ML20059B182

Summarizes 931214 Meeting W/Util at Plant Site Re SALP Rept Forwarded on 931202.List of Attendees & NRC Handout Encl

ML20059B182
Person / Time
Site:	Sequoyah
Issue date:	12/29/1993
From:	Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Medford M TENNESSEE VALLEY AUTHORITY
References
NUDOCS 9401040017
Download: ML20059B182 (25)

Text

TY DEC 29 as Docket Nos. 50-327, 50-328 License Nos. DPR-77, DPR-79 Tennessee Valley Authority ATTN: Dr. Mark 0. Medford, Vice President Technical Support 3B Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Gentlemen:

SUBJECT:

MEETING

SUMMARY

- SEQUOYAH NUCLEAR PLANT SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

This refers to the meeting conducted at our request at your Sequoyah Nuclear Plant on December 14, 1993.

The purpose of the meeting was to discuss the SALP report which was forwarded to you on December 2, 1993.

It is our opinion that this meeting was beneficial to us in aiding our understanding of your ongoing programs and activities at Sequoyah Nuclear Plant.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

Should you have any questions concerning this matter, please contact us.

Sincerely, (Original signed by J. Johnson)

Ellis W. Merschoff, Director Division of Reactor Projects

Enclosures:

i 1.

List of Attendees 2.

NRC Handout cc w/encls:

(See page 2) l 030005 9401040017 931227 l((

PDR ADDCK 05000327 O

PDR;

DEC 29 ngy Tennessee Valley Authority 2

cc w/ enc 1:

Craven Crowell, Chairman Robert Fenech, Vice President Tennessee Valley Authority Sequoyah Nuclear Plant ET 12A Tennessee Valley Authority 400 West Summit Hill Drive P. O. Box 2000 Knoxville, TN 37902 Soddy-Daisy, TN 37379 W. H. Kennoy, Director R. M. Eytchison, Vice President Tennessee Valley Authority Nuclear Operations ET 12A Tennessee Valley Authority 400 West Summit Hill Drive 3B Lookout Place Knoxville, TN 37902 1101 Market Street Chattanooga, TN 37402-2801 Johnny H. Hayes, Director Tennessee Valley Authority Michael H. Mobley, Director ET 12A Division of Radiological Health 400 West Summit Hill Drive 3rd Floor, L and C Annex Knoxville, TN 37902 401 Church Street Nashville, TN 37243-1532 TVA Representative Tennessee Valley Authority County Judge Rockville Office Hamilton County Courthouse 11921 Rockville Pike Chattanooga, TN 37402 Suite 402 i

Rockville, MD 20852 Bill Harris Route 1, Box 26 General Counsel Ten Mile, TN 37880 Tennessee Valley Authority ET 11H bec w/encls:

(See page 3)

)

400 West Summit Hill Drive Knoxville, TN 37902 B. S. Schofield, Manager Nuclear Licensing and Regulatory Affairs Tennessee Valley Authority 4G Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 j

Ralph H. Shell Site Licensing Manager Sequoyah Nuclear Plant P. O. Box 2000 Soddy-Daisy, TN 37379 l

DEC 2 91993 l

Tennessee Valley Authority 3

bec w/encls:

l J. R. Johnson, RII P. J. Kellogg, RII B. M. Bordenick, OGC M. S. Callahan, GPA/CA J. F. Williams, NRR l

G. Lainas, NRR l

F. Hebdon, NRR l

L. J. Watson, RII i

Document Control Desk NRC Senior Resident Inspector l

Charles Patterson U.S. Nuclear Regulatory Commission Route 12, Box 637 Athens, AL 35611 l

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9 ENCLOSURE 1 LIST OF ATTENDEES NRC S. D. Ebneter, Regional Administrator, Region II, (RII)

E. W. Herschoff, Director, Division of Reactor Projects (DRP), RII F. J. Hebdon, Director, Project Directorate 11-4, Office of Nuclear Reactor Regulation (NRR)

R. V. Crlenjak, Cheif, Reactor Projects Branch 4, DRP, RII-P. J. Kellogg, Chief, Reactor Projects Section 4A, DRP, RII W. E. Holland, Senior Resident Inspector, DRP, RII S. M. Shaeffer, Resident Inspector, DRP, RII S. E. Sparks, Project Engineer, DRP,RII TVA C. Crowell, Chairman, Tennessee Valley Authority W. Kennoy, Director, Tennessee Valley Authority J. Hayes, Director, Tennessee Valley Authority R. Eytchison, Vice President, Nuclear Operations M. Medford, Vice President, Technical Support R. Fenech, Vice President, Sequoyah K. Powers, Plant Manager J. Baumstark, Operations Manager N. Welch, Operations Superintendent Other members of TVA staff were also present.

