ML20114A664

920619 Self-Assessment. Several Hardware & Software Enhancements to Emergency Response Ctrs Completed During Reporting Period

ML20114A664
Person / Time
Site:	Sequoyah
Issue date:	08/15/1992
From:	TENNESSEE VALLEY AUTHORITY
To:
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ML20114A663	List: ML20114A661 ML20114A664
References
NUDOCS 9208200044
Download: ML20114A664 (42)

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s ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 JUNE 2, 1991 - JUNE 19, 1992 SELF-ASSESSMENT

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E I. FUNCTIONAL ARCA - PLANT OPERATIONS [

r tinior Accormlishmenty A'_though several events have re;ently occurred involving the Operations organization, there have bean numerous major accomplishments in this functional area during this assessment n

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peH ,d. Plant performance is perhaps the foremost indicator of nec y plant operation, btn also overall performance at SQN. A grapoic indicator of this performance is the plant's availability. Unit 2 completed the longest run, '06 days, ever ,

experienced at a TVA nuclear plant. Also, during the assessment 5 period, both units ran simultanec sly for over 200 days. These accomplishmencs are attributed to many factors, including an -

offective, preventive maintenance program and operator action -

during numerous transients to avoin lost generation. g Additionally, there have been few automatic scrams from power during the assessment period. Unit 1 experienced twa such I events, and Unit 2 had three. All five of the scrams were induced by equiprent failures. Unlike the last assessment period, none of the unplanned scrams during the carrent -

assessment pericd were due to personnel errors. Although the five trips were due to equipment failure, none could be traced to a lack o? maintenance or poor-maintenance practices. This -

reflects a heightened emphasis on perforraance expectations in the control room and during training.

Although noted improvements in personnel performance have been -

achieved during the assessment period, there huvo been weaknesses

[ identified (n.c- reactor coolar.t system (RCS) flow and containment spray suction valves), Nhich are being addressed in the Operations Improvement Plan. TVA recognizes that improvement in this area is necessary and is striving for effective and timely realization of that goal.

Nevertheless, there have been numerous instances in which SQN operators have taken timely and effective actions in respcnse to transients. For example, a Unit 2 reactor trip occurred near tha end of core life, Typically, other plants would have chosen to enter the refueling outage early rather than attempt the  :

difficult zero Boron start-up at end of life. Keeping in mind the increased emphasis on reactivity management, the need for safety, the large volume of water to be processed, and changing reactor poisons, TVA was able to confidently and successfully implement procedures ensuring 6 safe start-up. .

In the previous Systematic Assessment of Licensee Performance (SALP) report, the Board indicated a need for bettet management control over outage activities, such as complex evolutions,

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personnel overtime, and organizational structure. During the assessment period, TVA implemented measures that have' effectively-

' heightened the degree of Operations' management control over outages. The improvements described below were implemented, first, during the Unit 1 Cycle.5 (U1CS) refuuling outage and, as a result of lessons learned, later refined for use during the Unit 2 Cycle 5 (U2C5) ref ueling outage. .The success of those improvements is evidenced by the U2C5 outage, the first at a TVA nuclear plant to be completed ahead of schedule.

Improvements in organizational structure played a key role during the U2C5 outage and resulted in heightened Operation 3 awareness of overall plant activities and management control of outage activities. Specifically, Operations was organized so as to-prevent Unit 2 outage activities from interfering with and adversely affecting operation ot Unit 1. This was accomplished by instituting separate Operations organizations Aasponsible for i the operating and outage units.- The effectiveness of this dual organizational structure was demonstrated when, shortly after entering into the Unit 2 outage, a problem was discovered with the Unit 2 ice condenser doors. Unit 1 immediately was examined, the same problem was identified, Unit I was shut down, and TVA 3 made the necessary repairs. Throughout this process, the Units 1 and 2 Operations organizations were able to separate and control ongoing. activities on both-units in an officient and effective manner.

The nature of management oversight was further' refined after the UICS shutdown in order to bring about more afficient outage control. Specifica23y, day-to-day managerial accountability was driven to lower levels of the organizational structure while  ;

general oversight responsibilities wera retained in senior management. This division of responsibility enabled TVA to more effectively control UCC5 outage activities, as evidenced by the timely completion of the outage,

r. Control over Opt rations' personnel overtime also improved during the ascessment period. An earlier inspection report included a violation for exceeding overtime limits en numerous occasions without proper authorization. Corrective acticns taken by TVA included revisions to controlling procedures, reviews by site personnel of procedural and technical specification requiremente, quality assurance (QA) audits, and Site Vice President review of-all' overtime-limitation exceptions. Tne standard thresholds

,defini ng the' amount of overtime allowable for Operations' E

personnel have1been established and implemented during the

- assessment period. These thresholds cannot be exceeded without l' the approval of Operaticns' management and the Duty Plant Manager. Other' overtime controls included. implementation of a computer program that assists in tracking each individual's overtime. NRC reviewed the implementation of these meesures and closed the issue with no further violations identified in this I area.

