IR 05000327/1986017
| ML20210N808 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/22/1986 |
| From: | Stadler S, Wilson B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20210N804 | List: |
| References | |
| 50-327-86-17, 50-328-86-17, NUDOCS 8605050260 | |
| Download: ML20210N808 (13) | |
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2 KEs UNITED STATES
,[5 NUCLEAR REGULATORY COMMISSION o
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,j 101 MARIETTA STREET, N.W.
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ATLAN TA, GEORGI A 30323
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Report Nos.:
50-327/86-17 and 50-328/86-17 Licenswe: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and OPR-79 Facility Name: Sequoyah I and 2 Inspection Conducted:
February 17-21, 1986 v
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Inspectors:
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4h(/f6 S. D.'Stadler '
Date Signed J. D. Smith W. Oliveira D. P. Loveless D. T. Nelson Approved'by:
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LL wm B. A A ilson, Acting Section Chief Date Signed Division of Reactor Safety SUMMARY Scope: This routine, announced inspection entailed 160 inspector-hours onsite in the areas of licensed and non-licensed operator training and licensed requalifi-cation training.
Results:
No violations or deviations were identified as a result of this inspection.
8605050260 860428 gDR ADOCK 05000327 PDR
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- H.
Abercrombie, Site Director
- P. R. Wallace, Plant Manager
- T. M. Anthony, Operations Group Head
- C. O. Brewer, PWR Section Supervisor
- G. B. Kirk, Compliance Supervisor
- M. R. Harding, Engineering Group Supervisor
- B. C. Lake, Training Shift Engineer
- D. L. Conant, Quality Surveillance Supervisor
- C. H. Noe, Supervisor, Operator Training
- C. W. Lafever, Instrument Engineering Supervisor
- L. H. Sain, Operator Training
- R. Costiel, Licensing Engineer
- G.
A. Carroll, Instructor
- L. C. Bush, Assistant Operations Group Head
- H. Arnold, Non-Licensed Operator Training Supervisor Other licensee employees contacted included operatcrs, of fice personnel, training supervisors, and instructors.
NRC Resident Inspector P. Harmon
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on March 21, 1986, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
The inspector reviewed all commitments made as a result of inspection findings regarding the resolution of procedural discrepancies and operator training which will be completed prior to the restart of either unit. The licensee acknowledged and concurred with these commitments as listed in the details of this report.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
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3.
Licensee Action on Previous Enforcement Matters Unresolved Item 50-328/84-19-02 cited a failure to comply with the intent of 10 CFR 55.31(e) in the return of senior reactor operators to licensed duties folicwing a six-month absence. The licensee's procedures were deficient in that required recertification of an individual's proficiency to the Commission only when he/she has been away from the site for four months or longer.
The inspectors verified that Procedures 0202.05 and OSLT-1 have been revised to require the implementation of 55.31(e) for individuals away from licensed duties for four months or longer. A Training Letter STS-17 Revision I still read "away from the site" and was revised by the licensee on the day of this exit. Unresolved Item 50-328/84-19-02 is closed.
4.
Unresolved Items Unresolved Items were not identified during this inspection.
5.
Replacement Licensee Training The last Sequoyah SALP expressed concern with low pass rates of 50 percent on several occasions by Saquoyah applicants on NRC license examinations.
The inspectors reviewed the replacement examination results for the past three years and determined the average pass rate to be approximately 74 percent. A review of course content, interviews with licensed operators and instructors, and reviews of training records indicated several potential contributing factors to this relatively low license examination success rate. The Sequoyah Hot License Certification Program has in the past been relatively short in duration with a course length of 12 weeks. This course length provided only 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of mitigation of core damage training and very little comprehensive technical specification training.
The need to extend this training was recognized by the licensee, and the Sequoyah Performance Program indicated the course would be extended to 16 weeks in 1986. The licensee committed to the inspectors the 16-week course would begin with the next license class scheduled to start on March 10, 1986.
Thi s 4-week extension will allow 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of mitigation of core damage training, additional training in integrated technical specifications, and time for more emphasis on other important training topics.
Another contributing factor to this relatively low license success rate appeared to be a shortage of licensed instructors. This instructor shortage allows very little class preparation time, particularly when instructors are assigned other collateral duties such as examination preparation and rewriting lesson plans.
