ML18036B029

Responds to NRC 920720 Ltr Forwarding Initial SALP Repts 50-259/92-18,50-260/92-18 & 50-296/92-18 Covering 910524 Through 920523

ML18036B029
Person / Time
Site:	Browns Ferry
Issue date:	08/26/1992
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9209010103
Download: ML18036B029 (77)

Text

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ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 9209010103 DOC. DATE: 92/08/2b NOTARIZED: NO DOCKET 0 SCIL: 50-259'roens Ferry Nuclear Poeer Stationi Unit 1> Tennessee 05000259 50-260 Brains Ferry Nuclear Poeer Station> Unit 2> Tennessee 05000260 50-296 Broens Ferry Nuclear Poeer Station> Unit 3i Tennessee 0500029b AUTH. NAME AUTHOR AFF ILIATION ZERINGVE> 0.

RECIP. NAME J., Tennessee Val leg Authority RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) R

SUBJECT:

Responds to NRC 920720 ltr forutarding initial SALP Repts

.50-259/92-18i 50-2bO/92-18 h 50-29b/92-18 cover ing 920520 through 920523.

DISTRIBUTION CODE: IEOXD COPIES RECEIVED: LTR J ENCL ~ SXXE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Res'ponse REC IP IENT COPIES RECIPIENT COP IES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL HEBDON> F ROSS> T.

NILLIAMSiJ.

t INTERNAL: ACRS AEOD AEOD/DEIB 2 AEOD/DSP/TPAB AEOD/TTC 1 DEDRO NRR MQR I SSEAUX D 1 NRR/DLPG/LHFBPT NRR /DLP 8/LP EB 10 1 NRR/DOEA/OEAB NRR/DREP/PEPB9H 1 NRR/PMAS/ ILRB 12 NUDOCS-ABSTRACT 2 E P~

OGC/HDS3 1 REG F I LE 02 RGN2 FILE 01 2 EXTERNAL: EQSIG/BRYCEi J. H. NRC PDR NSIC NOTE TO ALL "RIDS RECIPIENTS:

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

ROOM P 1-3? (EXT. 504-2065) TO ELIMINATEYOUR NAME FROid DISTRIBUTION LISTS FOR DOCUMENTS YOU DOXNI'T HEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL ~9

Tennessee Valtey Autnority, Post Office Box 2000, Decatur,'Alabama 35609 O. J. 'Ike'eringue Vice President, Browns Ferry Operations

'AUS p6 ]ggZ U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of Docket- Nos. 50-259 Tennessee Valley Authority 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNIT 2 NRC INSPECTION REPORT 50-259,

'260, AND 296/92-18 RESPONSE TO SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT By letter dated July 20, 1992, the NRC Staff transmitted to TVA the initial BFN Unit 2 SALP Report for the period May 24, 1991 through May --23, 1992. Subsequently, on July 27, 1992, NRC and TVA representatives met to discuss the report. This letter provides TVA's response to that report.

TVA is encouraged with the overall results of the NRC Staff's SALP Report and its reflection of the efforts TVA has made to improve performance at BFN., TVA acknowledges the SALP Board recommendations and those sections of the report which identify areas needing additional attention and improvement. While there is still much to be accomplished, the SALP Report reflects a positive trend in performance that TVA is committed to continuing.

In addition, TVA is pleased that its self-assessment process reflected in TVA's April 17, 1992 self-assessment meeting with the NRC and subsequent follow-up letter dated May 8, 1992, resulted in findings generally consistent with the NRC Staff's SALP Report. Where TVA's conclusions differ with the Staff's, TVA will seek to understand the basis for the differences in order to refine its self-assessment efforts.

9209010103 920826 PDR ADOCK 0500025'P 8 PDR

U.S. Nuclear Regulatory Commission AUG Pg >ggg TVA appreciates the Staff's cooperative efforts in pursuing the common goal of excellence in operation at BFN. TVA believes that because of the combined efforts of the NRC and TVA, BPÃ has made remarkable strides this last year. However, TVA also knows that the current SALP period will be pivotal. Based on TVA's plant activities and directional focus discussed in its self-assessment provided to. the Staff, TVA fully expects and is committed to assuring that the upward trend in performance will continue.

