ML16341F494
| ML16341F494 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/13/1989 |
| From: | Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341F493 | List: |
| References | |
| 50-275-89-29, 50-323-89-29, NUDOCS 9001050185 | |
| Download: ML16341F494 (14) | |
See also: IR 05000275/1989029
Text
U.S.
NUCLEAR'EGULATORY COMMISSION
REGION
V
Report Nos.:
50-275/89-29
50-323/89-29
Docket Nos.:
50-275
50-323
Licensee:
Pacific
Gas
and Electric Company
77 Beale Street,
Room 1451
San Francisco,
CA 94106
Facility Name:
Diablo Canyon Units
1 and
2
Inspection at:
Diablo Canyon Units
1 and
2
Inspection
Conducted:
November
20 - 22,
1989
Inspect'or:
L.
F. Hiller, Jr., Chief, Operations
Section
Approved by:
Summary
L
F. Hi
er,
J .,
hief
Operations
Sect
ate Signed
Ins ection'on
November
20 - 22,
1989 (50-275/89-29,
50-323/89-29
Areas
Ins ected:
Special
announced
inspection to review how the licensee
sta
ed t e Shift Supervisor position at Diablo Canyon Units
1 and 2.
In
particular,
the apparent
assignment of an unlicensed
person to this position
from September
1,
1988 to January
6,
1989
was reviewed.
Results:
Three apparent violations were identified:
assignment
of an unlicensed
person to
a position responsible for directing licensed activities of
licensed operators,
failure to designate
a senior license'd
person to be
onsite at all times with responsibility for overall plant operation,
and
failure to provide complete information regarding
a
10 CFR Part 55 license
application.
900i050iag
gPy~1P
ADOCl( 05000~75
A
Ql ll
DETAILS
Persons. Contacted
- J. Townsend,
Plant Manager
L. Womack, previous Assistant Plant Manager,
Operational
Services
'S.
Fridley, Operations
Manager
".T. Grebel,
Regulatory Compliance Supervisor
- D. Miklush, Assistant
Plant Manager,
Operational
Services
- W. Kelly, Regulatory
Compliance
Super'visor
J. Molden, prev'ious Assistant Training Manager
The inspector also contacted
other licensee
personnel
for assistance
and supplementary
information.
- Attended the Exit Meeting
on November 22,
1989.
Introduction
This special
inspection
was conducted
from November 20-22,
1989,
to follow-up on information provided to Region
V by the licensee
that
a previously licensed
senior reactor operator at Diablo Canyon
had
been the Shift Supervisor
(SS) at Diablo Canyon from September
1,
1988, to January
6,
1989,
a period when
he
no longer held
a Senior
Operator's
License
(SOL) license.
As discussed
in this report,
the
Shift Supervisor position at Diablo Canyon is one which requires
an
SOL.
The person initially received
a
SOL in June
1981, at Diablo Canyon Unit .
No.
1.
This was
amended
to
a dual unit license
in January
1985,
and
renewed periodically as required. 't was
renewed
most recently in
June
1987, for a six year term.
On January
1, 1988,
the license
was
terminated at
PGSE's
request
due to their determination that the
utility had
no further need for it.
On October
25.,
1989,
the utility requested
reinstatement
of the
individual's license
by reapplying for
a
SOL and requesting
waiver
'f
the written and operating
examination.
In the request,
the
licensee
noted that the individual had continued to participate
in
all requalification training and testing,
and that
he
had
been
"on temporary assignment
to the Operations
Department in an
on-shift operational
management
role."
The inspector
reviewed the waiver request,
and
on November 7,
1989
requested
additional details
regarding
the assignments
of the
individual in the period since his license
had
been terminated.
On
November
13,
1989,
licensee
personnel
informed the inspector that the
individual
had
been
a Shift Supervisor
from September
1, 1988, to
January
1,
1989,
a period during which he was
no longer licensed.
On November
15,
1989,
a telephone
interview of the Diablo Canyon Plant
Manager,
was conducted
by Mr. A. Chaffee,
Deputy Division Director,
Division of Reactor Safety
and Projects.
