ML20046B926
| ML20046B926 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/03/1993 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308090031 | |
| Download: ML20046B926 (17) | |
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August 3, 1993 6
i U.S. Nuclear Regulatory Lommission ATTN: Document Control Desk
-i Washington, DC 20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 i
SEQUOYAH NUCLEAR PLANT (SQN) - RESPONSE TO NRC APRIL 15,~1993, LETTER l
REGARDING SQN RESTART ISSUES
References:
1.
Letter from David E. LaBarge (NRC) to TVA dated April 15, 1993, " Meeting of April 12, 1993 - Sequoyah Restart Issues" 1
2.
Letter from Robert A. Fenech to S. D. Ebnetar dated i
May 20, 1993, "Sequoyah Nuclear Plant (SQN) - Restart t
Plan" This letter responds to the restart questions posed by NRC in-Reference 1.
As discussed with NRC at the Restart Panel-meetings on April 12 and May 24, 1993, comprehensive efforts have been made to identify key problems challenging effective operations. Both hardware and nonhardware issues were identified and grouped into~ focus areas. The-l six focus areas are:
(1) Balance of Plant, (2)_ Operations, (3) Backlogs, (4) Programs,:(5) People / Organization / Culture, and (6) Corporate / Site
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t Interface and are audressed in the SQN Restart Plan.
In analyzing the underlying causes of performance weaknesses'over the past several years, two key areas were identified:
(1) ineffective-resource management and (2) ineffective personnel and management performance.
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U.S. Nuclear Regulatory Commission Page 2 August 3, 1993 I
Significant efforts are underway to address existing problems, implement the necessary corrective actions for the restart of the SQN units, and-ensure that processes are in place that not only prevent recurrence, but also affect long-term change to improve overall site performance.
In order to address the first issue (i.e., the restart of the units) TVA' has implemented ongoing restart efforts at SQN as described in the SQN Restart Plan, provided to NRC by Reference 2.
To address the long-term issue of continued performance improvement, a postrestart Site l
Improvement Plan will provide a detailed, structured document for identification and prioritization of postrestart improvement actions and will include defined performance indicators and processes for continuing periodic monitoring of progress and performance.
The Site Improvement Plan will provide the framework for the development of the SQN business plan.
TVA acknowledges that several of the current problems are the result of similar causes to those identified in 1985 and fully understands NRC's concern over these similarities.
In both instances, lack.of effective-
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manage ont is at the heart of the problems.
However, the scope and the.
resolution of the_ current problems. differ from the situation presented
-i during the 1985'to 1988 timeframe. This is in part because the: current issues are focused more on the secondary plant as opposed to the primary plant.
TVA is confident-that these efforts will not only address current problems but also will prevent recurrence and provide the bases for continued improvement. The scope and nature of the actions being undertaken by TVA, as more fully described in the enclosure, support this conclusion.
If you havr
'uestions concerning this submittal, please telephone
') 843-7170.
R. H. Shell Sincerely, Mark O. Medford Enclosure cc: See page 3
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1.-s-1 U.S.-Nuclear Regulatory Commission Page 3 August 3, 1993 I
i cc(Enclosure):
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Mr. D. E. LaBarge,-Project Manager U.S.-Nuclear Regulatory Commission One White Flint North i
11555 Rockville Pike j
Rockville, Maryland 20852-2739 t
t NRC Resident Inspector i
.Sequoyah Nuclear Plant-2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator.
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 y
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ENCLOSURE RESPONSE TO NRC APRIL 15. 1993 SE000YAH N" CLEAR PLANT (SON) RESTART LETTER QUESTION 1
" Describe the problems that existed in the early 1980s that subsequently lead to the shutdown of both Sequoyah units from 1985 to 1988. Describe the degree to which these problems are similar to the problems that currently exist at Sequoyah."
TVA RESPONSE 1.
Problems leadina to the 1985 to 1988 Shutdown in August 1985, TVA voluntarily shut down SQN because of questions raised regarding the adequacy of the environmental qualification of electrical equipment at SQN.
In response to events that reflected adversely upon the quality of TVA's nuclear program, TVA prepared a Corporate Nuclear Performance Plan. The Corporate Nuclear Performance Plan identified the root causes of the problems in the management of TVA's nuclear program as:
(1) the lack of a sufficient number of experienced managers to provide leadership and proper direction, and (2) the lack of an effective organizational structure. The Sequoyah Nuclear Performance Plan (SNPP) further identified the root causes of problems specific to SQN. The three primary causes were:
(1) lack of a clear assignment of responsibility and authority to managers and their organizations that clearly established accountability for performance, (2) insufficient management involvement and control in the workplace leading to a failure to adequately establish highest quality, and (3) failure to consistently document the design for the plai,t and maintain the plant's configuration in accordance with that basis.
