ML20059E185
| ML20059E185 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/31/1990 |
| From: | Wallace E TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9009100077 | |
| Download: ML20059E185 (8) | |
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- TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ot SN 157B 1.ookout Place AUG 311990 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlement f
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - NRC INSPECTION REPORT NOS. 50-327, 328/90 RESPONEE TO NOTICE OF VIOLATION 50-327, 328/90-22-01 Enclosed is TVA's response to B. A. Wilson's letter to 0. D. Kingsley, Jr.,
dated July 26, 1990, which transmitted the subject notice of violation rnardli.g noncompliance with procedures governing use and approval of overtime. provides TVA's response to the notice of violation. As a result of review of recent history both prior to and during the Unit 1 Cycle 4 refueling outage, TVA concluded that processes for controlling use of overtime 3
warrant further improvement both f rom a management and impicmentation perspective.
Beyond the actions needed to ensure compliance with approval and docuuentation requirements, TVA's ultimate goal is to further reduce the need for overtime usage consistent with regulatory guidance, effective personnel
. performance, and TVA's objectives. TVA considers corrective action described j
in our response to the notice of violation will be effective in both minimizing use of overtime and ensuring compliance with approval and documentation requirements when overtime must be used.
Summary statements of commitments contained in this submittal are provided in Enclosure 2. provides TVA's response to the additional question expressed by NRC regarding TVA's Quality Assurance group activities prior to NRO's identit'ication of the violation.
i1f you have any questions concerning this submittal, please telephone M. A. Cooper at (615) 843-6422.
Very truly yours, TENNESSEE VALLEY AUTHORITY E. G. Wallace, Mar ger Nuclear Licensing and Regulatory Affairs l
Enclosures cc:
See page 2-9009100077 900831 PDR ADOCK 05000327
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PDC Q
- UUUu, sjI An Equal Opportunity Employer
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U.S. Nuclear Regulatory Commission JLll8 811990 cc (Enclosures):
Ms. S. C. Black, 7eputy Director Project Directorate 11-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20tS2 Mr.'J. N. Donohew, Project Manager i
U.S. Nuclear Regulatory Conmission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 g
NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road I
Soddy Daisy, Tennessee 37379 Mr. B. A. Wilson, Project Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 i
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ENCLOSURE 1 G
,J RESPONSE TO NRC INSPECTION REPORT
>4 NOS. 50-327/90-22 AND 50-328/90-22 B. A. WILSON'S LETTER TO 0. D. KINGSLEY, JR.,
DATED JULY 26, 1990 t'
Violation 50-327. 328/90-22-01
" Technical Specification 6.8.1 states that, Written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix 'A' of Regulatory Guide (RC) 1.33, Revision 2,
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February 1978. Appendix
'A' of RG-1.33 requires procedures for Maintenance of p
Minimum Shift Complement and Call-In of Personnel.
L This requirement isiimplemented in part by AI-30, Nuclear Plant Conduct of F
Operations, and Nuclear Plant Standard STD-2.1.7, Administration of Overtime.
AI-30, Section 23 ' Plant Overtime Limits' requires authorization by the. Plant Manager or his deputy to exceed the overtime limits specified in AI-30.
Contrary to the above, from November 1989 to May 27, 1990, the licensee exceeded the overtime requirements of AI-30 on numerous occasions without proper authorization.
This.is a Severity Level IV violation (Supplement I)"
- Admission or Denial of_the Alleged Violation TVA admits the violation.
., Reason icr the Violation The cause of~this specific violation was insufficient Operations' management oversight and attention to the requirements specified in Administrative Instruction (AI) 30, " Nuclear Plant Conduct of Operation, regarding the approval for personnel to exceed prescribed overtime limits and the documentation of that approval.
TVA also examined cases'of personnel exceeding the overtime limits in other SQN organizations without the required documented authorization.
Inattention to detail and lack of proper oversight are again considered the causes of these: situations.- Contributing causes identified for these failures to meet AI-30' requirements included unfamiliarity with the requirements and ambiguity regarding which personnel were subject to the requirements.
TVA has concluded that processes for controlling use of overtime warrant
- further strengthening to both minimize the use of overtime and ensure compliance with approvat. and documentation requirements when overtime must be worked.
i Several additional concerns regarding overtime implementation in the Operations organization were identified in the inspection report and are addressed below.
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The inspection report stated that overtime was used regularly during times when both units were in operation. Routine use of overtime during two-unit power operations has been necessary largely to support current levels of operations upgrade training.
It is expected that the need for increased training will continue for a period of time.
However, broader efforts to
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promote efficiency improvements and corresponding overtime use reductions within the Operations organization are ongoing. These efforts are discussed in the corrective action section.
