ML20140D271
| ML20140D271 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/10/1986 |
| From: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Wilgus W FLORIDA POWER CORP. |
| References | |
| NUDOCS 8601290241 | |
| Download: ML20140D271 (4) | |
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C$ - 3S'l JAN 101986 floridaPowerCorporation 1
VATTN: Mr. Walter S. Wilgus Vice President Nuclear Operations P. O. Box 14042, M.A.C. H-2 St. Petersburg, FL 33733 Gentlemen:
SUBJECT:
FLORIDA POWER CORPORATION, CRYSTAL RIVER NUCLEAR STATION:
LICENSEE TRAINING MATTERS - USNRC 0FFICE OF INVESTIGATIONS REPORT 2-85-004 Encicsed is the synopsis of the subject Report of Investigation which is being forwarded for your information.
Feel free to contact me should you have any questions regarding the matter.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC's Public Document Room.
We appreciate your ccoperation in the matter.
Sincerely, l$&Wh#
Roger D. Walker, Director Division of Reactor Projects
Enclosure:
Synopsis of 01 Report 2-85-004 Sc w/ encl:
VE. M. Howard, Director td.SiteNuclearOperations F. McKee, Nuclear Plant Manager
. R. Westafer, Manager guclearOperationsLicensing and Fuel Management
,pecw/er' mPC Resias...t Inspector State of Florida Document Control Desk R
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This investigatior, was requested by NRC Region II on January 25, 1985, pursuant to a January 1985 Training Assessment (TA) inspection which disclosed that Florida Power Corporation (FPC) possibly violated Replacement Operator and Requalification regulations, commitments and requirements in a willful and deliberate manner at their Crystal River Nuclear Station (CRNS) training facility. According to the inspection results the files and records of FPC (licensee) personnel who received license training at the CRNS facility contained numerous discrepancies and deficiencies, including examination scores altered from failing to passing without explanation, ungraded examinations, incomplete train-ing documentation, missing and unsigned / undated records, illegible documents, inadequate and poorly maintained license training records and licensee certification letters to the NRC which contained inaccurate information and data not supported by specific documenta-tion.
Based upon these inspection disclosures, 0I was requested to determine the circumstances and extent of these discrepancies and to document any willful deliberate motives of the licensee to circumvent regulations and reouirements or to mislead the NRC in their decision making process regarding the issuance of Reactor Operator (RO) and Senior Reactor Operator (SRO) licenses.
During the investigation, NRC, Region II staff personnel discussed the significance of TA ir.spection disclosures and their potential for These officials willful, deliberate material false statements.
reiterated the NRC's concern regarding the licensee's intent relative to the documentation discrepancies noted during the TA inspection. A comprehensive review of twenty-two (22) current and former CRNS license training files and records, representing both ReplacementThis Operator and Requalificatic:t training activities was conducted.
activity identified extensive license training record discrepancies and deficiencies; confirming those revealed during the TA inspection and disclosing similar additional ones. After the file reviews, the individual license training participants, including R0 and SR0 c&ndidates and license training instructors, were interviewed separctely regarding their observations, experiences, impressions and activities in the license training programs.
Personnel who partic-ipated in Replacement Operator Training at the CRNS facility in 1983 and/or 1984 in preparation for the December 1984 NRC license examination reviewed their'NRC 398 forms (examination application) and reported they had completed all training activities listed therein.
Generally, these individuals were not fully cognizant of all license training regulations, requirements or commitments and were directed They claimed and guided in license training by the instructor staff.
they were unaware of discrepancies and deficiencies noted in their trairing files and excused them as inattentive and careless record The practice of altering exanination grades was ter ;.i r.g prac tices.
'M c as comonplace but for valid reasers such as challenges from cc-ca to matri errors, re-evaluatin c' ;. a t values or answer r;_
ci-ici(rcies.
Nor.c of these individuals u re aware of any
.,rieties regarding license training actisities by CRh5 training e.
lo c"1:icls.
