ML16343A312

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Insp Repts 50-275/95-04 & 50-323/95-04 on 950522-25. Deviations Noted.Major Areas Inspected:Qualifications of Applicants for OL & Licensed Operator Requalification Program
ML16343A312
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 06/20/1995
From: Pellet J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML16342C960 List:
References
50-275-95-04, 50-275-95-4, 50-323-95-04, 50-323-95-4, NUDOCS 9506280649
Download: ML16343A312 (20)


See also: IR 05000275/1995004

Text

ENCLOSURE 2

U.S.

NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection

Report:

50-275/95-04

50-323/95-04

Licenses:

DPR-80

DPR-82

Licensee:

Pacific

Gas

and Electric Company

77 Beale Street,

Room

1451

P.O.

Box 770000

San Francisco,

California

Facility Name:

Diablo Canyon Nuclear

Power Plant, Units

1 and

2

Inspection At:

Diablo Canyon Nuclear

Power Plant,

Units

1 and

2

Inspection

Conducted:

May 22-25,

1995

Inspectors:

Joseph I. Tapia,

Examiner/Inspector,

Operations

Branch,

Division of Reactor Safety

Stephen

L. McCrory, Examiner/Inspector,

Operations

Branch,

Division of Reactor Safety

Approved:

o

.

e

et,

ie

,

perations

rane

Division of Reactor Safety

ate

Ins ection

Summar

Areas

Ins ected

Units

1

and>> 2

Routine,

announced

inspection of the

qualifications of applicants for operating licenses,

the licensed operator

requalification program,

and ability to detect

and respond to steam generator

tube leaks

and tube ruptures.

Results

Units

1 and

2

~0eratioas

Both applicants for initial licenses

passed

the examinations

(Section 1).

The reference

material

provided

by the training department for

examination

development

was

good

and adequately

supported

examination

development

(Section

1. 1).

9506280649

95062i

PDR

ADQCK 05000275

8

PDR

The examiners

observed generally

good communication practices

by

applicants

during the conduct of the examination

(Section 1.2).

Operator

performance

during the requalification examination

was

satisfactory with some weaknesses

in communications

and

command

and

control.

Examples of nondirected

communications,

informal wording,

multiple conversations

and failures to repeat

back were noted

(Section 2.2).

~

The licensee's

handling of generic

communications

related to steam

generator

tube integrity was considered

appropriate,

however,

one

example of untimely implementation of generic

communications

was noted

(Section 3.1).

~

The licensee

exhibited

good capability and used diverse

methods for

detection of primary-to-secondary

leakage.

Appropriate alarm setpoints

were utilized to provide rapid notification of increasing

leakage

(Section 3.2

and 3.3).

.

The procedures

and supporting training that were

used

by operators

in

response

to primary-to-secondary

leakage

were good (Section 3.4).

Summar

of Ins ection Findin s:

~

The practice of allowing licensed reactor operators

to fill the position

of senior control operator

was not consistent with the commitment

made

by the licensee

in the

FSAR and resulted

in

a Deviation (Section 2.2).

~

One deviation

was identified during this inspection

(275;323/9504-01).

Attachments:

~

Attachment

1 - Persons

Contacted

and Exit Heeting

~

Attachment

2

Simulation Facility Report

- ~

-3-

DETAILS

1

LICENSED OPERATOR APPLICANT INITIALQUALIFICATION EVALUATION (NUREG-1021)

During the inspection,

the examiners

evaluated

the qualifications of one

license applicant for senior reactor operator

and

one applicant for reactor

operator.

The inspection

assessed

the eligibility and administrative

and

technical

competency of the applicants to be issued

licenses

to operate

and

direct the operation of the reactivity controls of a commercial

nuclear

power

facility in accordance

with 10 CFR Part 55 and

NUREG-1021,

"Operator License

Examiner Standards,"

Revision 7,

Supplement

1, Sections

200 (series),

300

(series),

and

400 (series).

Further,

the inspection

included evaluations of

facility materials,

procedures,

and simulation capability used to support

development

and administration of the examinations.

These

areas

were

evaluated

using the guidance

provided in the areas of NUREG-1021 cited above.

Both applicants

were being reexamined.

Accordingly, the written examination

was waived based

on prior successful

completion in accordance

with 10 CFR 55.35

and

10 CFR 55.47.

Similarly, the administrative topics

and control

room

systems/facility walk-through part of the examination

was waived for both

applicants.

