ML18036A698

Forwards Util self-assessment of Plant Performance During Period Beginning 910523 to Present,For NRC Consideration in Reviewing Unit 2 SALP & Documents Info Presented to NRC at 920417 Meeting in Atlanta,Ga

ML18036A698
Person / Time
Site:	Browns Ferry
Issue date:	05/08/1992
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9205180050
Download: ML18036A698 (136)

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P,CCELERATED DISTRIBUTION DEMONST$MTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9205180050 DOC.DATE: 92/05/08 NOTARIZED: NO DOCKET FACIL:50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 AUTH.NAME AUTHOR AFFILIATION ZERINGUE,O.J.

Tennessee Valley Authority'",

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards util self-assessment of plant performance during period beginning 910523 to present, for NRC consideration in reviewing Unit 2 SALP

& documents info presented to NRC at 920417 meeting in Atlanta,GA.

DISTRIBUTION CODE:

IE40D COPIES RECEIVED:LTRL ENCL I SIZE:

TITLE: Systematic Assessment of Licensee Performance (SALP) Report NOTES:

RECIPIENT ID CODE/NAME SANDERS,'M-ROSS,T.

INTERNAL: ACRS AEOD/DSP/TPAB DEDRO NRR/DLPQ/LHFB11 NRR/DOEA/OEAB11 NRR/DREP/PRPB11 NRR/DRIS/RSIB9A NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 EXTERNAL EG&G/BRYCEs J H'

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1 RECIPIENT ID CODE/NAME HEBDON,F AEOD/DOA COMMISSION NRR SHANKMAN,S NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DRIS/RSGB9 D NRR/PMAS/ILRB1 2 0

REG FILE 02 L ST LOBBY WARD NSIC COPIES LTTR ENCL 1

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1 NOTE TO AL'L"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE! CONTACT THE DOCUMENT CONTROL DESK.

ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAiVIEFROivI DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

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P Tennessee Vattey Auttiority.Post Office 8ox 2COO, Decatur: Afabama 35609 O. J. 'Ike'eringue tree President, 8rovms Ferry Operations

'NAY 0 8 ]992 U.S., Nuclear Regulatory Commissi'on ATTN: Document Control Desk Washington, D.C.

20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.

50-259 50-260 50-296 BROWNS FERRY NUCLEAR'LANT (BFN) UNIT,2 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

SELF ASSESSMENT This letter provides TVA's self-assessment of BFN performance during the period beginning May 23, 1991 to the present.

TVA

.provides this information for NRC's consideration in reviewing BFN Unit 2 performance during the. current assessment

period, which is scheduled to end on May 22, 1992.

This letter also documents the information presented to the NRC during a meeting conducted on April 17, 1992, in Atlanta, Georgia.

The previous SALP report for BFN was issued June 14,

1990, and assessed BFN performance for the period of January 3,

1989, to March 31, 1990.

Overall, this report concluded that performance in all areas of evaluation met or exceeded regulatory requirements'.

Improving performance trends were noted in the areas of Emergency Preparedness, Maintenance/Surveillance, and Safety Assessment/

Quality Verification.

Radiological Controls was identified as being a significant strength at the site, as evidenced by its Category 1 rating.

9205180050 920508 PDR ADOCN 05000260 PDR

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U.S. Nuclear Regulatory Commission Although the SALP results were generally positive, the report nevertheless indicated the need for continued improvement in all functional areas.

For example, the SALP Board noted weaknesses in the Maintenance/Surveillance area involving

unclear, difficult-to-use procedures, and insufficient attention to detail by personnel using those procedures.

As more fully described in Enclosure 1,

TVA has implemented a programmatic improvement effort and extensive corrective actions which not only address previously identified weaknesses but also significantly improve overall performance at BFN in all functional areas.

Attached to this letter are two enclosures.

The discussion in Enclosure 1 is structured to address "Major Accomplishments" and "Areas For Further Improvement" in each of the seven functional areas of evaluation.

Enclosure 2

contains

'the list of commitments resulting from the activities described in, the first enclosure.

The specific programs and improvement efforts discussed in Enclosure 1 are measures implemented in the operation of BFN to achieve first rate performance.

While TVA currently envisions that these measures or their equivalent will remain in place during the foreseeable future, TVA constantly willbe seeking to further upgrade and improve performance.

Therefore, some changes to the activities described in Enclosure 1

can be anticipated.

What is essential for purposes of this evaluation,

however, is that the programs and measures described in this enclosure reflect TVA's drive to improve performance

and, in many respects, have already helped TVA achieve that goal at BFN.

Despite improvement, TVA recognizes that its efforts have yet to come to full fruition.

Continued improvement is the goal in all functional areas.

At both the corporate and plant level, TVA has a management team committed to and capable of achieving that.

objective.

This management team is focused not only on the identification and analysis of underlying root causes but also on other weaknesses in nuclear performance at BFN.

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U.S. Nuclear Regulatory Commission In summary, TVA. has demonstrated its ability to operate the plant. safely and manage it with efficiency and foresight.

On-going improvement efforts will continue throughout the ensuing assessment period.

'TVA is committed to ensuring that BFN continues, to improve performance in all functional areas of performance.

We look forward to receiving the SALP evaluation for BFN.

Sincerely, 0

J. Zering e Enclosures cc (Enclosures)':

NRC Resident Inspector

'Browns Ferry Nuclear Plant Route 12,,Box 637

Athens, Alabama 35611

.Mr. Thierry M. Ross, Project Manager U.S. Nuclear Regulatory Commission One Whi.te Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr.. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region.IZ

, 101 Mari.etta Street, NW, Suite 2900 Atlanta, Georgia 30323

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ENCLOSURE

'TENNESSEE VALLEY AUTHORITY BROGANS'ERRY NUCLEAR PLANT (BFN) UNIT 2 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE,(SALP)

MAY 23'991 - MAY 22'992

.SELF ASSESSMENT

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EXECUTIVE

SUMMARY

In the previous SALP report dated June 14, 1990 (NRC Inspection Report 90-07), the SALP Board concluded that performance at BFN in all seven functional areas met or exceeded regulatory requirements.

The highest rating, Category 1, was assigned to the functional area of Radiological Controls.,Security, Engineering/Technical

Support, and Plant Operations received Category 2 ratings.

Emergency Preparedness was rated as Category 2,

Improving.

Finally, the areas of Safety Assessment/Quality Verification and Maintenance/Surveillance were assessed as Category 3, Improving.

TVA has addressed previously identified weaknesses and has also undertaken efforts to significantly improve plant performance in all functional areas.

TVA believes these actions-will ensure that BFN becomes a top-rated plant.

"Major Accomplishments" and "Areas For Further Improvement" in each functional have been identified and are summarized below.

Plant 0 erations:.

BFN successfully completed a broad-based Power Ascension Test Program comprised of 20 plant integrated

tests, without an unplanned, automatic scram.

Since completion. of the power ascension

program, plant performance has been

good, as evidenced by the limited number of operational

events, unplanned automatic

scrams, and high availability factor.

Other major accomplishments involve improved control room and fire protection performance, increased management involvement in and improved training for startups and planned shutdowns, and continued excellent performance on operator license 'xaminations.

In

addition, TVA has implemented a reactivity, management program at BFN.

Other major accomplishments include more effective communications between management and staff, implementation of a computerized hold order system, development and implementation of a nuisance alarm management

program, preparation of timely and self-critical

reviews, and a

program to address out of specification readings.

Areas for further improvement include the implementation of an equipment performance monitoring

program, completion of the long-term equipment labeling program, development of a systematic approach to identifying drywell leakage, enhancing auxiliary unit operator performance, improving the temporary alteration

program, and increasing the self-critical nature of incident investigations.

TVA is also initiating steps to develop a college degree program for Operations and other site personnel.

Radiolo ical Controls:

Major accomplishments in this functional area are numerous.

They involve include the development and use of shield

tables, source term reduction, development and implementation of a

computerized radiation exposure tracking

system, and reviews of design changes and work tasks to maintain dose as low as reasonably achievable (ALARA).

Other major accomplishments at BFN include improved management attention to and participation in the ALARA program, chemistry water

quality, effective utilization of power reductions to reduce

dose,

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heightened awareness of departmental dose

goals, and improved radioactive waste management.

TVA has also installed a nitrogen generator for the chemistry laboratory, and new continuous air

monitors, as well as improved radiological control training at BFN.

Improvement efforts to further reduce exposure and radwaste generation at BFN involve the use of closed circuit television, cobalt source term reduction, improved use of the post accident sampling

system, and modif'ications to the condensate demineralizers.

In addition, TVA will be purchasing a remotely-operated robot to assist in work performance in radiation areas, and will also be initiating development and implementation of a computerized plant video tour system; Maintenance Surveillance:

Major accomplishments realized during the assessment period include improved performance in the areas of modifications and surveillance testing, improvements in the work planning process, and a significant reduction in the maintenance backlog.

TVA also developed and implemented the maintenance peer evaluation program and the maintenance supervisory development

program, and the forced outage schedule.

In addition, TVA refined the maintenance trending program.

Further improvements are planned in the training and control of contractors, as well as implementation and completion of a craft team building training

program, and implementation of the reliability centered maintenance and preventive maintenance programs.

Finally, TVA will also continue to focus management attention on improving personnel performance.

Emer enc Pre aredness:

A major accomplishment in this functional area during the assessment period involves the enhanced training during drills by initiating use of the plant simulator, safety parameter display system, and mockups during drills.

Additional accomplishments include improved communications between emergency response

centers, corporate and plant management involvement in site activities, increased attention to emergency response performance, and enhanced community relations.

Continued improvement is planned through complete implementation of the response to NRC Bulletin 79-18, implementation of revised emergency action levels, and upgrading the radiological emergency response capability.

~securit Among the major accomplishments in this functional area during the assessment period are improvements in special nuclear material accountability, implementation of new detection equipment, weapon

upgrades, organizational improvements and heightened management interaction.

There have also been various programmatic and administrative improvements, security procedures

upgrades, improvements in safeguards and compliance, additional security personnel training, implementation of a new badging process, and fitness

'for duty program improvements.

Areas for further improvement include the security upgrade of the perimeter detection

systems, lighting, and access control systems.

En ineerin Techni.cal 8u ort:

During the assessment period several major program enhancements, combined with continued use of comprehensive

programs, have resulted in significant improvement in this functional area.

Particularly strong areas include completion of the simulator upgrade

project, improvements to the drawing

program, emergency operating instruction enhancements, close support of the plant by the site Nuclear Engineering organization, the comprehensive design change closure

process, high quality design

changes, the vendor manual

program, the research and development project on the control room emergency ventilation

system, system engineering

support, the motor-operated valve testing program, and the continued quality of the training program.

Areas for further improvement include the control of contractors, ensuring material availability during the upcoming refueling

outage, and additional enhancements to the system engineering program.

Safet Assessment ualit Verification:

Extensive corrective actions were undertaken in this functional area subsequent to the June 1990 report.

Several major accomplishments are the result, including improvements in the quality and timeliness of submittals, initiation of a licensee event report (LER) improvement effort, and improved communications with the NRC Staff.

TVA also successfully focused on the timely resolution and closure of open inspection

items, LERs and corrective action itemsg improvements in the incident investigation process; and enhanced root cause analysis training.

Additional accomplishments realized during the assessment period include effective overviews by the Nuclear Safety Review

Board, improved assessment capabilities of the Quality Assurance (QA) organization, improved QA communications with plant organizations, and restructuring the BFN QA organization and refocusing on performance-based audits and monitoring.

During the coming assessment

period, TVA will be progressing towards implementation of improved standard technical specifications, increasing the self-critical nature of incident investigations, implementing further measures to improve the

training, qualification, and objectivity of site QA personnel, and enhancing capabilities to trend performance.

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FUNCTIONAL AREA -,PLANT OPERATIONS In the June 1990 SALP assessment, the NRC SALP Board evaluated performance in the functional area of "Shutdown Operations," rather than "Plant Operations,"

due to plant configuration during the assessment period.

Performance in this functional area was rated as Category 2.

Weaknesses were noted in the response to control room instrumentation during normal shift operations and compensatory fire protection measures.

As more fully explained

below, there have been numerous accomplishments in this functional area at BFN during the assessment period.

TVA considers these accomplishments and improvements go beyond what was necessary to address the weaknesses identified in the June 1990 SALP report.

More importantly, they have been carefully designed and implemented to continually upgrade performance at BFN.

In this regard,.

TVA has laid a

strong foundation upon which to further improve BFN performance in this area.

Ma'or Accom li.shments 1.

Plant Performance Since Startu BFN's performance in this functional area may be most accurately reflected by plant performance during the assessment period.

For example, with respect to operational

events, the number of licensee event reports generated is usually a good indicator of plant performance.

Since completion of the power ascension testing program only 11 operational events have occurred at BFN Unit 2 6 in 1991 and 5

in 1992.

Additionally, the 3

unplanned automatic scrams that have occurred since restart have all been caused by unforeseen equipment failures.

Another graphic indicator of plant performance during the assessment period is the plant's availability factor.

Following completion of the power ascension testing program, Unit 2 has an average equivalent availability factor of over 88 percent.

This high availability factor is attributed to many factors, including a strong preventive maintenance program.and significant resources expended by TVA during the shutdown on balance of plant systems.

TVA considers that the improved plant performance can be attributed'o many factors.

Among the more important factors are management attention and emphasis on safe plant operation, as well as operators'erformance and sense of ownership.

Other significant contributing factors include timely performance of surveillances, implementation of the quarterly surveillance schedule and the forced outage

schedule, and system engineer support of operations and maintenance activities; all of which are discussed in greater detail in other sections of this enclosure.

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Control Room Performance Control room performance is another area in which significant improvement has been noted during the assessment period.

Operator response to alarms has been enhanced through continued emphasis by management at shift turnover meetings, biweekly shift operations supervisors meetings, weekly meetings with the Operations Superintendent, and weekly meetings with the Operations Manager.

Another indication of improved control room performance involves repeat backs.

Operators now repeat back, immediately and in a clear manner, acknowledged alarms, unexpected changes in plant conditions, and any command or request from other Operations personnel.

The improvement in repeat backs has also carried over to the auxiliary unit operators (AUOs) in the field.

TVA expects that control room performance will be further enhanced when new control room work stations are installed as part of the planned upgrade of the emergency operating instructions (EOZs).

These new work stations incorporate the latest human factors designs, such as raised platforms for the shift operations supervisor, refined operator console layout, and enhanced space usage.

Further improvements in control room performance will be realized during the upcoming assessment period

when, TVA implements Revision 4

of the BWR Owners Group Emergency Procedure Guidelines.

These improvements will include full implementation of the flow chart format and enhanced user-friendliness.

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Fire Protection Performance The June 1990 SALP report noted a

weakness in the implementation of compensatory, fire protection measures at BFN.

To address this weakness, TVA revised its limiting condition for operation (LCO) tracking system to include tracking of fire protection compensatory measures.

TVA also added procedural requirements for the shift technical advisor to review proposed compensatory measures prior to initiation.

Additionally, TVA has provided additional training to fire brigade personnel, responsible for preparing the form which documents fire protection system/equipment removal from service, to increase their awareness of technical specification (TS) and LCO requirements.

TVA's compensatory action program was further enhanced during the assessment period by requiring that compensatory measures be identified prior to removing fire hose stations from service.

This enhancement was,developed by TVA as a corrective action in response to a

November 4,

1991, event in which various hose stations.

were isolated 'without establishing compensatory measures.

