ML20199H145
| ML20199H145 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/06/1997 |
| From: | Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20199H107 | List: |
| References | |
| 50-327-97-300, 50-328-97-300, NUDOCS 9711260030 | |
| Download: ML20199H145 (14) | |
See also: IR 05000327/1997300
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U. S.' NUCLEAR REGULATORY COMMISSION-
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REGION--II-
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Docket-Nos.: 50 327, 50-328- !
- License Nos.: DPR-77. DPR-79-
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- Report Nos.: 50-327/97-300. 50-328/97-300- -;
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Licensee: --Tennessee Valley ~ Authority
Facility:
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Sequoyah Nuclear Plant Units 1: & 2 -
_ Location: Soddy-Daisy. TN
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Dates: September 19 - October 7,'1997'
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Examiners: P. Steiner. Chief License Examiner. *
P. Harmon. License Examiner
E. Lea. License Examiner-
-L. p ilen, Reactor inspector
~ Approved by: # // 97
l T. PeCleM11Ef20pqFator Licensing
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"('v and Human Performance Branch
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Division of Reactor Sa{ety
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EXECUTIVE SUMMARY
Sequoyah Nuclear Plant Units 1 & 2
NRC Examination Report Nos. 50-327/97 300, 50-328/97-300
During the period September 19 - 29, 1997. NRC examiners conducted an
announced operator licensing initial examination in accordance with the
Examiner Standards. NUREG-1021. Revision 7 and pilot guidance outlined in ROI
95-25. This examination implemented the operator licensing requirements of
10 CFR 555.41. 555.43. and 555.45.
Ooerations
. Three SRO-U. one SR0 Instant (SRD 1), and seven Reactor Operator (RO)
candidates received written examinations and operating tests. The
examinations were developed by the facility training staff and the
o)erating tests were administered by NRC operator licensing examiners.
T1e operating tests were administered September 22 - 29. 1997. The
written examination was administered by the facility licensee on
September 19, 1997. Only four candidates passed the examination. One
of the four passing candidates was a marginal performer on the simulator
scenario portion of the operating examination and one was a marginal
performer on the written examination.(Section 05.1)
. Landidate Pass / Fail
Pass 0 4 4 36%
Fail 4 3 l 7 64%
. The licensee identified 25 SR0 and 12 Rd generic kn.owledge weaknesses
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from post-examination review of the written examiria~tions.(Section 05.1)
. The examiners identified a generic candidate knowledge weakness in the
area of Rod Insertion Limits (RIL) and their relation to Shutdown Margin
during the post-mmination review of the operating tests. (Section
05.1)
. The examiners identified a generic canidate knowle@e weaknest in the
area of diesel generator operations during the post-examination review
of the operating tests. (Section 05.1)
. The examiners idem.ified a generic candidate weakness in the area of
actual pressurizer level versus indicated pressurizer level during the
post-examination review of the administrative section of the operating
tests. (Section 05.1)
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- The examiners concluded that the facility licensee's first effort at
developing the NRC operator licensing examination was a new and
difficult learning experience. However, the training staff was very
responsive to correct and improve the examination material as necessary.
(Section 05.2)
- The examiners were concerned with the licensee's written examination
grading techniques, The training staff used a Scantron machine to grade
the written examination and then made four errors when they transposed
the grading to the candidates answer sheet. There is no tolerance for
errors in grading the written examination. (Section 05.2)
- Examination security practices were reviewed and determined to be
acceptable. One minor incident occurred when a requal instructor, who
was not on the security agreement walked into the simulator room during
a scenario validation session, and then walked out uoon realizing his
errcr. Immediate compensatory action was taken by tbe training staff.
(Section 05.3)
- The inspectors were concerned with the licensee's audit process. An R0
candidate had failed an audit written examination and was allowed to
take a re-audit examination without receiving formal remediation. This
candidate scored c. 64.6% un the NRC written examination. The inspectors
reviewed the licensee's written audit examinations and found.the
discriminatory value to be lower than that of an NRC written ~
examination. This has been identified as an Inspector Follow-Up Item.
