ML20083C227
| ML20083C227 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/18/1991 |
| From: | Joshua Wilson TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9109260097 | |
| Download: ML20083C227 (20) | |
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A Ja; L w Captember 18, 1991 U.S. Nuclear Regulatory Commission ATTN:
Dccument Control Desk Wa s nin g t et., D.C.
20555 Gent leme '
Se Ma t t e r o f
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Docket Nos. 50-327 ee Valley Authority
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50-328 "c
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9 NUCLEAR PLANT (SQN) UNITS l AND 2 - INSPECTION REPORT s
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-327, 329/91 RESPONSE TO THE 1991 SYSTEMATIC ASSESSMENT OF I.i '" ' ' 7 PERFOR'1ANCE (SALP) 1^
6LP for Sequeyah Units 1 and 2 for the period of March 6,
!990, to June 1, 1991, was issued by NRC on August 8, 1991.
Subsequently, a meeting was held <' the Sequoyah Training Center on August 16, 1991, between NRC and Tt representatives to discuss the SALP report. to this letter provides TVA's response to the SALP report's recommendations including actions and improvements being implemented to address weaknesses.
TVA considers that the 1991 SALP presents an accurate portrayal of a plant striving to achieve excellence.
Performance has demonctrated lon -term progress, but at the same time, areas still require further ir vement.
Successful completion of the Cycle 4 refueling outages was saificant achievement for the site, both in terms of the specific itles and in the demonstrated capabilities of the collective c-ization. The Cycle 3 refueling outages will provide additional tienges to control and execute the outage activities while maintaining nigh standards of personnel performance and effective management controls in areas such as ALARA (as low as reasonably achievable) planning and overtime usage.
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o. 4 2 U.S. Nuclear Regulatory Commission September 18, 1991 As described in the enclosure, efforts are being focused in each of the functional areas to effect further improvements consistent with achievement of excellence in overall operations. Challenges clea ly lie in achievement of continued improvements in such areas as conduct of operations, firo protection program implementation, and Reactor Engineering. Further initiatives are being implemented to improve management effectiveness in instilling high standards of performance in all site personnel through focus on quality and ownership. Ongoing efforts reflect a clear management commitment not only to performance consistent with industry standards but consistent with industry best performers. We consider efforts over the past several years have served to move SQN forward in terms of safety and reliability. Our goal is achievement of sustained excellence in all facets of station operations. As discussed on September 17, 1991, with W. S. Little of your staff, our response.to the 1991 SQN SALP report is being submitted by September 23, 1991, to allow completion of final review and concurrence. If you have any questions concerning this submittal, please telephone me at (615) 843-7001. Very truly yours, TENNESSEE VALLEY AUTHORITY $ tW J . Wilson Enclosure cc (Enclosure): Mr. D. E. LaBarge, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector .Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379 L Mr. B. A. Wilson, Project Chief U.S.~ Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
ENCLOSURE i, TVA SEQUOYAH NUCLEAR PLANT (SQN) RESPONSE TO 1990 SYSTIMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) 1. FUNCTIONAL AR_ eat PLANT OPERATIONS B_0ARD REC 0mENDR IONS: Pressures of schedule may have contributed to events during this period and should be considered during the scheduling of future outages. RES_PONSE TVA concurs with the Board's assessment in this functional area. A discussion of the actions taken ta address the Board's observations follows. A. Outage Schedules and Performance The SALP report indicated that pressures to support schedules were placed on ;he Operations department and that the Operations department used large amounts of overtime without proper evaluation and justification in support of both outages, site management is mindful of the pressures outage schedules can exert on station personnel and has taken several actions since the Cycle 4 outages to promote appropriate nunagement controls and ensure tLat expectations are defined and communicated. Specifically, Operations' management assignments have been restructured for the upcoming Cycle 5 refueling outages. The Operations manager will be a member of the outage management team; however, the Operations superintendent's responsibilities and priorities will remain on the operating unit. This will allow the Operations manager to be directly involved in the decisionmaking process for the outage with the Operations supe:intendent remaining removed from the day-to-day outage schedule pressures and focused on review and approval of activities on the operating unit and assessing readiness to return the outage unit to power. Standards and expectations regarding Operations' performance nave been communicated and reinforced as part of the ongoing Operations' improvements program. A broader sitewide communications campaign has also been implemented to ensure performance expectations, relative to quality and schedule, are understood oy all employees. Y Outage planning has continued to receive close management scrutiny to effect improvements in resource loading, management control, and outage risk management. Corrective actions were taken to ensure proper implementation of the overtime policy. The implementinn procedure was revised to strengthen control for overtime usage and a computerized overtime management program was implemented to control and monitor overtime usage. Operations' shift staffing is being adjusted to ensure adequate coverage for the operating unit, maximize outage support, and minimize overtime usage.
