ML20058L700

Forwards Response to SALP Repts 50-327/90-09 & 50-328/90-09 for 890204 - 900305,including Corrective Actions & Improvements Being Implemented

ML20058L700
Person / Time
Site:	Sequoyah
Issue date:	07/16/1990
From:	Kingsley O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20058L699	List: ML20058L700
References
NUDOCS 9008080021
Download: ML20058L700 (22)

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TENNECEE VALLEY AUTHORITY l

cumawoosa, rewassses avaos i

6N 3sA lookout'Pisce Jlil161990 U.S. Nuclear Regulatory Cosmission ATTN. Document Control Desk Washington, D.C.

20555 Gent 1emen:

la the Matter of

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Docket Mos. 50-327 4-TeNessee Valley Authority

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50-315 SEQUOYAI NUCLEAR PLANT UNITS 1 AND 1 - INSPECTION REPORT NOS. 50-317, 328/90 RESPON$t TO Tgt 1990 SYSTEMA'lic ASSESSMENT Oy LICENSEE PERy0RMANCE i

(SALP)

The preliminary SALP for Sequoyah Units 1 and 2 for the period of February 4,1989, to March 5,1990, was issued by NRC on May 17, 1990.

Subsequently, a meeting was bold at the Saquoyah Training Center an May 30, 1990, i

between IRC and TVA representatives to. diteuse the SALP report.

I Esclosure 1 to this letter provides TTA's response to the SALP report findings imeluding corrective actions and improvements being implemented.

provides a listing of specific commitments being ande by this submittal.

TVA believes the 1990 SALP presents as accurate portrayal of a plant striving to achieve asce11ence.

TVA is proud of the progress achieved at Snuoyah, but is mindful that further improvement is needed to ensure continued progress.

It reesins our goal to operate Sequoyah at a standard well above regstatory requirements.

The enclorare to this letter describes some of the steps we are taking in pursuit of that goal.

i coe of the most satisfying sceoeptishments of Sequoyah this year has been successful completion of the Unit 1 Cycle 4 refueling outage. The work completed during this outage marks ptogress in three areast completion oY postrestart NRC consitments such as alternate analysis and Appendix t' modificational reduction of regulatory backlog work such as postaccident monitoring and control room design reviewt and plSat improvements, such as insta11stion of the Eagle 21 system and upper head injection removal.

One of the key goals at Sequoyah this coming year is to successfully complete the equivalent work on Unit 1 during its Cycle 4 refueling outage.

With these tasks completed, Sequoyah will be able to concentrate on additional improvements to enhance plant regulatory performance, reliability, and operational performance.

A number of initiatives are being undertaken to Laprove schedule ' performance, simplify work processes, infuse and develop additional talent in the line organisations, and improve orocedural adherence.

In addition, assessment of the secondary plant will cu..tinue to identify needed improvements in 9008080021 900720 PDR ADOCK 03000327 Q

PDC An Eausi 00portumtv E ~o'o*

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-2 U.S. Nuclear Regulatory Coisaission dh( } h $$Q performance and reliability. TVA will also continue to pursue implementation of the security system upgrade at Sequoyah at the earliest possible date.

Although improvement has been made in the.10 CFR 50.59 safety assessment and evaluation process, TVA is not yet fully satisfied with the results and will continue to work to further strengthen that process.

In summary, although we are proud of the progress made at Sequoyah during the

. past year, we are _ not yet satisfied with performance in all functional areas.

We recognise that many challenges still lie ahead and that continuation of improvement is vital to Sequoyah's future success.

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As discussed a June 29,'1990, vii.h Linda-Watson of your staf f, our response to this SAlf report is being submitted by July 13, 1990, to allow completion 7

of final review and concurrence.

Please feel free to call me if there are any questions concerning Sequoyah's impt vement plans or if additional information is nee,ded.

Very truly yours, A

i yis V AUT50RITT o

D.

Senior Vice Nuclear Deett-e Enclosure cc'(Rnelosure):

Ms. S. C. Black, Deputy Director Project Directorate II-4 U.S. Nuclear Regulatory Commission

.0ne White Flint, North.

11555 Rockville like.

Rockville Maryland 20852 Mr. J. W. Donobew i

U.S. Nuclear Regulatory Coannission One White Flint, North 11555 Reckville Pike Rockville, Maryland 20852 NRC Resident Inspector Sequoyah Nuclear Plant

. 2600 Igou Ferry Road.

Soddy Daisy, Tennessee 37379 l

Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Comnission Region II

.,101 Marietta. Street, NW. Suite 2900 Atlanta, Georgia 30323'

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ENCLOSURE L 1 s

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j TVA Sequoyah Nuclear Plant (SQN) Response to 1990 Systematic Assessment of Licensee Performance (SALP)

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FUNCTIONAL AREA:- PLANT OPERATIONS SOARD RECOP9tENDATIONS: None

RESPONSE

TVA concurs with the Board's assessment in this functional area. TVA acknowledges that opportunities exist for continued improvement in plant operations and will continue to emphasise those improvements over the next year. To that end, a number of corrective-actions have been or will be ' implemented to = address current issues in the plant operations 6

area.

A brief description of some of those corrective actions is given below.

A.

bix Reactor Trips s

The SALP report indicated that six reactor trips occurred of which five were secondary plant induced and that problems with the performance of Operations were found to contribute to three of the trips that occurred early in the assessment period.

