors also reviewed in detail eighteen comoleted Revision 20

'~ ecures wnich hac received procedure changes in the fielc, in arcer to catermine if the changes were tecnnical or non-technical in nature Jus deriving another measureinent of the technical adequacy of the procedures. The numcer of procacure changes ranged from one to twenty-one. Of the eighteen procacures reviewed, ten acceared to have received technical revi sions; i.e., tecnnical revi sions other than typograchical corrections or acministrative changes. The procedures reviewed were:

06-EL-1981-R-0001 06-OP-1P75-R-0004 06-0P-1P75-M-0002 06-CP-1921-M-1004 06-OP-1775-M-0001 06-IC-1921-M-1007 06-IC-1M71-R-0001 06-IC-1821-R-0001 06-IC-1E21-R-0004 06-IC-1E30-M-0002 06-IC-1C61-R-1002 06-IC-1530-R-0001 06-IC-1C71-R-0001 06-IC-1M23-M-1001 06-IC-1821-R-0008- 06-IC-1M23-M-1002 06-CP-1975-R-0003 06-IC-1M71-R-0002 Seven Revision 20 procedures were audited in detail to verify that all technical specification requirements were incargoratec/:erformec after field revisions (TCNs) were mace. Those procedures were:

06-0P-1C11-C-0008 06-IC-1E30-4-0001 06-IC-SC85-0-1C04 06-IC-1E30-M-0001 06-IC-1E12-R-0002 06-IC-1530-M-0002 06-IC-1E33-R-1002 s Based on the acove review, it amoears tnat neitner One Revision 20 nor

), the non-Revision 20 procedures were witnout tecnnical M aw . It coes accear that arter the crececures were testec in ne tielc, tne V

procecures met the recuirements of ne acolicaole surveillance

( requisite. It must therefore de conclucac :nat in orcer to assess One

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k I 1 1 technical adequacy of the procedures, it is necessary to await perfomance and fine tuning of eacn surveillance procecure.

In general, the TCN's could be categori:ed as:

1. Typographical error, panel and instrument designation correction,
2. Rearrangement of steps to enhance efficiency,
3. Increase tolerances on calibration acceptance, 4 Specify proper test jack connections to verify relay contact continuity,
5. Include heac correction in gauge reading (one examole gauge is for indication only),
6. Correct point at wnich alams occur / reset (three examples), and
7. Scecify correct knoo to turn on test cevice (one examole).

Only items 4 through 7 are concerned with technical adecuacy. From the above, it can be concluded that the review crocess prior to issuing :ne procedures is less effective than desirable and is recuiring meticuluous attention to detail by the personnel perfoming the procedures to make them workable.

e. ASME Section XI Review Insoection of inclusion of ASME Section XI into procedures was limited to verifying that the methods used to stroke / time valves and check oumo parameters are consistent with Section XI recuirements. The manual wnich defines the Section XI program is still in draft fem. No attemot was made to verify all required components are includec in :ne program. Inclusion of Section XI into the surveillance program remains an caen item, designated as IFI 416/83-38-03.
f. Review of 10 CFR 50, Accendix J Recuirements Inspection of inclusion of 10 CFR 50, Accendix J reouirements into procedures included discussions with the ISI coorcinator anc lead tes engir ter concerning type 3 and C tests. Metnods of test scheduling were examined and recorcs of results of comoletec tests were examined for icceptability and retrievability. Current total leakage for tyue 3 and C tests is stated to be less than 20% of :ne tecnnical scocifica-tion limit. Revi sion 2 of 06-ME-1M61-V-0001, wnien inciuces :nese tests, lists acceptance criteria for each catnway. The total of :nese is less than the tecnnical specification limit wnicn is not crevicec in the crocedure. The licensee agreed to incorocrate a cirect comoarison of total measured leakage agains: the tecnnical soecification limit as well a.5 maintaining the individual criteria in :nei r procacure.

Revision 1 of 06-ME-1M61-V-0001 contained valve lineuos to estacli sn

) test boundaries; however, Revision 2 deleted nese. Aoparently, scme J- of :ne tests which are considered current were cerformec using sketenes i  ! anc notes to estaclish procer bouncaries anc venting instead of an i' acoreved procedure. The licensee is undertaking a review of availacle information to estaclish :ne validity of :nese tests. Acceptacle

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1-l 1 1 perfomance of the tests is required to satisfy the Technical Specification surveillance requirement wnien becomes effective wnen power exceecs 1".. This is an unresolved item (416/83-38-04) pencing further review by Region II to detamine wnetner or not sufficient l controls were in place to allow acceptance. of those tests cerformec  !

without a detailed procedure to assure containment integrity.

g. Surveillance Scheduling and Implementation A -eview of the surveillance scheduling and isolementation crograms was perfomed. The following observations were mace:
1. Implementation of Technical Scecifications amencments accears adequate.
2. Technical Specification surveillances which become ocerative uncer l certain plant conditions have been compiled in a list. Veri fica-tion of inclusion of all these items is still in progress. This is IFI 416/83-38-05.
3. A cross reference between Technical Soecifications, surveillance

) procacures and modes has been issued. The document is a master

/ list wnich can be used to verify correctness of camouter and

( manual scheduling systems for identification of surveillances needed prior to a mode change.

