ML20204J721
| ML20204J721 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 03/16/1987 |
| From: | Russell Gibbs, Murphy M, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082280289 | List: |
| References | |
| 1338T, 307.08-SQN, 307.08-SQN-R03, 307.08-SQN-R3, NUDOCS 8703270296 | |
| Download: ML20204J721 (9) | |
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TVA EltPlhYEE CONCERNS REPORT NUMBER: 307.08-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER:
3 TITLE: Training Programs for Employees REASON FOR REVISION:
Incorporate SRP Coments Revision 1 Incorporate NRC Coments and findings from WBN evaluation.
Revision 2 Incorporate TAS and SRP connents Revision 3 i
s PREPARATION PREPARED BY:
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M. W. Murphy SIGNATURE
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SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASE GROUP L
OPERATIONS CEG 1
Subcategory: Nuclear Power Site Programs / Procedures Element: Training Programs for Employees i
Report Number:
307,08-SQN Revision 3 l
XX-85-122-036 XX-85-058-001 1
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Evaluator:
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4 R:visica 3 I.
Event Reporting This report evaluates two concerns, one regarding the required reporting of events at Sequoyah Nuclear Plant (SQN) and the other regarding the size of General Employee Training classes at SQN.
II.
Specific Evaluation Methodology Concern XX-85-122-036 states:
" Improper reporting of events at operating plants or in
, design / construction. TVA personnel are not adequately trained and are not knowledgeable in what is reportable."
To evaluate this concern, regulatory requirements for reporting of operating events were reviewed. TVA procedures governing those reportability requirements were reviewed and the training of individuals responsible for reporting events were reviewed.
A review of the report history since 1984 was conducted to determine if significant events were correctly reported and a document search for NRC or NSRS problems with reports was conducted.
The second concern XX-85-058-001 states:
" Employees at Sequoyah are run through indoctrination training classes "like cattle." Insufficient time is spent in training classes (specifically Health Physics) prior to being given tests.
Instructors who are familiar with the subject matter, " breeze through" the lessons.
This concern was previously evaluated by the Nuclear Training Branch and a report was issued which contained their findings (Reference 12).
t A review of the above referenced Nuclear Training Branch report was conducted to determine whether the evaluation conclusively established the validity of the concern. In addition, an interview with a cognizant training representative was conducted to verify that the report information was current.
III. Findings A.
XX-85-122-036 Reporting of potentially significant events at operating nuclear power plants is defined in 10 CFR 50.72 and 10 CFR 50.73 and 10 CFR 21.
These regulations require the utility to notify the NRC of certain events within specified timeframes depending on the severity of the event.
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s III. Findings' (cchtinued)
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g The format and content of follow-u0 written reportq is defined in NUREG 1022. These Licensee Event' Reports-(LER) must be filed within 30 days of the occurrence of an event.an,1.rsat adequately describe theevent.thecauseofthetwentandcorrectheactions-takento prevent recurrence of the event.
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2' Sequoyah Standard Practice SQA,84 contains TVA's "s@ctem for identifying potentially reportable occurrences. 'The occurrence may be reported by anyone. itaen forwarded to' the Shif t Technical Advisor (STA) and the Shift Engineer (SE) for evaluation of
,immediate reportability under 10 CFR 50.72 or 50.73.
The guidance for that evaluation is contained in Sequoyah Ad!dalstrstive
/
Instruction AI-18, file pachse 18.
The Potential Reportable Occurrence (PRO) form is then forwarded to the Plant Cperating Review Staff (PORS) for further evaluation and preparatien of an LER.
If necessary. A comparison of'the guidellpas in AI-18 to the requirements of 10 CFR 40.72,,50.73 and 10 CPR 21 rerealed no deficiencies. (*pon completiott of'LER propiratien. the'Lita is transmitted diteetly to the NiiC from SQN.
A review of trainiri < records or STA's, SE's and PORS\\perionnel" t
verified that training,was conducted,for all STA's and licensed '
operators during December 1985. This\\was the tium thetithe revislon to 10 CFR 50.72 and 50.73 was to be,impAenented.4 In this same timefrase four perponel assigned to what is now the PORS group attended a semina'r g!ve.1 by NRC in Atlanta regarding the changes to 10 CFR 50.72 and 50.73'as well as NUREG 1022.
