IR 05000327/1992026
| ML20125E404 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/27/1992 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Medford M TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 9212170041 | |
| Download: ML20125E404 (29) | |
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Docket Nos. 50-327,_50-328 License Nos. DPR-77, DPR-79 Tennessee Valley Authority j
ATTN: Dr. Mark 0. Medford, Vice President f
Nuclear-Assurance, Licensing and Fuels
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3B Lookout Place
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1101 Market Street
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Chattanooga, Tennessee 37402-2801 I
j Gentlemen:
SUBJECT: SYSTEMATIC ASSESSMENT OF. LICENSEE PERFORMANCE.(NRC INSPECTION REPORTL
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N0. 50-327/92-26 AND 50-328/92-26)-
This refers to_ the _NRC's Systematic Assessment of Licensee Performance (SALP);
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report for your Sequoyah facility which was sent _to you on 0ctober 19, 1992; our-
meeting ~of October 26, 1992, at which we discussed the report; and your written comments dated November 23, 1992. I have enclosed a summary of our presentation
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at the-meeting, a copy of your written comments, a copy of the SALP slides which
were used at the presentation, and the Final SALP report for the period June 2, 1991 through August 1, 1992.
l We appreciate your. efforts in-evaluating the Initial sal.P Report and providing
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coinments.
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l In accordance with Section 2.790(a), a= copy of this letter and its enclosures
will be placed in the NRC Public Document Room.
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No reply to this -letter is required; however, should you have - any questions
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F concerning these matters, I will'be pleased to discuss-them with you.'
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Sincerely,
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(Original signed-by L. Reyes)-
l I-Stewart'D.-Ebneter-
Regional Administrator d
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Enclosures:
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October-26, 199?
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Mee*%9 5tsury 2.-
Errita-Sheet-
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Final SALP_ Report 4.
SALP Slides-5.
Comments on Initial i
SALP Report-160022
REGION II:
SYSTEMATIC A
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LICENSEE' PERFORMANCE INSPL
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NUMBER 50-327,
TENNESSEE. VAL
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SEQUOYAH UNITS JUNE 2, 1991 THROUGH AUGt.
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ENCLOSURE 3
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l ENCLOSURE FINAL SALP REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION II
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMBER i
50-327, 50-328/92-26 l
l TENNESSEE VALLEY AUTHORITY SEQUOYAH UNITS 1 AND 2 JUNE 2, 1991 THROUGH AUGUST 1, 1992
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SUMMARY OF RESULTS During the assessment period, Sequoyah continued to demonstrate noteworthy performance in the' areas of Emergency Preparedness and-Security.
Performance in the areas of Radiological Controls, Maintenance / Surveillance, Engineering / Technical Support and Safety Assessment / Quality Verification continued to be good. Although still at an acceptable -level,- a declining trend was noted in the area of Plant Operations. An improving trend was noted-in the Engineering / Technical Support area.
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An increasing number of personnel failing to follow procedures, inattention to detail, and configuration control problems contributed to the decline of Operations performance.
Reliance on compensatory actions due to fire protection program deficiencies continued throughout the assessment period.
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SEQUOYAH SALP
Overview Performance ratings for the last rating period and the current period
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are shown below.
Functional Area Rating Rating last period this period Plant Operations
2 Declining Radiological Controls
2 Maintenance / Surveillance 2 Improving
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1 Security
1 Engineering / Technical Support
2 Improving Safety Assessment /
Quality Verification
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III.
PERFORMANCE ANALYSIS
A.
Plant Ooerations
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1.
Analysis This functional area addresses the control and performance of activities directly related to operating the units, as well as fire protection.
Operations performance during the assessment period was good. Operator response to unit transients and management of shutdown risk during the
refueling outages was very good. During periods of routint operation and startup activities after the Unit 2 refueling outage, significant performance problems were identified in the areas of conduct of routine operations, configuration control, and attention to detail.
Operator response to the reactor trips (3 on Unit I and 4 on Unit 2, none of which were caused by personnel errors), -transients, wbsequent
restarts and off normal events such as the heater drain tank valve failures was very good.
Early in the period, control room operations
were professional and well executed.
Later in the period, inconsistencies were noted in operator performance and attention to detail in control of plant system configurations.
Examples of these inconsistencies involved the events associated with the Containment Spray Suction Valves, Spent Fuel Pit Cooling System alignment and startup procedural adherence.
Several attention to detail problems were also noted which involved unlicensed operators.
For example, loss of fire protection header pressure during testing and improper drawing control in plant work areas other than in the control room were identified r violations involving unlicensed operators. A problem was identified with regard to a lack of adequate attention being focused on the plant component relabeling program.
Errors continued to be
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identified throughout the plant as well as some temporary labels being several years old.
Operator performance during the Unit 1 and Unit 2 Cycle 5 refueling outages which occurred in the Fall of 1991 and the Spring of 1992 respectively, was good.
Evolutions including reactor shutdown, preparations fcr fuel offload, and coordination of outage work, generally were well controlled.
A loss of decay heat removal event lasted for approximately one minute due to a maintenance activity during the Unit 1 outage.
This event was immediately recognized by control room operators and appropriate operator action was taken to minimize the consequences.
In addition the preparation and control of reduced inventory operations were accomplished in a very conservative manner.
Implementation and control of outage activities provided the potential for distraction of the Control Room Operators from their normal duties.
During the period, management recognized this problem and put plans in place to correct the problem.
Startup evolutions were considered good; however, weaknesses were identified with regard to general operating instructions in providing for good operator contral of unit startup evolutions.
Some problems were observed near the end of the Unit 2 outage with regard to the operator shift turnoser process and surveillance activities associated with an Emegency Diesel Generator (EDG).
In addition, activities associated with configuration control were considered poor resulting in a failure to properly align the Containment Spray System for operation prior to entry into Mode 4.
Appropriate safety focus was maintained on the operating units during the outage periods.
In the middle of the assessment period, several operational problems
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resulted from personnel failing to follow established procedures.
For example, operators failed to log unexpected annunciation, ensure timely performance of a 10 CFR 50.59 evaluation, perform required operator rounds, and properly verify Reactor Coolant System (RCS) flow parameters. Additional examples of weaknesses were identified with
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regard to effective communication of requirements for entry and exit of Technical Specification Limiting Conditions for Operation (LCO) during maintenance activities and lack of trending of important parameters on components known to be degraded such as the leaking code safety valves.
Immediate management attention was focused on these problems and improvement was noted during the Unit 2 Cycle 5 outage.
The transition from the old control room annunciator system to the new system during the Unit I and common system upgrade (Unit 1 Cycle 5 outage) was satisfactory; however, problems with the controlling process impacted operations ability to effectively monitor the plant.
l Overall, procedures used by operators were good and allowed for safe l
operation of the plant. At the end of the period, the operations procedure group had completed an upgrade of approximately 60% of the
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system operation instructions. General operating instructions (GOI)
were cumbersome, difficult to use and had contributed to several problems.
At the end of the period, some G01s were being upgraded.
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l Other examples of procedures requiring improvement _during. the _ assessment-period included freeze protection instructions, fire protection procedures, and other administrative-procedures associated with
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corfiguration control and conduct of operations.
At the end.of the previous assessment period, weaknesses were identified
in the quality and implementation-of the fire protection program -
Degradation of the high _ pressure fire protection system, personnel
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performance problems, and inadequate management. attention contributed to this condition. During the first half of this assessment period, the-i licensee continued to identify numerous fire-protection system hardware and programmatic problems. Due to continued _ expansion of the scope of problems, _ numerous compensatory measures were necessary to support dual unit operation. These included the continued use of fire; watches during the entire assessment period, which strained the resources of various plant organizations.
The problem identification process was facilitated by a comprehensive, four phase fire protection improvement plan,
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implemented in August of 1991, which controlled major work activities-required to correct weaknesses in the fire protection area. Completion
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of phase one activities was timely, with the exception of procedural
upgrades and raw service water system reliance on-the fire protection
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system. Additionally, the improvement program resulted in the
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initiation of improved system testing, better control of transient fire
loads, and the identification of the need for long term configuration control of fire barriers. Overall, licensee actions in this area have
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improved markedly; however, the-reliance upon certain compensatory j
actions continued throughout the assessment period.
