ML20133E901

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Forwards Further Detailed Info as Followup to 830930 Addl Info Re Discrepancies & Corrective Actions Taken on Applications for Operator Licenses.Training Program Adequate & Operators Fully Qualified to Safely Operate Facility
ML20133E901
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 11/01/1983
From: Mcgaughy J
MISSISSIPPI POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20081D396 List:
References
NUDOCS 8508080058
Download: ML20133E901 (111)


Text

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m]A MISSISSIPPI POWER & LIGHT COMPANY

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B O X 16 4 0. J A C K S O N. MIS SIS SIP PI 3 92 05 November 1, 1983 2

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U.S. Nuclear Regulatory Commission Region II 101 Marietta St., N.b'., Suite 2900 Atlanta, Georgia 30303 Attention:

Mr. J. P. O'Reilly, Regional Administrator

Dear Mr. O'Reilly:

SUBJECT:

Grand Gulf Nuclear Station Unit 1 t

Docket No. 50-416 J License No. hTF-13 File 0765/0260/0272/0092 Applications for Operators' and Senior Operators' Licenses AECM-83/0681 Mississippi Power & Light Company (MP&L) advised members of your O.,

staff during a special training assessment conducted on February 15-17,

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1983, of discrepancies discovered in previously submitted applications U'

for some of the operator license candidates.

On September 30,' 1983, MP&L submitted AECM-83/0629 providing additional information on these discrepancies and corrective actions taken or in progress. This subject was also discussed in a meeting with you on October 12, 1983. This letter provides further detailed information as a followup to our September 30, 1983 letter and our actions to resolve this matter.

MP&L performed a' complete review of training records for all currently licensed reactor operators and senior reactor operators at the Grand Gulf Nuclear Station.

Discrepancies were identified between license applications and training records.

Enclosed is our discussion of each discrepancy and the corrective action taken.

These discrepancies can be categorized into three general areas:

1)

Consistency of training duration (l'ength of course) with that stated on the license application, 2)

Existence of documentation to substantiate certain training listed on the license application, or 3)

Cotpletion of qualification cards.

A majority of the discrepancies identified in this letter is the O) result of training record errors that occurred prior to 1982. There has been a significant improvement in the maintenance of training records since that time.

The new NRC license application form has helped us to I

eliminate application errors.

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AECM-83/0651 MISSISSIPPI POWER & LIGHT COMPANY age 2 (O

In addition, MP&L's Operational Enhancement Program (MP&L letter to NRC, AECM-83/0177, dated March 11, 1983) addresses our plans to improve the Qualification Card Program.

These actions include performing a review of the effectiveness of qualification cards and improving methods for tracking qualification cards to completion. As noted above, MP&L letter AECM-83/0629 identified other corrective actions taken or in progress.

MP&L has taken a further action to eliminate errors in training records and license applications.

In the future, the person preparing each application will be required to sign a statement that training records substantiate the training listed on that application. The Operations Training Supervisor, the Training Superintendent, or their designee will independently verify the information on the training record and will sign a similar statement.

Identification and investigation of these discrepancies were performed by our Training Section. Further, as I requested, our Quality Assurance organization has conducted a completely independent review of these records. All discrepancies identified are discussed in the enclosure.

In addition, certain members of our quality assurance management have conducted oral interviews with approximately one-half of the licensed personnel. These interviews provided added assurance that the training subject listed on the applications is valid, with the exception of those discrepancies already identified. All licensed operators will be interviewed prior to November 14, 1983.

1 Although certain discrepancies involving the accuracy of license applications and training records were identified, MP&L has developed and maintained knowledgeable, well-trained, qualified operators. This conclusion is based, in part, on our review of the extensive training conducted, much of which is not shown on the license applications. Our conclusion is further based on review of in-house and independent examinations given and on experience gained during our preoperational testing phase.

Our investigation, including independent QA assessments, provides assurance that we have identified the nature and scope of the discrepancies. Corrective actions, where necessary, have been identified and are being expeditiously pursued. Based on our review and our meeting with you on October 12, 1983, we believe this satisfies the commitment in our letter, AECM-83/0629, dated September 30, 1983. This information should support the resolution of the matter.

In summary, we firmly believe that our training program is adequate and that our operators are fully qualified to safely operate the Grand Gulf Nuclear Station.

Yours truly, j

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Enclosure cc:

(See Next Page)

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1-j AECM-83/0681 1

3 MISSISSIPPI POWER & LIGHT COMPANY

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cc:

Mr. J. B. Richard (w/a)

Mr. R. B. McGehee (w/o) j Mr. T. B. Conner (w/o)

Mr. G. B. Taylor (w/o)

Mr. Richard C. DeYoung, Director (w/a) l Office of Inspection & Enforcement-U.S. Nuclear Regulatory Commission Washington, D.C.

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Enclosure to AECM-83/0681 Page 1 (O

Discussion of Discrepancies Between Operator License Applications and Training j

Records i

Discrepancies identified between operator license applications and training records can be categorized into three general areas. Discrepancies in each area and corrective actions taken are discussed below.

1 1.

Actual durations of training (length of courses) were not as l'ong as those stated on the license application.

It should be emphasized that durations of particular courses can vary for a number of reasons.

In particular, it should be noted that license applications are nor= ally forwarded to NRC several weeks prior to NRC examinations. In these cases, training listed may be in progress and/or projected, by date, fer completion prior to NRC examination.

Although durations may vary, it is important to note that the required

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material, or its equivalent, is thoroughly taught and operator candidates r

are extensively exacined by MP&L.

i In addition, operater candidates frequently participate in further one-on-one instruction, refresher reviews, and self study programs administered by MP&L.

Based on the following information concerning identified discrepancies and the general conclusion that the required material has been adequately covered by the training provided, no further action is necessary.

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a.

Several applications listed one week of Mitigation of Core Damage training. This course was actually taught in only four days.

Our letter, AECM-El/330, dated August 28, 1981, to Earold Denton committed to over eighty hours of Mitigation of Core Damage training.

Although only thirty two hours of training were documented for this

/N course, much of the material normally taught in the Mitigation of Core i

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Damage Course was taught, and documented, in other courses. The eight Week Grand Gulf Technology (or Systems Course) includes modules on P32rgi i

Enclosure to AECM-83/0681 Page 2

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fuel design, neutron monitoring and vessel instrumentation. Heat Transfer and Fluid Flow, Emergency Procedures, and FSAR Chapter 15 are taught as individual courses. Each of these areas is a major topic in the Mitigation of Core Damage Course. The duration of training in these related modules totals to over eighty hours, in excess of that coc=fted to in AECM-81/330. After completion of the above noted courses, the remainder of the Mitigation of Core Damage Course was taught in thirty two hours. A review was conducted of the course material and the examination for this four day course. This review substantiated that the material was thoroughly covered.

b.

Several applications listed a thirteen day Plant Operations Course addressing the FSAR, Integrated Operating Instructions, and Emergency Plan Procedures, and a seven day Plant Operations Course addressing Technical Specifications. These were actually taught as a combined fifteen day course. The thirteen day course listed was actually taught in ten days and the seven day course was taught in five days.

The course was listed in the training records as a fifteen day course.

U c.

Several applications listed a twelve day simulator refresher course which was taught in ten days. The schedule for this training was shown on the applications as 11/12-11/23/82. These applications were submitted in October, 1982, indicating this was training anticipated for completion per the above schedule. Only ten days were required to perform the training.

d.

Several applications listed a thfrteen day Plant Operations Course which was actually taught in twelve days.

One application listed a fourteen day simulator refresher training e.

course. The records of this course indicate that it was actually taught in thirteen days.

f.

One application listed a one day QA indoctrination Course which actually lasted one hour. This was an error in the appifcation as the t

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training records indicate the one hour course. This material can be satisfactorily addressed in one hour.

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Enclosure to AECM-83/0681 Page 3

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g.

Three applications listed a six week Heat Transfer and Fluid Flow Course. A three week ccurse was inadvertently entered twice in these applicants' training records; and, when the application was prepared, the duplicate courses were shown on the application as one six week ccurse. The training records for these individuals have been corrected.

h.

One application listed one day of fire brigade training which was actually taught in four hours,

i. Two applications listed a one week Plant Oper'tions Course which was a

actually taught in four days.

j.

One application listed a five month Introduction to Nuclear Power l

Course which was actually taught in four and one-half months.

l 2.

Documentation did not exist to substantiate certain training listed on applications.

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Several cases were identified where documentation in the training records did not substantiate training listed on the license applications; however, based on successfully completed equivalent training, which was documented for each applicant in the training records, we believe the operators to be fully trained and qualified. No further action in these cases is necessary. These discrepancies are discussed below.

a.

Several applications listed a six day Reactor Physics, Core Thermo-dynamics and Radiation Control Course. There are no records that document this course. Each of these applicants had other equivalent training that thoroughly addresses each of these subjects. Both the MP&L and NRC examinations test this area.

I b.

Several applications listed a three day Heat Transfer and Fluid Flow Course, yet documentation does not substantiate this training. Each of these individuals had other equivalent training which thoroughly addresses this material. This material is also well-covered on MP&L and NRC examinations.

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Enclosure to AECM-83/0681 Page 4 (A) c.

One applicant listed a twelve week Cold License Training Course / Grand Gulf Technology on three different applications. The training records indicate that he did not obtain a passing grade on week 10 of this course. Prior to his third application, he did satisfactorily cocplete a twenty one week License Operator Exa Prepratien Course which thoroughly covered this material.

d.

One application listed a twelve week Grand Gulf Techselogy - Cold License Training Course. There are no records te verify week 3,11, or 12, and week 9 is incomplete. This same applicatie: listed a three week Heat Transfer and Fluid Flow Course, but there are no records to verify this. This training material was thoroughly cevered in a later twenty one week License Operator Exam Preparatien Cocrse, which he satisfactorily completed, e.

One applicaticn listed a two week pre-simulator course, but there is no record to verify this. This applicant failed the FT.C exacination.

h Another application has been submitted for a Dece=ber, 1983 NRC

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examination. He has successfully passed a two and cre-half week simulator refresher course since the first applicatie. was submitted.

This individual is now considered to have adequate decumented training in this subject area.

f., Several applications listed self study retraining or reviews. This self study retraining was performed after the individ:als had failed the NRC examination. These individuals had already successfully completed all required training to take the NRC end.ation. This study was to meet the individual's particular needs. No records are maintained for this type of study. This is' considered satisf actory and is only documented in this enclosure because it was entered on the applications.

g.

One applicant listed several courses on his applicatie: that he was given credit for teaching rather than taking, but the distinction was f

not made on the application. His training records vC.1 be updated to

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clarify his function in these courses. Credit for teaching is considered acceptable.

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Enclosure to AECM-83/0681 Page 5 e

h.

One application listed a one week Mitigation of Core Damage Course (Brunswick, CP&L), but the training records indicate thirty two hours of actual training. Neither the materici covered nor the examination was reviewed since this course was taught at CP&L. However, the applicant successfully passed an examination covering the caterial of subject at Grand Gulf. This examination provided added assurance that the individual has adequate knowledge in the subject area.

f.

One application listed a five day Mitigation of Core Damage Course.

This was on a September, 1981 application. The individual did not pass the examination for the course. Prior to the applicant's 1982 license application submittal, he satisfactorily completed the one week course.

Note that both courses were listed on the 1982 application. Only the second course should have been listed.

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j. Some courses listed on one application were not actually attended but were credited to the applicant by successful ce=pletien of examination in each course. The application should have neced that credit for the subject courses was given by examination. This is considered an editorial error. A second application on the same individual correctly indicated credit had been granted.by examination.

In two cases, successful completion of equivalent training could not be substantiated.

In each case, we believe the individual to be fully trained and qualified; however, since training cannot be substantiated, we have taken specific actions requiring successful completion of training.

Each discrepancy, and any action necessary to resolve the matter, is discussed as follows.

k.

One applicant listed a five day"ditigation of Core Damage Course. His training records indicate he attended a total of four days but did not take the c_tamination. This applicant will be required to review the material and pass an examination covering the course material by Fovember 30, 1983.

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Enclosure to AECM-83/0681 Page 6 0

g 1.

One applicant listed a seven day Plant Operations Course covering

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Technical Specifications and a five day Plant Operations Course covering Technical Specifications on his original application in September, 1981. He did not pass the examination on the seven day course, and there is no record of attendance for the five day course.

He did not pass his NRC examination. The individual submitted another application in October 1982, which eliminated both the seven day and the five day courses. There is no record of this individual's training in the Technical Specifications; therefore, he will be required to review this material and satisfactorily pass an examination in the first quarter.of 1984 The individual has, however, passed both MP&L and NRC examinations on this subject.