After completion of the evaluations,

the examiners

recommended

that both

applicants satisfied the requirements

of 10 CFR 55.33(a)(2),

and both have

been

issued

the appropriate

licenses.

1. 1

Facilit

Haterials

Submitted for Examination

Develo ment

Host of the materials

had

been

submitted for development of the initial

reactor operator

examinations

administered

by the

NRC in October

1994.

In

addition, the licensee

updated

the materials prior to the re-examination.

The

materials

were adequate

in scope,

depth,

and variety for examination

development.

1.2

0 eratin

Examinations

The examiners

developed

comprehensive

operating tests

in accordance

with the

guidelines of NUREG-1021,

Revision 7, Supplement

1, Section

301.

The

operating examinations

consisted of an evaluation of integrated plant

operations.

The examiners

previewed

and validated the operating

examination

on Hay 22,

1995, with the assistance

of facility training personnel

under

security agreement.

The examination

was administered

on Hay 22,

1995.

The examiners

evaluated

the two applicants

on two scenarios

using the Diablo

Canyon plant-specific simulation facility.

The licensee

provided

a training

instructor to act

as

a surrogate for staffing of a three

person operating

crew

for purposes

of the examination.

The examiners

compared applicants'ctual

performance

during the scenarios

with expected

performance

in accordance

with

the requirements

of NUREG-1021,

Revision 7,

Supplement

1, Section

303, to

evaluate applicants'ompetency

on the operating

examination.

0

The applicants

demonstrated

good

command

and communication discipline during

the simulator scenarios.

The applicants

exhibited familiarity with facility

procedures

and were quick to evaluate

which procedure

was required

and then

locate

and reference that procedure.

Crew feedback

was solicited

and

appropriately

incorporated

into responses

to events.

The prioritization of

event responses

was appropriate.

1.3

Simulator Fidelit

During the preparation

and conduct of the operating

examination,

the examiners

observed

one minor discrepancy

in simulator fidelity, as described

in

Attachment 2.

The discrepancy

did not affect the validity of the operating

examination.

2

LICENSED OPERATOR REgUALIFICATION PROGRAM EVALUATION (IP 71001)

During the inspection,

ongoing annual requalification examinations

were

observed

and programmatic

requirements

were reviewed to assess

whether the

licensee's

requalification program

was evaluating operators'astery

of

training objectives

in accordance

with 10 CFR Part 55.

This included review

of the examination material

and

an assessment

of the examination

evaluators'ffectiveness

in conducting examinations.

2. 1

0 eratin

Examination

The inspectors

evaluated

the dynamic scenarios

being used in the operating

examination with respect

to the guidelines of NUREG-1021, section

604.

The

licensee

examined operating'rews utilizing two different scenarios

for each

crew during the week of the inspection.

The format and content of the

scenarios

were consistent

with the guidelines of NUREG-1021

and adequate

to

discriminate safe operator performance.

The initial conditions of the

scenarios

were realistic

and the scenarios

consisted of related events.

The

scenarios

had

been previously validated

by the training staff and allowed the

evaluators

to measure

the examinees'ompetencies

commensurate

with the

scenario objectives.

2.2

0 erator

Performance

An inspector

observed

one shift crew and

one crew composed of on-shift and

staff personnel

on two scenarios

each in the dynamic simulator examinations.

The crew composition included

a shift supervisor,

a shift foreman,

a senior

control operator,

two control operators,

and

a shift technical

advisor.

For

the shift crew, the inspector

noted satisfactory

performance of the crew and

individual operators,

with adequate

communications,

command

and control.

Some

examples

of nondirected

communications,

informal wording, multiple

conversations,

and failures to repeat

back were noted.

The mixed crew also

exhibited satisfactory

performance,

however,

the inspector

observed

conditions

which challenged

the

command,

control

and communication function during

response

to an emergency condition.

0

Diablo Canyon Administrative Procedure

OPI.DC11,

Rev.

1,

"Conduct of Control

Operations-Abnormal

Plant Conditions," establishes

the structure of the

control

room staff during abnormal

plant operations.

In accordance

with this

procedure,

the shift foreman provides overall direction

and supervision of the

control

room activities while the senior control operator

assumes

the duty of

procedure

reader.