(Section 05.4)
- The inspectors were concerned with the operators' ability to control
Auxiliary Feedwater (AFW) flow to a Steam Generator (S/G) while in the
Emergency Operating Drocedures (EOP). T.his has.been identified as an
Inspector Follow-Up Item. (Section 05.5) .,
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Report Details
Summary of Plant Status
During the period of the examinations. Unit I was at 100 percent power and
Unit 2 was coasting down for a refueling outage.
I. Doerations
05 Operator Training and Qualifications
05.1 Initial Ooerator Licensina Examinations
a. Examination Scoce
NRC examiners conducted regular. announced operator licenring initial
examinations during the period September 19 - 29. 1997. The facility
licensee developed and NRC examiners administered examinations in
accordance with the Operator Licensing Examiner Standards. NUREG-1021.
Revision 7 and the pilot guidance found in ROI 95-25. This examination
implemented the operator licensing requirements of 10 CFR 555.41.
S55.43, and S55.45. Three SRO-U. one SRO-I. and seven R0 candidates
received written examinations and operating tests.
b. Observations and Findinas
Written Examination
The written examination was administered by the facility licensee on
September 19. 1997. The facility licensee had eleven post-examination
comments which were received October 7. 1997. and are included as
Enclosure 4 of this report. Enclosure 5 of this report presents the
NRC's resolution of those comments. After review of the eleven Jost-
examin6 tion comments, the NRC deleted three questions from the SRO
- examination and one common question from both the SRO and RO
examinations. The licensee's post-examination review of the written
examination identified 26 generic knowledge weaknesses on the SRO
examination and 12 on the R0 txamination. A generic weakrtss is any
question where less than 50% of the candidates passed. A review of
lesson plans and training notes should be conducted to identify any
weaknesses in these topic areas.
All SRO candidates failed the written examination with the SRO-1
candidate achieving the highest score of 78.1%. Four R0 candidates
passed the written examination, with one receiving a marginal score of
80.8%. The R0 candidate that received a score of 80.8% will have his
license withheld until it can be determined that his score will not
decrease below 80.0% following any regrading associated with the appeal
process. A review to determine any possible effect on the candidate's
score will be conducted after the closing date for formal appeals.
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Doeratina Test
The operating examination was administered during the period of
September 22 - 29, 1997. All SRO U candidates failed the operating
examination with one candidate failing both the administrative and
walkthrough portions. One R0 candidate was marginal on the walkthrough
Jortion, three R0s were marginal on the administrative portion, and one
RO was marginal during the simulator scenario portion.
The examiners were concerned with the SRO-U candidates' performance
during the walkthrough examination because of their lack of ability to
successfully complete R0 tasks which they are currently licensed for.
The training staff should ensure the o)erators complete a remediation
arogram in the areas of concern as hig111ghted in the individual's Form
ES-303-1. " Operator Licensing Examination Report." Also, the training
staff should review both the requalification and initial training
programs to ensure adequate coverage of these knowledge areas.
The examiner's post-examination review of the operating tests identified
the following generic knowledge weaknesses:
a) A generic weakness was demonstrated in the candidates' ability to
respond to a RIL Low Low annunciator. The candidates were given
instructions that control rods had been inserted due to an
inadvertent dilution on a previous shift. The rods were
indicating one step above the RIL Low alarm setpoint. ..The ~
candidates were then faced with a failed Nuclear Instrument (NI).