Ji \\ 1 + _a_ L B. Operational Events-The SALP reportLindicated that during the evaluation period, five [ reactor' trips-occurred, two of which were the result of inappropriate Operations department actions. The causes of these and other events included inadequate communication, poor command and control, conducting work without written approved procedures, and inattention to detail. Detailed analysis of Operations' personnel and performance identified common causes for the diminished performance. -Operational standards were vague or were_not defined in some critical areas.-and other standards were not adhered to during the-7 outages. Complacency had developed with regard to standards of executien. These conuitions carried over to plant operations at power and were underlying causes of several operational events. As a result of this analysis. Operations' standards were reviewed and upgraded. A structured communication of these standards was executed with all Operations' personnel. Monitoring and follow-up -initiatives were put into place to ensure that the standards were i understood and practiced. Additionally. 0perations' training-was enhanced to reinforce the standards and the principles of excellence. Initiatives were-taken in the areas'of command and control and communications.- Operations' management. participation was increased in training-conduct and improvement. Additionally, during Week 6 of requalification in 1990, all licensed operators received the Institute of Nuclear Power Operations' Control Room Teamwork Development Training Course. Evidence of_ improvements and-effectiveness of these combined efforts -has been noted over the past several months during control room observations _and with a reduction of operational events. Management's focus to effect operational improvements is part of an-ongoing long-term ef fort. C. Material Condition and Administrative Burdens As noted in the:SALP report,-control room nuisance alarms remained uncorrected until late in-the_ assessment period when aggressive action _wasLtaken to reduce-the number of= alarms.- Material condition- [ of the-annunciator system, combined with administrative burdens' y; placed on--the operating 3crewsi had created = routine ' challenges-to operato'rs' ability to; monitor plant conditions. Significant improvements have been made in the reduction of lit annunciators and-interim _ improvements to the existing annunciator system hardware. -Additional priority and management focus have been applied to' control _ room hardware deficiencies. Improvements in conduct-of_ main control room operations with regard to access' control and refinement to. implementation of operator at the controls-1 ' served to minimize the impact'of. administrative tasks and . operational distractions. Development of tools such as an 3 i
L " Operations 10 Most-Wanted List" will continue to reinforce the control room. leadership role in identifying and establishing- . priorities for upgrading material condition and resolving operational impediments. Management's communication of and focus on operational priorities during plan-of-the-day meetings provide a control room focus to prioritization of plant activities. -The shift operations supervisor (SOS) is clearly defined as the primary customer of all site organizations to better focus staff resources to plant needs. D. Personnel Errors aAs noted in the SALP report, corrective action taken was usually effective in correcting the immediate problem, but had minimal effect on persoanel error rates because root causes were not adequately addressed in some instances. .As previously described, a detailed analysis of Operations' personnel performance was conducted-to better understand the underlying causes of performance weaknesses. Improvement initiatives were implemented to ensure proper understanding of -standards and expectations. Ongoing communications continue to emphasize and reinforce these expectations. Operations ' performance has improved over the past several months with a reduction in 1 personnel-errors. Close attention in this= area vill continue to ensure sustained improvement. An additional improvement in determining the cause of inappropriate personnel performance includes broader implementation of the Human Performance Enhancement System techniques in incident -investigations. Broad sitewide initiatives to improve root cause determinations, reduce-personnel errors, and effect overall improvements in personnel performance are further discussed in Section VII, i E. Fire Protection 1 Ac.noted in the SALP report, TVA identified weaknesses in the site fire protection program. TVA. initiated several special independent reviews of the fire protection program implementation and design, and the results of these-reviews were compiled:and analyzed. A fire protection ' improvement program was then developed basedLon the results of the analysis and is' currently _being expanded to_ fully envelope all related issues and establish long-term milestone schedules. 4 An' interim organization was establis'hed with clearsdelineation of-respons'ibilities to provide augmented supervisory oversight and technical expertise both for day-to-day fire protection activities and broader program improvement initiatives. Fire watch management has been consolidated, and the SOS's responsibilities have been strengthened to ensure fire protection issues are adequately w -v,.,r-- y, -..,. - -,- -r~ y-
