IR 05000327/1993037
| ML20059C032 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/17/1993 |
| From: | Lawyer L, Payne D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20059B990 | List: |
| References | |
| 50-327-93-37, 50-328-93-37, NUDOCS 9401040337 | |
| Download: ML20059C032 (18) | |
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UNITED STATES-
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NUCLEAR REGULATORY COMMISSION REGloN H
'$ S 101 MARIETTA STREET N.W., SUITE 2900 p ATLANTA, GEORGIA 303234199
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/ ENCLOSURE 2-
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Report Nos.: 50-327/93-37 and 50-328/93-37 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah I and 2 Inspection Conducted: November 15-19, 1993
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Inspector: j ,, /,3 -/7- 93 D.'CharlesP&yng 7 Date Signed Accompanying Personnel: J. Moorman, RIl Approved by- W M bn5.rX L rence L. Lawyer, Chief /
M-/7-13 Date Signed
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0 erator Licensing Section '
erations Branch !
Division of Reactor Safety }
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SUMMARY
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Scope: f
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A special, announced inspection of the Sequoyah licensed operator :
, requalification program was conducted during the period November 15-19, 1993. ;
The inspectors reviewed and observed annual requalification examinations >
, conducted by the facility licensee and conducted inspection activities as j specified in Temporary Instruction 2515/117, Licensed Operator Requalification .
Program Evaluation. Seven Senior Reactor' Operators (SR0s) and five Reactor :
Operators (R0s) received facility administered written and operating ,
examinations. - Activities reviewed included examination development, l examination administration, training staff qualifications and training, and ;
simulator fidelity. ;
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l 9401040337 931217 PDR G
ADOCK 05000327 l PDR
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Results:
f Operator Pass / Fail:
(As-determined by facility results) -l SR0 R0 Total Percent -
Pass 7 4 11 91.7% ;
Fail 0 1 1 8.3% e
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The inspectors identified the skills and abilities of the training staff as a -l strength (Paragraph 2.c.(1)). .l The inspectors identified upper management observation of annual simulator evaluations as a strength (Paragraph 2.c.(1)).
The inspectors identified a violation regarding lack of site procedures for i directing implementation of the Sequoyah requalification process, ;
VIO 50-327,328/93-37-01 (paragraphs 2.b.(2) and 2.c.(4)).
l The inspectors identified a violation regarding documentation of individual y operator requalification examination results and of performance of required ;
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control manipulations as specified in 10 CFR 55.59(c)(5)(i) and 10-CFR 55.59(c)(3)(i), respectively, VIO 50-327,328/93-37-02 (paragraphs 2.b.(3), !
2.b.(4), and 2.c.(3)). .
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REPORT DETAILS
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1. Persons Contacted
Licensee Employees
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- D. Ashley, Operations Training Manager, Corporate
+J. Baumstark, Operations Manager
+*R. Driscoll, Site Quality Manager
- L. Durham, Manager, TVA Nuclear Training 1
- D. Keuter, Vice President, Nuclear Readiness i
+*R. Fenech, Site Vice President, Sequoyah
+*R. King, Manager Operations Training
- K. Powers, Plant Manger !
+*R. Proffitt, Compliance Engineer
+G. Sanders, Operations Support Manager
+R. Shell, Site Licensing Manager
+*M. Shepherd, Sequoyah Training Manager
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- N. Welch, Operations Superintendent '
Other licensee employees contacted included instructors, engineers, i technicians, operators, and office personnel.
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NRC Personnel j
+W. Holland, Senior Resident Inspector - Sequoayh j
+*S. Shaeffer, Resident Inspector - Sequoyah !
4 Attended entrance interview l
- Attended exit interview
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Acronyms and initialisms used in this report are listed in the last I paragraph.
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2. Discussion ,
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a. Scope
NRC inspectors conducted a special, announced inspection of the '
Sequoyah licensed operator requalification program during the period t November 15-19, 1993. This week was the fifth of seven weeks !
scheduled for cycle 6 of their requalification program. Seven SR0s !
and five R0s received annual operating examinations. The inspectors reviewed and observed annual requalification examinations conducted by !
the facility licensee and conducted inspection activities using the j guidance in Temporary Instruction 2515/117, " Licensed Operator
- Requalification Pr'ogram Evaluation". Activities reviewed included examination development, examination administration, training staff ,
qualifications and training, and simulator fidelity.