3.

For the majority of licensed personnel, Oualification Cards were not completed, or cannot be located, as stated in the FSAR and as indierted on the license applications.

In addition. Qualification Cards that were completed did not include a Practical Factors Section as required by the h

FSAR.

3U The participation in the plant's preoperational test program was considered adequate, practical experience for the cold license candidates.

However, to document this practical knowledge, these operators will complete the Practical Factors section of the Qualification Card.

The Practical Factors section of the Qualification Card has now been established for each licensed operator.

In many cases, operators performed, or directed another licensed operator to perform, plant surveillances. Where this was the case, Qualification Cards were signed indicating satisfactory completion of the particular practical factor.

Where performance of a practical factor cannot be established as described above, successful completion of the practical factor by observed perform-ance in the plant, by use of the simulator, or by walk-through of subject procedures will be required.

Each licensed operator will complete the Practical Factors Section prior to November 14, 1983.

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Enclosure to AECM-83/0681 Page 7

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Knowledge factors are considered satisfied based on an individual's documented training, extensive examination results, plant walk-through activities, and simulator training, Fcr these reasons, demonstration and documentation of knowledge factors are redundant to other documented training. However, if our review of Qualification Cards identifies a need for demonstration of knowledge factors, they will be de=cestrated and documented.

Based on our evaluation of identified discrepancies and on the corrective actions stated, we firmly believe that our training program is adequate and that our operators are well-qualified.

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i MEMO TO:

Mr. J. B. Richard, Senior Vice President, Nuclear FROM:

T. E. Reaves, Jr., Quality Assurance Manager

SUBJECT:

Su= mary Report of QA Management Interviews of Operators Concerning License Applications FILE:

0765/0290/0490/16694.4 PMI-83/13776

REFERENCE:

PMI-83/12634 CAR 2051 - dequired Reading Program CAR 80'3 - Credit By Examination CAR 805 - Applicatio Changes Interviews with all presently Licensed Reactor Operators and Senior Reactor Operators have been completed. Additionally, several License Candidates, former employees, present and former contractors were interviewed personally or by telephotte. Subject interviews were accomplished between October 22, 1983 and November 14, 1983 for License Operators and extended until December 5 to include other individuals.

Interviews were conducted by S. M. Feith and/or T. E. Reaves.

The September 3, 1981, Operator Licenses applications were reviewed with each individual who is presently Licensed on CGNS. Each licensed individual had received a record of previously identified discrepancies which was reviewed during the interview. Discussions centered on the

[nj following issues:

1.

Did the individual receive additional training which was not recorded in his application?

2.

Was there training listed on the application which was not received?

3.

Did the individual believe that his training record or application had been altered?

4 Was the training received adequate to prepare the individual for the RO/SRO position?

5.

If they had not completed a Qualification Card how was that entry made on their record?

Note:

Several ancillary questions were used to expand on these issues.

None of the present Licensed Operators believed there had been any intentional wrong doing or that falsification of records had occurred.

Most credited errors to staffing levels, lack of experience in the training department, failure to maintain adequate records, and multiple personnel changes in the Training and Operations Department. Several felt that there were no errors, only the loss of records to substantiate training received.

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PMI-83/13776 Page 2 of 6 During a telephone interview a former consu'. tan: to the training section indicated that an intensive effort was made to ensure all September, 1981, applications listed correct training. He described the preparation of a matrix of required training versus training received by each applicant.

Where blanks existed in the matrix, courses were scheduled or arrangements made to have the applicant challenge the course by taking the examination.

A review of the 1981 applications confirms a number of course entries are annotated with "9/81" or "CBE 9/81" indicating the course would be taken in September, 1981 or credit by examination (CBE) by challenging the examitation in September, 1981. He subsequently mailed copies of a memor $ndu= dated Augus t 10, 1981, G. A. Johnson to All NRC License Candidates and four shift schedule sheets for the four week period August 29, 1984 through September 18, 1981. The August 10, 1981 memorandum contains a list of course schedules during August and September 1981, for applicants in three courses. Handwritten notes on the bottom of the shift schedules indicate a rescheduling of some of the same applicants for the same thrse courses during a later time period ending in late September, 1981. These two documents along with two other memorandums dated June 12, 1981 and June 23, 1981 are included in Attachment 1.

These document areas AttCh (l) of training necessary to meet license commitments and substantiate the review effort to ensure accuracy prior to submittal of applications. It r-~s should be recognized that the Attachments to this document contain the two f

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documents f rom a former contractor and others not available from the

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project files. All attachments which do not contain a PMI or IPC Number were obtained from an individual's personal hard copy file, from training record packages or sources other than the official project file system.

Most of the RO & SRO personnel felt-they had received more training than was listed on their record. Many recalled the instructor's name or events related during the course with such consistency as to convince us that in some cases an entire course record was misplaced and the course was actual-ly conducted, rather than an application error.

All RO & SRO personnel felt they were adequately prepared to perform their licensed duties. Many felt that their present state of readiness was due to self study rather than formal training. With one exception, all others felt the present management commitment to utilize Quadrex Instructors until qualified HP&L SR0s could staff training was a sound approach. The one negative individual only criticized that the present commitment had not been made earlier and had no additional positive actions to of fer at this time. While there were criticisms of past performance of the Training Department, there were no suggestions of improvements which are not in progress.

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PM1-83/13776 l

Page 3 of 6 During the interviews there were a few additional cases of inaccuracies in original applications that in general fell into the same categories as those previously identified. The additional items are listed in to this memorandum. Corrective Action Request Nos. 803 & 805 were generated as a result of both interviews with Licensed Operators and, Attch (2) as a result of allegations from former employees. The only other non-conformance identified during the interviews was regarding deficiencies in the Required Reading Program, CAR No. 2051. (Attachment 3-CARS 803, 805 and 2051).

Attch (3) 1 Additional insight with regard to the Qualification Card entry was gained, however, objective evidence was not obtained as to why all the 1981 applications except one contained this entry. The following is of fered to help understand and perhaps mitigate the seriousness of this error.

From interviews and reviews of records, it is clear that the Training Procedure 01-5-04-1 contained the Qualification Card requirement prior to the FSAR. The procedure in effe:t at the time of the first license applic-ations (Sept. 1981) required Qualification Cards for all 1,icensed Operators as did the FSAR; however, the procedure liste d practical factors as "Later".

The first submittal requesting operator license examinations was September 3, 1981 (AECM-81/002). to subject letter listed 30 candidates for Senior Reactor Operator and 4 for Reactor Operator. At some time prior to the NRC examination some of the SRO candidates must have been downgraded to RO candidates, that is, some of the listed SRO candidates were administered only the RO examination.

Both present and former employees acknowledge that the understanding and philosophy in effect during 1981 was that Shif t Supervisors and Superintendents would not complete Qualification Cards. It should be noted that all SR0s are either Shift Supervisora or Superintendents. One present SRO related a conversation with the Operations Superintendent where he returned his Qualification Card because there was no one more knowledgeable of the plant than himself to sign for listed items. The procedure in ef fect; however, allowed both the Training and Operations Superintendents to perform check outs and sign line items.

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PMI-83/13776

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Page 4 of 6 Memorandums in 1980 and prior to September, 1981, establish lists of individuals authorized to sign Qualification Cards.

Attch (4)

-Memorandum, IPC-81/497, 4/2/81, G. A. Johnson, Operating Superintendent to J. E. Custer, Training Superintendent, request current Shift Supervisors be added to the list of personnel authorized to sign Qualification Cards. The handwritten copy from which IPC-81/497 was typed is of special importance in that it specifically directs omission of one of the then current Shift Supervisors from the approved list to sign Qualification Cards. This handwritten note implies there must existed a method to determine progression of certification / qualification on systems even for Shift Supervisers.

-Memorandum IPC-81/618, 5/27/81, Custer to Johnson contains a list of personnel authorized to sign Qualification Cards, as does IPC-81/746, 7/8/81. These authorized lists contain a restriction for some individuals, including some Shift Supervisors, which allowed them "to sign only those items on which thav O

have received a valid signature".

Memorandum IPC-81/497 indicates an attempt to " grandfather" Shift Superintendents, Memorandum IPC-81/618 6 81/746 indicate for those individuals which were not "grandf athered" there was a mechanism in place to determine those items for which they had received a valid signature.

IPC-81/497, 81/618 6 81/746 are included as Attachment 4 to this memo along with a collection of other documents dated prior to September, 1981. Collectively, these documents in-dicate a major effort to ensure progressive certification /

qualification of operators as the plant systems were turned over to MP&1. Operations.

Other memorandues, Attachment 5, indicate a concerted Attch (5) effort to complete Qualification Cards for all candidates other than SR0s. Memorandum to Operations Personnel from G. A. Johnson, 3/31/81, Attachment 6 was utilized as strong management action to force completion of Qualification Attch (6)

Cards, however, it did not apply to SR0s.

It appears that the original Shift Supervisors (SRos) were probably considered "grandf athered" and exception not taken to the FSAR or the procedure. Memorandum IPC-81/497 indicated that a progressive method of certifiestion of Shift Supervisors must have been in place even though Qualification Cards as such were not used. At the time of' initial application submittal,

PMI-83/13776 V

Page 5 of 6 September,1981, all Shif t Supervisors were probably considered qualified by virtue of their ability to sign Qualification Card entries. Berefore, the entry of Qualification Cards on their applications did not raise a question in any review of the documents.

It appears that for RO candidates, efforts were made to complete Qualification Cards, although systems were not physically complete at the time of application submittal.

There were restrictions on obtaining complete signof f s for all systems due to lack of approved / issued procedures and turnover of the physical plant to MP&L, reference IPC-82/204 Attachment 5.

At the time of initial application submittal Qualification Cards were probably thought to be as complete as allowed by the plant status.

The NRC License was thought by many to constitute the ultimate qualification. This contributed to inadequate remedial actions once the issue was discovered. It should be noted that after the October 12, 1983, meeting with Mr.

Jim O'Reilly this philosophy no longer exists.

De only Qualification Card entry on the original applications, Sept. 1981, which appears to be completely

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without merit is that of a former employee, Andrea Hotham.

b The only application without error was that of a present SRO, Ceorge Lee.

Mr. Lee was in the Training Department at that time and was the only individual identified as having a high probability of personally reviewing his application against his training record.

With regard to original applications, no evidence of willful wrong doing or fraud is evident. It appears to be a matter of inattention to detail and a function of extreme time pressure. Applications were not treated as QA records after signature and there is evidence of additions, deletions or modifications of applications. This nonconformance was documented in CAR 805, and included in Attachment 3.

Interviews with former employees / contractors identified little new information. One former employee, however, levied serious allegations that a memoranda was signed by the Plant Manager in-October or November, 1982, indicating training was complete when in fact it was not " backed up" by training records. While there are inaccuracies in the application letter AECM-82/467, they were not of the magnitude to constitute fraud.

If the differences or inaccuracies had been pointed out prior to sub-sittal, corrections could have been easily made. QA investigations taken to resolve allegations are included in Attachment 7.

Again there is n Attch (7) evidence to confirm a-.

willful wrong doing. The same former employee also alleged that "Creatt by Examination" had been abused in the case of one applicant. This allegation was confirmed and is documented in CAR 803, of this meno.

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1 PMI-83/13776 t

Page 6 of 6 l

f During the interview process only one other major area of concern was l

identified. A significant number of operators felt deficient in their i

ability to read electrical blue prints, and requested additional training l

in this area.

Each shift also acknowledged that there was always some one on their shift with this skill as well as 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage by knowledge-j able maintenance personnel. Therefore. this is not an immediate concern

. but one that should be rectified in the near future. Plant Management has l

been verbally informed.

4 Other areas identified in the areas of personal job satisfaction, monetary i

. rewards, working conditions, etc., have been discussed with you as the

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interviews progressed Memorandum PMI-83/12634, which documented early concerns identified during i

these interviews, is included as Attachment 8.

Concerns relative to the i

Qualification Cards are being corrected in the current recertification Attch (8) effort. The issue of Required Reading has been documented and corrected i

by CAR 2051. No further action as a result of PMI-83/12634 is required.

i In conclusion, while several significant nonconformances were identified during this process, I did not detect any evidence of fraudulent activities nor was I able to determine motivation which would have led to willful wrong doing.

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4 T. E. R.

2/13/84 i

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i Attachments 1 through 8 cc Mr. J. P. McCaughy, Jr.

l Mr. !.. F. Dale l

Mr. J. E. Cross i

Mr. J. F. Pinto l

Mr. T. H. Cloninger Mr. J. W. Yelverton Mr. R. C. Fron Mr. S. M. Feith Mr. C. C. Hayes l

Manual File File (Plant)

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.i P.DD TO: Gil Johnsen, Operations 4

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Bob Greene, License Training instrue:c; St.' MECH: Training Deficiencies Noted f or 1.i:ense Candidates j

The felleving deficiencies have been no:ed by :he Training Departnen: for :ha:

l training required :c nee: our license ec=1:::ent.

i A.