STA training course content contalha a comprehensive lesson plan on reportability requirements which indudes practical exercises on determining rsportability for var 14Ls scenarios. This is again reviewed towards the end of the course.
Classes on reportability requirements have been conducted during licensed operator requalification and simulator scenarios include reportability requirements as objectives.
Further, the PORS Supervisor indicated in(ormal (no documentation maintalued) classes have been held 41th newly assigned personnel on the repertability requirements.f,This informal training includes review of 10 CFR, AI418, NUREG 102R. E Additionally, the job descriptica for PORS personnel incluks STA training as a qualificacion consideration, but da.e's) not preclude hiring individuals without STA training.
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A computer search through Document Acitrol for NRC or NSRS generated communications c)garding LERs or Reportab y Occurrences (R0s) since 1983 revealed othy one instance of questIvnalle accuracy of an LER.
This LER was submitted as a result of th 'udit 1 1ncore 3
instrumentaticn thlmble tube ejection accidait 1rhich occurred on 3
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III. Findings (continued)
Apell 19, 1984. NSRS, while not disputing the accuracy of the LER, did not feel the LER was complete, and by omaission, was misleading. The NSRS recommendation to submit a revised report containing the additional information was followed and the revised LER was determined to be adequate by NRC.
A review of 762 PR0s issued since January of 1985 indicated a wide diversity of potential events reported. This review determineu that there were no areas of required reporting under 10 CFR 50.72 or 10 CFR 50.73 that were consistently not reported. A review of the PORS database did not reveal-any instances where a situation required reporting and an LER was not issued. It should be noted, however, that the majority of PR0s initiated do not require NRC reporting.
It is possible that the initiator could disagree with the final disposition of the PRO, but no instances were found to indicate incorrect determinations. A random sample of 30 PR0s were reviewed which revealed no instances of improper determination of reportability requirements. A random sample of 14 LERs issued were reviewed for adequacy and content with no deficiencies found.
Subsequent to the initial evaluation at SQN, during the course of the WBN evaluation, it was found that the NRC had issued Order Nodifying License (EA-85-49) to SQN and BFN. This order required "TVA to review and correct programmatic deficiencies in the og 5
reporting system.
The event which led up to this order involved the environmental qualifications of certain containment pressure transmitters at WBN.
This event took nearly two months before SQN personnel were notified of the potential operational significance of the engineering evaluation.
In response to the NRC order. TVA convaitted to totally rewrita the correctiv action reporting system then in use.
The schedule for implementation of the new program is March 30, 1987.
The revised conditions adverse to quality (CAQ) reporting program was designed to provide consistency and consolidation between many CAQ reporting methods previously used. The revised program requires I
all divisions to use one CAQ reporting document to replace any others previously used. The requirements of the revised program were written into the NQAM, Part I, Section 2.16 and are to be incorporated into site implementing procedures, i
Training on the revised program was developed in two parts, for j
potential initiators, and for potential CAQ processors. Training was begun in January of 1987, and is to be completed by March 30, 1987. At the date of this evaluation (February, 1987) over 5,000 individuals had received this training and the training was proceeding on schedule.
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III. Firdings (continued)
'A review of the training lesson plans revealed that they adequately addressed the requirements of the NQAM. Part I. Section 2.16 with the appropriate level of detail. Personnel attending the processor i
part of the-training are' tested for comprehension upon conclusion of the training.
a B.
XX-85-058-001 i
The Wuclear Training Branch evaluation report for concern XX-85-058-001 did not substantiate the concern. The following
. excerpt from the report documents the reasoning behind this
't conclusion.
General Imployee Training (GET) classes are attended by employees with various educational backgrounds and occupations. The time allotted to a specific class is based on experience with typical j
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classes containing a cross section of employees. An instructor may j
not know if a particular person is having Girticulty unless that individual informs the instructor.
It. should be noted that j
instructors are certified by TVA through special training courses.
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i The appcored instructor lesson plans specify what material is to be
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covered and also specify the timeframe allotted. At SQN. when an instructor is aware that a particular employee needs individual 4
att.en' tion, special errangements may be made to tutor the ladividual. This has occurred on at leastzone occasion.
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With regard to class size the following actions are being or have been taken:
1 1.
Additional classes are scheduled for peak periods, such as outages.
i 2.