Sincerely, 0 J. Zeringue cc~ 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 White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

ENCLOSURE 3 NRC SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

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SALP CYCLE 10 MAY 24,1991 THROUGH MAY 23, 1992 BR WNS FERRY NU LEAR PLANT JULY 27,1992

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CL, BROWNS FERRY 2 A. GIBSON, SALP CHAIRMAN, DIRECTOR, DIVISION OF REACTOR SAFETY, Rll J. JOHNSON, ACTING DIRECTOR, DIVISION OF REACTOR PROJECTS, Rll B. MALLETT, DEPUTY DIRECTOR, DIVISION OF REACTOR SAFETY AND SAFEGUARDS, Rll F. HEBDON, DIRECTOR, PROJECT DIRECTORATE ll-4, OFFICE OF NUCLEAR REACTOR REGULATION B. WILSON, CHIEF, REACTOR PROJECTS BRANCH 4, DRP, Rll T. ROSS, SENIOR PROJECT MANAGER, NRR C. PATTERSON, SENIOR RESIDENT INSPECTOR (BFNP), DRP, RII SALP CYCLE 10

Ck, NRR ORGANIZATION OFFICE OF NUCLEAR REACTOR REGULATION DIR. T. MURLEY ASSOC. DIRECTOR FOR ASSOC. DIRECTOR FOR PROJECTS INSPECTION AND J. PARTLOW TECHNICAL ASSESSMENT DIVISION OF ENGINEERING TECHNOLOGY DIVISION OF REACTOR PROJECTS I/II DIVISION OF OP ERATIONAL EVENTS S. VARGA, DIE I/II ASSESSMENT G. LAINAS, ASST. DIE II F. HEBDON, DIFF'IX DIVISION OF REACTOR INSPECTION T. ROSS,SR PROJ MGR AND SAFEGUARDS BFNP2 DIVISION OF RADIATION PROTECTION AND EMERGENCY PREPAREDNESS DIVISION OF DIVISION OF LICENSEE PERFORMANCE AND REACTOR PROJECTS III/IV/V QUALITY EVALUATION AND SPECIAL PROJECTS DIVISION OF SYSTEMS TECHNOLOGY

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"REGION Il ORGANIZATION OFFICE OF THE ADMINISTRATOR ADMINISTRATOR S. EBNETER DEPUTY L. REYES DIVISION OF DIVISION OF DIVISION OF REACTOR PROJECTS REACTOR SAFETY RADIATION SAFETY AND SAFEGUARDS

.ACT.DiR. J. JOHNSON DIR. A. G! BSON Dl R. J. STOHR DEPUTY J. JOHNSON DEPUTY E. MERSCHOFF DEPUTY B. MALLETT-

v DIVISION OF REACTOR PROJECTS ORGANIZATION DlVlSlON OF REACTOR PRO JECTS OIR. J. JQHNSQN (ACTING)

DEPUTY J..JOHNSON REACTOR PRO JECTS BRANCH NO. 4 CHIEF B. NILSON PROJECTS SECTION PRO JECTS SECTION NO. 2A NO. 4B CHIEF CHIEF P. J. KELLOGG K. P. BARR BROWNS FERRY SRI WATTS BAR C. PATTERSON SEQUOYAH BELLEFONTE.

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SALP CYCLES 9 AND I0 FUNCTIONAL RATING RATING AREA LAST PERIOD THIS PERIOD OPERATIONS 2 (SHUTDOWN)

RAD CONTROL MX/SURV 3, I MPROVING EMER PREP 2, IMPROVING ENG R/TECH SA/QV 3, IMPROVING 2, IMPROVING SECURITY BFNP2

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STRENGTHS

~ CREW PERFORMANCE

~ STAFFING

~ OPERATOR TRAINING

~ FIRE PROTECTION

~ PLANNING

~ SELF ASSESSMENT CHALLENGES

~ INDEPENDENT VERIFICATION

~ LABELING

~ ATTENTION TO DETAIL

(CATEGORY I )

STRENGTHS

~ MANAGEMENT SUPPORT

~ ALARA INITIATIVES

~ STAFFING

~ AUDITS

~ EFFLUENT CONTROLS

~ CHEMISTRY

~ SOLID RADIOACTIVE WASTE CHALLENGE

~ MAINTAININGGOOD PERFORMANCE

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(CATEGORY 2)