During the assessment period, staffing for operations crews was adequate L
to ensure safe operation of the plant.
Staffing levels included six shifts, which rotated on an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> basis.
Shift manning included at-
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least four-Senior Reactor Operators (SR0s), and four Reactor. Operators i
(R0s) per shift. A previous problem regarding failure to control operator overtime was corrected. _A review of overtime usage indicated that, although-significant overtime was used by _ licensed operators i
assigned to refueling evolutions during the'out' ages, it was being j.
properly managedt
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During the assessment period, several examples of; poor communication of management's expectations to shift supervision were observed. The
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examples included system maintenance boundary protection, switchyard control _s, and: guidance for s_imultaneous-Residual-Heat Removal (RHR) and EDG outages. Other communications problems were-noted between
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i operations work control personnel _ and operators, and between SR0s and modifications personnel. These resulted in. examples where maintenance activities affected operable shutdown cooling -lineups due to inadequate communication of the scope of work-activities and a failure to maintain adequate control of breaches. Attention to detail problems were noted in the operations department's upkeep-of control room logs related to temporary alterations and tracking of required safety assessments for-changes to the facility.
Plant _ housekeeping was. noted to' be weak during -
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the Unit 1 Cycle 5 ' outage and. continued _to be a problem area throughout
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the assessment period. A positive initiative taken by management was to
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establish a model safety-related pump room during the latter part of the
period.
This area established a standard in housekeeping and defined-i management's expectations for housekeeping-excellence.
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Several self-performance evaluations and assessments were conducted
during the period. Management was aggressive in performing these j
evaluations and corrective actions were being implemented-at the end of
the period.
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Eight violations were identified during-the assessment period.
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2.
Performance Ratina I
Category:
2 Declining 3.
Board Recommendations
The board noted that operator performance with regard.to conduct of operations and configuration control of plant-systems has.been i
a problem during the period and that continuing management l,
attention is warranted to correct-this adverse trend.
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Radioloaical Controls 1.
Analysis
This functional area addresses those activities directly related to
radiological controls, radioactive waste management, environmental l
monitoring,: water chemistry and transportation of radioactive material.
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Overall, the radiation protection program ' continued to adequately i:
control personnel exposure to radiation and radioactive materials hnd
protect the health and safety cf the plant personnel-and the public.
j Management continued to adequately support the radiation protection
program including the as low s reasonably achievable (ALARA)- efforts.
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External and internal exposure controls were effective during the assessment period. No personnel. exposure-in excess of;10 CFR Part 20 limits occurred during the assessment period. With the units operating at power, an average collective dose of approximately 50 millirem per day was achieved, which was considered to be good.
The total personnel dose at the site for the SALP period was-approximately-1100 person-rem.
The dose for 1991 was approximately 349 person-rem per unit.. Although still high, these figures represent a decreasing trend in exposure from the previous SALP period-.
The Radiation Protection staff was well qualified.
The staff did a good:
- job of supporting Unit I shotpeening outage problems and helped minimize collective dose goal overrun.
Posting and labeling was considered effective, and worker-awareness of general radiation conditions within
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the radiation control area and post-job debriefings were found to be a positive influence in dose reduction.
The licensee conducted two planned refueling outages during the assessment period, in addition, a Unit 1 unplanned outage lasting approximately one month and requiring extensive containment work, occurred during the Unit 2 planned outage.
The work performed during the outages presented a major radiological challenge during this period.
The total personnel dose was 670 person-rem for the Unit 1 outage an'
380 person-rem for the subsequent Unit 2 outage with comparable work performed during the two outages.
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During the Unit I refueling outage, radiological dose expenditure, early in the outage, was better than in past outages. This improvement was based on increased use of shielding in containment prior to starting outage work. As the outage progressed, radiological performance decreased, and resulted in expenditure of radiation dose and more personnel contamination events than projected. This decline in radiological performance was due to significant problems associated with steam generator shotpeening and a lack of proper evaluation of high contamination levels in the reactor coolant system due to known leaking fuel assemblies.
The person-rem goal for the Unit 1 outage for shotpeening was 40 and the actual dose was 154.
Radiological controls were observed to be significantly improved during the Unit 2 refueling outage.
The licensee performed substantially the same shotpeening work on Unit 2 with a dose of 35 person-rem compared to Unit 2 outage goal of about 67. The licensee was able to perform the Unit 2 shotpeening work for approximately one-third of the RWP-hours expended for similar Unit I work.
Good ALARA planning was exhibited on several dose-intensive jobs, with total dose and personnel contaminations well below projected level;, even though there was a 5%
growth in radiological work after the outage began, Major contributors to this improved performance were better cleanup of the reactor coolant system prior to cooldown and significant improvement in steam generator shotpeening performance due, 'n part, to lessons learned being implemented from Unit 1 problems.
Some coor work practices associated with Refueling Water Storage Tank (RWST) level transmitter work and other personnel errors were noted during the middle of the outage.
Aggressive management focus promoted additional craft attention to detail and resulted in a reduction of events for the remainder of the outage. Containment cleanup by radiological protection personnel after both outages was considered to be good.
Out-of-core source term reduction continued to remain an issue being ddressed by the licensee, with recent gamma spectral analysis showing re?atively high cobalt activity on the Unit I cold leg pipe wall surface. Stellite reduction programs were still under development.
Plant radiological contamination control was improved over the assessment period.
Early in the period, several safety-related pump rooms were posted as contaminated zones, resulting in less frequent
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tours by operations personnel during performance of their duties.
During the latter part of the period, these areas were decontaminated allowing for operators to more easily inspect safety-related components on a more frequent basis.
The number of personnel contamination events continued to trend downward as well as plant contaminated square footage.
The licensee's program to control and quantify radioactive effluents was effective.
There were no abnormal liquid or gaseous radioactive releases that occurred during this assessment period.
In addition, the quantities of radioactive material released in both liquid and gaseous effluents during 1991 showed no significant increase over the previous year.
The estimated potential doses to the public due to the release of liquid and gaseous effluents for calendar year 1991 were well below the dose limits specified by the Technical Specifications and were less than one percent of the environmental dose limits specified in 40 CFR 190.
The licensee's effluent releases for calendar year 1991 were "as low as reasonably achievable" (ALARA).
During the assessment period, continuing instrumentation problems were noted with regard to radiation monitors being inoperable and requiring repetitive work to maintain them in an operLble condition.
Specific problems were being addressed on radiation monitors for both the Unit 1 and Unit 2 condenser vacuum exhaust. The:e monitors were still experiencing spiking problems when the assessment period ended.
In addition, several other radiation monitors required frequent maintenance. The effluent monitoring system maintenance and system operability continued to challenge the licensee and showed no significant improvement during this assessment period in that several systems were inoperable for greater than 30 consecutive days. All effluent radiation monitoring systems were either repaired or replaced and returned to an operable status by the end of this assessment period.
During this assessment period, the licensee performed audits in the areas of radiological effluents, the Offsite Dose Calculation Manual, the Process Control Manual, environmental monitoring, and radioactive materials management. The audits were technically sound and well documented. The findings and observations were of low safety -
significance and had been adequately addressed by the licensee's technical staff.
The licensee's program for monitoring and controlling chemistry parameters was effective.
The licensee had adopted the industry guidelines for chemistry control and had maintained primary chemistry well within the Technical Specification (TS) requirements and secondary chemistry within the recommended guidelines. Typically, the plant's administrative limits were more restrictive than industry guidelines.
The licensee had taken several actions to improve the quality of
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secondary water, protect the integrity of the steam generators, and reduce the primary side corrosion product source term.
In general, the licensee maintained an effective quality control program for radiological measurements.
Licensee results for the radiochemical analyses of beta-emitting isotopes provided by the NRC's independent measurements program were satisfactory except for Fe-55, where the result was 46% above the known value.
Concurrently, the licensee's quarterly cross check program with their vendor resulted in similar disagreements.
The licensee was considered to be proactive in monitoring vendor laboratory performance, establishing a data trending system, and recognizing the need for closer management review of vendor laboratory results.