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As a first step toward implementation of Generic Letters 86-10, Im ementatio of F re P otect e u e

e ts, and 88-12, Remova of Fire Protectio Re u' ts Fro c

'ca S eci ications, TVA developed the BFN Fire Protection Report.

This report is a consolidation of BFN fire protection programs and will serve as the basis for removal of fire protection requirements from the TS.

This report was submitted to the NRC on January 15,,

1992.

On April.13,

1992, TVA initiated the second step in this process by submitting.a license amendment request to change the BFN Units 1, 2 and 3 TS.

The requested changes would involve replacing current Unit 1

and 2 license conditions with the Units 1,

2 and 3 Fire Protection Report standard license condition, removing the fire protection systems and fire brigade staffing requirements from the TS and relocating them to the Fire Protection

Report, and adding administrative controls of the Fire Protection Report to the TS to implement the license condition.

4.

Successful Power Ascension Test Pro ram The BFN power ascension test program consisted of 20 plant integrated tests and was modeled after those undertaken at the Peach Bottom and Pilgrim nuclear

plants, as well as the criteria outlined in Regulatory Guide 1.68.

Prior to conducting each

test, TVA prepared a

detailed briefing package identifying the test director, responsible personnel, and plant conditions that would precipitate suspension of testing.

TVA conducted two pre-test briefings for each power ascension test:

a general test overview, prior to the test crew assuming shift duties; and a second',

detailed briefing conducted.prior to initiating the test.

Management attention and involvement in-the power ascension testing program was extensive.,

This included a detailed review of each test and 24-hour shift coverage during the program.

The program was completed in 75 days, which was within 2 days of the forecasted schedule.

More significantly, no unplanned automatic scrams occurred during the program.,

TVA considers that the keys to the program's success were significant pre-planning, management involvement and expenditure of significant resources on balance of plant equipment/systems during recovery activities.

As a result, TVA avoided the types of operational problems experienced by other licensees returning to operation after similar extended outages.

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Additional shift 8u ort During the assessment

period, operational activities were conducted with an additional senior reactor operator (SRO) on shift.

This additional SRO exceeds TS requirements for shift manning.

Additionally, TVA established a shift work control supervisor (who is a

licensed SRO) to review shift work activities and remove additional administrative burden from the shift operations supervisor.

TVA also established an additional SRO in the work control organization to assist in planning the upcoming refueling outage.

Additional shift support will be provided in the future since TVA plans to hire 45 additional AUOs to support long-term operation of the 3 BFN units.

6.

Increased Mana ement Involvement in and Im roved Trainin for Startu s and Planned Shutdowns Another aspect of TVA's conservative philosophy towards operation of BFN involves training of Operations groups.

Specifically, the simulator is utilized to train each Operations group on the specific plant conditions and evolutions to be performed during startup, shutdown, or special tests.

This training is a

logical continuation of that performed in connection with power ascension activities.

Since startup, TVA has continued training Operations personnel on the simulator in preparation for future startups, planned shutdowns, and special tests.

For example, the simulator is programmed to simulate plant conditions at the time of shutdown in order to expose the operating crew scheduled to initiate shutdown to expected evolutions through the end of their shift.

The next group is then trained on plant conditions they will experience until their shift ends, etc.

TVA's conservative operational philosophy is also demonstrated by Operations management's coverage of startups and planned shutdowns.

For these activities, Operations management has provided 24-hour shift coverage from the time shutdown is initiated until the unit attains 50 percent power after startup.

7.

Continued Excellent Performance on 0 erator License Examinations During the assessment period BFN operators continued to perform very well on operator license initial and requalification examinations.

During examinations conducted in June, July and December 1991, all 23 candidates passed the examinations.

Furthermore, since January

1990, 61 of 64, candidates have passed initial or requalification examinations.

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Although the pass ratio for these examinations remains high, TVA nevertheless is in the process of developing a program to help operators better prepare for initial,and requalification examinations.

On March 2, 1992, TVA established an action plan for developing a

management review team that will be responsible for implementing the program.

The management team will be composed of

plant, corporate and training representatives.

TVA is currently developing implementation strategy for the program.

I'm lementation of Reactivit Mana ement Pro ram Prior to restart, TVA developed and implemented a reactivity management program, including a site specific procedure, at BFN to sensitize plant personnel to the significance of reactivity changes.

Subsequently, during the assessment period TVA enhanced the program through development and implementation of a special training film for plant personnel, modeled after a

similar film developed by Commonwealth Edison Company; and revised procedural requirements to specifically address review of proposed design modifications and temporary alterations, as well as changes to other procedures.

The purpose of this review is to identify events or conditions that could potentially affect reactivity,,

reactivity

control, or reactivity monitoring.

As an example of TVA's heightened sensitivity to reactivity management, TVA has assigned a reactivity manager (a licensed SRO specifically charged with monitoring reactivity) to be on shift during startups.

Additionally, a reactor engineer is in the control room during preplanned control rod movements.

Another example of the heightened sensitivity to reactivity issues at BFN occurred on July 31,

1991, during final preparations for conducting the high pressure coolant injection system power ascension test.

TVA recognized that performing the test in accordance with the initia'l conditions, established in the test procedure could have resulted in power oscillations.

This was due to the possibility of reactor operation in the region of potential flow instability.

Following identification of the potential

problem, TVA suspended testing to review the results of similar tests conducted at other plants.

Based on this review, TVA verified the validity of the

concern, and subsequently revised the initial plant conditions specified in the test procedure.

The test was then successfully conducted on August 1,

1991.

Actions taken during this test exemplify TVA's ability to promptly identify potentially safety significant events, as well as the conservative philosophy TVA employs to address them.

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Effective Communications Between Mana ement and Staff During the assessment

period, Operations management has continued to conduct face-to-face meetings with plant operators to ensure the effective communication of management expectations.

These meetings include the biweekly shift.

operations supervisors meeting and weekly meetings with Operations groups.

In the course of these meetings, Operations

,management consistently reiterates management expectations, such as plant ownership, command and control, system status control, timely performance of surveillance instructions, and complete and accurate logging.

Evidence of the effectiveness of these meetings can be seen in operators'esponse to alarms and in operator repeat backs..

Other significant examples of the benefits achieved through communications between Operations management and staff include improved morale and effective utilization of the shift complement, which has also reduced overtime.

In addition, significant procedural deficiencies are now corrected during the shift in which they are identified.

10. Pre-lannin and Mana ement Xnvolvement Several specific examples of significant pre-planning and management involvement, such as the detailed test briefing packages prepared for power ascension

tests, the reactivity management

program, and use of the simulator for startups, shutdowns, and special tests have been discussed above.

However, the detail and content of the Unit 2 Plan of the Day (POD) meeting

,package and management involvement in POD meetings are two of the most telling examples of pre-planning and management involvement at BFN.

For instance, all phases of plant operations are reviewed at POD meetings, including plant

status, priority work activities, control room instrument

status, and integrated schedule/system outages.

A more subtle example of hands-on management involves the integration of plant operations expertise throughout BFN organizations.

In addition to the previously discussed SRO in the Work Control organization, TVA assigned a licensed SRO to the Site Licensing organization (due to the change in duties, the individual is no longer licensed).

TVA is also currently planning to rotate a licensed individual from the Operations organization to the Training organization in June 1992, and an additional two licensed individuals in December 1992.

Furthermore, TVA has been assigning a

shift operations supervisor in a rotational assignment in the Quality Assurance (QA) organization since June 1990.

The latter rotational assignment is discussed in greater detail in Section VII of this enclosure.

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Zm lementation of Cpm uterized Hold Order S stem In August 1991, TVA purchased and placed into service at BFN a computerized hold order (equipment clearance) system to reduce the time required to 'repare hold orders and facilitate preparation of.more consistent hold orders.

The system has the capability of storing previous hold order boundaries, thereby allowing TVA to prepare and re-use, after verification, hold orders for frequently performed plant activities, such as surveillances or preventive maintenance items.

TVA will upgrade the computerized hold order system by adding computerized system status capabilities.

This enhancement will provide up-to-da'te information to Operations personnel on component status.

TVA will complete implementation of this enhancement by February 11, 1993.

12.

Mana ement Observation Enhancements During the assessment period TVA enhanced management observation of plant activities.

For

example, Operations management checklists were.

recently revised to establish standardized evaluation criteria which enable computerized tracking and trending. of observations by group, classification and performer.

TVA also initiated a continuing self-assessment program for plant organizations.

This program involves periodic review of plant activities on a

6-week cycle.

Specific operations activities reviewed during each 6-week period include performance of independent verification, hold order implementation and removal, shift turnover, surveillance instruction implementation, and compliance with radiological controls,,security and industrial safety practices.

13. Nuisance Alarm Mana ement During the assessment

period, TVA developed a formal program to address Unit,2 nuisance alarms.

The ipurpose of the program is to correct the cause of the alarm not simply to disable it.

This effort was accomplished by the implementation of a

computerized, system to track the status of work activities associated with affected annunciators.

The nuisance alarm program receives high visibility through management review.at POD meetings.

Increased management attention ensures a minimum number of lit annunciators.

Currently, TVA is expanding the focus of this program to also address common annunciators.

14. Pre aration of Timel and Self-Critical Reviews As discussed more fully in Section VII of this enclosure, TVA has instituted significant changes designed to improve the timeliness and self-critical nature of incident investigations (IIs).

One such change involves review of the status of IIs at POD meetings.

This review helps to ensure that IIs are completed in a timely manner.

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Another example of timely and self-critical reviews involves the critiques performed following forced outages and power reductions.

These reviews focus on any problems or delays encountered, including procedural problems, as well as methods to facilitate performance of work.

15.

Out of S ecification Readin s

During the assessment

period, BFN's AUOs identified a concern to Operations management that out of specification readings of plant components, which the AUOs identify during performance of their daily rounds, were not.bei.'ng promptly investigated and addressed.

As a result, TVA instituted review of out of specification readings at POD meetings.

The purpose of this review is to ensure that management attention is focused on components that are not functioning within established, acceptable performance regions. It also ensures that degraded equipment performance is.corrected in a timely manner, before it impacts safe and continued plant operation.

'Areas for Further Im rovement 1.

Im lement the E i ment Performance Monitorin Pro ram To improve equipment reliabili.ty and enhance plant performance, TVA has developed an equipment performance monitoring program at BFN.

This program, initiated on April 2,

1992, enhances early detection of degradation of systems and equipment important to plant safety and efficiency not just those systems addressed in the TS and commitments.

Such detection efforts are considered to 'be crucial to the prevention of catastrophic

failure, either by signaling the need for immediate corrective action or by promoting improved maintenance and outage planning.

In determining which components require periodic monitoring, the program provides for systematic review of systems and components that could affect unit heat rate, availability, or capacity factor.

Other elements of the BFN equipment performance monitoring program include: the identification of parameters, testing frequencies, and analyses necessary to evaluate both the efficiency and reliability of systems and components requiring periodic monitoring; documentation of program activities, as well as the bases for including or excluding systems and components from the program; and routine reports to management summarizing program results and recommendations.

Currently, TVA is preparing the first report documenting system performance for the period of January through March 1992.

This report is scheduled to be issued by the end of May 1992.

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Com lete -the. Lon -Term E i ment Labelin Pro ram In December

1991, TVA formally established a dedicated plant labeling group at BFN.

This action was taken in response to problems experienced with plant labeling prior to and during the assessment period.

The group is responsible for re-verifying current system labeling and identifying discrepancies in the labeling of non-critical plant systems.

(Labeling of critical plant systems was performed as part of system return to service activities.)

The group is also replacing existing old-style metal tags with BFN's standard equipment identification labels.

The new labels use standard system terminology, color coding, and bar codes, and can be read from a greater distance.

TVA expects to complete this long-term labeling project in April 1993.

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Develo a

8 stematic A

roach to Identif Dr ell Leaka e

During the assessment

period, TVA initiated two voluntary

.shutdowns of Unit. 2 in order to identify and repair leakage in the drywell.

In each case, TVA made a conservative management decision to voluntarily initiate unit shutdown if the unidentified drywell leakage increased to a pre-established administrative limit of 4 gallons per minute (gpm) a leakage rate below the TS limit of 5 gpm.

In both cases, TVA shut down the unit when leakage reached approximately 3.6 gpm.

As a, result of these voluntary shutdowns, TVA has gained valuable experience in the identification of drywell leakage.

This, in turn, has led TVA to develop a systematic instruction to streamline the process for identifying drywell leakage.

Lessons learned were relied upon and incorporated into the development of this instruction.

For example, TVA initially had difficulty determining why the radioactivity levels in a reactor coolant sample were sometimes nearly double that found in a sample from the drywell sump.

As a result of its shutdown experience, TVA now realizes that the difference in these two radioactivity levels can indicate the relative distance of a leaking component from the drywell sump.

4.

AGO.Performance Another area which will be the focus of continued attention at BFN during the upcoming assessment period'nvolves AUO performance.

TVA's current program for monitoring and assessing AUO problems includes a senior-level retired naval petty officer assigned to provide operations expertise and dedicated leadership to the AUOs.

TVA also conducts performance monitoring of AUOs through use of management observation checklists,,which are used to document deficiencies in AUO performance.

Management periodically discusses these findings with the AUOs during the weekly Operations group meetings or at the periodic quality meetings with the AUOs.

Page 9

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d

Periodic qual'ity meetings also serve

-as

.a.forum in which the AUOs can express their problems to management and offer solutions to existing, problems.

Based on the success of these

meetings, TVA plans to continue these meetings during the upcoming assessment period.

TVA also plans to continue rotating AUOs through each assigned position to ensure that they retain proficiency in and overall knowledge of plant operations.

5.

Im rovements to the Tem orar Al'teration Pro ram During the upcoming assessment

period, TVA wi;ll be focusing increased management attention on the temporary alteration program at BFN -to enhance the program.and further reduce the.

number of temporary alterations.

Some of the actions taken to date include additional requirements for review of proposed temporary alterations..

This change implemented on. February 19,

1992, requi;res the site Nuclear Engineering (NE) organization to review-and approve proposed.

temporary alterati'ons and corresponding 10 CFR 50.59,safety evaluations.

Another improvement that has been initiated is the review of temporary alterations at POD meetings.

This initiative increases management awareness of temporary alterations installed in the plant.

Additionally, through review at POD

meetings, management routinely requests that design changes be initiated if temporary alterations are. not promptly resolved.

6.

.Colle e De ree Pro ram for 0 erations.Personnel

.During the assessment

period,

'TVA initiated steps towards assisting Operations personnel and other site personnel-attain college degrees in a technical field.

Currently, TVA is evaluating'two programs offered by, accredited institutions,that would allow BFN personnel to pursue a.Bachelor of Science degree in either Nuclear Science or Nuclear Engineering Technology.

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PUNCTZONAL AREA - RADZOLOGZCAL CONTROLS Performance in this area was rated as Category 1 in the June 1990 SALP report.

TVA has identified additional actions designed to maintain and further improve its superior performance in this functional area.

For instance, TVA committed to develop generic shield tables to streamline the process for.shielding installation on various components.

In addition, measures were undertaken to minimize collective radiation exposure at the site.

As explained below, these and other improvement efforts have been or are being implemented at BFN.

Ma'or Accom lishments 1.

Develo ment and Use of Shield Tables As discussed

above, in TVA's response to the June 1990 SALP

report, TVA committed to develop generic shield tables for operational and shutdown conditions.

