ML20079C711
| ML20079C711 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/19/1991 |
| From: | Joshua Wilson TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9106250182 | |
| Download: ML20079C711 (14) | |
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June 19, 1991 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentiemen In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAll NUCLEAR PLANT (SQN) - PERFORMANCE STATUS The purpose of this submittal is to provide a status of SQN's performance over the past year, both overall and in specific functional areas.
'1VA met with the NRC staff on March 13, 1991, to discuss the results ui vur assessment.
This year has marked significant milestones for SQN following the restart of the units in 1988. Performance has demonstrated long-term progress in terms of operational performance, overall improvement of standards of performance, significant plant upgrades, and reductions in implemention of outstanding regulatory requirements. At j
the same time, areas requiring further improvement have also been identifled, both from assessment of specific events and self-assessment i
activities and as a result of the ongoing evolution and developing of the SQN organization relative to expectations. The enclosure provides a discussion of the achievements and the areas for continuing focus for principal functional areas.
-Successful completion of the Cycle 4 refueling outages was a significant achievement for the site, both in terms of the specific activities.and in the demonstrated capabilities of the collective organization. A significant portion of the regulatory backlog was cleared,' including both long-standing issues such as Regulatory Guide 1.97 postaccident monitoring, control room design review implementation, molded case circuit breaker resolution, and resolution of out:canding 10 CFR 50 Appendix R issues; and large pestrestart commitments, such as those involving rigorously and alternately analyzed pipe supports and cable tray supports. Multiple plant upgrades and simplifications were also 9106250182 910619 PDR ADOCK 0500032~7 P
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2 U.S. Nuclear Regulatory Commission June 19, 1991 implemented during the same outages, such e the Eagle 21 reactor protection set upgrade, boron injection tank and upper head injection removal, resistance temperature detector bypass elimination, and component cooling water heat exchanger replacement.
The scope of these efforts reflected a significant management commitment of resources to continue moving SQN forward in terms of safety, reliability, and excellence in operations.
Various programmatic enhancements were also pursued over the past year to simplify basic work processes; to provide better tools for conduct of activities; and to better focus assessment, corrective action, and tracking processes and/or programs.
Examples include overall revision to the plant modification process, upgrade of the SQN simulator model, broader implementation of the lluman Performance Evaluation System (IIPES),
full implementation of the Q-list, continued enhancement of site procedures, improvements in the scheduling and outage planning processes, and an overall upgrade to the corrective action program.
The many changes these efforts represent, along with the extensive outage modifications, combined to challenge the entire station.
Although these efforts will result in long-term benefits, the near-term effects did, in some cases, result in performance below management expectations; and a loss of focus was identified in several areas. These weaknesses were largely recognized during the early fall of last year, and management attention was quickly applied to strengthen the organization.
TVA management met with NRC last November to address these issues and to describe the plans for resolution. Weaknesses were identified in the conduct of SQN's Operations steff, pciformance of incident investigations, personnel performance and communication, and control of site overtime.
Since that time, we have seen improvement in these areas; however, as described in the enclosure, overall performance still needs improvement to meet our expectations in several areas.' These areas will continue to receive significant management oversight and attention to promote further improvements.
The enclosure provides a summary of key perfonnance issues for specific functional areas.
In the various functional areas, reference is repeatedly made to outage accomplishments, continued improvement in plant conditions, and organization performance. While recognizing that the outage accomplishments alone are not a full measure of site performance, we consider the efforts and processes that led to their successful accomplishment to be a good barometer of the maturing process for SQN since restart in 1988. Many things had to be done very well by all organizations in order for those outages to have been accomplished as l
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3 U.S. Nuclear Regulatory Commission June 19, 1991 they were. While we continue to target areas for improvement against a backdrop of increasingly higher expectations, both internal and external assessments tell us that overall station performance is tracking upward.
Overall, we are proud of the accomplishments made at SQN over the past year, but at the same time are clearly mindful of the task before us.
If you have any questions concerning the infortnation contained in this submittal, please telephone me at (615) 843-7001.
Very truly yours, TENNESSEE VALLEY AUTIIORITY h61%L J
L. Wilson Enclosure cc (Enclosure):
Ms. S. C. Black, Deputy Director Project Directorate 11-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission one White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector E
Sequoyah Nuclear Plant 2600 Igou Ferry Road
-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 L
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TRCLOSURE FUNCTIONAL AREA FERFORMANCE ASSESSMENT A.
