ML20214R423
| ML20214R423 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 09/19/1986 |
| From: | Lagergren W, Scott R, Danni Smith TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082421095 | List: |
| References | |
| 1580T, 310.02-SQN, 310.02-SQN-R01, 310.02-SQN-R1, NUDOCS 8609290171 | |
| Download: ML20214R423 (11) | |
Text
i TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG i
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Subcategory: Operationd/ Operational (310) l Element: Operator Qualifications Report Number:
310.02 SQN Revision 1 IN-85-289-001 IN-85-767-006 IN-85-894-001 IN-86-209-013 XX-85-048-002 XX-85-093-001 XX-85-093-002 XX-85-093-003 WI-85-060-001
/
Evaluator:
(('M 9'/['8d firD.E.S[t' Date Reviewed by:
M S-/A8g r
OPS Cf6/ Member Date Approved by: S. _ f M
/f[N
[ ' W. R. I!agergren
' Date 1580T B609290171 86 j27 PDp ADOCK PDR P
._,_ )
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I.
Operator Qualifications This element report addresses the qualifications of operations l
personnel. The aspects range from generally inadequate operator lR1 qualifications to specific issues entailing the Shift Engineers I
and Assistant Shift Engineers being inadequately trained for electrical station operation, and plant operators not adequately trained in QA requirements or firefighting.
1 II.
Specific Evaluation Methodology
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The following concerns were reviewed and incorporated into this element report:
IX-85-048-002 At Sequoyah, the major responsibility for firefighting has been turned over from Public Safety Service to the Fire Brigade. Since most Public Safety Officers have been trained in the State Fire Training School and the Fire Brigade have not, C/I feels that the Fire Brigade's lack of expertise will pose a fire protection problem at Sequoyah. C/I stated that at Brown's Ferry NP, Public Safety was chosen to provide fire protection services and questions why Sequoyah did not.
XX-85-093-001 Sequoyah's Shift Engineers (SE) and assistant Shift Engineers (ASE) are inadequately trained in electrical station operation (switchyard, off-site power feed, etc.)
such that there could be an excessive delay in restoring off site power feed to the plant in the event of an emergency. CI feels that SE/ASE personnel should i
receive better training in this area.
1 XX-85-093-002 Bellefonte: (same concern as XX-85-093-001)
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XX-85-093-003 Browns Ferry: (same concern as IX-85-093-001)
WI-85-060-001 Watts Bar: (same concern as XX-85-093-001)
I IN-85-289-001 (Watts Bar) operators have already made errors during lR1 i
hot functional testing in unit 1, approximately one year ago (1984) which would have been significant if plant had been operating.
CI expressed concern regarding the inadequate qualifications & training of i
operators.
J IN-85-767-006 CI; expressed that plant operators are not adequately trained to nor abide by the QA requirements of plant procedures.
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IN-85-894-001 Plant operators are inadequately trained for their positions. The CI listed several incidences as i
examples.
1.
An oil ring blev-up while replacing
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filters in mechanical maintenance, due to head pressure.
2.
Women operators do not have enough l
strength to open and close isolation valves. CI had to help many times.
3.
While hot functional testing about a year ago, Hydrazine spilled all over people and the floor in South Valve Room, Unit 1 Auxiliary.
Building, Elevation 737'-0" due to operator error.
IN-86-209-013 Since the plant operator training was conducted at the same training center, under the same management as the
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STA (Shift Technical Advisor) program; the quality of the operator training that started approximately 10 years ago may have been as inadequate as the STA l
training.
Concerns IN-85-289-001, IN-85-894-001 WI-85-060-001, IN-86-209-013, and l
XX-85-093-002 were previously evaluated by the Sequoyah Generic Concern Task Force (GCTF) and their results documented in a report dated April 22, 1986.
I The concern regarding errors made during hot functional testing in lR1 i
concern IN-85-289-001 is specific to Watts Bar and not evaluated for l
Sequoyah. The overall operator qualifications and training were evaluated.