Inspection preparation was accomplished on-site during the week of October 25, 1993. During this week, one crew of operators failed t their annual simulator examination. As a result, an NRC operator :
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licensing examiner observed additional simulator examinations t
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that were administered during the weeks of November 1, November 8, l' November 15, and December 6, 1993. Information gained during these additional observations was used to augment this inspection.
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b. Examination Development .;
- (1) Sample Plan !
The facility developed a sample plan intended to represent the i training received and material covered during the requalification cycle. Examination items were then selected based on the sample .
plan. The inspectors found that no approved procedure existed for directing the development of the sample plan. Corporate training procriure TRN-11.4, " Continuing Training For Licensed i Personnel" stated that the format of the Sequoyah annual '
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examinations shall be in accordance with the format of NUREG-1021, " Operator Licensing Examiner Standards" section ES-601.
ES-601 gives criteria that a sample plan should meet and ;
refers to NUREG/BR-0122, " Examiner's Handbook For Developing ,
Operator Licensing Written Examinations" for further guidance.
The Sequoyah sample plan did not follow these guidelines.
The Sequoyah sample plan development followed an informal and apparently unapproved process documented in the sample plan.
Test item selection was determined by a " priority factor" which '
was the product of the average R0 K/A rating and the amount of time spent on the topic. As a result, no SRO-specific topics ,
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were identified. Latitude was available to select / deselect specific topics based on licensee needs.
l The inspector identified several weaknesses in the approach used i by the training staff.
First, topic selection was strongly i weighted towards items which had received a great amount of ,
training time with secondary emphasis given to the topic i importance. Second, no consideration was given towards difficulty of the topic / task or its frequency of performance. As a result, some important safety-related topics / tasks which received little training time were not sampled. For example, no ,
industry event, SOER or LER topics were selected for testing "
because of low priority factors. Additionally, Procedure A01-14,
" Loss of RHR Shutdown Cooling" and simulator exercise scenario
" Loss of RHR Shutdown Cooling" were not selected for testing i despite recent industry concerns in this area and significant ,
time spent in training on the topic. This appeared to be a !
result of an error by the training staff because the priority '
factor for A01-14 was high enough that it should have been sampled. Also, some topics were not assigned an importance rating and thus were not sampled by default including some with !
significant training time spent on them. One simulator exercise topic, " Reactor Startup, Pull To Critical" was selected for ,
testing yet 10 CFR 55.59(a)(2)(ii) specifically exempts this '
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i topic from its list of required items to sample from 10 CFR 55 45(a). Overall, high reliance was placed on the sample plan developer to manually force fit the plan to make it resemble a reasonable sample of the topics covered during the two year requal cycle.
The inspector verified that the examination items actually selected were appropriate for testing'and represented a >
reasonable sample of the items specified in 10 CFR 55.45(a). The ,
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facility presented a reasonable examination of licensed operator skills, knowledges and abilities. How representative the examination was of the training that whs conducted could not be determined from the information provided.
- (2) Reference Materials and Training Department Procedures i
A list of procedures reviewed during the inspection is provided in Enclosure 4. The inspectors noted the absence of facility i procedures for implementing the Sequoyah licensed operator requalification program. Instead of having site-specific ,
procedures, generic requirements were specified in corporate ;
level procedures. These procedures provided guidance for :
implementation of TVA's continuing training program for licensed personnel to ensure consistency among its various licensed facilities.
NUREG-1021 was incorporated by reference into the corporate procedures establishing TVA's standards for licensed operator examination format, time limits and grading criteria. However, NUREG-1021 was written to provide guidance for NRC examiners to develop, administer and grade initial and requalification examinations for operators licensed under 10 CFR 55. As a result, it does not include requalification program requirements specified in 10 CFR 50 and 10 CFR 55.