Plant _ Operations The Operations department has continued to demonstrate the capability to safely operate Sequoyah Nuclear Plant (SQN).
This includes demonstrations of operational expertise and effective and safe control of high levels of in-plant activities, such as that experienced during the Cycle 4 refueling outages, and the ability to control plant transients that had previously resulted in reactor trips. While overall improvement has been demonstrated in operator response to operational events, e.g.,
control of feedwater evolutions during start-up and response to secondary side transients at power, performance in several areas has not been at the expected levels and has highlighted areas for continuing focus.
SQN completed two very difficult and successful outages in 1990. We consider that this success can be largely attributed to the fact that both outages were Operations-driven.
This was a deliberate attempt to reinforce to Operations and the rest of the site the concept that Operations owns the plant.
Operations' ownership is considered very important, and-this philosophy is rapidly becoming a routine way of conducting business. Operations' personnel are now very involved with prioritizing work when the schedule is built, and they are actively involved in the execution of that work. This provides built-la cognizance and control of plant status.
Despite the clear successes noted during the Cycle 4 outages, areas for overall Operations performance improvement were identified as well. A trip was experienced for each unit coming out of the Cycle 4 refueling outages. While numerous improvements over the past year resulted in avoiding the feedwater start-up trips that were experienced coming out of the previous Cycle 3 refueling outages, a reactor trip associated with the isolation of steam to the main feed pumps was experienced when coming out of.the Unit 1 Cycle 4 refueling outage and another trip associated w th d
the loss of a reactor coolant pump when coming out of the Unit 2 Cycle 4 refueling outage.
Both trips involved performance of the Operations crews and could have been prevented.
l As a result of these events and other indications for needed improvement in overall command and control, an Operations improvement program was initiated in the fall of last year to further achievement of standards of l
excellence in operational performance. This improvement program involves, among other things, management. reinforcement and monitoring of expectations, which are being achieved by increased management discussions with the shift crews; observations in the main control room and planti and overall focus on operations.
Improvement plans for Operations' managers were initiated as part of this-overall program and cover personnel error reduction, command and control, communications, Operations' management participation in training, and succession planning. Additionally, du ing Week 6 of requalification in 1990, all licensed operators received the Institute of Nuclear Power Operations (INPO) Control Room Teamwork Development Training Course.
Evidence of improvement has been noted in these areas.
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- Since the Unit 2 reactor trip in November, several major transients were successfully mitigated (two balance-of-plant runbacks and a load rejection on Unit 2) that previously could have resulted in reactor trips.
Significant improvements were noticed in command and control, communications, and self-verification during these transients.
The results of a recent INPO assistance visit and the overall site evaluation indicated improvement in these areas.
As a result of the findings from the INP0 reviews, an ongoing self-assessment, and recent u.' events involving maintaining proper attention and response to
. ant r..nunciators, additional initiatives have g Operations improvement initiatives.
been incorporated into ths m
Refinements to ','Operato.
the Controls" (OATC) procees have been implemented; one operator is designated as the OATC and has only one responsibility--to operate and monitor the status of the unit.
Administrative responsibilities, such as work approval, test support, or answering telephones, are handled by tl.e other unit operator.
The administrative load in the MCR has been reduced by limiting calls and enforcing strict access control. A significant reduction in lit annunciators and nuisance alarms has been accomplished over the past six months as a result of ongoing initiatives.
An evaluation of recent performance indicated that expectations regarding besic standards of performance in overall conduct of operations were not clearly defined, understood, or adequately reinforced. As a result, a review of currently published operating standards has bcen conducted to detennine if expectations are appropriately conveyed and underr.cood and reflect the desired level of performance. An independent review by senior management will be conducted to determine where interim measures are warrcnted, and additional actions will be implemented as appropriate.
Stan1ards will then be revired, where needed, to provide the requisit-long-term guidance.
Expectations are being and will be clearly communicated throughout the organization by cascading, two-way communication meetings and will be incorporated into the licensed operator training program to continually reinforce standards cod ensure a long-term effect.
Independent personnel analysis efforts have been ongoing to identify areas for additional focus and to determine optimum methods to effect performance improvements.