In addition, the shortage provides for only one instructor per simulator class. A single simulator instructor reduces the efficiency of simulator instruction as it is very difficult to closely monitor the performance of four trainees at one time.
The licensee indicated plans to increase the training staff by at least two full-time instructors. One other factor which may be negatively impacting the effectiveness of the license training appears to be the lack of a requalification training
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program for non-licensed operators.
Sequoyah non-licensed operators presently attend requalification training only one week per year.
The initial non-licensed operator training program at TVA is 24-months in length and is very comprehensive.
The new operator receives detailed training in many areas including reactor theory, thermodynamics, fluid flow, heat transfer, systems, and integrated plant operation.
The skills acquired in areas such as reactor theory and thermodynamics are not frequently utilized by non-licensed operators, and are difficult to retain. Since several years may lapse before a non-licensed operator enters license training, the lack of proficiency may negatively impact the chances of success in an accelerated training program.
Systematic rotation through requalification training, as being implemented within at least one other TVA nuclear facility, should help maintain the skills necessary for license training.
Lesson Plans:
The inspectors reviewed the status of development of
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license certification training lesson plans.
The lesson plans are being rewritten to meet INPO guidelines and also to support the new 16-week license course format.
The next license training course is scheduled to begin March 10, 1986, but only about 30 percent of the required lesson plans had been developed at the time of this inspection. The licensee had assigned an individual full-time in order to expedite completion of these lesson plans, and committed that they would be completed and approved prior to being needed to support classes.
The inspectors expre>>cd concern with the potential for technical errors in such rapidly developed training materials.
The licensee's review and approval process for these lesson plans must be stringent enough to ensure that significant misinformation is not presented as part of license training.
The inspectors noted that the revision process for approved lesson plans was well controlled.
There is only one master lesson plan for utilization in teaching a specific topic, and instructors are not permitted to teach from uncontrolled copies.
No intent changes to lesson plans are allowed without review and approval. An intent change is defined as a change to any stated lesson objectives. A review of these completed license training lesson plans will be an inspector followup item (327, 328/86-17-01).
Instructors:
The inspectors verified that all staff instructors
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presently teaching license training courses were SRO licensed, attending license requalification training, and were certified as instructors per the training procedure requirements.
The TVA instructor certification process includes the requirement to complete several instructor training courses and to complete evaluations by members of the training staf f.
This evaluation process at Sequoyah includes the use of video tape sessions which are an excellent vehicle for constructive feedback to instructors in training.
The licensee's procedures also required that instructors be recertified on an annual basis, and this recertification was verified for the current license training instructors.
Interviews with recently licensed operators and a review of student course evaluation forms indicated a very high confidence level in the technical ability of license instructor.
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Simulator Status:
The inspectors reviewed the physical status of the
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Sequoyah Simulator and found it to be in good condition.
Indicating lights, chart recorders, controls, and alarms all appeared to be
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operable. A review of training materials utilized on the simulator including simulator guides, operating procedures, system drawings, and technical specifications were all verified to be the latest controlled versions. Modifications to the simulator to reflect plant modifica-tions appeared to be well controlled and to be completed in a reasonable period of time.
Simulator modifications are generated by the original work request from the plant.
Documentation is generated to reflect what plant changes are to be incorporated into the simulator, and weekly meetings are held to prioritize these modifica-tions. All simulator modifications are logged and not signed off until the hardware or software is modified as required.
The inspector reviewed two simulator modifications as follows:
Flow Control Valve (FCV)-63-1 handswitch, the common suction valve
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from RWST to the RHR pump, was moved from the bench section to the vertical section.
The in plant modification was completed in May 1982, the simulator work requested generated in December, and the simulator modification completed in February 1983.
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FCVs 3-132 and 133, the pressure regulators at the discharte of an auxiliary feedwater pump, were replaced by venturies.
The in plant modifications were completed in April 1984, the simulator work requested was also generated in April, and the simulator handswitchs were removed in July 1984.
Although the simulator is modified on a timely basis to reflect plant changes, the early generation of this simulator and the computer software limits the malfunctions which can be inserted and the scope of the training which can be performed.
