ML18036B029

Responds to NRC 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 DISTRIBUTIONDEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 9209010103 DOC. DATE: 92/08/2b NOTARIZED:

NO SCIL: 50-259'roens Ferry Nuclear Poeer Stationi Unit 1>

Tennessee 50-260 Brains Ferry Nuclear Poeer Station>

Unit 2>

Tennessee 50-296 Broens Ferry Nuclear Poeer Station>

Unit 3i Tennessee AUTH. NAME AUTHOR AFFILIATION ZERINGVE> 0. J.,

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

DOCKET 0 05000259 05000260 0500029b 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 ID CODE/NAME HEBDON> F NILLIAMSiJ.

COPIES LTTR ENCL RECIPIENT ID CODE/NAME ROSS> T.

COP IES LTTR ENCL INTERNAL: ACRS AEOD/DEIB AEOD/TTC t

NRR MQRISSEAUX D NRR /DLP8/LP EB 10 NRR/DREP/PEPB9H NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 2

1 1

1 1

2 1

2 AEOD AEOD/DSP/TPAB DEDRO NRR/DLPG/LHFBPT NRR/DOEA/OEAB NRR/PMAS/ ILRB12 E P~

REG FILE 02 EXTERNAL:

EQSIG/BRYCEi J. H.

NSIC NRC PDR 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 Tennessee Valley Authority Docket-Nos.

50-259 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)

f.

SALP CYCLE 10 MAY24,1991 THROUGH MAY23, 1992 BR WNS FERRY NU LEAR PLANT JULY 27,1992

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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 PROJECTS J. PARTLOW ASSOC. DIRECTOR FOR INSPECTION AND TECHNICALASSESSMENT DIVISION OF REACTOR PROJECTS I/II S. VARGA, DIE I/II G. LAINAS, ASST. DIE II F. HEBDON, DIFF'IX T. ROSS,SR PROJ MGR BFNP2 DIVISION OF ENGINEERING TECHNOLOGY DIVISION OF OP ERATIONAL EVENTS ASSESSMENT DIVISION OF REACTOR INSPECTION AND SAFEGUARDS DIVISION OF RADIATION PROTECTION AND EMERGENCY PREPAREDNESS DIVISION OF REACTOR PROJECTS III/IV/V AND SPECIAL PROJECTS DIVISION OF LICENSEE PERFORMANCE AND QUALITYEVALUATION DIVISION OF SYSTEMS TECHNOLOGY

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

.ACT.DiR. J. JOHNSON DEPUTY J. JOHNSON DIVISION OF REACTOR SAFETY DIR.

A. G!BSON DEPUTY E. MERSCHOFF DIVISION OF RADIATION SAFETY AND SAFEGUARDS DlR.

J. STOHR DEPUTY B. MALLETT-

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

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SALP CYCLES 9 AND I0 FUNCTIONAL AREA OPERATIONS RAD CONTROL MX/SURV EMER PREP ENG R/TECH SA/QV SECURITY RATING LAST PERIOD 2 (SHUTDOWN) 3, I MPROVING 2, IMPROVING 3, IMPROVING RATING THIS PERIOD 2, IMPROVING BFNP2

I

(CATEGORY 1)

STRENGTHS

~

CREW PERFORMANCE

~ STAFFING

~ OPERATOR TRAINING

~

FIRE PROTECTION

~ PLANNING

~ SELF ASSESSMENT CHALLENGES

~ INDEPENDENT VERIFICATION

~ LABELING

~ ATTENTION TO DETAIL

(CATEGORY I )

STRENGTHS

~ MANAGEMENTSUPPORT

~ ALARAINITIATIVES

~ STAFFING

~ AUDITS

~ EFFLUENT CONTROLS

~ CHEMISTRY

~ SOLID RADIOACTIVEWASTE CHALLENGE

~ MAINTAININGGOOD PERFORMANCE

I I

I

(CATEGORY 2)

STRENGTHS

~

MATERIALCONDITION

~

PREVENTIVE MAINTENANCE

~

BACKLOG MANAGEMENT

~

PROCUREMENT

~

POST MODIFICATIONAND POST MAINTENANCETESTING PLANNING

~ SURVEILLANCE PROGRAMS AND IMPLEMENTATION

(CONTINUED)

CHALLENGES

~

CORRECTIVE ACTIONS

~

CONFIGURATION CONTROL

(CATEGORY 2)

STRENGTHS

~

MANAGEMENTSUPPORT

~

EXERCISE PERFORMANCE

~

EVENT CLASSIFICATION

~

FACILITIES

~

PLAN CHANGES

~

SELF ASSESSMENT CHALLENGES

~ AUDIBILITYOF ADDRESS SYSTEM

~

OSC/REPAIR TEAM COORDINATION

I i

(CATEGORY 2)