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Prior to the U2C5 outage, quality action teams (QATs) were formed to address areas identified by the outage management team as vital to outage success. These teams were drawn from a cross section of site organizations and consisted primarily of nonmanagement personnel. One of the most successful recommendations of the QATs was publication of a daily U2( ;

Outage Updato Report. This single page document quickly summarized in an easy to read format, the immediate critical path, outstanding performances by individuals or groups in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and items of common interest. It also provided a graphic summary of actual performance, such as ALARA (as low as l[ reasonably achievable) goals for the outage.

Another outgrowth of the QATs was implementation of customized sp0R outage presentations to each working level group onsite, -

4Ef3 including backshifts, Each discipline group in Maintenance received its own presentation. In the past, outage presentations lf7h agi focused on management and supervisory personnel who were, in h turn, expected to carry information hack to the working level.

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,o To reinforce ownership, over 75 tasks were identified and owners 3Rjh assigned. All of tnese tasks were published and distributed to 3" naintain visibility throughout the outage. A contract form explaining the meaning of task ownership was distributed,and task owners in each group were asked to return a signed contract accepting ownersnip of their items.

During the assessment period, TVA has made a concerted effort to upgrade risk control, as well as establish and maintain a heightened awareness of shutdown risks during outages. For instance, prior to commencement of the UICS outage, Operations preparad an vnalysis of the outage schedule in order to identify activities involving risk. Identified activities were then scheduled, in a coordinated fashion, so as not to compound existing risks. In this manner, TVA protected key systems during the outage, a time when many backup systems are out of service.

Another example of risk management involves midloop operations, specifically, fuel was off-loaded before going to midloop operation. Even though time was added to the outage schedule, these atops were effective to reduce midloop risk.

A third example involves switchyard controls. TVA takes measures, during midloop operations and other critical periods, to protect against electrical interruptions and disturbances of shutdown cooling systems. These include standing orders requiring that at least two barriers be maintained to protect

-forced core flow during residual heat removal (RHR) operation.

This means that simultanaous work is not allowed on: (1) one RHR pump and the cpposite train diesel generator (D/G), (2) one RHR pump and the switchyard, and (3) one D/G and the switchyard, In addition, work could not be authorized if it would cause less 3

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i than two of the barriers listed above to be maintained without  ;

permission from the operations _ Superintendent, the Operations Manager, or.the Plant-Manager.  !

The innage schedulo-also contributes to risk management during planned outagen. ~It identifies the systems and components that 4  ; are in service and need to be protected from being out of

-service.

The Work Control Manager prepares forced outage schedules for unit power reduction, Mode 3 inmediate restart, Mode 3. minimum work, and Mode 5 minimum work schedules. A forced outage schedule is produced for each unit on a weekly basis and retained by the Operations Shift Outage Manager in the Work Control area.

Should one of the units trip, the Shift Outage-Manager utilizes the schedule to-immediately begin notifying appropriate personnel

-to begin approved work activities.

In March 1992, the' Forced Outage Recovery Team was organized Uithin-Operations to facilitato a unit's recovery to a full-power condition-from a forced outage or downpower event. The team's primary responsibility is to ensure that each approved, forced coutage activity is-implemented in a tirely manner and that appropriate resources are utilized-to return the unir to full-power condition without impacting or degrading Operations or Maintenance on the opposite unit. The Forced Outage Recouery Team' monitors each activity and, through aggressive interaction, anticipates potential delays-and develops alternate methods and plans to minimize their effect. In addition, reactor / turbine trip investigation Teams A and B are procedurally identified to obtain a quick, thorough investigation in such an event. The Forced Outage Recovery Team has been successfully utilized in all ,

three Unit l' forced-outages during 1992. The establishment of two teams allows not only full, 24-hour coverage but also clean separation of investigation from recovery activities. Upon activation, the team remains in existence until it is disbanded by the Duty Plant Manager or the unit returns to full power. Any problems detected.by the team-during a forced outage that cannot

'be resolved by the team are immediately communicated by the team leader-to senior plant management. This le"el of management

- attention, in turn, ensures satisfactory reeolution of unresolved items.

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.The forced outage recovery team assists the Work Control supervisor in finalizing-the forced outage schedule. This is discussed-in more detail in Section III, " Functional Area -

Maintenance / Surveillance." The team also participates in a L periodic review of thefforced outage schedule to ensure that all l  : items are appropriately scheduled and planned and that material 1sistaged and available to the greatest extent possible. The l

team leader ensures that team members are familiar with each approved work order, preventive maintenance (PM), and 4

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L surveillance instruction (SI) to be performed during a forced .

L outage so as to identify and eliminate potential conflicts.