Supervisory Training -

1 All SRO candidates still require Supervisory Training -

jl Training is scheduled :c take place the weeks of 21 and 28 Septe her.

1 B.

P.itigatica cf Core Da= age -

All license candida:es require this training -

Training is scheduled to :ake place beginning 31,

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Augus: vith 3 ene week classes of 20 students each.

4 C.

10 Critical Pulls -

The folleving personnel need critical pull training:

l 1.

Jay Dotter R. Perryman 3.

B. Shaddix 4

R. Ambrosino This training is presently scheduled fer the weeks of 20, July and 27, July at Menphis State University.

There is allowed a maximum of 3 persons per week for the course due to the ti=e consumed for the individual I

critical pulls.

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Observation Training

- Performed at Vermont Yankee I

- Schedule Open 1.

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Grand Gulf Techn: logy -

- Taught By Grand Cu'! Training

- Nex: 8 week course scheduled to begin 6, July 1.

E. Harris 2.

D. Powell 3.

B. Shaddix 4.

P. Whaley 5.

!!. Ellis F.

Si=ulater Cer:ifica:1en -

Perfer:ed a: C.E. SWR Training Center, Tulsa, Cklah::a.

Ti e Required - 9 weeks Nex: Class - March 1952 1.

Seb Shaddix The C:and 0;1f Training Depart =en: vill =ake every possible eff::: :: ensure that cur training ce=:it::en: for licensing is cet.

'a'e vill d: wha:ever is ne:essary ::

avoid any undue ccnflicts er hardships in meeting th:se cc :1:::ents.

H:vever, as :he :1:e re=aining bef::e cur li:ense date bece:es sh:::, s::e hardsh ;s and g'~'s c:nflicts may be 1:pessible to av id.

k Respe : fully, s-f' L },) LP A"s " -

W Bob Creene 6-12-61 R*a*C/JPH/JEC/ CJ : ash cc:

R. A. Amb rosino C. L. Stuar:

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MEMO TO: John E. Caster TROM:

Andrea D. Hotha=

SUBJECT:

Perscnal Schedule for Licensing in keeping with our conversatien en Monday, 6-22-Si, =y personal schedule for licensing vill be as fellevs; July 6 - August 14 Crand Gulf Tech:01:gy August 17-28 Refueling Training and/or Tech Specs & Pr edures (self-study)

Aur.it 31-Sept. 11 Si=ulater Refresher Septe=ber 14-18 Mitigatics of Cere Oa: age Septa =ber 21-25 Heat Transfer and Pluids Sept. 26 - Oct. 2 Superviscry Training October 5-9 License Preparatien October 12-23 Self Study - Procedures, Tech Spe:s, Physics, etc.

October 26-30 NRC **ritten Ext =s I will be a student in the above-menti:ned classes.

It is =y intent to devote a =ax1=u= cf 1 or 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day to si=ulator follow-up and/or si=ulater training course develop =ent.

Major si=ulator ite=a requiring =y attentien vill be handled en a case-by-case basis with your clcse cooperation.

Immediate action should be taken to confir: with the NRC =y eligibility to take the exa=s required for SRO licensing.

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.T & b [M,s9,__.

Andrea Hetha:

Si=ulater Superviser 6-23-81 ADH: ash cc:

G. A. Johnson R. A. Ambrosino Tile

I E.

MEMO To:

All NRC I.icense Candidates FROM G. A. Johnson SINEO:':

Examinations and Refresher Training NMC written examinations are scheduled for October 28 and 29.

I am confident that all candidates will be successful; many months of training has been successfully completed by all of you.

Three weeks of training are scheduled for each candidate at the training center for the following courses:

Reactor Physics Review (2 days) l Core Thermal Hydraulics (2 days) l Radiological Controls (2 days)

Heat Transfer and Fluid Flow (3 days): Memphis State Mitigation of Core camage (5 days): General Physics The attached schedule details when each of you are required te be at the training center for these courses.

Qualification Evaluation Services, Inc. (QE3) will adnLinister written evaluation exams on September 10-13, and walk-through evaluations on September 14-25.

At the present time, all NCA's have been scheduled to take both RO and SRO written exams, but if anyone feels that they do not desire to take the SRO exam, please let me know by August 17.

A schedule for these exams will be available in a few days.

The Training Department is preparing a schedule to provide training personnel on shift to review with license candidates plant systems, plant operating procedures, centrol panels, etc. Time will be made available for each operator to spend time with the training, personnel on shift reviewing for the NRC examinations.

We have also scheduled 2 days of simulator refresher starting November 30, for each operator which is just prior to the NRC Simulator Performance Exams.

If anyone has any particular areas they would like help in reviewing, please contact me or the training department.

We realize that the schedule is very heavy, and will require some overtime, but that is the only way that this extra training could be

8 letc License candidates Page 2

~~

provided. Everyone's cooperation in meeting the licensing objective is greatly appreciated.

7

'G G. A.

hnson operations Superintendent 8/10/81 GAT:vj Attachment cc C. L. Stuart J. E. Custer File l

4

i ATTACHMDr I

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Core Thermal Hydraulic Rad / Con Mitigation of Core Rx Physics Review HT & FF Damage

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ATTACHMENT 2

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i MEMO TO:

Mr. J. E. Cross, GCNS Plant Manager FROM:

Mr. T. E. Reaves, Jr., Manager of Quality Assurance

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S L*3 JECT :

License Operator Application Problems l

j

REFERENCE:

PMI 83/13,776 1

4' t

FILE:

0765/0290/0490/16694.4 I

i t

PMI 83/13,835 i

l As a result of QA Management Interviews of Operators concerning i

License Applications, several application inaccuracies were noted.

i Those inaccuracies are shown in Attachment 1, and are presented 4

for your information.

4

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es C'4H:TER:nr a

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Mr. J. B. Richard Mr. J. P. McCaughy, Jr.

Mr. J. E. Cross Mr. T. H. Cloninger l-Mr. L. F. Dale Mr. J. F. Pinto Mr. S. M. Feith Mr. C. C. Hayes File (Plant)

Manual File File (Project) (4) i I

f 1

1 7

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APPLICATION PROBLEMS 1.

01arles A. Bottemiller -(l) May 1982 (First) - Application stat'es "2 day Fire Brigade Training (CCNS)."

Mr. Bot temiller does not remember any Fire Brigade Training at GGNS prior to first ap pl i c a t io n.

NOTE: Per Memo, Hunt to Bot temiller Training Record, Mr. Bottemiller was given credit by examination (CEB) for the 2 day Fire Brigade Training (CCNS) in his training records for passing the License Operator Exam Preparation Course examination (LOEP). The LOEP examination t aken on 6/17/82 did not contain any Fire Brigade Training questions and is considered in ap pr opri at e for this use.

Ref CAR 803.

-(2) October 1982 (Second) - Application states "2 day Fire Brigade Training (CP&L)."

It is thought that "(CP5L)"

was a transfer error from first application.

-(3) October 1982 (Second) - Application states "I week Heat Transfer & Fluid Flow (CBE)."

Mr. Bottemillers

" Individual Training History" folder does not indiccte an entry for this course or credit by Examinatino (CBE) for thi s course. Review of check list for MAR-83/133 f}

indicates auditor accepted LOEP exam dated 6/25/82 to

(

include this course material. Ref CAR 803.

-(4) May 1982 (First) and October 1982 (Second) - Application states:

"5 day R0 Re-training (CP&L)."

Mr. Bot t emil le r is not sure what this refers to.

2.

John Forrest Manby September 1981 - Applicat ion contained an attachment

" License Car.didat e Training / Experience Summary. Item E.3. of. Summary list 4 weeks of Observation Training at Dresden dien observation training was actually conducted at Millstone.

September 1981 - Application st ated US Navy Elect ronics 3.

Wayne A. Russell Technician "A" and "B" School 1960.

Mr. Russell felt that this Navy School was probably in 1965 or 1966.

Sept ember 1981 - Appli' cation list s "5 day Plant 4

William M. Shelly Operat ions Course (Admin. Reg's)."

" Problems on Application" sheet probably in error on it em 2 which states "5 day POC on Tech. S pe c s. "

May 1982 (second) - Applicat ion states " Ret raining - 10 5.

James L. White week s supe rvi sed sel f s t udy on Rea ctor Theo ry....."

" Problems on Applicat ion" sheets states under App d2 Item 3, "No document ation in recerde for 10 week retraining." Mr. Wh i t e s t at es he wa s un ab le t o a t t end 10 week session but was all owed 4 weeks of sel f-st udy.

[~]

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V Page 1 of 2

i i

6.

Ga ry D. th amo n September 1981 - Application stated under Item 8 Experienc e "Quali fied Engine Room '='at ch Su pe rvi sor."

Mr. Lhamon stated the correct entry, should h ave been

" Engineering Wat ch Su pervisor."

I

'l i

I Page 2 of 2

2

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MEMO TO:

Mr. J. E. Cros s, Nuc lear Plant Manager FROM:

T. E. Re aves, Jr., Man age r of Quality Ass uranc e

SUBJECT:

Corrective Action Reque st s (CARS) 803 6 805 Res ponse Required for CAR 805 by January 19, 1984 FItZ:

0147/0290/16694.4 PMI-83/13748 Attached you will find Corrective Action Request (CAR) 803 regarding there not being adequate directions commensurate with the nature of the Credit By Examination act ivity to assure that activities have been satisfactorily accomplished and CAR 805 regarding inadequate controls to assure that NRC Form 398 is treated as a Quality Assurance record af ter signature by the applicant.

The proposed correct ive action for CAR 805 is to be determined by Plant Staff.

In the event that corrective action cannot be completed by January 19, 1984, pl e a se submit an interim report indicating the current st atus of the nonconformance d oce ne n t and an estimated date of completion of correct ive action.

The proposed correct ive actions for CAR 803 was discussed on Monday, Dec e=be r 19, 1983, bacween your Mr. J. Yelverton and our Mr. W. Edge. All proposed corrective were agreed to by your organization.

actiongg

's QA wi f5 verify the completed corrective act ion on CAR 803 at the end of the scheculed time period. No further fo rmal corres pondence regarding CAR 803 i s required from you unless an extension is needed or investigat ion reveals more extensi,ve or different correct ive action, i

If you have any que stions in regards to these CARS, please c on t ac t me on extension 2476 or Mr. W.

Edge on extension 2463.

We sincerely appreciate the cooperation received in this matter.

T. E. R.

41 ;., oa_

/2 21

  • M LCB:dr At t achme nt s :

(A) CARS 803 & 805 (B) CAR St atus Fo rms (w/o t o Addressee) cc:

Mr. J. B. Richard, w/A Mr. W. E. Edge, w/A Mr. J. P. McCaughy, Jr., w/A Mr. J. E. Re aves, w/A Mr. L. F. Dale, w/A CAR Files, w/A & B Mr. T. H. Cloninger, w/A Manual File, w/A & B Mr. J. F. Pinto, w/A File (Plant ), w/A & 5 Mr. S. M. Feith, w/A File (Project), w/A & B.

)

Mr. C. C. Hayes, w/A

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CORRECTIVE ACTION REQUEST (CAR)

(1) Issued To J. E. Cross (2) Number 803 Date Due Januarv 19, 198.

Nuclear Plant Manager Unit No.

]

Person Contact ed D.

L. Hunt, Audit No.

N/A J. W. Yelverton NONC0KFORHAN((: (3)

Discussion:

Review of Charles A. Bott emiller's " Individual Training Hi s tory" record indicates the foll owing :

Crse/ Reading Training Program / Required Course Crade/ Hrs.

Compt. Date Reading Title 82 12 06 CCT (Grand Cul f Technology)

CBE 82 12 06 Administrat ive Requirement s CBE Course 82 12 06 POC (Plant Operat ions Course)

CBE 82 12 06 MCD (Mitigation of Core Damage)

CBE 82 12 06 FBT (Fire Brigade Training)

CBE f-~x The entries listed above were transc ribed from a 12/6/82 memo, Hunt to

[

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Bot t emil le r.

It appears that Credit by Examination (CBE) for these

\\s_l five courses was granted for successfully challenging the License Operator Exam Preparat ion Course (LDEP) examination on 6/17/82.

A review of the 6/17/82 LOEP examination has indicat ed there were no questions relating to Fire Brigade Training and it appears quest ionable as to the coverage of the other 4 courses for which CBE was granted.