For example, NOREG-1021 specifies that only crew evaluations of simulator examinations be conducted. It does not require that each licensed operator be individually evaluated during the dynamic simulator examination since it was expected that utility instructors would continue to conduct individual evaluations as required by 10 CFR 55.59.
Additionally, the record keeping guidance of the Examiner Standards is written to meet NRC needs since 10 CFR 55.59 specifies that the facility licensee retain the documentation of operator performance from requalification examinations. The lack of adequa'te procedural' guidance for conducting the licensed operator rcqualification program is contrary to the requirements of activities affecting quality per 10 CFR 50, Appendix B, Criterion 5, " Instructions, Procedures and Drawings" and is identified as Violation 50-327,328/93-37-01.
The inspectors determined from operator and management interviews that a feedback process was in place to incorporate lessons
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learned, changing industry standards and events, as well as operator and management comments. Lesson plans were found that addressed industry events and SOERs, but no formali md process for tracking and incorporating the feedback into the training program was in place. This is another example of Violation 50-327,328/93-37-01.
l Review of all emergency and abnormal instructions on a regularly i scheduled basis over the two year requalification cycle was ,
required as part of each operator's OJT. Additionally, design i changes, procedure changes, facility license changes, and recent '
site and industry events were covered via the " required reading" ,
program. While required reading was subject to periodic test coverage, it was not included on the annual examinations due to low priority factor. See Paragraph 2.b.(1) above.
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- (3) Written Examinations :
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Written examinations were not administered during this ,
inspection. Written examinations were conducted on a biennial ?
basis at Sequoyah as permitted by 10 CFR 55.59. The examinations ;
observed during this inspection were the "off-year" annual !
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operating examinations. Therefore, the inspectors checked a sample of weekly quizzes and the 1992 comprehensive written examination for grading accuracy and question validity. In general, questions appeared to test higher level cognitive skills 5 and instructor grading of the tests was accurate. However, control of exam banks and question development needs improvement.
for example, several two part questions were used on the :
comprehensive written exam. The inspectors noted that these questions were modified slightly between weeks of the exam and ,
that the grading criteria in the answer key specified partial ,
credit for one and no partial credit for the other. This action .
was contrary to the guidelines provided in NUREG-1021 which !
specifies that all partial credit should be identified. Another example of the need of improved question control was questions '
that required the operator to perform a calculation and the associated answer key provided a range of acceptable answers.
One week the question would have a_ specified range for the correct answer and the next week another, wider (or narrower)range would be correct.
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The inspectors identified two errors in the grading of one -
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operator's biennial comprehensive written examination (one of which involved the partial credit issue discussed above). The errors resulted in the operator receiving a passing grade for the examination.
However, an examination failure would have resulted l if the examination had been graded correctly. This occurred despite the grading being double checked by another instructor.
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While individual whose exam was misgraded no longer holds a l
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license, the ability of the trai.iing staff to accurately make pass / fail decisions for identifying operators requiring remediation is paramount to the requalification process.
Finally, the inspectors noted that the official record copy of the written examination and answer key did not always reflect how the examinations were actually administered and graded. For i example, when questions were deleted from the examination, the answer key was not annotated. As a result, an accurate record of the as-given examination was not available for inspection. This was contrary to the record keeping requirements of 10 CFR 55.59(c)(5)(1) and is identified as Violation 50-327,328/93- ,
37-02.
- (4) Operating Examinations !
The inspectors determined the dynamic simulator scenarios to be
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well written, comprehensive, and representative of an operationally challenging series of events. They were designed to exercise the Sequoyah E01s and the operators' understanding of integrated plant operations. Each scenario contained complete r
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informaticr. on simulator setup, simulator operator cues, performance objectives, grading criteria, and expected operator actions. Crew and individual critical tasks were well defined i and specified in each simulator guide. Additionally, each crew was evaluated against performance competency ratings. However, .
individual competeacy ratings were determined only when !
significant " weaknesses" to a specific operator were noted. This is contrary to the requirements of 10 CFR 55.59(c)(4)(iii) which specify that the requalification program must include:
" Systematic observation and evaluation of the i performance and competency of licensed operators and senior operators by supervisors and/or training staff members, including actions taken or to be taken during actual or simulated abnormal and :
emergency n- maures."