4. The computeri:ed surveillance scheduling system in ~ clace was reviewed. The type of infomation included appears to be adequate to schedule periodic surveillances. However, :ne system's usefulness for controlling surveillances crier Oc moce :nange is limited by the inability to upcate the test comoletion cates in a timely manner. The licensee is reviewing the program to see if this snortcoming can be remediec. Also, the camouter cata base has not been fully modifiec to reflect new anc/or deleted surveillance procedures which nave resultec from :ne rewri te program. These items are IFI 416/83-38-06.
5. Selection of surveillance crocacures to be cerformed prior to next nuclear heatup was discussed. It is the intent :nat all surveillances wnich require a shutcown to ce cerformec will be run prior to nuclear heatuo if they woula : cme cue witnin 3 montns after nuclear heatuo. A firm cecision nas not caen mace on :ne time interval nor has the scoce of work involved caen icentified.

This is IFI 416/83-38-07.

h. Logging System for Annunciators O-Lj A reactor ocerator incicated :nat no logging system has caen estaclished for annunciators in alarm to sucaly information as to :ne

- nature of the alam i .e. , valid condition, malfunctioning alarm neecing repair, etc. The establishment of such a logging system is a valuaale

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aid to control room operators and a desirable coerating cractice.

Licensee reoresentatives stated ha: this matter will :e consicered.

IFI 416/83-38-08.

6. Mode Required Surveillances The licensee is obligated pursuant to their Operational Enhancement Program, dated Maren 11, 1983, Action Item 1.3, to develop and implement prior to recriticality, an effective program to assure that those tecnnical soecifica-tions required surveillances applicaole in certain operating modes are incorporated into appropriate operations Integrated Ocarating Instructions (IOI), thus assuring implementation and performance of the surveillances.

A review of procedure IOI 03-1-01-1, " Cold Shutdown to Genera ce Carrying Minimum Load," revealed that accroariate surveillances applicaole to those operating conditions apoeared to have been acequately emoediec. Anotner IOI wnich entails plant coerating conditions from minimum load enrougn full load was not complete at the time of inspection thus was not reviewec. This is IFI 416/83-38-09.

O A review of operations surveillance procedure 06-0P-1000-0-0001, " Daily ,

V Operator's Log," revealed that the applicable, frequent (i.e., shiftly, j

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daily) surveillances appeared to have been incluced.

Sased on the above review and that of GGNS Acministrative Procacure 01-5-06-12, "GGNS Surveillance Program," which imolements surveillance requirements, it appears that the licensee has a program in force to assure that mode specific surveillances are performed.

7. Change of Mode Procedures The licensee is obligated oursuant to their Coerational Ennancement P-ogram, dated Maren 11, 1983, Action Item 1.4, to covelco and imolement criar ::.

recriticality an effec-ive program to verify :nat all tecnnical scecifica-tion recuired surveillance testing that is prerecuisite to moce cnanges nas been performed prior to entering snat mode.

The licensae nas comoiled a moce enange suiveillance crocecure wnich consists of a cross reference index of recuitec surveillances to :ne moce in whien the surveillance is requi red.' This incex usec in conjunction witn manually kaot surveillance logs anc a comouter printout of late surveil-lances wnich accorcing to the licensee may take two weer.s or more to uccate comorises the current program proposed by one licensee.

It is concluded that through ths <ery meticulous use of :nis cumcerseme manual system, it can be verifiec that :ne accroariate surveillances nave

( oeen performed prior to moce cnange. ,_

During the insoection, licensee reoresentatives cascribec a more soonisti-g catec moce change computer tracking system :nat is ceing cavelocec. Such a

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\ i h l system will be real time available and a great aid to the operating l personne1. l

8. Breacn of Fire Rated Assesclies On August 17, 1983, at 'approximately 2:30 p.m. , the inspector, while performing a routine plant tour, detected that fire doors 1-A306 and 1-A309 were blocked open. The inspector notified the shift suoervisor who in turn
took appropriate corrective actions. The doors had not been previously identified as open thus no compensatory measures were in force.

Technical Specification 3/4.7.7, " Fire Rated Assemolies," neouires in part l that all fire deces shall be operable at all times. Contrary to :nat requi rement, fire doors were found by the inspector to be blocked coen anc inocerable and no fire watch had been posted. This is a #iolation (416/83-38-10).

