IR 05000275/2019002
| ML19214A279 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/01/2019 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-A |
| To: | Welsch J Pacific Gas & Electric Co |
| References | |
| IR 2019002 | |
| Download: ML19214A279 (28) | |
Text
August 1, 2019
SUBJECT:
DIABLO CANYON POWER PLANT, UNITS 1 AND 2 - NRC INTEGRATED INSPECTION REPORT 05000275/2019002 AND 05000323/2019002
Dear Mr. Welsch:
On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Diablo Canyon Power Plant, Units 1 and 2. On July 11, 2019, the NRC inspectors discussed the results of this inspection with Ms. P. Gerfen, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at the Diablo Canyon Power Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at the Diablo Canyon Power Plant. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Jeffrey E. Josey, Chief Project Branch A Division of Reactor Projects
Docket Nos.: 05000275 and 05000323 License Nos.: DPR-80 and DPR-82
Enclosure:
Inspection Report 05000275/2019002 and 05000323/2019002 with attachment 1. RFI Biennial Requalification
Inspection Report
Docket Numbers:
05000275 and 05000323
License Numbers:
Report Numbers:
05000275/2019002 and 05000323/2019002
Enterprise Identifier: I-2019-002-0001
Licensee:
Pacific Gas & Electric Company
Facility:
Diablo Canyon Power Plant, Units 1 and 2
Location:
Avila Beach, California
Inspection Dates:
April 01, 2019 to June 30, 2019
Inspectors:
R. Bywater, Resident Inspector
N. Hernandez, Operations Engineer
C. Newport, Senior Resident Inspector
J. Reynoso, Resident Inspector
Approved By:
Jeffrey E. Josey, Chief
Project Branch A
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Diablo Canyon Power Plant, Units 1 and 2, 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.
NRC-identified and self-revealed findings, violations, and additional items are summarized in the table below. Licensee-identified non-cited violations are documented in the Inspection Results at the end of this report.
List of Findings and Violations
Human Performance Event Leads to Inadvertent Unit 2 Bus F Vital Bus Transfer Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000275;05000323/2019002-01 Closed
[H.12] - Avoid Complacency 71111.15 The inspectors reviewed a Green, self-revealed non-cited violation of Technical Specification (TS) 5.4.1.a, Procedures, because PG&E personnel failed to follow the requirements of procedure STP M-75F, 4 kV Vital Bus F Undervoltage Relay Calibration,
Revision 7. Specifically, on June 28, 2019, during restoration from STP M-75F, PG&E technicians inadvertently left a jumper in place resulting in an inadvertent transfer of the 4 kV vital bus F from the auxiliary power supply to the startup power supply. As part of this transfer, auxiliary saltwater pump 2-2 and containment fan cooler units 2-1 and 2-2 started.
Additionally, emergency diesel generator 2-3, which was out of service for maintenance at the time of the event, received a start signal.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000323/2018-001-00 LER 2018-001-00 for Diablo Canyon Power Plant, Unit 2,
Automatic Reactor Trip of Unit 2 Following a Load Rejection.
71153 Closed LER 05000323/2018-001-01 LER 2018-001-01 for Diablo Canyon Power Plant, Unit 2,
Automatic Reactor Trip of Unit 2 Following a Load Rejection.
71153 Closed
PLANT STATUS
Units 1 and 2 began the inspection period at full power.
On April 1, 2019, Unit 2 reduced power to 50 percent to clean water boxes and condensers.
Unit 2 returned to full power on April 6, 2019.
Units 1 and 2 operated at full power for the remainder of the inspection period.
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 performed plant status activities described in IMC 2515 Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.03) (1 Sample)
The inspectors evaluated readiness for impending adverse weather conditions prior to the onset of seasonal heavy rains and winds on April 10, 2019.
Summer Readiness Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated summer readiness of offsite and alternate alternating current power systems.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 2, emergency diesel generator 2-3 on April 3, 2019
- (2) Units 1 and 2, control room ventilation system on April 16, 2019
- (3) Unit 1, component cooling water system train B on June 16, 2019
- (4) Unit 2, auxiliary building ventilation system on June 17, 2019
- (5) Unit 2, emergency diesel generator 2-1 on June 25, 2019
71111.04S - Equipment Alignment
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of the Units 1 and 2 safety injection systems on May 8 - June 25, 2019.
71111.05A - Fire Protection (Annual)
Annual Inspection (IP Section 03.02) (1 Sample)
The inspectors evaluated fire brigade performance during a drill on June 13, 2019.
71111.05Q - Fire Protection
Quarterly Inspection (IP Section 03.01) (4 Samples)
The inspectors evaluated fire protection program implementation in the following selected areas:
- (1) Unit 1, component cooling water heat exchanger room on April 3, 2019
- (2) Units 1 and 2, auxiliary building 115 foot elevation on April 15, 2019
- (3) Unit 2, spent fuel building 100 foot elevation on May 3, 2019
- (4) Unit 2, emergency diesel generator rooms 2-1 and 2-2 on June 25, 2019
71111.11B - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Requalification Program (IP Section 03.04) (1 Sample)
Biennial Requalification Written Examinations The inspectors evaluated the quality of the facility licensees biennial requalification written examination administered on May 28, 2019.
Annual Requalification Operating Tests The inspectors evaluated the adequacy of the facility licensees annual requalification operating test.
Administration of an Annual Requalification Operating Test The inspectors evaluated the effectiveness of the facility licensee in administering requalification operating tests required by 10 CFR 55.59(a)(2) and that the facility licensee is effectively evaluating their licensed operators for mastery of training objectives.