. addressed and resolved in a timely manner. The fire foreman's responsibilities have been clarified to ensure ampliance and . consistency. The training of Fire Operations' personnel has been- _ updated-to_ ensure proper conduct of testing. Surveillance procedures and administrative controls are being upgraded to ensure technical sufficiency and programmatic effectiveness The ongoing ? initiative has additionally heightened station personnel's-sensitivity to fire protection issues, including control of transient fire-loads. Management oversight of the improvement program implementation will continue to be maintained at very high levels. Long-term efforts include areas such as upgrades to testing i; methodologies, evaluation and upgrade to design basis documentation, t and coordinated walkdowns to verify in-plant configurations and fire protection system hardware changes. Additionally, the efforts will provide._ critical _ insight to management _for the organization needed to maintain the long-term effectiveness of the SQN fire protection program. II. FUNCTIONAL AREA: RADIOLOGICAL CONTROL RECOMMENDATIONS: -None
RESPONSE
TVA concurs with the Board's appraisal of this functional area. A discussion of the actions taken to address the Board's observations follows. A. ' Management Support of Dose Coals As noted in the SALP report, the site exceeded an unrealistic fiscal year dose goal'in April 1990 and did not clearly reestablish a meaningful: goal to aid in the management of collective dose. TVA recognized deficiencies in the goal-setting process'and implemented a process to support goal. adjustments. The site also 0 implemented a-program of monthly and job specific dose goals that-provides significantly increased involvement in.real-time dose management. This process of goal setting and__ adjustment has_been incorporated into site-procedures. Since the implementation of the. = process in mid-1990, the site has demonstrated aggressive dose management'with_the-result that site. dose goals have been reduced
- and current performance'is well within established goals.
B. ALARA (As Low As Reasonably Achievable) Planning and Outage L Scheduling 4 As noted in the SALP report, the primary causes for the high-collective Unit 1 outage doses were attributed to additional work scope, reduction in the outage schedule, and late arrival for ALARA l-review-of modification packages. These factors also impacted work sequencing, airborne radioactivity controls, and temporary _ shielding . applications. l . =~
. i To improve the ef fectiveness of ALARA Planning and Outage Scheduling, a number of improvements have been implemented to correct these weaknesses. A Radiological Control manager has been assigned to the outage scheduling team. Major outage activities were identified in June and any scope growth after June required approval from the site vice president. ALARA reviews of modification packages have been completed. ALARA engineers are assigned outage projects in advance, which enables them to incorporate ALARA initiatives into the scheduling process, evaluate worker time in the area, perform effective mock-up training, and institute engineering centrols to reduce contamination and the use of respiratory devices. Radiological Control has developed and implemented standardized outage temporary shielding packages. An aggressive shielding plan has been developed and incorporated in the outage.cheduling process. Approximately 200,000 pounds of temporary shielding will be installed in the Unit 1 Cycle 3 outage, including the installation of a reactor head shield. An ongoing critique of ALARA planning reports has been implemented in which jobs and lessons learned from those jobs are reviewed and applicable corrective measures are implemented. C. Elements of the ALABA Program As noted in the SALP report, the ALARA program was found to not include several key elements. Among those items identified in need of improvement were establishment of collective goals, implementation of a comprehensive source term reduction program, and overall awareness of station standards. As previously indicated, the ALARA program now consists of a goal-setting and adjustment process to ensure that goals remain meaningful and provide a useful management tool. In March 1991, a comprehensive source term reduction action plan, which contained several short-and long-term initiatives, was approved for the site. A number of actions that include replacing Inconel grid straps in the fuel assemblies with Zircaloj 4, " hot spot" identification and removal program, contamination area and leak reduction, and improved primary coolant chemistry control are underway. Site procedures have been revised to provide more guidance and enhanced ALARA engineering coverage for entries inside the lower containment crane wall at power.
