ML20214U364

Shoreham Startup & Low Power Testing Operations,Special Rept:Lilco QA Audit on Training & Qualifications

ML20214U364
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	10/31/1986
From:	MHB TECHNICAL ASSOCIATES
To:
Shared Package
ML20214U333	List: ML20214U331 ML20214U364
References
NUDOCS 8612090243
Download: ML20214U364 (7)

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Shoreham Start-Up and Low-Power Testing Operations

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. SPECIAL REPORT:

LILCO DA AUDIT ON TRAINING AND QUALIFICATIONS 1

Prepared for STATE OF NEW YORK CONSUMER PROTECTION BOARD 1

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MMB Technical Associates 1723 Hamilton Avenue, Suite K San Jose, California 95125 (408) 266-2716 October 31, 1986 ,

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Shoreham Start-Up knd Low-Power Testing Operations I

SPECIAL REPORTS LILCO DA ADDIT M D QUALIFICATIONS A. BACKGROUND The State of New York Consumer Protection Board has l contracted with MMB Technical Associates to monitor start-up and low-power testing operations at the Shoreham Nuclear Power Station, operated by Long Island Lighting Company (LILCO) under NRC license NPF-36. In the MHB Monthly Moni-toring Report dated July 7, 1987, it was recommended that the Consumer Protection Board attempt to obtain a copy of a LILCO quality assurance (QA) audit report on training and qualifications of Shoreham personnel. Concerns about the adequacy of training and qualifications of LILCO personnel in the radicchemistry group had been raised by the U.S. Nu-clear Regulatory Commission (NRC) in a Special Inspection in March 1986. ,

I Following several months of effort by the Consumer Pro-tection Board and repeated ICquests to LILCO to release the audit report, the NRC was requested by Congressman Edward J. '

Markey, Chairman of the Subcommittee on Energy Conservation and Power, Committee on Energy and Commerce, U.S. House of Representatives, to release the audit report. On October 28, 1986, NRC transmitted the LILCO audit report to Chairman Markey. At the request of the Consumer Protection Board, MHB has reviewed the LILCO audit and has prepared the fol-lowing report based on that review.

B. BRIEF SYNOPSIS OF THE ISSUE i

The NRC conducted a Special Insoection of the LILCO Ra-

, diochemistry Program from January 2'7 to February 14, 1986.

The results of this inspection are detailed in an Inspection Report dated March 14, 1986. [NRC Inspection Report 50-322/86-03] The NRC Special Inspection concluded that the

' results of the inspection " raise serious concerns regarding the quality and management of the Radiochemistry Program at Shoreham and the attentiveness of Senior Management to iden-tified program deficiencies. ... Our inspection found that serious deficiencies identified in May and June of 1985 by a

' LILCO QA audit still existed in February 1986 and that lit-tle progress in implementing effective fixes had been made."

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[ Letter dated March 14, 1986, from Richard W. Starostocki (NRC) to John D. Leonard, Jr. (LILCO)]

NRC held an Enforcement Conference with LILCO at Region I offices in King of Prussia, Ponnsylvania, on March 20, 1 l 1986, to discuss the results of the NRC Special Inspection. -

On March 21, 1986, the NRC issued a Confirmatory Action Let-

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i ter describing a series of corrective actions to which LILCO had committed. [ Letter dated March 21, 1986, from Richard W. Starostecki (NRC) to John D. Leonard, Jr. (LILCO), NRC Confirmatory Action Letter CAL No. 86-05]

Subsequently, NRC held an inspection from April 16 to May 31, 1986, part of which was a review of LILCO corrective actions taken in response to the NRC Special Inspection and Confirmatory Action Letter. The NRC Inspection Repert docu-menting this inspection [NRC Inspection Report No. 50-322/86-10] mentioned a LILCO Nuclear Review Board and QA audit of training and qualifications. According to the NRC Inspection Report, the LILCO audit " indicated proper quali-fication of personnel with no problems similar to the quali- I fication deficiencies identified in the radiochemistry 1 area". It was noted, however, that the LILCO audit resulted in 35 audit findings and 19 observations. The NRC Inspec-tion Report also noted that the LILCO audit recommended that "further management attention be applied in the training and qualification area to assure timely resolution of these audit findings and observations".

As explained in the NRC Special Inspection report in March 1986, audit findings " detail failures to comply with a commitment or conform to an established regulation, industry l standard, license condition, or internal procedure", whereas an observation " details a suggestion for a non-mandatory change in an area which is in compliance". [NRC Inspection Report No. 50-322/86-03, page 1] MHB discussed the avail-ability of the LILCO audit with the NRC Senior Resident Inspector at Shoreham and was informed that NRC had only l reviewed a copy of the audit and did not retain a copy for its own files. The large number of audit findings and observations in the LILCO audit suggested that the training i and qualifications problems in the Radiochemistry Program l noted earlier by the NRC were widespread. Thus, MHB recom-

, mended that the Consus.er Protection Board attempt to obtain l

the LILCO QA audit.

