ML20151W631

Affidavit of ET Beadle.* Affidavit Relates to Denial of Senior Reactor Operator License Application for Rl Herring. with Certificate of Svc

ML20151W631
Person / Time
Site:	Catawba, 05522234
Issue date:	09/08/1998
From:	Beadle E DUKE POWER CO.
To:
Shared Package
ML20151W574	List: ML20151W572 ML20151W594 ML20151W613 ML20151W631
References
98-745-01-SP, 98-745-1-SP, SP, NUDOCS 9809160052
Download: ML20151W631 (9)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE PRESIDING OFFICER In the Matter of Docket No. 55-22234-SP l l

RANDALL L . HERRING ASLBP No. 98-785-01-SP (Denial of Senior Reactor Operator's I

License Application) 1 AFFIDAVIT OF EVERETT THOMAS BEADLE l I, Everett Thomas Beadle, being duly sworn, do depose and say:  ;

1. Training and employment - I am employed as a Nuclear Instructor, Operator Training, at Catawba Nuclear Station, in York, South Carolina. I have been so employed for six years. I have been employed by Duke Power Company for twenty one years. My work experience and education are attached as a resume to this certification.

2. Topic A.2 - Equipment Control- of the administrative portion of the operating examination administered to Randall L Herring (Contention 4) was developed by members of the Catawba Training Center staff and consists of two questions.

3. The questions were developed to evaluate the candidate's knowledge of the Technical Specifications fd 'he Nuclear Service Water (RN) System and the documents necessary to determine the operability of the System's trains and components, and are based on the knowledge requirement K/A 2.2.20 (Managing Troubleshooting Activities) listed in NUREG I122, revision 1 (draft).

4. The questions were developed by a Senior Reactor Operator (Rodger W. Ellingwood) with an active license and 2.5 years of on-shift experience. The questions were given to active licensed operators for validation. Validation involved answering the questions with the allowed references and reviewing the l proposed correct answer. Constructive feedback was solicited and revisions were made asjustified. Each question was revie.wed and approved by a designated member of management for the Operations group

(,lohn K. Suptela, Operations Training Coordinator).

5. The candidate is allowed to use Control Room reference documents to answer the questions.

Operating Procedure No. OP/0/A/6400/06C, Nuclear Service Water System, Technical Specifications, including 3 / 4.7.4 (Nuclear Service Water System) and 3 / 4.7.5 (Standby Nuclear Service Water Pond) and Nuclear Service Water (RN) System Design Bases Specification, CNS-1574.RN-00-0001, are normally available in the Control Room with their current issues in effect. (Revision 216. Revision 6, and Revision 12, respectively).

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6. The initial conditions for Questions I and 2 state that an alignment of the Nuclear Service Water System (RN)is in progress and that valve IRN-2B will not operate. With 1RN-2B open and not capable of closing, it cannot perform its design safety function to isolate the nortnal source of water (Lake Wylie) from the "A" loop RN pumps.

7. Question I asks for an operability determination of the RN System based on the failure of valve IRN-2B to operate. Technical Specification 3.7.4 (Nuclear Service Water System) requires that the suction and discharge flow path of both loops of the RN System must be " capable of being aligned to the SNSWP" Valve 1RN-2B is associated with the "A" loop and thus operability of the "A" loop is in question. The RN Design Basis Specification for valve iRN 2B (RN Design Basis Specification, section 20.4.2.1 Power Operated Valves) states the inoperability of the "A" loop in the Recommended Action l Statement. Operations management expects the licensed operator to follow this guidance and declare the (

"A" h>op inoperable.

8. Question 2 asks for an evaluation of the RN System configuration control requirements. The RN Design Basis Specification, Power Operated Valves for valve 1RN-2B states in the Recommended Action Statement, " To return "A" loop to operable, close and remove power from IRN-1 A." Operations management expects the licensed operator to follow this guidance and take action to close valve IRN-I A and remove motive power from the valve motor.