Performance Program Improvements:
The Sequoyah Performance Program
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provided for several improvements in the Hot License Certification Program in addition to increasing the length from 12 to 16 weeks. The licensee has developed study guides for utilization by R0 and SRO license candidates during the required three months of on-shift training.
The inspector reviewed these documents and determined that they should provide structured and ef fective guidance for this section of license training, as well as documentation of specific completed training completed by an individual. To provide engineering expertise in Operations, selected engineers are being SRO trained with the objective of becoming SRO licensed.
The initial group of these engineers was in training at the time of this inspection and was scheduled to take the NRC SRO examinations in May 1986. The evaluation process utilized by Sequoyah to determine license candidates' readiness to take an NRC examination includes written and simulator / oral examinations, but no in plant walkthrough examination.
Since all SRO applicants at Sequoyah in the past have been former reactor operators and non-licensed operators, it was felt that an audit in this area was
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unnecessary. Tne inspectors expressed the concern, however, that since these instant SR0s have no previous in plant operating experience, they should be evaluated in this area prior to licensing. Another concern was that the licensee's procedures required a year as an R0 licensed individual prior to taking an SR0 license examination.
The licensee
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indicated that these procedures will be revised to provide for instant SR0 license applicants.
In order to provide a career path frr licensed operators to progress through the Operations management chain, Sequoyah is also sending selected licensed individuals to college full-time to obtain Bachelor of Science degrees.
The first group of operators is scheduled to receive degrees in 1986.
6.
Licensed Operator Requalification Training Interviews of licensed operators and senior operators indicated a high level of confidence that the training helps them be prepared to operate the plant, and that the training has significantly improved in the last year.
There was a general concern expressed by all interviewees, however, that the present four weeks of scheduled requalification training was inadequate in i
length to maintain the proficiency levels expected by the NRC, particularly l
in areas such as reactor theory and thermodynamics. Two weeks of the arnual four weeks in classroom and the remaining two are simulator training. The staff also considers four weeks of annual license requalification training to be very brief considering the amount of training required to be completed in a requalification period.
An audit by Region 11 personnel of the licensee's requalification examinations was conducted January 28 ar.d 29, 1986, which indicated the licensee's examinations to be limited in scope.
" Questions on the written examination tended to reflect only what was taught during the requalifica-tion lecture period rather than the spectrum of topics listed in Appendix 'A'
of 10 CFR 55."
This limitation in the scope of the examinations is probably attributable, in part, to the four-week time constraint placed on annual requalification training, and would appear to impede the ability of the licensee to schedule requalification topics per the results of the annual examination as required. The licensee was aware
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of this deficiency and committed in the Sequoyah Performance Plan, Section 4.13.2, to establish six rotating shif ts early in 1986, to allow more license requalification training time. It had not been decided whether this change would result in a regular requalification training rotation with eight cycles per year, or just one additional week of requalification training. Union concerns and a shortage of licensed personnel were cited by the licensee as obstacles to final resolution of this concern. It should be noted that another TVA facility recently committed to implement eight requalification weeks annually as soon as staffing permits.
In the absence of a licensee commitment in this area, the resolution of this concern will be an inspector followup item (327,328/86-17-02).
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License Requalification Examinations:
The inspectors reviewed the average results for R0 and SRO license requalification examinations for the last three years. In 1983, the NRC administered Sections 6 and 7 of the Sequoyah SRO requalification examination and Sections 2 and 3 of the R0 examination. In addition, the NRC graded all sections of four SRO examinations and graded three R0 examinations.
All seven examinations administered and graded by the NRC were passes, and the only failure on requalification examinations in 1983 was one written SR0 administered by the licensee.
The overall requalification examination average for R0s in 1983 was 89.11 and 91.26 for SR0s. In 1984, there was only one R0 written failure and the R0 examination average was 88.52 and the SRO average was 91.32.
In 1985, there was one R0 written failure and one simulator / oral examination failure, with an R0 average of 90.54 and and 'R0 average of 90.09. These examination results and the interviews conducted appear to indicate that the Sequoyah Requalification Program has been effective.
The inspectors reviewed completed requalification examinations for 1984 and 1985 and noted several concerns, however.
The grading of examinations is not required to have a second review by another instructor or training supervisor.
In a number of cases, the grading appeared to be easy or inconsistent, and the points allowed for incorrect responses on sections of multiple part questions too great.