. Contract incentives for ALARA performance are being utilized in vendor contracts. The ALARA staff will continue to meet with supervisors and workers that are brought in for outages to reinforce the station ALARA standards. D. A1 ARA Training The SALP report noted that during the assessment period, two dose reduction training programs, advanced radiation worker and ALARA training for design engineers, were cancelled. These courses were cancelled because TVA determined that they provide marginal benefit. Dose reduction awareness is instilled through job-specific mock-up training. Scated mock-ups are performed at the Watts Bar Nuclear Plant when applicaale, and the Surrogate Tour system is also being used to familiarize workers with the work area. Also a practical factors module for training of craft personnel is currently under development. Additionally, design engineers have been recently provided ALARA retraining and initial training as appropriate. E. Radioactive Effluent Monitoring The SALP report noted that during the assessment period, two radiation eftluent monitors were inoperable for greater than 30 consecutive days. However, the licensee's compensatory measure for all inoperable monitors was adequate and the overall program was effective. The inoperable flow instrumentation discussed in the report was replaced in January 1991 and equipment returned to operable status. Increased management attention is being provided to monitor performance. III. FUNCTIONAL AREA: 51AINTENANCE/ SURVEILLANCE BOARD RECOMMENDATIONS: None
RESPONSE
TVA concurs with the Board's appraisal of this f unctionni area. A description of corrective actions already taken or planned to address the key issues follows. A. Predictive Maintenance Program The SALP repo'rt indicated that only a limited predictive maintenance program had been implemented.
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- A' predictive maintenance (PDM) improvement plan had been initiated-to enhance the SQN maintenance program.
The overall PDM program-objectives are to improve plcnt safety and reliability by detecting and correcting equipment degradation to prevent failure, reduce maintenance costs by eliminating or minimizing unnecessary preventive maintenance' activity. and resolve weaknesses'within the maintenance program. The base PDM program is expanding thr applicatiou of vibration analysis, lubricating oil analysis, transformer oil analysia, and ferrography to provide earlier indications of potential equipment problems and diagnose specific failure modes. Infrared thermography and motor current monitoring are being implemented on a limited basis. As knowledge and experience with these processes are utilized, the implementation.will be expsnced if warranted. Efforts are underway to strengthen the total PDM program with the reliability-centered maintenance (RCM) program providing the guiding-focus. B.- Trending and Failure Analysis An area of' concern identified in the SALP report was the need for-more effective implementation of trending and failute_ analysis. A number of efforts are ongoing to strengthen trending and failure analysis capabilities and implementation. Technical Support has implemented reviews of: nuclear plant reliability data system failures. Trending threshold and failure root cause is determined and: corrective action is initiated. Utillzing thc calculation of i the mean time between failures, RCM's personnel are also performing a trend analysis of the failure modes that have occurred since- ~1985. The results from this-calculation are used 1,' determining the . proper preventive task required to minimize _and-prevent _ failure. The RCM program is being applied to.84 systems, with a scheduled completion date of March 1994; to date, reviews for 10 systems have been-ccmpleted. C. Preventive Maintenance (PM) The SALP report noted a weakness concerning.PM program control and 1 deferment of PMs and with. System Engineering's involvement, particularly tne.echnical -justification for deferment. 1 l