Case No. 2-85-004 1
JAN 101986 Interviews of licensed operations personnel and~5Mft Technical Advisors / Operations Technical Advisors (OTA) were also conducted. The OTA personnel reported that to the best of their knowledge, they fully and completely participated in license training, bott in the new license and requalification pregrams. They also related * :;su discrepancies to careless administrative practices, inadequate examination process controls, ineffective supervision and general disorganization within the CRNS training facility and not, to their knowledge, from any deliberate, willful motives of training officials.
One OTA at the CRNS acknowledged that, although FPC had committed to utilize only " degreed" engineers in this program, he had the equivalency from the International Correspondence School.
He did not view this as a commitment violation because he had attained the equivalent of an engineering degree.
One Operations official was
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removed from license duties after the TA inspection revealed he was incorrectly assigned a passing grade on his 1984 requalificai. ion examination. Upon interview, this individual excused the error as inadvertent and claimed no knowledge of deliberate willful actions by CRh5 training officials to falsely certify satisfactory completion of recualification training.
License training officials, including current.and former instructors, supervisors and managers, who were generally candid and forthright in their discussions of license training matters, categorically denied willful, deliberate violations of regulations, requirements or commit-nents. One instructor acknowledged that he had not participated in required training prior to the issuance of his SRO license, notwithstanding tha fact that FPC certified the training had been completed. Although this individual was reportedly exempted from the on-shift training requirement no evidence to support this contention was disclosed during the investigation.
Instructors also reported that the content of their requalification training program differed fron other personnel in that they did not attend classroom training or take an annual examination.
Training officials concluded that instructors satisfied requalification training by teaching and by ad-inistering examinations to other participants.
Training officials c,;iained thct the apparent causes of the license training ce#iciencies were rismenagement, inadequate administrative controls, an apparent disregard for the record keeping process, inattentiver.:s and carelessness, and limited staff and administrative resources.
These individuals also related that FPC's interpretation of some license training requirements and licensee commitments differed from that of the NRC and this was reflected in the implementation aspects of the programs.
All license training officials categorically denied willful, deliberate improprieties regarding their affiliation with these activities and claimed good faith attempts to comply with all ruuirements and commitments.
. rate officials responsible for licer.se training matters defined r:les pertcir'r' tc this activity arr cenied any knowledge of u.c discre;r L'til they were reveelec
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iney further statt. 19t, notwithstandir:9 (n:es ir, it-irmpretations of sc i license training require-r;C has a k supported and has e:te n ted to provide all of the Case No. 2-E5 2
JAN.101986
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l i fe~n s e~ trit i M ngTpec i fi ed by regul ati ons and ~Bther~ appl i cabl e -
documents.
A training consultant employed by FPC after the NRC inspection to assist in the identification of license training deficiencies and to implement corrective measures, candidly discussed the results of his analysis and review of the license training programs.
He advised that, in his opinion, inadequate FPC training procedures, records mismanagement, communications deficiencies between the licensee and the NRC, superficial administrative practices by license training officials and an ineffective commitment tracking system have all contributed to the license training discrepancies. This individual stated unequivocally that he found no evidence during his review and analysis of willful, deliberate deviations from or violations of regulatory requirements or licensee commitments.
Following the interviews of CRNS personnel and corporate officials, applicable correspondence between the licensee and the NRC relating to license training matters was reviewed. Some correspondence contained licensee training commitments which had not been implemented consistent with NRC interpretations or which the licensee had failed to a complish. When confronted with these discrepancies, licensee trainine and corporate officials adamantly maintained that they had attempted to comply with all requirerrents and commitments as they understood them. These individuals stated emphatically that any commitments which had not been completed or accomplished were inadvertent omissions and were not deliberate actions to mislead or deceive the NPC. A review of licensee's Quality Program Deficiency Reports prepared after the January 1985 NRC inspection regarding license training deficiencies confirmed NRC findings but failed to identify any willful, deliberate violations of commitments and requirements.
Although the investigation confirmed the NRC inspection results and further revealed the presence of extensive discrepancies and deficiencies in FPC's license training program, there was no evidence developed to suppcrt willful and intentional actions by training or corporate officiels to violate applicable regulations or to deliberately provice false license training information to the ARC.
Case ho. 2-85-004 3