Examinations reviewed did not indicate that the observed errors would have changed the final pass / fail results.
To prevent the potential for a failed requalifica-tion examination to go undetected, however, the procedural controls need to be strengthened to ensure examination grading quality control.
The inspectors reviewed the records of the removal from, and restoration to, licensed duties of the three individuals who failed requalification examinations in 1984 and 1985.
This process appeared procedurally controlled and well documented in each case.
Each training record contained a letter of failure and removal from licensed duties and a description of required remedial training as determined by the Training Review Committee.
The records also documented the examination retakes, a second review by the Training Committee, and the date of return to licensed duties.
In one case, nearly two months lapsed between date of the failed examination and the removal from licensed duties.
Further review determined that the individual was removed from licensed cuties as soon as the examination was graded, but that the grading had taken an unusual amount of time.
Annual requalification examinations should be graded on a timely basis to ensure that operators are not allowed to continue licensed duties with identified training deficiencies.
One last concern identified with requalification examinations was the lack of question banks. Writing each examination from scratch would appear to place an excessive burden on a training staff which is already heavily taxed.
The inspectors reviewed the security controls over assembled examinations and determined the controls to be adequat.
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Operating Experience Feedback: The inspectors reviewed the incorpora-
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tion of three Sequoyah operating events, and one event from a PWR plant in another region, into licensed operator requalification training. In each case, the information was incorporated as warranted into operator traininc. Depending on the type of information and complexity of the event, the information was incorporated into training letters, lesson plans, systems descriptions, special classes, or simulator training.
One of the events reviewed involved repetitive reactor trips on low / low steam generator levels during unit startup, with five occurrences in recent months.
The licensee has made a significant effort to reduce these level trips including hardware modifications, training, and increased calibration frequencies.
A single element feedwater control system has been installed for unit startups, as well as new bypass feedwater control val"e systems.
The new bypass system is not yet modeled on the simulator, but the licensee indicated that this simulator modification may be completed prior to the Unit 1 startup and training provided to the operators. Additional simulator training on steam generator level control during startups has already been completed, and additional training is planned for operators involved in the Unit 2 restart.
Additicnally, the licensee has now required calibration of the main and bypass feedwater control systems prior to each unit startup.
Another method utilized by Sequoyah to quickly provide operational experience feedback to operators is the weekly one-hour shift training meetings.
These meetings are held on each shift to discuss lessons learned from operating events as well as subjects such as plant status and safety.
If the meetings cannot be held due to operational priorities, they are rescheduled.
The inspectors witnessed one of these training sessions which appeared to be informative and well controlled, with good participation by the operators. The feedback of operating experience to licensed operators at Sequoyah appeared to be procedurally controlled, timely, effective, and well documented.
Review of Modifications to Emergency Operating Instructions (E01s),
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Abnormal Operating Instructions (A01s), and General Operating Instructions (GOIs): In addition to the required annual review of all these procedures, each licensed operator and STA is required to review all revisions to these procedures.
The Training Shift Engineer distributes a procedure revision verification sheet to all licensed personnel.
High priority revisions which are important to safe operations are designated for immediate action, and must be signed off by licensed personnel before assuming a shift.
Revisions not designated for immediate action must be reviewed and signed off within five working shif ts by all licensed personnel.
STAS must review and sign off the revisions within seven working shifts.
The inspectors reviewed the documentation for these reviews for the year of 1985 and noted no deficiencie.
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Annual Control Room Inaccessibility Drills:
As part of the requalification program, each licensed operator is required to participate in at least one drill annually for shutdown from outside of the control room. The drills consist of a walkthrough and simulated operation of the controls which would be utilized to safely shut down the reactor in the event of an inaccessible control room. The lice see has failed to complete these drills for staff SR0s in the past, and has attributed this deficiency to the implementing procedure which addressed only shift licensed personnel.
This procedure has been revised to address all licensed personnel, and a review by the inspectors indicated the training is being completed as required.
In addition, during planned unit shutdowns, the licensee normally attempts to perform some part of the shutdown from these backup controls.
Some examples revie"ed included boration, pressurizer pressure control, and steam generator level control.
Selection of Annual Requalification Training Topics:
The licensee
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conducts semi-annual meetings to determine topics to be emphasized in requalification training.
