ML19296B870
| ML19296B870 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/11/1980 |
| From: | Andrea Johnson Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19296B831 | List: |
| References | |
| NUDOCS 8002220286 | |
| Download: ML19296B870 (12) | |
Text
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UtilTED STATES OF A" ERICA fiUCLEAR REGULATORY COMMISSION O
BEFORE THE ATOMIC SAFETY Af!D LICENSING BOARD In the Matter of
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SACRAMENTO MUf11CIPAL UTILITY
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Docket flo. 50-312 (SP)
DISTRICT
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(Rancho Seco fluclear Generating
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Station)
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f;RC STAFF TESTIM 0fiY OF ALLEf1 D. JOHNSON RELATIVE TO THE COMPETENCY OF SMUD TO OPERATE THE RAf!CHO SECO FACILITY (F0E Contention III(d) and Board Question 32)
Ql.
Please state your name and your position with the NRC.
A.
My name is Allen D. Johnson and I am a Reactor Inspector for the Office of Inspection and Enforcement, Region V.
Q2.
Have you prepared a statement of professional qualifications?
A.
Yes.
03.
Is that statement attached to this testimony?
A.
Yes.
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_2 Q4 What f5 the purpose of your testimony?
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A.
The purpose of my testimony is to respond,in part, to the following Contentions.
F0E Contention III[d)
"The NRC orders in issue do not reasonably assure adequate safety because no procedures have been taken to assure facility managemen+
competence."
Board Question 32
" Rancho Seco, being a Babcock and Wilcox designed reactor, is operated by personnel and management whose competence has not been adequately tested and evaluated, namely testing has not been conducted as to whether such employees can act responsibly and appropriately to make judgment decisions during a loss of feedwater transient, personnel in-terviews have not been conducted to properly evaluate the test results with such employees and some employees have never been tested because of grandfathering, and therefore, is unsafe and endangers the health and safety of Petitioners, constituents of Petitioners and the public."
05.
Please state the nature of responsibilities that you have had with respect to the Rancho Seco generating station.
A.
I was the responsible NRC inspector for Rancho Seco during the final phase of construction and during preoperational and power ascension testing.
Since that time, I have assisted the responsible inspectors in performing the routine NRC inspection program and was the responsible inspector from January 1979 until August 1,1979, when the current resident inspector assumed his duties at the Rancho Seco site.
. Q6.
liow long have you had responsibilities with respect to inspection at Rancho Seco?
A.
About nine years.
Q7.
Please describe the scope of IE's inspection program.
A.
The NRC Office of Inspection and Enforcement (I&E), in part, is responsible for the development and administration of programs and policies for inspect-ing licensees to ascertain whether they are complying with NRC regulations, rules, orders, and license provisions, and to determine whether licensees are taking appropriate actions to protect nuclear materials and facilities, the environment, and the health and safety of the public.
The procedures for accomplishing I&E's reactor inspection program are contained in I&E Manual Chapter 2500 which contains detailed instructions for performing required inspection activities.
This program has been in effect since January 1975.
More specifically, the inspection program requires that licensed activities be periodically inspected in depth.
E.g., on an annual basis, the licensee's programs and activities related to design changes and modifications to the plant; surveillance of safety related structures, systems and components; onsite and offsite safety review committees' activities and quality assurance aduits and results; performed maintenance; and instrumentation calibrations are examined and evaluated by NRC inspectors.
The total program includes 29 separate procedures that must be completed at frequencies ranging from quarterly to once every three years.
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In addition, the program includes another 24 procedures which address
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non-routine inspection activities.
Q8.
In the course of your inspection activities, do you have discussions with the managcment of the licensee, SMUD?
A.
At the conclusion of each inspection, the responsible inspector meets with the senior member of management on site and his staff and informs the licensee representatives of the scope and findings of the inspection.
Q9. Who is the highest officer of SMUD with whom you have had discussions?
A.
Assistant General Manager and Chief Eningeer of SMUD.
Q10. Have you ever administered any " test" to SMUD management?
A.
No; however, the responsible onsite management personnel at Rancho Seco, including the Manager of Nuclear Operations, Plant Superintendent, Technical Supervisor, the Technical Assistant, Operation Supervisor and the Shift Supervisors, all currently hold valid NRC Senior Operator Licenses.
Qll. What employees of SMUD would be called upon to respond to a loss of feedwater transient?
. A.