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ENCLOSURE 2 UNITED STATES NUCLEAR REGULATORY COMMISSION

~~

pra Re oe SEQUOYAH NUCLEAR PLANT August 2,1992 through October 9,1993 SYSTEMATIC ASSESSMENT OF LICENSEE. PERFORMANCE (SALP)

M EETING December 14,1993

L NEW SALP PROCESS R.... ni g,

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FUNCTIONAL AREAS FOR OPERATIN.G REACTORS 1.

PLANT OPERATIONS 2.

MAINTENANCE 3.

ENGINEERING 4.

PLANT SUPPORT

- Radiological Controls

- Emergency Preparedness

- Security 4

4

PERFORMANCE CATEGORY RATINGS Category 1.

Licensee attention and involvement have been properly focused on safety and resulted in a superior level of performance. Licensee programs and procedures have provided effective controls.

The licensee's self-assessment efforts have been effective in the identification of emergent issues. Corrective actions are technically sound, comprehensive, and thorough.

Recurring problems are eliminated, and resolution of issues is timely. Root cause analyses are thorough.

Category 2.

Licensee attention and involvement are normally well focused and resulted in a good level of safety performance.

Licensee programs and procedures normally provide the necessary control of activities, but deficiencies may exist.

The licensee's self-assessments are normally good, although issues may escape identification.

Corrective actions are usually effective, although some may not be complete.

Root cause analyses are normally thorough.

i Category 3.

Licensee attention and involvement have resulted in an acceptable level of safety performance.

However, licensee performance may exhibit one or more of the following characteristics.

Licensee programs and procedures have not provided sufficient control of activities in important areas.

The licensee's self-assessment efforts may not occur until after a potential problem becomes apparent.

A clear understanding of the safety implications of significant issues may not have been demonstrated. Numerous minor issues combine to indicate that the licensee's corrective action is not thorough. Root cause analyses do not probe deep enough, resulting in the incomplete

)

resolution of issues.

Because the margin to unacceptable performance in important aspects is small, increased NRC and licensee attention is required.

f SEQUOYAH NUCLEAR PLANT I

SALP BOARD AEMBERS-i d

1 Ellis W. Merschoff Director (Chairperson)

Division of Reactor Projects Region H

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i Fredrick J. Hebdon Director, Project Directorate H-3 i

Office of Nuclear Reactor Regulation i

Albert F. Gibson Director Division of Reactor Safety Region H J. Philip Stohr Director Division of Radiation Safety and Safeguards Region H 1

I

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.i SEQUOYAH SALP MEETING i

OPERATIONS l

CHALLENGES:.

I LACK OF MANAGEMENT INVOLVEMENT AND-SAFETY SENSITIVITY EARLY lN THE PERIOD.

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e POOR CONFIGURATION CONTROL i

PROCEDURE ADEQUACY AND COMPLIANCE-

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COMMUNICATIONS AND ATTENTION TO DETAll STAFFING / TRAINING

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STRENGTHS-i OPERATOR RESPONSE TO PLANT TRANSIENTS

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AUDITS, ASSESSMENTS, AND SAFETY REVIEWS LATE IN THE ASSESSMENT PERIOD WERE j

EFFECTIVE i

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' i SEQUOYAH SALP MEETING i

MAINTENANCE l

CHALLENGES:

j MATERIAL. CONDITION OF PLANT HAS ADVERSELY AFFECTED PLANT PERFORMANCE i

e CONFIGURATION CONTROL

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PROCEDURAL ADEO.UACY AND COMPLIANCE DEFICIENCIES 4

STRENGTHS:

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ASSESSMENT PERIOD, SIGNIFICANT ATTENTION' WAS FOCUSED ON MATERIAL CONDITION OF BALANCE OF PLANT l

