IR 05000327/1998002

Insp Repts 50-327/98-02 & 50-328/98-02 on 980202-06.No Violations Noted.Major Areas Inspected:Aspects of Licensee Operations & Maint.Review of Initial & Requalification Training Programs Were Also Conducted

ML20216E686
Person / Time
Site:	Sequoyah
Issue date:	03/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20216E651	List: IR 05000327/1998002 ML20216E648
References
50-327-98-02, 50-327-98-2, 50-328-98-02, 50-328-98-2, NUDOCS 9803180125
Download: ML20216E686 (14)

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U.S NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos: 50-327. 50-328 License Nos: DPR-77. DPR-79 Report No: 50-327/98-02. 50-328/98-02 i

Licensee: Tennessee Valley Authority (TVA) l Facility: Sequoyah Nuclear Plant. Units 1 & 2 Location: Sequoyah Access Road l Hamilton County. TN 37379 {

Dates: February 2-6, 1998 Inspectors: D. C. Payne. Senior Reactor Inspector. Region II (Sections 05.1 and 05.2)

R. F. Aiello. Senior Reactor Inspector. Region II (Section 05.3) i W. F. Smith. Senior Reactor Inspector, Region II I (Section M5.1)

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Approved by: T. Peebles. Chief Operator Licensing and Human Performance Branch  ;

Division of Reactor Safety l l

Enclosure j 9803180125 980305 PDR G ADOCK 05000327 ,

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EXECUTIVE SUMMARY Sequoyah Nuclear Plant. Units 1 & 2 NRC Inspection Report 50-327/98-02, 50-328/98-02 This special, announced inspection includes aspects of licensee operations and maintenance.- The report covers. reviews of the initial and requalification training programs for licensed operators. the training program for non-licensed operators (NL0s) and the training program for maintenance personnel, primarily instrumentation and controls (I&C) technician Doerations

. Both units operated at power during the period. Control room activities were observed during the inspection. The operators were found to be attentive and professional in their duties. Operations were considered to be good (Section 01.1).

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The inspectors concluded that the licensee's initial operator license

. training program followed a Systems Approach to Training (SAT) process and met the requirements of 10 CFR 55. However the evaluation phase of the program (element 4) did not effectively measure the candidate's level of understanding and mastery of licensed operator knowledges nor did it prepare candidates for the intensity and focus of the NRC license examination. The inspectors determined that the licensee had self-identified these same issues during its root cause analysis and had initiated actions to correct these weaknesses (Section 05.1).

. The inspectors concluded that the licensee's SAT process for licensed operator requalification (LOR) training was being satisfactorily implemented as required by 10 CFR 55.59. The inspectors also concluded that management attention was needed to ensure that deficiencies identified during the Main Control Room (MCR) abandontnent drills are promptly and appropriately resolved (Section 05.2).

. The inspectors concluded that the licensee's Auxiliary Unit Operator

.(AUD) training and qualification program complied with the requirements-of 10 CFR 50.120 for the areas inspected. The inspectors determined that AUD personnel have qualifications commensurate with the performance requirements of their jobs. However. the inspectors also observed that the AVO written examinations were a marginal tool for discriminating between a competent and less than competent operato The inspectors concluded that testing standards for AU0s were very low (Section 05.3).

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Maintenance

. The licensee's SAT process for the maintenance area's Instrumentation and Controls (I&C) training was being satisfactorily implemented as required by 10 CFR 50.120 (Section M5.1).

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Reoort Details Summarv of Plant Status

- Units 1 and 2 operated at full power for the-entire inspection perio Review of Systems - Acoroach to Trainino (SAT) Imolementino Procedures

'The inspectors performed a review of the.following Tennessee Valley Authority (TVA) Nuclear Training Manual procedures (TRNs) that generically implemented the training process for Non-Licensed' Operators (NL0s). Reactor Operators (R0s), Senior Reactor Operators-(SR0s). Licensed Operator Requalification (LOR). and' instrumentation and controls (I&C) personnel:

. TRN-11.1, "Nonlicensed Operator Initial and Continuing Training,"

Revision . TRN-11.2, " Reactor Operator Initial Training." Revision * TRN-11,3, " Senior Reactor Operator Initial Training," Revision . TRN-11.4 " Continuing Training for Licensed Personnel,"

Revision .. :TRN-17. " Instrumentation and Controls Personnel Training,"

Revision 1. CN-1, 2, and The. inspectors also performed a ' review of the following licensee Training Process Instructions (TPIs) that specifically implemented the SAT process for the training programs required by 10 CFR 50.120 and 10 CFR 55.59:

. TPI-201.1. " Conducting Analysis (Needs, Job, and Task)."