During the assessment period, TVA took actions to improve control '

room performance, for instance, the installation of the control room annunciator modification. This is a computer-based, digital,.two-train system that provides improved capability to print out historical events. Previous assessments identified large numbers of " lit" annunciators. A concerted effort was made to reduce the number of lit annunciators in the Units 1 and 2 horseshoe areas, as well as on the common boards. The-result is no lit annunciators in either horseshoe area and only a minimal number of annunciators lit on the common board.

Changes made to the work control process have renulted in l improved control room performance. Charts and trends, as opposed to lists, are now being used to identify and report on degraded equipment in scheduled management meetings. Furthermore, in May 1992, TVA implemented improvements in procedurea to improve operator response to alarms, In March 1992, TVA implemented the complex, infrequently performed, tests or evolutions (CIPTE) process. The process estanlishes specific management controls and responsibilities to ensure that preservation of the plant's margin of safety remains the highest priority during the conduct of complex, infrequently performed tests or evolutions. This goal is achieved, in part, through procedures designed to ensure review of test activities by technically qualified individuals, availability of work-control documents governing the installation-and verification of special test equipment, and the operator's and test personnel's understanding of expected equipment responses and procedure applications. The latter is accomplished,_when feasible, by trials on the plant simulator.

The CIPTE-. process also provides senior management review and .

oversight of relevant tests and evolutions. For instance, the ,

process requires approval by the Plant Operating Review Committee -

(PORC) of new or revised complex procedures. A thorough initial pretest briefing is conducted during which the Duty Plant Manager briefs Operations' personnel on management expectations'for the activity. Finally, unexpected problems or difficulties encountered'during testing must either be resolved or escalated to a management level with autnority-to effect a solution before

-continuation of testing.

Management-invo'lvement in and oversight of the CIPTE-procesc

.cnsure that caution and conservatism _are exercised during test

= performance, especially when test personnel encounter uncertainties. Another result is that personnel remain focused on maintaining.the highest margins of safety, especially when a sense of urgency might otherwise prevail because of schedule or 5

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.1 delays. The process also ensures adequate training of test Eparticipants, maintenance of clear lines of-communication, responsibility during all phases of testing (including.

preparation, performance, and review), and the availability of adequate technical support.

In May 1992, SQN issued an upgraded version of the emergency operating instruct <2ns (EOIs) and their associated support documentation. To further improve control room performance, the

, upgraded EOIs were prepared in accordance with the Westinghouse Owners Group-(WOG) Emergency Response Guidelines (ERG). Operator input was actively sought and incorporated in drafting the upgrade. In addition, comprehensive verification and validation were performed by representatives from appropriate disciplines.

Numerous improvements have been realized as a result. For instance, the Procedures Generation Package was upgraded and reformatted for easier use. Numerous technical deviations from the ERGS were eliminated. EOI setpoints were reverified and validated. A plant specific analysis was performed to provide criteria for emergency core cooling flow reduction during a small break loss of coolant accident (LOCA). TVA also developed and issued a plant specific EDI User's Guide.

Permission from the onshift operating crew is now required for entry into the central control area. - In addition, the operating <

crew As allotted one hour at the beginning of each shift for shift turnover. During this time, the control room is off-limits to non-Operations personnel. No work authorizations, issuance or release of_ clearances, or discussion with Operations' personnel is allowed during this one-hour timeframe. These actions allow ,

SQN operatore to dedicate their time to conducting quality turnovers. During the U2C5 outago, a senior reactor operator (SRO)_was dedicated to Unit 2 for the sole purpose of authorizing work.- This allows the unit SRO to dedicate his time to supervision of control room activity.

As a result of the nearly= completed HED-effort, TVA has enhanced input-and output control of information for reactor operators, as well as reduced the number of human-hardware interface errors.

In addition to the normal 1 shift turnover -(i.e., completing control board status periodic instructions [PIs], reviewing the log, and discussing significant problems), all control room

-operators-are required to perfo:rm-a detailed board walkdown with

-their-relief. The purpose in doing so is to-discuss abnormal or off-normal alignments of components and log the content of such p discussions in the operator journal.

Several "next level down" communication efforts have been

. undertaken to improve the-communication-of management expectations. For instance, the Operations Manager and 1 6' o

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e b-Suparintendent have met with Operations' personnel to reinforce

the need_for. rigorous attention to_all processes. Assistant shift operations. supervisors (ASOss) have been tasked to define existing problems, offer solutions, and maintain responsibility foritheir implementation. An Operations Advisory Committee, consisting of elected menbers from all levels in Operations, has been' established to facilitate consistent behavior and resolution of Operations' concerns at all levela.

The primary. benefit resulting fre .hese efforts has been the ASOSs' assumption of rccponsibli_.y and the shift operators' increased accountability. Other benefits include assignment of a dedicated configuration centrol unit operator, a complete rewrite of the work authorization procedure, improvement in control room appearance (including operator uniforms) , and enhanced test briefings.