During a loss of feedwater, as well as any other abnormal operating condit(on, the NRC licensed operators assigned to the shift operating crew at the timc4>
are responsible for responding to the event in accordance with established proce-dures and take the necessary action to control the reactor and associated plant systems. As part of the NRC's routine inspection program, SMUD's pro-cedures for coping with equipment casualties and operating emergencies are examined and have been found in the past to be readily available to the operating staff in the reactor control room and have been considered accept-able by NRC inspectors.
In addition, other unlicensed persons may be called upon to respond in the event of a loss of feedwater transient and this subject is discussed in the testinony of Mr. Philip Morrill.
Ql2. Under what conditions would SMUD management become involved in responding to a loss of feedwater transient?
A.
A loss of feedwater transient is an expected and planned for event to be handled by the Shif t operating personnel.
Should a SMUD manacement person be present at the time of such a transient, he would likely evaluate the actions being taken by the operating crew and would assist as requested by the Shift Supervisor.
Should plant systems or equipment fail during a transient, or any other abnormal condition arise which results in unsafe conditions, onsite and offsite management are required to be notified.
. Ql 3.
Have you formed an opinion as to the competence of SMUD operations personneh particularly with respect to their ability to act respolsibly and appropriattly to make judgement decisions during loss of feedwater transients?
A.
Yes.
Q14. What is the opinion?
A.
For the purpose of this testimony, I have restricted the basis for my opinion to the licensee's activities related to operation of the reactor and its associated auxiliary systems during the period of time fram January 1, 1978, through July 31, 1979.
I believe that this period is appropriate to provide a basis for evaluation of the current competence level of the liceicee's operating 'and managing personnel. The plant has been operating for the past 5 years.
Our experience shows that, altlough a licensee is competent to operate plant safely at the time of licensing, personnel become more proficient in their duties as they gain operating experience.
Therefore, I consider the past two years to be an appropriata period of time to judge the current competence level of the personnel.
With this in mind, I am of the opinion that the personnel operating and managing the Rancho Seco fluclear Generating Station have demonstrated their willingness to evaluate any and all problems brought to their atten-tion and have shown their capability and fitness to operate the station sa fely.
This opinion is based on the following observations.
. In my-judgement, the number of reportable events and items of noncompliance _
identified during inspections of licensee activities, along with the manner
- in which a licensee responds to the identified problems, provides some measure of the capability and fitness of a licensee to safely operate a nuclear power plant.
First, let me speak to the reportable events that have occurred at Rancho Seco.
Section 6 of the facility Technical Specifications prescribes events related to the safety of operations that must be reported to the flRC for evaluation.
Such events have been classified according to safety importance.
Those considered by flRC to be most important to safety must be promptly (within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) reported by the licensee to the NRC Regional Office with a follow-up. written report required to be submitted within 14 days. Events
.that impact on the safety of operation but do not represent an inmediate and significant safety concern must be reported in writing to the flRC within 30 days.
For example, failure of the emergency core cooling system to func-tion upon a signal to initiate operation of the system would require a prompt report to flRC; whereas, failure of a corponent or subsystem that did not preclude the system from performing the required safety function, would be reportable to NRC within 30 days.
During 1978, the licensee reported eighteen (18) events pursuant to the above mentioned requirements. fline (9) of the events were considered to be reportable in 14 days with the remaining (9) being reportable within 30 days.
. During the period of January 1 through October 1,1979, eleven (11) reporta41e events have occurred. Three (3) of the events required a 14 day report witt the romaining eight (8) event-being reportable within 30 days.
The more important events identified above included failures involving hydraulic shock suppressors, structural restraints, diesel generators, the fire protection system, weld materials, main steam safety valves, non-nuclear instrumentation, and the integrated control system (ICS).
Two of the events, one occurring in March 1978 and the other in January 1979, resulted in a loss of feedwater transient.
These events involved loss of non-nuclear instrumentation and loss of the ICS system, respectively.
In both bases, the licenst.e's onsite operating personnel handled the events in an acceptable and safe manner. The licensee management in each case subsequently conducted investigations of the circumstances associated with each event and initiated actions considered appropriate by the IE inspection staff. When the number of reportable events is used as a factor in evaluating the licensee's competence, considerations should include the total number of occurrences; the degree to which they are repetitive to particular systems or personnel groups; the relationship of events to plant safety; and the quality, depth and timeliness of licensee response.
Based on the foregoing, I have concluded that SMUD's past performance has been acceptable.