This drove rods inward beyond the RIL Low-Low alarm setpoint. The
candidates chose to take action to respond to the failed NJ, and
only responded to the annunciator for the RIL when prompted by the
examiners. The RIL Low-Low annunciator response procedure (ARP)
required that the operators immediately borate upon receipt of the
annunciator. This action is driven by the Shutdown Margin
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Technical Specification (TS) Limiting Condition for Operation
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(LCO) 3.1.1.1. This action statement requires inmediate boration
at 35 gpm until the required shutdown margin is restored. The
candidates did not demonstrate knowledge of this TS. The
candidates believed the condition was covered solely by the RIL
TS,'3.1.3.6. which requires that the control banks be restored to
within Core Operating Limits Report (COLR) position within two
hours. Both TS actions are in effect upon receiat of the RIL Low-
Low annunciator. The candidates believed that t1e loss of
shutdown margin could be corrected by withdrawal of the control
rods. Some of the candidates responded that they did not take
action per the ARP, because they were trained that Abnormal
Operating Procedures (A0P) take precedence over ARPs. In this
case, the candidates took actions required by the AOP for the
failed NI. The e) Miners were concerned with this training
deficiency. Operars are required to evaluate all annunciators
upon receipt, and take the required actions as necessary,
b) A generic weakness was demonstrated in the candidate's ability to
take prompt corrective actions in response to enrgent conditions
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that arose during diesel generator testing. In one case. SRO U
candidates were required to parallel and load a diesel generator
(DG). While loading the DG, the speed control circuitry sticks in
the raise condition. This continuously loads the DG. Prior to
loading the DG. the candidates read a CAUTION which states. " Care
must be taken to not exceea 4.84 MW (2-hour rating)." (he SRO O
candidate allowed the DG to run for ap3roximately two mii.Jtes
pegged high on KW until the DG output areaker tripaed on
overcurrent. He verbalized that he would inform t1e Shift Manager
of the condition.
In another case, the R0 candidates were required to parallel and
load a DG, After paralleling the DG the candidates were faced
with a low lebe oil pressure annunciator. The DG should
automaticaliy trip in this condition. The candidates chose to
pull out the annunciator response procedure and read the
appropriate steps, dela ing emergency stoppir.g of the DG. The
candidates had previous read the precaution statement which
stated. " Operating the 1esel engine with < 40 psi lube oil
pressure could damage the engine." The candidates did not take
prompt manual corrective action upon failure of an automatic
protective function,
c) A generic weakness was demonstrated in the candidate's ability to
transfer from indicated pressurizer level to actual pressurizer
level. The candidates were tasked with calculating the time to
drain from 70% hot calibrated 3ressurizer level to 30% actual
level given a 25 gpm mismatch ]etween charging and letdown while
in Mode 5. The candidates were cafamiliar with or did not
understand the instructions of 0-G0 7. " Unit Shutdown from Hot
Standby to Cold Shutdown". Rev. 8. Appendix D. " Pressurizer Level
Correction Curve for Hot Calibration Channel Read at Cold
Condition", and Appendix E. " Pressurizer Inventory Calculation",
and were unable to complete the t5sk. .,
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c. fanclusions
Poor performance by a high percentage of candidates on both the written
end operating examinations is indicative of a breakdnwn of the training
process, from initial candidate selection and formal training, to
subsequent e u uation in the audit program. The candidates seemed to
perform more poorly on NRC developed tasks that were modifications of
facility training mat 3 rial. Two of the generic weaknesses arose from
tasks that were modified from original licensee training material. When
the NRC modified the facility tasks to challenge the candidates ability
to handle faulted plant conditions. performance declined.
05.2 Pilot Examination Development
a. Inspection Scone
The NRC examiners worked with the Sequoyah training staff for three
months prior to administration of the examination. The examiners
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evaluated the time taken to generate the examinations, the quality of
the material and the agreement with the time line for submittal.
