ML21055A001
| ML21055A001 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/24/2021 |
| From: | Anton Vegel NRC/RGN-IV/DRP |
| To: | Franssen R Entergy Operations |
| References | |
| 4-2019-021, EA 20-125 IR 2020016 | |
| Download: ML21055A001 (10) | |
Text
February 24, 2021 EA-20-125 Mr. Robert Franssen Site Vice President Entergy Operations, Inc.
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION- NRC INSPECTION REPORT 05000416/2020016 AND INVESTIGATION REPORT 4-2019-021
Dear Mr. Franssen:
This letter refers to the investigation completed on September 14, 2020, by the U.S. Nuclear Regulatory Commission (NRC) Office of Investigations at the Grand Gulf Nuclear Station. The investigation was conducted, in part, to determine if a licensee employee (exam proctor) willfully provided inappropriate assistance to engineering students, contrary to plant procedures. provides a factual summary of the basis for the NRC concern that willfulness was associated with the apparent violation of NRC requirements in this case. This issue was discussed with you and other members of your staff during a telephone conversation on February 2, 2021.
Based on the results of this investigation, one apparent violation was identified and is being considered for escalated enforcement action in accordance with the NRC Enforcement Policy.
The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The apparent violation involves Title 10 of the Code of Federal Regulations (10CFR) Section 50.120, which requires, in part, that each holder of an operating license shall implement a training program derived from a systems approach to training that provides for the training and qualification of engineering support personnel. The circumstances surrounding the apparent violation, the potential significance of the issue, and the need for lasting and effective corrective action were discussed with you on February 2, 2021. Further details regarding this apparent violation are documented in Enclosure 2 to this letter.
Before the NRC makes its enforcement decision, we are providing you an opportunity to:
(1) respond to the apparent violation addressed in this inspection report within 30 days of the date of this letter, or (2) request a Pre-decisional enforcement conference (PEC). Although the use of alternative dispute resolution (ADR) should normally be offered for cases that fall within the programs scope, the staff may, with the prior approval of the Director, Office of Enforcement, decide not to engage in ADR with a licensee if the issue is of a similar type previously addressed in ADR and the staff believes that an additional ADR is not an effective
R. Franssen 2 means to resolve the issue. Therefore, in consultation with the Director, Office of Enforcement, ADR will not be offered in this case.
If a PEC is held, the NRC will issue a press release to announce the time and date of the conference; however the PEC will be closed to public observation since information related to an Office of Investigations report will be discussed and the report has not been made public. If you decide to participate in a PEC, please contact Mr. Jason Kozal, Chief, Projects Branch C, at 817-200-1144 within 10 days of the date of this letter. A PEC should be held within 30 days of the date of this letter.
If you choose to provide a written response, it should be clearly marked as a Response to An Apparent Violation in NRC Inspection Report 05000416/2020016; EA-20-125 and should include for the apparent violation: (1) the reason for the apparent violation or, if contested, the basis for disputing the apparent violation; (2) the corrective steps that have been taken and the results achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response.
Additionally, your written response should be sent to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Director, Division of Reactor Projects, U.S. Nuclear Regulatory Commission, Region IV, 1600 E. Lamar Blvd., Arlington, TX 76011-4511, to the NRC Resident Inspector at the Grand Gulf Nuclear Station, and emailed to R4Enforcement@nrc.gov within 30 days of the date of this letter. If an adequate response is not received within the time specified or an extension of time has not been granted by the NRC, the NRC will proceed with its enforcement decision or schedule a PEC.
If you choose to request a PEC, the conference will afford you the opportunity to provide your perspective on these matters and any other information that you believe the NRC should take into consideration before making an enforcement decision. The decision to hold a PEC does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. This conference would be conducted to obtain information to assist the NRC in making an enforcement decision. The topics discussed during the conference may include information to determine whether a violation occurred, information to determine the significance of a violation, information related to the identification of a violation, and information related to any corrective actions taken or planned.
In addition, please be advised that the number and characterization of the apparent violation described in Enclosure 2 may change as a result of further NRC review. You will be advised by separate correspondence of the results of our deliberations on this matter.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter, its enclosures, and your responses, if you choose to provide them, will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs ADAMS, accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.
However, you should be aware that all final NRC documents, including the final Office of Investigations report, are official agency records and may be made available to the public under the Freedom of Information Act, subject to redaction of certain information in accordance with the Freedom of Information Act.