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SEQUOYAH SALP MEETING ENGINEERING

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IMPROVED PERFORMANCE OF TECHNICAL f

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PROBLEM IDENTIFICATION AND CORRECTIVE ACTIONS IMPROVED OVER THE ASSESSMENT PERIOD

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i CHALLENGES:

e SUPPORT TO OPERATIONS e

SUPPORT TO MAINTENANCE (EARLY IN ASSESSMENT PERIOD)

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i SEQUOYAH SALP MEETING i

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PLANT SUPPORT i

STRENGTHS:

e RADIOLOGICAL CONTROLS PROGRAM, INCLUDING ALARA AND EXPOSURE CONTROL:

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LIQUID AND GASEOUS RADIOACTIVE EFFLUENTS EFFECTIVELY CONTROLLED e

PROCESSING OF RADWASTE, INCLUDING SHIPPING e

STRONG SUPPORT FOR EMERGENCY i

PREPAREDNESS PROGRAM WAS EVIDENT e

RESPONSE TO ACTUAL EVENTS i

o EFFECTIVE AUDIT PROGRAMS e

EFFECTIVE-SECURITY PROGRAM i

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b SEO.UOYAH SALP MEETING PLANT SUPPORT (CONTINUED 1 i

CHALLENGES:

e FIRE PROTECTION SYSTEM MATERIAL CONDITION o

e PROCEDURAL ADHERENCE IN RADIATION CONTROLS e

PROTECTION OF SAFEGUARDS INFORMATION i

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SALP RATING

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101 MARIETTA STREET. N.W. SUITE 2900 ATLANTA. GEORGIA 33330199 g

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DEC 0 21993 Docket Nos. 50-327, 50-328 License Nos. DPR-77, DPR-79 Tennessee Valtdy Authority ATTH:

Dr. Mark O. Medford Vice President, Technical Support 3B Lookout Place l'

1101 Market Street Chattanooga, TN 37402-2801 Gentlemen:

SUBJECT:

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

SEQUOYAH NUCLEAR PLANT REPORT NO. 50-327/93-43 AND 50-328/93-43 The NRC Systematic Assessment of Licensee Performance (SALP) has been completed for your Sequoyah Nuclear Plant. The facility was evaluated for the period of August 2, 1992, through October 9, 1993. The results of the evaluation are documented in the enclosed SALP report. This report will be discussed with you at a public meeting to be held at the Sequoyah site on December 14, 1993, at 2:00 p.m.

This SALP was conducted under the revised SALP process that was implemented by the Nuclear Regulatory Commission on July 18, 1993. The revised SALP process rates licensees in four functional areas: Operations, Maintenance,

)

Engineering and Plant Support. The Plant Support area includes: radiological i

controls, security, emergency preparedness, fire protection, chemistry, and housekeeping controls.

The performance of Sequoyah has declined in the Operations and Maintenance functional areas, and the improving trend observed in Engineering in the previous assessment period was not sustained. The second half of the j

assessment period was characterized by an increased emphasis by licensee j

management on this decline and establishment of a restart plan to correct i

problems in the areas of operations, technical programs, backlogs, balance of plant material condition, and other management issues.

In the Operations area, a lack of management involvement and safety sensitivity was noted early in the assessment period. Configuration control issues due to poor personnel performance and procedural problems continued to be a challenge throughout the period.

Late in the assessment period, j

management involvement in addressing these and other Operations concerns was i

observed. As in the previous assessment period, operators continued to I

perform well in responding to plant transients.

In the Maintenance area, it was noted early in the assessment period that plant management had not provided sufficient oversight, resources, and i

emphasis in maintaining secondary equipment, resulting in several plant

0 02 sg3 Tennessee Valley Authority 2

transients. Although the overall condition of the safety related portion of the plant'was generally adequate, improvement could also be achieved there as well. A lack of attention to detail and procedural problems during maintenance indicated that management involvement and oversight have not been fully effective in instilling the approp"iate sensitivity among plant personnel as to the importance of procedoral adherence and quality of maintenance activities. Lack of configuration control during maintenance and fragmented management of the inservice inspection program were also identified. TVA management should closely monitor progress regarding the above weaknesses.

Overall, performance in the area of Engineering was adequate.