STRENGTHS

~

MANAGEMENTSUPPORT

~

FACILITYUPGRADES

~

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 INVESTIGATIONPROGRAM

~

UNIT 3 INTERFACE

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

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

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

MAINT/SURV 14%%uo EMERG. PREP 1'Po SA/QV S%%uo RAD CON 2%

ENGR/TECH SUPT 7%%uo OTHER 4%%uo OPERATIONS 62%

(STLMEI.CH3)

SALP CYCLE 10 FUNCTIONAL AREA OPERATIONS RAD CONTROL MX/SURV EMER PREP ENGR/TECH SA/QV SECURITY NONCITED 0

LEVEL IV

~

I 3 0

LEVEL ill TOTAL BFNP2 13

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SALP CYCLE 10 COMP FAILURE 36%

DESIGN/

CONSTR.

l8%

PERSONNEL 47%

TEST/CALIB 2 MAINT. 3 OPEHATINQ 3 TOTAL (17)

PERSONNEL (8)

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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 29 two violations An auxiliary plant operator pulled the wrong fuses during a routine tagout.

one violation

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

Deleted Basis:

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

15 15 15 12 13 14 During this assessment weaknesses One was...

A second was...

period.....

Prior to...

one weakness Deleted 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 the problem but the corrective action commitment date has been extended.

Engineering expended considerable man-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 manner...

Deleted 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 Basis:

Examples do not support a trend.

Some problems

1

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ENCLOSURE INITIAL SALP REPORT NUCLEAR'EGULATORY COMMISSION REGION II SYSTEMATIC A'NSPEC1 TENNESSEE VALLE)

BROWNS FERRY UN.

'c LICENSEE PERFORMANCE c"

NUMBER O~

50-2, c~

FROM MAY 24, 1991 THROUGH MAY

B."owns Fer re~

unex train next p

later ci implemenl.

ir error occurred during a controlled plant shutdown.

The

~tor exciter field -breaker was not opened as required an operator tripping the reactor due to a number of uipment responses.

As a result of this, additional

~ven to operating crews on the simulator before the

'tdown.

A shutdown for a maintenance outage was

'ithout difficulty indicating an ability to learned.

Close coora were display<

control and il.

and scheduling significant prob was further expan, Assurance (gA) org.

and other departmenl.

assigned to provide s

was returned to power The outage planning cond'utage was a strength.

Tl guidelines for risk reductl were conducted several times zg an eight day maintenance ately implemented the NUMARC outages.

Outage meetings v~

nt verification, ctive independent

'se replacement in a

ling problems resulted was found labeled on ications was a

'rong fuses during ry Containment t chart paper O

Problem areas were identified

+

4e

labeling, and attention-to-detal verification failed to identify i.

diesel generator (DG) control circ.

in two violations.

A drywell blower two diFferent electrical boards.

On~

spare.

An auxiliary plant operator pu a routine tagout.

Problems associated Radiation Monitor three pen recorders an.

recurred due to ineffective corrective ac'i

'd effective communication between departments olan of the day meetings.

Operations've helped to achieve effective planning evolutions.

This led to a lack of ig the PATP.

The operational influence

'cing a licensed SRO into the equality work control group, outage

planning,

~s of operations management were "age during outages until. the unit Strong management support of operator train>

evident.

All candidates passed initial licen.

June and December 1991.

The plant simulator w, certified during this period.

ed to be given in 1 and TVA maintained a dedicated professional fire prote with a fire truck located inside the protected area 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.

1 on te.

t I

~LP 1

ace w>th pr;

'rainin dut.

larif effec locke Condit

~pe Improvei.

compensate effective'i.

training dr watch was no.

residual heat intake structur personnel, a con.

operations work ci Six Violations were 2.

Performance Ratir.

exist,

,Fire protection systems and equipment installed ction of safety-related areas were functional and tested requirements specified in the TS.

Fire g was comprehens,ive.

Oefinitions of fire watch ied to insure compliance with TS.

TVA d Appendix R and TS fire protection Limiting ration (LCOs) during plan of the day meetings.

noted in labeling of Appendix R equipment and Nose station.

The ability to quickly and to plant fires was demonstrated through inor events in the plant.

A TS required fire ed after fire wrap was removed from. operable

~rvice water pump power cables in the igh this activity was performed by Unit 3

factor to this problem was separate ters for Unit 3 and Unit 2.

Category:

1 3.

Board Recommendations None Radiolo ical Controls O~

c~

1.