R. Franssen 3 If you have any questions concerning this matter, please contact Mr. Jason Kozal of my staff at 817-200-1144.
Sincerely, Anton Digitally signed by Anton Vegel Vegel Date: 2021.02.24 08:54:46 -06'00' Anton Vegel, Director Division of Reactor Projects Docket No. 05000416 License No. NPF-29
Enclosures:
- 1. Factual Summary
_SUNSI Review: ADAMS: Non-Publicly Available _Non-Sensitive Keyword:
By: JGK _ Yes No _ Publicly Available Sensitive OFFICE ES:ACES TL:ACES C:DRP/PBC RC OE NRR NAME PJayroe JGroom JKozal DCylkowski Jperalta GSuber SIGNATURE /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E /RA/ E DATE 01/29/21 01/29/21 02/01/21 02/01/21 02/17/21 02/22/21 OFFICE OGC D:DRS D:DRP NAME RCarpenter RLantz AVegel SIGNATURE /NLO/ E /RA/ E /RA/
DATE 02/17/21 2/23/21 2/24/21 FACTUAL
SUMMARY
OFFICE OF INVESTIGATIONS REPORT 4-2019-021 On September 19, 2019, the U.S. Nuclear Regulatory Commission (NRC) Office of Investigations (OI) Region IV initiated an investigation to determine if a senior engineering training instructor employed by Entergy Operations, Inc. (licensee) working at the Grand Gulf Nuclear Station (GGNS), willfully compromised an exam by providing additional information during an engineering support qualification exam in the form of diagrams and verbal cues. The investigation was completed on September 14, 2020.
On July 11, 2019, the instructor proctored an engineering qualification exam for an engineering student. After the exam, the student reported to a licensee supervisor that the instructor provided inappropriate assistance during the engineering qualification exam. Specifically, the student reported that the instructor directed the student to read the questions and answers out loud and sat behind the student where he could view the screen. On several occasions, the instructor made comments or noises to indicate that the student should keep or change an answer. For one question, the instructor stated, lets re-think that, and in another instance, he drew a diagram on a white board that helped narrow down the multiple-choice answers for a question. The student also stated that they were about to change an answer for another question when the instructor stated, your first answer is usually your best answer. In addition, from testimony obtained by OI, the student testified that upon the completion of the exam the instructor stated, you passed by the skin of your teeth, with a lot of help from me.
In addition to the student above, testimony from other student engineers corroborated the students account of the exams proctored by this instructor. Three additional student engineers interviewed during the licensees internal investigation testified that the same instructor had given them improper assistance during exams by using verbal and non-verbal cues to encourage them to either change or not change an answer. Furthermore, OI obtained testimony from five engineers that the instructor had provided similar inappropriate assistance.
Based on the evidence developed during the investigation, it appears that the instructor willfully provided additional information during an engineering support qualification exam in the form of diagrams and verbal cues. This appears to have caused the licensee to be in violation of 10 CFR 50.120. This also appears to have caused the instructor to be in violation of 10 CFR 50.5(a)(1).
Enclosure 1
U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 05000416 License Number: NPF-29 Report Number: 05000416/2020016 Enterprise Identifier: I-2020-016-0000 Licensee: Entergy Operations, Inc.
Facility: Grand Gulf Nuclear Station Location: Port Gibson, MS Inspection Dates: November 8, 2020 to February 2, 2021 Inspectors: A. Sanchez, Senior Project Engineer C. Young, Senior Project Engineer Approved By: Jason W. Kozal, Chief Reactor Projects Branch C Division of Reactor Projects Enclosure 2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an NRC inspection at Grand Gulf Nuclear Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations Exam Proctor Provided Inappropriate Assistance During Engineering Qualification Exams Cornerstone Significance Cross-Cutting Report Aspect Section Not Applicable AV 05000416/2020016-01 Not Applicable 71153 Open EA-20-125 The inspectors identified an apparent violation of 10 CFR 50.120, Training and qualification of nuclear power plant personnel, for the licensee's failure to appropriately implement a training program that provides for the training and qualification of engineering support personnel. Specifically, an NRC investigation found that for six engineering support students, an exam proctor provided inappropriate assistance in the form of a drawing on a white board and verbal cues regarding their selection of answers during qualification exams in the November 2016 to July 2019 timeframe.
Additional Tracking Items None.
