ML20236E558
| ML20236E558 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 07/21/1987 |
| From: | Wagner M NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Environmental Coalition on Nuclear Power, GENERAL PUBLIC UTILITIES CORP., NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| CON-#387-4124 CLI-85-19, LRP, NUDOCS 8708030007 | |
| Download: ML20236E558 (13) | |
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July 21,1987 '87 JUL 28 K0:59
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ii Note to: Parties to TMI-2 Leak Rate ~ xeeding L88 From: Mary E. Wagner Counsel for NRC Staff 4
Enclosed is a copy of a July 20, 1987 Memorandum from Victor Stello, Jr. to the Commissioners, containing the Staff's recommendations pursuant to the Commission's instructions in CLI-85-19.
t 0 Mary . Wagne(
Cou el for NRC Staff .
Enclosure:
As stated cc w/ encl.: Sheldon J. Wolfe '
Glenn O. Bright James H. Carpenter l
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MEMORANDUM FOR: Chairman Zech Commissioner Roberts Commissioner Bernthal Commissioner Carr FROM: Victor Stello, Jr.
Executive Director for Operations
SUBJECT:
STAFF RECOMMENDATIONS REGARDING INDIVIDUALS ASSOCIATED WITH THE LEAK RATE SURVEILLANCE TESTING IRREGULARITIES AT THI-2 Purpose To provide the Commission with recommendations regarding enforcement and licensing actions to be taken in connection with individuals associated with the pre-accident irregularities Reactor Coolant System (RCS) leak rate surveillance testing at THI-2.
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Background
In an order issued in the THI-1 Restart Proceeding, the Comission stated that '
it would institute a separate hearing, apart from.the Restart Proceeding, to develop the facts surrounding the reactor coolant system leak rate surveillance testing data falsifications at THI-2 prior to the March 28, 1979 accident "in sufficient detail to determine the ultimate status of those likely involved,"
- including those segregated from THI-1 and those now working at other facilities.
CLI-85-2, 21 NRC 282, 298-99 (1985).
In December 1985 the Comission issued an Order and Notice of Hearing initiating that proceeding, specifying the procedures to govern the separate hearing and identifying the steps to be taken, after ti.e Presiding Board has issued a recommended decision setting I forthbethe will facts, in taken. order for22the CLI-85-19, NRCCommission 877. to determine what action, if any, I
Specifically, the Commission in CLI-85-19 gave the following instructions to the NRC Staff:
On the basis of the Presiding Board's recommended decision and taking into account any other information which it believes is appropriate for Commission consideration, the NRC Staff shall make recommendations to the Commission regarding what action, if any, should oe taken. The NRC Staff is to provide its recommendations to the Commission within 60 days after issuance of the Presiding Board's decision. Those recommendations are to include whether the Commission should remove .
CONTACT: J. Lieberm&n, OE 492-8214 T. Murley, NRR 492-27691 W. Russell, RI 488-1299
1 The Commissioners JUL 2 01887 the condition imposed in the TMI-1 restart proceeding barring certain individuals from certain positions at TMI-1. CLI-85-19, 22 NRC at 883.
On May 21, 1987, after a hearing consuming 33 hearing days and resulting in over 5,000 transcript pages, the Presiding Board issued its Recommended Decision on leak rate surveillance testing data falsification at TMI-2. In sum, the Board found, first, that virtually all Operations Department personnel worked tions. under an erroneous interpretation of the leak rate technical specifica-NRC inspector, the licensee took inadequate corrective actio personnel on proper leak rate surveillance testing practices. Second, the Board found that there was a nearly unanimous lack of confidence in the computer-calculated test results, yet the tests were routinely submitted by Control Room Operators performance.(CR0s) and approved by Shift Foremen in "resarkably unprofessional" on line While operators felt a general sense of pressure to keep the plant they did not feel theyfalledtoobtain" that adverse actions would be taken against them if good"testresults.