The licensee's program for processing, packaging, storing and shipping radioactive solid wastes was effective.
The technicians who performed radioactive waste shipments were adequately trained and performed their duties competently. Daily solid waste generation has been reduced through aggressive management attention and the bulk material permit program which basically limits the material entering the radiation controlled area.
No violations were identified during this assessment period.
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Performance Ratina Category: 2 3.
ILo_ard Recommendations None C.
Maintenance / Surveillance 1.
Analysis This functional area addresses those activities related to equipment condition, maintenance, surveillance performance, and equipment testing.
Maintenance performance, during the assessment period, was good.
Planning and scheduling work activities were very good and considered to be a continuing strength.
Deficiencies were noted in the areas of proper control of completion of work including post maintenance testing
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requirements, verification of completed work, and plant material
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condition.
Surveillance performance was considered to be adequate with some minor attention to detail items being appropriately addressed.
Reviews of the licensee's maintenance scheduling and planning processes determined that these programs were being effectively implemented. The licensee's progress on reducing the non-outage maintenance backlog during the assessment period indicated a gradual decrease in the number
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of outstanding work requests.
Continuing strengths were noted in the areas of schedule tracking and the completion rates for maintenance.
Completion rates for scheduled maintenance activities ir. creased to 90%
by the end of the assessment period. An example of exceptionally good performance of maintenance activities was noted during the 2A-A Emergency Diesel-Generator annual preventive maintenance outage.
These scheduled maintenance activities, which were greater than 30 in number, were well coordinated and demonstrated good planning and scheduling.
Non-outage maintenance and surveillance activities associated with the diesel-generators was also identified as a continuing strength.
The licensee's ability to plan and control work appeared to be working very well with weekly schedule adherence and management attention to schedules and backlogs.
The work order priority process was also functioning well.
During the Unit I refueling outage, performance by both maintenance and modifications was good, with work quality being understood as being more important than schedule adherence. One problem, which involved a failure to properly control work caused the loss of decay heat removal event discussed in the Operations functional area.
Performance during the Unit 2 refueling outage later in the period was also considered to be good, even though a Unit : forced outage required reaction to numerous unplanned maintenance and surveillance activities.
Schedule adherence for the outage resulted in adequate ccordination of work activities.
During the Unit 2 outage one problem was experienced with a failure of foreign material exclusion controls, which resulted in an inflatable pipe plug being found in a coolant loop. Also,-during the Unit 2 outage the condition of frost upheaval of the ice condenser floors was found. The licensee took prompt corrective actions in response to this finding; however, one of the contributing causes was attributed to past poor maintenance activities involved with cleaning and defrosting the ice condensers.
During non-outage periods, the maintenance and modifications groups generally performed well. A strength was identified with regard to ALARA planning, work performance, and personnel safety measures
associated with a maintenance activity to replace the Unit I letdown line relief valve. The licensee continued its successful implementation of other programs such as forced outage scheduling, preventive
maintenance deferrals, and~ Reliability Centered Maintenance.
Several problems occurred during the period associated with more basic root causes such as communications, attention to detail and control of the non-permanent work force.
Examples of these problems included the breach of the control room door boundary, improper control of transient fire loads, an inoperable main steam check valve following packing replacement and a craft induced phase-to-phase short in a motor control center. Ancther significant problem area was independent /second party verification. This resulted in two events in this functional area, an inoperable safety function for the Unit 1 Main Steam Isolation Valves (MSIV) and mislanded leads on an RHR mini-flow valve. Other failures of I
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independent /second party verification were discussed in the Operations functional area.
During the period, plant material condition was generally good and had received appropriate attention in several areas during the Cycle 5 outages.
Examples of improved plant material condition included a new control room annunciation system, Auxiliary Feedwater system recirculation flow modifications, diesel generator air system upgrades, pressurizer safety valve improvements, and auxiliary building protective coating applications. Other plant components in need of additional attention included heat trace for borated water flowpaths in the Chemical and Volume Control System, roam and space coolers, radiation monitoring equipment, remote valve operators, and secondary system equipment problems.
The secondary plant problems continued from the last assessment period to cause plant transients.
During the period, three reactor trips were initiated on Unit I and four reactor trips were initiated on Unit 2.
All of the trips were the result of failures of components. These failures included limit switches on main steam isolation valves, a solenoid valve in the main turbine auto stop oil system, a control rod step counter, secondary system level control valves, a main transformer relay, steam dump valve controller circuitry, and a Resistance Temperature Detector containment penetration connector.
In addition, secondary plant equipment material condition caused a delay in identification of the location of waterbox leakage into the main condenser after one of the trips.
During the latter part of the assessment period, reviews of the licensee's reliability centered maintenance and predictive maintenance programs determined that these programs were being well implemented and provided good information for evaluation of equipment condition.
The latter program was not extensively useJ on safety-related American Society of Mechanical Engineers (ASME)Section XI components. The use of thermography was initiated during the latter part of the assessment period on transformers and raw service water heat exchangers. The equipment failure trending program was being implemented in a good manner; although, one generic component problem involving room cooler degradation was not identified by program parameters.
Procedure quality was good in many areas; however, additional work was needed to complete procedure upgrades and convert to more user friendly Preventive Maintenance (PM) instructions in the Instrument & Control (I&C) and Electrical areas.
Surveillance test procedures also exhibited problems with multiple configuration control evolutions being performed for one signoff.
Staffing of the Maintenance department was considered to be adequate to perform required activities.
The Modifications department maintained a minimum permanent staff and used a contractor to support modification and outage activities. Maintenance training appeared to be focused on apprentice craft and future training was being focused at maintenance l
supervision.
Self-assessment reviews of department functional elements were being accomplished. Maintenance management focused on programs and
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training activities to improve maintenance performance and plant material condition.
Post maintenance and post modification test programs appeared to be adequate.
Several events occurred during the middle of the period which were associated with inadequate configuration verifications and/or inadequate post maintenance testing requirements after maintenance or modifications activities.
Examples included failure to verify requirements for vital battery testing, inadequate post modifications testing (PMT) of Unit 1 generator Current Transformer changeout, inadequate PMT of Unit 1 MSIVs, and inadequate PMT during restoration of containment air lock doors to an operable status.
The problems were recognized by licensee management and appropriate corrective actions were implemented.
Corrective actions had not been effective in precluding events from occurring by the end of the assessment period.
Implementation of the surveillance program was adequate.
However, problems were identified with regard to untimely reviews of TS required surveillances, unqualified test directors performing safety-related testing, and examples of surveillance test procedures not being performed in the order prescribed by the procedure.
Licensee management focused additional attention in these areas and improvement was noted.
A surveillance program review during the latter part of the period determined that overall surveillance program activities continued to be adequate.
Some lingering problems indicated weaknesses in the areas of ptrsonnel accountability, implementation of corrective actions once surveillance deficiencies are identified, and craft attention to detail.
Examples included numerous documentation errors, technical problems which were identified in licensee Condition Adverse to Quality Reports, and a lack of procedural compliance by I&C technicians.
Licensee management focused on corrective actions for these weaknesses during the assessment period.
Six violations were identified during the assessment period.
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Performance Ratin.g
Category: 2 3.
Board Recommendations Continuing management attention needs to be focused on craft
performance in the areas of control of completion of work activities, including adequate assignment of PMT requirements, independent verification and improvement in plant material condition.
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Emeroency Preparedness I
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Analysis j
This functional area addresses activities related to the implementation-
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of the Emergency Plan and procedures, support and training of onsite and
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i offsite emergency response organizations, licensee performance during emergency exercises and actual events, and interactions between onsite i
and offsite emergency response organizations during exercises and actual l
events.
i Management support for and involvement in the emergency preparedness
program was evident from program strengths identified during the
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assessment period.
Program strengths included a strong management j
staffing commitment for the Emergency Preparedness (EP) program, y
resulting in an effective base of expertise at both corporate and site
levels. Management support for the EP program was also demonstrated.
j with the acquisition of a new Operations Support Center with expanded l-space and equipment, a surrogate tour system and a state of the art
Emergency Monitoring Van. The program also benefitted from the
installation of an improved agency wide phone system that should improve l
communication reliability.