The focus during this shutdown on the primary plant contributed significantly to the inadequate attentior to balance-of-plant.
2.
Similarity to the 1993 Shutdown in a meeting with NRC on April 12, 1993, TVA identified the causes of the current problems at SQN.
First, a lack of effective management was manifested in inadequate oversight and follow-up, in a lack of clear definition of responsibilities, and in poor resource utilization.
The i
second cause was poor personnel performance. As described to NRC at the May 24, 1993, meeting, TVA concluded that the single, underlying root cause of recent deficiencies was ineffective management.
TVA acknowledger, that the ineffective management problems experienced from 1985 to 1988 are similar to those that resulted in the 1993 shutdown. As often is the case with performance deficiencies, the _ lack of effective management
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is the root cause of SQN's current problems.
However, the 1985 l
shutdown.;as due to pervasive problems whereas the current shutdown i
I is dur
.i specific management deficiencies as well as ineffective management of BOP systems.
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TVA leade ship
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- 0. D. Kingsley, Jr., took command of TVA's nuclear program in late i
1988, at which time senior management was a combination of contractor and TVA personnel. Also, the direction of TVA's nuclear program was provided by corporatre management. Several of Mr. Kingsley's immediate goals were to replace the remaining contract senior l
managers with existing TVA personnel, have nuclear direction transferred to the sites, and seek more qualified personnel. The replacements hired at SQN in the early phases did not always meet-the expectations or the goale set for the recovery of the nuclear program.
Therefore, th u as well as normal attrition, has necessitated the numerous management changes at.SQN.
The current SQN management team has Mr. Kingsley's full confidence.
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SOLUTIONS l
TVA has initiated prompt, comprehensive action to effectively address the l
problems before restart and ensure that they do not continue after
-l restart. For example, the following-actions.have been taken-in response to the problems described above.
1.
SON Leadership t
As a result of lessons learned in the development of the SQN l
management team, changes have been and are being made. The Site Vice i
President, Plant Manager, and Operations Manager have been replaced.
Additional management experience has been added in Engineering, Licensing, Quality Assurance, and Technical Support. Other key i
management positions are being evaluated. These changes are being made to effect long-term cultural changes to improve overall site j
performance.
In order to foster effective leadership at SQN, a i
personnel evaluation team has been formed for short-and long-term j
strengthening of personnel-performance. TVA is taking aggressive-development actions for the SQN management team.
In addition, line managers are being evaluated for the purpose of determining their l
effectiveness.
l 2.
Manaaina Chat,ae of Responsibility i
Individual responsibility and accountability are being established.at SQN.. For example, the erosion / corrosion program is now " owned" by i
the site with responsibilities clearly defined.
Switchyard management responsibilities and interfaces have been defined by_
i establishing an onsite owner and tightening the control of switchyard work. As discussed in response to questions 4 and 6, substantial changes have been made in the management at SQN.. Additional-
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limitations have been placed on switchyard activities during high-risk evolutions in the plant in accordance with recommendations contained in NUMARC 91-06 (Guidelines for Industry Actions to Assess Shutdown Management).
Department managers, as part of readiness assessments, are responsible for evaluating the effectiveness of their programs prior to restart.
3.
Corporate Manaaement TVA corporate management has undergone a recent reorganization that included the selection of a new Vice President of Nuclear Operations (R. M. Eytchison), who has extensive nuclear and management experience. A Vice President of Nuclear Readiness (D. R. Keuter) reports to Mr. Eytchison and is responsible for ensuring operational readira.ss through site assessments of management, readiness reviews, organizrtional effectiveness, policy and procedures.
The reorganization realigns the corporate nuclear support functions under a single Vice President of Technical Support (Mark 0. Medford) to combine and streamline related technical support functions and enhance corporate oversight functions.
The corporate reorganization provides further management direction on expectations for the oversight function. All site technical activities performed by corporate personnel are under the direction of site management.
Furthermore, a corporate support document has been developed that i
defines corporate's division of responsibilities for SQN activities.