Use of the tables, which were completed and put into use on August 22, 1991@ expedites the process for installing shielding on various components, thereby reducing dose.

'To date, shield tables have received limited use due to plant configuration.

With respect to BFN's overall shielding

program, TVA estimates that the lead shielding installed to date has resulted in an estimated exposure savings of 14 person-rem during the period from June to December 1991.

2.

Source Term Reduction In TVA's response to the June 1990 SALP report, TVA discussed the development of a

long-term, comprehensive source term reduction program.

This multi-faceted program is still being implemented at BFN.

The first element of this program involves a

chemical decontamination project which was initiated in December 1991 and successfully completed in February 1992.

During the

project, the Unit 3

recirculation system was chemically decontaminated, resulting in removal of approximately 11.5 curies of radioactivity and a

subsequent average decontamination factor (ratio of pre-and post-decontamination contact dose rates) of approximately 62.

TVA also chemically decontaminated the Units 1,

2 and' fuel pool cooling heat exchangers, which resulted in a

decontamination factor of roughly 7 for the Unit 1 heat exchanger and,8 for the Unit 2 and 3 heat.exchangers.

Additionally, TVA achieved an average decontamination factor of 13 following chemical decontamination of the Unit 3

reactor water cleanup

.(RWCU) system.

Furthermore, TVA willbe performing chemical decontamination of the Unit 2 recirculation and RWCU systems during the upcoming Unit 2, Cycle 6 refueling outage.

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6 Another element of the source term reduction program is the hot spot tracking, trending and.reduction program.

Developed at BFN in January 1991, this program provides a mechanism for.the reduction and elimination of hot spots.

As such, it is another method used at BFN to maintain dose

.as low as reasonably achievable (ALARA).

Since its initiation, this program has resulted in the identification of 77 hot spots (57 prior to

restart, 20 afterward).

Of that totals 29 have currently been eliminated (4 prior to restart, 25 afterward) by flushing, shielding, or other methods.

Of the remaining 48, 35 are in inaccessible areas or are not contributing to work area dose rates.

Another source term reduction measure undertaken at BFN during the assessment period was cleanup of the Units 1, 2 and 3 spent fuel storage, (SFSPs) pools.

This effort involved removal of highly contaminated filters and approximately 35,000 curies of irradiated hardware from the SFSPs.

Compaction and removal of control rod blades is also underway as part of this effort.

3 ~

Develo e

and Im lemented the Com uterized Radiation E

osure Trackin 8 stem In September

1991, TVA implemented the Radiation Exposure System (REXS),

a computerized radiation, exposure tracking

system, at BFN.

This real-time computerized radiological information system provides users with automated access control to radiological control areas.

It also has radiation work permit issuing and tracking capabilities.

REXS has enhanced the processing of ALARA information and enables continuous tracking of dose accrued on radiation work permits (RWPs).

The latter feature can be used by TVA to monitor performance and compare it to established radiation dose goals on a daily basis

~

To complement REXS in the future, TVA is phasing in the use of electronic digital dosimeters.

These digital dosimeters have pre-set alarm capability and should further improve the accuracy of dose tracking.

The dosimeters are currently being used as alarming dosimeters for entry into high radiation areas.

Full implementation of the dosimeters for automated access control is targeted for 1993.

4.

ALARA Reviews of Desi n Chan es and Work Tasks At BFN, the ALARA concept is initiated early in the design and work implementation process.

For example, design changes are reviewed by the site Radiological Controls (Radcon)

ALARAgroup during the development phase to ensure that the proposed design incorporates ALARA concepts.

Additionally, workplans are reviewed by this group, prior to implementation, to ensure incorporation of the ALARA concept.

Furthermore, site procedures have also been revised to ensure that ALARA considerations are an integral part of project design development.

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In-process reviews of jobs are also performed to maintain dose ALARA.

Work tasks having a projected dose of greater than 1

person-rem are reviewed when the dose accrued on the job reaches 25, 50, and 75 percent of the estimated exposure levels.

Work tasks are reviewed again for ALARA purposes if there is a

change in either the scope of work or estimated exposure.

5.

Mana ament Attention To and Involvement With the ALARA Pro ram During the assessment

period, as in the

past, management attention has been closely focused -on the site ALARA program.

Continued improvement in management involvement is nevertheless evident.

For -example, ALARA goals'ave been included in management's performance standards for Fiscal Year,(FY) 1992.

The ALARA/Radwaste Committee (ARC) was restructured in June 1991 to require the BFN Plant Manager or the Vice President, Browns Ferry Operations, to chair ARC meetings.

The latter change has resulted in improved attendance of key management personnel at ARC meetings.

The plant manager periodically relays his expectations concerning ALARA issues during POD and staff meetings.

This interaction has resulted in increased sensitivity of plant personnel to ALARA issues, as evidenced by participation in the ALARA suggestion program..

Management attention and involvement is also demonstrated by the special reviews required for planned work activities that are projected to exceed pre-determined limits.

Specifically, the site Radcon organization and the job leader are required to review any work task with an estimated exposure of greater than 1

person-rem.

A special ARC subcommittee reviews jobs projected to exceed 5 person-rem, and the Nuclear Power ALARA Committee reviews any work task expected to exceed 50 person-rem.

6,.

Chemi'str Water ualit During the current operating cycle, BFN Unit 2 has consistently maintained excellent water chemistry.

As an example, in 1991 TVA established a goal for the chemistry performance index of 0.29, which is below the 1991 INPO median (0.33) and the 1995 INPO goal (0.30).

In

1991, the Unit 2

average chemistry performance index was 0.26, and in 1992 the current average is less than 0.20.

Chemistry water quality and other chemistry parameters are monitored daily at POD meetings.

In addition, TVA takes other measures to ensure Unit 2 water quality is maintained.

For

example, TVA limited the.power ascension rate to ensure fuel integrity-, and also administratively limits recirculation flow to 100 percent for this reason.

This aggressive management plan

has, to date, resulted in no leaking fuel rods, as Page 13

II

measured by the Fuel Reliability Indicator (FRI).

Since

startup, the FRI has averaged less than 100 microcuries per second (pCi/s).

INPO guidance states that an FRI less than 300 pCi/s indicates a high probability of zero fuel defects.

Effective Utilization of Power Reductions One of the successful methods employed at BFN during the assessment period to reduce dose accrued has been the utilization of power reductions to perform dose-intensive tasks.

Since startup in May 1991, TVA has taken advantage of 10 power reductions to perform tasks such as valve leak repairs and equipment maintenance.

At least five of these power reductions 'have been performed solely for ALARA purposes.

The total estimated dose savings during these power reductions is 24 person-rem.

As an example of a power reduction initiated to reduce

dose, following startup from the most recent voluntary shutdown, Unit 2 experienced high air inleakage

.into the offgas condenser system.

Work activities were initiated in low dose areas to

.identify and correct inleakage sources.

During these work activities TVA identified additional sources of inleakage.

These sources were not corrected,

however, due to high dose rates in these areas during power operation.

As a result, at the direction of the BFN Plant

Manager, TVA initiated, a

power reduction (from 100 to approximately 60 percent.power) on March 9,

1992, so as to reduce dose accrued during the performance of necessary work.

This power reduction lasted approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

To maximize dose savings, the forced outage

schedule, discussed in Section III below, was used to identify other work tasks that should be performed during the power reduction.

Planning for both the power reduction and work activities was closely coordinated between the Operations,

Radcon, and Chemistry organizations to ensure minimization of accrued dose.

Planning included the use of actual plant components in Units 1 and 3

as mockups during dry runs to prepare for the work activities on the Unit 2 components.

TVA estimates that the power reduction, combined with use of the forced outage schedule and Unit 1 and 3 components as mockups, resulted in a dose savings of over 1.36 person-rem a reduction of over 50 percent during these work tasks.

Hei htened Awareness of De artmental Dose Goals Prior to commencement of the assessment

period, TVA implemented use of radiation exposure goals applicable to each site organization.

The purpose of this activity was to improve tracking of dose accrued and enhance participation of site organizations in implementation and achievement of the ALARA concept.

During the assessment

period, use of these goals was improved, primarily due to enhancements in the presentation of Page 14

I

goals to plant personnel and line management, and in their comparison to actual performance; For example, performance towards goals and dose accrued during the previous 24-hour period is discussed during POD meetings.

This ensures management attention and awareness of dose goals.

In addition, organization-specif ic goals now receive high visibilityon-site by means of display, on the site video information network.

Certain actions are required should an organization's dose goal be exceeded or exhibit an adverse trend.

In particular, the ARC reviews the goal and the reason(s) for the variance.

The responsible manager is then required to address the reason(s),

provide a revised proposed dose goal for the remainder of the year based on known work, and identify actions that have been or will be taken to ensure that the revised.goal will be met.

9 ~

Im roved Radioactive Waste Mana ement During the assessment period, several improvements were made in the area of radioactive waste management.

One involves decreasing the contaminated area in the

plant, thereby significantly reducing the dose accrued and also limiting the potential for spread of contamination.

For example, during the assessment

period, the contaminated area was reduced from approximately 4.0 percent (as measured at the beginning of the assessment period) to the current level of approximately 3.3 percent of the total plant radiologically controlled area.

TVA has established an ambitious goal of reducing the, contaminated area to 2 percent by September 30, 1992.

Another

-important aspect of radioactive waste management involves the elimination of certain radioactive material storage areas.

During the assessment

period, the number of these storage.areas was reduced from approximately 100 to the current level of 59.

Daily waste generation has also been reduced through aggressive management attention, such as the assignment of an SRO full-time to radwaste..

The effectiveness of TVA's actions is demonstrated by the volume of waste generated, which is approximately 50 percent of the average BWR.

10.

Use of Nitro en Generator In early March 1991, TVA initiated use of a nitrogen generator at BFN to provide a continuous nitrogen supply to the total organic carbon analyzer and the gas chromatograph.

This has resulted in reduced instrument downtime and minimization of the time typically required to recalibrate these instruments after a change in gas supply.

This action also eliminates the use of compressed gas cylinders, thereby reducing the potential for personnel injury.

Use of the nitrogen generator has been recognized by INPO as a strength.

Page 15

11. Installation of New Continuous Air Monitors CAMs In May 1991 TVA installed new state-of-the-art CAMs at BFN to.

support Unit 2 restart.

These CAMs utilize digital, rather than

analog, circuitry; have data storage capability, which allows for trending of a CAM's readings over periods of timey and permit direct reading of airborne radioactivity concentrations.

Following installation of the new CAMs, TVA began experiencing various operational probl'ems with

them, primarily due to installation difficulties. and personnel lack of familiarity with the new monitors.

Since that

time, TVA has taken aggressive corrective actions, such as dedicating a maintenance crew to the CAMs and providing additional training to personnel servicing the

CAMs, which have resolved the previous operational problems.

12.

Radcon Trainin For purposes of Radcon training at

BFN, since the last assessment period Radcon shift supervisors and engineering staff have been certified in accordance with TVA's Instructor Certification Program, which meets the requirements of INPO accreditation guidelines.

The primary benefit of this training is the resulting ability of Radcon supervisors to identify and correct Radcon technician performance problems.

Furthermore, qualification of the Radcon.supervisors allows for more on-shift training and enhances classroom training by providing technically qualified subject

.matter experts within the classroom.

It has also improved communication between the supervisors, Radcon technicians, and,other plant personnel.

Performance of the Radcon shift supervisors at

BFN, and especially their ability to recognize and correct the aforementioned performance problems, was recognized by INPO in its most recent evaluation of BFN as a strength.

Additionally, this training has resulted in enhanced feedback to the BFN training department on radiation protection and other radiological issues.

TVA also encourages BFN Radcon technicians to expand their knowledge by means other than traditional training.

For

example, TVA management actively supports certification by the National Registry of Radiation Protection Technologists (NRRPT).

For technicians interested in this opportunity, TVA makes special arrangements for training, as well as on-site testing.

To date, 30 Radcon personnel have been certified by the NRRPT.

Final'ly, TVA continues to emphasize ALARA Awareness Training.

(AAT) for plant personnel.

In February and March

1991, to support Unit 2 restart, TVA expanded the program beyond the scope of existing modules addressing

RWPs, exposure

control, and contamination containment construction.

This expansion Page 16

1f

focused on training for personnel in both the Planning and Scheduling, as well as Chemistry, sections.

To supplement the AAT program, TVA has developed a specialized AAT module for BFN engineers.

This specialized module was implemented March 30, 1992.

Areas for Further Im roveme t 1.

Use.of Closed Circuit Television CCTV TVA has purchased the necessary cameras and will begin use of CCTV at BFN during the Unit 2, Cycle 6 refueling outage.

Use of CCTV during operating and outage conditions is expected to reduce the. number of manhours required for inspections, reduce the amount of radwaste generated through fewer required dress-

outs, and improve radiological surveillance capabilities.

TVA estimates an annual exposure savings of about 33 person-rem per year through the use of CCTV.

2.

Cobalt Source Term Reduction During the upcoming assessment

period, TVA will focus on reducing the cobalt source term through removal of stellite from plant components.

This effort involves replacement of control cell control rod blades with non-stellite blades.

This should result in an expected dose savings of approximately 95 person-rem per year.

A companion effort, involving the removal of stellite from primary system valves, is also being planned at BFN.

Currently, a list of candidate valves is being compiled for purposes of the latter effort.

3.

Im rove Use of the Post Accident -Sam lin S stem PASS Prior to Unit 2 restart, TVA completed installation of the PASS and the wide range effluent radiation monitoring system at BFN to satisfy the requirements of NUREG-0737.

Subsequent to installation, TVA has completed necessary training on the use of the PASS to obtain samples of reactor coolant.

However, during

,a self-assessment of the training

provided, TVA determined that additional actions could improve personnel knowledge about and proficiency in use of the PASS.

These additional actions are considered. to be necessary, primarily due to the non-routine use of the PASS.

As a result, TVA will be conducting additional "hands-on" training at the PASS panel.

This training will begin by May 28,

1992, and is scheduled to be completed by November 1992.

4.

Modifications to the Condensate Demineralizers During the upcoming assessment

period, TVA will be performing modifications to the condensate demineralizers at BFN to improve performance.

Modifications will include equipment upgrades such as increasing the surface area of the elements, eliminating the stepping switches, and adding the capability to Page 17

E'utomatically control the precoat addition process.

These modifications are currently scheduled to be completed prior to startup from the Unit 2, Cycle 6 refuel'ing outage.

The end result is an expected increase in the average run length of the demineralizers from 10 to 20 days, improved water chemistry, and an approximate 50 percent reduction in the radwaste generated by the demineralizers.

5.

Im lementation of Interactive Plant Video Tour 8 stem In the upcoming assessment period TVAwillinitiate development and implementation of a comprehensive and interactive plant video tour system.

This system willallow individuals to view, via a computer.and video disc player, any area of the plant, "travel" through the plant at various

speeds, "look" in any direction from where the user is "standing,"

and view details of various plant components.

Upon implementation, the system can be used for pre-outage scheduling and

planning, for emergency planning, as a safety tool for operators, for routine ALARA planning for any work task, and as mockups or during prejob briefings to better prepare for performing work.

TVA estimates that use of this system would result in an annual exposure savings of 35 person-rem.

The first phase of this project will involve still photography of accessible Unit 2

plant areas and components, and development of the initial video program for these components.