STRENGTHS

~ MATERIAL CONDITION

~ PREVENTIVE MAINTENANCE

~ BACKLOG MANAGEMENT

~

PROCUREMENT

~ POST MODIFICATIONAND POST MAINTENANCE TESTING PLANNING

~

SURVEILLANCE PROGRAMS AND IMPLEMENTATION

(CONTINUED)

CHALLENGES

~ CORRECTIVE ACTIONS

~

CONFIGURATION CONTROL

(CATEGORY 2)

STRENGTHS

~ MANAGEMENT SUPPORT

~ EXERCISE PERFORMANCE

~ EVENT CLASSIFICATION

~ FACILITIES

~ PLAN CHANGES

~ SELF ASSESSMENT CHALLENGES

~ AUDIBILITYOF ADDRESS SYSTEM

~ OSC/REPAIR TEAM COORDINATION

I i (CATEGORY 2)

STRENGTHS

~ MANAGEMENTSUPPORT

~ FACILITY UPGRADES

~ STAFFING AND TRAINING

~ AUDITS

~ PLAN CHANGES

~ FITNESS FOR DUTY PROGRAM CHALLENGES

~ ACCESS CONTROL

~ SNM INVENTORY

P

(CATEGORY 2)

STRENGTHS

~ DESIGN CONTROL

~ ENGINEERING SUPPORT TO OPERATIONS

~ ENGINEERING SUPPORT TO MAINTENANCE

~ SYSTEM ENGINEERS

~ OPERATOR TRAINING CHALLENGES

~ CONTROL OF CONTRACTORS

~ INCIDENT INYESTIGATIONS

(CATEGORY 2 - lMPROVING)

STRENGTHS

~ MANAGEMENTSUPPORT

~ CORRECTIVE ACTION PROGRAM

~ TEAMWORK

~ LICENSING SUBMITTALS

~ LICENSING STAFF CHALLENGES

~ PROBLEM IDENTIFICATION

~ MEETING SCHEDULES

~ INCIDENT INVESTIGATION PROGRAM

~ UNIT 3 INTERFACE

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FUNCTIONAL AREA DISTRIBUTION For Eighteen Region II.Sites SALP CYCLES 8, 9, AND 10 Number of Sites 16 12 10

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OPS IUD'/S EP SEC ENG/TS SA/QV Functional Areas E3 CATEGORY 1 I CATEGORY 2 Rl CATEGORY 3

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. INSPECTION HOURS/FUNCTIONAL AREA BROWNS FERRY, CYCLE 10 SECURITY 1%

MAINT/SURV 14%%uo EMERG. PREP 1'Po SA/QV S%%uo OPERATIONS 62%

RAD CON 2%

ENGR/TECH SUPT 7%%uo OTHER 4%%uo (STLMEI.CH3)

SALP CYCLE 10 FUNCTIONAL AREA NONCI TED LEVEL IV LEVEL ill OPERATIONS RAD CONTROL MX/SURV ~ I 3

EMER PREP 0 0 ENGR/TECH SA/QV SECURITY TOTAL 13 BFNP2

f' SALP CYCLE 10 COMP FAILURE TEST/CALIB 2 36%

PERSONNEL MAINT. 3 47%

OPEHATINQ 3 DESIGN/

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PERSONNEL TOTAL (8)

(17)

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ENCLOSURE 4 REVISION SHEET SALP BOARD REPORT REVISION SHEET PAGE LINE NOW READS SHOULD READ Coversheet N/A INITIAL SALP 'REPORT FINAL SALP REPORT Bas'is: This revision changes the Initial. SALP Report to the Final SALP report.

27 two violations one violation 29 An auxiliary plant operator ,Deleted pulled the wrong fuses during a routine tagout.

Basis: One violation with two examples is correct. The operator did not pull incorrect fuses. The fuses were disconnected by opening the cubicle door.

14 Although this activity was Deleted performed by Unit 3 personnel, a contributing factor to this problem was separate operations work control centers'for Unit 3 and Unit 2.

Basis: Separate work control centers were not identified in the inspection report as a causative factor.