QUESTION 2
" Describe the issues that had not been resolved prior to restart of Sequoyah Units 1 and 2 in 1988. Describe the basis for delaying resolution until after restart and the current status of resolution of these issues. Describe the degree to which the delay in resolution of these issues contributed to the recent decline in performance at Sequoyah."
TVA RESPONSE 1.
1988 Restart Open Items In general, a number of design and engineering issues remained to be resolved at the time of the 1988 SQN restart.
Post-restart engineering activities were evaluated and determined not to be of sufficient significance to require resolution before restart.
hsues carried forward for resolution after restart established additional margin or extended restart programs beyond accident mitigation safe shutdown systems.
The following list summarizes most of the key issues that were outstanding at SQN at the time of restart.
Phase 11 of the design baseline and verification program which was limited to safety related systems.
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This included the completion of a final as-constructed f
configuration, additional refinements to the new design control i
process, and a drawings upgrade. Phase I included the implementation of a change control board and a transitional 1
design control system.
i Phase II of the alternately analyzed (AA) piping.
Large bore pipe support modifications to establish additional t
margin consistent with the Final Safety Analysis Report limits.
Some 10 CFR 50 Appendix R issues.
Control Room Design Review human engineering deficiencies, f
i Electrical issues such as the diesel generator loading and voltage response and the 6.9-kilovolt (kV) unit board load breaker issue.
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Some design calculations in the electrical, mechanical, and civil / structural areas.
The cable program included numerous actions required-in the-areas of. pulling,' tray support design, testing (low voltage),
routing, conduits, silicone cables, submergence, and bend.
radii.
These' issues,were-the subjectrof significant analysis i
and staff review before restart.to define restart requirements 1
and safety significance.
l The piece parts qualification (procurement) program had several post-restart activities that included commercial grade dedication, engineering evaluations, and developing.
pre-engineered specifications.
i Remaining environrr.antal qualification items were to be
-l incorporated into Regulatory Guide 1.97 or post-TMI NUREGs-1 implementation and closed when the instrumentation was installed and operable (based on staff agreement on' Regulatory Guide 1.97 and NUREG 0737 implementation schedule).
Employee Concerns Special Programs corrective action tracking documents representing a broad range of electrical, civil, maintenance, industrial safety, and other issues.
2.
Basis for Delayed Resolution of Open Items' i
in March 1986, TVA established a SQN task force to review implementation of corrective actions at the site, to_ initiate
.i specific actions to address problems at SQN, to monitor and. ensure that the list of all known work items had been compiled, and to.
review the processing and identification of those items required to j
be completed before restart. The task force also established the.
restart requirement criteria that are set forth in Section IV-4,-
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i Table 7, of the SNPP.
NRC subsequently reviewed and accepted those criteria by letter dated June 9, 1987.
3.
Current Status of Open Issues The following 1988 postrestart issues remain open at SQN:
(1) Twenty-three Employee Concerns Special Programs corrective action tracking documents primarily representing civil issues and electrical calculation concerns, (2) Category III Control Room Design Review (CRDR) human engineering discrepancies, which are the least significant CRDR finding, (3) civil issues (primarily associated with Inspection Report 327,328/88-12), and (4) 6.9-kV unit board load breaker issue.
4.
Open Issues Did Not Directiv Contribute to SON's Recent Problems The resolution of post-restart open items did not have a direct
.i effect on the current problems at SQN.
However, when SQN restarted in 1988, there were additional activities requiring a significant amount of resources to address.
These items (e.g., vendor manuals, drawings, and calculations), as well as a large number of commitments (approximately 250 were identified as post-restart), were remaining to be completed.
In addition to these, over 1200 other NRC commitments have-been completed since restart in 1988. Additionally, significant resources were applied to improve primary side l
performance, clear regulatory backlog, and improve plant safety.
t These improvements include control room redesign; reactor protection system replacement-(Eagle 21), including reactor trip reduction features; upper head injection removal; implementation of Regulatory Guide 1.97; boron injection n ok removal; generator rewind; annunciator system replacement; RTD bypass elimination; and reactor coolant pump seal replacement.
The commitment of significant resources to these issues and emerging i
regulatory issues indirectly impacted TVA's ability to effectively focus on and understand the composition of the BOP backlog and the magnitude of potential problem areas in the secondary plant.
OVESTION 3
" Assess the degree to which the backlog of maintenance work, particularly work associated with the Balance of Plant, has contributed to the recent number of reactor trips and challenges to the safety systems. Describe steps being taken to reduce this backlog."