These meetings include both Training and Operations personnel, and appear to be an effective means of accomplishing the objective.
The minutes of the last two meetings conducted were reviewed, and the areas designated for training emphasis included INp0 50ERs, INP0 SERs, plant modifications, systems, procedures, regulatory changes, and deficiencies revealed by previous requalification examinations.
Appendix A of 10 CFR 55 requires that the results of the annual examinations be utilized to determine requalification topics, and this is an area of concern at Sequoyah due to the previously noted narrow scope of the examinations. The annual requalification examinations at Sequoyah are totally limited to material taught in a specific requalification year. This would appear to make it very difficult to determine weaknesses in other areas which should be emphasized in the next year's requalification training.
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Instructors:
Interviews of licensed operators indicated a high level
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of confidence in the technical ability of instructors teaching requalification training.
These instructors were all SRO licensed and verified to be attending requalification training. Previous exemptions from requalification training and the annual examination for licensed instructors had been deleted from the licensee's procedures.
It was noted by the inspectors that two of the requalification instructors had not completed the licensee's instructor certification process.
One of the instructors had not reached 18 months as an instructor which is the procedural limit for completing the certification.
The other individual has been an instructor for several years, but was exempted by the licensee's procedures because he is a supervisor. The exemption from the certification process was made on the premise that he teaches infrequently and can be classified as a " guest lecturer."
The inspectors do not agree with this " guest lecturer" designation.
Item 1.A.2.3 of NUREG 0737 specifies that guest lecturer does not apply
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to permanent members of the training staff.
This designation is reserved for experts in a particular field who lecture on an infrequent basis such as an engineer or an instrument and control supervisor. The licensee indicat ed that these two instructors had completed one of the seven required training courses, and would be certified as soon as possible.
Since the failure to complete the required instructor certification has been a concern in recent NRC and licensee QA audits, the certification of these two individuals will be an inspector followup item (327,328/86-17-03).
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Procedure Deficiencies:
The licensee has recently revised the corporate training procedures 0202.05 and OSLT-1.
The inspectors identified numerous cases where Sequoyah procedures and training 1-tters had been revised to reflect these changes and were in disagreement.
The licensee was very responsive and implemented revisions to correct these deficiencies.
Two procedural deficiencies noted in the area of requalification training included the following:
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OSLT-1, dated January 6, 1986, required that records of requalification training be retained for two years. While this retention period meets the minimum requirements of Appendix A of 10 CFR 55, it is less restrictive than other Sequoyah documents.
Technical Specification 6.10.2.g requires the retention of records of trair,ing of the plant staff for the duration of the license.
Procedure 0202.05 also requires lifetime retention of the records.
The inspectors verified that these records were being maintained per the Technical Specification requirements, and the licensee implemented a change to T-1.
The inspectors also noted that the OSLT-1 reference page referenced a number of procedures that had been cancelled or superceded as early as 1982.
It appeared that the old reference page from the previous revision of the procedure had been re-utilized, and the licensee committed to update the references.
7.
Non-Licensed Operator Training Newly hired operators at TVA receive a comprehensive two year training course in nuclear fundamentals and systems at the Power Operations Training Center (POTC).
This is one of the more extensive non-licensed operator training courses in existence.
Since it has been inspected and found satisfactory in the past, it was not reviewed in detail during this inspection.
The inspectors reviewed the Sequoyah specific training including both classroom and on-the-job training (0JT).
The initial training in these areas appeared to be adequate, although interviews indicated that the OJT qualifications were rushed due to time and personnel constraints.
The major concern of licensed and non-licensed operators interviewed was the lack of a regular requalification training program for non-licensed operators. As mentioned previously, the non-licensed operators
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receive only one week of requalification training annually.
This single week appeared to be utilized for annual retraining requirements such as general employee training, fire fighting training, and emergency planning.
The limited time provided does not allow requalification training in areas covered in the initial training program such as reactor theory and thermo-dynamics.
This makes the eventual entry into license training for a non-licensed cperator more challenging than necessary, and would appear to reduce the chances for success. The inspectors also noted that there is no requalification or recertification program associated with the 0JT qualifications.
For tasks which are not frequently performed, it would appear that the operators could incur a problem in maintaining a high level of proficiency. Ideally, the non-licensed operators would rotate regularly through requalification training as being implemented at another TVA facility.