Engineering assessments of balance of plant systems during the dual unit outage identified modifications and repairs to improve the reliability of these systems. The quality of design change packages, the technical support provided to operations, and the performance of system engineers was found to be satisfactory. Weaknesses were identified in engineering evaluations, and operators were challenged by some design deficiencies.

In the Plant Support area, effective programs were implemented in areas of radiological controls, chemistry, emergency preparedness and security.

Strengths were noted in the ALARA program and accomplishments in the area of exposure control. Also noted as a strength was the overall processing of radwaste, including shipping. Effective training programs in Security and Emergency Preparedness were reflected by well performed drills and exercises.

Room for improvement was noted in procedural adherence in radiation controls.

The fire protection program was adequately implemented, however, continued support should be given to program improvements and system material condition.

Our reviews of your self-assessment efforts indicate that early in the assersment period, plant management did not fully recognize the magnitude of longstanding problems that existed at the site. These self-assessment inadequacies resulted in an extended dual unit outage.

Actions taken by management resulted in programs that were proven to be generally effective late in the assessment period. The internal and external assessments provided meaningful input to the site management during Unit 2 restart efforts. Plant management was receptive to the identification and resolution of longstanding problems. The continuation of critical self-assessments throughout your organization over the long term is essential to address the many challenges that have been identified throughout the SALP period.

Please provide a written response within 30 days to address the weaknesses identified in the functional areas of Operations and Maintenance.

In addition, please be prepared to discuss performance and planned actions in these functional areas during the'SALP presentation of December 14, 1993.

In accordance with Section 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.

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t DEC 02 g Tennessee Valley Authority 3

Should you have any questions or comments, I would be pleased to discuss them with you.

i Sincerely,

.l 7) c g'#ftit;;/ (./d e (.[h{.

Stewart D. Ebneter-Regional Administrator e

Enclosure:

SALP Report cc w/ encl: (See page 4) i

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Tennessee Valley Authority 4

DEC 0 2 1993 cc w/ encl:

Mr. Craven Crowell, Chairman Mr. Robert Fenech, Site Vice Tennessee Valley Authority President ET 12A Sequoyah Nuclear Plant 400 West Sumit Hill Drive Tennessee Valley Authority Knoxville, TN 37902 P. O. Box 2000 Mr. W. H. Ken'n'oy, Director Tennessee Valley Authority Mr. R. M. Eytchison, Vice Pre:;ident ET 12A Nuclear Operations 400 West Sumit Hill Drive Tennessee Valley Authority Knoxville, TN 37902 3B Lookout Place 1101 Market Street Mr. Johnny H. Hayes, Director Chattanooga, TN 37402-2801 Tennessee Valley Authority ET 12A Mr. Michael R. Mobley, Director 400 West Sumit Hill Drive Division of Radiological Health Knoxville, TN 37902 3rd Floor, L and C Annex 401 Church Street TVA Representative Nashville, TN 37243-1532 Tennessee Valley Authority Rockville Office County Judge 11921 Rockville Pike Hamilton County Courthouse Suite 402 Chattanooga, TN 37402 Rockville, MD 20852 Mr. Bill Harris General Counsel Route 1, Box 26 Tennessee Valley Authority Ten Mile, TN 37880 ET 11H 400 West Sumit Hill Drive INPO Knoxville, TN 37902 Mr. B. S. Schofield, Manager Nuclear Licensing and Regulatory Affairs Tennessee Valley Authority 4G Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Ralph H. Shell Site Licensing Manager Sequoyah Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Soddy Daisy, TN 37379 i

6

SALP REPORT - SEQUOYAH NUCLEAR PLANT 50-327/93-43 & 50-328/93-43 I.

BACKGROUND The SALP Board convened on November 8, 1993, to assess the nuclear safety performance of'Sequoyah Nuclear Plant for the period of August 2,1992, through October 9, 1993. The Board was conducted pursuant to NRC Management Directive 8.6, " Systematic Assessment of Licensee Performance." Board members were Ellis W. Merschoff (Board Chairperson), Director, Division of Reactor Projects, NRC Region II (RII); J. Philip Stohr Director, Division of Radiation Safety and Safeguards, NRC RII; Frederick J. Hebdon, Director, Project Directorate II-4, NRC Office of Nuclear Reactor Regulation; and, Albert F. Gibson, Director, Division of Reactor Safety, NRC RII. -This assessment was reviewed and approved by Stewart D. Ebneter, Regional Administrator, Region II.