I .g_. The PM program has been revised so that PMs are written in a format-similar to that of a work order, which includes breaking down PM-packages into smaller tasks. The' Technical' Support systems engineers.have significantly increased their role in the PM program. The systems engineers determine the need for PMs and request new PMs, as necessary. _ Technical assistance is also. provided by the system engineer in the PM development. In addition, the justification for deferrals of PMs has been strengthened by requiring a technical justification by engineering in accordance with the PDM program. D. Procedure Validation The SALP report identified weaknesses in the-procedure validation program. For maintenance procedures and surveillances, the verification process of confirming and documenting-usability and operational correctness is accomplished through an actual.or-staged performance conducted before approval. This process confirms that correct, c = sufficient, and understandable information is-provided and that information is compatible with responses, hardware, and~ manpower. A procedure and, instruction are " validated" every time it_is used. The completed work package is considered the documentation of this validation. -Concentrating on verification over validation will promulgate required changes prior-to approval. lending itself as a L more prudent-method of conducting business. Furthermore, the procedure change forms nuy be used as' a feedback c'ommunique for recommended enhancements. I E. Housekeeping .The SALP. report _ indicated that occasionally maintenance debris and other material and housekeeping deficiencies existed in various plant spaces during and in-preparation for outages.- SQN has assigned material condition and housekeeping )~ . responsibilities 1for specificiplant areas _to management employees. They are responsible for performing monthly housekeeping inspections-and rating of the area.- These ratings'are posted,-action plans to correct deficiencies are implemented, and these issues are discuss ~d e during POD meetings. Sitewide housekeeping cleanup days are periodically performed, which additionally serves to instill-a sense .of plant ownership in_all personnel. Plant housekeeping and material condition will remain a top priority. 4 i -n-. - - ~ ~. +.
1 + 3. -j -9 F. Procurement of Routino Material The_SALP report' indicated that slow procurement-of routine materials and equipment continues to result in a,large number of maintenance items on material hold status. ? To improve procurement items, Materials and Procurement has coordinated establishment of more than 30 blanket purchase agreements with vendors from whom TVA frequently procures materials-and-equipment. This change will allow the site to deal directly with vendors, bypassing the bid solicitation and contract award process. In addition, a single individual in. Materials and Procurement has been assigned the responsibility for all material restraint work requests. The percentage of corrective maintenance work requesta on nuterial restraint has been reduced from 14 percent in May-1991-to 10.5 percent at the end of August 1991. The corporate materials organization is developing an enhanced computer system for materials that will include automated procurement functions. C. Procedural Adequacy The SALP report indicated that two instances occurred where
- technical specification operability was affected by surveillance instruction technical adequacy
-In the-cited occurrence involving-theidiesel generator test ~ ~ procedure, acceptance criteria had not been updated although the revised-acceptance criteria had been identified and were utilized in evaluating test data. Additionally, the procedure format was found to-be difficult to follow from a human performance perspective. SQN has an ongoing procedure enhancement program to make procedures consistent with the writer's guide format and. user-friendly. The -majority of the operational and maintenance-procedures has-been completed, and the' remaining procedures are being revised as'part of the ongoing procedure. upgrade program. As discussed in Section D, procedures also undergo verification and validation to ensure usability and'to identify weaknesses. s In the cited occurrence involving testing of the reactor protection system : personnel performed procedural steps out of sequence and failed to appropriately stop the activity when the condition wasi realized. Aspects of both of the cited occurrences involved some. weakness in personnel accountability and' responsibility for the identification and resolution of problems. - Focus in this area is .being emphasized as part of ongoing s! forts to improve personnel ~ performance. Additional' details of these efforts are provided in Section'VII.