In November-1991, TVA implemented the shift operations supervisors (SOS) training pregram. The purpose of the program is to ensure that the selection, training and qualification, and continuing _ development of SOSs provide the mix of technical and managerial skills necessary to safely and efficiently direct SQN

. operations in normal'and emergency situations. TVA is one of.ths first utilities to have.its SOS qualification program accredited

-.by the Institute of Nuclear Power Operations (INPO).

In fact, numerous Operations training programs were reaccredited as of January 30, 1992. They include programs addressing Nonlicensed Operator 1 Training, Reactor Operator Training, Senior Reactor Operator Training, and Licensed Operator Continuing Training. In' addition,:the shift technical advisor program and the1 shift supervisor program were reaccredited in January 1992.

The importance of reaccreditation is its inherent recognition of a systematic, ordered, andfuniform approach to Operations'

. training activitiesfan SQN.

-During this assessment period, there have been major accomplishments involving-fire protection. Specif.ically, Phase I

of the Fire Protection Improvement Plan.at SQN was completed on May 14, 1992. The.overall_. plan is comprised of four phases and-is expected to be fully implemented by December 1994. As part of the Phase I effort, TVA completed an evaluation of fire

% -suppression; system hydraulic performance. This evaluation

-involved development of a computer model of system performance,

_ including the degradation factor expected over_a full 40-year license term. The latter analysis, as demonstrated by testing, concluded that thel system would perform its intended function throughout the life of the plant.

Other elements of the Phase I effort include upgraded training and increased management oversight. For instance, an interim organization has been-established to implement required 7

improvements and manage day-to-day fire protection activities.

Additionally, both position-specific and genera) employee training have resulted in an increased ewareness of fire protection requirements and individual responsibilities.

Fire protection procedures also have been reviewed in order to identify technical inadequacies and prioritize necessary revisionse Procedures identified as being deficient have been removed from use or compensatory measures have been established pending completion of any necessary revisions to fire protection procedures. TVA has strengthened administrative controls over transient fire loads, fire watch management, and performance and review of surveillance activities. For instance, the Fire Protection foremen's responsibilities have been clarified to ensure compliance with procedural and administrative controls _

over surveillance activities.

As part of the Phase I effort, TVA developed a plan to address fire hazards analysis update and penetration seal documentation.

Walkdowns to perform the required evaluation are scheduled to begin this month, and the output documents will be issued during Phase III of the improvement plan. Additionally, fire barrier walls were confirmed functional and the sprinkler system was compared with applicable procedures and drawings to verify the installation.

Overall, Phase I efforts resulted in program stabilization and resolution of immediate areas of concern. A clear organizational direction has been established and more personnel and management attention has been devoted to fire protection activities. During the assessment period, significant improvement in fire-protection-related performance has been demcnstrated by a s ostantial reduction in the number of fire protection licensee event reports (LERs) and special reports. -

Areas _f_or Future _ Focus As part of the Operations improvement efforts, it is intended that communications to and response from the SOS /ASOS teams will improve. This will result in a more systematic approach for shift turnover, strengthening operator practices, such as communications, profesaionalism, and procedural compliance. SQN SROs will be expoced to top industry performers via site visits to learn firsthand how best performers operate. As part of the ASOS improvement process, the configuration control process is being revised. The goal is to implement a more rigorous process, such as those employed by industry leaders.

During the assessment period, TVA implemented the initial phases of a plan to further improve assistant unit operator (AUO) performance at SQN. Additional improvements are ongoing and more 8

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fully described below. For instance, TVA raised AUO training expectations by incorporating job performance measures into AUO

-training.

TVA also established comprehensive annual requhlification exams for AUOs. These exams are given on a weekly basis during requalification training with a comprehensive exa.n at the end of the training. PIs also have been issued on AUO routines.

Finally, TVA has implemented a monitoring plan in order to increase management involvement with AUOs.

As part of the current Operations improvement plan, Operations has identified a need to provide a method to efficiently handle the vast amount of information control room operators are required to process on a daily basis. Thus, during the upcoming _

assessment period, TVA intends to implement a user-friendly, multi tank computer network that will provide Operations personnel, and other TVA organizations, better access to this

)) information.

several goals.

This multi-phase effort is meant to accomplish For instance, rather than continue the current practice of installing single-use terminals in the main control room (MCR), the system would provide multi-task workstationa integrating and simplifying Operations' administrative processes.

This would includo, for example, the integration of hand-held personal computers used by AUOs on their rounds with a data base residing in the MCR.

As part of the Fire Protection improvement plan, organization ,

stability was of utmost significance. An outline of the permanent organization has been established, and the selection of the Fire protection Manager is being finalized.

By the end of 1992, TVA expects to refurbish the shift clerk's office, redesigning it into an ASOS work area. The purpose in doing so is to move work administration activities outside the MCR, so as to minimize their impact on conduct of operations.