9. Training
a. Tecnnical Specifications and Precedure Compliance In the CCA letter dated Octooer 20, 1982, MP&L committed to conducting femal training of operating and staff personnel on the procer implementation of technical speci fication requirements, including procacure compliance. This commitment was to nave been completed orior to next reactor criticality. Additionally, Action Item 2.4 of :ne GGNS Goerational Enhancement Program recuires training oe concucted on recent TS cnanges and associated surveillances. The training program conducted to satisfy these commitments was reviewed anc a cortion of
ne training was attended by memoers of :ne assessment team.

The training program consisted of three lectures; T5 training Phase I and II, and surveillance precedure enange training. 75 training 3hase I consisted of a discussion of the history, format anc legal casts of GGNS technical specifications; the need for stric vercatim comoliance l was stressed. Phase I enced with a ciscussion of recent enanges to 75.

T5 training Phase II began with a discussion of recent preolems a:

l GGNS, followed by a practical exercise in TS intercretation. This  !

session ended as did Phase I with a discussion of recent 75 cnanges.

The lesson plan for training on survefilance crocecure enanges inclucac i a review of orcelems associated with surveillances, recent changes mace l l :o :ne surveillance program, and cesignations of incivicuals l responsible for evaluation of the results of comoleted surveillances.

l l Eacn of tne above courses, consisted of one or two nours of classroom lecture followed by cuestion and answer sessions. The surveillance i crocacure enange training additionally inclucec a cos lecture written i

evaluation (quiz).

s A review of the documentation of Mis training ceterminec :na: training i s received by each licensed coerator was being trackac. At :ne time of l this review, nearly all licensed operators hac received :nis training.

11 Additionally, licensed coerator candidates seneduled for NRC licensing exams in September and Octocer nave received this training. During thi s documentation rev;ew, it was ceterminec :na :ne Shift Tecnnical Advisors had not been targeted to receive this training. This item of STA training was discussed with the licensee and a commit. ment was mace-to administer this training to the STAS. Subsequent review snowed that this training had been completed through the required reading program.

The inspector discussed the classes with the training manager and expressed concern at the lack of technical detail in :ne ciscussion of past problems and TS bases. The licensee stated that accitional detailed TS training would be included in the initial and recualification training program for licensed operators.

Pending completion of this training for all corsonnel icentifiec, including STA's, the CCA commitment to conduct TS training is considered sati sfied.

b. Design Change Package Training ,

Ouring an assessment of operator training at GGNS conducted in February 1983, cocumented in IE Insoection Report 50-416/83-06, it was determined that a significant number of modifications /casign changes had occurred for wnich training had not been conducted. In response to this finding, MP&L conunitted to crovice information/ training to operations personnel on plant modifications comoletec during the current outage.

In response to thi s commitment, MP&L contracted GE :o ceveloo and conduct this modi fications training. During :nis assessment, :ne lesson plans caveloped to support :nis training were reviewec as well as ne documentation of training concucted. The lesson clans reviewed appeared acequate to establisn the reason for the mocification, wna:

was enanged and how the change affected plant systems /rescanse. The documentation review determined that eacn individual targetec to receive this training was tracked to ensure completion of all cortions.

At the time of this review, nearly all the required training nad caen completed. A program to pick uo any incividual wna missed training sessions had been develooed. The licensee anticicates no cifficulty in completing this training prior to one next criticality.

As icentified above uncer paragraon 9.a. , tnis review cetermined that the Shift Tecnnical Advisors hac not caen targetec to receive :nis DCP training. The licensee stated na the STAS woulc receive :nis training. Sucsecuent review snowed tha: the STAS hac receivec training on all but seven DCPs. The remaining training is seneculec :o ce O

( b-comoiete prior to next criticality. The item, wnien nac caen icenti fied as violation 416/83-06-02, is enerefore closec. -

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c. Training Occumentation Deficiencies l In January 1983, GGNS training decartment initiated several Plan:

Quality Deficiency Reports (PQDR) icentifying existing cocumentation ceficiencies associatec with the training records for several licensed operators and senior operators. The acparent deficiencies anc the existance of the associated PQDR's were documented during the Feeruary 1983 NRC Training Assessment as noted in IE Repor 50-416/83-06. In this report, the deficiencies were left as an unresolved item (415/83-06-01), pending comoletion of the licensee's documentation search. Inspector followup on this unresolved item, during this inspection, detarmined that the licensee's cocumentation search had been completed.

The licensee's documentation search determined snat for PODR's 5-83 and 7-83, which identified deficiencies regarding training c:mmitments mace in the facility :inal Safety Anijysis Report (FSAR) and plant administrative pro:ecure 01-5-04 ', training identifiec as accomplished on the individual iRC license applications had not been c mpleted. In the case of PQDR 3-83, r.te training recuirements in question were determined to have be=n satisfied by other training sucn as nat received in the Navy nuclear program. In tne case of PGDR 7-83, wnich G(- identified deficiencies in control room qualification card documenta-tion, it was determined that this training nad not caen c:moleted by eignteen licensed personnel . Althougn the c:moletion of the control room qualification card is not an NRC crelicense training recuirement, it is a commitment in GGNS F5AR Section 13.2.1.1.