The senior control operator is expected

to interact with

the shift foreman whenever there

are procedure transitions,

entry points,

or

questions

as to the effectiveness

of the procedure.

During observations

of

the mixed crew, the inspector

noted that the shift foreman spent

a

considerable

amount of time in activities that did not lend themselves

to

maintaining overall direction of control

room activities.

These

included

protracted

conversations

with both the shift supervisor

and the shift

technical

advisor,

and telephonic

communications

with plant personnel.

At the

same time, the senior control operator

adopted

a role beyond that of procedure

reader

and included directing

and providing responses

to questions

from

control board operators.

The consequence

of the assumption of those roles

by

the shift foreman

and the senior control operator

was that

command

and control

of control

room activities

and communications

among operators

suffered.

Overall coordination in response

to the scenario

events

became

focused

on the

senior control operator

and the involvement of the shift foreman

was

fragmented.

As

a result of the performance

exhibited by the mixed crew, the inspector

reviewed the licensee's

programmatic

requirements

which delineate

the general

authorities

and responsibilities of operating shift personnel.

During this

review, the inspector

noted that the position of senior control operator

was

allowed to be filled by either

a licensed reactor operator or licensed senior

reactor operator.

Further review disclosed that seven of the nineteen

designated

senior control operators

are licensed reactor operators

while the

remaining twelve have senior reactor operator licenses.

The senior control

operator in the mixed requalification examination

crew was

a licensed reactor

operator.

In addition, the inspector verified that,

on Hay 23 and 24,

1995,

the on-shift Unit 2 senior control operator

was

a licensed reactor operator

and not

a licensed

senior reactor operator.

The inspector

expressed

concern

that

a licensed reactor operator

was being placed in a position of directing

the licensed activities of other licensed reactor operators.

10 CFR Part 50.54(l) specifically authorizes

only those licensed

as senior reactor

operators

to direct the licensed activities of licensed operators.

The

licensee

agreed that the observations

made

by the inspector of the constituted

crew were of concern,

but did not agree that the senior control operator

was

directing the activities of other licensed reactor operators for actual

operating

crews.

The licensee's

Updated Final Safety Analysis Report Section

13. 1.2.3, "Shift

Crew Composition," provides

a description of the minimum shift organization

that the licensee

provided to satisfy

10 CFR Part 50.34(b)(6)(i).

The Final

Safety Analysis Report

was originally submitted

as part of the application for

the operating license

and

has

been periodically updated

in accordance

with 10 CFR Part 50.71.

The most recent

update,

Revision

10,

was issued

on April 27,

1995.

Figure

13. 1-3 is referenced

by Section

13. 1.2.3

and describes

the

senior control operator

as requiring

an

NRC senior reactor operator license.

The licensee's

current practice of allowing licensed reactor operators

to fill

the position is not consistent with the Updated Final Safety Analysis Report

and represents

a deviation from a commitment

(275;323/9504-01).

2.3

Evaluations

The inspector

observed

the post scenario

evaluations.

The observations

and

analyses

made

by the training department

evaluators

were detailed

and well

focused.

The facility evaluators

identified crew strengths

and weaknesses

as

well as individual strengths

and weaknesses.

The evaluators

rated the

examinees'ompetencies

by comparing actual

performance

during the scenarios

against

expected

performance

in accordance

with the guidance of NUREG-1021.

The evaluators

did not record that the senior. control operator,

a licensed

reactor operator,

was directing the activities of other licensed reactor

operators.

As

a result,

no performance

feedback

was provided to the operator.

3

PRIHARY-TO-SECONDARY LEAKAGE NONITORING AND RESPONSE

An inspection

was performed to determine

the effectiveness

of the licensee

programs

and actions

concerned

with monitoring of and response

to steam

generator

primary-to-secondary

leakage.

The areas

reviewed included handling

of generic communications

related to steam generator

tube integrity, the

adequacy of procedures

and equipment to provide real time information on leak

rate

and rate of change of leak rate,

the adequacy of alarm set points

on

radiation monitors

used for detection of leakage

and for alerting operators

to

any increasing

primary-to-secondary

leak rate,

and operator training.

3. 1

Licensee

Res

onse to Generic

Communications

The inspectors

reviewed the licensee's

handling of specific generic

communications

related to steam generator

tube integrity.