II. FUNCTIONAL AREA - RADIOLOGICAL CONTROLS liajor Accomplishments Throughout the assessment period, TVA has instituted various '

measures to improve the ALARA program at SQN. In December 1991, the SQP Radiological Control (Radcon) ALARA group began to review design changes during the developmental phase to ensure that the

. proposed design incorporates ALARA concepts such as maintenance and operations, shiclding, source-term reduction, contamination control, and implementation. Additionally, workplans are reviewed by the group, prior to implementation, to ensure incorporation of the ALARA concept. Both measures avoid reactive decision making.

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x In Februaryfl992, TVA completed implementation of the Radiation Exposure System _(REXS),-a computerized radiation exposure tracking system. The REXS computer program integrated four different software systems into a real-time radiological information system that contains pertinent radiological information.

broad areas: ' .REXS is a system (1) personnel that encompasses information,- the following (2) radiation work permits,_ (3) ALARA tracking and trending, (4) radiological surveys,' (5) equipment issue and return, and (6) equipment inventory.

In September 1991, TVA significantly enhanced remote monitoring accuracy and capabilities at SQN through the use of electronic dosimeters. These devices can be installed in plant areas or worn by individuals and, thereby, enable remote monitoring and

. trending of dose. In sum,_they provide-a very accurate means of measuring dose on a job-by-job basis, improved worker

.information, and'the capability for remote monitoring of both workers and plant areas.

In-process reviews of jobs are performed to maintain dose ALARA.

Work tasks having a' projected dose of great 9r than one person-rom receive formal reviews by the ALARA staff with feedback provided daily to the work supervisor and documented when the dose accrued on the job reaches 25, 50, and 75 percent of the estimated dose.

The success of these__ measures and increased management attention were demonstrated during the U2C5 outage, during which the exposure dose goal was achieved for all.of the major work activities. Overall, the U2C5 outage dose of 380 perscn-rom was significantly under the 450 person-ren goal'and represents contiauing best-ever performance in all major work areas.

Additional enhancements to the SQN ALARA program include the Daily Employee Information Bulletin and daily tracking and reporting of-personnel dose information, both implemented in February.1992, as well as thelALARA. hotline, established in March

! ~1992. During U2CS, ALARA information on major outage jobs and

.cVerall-outage ALARA-~ performance was included on the outage status boards and on the front page of the outage status sheets, which were discussed at the beginning of_each shift. These

_ initiatives provided the' emphasis and sensitivity to dose minimization and control that were necessary for a very successful outage. These initiatives provide SQN personnel with dose information, both on an individual and site-wide basis, in a clear and concise manner, either by telephone or in user-friendly graphs.

L l TVA implemented an incentive plan to further improve outage dose l- performance at SQN. The plan has two elements, one applicable to p ' employees and the other to contractors. The employee plan L 10 l

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1 provides administrative leave as in incentive for outage performance exceeding preestablished ALARA goals. The contractor plan works on the same principle, offering monetary incentives in place of administrative leave.

As a result of vendor performance problems during the U1C5 outage, TVA adopted an ALARA team approach to the Westinghouse Steam Generator Shotpeen Project. In essence, TVA engaged in a cooperative effort with Westinghouse Electric Corporation to ALARA engineer steam generator shotpeen equipment and process.

The benefits resulting from this team arrangement were significant improvements in ALARA design and equipment reliability. This process involved hands-on participation in the de.2 ig n , modification, and testing of the shotpoening equipment enhancements. The changes included implementation of integral shielding. It also improved personnel access and minimized Raccon and other support. The end result was essentially an industry best performance (36.6 Rem) for the shotpeen project.

Given these benefits, TVA has implemented long-term cooperative agreements for ALARA support with Westinghouse in other areaa (e.g., steam generator maintenance and refueling).

Long-term performance trends have improved at SQN during the assessment period. These include steam generator maintenance and nozzle dam dose rates, shielding dose trends, and refueling dose trendse In all these areas, the continuing improvement has e achieved SQN best-ever performance and established new benchmarks for future planning.

TVA is in the process of implementing a comorehensive, long-term, source-reduction program at SQN. This multi-faceted effort involves changes to engineering design criteria in order to preclude use of high-Cobalt components, as well as implementation of a non-Stellite policy. Radcon/ALARA review of all design -

changes ensures the implementation of the policies to the extent practical.

The basic method for primary chemistry control and cleanup changed during the Cycle 5 outages. The new method was proposed to make the RCS moderately acidic for an extended period of time to cause possible oxide layers in the RCS piping and steam generator inlet / outlet plenum to go into solution. The new method was followed by the traditional Hfh addition to remove CO-58 from within the core. The early boration of the reactor coolant system in Mode 3 produced the desired acidic-reducing phase. Maintaining the acid-reducing state for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> resulted in the desired removal of Cobalt 58 from out-of-core areas.

Approximately 1100 Curies were estimated removed from the RCS.