Examiners reviewed the facility's grading of the written examination and
conclusions on post examination review of generic knowledge weaknesses.
b. Observations and Findinas
Written Examinat100
The NRC examiners reviewed and validated the written examination over a
period of six weeks. After an initial' review. Operator Licensing
management made the decision to continue with the validation of the
submitted material br ed on the overall quality of the original
- questions. However, many changes to the examination were required prior ;
to receiving final HRC approval on September 17, 1997. .The training
staff was very responsive to the examiner's comments and were prompt in
making the necessary corrections. Some questions required several >
iterations before a satisfactory question was developed. The examiners ;
evaluated the R0 written examination as approximately 55% comprehension
level and 45% memory level, with the SR0 examination approximately 60%
comprehension. The following is a sunnary of the changes and
developmer.t required to meet the acceptance criter:on of an NRC initial
operator licensing written examination:
336 Questions were submitted to the NRC for review.
15 Questions were re written entirely. per NRC request. '
87 Questions were modified.
24 Questions out of the 87 were modified twice for a total of
111 comments.
67 Questions were changed to make the distractors more
plausible.
7 Questions were modified to raise the question from memory
leveltocomprehensionleve},
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Ofthe111 comments,approximately80%ofthechangeswerecontent
based, and 20% were administrative. The examiners found ;:.dt the ,
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question stems were of high quality, with the distractors requiring a
greater portion of the re-work.
The examiners reviewed the licensee's grading of the written
examination The examiners identified flaws in the submitted results.
The examination was electronically graded using a Scantron machine which -
produced the correct results. The missed questions were then marked on
the original copy of the-randidate's answer sheet. The grader made 4
errors while transposing ne question grading. The NRC is concerned
with the results of this 9rading process. The examiners manually
regraded the written examination twice to verify the results.
The examiners evaluated the licensee's post examination review of
generic written examination weaknesses. The review stated that there .
was a high miss rate on questions primarily due to candidate weakness,
and that the material was adequately covered in lectures.
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Doeratina Examination
The examiners reviewed and validated all portions of the operating test
on September 8 - 11, 1997, using the Sequoyah Nuclear Plant simulator
and walking down in plant JPris.
The licensee training staff sent a team to the Region 11 office in
Atlanta in July of 1997 to discuss examination content with the chief
examiner. This meeting was helpful in identifying weak areas in the
proposed operating test. The training staff incorporated the examiners'
feedback into the final examination product.
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c. Conclusions
The examiners concluded that the facility licensee's first effort at
developing NRC operator licensinq examinations was a new and difficult
learning experience. The examiners found that the exam writer
maintained a high standard of operator performance that was in agreement
with NRC expectations. The examiners noted that the training staff was
very responsive in correcting and improving the examination material.
The examiners were able to administer the operating and written tests as
scheduled. The licensee did an adequate job in the post-examination
review of generic weaknesses on the written examination. The grading
errors made on the written examination were unacceptable. and should be
double checked in the future to ensure accuracy.
05.3 Examination Security
a. Event Descriotion
The examiners and training staff were working in the simulator room when
a requalification instructor entered the premises and then exited,
b. Observations and Findinas ,,
The licmisee had adequately posted the simulator room wit.h signs warning
people to stay out due to the exam development in progress. In
addition, a blind was drawn over the doorway as an additional barrier.
The requalification instructor had to ignore the sign and lift up the
blind in order to enter the room. ,ie then realized his mistake and
walked out of the room. An exam team member then pursued the individual
and discussed the event. The individual was added to the security
agreement. The examiners are concerned with two areas. Sequoyah
personnel are becoming desensitized to signs and barriers warning of the
presence of exam material, and that the individual left the room after
compromising security. If the exam team member had not caught up with
the instructor, the simulator material would have become invalid and
subsequently discarded. As carrective action, the licensee sent an E-
mail letter to all training instructors describing the event.
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c. Conclusions
Examination security is the greatest challenge facing the pilot -
examination process. The examination materials are now on site a much l
greater period of time versus the old examination process. The licensee
must insure that procedures and practices are in place to prevent
violations of regulatory requirements involving examination security.
Maintaining the level of security awareness over time will present an on
going challenge.