Considerable. work has been done in the last year to instill the correct and proper philosophy of operations at SqN. Emphasis has been put on= teamwork and communication among plant operators, as well as the responsibility for maintaining cognisance of plant status and following' principles of good operation. Additional training. in the area of' teamwork and cr==neications will be cceducted by the institute lfor Nuclear Power Operations (INPO) during requalification this year. Progress in this area will continue to be carefully monitored.

Severa1' specific actions were taken.in response to the cited reactor trips. Start-up procedures were revised to require a more specific and consistent'means_of controlling feedwater during start-up-periods. The. simulator has been used, as time permits, for start-up.

retraining prior to coming out of a forced outage and was used for crew training priori to restart of Unit 1. af ter the Cycle 4 refueling.

Subsequent to implementation of' these ac,tions, no reactor-outage.

or turbine trips' have occurred during start-up or shutdown as a result of feedwater control problems.

Additionally severa! hardware laprovements have been made to feedwater controls ar.d control stations on Unit 1.

These improvements (one example Leing the Eagle 21, which provided a trip time delay during low power start-up evolutions, and increased additional operating margin to lo-lo level setpoints) are expected to significantly assist Operations in preventing unnecessary feedwater transients and trips.

Experience to date has already proven these modifications to be a significant improvement.

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corresponding Unit 2 upgrades will be completed in the upcoming

"'ZM Cycle.4 ref ueling outage. - Additional hardware improvements are i

L planned for Cycles 5 and 6 for both units including improvements to

'l main feedwater pump speed control and main feedwater regulating I

valve bypass design and control.

These impt svesents will increase

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both the performance and reliability of the main feedwater system.

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Emergency Plan Entries

.t The SALP report confirmed that probles areas existed in emergency plan entries.

Management in Operations'and Emergency Preparedness L

(EP) has taken several corrective actions to address this issue as m.,,

discussed in the Emergency Preparedness responst, in Section IV.

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e' As a result of the improvements, event classifications made during the last eight months have been both timely and accurate.

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Further, i

i an NRC inspection of the emergency preparedness area conducted in April-of this year specifically reviewed the event classification process and performance, and concluded.that the program is effective.

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^ Main Control Room Annunciators and Procedure Enhancement C.

The SALP report confirmed the slow progress in reducing nuisance alarms and in procedure enhancements and-standardisation.c y

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Annunciators

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TVA remains committed to achieving a " dark board" annunciator r,

. systes at SQN and'is planning' to install a new annunciator y

S system in the Cycle 6 outages to achieve this goal.

I interim, Operations' management it: developing a proce.In the dure that n<

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.will control disabling and enabling annunciator inputs to alarm' Li windows.that do not have reflash capabilities. ' Additionally, l

this instruction will initiate corrective = action to track and 1

restore disabled inputs. This instruction will be fully i

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implemented by September 1990.

,o As an additional improvement to ensure prompt and consistent t

operator actions in response to annunciations, annunciator L0

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response instruction (ARI)' storage boxes have been strategically placed on the main control board.

Tliese storage boxes contain the ARIs for the annunciators located directly above the storage g

C box, providing the operator with immediate access to the-needed 1

F information.

Operations' managsment is monitoring the use of e

ARIs to' determine the offsetiveness of the storage boxes.

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2.

Procedure Enhancement and Standardisation

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The operations Procedure Inhancement' effort was ass.igned Additionally, increasej annagement attention has been exerted in directly to the Operations Procedure Group in October 1989.

this effort to monitor its prugress. Marked improvement has been noted by management in the progress of this effort

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.following this administrative change. Approximately 20 percent of the procedures have been enhanced to date. With the exception of approximately 140 infrequently used procedures, the upgrade project will be completed no later than September 1991.

D.

Management Involvement in Plant Operations y

The SALP report indicated that management involvement in plant iY operations was not always effective. Operations' management has taken corrective action with respect to each area referenced (e.g.,

back-leakage into the baron injection tank, operability of the ice bee temperature monitor, and residual heat removal pump.

deadheading). Specific corrective actions implemented involved training and infomation-distribution or procedure revision. In l

general, as a result of improved communication of ' expectations, Operations' shift management works more closely with senior Operations' management and plant duty managers-on special problems or situations. Additionally, senior Operations' management is on shift during outages and special evolutions. This allows senior Operations' management to be more directly involved in the decisionmaking process as plant conditions evolve and to communio 4 espectations more clearly. The effectiveness of these actions wili continue to be monitored.

i E.

Operator Cognisance of Alarm and Equipment Status m

The SALP report indicated that on several occasions the costtrol room 9

operators were not fully cognisant of.alara and equipment status and did not appear to have an. aggressive' questioning attitude.

Operations' management has taken corrective action in' this' area,

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. primarily in the form of management appesisal objectives, whieh:

require Operationa? management to spend time in the-plant each month interfacing with shif t crew members. During these periods, Operations' managers actively work to promote a questioning attitude in the crew members anC specifically question operators on. equipment conditions and status of the plant. ' Additionally, shift operations supervisors (808) are required to monitor equipment condition more i

closely through their shift crews. The SOS conveys needs:and priorities with. respect to equipment conditions at shif t turnover meetings where appropriate personnel free Work Control and-Maintenance are present. Operations' senior reactor operators are-now responsible for daily-schedule development and work priority assignment.