Third, the Board found that fifty percent or more of the tests were discarded, with the knowledge of the CRO's, Shift Foremen, Shift Supervisors, Supervisor of Operations and Superintendent of Technical Support.1/ In addition, the Board found that many operators manipulated tests or falsified test results, that Shift Supervisors who did not personally participate in the tests were guilty of " culpab technical specifications and administrative procedures, and that the Supervisor of Operations for Unit 2 knew about the difficulties the operators were having with the leak rate surveillance tests and was also guilty of culpable neglect.
Finally,ofthe guilty Board neglect.
culpable found that2/ three other members of TMI-2 management were also In accordance with the Commission's instructions to the Staff in CLI-85-1 this memorandum contains the staff's recommendations to the Commission. 3/,
Discussion Enforcement Action 4
In considering possible actions regarding leak rate surveillance test data falsification at THI-2, the staff took into account the Board's Recommended Decision on leak rate surveillance testing data falsification at TMI-2, the !
joint Office of Nuclear Reactor Regulation (NRR) and Office of Investigations 1/
There were two Superintendents of Technical Support from January 1977 until The accident at THI-2.
Support from January 1977 until December 1978.This statement refers to the 2/
Theto referred Superintendent in n.1, supra. of Unit 2 and both Superintendents of Techn.ical Support 3/
hmments for consideration by the staff in making its recommendations were submitted on behalf of John G. Herbein and Gary P. Miller.
been considered. These comments have
I The Commissioners , ; ;; g i
(01) investigation and evaluation of ten operators involved in the leak rate surveillance testing irregularities, the Department of Justice (D0J) action i taken on THI-2 leak rate surveillance testing irregularities, the Commission's i guidance for enforcement action regarding individuals, and the statute of limitations for enforcement actions. For the reasons discussed below, the staff recommends that no further enforcement action be taken against the facility licensee or tu 35 individuals, formerly at THI-2, regarding leak rate surveillance testing irregularities at that facility.
In reaching its conclusion that further enforcement action is not warranted, the staff relied primarily on the Commission's policy regarding enforcement action aoainst individuals and the Recommended Decision of the Board. Among other thlngs, the Guidelines on Enforcement Action Against Individua!s, enclosed with this memorandum, set forth the policy that the NRC should defer to the lice See in the supervision of operators but should take action against licensed werators when their actions result in significant violations of HRC requirements involving incompetence or willfulness or where it appears I operators are not competent to safely perform their duties. Such sn approach places primary responsibility for operator errors where it belongs -- with the facility licensee which is responsible for operator training and for developing adequate procedures to govern facility operations.
The Board found that some CR0s manipulated and falsified leak rate surveillance test results. The Board also found that the operators were faced with a grossly inadequate surveillance system and that there was a universal lack of confidence in the surveillance test results among the operators. 4/ More importantly however, the Board found that all of the Shift Supervisors and Foremen were, negligent in failing to ensure the proper performance of leak rate surveillance testing by those they supervised and that the greater responsibility for what went wrong with leak rate surveillance testing at TMI 2 rests with the Supervisor of Operations more than any other single individual. The Board found that the Supervisor of Operations had overall responsibility for seeing to it that the leak rate surveillance testing was conducted correctly and that the unit was operated in accordance with the Technical Specification limit for unidentified leakage. The Board found that the conclusion is inescapable that the lack of meaningful training was a major cause of the problems with leak rate surveillance testing at THI-2. When the operators' actions are balanced against the management shortcomings regarding procedures and training, the
. appropriate object of NRC enforcement clearly would be the facility licensee.
4/ NRR, in the joint 01/NRR investigation and evaluation of ten licensed !
l "6perators, also concluded that most operators did not consider the test to be a i true measure of actual plant leakage. NRR further concluded that based on post-accident evaluation of the leak rate surveillance test procedure, the operators were correct. NRR believes that many instances occurred 'where leak rate surveillance test results were in excess of the technical specification :
I limits, the yet the specification technical actual unidentified limit. leakage did not exceed 1 gallon per minute, i
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The Commissioners JUL 2 01987 In reaching its recommendation regarding enforcement action against individual operators, the staff also considered the time that has passed since the leak rate surveillance testing irregularities and since the restriction regarding THI-2 operators in THI-1 restart conditi, n No. I has been in place, the awareness of both the involved individuals as well as the industry that has resulted from the NRC attention and publicit 01/NRR -1985 investigation and evaluation of ten y givenoperators licensed this matter, the joint.
involved in
^ THI-2 pre-accident leak rate surveillance testing irregularities (April 1,1986 Staff report to the Commission) and the fact that 00J declined to prosecute any of the operators investigated in the joint OI/NRR investigation and evaluation.