C. MHB

SUMMARY

OF THE LILCO AUDIT RESULTS The subject audit is designated NB-86-01 and QS-86-03, and documents the results of two concurrent audits of train-l ing and qualifications by the LILCO Nuclear Review Board and LILCO Quality Assurance Department. A 12-man audit team performed the audit, which required in excess of 1,000 person-hours for preparation and conduct of the audit.

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Among the audit team members were consultants from CYGNA Energy Corporation and Operations Analysis Corporation. The

! audit was conducted over the period from April 6 through April 17, 1966. The audit results are contained in a 35-page report with attachments and a two page transmittal let-ter dated May 21, 1986, and signed by the Chairman of the LILCO Nuclear Review Board.

i , The purpose of the audit was "to examine the overall status and performance of LILCO Personnel Qualification and Training of Shoreham plant and appropriate support organiza-tion personnel." [LILCO Audit Report, page 1] Sixty-five

personnel interviews were conducted during the course of the audit. In addition, records were reviewed as were findings from previous audits. [LILCO Audit Report, page 2)

The audited organizations included Licensed operators, Non-licensed Operators, Reactor Engineering, Shift Technical Advisors, Compliance, Instrumentation and control, computer, Radiochemistry, Health Physics, Radwaste, Maintenance (Mechanical, Electrical and Welding), Modification Engineer-ing, Plant Management, Technical Staff and General Employee Training. Support organizations audited included Nuclear Operations Support, Nuclear Engineering, Purchasing, General

'. Services (Production Training Center) , and Information Sys-tems Departments. (LILCO Audit Report, pages 2-3)

The audit conclusion was stated as follows: [LILCO i

Audit Report, page 3)

Based on a review of educational and experience backgrounds, individuals assigned to, or in sup-port of, the Shoreham Nuclear Power Station are considered to be competent, knowledgeable and ap-Propriately qualified. However, important ele-ments of the qualification and training program as they apply to Plant Staff and support organiza-tions are not effectively implemented.

Among the " principal areas of concern" cited by the i audit were the lack of a formally approve Administrative l Training Manual, the lack of a training program and proco-

dures for the training of management and supervisory person-l nel and engineers-in-training, lack of a procedures govern-ing requalification for non-licensed personnel, lack of ad-ministrative procedures for control of the training program l

, by the Nuclear Training Division, poor quality training records, and inadequate resources (instructors and trainee time) allocated to training. [LILCO Audit Report, pages 3- l

5) LILCO personnel interviewed during the audit indicated a number of additional problems, including lack of of factive

communication between training and user organizations, weak-ness in cooperation between departments, and lack of clear direction associated with the training program effort. In 1

addition, it was indicated that several-groups of LILCO per-sonnel desired additional training that was not being pro-vided. (LILCO Audit Report, page 5]

The specific " Audit Findings" made by the auditors are broad in scope. It should be noted that the definition of -

an " Audit Finding" provided in the NRC Inspection Report (cited above) makes it clear that a LILCO " Audit Finding" is equivalent to what is more commonly referred to as a "Nonconformance". Among the audit findings are A. Deficiencies in training records and in training and qualification practices.

Failure to generally perform or document on-the-job training.

• Lack of objective evidence of completion of qualifications for some operators for certain buildings at Shoreham

• Activities being performed by individuals before they were qualified to perform the work.

Qualification of personnel without ade-quate supporting documentation.

Failure to properly cortify personnel for their assignment to responsible positions.

Violation of Station Procedure 21.006.01 in that ,lthough the procedure does not provide for waiving training require-ments for licensed operators, six opera-tors had some training waived.

Failure to maintain documentation con-

, cerning drill participation of licensed and non-licensed personnel.

• Failure to perform training required by NRC IE Bulletin 79-19, " Packaging of Low-Level Radioactive Waste for Trans-port and Burial".

• Recertification of personnel prior s to j receipt of eye examination documentation required for recertification.

B. Failure to develop and implement training programs.

• A lack of a training program for manage-ment, supervisory, and techni-cal / professional personnel, contrary to the requirements of ANSI N18.1-1971,

" Selection and Training of Nuclear Power Plant Personnel".

• Lack of a formal training program for engineers-in-training to clearly iden-tify responsibility, authority, and acceptance criteria to assure that safety-related tasks are accomplished under the supervision of a qualified individual.

C. Failure to comply with the LILCO QA Manual, Section 5, which requires that activities affecting quality be accomplished in accor-dance with documented instructions and proce-dures.