Requalification Examination Security The inspectors evaluated the ability of the facility licensee to safeguard examination material, such that the examination is not compromised.
Remedial Training and Re-examinations The inspectors evaluated the effectiveness of remedial training conducted by the licensee, and reviewed the adequacy of re-examinations for licensed operators who did not pass a required requalification examination.
Operator License Conditions The inspectors evaluated the licensees program for ensuring that licensed operators meet the conditions of their licenses.
Control Room Simulator The inspectors evaluated the adequacy of the facility licensees control room simulator in modeling the actual plant, and for meeting the requirements contained in 10 CFR 55.46.
Problem Identification and Resolution The inspectors evaluated the licensees ability to identify and resolve problems associated with licensed operator performance.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
The inspectors observed and evaluated operator performance during the following activities:
- (1) Unit 2, unexpected plant process computer annunciator alarms on June 11, 2019
- (2) Units 1 and 2, control room turnover and walkdowns on June 14, 2019
- (3) Units 1 and 2, control room turnover and station production, work order, and corrective action program computer system outage on June 16, 2019
- (4) Units 1 and 2, control room turnover on June 23, 2019
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
The inspectors observed and evaluated a crew of licensed operators in the plant's simulator during the licensed operator annual exam on May 8, 2019.
71111.12 - Maintenance Effectiveness
Routine Maintenance Effectiveness Inspection (IP Section 02.01) (1 Sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
Units 1 and 2, safety injection systems on June 20, 2019
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
- (1) Unit 1, vital battery charger 132 out of service for maintenance on April 8, 2019
- (2) Unit 2, control room ventilation system emergent maintenance on May 1, 2019
- (3) Unit 2, vital battery charger 2-2 out of service for maintenance on May 6, 2019
- (4) Unit 2, auxiliary saltwater pump 2-2 out of service for maintenance on June 6, 2019
- (5) Unit 2, emergency diesel generator 2-3 out of service for maintenance on June 25-26, 2019
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 02.02) (6 Samples)
The inspectors evaluated the following operability determinations and functionality assessments:
- (1) Unit 1, elevated safety injection pump 1-1 shaft seal leakage on April 3, 2019
- (2) Unit 1, control room ventilation motor operated damper MOD-3 sheared pin on April 17, 2019
- (3) Unit 1, momentary reactor trip and safety injection initiate alarms on May 13, 2019
- (4) Unit 2, turbine building high energy line break seized louvers on May 16, 2019
- (5) Unit 2, emergency diesel generator 2-1 erratic speed control on May 29, 2019
- (6) Unit 2, inadvertent transfer of 4 kV vital bus F on June 27, 2019
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
Unit 1, turbine driven auxiliary feedwater pump 1-1 governor replacement on May 19, 2019
71111.19 - Post-Maintenance Testing
Post Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post maintenance tests:
- (1) Unit 1, centrifugal charging pump 2-1, anti-rotation pin replacement on April 1, 2019
- (2) Unit 1, safety injection pump 1-1, mechanical seal maintenance on April 1, 2019
- (3) Unit 2, auxiliary feedwater system valves LCV-106 and LCV-107, preventative maintenance on April 9, 2019
- (4) Unit 1, auxiliary building ventilation system fan S-31, preventative maintenance and sheave replacement on April 25, 2019
- (5) Unit 2, safety injection pump 2-1, lube oil cooler end bell replacement on April 30, 2019
- (6) Units 1 and 2, diesel fuel oil transfer pump 0-1, preventative maintenance on June 10, 2019
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Inservice Testing (IP Section 03.01)
Unit 1, comprehensive testing of component cooling water pump 1-1, per procedure STP P-CCW-A11 on May 1, 2019
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
- (1) Unit 2, main turbine valve testing, per procedure STP M-21C on April 4, 2019
- (2) Unit 2, solid state protection system train B actuation logic testing, per procedure STP I-38-B.1 on April 24, 2019
- (3) Unit 1, vital battery charger 1-1 surveillance testing, per procedure STP M-12B on June 4, 2019
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)
The inspectors evaluated an emergency preparedness drill on June 5,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1, date range: April 1, 2018 through March 31, 2019
- (2) Unit 2, date range: April 1, 2018 through March 31, 2019
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
- (1) Unit 1, date range: April 1, 2018 through March 31, 2019
- (2) Unit 2, date range: April 1, 2018 through March 31, 2019
MS07: High Pressure Injection Systems (IP Section 02.06) (2 Samples)
- (1) Unit 1, date range: April 1, 2018 through March 31, 2019
- (2) Unit 2, date range: April 1, 2018 through March 31, 2019
71152 - Problem Identification and Resolution
Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Evaluation and corrective actions related to Units 1 and 2 emergency diesel generator fuel oil transfer piping compliance with technical specification testing and surveillance requirements on May 13, 2019
- (2) Evaluation and corrective actions related to Unit 2 auxiliary saltwater pump 2-1 motor bearing degradation on May 13, 2019
Semiannual Trend Review (IP Section 02.02) (1 Sample)
The inspectors reviewed the licensees corrective action program for trends that might be indicative of a more significant safety issue. The inspectors review was focused on human performance issues but also considered the results of daily corrective action program item screening and licensee trending efforts during the period of January 1, 2019 to June 30, 2019.