The inspectors

reviewed the licensee

evaluations of Information Notices 88-99,

"Detection

and Honitoring of Sudden

and/or Rapidly Increasing

Primary-to-

Secondary

Leakage";

91-43,

"Recent Incidents Involving Rapid Increases

in

Primary-to-Secondary

Leak Rate";

and 93-56,

"Weakness

in Emergency Operating

Procedures

Found

as

a Result of Steam Generator

Tube Rupture."

The licensee's

actions

in response

to these

generic

communications

were found to be

appropriate

and included implementation of applicable mitigation strategies.

The inspector

reviewed the licensee's

actions

in response

to the industry's

Significant Operating

Experience

Report

(SOER) 93-1,

"Diagnosis

and Hitigation

of Reactor Coolant System

Leakage

Including Steam Generator

Tube Ruptures."

This document

was evaluated

by the licensee's

Independent

Safety Engineering

Group

(ISEG)

and resulted

in eight recommendations,

dated

June 7,

1994.

The

Plant Staff Review Committee

(PSRC)

concurred with six of the eight

recommendations

in June,

1994.

The necessary

"Action Requests"

to implement

the resulting

recommendations

were not generated

by the

ISEG until Harch,

1995.

This untimely action resulted

because

of informal processes

which

allowed the generation of the Action Requests

to be overlooked.

The delay in

implementing the recommendations,

which resulted

from the

ISEG evaluation of

an industry report,

indicates

a potential vulnerabili'ty which, in this case,

did not significantly impact the safety of the plant.

3.2

Procedures

and

E ui ment Ade uac

for Leak Rate Information

Chemical Analysis Procedures

AP-I, Revision 2,

"Prompt Steam Generator

Leak

Identification Procedure,"

and D-15, Revision 6,

"Steam Generator

Leak Rate

Determination,"

were reviewed

by the inspector.

These

procedures

were found

to provide good bases for promptly identifying which steam generator

is

leaking or ruptured

and for quantifying the primary-to-secondary

leak rate.

The referenced

radiation monitoring equipment

was capable of measuring

the

concentrations

of contaminants

in the secondary

system

and comparing those to

the concentrations

in the primary system,

identifying and quantifying the leak

rate

and thereby minimizing the potential for large-scale

secondary

contamination

and effluent releases

by isolating the affected

steam generator.

3.3

Alarm Set pints

on Radiation Monitors

The inspector

reviewed the alarm set points

on radiation monitors

used in each

unit for detection of leakage

and alerting operators

to an increasing

leak

rate.

The inspector

determined that the radiation monitors in both units,

that- were used for detection of leakage,

were set suitably low to ensure rapid

notification of any increasing

primary-to-secondary

leak rate.

Confirmation

of any primary-to-secondary

leak rate indications were to be

made through

independent

chemistry measurements.

The first indication of primary-to-secondary

system leakage

was provided

by

redundant

condenser air ejector monitors which were Victoreen beta

scintillators that monitor noble gases.

These monitors provided alerts at

settings equivalent to 20 gallons per day and high alarms at

50 gallons per

day.

The chemistry department

provided operators daily values for equating

gallons per day to counts per minute.

This allowed operators

to linearly

scale

the air ejector readings

and monitor changing

leakage rates.

Any

increase of 50 gallons per day in four hours

was then considered

a good

indicator for a potential

tube rupture

and appropriate

action

was to be taken.

Main steam lines were monitored with upgraded

gamma detectors

which alarm

an

alert at the equivalent of six gallons per minute

and high alarm at 46 gallons

per minute.

These detectors

provided indications of significant leakage.

More accurate

results

were provided

by counting

samples

taken from each

steam

generator within 30 to 45 minutes.

A common

steam generator

blow-down monitor

served

as

a backup to the other two methods

and alarmed at

an equivalent

250

gallons per day.

Sample lines from each

steam generator

also

passed

over

radiation detectors,

serving

as

an additional

backup.

0

3.4

Ade uac

of Emer enc

0 eratin

Procedures

and

0 erator Trainin

I

The inspectors

reviewed the adequacy of the licensee's

emergency

operating

procedure

(EOP)

E-3, Revision l2,

"Steam Generator

Tube Rupture,"

and

abnormal

operating

procedures

(AOPs) AP-3A, Revision 6,

"Steam Generator

Tube Leak,"

and AP-3B, Revision 8,

"Steam Generator

Tube Failure."

