ML23298A178
| ML23298A178 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/26/2023 |
| From: | Heather Gepford NRC/RGN-IV/DORS/OB |
| To: | Gerfen P Pacific Gas & Electric Co |
| References | |
| 50-275/23-301, 50-323/23-301 50-275/OL-23, 50-323/OL-23 | |
| Download: ML23298A178 (10) | |
Text
October 26, 2023 Paula A. Gerfen Senior Vice President, Generation and Chief Nuclear Officer Pacific Gas and Electric Company P. O. Box 56 Mail Code 104/6 Avila Beach, CA 93424
SUBJECT:
DIABLO CANYON POWER PLANT, UNITS 1 AND 2 - NRC EXAMINATION REPORT 05000275/2023301 AND 05000323/2023301
Dear Paula. Gerfen:
On October 5, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at Diablo Canyon Nuclear Power Plant, Units 1 and 2. The enclosed report documents the examination results and licensing decisions. The preliminary examination results were discussed on August 2, 2023, with Mr. A. Peck, Site Vice President for Operations, and other members of your staff. An exit meeting was conducted on October 5, 2023, with you and your staff, who were provided the NRC licensing decisions.
The examination included the evaluation of eight applicants for upgrade senior reactor operator licenses. The license examiners determined that all of the applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued. There were no post-examination comments submitted by your staff. The enclosure contains details of this report.
One finding was reviewed during this examination.
P. Gerfen 2
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, Heather J. Gepford, Ph.D., Chief Operations Branch Division of Operating Reactor Safety Docket No. 05000275, 05000323 License No. DPR-80, DPR-82
Enclosure:
Examination Report 05000275/2023301, and 05000323/2023301 Electronic distribution via LISTSERV Signed by Gepford, Heather on 10/26/23 U.S. NUCLEAR REGULATORY COMMISSION Examination Report Docket Numbers:
05000275, 05000323 License Numbers:
DPR-80, DPR-82 Report Numbers:
05000275/2023301, 05000323/202301 Enterprise Identifier:
L-2023-OLL-0038 Licensee:
Pacific Gas and Electric Company Facility:
Diablo Canyon Power Plant, Units 1 and 2 Location:
Avila Beach, California Inspection Dates:
July 31, 2023, to October 5, 2023 Inspectors:
N. Hernandez, Operations Engineer, Chief Examiner J. Kirkland, Senior Operations Engineer K. Clayton, Senior Operations Engineer Approved By:
Heather J. Gepford, Ph.D., Chief Operations Branch Division of Operating Reactor Safety
2
SUMMARY
Examination Report 05000275/2023301 and 05000323/2023301; July 31, 2023 - October 5, 2023; Diablo Canyon Power Plant, Units 1 and 2; Initial Operator Licensing Examination Report The NRC examiners evaluated the competency of eight applicants for upgrade senior reactor operator licenses at Diablo Canyon Power Plant, Units 1 and 2.
The licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 12. The written examination was administered by the licensee on August 11, 2023. The NRC examiners administered the operating tests on July 31 - August 2, 2023.
The NRC examiners determined that all applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.
A.
NRC-Identified and Self-Revealing Findings Failure to Maintain NRC Licensing Exam Security Cornerstone Significance/Severity Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000323/2023301-01, 05000275/2023301-01 H.14 Conservative Bias
.5b Examination Security The inspectors reviewed a self-revealed Green finding and associated Severity Level IV non-cited violation (NCV) of 10 CFR Part 55.49, Integrity of Examinations and Tests, in which the licensee failed to maintain examination security of the initial licensed operator written examination during preparations for administering the 2023 NRC examination. Specifically, on August 9, 2023, the original copy of the examination was left unaccounted for and unguarded on a copy machine, in a space where individuals not on the NRC exam security agreement had access, for approximately three hours.
B.
Licensee-Identified Violations None.
3 REPORT DETAILS OTHER ACTIVITIES - INITIAL LICENSE EXAMINATION
.1 License Applications a.
Scope The NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. The NRC examiners also audited four of the license applications in detail to confirm that they accurately reflected the subject applicants qualifications. This audit focused on the applicants experience and on-the-job training, including control manipulations that provided significant reactivity changes.
b.
Findings No findings were identified.
.2 Examination Development a.
Scope The NRC examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examiners conducted an onsite validation of the operating tests.
b.