The lack of x m s1 guidance for conducting licensed operator individual s W ,r evaluations is another example of Violation '
50-327,328/93 . c02. The performance standards for satisfactory _
completion of the simulator examination were concurred on by an i Operations Department representative.
The inspector found that each JPM completely defined the task to !
be performed and contained prompts and cues where appropriate.
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The JPM tasks that could be performed on the simulator, contained simulator setup information. Steps critical to the correct performance of the task, were appropriately identified and marked '
in the JPM.
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The inspector verified that the operating examination adequately sampled the items stated in 10 CFR 55.45.
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c. Examination Administrction The inspectors observed a sample of & wiministered in the simulator and in the plant during the preparation . d inspection weeks. The ,
inspectors observed all simulator examinations administered during the four week period from October 25 through November 19, 1993 and during '
the week of December 6, 1993.
- (1) Dynamic Simulator Examinations The administration of dynamic simulator examinations was observed to determine if training department evaluators could perform accurate and objective evaluations of licensed operator performance.
A total of four shifts of licensed operators were observed taking >
simulator examinations. Each shift was partitioned into three crews for the purpose of the examinations. The crews were comprised of two SR0s, two R0s and an STA who, in some cases, was SR0 licensed. The SR0s filled the positions of SOS and AS05.
The R0s filled the positions of 0ATC ar,d CRO. The 0ATC, CRO, and ASOS were each assigned one evaluator. One evaluator was ,
assigned to watch both the SOS and the STA. This arrangement had .
no adverse affect on the quality of the evaluation of the SOS or
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the STA and was consistent with how the NRC conducts requal i simulator evaluations.
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The inspectors determined that the training department evaluators were capable of accurately detecting operator mistakes and ,
deviations from procedures made during the evaluation scenarios.
They were also capable of analyzing their observations and arriving at appropriate pass / fail decisions. When operator performance was above established failure criteria but indicated weaknesses, the training department evaluators identified the ..!
operator as needing remedial training. No objective standards .
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for measuring individual operator competency were applied unless
" weaknesses" were identified. As discussed in Paragraph 2.b.(4)above, this approach was contrary to the requirements of 10 CFR 55.59(c)(4)(iii). All training department decisions concerning simulator examination failures and identification cf operators needing remediation were supported by the Operations.
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Department. Despite the failure to perform individual operator ;
competency evaluations on the simulator examinations, the :
inspectors concluded that the training department evaluators had the ability and skill to properly determine whether operator performance met TVA and regulatory minimums. This ability was considered a strength. Weaknesses identified during the ;
scenarios were noted and discussed among the evaluators and then
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documented in crew and individual writeups. A management representative from the operations department was present at each simulator examination but did not participate as an evaluator.
The inspectors also noted that the Site Vice President observed some of the simulator exams and provided his comments to the operators and evaluators at the conclusion of his visit. The inspectors considered the involvement of higher management in the evaluation process as a strength.
During simulator examinations administered the week of October 25, 1993, facility evaluators identified the performance of one crew as unsatisfactory. The individual performance of the five operators on this crew was also determined to be unsatisfactory. Training department personnel analyzed the unsatisfactory performance to determine root causes and, following a iraining Review Board meeting, prepared a remediation progrec fo. the crew and the individuals. The crew was given remedial training and re-evaluated. Both the crew and the operatcrs exhibited satisfactory performance during the retake examin' tion.
During simulator examinations administered the week of November 1,1993, facility evaluators identified performance of one crew as not meeting performance standards desired by Sequoyah management. Also, the individual performance of one crew member was judged to be below minimum standards resulting in an unsatisfactory evaluation. Although the crew met the minimum requirements to pass their examination, collectively they exhibited a lack of proficiency in certain crew operating competencies. The training department evaluators identified the crew as needing remedial training and a Training Review Board was convened to define the scope of the remediation. After completing the remedial training, the crew and the individual operator demonstrated the desired level of performance during a retake examination.