II.

OPERATIONS This functional area consists of the control and execution of activities directly related to operating the plant.

It includes activities such as plant startup, power operation, plant shutdown, and response to transients.

It also includes initial and requalification training programs for licensed operators.

In this area, TVA's attention and involvement have resulted in an acceptable level of performance. However, performance has declined from the previous assessment period.

Operators have typically performed well in responding to several plant transients. The prompt and appropriate response to transients initiated by control air problems, the rapid power reduction of Unit 2 during a main bank transformer fire, and the response to the Unit 2 extraction steam line rupture, demonstrated plant operators were capable of placing the plant in a safe condition. However, the response to the December 31, 1992, dual unit trip was handicapped by inadequate operator staffing and training, and resulted in several operator errors on Unit 2 which complicated plant response and recovery. The decision to maintain minimum operator staffing levels, and 3

not consistently train at these levels, indicated plant management was not sufficiently involved in day to day operation to recognize the needs of the operating staff.

A general lack of management involvement and safety sensitivity was identified early in the assessment period.

Inappropriate management involvement during steam inlet valve testing resulted in a Unit I turbine runback in August 1992.

Licensee management failed to fully evaluate the consequences of a testing evolution in December 1992, which resulted in the cooldown of the refueling water storage tank. Additionally, a poor safety attitude was exhibited by a r2 fueling senior ree:. tor operator during the recovery of a tilted fuel assemP y in June 1993.

2 During the latter half of the assessment period, the NRC observed an increase in management involvement and direction, which resulted in a more conservative approach toward operation of the facility.

The oversight and direction i

provided by the Management Restart Review Comittee and Backlog Review Committee were generally conservative. Good progress in the implementation of the restart plan was also a direct result of increased management involvement.

Improvements in this area were due, in part, to the efforts of new senior managers on sTte, who began to establish a rigorous safety attitude among the staff.

Licensee assessments and audits, after the units were shut down, indicated that plant management was receptive to the identification and resolution of 1

longstanding problems. The assessments by an independent management oversight group provided meaningful input to site management that assisted in focusing the restart effort. However, plant management initially did not fully recognize the magnitude of longstanding problems that existed at the site.

These problems resulted in an extended dual unit outage.

During the previous SALP assessment, several problems were identified with configuration control of plant equipment. These problems have persisted during this assessment period.

Examples included incorrect emergency raw cooling water throttle valve settings, an incorrect thermal barrier booster pump switch alignment, and an incorrect discharge throttle valve setting for a reactor coolant drain tank pump. The continuing problems in configuration control were due, in part, to the lack of a questioning attitude by plant personnel and procedural inadequacies. Although management attention was evident late in the assessment period, continued effort is needed in both of these areas.

Weaknesses were also noted in the areas of comunications and attention to detail, as exemplified by the failure to maintain the proper refueling water -

storage tank solution temperature, and the failure of multiple shift crews to recognize this deficiency.

However, observation of operator performance late in the SALP period indicated this area was improving.

TVA continued implementation of an adequate training program, including the initial licensed operator training program and the operator requalification program, as demonstrated by acceptable performance of operators on NRC administered examinations.

The operations area is rated as a Category 3.

III.

MAINTENANCE This functional area includes all activities associated with diagnostic, predictive, preventive, and corrective maintenance of plant structures, systems, and components.

It also includes surveillance testing, inservice inspection and testing, instrument calibrations, equipment operability tests, post-maintenance testing, containment leak rate tests, and special tests.

3 TVA's attention and involvement have resulted in an acceptable level of performance in this area. However, performance has declined from the previous assessment period.

During the assessment period it was noted that some equipment was not adequately maintained.

For example, failure to properly maintain control air receivers resulted in blockage of a drain line and water injection into the control air system, initiating a dual unit transient. An extraction steam line rupture event revealed that some balance of plant equipment was degraded, which resulted in challenges to safety systems. These examples indicated that plant management had not provided sufficient oversight, resources, and emphasis in maintaining secondary equipment. The overall condition of the safety related portion of the plant was generally adequate. However, the lack of a periodic corrosion inspection to identify potential degradation of the containment liner indicated improvement could be achieved in primary plant maintenance as well.