Findings The NRC examiners provided outline, draft examination and post-validation comments to the licensee. The licensee satisfactorily completed comment resolution prior to examination administration.
The NRC examiners determined the written examinations and operating tests initially submitted by the licensee were within the range of acceptability expected for a proposed examination.
.3 Operator Knowledge and Performance a.
Scope On August 11, 2023, the licensee proctored the administration of the written examinations to all eight applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis to the NRC on August 21, 2023.
The NRC examination team administered the various portions of the operating tests to all applicants on July 31 - August 2, 2023.
b.
Findings No findings were identified.
4 All applicants passed the written examination and all parts of the operating tests. The final written examinations and post-examination analysis may be accessed in the ADAMS system under the accession numbers noted in the attachment. There were no post-examination comments as indicated in the licensee submittal.
The examination team noted no generic weaknesses associated with applicant performance on the operating tests. Post-examination analysis revealed no generic weaknesses associated with applicant performance on the written examination. Copies of all individual examination reports were sent to the facility training manager for evaluation and determination of appropriate remedial training.
.4 Simulation Facility Performance a.
Scope The NRC examiners observed simulator performance with regard to plant fidelity during examination validation and administration.
b.
Findings No findings were identified.
.5 Examination Security a.
Scope The NRC examiners reviewed examination security for examination development during both the onsite preparation week and examination administration week for compliance with 10 CFR 55.49 and NUREG-1021. Plans for examination security and applicant control were reviewed and discussed with licensee personnel.
b.
Findings Failure to Maintain NRC Licensing Exam Security Cornerstone Significance/Severity Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000323/2023301-01, 05000275/2023301-01 H.14 Conservative Bias
.5b Examination Security The inspectors reviewed a self-revealed Green finding and associated Severity Level IV non-cited violation (NCV) of 10 CFR Part 55.49, Integrity of Examinations and Tests, in which the licensee failed to maintain examination security of the initial licensed operator written examination during preparations for administering the 2023 NRC examination. Specifically, on August 9, 2023, the original copy of the examination was left unaccounted for and unguarded on a copy machine, in a space where individuals not on the NRC exam security agreement had access, for approximately three hours.
==
Description:==
On August 9, 2023, an initial licensed operator program instructor took a copy of the NRC written examination from the NRC exam room to another learning services examination room to make copies in preparation for administering the examination on August 11, 2023. After making the requisite number of copies, the original copy of the examination
5 was left on the copy machine which was located in a room accessible to individuals not on the NRC exam security agreement. This original copy of the NRC examination was left unaccounted for and unguarded for approximately three hours, until a licensed operator requalification program instructor, who also was not on the NRC exam security agreement, discovered the examination material and informed his supervisor. A total of five individuals who were not on the NRC exam security agreement were exposed to the examination while alone in the space. The original examination copy was then placed in a red, locking bag and returned to the initial licensed operator examination team.
The senior resident inspector walked down the training building, including the room where the examination was left unattended, and noted that tailgating is allowed in and out of this copy room, and that the door to this copy room is sometimes propped open. The examination compromise existed because personnel not signed onto the examination security agreement had access to the space with an unguarded copy of the NRC written examination. Therefore, unauthorized personnel could have gained knowledge of initial license examination material prior to the administration of the examination.
Leaving the examination unguarded was a failure to ensure examination security requirements were met as required by 10 CFR 55.49 and site procedure TQ2.DC12, Initial Licensed Operator NRC and Audit Exam Development and Administration. Step 4.5.2 of TQ2.DC12 states that the NRC examination development team is responsible for maintaining examination security during the development, validation, and administration of the exam; step 5.3.3 requires that only personnel on the security agreement shall be allowed unescorted access into examination development and validation areas.
Corrective Actions: The licensee informed the NRC chief examiner, entered the issue into the corrective action program, and performed an investigation to determine the impact of the compromised examination. The licensee noted that this copy machine is in a room with a keypad lock on it. Using the time log for the lock, the licensee determined how many times and at what times the door was opened. The licensee then conducted department-wide interviews and concluded that five personnel not on exam security had entered the room while the unguarded examination was on the copy machine. Each of the five individuals were then signed onto the NRC exam security agreement. Based on the investigation and interviews conducted by the licensee, and the observations by the resident inspector, the NRC determined that there was no indication that the exam compromise would have an effect on the equitable administration of the exam. The examination was administered as scheduled.