5/ The NRR evaluation made findings similar to those of the Board in that a root cause of the problem laid squarely with management shortcomings regarding procedures and training. The NRR evaluation specifically recommended that no enforcement action be taken against the ten operators it had evaluated and there is nothing6/in the Board s decision to cause the staff to revise that recommendation. Eight of the pre-accident individuals are currently licensed operators at TMI-2 and one is a licensed operator at San Onofre.
The staff believes the D0J action taken regarding the TMI-2 leak rate surveillance testing irregularities is sufficient enforcement action against the facility licensee. This action consisted of an indictment and subsequent conviction of the licensee in accordance with the plea agreement accepted by the U. S.
District Court for the Middle District of Pennsylvania on February 29, 1984.
Metropolitan Edison, the licensee at the time of the accident and the predecessor licensee to GPU Nuclear, pleaded guilty to one count of the indictment charging it with failure to establish, implement, and maintain an accurate and meaningful reactor coolant system water inventory balance procedure to demonstrate that unidentified leakage was within the allowable limits. The licensee also pleaded no contest to six other counts of the indictment, including those which charged the licensee with improper manipulation of TMI-2 leak rate surveillance tests to generate results that would fulfill the licensee's license requirements.
In summary, for the reasons discussed above the staff does not believe that the past involvement of certain individuals rega,rding THI-2 leak rate surveillance 5/ As the result STTommission Mettings on March 23, 1984 and May and NRR were directed to jointly investigate if ten of the eleven individuals-23, 1984 0 licensed at the tiae of the investigation had any role in the pre-accident leak rate surveillance 3esting irregularities. The OI Report of Investigation was -
forwarded to D0J, which declined prosecution.
6/ The placed in NRR evalu4 tion also recommended that five of the ten operators be a )tobationary status until expiration of their current licenses. ]
Because of tse Commission's action instituting a hearing on the matter, no NRC action regardin,) thy recommendation was taken. Subse two of- the five opeoators terminated their licenses. quent to the NRR report, GPU Nuclear, on its own, 3
4 instituted discipli ary9 action against the remaining three operators and the other pre-accident licensee. TMI-2 operators, supervisors, and managers employed by the
. 8 The Commissioners JUL 2 01987 testing irregularities warrants enforcement action. Accordingly, the staff recommends that no additional enforcement action be taken regarding this matter. 7/ However, the staff remains concerned regarding the former Supervisor of OperaIions' suitability for duty in connection with NRC licensed activities.
This concern is addressed below.
The Condition Barring Certain Individuals From Certain Positions At THI-1 The Board findings indicate that virtually all Operations Department personnel !
worked under an erroneous interpretation of the leak rate technical specification and most of the personnel had some degree of culpability regarding leak rate surveillance testing irregularities or falsification. The performance of 10 pre-accident individuals employed as licensed operators in 1985, as documented in the April 1,1986 staff report to the Commission, appears to demonstrate that they now can be relied upon to conform with procedural and regulatory requirements.
The current performance of the remaining 25 individuals, 24 of whom were not licensed at the time of the joint OI/NRR investigation, has not been evaluated in the same detail, or in some cases, at all. 8/ However, there are other considerations which justify lifting the THI-l' restart condition at this time on all individuals except the pre-accident THI-2 Supervisor of Operations and those individuals employed in the THI-2 Site Operations Department as of July 9, 1987.
The importance of the leak rate surveillance testing issue has certainly been driven home for those involved at TMI. Im in the measurement procedures, techniques,provements calculationalsince the THI-2 methods, and aaccident clear understanding of the technical specification requirements establish a signifi-cantly improved basis for correctly performing this routine task. 9/ GPU Muclear has made significant and substantial changes in sanagement~and operating practices since the accident at THI-2 which are rereted in high SALP evaluations. Additionally, all individuals to be used in a licensed operator position would be subject to the normal licensing process required by the NRC regulations.