As in the week of September 9.1985, special classes were held on back shifts.
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's 3.
An evaluation of position' requirements is being conducted to determine if some employees are being required to attend
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. unnecessarily. This could contribute to reduced class size.
1 4.
GET-2.4. Level 0 Health Physics was recently implemented for those employees not requiring access to the Power Block. This tiso contributes to reduced class size in HP GET.
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Additionally.,it should be noted that all/ instructors are evaluated by the Instructor Certification and Staff Development,(IC&SD) Unit.
3 annually. AlsoJ the Plant Training Supervisor sits on two classes per week for'the purpose of instructor evaluation. These j
evaluations are documented in his weekly activity report to the Power. Operations Training Center (POTC).
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R:visica 3 III. Findings (continued)
It should also be noted that each individual attending a GET class is handed a course evaluation form by which they may provide feedback to the training section regarding both the program and the lastructor. A review of recent evaluation forms did not reveal any comments similar to the concern.
Conclusions Concern II-85-122-036 was determined to be valid. Corrective action l
reporting program deficiencies were identified by the NRC and program l
improvement initiated by TVA. CATD-30708-NPS-01 was issued during the IR2 WBN evaluation to track closure of the revised program.
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Concern II-85-058-005 was not substantiated. While GET class sizes may be large at times, no evidence that the quality of instruction is impacted was found. In addition, efforts have been effected to reduce the class sizes to a manageable level.
IV.
Root Cause The root cause of concern II-85-122-036 is perceived to be the result of I
a fragmented system for reporting and reviewing conditions adverse to l
quality.
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V.
Generic Applicability l
lR3 Concerns WI-85-100-035 for WBN, 11-85-122-036 for SQN, II-85-122-037 for BLN and II-85-122-038 for BFN are identical in wording and the issue of reporting of events was evaluated at each TVA site.
Concern 11-85-058-001 was not valid at SQN and is not considered applicable to other sites.
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Aqvision 3
- e VI.
References 1.
10 CFR 50.72; 1985 2.
10 CFR 50.73; 1985 3.
NURRG 1022; 1984; Licensee Rvent Reports 4.
SQA 84, Revision 4; Reportable Occurrences 5.
AI-18, Revision 43; Plant Reporting Requirements 6.
PRO database (PORS maintained) 7.
Licensee Rvent Reports a.
1-84030 b.
1-84030, Revision 1
,c.
1-85001 d.
1-85019 e.
1-85026 f.
1-85029 g.
1-85040 h.
1-86004 1.
1-86008
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2-85005
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2-85009 m.
2-85012 n.
2-86003 i
8.
NSRS report I-84-12-SQN 4
9.
STA lesson plans SYS 003.55. Revision 0, Technical Specifications and Reportability a.
Requirements b.
SNT 202C341 Revision 0, Review of Technical Specifications and Reportability Requirements 10.
Nuclear Training Program Nanual Procedure 0202.04, Revision 0; General Reployee Training 11.
Nuclear Training branch Standard Practice ICT-16; Certification of All Instructors;. September.20, 1985 12.
Memorandum from N. L. Abercrombie to W. H. Thompson dated September 19, 1985, regarding 11-85-058-001 (S00 850917800).
13.
Order Nodifying License (RA-85-49) RIMS A02 850619 004 lR3 14.
NQAM Part I Section 2.16. " Corrective Actions" Revision 2 lR3 VII. Immediate and Long-tern Corrective Actions l
lR3 CATD 30708-NPS-01 was issued as a result of the WBN evaluation to track l
closure of the revised CAQ reporting program.
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GENERIC KEYNORD H
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CSNCERN KEYI NUMBER CAT CAT D LOC FLQB REPORT R
S!!SCRIPTION K1 XX 058-001 OP 30708 N SON NNYN XX-85-058-801 NS B FLOYtES AT SE400YAN ARE RUN TNROUD TRAIN!W I
T50108 K-FORM N INDOCTRIIIATISII TRAINING CLASSES "L NEALTl IltE CATTLE *,
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PERSSIIIIEL ARE NOT GENI AIIEGWATELY TRAI AND ARE net RNOWL Of ElletABLE III 18147 $ REPORTABLE. CI H A3 NS FURTIIER I N TION. ANOIIYMOU 3 CONCERN VIA LETTER.
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