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. TPI-202.1, " Written Examination Requirements," Revision . TPI-203.1, " Developing. Revising, and Controlling Training Materials " Revision . TPI-203.2 " Incorporating Nuclear Experience Reviews (NERs) into Training Programs," Revision * TPI-203.3, " Managing Change Actions," Revision . TPI-205.1, " Managing Training Assessments, " Revision . TPI-205.2, " Evaluating Training Programs," Revision The ' inspectors noted that the above listed procedures and instructions reflected the controls needed to successfully implement the SAT process. Also noted was that the documentation for implementating training was difficult to identi fy. It was addressed in at least two of the above instructions:

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however, the-licensee was in the t'ocess of developing an overall implementing instruction which would reference che above listed instructions as appropriat I. Doerations 01 Conduct of. Operations 01.1 General Comments (71707)

The inspectors observed the conduct _of operations by currently licensed-operators in the control room and Auxiliary Unit Operators (AU0s) in the plant. The Unit Operators (U0s) were attentive to the evolutions in progress. Annunciators were promptly acknowledged by the U0s and reported to the other crew members. Communications followed the guidance and expectations set by Operations management. The Unit Supervisors (USs) limited personnel access for official business only, which contributed to a quiet, professional atmospher Operator Training and Qualification This special, announced inspection was conducted in the areas of initial R0 and SRO training and preparation for a recent Nuclear Regulatory Commission (NRC) licensing examination.' LOR training, and AUD trainin Activities included observation of work in progress, observation of training, reviews of procedures and records, and interviews of operators and trainees. Inspection Procedure (IP) 41500, which implemented NUREG-1220. Revision 1. ' defined the scope of the inspection and specified the methods and techniques utilized by the inspector .1 Initial Doerator License Trainina (41500) Insoection Scone-During the site visit the inspectors reviewed the licensee's initial license operator training and qualification program to determine

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compliance with 10 CFR 55. Specific areas of review included interviews of recent operator license candidates and evaluation and analysis of the audit examinations that were administered to determine if the candidates were prepared for the NRC licensing examinatio ,

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4 b. Observations and Findinas The inspectors interviewed two participants from the last initial ,

operator license class; one had failed the examination and the other had !

passe Each interviewee indicated that the NRC written examination was i challenging but fair. They stated that the questions tested information they had been exposed to during training: however. the improved I distractors made it difficult to answer the questions fast enough to l complete the examination in the four hours allocated. Both interviewees i stated their test scores would have been higher if another hour had been available to complete the test. The licensee's self-assessment of the !

candidate's poor performance on the NRC license examination came to a similar conclusion, i

The inspectors reviewed the written audit examination administered to ;

the candidates to validate readiness to take the NRC licensing tes l The inspectors noted that the test's level of difficulty was much less 1 than the NRC exam and the plausibility of many question distractors was ,

such that the correct answer could be quickly narrowed down to two or at most three, possible choices. This type of question was inherently simpler and faster to answer. Consequently, the candidates did not appear to be prepared for the quantity of more complex and discriminating questions on the NRC examinatio l The inspectors also reviewed the draft remedial training program l developed to prepare those candidates that failed their NRC license examination for a retake examination at the end of May 1998. The i inspectors noted that an extensive and complete training program was l laid out. Particular emphasis was placed on administrative topics. The licensee's root cause analysis of candidate poor performance on the NRC license examination identified that administrative topics were superficially covered during the training process. The licensee determined that a more structured approach to this topic was warrante The licensee also determined that several areas of administrative knowledge, the NRC expected to be covered, were not addressed during 1 training. Additionally, several other areas of administrative knowledge i the licensee expected to be covered during the course of training had ,

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been overlooked as wel The remedial training program would correct these self-identified weaknesses in the licensee's training progra The inspetors noted that the retake candidates would be administered l three complete.100 point. NRC-level-of-difficulty written examinations during the remedial training program as well as a comparable, final audit examinatio :