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Concern XX-85-093-001 was previously evaluated by NSRS and their results j
documented in NSRS report I-85-619-SQN.
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These reports were rceviewed to determine if they adequately addressed and resolved the following items:
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1.
Is the training received by the operators on hold orders and j
clearances adequate to prevent unanticipated transients and ensure j
personnel safety?
2.
Is the training received by SEs and ASEs on electrical station operation adequata to ensure correct, responsive action in case of loss of offsite powerf 1
i 3.
Can women operators adequately dispense their duties? If not, what j
potential impact could this have on safe plant operationf i
4.
Does TVA (Sequoyah) adequately train their licensed, and non-licensed operators, to perform their expected duties?
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l Since concern XX-85-093-003 is id:nticci to c:necens XX-85-060-001, XX-85-093-002 and WI-85-060-001, the findings of the above two reports are consideted to have equal applicability to XX-85-093-003.
Concern IN-8 -767-006 was previously evaluated by the GCTF and their findings dou mented in a report dated May 17, 1986.
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This report was reviewed to determine if it conclusively established that operators receive adequate training on QA requirements and abide by the QA requirements of plant procedures.
Concern XX-85-048-002 has not been previously investigated. The scope of this evaluation was to determine if the Fire Brigade at Sequoyah is adequately trained in fire fighting techniques and if there is a fire problem because of the Fire Brigade's lack of experience.
Applicable procedures for SQN were reviewed for all areas identified by the above concerns and interviews with cognizant personnel were conducted.
III.
Findings i
I Evaluation Results i
Findings of this evaluation are listed below, by concern number.
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XX-85-048-002 A memorandum from P. R. Wallace to H. L. Abercrombie was found during the evaluation of this concern. This memorandum documents that:
The Fire Brigade at SQN has existed since 1979 with responsibility for fire protection activities for the operating nuclear plant. The training provided and required (Procedure No. 0202.05 and OSLT-1) for the Fire Brigade is in most aspects more extensive and comprehensive than the State Fire Training School. Operations Section personnel compose the entire Fire Brigade at SQN; therefore, they are familiar with the plant, its hazards, and the location and function of the various plant operating and fire protection systems.
XX-85-093-001, XX-85-093-002, XK-085-093-003, and WI 85-060-001 NSRS Report I-85-619-SQN evaluated concern XX-85-093-001 previously.
The results of the NSRS evaluation are listed below.
1.
10 CFR 55 establishes the procedures and criteria for issuance of reactor operating licenses to operators of nuclear facilities, lR1 including senior reactor operators (shift engineers and assistant shift engineers). In order to obtain a license as a reactor operator or senior reactor operator, the candidate must demonstrate an understanding of the design and operation of the Page 3 of 10 1
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Sequoyah facility including cuzilicry systcas (switchyced and offsito power supplies) which affect it.
2.
ANSI /ANS standard 3.1 - 1981 has been adopted by the NRC and identifies training requirements for reactor operators and senior d
reactor operators to be licensed by the NRC. Section 5.2 of this standard requires plant specific system instruction on power plant systems including electrical systems.
In addition, it also specifies l
the content of required nuclear power plant fundamentals training i
which includes fundamentals of electrical theory.
3.
NUREG-1021 provides guidance to NRC examiners in determining the qualifications of an applicant for reactor operator and lR1 senior reactor operator licenses.
Section ES-402, category 6, specifies that the candidate be able to reproduce, from memory, sketches and
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descriptions of various plant systems including electrical distribution systems on nuclear power plant operation and reactor safety. NUREG-1021, section ES-502, specifies control manipulations and plant evolutions for which an applicant for an j
SRO license must demonstrate proficiency. Control manipulations j
not performed at the plant may be performed on a simulator. One j
of the specified plant evolutions is a response to loss of electrical power and/or degraded power sources. A candidate's performance i
can be evaluated using the Sequoyah plant simulator.
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4.
A comprehensive operator training program has been developed and I
implemented to ensure that Sequoyah reactor operators and senior j
reactor operators meet the qualifications and training requirements 4
established or endorsed by the NRC. This training program is l
described in Nuclear Power Area Plan Procedure 0202.05 entitled j
" Nuclear Plant Operator Training Program."