Corrective Action
References:
Notifications 51199681, 51199682, and 51201199 Performance Assessment:
Performance Deficiency: The failure to meet the examination security requirements of site procedure TDQ2.DC12, Initial Licensed Operator NRC and Audit Exam Development and Administration, is a performance deficiency. The failure also constitutes a violation of 10 CFR 55.49, which was evaluated through the traditional enforcement process.
Screening: The inspectors determined the performance deficiency was more-than-minor, and therefore a finding, because if left uncorrected, the performance deficiency could have become more significant in that allowing licensed operators to perform duties in the control room without valid demonstration of appropriate knowledge on licensing examinations, i.e.,
6 the examination contents were known by the applicant prior to its administration, could be a precursor to a more significant event.
Significance: Using NRC Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4, Tables 1, 2, and 3 (dated December 13, 2019); and the corresponding Appendix I, Licensed Operator Requalification Significand Determination Process, flowchart blocks 10 and 11 (dated January 10, 2019), the finding was determined to have very low safety significance (Green). Although the performance deficiency resulted in a compromise of the integrity of the examination, the equitable and consistent administration of the examination was not actually affected by the compromise.
Cross-Cutting Aspect: H.14 Conservative Bias, Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop (DM.2).
Specifically, the instructor could have printed the copies in the NRC exam room but chose to go to a different room, since that is allowed, without analyzing potential negative outcomes and taking appropriate risk management actions.
Enforcement: The ROPs significance determination process does not specifically consider the regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability regulate using traditional enforcement to adequately deter non-compliance.
Violation: Title 10 CFR Part 55.49, Integrity of Examinations and Tests, states, in part, Applicants, licensees, and facility licensees shall not engage in any activity that compromises the integrity of any application, tests, or examination required by this part. The integrity of any test or examination is considered compromised if any activity, regardless of intent, affected, or, but for detection, would have affected the equitable and consistent administration of the test or examination.
Contrary to the above, the licensee engaged in an activity that compromised the integrity of an application, test, or examination required by this part. Specifically, the licensee failed to ensure the requirements of 10 CFR Part 55.49, Integrity of Examinations and Tests, were met for approximately three hours subsequent to making copies during preparation for administering the 2023 NRC initial licensed operator written examination. If not for detection, this could have affected the equitable and consistent administration of the written examination. This is a violation of 10 CFR 55.49, Integrity of Examinations and Tests.
Severity: The failure of the licensee to meet 10 CFR 55.49 requirements was determined to be a Severity Level IV (SL-IV) violation because it is consistent with section 6.4.d, Violation Examples: Licensed Reactor Operators, of the Enforcement Policy. Section 6.4.d states, Severity Level IV violations involve for example: a non-willful compromiseof an application, test, or examination required by 10 CFR part 55. The performance deficiency would have impacted the regulatory process if licensing decisions were made with applicants who had prior knowledge of examination materials.
Enforcement Action: This violation is being treated as an NCV, consistent with Section 6.4, Licensed Reactor Operators, of the NRC Enforcement Policy and is designated as Severity Level IV, NCV 05000323/2023301-01, 05000275/2023301-01.
7 EXIT MEETINGS AND DEBRIEFS Exit Meeting Summary The chief examiner presented the preliminary examination results to Mr. A. Peck, Site Vice President for Operations, and other members of the staff on August 2, 2023. An exit meeting was conducted on October 5, 2023, between Mr. N. Hernandez, chief examiner, and Ms. P.
Gerfen, Senior Vice President, Generation, and Chief Nuclear Officer. The licensee did not identify any information or materials used during the examination as proprietary.
ADAMS DOCUMENTS REFERENCED Accession No. ML23272A146 - FINAL WRITTEN EXAMS Accession No. ML23277A303 - FINAL OPERATING TEST Accession No. ML23272A152 - POST-EXAMINATION ANALYSIS
ML23298A161 SUNSI Review:
ADAMS:
Non-Publicly Available Non-Sensitive Keyword:
By: NAH1 Yes No Publicly Available Sensitive NRR-079 OFFICE OE:DORS/OB SOE:DORS/OB SOE:DORS/OB C:DORS/OB NAME NHernandez JKirkland KClayton HGepford SIGNATURE
/RA/
/RA/
/RA/
/RA/
DATE 10/26/23 10/26/23 10/26/23 10/26/23