The Plant Manager committed
that the licensee
would ensure that the Shift Supervisor position
was
staffed with a licensed senior reactor operator until this matter
was
resolved'e
volunteered that the licensee
had always considered
that
'he
Shift Foreman position, which was always staffed with a senior reactor
operator,
was the one which the licensee
equated
to the "Shift Supervisor"
position in the Technical Specifications.
The special
inspection,
conducted
November 20-22,
1989,
reviewed the
following documents,
including all approved revisions
as noted below:
Technical Specifications Section 6.1, "Responsibility,"
and
Section 6.2, "Organization," through
Amendment 28/29
Nuclear Plant Administrative Procedure
(NPAP) A-102, "General
Authorities and Responsibilities
of the Shift Foreman,"
Revisions
0 through
6
Administrative Procedure
(AP) A-150, "General-Authorities
and
Responsibilities
of the Shift Supervisor,"
Revisions
0 through
3
NPAP A-5, "Organizational
Control of Emergencies,"
Revisions
0
through
5
Other licensee
procedures
and
memoranda
related to the authority and
responsibility of the Shift Supervisor
were also reviewed.
In addition,
several
licensee
personnel
were interviewed.
Histor
of Shift Su ervisor Position at Diablo Can
on
Based
upon the above reviews,
the inspector
determined that the Shift
Supervisor position at Diablo Canyon
had developed
as detailed
below.
On June
1,
1980 the Shift Foreman position
was defined.
This person
was
responsible
to direct all activities= affecting the safety of the nuclear
power plant.
This was prior to licensing of either unit.
On June
26,
1981 the licensee's
response
to
NUREG 0737 explicitly
equated
the Shift Foreman position to the "shift supervisor"
discussed
in Section
6. 1 and 6.2 of the Technical Specifications
(TS).
In April 1985, Pacific
Gas
and Electric was licensed
to- operate
Diablo Canyon
1 and
2 using its
common control
room.
The Technical
Specifications
established
control
room staffing requirements
which have
remained
unchanged
to the date of this inspection, with respect
to
mann'ing.
These
required
a Shift Supervisor responsible for the Control
Room
Command function, with a Senior Operator's
License (SOL),'n addition
to another operator with a
SOL,
and three operators
with Operator Licenses.
0
The
TS also required the Vice President,
Nuclear
Power Ge'neration,
to
annually designate
that the Shift Supervisor shall
be responsible for
the "Control
Room
Command function."
The licensee
considered
that this
requirement
had
been
met by an annual directive to all Shift Foremen
advising
them that they were responsible for all control
room
activities.
In April 1985, the licensee
commenced
operating with two Shift Foremen,
one for each unit, both having
SOLs.
Prior to this time, only the
Unit
1 Shift Foreman
had
been .required,
since only Unit
1 had
an
operating license.
The Plant Manager
and others recollected that the Unit
1 Shift Foreman
continued to have authority over the Unit 2 Shift Foreman,
but the
licensee
could not substantiate
that this
had ever
been
a formal
assignment.
Both Shift Foremen
reported to the Operations
Manager,
who'as
required
by the
TS to hold an
SOL.
The Operations
Manager
was not
on shift, however.-
The inspector
found that
no one person
was formally assigned
to be in
overall control of plant operations,
present
on site,
and possessing
an
SOL.
Also, the requirement that management
direct
a single individual
to be responsible
for the "Control
Room Command" function was,
apparently,
never recognized.
Licensee
representatives
stated that the designation of two senior
licensed operators,
the
two Shift Foremen,
to both have "control
room
command" function for their individual units
was thought to exceed
the
TS requirement.
The Plant Manager,
J.
Townsend,
stated
repeatedly that
management's
intention was that one senior licensed
person,
the Shift
Foreman,
was in charge of his respective
Unit.