• Numerous procedures contained inaccurate l information or lacked necessary informa-tion, which precluded effective accom-plishment of training activities.

D. Failure of the Nuclear Training Division to issue an administrative manual or procedures governing the implementation of training activities.

D. MHB COMMENTS ON THE LILCO AUOIT REPORT AND NRC'S HANDI.ING OF THE REPORT Taken individually, many of the findings of LILCO audit report are not serious matters, but some clearly identify violations of LILCO procedures and/or NRC regulatory requirements. The failure of both LILCO and the NRC to rec-ognize that regulatory requirements were violated is dis-turbing. This is all the moreno in the case of the NRC's use of the summary-level results of the LILCO audit in essentially closing out the radiochemistry program training issue raised in March 1986. In MHB's view, the LILCO audit clearly provides evidence of violations of NRC's quality assurance regulations and should have prompted the NRC to i cite LILCO for these violations. .

l Further, NRC apparently failed to appreciate the depth

and breadth of problems revealed in the LILCO audit in terms of LILCO management's failure to adequately supervise activ-ities at Shoreham. In what MHB believes to be an identifi-

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cation of the root cause of the problems, the LILCO audit report stated, "The absence of systematic controls and lack of effective implementation, in conjunction with identified deficiencies and inconsistencies, indicate a previous lack of management attention to training and qualification."

(LILCO Audit Report, page 4)

It should be noted that the NRC's " Systematic Assess-ment of Licensee Performance" (SALP) program assessment for the period from March 1, 198b, through February 28, 1986, also found that there were training problems. The NRC SALP report concluded that the training of non-licensed personnel "is an area where a significant increase in the level of management attention is warranted." The report further stated that "the arear of non-licensed operator training and management involvement in training are considered to be areas of significant weakness." The SALP report rated the area of " Training and Qualification Ef fectiveness" as Cate-

. gory 3 and dec11nir7 A Category 3 rating in the SALP pro-l gram means, "Both NRC and licensee attstion should be increased. License's management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appeared strained or not ef fec-tively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved." [NRC Inspection Report No. 50-322/36-99]

NRC took prompt action on the radiochemistry training and qualifications problems, including calling a management conference at Regicn I headquarters to basically " lay down the law" to LILCO. Considering the broader nature of the training and qualifications problems identified in the LILCO audit, and recognizing that this audit was performed only months af ter both the radiochemistry inspection and manage-ment meeting and the poor and declining SALP rating in the training and qualifications area -- M1 B believes that the issue of training and qualifications at Shoreham is clearly not a trivial problem and deserved similarly prompt i attention from both NRC and LILCO. l l

While the training and qualifications problems in the '

radiochemistry area (found by NRC in March 1986) were seri-

, ous in their own right, the LILCO audit report from April 1986 indicates that there is a more pervasive problem in training and qualifications throughout the LILCO organiza-tion for activities related to Shoreham. The audit report noted problems in training and qualifications related to almost every discipline examined during the audit.

Moreover, some of these problems represent violations i of NRC quality assurance regulations. NRC quality assurance regulations clearly require, at the earliest practicable

time consistent with the schedule for accomplishina the

! activities, the development and implementation of adminis-i

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trative controls for all activities affecting quality. NRC regulations also require that activities affecting quality shall be prescribed by documented instructions and proca-dures, and shall be accomplisted in accordance with those instructions and procedures. The LILCO audit of training and qualifications plainly indicates that these requirements were not met, and should have prompted both LILCO and NRC to institute prompt and extensive actions to assure that the problems identified by the audit are corrected. The simple fact that there were 35 " audit findings" -- in simple terms, failures to meet LILCO procedures and/or NRC regula tory requirements -- should have been indication enough that there were problems that merited prompt and vigorous atten-tion by the management of both LILCO and the NRC. This is clearly not a minor matter; rather, it represents a serious problem with a basic activity which is important to the safety of plant operations, and should have been dealt with promptly and forcefully by the NRC at the time the LILCO audit report was reviewed by the NRC. Instead, a cryptic '

reference to the audit and its results were buried in the details of an NRC inspection report.

Finally, MHB notes that it is a necessity - given the  ;

current regulatory structure -- for NRC to rely in part on audit activities by utility QA organizations to alert the NRC to possible problems. NRC simply does not have the resources to duplicate the depth and breadth of the audit program required of utilities by NRC regulations. Thus, NRC's reference to and use of the LILCO audit report in per-forming an inspection was in itself proper.

However, the apparent failure of NRC to retain a copy of a document which it relied upon as part of the discharge of its regulatory responsibilities is inexplicable. MMB recommends that NRC adopt a formal policy requiring that copies of such documents be retained by the agency when they are used as the basis for an inspection finding.

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