71153 - Followup of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event reports (LERs) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
- (1) LER 05000323/2-2018-001-00, Automatic Reactor Trip of Unit 2 Following a Load Rejection (ADAMS Accession No.: ML19030B857)
On December 1, 2018, Diablo Canyon Power Plant (DCPP), Unit 2, tripped from 100 percent power following a load rejection initiated from the 500 kV offsite power supply Special Protection Scheme (SPS) switch. The SPS switch is designed to detect abnormal grid conditions and preemptively initiate a load reject on one of the two reactor units at DCPP to avoid a grid overload condition that could potentially damage grid hardware and cause a dual unit reactor trip. The SPS switch load reject function is selected to either Unit 1 or Unit 2. At the time of the Unit 2 reactor trip, the load reject switch was selected to Unit 2 and Unit 1 was decreasing power to 50 percent power for unrelated reasons. This condition, coupled with prevailing grid conditions, reduced 500 kV line amperage flows to below the SPS switch remote outage detection logic trigger levels and initiated a load reject of Unit 2 per design.
The load reject occurred without any preliminary indications to DCPP plant operators.
Control room operators responded to the Unit 2 reactor trip in accordance with applicable procedures and stabilized the plant in Mode 3. No operator performance issues were identified. All safety systems functioned as designed. The initial event response and assessment was documented in NRC Inspection Report 05000275/2018004, 05000323/2018004 (ML19028A382). No performance deficiencies were identified during the review of the event or this licensee event report. The inspectors also concluded that no violation of NRC requirements occurred.
- (2) LER 05000323/2-2018-001-01, Automatic Reactor Trip of Unit 2 Following a Load Rejection (ADAMS Accession No.: ML19101A435)
The inspectors reviewed the updated LER submittal which included results of the licensees causal evaluation of the event. The licensee conducted a root cause evaluation and determined that the root cause of event involved a latent design vulnerability with the SPS switch and inadequate required grid evaluations that could have identified the vulnerabilities of the SPS logic scheme. The root causes of the event occurred within the PG&E transmission and distribution organization and were outside of the cognizance of the DCPP, PG&E nuclear organization. As such, the causes of the load reject and reactor trip were not reasonably within the ability of the DCPP, PG&E nuclear organization to foresee and correct; therefore, no performance deficiency was identified. The inspectors also concluded that no violation of NRC requirements occurred.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTION, INFREQUENT, AND ABNORMAL Evaluation of Diablo Canyon Power Plant Safety Condition in Light of Financial Conditions Because Pacific Gas & Electric Corporation, and its subsidiary, Pacific Gas & Electric Company (the licensee) was under bankruptcy protection/reorganization during the inspection period, NRC Region IV conducted special reviews of processes at Diablo Canyon Power Plant. Using the flexibilities in the baseline inspection program, the inspectors evaluated several aspects of the licensees operations to determine whether the financial condition of the licensee impacted plant safety. The factors reviewed during this period included:
- (1) impact on staffing,
- (2) corrective maintenance backlog,
- (3) changes to the planned maintenance schedule,
- (4) corrective action program implementation, and
- (5) any reduction in outage scope, including risk-significant modifications. Considering the licensees financial difficulties, the inspectors verified that licensee personnel continued to identify problems at an appropriate threshold and enter these problems into the corrective action program for resolution. The inspectors also verified that the licensee continued to develop and implement corrective actions commensurate with the significance of the problems identified.
The special review of processes at Diablo Canyon Power Plant included continuous reviews by the resident inspectors, as well as the specialist-led baseline inspections completed during the inspection period - emergency preparedness, inservice inspection, and radiation protection - which are documented in this report. During this period, the inspectors did not identify any indications that the licensees financial circumstances were adversely affecting plant performance and safety.
INSPECTION RESULTS
Observation: Semi-Annual Trend Review 71152 The inspectors review was focused on human performance issues and considered the results of daily inspector corrective action program (CAP) item screening and licensee trending efforts. The inspectors review considered the 6-month period of January 2019 through June 2019, although some examples beyond those dates were considered when warranted.
The inspectors reviewed CAP notifications, trend reports, and performance indicator evaluations to address potential performance gaps at Diablo Canyon Power Plant. During the inspection period, the inspectors noted instances where low level human performance errors occurred in multiple departments, including operations, maintenance, and security.
Examples include: component mis-positioning events (including two that resulted in re-performance of surveillance tests), bumping valves out of position, fuses shorted out during maintenance, and two events associated with inadvertently working on the wrong component. Additionally, two human performance events associated with the performance of a routine surveillance test on the containment spray system and a routine surveillance test on the vital 4 kV bus F were noted that resulted in impacts on plant equipment and unplanned entries into technical specification LCOs. Both of these events were dispositioned as Green, non-cited violations and documented in NRC inspection reports.
The inspectors noted that the licensee appropriately entered these issues into the CAP and completed timely evaluations and self-assessments of these issues to determine their causes and actions to prevent recurrence. As a result, the licensee increased the oversight and observation of field activities and all maintenance and operations personnel will be provided training focused on improving work performance in the field to address mis-positioning errors.
Other corrective actions included training and plant communications with emphasis on pre-job briefs as well as procedure use and adherence with validation activities. At the end of this inspection period, some corrective actions were still open, and the effectiveness of the actions taken were still being assessed. However, the inspectors determined that the corrective actions taken to date appeared to be effective at addressing the identified gaps.
The inspectors noted that many of these low-level errors were 'near-miss' events and most were a result of a lack of focus and were preventable with proper use of human performance tools. Although these identified events were low level in nature and PG&E has taken actions to identify and correct the causes of the events, they may nonetheless indicate a decline in Diablo Canyon Power Plant human performance.