5.
Training of Sequoyah operators in electrical operation of plant and i
switchyard systems is ccnducted from the initial auxiliary unit i
operator training through the assistant shift engineer training. This l
training is comprehensive and covers details of electrical theory and the actual operation of switchyard equipment. The operators are required to pass tests to demonstrate their knowledge. The operation of electr! cal switchgear is a normal and routine part of the unit operator job. The electrical training program for nuclear plant j
operators is presented in four steps in Nuclear Power Area Plan i
Procedure 0202.05, i
j a.
Step 1 is a 13-week program on basic electrical theory and t
equipment. It is presented during the Nuclear Plant Operator l
Training Program (NOTP) during the student level II phase (before i
training for reactor operator or senior reactor operator). All, l
ASEs and SEs must have successfully completed this training or its j
equivalent.
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b.
Step 2A is a 2-week, Inplant electrical training program on plant electrical systems (onsite and offsite) presented during the student level III phase. All ASEs and SEs must have successfully completed this training or its equivalent.
c.
Step 2B is defined as unit operator upgrade electrical training and is a 4-week program of inplant training on plant electrical systems and station service. All ASEs and SEs must have successfully completed this training or its equivalent.
d.
Step 3 is a 6-week ASE upgrade electrical training program required before taking the accrediting examination for ASE. All ASEs and SEs must have successfully completed this training or its equivalent. This training addresses both offsite and onsite electrical systems.
6.
The Sequoyah Nuclear Plant Operator Training Program, which includes the electrical training, was one of the first in the nation to receive accreditation from INPO. This accreditation required a complete review of the training program and approval by an independent INPO Accreditation Poard.
INPO continues to review accredited programs on a regular basis to ensure the training meets their standards.
Accreditation was received in January 1984.
7.
The " emergency" referred to in the concern is related to power system emergencies. No documented evidence was found in this investigation to substantiate the complaint of Plant Systems Operations personnel that Sequoyah switchyard operations were not carried out on a timely basis. Sequoyah shift engineers that were interviewed stated, however, that switchyard operations did not take first priority if the nuclear units were in an abnormal status.
8.
IVA's Nuclear Safety Review Staff (NSRS) has conducted an investigation for a Sequoyah specific employee concern (XX-85-093-001) which addresses training and qualification of SEs and ASEs on switchyard operation. This investigation (Reporc t/I-85-619-SQN, Reference 3) concludes that Sequoyah SEs and ASEs are fully trained in switchyard operations.
Further, it states that Sequoyah's training program meets NRC requirements and is accredited by INPO as documented in Reference 1.
IN-85-289-001, IN-85-894-001, and IN-86-209-013 These concerns were previously evaluated by the SQN-GCTF (Reference 1) with the following results:
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Operations p!rsonnel cro train d thercushly en tha uss and issutnco j
of clearances as described in SQN Administrative Instruction, AI-3 (Reference 8).
This training occurs at.several levels during the training progress between AUO and SE.
Operations Section Letter OSLT-1, " Training" (Reference 11), gives a j
detail description of the phases of operator training.
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l 2.
Members of Sequoyah's Compliance Staff were interviewed about events caused by mishandling of clearances. A search of compliance's l
computer data base was also performed. No evidence was accumulated either from the interviews or the computer search identifying any I
event caused by improper handling of clearances which were reported.
l or potentially reportable, under 10 CFR 50.72 or 10 CFR 50.73.
This means that any events caused by mishandled clearances are not of i
i significant safety impact.
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j 3.
During weeks three and four Requalification Training, Sequoyah
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licensed operators are annually retrained on the procedures for use
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and issuance of clearances. Tests and lesson plans documenting coverage of this subject are kept on permanent file by TVA. OSLT-1, j
section XI.D.2 (Reference 11) describes the commitment made by i
Sequoyah to annually update training for operators on safe clearances.
4.