Several other areas of concern identified curing this PODR review are as follows:

1. The control room qualification card was listec as cart of :ne training received on license apolications sucmittec to :ne NRC.

Althougn the absence of this training woulc not necessarily nave been grounds for denying these indivicuals examinations, One applications contained information known by ne licensee to e incorrect; yet, no attemot to correct this information was mace.

2. The PQDR program's review crocess allowed :nese :COR's, wnien contained information of regulatory concern, to : ass :nrougn :ne system uncetectac.

Corrective action initiated as a result of :nese PCORs inclucec :ne estaclishment of a checklist as part of the imolementing :rocecure for licensed operator training. This checklist will scecify all recuirec training and crovice means of cocumenting rocer eviews anc evaluations prior to sucmitting license acclications.

A subsecuent review of the PQDR program revealed a :rogram ceficiency

( resconsible for :ne creakdown in :ne recorting process. The PQORs, as one method utilized to alert the Plant Quality organi:ation of

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deficiencies, have in the pas during plant construction :een reviewed I almost exclusively with respect to 10 CR Part 21 anc 50.55(e) recorting requirements. To ace:molisn a more comorenensive review, :ne licensee has c:mmitted to change :ne review crecess to incluce review I by the plant Regulatory Compliance Group. This program enange snoulc fill the existing gap in the PQDR review process.

Supplying incorrect information to the NRC on coerator license applications is a subject which will ce considered for enforcement action and is identified as an unresolved item (416/83-38-11). This issue remains open pending further review of this matter by Region II.

This unresolved item superceces the previous item concaming cocumen-tation. Therefore, unresolved item 416/83-06-01 is closec.

10. Quality Assurance Audit Program Item 4 of the Confimation of Action (CCA) letter dated Oc::cer 20, 1982, specifically stated tnat the licensee would, " Establish a formal Quality Assurance audit program to assure c:moliance with the acove cegulatcry requirements." The three preceecing items of the CCA letter certained to O review of surveillance procecures to ensure technical adecuacy, preparation of license amencments requests and training of staff personnel. The inspector reviewed the licensee's audit program and concucted extensive

, interviews with audit personnel.

The inspector reviewed Master Auci Plan (MAP), Revision 6 (CAMI-33/0420) dated July 12, 1983. MAP Reference S.019.00.a states :nat aucits are conducted to assure conformance of unit coeration to provisions containec within the Technical Specifications ( Accencix A to License No. NPC-13) and acclicaole c:nditions at least once :er 12 montns. MAP Reference 3.020.00.o states that aucits are conductac to assure performance, training anc cualifications of ne entire unit staff at least once per 12 mon:ns. MAP i Reference C.038.00 includes three carts. Audits are concuctec to assure nat witnin the first three years of Unit oceration, that all surveillance requirements delineated by Tecnnical Scecifications are aceouately accressac and are performed at the specified frecuency. Semi-annual audits are concucted of Technical Specification enanges ,to assure sna cnanges have teen incor:oratec into surveillance procecures. Annual aucits :: verify, ty means of representative samola, :nat ASME Boiler anc 3-essure Vessei Cece, i See:1on XI, recuirements and 10 CR 50, Accencix J recuirements ::ntainec in

ne Dumo & Valve Program .,a v e een accressec anc imolementec for pre / inservice inspection of Class I, II, anc I:I c:moonents, cicing anc pumps / valves.

The inscector reviewec :ne Quality Assurance Section Auci: 3-ogram Plan (APD) catec Decemoer 31, 1982 anc APo, Revision 1, catec :soruary 9,1983.

Soth of :nese plans enc:moass auciting schecules for :erices January 1,1983

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q-[ :nrougn Decemoer 31, 1983. Revision 1 acded accitional aucits to reViec:

MAP Reference C.038.00.

s The inspector reviewed Quarterly Aucit Senedule updates for :ne seconc and third quarters of 1983 (CAMI-83/0440 and -83/0360 catec March 30, 1983, anc June 24, 1983). Audits have been conducted of Tecnnical Specifications (TS)

14 b)

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3.8.1.2, 4.8.1.2, 3.8.2.2 and 4.8.2.2. Corrective Action Recues: (CAR) 2022 and 2018 were issued as fincings in Monitoring Auci: Recor:s (MARS) 83/0040  :

and 83/0050. Four additional audits were seneculee out were cos:conec due I to problems encountered with TS by Surveillance Group reviews. These aucits )

will be rescheduled at a later cate. Another aucit (MAR-83/0038) was in l process relative to the Surveillance Review Program. Three QA personnel  :

performed a technical adequacy review of 99 surveillance orecacures. l Conusents generatec by this review will be tracked and rescondec to by the Surveillance Review Group. This audit was seneculed for issuance the week of August 15, 1983. One TS cnange audit was seneculed during June 1983, however, this audit was delayed since no TS amencments had been received curing the second quarter of 1983.