Human Performance Event Leads to Inadvertent Unit 2 Bus F Vital Bus Transfer Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events
Green NCV 05000275;05000323/2019002-01 Closed
[H.12] - Avoid Complacency 71111.15 The inspectors reviewed a Green, self-revealed non-cited violation of Technical Specification (TS) 5.4.1.a, Procedures, because PG&E personnel failed to follow the requirements of procedure STP M-75F, 4 kV Vital Bus F Undervoltage Relay Calibration, Revision 7. Specifically, on June 28, 2019, during restoration from STP M-75F, PG&E technicians inadvertently left a jumper in place resulting in an inadvertent transfer of the 4 kV vital bus F from the auxiliary power supply to the startup power supply. As part of this transfer, auxiliary saltwater pump 2-2 and containment fan cooler units 2-1 and 2-2 started.
Additionally, emergency diesel generator 2-3, which was out of service for maintenance at the time of the event, received a start signal.
Description:
Procedure STP M-75F, 4 kV Vital Bus F Undervoltage Relay Calibration, Revision 7, step 7.7.3.n states, Remove all test equipment from relays 27HFB3, 27HFB4, 62HF3A, and 62HF3B. However, while performing this step of STP M-75F, on June 27, 2019, PG&E technicians inadvertently left two test equipment jumpers in place and moved on to the next step of the procedure which restored control power to the system. This resulted in an electrical short across two phases via the jumpers, and the subsequent actuation of a protection fuse which led to the drop out of multiple 4 kV bus protection relays. This resulted in an inadvertent transfer of the 4 kV vital bus F from the auxiliary power supply to the startup power supply. As part of this transfer, auxiliary saltwater pump 2-2 and containment fan cooler units 2-1 and 2-2 started. Additionally, emergency diesel generator 2-3, which was out of service for maintenance at the time of the event, received a start signal. Due to the light loading on 4 kV vital bus F and the transfer of only a single bus, the startup transformer automatic load tap changer was taken to manual by operators to lower bus voltage to within acceptable limits. This action, along with emergency diesel generator 2-3 already being out of service for unrelated maintenance, required entry into a 12-hour shutdown technical specification limiting condition of operation (TS LCO 3.8.1.D).
Corrective Actions: After troubleshooting and system configuration verification, PG&E personnel were able to successfully replace the fuses and restore the system to an operable condition prior to the expiration of the shutdown technical specification LCO. A cause evaluation to understand the causal factors that led to the event was also initiated.
Corrective Action References: Notification 51034990
Performance Assessment:
Performance Deficiency: The inspectors determined that PG&Es failure to follow procedure STP M-75F, 4 kV Vital Bus F Undervoltage Relay Calibration, Revision 7 was a performance deficiency within PG&Es ability to foresee and correct.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance attribute of the Initiating Events cornerstone. The performance deficiency was considered to be more than minor because it adversely impacted the equipment performance attribute of the Initiating Events cornerstone and its objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the human performance event associated with execution of procedure STP M-75F, 4 kV Vital Bus F Undervoltage Relay Calibration, led to an inadvertent transfer of the 4 kV vital bus F from the auxiliary power supply to the startup power supply. As part of this transfer, auxiliary saltwater pump 2-2 and containment fan cooler units 2-1 and 2-2 started. Additionally, emergency diesel generator 2-3, which was out of service for maintenance at the time of the event, received a start signal. This action, along the with emergency diesel generator 2-3 already being out of service for unrelated maintenance, required entry into a 12-hour shutdown Technical Specification LCO (TS LCO 3.8.1.D).
Significance: The inspectors assessed the significance of the finding using Appendix A, Significance Determination of Reactor Inspection Findings for At - Power Situations. Using Exhibit 1 from Appendix A, the inspectors determined the issue was of very low safety significance (Green) since the inadvertent actuation of the 4 kV vital bus F bus transfer did not result in a plant trip and the loss of mitigation equipment relied upon to transition the plant from the onset of the trip to a stable shutdown condition.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. Specifically, PG&E technicians failed to fully complete a procedural step using appropriate human error prevention tools requiring all testing equipment to be removed prior to moving on with the procedure which resulted in the inadvertent transfer of the 4 kV vital bus F.
Enforcement:
Violation: Technical Specification 5.4.1.a, Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Regulatory Guide 1.33, Appendix A, Section 9, requires, in part, that maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances. The licensee established procedure STP M-75F, "4 kV Vital Bus F Undervoltage Relay Calibration, Revision 7, as a procedure appropriate to the circumstances to support maintenance and testing of the safety-related 4 kV Vital Bus F. Contrary to the above, on June 28, 2019, PG&E personnel failed to follow the requirements of STP M-75F, 4 kV Vital Bus F Undervoltage Relay Calibration, Revision 7. Specifically, the human performance event associated with M-75F 4 kV bus F relay calibration procedure led to an inadvertent transfer of the 4 kV vital bus F from the auxiliary power supply to the startup power supply. As part of this transfer, auxiliary saltwater pump 2-2 and containment fan cooler units 2-1 and 2-2 started. Additionally, emergency diesel generator 2-3, which was out of service for maintenance at the time of the event, received a start signal. This action, along emergency diesel generator 2-3 already being out of service for unrelated maintenance, required entry into a 12-hour shutdown technical specification LCO.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 31, 2019, the inspectors presented the biennial operator licensing requalification inspection results to Mr. J. Welsch, Senior Vice President, Generation and Chief Nuclear Officer, and other members of the licensee staff.