Sequoyah employs, and will continue to employ, as part of its l
connaitment to Equal Employment Opportunity Act, women in its j
Operation Section.
i Three individuals were contacted from Sequoyah Operations Staff.
Individuals A and B are licensed reactor operators (RO) and individual C is a licensed Senior Reactor Operator (SRO) and an ASE.
t When interviewed, each of these individuals stated that they had i
experienced no greater incidence of occurrence with women operators j
being physically incapable of performing inplant duties than with j
males in the same positions.
i Each individual stated that as licensed operators (R0 and SRO) they
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were fully aware of the problems areas in the plant and the capabilities of the Assistant Unit Operators (AUOs) on their staff.
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If necessary, the AUO (male or female) may at any time request i
assistance in performing a manipulation. Individual C further stated I
that in the case of a plant emergency it is common practice to l
dispatch more than one AUO to a job for personnel safety reasons.
5.
Sequoyah's training programs for operators at all stages meet or exceed all applicable guidelines. As such, INPO has accredited Sequoyah's training program as of January 1984.
INPO continues to j
review accredited programs on a regular basis to ensure the training j
meets their standards (Reference 1).
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IN-85-767-001 This concern has been evaluated by the SQN-GCTF (Reference 2) with the following results:
Ihe General Employee Training Course, GET-4, " Introduction to Quality Assurance / Quality Control" is required training for all uperators, and retraining is required every two years.
Informal QA training by way of required reading is also required for all operators. This required reading falls in three areas:
1.
Initial required reading of numerous PORC approved instructions.
2.
Required reading of change summaries to specific PORC approved instructions.
3.
Reading assignments on an as determined basis by the training section.
Certain instructions required to be read are QA requirements and other procedures which implement various QA requirements. The required reading progrant are addressed in Operations Section Letters, OSLT-1, and OSLA-1.
The required reading outlined above was previously covered by OSLT-4 dated May 19, 1980. This instruction letter has never been canceled and prescribes formal training which has not been given for over two years.
The SQN operators are required to attend six weeks of requalifications annually. Quality Assurance requirements are always a part of the requalification training. The 1985 requalification class session titled
" Maintaining Awareness of Plant and System Operational Status" included retraining on first and second person verification and retraining on procedures and procedure usage.
As stated in the summary of the " Maintaining Awareness class, there is no place at SQN for an operator who is not dedicated to the correct usage of plant procedures."
There are various cases where procedures and QA requirements have been violated at SQN. The SQN personnel interviewed feel these cases are isolated and not generic to a lack of training on QA requirements.
The findings above reported in the Generic Concern Task Force reports and the NSRS report have been reviewed and verified to be accurate with the following additions:
1.
Operator clearance training consists of formal, documented, classroom
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training for SE, ASE, and UO positions, while the AUO receives on-the-job training by assisting the ASE in the execution of a clearance order.
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2.
Operators are required by OSLT-4 (05/19/80) to meet specific QA training requirements of which AI-4, Procedure Instructions - Document Control, Revision 54, is included. AI-4 stipulates under the use of instructions that each employee shall be responsible for conformance with the requirements of plant instructions.
Employees guilty of willful or repeated violations shall be disciplined in accordance with Appendix J.
The policy in Appendix J states the disciplinary action should be selected and administered to correct the cause of the nonconformance. There are progressive steps of disciplinary action which lead to a proposal of termination.
Conclusions The conclusions stated in the two referenced Generic Concern Task Force reports, and NSRS report I-85-619-SQN are appropriate based on this evaluation and are as follows:
Concern XX-85-048-002 is not valid due to the fact that SQN's major firefighting responsibilities have not belonged to the PS0s since 1979 and then subsequently turned over to the Fire Brigade. The Fire Brigade receives extensive comprehensive training and firefighting practice to ensure there is no lack of experience on the fire brigade. Also, Browns Ferry PS0s have no fire protection responsibilities in the plant operating areas.
Concerns IN-85-289-001, IN-85-894-001, WI-85-060-001, IN-86-209-013 IN-85-767-006, and XI-85-093-001 are not valid based on the following reasons.