_9 Turning now to violations of flRC requirerrents, i.e., items of noncompliance u the flRC Office of Inspection and Enforcement maintains a continuing evalua-*
tion of licensee performance, capabilities and fitness to operate an t;RC licensed nuclear power station by taking appropriate enforcement action, pursuant to IE Manual Chapter 0800. This manual chapter contains the de-tailed procedures for initiating enforcerrent action that irust be followed by the f1RC inspection staff.
Subsequent to each inspection, the findinos of the inspector are discussed with IE regional office manaaement. Any and all adverse findings are analyzed by the inspectors and ISE supervisors as to how the findings reflect on the licensee's management control systems.
Whenever the licensee activities are found to be in noncompliance with regulatory requirements or deviate from relevant industry standards, IAE takes enforcement action to assure that appropriate corrective reasures are initiated by the licensee to correct the item and to preclude recurrence.
In addition, when I&E inspectors, along with Regional Office sunervision, detect a licensee managing its activities in a mar.ner such as to demonstrate either its inability to or lack of concern to operate in compliance with I;RC requirements, I&E Management personnel meet with the top level of manaae-ment and express I&E's related concerns.
Should the licensee fail to heed ISE's stated concerns, enforcement action is taken in the form of civil penalties or orders to provide the necessary incentives to licensee manage-ment to take the appropriate action to assure compliance with reculatory requirements.
. During-1978 and through July 31, 1979, the !&E's reactor inspection progra n identified and issued only one flotice of Violation to SMUD, for failure +
to document testing of the redundant high pressure injection recirculation valve when the other corresponding valve was removed from service for inspec-tion on April 6,1978. To prevent or minimize similar occurrences in the future, the Rancho Seco Supervisor of t!uclear Operations issued a l'emoran-dum to all Shift Supervisors of the necessity for prompt and coroplete log entries on all such actions.
This noncompliance dealt with a record keep-ing requirement and is considered to be minor and of little significance.
Relative to operation of the Rancho Seco fluclear Generating Station, I&E has not identified a"need to meet with licensee management to discuss concerns related to operation of the reactor and associated systems nor have the flRC inspection personnel proposed escalated enforcement actions relating to such activities.
In addition'to the above, and based on my knowledge and experience, I believe that a determination of the competency of a licensee and its responsible personnel to safely operate a nuclear power plant is a corplex judgement involving a host of factors.
During my inspections of the SMUD operation, I have over the years considered and weighed the following factors as they relate to individuals, groups and organizations within and under the control of SMUD.
. Attitudes Morale 4
Respect Trust Pride Knowledge Experience Freedom Discipline Organization Structure Personnel Selections
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Instructions, Policies and Procedures
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Regula tory Requirements Response to Unplanned Events During the many discussions that I have had with personnel of SMUD and its contractors along with opportunities to observe personnel response to planned and unplanned events, my conclusion is that the SMUD organization and personnel are competent to safely operate theRancho Seco nuclear generating station.
Allen Dale Johnson STATEMEf1T OF PROFESS 10f;Al. QUAL.IFICATI0f1S My name is Allen Dale Johnson.
I was born July 22,1931, at New Salem, fl orth Dakota.
I am employed by the United States fluclear Regulatory Connission as a Reactor Inspector in the Reactor Operations and fluclear Support Branch, Office of Inspection and Enforcement, Region V, Walnut Creek, California.
I was graduated from the University of Idaho in 1953 with a Bachelor of Science degree in chemistry and received a Juris Doctor degree from John F. Kennedy University, Orinda, California, in 1971.
I am a member of the California State Bar and am duly licensed to practice law in the State of California.
I served as an officer in the U.S. flavy from July 1953 to July 1955.
From fiovember 1955 through April 1963, I was employed by the Atomic Energy Division of Phillips Petroleum Company at the flational Reactor Testing Station (fiRTS) near Idaho Falls, Idaho.
During my entire employ-r.ent with Phillips Petroleum Ccmpany, I worked at the Material Testing Reactor (MTR) in the Operations Department. My job assignments were:
Reactor Technician, Reactor Engineer, Shift Foreman and Shift Superin-tendent.
As Shift Superintendent (3 years), I was responsible for the safe efficient operation of the reactor, associated supporting facilities, and experiments.
From May 1963 to the present, I have been employed by the fiRC/AEC as a Reactor Inspector. My duties have included inspection and investi-gation of licensed facilities and activities for the purpose of ascertain-ing safety of facility operations and related activities.
In addition, the duties include verification that activities conducted at licensed facilities have been performed in accordance with the rules and regulations of the commission.
I have been the principal inspector for power, test, and research reactors during all phases of construction, startup testing, and subsequent operations.