Further review of Bottemillers second application (10/8/82) indicates a I week Heat Transfer & Fluid Flow (CBE) wh'ich could not be identified on his " Individual Training History" record.

Finding:

There are not adequate direct ions commensurate with the nature of the Credit By Examinar. ion act ivit y to assure act ivities h ave been s a t is f act o ril y ac compl i shed. The only direct ions appear in Plant Administrat ive Procedure 14-5-01-4, Section 6.1.9, and they are inadequate to control act ivity.

Commitment:

1.

The Operational Quality Assurance Manual, Revision 3, Section 5.5 states in part:

"5.5.2 Directions commensurate with the nature of the activity shall be prescribed in inst ruct ions, procedures and/or d rawi ng s for the performance of act ivities af fect ing que'ity.

The act ivities shall then be performed in accordance wi th t he inst ruct ions, procedures and /or d r awi ng s.

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CAR 803 Page 2 5.5.3 Instructions, procedures or drawings shall include quantitative and/or qualitative acceptance criteria f:r verifying that the activities have been satisfactorily accomplished."

2.

' Plant Administrative Procedure 14-5-01-4, Revision 7 states in part:

"6.1.9 Written exa:ninations may be used to place a student in a particular training program or course at an inte rmediate position or to document satisfactory knowledge leve; in the subject area (s) without requirement for attendance in the training course. Based on the examination results, the Training Superintendent may assign credit for specific portions of a training course progra: if the program description specifies that successfai completion may be satis fied by mear.s of examination."

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'AUSE OF NONCONFORP.ANCE: (3a) s Lack of adequate procedural definition and controls for granting Credit By Examination.

PROPOSED CORRECTIVE ACTION (S)/ SCHEDULE: (4a)v Both remedial and preventive corrective actions are required. Th e following should be considered in the development of proposed corrective actions.

Actions to prevent recurrence:

1.

Es t ablish adequate procedural definition and control to assure Credit by Examination (CBE) is properly administered. Consideration should be given to the following in the establishment of controls, a.

Should Credit by Examination (C3E) be allowed for only Technic al Courses or is it also appropriate for CCNS specific activities such as Fire Brigade or Administrative Courses?

b.

Should the (CBE) examination be limited to one of the standard examinations normally administered upon completion of the course?

c.

Should instructed study be allowed prior to challenging a course by

,/'~'T (CBE)?

b

2 k

CAR 803 Page 3 d.

If the first attempt at challenging a course by (CBE) is unsue:essfal should the individual be required to take the normal course. If :ourse attendance is not required then the second (CBE) examination must be substantially different from the first examination.

i Remedial Corrective Actions:

For a!! Licensed Operators determine where Credit by Examination (CBE) was 1.

used to meet FSAR Training Commitments.

2.

Review the actual (CBE) examination utilized to determine if the approach is defendable.

3.

Establish reexaminations or course attendance as necessary.

06J V

/2 - /1-Y1 PLANT MANAGER, SIJP? ORT DATE ys:s:Ay.

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~ PROGRAMS Q( MANAGER DATE smf

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'INfTIATOR DATE"~

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CORRECTIV! ACTION REQUEST (CAR)

(1) I s s ued To J.

E.

Cross (2) Number 805 Date Due January 19, 196 Nuclear Plant Man age r Unit No.

I Person Cont act ed J.

W.

Yelverton Audit No.

N/A NO NCO NFORMANCE : (3)

Discussion:

Int erviews wi th CCNS Lic ensed pe rsonnel, and previous ernpl oye e s, and review of Reactor Operator / Senior Reactor Operator applications indic ate t hat appl ic at ions' h ave not been treated as Quality Assaranse Records after signature of the applicant. There are indications that in some instances the second page of the initial September 3,1981, application is in a dif ferent fo rma t, or contains additions or deletions that we re made a f ter the applicant's signature was affixed.

There are indications that one 1983 NRC Form 398, "Pe rsonal Quali fic at ion St atement - Licensee", was signed as a blank for: to be completed at a later t ime.

Fi nd i ng :

Appl ic at ions for Reactor Operator and Senior Reacter Operator have not been controlled as Quality Assurance Records af t er s ignat ure of the ap plican t.

(

Com=itments:

1.

ANSI N45.2.9 - 1974, Section 3.2.6 states:

"4)

Supplemental Information to Quality Assurance Records.

Quality assurance records may be correct ed or supplement ed in accordance with procedures which provide for appropriat e review or approval by the originating organizat ion. The correction or supplement shall include the date and the identification of the person authorized to issue such corrections or supplement s."

2.

NRC Form 398 Section 17a states, in part, above the appl ic ant s aignature:

"I certify that the informat ion provided on this form is true and correct to the best of my knowledge."

CAUSE OF NONCONFORMANCE: (3a)

There are inadequate controls to assure that NRC Fonn 398 " Personal Quali fic at ions St at emen t - Licensee" are t reated as Quality Assurance Records af ter signat ure of the applic ant.

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j PROPOSED CORRECTIVE ACTION ( S ) / SCHEDULE : ( t.a j e i

To be detennined by Plant St af f i

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MEMO To:

Mr. J. E. Cross, Nuclear Plan Mana;er FROM:

S. M. Feith, Nuclear Si:e QA Manager SU3 JECT: Cerrective Action Request (CAR) 2051 regarding i=ple=en:ation of :he Required Reading Pr:gra:: and ad=inistra:ive closure of the CAR 2251 FILE:

0147/0290/16694.4 PMI -

83/12,118 A : ached is CAR 2051 regarding improper i=ple=entation of the Required Reading Progra..

This CAR is being faitiated subsequen: :o the special training asses =en:

des:ribed in AECM-83/0681. A corrective action conf erence was cenducted, causes identified and i=x=ediate actions taken to prevent recurrence. These acti:ns are considered adequate to justify the administra:1ve closure of this CAR.

This area vill be re-e.xa=ined during future audits of this area. No additional respense is necessary.

If you have any questions on this CAR please contact Steve Fei:h at 3285.

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S.M.Feikh 12/6/83 SFM:=s A::ach=ent: CAR 2051 Corrective Action Status For= (only to files) cc:

Mr. J. 3. Richard Mr. J. P. McGaughy, Jr.

Mr. T. E. Reaves, Jr.

Mr. T. H. Cloninger Mr. L. F. Dale Mr. J. F. Pinto Mr. C. K. McCoy v

Mr. C. C. Hayes Mr. L. F. Daughtery Mr. P. R. Hughes Site QA File Manual File. -

CAR File i

LCTS

.,Is i,-

Plant File (CCNS)

Project File (k)

M

E CORRICTIVE ACTION RIOUEST CAR No.

2051 Due Date:

12/6/83 Audit No.

None Initiators:T. E. Reaves, Jr.

S. P.. Feith FINDING:

Imple=entation of the Required Reading Progra: has no: provided assurance tha:

(RCLicensedOperators/LicenseCandida:esreceiveandreadassigned=aterials.

COMMITMINTS:

1.

FSAR 18.1.12, Procedure for Feedback of Operating Experience to Plan:

Staff states, in part, that:

"GONS Administrative Procedure 01-S-04-15, Required Reading Progra=,

further details the persons responsible and the mechanis= used to disse =inate operating experience information to operations personnel."

2.

GONS Ad=inistrative Procedure 01-5-04-15, Required Reading Progra= sta:es tha: the Section Supervisors /Superintenden:s are responsible for:

" Ensuring that his personnel acco=plish the required reading and d ocu =e n t the cempletion as expeditiously as possible" (paragraph 2.7.3) s

" Ensuring that Attach =en: II, or similar form, is properly completed

('

and returned to the Training Superintenden: so that training record entries may be completed" (paragraph 2.7.4)

" Ensuring that required reading necessary for certification of a particular individual wi:htn the sec tion is documen ted..... "

(paragraph 2.7.5)

DISCUSSION:

Interviews were held with all N'RC Licenced Operators and several license applicants in support of a special training assessment as described in AECM-83/0681. An in-depth review of training records was performed as par: of this effort. The Required Reading Progra= vas exa=ined and discussed and several examples of noncompliance were iden:ified. Specific examples are as follows:

1.

The required initialling on the " Required Reading /Se=inar Report" had been completed by someone other than the listed individual in so=e cases. The listed individuals printed name and forged initials were placed on the forms in the operator's absence.

The forms were sub-sequently reviewed and submitted as a record of training received.

2.

Operators have signed-of f on the above referenced form without reading e

the material in some cases. The operators apparently felt pressured to return the required reading material to the Training Section in order

/'~'}

to meet a deadline. The time available to complete the reading on-( _ /

shift was simply inadequate.

3.

Operators have been asked to sign for required reading without reading the material because it was presented as "not applicable". The material may indeed be not applicable, but should be noted as such, not falsely

..u.~.,1.a..a

. _ _ _ ~ -

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l CORRICTIVE ACTION RIO'JIST i

1 CAR 2051 Page 2 of 2 l

SUMMARY

OF CORRICTIVE ACTION CONTERENCE:

A corrective action conf erence was held between J. W. Yelverton, Asst. Plan:

Manager-Support and S. M. Feith, Nuclear Site QA Manager in ordef to outline the scope of the CAR and to deter =ine appropriate corrective action.

l Regarding the forging of initials, an atta=p: was =ade to identify the individual ( s) responsible. All personnel interviewed were aware of the require:ents and stated tha: they had never acted in this =anner.

This action is documen:ed l

5 on IPC-83/10,299, dated 12/2/83 fro: J. W. Yelverton to J. E. Cross.

Subsequen:

to this action, IPC-83/10,386, da:ed 12/5/83 regarding accuracy of : raining records, and directly addressing forgery, was issued f re= J. E. Cross to all depar:=ent heads. These actions are considered adequate.

Operators have been reinstructed regarding the requirements to read the required material before signing. An Lnternal me=o f ro J. L. Robertson, Acting Cpera: ions Sup. da:ed 11/21/83 addresses this subj ect.

This action is considered adequatc.

These actions will be re-audited for verifica: ion of proper L=plemen:ation during the next scheduled audit of the Required Reading / Feedback progra=s. Actions taken are considered adequate to prevent recurrence and justify ad=inistrative closure of this CAA. No additional response is required f ro= Plant Staf f.

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MD'.0 TO:

Jerry Yelver:o:

fROM:

Ji= Cross 5*JMIC : Required Readi=g P cgra=

1 I?C:

83/ 10299 l

M?SI. Quality Assurance recastly held interviews with all licensed Opera:::s cc=:er:f=g various ::ai:1:g proble=s. 0:e particular 1:e= ide::1fied as a deficiency requires your atte::1c:.

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!= se:e cases, che required readi:g 1:1:ialing had evidestly been perfer=ed l

by se=ec:e c:her tha: :he i=dividual listed.

The opera:e: vas 1: ::aining a: the :1=e, and i: vas suspec:ed :ha: :he pers:: forging the 1:i:ials was in the Traisi=g See:1==.

n.is is an unacceptable 1:e= tha: requires your

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response :o answer this CAR.

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t Ji= u =ss 11/23/83 i

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J. E. Cross, Plan: Msnsger TROM:

J. W. Yelverten, Assis:snt Plan: !bnsger - SUPPORT 5"3 JECT:

Required Reading Program P.ETIRISOI:

IPC-33/10,299 i

IPC-8 3 /10,36S An attengt has ben. nade to identify :he persen who may have ferged the operator's initials on the Required Reading.. Sele::ed persennel were in:erviewed by Dcug F.un: in an attempt to selve this problem.

Each persen was aware tha: the practice was w :ng and assured Doug tha: they had never performed anything of this nature.

i We were not able to iden:ify the responsible persen, so I have written the at: ached mc=o fer you to address this concern.

If you have any questions, please advise.

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elverton Assis.sn: Plan Manager SUPPCRT 12/2/83 JY/vje a4 4. /

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Dis:ributien j

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J. E. Cress, Plan: Manager

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SU3 JECT:

Accursey of Trsining Records IPC-83/10.386 Quali:y Assurance has recently iden:ified a preble: vith the docunenta:icn of the Required Reading Program.

It appears tha:

the ini:ials en the existing documenta:icn uere ferged by se:e-ene other than the individual responsible te have perferred the required reading. Since this decuments:1:n is censidered a QA Reccrd, this is a sericus problem.

Under _rj; circunstances should any persen ferge :he initials er i

si;na:ure of the responsible persen en any reccrd. Ne exceptiens to this policy can be accep:ed, and failure to cceply vi:h this re:uiremen vill resul: in dise plinary ac:icns. Please ensure tha: this est:er is discussed with all pers:nnel vi:hin your-depar:=ents and that everyone unders: ands the i=pertance of this issue.

l Your coeperatien in this na::er vill,be appreciated.

