ML20148P589

Notice of Violation from Insp on 860127-0214.Violations Noted:Practical Abilities of Chemistry Technicians Demonstrated by Open Book Exams Rather than by Use of Procedure Checkout Guidelines

ML20148P589
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	03/28/1988
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20148P582	List: ML20148P589
References
50-322-86-03, 50-322-86-3, EA-87-173, NUDOCS 8804110317
Download: ML20148P589 (7)

Text

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NOTICE OF VIOLATION Long Island Lighting. Company Docket No. 50-322 Shoreham Nuclear Power Station License No. NPF-36 EA 87-173 During an NRC inspection conducted on January 27 - February 14, 1986, and subsequent investigations conducted by the NRC Office of Investigations, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR 2, Appendix C (Enforcement Policy) (1987), the violations are set forth below:

A. Technical Specification 6.4, "Training", requires, in part, a r.' raining and replacement program for the station staff be maintained under the Training Supervisor that meets or exceeds the requirements of Section 5 of ANSI N18.1 - 1971. ANSI N18.1 - 1971, Section 5, establishes requirements for training radior.hemistry technicians.

Procedure SP No. 71.006.01, written pursuant to the requirements of Technical Specification 6.4, requires that individual technicians demon-strate practical abilities by either following procedure checkout guidelines or through technician task evaluation guides.

Contrary to the above, as of February 1986, the practical abilities of chemistry technicians were demonstrated by open book exams rather than by the use of procedure checkout guidelines or through the use of task evaluation guidelines.

B. Technical Specification 6.3.1, "Unit Staff Qualification", requires, in part, that each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1 - 1971 for comparable positions. ANSI N18.1

- 1971 requires that repairmen in responsible positions shall have a minimum of three years in one or more crafts.

Contrary to the above, as of February 1986, radiochemistry technicians, repairmen in responsible positions, routinely performed electrical repair maintenance on electronic equipment of the Radiation Monitoring System, including safety related equipment, without any training or previous background in the electronics craft.

l l C. Technical Specification 6.8.1.a, "Procedures and Programs", requires that

[ written procedures be established, implemented and maintained covering the l

activities of Appendix "A" of Regulatory Guide 1.33, Revision 2, February, 1978. Appendix "A" of Regulatory Guide 1.33 requires chemistry and radiochemistry procedures.

8804 0 PDR G OFFICIAL RECORD COPY PROP EA SHOREHAM - 0007.0.0 03/25/88

2 f

Chemistry Procedure SP 78.011.38, "Chloride Analysis, Specific Ion Electrode Method", written pursuant to the requirements of Technical Specification 6.3.1.a, requires the use of control charts for plotting ,

results of control standards for chloride analysis which is required by the Technical Specifications. ,

Contrary to the above, between November, 1985 through February, 1986, control charts for plotting results of control' standards for chloride analysis which were required by the Technical Specification were not used.

D. Technical Specification 6.8.1.d requires that written procedures be established, implemented, and maintained covering surveillance and test activities of safety-related equipment.

Station Procedure SP No. 74.631.17, "RBSVS Normal Range Radiation Monitor Functional Test" written pursuant to the requirements of Technical Speci-fication 6.8.1.d, requires that procedural steps on the surveillance of certain safety related equipment be initialed off as they are performed.

. Contrary to the above, o, November 21, 1985, surveillance testing of Panel 21 of the safety-related Reactor Building Standby Ventilation System was initiated, and

1. the procedure was signed of f as complete, by a Nuclear Chemistry Technician, even though he had not completed and initialed all the procedural steps; ar.d

2. the procedural steps were subsequently initialed by a Radiochemistry Foreman using the initials of the Nuclear Chemistry Technician, and these procedural steps had not been performed. 7 E. Appendix "B" to License NPF-36 incorporates New York State Discharge Permit No. 0026344. The New York State Discharge Permit No. 0026344 requires that water samples from Outfalls 002 and 003 must be collected -

during the middle and end of each month for analysis. Section 5.2 of i Appendix "B" requires that records and logs relative to environmental aspects of facility operation shall be made and retained in a manner convenient for review and inspection.