05.4 Initial License Examination Audit Process
a. Insoection Scope l
The examiners reviewed the audit examinations given to the SR0 and R0
candidates. They also reviewed a second audit examination given to a
candidate that failed the first audit examination,
b. Observations and Findinas
The licensee audit examinations were not at the same cognitive level as
NRC written examinations, and in many cases the questions are invalid
due to the presence of imalausible distractors. Even in the cases where
the question stem was of ligh quality, there would typically be one or
two implausible distractors, making the question into a true/ false
question. The licensee's post examination review of the written test
indicated that a high number of questions were missed because.of
" Candidate weakness. Topic area was covered in training at sufficient
level of detail." If the material was sdequately covered in training,
then there are two issues of concern. The first is that the candidates
selected to be in the initial operator licensing training program lack
the ability to retain this knowledge. Second. that they were able to
identifying these
3 ass weekly
cnowledge quizzes and
weaknesses. audit examinations
Knowledge without 'not be identified
weaknesses should
, during the NRC examination. The level of knowledge required to pass the
! audit examinations was clearly below that required of the NRC
examinations.
The NRC is concerned with the practice of allowing a candidate to retake
an audit examination without documented formal remediation. A candidate
failed the initial audit written examination with a score of 77%. His
remediation, as documented in the training review board minutes of
August 25, 1997, was as follows:
ACTION:
Based on the above considerations. the TRB decided to allow
Hr. XXX to take the NRC exam under the following conditions:
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l . Mr. XXX agrees with the following conditions for
j continuing in the training program.
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. Mr. XXX will take another written examination in the
same format and level of difficulty as the original
exam and achieve a minimum grade of 85%.
. The second examination will be administered as soon as
it can be developed.
. No specific training will be provided to Mr. XXXX in
preparation for this exam.[ bold added for emphasis 1
The cantidate passed the audit examination with a score of 88% and
subsequently failed the NRC examination with the lowest score of 64.6%.
c. Conclusions
A 24 point disparity between the NRC examination and the audit
examination brings to question the discriminatory value of the audit
examination. Allowing a candidate to retake an examination without
formal remediation is a poor practice, which came to fruition when the
candidate failed the NRC examination by answering more than 1/3 of the
questions incorrectly. The NRC is concerned with both the licensees
audit and remediation programs and has ident1fied this as IF1-
327.328/97-300 01.
05.5 Control of Auxiliary Feedwater Flow
a. Ina cction Scoce
The examiners evaluated the candidates performance during a steam
generator tube rupture event and a large break Loss of Coolant Accident
(LOCA) event. The examiners also evaluated feedback forms generated
from comments operators made during requalification scenarios. The
candidates had difficulty reaching the step in the E0Ps which allowed
them to reduce Auxiliary feedwater (AFW) flow to a Steam Generator (S/G)
prior to the S/G reaching a water solid; condition.
b. Observations and Findinas ,
The Emergency Operating Procedure (EOP) E-0 " Reactor Trip or Safety
injection", does not allow operators to control AFW flow until step 14.
At Sequoyah, the Turbine Driven (TO) AFW flow control valves fail open.
causing S/G levels to rise uncontrollably until step 14 of E-0 is
reached and the o>erators can take control. During a S/G tube rupture
scenario the pro)lem is multiplied because the Reactor Coolant System
(RCS) is adding water through the tube break. In one case, the
candidates filled the S/G solid and were pumping water out the
atmos)heric dump valves (ADV). This is an undesirable situation. If
the A)V were to fail, the contents of the S/G and RCS would be released
to the environment via an unisolable path. During a LOCA scenario, the
candidates also had difficulty reaching step 14. Earlier in the
scenario, they had transitioned out of E-0 and were subsequently
required to transition to FR Z.1. "High Containment Pressure". due to
the high containment pressure created by the LOCA. During this event.
l the operating crew also filled the S/G solid. One of the complicating
l factors in the design of the E0Ps. is that they are based on ". e
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Westinghouse Owners Group (WOG) guidelines, which assume automatic level
control for the AFW valves. The WOG does not require the operators to
check AFW flow until step 16 because overfilling is not a concern with
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automatic level control. Additionally, the E0P users guide does not
provide guidance to allow operators to secure AFW to a ruptured or
faulted S/G. In the case of the faulted S/G. this could lead to
increased cooldown increased containment pressure, and an increased
personnel hazard if the break is outside of containment. Feedback forms
provided by operators during requalification scenarios also indicate
they are having difficulty controlling AFW flow and preventing overfill
of the S/Gs.
c. Conclusions
The inspectors are concerned that E-0 does not take into account the
complications created by the TD AFW flow control valves failing open.