TVA RESPONSE 1.
The Maintenance Backloo Contribution to Reactor Trios and Safety System Challence at SON t
The secondary plant material and design condition has been.the source of numerous plant problems.
Since 1988, Sequoyah power generation 1
t has been reduced numerous times, and a number of reactor trips have i
occurred because of problems in the secondary plant.
These occurrences represent a large percentage of the total power i
reductions or trips during this period. TVA is taking significant steps to address the secondary plant problems.
i TVA has assessed the reactor trips and safety system challenges,
.i along with supporting analyses, in order to determine the 7
relationship of any failed component to any outstanding maintenanca 4
work. Based on the results of the assessment, TVA has concluded that there were no reactor trips that were related to backlocaed.
maintenance work items. Although most of the components involved in the reactor trips had received regular maintenance, there were no l
open work requests on that equipment. The most significant component aspects of the postrestart reactor trips at SQN are as follows:
a.
The April 15, 16, and 19, 1989, Unit 2 trips that were caused by the main feedwater system performance have been correted with 1
the replacement of the controller and the implementation of a j
trip reduction package through the Eagle 21 system.
b.
The December 10, 1989, Unit 1 trip was induced by the failure of the No. 3 heater drain tank level control valves. Failures 1
associated with'the valves have been attributed to-design deficiencies. Although resolution of this: issue.hasttaken' considerable time, design changes are'being implemented to address these problems.
c.
The September 19, 1990, and April 28, 1992, Unit 1 trips were l
caused-by the failure of gas operated relays in the' main transformer. The two failure modes are not related. The relays are being upgraded as directed by the Secondary Plant Reliability Study and are scheduled to be completed before restart.
d.
The June 27, 1992, Unit 2 trip was caused by a containmer.t penetration connection problem. This failure was considered 1
nonmaintenance preventable and was more properly considered a i
design issue. A plan is in place to remove one penetration during the Unit 2 Cycle 6 refueling outage, analyze the cause of the failure, and develop corrective actions.
e.
The October 26, 1992, Unit 1 trip was caused by a failure of:a-relay during a transient caused by water in the control air system. The accumulation of water in the control air receiver was caused.by the accumulation of debris'in the bottom of a receiver tank and a drain trap pressure balance line being installed improperly. This resulted in erroneous information to the craft that performed daily preventive maintenance and 1
Operations personnel that performed blowdown of the tanks every shift. The' preventive maintenance' activity'was revised. 'The-1 drain system is being redesigned with implementation scheduled-before restart.
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The manual trips and shutdown that occurred January 28, February 5. March 1, and March 2, 1993, on Units 1 and 2 were the result of extraction line and drain line ruptures.
These failures exhibited a wakness with the erosion / corrosion l
program. Eroded pipes are being replaced before the restart of i
each unit. The erosion / corrosion program also is being strengthened (e.g., new site organization, detailed program review. and Electric Power Research Institute third-party review).
r Challenges to SQN safety systems were considered to be events that caused turbine runbacks or other events that may have required an i
operator to take responsive actions. The challenges to SQN safety systems assessed by TVA are as follows:
a.
Several challenges were caused by the No. 3 heater drain tank level control valves (LCV-06-105 and LCV-06-106).
These valves i
also have caused transients, resulting in reactor trips. This problem is a design issue that is being corrected this outage with design changos to the valves and piping.
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'l b.
Two challenges, one for each unit, occurred during water intrusion into the control air system as discussed previously in l
the October 26, 1992, Unit 1 trip above.
c.
Two challenges, one for each unit, occurred during'the partial loss of control air because of a. failure of a selector. switch.
I The switch had an open work request that was on hold awaiting replacement parts to arrive.
d.
Two challenges were caused by:
(1) a blown fuse which resulted in the loss of diesel generator starting air pressure and (2) an j
engineered safety feature actuation (the start of all four diesel generators) during the performance of a surveillance.
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The results of the review indicated that there were no open work i
requests at the time of the event for the components that caused the challenges, with the exception of the failure of a selector switch as discussed previously.
However, it was determined that the proper priority has not been placed on the resolution and prevention of j
deficiencies in the secondary plant by site management. As a result of this " inattention" to the B0P, material condition deficiencies in the secondary plant have in some cases been long standing and contributed to plant transients and events.
2.