Coordinated chemistry control for shutdown and implementation of primary coolant elevated pH has significantly reduced radiation 11

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i levels experienced as a result of plannad shutdown activities

. undertaken during the assessment period.- Specifically, the

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target exposure.during the U2C5 outage was approximately 450 men-rem. Actual exposure was significantly lower than the target, approximately 380 man-rem. Coordinated chemistry control also resu.lted in reductions in personal contamination. The target for persunal contaminations, established prior to the outages, was 120. The actual number of personal contaminations  ;

was 75. j During the Cycle 5 outages, SQN also has implemented improved cleanliness criteria for valvo maintenance. These criteria are designed to reduce the introduction of particles into the RCS i from maintenance activities and, thereby, achieve further reductions in source term. A Cobalt valve " hit list" has been compiled by Radcon. - This prioritized list is a key element of the. process for removing. Cobalt valves from the plant. In-conjunction with this effort, TVA has focused on the procurement of low-Cobalt valves and components and installed low Cobalt-check' valves in RHR.

-SQN has completed gamma spectroscopy characterization of both units in order to identify major dose contributors. The results offthis ongoing effort are trended so as to determine the effectiveness of source-term r duction efforts on a long-term basis. - Finally, sub-micron filters have been installed in the

'RCS to remove particles from-the RCS and thus prevent their activation and contribution'to plant' radiation levels.

During the last two Cycle 5 outages, TVA has implemented several contamination control measures. These include implementation of scheduled decontamination cleanups of containment prior to shutdown; improved-C+ zone exit procedures to reduce personal contaminations; application of improved', strippable coatings for

. purposes-of cavity decontamination; and implementation of cloth bags and-absorbent mats to inhibit' transportation of hot particles across boundarier After the U2C5 refueling outage, a decontamination plan was developed and aggressively pursued. The plan included initiation of corrective measures to repair leaking valves: and equipment and application of now floor coatings. As a r- , result, the total contaminated area snis reduced to less than-4.1 percent. With continued emphasis on corrective measures and- ,

y aggressive decontanination, contaminated-square footage will be L 'further reduced.

Effective hot particle-controls were also impicmented. Continued

-emphasis on contaminated area controls has resulted in a significant reduction in the use of respiratory protective equipment, which improves work efficiency and minimizes dose. A worker information handbook summarizing Radcon practices and requir ments designed to prevent personnel contamination has upgraced work practices. These improvemencs have resulted in a t 12 i

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' reduced .1 umber of-personal contaminations at SQN during the  ;

assessment period.

During the assessment period, the initiatives taken in solving

-radwaste reduction issues have proven very effective. Improved volume. reduction techniques have significantly reduced radwaste burial volume. More importantly, however, the implementation of initiatives ta reduce volume generation has resulted in a continued downward trend in radwaste volume. Improvements such as utilizaticn of reusable laundry items and control of materials entering the radiologically controlled area have resulted in an approximate 50 percent reduction in generated radwaste when-comparing the two cycle 5 outages.

Areas for Future Focus While many program improvements have been implemented, there are still several areas where additional emphasis must be placed in order to achieve the desired level of performance. In the area

! of plant housekeeping, additional attention is required to obtain l an acceptable level of individual worker responsibility and I ownership for his/her work area. A major effort is currently underway to restore plant coatings. This will greatly improve plant appearance and permit further area decontamination.

Improvements in performance will also be achieved through the continuance of team training. This.provides a mechanism to build good radiological control practices into maintenance activities, L

rather than have radiological controls as an add-on. Through this training, expectations are communicated and practiced in -

many of the areas, which result in a well-executed and documented job. {

Further attention must also be given to every aspect of dose reduction. . Management support for thorough-inspection of fuel to ensure-that no leakers are reinserted into the-core during reload is a significant' element of-the overall dose reduction plan.

Both units are currently operating with no leaking fuel. Dose-for-cleanup;and area maintenance during outages will be reduced i with improvement in. tool and materials control. The increased emphasis on individual responsibility and ownership of work areas will also contribute to success in this area.

To date, the plant contaminated area has been reduced to less

than 4.11 percent of the radiologically controlled area. With the restoration of plant coatings, implementation of charging pump L -spray shield, and' continuation of aggressive contamination o -efforts, the plant contaminated area will be minimized.

L Over'the past two refueling cycles, SQN has made nany needed improvements in the plant. Some of these required significant 13

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investment in resources and dose to accomplish. These major projects, such as' resistance temperature detector (RTD) and upper-head injection (UHI) removal, were significant ALARA challenges. The benefits-of these initiatives are being realized through continuing improvement in all activities that contribute i to plant dose, _ Although the last outage represented record D o performance in essentially all areas, plans for future outages are currently being reviewed to achieve even better performance.

The succous of these long-term plans is greatly dependent on the effective implementation of current source-term reduction initiatives in the area of system decontamination and stellite reduction. TVA intends for SQN to_become an industry leader in this area.

JFinally, while SQN's primary chemistry is among the industry best, the continuing improvement of our program in this area F depends upon the upgrade of chemistry process instrumentation.

This will receive significantly increased management attention and support during the coming year.