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20210 To: All Operatic:s Perse::el TROM:

J. L. Rober:se:

SL*3 JECT: Required Readi g P:cgra=

As a resul: cf MP&L Quali:7 Assura::e 1 :erviews vi;h lice = sed pers el, ve have received a CAR en eur Required Reading progra=. This se=o is :s 1:sure we cer:ee: c=e deficie 7 ide::1.fied.

Material se:: to you as required readi=g sus; be read by the 1:div-duals lis:ed. The prese=: pr:gra= d:es :: all:v :eachi:g the caterial as adequate, al:h: ugh the p:cgra= =ay be revised :o include :his at a 14:e:

date.

I reali:e there is a large a==u:: ef =a:erial 1:velved is the required reading progra=, 4:d ::ai i:g vill be verki=g vi:h us :: =ake :he p :gra=

easier :: :== ::1 and :::e._eaci gful :o the participants; but us:11 :his is de=e, I rus: insist : hat everycne read all required reading =a:erial pri:: :o 1:1:ialing.

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J. L. Robertsc 11/21/83 i

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ATTACHMENT 4

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MEMO TCt J.

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Custer FROM:

G.

A.

00hnsen S L'E JE C T :

Autheri:ed Signatures fer Qual Cards IF C-51/ 4 9 7 1

All of the current Shift Supervisers have had extensive classrcem training en GGNS Systens and have bee.. parti-cipating daily, for the last three menths, en pre-epera-tional testing of GGMS Systems.

In addition, they have been d ing te chnica l revfEws of Syster C;erating Instructi ns, Alarm Re s.:en s e Instru:ti:ns, and Integrating Cperating Instru:tiens.

Tc the abcVe reasens, I am re e:rnen ding th at we add the fellowing names to these pers:nnel autheri:ed ic sign eff ::=ple ti:n of sys tem Operati..g Instruettens, and Alare Respense In s tru c t i:n s in the Licensed an d Ncn-Licensed Cperater Qual Cards, e f f e ctive teday.

R.

G.

Ke e ten i

L.

B.

Moulder J.

L.

Robertsen J.

B. Warner L.

R.

Miller

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C.

Bearden W.

A.

Russell C.

M.

Rice C.

V.

Hicks D.

R.

Anderson G.

O.

Lhamen The Attached certificatien f=rm will be used until all Systems / Buildings are completed.

G.

A. Johnson 4/2/81 GAJacsc A t t a ch m e n t cer C.

L.

Stuart Night Orders D.

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IPC-81/497 ATTACHw. INT :

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.n I have personally revieve d the in dividual's qualification card and certify that has ret (Cpera:crJ all qualtfication require er.ts specified in G.

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J eh.. s en 's me=c of 3/27/61 for the position of 4

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(Shif t Supt /Supv)

(Oste)

Based en the abcVe I hereby certify (Operater) as qualtfied for (Pes ::en) 1

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(Cperations Superintendent)

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J. E. Cus:er SL*32ECT: Designa: ion of Personnel Autheri:ed to Sign Centrel Ko: Opera:cr and Ncn Licensed Opera::: Qualift:ation Cards IPC:

81/615 This cer:randu super:edes PMI 80/2'17 dated 11/10/S0.

The felleving lis: of persennel are authori:ed to sign the Cc ::ci Re::

Operat:r and ::en Licensed Operator Qualification Cards effective the da:e of this cercrandus. Any signature which has been made by an individual no: authori:ed by the issue of this me:::andu whi:h was in effect at the

ire of :he signature vill be c:nsidered an invalid signa:ure.

Persennel designated by an asterisk (*) are authori:ed te sign enly :hese itens on which : hey have received a valid signa:ure.

k J. E. Custer Training and Ad=inistrative Supt.

1 5/27/81 Ka'F/JPH/JEC/d:

A::a:hments i

cc:

C. K. McCoy C. Lj Stuar:

R. A. Ambrosino J. P. Hanton File (Plant)

File (IPC) i F13e 1

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Secticas I, II, III, IV J. L. Robertsen J. P. Hanton L. B. Moulder W. A. Russel W. C. Bearden R. G. Kee en=

G. A. Jchnson G. Lha=:n*

G. H. Lee L. R. Miller G. C. Allen J. F. Manby

  • M. W.

Flynn W. M. Shelly C. V. Hicks

  • R. W. Greene O. R. Andersen*

L. R. Syrd J.

arner*

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1 Section I i

9 j

J. P. Hanten Section II J. L. Robertson J. Manby L. 3. Meulder C. Hic'a j

W. C. Searden G. A. Jchnsen G. C. Allen M. W. Flynn j

J. F. Hanten J. J. Be::y l

G. H. Lee W. A. Russell l

W. M. Shelly W. C. Sect:

t R. W. Greene R. G. Kee:en

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D. R. Andersen G. Lhanen

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. Warner J. Fracter i

R. Powers K. Benefield W. Cade

3. Lewis L. R. Byrd R. Jacebsen i

K. Gcrden K. McDenald I

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G. McMillin L. Miller i

E. K. Hall

  • C. Stafford i

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NON LICENSID OPERATOR CUALIFICATION 3!/J :ARD & WORKBOOK See:1:n B L. R:ber: son J. Manby L. B. Meulder C. Hicks

. C. Bearden G. A. Jchnson G. C. Allen C. Stafferd M. 'a'. Flynn J. Han:en J. J. Be:ty G. H. Lee W. Russell

'a'. M. Shelly W. Scot:

R. W.

Greene R. G. Kee:en*

D. R. Andersen*

G. Lhanen*

J. Warner

  • 4 J. Fra:1er*

R. Fevers

  • K. Benefield*

2 Cade*

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B. L:.:is*

L. R. Byrd*

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K. Gerden*

l K. M:Denald*

G. McM.1111n*

i L. Miller E. K. Hall

  • 4 1

Secti n C L. Rcher: son L. Miller L. B. Meulder J. Manby

'a'. C. Bearden C. Hicks G. A. Johnson G. C. Allen l

S: afford M. W. Flynn w.

J. Han:en J. J. Be::y G. H. Lee W. Sco::

W. M. Shelly R. G. Keeton*

i R. W. Greene G. Lhanen*

D. R. Anderson

  • W. Russell J. Warner
  • J. Fra:ie
  • R. Powers
  • K. Benefield*

l a.

Cade*

B. Lewis

  • L. R. Byrd*

R. Jac:bsen*

,K. Gcrden*

K. Mcdonald

'G. M. Millin

  • E. K. Hall
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BUILDING / AREA QUALIFICATION CARDS i

See:1on II L. Robertson L. Miller L. B. Moulder J. Manby I

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Section II W. C. Bearden C. Hicks i

G. A. Johnson G. C. Allen l

M. *a*. Flyr.a J. P. Han:cn J. J. Be::y G. H. Lee W.

Russell W. M. Shelly 1

W. Scot:

R. W. Greene R. G. Keeten*

D. R. Anderson

  • G. Lha:cn*

J. Warner

  • I L. R. Byrd Section III 1

Individuals Specified en Each Qualifica:icn Card f

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t MEMO TO:

G. A. Johnson FROM:

J. E. Custer

SUBJECT:

Designation of Persernel Authori:ed to Sign Centrol Roc = Operator and Non-Licensed Operater Qualificatica Cards IPC:

81/ 746 This =e=orandu: supercedes IPC S1/618 dated 5-27-81.

The following list of personnel are authorized to sign the Centrol Rec =

Operator and Non-Licensed Operator Qualificatien Cards effective the date of this =e=crandu=.

Any sig=ature which has been =ade by an individual 1

not aucht:1:ed by the issue of this =e= randu= vhich was in ef feet at the ti=e of the signature vill be censidered an invalid signature.

Personnel designated by an asterisk (*) are autherized to sig: only those ice =s en which they have received a va id signature.

i J. E. Custer Training and Ad=inistrative Supt.

7-8-81 JPH/JEC: ash Attachments cc:

C. K. McCoy C. L. Stuart R. A/ A=brosino J. P. Hanton File (Plant)

File (IPC)

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File

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i CONTROL ROOM OPERATOR QUALIFICATICN CARD 1

Sections I, II, III, IV I

'J. L. Robertson J. P. Hanton L. B. Moulder W. A. Russel W. C. Bearden R. G. Keeten*

4 G. A. Johnsen G. Lhamon*

i G. H. Lee L. R. Miller G. C. Allen J. F. Manby*

i C. V. Hicks

  • W. M. Shelly 1

D. R. Andersen*

R. W. Grea:e l

Warner

  • L. R. Byrd j

'C.

M. Rice Sectica V i

Individuals Specified en Each Qualification Card i

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Section I J. P. Hancon i

Section II J. L. Robertson J. Manby L. B. Moulder C. Hicks W. C. Bearden G. A. Johnson W. A. Russel G. C. Allen R. G. Keeten J. P. Han:ca G. Lhanen G. H. Lee J. Frazier W. M. Shelly K. Benefield R. W. Greene D. R. Anderson B. Lewis R. Jacobson J. Warner K. Mcdonald R. Powers L. Miller W. Cade C. Stafford L. R. Byrd l

E. Cresap K. Gorden C. M. Rica G. McMillin E. K. Hall

  • R. Perryman l

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NON-LICENSD OPERATOR QUALIFICATIOh* STANDAE & WO?X3OOK i

l Section B L. Rober: son J. Manby L. B. Moulder C. Hicks W. C. Bearden G. A.-Johnson G. C. Allen C. Stafford W. Russell J. Hanton R. G. Keeton*

G. H. Lee G. Lhamon*

W. M. Shelly J. Frazier*

R. W. Greene K. Benefield*

D. R. Anderson

  • B. Lewis
  • J. Warner
  • R. Jacobson*

R. Powers

  • K. Mcdonald W. Cade*

L. Miller L. R. Byrd*

C. M. Rice K. Gordon*

G. McMillin*

E. K. Hall

  • Section C L. Robertson L. Miller L. B. Moulder J. Manby W. C. Bearden C. Hicks G. A. Johnson G. C. Allen C. Staf ford J. Hanton G. H. Lee W. M. Shelly R. G. Keeton*

R. W. Greene G. Lhamon*

D. R.' Anderson

  • W. Russell J. Warner
  • J. Frazier*

R. Powers **

W. Cade*

K. Benefield*

3. Lewis
  • L. R. Byrd*

R. Jacobson*

K. Gorden*

K. Mcdonald G. McMillin*

E. K. Hall

  • C. M. Rice

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BUILDING / ARIA QUALIFICATION CARDS Section II L. Robertson L. Miller L. B. Moulder J. Manby f

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I BUILDING / AREA QUA:.IFICATION CAPOS CON INUD f

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G. A. Johnson G. C. Allea l

l J. P. Hanton G. H. Lee i

W. Russell W. M. Shelly R. W. Greens R. G. Keeton*

j D. R. Andersen*

G. Lhamen*

j J. Warner

  • L. R. Byrd l

C. M. Rice r

Sectica III f

Individuals Specified on Each Qualification Card J

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C. A. Johnson UN FBas J. E. Caetas, Trai aing & N mi strative Superintand==t SMTECT: Deeignation of Personnel Aetherised to 51p goalifimetian Carda F112:

4290/0765 g

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L' 7' The ateW list designates tha== indie d=mia who are authorised to sign the (Ih*.

class son Licensed operater Qualification Cards.

Quesencing Epwamber 7,1990, eesh age Licensed Operator will be ta==d a Een f

Edesmeed guaLitimmt.5em Card See, at whican time all eld geslificaties casd vari.

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flad signatures will he tressfersed to the asw Laesed goalification Cast. Amry Ey, a signature which has been ande by an individual not authorised by the iseus of this i

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latter which wee La effect at the time of the signature will be considered an 7

D invalid signature.

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'All shift Sparvisors are requested to have a review conducted of the sapetures in the qualificatice eerde on their crew and correct any def f Mm=Maa.

[ $

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11/10/90 i

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cca W. C. Searden M. J. Krisses I

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C. C. Allen C. N. Ime ic i.h; M.

W. Flyon D. R. Anderson I

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J. J. Betty J. merper W. Scott R. A. A erosino I

I L. Miller File w

y, C. E. Mr.cey Pitt File C. L. Senert Plant Fila e,

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J. E. Custer, Training & Ad.-'.inistrative Superintendent

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p.t Please notify me of any dif ficultics you might hsvo in cceplying with the abcve f;7 listing, and I will try to provide assistance.

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  • de On Decer.ber 31, please routo a note to me indicating which N.C.A's on your shif t j
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che only *;0A's to have all green and green-wnite tagged safe:y rela:ed syste: s signcc Of f are Kat:h uanefield, John Tra:Act and Bob Byrd.