F.

Root Cause Determinations and Corrective Action

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The SALP report indicatta that violations indicated ineffective corrective action or root cause determinations.

SQN's management has taken a more aggressive approach with respect to incident

' investigations. Detailed investigations are conducted by multiorganisation teams led by responsible line managers.

Investigations consist of a detailed review of the s :quence of M

. events, including personal interviews to ascertain the root cause(s) of the event, close examination' of personnel performance using Human Performance Enhancement System (HPES), analysis of safety

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implications, and establishment of detailed corrective actions.

Corrective actions are reviewed by senior. management and are tracked.

This structured process with extensive management y

oversight and involvement is intended to facilitate' determination of w

the true root cause and formulation of = effective corrective action Additional corrective action is still needed to reduce the number of personnel errors.

of lee.k of attention to detail, inadequate use of theErrors have primari u

self-verification process, and improper communication.

self-verification training module was perforned during A

r6palification, and a special,1NPO team work and communications training module will be conducted during requalifica*i To reduce personne'l errors, the site has implemente ~

'Js year.

4 INP0-recommended program involving.an 11-part semin Aensive event investigations.- and a personnel error reductir

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C.

Responses to operational Events The SALP report indicated that responses.to operat a l events were not alwaye effective.

Specific to the weakness no wd, Operations' annagement_ has taken steps to improve performance in' this area through improvements in training, specific methods of feedwater-control, and procedure revisions.

The technical. adequacy and consistency of responses to operational events are stressed during mammal simulator proficiency training.

In addition, the efforts in two nontechnical areast. personnel error reduct efforts and continued involvement of shift personnel in event investigations and interaction with EPES evaluations.

II. FUNCTIONAL AREA:.RADIOLOCICAL CONT 20LS BOARD REC 0f9tENDATIONS_: None RESPONSE-TVA agrees with the Board's evaluation of this functional area.

discussion of the actions taken to address the Board's observations A

follows.

i The 1990 SALP report noted the problem associated with the persistent

. noble gas problems encountered since restart in the auxiliary building.

The report states that corrective actions of airborne r,adioactivity-problems were for the most part ineffective and that problems continued-in specifie areas during 'certain operations.a

• To rectify this problem, increased management attention has been airborne problems.provided through the establishment of a task force to address the Operations, Radiological Control (RADCON) Technical Suppor Nuclear Engineering (NE).

The function of this group is to identify sources of airborne radioactivity, correlate the source to operational

events, and initiate appropriate corrective actions through maintenance and modification activities.

This task force has initiated several work

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review Process is' designed to ensure that the appropriate requirements or barriers are. includsd in the work order to complete the task in the safest and most efficient manner.

4 Maintenance does not work on energised equipment or high enerly systems when other

- options are available.

A conservative barrier approach for protection of work area and personnel will be implemented as required.

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Open Unattended Work and gousekeepir e w

The SALP report confirmed that equipment under repair was occasionally left oper and unattended, and occasionally maintenance debris and other material and housekeeping deficiencies existed in the auxiliary building and other plant spaces.

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TVA agrees that there is a need for continued improvement in work housekeeping practices.

A revision to Administrative-Ihstruction 26, " Zone Control for Foreign Material Exclusion," has been-issued, which further defines and prescribes controls for work on open-plant systems.- This instruction, in conjunction'with a.

used to administer the control of Maintenance's wo addition to these administrative controls, plant person.sei have been assigned specific areas within the plant that are toured routinely to identify plant material deficiencies and areas requiring,

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bousekeeping improvement.

performance in this area to-ensure systees-ara not.lef t o 1

unattended during breaks or between shifts.

C.

Maintenance's Outage Schedule Sanagement The gALP report ind'icated that Maintenance's outage schedule management was considered to be a wisakness.

TVA's management previously outage scheduling process an. recognised existing deficiencies in the improvements.

d has been working to achieve.

. prior to the outage to provide' additional time. for' review refinement.. Critique meetings are held following major outages to

' identify and assign 1 responsibility for resolution of lessons learned during an outage.

Many deficiencies identified.in'the Unit 2

. Cycle 3 critiques were successfully eliminated during the Unit 1 Cycle 4 refueling outage.

during the Unit 1 Cycle 4 outage in specific areas such as:As a W

proactive outage management anticipating and avoiding potential l,

problems;- improved teamwork between the* PDsnt Manager's organisations'to accomplish outage schedules and goals; and significant reductions in airborne radioactivity during the outage.

Implementation of the critique process was continued fallowing the

' Unit 1 Cycle 4 outage i Items-such as workplan status control, improved workplan doc closure control, and improved communication of outage schedule priorities to the RADCON staff have been targeted for further improvement during the Unit 2 Cycle 4 outage.

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procedure revision-is no longer required if the only changes found to be needed during the biennial review are administrative changes-such as orgsnization name changes.. In such a case, the changes, are documented and will be included in the procedure-during.Its next revision.

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.R Tracking and Closure: Additional administrative controls have been implea.ented to aide-in accurate, tracking and closure of r.aintenance Ms.

The Plant Manager Standard Practice (PMCP) 6.2 series (Maintenance Management System) defines the responsibilities and accountability.for work request packages.