The Maintenance Backloa Reduction Effort at SON
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l As discussed during the April 12, May 24, June 14, and June 21, 1993, meetings with NRC, TVA has implemented a number of activities to l
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e address not only the causes of the post-restart trips and challenges s'
at SQN but also the maintenance backlog--including those in the Balance of Plant (BOP). These activities include:
a.
Analysis of the trips using a quality improvement technique.
The study identified the BOP as being the major contributor to SQN trips and prompted the Secondary Plant Reliability Study.
b.
Completion of the Secondary Plant Reliability Study included a review of the backlog of corrective maintenance and design changes for BOP systems and made recommendations-for restart and postrestart. Restart activities include:
(1) replacement of normally energized relays in the Nos. 3 and 7 heater drain tank l
level control circuitry; (2) replacement of the transformer cooling fan circuit fuses; and (3) replacement of level control j
valves LCV-6-105 and reconfiguration of LCV-6-106 valves piping.
Post-restart activities will include the completion of the reliability centered maintenance (RCM) for BOP, including the recently completed BOP single-point failure analysis and the
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implementation of preventive maintenance or design changes, as appropriate. Priority has been placed on the following BOP systems: heaters, drains and vents; extraction steam, turbo-generator controls, switchyard, and transformers.
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.As a result of these activities, approximately 40 design-modifications will be implemented before restart.
In addition, the corrective maintenance work order backlog is being significantly reduced before restart. The work order backlog has been reviewed to i
ensure that items that potentially impact plant reliability have been added to the restart schedule.
In addition, this review will be i,
revisited on a weekly basis by Technical Support to address new work j
requests to assess the aggregate impacts on system performance.
A dedicated team has reviewed non outage work orders more than one year old to determine whether the problems still exist and whether those low-priority work orders should be placed into the outage.
Work orders more than six months old are currently being reviewed.
As part of the SQN Restart Plan, a Backlog Review Committee (BRC) was established. The BRC is composed of the Technical Support Program Manager, a senior reactor operator, a Maintenance manager, and a Nuclear Engineering manager.
The objective of this committee is to review the backlogs against the restart criteria, including work requests, to determine restart issues. This assessment has evaluated individual and aggregate impact on system functionality of open postrestart items, providing input to the system readiness assessment.
Finally, before restart, maintenance self-assessments will be i
performed to ensure'the effectiveness of the backlog reduction. The SQN Site Quality organization is. assessing the makeup of the maintenance backlog versus the industry to assess restart. readiness.
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@ESTION 4
" Describe the steps that will be taken to more clearly assign responsibility und accountability to the site organization. Describe the steps being taken to identify programs that require modification (e.g.,
programs where fragmented responsibility and a lack of ownership have resulted in ineffective program implementation) in order to improve the performance at Sequoyah."
TVA RESPONSE As discussed in the April 12, 1993, NRC meeting, a significant effort has i,
been underway to reorganize a number of technical programs, which include erosion / corrosion, in-service inspection,Section XI pumps and valves, repair and replacement, pressure tests, check valves, motor-operated valves, 10 CFR 50 Appendix J, environmental qualification, raw water (microbiological-induced corrosion), boric acid, and coatings. TVA concluded that these technical programs were in need of modification because nf the fragmentation of organizational responsibility and implementation between corporate and SQN and between SQN organizations.
As a result, these technical programs have been assigned to the site where appropriate and now are the responsibility of the Technical Programs and Performance Manager, reporting to the Engineering and Modifications Manager.
The establishment of responsibilities and objectives has been defined.
The completion of program assessment, the implementation of the' transitional phase, the establishment of governing procedures, and the establishment of site / program interfaces will be completed before restart.
Performance indicators have been developed to monitor progress.
Corporate oversight had not been effective in preventing problems, and SQN did not readily resolve identified problems.
TVA recognizes this and has taken steps to improve the assignment of responsibility and accountability at SQN. Before the recent shutdown, several of the corporate technical programs were already in the process of being assigned to the site.
Weaknesses that included the inadequate definition of program ownership, fragmented implementation, and lacking clear lines of accountability and responsibility (both site and corporate) had been observed in the organizational structure for several technical programs.
Elements of some technical programs were divided between Operations Services and Corporate Engineering.
The corporate nuclear organization was reorganized in April 1993 in order to provide consistent management direction concerning TVA expectations regarding the corporate organization's oversight function.
The corporate technical support organizations now report entirely to one Vice President of Technical Support (M O. Medford). Before this change, the corporate technical oversight function was performed by several corporate organizations without centralized focus or control.