Several examples were identified that indicated a lack of attention to detail during maintenance activities.

For example, a sump pump was decoupled, the pump motor electrically disconnected, and a refurbished motor installed with the pump capable of being electrically operated. Subsequent review detemined that the craft performed work on a pump other than the one identified in the work package. Also, a maintenance error resulted in the improper installation of a containment blind flange air lock penetration, resulting in a failure to itaintain primary containment integrity within required limits.

Problems with procedural adherence and quality of procedures were identified as well. Lack of detailed testing procedures for replacement of a breaker in the switchyard resulted in unnecessarily bypassing many levels of primary fault protection.

This condition resulted in a dual unit trip.

Inadequate administrative procedural guidance resulted in more than 50 safety-related instrument calibrations not being performed as required.

Late in the assessment period, procedures were not followed during maintenance on a 6.9 KV unit board. The above examples of lack of attention to detail and procedural problems during l

maintenance indicated that management involvement and cversight have not been fully effective in instilling the appropriate sensitivity among plant personnel as to the importance of procedural adherence and quality of maintenance activities.

Lack of configuration control during maintenance was evident for some plant activities. A system engineer and auxiliary unit operator performed maintenance (field tuning) on a heater drain tank level controller without a i

procedure or work request, resulting in a unit transient.

In addition, failure to maintain configuration control while performing corrective maintenance on a drain tank level control bypass valve resulted in a wiring error, an air supply piping error, and removal of a check valve without proper documentation.

Also, foreign material in the Unit I reactor vessel was not identified and removed prior to core reload. Again, these problems are reflective of management's ineffective oversight at ensuring quality and maintaining control of maintenance activities.

4 Examples were also identified in which more care is needed when developing tests that are designed to determine operability. A safety injection pump was 4

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4 inoperable due to a maintenance activity, and testing performed following maintenance failed to determine that the pump was inoperable. Also, TVA failed to recognize that during quarterly safety injection pump testing, the acceptance criteria for the pump suction pressure could allow testing with potentially inadequate suction pressure. This condition could have resulted in pump damage. Also, problems were identified involving conduct of required i

testing. Examples included baron sampling of water in the refueling cavity and failing t6 control post maintenance testing activities as required.

TVA maintained an adequate inservice inspection program during this assessment period. However, need for additional improvement was demonstrated by a weakness associated with management oversight and lack of attention to detail i

by TVA technical personnel. Specifically', TVA failed to perform some pressure test visual inspections on several safety related systems. A Waiver of Compliance was necessary to extend the time limit required for a plant shutdown to perform the tests. The inservice testing program was found to be generally adequate.

The maintenance area is rated as a Category 3.

IV.

ENGINEERING The functional area of engineering addresses the adequacy of technical and engineering support for all plant activities. Design control and modifications are encompassed as is engineering and technical support for operations, maintenance, outages and testing.

TVA's attention and involvement in the area of engineering and technical support have resulted in good overall performance.

The quality of design change packages was adequate. Safety evaluations were generally satisfactory and modifications were properly implemented in accordance with licensee procedures.

Design engineers had a good understanding of design changes. However, some problems were identified i

involving modification of the chemical and volume control system heat trace and modification of the control room ventilation system.

Engineering support to operations was weak. Operators were challenged by deficiencies in design documentation. An error in a Category 1 drawing caused a personnel error which resulted in the actuation of engineered safety features, drawings of piping in the balance of plant were incomplete, Category 2 and 3 drawings were not updated in a timely manner, and the Final Safety Analysis Report was inconsistent with the as-built plant.

Engineering solutions to operational problems were not always timely or effective, and documentation of some technical evaluations performed prior to Unit 2 restart i

did not contain sufficient information to support conclusions.

Engineering support to maintenance improved over this assessment period.

Early in the period, significant deficiencies were apparent.

Examples

)

included a deficient program for predicting piping degradation due to erosion i

and corrosion and failure to include appropriate environmental qualification i

5 requirements in maintenance and surveillance procedures.

Engineering support improved later in the period.

System engineers performed walkdown inspections of their assigned systems to identify needed maintenance and actively participated in the prioritization of maintenance and modifications to upgrade these systems. Additionally, steps were taken to strengthen other technical programs including the program for predicting erosion and corrosion.