- On July 11, 2019, the inspectors presented the quarterly resident inspector inspection results to Ms. P. Gerfen, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Notifications
50981582, 51018665, 51027248, 51032504
Procedures
CP M-12
Stranded Plant
Procedures
CP M-16
Severe Weather
Procedures
Loss of AC Power
Procedures
OP AP-26
Loss of Offsite Power, Unit 1/2
21A/20
Procedures
OP O-28
Operations Response to Storms or Biofouling
Corrective Action
Documents
Notifications
51012144, 51031355, 51031356, 51034157
Drawings
106714
CCW OVID
Drawings
107721
Starting Air System EDG 2-3
Drawings
107723
Control Room HVAC Unit 2
105
Drawings
57726
Aux., Containment, and Fuel Handling Buildings
Procedures
AD13.DC12
Control Room Envelop Habitability Program
Procedures
OP F-2:VI
CCW system Alignment Verification
Procedures
OP H-1:I
Auxiliary Building Safeguards Ventilation (ABVS) - Make
Available
Procedures
OP H-1:II
Auxiliary Building Safeguards Ventilation - Normal
Operation
Procedures
OP H-5:II
Control Room Ventilation System-Alignment Verification
Procedures
OP J-6B:I-A
Diesel Generator 2-1 - Alignment Checklist
Procedures
OP J-6B:II-A
Diesel Generator 2-2 - Alignment Checklist
Procedures
OP J-6B:III-A
Diesel Generator 2-2 - Alignment Checklist
Procedures
OP J-6C:II
Diesel Fuel Oil System - Alignment Verification for Plant
Startup
Procedures
OP K-10E1
Seal Valve Checklist for Component Cooling Water
Corrective Action
Documents
Notifications
50836988, 50888946, 50034848, 50925406, 50936644,
50967009, 50967030, 50967595, 50968643, 50549533
Drawings
106709
Safety Injection, Unit 1, Sheet 4
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
107709
Safety Injection, Unit 2, Sheet 4
Procedures
DCPP A-30
Plant Labeling Program
Procedures
OP B-3A:11
Safety Injection System Alignment
23B
Procedures
OP K-10A12
Seal Components for Safety Injection
Work Orders
60087891, 60004369, 60101584
Corrective Action
Documents
Notification
51026411
Drawing
RA-3
RCA Elev. 73'
Procedure
CP M-6
Casualty Procedure - Fire
71111.05Q Corrective Action
Documents
Notifications
51026187, 50937062, 50622051, 50655050, 51026373,
51015502, 51002807, 50938102
71111.05Q Drawings
111805, Sheet 60
Fire Department
71111.05Q Drawings
111805, Sheet 61
Fire Department
71111.05Q Drawings
Pre-Fire plans; RCA and H-block, 115 foot elevation
71111.05Q Drawings
Radiological Control Area Elev. 100
71111.05Q Drawings
TB-3
Turbine Building Elev. 85'
71111.05Q Work Orders
60116410, 60114723
Corrective Action
Documents
Notifications
50914432, 50937919, 50945261, 50945751, 50953015,
50954525, 50957474, 50965876, 50979165, 50979651,
50990860, 50991733, 50992512, 50992513, 50992514,
50943255, 50944990, 50951368, 50953221, 50953775,
50956899, 50958114, 50959130, 50966981, 50973710,
50907386, 50957614, 50959111, 51023738, 51004051,
51015231
Miscellaneous
2019 Operations Crew Roster
3/12/2019
Miscellaneous
2019 Operations Exam
3/29/2019
Miscellaneous
2019 Written Exam RO/SRO Week 1
4/5/2019
Miscellaneous
2018 Annual Operating Exams
5/24/2018
Miscellaneous
71111.11 Self-Assessment Report
10/5/2018
Miscellaneous
2018 Operations Training Self-Assessment Report
10/10/2018
Miscellaneous
9/4/2009
Miscellaneous
Simulator Plant Differences Report
4/1/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
B3-2-1(1)
ANSI-3.5 Simulator Test Manual Reactor Trip
2/13/2019
Miscellaneous
B3-2-1(3)
ANSI-3.5 Simulator Test Closure of all MSIVs
2/13/2019
Miscellaneous
B3-2-1(5)
ANSI-3.5 Simulator Test Trip of Single RCP
2/20/2019
Miscellaneous
B3-2-1(9)
ANSI-3.5 Simulator Test Main Steam Line Rupture
2/25/2019
Miscellaneous
B3.1 (100)
ANSI-3.5 Simulator 100% Steady State Power Test
3/25/2019
Miscellaneous
B3.1 (25)
ANSI-3.5 Simulator 25% Steady State Power Test
3/21/2019
Miscellaneous
Form 69-2034
RO License Reactivation
2/12/2018
Miscellaneous
Form 69-2034
RO License Reactivation
6/29/2018
Miscellaneous
Form 69-2035
SRO License Reactivation
4/25/2018
Miscellaneous
Form 69-2035
SRO License Reactivation
7/7/2018
Miscellaneous
Form 69-2035
SRO License Reactivation
2/26/2019
Miscellaneous
Form 69-2035
SRO License Reactivation
9/9/2017
Miscellaneous
Form 69-20642
Individual Remediation Training Record
1/31/2018
Miscellaneous
Form 69-20642
Individual Remediation Training Record
2/9/2018
Miscellaneous
Form 69-20642
Individual Remediation Training Record
1/5/2018
Miscellaneous
Form 69-20642
Individual Remediation Training Record
1/12/2018
Miscellaneous
Form 69-20642
Individual Remediation Training Record
6/4/2018
Miscellaneous
Form 69-20642
Individual Remediation Training Record
8/7/2018
Miscellaneous
Form 69-20642
Individual Remediation Training Record
9/28/2018
Miscellaneous
Form 69-20642
Individual Remediation Training Record
10/31/2018
Miscellaneous
Form 69-20642
Crew Remediation Training Record
4/9/2019
Miscellaneous
Form 69-20642
Individual Remediation Training Record (Student A)
9/8/2017
Miscellaneous
Form 69-20642