TVA will begin this work by October 14,

1992, and is currently planning to implement the partial working system in time to be utilized during the Unit 2, Cycle 6 refueling outage.

The remaining elements of the Unit 2 project, as currently planned, include photography of Unit 2 drywell components and subsequent completion of the entire Unit 2 video system.

6.

Initiate Use of Robotics During performance of the previously discussed work activities associated with identification of condenser air inleakage, TVA determined that utilization of robotic equipment would result in considerable dose savings and facilitate work in high radiation areas.

Consequently, during the upcoming assessment period TVA willpurchase a remotely-operated robot to assist in work performance in radiation areas.

TVA estimates that use of this robotic equipment will result in an annual exposure savings of 20 person-rem.

Page 18

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III.

FUNCTIONAL AREA - MAINTENANCE/SURVEILLANCE This was one of two functional areas designated as Category 3,

Improving, in the June 1990 SALP report.

Performance of modifications was deemed to be a weakness.

Problems were also noted in the area. of surveillance activities.

Substantial improvements have been and continue to be implemented at BFN which effectively address these problem areas and weaknesses.

TVA also has implemented additional enhancements to further improve performance and other aspects in this functional area.

As a result, TVA has demonstrated a level of performance superior to that experienced during the prior SALP assessment period.

Evidence of this conclusion is more fullydescribed below.

Ma or Accom lishments 1.

Modifications Performance In the June 1990 SALP report, modifications performance was repeatedly cited as a weakness.

TVA recognized this weakness

and, as a result, has

.taken aggressive corrective actions to improve modifications performance.

TVA considers these efforts to be largely successful, as evidenced by completion of the modifications work, restart of Unit 2, and subsequent operation without any problems caused by poor modifications workmanship.

Following Unit 2 restart, TVA significantly changed the way modifications work is performed at BFN by restructuring the Modifications organization from a direct-hire to a contractor management organization.

TVA also established the TVA task manager position for contractor.work.

Individuals. acting as task managers are responsible for ensuring proper implementation of work, such as by verifying that procedures are followed, hold orders are in place, and required paperwork is completed.

In November 1991, TVA enhanced contractor control by developing

,a contractor interface manual which specifies divisions of responsibility for both TVA and contractor personnel.

Additionally, in March 1992, TVA developed and implemented a

human performance enhancement system seminar which addresses all phases of the modifications work

process, including specific focus on, such areas as proper work practices and proper use of procedures.

2.

Performance of Surveillances Prior to the beginning of the assessment period, performance of surveillances had been a

weakness at BFN.

However, TVA's extensive corrective actions taken in response to a

1989 enforcement

action, combined with implementation of the Page 19

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divisionalized quarterly surveillance schedule and management attention, have resulted in a

dramatic improvement in surveillance performance at BFN during the assessment period.

The divisionalized quarterly surveillance testing program was implemented at BFN in January 1991.

Its purpose is to group the surveillance instructions (SIs) into divisions or trains so that SIs are run on one division or train at a time.

This type of schedule avoids the removal of all divisions or trains from service at one time to perform SIs.

The divisional tests are based on a 28-day monthly schedule with monthly tests performed 13 times per year.

Management attention continues to be focused on the performance of surveillances.

For example, surveil'lances scheduled to be performed during the current week and the upcoming week are discussed daily at POD meetings.

Any. test deficiencies identified during performance of a

surveillance are also discussed at the meetings.

Additionally, upcoming surveillances scheduled to be performed during the next 7 days, with specific emphasis on the upcoming 24-hour period, are discussed at the daily Maintenance meeting.

Since startup, timely performance of surveillances has been a

strength at BFN.

This is demonstrated by the fact that since startup all of over 2800 surveillances have been performed within their TS-required time frame.

Furthermore, TVA has not experienced problems with the technical accuracy of these surveillances.

3.

Im rovements in the cwork Plannin Process As more fully explained in TVA's August 9,

1990, response to the June 1990 SALP report, TVA implemented a

computerized maintenance planning and control (MPAC) computer software program during the previous assessment period.

TVA later upgraded MPAC by adding tracking and trending capabilities which were previously lacking at BFN.

In October

1991, TVA further improved MPAC through software upgrades which streamline the work order planning process.

This software upgrade also added text editing and work order history retrieval capabilities.

One of the primary benefits of the software upgrade is a reduction in the amount of time a job is in the planning process.

As a result, work orders are more quickly delivered to craft personnel.

Additionally, MPAC now provides the database for live time monitoring of each maintenance work item.

Furthermore, routine monitoring of constraints to work and timely responses to problems are two of the many beneficial byproducts of MPAC.

An additional improvement in the work planning process employed at BFN is the forced outage

schedule, discussed in greater detail below.

The effectiveness of the schedule was most recently demonstrated during the February 1992 shutdown when Page 20

t

4 planned work items, surveillances, design

changes, and even emergent work items were completed within approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of the scheduled time of completion.

Of particular interest from a maintenance, perspective is the development of generic timelines and corresponding job assignments and responsibilities.

The result is individual accountability and, concomitantly, a more effective repair process.

4.

Si nificant Reduction of Maintenance Backlo The last SALP report noted an excessive backlog in the areas of both corrective and preventive maintenance items due, in part, to inadequate coordination and material unavailability.

During the prior SALP evaluation period, as 'assessed in the June 1990 report, the maintenance backlog stood at over 7200 corrective maintenance (CM) items and close to 1000 late preventive maintenance (PM) items.

TVA's aggressive efforts during system return to service activities resulted in a reduction of CM items to 636 and late PM items to approximately 20 at startup.

Management attention, combined with aggressive efforts by Maintenance,'have resulted in further reductions to the current level of approximately 250 CM items and zero late PM items.

Additionally, TVA has been able to perform this significant amount of work while reducing rework from a

high of approximately 4.5 percent shortly after startup to the current level of approximately 1.9 percent.

TVA continues to focus management attention on the CM backlog and maintenance work activities in general.

This is accomplished through the daily Maintenance meeting where work activities conducted over the previous 24-hour period are reviewed.

In addition, TVA conducts a weekly review of the maintenance backlog at POD meetings.

Furthermore, management attention and overall aggressive efforts by

TVA, such as consistently lowering goals and weekly reviews of the oldest work orders, maintain the low number of backlog CM and late PM items and low incidence of rework.

5.

Maintenance Peer Evaluation Pro ram During the assessment

period, TVA developed and implemented a

Maintenance peer evaluation program at BFN.

The program addresses a wide range of work activities from initial planning stages through documentation of completed work.

A comprehensive checklist of over 65 items is used in the evaluation process to assess work activities such as the use of personnel protective equipment, ALARAconcerns, verification of hold order boundaries, foreign material exclusion practices, and procedural adherence.

TVA's Corporate Maintenance organization provides valuable support to the Peer Evaluation Program.

Each week, a different representative from the Corporate Maintenance organization is scheduled to come to BFN to perform a peer evaluation using BFN's standard checklist.

The results of this individual's Page 21

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evaluation are compared to the results of the BFN peer evaluator's to ensure consistency in the reviews.

Evaluations are also critiqued to identify weaknesses and resulting conclusions are incorporated into the process so as to continually improve the program.

Additionally, peer evaluation checklist items are routinely trended by the BFN Maintenance organi'zation and appropriate corrective actions are taken when necessary to address adverse trends.

6.

Maintenance 8u ervisor Develo ment Pro ram On June 5, 1991, an event occurred at BFN during which primary containment was not maintained while the reactor was at power (this event is documented in NRC Inspection Report 91-23, dated June 21, 1991).

After an intensive self-assessment effort, TVA concluded that a

contributing factor involved management overview.

Thus, the event served as a catalyst for development of the supervisory development program for Maintenance personnel.

The program consists of six weeks of training: five off-site and the remainder on-site.

The first five weeks concentrate on team building, project management, speaking and writing skills, problem solving, supervisory skills, regulatory requirements, and technical skills.

The sixth week is devoted to Kepner-Tregoe analytical trouble shooting.

This type of training educates BFN maintenance supervisors, fosters

teamwork, and instills a

sense of ownership and responsibility throughout the organization.

TVA has assessed the effectiveness of this training effort through subsequent observation of trained personnel.

Based on this assessment, TVA considers that the training objectives have been achieved and put into practice at BFN.

This program was begun in November 1991 when the first group of BFN Maintenance supervisory personnel entered training.

To

date, three classes of approximately 20 persons each have completed the course, and a fourth class began training on April 12, 1992.

Key TVA management personnel routinely attend and participate in this training initiative to demonstrate TVA's commitment to the program.

Furthermore, a number of the individuals who have or will complete this training are expected to act as future instructors at BFN.

As such, the knowledge obtained in this endeavor will be brought back to BFN, thereby diminishing reliance on the use of contractors as instructors.

Page 22

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The current program to train existing and candidate Maintenance supervisors will be completed by June 15, 1992.

Future plans for this type of training course include the craft team building training discussed later in this section.

Additionally, TVA is evaluating plant and company-wide implementation of this program.

7.

Forced Outa e 8chedule In 1991, TVA developed and implemented a forced outage schedule at BFN.

This schedule provides a list of work activities that can be performed during all types:of forced outages, from short duration power reductions (3 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) to outages requiring cold shutdown.

The schedule is organized in relation to the specific work tasks that can be performed under each type of plant shutdown (e.g.,

power reduction, hot

shutdown, cold shutdown).

The schedule contains a forced outage duty roster, scheduled surveillance instructions, required preventive maintenance

items, and other work items ranging from corrective maintenance to plant modifications.

The schedule is updated on a weekly basis.

As new work items are generated, they are categorized and added to the schedule.

Design change packages for any modifications scheduled to be performed during a forced outage or shutdown are complete

and, where practical, revised primary and critical drawings are staged in the control room.

During a 1991 evaluation, INPO recognized the development and implementation of the BFN forced outage schedule as a strength.

This schedule was used at BFN during voluntary shutdowns in October 1991 and February 1992 to identify and repair unidentified leakage in the drywell.

During the October 1991 shutdown, approximately 97 work items and 42 surveillances were completed, in addition to identifying and repairing a leak in the drywell.

These activities were completed within approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of the, forecasted schedule.

During the February 1992

shutdown, roughly 213 work

items, 42 "surveillances, and 2

design.

changes were completed.

Additionally, about 41 unplanned emergent work items were completed, turbine vibrati'on problems were corrected, and leaks in the drywell were identified and repaired.

These activities were completed within approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of the forecasted

schedule, even though actual breakage was greater than that assumed in the forecasted schedule.

Implementation of the forced outage schedule demonstrates significant pre-planning and coordination between TVA's Work Control/Outage

Planning, Operations, Maintenance and NE organizations. It also reduces outage time.

Furthermore, this scheduling method has proven to be an invaluable tool to ensure that outage-related work is performed efficiently and safely.

To further refine the forced outage

schedule, TVA performs critiques on each outage or shutdown in which the schedule is used.

Critique results provide for continued enhancement and improvement of the forced outage schedule.

The forced outage Page 23

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schedule was also enhanced in February 1992, prior to the latest voluntary shutdown, through implementation of the newly approved NUMARC guidelines to reduce shutdown risk.

8.

Maintenance Tren4in Pro ram TVA has developed a comprehensive equipment history trending program at BFN to promptly identify and evaluate repeated equipment failures.

Trending is performed primarily through use of the MPAC computer program.

Specifically, on a monthly

basis, TVA generates a computer printout of component failures sorted by the BFN unique identifier, using a threshold of two failures within the previous 12-month period.

Any trends identified are evaluated by both the Maintenance and Systems Engineering organizations at BFN.

On March 22,

1992, TVA upgraded maintenance trending

.- capabilities at BFN through implementation of a computerized root cause analysis system to assist in evaluation of component failures.

This new system utilizes Kepner-Tregoe analysis techniques and prompts the user to address specific causal factors when classifying equipment failures, thereby ensuring thorough root cause evaluations.

Areas for Further Im rovement 1.

Trainin an4 Control of Contractors TVA recognizes that one of the most significant areas for continued improvement is the training and control of contractors.

One. of the measures TVA has already implemented in this area involves procedural requirements and responsibilities for contractors.

For

instance, these requirements specify that prior to performing work the contractor must specify organizational structure, procedures to be utilized and work control mechanisms.

Nevertheless, during the upcoming assessment period TVA will continue to focus on identifying and understanding the root causes of any weaknesses in this

area, and will also continue to focus increased management attention on the training and control of contractors.

With respect to training, the unit separation video, which is a part of initial employee

training, provides a

detailed overview of unit separation requirements and control of access to Unit 2 for incoming personnel.

Another specific area where TVA has implemented improvements for contractor training is the program for qualification of contract welders.

The elements of this program include re-certification of contractor

welders, as well as initial certification of new welders..

The certification program consists of program instruction and performance of all weld details, for which a welder is to be qualified, in the presence Page 24

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of a certified instructor, followed by destructive examination of all welds to ensure weld adequacy.

Subsequent to initial re-certification, each welder is required to pass an abbreviated requalification test if he has not welded in the plant during the past 90 days.

These procedures not only satisfy ASME Section 9 code requirements but also ensure that BFN contract welders maintain proficiency in the weld processes they have been qualified to perform.

2.

Craft Team Buildin Trainin Pro ram Based on the successful implementation of the supervisory training program, and the benefits achieved to date using the

program, TVA has developed a similar program for Maintenance craftsmen.

This craft team building training program will consist of a one-week session focusing on team building and customer

focus, and will also review the concepts of the supervisory training program.

The session will be led by the craft's foreman and general foreman.

The program will be initiated by August 20, 1992.

TVA will complete initial training of existing Maintenance craft personnel by March 23, 1993.

3.

Reliabilit Centered Maintenance RCM and Preventive Maintenance PM Pro rams The BFN Maintenance organization is in the process of enhancing the PM program by implementing the RCM program.

The RCM

program, which will utilize personal computer-based

software, is a programmatic approach to the development and optimization of plant maintenance.

RCM also utilizes probabilistic risk analysis (PRA) techniques, such as a decision logic tree, to identify equipment maintenance requirements according to safety and operational consequences, as well as the responsible degradation mechanism of each failure.

Once fully instituted, this system will integrate RCM approaches with failure trending, root cause analysis, and craft feedback to ensure a

superior program from the standpoint of safety and reliability.

TVA will begin loading the first systems into the RCM program by June 23, 1992, and is currently targeting completion of this long-term project for November 1993.

4.

Continue Mana ement Focus on Personnel Performance In TVA's response to the June 1990 SALP report, TVA identified reducing personnel errors as an area for further improvement.

TVA noted that the personnel error problem had several major

causes, including lack of attention to detail, lax attitude toward procedural adherence, inadequate procedures and poor human factors considerations.

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TVA considers that BFN Unit 2's performance during the assessment period demonstrates that TVA has made significant i'mproyement in the area of personnel error reduction.,

For

example, TVA management stressed and'ontinues to consistently emphasize the importance of strict procedural adherence.

TVA considers that this strategy has worked to nearly eliminate the previous lax attitude.

Notwithstanding, these accomplishments and the progress made to

date, TVA is mindful that further improvement is necessary to make BFN a

top performing plant.

.Accordingly, TVA will continue to focus management attention on personnel performance in the upcoming assessment period.

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ZV FUNCTIONAL AREA - EMERGENCY PREPAREDNESS The NRC SALP Board rated performance in this functional area as Category 2, Improving, in the June 1990 evaluation.