Performance in'the areas of problem identification and corrective actions improved over the assessment period.

Early in the period, many deficiencies in plant condition and engineering programs were not recognized and a large backlog of identified deficiencies had not been properly prioritized. By the end of the period, the threshold for problem identification had been lowered, items in the backlog had been properly prioritized, and appropriate corrective actions had been completed. Corrective actions taken in response to erosion and corrosion problems illustrated this change. The scope of the licensee's self-assessments and corrective actions in this area extended well beyond the erosion and corrosion issue.

The engineering area is rated as a Category 2.

V.

PLANT SUPPORT The Plant Support functional area covers all activities related to _the plant support function including radiological controls, emergency preparedness, security, chemistry, fire protection, and housekeeping controls.

The radiological controls program effectively controlled both internal and external radiation exposcres during this period. A well supported, aggressive As Low As Reasonably Achievable (ALARA) Program achieved a continued downward trend in person-rem / reactor with the cur ent fiscal year goal of 200 person-rem / reactor projected to be met which t..il be the lowest annual dose in Sequoyah history.

Particularly noteworthy this period was the low exposure achieved as a result of excellent planning for the core barrel removal and reinstallation for its ten year inservice inspection.

Professional and technical radiation protection staff were knowledgeable and committed to minimizing personnel radiation doses. The contamination control program was strong with personnel contamination events well below the goal. Housekeeping and contaminated area controls were generally good during normal operations and also during the outage. Good planning allowed a significant reduction in the use of respirators, helping to reduce external dose with no significant internal uptakes.

Although the overall program was strong, there were some failures to adhere to radioactive material control requirements which indicated room for improvement in this area.

Liquid and gaseous radioactive effluents were also effectively controlled and monitored during this period. The projected offsite doses resulting from effluents were well within applicable limits. The radiological environmental monitoring program was well conducted and confirmed the low levels of effluents released from the plant. Management directed increased attention to the reliability problems with the Post-Accident Sampling System which had been experienced throughout the period. The effective processing, packaging,

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4 6

storing and shipping of radioactive wastes was a strength.

Solid radwaste generation was reduced during the period through a good level of management attention.

Effective audit programs were conducted in both the radiological protection areas and also the physical security area.

Prompt corrective actions were taken for audit findings.

In general, the physical security program was well supported and effectively implemented, although there were some problems identified during this period.

Management continued to provide strong support for this program as evidenced by the ongoing extensive program upgrade. Significant improvements during this period included an alarm station computer simulator for training on the new system and upgraded firing range facilities.

Security staff training and qualification was considered a strength.

Response force training was conducted with local law enforcement authorities, and training was added in hostage negotiations and terrorist countermeasures. This was reflected in well performed drills.

Early in the period, there were some significant failures to properly protect safeguards information. These problems were properly addressed and effectively corrected, as confirmed by inspection later in the period.

Problems identified with the initial implementation of the access authorization rule were also promptly corrected.

TVA continued to provide strong support for the emergency preparedness program.

Trat u g and exercise performance were considered a strength.

Shift personnel demonstrated a comprehensive knowledge of emergency duties and responsibilities.

There was continued support training provided for offsite responders. Off-hours staff augmentation drills were perfonned to ensure activation times could be met for all times of the day.

Facilities and equipment were maintained in a state of readiness. The Operations Support Center was moved and improved, and an additional environmental monitoring van was added during the period. Sequoyah responded well to actual events during the period.

Four emergency declarations occurred, and all were appropriately classified with proper notifications.

The fire protection program was adequately implemented during the period.

Progress continued with regard to the fire protection improvement plan.

Management's monitoring of fire protection issues was good and innovations to improve fire operations performance were being successfully tested and implemented.

Sequoyah identified a number of through wall leaks in carbon steel fire protection piping as a result of their problem trending program.

As a result, repair and replacement were planned with extensive compensatory measures. However, review of this issue and significant leakage through fire protection system valves at another TVA facility in the past identified an initial lack of effective communication between the TVA sites on this matter.

Management attention focusing on communication of potential generic issues in the company is warranted. An inspection and evaluation program for microbiological corrosion of the fire protection system was initiated during this period.

The plant support area is rated as a Category 1.

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