The insoector reviewed the following MARS: 82/47, 82/89, 82/90, 82/102, 83/002, 83/004, 83/007, 33/008, 83/009, 83/014, and 83/023. The insoector reviewed the following CARS: 633, 639, 640, 641, 642', 643, 676, 687a-0, 692, 2000, 2002, 2004, 2005, 2007, and 2008.

Within these areas, three violations and two inspector followuo items were icentified and are discussed below.

a. Failure to Issue An Incident Report (IR)

MAR-82/89, concucted October 13-20, 1982, reviewed imolementation of TS

( 3/4.1.1 Shutdown Margin, 3/4.1.2 Reactivity Anomalies, and 3/4.10.3 Scecial Test Exception - Shutdown Margin Demonstration (SCM). The auditcr identified that potentially TS 3/4.10.3 had been missac due to the lack of an imolementing procacure to verify compliance witn :ne 30 minute requirements for full core SCM cemonstration erformed August 8, 1982. The auditor notified the Shift Sucerintancent at 9:00 a.m. on August 18, 1982, with the recommencation :nat furtner investigation ce a::ncucted to cetermine reportability recui rements . Discussions with clant personnel icentifiec :nat no investigation was concuctec nor was an IR prepared. Acministrative Precacure 01-5-05-06, "!ncicent Reports / Reportable Events," Revision 4, states :nat eacn incivicual .no becomes aware of a reportable type ceficiency is resconsible for initiating an IR and the Shift Suoerintancent is resconsible for ensuring that all incidents that occur or are crougnt to nis attention are reported. This failure to crepare an :R anc recor :ne missac surveillance constitutes a violation (416/83-38-12).

b. Failure to Correct Concitions Adverse o Cuaitty In A Timely Manner.

The inspector reviewed the licensee's 31'an t Quality Ceficiency Recorting (PCDR) system. This mecnanism is usec :o recor: non-material clant problems icentifiec by slant oersonnel. Plant Guai *:y is resconsible for tracking and seesing timely resolution of :CCRs. A j Q- samole of accroximately half of ne outstancing PCCRs (46) .ere l reviewed. Since May-Aoril 1983, the PGDR system nas imorevec.

s Discussions with plant QA and PQ personnel incicate that accu: :nis

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time frame PQ revised the PQDR system. Audits concucted by CA of PQDRs issued from numbers 83-43 indicate no deficiencies, f

However, wnen the new PQDR program was institutac, no provisions were made to incorporate previously open PCORs into the rev/ sed system. One PQDR remains open from the latter part of 1981 (00051-81 identi fiec October 16, 1981) son's from 1982 (00056-82, 00070-82, 00099-82 and 00138-82) and some from early 1983 (0005, 6, 7, and 8-83). The inspector identified numerous examples of improper documentation, lai:e or inacequate responses to PQDR findings and failure to follow procedures prior to the April-May 1983 upgrade of the PQDR system.

Multiple Corrective Action Recuests (CAR) had been written by QA relative to PQCR system problems but these CARS have been closed out.

The failure to correct conditions adverse to quality in a timely manner for those PQDRs written before April-May 1983, constitutes a violation (416/83-38-13).

c. Failure to Issue An Audit Within TS 'tequired Time Frames.

MAR 82/89 conducted October 13-20, 1982, was signed by the auditors on Octocer 22, 1982, but was not signed or issued cy the site QA Manager

) until January 17, 1983. Tnis audit identified one nonconformance, CAR 687b. This CAR was issued and responded to prior to the audit being -

formally issued. The failure to issue the audit within TS referencac time frames could not be explained by audit personnel. The issuance and response to the CAR was provided as supplementary information. It was exclained that this audit may have been issued without the site OA Manager's signature and then recalled for his signature ::ut this coulc not me verified. This MAR was the only one issued outsice of TS reouired time frames of the eleven reviewec, newever, :nis failure to

, issue MAR-82/89 within TS requirec time frames constitutes a violation i (416/83-38-14).

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d. Clarify Responsibilities For Initiation Of Inciden: Recorts (IR)

AP 01-5-06-5, Inci dent Reports / Reportable Events", Revi sion 4, j Section 2.2 states that each individual who becomes aware of a recort-able deficiency is responsible for initiating an Incicent Recor: (IR) and delivering it, without celay, to :ne Shift Sumerintancent. Section 6.1.2 states that the IR will normally be initiated by :ne incividual wno discovers the incident or oy his sucervisor. Unti1 :nis crocacure is upcatec to specifically reflect resconsibilities for initiating an IR this is icentified as IFI (416/83-38-15).

e. Erroneous Reference In Corrective Action Procedure s .