Management involvement has also been incteased over the last year. The Site Vice President, Plant Manager, and Operations Manager rotate weekly hours of control rcom observation, both for performance assessment and continued feedback of expectations. The Plant Manager is meeting with each shif t operations supervisor (SOS) individually to express his full support and define his expectations.to the Operations crews.
lie is conveying that the SOS has complete authority for onshift activities and management support of conservative decisionmaking relative to these activities. These meetings also provide both an opportunity for the Plant Manager to receive feedback on improvement initiatives and an opportunity to assess the management skills of the SOSs. This level of involvement is similarly expected to reinforce management expectations and awareness of performance.
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- l In summary, accomplishments and improvements in the Operations organization have been achieved over the past year.
Performance improvements in ownership, communications, teamwork, control of evolutions, response to transients, start-ups, and cognizance of plant status are being noted in addition to material in;provements in cont rol room panels and annunciators and Operations procedures.
However, at the same time there is clear recognition that many of these areas still require further improvement.
TVA considers that the direction for continued improvement is properly focused and that ongoing initiatives will facilitate achievement of higher levels of performance.
Management oversight and assessment will remain high in this area.
B.
Rhdio. logical _Controla The Radiological Control Program (RADCON) at SQN is very strong and continues to improve. Aggressive initiatives in the areas of personnel exposure reduction and contamination control have resulted in facility and p~ogram changes that prcvide both short-and long-term improvements in employee protection and operational efficiener.
Increased management involvement and attention to the performance of work in the field have resulted in significantly improved worker recognition of the program and will further enhance the control of radiological work and worker protection. A number of achievements over the past year indicate perf ormance at a level above industry norms.
A previous long-term problem experienced at SQN involved noble gas in the auxiliary building and certain enclosed spaces. The primary sources of noble gas have been identified and addressed either by maintenance or modifications of equipment or processes.
These long-term problems are now resolved.
A problem area identified early in the assessment period was high dose experienced during the Unit 1 Cycle 4 refueling outage. The high dose was due in part to a direct by-product of the magnitude of the outage efforts. However, detailed assessment and effective corrective measures resulted in a 21 percent dose reduction during the Unit 2 Cycle 4 outage and that further strengthened the proficiency of the entire SQN site in minimizing radiological dose. The dose for fiscal year 1991 through April 30, 1991, is 399 man-rem, including 50 outage days, and is expected to be less than 480 man-rem for the entirt fiscal year.
In the areas of personnel contamination and contamination control, significant improvements have been made during the past year. Aggressive contaminated area reduction efforts have resulted in the decontamination of areas previously classified as nonreclaimabic areas. The contaminated area has been reduced to 5.4 percent of the radiologically controlled area. This aggressive approach to
'ination control was applied during the Unit 2 Cycle 4 outage witn excellent results. Outage personnti contaminations in the Unit 2 Cycle 4 outage were reduced by 20 percent, and the use of respiratory protection equipment was reduced by approximately 40 percent. Nonoutage personnel contaminations now average less than 4 per month; down from 13 per month before March 1990.
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In summary, performance in the RADCON area over the past year has been achieved at very high levels; and ongoing performance and initiatives are considered to reflect an industry best program and implementation.
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C.
Nucleat_ Engineering _INE)
The NE department has continued over the past year to demonstrate improvements in timeliness of preoutage engineering releases leading to the successful support of the extensive Cycle 4 refueling outage objectives. While areas for continuing focus have been identified, overall performance over the last year has reflected continued improvement.
NE has concentrated on three principal areas:
(1) significant improvements in hardwate to increase reliability and efficiency implemented in the Cycle 4 refueling outages; (2) improvements in plant support to aid Operations, Maintenance, and Technical Support; and (3) reductions in backlogs. These efforts commanded significant engineering resources and extensive involvement during implementation.
An Operations Support section was established this past year to function as a focal point for plant support and to provide improved engineering support for operational priorities. This action reflects the continued commitment to the improvement of engineering support for plant operational priorities. As an example of support for plant initiatives, a four-part program that consists of clearing abandoned equipment alarms, clearing setpoint initiated nuisance alarms, initiating logic changes, and upgrading the annunciator system has been implemented to reduce lit annunciator windows in the MCR.
These efforts have reduced the number of lit annunciators f rom aoproximately 115 to less than 25 on May 1,1991, and the required engineering is being completed to provide the overall annunciator system upgrade in the Cycle 5 outages.