In the fall-of 1989, an effort was initiated to track and ensure the closure of LAs that were found to be in noncompliance with-the PMSP 6.2 series. As discussed in Section III.J. this effort 4

has result'ed in '1,165 old as being closed <with 125. remaining to be closed.. Weekly reviews of the WR data base are conducted to ensure that new Rs are closed within the established timeliness criteria'.

Additionally, detailed plans have b'een developed and implemented to reduce the backlog of open corrective maintenance work '

orders.. These plans include enhaneaments :to the maintenance planning process, development of.a seven-day fixed schedule for-all maintenance and testing activities, and monitoring and-critiquing schedule performance both daily and weekly. The goal is to-reduce-the coooutage corrective maintenance backlog:to 600 or less open work orders.

Procedure Upgrade Process: Several initiatives have been taken to improve this area. Some of these include the, assignment of primary responsibility within the Maintenance organisation, use

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of a standard format, use of'a consistent group of personnel performing -procedure writing, and simplification of the revision and upgrade process.

Procedure;needs have been prioritised to ensure the correct:

procedures are revised first. For example, completion was expedited for procedure revisions' required for Unit.1 start-up following the modifications performed during the-Cycle 4 refueling outage. The procedure upgrade program will be completed by, September 30, 1991.

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Validation.and Translation of Vendot Manual Drawings: Under the Vendor Manual Program, administrative control procedures are being revised (A ran.crt the plant needs and maintain regulatory i

requirement's - A vendor manual task force / quality action team consi". lag of< supervisory and technica1' personnel in NE.

Tedaical Support, hintenance, and Nuclear Quality Assurance (NS) has, been establichsd to address vendor manual probleas that cou'Ld affect plant +peration. The task force is evaluating octer:cial enhancements to the current program and will provide recommendations to the vendor manual program annager on -a continuing basis.

Improvements are expected to the indexing and accessirning of vendor annuals as well as to the interface with vendors of safety-related components.

In addition, an ongoing 4' $

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program has.been established to upgrade and maintain the vendor

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manuals for use by the plant organisations. These efforts are being incorporated into acainistrative processes to ensure i

appropriate control of each vendor manual.-

Control of Vendor Materials Used During Onsite Maintenancs L

Activities: The SALP report identifies instances of poor control of vendor services and materials while performing work.

TVA's management has instituted steps intended to prevent recurrence.

New contracts with vendors now include clauses requiring l

adherence to TVA administrative procedures for vendor ' support, including material uses.

In certain applications a=" vendor' letter" has been used to outline responsibilities for vendors

-l and'TVA employees. The letter. includes TVA policies concerning work-environment, use of vendor manuals, and use of materials.

-l This letter is subsequently reviewed and signed by the vendor,.

craft foremen craftsmen, and general forenen responsible for the work.

F.

Material / Equipment Procurement The SALP report' confirms that the procurement process is at times slow, and the number of maintenance items on asterial hold status is too high.

Maintenance's management acknowledges that improvement is needed in the procurement of routine'asterials and equipment and is working with Nuclear Stores' mana6asient to establish appropriate priorities i

for material procurements. Priorities'will be based on plant' J

conditions and requirements.- There are currently 107 nonoutage-

'i corrective work orders on asterial hold status. - A goal has been established to reduce the nonoutage corrective maintenance work orders' on material hold status to less than' 50 by September 30, 1990. Attainment of this goal will aid'in the:

reduction of the outstanding work. order backlog and' improve the material condition of the plant.

To achieve this goal. improvements have been made in areas such as early planning'and identification of material needs. ensuring reserved material not needed' for a specific job is ' removed-from reserved status, and establishing a more -

reliable asthod for notifying. users -when material' for WRs on l.

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asterial restraint'is available for use.

L Parts lists are developed for plant components during development of J

L work order packages. These lists are factored into future adjustments to stocking levels. Correct stocking levels will reduce the number of material hold issues restraining work.

C.- Procedural Adherence L

l-The SALP report identifies procedural adherence as an area with a significant number of NRC findings (five of six violations).

As further noted in the SALP report, TVA has reduced the number of procedural adherence problems from previous SALP periods. However.

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. procedural adherence problesis are categorized as personnel errorst.

personnel error reduction is receiving significant management focus sitewide as a result of adverse trends. Management has instituted a review board that addresses each personnel error with the individual (s) involved and their supervision. Review board meetings are used to ensure that personal accountability, coaching. and disciplinary action are administered appropriately.

In addition, the 'EPES is being implemented sitewide.

TVA management will monitor this area closely and will institute further corrective actions as appropriate'to ensure continued improvement..

1 E.

Security Maintenance 0

The SALP. report states that resources were not always adequately allocated ' to achieve good " plant and personnel performance."

Problems were also noted in the management of security maintenance

'and in communications between' security and the plant Maintenance.

organisation.

Maintenance's management is working in cooperation with Site i

Security's management to ensure that security WRs,are appropriately j

prioritised and that maintenance work is performed in accordance s

with:the-assigned priorit;. To that end, a dedicated instrument crew works on security-related maiutorynce, and Maintenance's-annagement bas been communicating ds dy with.the Site Security i

Manager to' ensure the appropriate g 4 tority is given to.eaerging security maintenance work..As a.. ult of these offorts, the backlog of security-related WRs has been reduced by approximately 50 percent. The short-term goal is to minimise both the number and duration of open security-reisted WRs._ In the longer tera,.

completion of the security system upgrade is expected to 1

considerably ease this. burden.

l3 I '. Secondary Plant Maintenance Activities The SALP report cited a number of maintenance-related reactor trips, engineered safeguards features actuations, and plant power reductions; and attributed these event,s to a previous history of 1

wask secondary plant maintenance = activities.