The licensee continued to maintain an effective onsite and offsite
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Emergency Response Organization training program throughout the assessment period. Also, during the period the licensee continued to
maintain good emergency response facilities and equipment in a state of
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readiness through equipment surveillances and functional tests.
The I
licensee's audit program was found to be effective in identifying
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routine and exercise conditions requiring corrective action, as well as
recommendations for improvement.
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TVA demonstrated an effective response capability for dealing with-site i
emergency situations during two annual exercises in July,1991 and June,
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1992. During the exercises, the licensee demonstrated it could implement -the emergency plan and its _ implementing procedures, as well as
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take suitable actions to mitigate the consequences of the accident
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scenario.
Emergency elassifications were timely-as the' scenario 1'
progressed, and operation of the emergency response facilities and i-equipment observed during the annual exercise were good.
Performance i
strengths observed during the exercise included teamwork, attitudes and aggressive play of participants. The command-and control. exhibited by l-the Emergency Directors, use of the simulator control room and the licensee's critique' process were also exercise strengths.
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administration and management and procedural controls' and methodology l'
for the licensee's offsite notification process were identified as l
program areas needing improvement.
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l Three Emergenc, Plan revisions were submitted during the assessment
period. Subsequent review determined that the r'evisions did not decrease the effectiveness of the Plan and were approved as submitted.
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The licensee implemented its Emergency Plan in response to seven events this per.od. Six were classified as Unusual Events and_ one as an Alert.
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j The events were determined to be correctly classified and timely
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notifications were made.
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During the assessment period, no violations were cited and no exercise j
weaknesses were identified.
I 2.
Performance Ratin']
Category: 1
j 3.
Recommendatiqn i-
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Nor.e
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E.
Security 1.
Analysis
i This functional area addresses the adequacy.of. the security progra to
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provide protection for plant vital systems, equipment and specici.
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nuclear material as required by safeguards progrars commitments and
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regulatory requirements.
In addition, the area addresses the licensee's
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Fitness for Duty Program.
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During the assessment period, the site security force maintained
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effective control of. plant protected areas.. During the Unit'l outage,.a problem was identified involving. personnel ~ accountability in the-i'
containment during an emergency.
Licensee actions to correct this
problem were thorough and comprehensive and an improved accountability _
L method for monitoring personnel access to containment was observed
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during the Unit 2 outage. Also noted were examples of security.
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personr.el not being familiar with the use of containment access and
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material control procedures during'this outage.
Better performance was
roted at the end of the assessment period.
Site and Corporate management evidenced their support of the safeguards program by their support of the Security Upgrade, which is a significant i
effort to improve overall program' performance.
The Upgrade will correct lighting, alarm station operation, perimeter assessment and detection
vulnerabilities Extensive planning and engineering reviews have i
prioritized construction ~ schedules to replace, antiquated systems and:
improve equipment reliability.
,f I
The licensee adequately staffed, trained and equipped the site's proprietary security force. The' licensee provided the security force j-with adequate procedures identifying their duties.
Security force
personnel performance was professional and demonstrated appropriate l'
skill, training,- and qualification during this assessment period.
Site j
security management was aggressive and knowledgeable, the security
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training staff was, dedicated and motivated.
Security communications and
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cooperation between site functional group and corporate were effective
and responsive.
Self-assessments were superior.
The required quality assurance audits were thorough and aggressive. Additional compliance audits from Corporate Nuclear Security and site security organizations provided extensive self-assessment.
Root cause analysis and human performance evaluations assure corrective actions were effective.
Trending of Safeguard: Event Logs by security management resulted in pro-active measures as part of the Security Upgrade improvements to the protected area alarm system and its reliability.
During this assessment period the licensee has exhibited technically sound and effective resolution to regulatory issues associated with the operation of the central alarm station during the Upgrade construction.
The licensee used the services of consultants to provide tecnnical assistance day-to-day while the Security Upgrade was being implemented.
With respect to training, the licensee contracted with a vendor to install a " simulator" alarm station et the Security Training Facility so
that security operators from all four nuclear stations can be trained on the new equipment. Another facility being renovated was the pistol / rifle firearms range to include an embanked " live fire" tactical training area.
Training with the offsight contingency authorities was also conducted this period, to include, federal, state and county law er#orcement l
agencies.
l To facilitate revisions to the Security Plan as a result of the Security Upgrade, the licensee has extensively coordinated licensing actions with
,
I the NRC. These revisions address better access controls, barriers, l
reduced compensatory measures, and a more reliable perimeter detection l
system.
i The licensee's Fitness-For-Duty Program was found to have many strengths; i.e., professionalism of the medical staff, training of employees and contractors and efforts to test randomly chosen candidates
who were initially unavailable.
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No violations were identified during this assessment period.
2.
Performance Rating
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Category: 1 l
Board _fe. commendations 3.
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None i
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F.
Enaineerina/ Technical Suocort 1.
Analysi s This functional area addresses those activities associated with the design of plant modifications, engineering and technical support for operations and maintenance, and licensed operator training.
Engineering performance during this assessment period was good.
In particular, the quality of design change packages, the technical support provided to operations, and the performance of system engineers were good. The support to maintenance was adequate. Operator training was effective.
The quality of design change packages improved during the assessment period and was good by the end of tbr period. The improvement was evidenced by a significant reduction in the number of field changes made to design change packages. The number of field changes made during the Unit 2 outage ending May 1992 was a smali fraction (30%) of the number made during the proceeding Unit 1 outage of comparable scope.
The improvements 7.re attributed to application of lessons' learned during the Unit 1 outage to the Unit 2 outage, increased engineering support for the modifications group in the field, more effective contractor oversight, and implementation of design review meetings.
The design review meetings were held at 10%, 50% and 80% of design development and included operations, maintenance, modifications, technical support and angineering personnel. These meetings allowed feedback from operations and maintenance to be factored into design development at an early stage, thus improving the quality of design change packages.
Management and organization changes were made during the assessment period to improve the effectiveness of the engineering functions.
New lead engineers for the electrical and mechanical disciplines brought system, modification and SR0 experience to engineering department.
The position of Director of Modifications and Engineering was filled, providing cohesive direction for design development and implementation.
A single engineering contractor was selected who was capable of augmenting the TVA engineering staff and providing project and task management skills.
Technical support provided to operations was generally good.
For i
example, a modification was implemented to upgrade control room annunciators.
The modification aided oper-+ ors by eliminating nuisance alarms and lit annunciators for equipment tut was functioning properly.
During installation of the modification, coordination between engineering and operations was not always effective in that operators were not fully cognizant of the operational status of annunciators.
Operations was also supported by development of a reactivity management program to improve performance and increase sensitivity to the
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importance of reactivity control.
Reactor Engineers have been fully
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staffed and trained. Their support to and communications with operations has improved.
Technical support engineers participated effectively on
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Incident Investigation leams and in the Plant Engineering Review Process to identify root causes of operttional problems.
System engineers performed well as evidenced by the su) port provided to the operations department. Weaknesses identified in t.1e previous
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assessment per.od regarding the systems engineering program and training
were corrected.
System engineers demonstrated improved knowledge of
their assigned systems. More effective supervisory oversight
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contributed te these improvements.
A comprehensive training and certification program was established to further improve performance.
Engineering support provided to maintenance was generally adequate.
For
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example, the licensee developeo a program for diagnostically testing motor operated valves which adequately addressed most of the i
recommendations in Generic letter 89-10.
Licensee engineers were
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knowledgeable of motor operated valve issues, and good communication
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existed between corporate and site personnel. Concerns were noted
regarding completion of diagnostic testing within the schedule i
recomn.=ced by the Generic Letter and regarding a lack of justification for some aspects of the program.
ExampM,f inadequate cngineering support to maintenance were also identifwd.
In one example, NRC inspectors found that main steam check valves were not included in the licensee's Inservice Testing (IST)
{
Program.
Licensee engineers had not recogn1 zed the requirement or the i
need to include these valves in the IST program, even though the valves
had a history of failure.