15 12 During this assessment period..... Prior to ...

... weaknesses one weakness 15 13 One was... Deleted 15 14 A second was... A second access control weakness Basis: One of the access control .problems occurred before this assessment period.

17 18 Several violations A violation Basis; While several violations did occur only one was concerned, with Unit 2.

.18 23 Engineering has considered the Engineering the problem but the corrective expended action commitment date has been considerable man-extended. hours evaluating the probl'em but the design

completion date has been extended several times.

Basis: Put in proper perspective the effort that engineering put into the problem.

21 46 following closure ...timely Deleted manner...

Basis: The design change was not closed.

22 3 LER (50-260/91-09) LER (50-260/92-03)

Basi's: LER '91-09 did not occur in this period, LER 92-03 did.

22 28 10CFR54(w)... incorrect 10CFR50.54(w).....

unclear schedule Basis: Corrects reference to 10CFR and better characterizes the information.

22 34 continued to exhibit exhibi ted Basis: Better characterizes to isolated instances rather than a continuing problem.

23 22 However a negative trend Some problems Basis: Examples do not support a trend.

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ENCLOSURE INITIAL SALP REPORT NUCLEAR'EGULATORY COMMISSION REGION II SYSTEMATIC 'c LICENSEE PERFORMANCE c"

A'NSPEC1 NUMBER O~

50-2, c~

TENNESSEE VALLE)

BROWNS FERRY UN.

FROM MAY 24, 1991 THROUGH MAY

B."owns Fer ir error occurred during a controlled plant shutdown. The

~tor exciter field -breaker was not opened as required re~ an operator tripping the reactor due to a number of unex uipment responses. As a result of this, additional train ~ven to operating crews on the simulator before the next p 'tdown. A shutdown for a maintenance outage was later ci 'ithout difficulty indicating an ability to implemenl. learned.

Close coora 'd effective communication between departments were display< olan of the day meetings. Operations've control and il. helped to achieve effective planning and scheduling evolutions. This led to a lack of significant prob ig the PATP. The operational influence was further expan, 'cing a licensed SRO into the equality Assurance (gA) org. work control group, outage planning, and other departmenl. ~s of operations management were assigned to provide s "age during outages until. the unit was returned to power The outage planning zg an eight day maintenance was a strength. Tl ately implemented the NUMARC cond'utage guidelines for risk reductl outages. Outage meetings were conducted several times v~

O Problem areas were identified + 4e nt verification, labeling, and attention-to-detal ctive independent verification failed to identify i. 'se replacement in a diesel generator (DG) control circ. ling problems resulted in two violations. A drywell blower was found labeled on two diFferent electrical boards. On~ ications was a spare. An auxiliary plant operator pu 'rong fuses during a routine tagout. Problems associated . ry Containment Radiation Monitor three pen recorders an. t chart paper recurred due to ineffective corrective ac'i Strong management support of operator train> ed to be evident. All candidates passed initial licen. given in June and December 1991. The plant simulator w, 1 and certified during this period.

TVA maintained a dedicated professional fire prote 1 on with a fire truck located inside the protected area te.

The fire protection program remained the responsibil single designated manager in the Operations Departmen, reviews of the program by the NRC found the program to maintained in conformance with regulatory requirements, Specifications, and industry guides and standards. TVA p.

reviewed the generic applicability of problems in fire pro.

at another licensee facility and concluded that similar prol.

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~LP exist, ,Fire protection systems and equipment installed ction of safety-related areas were functional and tested 1 ace w>th requirements specified in the TS. Fire pr; . 'rainin g was comprehens,ive. Oefinitions of fire watch dut. larified to insure compliance with TS. TVA effec locke d Appendix R and TS fire protection Limiting Condit ~pe ration (LCOs) during plan of the day meetings.

Improvei. noted in labeling of Appendix R equipment and compensate Nose station. The ability to quickly and effective'i. to plant fires was demonstrated through training dr inor events in the plant. A TS required fire watch was no. ed after fire wrap was removed from. operable residual heat ~rvice water pump power cables in the intake structur igh this activity was performed by Unit 3 personnel, a con. factor to this problem was separate operations work ci ters for Unit 3 and Unit 2.