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4 Conclusions

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The ' inspectors did not identify any factors which could have contributed to the poor. performance on the NRC license examinations that had not already.been addressed in the licensee's own root cause analysis. The inspectors concluded that the licensee's initial operator license training program followed an SAT process and met the requirements of 10 CFR 55. However, the evaluation phase of the program (element 4) did not-effectively measure the candidate's level of understanding and mastery of licensed operator knowledges nor did it prepare candidates for the intensity and focus of the NRC license. examination. The inspectors determined that the licensee had self-identified these same issues during its root cause analysis and had initiated actions to correct these weaknesse .2 Licensed Goerator Recualification Trainino (41500) Insoection Scone During the site visit, the inspectors reviewed the licensee *s licensed operator requalification training program to determine compliance with 10 CFR 55. Specific areas of review included interviews of. licensed operators, observation of simulator training and evaluation scenario observation of routine control room activities and observation of the l annual control room abandonment drill for one crew of operator ! Observations and Findinas The inspectors observed the licensee administer simulator evaluations to

.two crews of licensed operators. The inspectors noted that the R0s and SR0s properly exercised 3-way communication techniques in most circumstances. The SR0s exhibited good command and control skill Additionally, crew briefings were regularly conducted by the SR0s when appropriate. These briefings were thorough and well managed. Operator ,

performance during the scenarios was also good. An Operations manager co-evaluated operator performance with the training departmen Following the evaluation, the inspectors observed.the crew debriefing and critique of their performance. Areas needing improvement were identified and discussed.- Additionally, operations management expectations of operator performance were frequently and consistently ,

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The inspectors observed Main Control Room MCR activities to verify that actual conduct of operations was consistent with the training provide The inspectors did not identify any operator actions or performance that was inconsistent with that observed in training or required by licensee administrative procedure The inspectors observed licensed operators and NL0s conduct their annual MAIN CONTROL ROOM abandonmer* training and in-plant drill. The inspectors noted that many areas for improvement were identified by the operators, several of which were previously identified but not adequately addressed. The inspectors determined that the noise level in the Auxiliary Control Room (ACR) was excessive and detracted from the operators ability to communicate among themselves and with the Auxiliary Unit Operators (AU0s) out in the plan The sound powered telephone system had constant background noise that made effective communication di f ficult. Radios could not be used due to possible actuation of nearby protective relays. Consequently, the commercial telephone system was used extensively. The ACR had one wall-mounted telephone assigned to each unit which was located behind the remote shutdown control panels in !

the corner of the room. However, the noise level in the ACR made it ]

near impossible to hear the telephone ring nor could the operators i easily determine which telephone to answer. Also, in order to answer the telephone, the operator had to stop monitoring the controls and ,

indications of his shutdown panel for a period of time. The inspectors I observed one example of improper 3-way communication technique in the ACR when an R0 failed to receive, and did not insist upon, a repeat-back of an order given to an AUO. This error was also identified by the drill's lead instructor and immediately corrected. See section 0 '

below for NLO comment c. Conclusions The inspectors concluded that the licensee's SAT process for LOR training was being satisfactorily implemented as required by 10 CFR 55.59. The inspectors also concluded that management attention was needed to ensure that deficiencies identified during the MAIN CONTROL ROOM abandonment drills are promptly and appropriately resolve .

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05.3 Non-Licensed Doerator'(NLO) Trainina (41500)

a. Insoection Scone During the site visit the inspectors reviewed the licensee's NLO training and qualification program to determine compliance with 10 CFR 50.120. : Specific areas of review included interviews, observation of'

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the' conduct of AU0 routine rounds. AU0 classroom training, AU0 feedback reports and the most recent AVO written examination. At Sequoyah, the term AUD was synonymous with NL b. Observations and Findinas The inspectors accompanied two AV0s while they performed their duties in the plant. The AU0s demonstrated proficiency during the performance of '