9. The answers to Question I and 2 require the knowledge that valve IRN-2B has a safety function, such that the vahe is capable of closing, and has Technical Specification significance requiring operator action. Training for the safety function knowledge was provided to Randall L. Herring from the Nuclear Service Water (RN) System lesson plan (OP-CN-PSS-RN, Revision 25, sections 2.1.C,2.2.A.4, and 2.5, respectively). The knowledge of Technical Specification significance requiring operator action involves the p.ocess to determine operability of a structure, system, or component. Nuclear System Directive 203, Operability describes the responsibilities and process for determining operability (decision) and the process of performing an operability evaluation (analysis and recommendation) to support the operability determination. Operability determinations are made by the Operations Shift Manager (SRO) and operability evaluations are performed by other authorized personnel. Training on the operability determination process was provided to Randall L. Herring from the Technical Specification lesson plan (OP-CN ADM-TS Revision 15, section 2.2).

10. Operations management (Donald W. Bradley, Shift Operations Manager) supports the answers for the questions as they were developed. Mr. Herring's contention has merit as an engineering evaluation for operability, but it would be considered a subsequent action to the licensed operator actions taken at the time the valve failure was found. Mr. Herring was being evaluated as a licensed senior reactor operator j candidate, not a systems engineer.

I1. Topic A.4 - Emergency Procedures / Plan - of the administrative portion of the operating examination administered to Randall L. Herring (Contention 2) was developed by members of the Catawba Training Center staff and consists of three questions. Contention 2 involves the second question only.

12. The questions were developed to evaluate the candidate's knowledge of emergency plan l protective actions and recommendations, and are based on the knowledge requirement K/A 2.4.44 l

(Emergency Plan Protective Action Recommendations, listed in NUREG 1122, revision I draft).

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13. The questions were developed by an examination team member who formerly held an Senior Reactor Operator's license at McGuire Nuclear Station. This person (Charles W. Sawyer Jr.) was the lead examination author for the 1997 NRC Initial Licensed Operator Examination at McGuire Nuclear Station.

The questions were given to active licensed operators for validation. Validation involved answering the questions with the allowed references and reviewing the proposed correct answer. Constructise feedback was solicited and revisions were made asjustified. Each question was reviewed and approved by a designated member of management for the Operations group (John K. Suptela. Operations Training Coordinator).

14. The candidate is allowed to use Control Room reference documents to answer the questions.

Response Procedure RP/0/A/5000/05, General Emergency is normally available in the Control Room with the current issue in effect (Revision 32).

15. The initial conditions on which the three questions are based, give a plant situation in which a  !

" general emergency" classification has been determined. Question I asks whether protective action recommendations should be made and if so, what they are. Question 2 changes the weather of the initial l conditions and asks for a re-evaluation of the decision made in Question I and the effect of the weather change on protective action recommendations. Question 3 asks for a recommendation on the evacuation of non-essential personnel from the site, based on the initial conditions, as modified by Question 2.

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16. Question I is answered by following the immediate actions of RP/0/A/5000/05, General Emergency. Based on a given wind speed greater than 5 miles per hour (8 mph), enclosure 4.2, page 2 of 3, J

Protective Action Recommendation Determination Table is used to determine the protective action ,

recommendations.  ;

17. Question 2 is answered, based on the resised initial conditions, for wind speed and wind )

direction, as given in Question 2. The subsequent actions of RP/0/A/500()/05, General Emergency are used to address the need to assess plant conditions, off-site dose projections, and field monitoring team data to  !

update protective action recommendations previously made. Specific guidance to perform this assessment is given in enclosure 4.3, page 1 of 3 Guidance for Protective Actions, Protective Action Recommendation Flowchart and enclosure 4.4, Evacuation Time Estimees for Catawba Plume Exposure (EP7.).

18.. Enclosure 4.3, page 1 of 3. Guidance for Protective Actions, Protective Action Recommendation Flowchart leads the operator through the following logic. A general emergency exists with winds not less than or equal to 5 n.iles per hour (20 mph). The " urgent" protective action recommendations have already been made(answer to Question 1) and a large fission product inventory greater than gap activity in containment does not exist. Off-site doses (l.2 TEDE) are projected to exceed protective action guides lines and protective action recommendations are to be made in accordance with enclosure 4.3, page 3 of 3 Guidance for Protective Actions, Protective Action Guides.

19. Enclosure 4.3, page 3 of 3, Guidance for Protective Actions, Protective Action Guides gives i I

guidance to recommend evacuation of the affected zones and shelter the remainder of the 10 mile EPZ not evacuated, but it does not specify which enclosure to use. Only two tables are provided to make the protective action recommendations, namely enclosure 4.2, page 2 of 3 and enclosure 4.2, page 3 of 3.  ;

Enclosure 4.2, page 3 of 3 is not applicable, since there is no large fission product inventory greater than j gap activity in containment. 'Thus by elimination, enclosure 4.2, page 2 of 3 is the only applicable table to i determine protective action recommendations based on wind speed and direction.