Operators taking simulator examinations during the weeks of November 8 and November 15, 1993, exhibited satisfactory performance during these examinations.
During the week of December 6,1993, simulator examinations administered to one crew of NRC licensed training department instructors were observed. The scenarios used for this examination were of similar complexity to the scenarios used to evaluate operators who routinely operate the plant. Evaluators used the same standards for evaluating the performance of their peers as were used to evaluate the plant operators. Observations made by the evaluators highlighted weaknesses in performance with the same rigor applied in the evaluation of the plant operators.
The inspectors noted that the evaluated instructor crew
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demonstrated weaknesses in communications skills similar to those demonstrated by the on-shift operators.
- (2) Generic Operator Performance Weaknesses Throughout the simulator examinations, individual operators exhibited some generic weaknesses in their ability to operate the reactor during abnormal and emergency event mitigation actions.
- These weaknesses are described in the follo ing paragraphs.
SR0s and R0s demonstrated a misunderstanding of some E01 rules of usage and definitions. The rules of usage are delineated in the SQN E01 Program Manual EPM-4, " User's Guide". SR0s and R0s did- t not understand the meaning of the term " controlled" as it was '
defined in EPM-4. Understanding this is important when i implementing accident mitigation strategy because transitions between procedures within the E0Is are sometimes based on whether a parameter is " controlled". Examples of this misunderstanding :
were demonstrated when operators performed improper transitions ,
within the E01 procedures during the simulator examination.
l The S0S, ASOS, and STA of one crew did not understand the intent of a caution at the beginning of FR-H.I, " Loss of Heat Sink". As a result, the crew deliberately proceeded with their accident >
mitigation strategy having less than the required flow from the AFW system. Without the required AFW flow, a degraded core i cooling condition existed and the plant was closer to overheating ,
the fuel. This lack of understanding significantly contributed- !
to the crew's unsatisfactory examination performance.
Operators were inconsistent in performing actions to take manual !
control of equipment that failed to respond to valid automatic !
initiation signals.
Interviews with operators and instructors :
indicated there had been plant policy changes on how to perform this task. They also indicated that there was confusion on what ;
the current policy was.
EPM-4 provides guidance on how to read E0Is during a plant accident. Operators who were tasked with reading the E01s did .
not adhere to the guidance for procedure reading in as stated in i EPM-4. This guidance states that the operators shall read all high level action steps, notes and cautions in an E01. When .!
reading procedures, the operators applied this guidance with varying degrees of compliance.
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There were many instances of imprecise and/or incomplete communications between operators. An example of this occurred '
during one crew's implementation of the E01s. An R0 informed the ASOS that only one steam generator was intact, when in fact three !
steam generators were intact.
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an indication for actual valve position. This occurred during simulator scenarios in which the MFRV would not move from tha -
mid-position. When responding to an alarm for cold leg accumulator low pressure, one R0 incorrectly reported to the AS0'S that the alarm was for low accumulator water icvel. This misled the crew and caused an unnecessary challenge to TS limits for one of the four cold leg accumulators.
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The inspectors noted that Sequoyah management has implemented the ,
" STAR" program for personnel who operate plant equipment. This program states that an operator should "Stop, Think, Act, and Review" when operating equipment.
Licensed operators, who are very much involved in the day-to-day operation of equipment, very rarely used the " STAR" principle when operating equipment in the simulator. Plant managers stated that the STAR program was a recent initiative and not all operators had gotten in the habit of routinely applying its principles.
- (3) Written, Simulator and JPM Examination Documentation The inspector reviewed documentation of previously administered requalification examinations. Records consisted of a summary i sheet listing the JPMs and simulator scenarios used in the operator's exam and a copy of the written examination taken by the operator. Unless the operator failed the examination or exhibited significant performance deficiencies, no other documentation was kept. By only listing the simulator scenarios and JPMs used for an examination, reconstructing the record of an operator's examination requires going to the simulator or JPM exam bank to look at the test item. There are no controls on the exam banks to ensure that a record of changes to test items is kept or to ensure that an item is not deleted.