their routine work in accordance with plant administrative requirements and approved instruction The inspectors interviewed 14 AU0s on two different crews. Several AU0s stated that they would like more training ~in the use of drawings particularly in the electrical arena. The inspectors identified one example that supported this need during conduct of the MAIN CONTROL ROOM abandonment dril The AUO at the emergency boration valve gallery could not explain the fluid flowpaths without the aid of a drawin The inspectors noted that AU0 understanding of safety system purpose, design function and interrelationships with other plant systems and equipment appeared to be wea The inspectors reviewed the open book AU0 Exam (Exam 98CY1WK4.TST) dated February 5. 1998. Version 1. The inspectors determined that the AUD written examination was marginal as a tool for discriminating between a j competent and less than competent operato The fill-in-the-blank and I the mu'Itiple choice questions were all direct look-ups. Many of the blanks could be filled in without the use of the procedure. Many of the distractors on the multiple choice questions were not plausible and could be easily eliminated. The testing standards for the NL0s were at a level that would make any future licensed operator training and preparation very challengin The inspectors reviewed the AUO feedback reports from December 1996 to March 1997. All of the feedback comments that were reviewed were adequately addresse .

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The_ inspectors monitored two AU0 lectures (SSP-12.6. " Equipment Status Verification and Checking Program." Revision 9 and industry events).

The course objectives were met, the training environment was good, and class-tc-instructor interaction as well as class participation were encourage Conclusions The inspectors concluded that the licensee's AUO training and

. qualification program complied with the requirements of 10 CFR 50.120 for the areas inspected. The inspectors determined that AU0 personnel'

have qualifications commensurate with the performance requirements of their jobs. However, the inspectors also. observed that the AU0 written examinations were a marginal ~ tool for discriminating between a competent and less than competent operator. The inspectors concluded that testing standards for AU0s were very low. Therefore. AU0s subsequently selected for initial license operator training would be severely challenged just to adapt to the NRC level and style of examinatio II. Maintenance M5 Maintenance Staff Training and Qualification This special, announced inspection was also conducted in the area maintenance personnel training with specific emphasis on I&C technician knowledges. skills and abilities. Activities included observation of work in progress, observation of training, reviews of procedures and records, and interviews of technicians and supervisors. Inspection Procedure (IP) 41500, which implemented NUREG-1220. Rev.1. defined the scope of the inspection and specified the methods and techniques utilized by the inspector M Instrumentation and Controls (I&C) Maintenance Personnel Training Insoection Scoce (41500)

During the site visit, the inspectors conducted an assessment of I&C Maintenance training by observing activity in the field, conducting interviews with I&C technicians, and reviewing maintenance training'

implementing procedures and documentation, to gain confidence that there were no significant weaknesses in other, non-operator training program U

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b. Observations and Findinas The inspectors observed I&C technicians as they performed a portion of Procedure 2-PI-ICC-090-400. 0 " Calibration of Shield Building Ventilation Radiation Monitor 2-RM-90-400." Revision 3. Concurrent with the work, the qualified technician was observed conducting on-the-job training (0JT) for another technician, who was initially qualifying for Task IMR132. " Verify Operability of Shield Building Radiation Monitor."

The qualified technician performed the calibration in accordance with the procedure, and appeared to be well trained and experienced in working with the radiation monitor. He made every effort to ensure the trair > followed what the qualified technician was doing. such that the trainee would benefit to the greatest extent practical. When the I technicians found minor editorial discrepancies with the procedure, they stopped work and contacted their supervisor, and then the procedure was corrected in accordance with administrative requirements. The inspectors did not observe aiy training deficiencie The inspectors also observed I&C technicians as they performed the quarterly functional test of a steam generator water level circuit in i accoidance with Procedurc 2-SI-IFT-003-051.1 " Functional Test of Steam

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j Generator 2 Level Channel I Rack 1. Loop L-3-51 (L-529)." Revision !

Concurrent with this surveillance activity. 0JT on this task was being conducted for another technician. The foreman appropriately briefed the technicians before they departed for the work site. Under the direction and step-by-step concurrence of the qualified technician. the trainee performed the test satisfactorily. Both technicians performed their tasks in a professional manner and in accordance with the procedur .