Apart from a concern about the timeliness of TVA's implementation of measures to improve notification and evacuation of personnel in high-noise areas (Inspection and Enforcement (IE)

Bulletin 79-18, "Auditability Problems Encountered on Evacuation of Personnel From High-Noise Areas" ), no weaknesses or problem areas were identified in the previous SALP report.

Nevertheless, TVA has continued to strive for improvement in this area and, in order to become a top performer, has undertaken the measures described below.

Ma'or Accom lishments-1.

Enhanced Trainin Durin Drills h Znitiatin Use of Simulator Safet Parameter Dis la S stem SPDS and Mocku s During the assessment

period, TVA significantly improved the conduct of

-emergency response drills.

One of these improvements involves use of the plant simulator.

The simulator:, first used during the March 25,

1992, quarterly training drill, enhances emergency response training by providing emergency data that is more realistic, accurate, and timely.

This eliminates the pre-existing system of handing sheets of paper describing the emergency scenario or plant status changes to plant personnel, which resulted in time delays in emergency response actions.

TVA implemented the interim SPDS during the September 11, 1991, dress rehearsal for the graded exercise.

TVA will complete installation of the permanent SPDS during the Unit 2, Cycle 6

refueling outage.

Use of the system allows plant conditions to be displayed on the interim SPDS in the Technical Support Center (TSC),

as well as in the offsite central emergency control center.

TVA enhanced use of the interim SPDS on March 25,

1992, by connecting it to the simulator.

This connection enables the simulator to provide interim SPDS data

and, therefore, results in more realistic drill scenarios and better emergency response training at BFN.

Another improvement -made by TVA during the assessment period involved the use of mockups during emergency response drills.

.Mockups were first used during the September 11,

1991, dress rehearsal for the graded

exercise, and subsequently were employed during the October 23, 1991, graded exercise.

Mockups were also used during the three training drills conducted in January and February 1992; the March 25,

1992, quarterly training drill; and during a medical training drill conducted on March 11, 1992.

The mockups used include a reactor core isolation cooling system pump and valve (with a broken coupling Page 27

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f

on the valve), control rod drive motor repair activities, a

broken control air system

line, and, for purposes of the medical drill, spilled drums of simulated torus sludge which caused personnel to become severely contaminated.

Use of the mockups further enhances the emergency exercise scenario.

During the October 23, 1991, graded exercise, use of the mockups was one of the factors that allowed TVA to identify weaknesses in communications between emergency response

centers, which is discussed in more detail below.

These improvements enhance training during the drills by providing a more realistic scenario, which in turn ensures that emergency response teams are better prepared for an actual emergency, should it occur.

2.

Im roved Communications Between Emer enc Res onse Centers During the assessment

period, TVA initiated many hardware and software enhancements to the emergency response centers to improve communications within each center and communications between centers.

For

example, on October 21,

1991, TVA upgraded the emergency center status boards by adding electrical system and mechanical system boards.

These large-scale boards contain simplified drawings of major plant components and allow Operations Support Center (OSC) staff to quickly determine the status of affected plant components.

In addition, following TVA's assessment of the October 23,

1991, graded

exercise, TVA identified the need to further improve communications between the emergency response centers.

This area for improvement was also identified by the NRC.

Subsequently, TVA developed a

prompt set of comprehensive actions to address this communications issue.

One of these actions involves the addition of automatic-dialing telephones in mid-March 1992 for each emergency responder position in the OSC.

The direct dial telephone numbers of key TSC personnel are pre-programmed into the new telephones, thereby improving communications between the two centers.

TVA also installed telephone headsets for some positions in both the TSC and OSC that require continuous telephone communications.

Telephone headsets are more comfortable, easier to use, and allow freer movement of personnel.

Another OSC improvement includes the addition of a 911 terminal with the capability to identify the telephone number of any person calling in a fire or medical emergency.

On March 25, 1992, TVA, added computer terminals in the OSC that access the MPAC database.

These terminals allow maintenance personnel to verify material availability on necessary repair parts before dispatching repair crews.

Thus, this improvement feature decreases the time necessary to obtain repair materials during emergencies.

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TVA also initiated administrative improvements to enhance communications between BFN emergency response centers.

For

example, on February 12, 1992, TVA established the Team Manager position in the OSC to take requests for repair

.and surveillance teams from the TSC.

This new position removed some of the administrative duties previously performed by the OSC Director, thereby enhancing the ability of the OSC Director to communicate with the TSC and OSC staffs.

TVA also conducted practice drills on January 21, February 12, and February 20,

1992, with each of the three emergency response

teams, respectively.

These practice drills were specifically focused on communications issues and emphasized the, importance of good communications.

Key members of each of the threeteams observed their counterparts during performance of these drills, enhancing their knowledge of overall emergency response capabilities.

These actions have significantly improved communications between the emergency response centers.

Nevertheless, TVAwill continue to search for additional methods to further improve communications.

3.

Cor orate and Plant Mana ement Involvement in 8ite Activities TVA's performance in'his functional area is greatly enhanced by corporate and plant management's involvement in emergency preparedness activities.

For example, corporate support of site emergency preparedness activities is.provided through monitoring and maintaining the prompt notification system (PNS).

The effectiveness of this effort is demonstrated by PNS operability of greater than 99 -percent during the assessment period.

Additionally, corporate management coordinates a

cooperative effort between site and corporate emergency preparedness staffs to develop and implement emergency exercise scenarios for graded exercises and dress rehearsals.

Corporate emergency preparedness management also participates in periodic site meetings with site management to exchange information and engage in joint problem resolution.

These periodic meetings foster an attitude of cooperation and improve working relationships.

Corporate management also frequently calls on emergency response personnel from other TVA sites to assist in drills.

4.

Increased Attention on Emer enc Res onse Performance During the assessment

period, TVA has focused increased management attention on improving emergency response training during drills and exercises.

Some of the improvements implemented as a result of this increased management attention, discussed in greater detail

above, include using the plant simulator during drills, OSC communications improvements, and the three additional practice drills conducted in January and February 1992.

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TVA has taken steps to increase the sensitivity of plant personnel to emergency response responsibilities.

For example',

in June

1991, TVA instituted weekly notification and response tests of emergency response personnel.

TVA schedules these tests to coincide with transfer of emergency response responsibilities from one emergency response team to another.

The timing of this test also serves to reinforce the responsibilities to the incoming team.

Management attention on the results of these tests is provided through weekly review of test results during POD meetings.

TVA has also identified an additional action to increase the sensitivity of plant personnel to emergency response responsibilities.

Specifically, in 1992, TVA will initiate

,off-hours staff augmentation drills for all three emergency response teams.

Previously, in Inspection Report 91-39, dated November 6, 1991, TVA informed NRC that it would be performing only one test annually.

TVA considers this additional enhancement to be a graphic indication of TVA management's commitment to excellence with respect to emergency response capabilities.

5.

Communit Relations TVA enhanced its relations with local communities during the

.assessment period through increased involvement in community affairs (e.g., providing access.to the plant to area residents; and civic, government, and business leaders),

and continued focus on providing timely and accurate information to print and broadcast media representatives in the general plant area.

For

example, effective January 1,

1992, the BFN Emergency Preparedness Manager became the chairman of the Morgan County (a

neighboring county)

Industrial Emergency Association.

Previously, he had served as a member of the association since 1988.

Participation in this association improves TVA's relationship with neighboring industries and communities.

TVA also routinely conducts plant tours and briefings for area

business, professional,

civic, customer.,

and governmental groups located in the general plant area.

Additionally, TVA continues to conduct quarterly meetings with the Alabama Emergency Management Agency, the Alabama Radiological Health Department, and the surrounding four counties'mergency agencies located within, a ten mile radius of BFN.

During the assessment period TVA continued to strive to improve its working relationship with broadcast and print media representatives in the general plant area.

This includes 5

daily newspapers, 4 television stations, and numerous radio stations.

The work involved includes providing timely and responsive information about TVA

events, coordinating interviews with TVA managers

and, most importantly, ensuring that the media representatives understand plant operations and how to obtain timely and accurate information when emergency response plans are put into effect.

Page 30

Areas for Further Im rovement Com lete Im lementation of Res onse to IE Bulletin 79-18 As discussed in TVA's response to the June 1990 SALP report, TVA will complete the upgrade to BFN's public address and alarm system. prior to startup from the Unit 2, Cycle 6 refueling outage.

To date, TVA has completed implementation of Phase I of the upgrade project.

This included installation of 4 radio repeatersg installation of a Radiax cable which provides better 2-way communications in the.plant, including high noise and infrequently traveled areas; and expanded capability of the radio system in high-noise areas.

To complete the upgrade project, TVAwillinstall strobe lights to provide visual notification in high noise areasg expand the use of alarm bells; replace existing speakers with improved speakers which more accurately reproduce sounds; and replace mechanical sirens with electronic sirens, which allow better control of siren tones.

Installation of these modifications in accessible areas of the plant will begin prior to the refueling outage.

2.

Im lementation of Revised Emer enc Action Levels EALs As part of TVA's ongoing commitment to incorporate industry advances into the emergency preparedness program at

BFN, TVA will be developing revised plant-specific EALs for BFN.

These revised EALs will be based on the NUMARC methodology contained in NRC Draft Regulatory Guide DG-1022, Emer enc Plann n

a d Pre aredness for Nuclear Power Plants.

The revised EALs will provide updated information to be used in the classification of emergencies.

Use of revised EALs is also expected to reduce the number of unusual events declared at BFN.

Following NRC approval of the NUMARC methodology and issuance of the final regulatory guide,

.TVA will incorporate the revised EALs into the radiological emergency plan.

3.

0 radin Radiolo ical Emer enc Res onse Ca abilit During the assessment

period, TVA initiated steps to improve radiological emergency response capability at BFN.

Specifically, TVA purchased an upgraded radiation monitoring van for BFN.

This vehicle, which was assigned to BFN on September 7,

1991, is used to respond to transportation accidents, radiological emergencies, and'edical emergencies involving transportation of individuals who are injured and radiologically contaminated; and provide environmental monitoring within the emergency planning zone.

In Inspection Report 91-30, dated September 25,

1991, NRC recognized the use of this van as a program strength.

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'This new vehicle,was designed by 'TVA personnel using human factors improvements.

For

example,

.the new vehicle, has a

larger.working area, a buffer zone between the contaminated area and the clean area, upgraded counting, equipment, cellular telephones, and built-in electric generators.

The latter improvement obviates the need for personnel to exit the vehicle into a potentially contaminated area to set up and start the generators.

The state-of-the-art capabilities of this van have also been recogn'ized by.,other industry organizations.

For example, an identical van used by TVA's central emergency control center was displayed -at the American Nuclear Society's 1991 annual emergency preparedness conference.

This vehicle significantly improves BFN's radiological emergency response capability.

Nevertheless, to further improve in this area, TVA will purchase a

second upgraded radiation monitoring van to replace the existing second van,by May 11, 1993.

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V FUNCTIONAL AREA - SECURITY This functional area was assessed a Category 2 rating in the 1990 SALP report.

Problems were identified in the control of Special Nuclear Material (SNM) inventories.

Two Severity Level IV violations were also cited in the 1990 SALP report for failure to control safeguards information and protected area access.

Thus, the need for improvement was evident.

The resulting improvements, however.,

go beyond those necessary to simply address the problems identified in the June 1990 SALP report.

TVA's work in this area is by no means complete.

For

example, TVA.continues to concentrate on improving control of SNM inventories.

Additional improvement efforts targeted at this functional area are detailed in the section below.

Nevertheless, TVA has laid the groundwork essential to progressive improvement in this area throughout the coming assessment, period.

Ma or Accom lishments 1.

SNM Accountabilit To address previous SNM inventory issues raised in NRC Enforcement Action 89-239, TVA developed a comprehensive three-phase plan in 1990 to complete non-fuel SNM storage activities.

Phase I of the plan consisted of performing extensive plant searches and detailed piece counts.

High level radwaste barrels and lead bricks were opened, and searches were made in the spent fuel storage pools (SFSPs).

SFSP searches involved the use of robots and video equipment to provide a detailed piece count.

In

addition, TVA reinventoried previously packaged shipping liners and defined specific SNM storage areas within the SFSPs.

Phases XI and III consist of a

cleanup of the SFSPs and disposal of non-fuel items stored in the SFSPs.

The cleanup efforts provided TVA with a validation of the SFSP inventory and facilitated maintenance of the inventory.

These items include boxes,

brushes, cold end material, and miscellaneous fuel assembly parts.

The disposal efforts will involve removal and disposal of known non-fuel and non-essential components.

As TVA discussed in its November 27, 1991, letter to the NRC responding to a notice of violation, removal of the non-essential components, excluding the stellite

rollers, is expected to be completed by June 1, 1992.

Additionally, final videotaping is expected to be completed by July 1, 1992.

TVA has also procured the services of a consultant to review TVA's SNM program and provide additional suggested improvements to further reduce the probability of future problems.

This individual is currently on site and is expected to complete a

preliminary assessment of TVA's program by May 15, 1992.

Page 33

2.

New Detection F. i ment Just prior to the assessment

period, TVA purchased and implemented new detection equipment at BFN.

The resulting improvement in BFN security capabilities,

however, has been realized during the assessment period and, for that reason, is treated as a major accomplishment for purposes of the current evaluation.

Specifically, security at BFN has been improved due to the acquisition

-and use of new detection equipment including perimeter cameras-,

improved metal detectors at plant access

points, an X-ray machine capable of performing bulk monitoring, and upgraded perimeter detection systems.

In April 1992, security officers also began using newly acquired hand-held metal detectors.

These

devices, proven effective by the military and law enforcement

agencies, allow for quick and reliable identification of metallic items.

In

addition, they speed up the visual observation

process, are useful in determining the location of suspect

items, and are designed to provide high sensitivity to metallic objects while retaining a reasonably large search field.

3.

Wea on U

rades Two weapons upgrades transpired during the assessment period which have further improved the effectiveness of BFN Security.

In December

1991, TVA completed the transition from use of Smith

& Wesson

.38 caliber, six-shot revolvers to Sig-Sauer

9mm, 15

round, semi-automatic handguns.

In addition, TVA transitioned from the use of the Ruger Mini-14 rifle to the Colt M16A2 rifle in June 1991.

Both the Sig-Sauer handgun and the Colt M16A2 rifle are considered to be more reliable and provide more firepower than either predecessor weapon.

They are ergonomically designed to facilitate comfortable and instinctive shooting and provide BFN Security officers with weapons that incorporate design improvements that meet or exceed regulatory requirements.

4.

Or anizational Im rovements and Hei htened Mana ement Interaction A number of organizational improvements were implemented during the assessment period that have resulted in improved performance in this functional area.

On March 9,

1992, the Security work force schedule was revised, in direct cooperation with affected personnel, to eliminate rotating shifts and place security officers on straight shifts.

The result is improved officer morale, greater shift continuity, and better direction of line supervision.

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In November 1991, TVA initiated weekly and monthly round table discussions between security management and staff.

These discussions facilitate the identification of potential,probl'ems and formulation of corresponding resolutions.

More importantly, they provide an open channel of communication between management and staff.

A beneficial by-product of this effort is improved morale within the BFN Security organization.

TVA is also providing Customer Focus Training to BFN security personnel to aid in the identification of customers at all levels.

This training was initiated on March 16,

1992, and is scheduled to be completed by July 28, 1992.

As a result, working relations have improved within the Security organization, with other plant organizations, and with contractor and non-TVA personnel.