Contrary to the above,

1. water samples were not collected for Outfalls No. 002 and 003 in  ;

mid-December, 1985; and ,

l 2. when it was discovered in January, 1986 that no mid-December, 1985 l sample was available for analysis, a sample from a different l

collection was analyzed and its results were recorded in a discharge  ;

{ log as results of water samples from mid-December,1985.  ;

l t

t 0FFICIAL RECORD COPY PROP EA SHOREHAM - 0008.0.0 l 03/28/88

3 These violations are categorized in the aggregate as a Severity Level III problem (Supplements I and IV).

Pursuant to the provisions of 10 CFR 2.201, Long Island Lighting Company is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.

20555 with a copy to the Regional Administrator, Region I, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the result achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order may issued to show cause why the license should not be modified, suspended, or revoked or why such action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown.

FOR THE NUCLEAR REGULATORY COMMISSION Or!cin21 signed Bv n::L:1: ?. L1J3 LL William T. Russell Regional Administrator Dated ah King of Prussia, Pennsylvania thisM__5_dayofMarch1988 OFFICIAL RECORD COPY PROP EA SHOREHAM - 0009.0.0 03/28/88

SYN 0PSIS This investigation was initiated following the receipt of a. written request, dated February 10, 1986, from the Regional Administrato'- (RA), Region I. The Office of Investigations (01) was asked to determine the circumstances surrounding the forgery of Station Procedure (SP) No. 74.631.17 by a radio-chemistry foreman in the Radiological Controls Division (RCD) at the Shoreham Nuclear Power Station (SNPS), Wading River, New York, in November 1985. SNPS is owned by the Long Island Lighting Company (LILCO).

An alleger telephonically contacted Region I on January 17, 1986, to disclose several concerns regarding the RCD at SNPS. The alleger's complaints focused upon the use of unqualified personnel, inadequate training of technicians, the forgery of a test record, and the falsification of an environmental water sampling report. Duringi&uary and February 1986, Region I personnel con-ducted an inspection of the RCD which addressed the technical concerns raised by the alleger. The investigation involving the forgery of a test record is reported herein but the alleged falsification of an environmental water sampling record is addressed in a separate Report of Investigation, 0! Case No. 1-86-008.

The alleger was interviewed and said he overheard a nuclear control technician (NCT) tell an unidentified third person that a radiochemistry foreman forged his (NCT's) initials upon an incomplete SP. This investigation disclosed that the NCT was following certain steps setforth in the aforementioned SP while conducting tests on panel 21. This panel is part of the "safety-related" Reactor Building Standby Ventilation System (RBSVS) and is connected to panel 808 in the SNPS control room. According to the SNPS Systems Description, panel 21 provides "Radiation level indication and alarm functions..." for the RBSVS.

The NCT professed that he was testing panel 21 on November 21, 1985, when he encountered problems. Before running into trcuble, he had prematurely and improperly signed the SP as being complete when, in fact, he had not finished several procedural steps and did not insert his initials in the designated spaces. He said that he intended to complete the job the next day. On November 22, the NCT discovered that panel 21 was "tagged out" for modifica-tion so he returned the SP to his supervisor, the Radiochemistry Foreman, because work on the panel had been delayed indefinitely. On December 2, 1985, the NCT happened upon the document and realized that someone forged his initials next to the 18 procedural steps he hadn't finished. He immediately reported this apparent forgery to a forenan sitting nearby and to the Acting Radiochemistry Engineer. On December 17, 1985, the NCT completed his examina-tion of panel 21 using a different SP. On or about February 2,1986, tne NCT told the Radiological Controls Division Manager and the Plant Manager about the forgery. The Plant Manager subsequently suspended the Foreman pending completion conducted by of its Ol's investigation consultant, andNuclear Hydro LILCO's internal Inc.

Services, inquiry (HNSw)hich

. was Case No. 1-86-003 1

Furthermore, this investigation disclosed that the Acting Radiochemistry Engineer had conf ronted the Radiochemistry Foreman shortly af ter learning of the incident on December 2,1985, at which time the Foreman admitted to the forge ry. However, the Acting Radiochemistry Engineer did not inform his superiors about the forgery claiming he was unable to find an opportunity to do so.

When interviewed by 01, the Radiochemistry Foreman admitted forging the document on November 26 or 27,1985, while sitting in his office at SNPS. At that time, he only "assumed" that the NCT's work on panel 21 had been comoleted.