1 Several secondary plant problems were encountered during the.past 3

year, primarilyiassociated with heater drain tank level controls.

q Numerous maintenance activities, both preventive and corrective, were performed to address chose conditions. An action plan was developed to coordinate the interia corrective action and implcmentation of' longer-tera design leprovements that may be identified during secondary plant evaluation efforts, which will be ongoing this year. A number of related work items were completed on Unit 1 during its recent Cycle 1. refueling outage and are planned for Unit 2 during its upcoming Cycle 4 refueling outage.

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'significant initiatives for secondary side equipment improvement are oogoing or planned over the current SALP period, but-can be more i

f accurately characterised as elements of a dynamic-secondary side equipment program. The efforts are intended to initiate'an ongoing Ic refurbishment or upgrade process to secondary side equipment, implementing portions' on a rotating outage basis.. Oregoing or planned initiatives include activities such as implementation of the EPRI valve repacking program, refurbishment of condensate and heater drain j

j tank. pump motors,'. implementation-of a coating program in the condensate desineraliser building, recoating of major equipment in the turbine. building, and rebuilding of secondary' side control valves.

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'i should be noted that secondary plant work processes are given the same emphasis on quality and the same attentien to detail as primary side i.

work processes. Operation of secondary plant systems will be closely L

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' monitored over the next year to promote reliable performance.

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Backlog of WR Postcompletion Reviews The SALP report indicated that a backlog of work request postecqletion reviews was identified.

' A backlog of Was awaiting.postcompletion reviews did exist is mid-1989. As a result of: corrective actions that were implemented, the backlog has been reduced from approximately 1,165 WRs to 115. ~A review of remaining WRs is being tracked and will be completed this L

fiscal' year.

In addition. the site procedure governing asiatenance L-probles.-

request processing has been revised to prevent recurrence of the:

K.. Scheduling of Non-Technical-Specification (TS) Surveillances The SALP Report indicated that the scheduling of non-TS suneillances-was less aggressive and resulted in a number of delinquent performances.

During ths.last SALP period.- a number.of non-TS-required surveillances j

did become delinquent. Through-added emphasis and management 4

priority, this backlog was reduced' to approximately 30 prior. to the Unit 1 Cycle 4 refueling outage. During the outage, the backlog increased 'slightly because of dispiscenent by higher priority.

outage-related work. With the outage completed, the remaining backlog is being scheduled and will: be tracked in acco-da'nce with SQN administrative procedures.

Emphasis over' the past year. has been placed on getting the right 4

maintenance team' in place and in improving work processes.

The I'

h reliability-centered maintenance program is fully staf fed and is expected to provide valuable input to the preventive maintenance (PM) program over the next year to further improve the PM process. Additionally, improvements have been made in the maintenance planning and scheduling process to interf ace more ef ficiently with the Work Control group. TVA's management will continue to provide the oversight needed in this-functional area to ensure continued progress and reliable plant perfor'sance.

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IV. : FUNCTIOM ' AR EA: lEMERCENCY PREPAREDNESS E

BOARD REC 0feENDATIONS: None-

RESPONSE

TVA agrees with the Board's assessment of this functional area.. There were three areas of weaknese for EP ideetified in the 1990 SALP report:-

emergency procedure revision, event clasaffication, and exercise control.

. The following corrective actions have or vill be ' taken in each area.

A.

Procedure Revisions s

The SALP report indicated that NRC identified an EPIP-1 revision as-O I

unacceptable'during review because it allowed 60 minutes to declare an emergency =af ter meeting a classification criterion.- The report also noted TVA promptly revised the procedere.

l3 To enhance procedures and ensure implementation consistent with'NRC guidelines and requirements, the following actions have been taken.

4 Prior to enjor or significant revisions of procedures, such as-L EPIP-1, the revision is discussed with corporate emergency planning and Inc to benefit from other perspectives and experience. This action is taken even when the procedure intent is not changed and EP determines the requirements of 10 CFA 50 l

are met..

L A basis document for-emergency action levels (EALa) required by NUREG-0654, " Criteria for Preparation and Evaluation of.

Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," has been written and incorporated as part of the TVA' Radiological Emergency Plan i

-(REP). The document identifies the basis for the EALs in EPIP-1.

-Information is also provided' to aid operators in properly -

classifying events, including example initiating conditions and NUREC-0654 requirements.

B.

Event Classification u

The'SALP report observed that on two ocEasions there were failures lto classify or promptly classify emergency events'.

p To promote consistent, accurate, and timely classification of m

events, a number of initiatives have been undertaken.-

EPIP-1 has been rewritten in the Nuclear Management and L

Resources Council format.

EPIP-1 is more user f riendly and more specifically defines events that are measurable and require emergency classification.

j The EP staff conducts onshif t training with each operating L

This continuing training has resulted in an increased crew.

L awareness of the emergency plan and timely, conservative b

classification of four unusual events since October 1989.

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Operations' requalification simulator training includes continuing training on emergency plan entries at the low threshold event (notification of unusual events) levels as part of simulator exercises.