7/ The staf f considered the impact of the statute of limitations 28 U.S.C. ,
2462, on the Commission's ability to take enforcement actions regar, ding matters J that occurred in 1978 and 1979. Whether or not the statute would preclude enforcement action at this time regarding the THI-2 leak rate surveillance 1 testing irregularities was a matter the staff did not have to reach because i of its conclusion that further enforcement action is not warranted.
8/ Thirty-five individuals are subject to the THI-1 restart condition No.1 Ghich bars them from certain positions at THI-1. The Board essentially exonerated 9 of the 35 individuals. Of the remaining 26, the staff conducted interviews with the supervisors of those individuals who are currently employed by licensees in licensed activities (GPU Nuclear and one by Southern California Edison Co.). No staff evaluation has been made of the current performance of the remaining individuals.
9/ The Office of Nuclear Regulatory Research has been tasked to update the llegulatory Guide regarding leak rate surveillance.
The Commissioners
..: ;~"W Although there is no absolute assurance that reemployment of the pre-accident individuals at TMI-1 within the present management or operational structure will not adversely affect continued safe operation of the plant, such absolute assurances do not exist for any individual employed by GPU Nuclear or by any other licensee. Instead, the licensee's management of licensed activities and compliance with Commission requirements and the NRC's oversight of these activities provides the reasonable assur,ance of safe operation. Noncompliance with Commission requirements by pre-accident individuals'that may occur in the future will be addressed by appropriate NRC action. Given the time that has passed and the fact that the leak rate surveillance testing irregularities directly flowed from management shortcomings in training and procedures, there ,
is no clear reason for not lifting the restriction in restart condition No.1 for all individuals except James r~loyd and, as explained below, a group presently employed at TMI-2, and treating those individuals released from the restart ,
condition the same as other current or potential employees in responsible {
j management or operational positions at TMI-1.
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James R. Floyd to the concluslon made regarding the other pre-accidentThe individuals.t Board concluded that Mr. Floyd bore greater responsibility for what went wrong with leak rate surveillance tests at TMI-2 than any other single individual. Further-more, the Board found that Mr. Floyd was not fully forthcoming and candid before the Board and noted many conflicts between Floyd's testimony and the evidence in the record.10/ Also, Mr. Floyd has been convicted for making material false statements. ~711 of this reasonably calls into question Mr. Floyd's present suitability for duty in connection with NRC licensed activities. Thus, in the case of former TMI-2 Supervisor of Operations, James Floyd, the staff does not find sufficient reason to remove the TMI-1 restart condition. Accordingly if GPU Nuclear proposes in the future to employ Mr. Floyd in a responsible man, age-ment or operational position at TMI-1, specific NRC approval should still be required.
The group of pre-accident individuals employed in the Site Operations Department as of July 9,1987 at TMI-2 (8) is the second exception to the staff conclusion made regarding the pre-accident individuals. In the process of forming its ;
recommendation, the staff received information regarding allegations of sleeping :
while on duty at TMI-2 that calls into question the current performance of one l or more of the pre-accident individuals in the TMI-2 Site Operations Department.
The staff requires additional time to evaluate this matter and assess its effect, if any, on the staff's recommendation regarding the pre-accident individuals in the TMI-2 Site Operations Department. For this reason, the staff is unable to l' recommend removal of the TMI-1 restart condition for this grcup at this time.
10/ The Board also made negative comments regarding the credibility of at least Diree other individuals, but stopped short of finding that the individuals deliberately misled the Board. In the staff's view, the evidence available regarding these individuals, although sufficient to raise questions' regarding their credibility on remembering facts a number of years old, is not sufficient to conclude that they deliberately misled the Board. Therefore, no further action is appropriate.
The Commissioners JUL 2 01987 In summary, the staff recomends removing TMI-1 restart condition No.1 for 26 of the 35 individuals subject to that condition. Cutrently any of the 35 individuals may I hired by any licensee but may not be hired by GPU Nuclear for responsible management or operational positions at TMI-1 without NRC pre-approval. Lifting this restriction extends their eligibility for employment at THI-1. It is expected, as in the case of any candidate for employment in connection with licensed activities, that GPU Nuclear would make an appropriate suitability determination including the screening required for access to vital and protected areas, if it decided to reemploy any of the individuals.