The qualified technician demonstrated a strong knowledge of the l installed equipment and the Eagle 21 man-machine interface test equipment. The inspectors did not observe any training deficiencie The inspectors attended classroom training for maintenance personne The class was a pilot course on generic troubleshooting in the electrical, mechanical, and I&C disciplines. Technicians from each discipline were present for the training. ' e instructor discussed and

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explained the course objectives. Trainint :ility conditions were l conducive to the learning process and ther as good class involvemen It appeared that the course objectives were met. Plant management l representatives visited the class to observe the session and obtain feedback from the attendees and instructor ;

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The-inspectors interviewed seven I&C technicians to obtain craft perspectives and attitudes toward their training. Two of the technicians were selected from the night shift to identify any potential differences between the shifts. There were no significant differences in the shifts, and the. technicians exhibited a positive attitude toward training in general. Most of the technicians expressed a desire for more frequent continuing training, but in ss.iler portions. Subjects suggested by the technicians were refresher training on basics such as Ohm's Law, print reading, transmitter theory, and tasks for which the technicians were initially qualified in the past. but there was no recent hands-on experience. The inspector noted that most technicians responded that training had improved over the past 2 year The licensee stated that in addition to the SAT programs implemented, there were actions underway to address improvements in human performance and attitudes. As corrective action in response to recently declining electrical maintenance performance, the licensee implemented 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of performance improvement block training for all maintenance personne The licensee explained that this training included personal excellence lectures, sessions on human error avoidance techniques, a Myers-Briggs person 61 profile workshop, discussions on the licensee's work standards manual, and explanation and implementation of observation skills (i.a.,

peer checking techniques). The inspectors were informed by the licensee that approximately half of electrical maintenance and approximately 40 percent of mechanical maintenance had received this training. I&C technicians were scheduled to obtain this training las The licensee projected completion of this training by July 1998. In addition, the licensee was in the process of implementing a similar 3-day course for all personnel at all TVA nuclear sites. The licensee explained briefly that this initiative was designed to reinforce excellence in human performance by stressing self and peer checking, and pride in ownership of their respective facilities. These actions demonstrated the licensee's commitment to improving human performance through training and reinforcemen The inspectors reviewed training documentation for Task IMA110. " Perform Hydrogen Analyzer Functional Test," and Task IMF101, " Calibrate Rod Position Indicators." In both samples the licensee provided . lesson plans, written examination keys, and OJT qualification data sheets. The lesson plans appeared to be comprehensive and the examinations were sufficiently challenging to assure adequate technician training preceding 0JT. These tasks were analyzed prior to the implementation of the SAT process; however, the results of analyses performed existed in the Sequoyah Instrumentation Maintenance Task to Training Matri The

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. inspectors requested analysis documentation supporting examples of new tasks since the implementation of the SAT process. The licensee provided completed job survey forms and task analysis data sheets which reflected the completion of the appropriate task analyse Conclusions The inspectors concluded that the licensee's SAT process for I&C Maintenance training was being satisfactorily implemented as required by 10 CFR 50.120. This was based upon observations of work in progress in the field. technician and training management interviews, and a review of sample documentation of the progra V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on February 6.1998. The licensee acknowledged the findings presente I During the inspection, the inspectors asked the licensee whether any materials would be considered proprietary. No proprietary information was identifie PARTIAL LIST OF PERSONS CONTACTED -l Licensee

• Bajestani, M., Site Vice President i

• Burton C.. Engineering and Support Systems Manager .i

• Butterworth. H.. Operations Manager

• Driscoll . R. , Site Training Manager

• Freeman. .E. Maintenance and Modifications Manager

• Herron. J., Plant Manager j

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• Hunt. Operations Training Manager

• Kent. C.. Radcon/ Chemistry Manager ,

• Koehl. D... Assistant Plant Manager i

• Norton. R., Site Quality Manager

• Palmer. M., Radiation Protection Manager

• Salas. P. Licensing and Industry Affairs Managtr

• Summy. J.. Assistant Plant Manager

• Vincelli, J., Radiation Control Manager

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• Attended exit interview MC Shannon. M., Senior Resident Inspector l

• Starkey. D., Resident Inspector I l

INSPECTION PROCEDURES USED IP 41500: Training and Qualification Effectiveness IP 71707: Plant Operations l

ITEMS OPENED. CLOSED. AND DISCUSSED l

Ooened i None l

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None l Discussed None LIST OF ACRONYMS USED AUD Auxiliary Unit Operator CFR Code of Federal Regulations I&C Instrumentation and Controls IP Inspection Procedure LOR Licensed Operator Requalification NLO Non-licensed Operator NRC Nuclear Regulatory Commission OJT On-the-Job Training R0 Reactor Operator SAT Systems Approach to Training SR0 Senior Reactor Operator SSP Site Standard Practice TPI Training Process Instruction TVA Tennessee Valley Authority UO Unit Operator US Unit Supervisor