Finally, TVA established a coordinator position for Unit 3

recovery work in June 1991.

This has not only improved manpower utilization of Security personnel assigned to Unit 3 but also improved the working relationship with restart management (TVA and contractor).

5.

Pro rammatic and Administrative Im rovements Several improvements of a

programmatic and administrative nature have been implemented during the assessment period.

The Contractor Information

System, a

computerized system which contains pertinent information relative to site contractor employees, has been re-assigned. from the BFN Employee Relations and Development (ER&D)

.organization to the Security organization.

This transfer allows Security direct access to pertinent contractor status information and allows Security to maintain better access control of contractor personnel.

In October 1991 TVA developed and implemented a

contractor orientation package to improve contractor awareness.

of BFN security requirements.

This package contains pertinent badging information, access control guidelines, and other physical security requirements.

As discussed in greater detail

below, there have also been improvements in the safeguards information (SGI) program, such as additional training and the replacement of old-style locking bars on safeguards cabinets.

TVA also implemented a tracking and trending program for the control of security-related work requests in January 1992.

This system not only expedites the identification of security equipment problems but also reduces security compensatory measures due to inoperable/malfunctioning equipment.

In addition, TVA implemented a Training Records Audit Program in June 1991.

It established a guideline for the review and audit of security force task qualification records.

Thus, it provides guidance pertinent to the conduct of training and Page 35

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k y'I qualification, creates a separate suspension file of annual qualifications that are incomplete, provides Security management with documentation verifying the completion of re-qualification phases, and.provides for weekly review,of monthly training and qualification scores.

6.

Securit Procedure U

rade TVA completed a procedure upgrade in March 1992 that reduced the number of Security Site Instructions from seventeen to three.

The result is.

more user-friendly, human factored procedures.

In particular, major security requirements were incorporated into a single procedure.

This change enables site employees and contractors to better understand and comply with security rules and regulations, thereby reducing the potential for regulatory violations.

An internal.security procedure audit was performed by Security supervision to ensure the adequacy of procedures to satisfy both regulatory and TVA requirements.

7.

Im rovements in Safe ards Cpm liance TVA completed the establishment of designated classifiers for SGI in August 1991, which is expected to reduce the number of documents that potentially can be incorrectly classified.

TVA has 'reduced the number of SGI storage containers on site, to decrease the likelihood of an SGI event.

TVA also replaced the site manufactured locking bars on SGI cabinets with factory manufactured, bars in May 1991.

This should reduce the probability of an SGI cabinet being surreptitiously opened.

SGI training requirements were broadened by providing basic SGI training for site employees during general employee training.

This revised training curriculum was implemented in June 1991.

A review of BFN safeguard drawings for correct classification was completed in February 1992.

This effort resulted in a declassification of drawings that no longer meet the SGI criteria.

As a result, the likelihood of an SGI event has been reduced.

Site Security has also assumed responsibility for SGI distribution to ensure more stringent control and to aid in maintaining continuing compliance.

8.

Securit Personnel Trainin Security personnel have been provided"with additional training during the assessment period for the purpose of improving their performance in the field.

In October and December

1991,

,Security officers were provided transitional training in the use of the Sig-Sauer 9mm handguns and the M16A2 rifles.

Training was also provided in the use of hand-held metal detectors in February 1992.

Precision marksmanship training was completed in April 1991.

The latter type of training is Page 36

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designed to provide TVA with a

select group of officers specifically trained in the

.use of telescopically equipped rifles and to meet the NRC requirements for establishing a

deterrent.

to the land-vehicle bomb threat.

The benefits of this training have been realized in the current SALP period.

Special fitness for duty training was provided to Security Supervisors throughout the year and was completed in March 1992.

This training establishes administrative controls and

.provides requirements and processes for the handling of drugs and suspect substances found onsite.

Security personnel refresher training is provided on an ongoing basis to re-familiarize personnel with required

weapons, provide an opportunity to practice marksmanship skills, provide an update of security systems

upgrades, and familiarize personnel with unit, separation requirements.

In addition, a

local law enforcement agency (LLEA) seminar was completed in March 1992.

This seminar assisted in the development of a

working relationship with law enforcement agencies that have agreed to provide response capabilities.

In addition, the

.seminar served to familiarize LLEA officials with BFN Security management.

personnel, site equipment, site

layout, etc.;

confirm LLEA agreements; and open an avenue for mutual exchange of technical information.

9.

New Bad in Process In response to an incident that occurred prior to the assessment

period, TVA revised'ts badging process to

,strengthen control of personnel access.

For

example, TVA established new employee check-in/check-out requirements and a contractor access control procedure.

TVA also provided additional training on employee and contractor access control requirements.

Furthermore, TVA now provides a security access control instruction bulletin to employees upon initial check-in.

Another aspect of TVA's. revised badging process is the installation and implementation of new badging equipment at BFN.

This state-of-the-art equipment adds the capability to electronically store an individual's picture along with other vital information required for badging.

This improvement will expedite the badging process and improve BFN's capability for handling large numbers of transient workers.

10. Fitness for Dut Pro ram Im rovements During the assessment

period, TVA revised the layout of the BFN testing facility to provide work stations with attached bathrooms, which in turn are isolated from normal traffic flow.

This change precludes non-test personnel from entering the testing

area, reduces the potential for compromising the

sample, and improves overall control of test specimens and personnel in the testing area.

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In addition, TVA upgraded its fitness for duty program by implementing procedural requirements for individuals who test below the cut-off level for alcohol, but have a measurable reading.

TVA now requires the ER&D organization and the individual's supervisor to review the individual's fitness for duty if that individual's blood alcohol level measures between 0.02 and 0.039 during testing.

The ER&D representative and the individual's supervisor will then make a determination on whether to allow that individual to return to. work the day he or she is tested.

This new requirement provides further assurance that individuals performing work are free from the effects of any substance which could adversely affect their ability to perform work safely and competently.

Any individual testing in this range is also referred to TVA's Employee Assistance Program for counseling.,

Additionally, any applicant who tests within the 0.02 to 0.039 range during pre-employment testing will not be hired by TVA.

Another improvement initiated in this area involves the implementation of procedural requirements for the handling of drugs and suspect substances found on site.

These new procedural requirements.

specify that any suspect substance found on site is to be transferred to the Medical organization, where chain of custody will be established.

The Medical organization is then responsible for ensuring that the substance is forwarded to TVA's laboratory for analysis.

This change provides for a stricter chain of custody.

Areas for Further Im rovement 1.

Securit U

rade Pro ect TVA is essentially complete with the design for the

$ 24 million security upgrade project at BFN that will improve and enhance the overall security program throughout the coming assessment period.

In November 1991, TVA established the security project coordinator position to coordinate transition requirements, manpower utilization and other regulatory issues associated with the project.

State-of-the-art security equipment to be installed as part of this project includes new central and secondary alarm stations, personnel access

portal, security computer

system, protected area perimeter barriers and associated intrusion detection system and closed circuit television assessment

system, and access control equipment for the vital area portals.

In addition, an alarm station training simulator has been installed to train BFN Security personnel on the new central alarm station and secondary alarm station.

Other aspects of this project include an upgrade and on-going review of plans, procedures, and site instructions, as well as improvements in the self-audit program.

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RUNCTZONAL AREA ENGZNEERlNG/TECHNZCAL SUPPORT Performance in this area was rated as Category 2 in the June 1990 SALP report.

A limited number of problem areas were identified in the evaluation.

For instance, the Staff noted that the simulator had fidelity probl'ems, and that EOIs were not considered to be user-friendly.

The Staff also noted that there was a large number of drawing deviations (drawing discrepancies),

and that inconsistencies existed between procedural time limits for revision/correction of primary drawings significant to plant operational safety.

Significant corrective actions have been implemented at BFN.

Organizational and procedural improvement efforts are detailed below.

These actions are indicative of sweeping improvements in this functional area.

Ma'or Accom lishments 1.

Simulator U

rade Pro ect In December

1991, TVA culminated its simulator upgrade project by certifying the BFN plant-referenced simulator in accordance with 10 CFR 55s45(b)(5).

In comparison to other facilities, TVA considers this certification, with a minimal number of exceptions, to be a significant accomplishment.

BFN's plant-referenced simulator has completely upgraded software and new computers.

The new simulator now features state-of-the-art

modeling, reactor core and thermal hydraulics

modeling, extensive electrical system

modeling, and an updated instructor's station.

Much of the advance modeling allows performance of the simulator to exceed American National Standards Institute (ANSI) standard ANS-3.5 (1985) requirements for simulator certification.

During the upcoming assessment

period, TVA will be upgrading the simulator to implement changes required by the Control Room Design Review (CRDR) project and installing integrated computer system (ICS) software.

TVA currently plans to make the CRDR changes to the simulator prior to actual implementation of the modifications in the field.

The underlying purpose of this schedule is to allow operator training on the changes prior to restart from the Unit 2, Cycle 6 refueling outage.

TVA also plans to implement the ICS changes to the simulator first to permit time for operator training prior to operating the ICS in the plant.

2.

~Drawin s As noted in the introduction to report noted a large backlog of During the prior SALP evaluation 1990 report, the number of DDs aggressive efforts during system this section, the last SALP drawing discrepancies (DDs).

period, assessed in the June stood at over 2000.

TVA's return to service activities Page 39

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resulted in a reduction of DDs on primary and critical drawings from approximately 1575 in June 1990 to zero by startup.

Since that time, management attention has been focused on revising drawings as discrepancies are identified.

Currently, no backlog of primary and critical drawings exists.

With respect to secondary

drawings, TVA has developed and implemented a

program to upgrade and maintain secondary drawings at BFN.

This program involves resolution of "D"

design change notices or "DDCNs" (DDCNs are the vehicle used to identify potential discrepancies between plant configuration, and the current as-constructed drawing) as they are identified, procedural steps that require updating secondary drawings as plant modifications are completed, and aggressive management attention towards reducing the backlog of secondary

drawings, and the backlog of DDs on secondary drawings.

To date, the above efforts have resulted in reduction of the backlog of secondary drawings from a high of nearly 23,000 at startup to the current level of less than 6000.

In addition, the backlog of DDs on secondary drawings 'has been reduced from nearly 3800 at startup to the current level of approximately 2550.

3.

EOI Im rovements TVA's response to the June 1990 SALP report stated that TVA was in the process of upgrading BFN's EOIs to implement Revision 4

of the BWR Owners Group Emergency Procedure Guidelines (EPGs).

TVA stated that this upgrade would be completed by December 31, 1991.

Notwithstanding this future upgrade, TVA also stated that the EOIs had been revised to increase emphasis on logic statements, and that the EOIs and writer's guide had also been revised to clearly define conditions under which logic diagrams are to be used.

In addition to the revision noted above, TVA further revised the EOIs prior to startup of Unit 2 to support restart and to improve human factors considerations by placing more emphasis on logic terms, action verbs and conditional statements.

This revision also improved references to conditional statements and the format in which these statements were presented.

Furthermore, this revision segregated procedural requirements from the graphs,

tables, charts and supporting information by placing the procedural requirements on one page and the remaining information on the facing page (previous page).

With regard to implementation of Revision 4'f the

EPGs, as noted in TVA's September 20, 1991, letter to the Staff, TVA stated that due to startup of Unit 2 and the manpower needed to support restart, full implementation of the revised procedures would be completed by June 15, 1992.

Currently, TVA has completed development of the new procedures which utilize the flow-chart format, with the exception of incorporating minor training comments.

Additionally, on August 19,

1991, TVA initiated training on the new procedures.

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En ineerin Su ort of the Plant The BFN NE organization has continued to work closely with plant personnel to ensure safe continued operation of the unit.

During this assessment

period, TVA formed a dedicated group within NE to support plant operations.

Additionally, during forced outages and voluntary shutdowns, NE provides around-the-clock coverage to provide more timely response to emergent work items.

NE's support of the plant is evidenced by its participation in the Plant Operations Review Committee (PORC),,

the daily attendance of key NE management at Unit 2 POD meetings, and its membership on the Management Review Committee (MRC).

The MRC is a site-level review group responsible for the initial review of potential adverse conditions and determination of whether a condition meets the criteria for a

Significant Condition Adverse Report (SCAR) or inclusion in the corrective action program.

Many other daily activities further demonstrate the continued support NE, provides at BFN.

As discussed previously in the Maintenance/Surveillance functional area, NE works closely with outage planning.

personnel to ensure the pre-planning and completion of design change packages for modifications scheduled to be performed during forced

outages, prior to commencement of plant shutdown.

Evaluations of the safety significance of conditions identified in SCARs and problem evaluation reports are also promptly performed by NE.

Consistently, the engineering evaluations provided by NE are technically accurate and performed in a timely manner.

For

example, on June 5,

1991, TVA experienced a loss of primary containment 'integrity when both drywell personnel airlock doors were simultaneously open for a period of approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

Prompt evaluation by NE enabled TVA management to quickly assess the safety consequences of the event.

5.

Com rehensive Desi n Closure Process Another key strength of BFN's NE organization i;s the design change closure process.

A principal obj'ective of this process is to promptly close engineering documentation following completion of plant modifications.

This minimizes the probability of future engineering problems.

At BFN, TVA goes beyond ensuring engineering documentation is promptly closed following completion of plant modifications.

For example, prior to closing the design paperwork, TVA issues primary and critical drawing revisions depicting, the revised plant configuration, and removes unverified assumptions from affected calculations.

TVA also ensures that required post-modification tests are evaluated and the plant has accepted the Page 41

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modification and, in fact, returned the system or component to service.

At BFN, these elements are not just a good practice but are procedural requirements.

6.

Desi n Chan es During the assessment period TVA continued to maintain the high quality of design changes for BFN.

This is evidenced by the low rejection rate of proposed design changes by PORC.

Additionally, the low number of field changes issued per parent design change due to design error provides further evidence of'he quality of design changes.

BFN's Modifications organization was also instrumental in improving the design change/modification process.

First, modifications personnel work closely with NE personnel to ensure that design change packages are "workable" when issued.

This is accomplished by performing constructability walkdowns of proposed design changes during the design development process.

As a result of this close working relationship, higher quality design changes are implemented and the number of field changes is minimized.

Second, in August

1991, the Modifications organization completed development of and began using a

custom computer program to generate the workplans that install design changes.

This interactive work plan writing program is user-friendly and ensures requirements such as fire watches and procedure usage are specified in the work plan.

This is accomplished by prompting the writer to answer questions basic to any work plan.

For example, the user is prompted to specify procedural requirements, whether fire watches are necessary, and whether hold orders are necessary.

The program not only ensures that plant administrative controls are addressed but also that consistent quality workplans are delivered to craft personnel to perform work.

Use of this program has minimized personnel errors associated with work plan writing, thereby resulting in overall process improvement.

7.

Vendor Manual Pro ram At

BFN, TVA has tasked NE with the responsibility of maintaining the vendor manual

program, to benefit from NE's technical expertise.

TVA's objective for the vendor manual program is to ensure that site personnel have up-to-date manuals to use as a reference in completion of work activities (e.g.,

work orders, work plans, design changes).

Review and control requirements for vendor manuals at BFN are documented in plant procedures, and are based on the guidance provided in INPO Good Practices87-009, Control Vendor Manuals, and 88-022, Vendor Manual S ecification and Procurement.

For

example, new vendor manuals or revisions to existing manuals are reviewed by NE to ensure BFN programmatic requirements are incorporated.