In another exam)1e, investigation of a leak from a main feedwater pipe weld revealed tlat improper evaluation of i;,
ultrasonic test results of this and other feedwater pipe welds had failed to identify significant cracks. This failure to identify cracks
was caused by a programmatic weakness in the nondestructive examination program which, in this instance, was manifested by the use of
nondestructive examination techniques that were inadequate.
Operator training was generally Mfective.
The training program for new operstor candidates continued to be effective as indicated by a 100%
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pass rate on both the Generic Fundamentals Examina,lons and Initial Examinations. The Sequoyah requalification trainie program was evaluated as satisfactory based upon an examination conducted -in
December 1991. Sixteen of 19 operators (84%) passed the examination.
The three failures were SR0s who passed a retake examination in July
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1992.
The simulator was imprcved to more accurately reflect the unit's control room and plant operational charaderistics. Licensee training
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personnel were effective in evaluating the performance of their operators.
Command and control exhibited by the SR0s, which was
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reported as a weakness during the last assessment period, was noted to have improved on the requalification exam this period.
There was a lack of diversity in the facility's requalification exam bank.
This condition encouraged operators to study exam bank questions instead of
the entire field of knowledge. This was evidenced by a poorer performance on test questions which were developed or altered by the NRC exam team than those questions taken directly from the facility's exam
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SEQUOYAH SALP
bank. Another problem identified during both initial and requalification examinations was the determination of the proper Emergency Action Level f rom the Radiological Emergency Procedure.
Hisapplication of the criteria in this procedure led to both under and overly conservative classifications.
Three violations were identified during this assessment period.
2.
Performance Ratina Category: 2 Improving 3.
Board Recommendations None G.
Lafety Assessment /0uality Verification 1.
Analysis This functional area addresses those activities related to licensee implementation of safety policies, license amendments, exemptions and relief requests, responses to generic letters, bulletins and information notices, resolution of safety issues, safety review committee activities, and use of feedback from self-assessment programs and Quality Assurance (QA) activities.
Safety assessment performance during the period was considered to be good. Management's safety attitude with regard to safe operation and incident investigation was very good.
Continuing recurrence of some problems indicated that management's expectations had not been effectively communicated and implemented by lower levels of supervision and craft.
Quality verification activities provided good indication of
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plant performance and management introduced new quality programs to help correct identified problems.
During the assessment period, management involvement in assuring safety in plant operations, including oversight of outage activities, was evident.
Examples included delaying entry into reduced inventory operation during refueling outages until after core offload, delaying the annunciator changeout modification start time until after core
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offload, and assuring that scheduling considerations focused more on safety than schedule adherence. Several minor events occurred that indicated management was not able to effectively communicate their safety attitude and " attention to detail" policies down into lower supervisory and craft personnel.
Examples included failure to take
I adequate corrective action for a previously identified event resulting in a loss of indicated RUST level, and a weakness % volving inadequate corrective action for assuring performance of sur millance testing.
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Also, problem areas were identified with regaid to a lack of management attention in assuring that proper controls were being implemented.
Examples included elimination of necessary equipment identified in the Final Safety Analysis Report during temporary alteration reduction, cable tray cover control, material / equipment control in and around the spent fuel pool, and failure to take adequate programmatic corrective action for previous problems relating to freeze protection program deficiencies. Also, a weakness was identified with regard to licensee implementation of the problem evaluation report portion of the corrective action program.
The weakness involved unclear guidance to personnel concerning when to initiate problem evaluation reports.
After identification of each of these problems, management focused on each issue and improved performance.
During the latter part of the assessment period, additional management attention was focused on establishing better communication of expectations to lower levels of the organization. Management meetings were improved in format and consistency and additional accountability was stressed, in addition, a management program was established to monitor performance based attributes.
Safety reviews by on and off site review committees were good.
The Plant Operations Review Committee conducted reviews with an appropriate emphasis 9n safety.
The licensee's Independent Safety Engineering Group consisted of experienced engineers of various disciplines and provided the plant with an effective overview of industry, NRC, and other information relative to improving plant safety. Other reviews performed were responsive to plant management directives and provided substantive recommendations in areas afLeting plant safety.
Specifically, an outage nuclear safety review lead to numerous improvements in activities related to outage risk management.
The corporate review board provided l
good independent review and audit of the TS required areas.
During the assessment period, increased management involvement and effectiveness in the incident investigation process of the corrective action program was observed. This involvement resulted in more comprehensive evaluations of events, including the post trip review process. Management involvement was also evident in plant event review i
panel meetings, and in comprehensive evaluations of outage identified problems and fire protection programmatic problems in order to address root causes for the problems.
Management oversight of eacn unit's outage from a safety perspective was very good. Management involvement in outage activities focused on safety with evolutions such as reduced inventory operation and annunciator changeout being scheduled after fuel offload.
During the Unit 2 outage, management instituted changes to promote accountability for outage activities to lower levels of the outage management team with some positive results. The continuing identification of problems indicated that management's expectations for high quality of work and procedural compliance had not been fully accepted by lower levels of supervision and craft.
Examples of a lack of effectiveness included
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configuration control problems, continuing housekeeping problems, and less than effective use of procedures. Additional management actions were being focused on these areas at the end of the period.
l TVA has implemented an effective program for evaluating plant changes, in accordance with the requirements of 10 CFR 50.59. A review of the licensee's safety assessment / safety evaluation program showed evidence of extensive prior planning and implementation of detailed procedures, well trained and qualified personnel, and comprehensive evaluations.
Reviews of LERs during the assessment period indicated that ri; wement promoted plant identification and implementation of compreheolve corrective actions for significant conditions adverse to quality. A strength was identified with regard to the quality of the LERs reviewed during the latter part of the period.
The format had been modified to include a better description of events. The format also included a sequence of occurrences which allowed for a better understanding of the event causes. Nuclear event report reviews were also being conducted by the licensee in a good manner. A weakness was identified with regard to timely identification of a potential safety issue from one TVA nuclear site to another. The issue, potential for degradation of voltage and resultant loss of some safety loads under certain conditions, was identified at Browns Ferry four weeks prior to being identified in a condition adverse to quality report at Sequoyah.
TVA implemented a comprehensive and effective quality verification program designed to identify and correct substandard or anomalous perfo mance, as evidenced by the reports generated by the Quality Assur vce Department.
This process identified problem areas that required management attention, as well' as areas of good performance and strengths. During the Unit I and Unit 2 refueling outages, the site QA organization provided assessments of outage performance to plant
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management. A strength was identified with regard to ongoing audit, monitoring, and quality control activities in the Site QA organization.
One area, which was noted as being very good was tH Quality Assurance Trend Analysis Report.
The report, published qugftely, provided timely.
evaluation of selected functional area performance in windows format, and also identified trends for the areas. Another program, which was in the initial stage of implementation at Scquoyah was the Operations Performance Evaluation.
This evaluation, using specific criteria for conduct of monitoring activities, will provide a quantitative evaluation of performance.. As a result of its activities, _the. site QA organization provided plant management with useful and timely feedback of problem areas.
The site QA organization had well defined staffing functions with no management vacancies at the end of the assessment period.
Staffing levels were adequats to perform assigned functions.
During the assessment period, the NRC staff acted on 9 amendment requests, 9 relief requests, 10 responses to generic letters and bulletins, and other information re'c+.ed to Three Mile Island and other
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regulatory initiatives, that were submitted by TVA.
The information was usually of high quality, accurate, well organized, presented a clear explanation of the issues, and timely.
They reflected involvement by management and, where appropriate, use of NRC and industry guidance.
They demonstrated a good understanding of the technical issues involved and used a ceaservative, viable, clearly-written, approach, for example, the use of quality control was evident in the preparation of the amendment to incorporate new reactor vessel pressure-temperature limits in accordance with Generic Letter 88-11, in the Low Temperature Over)ressure Protection and Power 0)erated Relief Valve amendment, and in tie amendment that implemented tie Core Operating Limits Report.
All required careful and detailed analysis to ensure all issues were analyzed correctly and the proper technical specification requirements incorporated. Aho, understanding of the issues was apparent when new technology was used to provide a better safety and quality approach for alternative testing of the reactor vessel head and internals lifting rigs. Responses by TVA to NRC's generic concerns involving the digitalized Reactor Protection System, called the Eagle-21 System, were generally thorough and exhibited the use of safety conscious approaches.