Ef f orts have been ongoing to work of f the engineering backlogs in stages, and significant progress has been made over the past year. With regard to the reduction of open NE change paper, 440 engineering change notices and/or design change notices and 1,176 field change requests were closed in Fiscal Year 1990. The number of field change requests is particularly significant because it represents changes based on engineering judgement and constituted a 50 percent reduction in this backlog.
Efforts are ongoing to achieve better retrievability and useability of calculations. Also, an improved modification process is being developed to provide increased Operations, Maintenance, and Technical Support involvement on the front end of the design work and to provide a single implementation process for all output.
In summary, continued Fains have occurred in engineering performance over the past year, and the focus of resources and processes within the organization is being appropriately refined to achieve further improvements in the quality and timel.iness of plant support.
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D.
TechnicaLSupport Over the last year the Technical Support organization has continued to develop through expanded program implementation and colidification of the organization. The roles of the organization and system engineers have continued to expand into a lead capacity, initiating plant reliability and availability improvements and driving the resolution of key plant problems and issues. Weaknesses identified in the Reactor Engineering organization have been addressed from personnel, procedural, and programmatic standpoints, with noted progress.
Overall, growth in the Technical Support organization has continued throughout the past year, and efforts are ongoing to promote continued development.
A system engineer walkdown program has been implemented through which regular system walkdowns address key site hardware problems and monitor system condition and performance.
As a product of Technical Support's expanding and lead role, key site problems and issues are being assigned to Technical Support for resolution. This was the case in both of the incident investigations for the Unit 1 main steam check valve failures and the recent failure of the Unit 1 centrifugal charging pump.
System engineers have additionally become more involved in the modification and preventive maintenance (PM) programs, and significant initiatives are being implemented in the trending program.
SSP-6.5,
" Equipment Maintenance History, Trending, and NPRDS Program" was issued.
This new procedure clarifles and simplifies the process for Technical Support evaluation to component failure reports, provides for initiation of a problem evaluation report to address an identified adverse trend, and directs a report to be submitted to QA on a quarterly basis that summarizes the component failure reports received over the previous quarter. System engineers are specifically tasked to determine potential problem equipmen; in their assigned system (s) that is to be trended.
System engineers now receive component failure reports and other related reports on components in the equipment identification system data base whose failure rate exceeds predetermined threshold values.
Significant attention has been focused on the SQN Reactor Engineering section as a result of adverse performance indicators. We are wo; king to achieve an experienced stable group. New personnel have been and are going through an extensive station nuclear engineer training course to establish a broad base of knowledge and expertise in reactor engineering practical applications. While this new staff develops experience, the organization is being augmented with experienced reactor engineers. As part of the overall upgrade and as a result of difficulties recognized coming out of the two Cycle 4 refueling outages, a formalized reactivity control program that includes extensive programmatic and training improvements for both the Reactor Engineering personnel and Operations staff and key program interfacing organizations has been established.
- I A recent review of the Reactor Engineering organization by both TVA and NRC indicates progress is being made, and TVA considers that the actions taken over the past year will significantly improve future performance in this area.
However, strong management oversight will continue to ensure full implementation of ongoing upgrades and monitor demonstrated performance during the upcoming Cycle 5 refueling outages.
E.
Maintenante Performance in this functional area over the past year has been solid, resulting in the achievement of significant improvement in overall plant condition.
Extensive efforts were successfully implemented to support the major Cycle 4 refueling outage activities and significant hardware recovery activities, e.g., main steam check valves and centrifugal charging pump (CCP) failure.
Beyond tbtse activities, efforts have been equally successful in improving the overall plant material condition, housekeeping, hardware reliability, and schedule performance. Additional ongoing initiatives are expected to yield further improvements in ovetall conduct of maintenance and in-plant reliability and availability.
The foreign material exclusion program has been upgraded through the expanded use of barriers.
Previously, unattended work was controlled weekly but is now barricaded to prevent intrusion and tagged with the name and the phone number for the responsible foreman and details concerning the specific activity. Tools and disassembled components are neatly assembled within the barricaded area for resumption of the work activity.
Monitoring of the implementation of this process has indicated good adherence and consistent performance at a higher standard.
Schedule performance improvements have also been significant. Weaknesses had been identified in previous years regarding the ability to develop and meet schedules. The successful Cycle 4 refueling outages clearly demonstrated the ability to effectively schedule and manage a large scope of work. Additionally, nonoutage schedule performance has improved to greater than 90 percent for the last eight weeks and to greater than 85 percent since December 1990. The improved schedule performance has also contributed to reducing the corrective maintenance backlog.