k.. !!.~ Security _ Maintenance The SALP report noted that continued attention to maintaining ' reliability of security equipment.is important. I Maintenance will continue to work closely in cooperation with Site Security's management to ensure that implementationHof security equipment work requests receives high priority. IV.; FUNCTIONAL AREA: EMERGENCY PREPAREDNFSS 3 BOARD RECOMMENDATIONS: None
RESPONSE
TVA agrees with the Board's assessment of this functional area. It-is recognized that the initiatives must continue to-naintain high standards of-performance. Efforts over the next SALP period will continue to focus on emergency response center staffing ccpability; promoting consistent, accurate, and timely ~ classification of events by operating crews; implementing-procedure enhancements; providing effective training; and providing effective plan-implementation. IV. FUNCTIONAL AREA: SECURITY BOARD RECOMMENDATION: The Boardenoted the~ improved-reliability of security equipment, which i reduced-the-use of-compensatory measures. Continued attention to this area _is particularly important during the transition to the-upgraded. security system. RESPONSE-TVA-agrees'with the Board's assessment of this-functional area and recognizes that efforts-that improved equipment reliability and performance must continue. 6. Progress continues on the security. upgrade project. This project will ll replace the= security computer system, upgrade the protected area perimeter and-alarm system, and replace guard = towers _with closed-circuit-televisions; and ainew protected area access: control' portal will be installed. Design and procurement of the rystem are at the 80 percent review phase with design' completion expected by September 30,-1991.- The current schedule for completion of the security; upgrade project isL _ March-31 -1993. L TVA$will continue the_ programs that resulted in improvements in security L force skill, training, motivation, and-morale. Results from ls -self-assessments, program audits, and program monitoring and trending will be utilized to: identify areas for improvement. I L l. .-.m sm.- ,... ~.. _ _. _.._,__,.-_
~ . V1. FUNCTIONAL AREA: ENGINEERING / TECHNICAL SUPPORT BOARD RECOSNENDATIONS: None
RESPONSE
TVA agrees with the Loard's assessment for this functional area. >1anagement attention to strengthen areas noted as weaknesses will continue. A. Calculation Errors and Design Document Discrepancies t The SALP report indicated that some calculations were not as definitive or complete as expected. A training session on i preparing, checking, and independently verifying calculations will be conducted with each discipline to enhance Nuclear Engineering (NE) personnel's awareness of the potential problems. These sessions will be completed by October 15, 1991. B. Reactor Engineering As noted in the SALP report, several errors were made by reactor engineers in calibrating nuclear instrumentation. Actions taat have been completed to improve the reactor engineering program include comprehensive training for the reactor engineers conducted by Westinghouse Electric Corporation, participation in start-up testing programs at other sites, and development of a comprehensive reactivity management program. Other actions that are still in progress include optimization and human engineering of the reactor engineering procedures, staff augmentation by experienced engineers, and independent review of the start-up process for the Cycle 5 refueling outages. Focus on performance and improvement initiatives in Reactor Engineering will continue. C. Shin Steam Check Valve Failures The SALP report pointed out an exception to the generslly, technically adequate nature of plant modification packages. This exception occurred for the modifications to the main steam check valves. The site engineering nanager has conducted communications sessions with the engineering groups to em hasize management's e expectations .o questior, assumptions and to have a deliberate and rigorous apprcach to problem solving. These sessions pointed out recent lessons learned as examples where attention to detail and rigorous problem solving could have prevented the problems. Actions have been taken to heighten sensitivity of NE's personnel to the potential for similar interactions and the impact that implementation processes may have on a design. Emphasis was given to ensuring that when relying on vendor concurrence. the basis for that concurrence is cletrly understood. In addition, training has been provided to dealgn engineers on the utilization of vendor information in developing design output.