In contrast to the usual high quality of the submittals, failure to provide prompt responses to staff requests for additional information and analysis has delayed the staff's resolution of some issues.
In addition, revisions to the original submittals related to Station Blackout, the Employee Concerns Corrective Action Implementation Program, the technical specification change for the Containment Radiation Monitor Isolation Signals, the technical specification change related to the Operations Manager and Operations Superintendent positions, were needed; which indicated either that management's reviews were not always effective, or that the issues were technically complex and required further detailed analysis to resolve. A delay in preparation of an amendment for the Eagle-21 cross calibration of
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j approximately two months required staff processing of an emergency amendment on an expedited bases.
In summary, TVA personnel exhibited a strong desire and ability to focus on safety-conscious approaches to plant operation, in the evaluation of problems and changing plant conditions, and in the determination of corrective actions.
t One violation was identified during the assessment period.
2.
Performance Ratina Category: 2 l
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1 3.
Board Recommendations The board is encouraged by improvements in the cuality of information supplied by the licensee.
The Boarc is concerned
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that, on several occasions, an excessive length of time has been taken before the licensee generated a response to information
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requests and has not met agreed upon dates for the submittal of
information.
Therefore, the Board recommends that licensee management increase focus on reducing response times so that issues can be resolved in a more timely manner.
I IV.
SUPPORTING DATA A.
Ma.ior Licensee Activities
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Unit 1 began 60
'se m ent period at full power.
During this
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period, the nH c 9 4 eetly at power with the exception of a 75-day refue1Ing Mrsy! 44r as completed in December 1991, and a 29-day forevf af 2 a J M w4s completed in mid-April 1992.
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During the refud n t.;tege, significant process problems were encountered with regard to a modification involving shotpeening of steam ger.erators rest 1 ting in higher than anticipated person-rem
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expenditure. The Uni t I forced outage was due to degredation of ice condenser doors and a failure of a main feedwater line requiring replacement of the four transition pieces in these lines.
The unit experienced two automatic reactor trips and one manual reactor trip during the period.
At the end of the period, Unit I was operating at full power.
Unit 2 began the assessment period at full power.
During this period, the unit operated mostly at power with the exception of a 10-day forced outage in November 1991, and a 65-day refueling outage which ended in May 1992.
The forced outage was initiated by an automatic reactor trip due to a main steam isolation valve failure.
Restart was further delayed due to electrical repairs that were required on a 480 volt vital power distribution board,-
which was damaged during maintenance activities subsequent to the trip.
The unit experienced three automatic reactor trips and one manual reactor trip during the period.
At the end of the assessment period, Unit 2 was operating at full power.
Management and/or organization changes instituted by the licensee at Sequoyah during the assessment period included: (1) a new Operations Manager in February 1992, (2) a new Site Quality Manager in March 1992, (3) a new Modifications and Engineering Manager in April 1992, (4) a new Training Manager in May 1992, and (5) a new Site Security Manager in June 1992.
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B.
Direct insDection and Review Activities During the assessment period, 40 inspections were conducted.
Eight of these were special inspections:
(1) Team inspection
relatin'g to licensee program implementation in response to NRC Generic Letter 89-10, SAFETY RELATED MOTOR-0PERATED VALVE TESTING
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AND SURVEILLANCE, (2) Operational Safety Team Inspection to evaluate performance in the area of operations, (3) Inservice Inspection program inspection to review licensee's evaluation and corrective actions associated with the Unit 1 feedwater line pipe crack, (4) Review of licensee evaluations and corrective actions associated with ice condenser door binding issue, (5) Fire J
Protection Program team inspection, (6) Inspection in the area of licensee conformance to Regulatory Guide 1.97, (7) Resident inspection in the area of plant operational configuration control, and (8) review of corrective actions for Electrical Distribution
System Functional Inspection findings.
C.
Escalated Enforcement Action
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1.
Orders None 2.
Civil Penalties A Severity Level Ill violation with a $75,000 civil penalty was issued on July 2, 1992 for failure to meet the requirements of TS LCOs 3.0.4 and 3.6.2.1. due to a failure to maintain configuration control of the Unit 2 containment spray system resulting in the system being inoperable.
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A Severity Level III problem with a $75,000 civil penalty was issued on July 2,1992 for failure to initiate prompt corrective actions and failure to provide complete and
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accurate information regarding a material matter for an
issue involving an unissued calculation for IE cable testing.
This Level III problem occurred during a previous
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SALP period and was issued to the licensee during this period.
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D.
Licensee Conferences Held Durina Appraisal Period
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July 31, 1991 - Enforcement Conference at the NRC Region-11 office to discuss issues related to the improper breach of a control building boundary door.
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August 19, 1991 - TVA/NRC Meeting at Sequoyah Nuclear Plant to discuss Fire Protection Program problems and the licensee's
improvement plan to effect program recovery.
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September 25, 1991 - Management Meeting at the NRC headquarters office to discuss steam generator inspection plans for the upcoming Sequoyah Unit I refueling outage.
October 7, 1991 - Management Meeting at the NRC Region 11 office to discuss site initiatives including Unit 1 Cycle 5 refueling outage scope and preparation, operations department and fire protection efforts, special nuclear material inventory and control, and management effectiveness.
January 29, 1992 - Enforcement conference at the NRC Region II office to discuss the failure to remove jumpers from the Unit I train A Main Steam Isolation Valves' automatic closure circuits which caused the valves to be inoperable.
January 29, 1992 - Management Meeting at the NRC Region II office to discuss issues'related to radiological controls performance during the Unit 1 Cycle 5 outage.
March 11, 1992 - Management Meeting at the NRC Region !! office to introduce the new plant Operations Manager and to discuss operations-related issues.
April 3, 1992 - Management Meeting at the NRC Region II office to discuss ice condenser floor degradation and feedwater line cracking issues.
May 1, 1992 - Enforcement conference at the Region II office to discuss weaknesses with the implementation of the Inservice Inspection Program which failed to detect cracks in feedwater piping prior to failure.
May 1, 1992 - Enforcement conference at the NRC Region 11 office to discuss the inoperability of the ice condenser lower inlet doors due to binding on rising floor wear pads.
May 27, 1992 - Enforcement conference at the NRC Region II office to discuss violations for failure to initiate prompt corrective actions and failure to provide complete and accurate information regarding a material matter for an issue involving an unissued calculation for 1E cable testing._
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June 2,1992.- Enforcement. onference at the NRC Region II office to discuss the entry of Unit 2 into MODE 4 with both containment
spray subsystems inoperable, i
June 23, 1992 - Enforcement Conference at the NRC Region II office to discuss the apparent breakdown of the plant fire protection
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program.
July 1,1992 - Management meeting at the NRC Region II office to discuss a self-assessment conducted by the licensee for Sequoyah.
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E.
Confirmation of Action Letters March 23, 1992 - Confirmation of Action Letter issued with regard to interference of the operation of the ice condenser doors on both Sequoyah Units apparently caused by frost upheaval of the
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four inch thick concrete wear slab in the ice condenser bays.
F.
Review of Licensee Event Reports (LERs)
During the assessment period, a total of 44 LERs were analyzed.
The distribution of these events by cause, as determined by the
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NRC staff, is as follows:
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Common Cause Unit 1 Unit 2 Component Failure
3 Design
Construction, Fabrication or Installation
Personnel Error
- Operating Activity
4
- Maintenance Activity
4
- Test / Calibration Activity
3
- Other
Other
3
_____________________________________________________________
Total
14
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Note 1: With regard to the area of " personnel Error," the NRC considers lack of procedures, inadequate procedures, and erroneous procedures to be classified as personnel errors.
Note 2:
The "Other" category is comprised of LERs where there was a spurious signal or a totally unknown cause.
Note 3:
The above information was derived from a review of LERs performed by the NRC staff and may not completely coincide with the licensee's cause assignments.
G.
Licensina. Activities During the assessment period 9 licensee amendments, 9 relief.
requests, 10 responses to generic letters and bulletins, and other
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information related to TMI and other regulatory initiatives were issued or processed.
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H.