Recommendation:
That the Commission not take further enforcement action regarding the pre-accident let.k rate surveillance testing irregularities at THI-2.
That the Commission issue a Memorandum and Order revising the THI-1 restart condition No.1 in CLI-85-02, 21 NRC 282, at 341-342 to read:
No pre-accident THI-2 operator, shift supervisor, shift foreman, or any other individual both in the operating crew and on shift for training as a licensed operator at TMI-2 prior to the accident and who was employed in the TMI-2 Site Operations Department as of July 9,1987 shall be employed at THI-1 in a responsible management or operational position without specific NRC approval.
This condition shall also apply to the pre-accident TMI-2 Supervisor of Operations. " Operational Position" as used here includes any position involving i actual operation of the plant, the direction or supervision of operations, or independent oversight of operations.
i Coordination:
OGC has reviewed this action and has no legal objection to the recommendation, w '
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- ictorSt'ello,Jr.
l Executive Director for Operations
Enclosure:
As stated
The Commissioners JUL 2 0 1987 DISTRIBUTION:
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EGM 86-05 MEMORANDUM FOR: T. Murley, Regional Administrator, RI N. Grace, Regional Administrator, RI! I J. Keppler, Regional Administrator, RIII R. Martin, Regional Administrator, RIV J. Martin, Regional Administrator, RV '
FROM: James M. Taylor, Director Office of Inspection and Enforcement
SUBJECT:
GUIDANCE FOR ENFORCEMENT ACTIONS REGARDING INDIVIDUALS PURPOSE:
As indicated by the Connission in its memorandum of September 17,1986 from
- 5. Chilk to V. Stello, this guidance has been approved by the Connission for use by regional offices when considering enforcement actions against individuals in connection with violations of NRC requirements at NRC-licensed power reactor facilities.
It is intended to reflect the importance the NRC places on 'high standards of performance by power reactor facility staff and to outline when enforcement action against an individual should be considered.
) BACKGROUND:
The staff has been developing for some time guidelines for when actions against individual operators should be taken. Since the question of actions against individuals was one of the issues referred to the Enforcement Advisory Connittee, !
the staff was waiting for the Connittee's report before putting the guidelines !
in final form. The guidance and the principles upon which it is based are described below. !
Generally, the agency's philosophy in this area has been that the primary responsibility for safe operation of a facility is on the facility license holder.
The facility licensee is expected to take appropriate remedial action when misconduct occurs including action to prevent its recurrence. If the facility licensee fails to discipline, retrain, or reassign an unsatisfactory operator, the NRC can take appropriate enforcement action against the facility licensee.
Despite this philosophy, the NRC does issue licenses to operators and has many regulations that recognize that timely actions by NRC-licensed individuals are an important part of safety. Specifically, the regulations state that: ,
Generally, only licensed operators are permitted to manipulate "the controls that directly affect reactivity (10 CFR 50.54(1)),
Licensed operators must be operation of the facility (present at the controls at al.1 times during the 10CFR50.54(k)),
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Regional Administrators , EGM 86-05
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- Mechanisms and apparatus, other than controls, the operation of which may indirectly affect the power level or reactivity of a reactor, may be manipulated only with the knowledge and consent of an operator licensed in accordance with Part 55 (10 CFR 50.54(j)),
Licensed senior operators must be present at the facility during specified conditions, and a.'a11able or on call at other times during operation (10 CFR 50.54(m)), and An NRC licensed individual must observe all applicable rules, regulations and orders of the Comission, whether or not stated in the license (10CFR55.31(d)).
The NRC has taken actions against individual licensed operators in certain instances where misconduct occurred. Generally, the staff policy has been that the NRC should defer to the licensee in the supervision of operators but should take action directly against licensed operators when their actions result in significant violations of NRC requirements involving incompetence or willfulness or where it appears operators are not competent to safely perform their duties.