This would help ensure continued proficiency as non-licensed operators, maintain the skills necessary to enter license training, and would promote the shift team concept of training.
A number of other facilities who have established such non-licensed requalification programs have included these operators in some simulator training as observers. This practice also promotes the team concept, and provides the non-licensed operators with an insight to control room operations as related to their in plant duties.
Licensed operators interviewed indicated a definite need i
for this type of training interface with respect to control room operations.
The inspector accompanied non-licensed operators on routine inspections of operating plant equipment, and the operators observed appeared knowledgeable and well trained. One deficiency noted was that the operators were not aware of the status of instrumentation with significantly out-of-date calibration stickers.
The licensee indicated that these calibration stickers were no longer in use, and were a carry-over from construction.
These stickers should be removed, and non-licensed operators provided training on the current methods utilized at Sequoyah to ensure instrumenta-tion is calibrated at the required frequencies.
8.
Training Records The inspectors reviewed a significant number of records involving the documentation of licensed and non-licensed operator training, licensed requalification training, and instructor qualifications.
These training records appeared to be extremely well organized, retrievable, accurate, and legible. Each operator's entire training record was maintained in a single file including examinations, qualification checklists, evaluations, reactivity control manipulations, and records of remedial training.
In addition, these training files were subdivided and tabbed so that a record of any particular training course, such as GET on fire fighting, was instantly retrievable.
Maintaining such complete, well organized, and retrievable records of training not only improves the auditability, but enables the training staff to closely monitor individual performance and to readily detect training deficiencies.
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9.
Pre-Startup Training Comitments Sequoyah has experienced an extended outage of both units, and a number of plant modifications have been made during this period. This long period of relatively little operating activity may have had some negative impact on the level of proficiency of licensed and non-licensed operators in respect to a unit startup and any potential operating transients that may be encountered.
In addition, the present fuel configuration in Unit 2, which is the first unit to restart, will require a very high initial boron concentration.
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This high boron concentration may result in a positive moderator temperature coefficient during the startup which requires specific operating precautions.
In anticipation of the Unit 2 restart, the licensee had already conducted unit startups on the simulator for licensed operators in the last requalification cycle.
In response to concerns expressed by the inspectors in this areas, the licensee made several additional comitments for training to be completed prior to a Unit 2 restart including:
Ensure that each licensed operator completes a simulator reactor
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startup as part of requalification training.
Operators presently attending college full-time would be exempted from this pre-startup comitment. (This exemption does not apply to annual requirements for reactor startups and reactivity manipulations.)
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Provide a training letter to all operators on major plant modifications completed during the extended outage.
Provide a training letter regarding precautions to be taken on a unit
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startup with a high boron concentration and potential positive moderator temperature coefficient.
If the Unit 2 'startup does not occur prior to requalification cycle 2
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in May, additional simulator training startups would be conducted for all licensed operators except for those attending college.
If the startup occurs prior to this requalification cycle, the licensee comitted to provide additional simulator training for licensed personnel assigned to the shifts responsible for the startup.
These pre-startup training comitments will be an inspector followup item (327,328/86-17-04).
The licensee also indicated that if there was sufficient time between the Unit 2 and Unit I restarts, that the new feedwater control bypass modification would be completed on the simulator.
This would allow simulator training to be completed on this new feedwater control system prior to the Unit I restart.
These training commitments should help ensure that licensed operators are proficient, aware of the latest plant modifica-tions, and prepared to conduct a restart of Unit 2.
The inspectors still have some degree of concern regarding the preparedness of non-licensed operators to support a unit restart.
Since there is not a regular non-licensed requalification cycle, and no requalification program for on-the-job skills, the proficiency necessary to conduct local operations in
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support of the startup cannot be. ensured. The licensee should consider a limited amount of classroom training, and the performance of spot evalua-tions on local plant operations such as system alignments and equipment inspections and startups.
10. Summary The Sequoyah licensed operator, non-licensed operator, and licensed requalification training programs appeared to be well managed, effective, and very well documented. Although a number of deficiencies still exist in the programs, indications are that the level of training has significantly increased in the last year. Additional training staff, and the establish-ment of regular rotating requalification cycles. would substantially improve
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the programs and help ensure a continued high level of operator proficiency.
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