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INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE 71153 - Follow-up of Events and Notices of Enforcement Discretion Personnel Performance (IP Section 03.03) (1 Sample)
(1) The inspectors evaluated the circumstances surrounding the licensees performance related to potential improper conduct of an exam proctor during engineering support qualification exams at the Grand Gulf Nuclear Station during the timeframe of November 2016 to July 2019.
INSPECTION RESULTS Exam Proctor Provided Inappropriate Assistance During Engineering Qualification Exams Cornerstone Severity Cross-Cutting Report Aspect Section Not Apparent Violation Not 71153 Applicable AV 05000416/2020016-01 Applicable Open EA-20-125 The inspectors identified an apparent violation of 10 CFR 50.120, Training and qualification of nuclear power plant personnel, for the licensee's failure to appropriately implement a training program that provides for the training and qualification of engineering support personnel. Specifically, an NRC investigation found that for six engineering support students, an exam proctor provided inappropriate assistance in the form of a drawing on a white board and verbal cues regarding their selection of answers during qualification exams in the November 2016 to July 2019 timeframe.
Description:
On July 11, 2019, a licensee employee (engineering student taking a qualification exam) at Grand Gulf Nuclear Station reported that an examination proctor had provided inappropriate assistance during a training exam that same day. Specifically, the proctor drew a diagram on a white board to help explain the subject matter of an exam question and also provided verbal cues to the student regarding their answer choices. The student was uncomfortable with the actions of the proctor during the examination and self-reported the incident to their supervisor.
The licensee conducted an investigation and determined that the exam proctor provided inappropriate assistance and communication to the student. In addition, the licensee 3
determined that other engineering students indicated that this proctor had engaged in similar actions on multiple previous occasions.
On September 19, 2019, the NRCs Office of Investigations (OI) initiated an investigation to determine whether the proctors actions involved a willful violation of a regulatory requirement. Based on the evidence developed during this investigation, on July 11, 2019, a senior engineering training instructor compromised an exam by providing additional information during an engineering support qualification exam, in the form of diagrams and verbal cues. Further, OI obtained testimony from five additional licensee engineers that the same proctor had provided similar inappropriate assistance for training exams on previous occasions. The additional previous instances occurred during the November 2016 to late 2018 timeframe.
Corrective Actions: The licensee took personnel action against the exam proctor following completion of its investigation.
As a result of the exam proctors compromise of the licensees training qualification exam for several engineering support students, the NRC has identified an apparent violation of 10 CFR 50.120, Training and qualification of nuclear power plant personnel.
Corrective Action
References:
Condition Report CR-GGNS-2019-05674 Performance Assessment: This issue was associated with a willful violation of the licensees training program and did not directly affect the Cornerstones of the Reactor Oversight Process. The significance determination process does not specifically consider willfulness in its assessment of licensee performance. As a result, there was no finding associated with this violation.
Enforcement: The severity of this apparent violation will be determined in accordance with the Enforcement Policy pending a final enforcement determination.
Apparent Violation: Title 10 CFR 50.120, Training and qualification of nuclear power plant personnel, requires, in part, that each holder of an operating license shall implement a training program derived from a systems approach to training that provides for the training and qualification of engineering support personnel.
Entergy Procedure EN-TQ-104, Engineering Support Personnel Training Program, Revisions 21-27, a quality-related procedure intended to establish appropriate training and qualification requirements for the engineering support personnel training program, , NANTeL [National Academy for Nuclear Training e-Learning] Course Exam Pre-Job Briefing, requires, in part, that for students completing engineering support personnel NANTeL exams that if a non-engineering proctor is selected, the students supervisor, an engineering support personnel instructor, a mentor or a subject matter expert must be available to clarify questions. The assistance must be to only clarify questions and not to reword any exam questions, not to explain any terms, and not to provide any additional information.
Contrary to the above, from November 2016 to July 2019, for students completing engineering support personnel NANTeL exams, the proctor failed to only clarify questions, and the proctor explained terms and provided additional information to the students.
Specifically, for six students, an exam proctor provided inappropriate assistance to the students in the form of a drawing on a white board during the exam and verbal cues regarding their selection of answers during the exam.
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Enforcement Action: This violation is being treated as an apparent violation pending a final significance (enforcement) determination.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
x On February 2, 2021, the inspectors presented the NRC inspection results to Mr. R. Franssen, Site Vice President, and other members of the licensee staff in a telephonic exit meeting.
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