Progress in this area suffered during the extensive Cycle 4 refueling outages, and current process improvements are helping maintain the backlog at a reasonable level. These achievements resulted largely from inproved schedule adherence and continued effort to drive ownership anu responsibility f or clearing the backlog down into the Maintenance organization.
Plant leaks have been reduced by implementing the Electric Power Research Institute packing program, completing space cooler replacements, enhancing the through-wall leakage monitoring program, and upgrading secondary side pumps. Broad activities have been implemented to achieve additional secondary plaat reliability improvements, including the refurbishment of motors greater than 100 horsepower, fine tuning feedwater control components, upgrading heater drain tank controls, establishing a five-year plan, and enhancing pH control through the implementation of morpholine injection.
_7 Additional specific upgrade initiatives include reactor coolant pump seal upgrades, improved ice condenser chiller maintenance and online inspections and cleanings, upgraded inspection program for electrical load centers, and initiatives to improve diesel generator availability. Also, a major plant coatings effort was initiated to improve overall appearance and provide an easily decontaminated work surface.
In summary, performance of the Maintenance organization over the past year has resulted in significant plant material upgrades, numerous hardware reliability and system availability improvements, significant upgrades in plant housekeeping and material condition, effective schedule performance, and an overall elevation in the conduct of maintenance activities.
F.
Entergency_lrepartdneas_.IED Progress in this functional area over the last year is considered to be quite good. The EP program has continued to improve while past weaknesses have been resolved.
The annual graded exercise went very well, with strengths and/or improvements noted in many areas and no NRC violations or exercise weaknesses identified.
Previous problems with event classifications and timeliness of classifications have shown good improvement, and response effectiveness initiatives have been implemented and remain above industry norms in several areas. Controller and observer training exercises have also been enhcnced. The good performance of these individuals was noted during last year's exercise.
A significant improvement for conducting both the drills and the annual exercise is the use of the SQN s!.mulator for scenario implementation.
This removes the distractions of the drill and exercise activities from the MCR operating crews and provides the opportunity to better evaluate player reaction to changing conditions.
Portable mockups have been obtained and are currently being used for drills and exercises. The mockups are transported to plant locations and afford better opportunity tn realistically exercise response teams.
Additional important initiatives include developing and implementing state of the art environmental monitoring vans, irpicmenting the surrogate travel system, installing further conference circuits in the emergency response facilities, and expanding coverage of the prompt notification system sirens.
in summary, progress in EP over the past year has been quite good; the program remains solid and changes indicate aggressiveness in incorporating L
continued enhancements. The graded exercise was considered fully satisfactory and in NRC's words " convincingly demonstrated the capability to protect the public health and safety." Efforts will continue ir. this area to ensure continued achievement of a high level of performance, r
I consistent with industry best.
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Security Over the last year, SQN Site Security has demonstrated solidly improved performance indices in several areas.
Recognizing the vintage and status of the overall current security system hardware, we consider the accomplishments particularly noteworthy. Through aggressive management of the security program and resources, a high level of security capability and effectiveness is leing achieved.
One area where the results cf the efforts are very evident is with regard to manning of compensatory posts.
presently, Site Security has no manned compensatory posts because of maintenance problems.
Failed equipment is now repaired in a more timely manner, which requires less compersatory posting. This trend is even more pronounced during nonoutage periods.
The overall SQN security upgrade project also continues to progress. The design phase is nearing completion, and the construction contract is expected to be awarded near the end of this fiscal year. Modifications are planned for implementation over the next six months to improve near-term intrusion detection system (microwave) performance.
This change will improve the microwave and/or isolation zone terrain and replace stainless steel reflector screens, which are weather sensitive, with a less temperature-sensitive alloy.
TVA expects these efforts to yield a significant reduction in the system errors.
With regard to security degradations and events, SQN experienced no significant security events over the past year and no reportable events throughout the extensive outages, despite th" very large number of outage support personnel.
In the broader area of security force response capability, very aggressive initiatives have been implemented.
SQN Site Security has completed an overall, target hardening effort that includes installing vehicle barriers at all perimeter vehicle gates and other strategic areas. Additionally, all fixed perimeter posts are equipped with response weapons; and additional radios were purchased so that each security officer was issued an individual radio. Weapons were upgraded in a variety of areas to provide more reliable and superior accuracy and/or firepower. A firearms enhancement program has improved the performance of officers with the lowest weapons scores by requiring additional training and qualification.
