ML20059E588
| ML20059E588 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/03/1994 |
| From: | Fenech R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9401120055 | |
| Download: ML20059E588 (6) | |
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January 3, 1994 1
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:
SEQUOYAH NUCLEAR PLANT (SQN) - RESPONSE TO Tile 1993 SYSTEMATIC ASSESSMENT l
OF LICEMEE PERFORMANCE (SALP) REPORT NOS. 50-327, 328/93-43 t
By letter dsted December 2, 1993, the NRC staff transmitted to TVA the l
initial SQN SALP report for the period of August 2,_1992, through
'l October 9,1993. On December 14, 1993, NRC and TVA representatives met to discuss the report findings.
This letter provides TVA's response to the report.
TVA considers the report to be an accurate assessment of SQN's I
performance over the evaluation period, and it is consistent with our own assessments. The adequate rating in the Operations and Maintenance functional areas is not considered by TVA and the management team at SQN
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to be an acceptable level of performance. We have taken comprehensive actions over the last year to improve site performance. A SQN Site Improvement Plan (SIP) that addresses the weaknesser and clearly defines prioritica has been developed and is being implemented. The plan will continue to improve performance and reliability and will be enhanced as improvements and/or deficiencies are ident' tied. Specific efforts to 1
improve Operations and Maintenance are described in the enclosure.
Overall site performance improvements are described in the Sequoyah Restart Plan and the SIP.
A cooprehensive set of performance indicators is being monitored to determine progress against the site goals. To date, performance levels in (perations and Balance of Plant reliability have not reached the t
desired level. Performance deficiencies are being dealt with as they j
occur to ensure that root _causes are being identified and corrected and i
thet the lessons learned are applied.
Long-term improvement and success l
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depend on our commitment to a consistent course of action, continued l
management involvement, cicar definition of expectations and accountability, and implementation of the SIP.
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9401120055 940103 E
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- PDR ADOOK 05000327 L j'
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j U.S. Nuclear Regulatory Commission Page 2
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January 3, 1994 l
There are no connitments contained in this submittal.
If you have any questions concerning this submittal, please telephone R. H. Shell at (615) 943-7170.
Sincernly, i
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Robert A. Fenech cc (Enclosure):
INPO Records Center Institute of Nuclear Power Operations 700 Galleria Parkway AtInnta, Georgia 30339-5957 1
is t. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Connission One White Flint, North l
I 11555 Rockville Pike Rockville, Maryland 20852-2739 l
NRC Resident Inspector Sequoyah Nucienr Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S. Nuclear Regulatory Conaission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 1
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1 ENCLOSURE RESPONSE TO NRC REPORT NOS. 50-327, 328/93-43 DATED DECEMBER 2, 1993 L
OFERATIONS The Systematic Assessment of Licensee Performance (SALP) report indicated a decline in the Operations functional area.
Problems with the configuration control of plant equipment persisted during the assessment period. The configuration control problems are due, in part to the lack of a questioning attitude by personnel and procedural inadequacies.
Weaknesses in the areas of communications and attention to detail continue to result in plant events.
Initiatives were implemented as part of the Restart Plan to improve Operations ' performance. These initiatives include the development of an effective configuration control process; certifying the configuration of the plant, including balance-of-plant (B0P) components; strengthening management and personnel; continuing efforts to upgrade personnel standards and culture; and coaching to provide effective conduct in areas
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such as procedure adherence, plant ownership, command and control, formality of communications, self-checking, logkeeping, turnover, and status monitoring. As a result of the initiatives, the performance in Operations has improved over that at the beginning of the assessment period.
Initiatives, as described in the Site Improvement Plan (SIP), to continue improvement in the Operations area have been developed.
Management involvement and direction will continue to emphasize a risk-sensitive conservative approach toward operation of the facility.
This will be accomplished through continued department standdown meetings, management discussion during requalification training, leadership meetings, management observations of simulator training, and management presence in the field.
To continue the improvement process, Operations' performance evaluation and improvement will require critical self-assessments to be conducted to supplement Nuclear Assurance assessments.
Results of the assessments will be discussed with personnel on-the-spot with generic issues being covered with the entire department.
Increased emphasis will be placed on attention to detail and clear, concise communications. The self-checking " STAR" (STOP, TilINK, ACT, REVIEW) process will continue to play a key role in this area.
Personnel-will continue to be held accountable for their actions in accordance with established management expectations.
This program will be expanded to include definitive guidance on what is expected for frequently conducted evolutions (e.g., inspecting a skid-mounted component for proper.
operation).
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- m Further strengthening of operating management is being accomplished. The Operations organization has been restructured in order to allow Operations management to focus on site ownership and operational 1
decisions.
Nine assistant shift operations supervisor (ASOS) candidates with high potential have been hired and are in the senior reactor operator (SRO) tralning program. Five experienced TVA engineers are also in the SRO training program. These individuals should receive their SRO licenses by early summer. At that time, the number of ASOSs will exceed those needed-for a full-shift complement and will result in reduced overtime for the ASOSs. Additionally, some of the current ASOSs will be utilized in other job functions (e.g., Planning and Scheduling and Technical Support) to provide operator experience in those areas.
