ML20059J150
| ML20059J150 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/18/1994 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9401310375 | |
| Download: ML20059J150 (5) | |
Text
,,
8:
,E /
,I
>l l
HA 1
. f ens + e VWy Aimoc!y. Mt 0% Ela PTO Sodby Dn.y he,e c 3D79 2 rid
'i Robert A Fenoch va oewhet. soame tkicvs Mant
-3 4-January 18,.1994 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 I
Gentlemen:
In the Matter of
)
Docket Nos. 50-327 Tennessee Valley Authority
)
50-328' SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327, y
328/93 REPLY TO NOTICE OF VIOLATIONS (NOVs) 50-327, 328/93-37-01 AND.
11 93-37-02 Enclosure.1-contains TVA's reply to Thomas A. Peebles' letter to l
Mark 04 Medford dated December 17, 1993, which transmitted the~ subject; 2{
NOVs. NRC cited TVA with two violations. associated with' inadequate' training documentation. The first' violation is associated with-li inadequate procedures for conduct,ing and documenting annual operating '
tests. The second violation is for not properly documenting. that.
i operating tests and on-the-job training.were conducted in'accordance with
}
regulations.
4 TVA is performing an evaluation of the weaknesses demonstrated by operators during simulator-examinations. The evaluation will provide'the basis for developing training and management. actions to. improve and monitor operator performance in those areas. A training letter
?
addressing each area of weakness will be issued to the operatorr to cnsure that every operator is aware of the identified weaknesses. A-list-I of' commitments is contained in Enclosure 2.
q l
i j
r, pf-250026
\\ l 9401310375L940118~
e
- P D R -
- ADOCK 05000327 ~
0 POR ' -'
~
J!
L
..J.
~
.a
c-
- 1. -
L LU.S. Nuclear Regulatory Commission Page 2 January 18, 1994 sj If you have any questions concerning this submittal, please telephone J. W. Proffitt at (615) 843-6651.
Sincerely, M d. /M Robert'A. Fenech i
Enclosures cc (Enclosures):
[
Mr. D. E. LaBarge, Project Manager l
U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike
[
Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant q
2600 Igou Ferry Road Soddy-Daisy, Tennessee _ 37379-3624 Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-27:i '
l
~
l
'i
')
l l
q ENCLOSURE 1 REPLY TO NRC INSPECTION REPORT NOS. 50-327, 328/93-37 TIIOMAS A. PEEBLES' LETTER TO MARK 0. MEDFORD DATED DECEMBER 17, 1993 V.io l a tion a _jiQ-32 L_328/S3:31-QLand_.10-32L_.328/S3:31-02 "a.
10 CFR 50.54(1-1) states 'the licensee shall have in effect an operator requalification program which must, as a minimum, meet the requirements of 10 CFR 55.59(c) of this chapter'.
"10 CFR 55.59(c)(4) states 'The requalification program must include-(i) Comprehensive requalification written examinations and annual operating tests which determine areas in which retraining is needed...'.
"10 CFR 50, Appendix B, Criterion V, states ' Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished'.
" Contrary to the above, procedures delineating the process for administering the comprehensive requalification examinations did not contain appropriate guidance for conducting or documenting annual operating tests.
"b.
10 CFR 50.54(1-1) states 'the licensee shall have in effect an operator requalification program which must, as a minimum, meet the requirements of 10 CFR 55.59(c) of this chapter'.
"10 CFR 55.59(c)(3) states 'The requalification program must include on-the-job training so that (1) Each licensed operator manipulates the plant controls and each senior licensed operator either manipulates or directs the activities of individuals during plant control manipulations during the tenn of the licensed operator's or senior operator's license'.
"10 CFR 55.59(c)(5)(1) states 'The facility shall maintain records documenting the participation of each licensed operator and senior operator in the requalification program' and that the records must contain 'the results of evaluations and documentation of operating tests...'.
p+
]
c
.w
- t
+
" Contrary to the above, records maintained to document licensed operator. completion of operating tests and pertormance-cf i
on-the-job training did not contain auf ficient information to furnish evidence that the activities were conducted in accordance with regulations.
"These violations have been evaluated in the aggregate as a Severity Level IV problem (Supplement VII.D)."
Reason _for liolations The reason for Violation A was that only general guidance was provided for conducting and documenting annual operating tests in the training procedures. IVA did not refine the procedures to reflect the process as it evolved but relied on NUREG 1021 for guidance. NUREG 1021 does not address each requirement in 10 CFR 55.
The reason for Violation B was an oversight and misinterpretation of the regulations. The governing procedure required individuals to perform or participate in combinations of reactivity control manipulations.
However, TVA documentation matrixed crew participation in reactivity control manipulations.
Individual annual operating test performance was documented by exception; the details for unsatisfactory and marginal performers were documented.
Correttive_Actional hat Have Been laken and thn_Results Achieved A review of the training procedures was performed against the requirements of 10 CFR 55.
The review concluded that violation A resulted from the training procedures lacking the detailed guidance for
?
complete and consistent training implementation to meet the requirements of 10 CFR 55.
q As a result of violation B, individual simulator evaluations were
'l completed and documented for the 1993 annual operating examinations.
-1 l
EorJhe_Corre c t iveltepalhat._WilLhelaken_t oJYoitLEnturellnla tion s Training procedures will be revised or developed to provide the requisite detailed guidance for administering and documenting annual operating tests. The revision will include requirements for records of examinations and answer keys, individual simulator evaluations, simulator scenarios and job performance measures utilized, and individual reactivity control manipulations. To ensure our interpretations of the requirements are correct, IVA will compare the requirements of our procedurce with procedures of recognized good performance plants in Region II.
Training procedures will also be revised to require manipulations, stipulated by 10 CFR 55.59, performed by each individual licensed operator to be individually documented and retained.
Date_When_EulLCompliance_Will he Achiered b
TVA will be in full compliance by April 8, 1994.
- s[
~*
~ i f
^
4 i
' ENCLOSURE 2-COMMIIMENTS
'.NSPECTION REPORT 93-37 1.
Procedures will be revised or developed to provide the requisite.
guidance for administering annual operating tests. This action will be complete by April 8, 1994.
Training procedures will be revised to require that evaluations'be1 2.
performed and documented on an individual basis. This action will be complete'by April 8, 1994.
3.
IVA will compare the requirements of our procedures with procedures of recognized good performance plants in Region II.
This action will be complete by April 8, 1994.
4.
Training procedures will be revised to require manipulations, l
stipulated by 10 CFR 55.59, performed by each individual licensed operator to be documented and retained. This action will be complete by April 8, 1994..
- 5. - A training letter addressing each area of weakness will be insued to the operators by January 28, 1994, to ensure that every operator is aware of the identified weaknesses.
)
I n
9 0
h
. g.
L!
r