In additica, rc::po.sc, to r y attached memo came from only F.cy Kee:On, John Warnc e a.d ra:naal PawJ.

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Craininq and Administrativo Superintendent 1/0/81 v

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....a Cn 12/22/8C J. I. Caster sent a remo : 0:1 and you regarding c; erat:r qualifica:icns requar:n: a respense by 12/21/50. The respense :: this reme was inadequate as enly 3 shift Supervisers respe..ded.

Ea:h Shift Sc;erviser needs :: expedite this ;ch and supply me by means of a mere, the pr:gr'ss and/ : pre:lems en:cu..:ered by 1/14/51.

Atta:hed is a se::nd reco regarding the same pr:blem :: assis you.

Please n te the sta e ent regarding the persennel signed cf f en all green and c.reen-wh te ta=.:.ed s1etems.

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Shift Surertiser - May.e ?.ussell l

F Cn February 23, 19~1, J. D. Ke'gerre:.s attended Wayne Russell en a plant tcur with the intent of deter--ining Wayne 's prefi-ciency.

(See attached ene)

As a result cf this tcur, I feel W a"; ~.. =..". a s.' e...... s.. a. =. ^ a s a..' e '. ~. ~... ; > ~.~.. ' e ' - =..'

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Please ensure this mere is placed in Wayne's traininc 'ile.

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A walkthr ugh with Wayne 2.ussell was cenducted cn February 22, 1981.

Areas Of ::verage included..are:

1.

esel Genera: Ors 2.

Plant Ch lied Water

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Plant operations fr== Celd Shutdown := 100% pcwer 15.

,Reacter Theerv.

16.

Radiation Safety Wayne presented himself as a knowledgeable individual and was aware of many of the prenesed changes to systems and the reasons for these l

changes.

j It was apparent that Wayne has spent sometime reviewing the GG :E Technical Specifications and is starting to understand its centents.

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There was seme weakness, net uncommen during this time frame, of 10 CTR parts 19, 20, 21, 50 and 73.

When time avails, Wayne should 9

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I l22!J TO: Trsinina, Staff TiiCA:

Trcining Stnervise:

SU',JIC!: Chech-Out N:ies

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.1 1_s: of when each Operations ins: rue:ct is to =ake himself ev:11stle fer civing check-cuts :o individuals w rkin; en various quali-ficaticn :seds.

From 2: 30 p.=. until !.: 30 p.m. cn your assigned day, ycur pri ary responsibili:y is :: give cht:ck-:ut..

She.:ld a c:nflic:

ar:se su n tha yea vil! n:: 1e availabl-: durin, :his period of time, i:

is jour ras u sibili:v c arrsngs for another Occratiens Ins: rue:Or Oc t:.:ka ycur e.sec.

Sob Ceebel and 1 =us: be no:if*ed in advance.

."uring :i:.es when you are n:: assigned :o give check-:u:s. you are ur.:::.rc;ed to assist = embers Jf :he Operation.= Deus.r: en: in ec p3 c:in;;

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1.cir que'.:.fiestiens as yeu: c:hadule per.its.

!!0N 5/18 Mike 71ynn 1

I;I 5/19 G::de-Allen

'n?.D 5/20 1:ihe i'risman 1

T:!rR 5/21 Bob Creene l

TRI 5/22 Cecrge Lee i

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5/26 Mike Tlynn

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~ Mike Shelly G rde. Allen TK!

5/29 Sch Creene

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i l GGNS Cold License Operator N. U. b C CO l

Name:

l Oualification Card Section I - Prerequisites training record of N. (. borM has been The personal A.

reviewd and contains satisf actory docu:nen:ation that, the experience

...... are require =ents applicable to Reactor Operator / h-i--

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satisfied or will be satisfied at the time of core loading. (ref: Plan:

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Ad=inistrative Procedure 01-5-04-Temp-1)

WhS kCU.Ilsli7 Training Supervise /

Date h

operating experience has been acquired through one or a Extensive reac:c

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3.

combination of :he following (indica:e which ite=s are applicable):

Satisf actory co pletion of an NRC approved training program utili:ing

[)d 1.

a Nuclear Fower Plant si=ula to r.

a comparable

[]

2.

Holding or having held a reactor operator's license at licensed reae:or facility.

Satisf actory ec=pletion of an NRC administered license examination at

[ ]

3.

a ec= parable licensed reactor facility.

[ } 4 Experience obtained at a co= parable reactor facili:y opera:ed by ERDA or the P.ilitary.

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l GONS Cold License Operator l

l Oualification Card Name: b. N. b\\

l Section I - Prerequisites A.

The persona'l training record of C. U. NGO \\

has been reviewed and contains satisf actory documentation that the experience requirements applicable to Reactor Operator / :-f r-r ": -

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are M Id satisfied or will be satisfied at the time of core loading. (ref: Plant Administrative Procedure 01-S-04-Temp-1) o I

Training Supervisor []

Date 3.

Extensive reactor operating experience has been acquired through one or a

[mi combination of the following (indicate which items are applicable):

\\

1.

Satisf actory ccepletion of an NRC approved training program utilizing b

a Nuclear Power Plant si=ulator.

[]

2.

Holding or having held a reactor operator's license at a comparable licensed reactor facility.

[]

3.

Satisfactory ec=pletion of an NRC administered license examination at a comparable licensed reactor facility.

[} 4 Experience obtained at a comparable reactor facility operated by EROA o r the Military, of A

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O.. Y. N kC k S l Oualificatien Ca-d Name:

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See:ica I - Prerequisites A.

The perscial training record of

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/ Senior Reactor Operator are Ak satisfied or s-111 be satisfied at the time of core loading. (ref: Plant Adminis:ra:ive Procedure 01-5-%-Temp-1) o

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  1. Training Supervisor /

Date S.

Extensive reae:or 0; era:ing experience has been acquired through one or a combinati:n of :he icilowing (indica:e which ite:s are applicable):

1.

Satisf ae: cry ec=pletien of an NRC approved training program utilicing 3 Nuclear Powe r Plant si=ulator.

[ ]

2.

Holdirg or having held a reactor operator's license at a comparable licensed reae:or facility.

[}

3.

Satisf ac tory completien of an NRC administered license examination at a cc parable licensed reactor facility.

N},

4 Experience Ob:ained a: a cc: parable reactor facility operated by ERDA c

he.v.ili:ary.
i. n c., m m-L. -r Mfw I Training Supervisor' Dat:e t Pag e 1 of 21

p k

G l GCNS Cold License Opetator

-l 2.K.daCob500 l

l Oualificatien Card Name:

Section I - Prerequisites A.

The personal training record of

. K. ho h.Co n has been reviewd and contains satisfactory doct:nentation that the ex requirements applicable to Reactor Operator /E-f:r ":i: : r ^perience- '--are M satisfied or will be satisfied at the time.of core loading. (ref: Plant Ad=inistrative Procedure 01-5-04-Temp-1) o r

! $0 bE-SY l

M Y

Training Supervisor /

Date B.

Extensive reactor operating experience has been acquired through one or a co.binatien of the following (indicate which items are applicable):

M 1.

Satisf ac tory co=pletion of an NRC approved training program utilizing V

a Nuclear Power Plant simulator.

[]

2.

Holding or having held a reactor operator's license at a ec= parable licensed reac tor facility.

[ ]

3.

Satisfactory co pletion of an NRC administered license examination at a ec= parable licensed reactor facility.

[ ] 4 Experience obtained at a comparable reac tor facility operated by ERDA o r the M.ilitary.

B A

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Page 1 of 21

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The personal training record of

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satisfied or will be satisfied at the time of core loading. (ref: Plant Administrative Procedure 01-5-04-Temp-1) t e

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Training Supervisor

[] Date B.

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Extensive reactor operating experience has been acquired through one or a combination of the following (indicate which items are applicable):

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Satisf ac tory completion of an NRC approved training program utili:ing a Nuclear Power Plant sim ul a to r.

[]

2.

Holding or having held a reactor operator's license at a comparable licensed reactor facility.

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3.

Satisfactory completion of an NRC administered license examination at a co= parable licensed reactor facility.

[] 4 Experience obtained at or the Pdlitary.

a comparable reac tor f acility opera;ed. by ERDA e

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l Pag e 1 of 21 l

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7 1J 1 cc.ss cold License operator l

J.P. Manby i

l Oualification Card Name:

e Section I - Prerequisites A.

The person'al training record of

. bddbM has been reviewed and contains satisfactory documentation Inat the experience requirements applicable to Reactor Operator /S-ic: "d.: :- 0;::: a r are satisfied or will be satisfied at the time of core loading. (ref: Plant Administrative Procedure 01-5-04-Temp-1) o r

s A e

(

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( N.bll ff TrainingSupervisor[

Date 3.

Ex t ensive reactor operating experience has been acquired through one or a ecmbination of the following (indicate which items are applicable):

'Lp 1.

Satisf actory ccepletien of an NRC approved training program utill:ing J

a Nuclear Power Plant s1=ulato r.

[]

2.

Holding or having held a reactor operator's license at a comparable licensed reactor facility.

[ ]

3.

Satisfactory co=pletion of an NRC administered license examination at a ecmparable licensed. reactor facility.

[ ] 4 Experience obtained at a comparable reactor facility operated by ERDA

~

o r the.vilitary.

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Training Supervisop Da te T

Pag e 1 of 21

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l INTERIM O U A'.! ?! C AT I O*! CERT!?!CATE I have personally reviewed the individual's qualification card kd SNN NW and certify that has met (Operator) all qualification requirements specified in G.

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IPC-81/497 ATTACHMENT I V

s INTERIM OUAI.IFICATION CE E T !F I C A TE 4

I have personally reviewed the individual's qualification card kM hMW has met and certify that (operator) all qualification requirements spe cified in G.

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Johnson's 4

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.w As the due date (3/31/E1) fer Operater ;ualif::ati:..s dravr

1cse a large numher cf pers:nnel have asked ques-icts : : r. -

cerning.:::ti:ns cf the ;;al Cards that ust he signed :ff

::. ply with the

.:::edure.

Chis cere is intendet :=

clarify e;. p:sitien en this.

First of all, we de ree:gni:e that the Licensed and !; n -

L :er. sed C.:erater ~.ualificatien Pr: rars were desi ned and huilt te he a.e li c ah le f er the f:r t'

v. e a r lifetine Of the r

plant.

Curing the pre-eper ational ph ase cf the plant scre cf the :ters en the qual cards are n=: installed and, there-fere, ne ate the pessibility cf " der:nstratien of knowieige'.

Als:, sene Of the Operating chara: eristics (such as radia-t; n/::ntarinati:n areas) are not kn vn.

Finally, s re Of

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the trainin. : curses have net heen c.:ven ner are thev rlan.ed

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NRC 11:ensing.

Ter NCA the

nimum requirements prier to Mar:h 31, 1951 include:

1.

All are as of Syste Cperation qual except CG3 and C64 2.

All areas of Plant Operatien qual that have appreved/is sued precedures i

3.

Sirulater certification 4.

CCNS Systems :: Course

  1. 5.

Nuclear Power Plant Fundamentals (or equiva-lent) 6.

Successful completion of o th e r specified training courses given prior to licensing For NCB the minimur. requirements prior to March 31, 1981 include:

1.

Power Plant Principles Course g

2.

NCB Systems Course

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3.

Component Qual Card (all sections) 4 Non-Licensed Operators Standard and workbook J

Operations Persennel Qual Card Completion Page 2 a.

Seetzen A-1 all issued prece dures b.

Systen knowledge fact:rs fer all systers 5.

B uilding /Are a qual Cards: S e :tien B 1-5 f:: all building a.. d S e ::: en : fer a l.' issued pr: edures 6.

Successful completi:n of other specified training courses given prior to fuel icad For ACN 0.e m

inur requirements prier tc. Tar:h 21, 1951

includ, 1.

Fewer P l an t P r i.. ::p le s Ocurse 1.

C penent Qual Card (all s e ctions)

A f

3.

Ncn-L: ense d Cperaters Stan dard and werkbeck

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a.

Section A all issued procedures b.

System Xnewledge facters fer all systems in en e building 4.

Building / Area Qual Cards: S e ction B 1-5 and 0 fer ene building (using is s ue d p r o ce du r e s.,

5.

Completien of other spe cifie d training courses As mere information becomes available, s ys te r.s /a r e a s are completed and prece dures are issued, applicable portions cf the Qual Cards should be signed eff.

I w:11 he reminding you cf these per iedi cally.

6 It should be recognized that all signef f s will be required for NOA's at NRC Licensing and for NCB's an d AON 's at fuel load.