The inspection report noted that confusion existed among shift operations supervisors (SOSs) regarding the minimum allowed turnaround time between work periods. The General Agreement with the operators' union stipulates a minimum turnaround time of six hours while AI-30 stipulates a minimum of eight hours.
While those two requirements are not mutually exclusive, the differences led to some inconsistencies in application.
The impact of these different views was recognized by Operations' management approximately half way through the Unit 1 Cycle 4 refueling outage and was corrected by verbally clarifying the applicability of the AI-30 minimum t'arnaround time requirements to the SOSs.
Additional stipulations in the General Agreement regarding selection and offering of overtine conflict to some extent with the AI-30 overtime guidelines and philosophy, and have resulted in examples of undesirable individual overtime deviations. Operations' management has also conveyed to personnel that, where conflicts exist AI-30 will take precedence.
The inspection report stated that licensed operators are not utilized to the extent necessary to reduce excessive levels of overtime, noting that
_ Operations' personnel were pooled for overtime. usage during the recent Unit 1 outage. The report further stated that, consideration of overtime for job assignment,was not being performed. The decision was made by Operations' management to' distribute overtime across both units during the refueling outage. TVA considers decisions regarding the distribution and assignment of overtime must be made in the context of ongoing activities, expected duration, and the personnel involved.
It was determined that impicmentation of this philosophy. requires further formalization to ensure appropriate and consistent application.
Corrective _Steog_That Have Been Taken and Results Achieved Overtime policy and requirements have been discussed with key site managers with added emphasis on expectations with regard to both minimizing the use of a
overtime and fully complying with associated procedures when overtime is used.
Extensive management focus is being applied to improve overtime use controls.
Both outage and nonoutage overtime limits have been established for individual organizations and the SQN site as a whole.
Deviations from these limits to support critical unforeseen situations must be preapproved at the senior management level. Weekly performance against these limits is being closely nonitored by senior site management.
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i Corrective Steps That Will be Taken to Avoid Further Violations To ensure that employees are fully aware of both management's expections and the regulatory requirements regarding use of overtime, managers are meeting j
with employees to address these issues in detail.
These meetings are to be completed by September 15, 1990.
Individual organizations are evaluating the adequacy of their internal processes for controlling and approving use of overtime. This includes evaluating adequacy of and upgrading as necessary the administrative processes (e.g., tracking, monitoring, and approving){ ensuring that employees are familiar with both overtime policy and specific requirements;and clearly defining accountability for compliance with requirements. These efforts are expected to both strengthen controls and reinforce expectations.
Control processes and practices are being examined to identify areas needing improvement that mr.y be contributing to the use of overtime. Actions being taken in the Operations organizations include streamlining of certain logkeeping practices and eliminating unnecessary or duplicate housekeeping preventative maintenance efforts.
Operations' management is focusing attention to achieve finer and more accurate scheduling.
It has been shown that overtime usage can be directly related to schedule completion performance. An example of efforts being taken in this area is walking down of the auxiliary unit operators.(AU0s) routes by the Operations managers to improve duration estimates. TVA considers that these ongoing efforts in the Operations organization will yield substantial reductions in the need for routine overtime and will allow greater flexibility to deal with emergent work without the need for excessive use of overtime.
Similar review of control processes and practices are being conducted in other site organizations.
Examples of improvements noted to date include application of reduced planning
.for minor maintenance activities, installation of a radiological exposure system terminal at the lower elevation of the auxiliary building to facilitate timely-exit and reentry into radiologically controlled areas, and refinement of workplan review requirements to eliminate unnecessary " boiler plate" review signoffs. Organization reviews of control processes and practices to identify l
areas needing improvement will be completed by September 14, 1990, with documented recommendations and improvements submitted to the site director by September 28, 1990.
The Nuclear Power Standard (STD) 2.1.7
" Administration of Overtime," will be revised by September 15, 1990, to clarify the documentation for authorizing deviations from overtime limits and to clarify which personnel the regulatory overtime limits apply (e.g., senior reactor operators, reactor operators, AUOs, Radiological Control, and key maintenance personnel). The standard additionally describes TVA's overtime policy for all site personnel, i.e.,
applicable to personnel that are not covered by the regulatory guidelines as well as to those that are.
The standard addresses monitoring of overtime use to avoid excessive overtime.
Site Standard Practice (SSP) 32.53
" Administration of Overtime," which directly implements STD-2.1.7, will be revised by September 15, 1990, to reflect the clarif1 cations to STD-2.1.7 described above. The overtime limits currently contained in AI-30 will be l
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deleted-by September 15. 1990, toavoid(duplicationwithSSP-32.53.
The AI revision'will also formalise.-the process used'in the Operations organization for making decisions regarding overtime distribution.and assignment in.