The EP staff will teach a 4-hour Operations' requalification h

clasa to licensed operators and shif t technical advisors. The.

L class will begin in July 1990 and will include instruction on low threst old events and associated bases, review of past events resulting in emergency declarations, and emergency organisation response.

In addition, nonlicensed assistant unit operators will receive four hours of EP trai'ning, including emergency response.

organaation and actions, use of EPIP-1 and the EA1.a. and conduct of dtills and exercises.

i 3e Nue1*ar Experience Review (NER) program now includes EP. rela i items that are reviewed by the EP staff along with EP-telated NRC notices.

Thorough and in-depth critiques of drills and exercises are p

conducted, and-action plans with assignments and due dates. are dowloped to address any identified weaknesses. The evaluation of findings or lessons learned from these activities includes a review of the site EPIPs to ensure problem areas are addressed or that procedures are revised if needed.

? A three-team emergency response organisation has been impit.sented on a rotating duty. schedule.

In addition, key plant. annagers who.

are thoroughly trained in the REP are designated as event.

investigation managers for any EP-related events.that might occur.. Imssons learned from the root causes of such events are used as feedback to further improve the EP program.

.i C.

Exercise Control L

a Although no exercise weaknesses were identified, the SALP report i

cited exercise, control problems.

To improve the effectiveness of EP drills and exercises and to

' enhance the formulation of drill scenarios, a number of improvements have been instituted.

A scenario development and control team representing major, plant

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3 disciplines.has been appointed by plant management. Each member serves -f or a full year and participates in t. reparation and conduct of site drills and exercises;*

Controller training has-been upgraded to include a 2-hour general l

controller training and a 3-to 4-hour individual controller walkthrough to review the scenario sequence and expected response in the controller areas.

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i When possible, drills and exercises are conducted from the simulator control room with a full Operations crew to remove a p

potentially disruptive event from the plant main control room.

p Realism is enhanced through live safety parameter display system 2

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operation in the Technical Support. Canter (TSC). Operations; Support Center (OSC), Central Emergency Control Center, and hands-on participation by the Operations crew in the simulat'or.

A recent Instituts of Nuclear Power OperationsJ (INPO): assistance

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visit with a casualty control drill conducted,from the simulator L

confirmed that improvements were being made-as a result of these H

actions.

Staffing and augmentation drills to demonstrate the ability to staff the TSC and OSC.in less than 60 minutes have been conducted. Unannounced staffing and augmentation drills will, continue to be conducted annually to demonstrate this capability.

Further initiatives being taken in this area include con' inued EP t

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-involvement with operators on the methodology and use of EPIP-1 through-onshif t and requalification training, increased use_ of EPIPs during annual operator _ requalification simulator training,. modernization of the site environmental.nonitoring van, and continued improvement 'of EP 1

. methods and procedures through' feedback and asperience.

TVA will continue to closely monitor this functional area to ensure the improvements needed in'this area are put in place.

j V.

FUNCTIONAL AREA: SECURITY BOARD REC 0tetENDATIONS The Board noted a continuing probles in the reliability of security equipment. This problem was identified during the last SALP period.

_I The Board recommends that significant management emphasis be placed on improving security equipment reliability.- - In addition, senior u

management should' emphasise that compensatory esasures are intended to i

be a short-term substitute, not an alternative to pursuing repairs of equipment.

3 RESPONS_E TVA concurs-with the Board's assessment of this functional. area.

A-number of improvements have been made and are ongoing to address the issues raised. - A description of some of these follows.

A.

Security System Upgrade I

The SALP report noted that progress during the assessment period g

toward implementation of the security system upgrade was good.

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A contract has been awarded to a security" system vendor to complete the design and installation of a state-of-the-art security system.

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When implemented, this new system will replace the security computer system, upgrade the protected area perimeter and alarm. system,

' replace guard towers with closed circuit television, and install new keycard readers. Also included in the project is a.new protected area access control portal and a new protected area boundary.. This project is scheduled for completion by May 1992.

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The SALP report indicated that ce wrces were not always adequately allocated: to achieve a good security maintenance program.

TVA recognizes that existing security equipment must be maintained in reliable and operable condition until replaced with the new system. TVA acknowledges that during the review period, equipment failures resulted-in reliance on security officers performing s

compensatory measures for longer periods' than desired. As previously discussed. in Section III.B. TVA has. implemented a process to better ensure adequate maintenance resources are allocated to security equipment problems and to ensure that Site Security and

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j Maintenance maintain open ~1ines of comununication. Direct uoper 4

annagement involvement. in a weekly review of security maintenance and compensatory measures is now occurring. This management review includes tracking and trending security WR status, the number of security compensatory measures, and the number and duration of backlogged security WRs. Additionally, frequent line management meetings by Site Security and Maintenance have been instituted to ensure the continuation of the positive trend in security maintenance noted at the end of the-assessment period.

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An instrument mechanic crew, a planner, and a 'hork control specialist have been dedicated to the security, maintenance program.

The Instrument Maintenance crew is responsible for maintenance on the intrusion detection systems, keycard reader system, and personnel-search equipment. Additionally, a dedicated crew of carpenters and electricians maintains security and' fire door hardware 'and locking devices. The timeliness.and effectiveness of the maintenance on existing equipment have been' improved as a result r

of administrative and procedural changes.