The manuals are then reviewed by appropriate Page 42

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plant organizations for impact on and/or implementation in programs and procedures.

Technical changes to manuals are processed by NE in a timely manner to support use by plant personnel.

This.is an example of NE's strong "customer focus" to the plant.

This program was cited as a strength by ZNPO in 1991 and by the NRC during the Operational Readiness Assessment Team inspection and the inspection of BFN's motor-operated valve testing program.

This program greatly enhances the ability of plant organizations to perform work and is another example of NE's involvement and close support of the plant.

8.

Research and Develo ment Znvolvin the Control Room Emer enc Ventilation 8 stem Historically,.BFN has experienced a problem with leakage into the control room emergency ventilation system.

TVA committed to correct the problem prior to restarting Unit 2 after the next refueling outage.

Early in the assessment

period, TVA believed it would have to perform significant modifications which, during implementation, would have interrupted'operations activities in the control room.

In light of this situation, NE initiated research and development activities to identify a better solution.

These activities led to the development of a technically innovative solution that would not significantly impact control room activities.

Testing of the new method is currently ongoing, and TVA fully anticipates successful results.

Nevertheless, TVA is also concurrently pursuing-a parallel approach should the new methodology fail.

9.

8 stem En ineerin Su ort

-The systems engineering program at BFN has, for some time, been recognized as a strength.

In the NRC's Maintenance Team Inspection, dated March 26, 1990, the system engineering group was noted as a significant strength.

Throughout the assessment period, the BFN system engineering group continued to provide thorough support for maintenance and operational activities.

BFN system engineers assist in troubleshooting and repair, and also apply a

philosophy of ownership to their respective systems.

As a result, they have been instrumental in ensuring

safe, continued plant operations.

For example, on August 26, 1991, during a routine walkdown of one of his systems, a

BFN system engineer discovered a main steam line flow spiking problem.

Recognizing that flow spikes in the main steam lines could cause a plant scram, the system engineer immediately initiated and directed analysis and testing actions to identify and correct this anomaly.

Through analysis and testing, the system engineer identified the cause of the problem and implemented a solution.

TVA believes that this individual's efforts prevented a Unit 2 scram.

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'Another example of system engineer.

ownership, and timely and thorough investigation and resolution of problems, occurred on January 16, and 17, 1992.

Zn this event, a system engineer observed higher than normal hydrogen consumption by the main turbine generator.

He performed a leak inspection of the main turbine generator and identified two leaks, both of which were promptly corrected.

As a result of this effort, hydrogen consumption was reduced from approximately 1340 to 600 cubic feet per day, which is approximately 60 percent of the normal or average hydrogen consumption specified by the vendor.

A third example of system engineer troubleshooting of plant systems occurred on October 28, 1991.

Zn this instance the system engineer postulated that the erratic level indications on one of the feedwater heaters were caused by a tube leak in the heat exchanger.

The system engineer coordinated adjustment of the level transmitter and the level indicating controller to prevent nuisance alarms in the control room.

The system engineer also recommended continued operation of the system, until the unit could be shut down, with higher than normal water levels to protect from further tube damage.

During the February 1992 voluntary

shutdown, the system engineer coordinated eddy current testing of the heat exchanger which resulted in confirmation of the suspected tube leak.

In summary, TVA believes that its system engineering program has been successfully implemented at BFN.

Moreover, it has demonstrated its capability to provide thorough and timely identification and resolution of problems.

Motor-0 crated Valve 'OV Testin Pro ram TVA has established a comprehensive program at BFN to implement the requirements of NRC Generic Letter 89-10 and its supplements.

Significant elements of this program are described below.

A key factor in the development and implementation of this program has been the aggressive support and overall program plan coordination provided by the TVA corporate program manager.

Some of the more significant elements of TVA's program include clear ownership of the program and a dedicated organization to support implementation, control of the project schedule through TVA's structured project management

process, and dedicated engineering and maintenance personnel for carrying out MOV activities.

Additional elements of TVA's program include aggressive corrective and preventive maintenance programs for MOVs, excellent communication and coordination between various plant organizations and corporate program personnel, and a

strong industry interface.

In NRC Inspection Report 92-04, NRC recognized TVA program personnel's knowledge of ongoing MOV issues, communication between corporate and site personnel, and the allocation of resources to support the MOV coordinator as program strengths.

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11. Maintainin and Enhancin Trainin Pro ram ualit Throughout the assessment

period, TVA took many steps to maintain and enhance the quality of training programs at BFN.

For example, in December

1991, TVA initiated a programmatic enhancement to BFN's INPO-accredited training programs.

This enhancement involves performing periodic self-assessments of accredited training programs in comparison to INPO accreditation renewal objectives.

TVA believes this self assessment program ensures that each of BFN's accredited training programs. maintains a consistent level of high quality.

Training program quality at BFN is also maintained and enhanced through TVA's participation in the Boiling Water Reactor Owners Group ad hoc committee on licensed operator requalification.

In December

1991, TVA participated in the pilot meeting of this ad hoc committee.as part of an ongoing effort to enhance the licensed operator requalification program at BFN.

Apart from the immediate enhancement objective, participation in committee activities augments in-house expertise and increases the knowledge base of BFN personnel.

In June 1991 and September 1991, respectively, TVA implemented new entry level trainee programs for Electrical and Mechanical Maintenance craftsmen.

These programs were implemented to improve the quality of entry level Maintenance personnel at

BFN, and to introduce these individuals to TVA's operating nuclear plant philosophy.

Additionally, to supplement these

programs, TVA will be implementing a similar entry level trainee program for Instrumentation and Control Maintenance craftsmen.

This new training program will be implemented by November 23, 1992.

Areas for Further Im rovement 1.

Control of Contractors In December

1991, a TVA contractor performing upgrades to the telecommunications equipment at BFN cut electrical cables serving accountability

readers, rendering them inoperable.

This event prompted TVA to identify control of contractors as an area in need of improvement.

As a result, TVA has initiated programmatic actions and upgrades to strengthen control of contractors at BFN.

For

example, TVA issued a site specific procedure to establish the methods to be utilized to effect positive control of contracted work,activities, at BFN.

This procedure requires the appropriate site vice president to designate an individual to function as the technical contract manager (TCM).

The TCM is responsible for determining the contract class (e.g., long-term unit recovery contracts, photocopier maintenance),

ensuring the Page 45

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appropriate work release is performed, and monitoring the contractor's performance to verify compliance with site administrative control programs.

Additionally, TVA's Modifications organization has been restructured to ensure better control of contractors.

This has been accomplished primarily through the assignment of former craft supervisors as task managers and providing comprehensive training to these individuals.

This cross-discipline training program is structured to provide minimum training requirements in each functional area to the task managers.

Task managers are responsible for speci;fic modification work, and physically follow progression of the modification from.design conception through work completion and post modification testing.

TVA modifications personnel have also been retrained on the requirements of programs such as environmental qualification, Appendix R, and ASME Section XI code.

TVA intends to focus continued management attention on this issue as Unit 3

modification work continues and Unit 2

approaches its next refueling outage.

Material Availabilit Durin the.0 comin Refuelin Outa e

During, the Unit 2 outage, TVA experienced many problems with material availability.

These problems were documented in the previous SALP report for BFN.

TVA has begun to develop measures to ensure that material availability is not a concern during the upcoming Unit 2 refueling outage scheduled to begin in early 1993:.

One of these measures involves TVA's Materials and Procurement organization, which has established a dedicated section to assist in planning work to ensure material availability.

This section was instrumental in ensuring material availability for maintenance and modifications work performed during the previous two voluntary shutdowns.

With respect to the upcoming refueling outage, this section is currently tracking identified materials an a line item level, and will also function to expedite the procurement and delivery process as necessary to support modifications or maintenance work.

Additionally, TVA has established a preferred materials list (PML) for use by the design engineering section.

TVA encourages personnel writing design changes to use material and components found in BFN's PML, since use of such materials and components

reduces, and sometimes eliminates, long procurement lead times.

Additionally, use of the PML can facilitate maintenance or refurbishment/replacement work should the component fail.

Another measure involves the dedicated individual within the BFN Modifications organization responsible for reviewing design changes to ensure material availability when the design change is implemented.

Yet another measure involves staging materials Page 46

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for design changes in the warehouses.

Thi.'s includes.removal of necessary materials for each design change from shelves and allocation to the corresponding design change.

Such actions ensure that when the design change is implemented, necessary materials are available and pre-assigned to that, design change.

TVA recognizes that ensuring material availability during the upcoming refueling outage is a major challenge.

Accordingly, TVA will continue to evaluate additional measures to ensure necessary material is available and delays in work due to unavailable material are minimized.

3.

S stem En ineer Pro ram Im rovements During the upcoming assessment

period, TVA will undertake further efforts to improve the system engineer program at BFN.

One of the methods

'TVA will utilize to achieve this objective is continuation of its effort to develop backup system engineers for each system.

TVA initiated this program in December

1991, and to date approximately 10 backup system engineers have been developed.

Due to the extensive training

required, the need for rotational assignments, and the time needed to develop necessary experience, this program will not be completed until approximately June 1994.

Another program enhancement is TVA's plan to improve the knowledge level of the system engineers.

TVA has developed a

two-phased approach to accomplish this objective.

The first

phase, which TVA completed in December 1991, involved sending BFN system engineers to General Electric's (GE) office in San

Jose, California, for head-to-head meetings with GE's system engineers.

These meetings were designed to familiarize BFN system engineers with industry expertise on their respective systems.

The second phase of this effort entails system engineer certification.

This program involves 6

weeks of systems training followed by 2

weeks of simulator training.

TVA initiated this program in August 1991, and to date 15 of the 57 system engineers at BFN have been certified.

TVA currently plans to complete certification of the remaining system engineers by July

1994, with a

program similar to INPO Guideline ACAD 91-017, Guidelines for Trainin and uglification of En ineerin Su ort Personnel.

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VZZ PUNCTZONAL AREA SAPETY ASSESSMENT/QUALITY VERZPICATZON In addition to the Maintenance/Surveillance functional area, as previously discussed in 'Section III, this functional area was assessed a Category 3,

Improving, rating in the June 1990 SALP report.

Weaknesses in. the timeliness and thoroughness of licensing submittals and. responses (e.g.,

the submittal evaluating offsite hazardous materials) were identified by the SALP Board.

In

addition, a

weakness was noted with respect to the failure to correct previously identified weaknesses.

Extensive corrective actions were undertaken subsequent to the June 1990 SALP assessment.

These actions continue, and extend beyond the scope of correcting the original deficiencies.

TVA management is dedicated to this. proactive approach to improving performance in the area of safety assessment/quality verification.

The ultimate

goal, as in all other functional. areas, is to transform BFN into a superior performer.

TVA believes that the activities summarized below are important steps toward achieving that goal.

Ma or Accom lishments 1.

ualit and Timeliness of Submittals In the June 1990 SALP report, the timeliness and quality of licensing submittals were repeatedly identified as. poor.

Since issuance of that report, TVA has taken actions that have resulted in improvements in both the timeliness and quality of BFN submittals.

An example of one of these efforts is the licensee event report (LER) improvement effort discussed

below, developed specifically to improve the quality of TVA LERs and ensure the timely submittal of LERs.

Similarly, TVA management has also taken actions to ensure that responses to notices of violation, and, in fact, any'FN submittal, are of high quality and are submitted in a timely manner.

In April 1992, TVA enhanced this effort by including a weekly review of licensing submittals in POD meetings.

In the June 1990 SALP report, violation responses were cited as not being timely.

Furthermore, the Staff noted frequent requests for extensions to the time requirements specified in 10 CFR 2.201.

As an example of the improvements in the timeliness of TVA submittals, during the current assessment period, only one extension was requested by TVA for submittal of a violation response.

In addition to the timely violation responses, during the. assessment period TVA has consistently submitted high quality LERs within the required 30-day time period'.

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2.

LER Im rovement Efforts In response to TVA Executive Management requests, TVA undertook an LER Improvement Project in late 1991.

The overall goal was to identify methods by which to improve the preparat'ion of complete and accurate LERs.

In order to accomplish that objective, TVA conducted a-thorough review of the processes it employs to generate and submit LERs.

The project a team effort --

was spearheaded by the BFN Site Licensing organization wi;th support from Sequoyah Nuclear Plant Site Licensing personnel and TVA Corporate Licensing personnel.

The team reviewed most 1991 LERs from BFN and

Sequoyah, identifying issues requiring further analysis.

This review was conducted on the basis of NRC regulatory requirements, guidance in NUREG-1022 and its supplements, and LERs from other utilities identified by the NRC Office for.Analysis and Evaluation of Operational Data as being superior in quality.

As a result, the team decided to substantially revamp the format of TVA's LERs to achieve a step change in the simplicity of their preparation, accuracy-,

and clarity.

TVA believes that the LER Improvement Project has resulted in a significant enhancement in the preparation and quality of BFN LERs.

3.

Im roved Communications With NRC Staff During the assessment period TVA has taken steps to improve its communications with the NRC resident,

Region, and headquarters Staffs.

For

example, TVA now conducts biweekly conference calls with the NRC Office of Nuclear Reactor Regulation and the NRC Senior Resident Inspector.

TVA instituted this change specifically to keep the Staff better informed of the status of

issues, and to obtain NRC feedback early in the planning stages of certain projects.

Another change instituted, by TVA is the daily meetings between Site Licensing management and the NRC resident inspectors.

TVA considers that these changes have resulted in development of a better working relationship with the Staff and provide a

forum for the frank exchange of information and ideas.

4.

Timel Resolution and Closure of 0 en Ins ection Items LERs and Corrective Action Items During the assessment period TVA management attention was responsible for ensuring the timely resolution and closure of open inspection items, LERs and corrective action items.

For

example, TVA currently has only 28 open inspection items and LERs.

Of these 28 items, 5 involve actions that are scheduled to be performed during the upcoming refueling outage, 13 are with the NRC awaiting closure, and

only, 10 have yet to be submitted to the NRC for closure.

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5.

Im rovements in the IZ Process Prior to the assessment

period, TVA had experienced difficulties with the II program at BFN, primarily due to program weaknesses.

During the assessment period TVA's aggressive management attention resulted in the development and implementation of a revised II program for BFN.

Significant elements of the new process include:

(1) a revised procedure with improved user friendliness and flexibility, (2) expansion of the previous two-category report classification scheme into three categories, (3) use of uniform report format, and (4) emphasis on evaluation of previous events/industry experience.

The new procedure requires that a

Human Performance Evaluation System (HPES)-qualified evaluator be a member of any team investigating more significant events (Category 1 and Category 2 events) where personnel performance is a potential contributing factor.

A form providing plant management with an opportunity to review the composition of the event team and the investigation plan at the onset of the investigation is also incorporated in the new procedure.

In

addition, the new procedure requires that Site Licensing personnel be represented on teams investigating events'hich require LERs or events with potential regulatory significance.

Furthermore, the new procedure incorporates requirements for conducting an annual program effectiveness review.

Another significant change in the process is the review of Category 1 and 2 events by the Plant Evaluation Review Panel (PERP).

This multi-disciplined panel of site management personnel provides an additional level of management review of the incident, the root cause and corrective actions.

The PERP is also a

real-time mechanism for management to provide expectations regarding event report quality to event managers and teams.

TVA has also taken actions to ensure management awareness of the

events, and timely completion of IIs, through daily discussion of the status of IIs at POD meetings.