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20. The answers to Questions I and 2 require knowledge of the process to determine protective action recommendations. Classroom training for this knowledge was provided to Randall L. Herring from the Emergency Plan lesson plan (OP-CN-EP-SEP, Revision 15, sections 2.1.B. C E, and F). On-the-job training required completion of the training and qualification guide that has the candidate explain and demonstrate how to use RP/0/A/5000/05, General Emergency and other emergency plan processes (Senior Reactor Operator T&Q EP-S0026, Assess Plant Problems and Declare Emergencies per Apprmed Procedures, revision 7 elements 10 and 11).

21. I am informed that on or about August 5,1998 Randall L. Herring consulted the Technical Support Supervisor, Emergency Planning (Steven R. Christopher) concerning the adequacy of the guidance provided in enclosure 4.3, page 3 of 3 of RP/0/A/5(XX)/05, General Emergency (Revision 32) to determine protective action recommendations (affected zones). Subsequently, revisions were made to RP/0/A/5000/05, General Emergency (Revision 33) to provide more specific guidance on which enclosure to use for protective action recommendations. In the view of plant management the revisions made were human factor enhancements and did not invalidate Question 2, as originally written, nor did they change the correct answer.

Further, Affiant sayeth not.

ULY bn1M '

R$G Everett Tho'mas Beadle Sworn to and subscribed before me this 8 day of September,1998

- 2 84 m J'c lic Notsry My Coma P[dssion Expiresa4 [M 9

Name EVERETT T. BEADLE Company Duke Power Company 1 i

Title / Position Nuclear Instructor l l

Years with Firm 21 4

1 Years Experience 26 l l

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1 Key Qualifications: Mr. Bradle is highly experienced in operations and training management as well l as nuclear training. As a Nuclear Instructor, he developed, conducted and evaluated licensed operator I and initial non licensed operasor training. As an Operations StaffSpecialist, he developed and l maintainedplant procedures and operations supportprograms. As a Shift Technical Advisor, he j coordinated maintenance and other shift activities in support ofplant operations . As a US Army Reserve Staff Officer, he managed the operations of school brigade , reorgani:ed and accredited the military training institution that was the prototypefor the US Army Reserve.

Education / Training BS, Chemistry Siena College,1971 Computer skills: Excel, MS Word, PowerPoint, RFFlow(flow charting)

Graduate US Army Command and General Staff Officer Course (non-resident), Ft Leavenworth, KS,1987 Professional Affiliations / Certifications:

Senior Reactor Operator Instructor Certification,1992 - present Licensed Senior Reactor Operator, 1984-1992 l

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l Experience: '

4/92 - present Nuclear Instructor, Catawba Nuclear Station, Duke Power Company Develops and conducts training for licensed and non-licensed operators.

Responsible for maintaining subject matter expertise on assigned systems, updating associated training materials (lesson plans, drawings, exam bank, simulator scenarios), and managing the conduct of Introduction to System Specifics (ISS) course and the Shift Technical Advisor (STA) training program.

l Performance of his duties involves instruction to other plant groups to include engineering, pe+rmance and radiation protection. Additionally he maintains expertise in plant 's'i$h vn and draindown operations. Served as the lead instructor for the development of the 1997 initial Operator License Examination at Catawba Nuclear Station 10/87 - 3/92 Senior Technical Specialist, Catawba Nuclear Station, Duke Power Company Planned, coordinated and conducted Operations support group activities.

I Responsible for implementation of plant modifications (with respect to shif t training, procedures and control room drawings), maintenance of emergency and abnonnal procedures, development of the Shift Supervisor Training program, and coordination of the response to Generic Letter 88-17, Loss of Decay Heat Removal. Provided management oversight for the first successful vacuum refill operation of the reactor coolant system on a commercial power reactor in the United States. Additional responsibilities included duties with the emergency response organization (TSC), emergency drill scenario development team, significant event investigation team and root cause analysis team for mispositioning events. Maintained SRO license during this period. i 7/84 - 9/81 Shift Technical Adsisor, Catawba Nuclear Station, Duke Power Company Fulfilled on-shift responsibilities as an SRO licensed Shift Technical Advisor.