III. FUNCTIONAL AREA - MAINTENANCE / SURVEILLANCE Major Accomplishments TVA:made significant progress during the assessment period in reducing the backlog of maintenance items at SQN. . In particular, the nonoutage maintenance backlog was reduced from approximately 1,560 items'to abcut-1,260. _Throughout the assessment period, the noncutage corrective maintenance bacxlog was maintained well below the INPO median. Material-restrained work orders were i reduced!from approximately 14 percent to 9 percent.

TVA continues to. focus management attention on backlog reduction measures. This is_ accomplished, in part, through formal quarterly reviews of all work orders _ greater than 90 days old.

In addition, there are scheduled weekly reviews of backlog reduction-efforts within Maintenance, as well as a weekly review of the maintenance backlog at the Flant Manager's meeting.

. Aggressive backlog goals have been established _at the section level and are given considerable management; attention. This attention wi-111 continue throughout-the coming assessment period.

TVA_ implemented controls over PM deferrals in October 1990. In sum,=these controls require-that PM tasks be performed within an established frequency and indicate-that they cannot be deferred

-unless'reviewe and approved by Engineering. The latter must

. include a technical-justification (based on Engineering's judgment), operating -history, work order history, and runtime, for deferring or. canceling mandatory PM tasks. In addition, there are signature requirements for all deferrals.

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4 The SQN Maintenance organization enhanced its preventive maintenance program through initial implementation of a reliability centered maintenance (RCM) program in January 1991.

Work continued to proceed on schedule throughout the assessment period. The RCM program, which utilizes personal c)mputer-based software, is a programmatic approach to the development and optimization of plant maintenance. The objective is to establish maintenance programs that safely and economically maintain plant equipment.

The scope of the RCM program is broad, encompassing 84 systems.

To date, work on approximately 17 systems has been completed at SQN, with an additional. seven systems in either the review or approval cycle. Accomplishments of the Sequoyah RCM, to date, include resolution of a control air compressor seal installation problem through procedure revision and craft training, improved PM schedule coordination for the chemical volume and control system, and improved consistency between Units 1 and 2 PMs.

Ultimately, TVA intends to integrate RCM with failure trending, root cause analysis, and craft feedback. Doing so will ensure a superior program from the standpoint of safety and reliability, f Throughout the assessment period, TVA has made a concentrated effort to improve the work planning process at SQN. For instance, in April 1990, SQN installed and implemented maintenance planning and control (MPAC) computer software. MPAC +

was subsequently upgraded in November 1991, with improved software streamlining the work order planning process. This software upgrade also added text editing and work ordet history retrieval capabilities.

One of the primary benefits of the upgrade is a reduction in the amount of time a job is in the planning prot ss. As a result, work orders are more quickly delivered to craft personnel.

Additionally , MPAC now provides f or live-time monitoring of each maintenance werk item, including on-screen review of work steps.

Routine monitoring of constraints to work, timely responses to problems, and elimination of separate work orders for support are some of the many beneficial byproducts of MPAC.

i Another improvement in the work planning process at SQN involves 9 the initiation of initial planner training and qualification in June 1992. The purpose of this training is to develop the

} ability of Maintenance planners to effectively and efficiently plan maintenance activities in a manner that ensures plant -

safety. It is applicable to all Maintenance planners at SQN.  ;

The Maintenance planner training program is designed to function as both a preparatory program for new planners and a developmental program for incumbent planners. It serves to enhance technical expertise, efficiency, judgment, motivation, and professionalism. Individual courses in the program ad6ress 15 l

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- - - - - _ - - - _ - _ _ - - - _ . - . _ . _ _ - - - - - _ _ _ _ . _ _ - - - _ - _ _ _ _ _ _ _ - _ - - - _ _ _ _ . - - _ _ _ _ _ - _ _ . _ _ _ _ _ - - - _ - _ - - - - _ _ - _ - - - _ - - - _ _ - - _ _ _ _ - - - - _ _ - - -D

~. -~ . - - - ~ , . -. _.

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initial, continuing, and specialized training requirements. The latter two elements are provided to improve planner performance on an ongoing basis at SQN.

TVA recognizes that one of the-most significant areas of importance in overall Maintenance performance is contr-1 of the-nonpermanent workforce. During the assessment period, several

• measures have been implemented at the plaut to improve the level of such control. Foremost among these is the-site' Maintenance management directive establishing and defining contractor controls. -Implemented in February 1992, it provides direction on nonpermanent craft duties.

In addition,.most of the nonpermanent workforce is contracted through a single source: Bechtel Construction Company. TVA works closely with Bechtel to ensure that personnel assigned to SQN are not only technically competent but also knowledgeable of administrative requirements, such as configuration control. All nonpermanent craft personnel attend a Maintenance-specific arientation session. There is a single point of contact for all Maintenance contractors. Finally, only annual craft personnel may perform verification activities.