Such an approach places primary responsibility for operator errors where it belongs - with the facility licensee which is responsible for operator t. fining and for developing adequate procedures to govern facility operations.
DISCUSSION:
Since enforcement actions against individuals are significant personnel actions, they should be closely controlled and judiciously applied. An enforcement action should be taken only when there is little doubt that the individual fully understood, or should have understood, his or her responsibility; knew, or should have known, the required actions; and knowingly, or with careless disregard (i.e., with more than mere negligence) failed to take required actions which have actual or potential safety significance. Most transgressions of individuals at the level of Severity Level III, IV or V violations can and should be handled by citing only the facility licensee.
More serious violations, including those involving the integrity of an individual (e.g., lying to the NRC) concerning matters within the scope of the individual's against the responsibilities, individual. Actionshould be considered for enforcement action against the individual, however, should not be taken if the improper action by the individual was caused by management failures. t The following examples of situations illustrate this concept:
Inadvertent individual mistakes resulting from inadequate training or guidance provided by the facility licensee.
Inadvertently missing an insignificant procedural requirement when the -
action is routine, fairly uncomplicated, and there is no unusual circumstance indicating that the procedures should be referred to and followed step-by-step.
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- Compliance with an express direction of management, such as the Shift Supervisor or Plant Manager, resulted in a violation unless the individual did not express his or her concern or objection to the direction.
Individual error directly resulting from following the technical advice -
of an expert unless the advice was clearly unreasonable and the licensed individual should have recognized it as such.
Violations resulting from inadequate procedures unless the individual used get a procedure the faulty procedure knowing it was faulty and had not attempted to corrected.
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Examples of situations which could result in enforcement actions against individuals include, but are not limited to, violations which involve:
Recognizing corrective a violation of procedural requirements and willfully not taking action. )
Willfully systems. perfonning unauthorized bypassing of required reactor safety Willfully defeating alarms which have safety significance.
- l Unauthorized abandoning of reactor controls.
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- Inattention to duty such as sleeping or being intoxicated while on duty.
I Willfully taking actions that violate TS Limiting Conditions for Operation.
Falsifying licensee. records required by NRC regulations or by the facility Willfully failing to take "innediate actions" of emergency procedures.
Willfully withholding safety significant information rather than making such infonnation known to appropriate supervisory or technical personnel.
Any proposed enforcement action against individuals should be done with the concurrence of the Director, Office of Inspection and Enforcement. The Director, Enforcement Staff, Office of Inspection and Enforcement should be notifiedagainst action as soon anasindividual.
any violation is identified that may lead to enforcement The opportunity for a enforcement Conference with the individual should be provided and a headquarters Enforcement Staff member should be involved.
Sanctions Examples of sanctions that may be appropriate against NRC-licensed operators are:
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- issuance of a letter of reprimand to be placed in the operator's license file.
- issuance of a Notice of Violation, and 1
suspension for a specified period, modification, or revocation of the license.
i The sanctions are listed in escalating order of si The particular sanction to be used should be determined on a casegnificance. by-case basis.
In the case of an unlicensed individual, an Order modifyirg the facility license to require the removal of the individual from all nuclear-related activities for a specified period of time or indefinitely may be appropriate.
St# MARY In sumary, enforcement action against individual NRC-licensed operators should be operator.
used for serious misconduct such as that involving the integrity of an Enforcement action against individuals, as for any enforcement action, should be taken as soon as possible after the offending act for the l action to be effective. Because enforcement actions against individuals are {
i significant personnel actions, they should be considered on a case-by-case basis to determine the most appropriate sanction for the particulars of the case under consideration. Ir. determining whether to take simultaneous enforcement action against a significant number of NRC-licensed operators at the same facility, sufficient optiores exist such that the consideration for proper staffing of the facility should not prevent taking the appropriate action.
Nonetheless, in all cases, the standard for measuring any action taken is the effect the action will have on assuring continued protection of the public health and safety or the comon defense.
This Chapter policy will be incorporated in a future revision to the IE Manual 0400. I
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s M. Taylo Director cc: J. Lieberman, OGC Enforcement Staff e-I
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