The inspectors

determined that the

AOPs

and

EOP required the operators

to

evaluate

the magnitude

and trend for various parameters

such

as pressurizer

level,

RCS pressure,

activity levels,

and primary-to-secondary

leak rate.

A

minor inconsistency

was noted

between

procedures

in the level of detail given

for securing the turbine-driven auxiliary feedwater

pump

and isolating it from

the affected

steam generator.

The licensee

issued

an On-The-Spot

Change which

added valve numbers for performing this activity to procedure

AP-3B and

resolved the inconsistency.

The inspectors

evaluated

the capability of an operating

crew to identify and

trend primary-to-secondary

leakage

by conducting

a dynamic scenario

in the

facility simulator.

The scenario

also served to verify the adequacy of

detection

and alarm indications in real time.

The scenario started with an

imposed

leakage of 0.01 gallons'er

minute which ramped to 0.03 gallons per

minute in 10 minutes.

A 0.03 gallon per minute leak equates

to about

50

gallons per day.

The operating

crew successfully

detected

the leakage within

the first minute.

A subsequent

step

change to 0. 1 gallon per minute, or 150

gallons per day,

was also detected.

Subsequent

step

changes

to

1 gallon per

minute

and

75 gallons per minute were also detected.

Crew actions in response

to the changing

leakage

were appropriate.

The reviewed procedures

adequately

provided control

room operators

the

guidance

necessary

for continued monitoring,

assessment,

and response

to

identified primary-to-secondary

leakage.

The symptoms

and entry conditions

were sufficiently diverse,

such that the operators

could correctly diagnose

a

steam generator

tube rupture

and enter the steam generator

tube rupture

procedure.

The performance of an operating

crew in response

to simulated

leakage conditions

was good.

ATTACHHENT 1

PERSONS

CONTACT AND EXIT HEETING

1

PERSONS

CONTACTED

1. 1

Licensee

Personnel

D. Bahner,

Operations

Engineer

  • J. Becker,

Operations

Director

  • K. Bych,

ISEG Supervisor

  • G. Deardorff, Senior Control Operator
  • B. Exner,

TS Supervisor

  • S. Fridley, Outage Services Director

W. Fujimoto, Vice-President

  • J. Fuhriman,

Engineer

J.

Gardner,

Senior Engineer

  • B. Glynn III, gA
  • T. Grebel,

Regulatory Services Director

  • J. Griffin, Learning Services Director
  • C. Harbor,

NRC Interface

C. Hartz,

gA Engineer

  • R. Jett,

Learning Services

Supervisor

  • D. Hiklush, Operations

Hanager

D. Oatley, Acting Haintenance

Hanager

K. O'eil,

ILC Engineer

  • D. Taggart,

Nuclear Safety Engineering Director

  • D. Vosburg,

Engineering Services Director

  • J. Welsch,

Learning Services

Supervisor

J.

Young,

NgS Acting Hanager

1.2

NRC Personnel

  • H. Tschiltz, Senior Resident

Inspector

In addition to the personnel

listed above,

the inspectors

contacted

other

personnel

during this inspection period.

  • Denotes personnel

that attended

the exit meeting.

2

EXIT HEETING

An exit meeting

was conducted

on Hay 25,

1995.

During this meeting,

the

inspector

reviewed the scope

and generic findings of the report.

The licensee

did not express

a position

on the inspection findings documented

in this

reports

The licensee

did not identify as proprietary

any information provided

to, or reviewed

by, the examiners.

0

-10-

ATTACHMENT 2

SINULATION FACILITY REPORT

'acility

Licensee:

Facility Docket Nos:

Pacific

Gas

& Electric

50-275/323

Operating Test Administered on:

Hay 23,

1995

This observation

does

not constitute

an audit or inspection finding and is

not, without further verification and review, indicative of noncompliance with

10 CFR 55.45(b).

This observation

does not affect

NRC certification or

approval of the simulation facility other than to provide information which

may be used in future evaluations.

No licensee

action is required in response

to this observation.

While conducting the validation of scenarios

for the operating examination,

the seismic

ground acceleration

level required to trip the reactor

was 0.4 g.

The in-plant seismic trip setpoint value is 0.3 g.