Enforcement Activity FUNCTIONAL NO. OF VIOLATIONS IN SEVERITY LEVEL AREA V
IV III
1 Plant Operations
1(*)
Radiological Controls Maintenance / Surveillance
1 Emergency Preparedness Security Engineering / Technical
Support Safety Assessment /
Quality Verification TOTAL
2 Civil Penalty discussed in paragraph IV.C.2
1.
Reactor Trios 1.
Unit 2 tripped from 100% power on November 7, 1991 due to a low-low water level on the #4 steam generator.
The low-low water level was caused by closure of the steam generator #4 main steam isolation valve during partial stroke testing in accordance with a routine surveillance procedure.
2.
Unit 2 tripped from 90% power on r9bruary 10, 1992 due to a turbine trip.
The turbine trip was caused by a failure of a solenoid valve in the turbine auto stop oil system.
3.
Unit 2 was manually tripped from a subcritical condition during withdrawal of shutdown bank control rods on February 10, 1992. The trip was initiated when operators observed erratic group demand step counter operation and initiated the opening of reactor trip breakers in accordance with technical specifications.
4.
Unit I tripped from 100% power on April 28, 1992 due to a-turbine / generator trip. The trip was caused by a failure of a sudden overpressure relay on the 18 main transformer.
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5.
Unit I tripped from a subcritical condition on April 29, 1992 due to a safety injection signal. The safety injection signal was caused by a rate-sensitive low steam line pressure condition.
7 0 low steam line pressure condition
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was caused by opening of the steam dump valves due to an
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apparent failure of the steam dump valve controller
circuitry.
.I 6.
Unit I was manually tripped from 82% power on May 16, 1992
)
due to a condensate flowpath isolation.
The condensate
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flowpath isolation was caused by a failure of level control valves to control level in the #7 heater drain tank.
7.
Unit 2 tripped from 100% power on June 27, 1992 due to a over temperature delta T logic initiation.
The cause of the trip was attributed to a spurious electrical failure of a loop 3 RTD containment penetration connector in conjunction
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with loop 1 protection channels in trip for maintenance.
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ENCLOSURE 4
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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4 ooc *
SYSTEMATIC ASSESSMENT t
OF
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LICENSEE PERFORMANCE l
(SALP)
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TENNESSEE VALLEY AUTHORITY SALP CYCLE 10 JUNE 2,1991 THROUGH AUGUST 1,1992 l
l SEQUOYAH NUCLEAR PLANT OCTOBER 26,1992
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SALP PROGRAM OBJECTIVES 1. IDENTIFY TRENDS IN LICENSEE PERFORMANCE 2. PROVIDE A BASIS FOR ALLOCATION OF NRC RESOURCES 3. IMPROVE NRC REGULATORY PROGRAM
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REGION ll
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0FFICE OF THE ADMINISTRATOR
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ADMINIGTRATOR S. EBNETER
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DEPUTY L.REYES i
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DIVISION OF DIVISION OF DIVISION OF REACTOR PROJECTS REACTOR SAFETY RADIATION SAFETY AND SAFEGUARDS DIR. E. MERSCH0FF DIR.
A. GIBSON DiR.
J. STOHR DEPUTY J. JOHNSON DEPUTY (VACANT)
DEPUTY B. MALLETT l
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JIV SION 0: REAC"OR 390J ECTS 0 9GA\\ ZATIO \\1 DIVISION OF REACTOR PROJECTS DIR. E. MERSCHOFF DEPUTY J. JOHNSON REACTOR PROJECTS BRANCH No.4 CHIEF B. WILSON PROJECTS SECTION PROJECTS SECTION NO.4A NO. 4B CHIEF CHIEF K.BARR P. KELLOGG
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BROWNS FERRY WATTS BAR SEQUOYAH. SRI DELLEFONTE W. HOLLAND
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NRR ORGANIZATION OFFICE OF NUCLEAR REACTOR REG ULATION DIR.
T. MURLEY ASSOC. DIRECTOR ASSOC. DIRECTOR ASSOC DIRECTOR
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FOR PROJECTS FOR INSPECTION AND REACTORS AND J. PARTLOW TECHNICAL ASSESSMENT LICENSE RENEWAL DIVISION OF REACTOR PROJECTS 1/II S. VARGA, DIR. I!!!
G. LAINAS, ASST DIR. Il F. HEBDON, DIR.11/4 D. LABARGE, PROJ. MGR.,
SEQUOYAH l
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l PERFORMANCE ANALYSIS AREAS
FOR OPERATING REACTORS A. PLANT OPERATIONS B. RADIOLOGICAL CONTROLS C. MAINTEhANCE/ SURVEILLANCE D. EMERGENCY PREPAREDNESS
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E. SECURITY F. ENGINEERING / TECHNICAL SUPPORT G. SAFETY ASSESSMENT / QUALITY VERIFICATION
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e AREA PERFORMANCE CATEGORY 1 LICENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT IN NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES RESULTED IN A SUPERIOR LEVEL OF PERFORMANCE.
NRC WILL CONSIDER REDUCED LEVELS OF INSPECTION EFFORT.
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l AREA PERFORMANCE CATEGORY 2 l
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l LICENSEE MANAGEMENT ATTENTION TO
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AND INVOLVEMENT Ik NUCLEAR SAFETY l
OR SAFEGUARDS ACTIVITIES RESULTED IN A GOOD LEVEL OF PERFORMANCE.
NRC WILL CONSIDER MAINTAINING NORMAL LEVELS OF INSPECTION EFFORT.
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AREA PERFORMANCE
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CATEGORY 3
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LICENSEE MANAGEMENT ATTENTION TO
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l AND INVOLVEMENT IN NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES RESULTED IN AN ACCEPTABLE LEVEL OF PERFORMANCE; l
l HOWEVER, BECAUSE OF THE NRC'S CONCERN THAT A DECREASE IN PERFORMANCE MAY APPROACH OR REACH AN UNACCEPTABLE LEVEL, NRC WILL CONSIDER INCREASED LEVELS OF INSPECTION EFFORT.
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l EVALUATION CRITERIA
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1. MANAGEMENT INVOLVEMENT AND CONTROL
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2. APPROACH TO IDENTIFICATION AND RESOLUTION OF TECHNICAL ISSUES
FROM A SAFETY STANDPOINT
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3. ENFORCEMENT HISTORY 4. REPORTING, ANALYSIS AND CORRECTIVE ACTION OF REPORTABLE EVENTS
5. STAFFING (INCLUDING MANAGEMENT)
6. TRAINING EFFECTIVENESS AND QUALIFICATION
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D?E;!K~ O \\ S (CA EGO 9Y 2 JEC_ \\ \\G)
OVERALL PERFORMANCE IN THIS AREA REMAINED GOOD WITH A D?.CLINING TREND NOTED
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STRENGTHS
- SHUTDOWN OPERATIONS
- RESPONSE TO TRANSIENTS
- CORRECTIVE ACTIONS CHALLENGES
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OPERATOR PERFORMANCE
+ CONFIGURATION CONTROL
- PROCEDURES
+ COMMUNICATIONS
- ATTENTION TO DETAIL
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..I VIA \\TE\\ A4CE/SURVE __A\\CE (CATEGORY 2)
OVERALL PERFORMANCE IN.THIS AREA REMAINED GOOD STRENGTHS
- PERSONNEL
- PLANNING AND SCHEDULING
- IMPROVED MATERIAL CONDITION
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- INNOVATION
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CHALLENGES
- POST MAINTENANCE TESTING
- FIRE PROTECTION SYSTEM SURVEILLANCE
- WORK CONTROL
- PLANT / EQUIPMENT PERFORMANCE l
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9AD 0_OG CA_ C0\\T90_
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j (CATEGORY 2)
OVERALL PERFORMANCE lN THE AREA
REMAINED GOOD
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- ALARA PLANNING
- CONTAMINATION CONTROLS
- CHEMISTRY CONTROLS
- AUDITS CHALLENGES
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- OUTAGE DOSE CONTROL
- SOURCE TERM REDUCTION
- RADIATION MONITORING EQUIPMENT CYf *.110RC
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EMERGEhCY 3REPAREJhESS
(CATEGORY 1)
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OVERALL PERFORMANCE IN THIS AREA REMAINED EXCELLENT
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i STRENGTHS
- PEOPLE
- FACILITIES i
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CHALLENGES
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SECURFY (CATEGORY -)
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d OVERALL PERFORMANCE IN THIS AREA REMAINED EXCELLENT STRENGTHS
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- PEOPLE
- PERFORMANCE
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- FACILITIES AND EQUIPMENT CHALLENGES
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- MAINTAINING PERFORMANCE
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l E\\G \\ EEI NG/TEC-4 CA_ SU3309T (CATEGORY 2 IMPROVING)
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OVERALL PERFORMANCE IN THIS AREA i
REAMINED GOOD WITH AN IMPROVING
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TREND NOTED
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- PERSONNEL
- PERFORMANCE j
LICENSED OPERATOR TRAINING l
CHALLENGES l
- ENGINEERING SUPPORT TO MAINTENANCE l
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SAFETY ASSESSMENT / QUALITY VERIFICATION (CATEGORY O
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OVERALL PEFf0RMANCE IN THIS AREA REMAINED GOOD STRENGTHS
- MANAGEMENT INVOLVEMENT.