Six Violations were

2. Performance Ratir.

Category: 1

3. Board Recommendations O~

None c~

Radiolo ical Controls

1. ~Anal sis This functional area addresses those a directly related to radiological controls, radioactive w, ~ment, environmental monitoring, water chemistry 'sportation of radioactive material.

Overall, the radiation protection program coi aggressively control personnel exposure to ra~ 'ateri al s and protect the health and safety of the plant, and the publ.ic.

Management oversight and support were effective. year (FY) 1992 ALARA goals were included in management pe standards. The ALARA/Radwaste Committee (ARC) was re to be chaired by the Plant Manager or Site Vice President.

revised the 1991 FY exposure goal downward from 650 per 539 person-rem and met this more challenging goal. Manag used planned power reductions to save dose. Five power reductions, for maintenance activities, were done solely foi purposes with an estimated savings of 24 person-rem. For exa

l, Brow~ .erry SALP 15

.ing the assessment period some improvements in security program

".tiveness were apparent as a result of the completion of the

'm security program upgrade initiated by TVA to comply with for Unit 2 restart. Included was the

'n"equired shed commitments the size of the protected area that decreased the compensatory patrols, replacement of ma 'ng turnstiles with electronic card key controlled doo, ~ portals, and modifications to the perimeter intro tion and assessment systems. The actions to date have c, to improved effectiveness of access control hardwar~ 'esponse.

During thi. >t period, TVA identified weaknesses in access control. On eermitting of two terminated contractor employees to ~ ~lant. A second was a vital portal that was unalarmed a. ied in excess of one hour. TVA had a prior history of ~trol problems of the first type which were outside this iod. This access control problem was under review by the ~ end of the period.

d~

The security organizat ~quately staffed and trained to perform duties related L dc control, detection and assessment, armed respons. ~nsatory measures. The security training program p 'equate training and qualification in the areas o. ', security system utilization, and procedural r~ as demonstrated by security personnel performance.

'Strong support of the security pro "porate and site security management remained evideni trated by the commitment and funding of a major upg ~ security system, the recent procurement of new hand-heli equipment to be utilized in the .access portals, and the to semi-automatic handguns and rifles. Hanagemen, 'ons to improve the operational effectiveness of the secur> and enhance personnel performance. Authority was delega t supervisors with encouragement to participat e 'el y involved in the management of the security prog.

An aggressive audit program contributed to the ide. and correction of security related issues and problems i.

tracked and trended with followup accomplished .to ens effective corrective action was implemented. Lessons .

the audits were disseminated to the security staff to pi recurrence.

The effectiveness of corrective actions in the Safeguards Information Program, in which several violations were identif,

4 B; owns " rry SALP 17 ring this assessment period, engineering and technical support

'vities were satisfactory relative to administration of design

'ol, documentation and modifications.

ontrols were generally effective. Design control e were upgraded to reflect the lessons learned through t Baseline and Verification program and a design en. group was established onsite to improve the effe of engineering functions. An upgraded Design Change Notic, osure process tracked modifications to completion and as all documentation, including drawings, were changed 'odifications before closure.

The quality 'odification and temporary design change if post modification packages was The packages contained adequate docui modification testing, 10 CFR 50.59 safety evaluat> 'ial procurement, and interfacing between design development '.allation responsibilities. One area where the design ~ ~cess was not fully successful was licensee control of ~ activities. Several violations, one deviation and a 'sued stop work order had occurred in this area since Aug +~ oncerning contractor performance of design work witho ut ~ +~ ion, failure to update a primary drawing, and failure to r, ~~ 't 2 Unit 3 separation and access control requi rement. ~< ah these items were related to Unit 3 design activi ties, ti. + 4 Unit 2 support systems.

An additional exampl e where t. +< control process was not fully successful con cerned the <a >ir monitoring (CAM) system. The effects of sharp ber sample piping and sample probes that did not meet ANSI rec, is were not thoroughly evaluated prior to system installax Primary drawing discrepancies, which we ied as a weakness in the previous assessment period, were ~lied in this assessment period. Primary drawings are x ained in the control room which are necessary for plant All known discrepancies in primary drawings were corre< to restart.