In addition to those nine ASOS candidates, eight additional SRO candidates, the majority of which are former Navy nuclear-trained officers, have begun SRO training. This training is scheduled to be complete in 1995.
To provide greater flexibility, improve productivity, and reduce overtime, the completion of the assistant unit operator (AUO) qualification program has been accelerated. Additionally, a new class of AUOs is scheduled to begin in 1994.
Specific SIP actions include efforts to reduce backlogs (e.g., hold orders and compensatory measures), improve B0P reliability, improve procedures, improve personnel effectiveness, identify and implement process improvements, and clearly define expectations.
MAINTENANCE NRC noted a decline in the Maintenance functional area over the assessment period, with weaknesses noted in two primary areas:
(1) oversight, emphasis, standards, and resources applied to the secondary plant, and (2) managemqnt involvement and effectiveness in instilling the appropriate sensitivity among plant personnel regarding procedural adherence and the quality of conduct of maintenance activities. While actions were taken to address the individual events or problems noted, actions are also being taken as described in the Restart Plan and SIP to address the broader issues.
Secondary plant reliability and design reviews were conducted to identify areas with the potential to impact reliable operations and the associated corrective actions. A large number of these activities (e.g.,
modifications, maintenance, procedure changes, etc.) were implemented before the restart of Unit 2; and others were prioritized for longer-term implementation based on the potential impact on secondary plant reliability. Additional resources have been allocated, as necessary, to address longer-term improvements such as secondary plant calculations that will assist in the efforts to optimize the operation, design, and maintenance of the secondary plant.
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The maintenance backlog for both preventive and corrective maintenance cn1 the secondary plant was reviewed for restart by SR0s and system engineers 4
to identify deficiencies that could adversely impact secondary plant reliability. Detailed system walkdowns of the secondary plant were i
conducted with a lowered threshold for problem identification.
Deficiencies were documented and similarly reviewed for potential impact on secondary plant _ reliability. The remaining backlog of maintenance j
items was reviewed collectively by system engineers to assess the overall i
impact on reliable system operation. Additional system engineering i
involvement in work prioritization, for both the secondary and primary plant systems, is being utilized to enhance ongoing assessments of the overall system material condition.
Temporary repairs to the Unit 2 secondary plant were made permanent during the recent outage. Repairs will be made on Unit 1 before l
restart. Temporary repairs now receive additional management oversight l
and involvement in approval.
Existing temporary repairs are reviewed weekly in the Plant Manager Daily Leadership meeting to ensure continued
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attention and focus. Temporary repairs are classified by the operating
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condition needed for permanent repair and are integrated into the forced' outage list to ensure timely correction.
Long-term maintenance improvement efforts are being focused to address backlog reduction and process improvements, and to optimize ongoing l
performance assessment and monitoring. Resources are being applied to i
the backlog management and reduction effort to ensure timely completion f
and effective integration of those efforts with other site priorities.
l Process improvements (e.g., planning and scheduling processes) are being closely examined to expedite the correction of material deficiencies, i
improve personnel effectiveness, and optimize resource allocation. The preventive maintenance program for BOP equipment affecting plant trip and transient events is being strengthened.
l The schedule performance accuracy requires improvement. However, a real measure of efficiency cannot be accurately determined until I
implementation of the 12-week rolling schedule. The 12-week rolling
-j schedule will be implemented in January 1994. The new schedule will i
allow foremen and general foremen to better preplan their activities, I
optimize productivity, and allow them to increane their time in the field.
Increased productivity and management involvement will aid in the reduction of outstanding deficiencies in a more timely manner. The increased time in the field by the foremen and general foremen will provide further reinforcement of management expectations and procedural adherence.
Performance monitoring has been strengthened through development and.
l implementation of key performance indicators, which are closely monitored
'l and reviewed on a weekly and/or monthly bases. A monthly Maintenance department performance report has been developed to improve performance i
measuring and monitoring, heighten overall department personnel knowledge and. involvement in department performance improvement, and enhance i
department management tools to identify areas for improvement.
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Maintenance personnel involvement in the Nuclear Assurance Maintenance j
Performance Evaluation Program implementation has served to establish the basis for long-term "line" performance assessment and improving line perspective on areas for improvement.
Periodic external corporate and i
industry reviews and assessments are being scheduled to further increase
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the effectiveness of self-assessment efforts.
1 Tn increase sensitivity of plant personnel regarding procedural adherence i
and the conduct of maintenance activities, several actions have been I
taken.
Lessons learned from events associated with maintenance activities have been discussed with Maintenance personnel. Special emphasis was made as to each person's responsibility in maintaining and documenting configuration control during maintenance activities.
Appropriate corporate personnel in the outage organization have been
,i trained in the configuration control and work order processes. A policy on configuration-control requirements, relative to temporary systems and devices, han been developed to ensure that proper configuration is maintained during all activities.
Extensive communication regarding management expectations and reinforcement of those expectations were discussed with Maintenance personnel during standdown meetings.
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