Managed shift work control for all maintenance and operational support activities during innage and outage to include callouts, notifications and NRC reporting.

Provided the shift supervisor with an on-shift training, qualifying and research resource to support station goals. Also performed duties as a Fuel Handling SRO for the initial fuel load and first core refuelings of each Catawba unit.

1 j 2/81 - 6/84 Operations Staff Engineer, Catawba Nuclear Station, Duke Power Company Assigned as a Operations Staff Engineer to coordinate projects associated with plant startup of Catawba Nuclear Station . Responsible for developing and publishing the periodic test program for the operations group. Published FSAR /

System Cross Reference manual for use by station personnel to review and write 10CFR 50.59 evaluations. Served as assistant shift supervisor while attaining cold license certification and cold operating licenses for a two unit Westinghouse l power plant.

10n8 - 1/81 Chemistry Supervisor, Catawba Nuclear Station, Duke Power Company Managed the development and establishrnent of the station environmental chemistry programs. Supervised a group of chemistry technicians to develop system operating and test procedures, to perform system acceptance tests and to perform the initial startups of plant treated water and wastewater treatment systems. Selected by station management as a candidate for the Shift technical Advisor (STA) program.

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6n7-9S8 Field Chemist, Environmental Laboratories, Duke Power Company Conducted field studies of the impounded waters of the Duke Power system.

Contributed to the Non-radiological Annual Report for Oconee Nuclear Station, the environmental impact studies for Catawba, Cherokee and Perkins Nuclear Stations, and the impact study of the jet plume from Oconce Nuclear Station on Lake Keowee.

In2-4R7 U. S. Army, Actise Duty Served as a commissioned officer in command positions with air and ground combat units within the United States. Trained and qualified as a rotary wing

' aviator. Participated in the U. S. Army Nuclear Surety Program.

4n7 - 1/96 U.S. Army Reserve Served as a staff officer in assignments of increasing responsibility within the U.

S. Army Reserve training command. Responsible for managing individual and unit training, security operations, war mobilization planning, instiuctor development and certification, and maintaining accreditation for a military training institution. Selected as Operations Officer of a new concept school brigade in September 1993, coordinated the reorganization of the unit, continued the conduct of non-resident military instruction and managed the successful accreditation of the new unit, that is the prototype for Army Reserve training institutions of the 21" century. Retired 16 January 1996.

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USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'96 SEP 14 A9 :22 BEFORE THE PRESIDING OFFICER l

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In the Matter of ADJUQ W i , GF

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RANDALL L. HERRING ) Docket No. 55-22234-SP i )

(Denial of Reactor Operator's ) ASLBP No. 98-745-01-SP License Application) )

CERTIFICATE OF SERVICE I hereby certify that copies of " NUCLEAR REGULATORY COMMISSION STAFF PRESENTATION IN SUPPORT OF DENIAL OF SENIOR REACTOR OPERATOR LICENSE FOR RANDALL L. HERRING" and attachments, in the above-captioned proceeding have been served on the following by deposit into the United States mail, or through deposit in the Nuclear Regulatory Commission's internal mail system as indicated with an asterisk, or with a double asterisk by hand delivery on this Ilth day of September 1998: ,

I Administrative Judge

• Office of the Secretary (2)** l Charles Bechhoefer ATTN: Rulemaking and Presiding Officer Adjudications Staff

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I Atomic Safety and Licensing Board Mail Stop: 0-16 G15 )

Mail Stop: T-3 F23 U.S. Nuclear Regulatory Commission  !

U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Randall L. Herring Administrative Judge

• 2148 Raven Drive Dr. Richard F. Cole Rock Hill, South Carolina 29732 I Special Assistant Atomic Safety and Licensing Board Office of Commission Appellate Mail Stop: T-3 F23 Adjudication

• U.S. Nuclear Regulatory Commission Mail Stop: 0-16 G15 Washington, D. C. 20555 U.S. Nuclear Regulatory Commission i

Washington, D. C. 20555 l

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p Atomic Safety and Licensing Board Adjudicatory File (2)*

Panel

• Atomic Safety and Licensing Board Mail Stop: T-3 F23 Mail Stop: T-3 F23 -

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 1 J

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f. Jt Susan L. Uttal Counsel for NRC Staff i

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