QAP 16.10, " Corrective Action Raouest, catec July 22, 1983, Section

(- III.G.3. states that snould a resconse continue outstancing :nFougn another week, proceed in accorcance with Paragraon IV.G.8.

( . Paragraph IV.G.8 does not exist. Until CAP 16.10 is uccatec to celete this erroneous ceforence, this is identified as IFI (416/83-38-16).

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11. L: ensee Actions On Previously Identified Insoection Fincings (Cicsed) Inspector Followuo Item (416/83-22-05) Review Actions for Unreviewec Safety Questions. The inspector reviewed Procecure 01-304,

" Design Change Packages," Revision 6. Section 6.6 has been revised to include necessary controls for handling 10 CFR 50.59 . reviews if an unreviewed safety question is identified. This item is closed.

(Closed) Inspector Followup Item (416/82-67-07.) The inspector determined that the surveillance program training and revisions to the controls on the surveillance procedure review process should provide the licensac operators witn information on how to assure tnat Technical Specification requirements were implemented by surveillance procedures. The inspector also reviewed the licensee quality assurance program and determined that aceouate provisions for audits of surveillance requirements were included. This 1:em is therefore closed.

(Closed) Inspector Followun Item (416/82-67-06) The insoector reviewed surveillance procacures for tecnnical aceouacy and incor: oration of TS requirements as discussed in paragraph 5. This item is closed.

(Closed) Inspector Followuo Item (416/83-22-02) The insoector reviewed training for licensed operators on design enange packages as discussed in paragraan 9.c. This item is closed.

(Closed) Inspector Followuo Item (416/81-46-12) The insoec:ce reviewed tne status of the rewrite of procedures for the surveillance program.

Procedures were reviewed for confor nance between acceptance criteria anc tecnnical saecification requi rements . No concerns were icenti fi ed. The item is closed.

12. Coerations Ennancement Program (CE?)

An aucit of corrective actions discussac in :ne CE? *as conducted. The inspection team reviewed actions taken for the following CE? items.

a. Action Item 1.1, " Review and Revise Surveillance Drececures anc Technical Sceci fications. " The resul t's ' of inat insocc ion of surveillance procacures anc TS are ciscussed in paragraons 5 anc M ,

respectively.

b. Action Item 1.2, " Establish Surveillance Auci: P-ogram." The item is discussed in paragraon 10. The inspector ceterminec :na an aceoua:e Quality Assurance Audit Program nac caen estaciisnec and imolementec.
c. Action Item 1.3, "Drecare Cross Reference Incexes." Task 1 is

,i discussed in caragraon 5. Tasx 2 is ciscussec f n paragraon 7. The d insoec ce verifiec tha ne cross reference incexes nave oeen iss~uec as committed.

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d. Action Item 1.4, " Enhance Control of Moce Changes." The inspector verified that a manual control system had been cavaloped. It was noted as discussed in paragrapn 7 that ne manual system was acequate out cumoersome. Licensee representatives described an imoroved l computeri:ed system that is being developed. I
e. Action Item 2.1, " Strengthen Long-Tem Operator Training Program." The inspector discussed the MP&L contract with Quadrex Corporation to provide instructors for RO and SRO training with the training suoervisor. Nine of these instructors are scheduled for certification exams in November, 1983. The remainder are scheduled to be certified by mid-1984. Several concerns identified during review of tne coerator training program and administration of recualification examinations were provided to MP&L in a letter dated August 29, 1983. This letter requests' additional information regarcing upgrace to the licensed operator certification process.
f. Action Item 2.2, " Strengthen Control Room Operator Training". The licensee has established a required reading program to provide shift

. personnel with information on modifications and significant events. A committee has been established to review and recommend apercoriate training material . A procedure was in place to track comolation of required reading packages with accropriate controls to assure timely comoletion. No concerns were icentified.

g. Action Item 2.4, " Provide Technical Soecification Training." This item is discussed in paragrapn 9.a.
n. Action Item 2.5, " Utilize Plant Soecific Simulator for Regular Coerator Training and Power Ascension Training." The inspectors toured :ne newly constructed training conter whien houses :ne simulator. The NRC participated in recent requalification testing inclucing :ne simulator cortion of :ne recualification exam. The results of :ne simulator testing, provided in a letter of August 29, 1983 to MP&L, were satisfactory. Training records for R0s anc SR0s were aucitec anc included records of training on power ascension procacures.
1. Action Item 2.5, " Provide Instruction to Ocerations Personnel on Dian l Modi fications. " This item is discussed in Section 9.c. Training was cetermined to be satisfactory witn :ne excention of Cesign Change Package (DCP) training for STAS. The inspec:ce confimec that training for STAS nas since been completed except for seven CCPs for nien training via the required reacing program was in progress.

J. Action Item 2.7, " Provide Training on Surveillance Program - :lecent Changes." This item is discussed in Section 9.a.