~Anal sis This functional area addresses those a

to radiological controls, radioactive w,

environmental monitoring, water chemistry radioactive material.

directly related

~ment,

'sportation of Overall, the radiation protection program coi aggressively control personnel exposure to ra~

and protect the health and safety of the plant, publ.ic.

'ateri al s and the to Management oversight and support were effective.

year (FY) 1992 ALARA goals were included in management pe standards.

The ALARA/Radwaste Committee (ARC) was re 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 ma

doo, intro have c,

hardwar~

During thi.

control.

On employees to

~

was unalarmed a.

prior history of were outside this under review by the

>t period, TVA identified weaknesses in access eermitting of two terminated contractor

~lant.

A second was a vital portal that ied in excess of one hour.

TVA had a

~trol problems of the first type which iod.

This access control problem was

~ end of the period.

d~

~quately staffed and trained to control, detection and

~nsatory measures.

The

'equate training and

', security system as demonstrated by The security organizat perform duties related L

dc assessment, armed respons.

security training program p

qualification in the areas o.

utilization, and procedural r~

security personnel performance.

'Strong support of the security pro security management remained evideni commitment and funding of a major upg the recent procurement of new hand-heli utilized in the.access

portals, and the automatic handguns and rifles.

Hanagemen, the operational effectiveness of the secur>

personnel performance.

Authority was delega supervisors with encouragement to participat involved in the management of the security prog.

"porate and site trated by the

~ security

system, equipment to be to semi-

'ons to improve and enhance t

e

'el y

.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 shed commitments for Unit 2 restart.

Included was the

'n the size of the protected area that decreased the "equired compensatory patrols, replacement of

'ng turnstiles with electronic card key controlled

~ portals, and modifications to the perimeter tion and assessment systems.

The actions to date to improved effectiveness of access control

'esponse.

An aggressive audit program contributed to the ide.

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, and

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.

t en.

effe

Notic, and as changed ontrols were generally effective.

Design control e were upgraded to reflect the lessons learned through Baseline and Verification program and a design group was established onsite to improve the of engineering functions.

An upgraded Design Change osure process tracked modifications to completion all documentation, including drawings, were

'odifications before closure.

The quality packages was adequate docui safety evaluat>

design development where the design

~

licensee control of one deviation and a

in this area since A

of design work witho

drawing, and failure access control requi Unit 3 design activi An additional exampl fully successful con system.

The effects probes that did not evaluated prior to system installax

'odification and temporary design change The modification packages contained if post modification testing, 10 CFR 50.59

'ial procurement, and interfacing between

'.allation responsibilities.

One area

~cess was not fully successful was

~ activities.

Several violations,

'sued stop work order had occurred ug

+~

oncerning contractor performance ut

~

+~ ion, failure to update a primary to r,

~~ 't 2 Unit 3 separation and rement.

~<

ah these items were related to ties, ti.

+

4 Unit 2 support systems.

e where t.

+<

control process was not cerned the

<a

>ir monitoring (CAM) of sharp ber sample piping and sample meet ANSI rec, is were not thoroughly ied as a weakness

~lied in this ained in the All known to restart.

~ primary ellation

'~ywell Primary drawing discrepancies, which we in the previous assessment

period, were assessment period.

Primary drawings are x

control room which are necessary for plant discrepancies in primary drawings were corre<

Subsequently, two isolated instances of failur drawings were identified:

one due to the inadv.

of a field change request to correct reversed wii radiation monitors to control room recorders and o

inadequately controlled contractor design work on t, tower switchgear C loop.

'ing 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

1

~ '

I SALP 18 I.

in exa.

corr~

oxyger The time, quality maintenanc e gene engineering as ob in the Unit.

A rigid time lie.

re performed as pl.

'1 problem and the Good engineering s

when analysis of fa.

specification, showei application with a lal not resolved in a timel.

ventilation system which specification.

Engineeril.

corrective action comnitmen of engineering support in the rally good.

For example, timely served during repair of leaking valves Technical Specification waiver placed a

pair.

When the job could not be neering provided a resolution to the depleted within specified time limits.

- also evident in materials control

'hich were slightly out of o.ners could be used in the planned margin.

One engineering problem

+<

'as the control room emergency outside its design

'idered the problem but the been extended.

ystem engineer

'dentifying and

owns, tests.

incident em identified s

(ATUs) which ere wer was reduced ering

~ the ystem ly result Work ful 1 y ctive 1

System engineers continued to W~ gth.

The s

c assumed ownership of his system

~tive in 1

resolving problems, performing ri

'.em walkd recommending design

changes, and I.

system Additionally, the system engineer t.

zd in investigations for his assigned system

~robl in a system walkdown concerned the ana

'nit indicate main steam line high flow.