Some-equipment traceability requirements that were found' to be unnecessary have been eliminated. This change reduced the time and effort required to obtain suitable replacement parts. Also, improvements in work l

scheduling methods now give maximum flexibility and increased responsiveness in addressing high priority tasks. - WRs are now worked based on priorities that are determined during daily meetings

- between line management in Site Security. and Maintenance.

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' written on equipment posted by a securit;y force member receive high priority and require expedited completich.

Improvements-in the central and secondary alara stations are:

ongoing. Material conditions have improved with an overall facility upgrade.

A corrective action program that will ensure that' spare and administrative alare panels are remove'd and that abs.ndoned and spare ' cablea will be c611st and tagged is ongoing with ' scheduled l-completion in August 1990.

i C.

' Security Supervision The SALP report indicated that active support and involvement by first-line supervisors and the compliance coordinator were lacking on two occasions.

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TVA concurs that in'the first example cited, the security supervisor f ailed to respond properly when informed of a security event. This failure was attributed to inexperience and a lack of understanding.

.In the second example, the problem occurred be cause of a lack of procedural guidance in test source control by members of the

-security force.- This omission was corrected by the procurement of a marked.. calibrated test source and by _ a revision to procedure.- In both cases, training in lessons learned has improved line management and compliance coordinator involvement.

VI. FUNCTIONAL AREA: ENGINEERING /TECENICAL SUPPORT BOARD RECOPefENDATIONS: None 8

NSPONSE TVA agrees with the Board's assessment that there has been an -

j improvement in this functic s.1 area over the past year. Iowever, as the Board noted, there are still several areas where improvement is needed.

A discussion of actione, being taken or. planned to address, issues in this functional area follows.

A.

Nuclear Engineering s

The EALP report noted that there is still a backlog of old engineering chan8e notices (some prelicensing), local design change

' requests, and design change requests still c. pen. An' improved d

process bas been developed for eiosing the change paper associated with the backlog of prelicensing engineering change notices. local design change re 1ests, and ~ design change requests not requiring-

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engineering char.

notices. This improved process will be implemented in.J.y 1990.- Implementation of this improved process, along with resource dedication to implement-it. is expected to expedite closure of the change paper noted above, which will result 1

in elimination of -this backlog in early FY 1991.

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A goal has been established to reduce the number of open CAQs by 40 percent during FY 1990. At SQN, there was's not increase in the number of conditions adverse to quallty'(CAQs) during each of the

'fitst seven sonths of FY 1990 except for March. Increased

- management' emphasis, along with completion of Unit 1 Cycle-4 work, has resulted in a not decrease ~of CAQs during May and June. An '

active closure effort is underway-that will er-sure the FY 1990 CAQ closure goal is set.

c To improve problem solutions and root cande developments, several key people will be given root cause-training over the next year.

In addition, key individuals will take INPO Human Performance Deficiency Evaluation System training-to better underrstand and

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~ resolve human error deficiencies.

TVA has implemented a process whereby consmitment dates are coordinated with involved parties, and funding and priority are assured through the use of the Integrated Living Schedule before l

being given o NRC. Management emphasis has and will continue to be

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placed on meeting consnitments in a timely fashion.

Weekly meetings are held between. plant organisations and Site -l.icensing to review progress toward implementation of conomitments so that corrective actions can be taken if necessary.

The SALP repo also noted that for a small number of issues, TVA did not exhibit adequate resolution to technical issues. Several causes hav been' identified for past occurrences of inadequate treatment d technical issues, including inadequate planning of engineering schedules and inadequate, interf ace review with other onsite and offsite organisations.' NE has recognised these past deficiencies and has addressed them by emphasizing technical ownership and. proper interface and review of issues.

4-SQN has instituted a systematic approach' for dealing with key problems identifled for equipment and systems.- The systematic approach ensures management attention and priority are focused on the problems.from initiation to final resolution.

Each problem is tracked to ensure an action plan is developed and is jointly approved by Technical Support Operations, Maintenance, NE, and Modifications. Definite completion dates are assigned and closely monitored in plaa-of-the-day meetings involving the appropriate management. This. approach is espected to improve the adequacy of resolution of technical issues. Additionally, systems engineers have been ande the focal point at the plant for systems-related problems and for ensuring joint Technical support and NE review of problems. The improved interaction between these organisations i=

aimed at continuing the improvement of' the-quality of technia.a1 submittals.

B.

Technical Support The CALP report noted improvements in the systems engineering area.

Previous weaknesses identified in the Technical Support area are being addressed in part through continued implementation of the systems engineering program. Efforts currently underway to strengthen this program include the hiring of ten experienced engineers. This effort is expected to be completed by the fall of

'1990.

In addition,' a total of.three line annagers have been replaced, and a program manager positida was filled-to strengthen Technical Support management.

During. the next evaluation period, three specific areas will be pursued to enhance plant support. These areas are the formalized involvement of ' systems engineers in the preventative maintenance program, increased involvement in the modification program, and development of a formalised systems engineer trending program.

Continued management emphasis will be placed on increased systes status knowledge through the walkdown program and focusing on top hardware and software problems, as well as trending.

In addition, a formal systems training program has been established including classroom, plant walkdowns, and simulator training to increase overall plant knowledge.

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Technical Support and NE have initiated a monthly meeting of the respective management teams to ensure goal coordination and problem

. resolution.

This coordination is expected to provide a forum to better focus the technical support provided to the plant.