In Spring
1987,
the licensee
created
a position to be
known as the Shift
Supervisor
(SS),
Licensee
representatives
stated that the
SS was
intended to have
been
a senior licensed
and degreed
person
who would
coordinate
and direct all personnel
onsite in the operation of the
entire plant,
They insisted that it was not intended that the
assume
any licensed authority of the Shift Foreman.
Initially, the
position
was only manned part time.
On May 6,
1987
an Operations
Department
memorandum
was sent to all shift
foremen,
advising
them that to maintain
an active license
(under
new 10 CFR Part 55 requirements)
they were to stand watch in certain designated
pos,itions for seven
days
per calendar quarter.
"Shift Supervisor"
was
one of the positions
designated
as acceptable
for maintaining
an active
license.
and 55,53 define
an active license
as
one where the
individual licensee
"actively perform[sj the functions of an operator
or senior operator."
This is defined
as
"a position
on the shift crew
that requires
the individual to be licensed
as defined in the
facility's TS,
and the licensee carries
out and is responsibl'e for the
duties
covered
by that position."
Shift Supervisors
have continued to
be permitted
by the licensee
to use their service
as Shift Supervisors
to count for the time needed
to maintain. active licenses.
On October 7,
1987, the
SS responsibility
procedure,
AP-150,
was
created.
AP-150, Section 4. 1. 1 stated that:
"The Shift Supervisor is
responsible for the direct supervision of the Shift Foreman
on the
assigned shift and for providing overall direction of all plant
activities to ensure
the safe operation of both Diablo Canyon units."
Section 4.2.2 further stated that:
"The Shift Supervisor
acts
as the
Interim Site
Emergency Coordinator
(ISEC) during plant emergencies
and
directly supervises
recovery actions."
According to
NPAP A-5, Section
4. 1.2c, the
ISEC was that person
"responsible for overall
command
and
control of the emergency."
Revision
1 to the procedure
(March 4,
1988)
added
a provision that the
Shift Supervisor
should relieve the Shift Foreman if the Shift Foreman
became
incapacitated.
Revision
3 (November
15,
1988) restricted
the
Shift Supervisor to relieving the Shift Foreman of the control
room
command" function only if the Shift Supervisor
possessed
an active
SOL.
This revision reaffirmed that the Shift Supervisor
was to become
the
Interim Site
Emergency Coordinator in an emergency.
In January
1988,
the Shift Supervisor position
began to be manned
continuously
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
per day.
The licensee
did not document this
policy decision.
Unlicensed
0 eration of Diablo Canyon Units
1 and
2
In August 1988,
the individual involved was requested
by the Assistant
Plant Manager,
Operational
Services
(APMOS) at that time, to serve
as
a
Shift Supervisor for a plant outage
scheduled
for October through
December
1988.
The
APMOS, previously the Operations
Manager,
held
an inactive
SOL.
The individual advised
the
APMOS that
he was neither degreed
nor
licensed.
The
APMOS responded
that neither
a degree
nor an
SOL was required for
the position,
and directed that procedures
NPAP A-102 and
AP A-150 be
revised to state that
an unlicensed shift supervisor
could not relieve
an incapacitated
licensed Shift Foreman.
The
APMOS stated that
he
knew
that the
TS requirements
were being met without reliance
on the
SOL
licenses
which Shift Supervisors
had always held,
and that
he
and his
management
had confidence
in the individual's qualifications for the
assignment.
The
APMOS stated that
he did not consider the decision
significant.
Both procedures
were modified with interim,changes,
but the interim
change to
NPAP A-102 (Shift Foreman's
responsibilities)
was rejected
by
the Plant Safety Review Committee
as
a change
not within their
authority.
No follow-up action to reconcile the procedures,
or the
'nterim
changes
proposed,
was
made
by the licensee.
On September
1,
1988, the individual
commenced
watchstanding
as the Shift
Supervisor.
He stated that
he stood this watch "jointly" with a senior
licensed shift supervisor for about
one week.
He then stood the watch
by himself.
This continued
through January
6,
1989.
The individual stated that
he attempted
to not take
any action
as the Shift
Supervisor which interfered with the
"command
and control" function of
either Shift Foreman,
and
he deferred signature authorizing certain work
where it was clearly identified on the document to be signed that
a senior
reactor operator's
approval
was required.