Ce.

w intermittently activating due to process to stabilize the units, data was taken foI evaluation and a modificati'on was developeo problem.

During installation of the modific.

engineer recognized that continuing work coul>.

in the loss of Technical Specification requireo was stopped, work instructions revised, and the.

completed.

Another example where a system walkdoi, was the identification of several interferences

due, 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

'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

'uring fast start.

The problem was resolved by i of a time delay in the trip circuitry.

Another qineering support for operations included the on-line the air leakage into the drywell, which created an

~tion problem.

'I 1

Brow~

SALP 21 magll delllo safet.

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 was frequently involved in site activities.

At any

'loth TVA management and plant personnel regularly

~ comprehensive grasp of the complex technical and hat affected plant performance.

Staffing evidenceo and mainta.

experience a

strength thro support of lic.

was.more than al.

services of outs>

used to augment i

~ and corporate licensing personnel was

ample, as ability to meet its regulatory responsibilities over the backlog of licensing actions.

The o.nce of TVA's licensing staff remained a

~ SALP period.

Technical and engineering

'ivities, both in expertise and staffing, 9n those occasions when TVA employed the

-.tors/consultants, they were generally n.

'bilities.

One of the most sign of TVA's corrective ac programmatic upgrades i.

significant issues, impri timeliness of addressing level of attention by manag Adverse to guality (CA() doc number and improve the timel action items.

The number of went from 81 at the beginnin of the period.

The number o

action document involved one late during Hay 1991 was 25 attention in this area, that April 1992 only 2 action items were lax

~ ~rovements was in the implementation ams.

This was evident by the

'ling of identified safety a the tracking and assurance of

problems, and an increased he review of Conditions

<~

'0 continued to reduce the il.

+~

'standing open corrective ope ws Adverse to guality g ot aeriod to 54 at the end f act.

'a single corrective or mor

'tems) that became Based o.d management number ci

~ decrease until in TVA's reportability threshold and root ca.

~nations were conservative throughout the SALP period.

', noticeable improvements occurred in TVA's incident inv~

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 we) chan Outag~

shutdo~

initiati.

was to max the minimum minimize sta, to enhance plant safety during outage activities by improved switchyard access controls and various

's program for management of outage activities.

~l planned and conducted with proper sensitivity to hese changes were based on recent NUMARC

'o.d to improve plant safety.

The main emphasis availability of safety related equipment above by the Technical Specifications and to ities during critical evolutions.

equality Assuran.

problems.

Severa identified by TVA were the control of fire wrap from operas problems.

Improvement.

between

managers, super'eamwork at the site; ano management toward improvem~

programs.

always proactive in identifying in licensee programs were not

'RC inspections.

Examples of these

- activities involving the removal of

< wnt and configuration control

~d in better communications

'he staff; improved management

>< 'ttention by senior TVA Condition Adverse to guality O~

and timel iness of eric Letters (GLs) most always timely,

".e during the SALP e

(GL 91-11 and 10 ion (ERDS).

These "opriately

'ulatory

~d a clear e'ent)

~

+

Improvement has been evident it.

+~> 'ity licensing submittals.

TVA's res,

%en and regulatory reporting requirem~

complete, and technically accurate.

period did TVA fail to provide a.tim, CFR 54(w));

and once provided incorre~

examples were isolated occurrences, tha dispositioned.

Furthermore, TVA's respond initiatives and requirements consistently understanding of the technical issues invol.

occasionally proactive (e.g.

expanded IPE at.

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 Chani routin calls a,

effective, frequently on the extei actions.

between TVA and the NRC staff was excellent.

~changing information were constantly open and

'sed at all levels of TVA and NRC.

Conference s were regularly used by TVA and the staff to

'e the progress of licensing actions.

TVA

'pecial meetings to brief new staff reviewers iry and background of specific licensing TYA continued tc schedules.

TVA t.

commitment dates fi TVA usually notifiea commitment schedules, alternatives.

The coon.

effective.

However a ne.

commitments and resolving identified during the SALP in resolving concerns asso monitor card and Rosemount resolution of the Control design.

e difficulty in meeting established

".hieve many of its own scheduled

'ng important licensing activities, f any impending slippage in its fluently negotiated acceptable cking program was generally

~d in the timely completion of o+

al Part 21 issues was samples of this were delays ci~

W~

afety relief valve acoustic tra

~

~oblems and extend,ing the Room i

'entilation System Unit 3 interface activities and conx was a weaknesses.

Although a unit se, examples were identified that indicatei understand personnel access requirements were not adequately controlled and superv.

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

Two Violations were issued in this area.

tractor activities "ogram existed, rs did not

'subcontractors field.

.re properly 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