VII. FUNCTIONAL AREA: ' SAFETY ASSESSMENT / QUALITY VERIFICATION BOARD RECOMMENDATIONS The Board no*.ed that licensee management should continue to pay particular-attention to the 10 CFR 50.59 review process, ensuring that the level of technical detail, the technical basis, and the safety-review of proposed changes are done in a prudent, complete, and safety conscious manner.

J.

RESPONSE

TVA concurs with the Board's assessment of performance in this functional area. A number of improvements have been ande and are ongoing relative to the issues raised. A description of some of these efforts follows, i

1 A.

10 CFR 50.59 Reviews s

The-SALP report indicated that some implementation problems still exist,.in the 10 CFR 50.59 review process.-

TVA believes significant improvements-have been ande in the

'i 10 CFR 50.59 review process during the past year, but recognises.

i that further improvements are needed to ensure continued progress.

A number of initiatives are planned or underway to ensure continued improvement in the 50.59-review process. The process is monitored by a periodic Nuclear Safety Review Board (NSRB) review of selected safety assessments = and salety evaluations to' judge' both adequacy and.

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adherence to program requirements. The NQA organisation also periodically monitors and audits l selected safety assessments and safety evaluations.

The overall performance of the 150.59 review i

process is assessed quarterly using both the NSRB review and NQA

'mer.itoring and auditing results to look.for trends related to progran performance and adequacy.

In addition, the Plant Operations i

Review Committee reviews randomly selected safety evaluations to ensure standards are being adhered to.

Feedback from these efforts will-be utilized to further refine the process as needed, Another improvement planned for this yeat*is to revise the procedure controlling the 50.59 review; precess, Standard 6.1.3, " Safety Assessment / Evaluation of Changes, Tests, and Experiments i

(10 CFR 50.59)," to aske it more user friendly. TVA will continue

'to monitor industry developments related to the.50.59 review process i

for the purpose of continued program refinement and improvement.

TVA will also periodically assess the need for providing retraining or supplemental training to the performers of safety assessments and safety evaluations based upon the number and significance of changes

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to the program. TVA is currently evaluating the merit of' requiring the same individual to be the independent qualified reviewer and 50.59-Level I preparer, thereby better focusing. technical expertise.

Expanded use of training from Westinghouse Electric w

Corporation-in areas such as emergency operating procedures and the bases for accident analysis has started and will continue this,

year.. TVA will continue to focus close management attention on the 50.59 review process to ensure the-technical adequacy and consistency of safety assessment and safety evaluations.

B.

Submittal Schedules _.

The SALP report noted that TVA continued to be overly optimistic in establishing submittal dates.

1.

The past year presented numerous challenges to the Site. Licensing organisation in support of Cycle 4 refueling outage initiatives.

Numeroustsubmittals and TS changes were coordinated with the staff to support significant plant upgrades and regulatory backlog s

reduction.. Ongoing efforts to improve planning and coordination are exp'ected to promote further improvements in the timeliness of submittals. For azample, lessons learned from Unit 1 Cycle 4 outage

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experience are being-applied during preparations for.the upcoming I

Onit-2 Cycle 4 refueling outage.- In addition, Site Licensing directly participates in Unit 2 Cycle 4 outage planning meetings and-coordinates closely with NE in support of reguistory based modifications.

Further improvements in outage planning, postoutage critique, and aggressive licensing project management are expected to enhance early identification of reguistory issues and minimise submittal

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schedule delays. ~teyond current-refueling outage preparations, Site Licensing management has and.will continue - to actively participate in Westinghouse Owner's Group (WOG)Tinitiatives. Participation in these initiatives, such as WOG methodically engineered, restruetured.' and -improved technical'. specifications -(MERITS), the s

WOG technical specification subcommittee, and general session I

1 seetings, is expected co further improve.the focus of licensing initiatives consistent with industry and staff' initiatives.

Licensing initiatives planned over the next SALP period include

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closecut of the majority of postrestart' commitment for Onit 2, planning and prioritising TS enhancement activities, and pursuit of r

further reductions-in open generic issues.

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' List of Comunitments f

1.

TVA' remains committed to achieving a " dark board" annunciator system at L'

SQN and is planning to install a new annunciator system in the Cycle 6 outages to achieve this goal.

t-L 2.

The procedure being developed to control disabling and enabling annunciator inputs to alara windows that do not have reflash capabilities-and to initiate corrective action to track and restore disabled inputs will be fully implemented by September 1990.

3.

With the exception of approximately 140-infrequently used procedures. the operations procedure enhancement project will be completed by September 1991.

4 The asintenance procedure upgrade program will be completed by September 30, 1991.

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5.

The-review'of remaining work requests awaiting postcompletion reviews is being tracked and will be completed this fiscal year.

f 6.

Implene'atation of the security system upgrade is scheduled for completion by May 1992.

7.

A corrective action program that will. ensure that spare and administrative alare panels are removed and that abandoned and spare cables will be rolled and tagged is ongoing with scheduled completion in -

August 1990.

4 - The' improved process for closing the change paper associated with the backlog of ;prelicensing engineering change notices (ECNs), local design

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change requests (DCRs), and DCRs not. requiring ECNs will be implemented in July 1990.

9.

Implementation of the improved process is expected to expedite the closure of change paper an1 to result'in elimination of the backlog in early FY 1991.-

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