Individual Remediation Training Record (Student B)
9/8/2017
Miscellaneous
Form 69-20642
Individual Remediation Training Record
9/7/2017
Miscellaneous
Form 69-20642
Individual Remediation Training Record
2/5/2017
Miscellaneous
R1718SPRO.XLS
RO Operating Test Quality Sample Methodology
Miscellaneous
R1718SPSRO.XLS SRO Operating Test Quality Sample Methodology
Procedures
B3-2-1(7)
ANSI-3.5 Simulator Test Maximum Rate Power Ramp
2/20/2019
Procedures
B3.1 (100)
ANSI-3.5 Simulator 100% Steady State Power Test
3/25/2019
Procedures
Form 69-2035
SRO License Reactivation
1/10/2018
Procedures
Form 69-20642
Individual Remediation Training Record
11/22/2017
Procedures
OM14.ID2
Medical Examinations
Procedures
OP1.DC10
Conduct of Operations
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
TQ2.DC 15
Licensed Operator Annual/Biennial Exam Development and
Administration
Procedures
TQ2.DC 3
Licensed Operator Continuing Training Program
Procedures
TQ2.ID 4
Training Program Implementation
47A
Procedures
TQ2.ID 9
Conduct of Training
71111.11Q Corrective Action
Document
Notification
51033211
71111.11Q Procedures
JSIM-507
Evaluator Skills
71111.11Q Procedures
TQ2.DC3
Licensed Operator Continuing Training Program
Corrective Action
Documents
Notifications
51027990, 51028008, 51028376, 51027833, 51028007
Drawing
107723
Control Room HVAC (south)
105
Procedures
AD13.DC12
Control Room Envelope Habitability Program
Procedures
AD7.DC6
On-Line Maintenance Risk Management
Procedures
AD7.DC6
On-Line Maintenance Risk Management
Procedures
AD7.ID14
Assessment of Integrated Risk
Procedures
OP O-36
Protected Equipment Postings
Procedures
OP O-36
Protected Equipment Postings
Corrective Action
Documents
Notifications
51027597, 51027678, 51027584, 51025593, 50595423,
50042226, 50042428, 50081646, 50503871, 50524751,
50945969, 50946204, 50946299, 50946368, 50946436,
51031744, 51034990, 50676578, 51031001, 51034990,
51030260, 51027610, 50913105
Drawings
441286
4160 Volt Bus Section F Automatic Transfer
Drawings
441340
Potential and Synchronizing Diagram 4160V Bus Sections
F, G, & H
Drawings
6018227-16
Louver Schedule Turbine Building
Drawings
663231
Reactor Protection System Vendor Manual
Drawings
663231
Schematic Diagram - Isolation Card
137
Drawings
663231
Solid State Protection System Interconnection Diagram
Procedures
AR PK02-02
Safety Injection Initiate Annunciator Response
Procedures
AR PK04-12
Reactor Trip Initiate
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
AR PK08-22
Auto S.I. Blocked
Procedures
AR PK18-19
kV Bus F Auto Transfer Annunciator Response
Procedures
CP M-16
Severe Weather
Procedures
OM7.ID1
Emerging Issue and Event Investigations
Procedures
OM7.ID12
Procedures
STP M-75F
kV Vital Bus F Undervoltage Relay Calibration
Procedures
STP P-SIP-11
Routine Testing of Safety Injection Pump Checks Required
by Licenses
Work Orders
60023251, 64212870, 60105138, 60049371, 60105023,
60007325, 60120339, 60119104
Corrective Action
Documents
Notifications
51022989, 51023045, 51029356
Miscellaneous
DCP E-049490
Replacing Starter and Overload Relay TDAFW
Procedures
MP M-4.25
Auxiliary Feedwater Pump Turbine Governor Maintenance
Corrective Action
Documents
Notifications
50954692, 50993690, 50032499, 51029229, 50965742,
51029180, 50965347, 51028587, 51029500, 51033565,
51033619
Miscellaneous
RPE 211571
Fan & Motor Sheaves, Bushings, and Keys
Procedures
CF5.ID1
Receipt of Materials
Procedures
MP E-53.10A
Preventative Maintenance of Limitorque Motor Operators
Procedures
MP E-8.1
Centrifugal Charging Pump Motor Overhaul
Procedures
MP M-23-FAN.4
Preventative Maintenance of Ventilation Fans With
Dampers and Inlet Vanes
Procedures
OP J-6C:1
DFO Alignment and Operations
Procedures
STP P-CCP-21
Routine Surveillance Test of Centrifugal Charging
Pump 2-1
Procedures
STP P-SIP 11
Routine Surveillance of Safety Injection Pump
Procedures
STP P-SIP-21
Routine Surveillance Testing of Safety Injection Pump 2-1
Procedures
STP V-3L2A
Exercising Valve SI-2-8821A, Safety Injection Pump
Discharge to RCS Cold Legs
Procedures
STP V-3P5
Exercising Valves LCV-106, 107, 108, and 109
Auxiliary Feedwater Pump Discharge
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
60106782, 64165539, 64156641, 64206103, 60118888,
60118889, 64206104, 60108508, 64174611, 60118821,
64077390, 64129545
Drawings
107722
Gland Steam Supply Main Turbine, Sheet 2
Drawings
EQP-626
Load Bank Constraints
Procedures
OP E-5:II
Auxiliary Saltwater CCW Heat Exchanger Operation
Procedures
STP I-38-B.1
SSPS Train B Actuation Logic Test in MODES 1,2,3, or 4
Procedures
STP M-12B
Battery Charger Performance Test
Procedures
STP M-21C
Main Turbine Valve Testing
Procedures
STP P-CCW-A11
Comprehensive Pump Test of Component Cooling Water
Pump 1-1
Work Orders
64168747, 64168976
Procedures
EP G-3
Emergency Notification of Off-Site Agencies
Procedures
R18-3
Simulator Event Sequence
Procedures
TQ2.DC3
Licensed Operator Training Program