Without controls '
on the exam bank or the inclusion of some part of the examination material used in an individual operators record, a reliable '
record of an administered exam cannot be reconstructed.
I To maintain proficiency doing certain infrequently performed tasks, operators are required by 10 CFR 55 to perform tasks on j the simulator or in the plant. Some of the tasks are crew oriented tasks while others are individually oriented.
Currently, the operators can receive credit for performing any !
task if they are a member of a crew that performs the task. This !
can allow an operator to receive credit for an individually oriented task even if it was not performed on an individual '
basis. The records maintained to document operators' performance of these tasks do not provide sufficient information to determine if the operator actually performed an individually oriented task to meet the proficiency requirements. Failure to maintain ,
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, e 10 records that contain sufficient information to furnish evidence that activities were conducted in accordance with requirements is another example of Violation 50-327,328/93-37-02.
- (4) Walkthroughs/JPMs Each operator was administered five JPMs as part of their operating test. Three JPMs were performed on the simulator and ,
two were simulated in the plant on either Unit 1 or Unit 2.
Some evaluator exam administration inconsistencies were identified by the inspectors. The lack of site srocedures, inadequate instructor training, and failure to perform annual audits of instructors while they conduct evaluations contributed to the weaknesses observed by the inspectors.
During some simulator JPMs, the annunciators were disabled, while during others they were enabled. During those simulator JPMs when the alarms were enabled, the simulator instructor or the evaluator acknowledged alarms they judged to be unassociated with the JPM without direction from the operator being examined. This provided inappropriate cuing to the operator and distracted the evaluator from performing his primary responsibility of operator evaluation. No guidance was provided in the JPMs or in site procedures regarding how alarms should be handled, especially when nuisance alarms were occurring. As a result, the evaluators and simulator instructors developed ad hoc " rules" as the JPMs were conducted.
Some Sequoyah evaluators conducted activities inappropriate for an examination setting. These included: allowing the examinee to observe the instructors while they established initial conditions for a JPM on the simulator, providing coaching on JPM test techniques during the examination, notifying the examinee how quickly a time critical JPM should be performed, failing to notify an examinee that a JPM was time critical, and using voice inflections to emphasize key information in the initial conditions or initiating cues. While many of these issues are addressed in guidelines provided in NUREG-1021, ES-603, the facility evaluators apparently were unaware of or forgot these guidelines. The items discussad in this and the previous paragraph are more examples of failure to develop adequate procedures as cited in Violation 50-327,328/93-37-01.
i Some operators were unfamiliar with the proper conduct of JPMs from the examinee perspective. Often these operators would fail to discuss the steps they were performing, they would fail to point out the indications they were observing, they would fail to ,
allow the evaluator provide feedback to the actions that were taken, and they would fail to role play actions they would take if additional information were needed to complete the task.
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While no operators failed as a result of this weakness and the
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evaluators compensated for it to some degree, future problems should be expected when alternate path or faulted JPMs are '
administered. The inspector noted that many other operators observed during the inpsection did not exhibit these weaknesses and actually role played the JPM quite well. Thus, the inspectors concluded that a lack of training was not the cause.
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d. Simulator Facility Sequoyah simulator fidelity and performance was good. The inspectors identified one fidelity deficiency during the course of the inspection. This item is described in Enclosure 3, Simulator Facility Report.
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e. Staff Training and Qualifications The inspectors reviewed the process for certification and recertification of Sequoyah Training Department nuclear instructors.
This process was documented in a corporate level instruction NTI-207.10, " Nuclear Training Instruction." The inspectors determined there were no equivalent site level procedures. They also determined that the Sequoyah nuclear instructors were trained, certified and retrained in accordance with the corporate level instruction. Non-TVA instructors, under contract to train at Sequoyah, were not required to complete the initial training in Appendix A of NTI-207.10 on instructor skills.
Instead, they were audited for satisfactory instructional skills then allowed to instruct. This approach was allowed by NTI-207.10 and it appeared to be adequate.