1.
Sequoyah SEs and ASEs are given extensive training on the use and issuance of clearances. This training includes detailed examination process assuring the competence of licensed operators (ASE or SE) to issue safe clearances.
2.
Sequoyah operators at all levels receive training on the use of clearances.
3.
No evidence could be accumulated either by interview or computer data base search of potentially reportable occurrences (10 CFR 50.72 or 10 CFR 50.73) caused by mishandled clearances at Sequoyah.
4.
TVA NSRS issued a report, I-85-619-SQN, which supports the adequacy of Sequoyah's electrical switchyard training for SEs and ASEs.
5.
Sequoyah operators receive training that meets NRC requirements and l
Sequoyah's training program has received INPO accreditation.
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6.
Interviews with operators (UO and ASE) accumulated no evidence of physical incapability of women to adequately perform AUO duties.
7.
The issue of operators not being adequately trained on QA requirements is perceptual and an individual opinion. QA requirements are trained both formally and informally by way of required reading, which is documented per OSLT-1.
(Reference 11) 8.
The issue of operators not abiding by QA requirements in plant procedures has no generic basis and must be handled on a case by case basis.
9.
The Operations Section Letter OSLT-4 is outdated and not being used.
s 10.
The Sequoyah shift engineer and assistant shift engineers are given extensive training in the operation of the switchyard (both classroom and on-the-job). The training meets NRC requirements.
11.
No ex11ples of poor switchyard operation or operation of this equipment in a manner that endangered the nuclear equipment at Sequoyah was found.
12.
The shift engineers and assistant shift engineers receive training in electrical station operation that meets the NRC requirements and the Sequoyah training program has received INPO accreditation.
The only recommendations that SQN has not implementea, al chis time, are the two associated with Generic Concern Task Force report for IN-85-767-006, (Reference 2) which states:
1.
Operations Section should verify that all current requirements regarding QA training outlined in OSLT-4 are covered elsewhere and then cancel or revise OSLT-4 as appropriate.
2.
Sequoyah Nuclear Plant should implement a periodic review program that would ensure section instruction letters are current.
IV.
Root Cause While the concerns were not valid, this evaluation determined that at l
least one operations section letter was not current, nor being used.
lR1 The apparent cause of this is the lack of an integrated, periodic review l
of procedures.
l V.
Generic Applicability All concerns addressed by this element report are not valid; therefore, there is no generic applicability to the other TVA plants.
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VI.
References I
1.
Generic Concern Task Force Report dated April 22, 1986, Revision 1, for: IN-85-289-001, IN-85-894-001, 11-85-093-002, WI-85-060-001, IN-86-209-013 j
2.
Generic Concern Task Force Report for IN-85-767-006 dated March 17, 1986, Revision 1 l
3.
NSRS Investigation Report Number I-85-619-SQN dated October 2-November 22, 1985 l
l 4.
NSRS Investigation Report Number I-85-736-WBN dated December 13-20, 1985 i
5.
NSRS Investigation Report Number I-85-222-WBN 6.
Memorandum to H. L. Abercrombie from P. R. Wallace dated August 16, 1985, "SQN - Investigations / Evaluation of NSRS Referred EC#
IK-85-048-002, SQN/ Fire Protection Services" i
7.
SQN - Physi-13 Revision 40 i
8.
SQN - AI-3, Clearance Procedure, Revision 31, dated June 27, 1986 l
9.
SQN - AI-4, Plant Instructions - Document Control, Revision 54, dated May 2, 1986 i
l 10.
SQN - OSLT 4, Operations Section QA Training, dated May 19, 1980 i
11.
SQN - OSLT 1. Plant Operating Training Programs, dated February 2, 1986 j
VII. Immediate or Long-term Corrective Action 1.
Operations Section should verify that all current requirements regarding QA training outlined in OSLT-4 are covered elsewhere and j
then cancel or revise OSLT-4 as appropriate.
j 2.
Sequoyah Nucletr Plant should implement a periodic review program that would ensure section instruction letters are current.
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