ML17325A002

NRC Inspection Report 05000416/2017014 and NRC Investigation Reports 4-2016-004 and 4- 2017-021

ML17325A002
Person / Time
Site:	Grand Gulf
Issue date:	11/20/2017
From:	Troy Pruett NRC/RGN-IV/DRP/RPB-C
To:	Emily Larson Entergy Operations
Kozal J
References
4-2016-004, 4-2017-021, AV 05000416/2017014-01, AV05000416/2017014-02, AV05000416/2017014-03, EA-17-132, EA-17-153, IR-2017014 05000146/2017014
Download: ML17325A002 (7)

See also: IR 05000416/2017014

Text

November 20, 2017

EA-17-132

EA-17-153

Mr. Eric Larson

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 05000416/2017014 AND NRC INVESTIGATION

REPORTS 4-2016-004 AND 4-2017-021

Dear Mr. Larson:

This letter refers to the investigations conducted at the Grand Gulf Nuclear Station by the

U.S. Nuclear Regulatory Commissions (NRCs) Office of Investigations. The purpose of the

investigations was to determine whether willful violations of NRC requirements occurred at the

Grand Gulf Nuclear Station involving the administration of training examinations and the

performance of operator rounds. The investigations were initiated on November 5, 2015, and

March 6, 2017, and were completed on July 21 and August 25, 2017, respectively. The issues

were discussed with you and other members of your staff during a telephone conversation on

November 16, 2017. A factual summary (Enclosure 1) provides the details of the NRCs review

of the case.

Based on the results of the investigations, three apparent violations were identified and are

being considered for escalated enforcement action in accordance with the NRC Enforcement

Policy. The Enforcement Policy can be found on the NRCs Web site at

http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The apparent violations

being considered for escalated enforcement action involve the failure to ensure that training

examinations were appropriately proctored, the failure of nonlicensed operators to perform

required operator rounds, and the creation of falsified records of the performance of the

operator rounds. The apparent violations are documented in Enclosure 2.

Before the NRC makes its enforcement decision, we are providing you an opportunity to:

(1) request a predecisional enforcement conference (PEC), or (2) request alternative dispute

resolution (ADR). If a PEC is held, the NRC may 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.

E. Larson 2

If you decide to participate in a PEC or pursue ADR, please contact Mr. Jason Kozal, Chief,

Project Branch C, at 817-200-1144 within 10 days of the date of this letter. A PEC should be

held within 30 days and an ADR session within 45 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 presenting your corrective actions, you should be

aware that the promptness and comprehensiveness of your actions will be considered in

assessing any civil penalty for the apparent violations.

In lieu of a PEC, you may request ADR with the NRC in an attempt to resolve this issue.

Alternative dispute resolution is a general term encompassing various techniques for resolving

conflicts using a neutral third party. The technique that the NRC has decided to employ is

mediation. Mediation is a voluntary, informal process in which a trained neutral mediator works

with parties to help them reach resolution. If the parties agree to use ADR, they select a

mutually agreeable neutral mediator who has no stake in the outcome and no power to make

decisions. Mediation gives parties an opportunity to discuss issues, clear up

misunderstandings, be creative, find areas of agreement, and reach a final resolution of the

issues.

Based on notifications to the NRC by Entergy Operations, Inc., on November 5, 2015,

January 31, April 19, and July 28, 2017, the NRC is aware of additional issues at the Grand Gulf

Nuclear Station, as well as the River Bend Station and the Waterford Steam Electric Station,

involving falsification of operator rounds and trainees receiving inappropriate assistance. If ADR

is selected, we would anticipate the scope of the mediation to include a discussion of these

additional issues. Additional information concerning the NRCs ADR program can be obtained

at http://www.nrc.gov/about-nrc/regulatory/enforcement/adr/post-investigation.html. The

Institute on Conflict Resolution at Cornell University has agreed to facilitate the NRCs program

as a neutral third party. Please contact Cornell at 877-733-9415 within 10 days of the date of

this letter if you are interested in pursuing resolution of this issue through ADR.

In addition, please be advised that the number and characterization of apparent violations

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.

For administrative purposes, this letter is issued as NRC Inspection Report 05000416/2017014,

and the apparent violations will be issued as AV 05000416/2017014-01,

AV 05000416/2017014-02, and AV 05000416/2017014-03, as described in Enclosure 2.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice and Procedure, a copy of this

letter, its enclosures, and your response, if you choose to provide one, will be made available

electronically for public inspection in the NRC Public Document Room or from the NRCs

Agencywide Documents Access and Management System (ADAMS), accessible from the NRC

E. Larson 3

Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response

should not include any personal privacy, proprietary, or safeguards information so that it can be

made available to the public without redaction.