Subsequently, two isolated instances of failur ~ primary drawings were identified: one due to the inadv. ellation of a field change request to correct reversed wii '~ywell radiation monitors to control room recorders and o inadequately controlled contractor design work on t, 'ing tower switchgear C loop.

Engineering oversight and involvement in plant operatio good this assessment period. Representatives interfaced management and other engineering groups in plan-of-the-day meetings and interfaced effectively with oversight committe~

as the Management Review Committee and Plant Operations Revie

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I SALP 18

'ttee. Improved engineering involvement in day to day

'ions resulted in effective support for plant operations. An of prompt problem analysis and design modification was in the resolution of the HPCI pump trip on low suction I. 'uring fast start. The problem was resolved by in i of a time delay in the trip circuitry. Another exa. qineering support for operations included the on-line corr~ the air leakage into the drywell, which created an oxyger ~tion problem.

The time, quality of engineering support in the maintenanc e gene rally good. For example, timely engineering as ob served during repair of leaking valves in the Unit . A Technical Specification waiver placed a rigid time lie. re pair. When the job could not be performed as pl. '1 neering provided a resolution to the problem and the depleted within specified time limits.

- also evident in materials control Good engineering s when analysis of fa. 'hich were slightly out of specification, showei o.ners could be used in the planned application with a lal margin. One engineering problem not resolved in a timel. +< 'as the control room emergency ventilation system which outside its design specification. Engineeril. 'idered the problem but the corrective action comnitmen been extended.

W~ gth.

c System engineers continued to The s ystem engineer assumed ownership of his system ~tive in 1'dentifying and resolving problems, performing ri '.em walkd owns, recommending design changes, and I. system tests.

Additionally, the system engineer t. zd in incident investigations for his assigned system ~robl em identified in a system walkdown concerned the ana 'nit s (ATUs) which indicate main steam line high flow. Ce. w ere intermittently activating due to process wer was reduced to stabilize the units, data was taken foI ering evaluation and a modificati'on was developeo ~ the problem. During installation of the modific. ystem engineer recognized that continuing work coul>. ly result in the loss of Technical Specification requireo Work was stopped, work instructions revised, and the . ful 1 y completed. Another example where a system walkdoi, ctive was the identification of several interferences due, 1 expansion.

System- engineers also contributed effectively to the sl.

the Power Ascension Test Program. For instance, during .

operability test, the reactor engineer in the control rooi.

constantly monitored core thermal limits and other core performance parameters. He made accurate predictions of rea

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Brow~ SALP 21 management attention and support for resolving significant al and safety issues were almost always evident. Important s were consistently made at appropriate levels to ensure

'. management review had taken place. Corporate ma was frequently involved in site activities. At any gll 'loth TVA management and plant personnel regularly delllo ~ comprehensive grasp of the complex technical and safet. hat affected plant performance.

Staffing ~ and corporate licensing personnel was ample, as evidenceo ability to meet its regulatory responsibilities and mainta. over the backlog of licensing actions. The experience a o.nce of TVA's licensing staff remained a strength thro ~ SALP period. Technical and engineering support of lic. 'ivities, both in expertise and staffing, was .more than al. 9n those occasions when TVA employed the services of outs> -.tors/consultants, they were generally used to augment i n. 'bilities.

One of the most sign ~ ~rovements was in the implementation of TVA's corrective ac ams. This was evident by the programmatic upgrades i. 'ling of identified safety significant issues, impri a the tracking and assurance of timeliness of addressing > problems, and an increased level of attention by manag he review of Conditions Adverse to guality (CA() doc <~ '0 continued to reduce the number and improve the timel il. +~ 'standing open corrective action items. The number of ope ws Adverse to guality went from 81 at the beginnin g ot aeriod to 54 at the end of the period. The number o act. f 'a single corrective action document involved one or mor 'tems) that became late during Hay 1991 was 25 Based o.d management attention in this area, that number ci ~ decrease until in April 1992 only 2 action items were lax TVA's reportability threshold and root ca.

conservative throughout the SALP period.

improvements occurred in TVA's incident inv~

~nations were noticeable orogram.