6'm roved Root Cause Anal sis Trainin Pro ram To supplement the improved II program, discussed

above, TVA implemented an improved root cause training program.to improve the assessment skills and investigative capabilities of TVA personnel.

This training program upgraded the previous two-day course on root cause analysis by expanding the course to three days and including training in the use of HPES methodology, in addition to basic root cause analysis techniques.

To date, TVA has provided the revised root cause and HPES training to over 210 individuals.

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A recent enhancement made by TVA to the root cause analysis training program is the addition of TVA's "Tools and Techniques" root cause analysis/problem solving course.

TVA developed this course as part of the new TVA Quality Improvement Program.

The course teaches several root cause methods and the basic problem solving process utilized by TVA Quality Action Teams.

7.

Nuclear Safet Review Board NSRB Prior to the assessment period TVA implemented changes to the NSRB to improve the quality of reviews performed by the NSRB.

However, since the resulting improvement has been fully realized during the assessment

period, TVA is treating it as a

major accomplishment for the, purposes of this SALP evaluation.

Specifically, TVA improved the quality of reviews provided by the NSRB through better utilization of the expertise of outside members.

TVA also developed a better plan for in-house membership by increasing'site participation, including a plant manager from another TVA site, and adding key line and senior corporate managers.

As a result of these

changes, NSRB now demonstrates consistent, high quality independent reviews of activities relating to nuclear safety.

In Inspection Report 91-31, dated October 3, 1991, NRC specifically complimented the probing questions asked by the NSRB and the level of knowledge of NSRB members on industry issues at other utilities and nati.onal laboratories.

8.

m roved Assessment Ca abilities of the BFN A Or anization An innovative change made by the BFN QA organization during the assessment

.period involves development and initiation of the "inspector of the day" program.

Pursuant to this program, a

different individual within the organization is assigned, each

day, to patrol the plant in search of actual or potential problems (e.g.,

housekeeping defi.'ciencies or procedural compliance difficulties during performance of work activities).

The individual filling the position reports directly to QA management.

Development of this program is one of the methods identified by QA to.increase its focus on performance-based inspections.

Examples of significant incidents/conditions identified by the inspector of the day include a

leaking drywell penetration discovered in December

1991, and a leaking instrumentation fitting on the diesel generator lube oil pressure line, also discovered in December 1991.

The BFN QA organization also utilizes specialists from outside TVA to augment the existing QA staff for specific audit or monitoring activities.

The immediate purpose of this staff augmentation is to assist QA in performing certain audits by utilizing the, particular individual's technical expertise in a specific area.

Moreover, another important reason for inter-acting with these outside technical experts is to internalize Page 51

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their specialized knowledge about the results of audits and assessments performed throughout industry.

This ensures the continual education and.up-to-date expertise of the BFN QA organization.

9.

Im oved A Communications, w th lant Or ani at o QA has also taken steps to improve its approach to the identification and resolution of.plant problems by enhancing communications with other plant organizations.

Revision of the manner in which quarterly assessments are presented is one such step.

Implemented in January 1992 at the beginning of the current evaluation quarter, this format change will present information in a standardized format by the corresponding SALP functional area.

Standardized criteria have also been developed to ensure consistent evaluation of performance.

This revised format not only provides QA with a more effective tool for evaluating performance but also enhances resulting feedback to plant management and regulatory agencies.

QA's interaction and communication with plant organizations has also improved during the assessment period.

For example, QA's Audit and Monitoring section now conducts monthly focus meetings with line organization management.

At these meetings, an organization's performance, and any identified problems, are discussed in addition to areas where QA will be focusing additional attention.

As such, these meetings foster a

mor' productive working relationship between QA and line organizations; for example, by precipitating discussions of findings and methods to improve performance.

10. Restructurin the BFN A

Or anization and Re-Focusin on Performance-Based Audits and Monitorin The QA organization at BFN has evolved and transformed as Unit 2

has undergone the transition from shutdown to operating status.

Specifically, QA has intensified its activities, becoming a

dynamic, aggressive organization focused on performance-based, rather than compliance-based, audits.

In order to do so, QA evaluated its overall audit and inspection program to identify changes necessary to better assess an operating, as opposed to a

shutdown, unit.

The resulting initiatives include organizational restructuring and other programmatic changes, as well as efforts to improve the quality and experience of its personnel.

For

example, in February

1992, the Quality Engineering and Quality Control functions were combined under one manager.

A similar

change, involving the reorganization

~ of Audit and Monitoring functions under one manager, was simultaneously made effective.

These organizational changes foster a

closer working relationship among affected personnel, in part, by improving communications between previously separate organizations with similar objectives.

Page 52

An additional organizational change illustrative of the change in audit emphasis was made in February 1992 when TVA formally established a dedicated group to oversee Unit 1 and 3 recovery activities.

This group remains a part of the QA organization that monitors Unit 2.

This change ensures the availability of resources for self-assessment of unit recovery activities and, at the same time, ensures that these activities are carried out

• in a manner consistent. with Unit 2 practices and experience.

Areas for Further Im rovement 1.

Im lementation of Im roved Standard Technical 8 ecifications ISTS In the upcoming assessment peri.'od TVA will be devoting increased resources on developing the ISTS at BFN.

Currently, TVA has completed preliminary screening of Unit 2

TS to identify requirements to be retained in the TS or relocated to other documents.

TVA is scheduled to begin the first draft of the Unit 2 ISTS in June 1992, with plans to begin drafting Unit 1

and 3

ISTS approximately, three months later.

In October

1993, TVA expects to submit the completed Unit 2 ZSTS for NRC approval, with Unit 1 and 3 ZSTS to be submitted approximately 6 months later.

Pending NRC approval, TVA plans to implement the new ISTS for all three units at the same time.

2.

Increase Self-Cri.tical Nature of IIs In TVA's response to the June 1990 SALP report, TVA stated that BFN management would be self-critical in the evaluation of

.events through the IZ process.

TVA considers that considerable progress has been made in the area of ZZs, and that overall IIs are detailed, self-critical reviews of events.

However, TVA has also identified some ZZs recently performed at BFN that lack the necessary level of self-critical review.

Therefore, in the coming assessment

period, TVA will continue to stress the need for self-critical evaluations of events through the Plant Evaluation Review Panel meeting and management review of ZZs.

3.

A Staff uglification U rades During the assessment

period, TVA has implemented ongoing programmatic enhancements to improve the

training, qualification and objectivity of site QA personnel.

For

example, in June

1990, TVA instituted a rotational assignment program whereby Operations personnel (licensed senior reactor operators) rotate into the QA organization for a pre-determined length of time (up to one year).

This ongoing rotational program not only provides Operations personnel with a

new perspective and renewed appreciati.'on for the functions of QA personnel, but also gives QA personnel a corresponding new Page 53

perspective on and'irst-hand understanding of operations activities.

Based on the positive results of these rotating assignments, TVA plans to continue this program throughout the upcoming assessment period.

Another ongoing program in the QA organization involves cross-training QA personnel to broaden their knowledge and objectivity.

QA has adopted unique methods for providing this cross-training.

For example, in February 1992, the supervisors for the QA monitoring and auditing sections exchanged positions for a period of approximately 6 months.

In October 1991, TVA initiated' program to certify monitoring personnel as lead auditors in accordance with ANSI N45.2 criteria. Additionally, TVA has supplemented existing programs for audit and monitoring personnel by providing observation training to inspectors.

This program was initiated in January

1992, and is designed to enhance the observational and assessment capabilities of QA inspectors.

To date, six QA inspectors have completed this training.

TVA will complete observational training of existing QA inspectors.

by. August 26, 1992.

4.

Enhance Performance Trendin As discussed

above, TVA has revised its. quarterly trend report issued by the QA organization.

This revised. trend report utilizes a

SALP functional area format and'tandardized evaluation criteria.

Using the revised format and standardized evaluation criteria, during the upcoming assessment period QA will be evaluating performance against each criteria and overall performance in each functional area.

QA will then classify performance as either a significant weakness, needing

'improvement, satisfactory, or a significant strength.

This new format change was recently implemented and a report using the new format was issued in March

1992, which evaluated performance for the period of October through December 1991.

This revised format will provide QA the tool to perform enhanced trending of plant performance in the upcoming assessment period.

Page 54

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ENCLOSURE 2 TENNESSEE VALLEY AUTHORZTY BROWNS FERRY NUCLEAR PLANT (BFN)

UNZT' SYSTEMATZC ASSESSMENT OF LZCENSEE PERFORMANCE (SALP)

/

MAY 23'991 - MAY 22'992 SELF ASSESSMENT'ist of Commitments 1.

TVA will upgrade the computerized hold order system by adding.

computerized system status capability.

TVA will complete implementation of this enhancement by February 11, 1993.

2.

TVA will perfor'm chemical decontamination of the Unit 2

recirculation and reactor water cleanup systems during the upcoming Unit'2, Cycle 6 refueling outage.

3.

TVA will begin use of closed circuit television cameras at BFN during the Unit 2, Cycle 6 refueling outage to assist in maintaining dose as low as reasonably achievable.

4.

TVA will be conducting additional "hands-on" training at the Post Accident Sampling System panel.

This training will begin by May 28, 1992.

5.

TVA-will initiate development and implementation of a plant video tour system.

TVA will begin work on the first phase of this

project, which will involve still photography of accessible Unit 2

components and development of the initial video system for these components, by October 14, 1992.

6.

TVA will purchase a remotely-operated robot to assist work performance in radiation areas by October 14, 1992.

7.

TVA will complete the current phase of the maintenance supervisory development program (i.e., training of existing and candidate Maintenance supervisors) by June 15, 1992.

8.

TVA will initiate a

team building training program for Maintenance craftsmen similar to the training program developed for Maintenance supervisory personnel.

This program will be initiated by August 20, 1992.

e (L

List of Commitments continued 9.

TVA will complete the craft team building training. program for existing Maintenance craft personnel by March 23, 1993.

10.

TVA will begin loading the first systems into the Rel'iability Centered Maintenance computer program by June 23, 1992.

11.

TVA will complete installation of the permanent Safety Parameter Display System during the Unit 2, Cycle 6 refueling outage.

1 12:. In 1992, TVA will initiate off-hours staff augmentation drills for all three emergency response teams.

13.

TVA will complete the upgrade to BFN's,public address and alarm systems prior to startup from the Unit. 2, Cycle 6 refueling outage..

14. Following NRC approval'f.the revised NUMARC methodology for emergency action levels (EALs),

TVA will implement revised plant-specific EAL's at BFN which are based on the NUMARC methodology.

15.

TVAwillpurchase a second upgraded radiation monitoring van to replace the existing second van by May 11, 1993.

16.

TVA will complete full implementation of Revision 4 of the BWR Owners Group Emergency Procedure Guidelines in, BFN emergency operating instructions. by June 15, 1992.

17.

TVA will implement an entry level trainee

.program for Instrumentation. and Control Maintenance craftsmen by November 23/

1992.

18.

TVAwillcomplete observational training of existing inspectors in: the BFN Quality Assurance organization by August 26, 1992.

Page 2

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Docket Nos. 50-259, 50-260, and 50-296 License 'Nos.

DPR-33, DPR-52, and DPR-68 Tennessee Valley Authority ATTN: Dr. Mark 0. Medford; Vice President Nuclear Assurance, Licensing an'd Fuels 3B Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Gentlemen:

Subject:

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (NRC INSPECTION REPORT NOS. 50-259/92-18, 50-260/92-18, AND 50-296/92-18)

The NRC Systematic Assessment of Licensee Performance (SALP) has been completed for your Browns Ferry Nuclear Plant, Unit 2.

The facility was evaluated for the period May 24,

1991, through May 23, 1992.

The results of the evaluation are documented in the enclosed Initial SALP Report.

This report wi.ll be discussed with you at a public meeting to be held at the Browns Ferry site on July 27, 1992, at 1:00 p.m.

The performance of your Browns Ferry, Unit 2

was evaluated in the functional areas of Plant Operations, Radiological

Controls, Maintenance/Surveillance, Emergency Preparedness,

Security, Engineering/Technical

Support, and Safety Assessment/guality Verification.

The assessment identified superior performance in the functional areas of Operations, Radiological= Controls, and Emergency Preparedness.

All other functional areas were assessed as good.

The Unit 2 reactor

startup, power ascension, and subsequent operations for the SALP period were well performed with significant management involvement and oversight.

The material condition of Unit 2 is very good and continues to improve.

A positive safety attitude has been demonstrated by management involvement and plant operations with a minimum number of-problems.

Teamwork is evident among the Brown's Ferry organizational elements and operational excellence clearly is a major goal of the station staff.

Any comments you have concerning our evaluation of the performance of your Browns Ferry facility should be submitted to this office within 30 days following the date of our meeting.

These comments will be considered in the development 9208070097 920720 PDR ADOCK 05000259 8

PDR

( A

(,

Tennessee Valley Authority of the Final SALP Report.

Your comments and a

summary of our meeting will be issued as an appendix to the Final SALP Report.

Enclosure:

Initial SALP Report cc:

w/encl (See page 3)

(Original signed by Stewart Ebneter)

Stewart D. Ebneter Regional Administrator

Jr

Tennessee Valley Authority cc w/encl:

Hr. John B. Waters, Director Tennessee Valley Authority ET 12A 400 West Summit Hill Drive Knoxville, TN 37902 TVA Representative Tennessee Valley Authority Rockville Office 11921 Rockville Pike Suite 402 Rockville, MD 20852 General Counsel Tennessee Valley Authority ET 11H 400 West Summit Hill Drive Knoxville, TN 37902

Chairman, Limestone County Commission PE 0.

Box 188

Athens, AL 35611 Hr. J.

R.

Bynum, Vice President Nuclear Operations Tennessee Val.ley Authority 3B Lookout Place 101 Market Street Chattanooga, TN 37402-2801 Hr.

R.

R. Baron, Site Licensing Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.

Box 2000

Decatur, AL 35602 Hr. 0. J.

Zeringue, Vice President, Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.

Box 2000

Decatur, AL 35602 Hr. H. J. Burzynski, Manager Nuclear Licensing and Regulatory Affairs Tennessee Valley Auth'ority 5B Lookout Place Chattanooga, TN 37402-2801 Claude, Earl

Fox, H. D.

.State Health Officer State Department of Public Health

.State Office Building Montgomery, AL 36130 State of Alabama INPO bcc w/encl:

(See page 4)

Tennessee Valley Authority bcc w/encl:

The Chairman K. C. Rogers, Commissioner J.

R. Curtiss, Commissioner F. J.

Remick, Commissioner J.

M. Taylor; EDO G. DePlanque, commissioner

'H. L. Thompson, Jr.,

EDO J.

F. Wechselberger, Regional Coordinator, EDO T.

E. Hurley, NRR S. Varga,'RR F.'Hebdon, NRR T. Ross, NRR F. Allenspach, SALP Coordinator, NRR Regional Administrators, RI, RIII RIV, and RV K. Clark, RII, PAO B. A. Wilson, DRP, RII P. J. Kellogg, DRP, RII R.

H. Bernhard, DRP, RII TSS, RII NRC Resident Inspector DRS and DRSS Branch Chiefs, and Section Chiefs g Document Control Desk DRP/RI I PKe logg 7/ ~/92 PD/N F

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7/(y/92 DRP/RII BWi son 7/I7 /92 DRSS/RII (er BMallett 7/ ~ /92 DRP/RII 7/ &/92 DRS/R AGibs 7/ g0/92'

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