71151
Corrective Action
Document
Notification
50974176
71151
Miscellaneous
CDE 4.0 UAI
Unit 1/2, MSPI Derivation Reports MS05/ MS06 / MS07
06/10/2019
71151
Miscellaneous
MSPI Self-
Assessment
1; Calculation File C.10, DCPP PRA Model
Technical Adequacy
2/01/2012
71151
Work Orders
201443, 60106784, 60110022
Corrective Action
Documents
Notifications
51021044, 51015768, 51026933, 51013123, 51012969,
51015353, 51012973, 51016307, 51015025, 51015362,
51016480, 51019481, 51020675, 51020974, 51022319,
51020443, 51026379, 51017815, 51019542, 51002648
Drawings
2021
Diesel Generator, Sheet 2
Drawings
108021
Diesel Fuel Oil System
Miscellaneous
9000041674
Buried Piping and Tanks Program Asset Management Plan
Miscellaneous
ANSI/ANS-59.51-
1997Property "ANSI code" (as page type) with input value "ANSI/ANS-59.51-</br></br>1997" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.
Fuel Oil Systems for Safety-Related Emergency Diesel
Generators
Procedures
MP E-17.1
Westinghouse Auxiliary Saltwater Pump Motor Overhaul
Procedures
OM15.ID11
Human Performance Event Response
Procedures
OM15.ID8
Human Performance Error Prevention Tools
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
OM4.ID14
Notification Review Team (NRT)
Procedures
OM7.ID1
Problem Identification and Resolution
Procedures
OM7.ID3
Root Cause Evaluation
Procedures
OP J-6C:VI
DFO Transfer System - Pipe Leak Detection Operation
Procedures
OP1.DC40
Operations Equipment Deficiency and Adverse Condition
Monitoring
Procedures
OP1.ID6
Plant Status Control
Procedures
STP M-121
DFO Leak Detection System ANI-501 Functional Test
Procedures
STP M-122
Diesel Fuel Oil Underground Storage Tanks 0-1 and 0-2
Interstitial Test and Enhanced Leak Detection Test
Procedures
STP M-9A2
EDG Routine Surveillance Test
2A
BIENNIAL REQUALIFICATION INSPECTION DOCUMENT REQUEST
Inspection Report:
05000275/0219002, 05000323/2019002
Inspection Dates:
April 8 to April 12, 2019
Inspection Procedure:
IP 71111.11B, Licensed Operator Requalification Program
Lead Inspector:
Nicholas Hernandez, Operations Engineer
A. The following information is requested in order to support inspection preparation
activities. These items are listed by section as they appear in the inspection module
(i.e. 2.02, 2.04, etc.). Requested materials should be sent either electronically or by
CD/DVD in order to arrive at the Region IV office no later than March 15, 2019. Do not
send USB flash drives.
Electronically:
To:
Nicholas.Hernandez@nrc.gov (lead Inspector);
Cc:
Clyde.Osterholtz@nrc.gov (inspector)
CD/DVD:
To:
US Nuclear Regulatory Commission, Region IV
ATTN: Clyde Osterholtz
1600 E. Lamar Blvd
Arlington, TX 76011
General Requests:
List of licensed operators (SRO & RO) by crew (operating & staff)
Training and Operations Department organization charts (with qualified LOR
evaluators identified)
Procedures that identify process for revising and maintaining LOR continuing training
program
List of outstanding LOR program changes
List of plant events and industry operating experience incorporated into LOR
program since last BRQ
Audits and/or self-assessment reports addressing the LOR training program
Last 2 years of simulator review committee (or equivalent) meeting minutes
Last 2 years of Curriculum Review Committee (or equivalent) meeting minutes
2.03: Biennial Requalification Written Examination Quality
The current and approved biennial written examination schedule
The current requalification cycle written examination results to date
All written examinations that have been approved for administration up to the date of
submittal. Include password protection if e-mailed or double envelope protection if
mailed per NUREG-1021.
The current requalification cycle examination methodology (sample plan)
2.04: Annual Requalification Operating Test Quality
The schedule for the operating tests to be given the week of April 8,, 2019
All operating tests (password protected) that have been approved for administration
up to and including the week of the onsite inspection
All 2019 NRC-required annual operating tests
Current requalification cycle operating test results
Current requalification cycle operating test methodology (sample plan)
List of time critical operator actions, including USAR references
2.05: Licensee Administration of Requalification Exams
All procedures used to administer the annual operating test
All procedures used to assess operator performance
All procedures that describe conduct of simulator training
All procedures used to test, operate, and maintain the simulator
2.06: Requalification Examination Security
Tracking tools used to prevent excessive overlap on the written examinations and
ensure sampling of required topics on a periodic basis
Tracking tools used to prevent excessive overlap on the operating tests and ensure
sampling of all required malfunctions (major events, instrument/component
malfunctions, TS calls, etc.) on a periodic basis.