.. - - - -. ~. - - - - - - -. -. ~ - -. -. - - -.. c 3.: i o, D.- Technical Support Training and. Qualification The SALP report indicated that Technical Support did not have a formalized' training and qualification program. Technical Support-has developed a systems engineering certification' program. This _ program is comprised of traininh in plant systems and components and technical and administrative subjects. The certification process requires written and oral examinations _as well as a practical factors demonstration. Engineer certification under this program will be an ongoing effort over the next SALP period. As a further follow-up to improve technical quality and expertise, additional after-hours systems training is being made available to NE's personnel,_ including some of the contractor personnel that support engineering. VII. FUNCTIONAL AREA: SAFETY ASSESS $1ENT/ QUALITY VERIFICATION BOARD RECOMMENDATIONS: None
RESPONSE
TVA agrees with the Board's assessment-for this functional area. Weaknesses were noted in several_ areas that require continued management's attention. A'. Management Effectiveness and Personnel Performance The SALP report indicated that problems' occurred involving attention to detail, following written procedures,' implementation of effective management p-ogram, and critical self-assessment by station line-management. A key site goal is to change the approach to_ problem identification -and resolution and implementation of program initiatives. Emphasis is being placed on achievement of. accurate root cause determinations, including full identification of corrective actions necessary to correct identified problems and prevent recurrence; middle-level management ownership and accountability for problem resotution and implementation of_ programmatic solutions; and institutionalized processes for assessing ' effectiveness of corrective actions and initiatives. The incident investigation system at SQN has been upgraded to include a plant evaluation review panel review of draft incident investigation reports. This panel is chaired by the plant manager -and_ consists of key site managers, the investigation team, and individuals = involved in - the event (at'all levels) to ensure-that a full understanding of the event and the event implications is achieved and that appropriate corrective actions ar6 initiated. L
- This process provides assurance that all significant aspects of an event are recognized by management early_in the investigation and that proper corrective actions'were established that correct the root and underlying causes of the occurrence. This process ensures that all parties understand the conclusions of the investigation and l- --.
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- r .s - : n provides an excellent forum for the plant manager to coach personnel and communicate expectations. Each event investigation is discussed daily in the plan-of-the-day meeting to ensure appropriate focus and progress. Significant_ emphasis is being directed to enhance the effectiveness of-first-line supervisors and middle-level managers in identifying ,= and correcting problems. SQN is providing each supervisor -specialir.ed developmental training to enhance supervisory, problem resolution, and teamwork skills. A comprehensive action plan has been developed to improve overall middle-management effectiveness by focusing-on expectations, attention to detail, oversight, communications, and teamwork. Communications-meetings with all site principal and middle-level managers are now being routinely conducted by the site vice president and plant manager to reinforce standards and expectations regarding quality and ownership and to clearly communicate near-term focus and objectives. These meetings alsc_rmphasize the identification of areas for improvement. Collectively, these initiatives are intended to improve management effectivenesa in instilling high standards of performance in all site personnel through focus on quality and ownership, increased involvement in the field, and identification and resolution of impediments to_ quality performance. B. -10 CFR 50.59 Reviews and Regulatory Responses The SALP report stated that the 10 CFR 50.59 reviews were generally adequate but were frequently lacking in documented detail or technical basis. A review of the 50.59 audit results of ?!A's Nuclear Manager's Review Group indicated that afrelatively small number of. safety assessments warranted documentstion changes. These safety assessments were appropriately revised. As assessment of the program indicated that the primary cause of-insufficient [information was inattention to detail. The findings of the review have been_ discussed with appropriate 50.59 preparers and reviewers. Additionally, a-formalized feedback procesc is being -developed to assist management.in effectively communicating and enforcing standards and expectations. Ownership and responsibility for the SQN'10 -CFR 50.59-process have ,been recently transferred to SQN Site Licensing. Site Licensing will be evaluating technical training needs and formalizing feedback mechanisms as part of the continuing 50.59 performance improvement- ~ initiatives. The SALP report-also noted several examples where the usually high-quality results were -not attained in TVA's reviews or respons'es to regulatory issues. The collective review of the noted weaknesses indicates a lack of proper attention to detail in performance of ) associated technical reviews. The above-described initiatives to improve personnel performance and attention to detail are expected to similarly yield further imptovements and depth to performance of -technical reviews and responses to regulatory correspondence. L}}