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k. Objective 3, "Imoreve Control of Plant Modifications." Control of plant modifications is the sucject of ongoing insoections cy :ne NRC senior resident inspector. Commitments in the CED in :nis area are

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being reviewed under :nis inspection effort.

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1. Action Item 4.1, "Imolement Management Verification Activities." The inspector discussed the overall program for management and control of MP&L's interface with regulatory agencies witn :ne Vice President -

Nuclear. No areas of concern were icentified. The following specific commitments were reviewed.

1. Action Item 4.1.1, " Establish Corporate Regulatory Compliance Functi on . The inspector interviewed the Supervisor of Regulatory Compliance who was appointed in Decemcer 1982. program goal s, procedures for commitment control, procedures for coordinating resconses to NRC open items and the schedule for imolementation of the procacure, were audited. Several revised procedures have yet to be approved. The licensee stated that tne actions were accroximately 30% complete and that implementation of the procedures would be comoleted prior to next criticality.
2. Action Item 4.1.2, "Estaolish GGNS/ Plant Staff Comoliance Section." The inspector reviewed the section responsibilities, interfaces and procedures and discussed *hese areas with the manager of this section. The areas appeared to be adequately defined. No areas of concern were idantified.
3. Acti,on Item 4.1.3, " Establish Recuirements Procacures Tracking System (RPTS). The inspector reviewed computer crintouts of portions of the RPTS. The licensee stated :nat icentification of recuirements to be entered into the data base is accroximately 75 percent complete. and 20 percent of the verification aucit is complete. No areas of concern were identified.

4 Action Item 4.1.4, "Imolement Licensing Commitment Tracking System

( L;TS ) .

  • The insoector reviewed an outline of :ne new Commitmen:

Tracking System (CTS). This system =cmoines the LCTS, wnien tracks NRC/NRR items, with a Safety Acministrative Tracking System, an NRC/I&E tracking system and a Corrective Action Tracking System. All tasks associated with this item appear to be comclete.

5. Action Item 4.1.5, Increase Management Attention to Quality Assurance Findings." A listing of outstancing Correction Action Recuests (CAR) is proviced to olant management on a weekly basis.

A tracking system for CARS has caen imolementec. No :encerns were identi fied.

m. Action Item 5.2, "Condue: Acministrative Level 3-ocacure Training.

The inspector reviewed the training crovicec to clant eersonnel on acministrative crocecures certinent to neir jocs. A crogram nac ceen establisned to icentify pertinent procecures, crovice lesson clans, Q'h training, anc cocumentation of attencance and examinations. Instances-were noted cy the inspector where stragglers had not recieved training The training department identified nese as incividuals no g- as yet.

longer emoloyed by MP&L or. scheduled for retraining. One .eanness was

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  • I 19 identified in that meaningful reexaminations were not given wnen an individual failed an exam, i.e., the same exam was acminstered a seconc time.
n. Action Item 5.3, " Conduct Review of Acministrative Procecures". The inspector reviewed the program established to review anc imoreve administrative procedures. The licensee stated : Mat a review of plant level and section level procedures had been completed. The majority of revisions needed had been comoleted. The remainder are to be c:molete prior to commercial operation. The licensee has hired a contractor to c=mpletely review all administrative procacures and rewri te and reformat the procedures to imorove clarity and useability. This effort was to begin Septemoer 1, 1983 and be c:moieted my July, 1984 During a review of procedures, the Resicent Inspector had noted :nat the licensee was using the term "shoulo", inacoropriately. "Shoulc" is defined in MP&L's QA program as a rec:mmendation. The inspector reviewed the orecedure for post trio reviews and ceterminec that, under

. the present MP&L definitions of "snall" and "snould," a post trip review would be categoriced as a recommencation instead of a require-ment. The extent of inacorcariate use of the term "should" in safety-related procedures will be examined in future inspections. This is icantified as IFI 416/83-38-17.

o. Action Item 6.3, " Enhance Operational Experience Feecback 3rogram."

The inscector reviewed the required reading program as discussed in 12.f aoove. No concerns were identifiec.

3. Action Item 6.4, " Improve Coordination of Coerations, Healta 3hysics, Security During Emergencies "and Action Item 6.5, "Increve Security Coerations." The inspector examined :ne Coerations/ Security interface as discussed in paragraan 13.
13. Review of Grand Gulf Security Program The inspector reviewed the management controls and succort for imolementa-tion of the security program and determined :nat :nese :entrols are aceouate for effective imolementation of the slant security crogram. The security manager recorts to assistant plant manager for succor: services. WP&L security supervisors manage eacn c:ntract guarc force snift on a 24-nour casis.

Concerns related to issues icentified cy :ne NRC safe:y-safeguarcs review committee nave been aceauately accressec. Anti-cass acK and (ey-cac features of the security c:mouter access c:ntrol system nave :een celetec.