0 l consideration of ongoing activities, expected duration, and personnel involved.- A sitewide dispatch will be issued by September 15, 1990, to apprise.SQN's. employees of:these procedure changes and reemphasize management's expectations.
General employee training will be revised'to include a review of the overtine requirements as specified in SSP-32.53 by' November l',
1990.
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-The Quality Assurance organisation will perform monitoring of overtime-use h
during and after the Unit 2 Cycle 4 refueling outage to verify the:
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effectiveness of the corrective actions being implemented.
Results of these ongoing activities will be reported to'the site director on a. periodic basis.
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.The QA monitoring is expected-to be completed 30 days after_the completion of~
the outage.
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.Date When FullLCompliance Will be Achieved
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- SQN will be in full compliar.ce by September 15, 1990.
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e ENCLOSURE 2 l
L LIST OF COMMITMENTS 1.
To ensure that employees are fully aware of both management's expectations and the regulatory requirements regarding use of overtime, managers are meeting with employees to address these issues in detail. These meetings are to be completed by September 15, 1990.
2.
Individual otganizations are evaluating the adequacy of their internal processes for controlling and approving use of overtime. This includes evaluating adequacy of and upgrading as necessary the administrative processes (e.g., tracking, monitoring and approving), ensuring that employees are familiar with both overtime policy and specific requirements and clearly' defining accountability for compliance with requirements.
These evaluations will be complete by September 15, 1990.
3.
Organization reviews of control processes and practices to identify areas needing improvement will be complete by September 14, 1990, with documented recommendations and improvements sul,mitted to the site director by September 28, 1990.
4.
The Nuclear Power Standard (STD) 2.1.7, " Administration of Overtime," will be revised by September 15, 1990, to clarify the documentation for authorizing deviations from overtime limits and to clarify which personnel the overtime limits apply (e.g., senior reactor operators, reactor operators, assistant unit operators, Radiological Control, and key maintenance personnel).
5.
SSP-32.53 will also be revised by September 15, '.990, to reflect the clarifications to STD-2.1.7.
6.
The overtime limits currently contained in AI-30 will be deleted by September 15, 1990, to avoid duplication with SSP-32.53. The AI-30 revision will also formalize the process used in the Operations organization for making decisions regarding overtime distribution and assignment in consideration of ongoing activities, expected' duration, and personnel involved.
7.
A sitewide dispatch will be issued by September 15, 1990, to apprise SQN's employees of the changes and clarifications to the overtime policy.
8.
General employee training will be revised to include a review of the overtime requirements as specifled in SSP-32.53 by November 1, 1990.
9.- Quality Assurance's (QA) organization will perform monitoring during and after the Unit.2 Cycle 4 refueling outage to verify the effectiveness of the corrective actions implemented.
Results of these ongoing activities will be reported to the site director on a periodic basis. The QA monitoring is expected to be completed 30 days after the completion of the L
outage.
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ENC 145URE 3 RESPONSE TO ADDITIONAL QUESTION NRC expressed an additional concern in the inspection report cover letter
_regarding why TVA's Quality Assurance (QA) organization had not identified the problem prior to NRC's identification.
The previous violation of overtime limits noted in the cover letter Violation 50-327, 328/87-78-01 issued March-14, 1988, was documented _by the TVA corrective action program (Condition Adverse to Quality Report (CAQR]
SQN880158) and was followed up by the Site Quality organization. Monitoring Report QSQ-88-919 issued December 13, 1988, documented that overtime limits
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_were being met at that time.
During 1989, the Site-Quality organization focused heavily'on the verification of implementation of the QA Plan and transition to a technical or c
performance-based approach to verification of plant operations.
Overtime problems'were not identifled and no overtime verifications were planned or documented during 1989.
In_ February 1990, Site QA verified that the quality of fire protection program implementation was not adversely affected by increased overtime usage by the Fire Operations personnel. The need for immediate focus was not identified and broader overtime verification was reschekled as part of immediate prioritization efforts. Extensive QA verification activities were devoted to other site activities.,The judgement to delay overtime monitoring occurred as part of prioritizing activities; in hindsight, the judgement proved incorrect.- Upon identification of NRC concerns and confirmation of the current problem, the Site Quality organization issued a signif{ cant CAQR (SQQ900287) on June 18, 1990, to document identified problems in-implementation of overtime guidelines at SQN.
TVA considers' corrective actions described in Enclosure 1 will be ef fective in both minimizing the use of overtime and ensuring compliance with approval and g
documentation _ requirements when used. As discussed in the violation response, the Site Quality organization will perform monitoring of overtime usage during and after the Unit 2 Cycle 4 refueling outage to verify the-effectiveness of
-the corrective actions being' implemented.
QA's management will continue to strive to effectively manage priorities so as to optimize the use and value of quality verification efforts.
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