These included requiring an evaluation for hu. ~ance factors for more significant events involving, errors and reduced time frames for more significant events. 'uch management attention went into this program, comp 1 event reports did not always identify the actual root ca ~r the full scope of the problem. An example of this was ~ed "1A" 0/G automatic start that occurred on December l~ ich failed to mention the engine overspeeding which also r.

during the event. Another example included an incident investigation associ.ated with failure to update primary i for the 4160V Loop following closure of a design change il.

timely manner resulting in configuration problems and an ir,

Brown~ "y SALP 22 ssment of electrical loads. The final event report for this 0 to identify the correct root cause. Additionally, an

~ of missing information in a LER (50-260/91-09) was

'o.d during the SALP period.

1. ts to enhance plant safety during outage activities we) by improved switchyard access controls and various chan 's program for management of outage activities.

Outag~ ~l planned and conducted with proper sensitivity to shutdo~ hese changes were based on recent NUMARC initiati. 'o.d to improve plant safety. The main emphasis was to max availability of safety related equipment above the minimum by the Technical Specifications and to minimize sta, ities during critical evolutions.

equality Assuran. always proactive in identifying problems. Severa in licensee programs were not identified by TVA ,

'RC inspections. Examples of these were the control of - activities involving the removal of fire wrap from operas < wnt and configuration control problems. Improvement. ~d in better communications between managers, 'he staff; improved management at the site; ano super'eamwork

>< 'ttention by senior TVA management toward improvem~ Condition Adverse to guality programs. O~

Improvement has been evident it.

+ 'ity and

+~> timel iness of licensing submittals. TVA's res, %en eric Letters (GLs) and regulatory reporting requirem~ most always timely, complete, and technically accurate. ".e during the SALP period did TVA fail to provide a .tim, e (GL 91-11 and 10 CFR 54(w)); and once provided incorre~ ion (ERDS). These examples were isolated occurrences, tha "opriately dispositioned. Furthermore, TVA's respond 'ulatory initiatives and requirements consistently ~d a clear understanding of the technical issues invol. e occasionally proactive (e.g. expanded IPE at. 'ent) ~

TVA continued to exhibit instances of poor plann> V pursuit of high priority plant specific licensing . 'ded to support plant operations or anticipated outage wi les of these instances, where inadequate planning by TVA unnecessarily exigent evaluations by NRC, included: AS, e N-491, HVAC Seismic Criteria, certain Technical Specifi~

(TS) amendments (TS-299 and TS-295), and an exemption frc 50 Appendix J.

The technical approaches used by TVA in their submittals were consistently sound,,thorough, and reflected appropriate 4

I Brown. erry SALP 23 onservatisms from a safety and regulatory perspective. In a

~ited number of cases the technical content of TVA's submittal incomplete or ambiguous (Status of Post- restart commitments "ywell Steel Seismic Criteria). On these, and other, ns where further clarification and/or additional

'on was warranted, TVA's responses were timely and In general, the quality of TVA submittals was high.

Copa between TVA and the NRC staff was excellent.

Chani ~changing information were constantly open and routin 'sed at all levels of TVA and NRC. Conference calls a, s were regularly used by TVA and the staff to effective, 'e the progress of licensing actions. TVA frequently 'pecial meetings to brief new staff reviewers on the extei iry and background of specific licensing actions.

TYA continued tc e difficulty in meeting established schedules. TVA t. ".hieve many of its own scheduled commitment dates fi 'ng important licensing activities, TVA usually notifiea f any impending slippage in its commitment schedules, fluently negotiated acceptable alternatives. The coon. cking program was generally effective. However a ne. ~d in the timely completion of commitments and resolving o+ al Part 21 issues was identified during the SALP samples of this were delays in resolving concerns asso ci~ W~ afety relief valve acoustic monitor card and Rosemount tra ~ ~oblems and extend,ing the resolution of the Control Room i 'entilation System design.

Unit 3 interface activities and conx tractor activities was a weaknesses. Although a unit se, "ogram existed, examples were identified that indicatei rs did not understand personnel access requirements 'subcontractors were not adequately controlled and superv. field.

Licensee management did not ensure these ac .re properly authorized prior to work beginning.

Two Violations were issued in this area.

2. Performance Ratin Category: 2 Improving

3. Board Recommendations The board recommends that TVA keep management attention foci timeliness of submittals and commitment schedules.

P e