On May 12,1986, LILC0 permanently terminated the Foreman's employment because of his participation in this wrongdoing.

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Case No, 1-86-003 2

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SYNOPSIS

-This investigation was initiated follnwing the recaipt of a. written eaquast, dated February' 10,1986,-from the Ragional Administrator (PA), Region I. The Office of Investigations (01) was asked to datemire the circunstances surrounding the falsification of an environrantal water samplino report by personnel from the Radiological Cnntrols Divisinn (RCD) at tha Shorehan Nuclear Powar Station (SNPS), Unit 1, Wading River, New York, in January 1986.

SNPS is owned by the Long Island Lighting Company (LILCO).

An allager telephonically contacted Racinn I on January 17, 1986, to disclosa several concerns regarding the RCD at SNPS. Tha allegar's complaints focusad upon the use of unqualified personnel, inadequate training of techniciars, tha forgary of a test record, and the falsification of an environnental watar sampling report. Durina January and February 1986, Ragion I personnal con-ducted an inspection of the RCD which addrassed the tachnical conrarrs raisad by tha alleger. The investigation involving the falsification of an anviron-nantal water sanplina report is addressed herein but the forgary of a test record is addressad in a separate Report of Invastigation, 01 Casa No. 1-86-003.

The allegar was intarviewed and said ha was told by a Fuclaar Centrol Tachnicie.r (NCT) that*a Radiochar.istry Foranan (RCF) instructad two other NCTs to falsify tha SNPS December /1985 State Pollution Discharga Elimination Systen (SPDES) report. The 290ES report contains tha rasults of tha tinaly collactinn-ard analyzation of watar samples from SNPS cutfalls 002 and 003. This function is required by their (SC Facility Operating Licansa No. NPF-36 and by Discharna Pamit Nn. NY-00263447which wae issued to SNPS by the Ste+e of Naw York.

Watar samplas must ha'tollected during tha niddle and tha end n' a?ch nnnth.

Outfalls 002 and 003 are pipes which anpty into tha SNPS intake canal which in turn f1rws into long Psland Sound. The NCTs, who had the spre RCF, ware interviewed separately on Fabruary 26, 1986. Each said they notified tha RCF on January 8, 1986, that no water samples wera collected for mid-Decanbar 1085.

Without the knowledge of the othar, one NCT visited the RCF and one NCT called hin on the phone since both wanted to knew how to account for tha rissing

nid-Dacembar water samples on the Dacamber/1985 SPDES repert. Tha RCF told one NCT to "invent ona" and the other to "naka soma."

l Rather than fabricate figures for tha report, the NCTs decided tn analyze old l Novanber 1985 water sanples in place of the uncollacted mid-Decambar serplas.

l Whan follrwing the improper instructions of PCF, tha NCT who fillad out tha

! nacessary documents, falsifiad a SPDES ina and tha Dacanbar/1985 SPDES raport hy omitting tha sanola nucher, and tha date the old Novanbar 1985 watar earnie was actually enllectad. The RCF, who was suspardad without pay by LILCO nn Fabruary P1, 1986, declined to na interviewed upon tha advica of his attornav.

He did subnit two saparate handwrittan statements to LILCO indicatino that ha aave nn such impropar instructions. Fowavar, tha two NCTs, a Shi#t Tachrician, l and anothar RCF, tastifiad that tha RCF intantionally diractad his tubnedinatas l to usa falsa data for the Dacambar/1985 SPDES raport.

This irvastigation detamirad that LILCO did not forward tha SPDES raports

M r Decamber 1985, January 1986, and February lop 6 to Naw York Stata until l March 1986. At that t'ra, the Dacarber/1985 SPDES report had baan correctad l and the nrecompliance was disclosed to Naw York Stata in a crvar letter from i

Case No. 1-86-008 1

LILCO. Therefore, LILCO did not submit a false documant to New York State.

• However, becausa the NCT falsified a SPDES log and the Decamber/1985 SPDES report at the direction of her P.CF, the licensee did not operate its facility in accordance with NRC Facility Operating License No. NPF-36.

On May 12,1986, LILC0 maragement parmerently terminated the RCF's employnant because of his participscion in this wrongdoing.

Case No. 1-86-008