3rovisions for raoic ac:ess of coerators curing emergencies nave :een n(j imolemented. Plant anc security force crocacures nave :een -evi sec to

'ecuire communications and operational interface, anc estaclisn clear g autnority lines. The security force reports to the snift sucervisor. A

(, training program to ennance the coerations/ security interface is :eing prepared for use in initial and recurring training. The security camouter

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T operational capacility has been imoreved by software enanges, exceditec maintenance, anc deletion of unnecessary features of :ne system.

A walkcown of all vital areas determined the licensee to e in comoliance with their approved security plan.

14. Technical Specifications (TS) Review The inspector reviewed the precaration, review process and implementation philosophy for tne original TS and changes to the TS. The licensee agreed that the draft (prior to issuance of OL) was not carefully or aceouately reviewed by MP&L personnel. Of the MP&L personnel :nat cid review :ne craft TS, few, if any had operating experience. The PSRC was not involvec in the review of the draft. MP&L did provide the craft TS to GE and Becntal for review and input; however, no efforts were mace to seek review, inouts or guidance from other ocerating SWRs. As a result of :nese inaceouate reviews, ne TS contained numerous errors.

Upon determining that various proclems existed witn the TS, the licensee establisned a TS review group to perform an intansive review of the TS, surveillance procedures, and the plant design. This review was c:ncuctec h

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during Octocar enrough Decencer of 1982. The review icentified amoroxi-mately 200 TS items wnich requirec changes.

The licensee stated that all changes required for oceration to the enc of the fi rst fuel cycle have been sucmitted to :ne NRC. Two additional packages of cnanges (i.e., licensee category Priority 3) will be sucmitted in the near future. The TS review group estaolished to perform :nis intensive review will be discanced when the current effort is c:moleted.

All future TS enanges will be coorcinated at :ne slant cy :ne c:moliance group.

During ne preparation of proposed TS cnanges,.:ne licensee coes not normally verify that tne proposed change will wars or verify :ne neec for the procosed change by walking through a procosed revision to One affectec imolementing procedure. In fact, revised procacures are not normally precarec until after sucmittal of a TS cnange recuest to the NRC. This oractica could potentially result in situations in wnien a enange recues will be sucmitted anc aporoved but will not wars wnen attemots are mace to imolement it, tnus, recuiring :ne sucmittal anc crocassing of yet ano:ner enange recuest. The inscactor rec mmenced sna: :ne licensee c:nsicer accoting a walk thru of a procosec revision in its initial review crocess.

Althougn TS cnange recuests are reviewed :y the 3SRC cr4or to succi::al to ne NRC, the licensee coes not normally have 75 cnange recuests reviewec :y Oceration's cersonnel. The inspector rec:mmencec :na: :ne licensee c:nsicer acocting suen a policy in its review process.

] The licensee stated nat surveillance procecures cc 10: recuire verification of instrument set points during montnly cnannel 'unctional tests (CFT).

\-- Review of current surveillance procedures for CFT seouitec by TS c:nfirmec

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that the setpoints are not verified as a step in the procedure. Lfconsee representatives stated that their position was that enis is not currently recuired. The inspectors stated that this matter will be reviewed further by NRR and Region II. (IFI 416/83-38-18)

A few of the recently proposed TS changes indicate a tendency by the licensee to attempt to resolve technical specification problems by simply deleting requirements from the technical specifications rather than by solving the original problem. A couple of examples of this amoroach are the proposal to delete the technical specification operability recuirements for the fire detection instruments in the steam tunnel because the expected operating environment would be 'too hot; and the proposal to delete a notation for a specific type calibration from the offgas post-treatment noole gas activity monitor because tne instrument readout was in CPM ratner than ar/hr. Licensee representatives stated at the exit interview that these are isolated instances and not the normal practice. The licensee agreed to orovide more accurate and comolete justifications for any future proposed changes.

In general, the licensee has attained a high level of technical accuracy and acequate understanding of TS requirements through intensive reviews, i

revisions to TS and training. The licensee's review of pronosed enanges is being conducted under organized and significantly imgroved programs.

15. Review of Shift Staffing Levels Shift staffing levels were reviewed with the following results. MP&L has i twelve Senior Reactor Goerators (SRO) (including two SRO licensed training personnel), eleven Reactor Operators (RO), and three Shift Technical Acvisors (STA). Six SRO candidates are senedulec to be examined Sootemcer 25, 1983. Four RO candicates will be examinec Novemcer 7,1983, and three STAS will ce certified in Novemcer, 1983. MP&L currently is staffing four shifts. NRR is reviewing :ne acceptamility of :nis action for the full. power license. Region II nas determinec :nat altnougn staffing levels are marginal, MP&L can meet :ne Tecnnical Scecification recuirements, using five shifts, without violating overtime limits. This would, however, require on shift duty of SRO licensed training corsennel .

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