An example of this was
authorization of revisions to test procedures.
He also stated that
he
understood
his responsibility
to be to enhance productivity by coordinating
the actions of all the plant departments
rather than direct control of the
plant.
He stated that,
as the author of the emergency classification procedure,
and the person
who had conducted training for all licensed operators
on
that procedure,
he was qualified to be the Interim Site Emergency
Coordinator in the emergency,
should that have
been required.
Licensee
representatives
asserted
that the individual's assignment
was the
only instance
wherein
a Shift Supervisor
who did not possess
an active
SOL
was assigned
to the
SS position.
5.
Conclusions
b.
The inspector
observed
that
as the Shift Supervisor for three months,
the individual was procedurally required to directly supervise,
on shift, the Shift Foreman,
a licensed senior operator,
to provide
overall direction of all plant 'activities to ensure
safe operation,
and to be responsible for overall
command
and control of any
emergency.
The inspector
concluded that the licensee's
assignment
of the individual to the position of Shift Supervisor apparently
violated the requirement of 10 CFR 50.54
1 that individuals
responsible
for directing the licensed activities of licensed
operators
shall
be licensed
as senior operators.
The inspector
observed that the licensee
operated
Diablo Canyon
Units I and
2 since initia'l licensing of both units in April 1985
without apparent
recognition of the requirement of 10 CFR 50.54
(m)(2)(ii), that
a senior licensed
person
was required to be onsite
at all times with responsibility for overall plant operation,
The
licensee
presumed that manning the site with a senior licensed
person
responsible for each unit was sufficient.
The establishment
of the Shift Supervisor position with the required authority and
senior license
in January
1988 corrected this apparent violation.
However', at the conclusion of the inspection,
there existed
no
procedural
requirement to staff the Shift Supervisor position,
nor
to require that the Shift Supervisor
be senior
licensed.
As
a corollary to this finding, the inspector
noted that the
licensee
had never satisfied
the Technical Specification 6. 1.2
'equirement
that the Vice President,
Nuclear
Power Generation
issue
ar, annual directive identifying the person
responsible for
the control
room command function.
Specifically, the annual
directive which was sent identified the Shift Foremen
as the
responsible
person with the control
room command function.
The
implicit bifurcation of overall responsibility
inherent in the
licensee's
assignment
of responsibilities
was not recognized
by
the licensee,
or acknowledged
by the licensee
when identified by
the
NRC.
0
'
C.
The inspector
concluded that. the information provided
by the
licensee
in their request
for relicensing of the individual
on
October 25,
1989
was incomplete in stating that his assignment
for September
1,
1988 through January
6,- 1989
had
been
"an on-shift
operational
management role."
The failure to specify that the .
individual
had
been the Shift Supervisor apparently violated the
requirement of 10 CFR 50.9(a)'hat
information provided to the
NRC by a licensee
shall
be complete
and accurate
in all material
respects
.
The subsequent
clarification of this significant detail
by the licensee
resulted
in this inspection
and the identification
of the apparent violations identified above.
6.
Exit Interview
The i'nspector
met with licensee
management
representatives
(Paragraph
1)
on November 22,
1989.
The scope of the inspection
and the inspector's
findings,
a's noted in this report,
were discussed
and acknowledged
by
the licensee
representatives.
The Plant Manager explained that the intent in creating
the
SS position
had
been to accomplish
something
broader in scope
than what they understood
as the control
room command function,
and that
PGSE
had always
intended
to maintain
a licensed
chain of command.
He stated that
he considered
the significance of inserting the
SS into the chain of command
had not
been appreciated,
He concluded
by, committing that
PGSE will have licensed
individuals in the direct chain of command
from the Operations
Manager to
the reactor operators,
to include the SS, for the present.
The person
designated
by all procedures
as the single person
in overall control of
the plant at all times will be senior
licensed.
If the organizational
structure
was modified, Region
V would be informed.
Ill