If you have any questions concerning this matter, please contact Mr. Jason Kozal of my staff at

817-200-1144.

Sincerely,

/RA/

Troy W. Pruett, Director

Division of Reactor Projects

Docket No. 50-416

License No. NPF-29

Enclosures:

1. Factual Summary

2. NRC Inspection Report 05000416/2017014

cc w/enclosures: Electronic Distribution

FACTUAL SUMMARY

Office of Investigations Report 4-2016-004

An investigation was initiated by the U.S. Nuclear Regulatory Commission (NRC) Office of

Investigations on November 5, 2015, to determine whether a former examination proctor willfully

failed to ensure that there was no examination misconduct and avoid compromise of the

examination when the proctor provided workers with answers to the training examination

questions. The NRC completed its investigation on July 21, 2017.

During an investigation interview, a trainee explained that the proctor would offer directions

while standing behind the trainee and looking at the trainees selected examination answers on

the computer screen. The trainee stated, Well, she might have came over and stood up and

like say, you sure you want to do one like that? Thats the answer right there. The trainee

recalled that the proctor provided this direction for about three examination answers.

During an investigation interview, another trainee explained that he met the proctor offsite and

told her that he needed some help to pass a test. The trainee stated that the proctor said that

she would take care of it. The trainee stated that a friend later told him that the proctor had

called to say that she had entered the trainee and his friend in the computer . . . the only thing

yall got to do is go out there. The trainee indicated that a friend provided him with a printout

showing that the trainees required examinations were completed. Examination records for the

trainee showed examinations with completion times under 180 seconds. The former

examination proctor is recorded as the proctor for those examinations.

Based on the evidence, it appears that a former examination proctor deliberately compromised

examinations by providing inappropriate assistance to trainees. This appears to have caused

the licensee to be in violation of 10 CFR 50.120.

Office of Investigations Report 4-2017-021

An investigation was initiated by the NRC Office of Investigations on March 6, 2017, to

determine if nonlicensed operators deliberately failed to perform the required operator rounds

and if the nonlicensed operators subsequently falsified records to show that they had conducted

the rounds. The NRC completed its investigation on August 25, 2017.

Security and badge access records showed that three nonlicensed operators failed to enter an

area required as part of their rounds, even though the nonlicensed operators in question

entered completed round logs into the electronic recordkeeping system. During the

investigation interviews, two nonlicensed operators admitted that they completed the electronic

logs without entering the assigned areas. For the dates in question, door access records do not

show that the third nonlicensed operator entered the area recorded in the logs; in fact, the

badge access records put him in another area of the plant on the date and time in question.

Based on the evidence, it appears that the nonlicensed operators deliberately failed to tour all

required areas of their watch station and deliberately entered inaccurate information into the

operator logs. This appears to have caused the licensee to be in violation of 10 CFR Part 50,

Appendix B, Criterion V and 10 CFR 50.9.

Enclosure 1

SUMMARY OF APPARENT VIOLATIONS

A. 10 CFR 50.120, requires, in part, that each holder of an operating license shall

implement a training program derived from a systems approach to training (SAT) as

defined in 10 CFR 55.4 that provides for the training and qualification of electrical

maintenance, mechanical maintenance, and engineering support personnel.

10 CFR 55.4 defines a SAT program as including, in part, an evaluation of trainee

mastery of the objectives during training.

Licensee Procedure EN-TQ-107, General Employee Training, Revision 9, a quality

related procedure, provides instructions for implementing the General Employee

Training Program for Entergy Operations, Inc., including plant access training and

radiation worker training for electrical maintenance, mechanical maintenance, and

engineering support personnel. Step 5.5[2] requires, in part, that all general employee

training examinations provided to non-utility personnel be proctored.

Licensee Procedure EN-TQ-201-04, SAT - Implementation Phase, Revision 5, a quality

related procedure, provides instructions for administering examinations in the training

program. Step 5.12[7](h) requires that proctors answer trainees questions carefully to

avoid compromise of the examination. Step 5.12[7](i) requires that the proctor not

modify a trainees answer or direct a trainee to change an answer.

Licensee Procedure EN-TQ-217, Examination Security, Revision 4, a quality related

procedure, provides controls necessary for examination security. Step 3.0[3] defines

Exam Compromise as any activity that could affect equitable and consistent

administration of the examination in question regardless of whether the activity takes

place, before, during, or after the examination administrated. Step 4.0[5] states, in part,

that instructors are responsible for establishing and maintaining examination security

and immediately reporting to training management any potential or actual examination

compromise.