The operators may need more procedural guidance on controlling AFW flow
based on this deviation. This item will be tracked as IF1-327,328/97-
300 2.
V. Manaaement Meetinas
X1, txit Meeting Summary
At the conclusion of the site visit, the examiners and 1,1spector met
with representatives of the plant staff listed below to discuss the
results of the examinations and other issues. The topics of poor
candidate performance on the written examination. Rod Insertion Limits,
and AFW flow control while in ELPs were discussed extensively. The
chief examiner informed the licensee senior management that a management
meeting will be considered to discuss their experiences with the pilot
process and the results of any root cause analysis done to explain the
poor candidate performance. .,-
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None of the material provided to the exapiners wafidentified by the
licensee as proprietary.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
B. Alsop. Operations OA Supervisor
M. Bajestani. Site Vice President
H. Butterworth. Operations Manager
R. Driscoll. Site Training Manager
M. Fect, Nuclear Assurance Manager
J. Herron Plant Manager
W. Hunt. Operations Training Manager
D. Koehl, Assistant Plant Manager
R. Proffitt. Nuclear Engineer -
J. Reynolds, Operations Superintendent
P. Salas. Licensing and Industrial Affairs Manager
J. Smith. Site Licensing Supervisor
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D. Seymour. Resident. Inspector
D. Starkey. Resident inspector
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ITEMS OPENED CLOSED, AND DISCUSM f;
OPENED
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327.328/97 300 01 IFI Poor quality of audit examination !
and remediation program (Section ;
05.4) i
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327.328/97-300 02 IFl AFW flow control to prevent overfill
while in E0Ps (Section 05.5)
CLOSED
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NONE
DISCUSSED
None
LIST OF ACRONYMS USED .
ADV Atmospheric Dump Valve
AOP- Abnormal 0)erating Procedure
AFW Auxiliary reedwater
ARP Annunciator Response Procedure
CFR Code of Federal Regulations .
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COLR Core Operating Limits Report ~'
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E0P Emergency Operating Procedure ' '
. DG Diesel Generator '
Ifl- Inspector Followup Item
KA Knowledge and Ability
LOCA Loss of Coolant Accident
NI Nuclear Instrument
NRC Nuclear Regulatory Commission
NRR Office of Nuclear Reactor Regulation
R0 Reactor Operator
RIL Rod Insertion Limits
SD System Description
S/G Steam Generator
SI Safety injection
SRO- Senior Reactor Operator
SRO U Senior Reactor Operator Upgrade-
- SRO-1-Senior Reactor Operator Instant
TS Technical Specification
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SIMULATION FACILITY REPORT
facility Licensee: Tennessee Valley Authority - Sequoyah Nuclear Plant ;
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Facility Docket Nos.: 50 327 and 50 ..S
Operating Tests Administered on: September 22 29, 1997
This form is to be used only to report observations. These observations do
not constitute audit or inspection findings and are not, without further
verification and review, indicative of noncompliance with 10 SCFR 55.45(b).
These observations do not affect NRC certification or a) proval of the
simulation facility other than to provide information tlat may be used in .
future evaluations. No licensee action is required in response to these
observations, f
While conducting the simulator portion of the operating tests. the following
items were observed (if none, so state):
11[d DESCRIPTION
No discrepancies that had not been previously identified were noted.
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Enclosure 2
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WRITTEN EXAMINATION (S) AND ANSWER KEY (S) (SR0/RO)
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Enclosure 3
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