In summary, the SQN security program has noteably improved and developed over the last year. Through aggressive management of the security program and resources, a high level of security capability and effectiveness is being achieved. Material conditions have improved, compensatory posts are more the exception than the routine, and response capabilities are well above industry norms.
System performance is improving and morale is high. This assessment of current SQN security performance was largely echoed by NRC during an inspection conducted in January.
Efforts will continue in this area to ensure that a high level of performance is sustained.
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11. B a[rtylan e s s mentlQual ity_Jerific a thnJ sal 0V.)
A number of activities have been assessed in the area of SA/QV, including 10 CFR 50.59 reviews, incident investigations (IIs), licensee event reports (LERs), violations, posttrip reviews (PTRs), justifications for TS changes, and quality assurance activities. While there are areas that need further improvement, overall performance in the SA/QV area had shown improvement over that experienced in the previous assessment period.
Regulatory and licensing activities have been significant over the past year, and initiatives in the conduct of the Site Quality organization and QA program have been implemented to better focus QA and problem correction activities.
SQN continually focuses on the area of 10 CFR 50.59 reviews. Weaknesses in these reviews had been identified at SQN in the past, and significant programmatic. upgrades were implemented. Audits performed over the past year have indicated positive results following initial implementation and generally continued good performance in this area; however, there is a need for further improvement in documentation.
During late summer and fall of last year, recurring weaknesses were identified in the implementation of the SQN II program. While some IIs had produced very good products, others were clearly lacking.
Extensive actions were taken to address these weaknesses, to strengthen both the overall program and the implementation of the program. Results to date indicate improvement; however, performance is not yet at the desired level. Management focus will continue in this area.
Posttrip reviews comprise a subset of SQN IIs. Concerns had been noted late last year that the basis for the restart decision following the trips was in some cases not being clearly documented. An overall upgrade was implemented, utilizing industry experience and INFO guidelines. The upgraded procedure provides clearer and more detailed instructions for the overall conduct and documentation of posttrip reviews, and the requirements for the restart of either the reactor or turbine are further clarified. Performance utilizing the new process will be evaluated following the next use.
In terms of regulatory at.d/or licensing performance, there have been some noteable accomplishments over the last ; tear and areas that bear f urther improvement. -Significant progress occurred relative to the resolution of
. longstanding and significant regulatory issues, e.g., the implementation of_ Regulatory Guide 1.97 and Control Room Design Review (CRDR) upgrades.
Remaining CRDR modifications (scheduled for the Cycles 5 and 6 outages) are the only Three Mile Island action items that remain open. Additional
-regulatory improvements were also implemented, e.g., automatic closure interlock deletion and Generic Letter 88-17 (reduced reactor coolant system inventory) implementation; and significant postrestart commitments were completed, such as pipe supports, Appendix R, and D/G modifications.
l In balance to these accomplishments, several regulatory issues occurred over the past year that indicated the need for further improvements, e.g.,
site overtime control and Operations performance. TVA will continue co monitor performance in these areas.
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In reviewing LERs over the last year, an approximately 10 percent reduction was achieved over the previous assessment period. While the number dio not meet our goals for improvements, it is noted that a number were attributed to the extensive outage activities. A more significant reduction in NRC violations was noted over this period; however, a severity Level IV violation was received with a civil penalty as a result of overtime control problems.
In summary, there have been noteable achievements; but at the same time, areas for continued improvement exist.
With regard to QA invc1vement and it.itiatives, the focus for QA has changed dramatically over the last year to better focus on the significant areas and increase time in the field. Real-time monitoring and special assessments have increased by more than 50 percent. SQN Site Quality is increasingly focusing on the more significant events and/or problems, especially repetitive errors and root cause and/or contributing factors analysis. Additionally, all major site initiatives are extensively monitored to assess the value of the ccrrective measures taken.
Significant corrective action program improvements have been implemented during this_ assessment period. These improvements will accelerate the corrective action process and increase the line management responsibilities and opportunities to control more of the process, especially for the less significant problems and conditions adverse to quality (CAQs). Additionally, the process allows better mansgement focus on the truly significant issues.
Efforts have continued in reducing the number of open CAQs. Although the rate of closure is not yet at the desired level, the focus on the timely completion of corrective actions will remain an overall site goal.
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