- SELF ASSESSMENTS
- PERFORMANCE
- LICENSING SUBMITTALS CHAll d'3ES
- CORRECTIVE ACTIONS
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Tennessee Yauey Authonty 1 tot Ma9et Street. ChattaAEga Tennessee 37402 j
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Mark O. Medford vice Presscent. Nxear Assu ance, bcensing and Fweis r
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U.S. NuciliidhRegulatory Commission a
ATTN:' Document Control' Desk Washington, D.Ch.2C555
Gentlemen:
In the_ Matter of
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Dockt.t Nos. 50-327 Tennessee Valley Authority
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.50-328 SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - INSPECTION REPORT
NOS. 50-327, 328/92-26 - RESPONSE TO THE 1992 SYSTEMATIC ASSESSMENT OF
l LICENSEE PERFORMANCE (SALP)
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By letter dated October 19, 1992, the NRC staff transmitted to TVA the initial SQN SALP Report fo;; the period of June 2, 1991, through August 1, 1992. Subsequently, on October 26, 1992 NRC and TVA representatives met to' discuss the report findings. This letter provides
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I TVA considers the-report to constitute a fair assessment of SQN
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performance over the. subject period and is consistent with our own
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self-assessment conclusions. Accomplishments, chalisuges, and
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improvement initiatives were discussed with the staff in our l
July 1, 1992, self-assessment meeting with NRC and addressed in the August 15, 1992, follow-up letter. While overall. performance has been
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good and accomplisheents realized, this effort is offset by declines or weaknesses in performance in the major functional areas of Plant Operations and Maintenance / Surveillance.
Improvements in the two major
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functional areas have also been discussed with the staff on several
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occcslons; while not complete, we believe that these initiatives are.
effecting improvements. We are clearly not satisfied with the level of performance over the past SALP period; the potential and expectations for SQN are substantially beyond good" performance.
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U.S. Nuclear Regulatory Commission Page 2 November 23, 1992 We have examined the initial SALP report very closely to ensure that identified areas for improvement have been captured within our own self-assessment and performance improvement program initiatives.
Detailed action plans have been developed for each functional area.
We are working to makn these programs ongoing, living efforts to ensure that long-term, continued improvement is achieved in all functional areas.
Even in the areas of Emergency preparedness and Security for which SALP ratings of
"1" were achieved, challenges lie ahead.
The more general challenge includes es'aining program and implementation excellence, coincident with in6u;;.y improvements and site facility changes. The ongoing major Site Security upgrade is an example of such change and is receiving careful management oversight to ensure Security program effectiveness is maintained during the transition period.
We are pleased with the improvements that have been realized in the Radiological Controls and Engineering / Technical Support areas and the staff's recognition of those improrements; however, we recognize the vital role that the associated organizations and activities play in supporting and contributing to the success of plant operations and are committed to further improvement. Proactive identification and resolution of system hardware and performance problems, and effective prioritization and support of hardware upgrades will remain the key areas of focus.
Effective minimization of personnel dose will remain a primary objective in the Radiological Controls area with continued focus on worker radiological practices and careful planning and control over outage activities.
A number of ongoing process improvement initiatives are targeted to elevate organization effectivaness in both the Plant Operations and l
Maintenance / Surveillance areas.
Key efforts in the Operations area include:
overall upgrades in the configuration control and clearance processes; work control and control room environmant improvements resulting from implementation of the new operations Control Center adjacent to the main control room area for work authorization; nonlicensed operator qualification upgrades and development of additional guidance for conduct of assistant unit operator rounds; and personnel participation and ownership in improvement efforts through the ASOS Improvement Plan and Operations Advisory Committee.
Key Maintenance efforts include:
completion of the ongoing supervisory development training; postmaintenance testing and verification program improvements including extensive training, augmented review and expanded application of end-device testing; and strengthening of the Reliability Centered Maintenance Program through integration with ongoing trip reduction and hardware reliability improvement efforts.
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i U.S. Nuclear Regulatory Commission Page 3 November 23, 1992
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Significant effort is being applied at optimizing overall plant material condition and reliability.
In addition to enhancements to the Reliability i
Centered Maintenance Program, a detailed analysis of secondary plant reliability is also being performed.
This analysis will take into consideration component failure modes, preventive and predictive maintenance applications, corrective maintenance improvements, and design upgrades to effect an overall improvement in reliability. Prioritization and scheduling of outstanding hardware upgrades are being carefully examined.
Existing
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hardware troubleshooting and problem investigation techniques are being reviewed for further strengthening.
The resolution of outstanding fire protection hardware deficiencies is Seing aggressively pursued, which will lead to a significant reduction in compensatory measures over the current SALP period.
Performance weaknesses identified in the Maintenance / Surveillance and Operations functional areas are considered to be directly related to the principal observation noted in the Safety Assessment / Quality Verification functional areas; management has not been fully effective in communicating expectations for and bringing about consistent implementation of requisite high standards of personnel performance. We clearly consider this area te constitute the most significant challenge to SQN achieving its potential for overall operational excellence.
Extensive actions are being taken to clearly define and reinforce management expectations and performance standards; improve management and supervisory effectiveness; assess employee performance against those expectations on an ongoing basis; and establish consistent performance feedback and l
accountability.
Expectations and accountability against those expectations I
have been established and communicated both verbally and in writing.
l Cascading and sitewide face-to-face communications sessions are being conducted by the Vice President, Nuclear Operations; Site Vice President; Plant Manager; and/or department heads to repeatedly reinforce expectations
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and standards and communicate performance assessment against those standards.
Both management effectiveness and personnel performance are being closely monitored; actions have been taken, and will continue to be taken where necessary, to reinforce accountability against expectations and effect the dtsired change.
In summary, TVA appreciates the staff's assessment regarding SQN's l
performance and has verified that the SALP report's findings are being appropriately addressed within the SQN performance improvement program initiatives. While noch has been accomplished at SQN, there are significant
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chcIlenges remaining. TVA will schedule a meeting with the staff by l
March 15, 1993, to review SQN's progress in these efforts. We are committed to continued improvement and achievement of operational excellence.
We, l
too, agree that effective management action is necessary to achieve this direction.
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U.S. Nuclear Regulatory Commission Page 4-
November 23, 1992
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If you have any questions concerning this submittal, please telephone l
M. A. Cooper at (615) 843-8924.
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Sincerely,
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f Mark O. Medford
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cc:
Mr. D. E. LaBarge, Project Manager
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U.S. Nuclear Regulatory Commission j
One White Flint, North l
11555 Rockville Pike
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Rockville, Maryland 20852-2739 i
l NRC Resident Inspector i
Sequoyah Nuclear Plant i
2600 Igou Ferry Road
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Soddy-Daisy, Tennessee 37379-3624 t
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Mr. B.
A.- Wilson, Project Chief-
'U.S. Nuclear Regulatory Conmission l-Region II l
101 Macietta Street, NW, Suite 2900 j
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Atlanta, Georgia 30323-0199 i
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