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Finally, a review of program ownership by corporate Technical Support managers, encompassing policy development and the retention of technical
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expertise, was conducted.
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DVlSTION 5
" Describe the criteria and process that will be used to determine what actions must be taken prior to restart (versus those which can be delayed until after restart)."
TVA RESPQN_SE TVA has developed and implemented a process, described in the Restart Plan (Reference 2), that will be used to determine what actions must be taken before the restart of SQN.
A Management Restart Review Committee (MRRC) was created in March 1993 to define, review, and manage SQN restart and to evaluate and approve items for restart action.
The MRRC is composed of the Site Vice President, Plant Manager, Engineering and Modifications Manager, Site Licensing Manager, Site Quality Manager, Operations Superintendent, and Maintenance Manager.
The restart criteria developed by the MRRC focus on nuclear safety, plant reliability, and operational impacts as documented in the restart plan.
Potential restart items are assessed-and presented to the MRRC by the responsible organization. The criteria do not preclude the approval and inclusion of other. items for restart if it is determined desirable or prudent in consideration of overall site objectives, e.g., activities associated with ALARA (as low as reasonably achievable), industrial safety, and/or resource optimization.
Many items have been included in the restart work scope because of the benefits of performing the work at this time. Examples include the performance of high risk preventive maintenance work ahead of schedule, and development of an improved Operator Aide Program.
QUESTION 6
" Describe the steps taken or planned for self-assessment of site and corporate activities including steps for improving the effectiveness of future assessments of material condition and management effectiveness."
TVA RESPONSE in addition to reviews conducted by site line management, TVA has conducted or plans to undertake several self-assessments of site and corporate activities. These steps are designed to ensure that the causes of performance problems at SQN have been addressed and that personnel, programs, and material condition at SQN are adequate to support restart.
As explained below, TVA also has taken steps to improve the effectiveness
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of future assessments of material condition and management i
effectiveness.
Both objectives are important to improved performance at SQN after "estart.
1.
Self-Assessments of Site and Corporate Activities As discussed in response to Questions 4 and 5, the technical program review team's purpose was to assess program adequacy, identify specific deficiencies or other work items that should be addressed before restart, and provide advice and assistance to implement long-terin program improvements. Review teams were comprised of 38 TVA personnel from corporate and site organizations.
Eight outside industry experts also participated in the review.
Recommendations i
resulting from the review were provided by the teams to the Site Vice President. Oversight was provided by a panel consisting of the Nuclear Safety Review Board (NSRB) Chairman; the Vice President, Technical Support; the Vice President, Nuclear Readiness; the General.
Manager, Nuclear Assurance; the SQN Site Quality Manager; and the SQN
'I Site Licensing Manager. This same panel also will review the actions l
being taken to resolve findings resulting from the review.
In April 1993, the SQN NSRB assessed the-SQN site action plans that f
address-the root causes of performance problems, corrective actions,-
1 and determination:of-actions required to restart.
The purpose offthe-NSRB review was'to' determine whether the plans are sufficiently 3
comprehensive to, ensure the identification of problems requiring l
correction before restart'and those necessary for long-term-improvements. The NSRB noted that the progress and development of the restart plan were satisfactory.
During April, the NSRB conducted a special review of the backlogs.of open. engineering work that were not planned for completion before i
restart.
The purpose of this assessment was to ensure that the i
backlog has been reviewed against site restart criteria and that there are no individual items, or aggregate of items, that could
-i adversely impact plant operations. With one exception (vendor manual items), the results indicated that the restart judgments were reasonable.
The vendor manual items were reevaluated, and the safety-related portions will be addressed for restart.
Additional self-assessment activities are being undertaken. The Site Quality organization, with assistance from corporate Nuclear
't Assurance, is conducting a comprehensive program of assessments and audits to ensure readiness for restart.
A senior. management oversight group consisting of experienced nuclear industry managers reviewed the SQN Restart Plan. The group' concluded-that the Restart Plan is adequate and if executed as planned, the
?;i plant will be ready to restart and operate safely.
Before restart,
-l the group will conduct an assessment of overall readiness for restart.- This is a-broad review addressing management, personnel,-
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hardware, and technical program issues, as well as the resolution of findings and the implementation of corrective actions resulting from other assessments.
The group reports to the Vice President, Nuclear Operations, and the Vice President, Technical Support.