NTI-207.10 required an annual audit of an instructor's skills. The inspectors found that the documentation and tracking of this process was incomplete. The inspectors reviewed the 1992 and 1993 audit records for all licensed operator instructors and reviewed the complete training records of two of these instructors. It was determined that a member of the Accreditation Section normally conducted an audit of an instructor's teaching skills while the Manager Operations Training conducted an audit of the instructor's technical knowledge. This " split" method of auditing was not prescribed in NTI-207.10, though it also was not precluded. There was no clear system for providing feedback from one auditor to the other.
The audits gave critical comments on the instructors' performance, documenting both strengths and weaknesses. The audited instructors '
had reviewed and signed their audits; however, few of these were found '
to have a manager's signature. This indicates that the instructor's supervi!or may not be aware of the performance level of his staff.
The protedure for conducting the audits, NTI-207.10 provided little guidance on the administration of the audit process. It was noted that several instructors did not receive audits in 1992. This was identified and documented by the Training Department Manager. The 4 audits were conducted at the first opportunity in 1993.
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e 12 NTI-207.10 also stated that the instructors' performance shall be evaluated in each training setting in which they instruct. Although the instructors were audited in the classroom and simulator setting, there were few audits in the OJT setting and no formal audits of the instructors as evaluators This weakness was evident by the r differences observed between evaluators in their methods of administering JPMs. See Paragraph 2.c.(4) above.
3. Action on Previous Inspection Findings The following items were reviewed and evaluated by other Region II inspectors based on information submitted by the licensee over the course of several months prior to this inspection.
Closure of these tracking items is documented in this report.
(Closed) IFI 50-327,328/93-300-01, 'AMi Piping Not Vented And Filled If Steam Voiding Occurs; Potential Water Hammer Hazard". This item concerned the possibility of a water hammer event following an AFW actuation with a voided discharge line due to backleakage from the steam generators.
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Licensee procedures only required venting of the AFW pump casing and not the discharge piping if backleakage into the discharge piping was detected. This issue was opened and tracked by the licensee under PER 930190. This PER was closed on June 30, 1993. The Sequoyah Engineering staff evaluation stated that the scenario required multiple failures to occur, therefore further corrective action was not warranted. The licensee also monitors the discharge piping shiftly which would detect any backleakage before it was a significant problem. NRC Information Notice -
91-50 stated that additional requirements to mitigate the number of water ,
hammer events were not cost-effective. The inspector considered the licensee's closure of this PER acceptable and no further corrective action is required. This Inspector Follow-up Item is closed.
(Closed) VIO 50-327,328/93-300-02, " Failure To Provide Quality Control To Ensure EPM-3 Was Accurate And Complete". There are two issues within this violation. The first issue is a distgreement between the Step Deviation Document, EPM-3 section 3.2.3, and the Post-SGTR Cooldown emergency procedure ES-3.2 step 10.b. The errar was in the summary section of EPM-3 and was corrected in Revision 1 dat-d September 3, 1993. The E01 was correctly written and was not revised.
The second issue was the incomplete implementation of WOG ERG ES-0.0, Rediagnosis. This action was contrary to the Step Deviation Document which stated that the intent of WOG guideline ES-0.0 was fully met by the Sequoyah E01s due to the transition steps within the procedures and inclusion of additional transitions on the foldout pages of applicable procedures. The WOG guideline for ES-0.0 had allowances for a transition from E-3 to E-1 which could not be done in the framework of Sequoyah's procedures. The licensee filed Direct Work Request DW-93-045 with Westinghouse and met with them in August to discuss several issues including this one. The inspector reviewed the minutes of this meeting and concluded that the WOG had determined that the transition was not '
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necessary because all the required actions to combat a LOCA could be found in the E-3 series. Westinghouse said it did not require a change to the ,
procedure and that it was not a human factors issue. Although a completc >
written response from Westinghouse to formally disposition this item is still several months away, the inspector concluded that the licensee had sufficiently addressed the concern r ised in the violation. This Violation is considered closed. Sequoyah will be starting work on Rev.
.8 of their E01s and development of a ES-0.0, Rediagnosis procedure in
l' accordance with the WOG ERGS is planned.