All procedures that describe examination security, including procedures used to
develop the examinations that include guidelines on overlap between examinations
in current exam cycle tests and prior year examinations
List of all condition reports since the last biennial requalification inspection related to
examination security and overlap
2.07: Licensee Remedial Training Program
List of remedial training conducted or planned since last biennial requalification
inspection (includes remedial training for exam failures and training to correct generic
or individual weaknesses observed during previous requalification exam cycle)
Remediation plans (lesson plans, reference materials, and final documentation)
2.08: Conformance with Operator License Conditions
All procedures and program documentation for maintaining active operator licenses,
tracking training attendance, and ensuring medical fitness of licensed operators
All procedures and associated documentation that supports reactivation of any
SRO/RO license (operating or staff crew) since the last biennial inspection
2.09: Simulator Performance
For the following cases, send the most recent transient test packages, which may be
electronic or in paper single test packages, and shall be complete with test procedures
for each test, the acceptance criteria, and results. For each transient
test, the reference chart should be included or an equivalent subject matter expert
review versus the simulator results with a write-up for any differences beyond the
ANSI 3.5 standard requirements.
o Transient test 3, Simultaneous closure of all main steam isolation valves
o Transient test 10, Slow primary system depressurization to saturated
condition with pressurizer relief or safety valve stuck open (inhibit activation of
high pressure emergency core cooling system)
o Steady State tests for low power test
SBT packages for any three scenarios used for the 2018 annual requalification
operating test
All simulator management and configuration procedures if not already provided for
Section 02.05 above
Simulator discrepancy report (DR) summary list for all open DRs. For closed DRs,
summary list for those items closed between April 8, 2017
Two examples of primary parameters tested in order to verify core physics
parameters. The applicable reference graphs from the plant physics data book
(electronic or other means as available) should also be included as well as the test
procedures used and the acceptance criteria with results.
All simulator modification packages that are on hold, delayed, or just not completed
in the last 2-years
A list of simulator modification packages completed in the last 2-year window
2.10: Problem Identification and Resolution
A summary report of all condition reports related to licensed operator actions/errors
in the control room since April 8,2017
Any revised requalification training that was based on licensed operator performance
issues since April 8,, 2017
B. The following information is requested in order to support the onsite inspection
activities. Requested materials should be available to the inspection team, either
electronically or hardcopy, upon site arrival on April 8, 2019.
2.02: Exam Results / 02.03 and 02.04: Written Exam and Op Test Quality
All approved operating tests (password protected) to be administered subsequent to
the onsite inspection
All results up to the day the team leaves the site.
2.08: Conformance with Operator License Conditions
Access to licensed operators records
Access to licensed operators training attendance records
Access to licensed operators medical records
2.09: Simulator Performance
Simulator discrepancies reports (DRs) since April 8, 2017. This should include all
open and closed DRs, with documentation / justification for closure
- Acceptance test documentation, including hardware and software model revisions at
the time of acceptance (as available)
Documentation that validates current models, including the thermal-hydraulic and
neutronics models, to the actual plant
All current model deficiencies, including USAR vs design differences in the simulator
Summary list of plant modifications since April 8, 2017
Plant modifications (both hardware and software) incorporated onto the simulator
since April 8, 2017.
The complete book of all simulator annual performance test packages (either
hardcopy or electronic), complete with all transient tests, steady state tests, and
malfunction tests. This should also include the test procedures for each test, the
acceptance criteria, and results. For each transient test, the reference chart should
be included or an equivalent subject matter expert review versus the simulator
results with an analysis for any differences beyond the ANSI standard requirements
Simulator reactor core performance test packages used to verify core physics
parameters (ANSI/ANS 3.5 sections 3.4.3.3 / 4.4.3.3), including applicable reference
graphs from the plant physics data book, test procedures, acceptance criteria, and
results
All simulator test, configuration management, and related documents available in the
room for inspectors to review. This includes training needs analysis packages,
simulator review committee meeting minutes, etc.
Current copy of ANSI 3.5 standard you are committed to for simulator testing
2.10: Problem Identification and Resolution
All condition reports related to licensed operator actions/errors in the control room.
All condition reports from the last initial license exam
C. Diablo Canyon Power Plant is required to send the final results and any remaining
written exams and operating tests to the lead inspector for final review and
comparison against the significance determination tools in order to communicate the
exit results for the inspection. Report results in the format below:
1. Total number of licensed operators.
2. Number of licensed operators administered a requalification examination
required by 10 CFR 55.59(a).
3. Number of individual licensed operators who failed any portion of a
requalification examination (written, JPM, or individual simulator scenario
failures).
3.a. Number of individual licensed operators who failed written exam
3.b. Number of individual licensed operators who failed JPM exam
3.c. Number of individual licensed operators who failed simulator
scenario exam individually
4. Divide line 3 by line 2 to obtain the individual requalification examination
failure rate
%
5. Number of crews administered simulator scenarios as part of a
requalification examination required by 10 CFR 55.59(a)
6. Number of crews who performed unsatisfactorily on the simulator
scenarios.
7. Divide line 6 by line 5 to obtain the crew simulator scenario failure rate.
%
8. Describe the reason for each licensed operator who was not administered
an NRC-required requalification exam, or who did not pass an administered
requalification exam, and the stations plan to satisfy the requalification
exam requirement for each.