ML17325A002
| 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-17-153
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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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