Implementation of the new Rev. IB E01s is scheduled for March 1995.
(Closed) IFI 50-327,328/93-300-03, "No Specific Guidance In EPM-4 On When To Use A01s During Implementation Of E0Ps". This item concerned two issues. First was the lack of specific guidance in the E0I User's Guide (EPM-4) on when to implement A0Is during the performance of E01s. Second was the lack of guidance on anticipatory performance of E01 steps before they're required to be completed per the procedure sequence. The licensee issued Revision 1 to EPM-4 dated September 2, 1993. This revision added guidance limiting A01 usage during E01 performance and requiring E01 steps, other than securing secondary and non-essential equipment, to be performed in sequence. The inspector reviewed the revised EPM-4 and >
considered the licensees corrective action to be satisfactory. This Inspector Followup Item is closed.
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4. Exit Interview At the conclusion of the site visit, the inspectors met with representa-tives of the plant staff listed in paragraph one to discuss the results of the inspection. The licensee did not identify as proprietary any material r provided to, or reviewed by the inspectors. The inspectors further ,
discussed in detail the inspection findings listed below. Dissenting comments were not received from the licensee.
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Item Number Description and Reference
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VIO 50-327,328/93-37-01 Licensee failure to develop adequate procedures for conducting the -
Sequoyah Requalification Program as required by 10 CFR 55.59 and 10 CFR 50, Appendix B.
VIO 50-327,328/93-37-02 Licensee failure to maintain i
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adequate records documenting operating tests and performance of annual and biennial control manipulations as required by i
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, 34 5. List of Acronyms and Initialisms l AFW Auxiliary Feedwater A01 Abnormal Operating Instruction ASOS Assistant Shift Operations Superdsor (SR0 licensed)
CFR Code of Feda 21 Regulations CR0 Control Room Oper& tor E01 Emergency Operating Instruction EPri E01 Program Manual ERG Emergency Response Guideline ES Examiner Standards >
ESF Engineered Safety Feature FR Functional Recovery '
IFI Inspector Follow-up Item JPM Job Perforraance Measure LER Licensee Event Report LOCA Loss of Coolant Accident MFRV Main Feed Regulation Valve NRC Nuclear Regulatory Commission 0ATC Operator At The Controls 0JT On-the-Job Training l
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PER Problem Evaluation Report R0 Reactor Operator RHR Residual Heat Removal SQN Sequoyah Nuclear Plant l SOER Significant Operational Event Report SOS Shift Operations Supervisor (SR0 licensed)
SR0 Senior Reactor Operator STA Shift Technical Advisor TVA Tennessee Valley Authority i VIO Violation i WOG Westinghouse Owners Group ;
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ENCLOSURE 3 SIMULATOR FACILITY REPORT Facility Licensee: Sequoyah I and 2 Facility Docket Nos.: 50-327 and 50-328 Operating Tests Administered on: October 25 - December 7, 1993 This form is to be used only to report observations. These observations do not constitute, in and of themselves, audit or inspection findings and are not, without further verHication and review, indicative of noncompliance with 10 CFR 55.45(b). These observations do not affect NRC certification or approval of the simulation facility other than to provide information that may be used in future evaluations. No licensee action is required solely in.
response to these observations.
While conducting the simulator portion of the operating tests, the following .
items were observed:
ITEM DESCRIPTION Pressurizer PORV tailpipe temperature During a scenario that caused'the pressurizer to fill and produce a
" solid" plant condition, a pressurizer PORY lifted due to a valid high pressure condition. The PORV tailpie temperature indicators did not show an increase in temperature as should have occurred.
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i ENCLOSURE 4 [
DOCUMENTS REVIEWED
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Document Revision '
Number Number /Date Title
NTI-207.10 Rev. 1 Nuclear Training Instruction
SQ OTIL-3 Rev. 5 Simulator Instructor Certification
TRN-11.4 Rev. O Continuing Training For Licensed Personnel
TRN-11.7 Rev. O Conduct of Simulator Training ,
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TRN-11.8 Rev. 0 Operator License Examinations and Renewals
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