P p

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A.

ohnson 3/27/83

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Stuart J.

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MEMO TO:

Operations Personnel TKOM:

C.

A.

Johnsen Sl' B J E C T :

Qual Card Comple:icn e

IPC:

S:/ 204 t As the due da:e (2/23/52) fer Operator Qualifications draws close a large number of personnel have asked ques:icns cen-cerning per:: ens of the Qual Cards that mus: be signed eff to cemply vi:h :he procedure.

This mere is in: ended :c clarify my pesition en this.

Firs: of all, we de recegnize that the Licensed and N:n-L :ensed Opera:ct Qualificatien Pregra s were designed and built to be applicable for the fer:y year lifetime of the plan:.

During the pre-eperatienal phase cf the plant seme ef the iters en the Qual cards are ne: ins:alled and, there-fere, nega:e the pcssibili:y cf "demenstra:icn cf kncviedge" I

Alsc, some of the operating chara : eristics (such as radia-tien/ con:aninatica areas) are ne: knevn.

Finally, sere ef the training courses have not been given ner are : hey plannei pri:: :e *: K licensing.

3 For NCA the mini =u-requiremen:s prior :c Teb. 23, 19E:

's.s/

include:

1.

All areas cf Syste: Opera:1on 2.

All areas of Plant Operation qual that have approved / issued procedures 3.

Simulater certification 4.

GGNS Sys: ems II Course 5.

Nuclear Pever Plan: Fundamen:als (or equiva-lent) 6.

Successful completion of other specified training courses given prior to licensing For NOB the minimum requirements prior to Feb. 23, 1982 include:

t 1.

Power Plant Principles Course 2.

NOB Systems Course 3.

Component Qual Card (all sections)

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Opera: ions Personnel Qual Card Comple:icn

, age s

a.

Secti:n A all issued pr:cedures b.

System Enevledpe fae:::s for all systens 5.

S u il d i n g /.\\ r e a cual Cards; Se::i:n 3 1-5 for al; bu:1 ding and Section D f:r all issued procedures Successfu1 :: pletien of ether specified trai-ing 6.

courses given prier :c fuel lead Ter A C :. the minitum r e q u i r e n e r. : s prior :: Feb.

~3,

!?El in:16de:

1.

Fever Plan: Principles C:urse 1

1.

Cenpenen: Gual Card (all see:i:ns) a 3.

'en-Licensed Cpera:crs 5:andard and verkteci all issued precedures a.

Se::ien A

  • b.

Syster kn:-ledge fae: rs for all sys:ers in one building 1

4 Building / Area Qual Cards; Se::1cn 3 1-5 and O for one building (using issued precedures) 5.

Comple:icn ef c:her specified : raining ceurses As more information be:c=es available, syste=s/ areas are cceple:ed and procedures are issued, applicable pertiens ef

'the Qual Cards sheuld be signed off.

I vill be reminding 4

i ycu of these periedically.

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Johnson t

2/19/62 i

CAJ:es cc:

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Stuart D.

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Hunt File I

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v MEMO TC:

Cperations Persennel tFRCM:

G. A. Ochnsen

SUBJECT:

Operater Qualificatien Today is the last day fer ccmpletien cf cualificatiens and

! noted that a number cf cperaters still have not ecepleted all recuired signeffs fer their current pay grade.

Shift Supervisers/ Superintendents are directed to use persen el caly in the highest classification fer which the.v are c.ual fied.

Persennel who are not cualified fer a position for which they are temperarily upgraded will be " move d ba ck " to their permanent pay status.

All persen el net qualified at their permanent pay grade will

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be relieved cf ether duties unless absciutel.v rec.uired.

No persennel will be selected fer evertire if they are ne qualified for their permanent pay grade.

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G.A.

Jchnsen 3/31/El GAJ:csc ec:

C.

L. Stuart J. E.

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MEMO TO:

Mr. T. E. Re aves, Jr., Manager of Quality As surance FROM:

W. E. Edge, Programs Quality Ass uranc e Man age r

SUBJECT:

Licensee Operator Training Allegations - Robert Byrd (11/9/83)

FILE:

0290/0490/166

94.4 REFERENCES

QAMI-83/0600; QAMI-84/0004; QAMI-84/0061 QAMI-84/ 0091 You requested both Bill Eiff and I investigate certain allegations made by a former MP&L employee: Lawrence Robert Byrd. The allegations were made to you by telephone on November 9,1983. Our investigation revealed the alleged abuse of Credit by Examination appears substantiated. This was documented in CAR 803.

One particularly serious allegation was made that a memoranda was signed by the Plant Manager in October or November,1982, indicating training was complete wh en in f act it was not " backed up" by training records. Memoranda signed on December 9,1982 by the Plant Manage r were discovered. Wile there were minor inaccuracies in existence at the time the December 9,1982

'N memoranda were signed and in the application letter AECM-82/467, they were not of the magnitude to constitute fraud. If the differences or inaccuracies had been pointed out prior to submittal, corrections could have been easily made.

No wrong doing by a present or former MP&L employee is evident. Further action on this investigation is not required.

3

/

W. E. E.

02/08/84 WEE:ky ec:

Mr. J. B. Richard Mr. J. P. McGaugby, Jr.

File (Plant)

Manual File File (Project) (1)

m MEMO TC:

Mr. T. E. Reaves, Manager of Quality Assurance FRON :

5. M. Faith, Nuclear Site Quality Assurance Manager SU3 JECT: Additional Infermation Regardies 1.iesese Applicaticca sutsitted via A10M 82/467 B.t F :

CAMI-84/0004 FILE:

0290/0490/16696.4 QAMI-84/0061 As you reques ted on February 8,1994, the specific discrepancies for each of the six re-examiestion applications tracesitted via AECM 82/467 were t abul a t ed. The results are as follows:

tottamiller 1.

Application showed credit by e.ramication where previous application implied course attendacca. (Note 2)

Stafford:

1.

No documentation available to support application entry for four week upgrade training.

(Note 1)

Frasier

\\

1.

No records to support applicatice entry for six day Reactor Physics, Core Thermodynaales and Radiation Control. (Note 1) 2.

Six Week Heat Transfer and Fluid Flow course shovt on application was actually three weeks in duratien. (Note 1) 3 No records to support application entry for five weeks of self-study.

(Note 1) 4.

Application showed two oce-week courses i: Mitigation of Core llamage (oce taught by General Physics and one ur. identified). Records showed Frasier failed General Physics course with no evidence of make-up. He did peas other course. (Note 2)

Melt 1.

Six week Heat Tra:s f er and Fluid Flow course shown on application was actually tirse veens in duration. (Note 1) t.ewis 1.

Six week Heat Transfer and Fluid Flow course shove oc application was actually three weeks in duration. [ Note 1) 2.

No records to support application entry for five weeks of self-study.

(Mote 1) 0 g

3.

Thirteen day simulator refresher shovu on application was actually twelve days in duration. (Note 2)

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Pese 2 of 2 Herries

1. ' tacords abow applicant f ailed exam for Cycle 1 cf Cold t,iceces Training with no evidecco of make-up.

(Note 3) 2.

Records abow applica:t received grade of 70 in 7-day Plant Operations (Tech Spec.) c:urse with no evidee.co of make-up.

(Note 3) 3.

Six week Heat Transfer and Fluid Flow course was actually three weeks in duration. (Note 3)

Mote 1:

14antified by Plant Staff Note 2:

Identified during MAR 83/0133 Note 3:

Identified during allegatioc investigation should you have any questions regardi:3 chie information contact Bill Eiff ac extension 3273.

5. M. Faith 2/8/84 A

V05:SMF:ka ec: Mr. W. E. Edge Mr. J. E. Reaves Site % File Manual File Project File [2l 5

' '~ l t -

l MEMO TO:

Mr. T. E. Reaves, Jr., Manager of Quality Assurance FROM:

S. M. Feich, Nuclear Site QA Manager

'~r.,

SUBJECT:

Verificaticn o: Infor=a t ton in AECM 82/464' -danc"idiri4g g

ig FILE:

0290/0490/16694.4

,p QAMI -

84/0004 y

J This memorandum sup=rsedes QAMI 83/0535 M r & t. t. 2 Q A As you reques ted, a review of training records was pertormed :or six individuals for whom re-examinations were requested in the above referenced letter. This review indicates that all training identified in the license applications had been accomplished prior to the submittal of AECM 82/467 except for that which was indicated as projected training. The certification of competency by the Plant Manager was found to be in order. The six individuals were:

Charles Andrew Bottemiller John Burk Frazier Errol Keith Hall Homer Herring A

Billy George Lewis

(

Clark Daniel Stafford V

Three questions were to be answered:

(1) Had all training identified in applications transmitted with above referenced letter been accomplished prior to the date of the letter?

(2) Had the Plant Manager certified the competency of each candidate prior to the above referenced. letter?

(3) Had all training been accomplished prior to certification of competency by Plant Manager?

The results of the review are as follows:

Traingg, accomplis M g ior to_ October 6, 1982 Five of the six candidates had been previously included in MAR 83/0133. For these five, all training had been accomplished prior to October 8, 1982 with two exceptions: (1) those discrepancies previous 1,y identified, either by Plant Staf f or in MR 83/0133; (2) training that was identified on application as " projected". These five candidates were Bottemiller, Frazier, Hall, Lewis and Stafford.

The remaining candidate (Herring) had not been included in MAR 83/0133. Three discrepancies of the same types as previously identified were found in his records. With these exceptions, all y

training had been accomplished prior to October 8, 1962.

v

QAMI 84/0004 Page 2 of 2 k

Plant Manager certification of candid

~

No evidence uf certification of :ompetency of the candidates by Plant Manager was found which pre-da:ed October 8, 1982; however, FSAR requirements is that certification be acco=plished prior to adminis tering NRC examination.

Memo from C. K. McCoy to J. P. McGaughy certifying competency of candidates was found for each of four candidates (Frazier, Hall, Lewis and Stafford). OTEC' evaluations were also found for the same individuals. Both documents (memo and evaluation) were dated December 9, 1982.

The referenced memoranda consisted of form letters with the following statement:

"A review of the individuals training shows that all requirements for sitting for the NRC Examination have been met."

" Based on the training record review and OTEC evaluation I certify that is considered competent in his knowledge to operate............"

An OTEC evaluation dated December 9, 1982 was found for Sottemiller; however, no memo from C. K. McCoy was found.

O In two cases (Bottemiller and Hall) Operator Upgrade Training was not f

actually completed until December 10, 1982. This one-day discrepancy

\\

is not considered to be significant.

Neither memo nor evaluation was found for Herring. Conversation with Training Superintendent revealed that Herring has been removed fec=

licensing program.

License exams were conducted on or about December 16, 1982.

J

.V S. M. Fetch 1/5/84 f?-

WCE :SMF :ms cc: Mr. W. E. Edge Mr. J. E. Reaves Site QA File Manual File Project File [2]

s

I j

1 i

MEMO TO:

Mr. T. E. Reaves, Jr.

FROM:

W. E. Edge

SUBJECT:

Licensee Operator Training Allegations -

Robert Byrd (11/9/83)

FILE:

0290/0490 QAMI-83/0600 You requested I investigate certain allegations ::ade by a former MP&L employee: Lawrence Robert Byrd. The allegations were made to you by telephone en 11/9/83. My investigation revealed the alleged abuse of Credit i

By Examination appears substantiated. The other allegations have little revelance as they have been previously identified, documented, corrected and the NRC notified. No wrong doing by a present or former MPEL employee is evident.

The detailed des:ription of the allegations and my investigation are provided in the attachment.

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) W W. E. Ed e 4 ' /1. / ^ ' -

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WEE:ky Attachment ec:

Mr. J. B. Richard, w/a Mr. J. P. McGaughy, Jr., w/a Manual File, w/a File (Plant), w/a File (Project) [

], w/a 4

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s I,

Attachment to QAMI-83/0600

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Page 1 of 4

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k INVESTIGATION OF LICENSE OPERATOR TRAINING ALLEGATIONS 11/10-11/83 A.

GENERAL Allegations were made by a former MP&L employee-Lawrence Robert Byrd-to MP&L's T. E. Reaves, Jr. by telephone on November 9,1983.

Mr. Byrd was an employee of MP&L from October 25, 1971, until his resignation effective March 7, 1983. He was in the first licensed operator class for GCNS and ultimately was licensed as an SRO.

He served in the following positions with regard to GCNS: Assistant Coerator-Nuclear, Plant Operator-Nuclear, Nuclear Operator A, Sh if t Supervisor and Operator Instructor.

B.

ALLEGATIONS AND INVESTIGATIONS 1.