Contrary to the above, from January through September 2015, the licensee failed to

implement the SAT training program that provides for the training and qualification of

electrical maintenance, mechanical maintenance, and engineering support personnel.

Specifically, the licensee failed to ensure that general employee training examinations

provided to non-utility (contractor) personnel were appropriately proctored. An

examination proctor compromised examinations by providing inappropriate assistance

(i.e., answers and/or information leading to answers) during trainee examinations.

This apparent violation is designated as AV 05000416/2017014-01, Inappropriate

Proctoring of Training Examinations.

B. 10 CFR Part 50, Appendix B, Criterion V, requires, in part, that activities affecting quality

shall be accomplished in accordance with documented instructions or procedures of a

type appropriate to the circumstances.

Procedure EN-OP-115-01, Operator Rounds, Revision 1, a quality related procedure,

provides instructions for operators to conduct watchstanding rounds. Subparagraph

5.1[7] requires, in part, that watchstanders tour all required areas of their watch station.

Enclosure 2

Contrary to the above, between February and December, 2016, three watchstanders

failed to tour all required areas of their watchstation. Specifically, three non-licensed

operators deliberately failed to tour the area of the standby service water pump houses,

which is an area they were required to tour for that watch station.

This apparent violation is designated as AV 05000416/2017014-02, Failure to Perform

Operator Rounds.

C. 10 CFR 50.9 requires, in part, that information required by the Commissions regulations,

orders, or license conditions to be maintained by the licensee shall be complete and

accurate in all material respects.

10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance Records requires, in

part, that sufficient records shall be maintained to furnish evidence of activities affecting

quality. The records shall include at least the following: operating logs and the results of

reviews, inspections, tests, audits, monitoring of work performance, and materials

analyses.

Procedure EN-OP-115-01, Operator Rounds, Revision 1, a quality related procedure,

provides instructions for operators to conduct watchstanding rounds. It defines operator

rounds as electronic media or data sheets used by the operator to record parameters

or conditions existing in his area of responsibility. Subparagraph 5.1[7] requires, in part,

that operators tour all required areas of their watch station, and Subparagraph 5.2[3]

requires operators assigned to an area to complete rounds applicable to that area.

Contrary to the above, between February and December 2016, the licensee failed to

ensure that information required by the Commission's regulations, orders, or license

conditions to be maintained by the licensee were complete and accurate in all material

respects. Specifically, non-licensed operators did not tour all required areas of their

watch station, and then deliberately completed falsified rounds for their assigned area.

These operator rounds are material to the NRC because when performing inspections,

the NRC uses the information contained in the rounds to ensure that the condition of

safety-related equipment is being monitored as required by station procedures.

This apparent violation is designated as AV 05000416/2017014-03, Falsification of

Operator Rounds Records.

2

E. Larson 4

GRAND GULF NUCLEAR STATION - NRC INSPECTION REPORT 05000416/2017014 AND

NRC INVESTIGATION REPORTS 4-2016-004 AND 4-2017-021 DATED NOVEMBER 20, 2017

Distribution w/o enclosure

RidsOeMailCenter Resource; NRREnforcement.Resource; RidsNrrDirsEnforcement Resource;

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RidsEdoMailCenter Resource; EDO_Managers; RidsOigMailCenter Resource;

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KKennedy, RA BMaier, ORA ABoland, OE

SMorris, DRA MVasquez, ORA FPeduzzi, OE

AVegel, DRS JKramer, ORA DFurst, OE

JClark, DRS CAlldredge, ORA RFretz, OE

TPruett, DRP JKozal, DRP GGulla, OE

RLantz, DRP JWeaver, ORA GFigueroa, OE

GWalker, OI VDricks, ORA NHilton, OE

MYoung, DRP CYoung, DRP LCasey, NRR

NDay, DRP JMartin, OGC RArrighi, OE

MHerrera, DRMA JWeil, CA JPeralta, OE

JBowen, OEDO AMoreno, CA

ADAMS ACCESSION NUMBER: ML17325A002

SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: CHY/rdr Yes No Publicly Available Sensitive NRC-002

OFFICE SPE:PBC C:PBC TL:ACES NRR OE OGC

NAME CYoung JKozal MVasquez LCasey RFretz DCylkowski

SIGNATURE /RA/ /RA/ /RA/ JK for /RA/ E /RA/ E /NLO/ E

DATE 11/02/17 11/03/17 11/03/17 11/16/17 11/16/17 11/16/17

OFFICE OGC D:DRS D:DRP

NAME LBaer AVegel TPruett

SIGNATURE /NLO/ E /RA/ /RA/

DATE 11/16/17 11/20/17 11/20/17

OFFICAL RECORD COPY