A Restart Readiness Team review, directed by the Vice President, Nuclear Readiness and comprised of senior TVA managers and industry consultants, has conducted two reviews to verify the readiness of the i
SQN Operations organization to conduct safe and effective reactor operations. The team members previously participated in the prestart operationel readiness review at SQN and Watts Bar and/or Browns Ferry Nuclear Plan:c. The results of the first review conducted in May indicated that Operations' performance was improving.
The review included oral hterviews, as well as observations of both plant and simulator acti.ities by operating crews. The conduct of both primary plant and BOF evolutions were assessed by the restart readiness
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team. A second review was conducted during the week of June 28, 1993.
The results of this review are currently being assessed.
Site management performance also has been the subject of critical self-assessment activities. A performance evaluation team, consisting of site management and members of the E nployee Relations and Development (ER&D) organization, has. developed a model for key-l SQN managerial behaviors. The team evaluated.those persons who l
report directly to the Site Vice President, as well as the next personnel level below the direct reports, against the model. TVA:has-also assessed all Operations personnel-and supervisory managers.down i
to the first-line supervisor.
Personnel actions resulting from the y
assessments have been initiated to include:
reassignments, removal, or establishment of a developmental plan. The remaining fiscal year 1993 activities will include integrating the elements of the-Performance Improvement Plan.
Key elements of the plan include behavioral and performance expectations, accountability, periodic performance reviews, consistent communications, and cultural aspects.
Site personnel will be evaluated against expectations established by the individual plan; and appropriate actions taken in cases where expectations are not met will include training, reassignment, personnel action plan development, team building activities, and disciplinary actions.
2.
Effectiveness improvements TVA recognizes the importance of improving the effectiveness of.
i future assessments of material condition and management effectiveness at SQN.
It has undertaken and plans to undertake several measures to accomplish that objecMve.
They are described below.
a.
Material Condition Over the past several years, an increasing number of SQN l
transients and reactor trips have resulted from secondary plant
problems, e.g., unexpected hardware failures and marginally designed or degraded systems / components.
Insufficient focus and priority have been applied to the secondary plant to achieve effective reliable operation. Before the March 1993 shutdown, TVA initiated a secondary plant reliability study to provide a structured, prioritized approach to effecting secondary plant performance improvements. As a result, modifications to the heater drains and vents, feedwater system, control air, switchyard, and turbine generator are scheduled to be completed before restart. Additionally, over 100 design changes on each unit to improve reliability and the' material condition of the plant will be completed before restart. As part of the system readiness, the system engineer will define the risks associated with unimplemented items to ensure that management can effectively establish priorities for the continued improvement of system performance and material condition.
In addition, initiatives are being taken to improve the assessment of impact and risk for outstanding secondary plant issues and work items. These include the development of a degraded equipment list prioritized on risk and level of degradation, adjustment in the site work prioritization processes to increase weighting of' plant reliability. issues, and augmented.. reviews.on work requests more thanz 90 days:old.
Results from-the secondary plant reliability. study also are being used to aid in the weighing of plant reliability considerations in work prioritization and monitoring.
b.
Management Effectiveness The Performance Improvement Plan was developed to improve individual and overall site performance as part of the restart effort. Even though it is recognized that_ improving performance and effectiveness is a long-term effort, immediate actions were identified to address ineffective performance prior to restart.
Key management behaviors were identified and established as a baseline for integration into all management performance expectations. The behaviors included high performance /
ownership, leadership / communications, teamwork, continuous improvement, and judgement and decision making.
Utilizing these key behaviors, the performance level of all managers was evaluated to identify developmental needs. These categories of performance were established and identified as:
Category 1 - Keep in current position as is Category 2 - Keep in current position with development Category 3 - Change needed in performance or position
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l Category 3 performers received initial management attention based on their performance in their current position. After assessing their performance with input from customers, a determination was made that the employee must improve performance in the current position; be reassigned to a position better suited to skills and abilities; or be removed from the current position with no opportunity to improve or be considered for reassignment.
The 1993 Performance Review and Development Form for managers has been revised to emphasize key behaviors and improve the clarity and measurability of performance objectives. Managers are being provided coaching and training to ensure they have the skills to address employee performance.
To ensure continued focus on performance, a similar process will be conducted for' specialists and represented schedule employees. The management performance reviews and individual development plans will be monitored to ensure performance management is continued.
Senior management will be briefed on the status on a quarterly basis.
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