ALLEGATION - Four applications for NRC license submitted for the December 1982 operator class included entries which were not " backed up" by training record entries or training records. Applications were for the following licensed candidates:

Karl Fredsrick Ehrhardt Stephan Wayne Humphries

/'-'s Thomas Oliver McIntyre (v)

Charles Andrew Bottemiller INVESTIGATION It is the practice of MP&L as exampled in the " December operator class" applications ( AECM-82/467) to indicate on the application scheduled training / activities which are to be performed prior to the applicant taking the NRC Examination. As of the date of submittal the applica-tions were correct and indicated that certain training was scheduled.

Af ter completion of the scheduled training some errors were discovered.

In the case of Ehrhardt, Humphries and McIntyre two of the application entries for scheduled training / activities proved incorrect / inaccurate-today due to circumstances which occurred af ter the date of application These are:

"12 Day Simulator Refresher Training at Tulsa, OK (GE) (11/12-a.

11/23/82) June 6 through September 3,'1982 on Shift Training" Later this was found to be ten days instead of 12.

This was identified by Plant Staff and provided to the NRC per AECM-83/0681.

b.

"5 Week Supervised Self Study and Practice Walkthroughs (GCNS)

(9/27/82-10/29/82)". Later it was found that no documentation was available in the training records to substantiate this training.

This was identified by Plant Staff and provided to the NRC per AECM-83/0681.

[

A review was made of the Individual Training History, specific class /

course records, QA Monitoring Audit Report MAR 83/0133, AECM-82/467 and s

AECM-83/0681.

Attachment to QAMI-83/0600 s

)

Page 2 of 4 a

ALLEGATIONS 'ND INVESTIGATIONS (con't)

B.

A INVESTIGATION FINDING At the time applications were submitted the entries on the applications were correct. Later a course length changed and the self study wasn't documented. The specific errors have been identified, documented, corrected and the NkC notified.

2.

ALLEGATION - Memoranda were signed by the Plant Manager in the October / November 1982 time frame addressed to the Vice-President, Nuclear which were not " backed up" by training documentation. The Plant Manager was so informed and indicated he would sign and not hold up the operators because the training section had not completed documentation in the training records.

INVESTIGATION 1

Some memoranda signed on 12/9/82 by the Plant Manager were discovered which included a statement that:

"A review of the individuals training shows that all requirements for sitting for the NRC Examination have been met."

" Based on the training record review and OTEC evaluation I certify

/' 'N thct is considered competent in his knowledge to

(

operate........."

These statements appear to be true as signed by the Plant Manager.

A review was made of the Individual Training History for Ehrhardt, Humphries, McIntyre and Bottemiller; specific class / course records; QA Monitoring Audit Report MAR-83/0133; AECM-82/0467; and AECM-83/0681.

INVESTIGATION FINDING The applications as submitted in AECM-82/467 contained no errors. As of the date of memoranda the same errors as per Allegation 1 existed. It was impossible to determination if conversation took place as stated.

I did not pursue.

3.

ALLEGATION - The firs t application for Charles Andrew Bottemiller contained a number of errors in that he had not received the training indicated and individuals were aware of this discrepancy. When Byrd joined the Training Section in June 1982, entries were not in Bottemiller's Individual Training History or other training files to

" backup" his May 1982 application. Further, Bottemiller was adminis-tered an examination and was given credit for several courses by " Credit by Examination." Although the application was corrected in the second application submitted in October 1982, it was felt that the "CBE" was being abused for Bottemiller and that MP&L did not explain the mistake in the first application more directly in the second application.

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Attachment to QAMI-83/0600

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Page 3 of 4 l

B.3. ALLEGATIONS AND INVESTIGATIONS (con't)

INVESTIGATION a.

Bottemiller's first application for license for GCNS was made by letter AECM-82/215 to the NRC on May 14, 1982. That application indicated he had received training in several courses. Actually he to be administered an examination and be given Credit By was Examination (CBE).

b.

The first examination was administered in June 17, 1982. He passed with a score of 80.24 (Passing Grade is 80).

The courses i'or which CBE was given were:

8 week Grand Gulf Technology (GGNS) 5 day Admin. Requirements Course (CCNS) 7 day Plant Operations Course (GGNS) 2 day Mitigation of Core Course (GGNS) 2 day Fire Brigade Training (GGNS)

(NOTE: This was later explained per memo D. L. Hunt to C. A.

Bottemiller Training Record - 12/6/82)

The examination given was the examination for License Operator Exam p

Preparation Course (LOEP) and separate examinations for the five

/

individual courses listed above were not administered.

The LOEP examination taken on 6/17/82 for which the CBE credit was taken was divided into five sections.

(1) Theory of Nuclear Power Plant Operation (2) Theory of Fluids and Thermodynamics (3) Plant Systems Design, Control and Instrumentation (4) Procedures-Normal, Abnormal Emergency and Radiological Control (5) Administrative Procedures, Conditions, and Limitations It appears the LOEP examination is questionable as represent-ing the examinations of the five courses for which CBE was taken.

It would appear the courses: Grand Gulf Technology, Mitigation of Core Damage and Fire Brigade Training were inappropriately considered CBE for Bottemiller for the LOEP ex aminat ion.

This was determined by review of the LOEP exam taken by Bottemiller and a review of a Mitigation of Core Damage Course 820921 [MCD-82159]; Grand Gulf Technology Course 820423

[8237); and Fire Brigade Training 820813 [FBT-82166]. The Fire Brigade Training was taken by Bottemiller on 830708 Course Number [8337-10].

I l

The LOER examination of 6/17/83 contained no Fire Brigade

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Training questions.

x c.

Bottemiller next failed the NRC examination and was entered in the LOEP Course which he attended in part.

Attachment to QAMI-83/0600 Page 4 of 4 g

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B.3. ALLEGATIONS AND INVESTIGATION (con't) d.

Bottemiller passed a second LCEP exam on 11/29/82 with a grade of 84.3.

e.

He then passed the second NRC exam on 12/16/82.

The letter to the NRC AECM-83/681 dated 11/1/83 incorrectly lists the first application "...should have noted that credit for the subject courses was given by examination". A more correct statement is that the examination was scheduled to be given to Bottemiller between the date of the first application 5/14/83 and the date of the NRC examination. This is what in fact occured.

The Mitigation of Core Damage Course quoted in AECM-83/0681 for Bottemiller:

"However, the applicant successfully passed an examination covering the material of subject at Grand Gulf."... is misleading in that the LOER Examinat. ion failed to include adequate questions for this subject.

An interview with Bottemiller; and a review of Bottemiller's Individual Training History, specific class / courses records, QA MAR-83/0133, AECM-82/467, and AECM-83/0681 indicated the above.

INVESTIGATION FINDING D

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The abuse of Credit By Examination is substantiated for Charles Andrew

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Bottemiller for the LOEP examination being used as CBE for Grand Gulf Technology, Mitigation of Core Damage and Fire Brigade Training.

a.

There is a lack of adequate procedural definition and controls on Credit By Examination.

b.

A review of Bottemiller's training record is needed to determine whether other examinations should be taken by him to clarify the record.

c.

Bob Byrd initiated a PQDR-04-83 on this subject 1-11-83, PQDR 83.

This PQDR was not adequately resolved in that corrective actions appear weak.

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4 L

MEMO TO:

Mr. T. E. Reaves, Jr., Manager of Quality Assurance FROM:

S. M. Feith, Nuclear Site QA Manager

SUBJECT:

Verification of Infor:ation in AECM 82/467, dated October 8,1982 FILE:

0290/0490/16694.4 QAMI -

83/0535 As you requested, a review of training records was performed for six individuals f or whom re-exa=inations were requested in the above letter. This review indicates that all training identified in the license applications had been acco=plished prior to the submittal of AECM 82/467 except for that which was indicated as proj ected training. The certification of competency by the Plant Manager was found to be in order. The six individuals were:

Charles Andrew Botte= iller John Burk Frazier Errol Keith Hall Homer Herring Billy George Lewis

"'s Clark Daniel Stafford Two questions were to be answered:

(1) Had all training identified in applications transmitted s

with above letter been accomplished prior to the date of the letter?

.)

(2) Had the Plant Manager certified the competency of each candidate prior to the above letter?

The results of the review are as follows:

Training accomplished prior to October 8, 1982 Five of the six candidates had been previously included in MAR 83/0133. For these five, all training had been accomplished prior to October 8,1982 with two exceptions:

(1) those discrepancies previously identified, either by Plant Staff or in MAR 83/0133; (2) training that was identified on application as projected. These five candidates were Bottamiller, Frazier, Hall, Lewis and Staf ford.

The remaining candidate (Herring) had not been included in MAR 83/0133. Three discrepancies of the same types as previously identified were found in his records. With these exceptions, all training had been accomplished prior to October.8, 1982.

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QAMI 83/0535

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Page 2 of 2

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Plant M.anager certification of candidates No evidence of ceritifcatien of co=petency of the candidates by Plant Manager was found which pre-dated October S,1982; however, a

FSAR requirement is that certification be accomplished prior to administering NRC examination.

Memo from C. K. McCoy to J. P. M:Gaughy certifying competency of candidates was fcund for each of four candidates (Frazier, Hall, Lewis and Stafford). OTEC evaluations were also found for the same individuals. Both docu=ents (memo and evaluation) were dated December 9, 1982. License exa=s were given approxi=ately Dece=ber 16, 1982.

An OTEC evaluation dated Dece=ber 9, 1982 was found for Botte= iller;

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however, no se=o f rom C. K. McCoy was f ound.

Neither =emo nor evaluation was found for Herring. Conversation with Training Superintendent revealed that Herring has been re=oved f rom licensing program.

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v S. M. Feith 11/18/83 WCE:SMF:=s cc:

Mr. W. E. Edge Mr. J. E. Reaves Site QA File Manual File Proj ect file (2]

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MEMO TO:

MR. J.

3. Rich a rd, Se nior Vic e Presid en - Nuc lear FROM:

T. E. Reav,es, Jr., Manager of Quality Assurance SU3 JECT:

Concerns Identified during QA Ma n ag eme n t In t erviews wi th Ope r ato rs FILE:

0765/0290/0490/16694.4 FM1-83/12,634 During the last 10 days in t e rvi ews h av e b ee n c ondu c t ed a s r eque s t ed wi t h CONS operators. The specific purpose of the interviews was to determine if any one h ad knowled ge of or suspect ed tr aining, or applic ation records c on t ained improper entries. The current review of applications by Training pesonnel and s ub seque nt QA Aud it d ocume n t ed nume rou s pr obl ems on pr eviously submi t ted applications. Our interviews indicated only one additional application error. One applic ant s t a t ed that the entry of "Re-training - 10 weeks of supervised self study on Reactor Theory and Reseter Behavior; Heat Transfer

.... " on h is se c orti applic aion wa s in e rror.

A f our we ek sel f s tudy retraining was accomplished as he was required to stand shif t during the normal 10 we ek ac t iv i t y.

The applic ant only raised a q ue s t ion a s to how incorrect entry was made and in no way indicated that it was intentional.

During the c ou r se of these i n t e rv i ews seve r al ot her i terns r ela t ing to cur rent and ongoing activities were revealed that neerssit ate Management review, c oncurrence and/ or ac t ion.

fb A.

Qualification Cards 1.

Fo r both knowl ed ge and pr ac t ic al factors a group of candidates eay be interviewed and based upon group response to the questions credit is given to all c andid at es.

2.

Some of the pract ic al factors may be ecrnpleted by the discussion of actions involved to complete the task as opposed to an actual walkd own of equi pme nt.

3.

Some qualification cards and/or sections of cards seem to indic at e the accomplishment of more than could reasonably be expected in the t ime allcwed. This may only indic ate signof f upon the ccrnpletion of a group of items as opposed to signing the day each item was completed.

B.

Required Re ading One unlic ensed individual indie nt ed that a secret ary had initialed his required reading sheets in his absence. Die individual indicated that he had retrieved and ecunpleted the mat erial during the pe riod in question. Confirmation could not be performed as the required reading sign-off sheets were not ma i n t a i n ed for record purposes durirg the period of concern.

OV) f t

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I PM1-9 3 /12,6 3 4 Page 2 of 2 The requested interviews of all Lirensed CONS personnel are expe:ted to b e compl et ed by Novemb e r 14, 1983.

A f in al r e po r t cove ring all i t em s will be submitted at that time.

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10/31/83 i

TER:drm ec:

Mr. J. P. McGau;5y, Jr.

Mr. C. K.

McCoy i

Mr. T.

H.

Cl on inge r Mr. L. F. Dale Mr. J. T. Pinto Mr.

S.

M.

Teith M r. k'. E.

Ed ge Mr. J.

E.

Reaves Tile (Plant)

Manual File l

Til e (Project) [2]

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