During.this assessment period, TVA started a multi-phase program to train 26. entry-level = Electrical, Instrument and Controls (I&C), and Mechanical Maintenance craftsmen. The initial training phase is at the Sequoyah Training Center. It includes both formal classroom and laboratory training in basic skills and knowledge in the applicable Maintenance craft.

Initial training is divided into four classroom and laboratory phases ard concludes at the plant site. After each classroom / laboratory session, trainees are assigned to the plant for hands-on training activities implementing the knowledge and skills conveyed at the training' center. Trainees are assigned to the plant.for the remaining portion of their initial training

'after the fourth: classroom / laboratory session.

During the plant portion of initial training, trainees are required to-participate in on-the-job training (OJT). Once they demonstrate their proficiency-in core tasks, trainees are evaluated for: purposes of task qualification. Trainees are promoted to journeyman once they have completed-the initial training phase and passed-a comprehensive oral examination.

Feedback on trainee performance and course content is provided to the. joint training subcommittee and Maintenance managers by instructors, foremen, general foremen, co-workers, and site managers. Ten electrical trainees are scheduled to complete Phase IV of their initial training in August 1992, and will then

.begin the-plant portion of OJT. On May 11, 1992, six I&C

.trai: 3G began Phase III of-their initial training. Finally, an 16

additional ten mechanical trainees began Phase III of their training on May 18, 1992. The two latter groups are scheduled to complete their training in October 1992.

The Maintenance Professional Recognition Program was initiated in January 1991. At that time, an award was made to one Maintenance craftsman per quarter. Quarterly award winners were then eligible for the annual award. Awards were made on the basis of safety, pride, teamwork, performance, positive attitude, and ,

effective communication. Employees, rather than TVA management, select the award winners. -

In July 1991, TVA modified the program. Although the award criteria have not changed, quarterly awards are now made to one deserving person in each of the four groups within the -

Maintenance organization: Electrical, Instrumentation, Mechanical, and Support. A single annual award winner continues to be chosen from the pool of craftsmen recognized on a quarterly basis. TVA believes that this program helps SQN satisfy the Maintenance Professional Code by publicizing commendable individual work values at the site.

In 1988, SQN developed and implemented a forced outage schedule, j Continued implementation and upgrades to the schedule have I transpired throughout the assessment period. The Work Control Group (WCG) Manager prepares forced outage schedules for unit power reductions, Mode 3 immediate restart, Mode 3 minimum work, and Mode 5 minimum work schedules. Forced outage schedules consider mandatory testing for escalating modes from the condition the unit is in through power operation, work that has a high potential to place the unit at risk if the work were performed online, work on systems or components that cannot be safely isolated online or that reduce the depth of safety systems below that acceptable by regulation of management requirements, <

and items identified by plant supervision and approved by the Plant Manager as requiring action at the earliest offline opportunity.

The WCG Manager makes all reasonable efforts to ensure that items added to the forced outage schedule are authorized, planning is complete, materials and equipment are available for use (including prestaging if practical) , and only those items necessary to support restart and sustain unit operation until the next refueling outage are included on the schedule.

Additionally, the WCG Manager maintains a list of potential work items and indicates the r lative priority of each. Should a forced cutage or power reduction occur, the WCG Manager develops an actual, daily forced outage schedule based upon plant conditions.

Implementation of the forced outage schedule requires significant preplanning and coordination between TVA's WCG, Outage Planning, 17

- Operations, Maintenance, and Engineering organizations. It also reduces outage time. Furthermore, this scheduling method has proven to be an invaluable tool to ensure that outage-related work is performed efficiently and safely.

To further refine the forced outage schedule, TVA performs critiques on each outage or shutdown in which the schedule is used. Critique results provide continued enhancement and improvement of the forced outage schedule. In March 1992, the '

forced outage schedule was enhanced through implementation of the newly approved NUMARC guidelines to reduce shutdown risk, as well as in-house procedural upgrades designed to ensure project coordination.

.The predictive PM program at SQN is the diagnostic element of the ,

overall Preventive Maintenance Program. Predictive monitoring is used to ensure that equipment is operating properly, diagnose problems, and schedule maintenancc. Predictive maintenance is performed by several groups, all within and outside of the 6 Maintenance organization. Within the Maintenance organization, the predictive group is responsible for such tasks as vibration analysis, oil analysis, acoustical and infrared monitoring, and thermography. The primary purpose of these activities is to 1 identify problems before they occur and determine the most effective type of maintenance to prevent tuture failure of plant components and systems.

The Predictive Maintenance Program has been inplemented in an efficient and effective manner throughout the assessment period.

-For example, a core group of machines, which operate continuously and are important to safety or power production, is monitored for vibration on a monthly basis. Oil samples are collected regularly, depending on component function. Acoustical monitoring is used in periodic monitoring of valves and check I valves.

The Predictive Maintenance Program has been successful. For instance,-in July 1991, Reliability Centered Maintenance recommended vibration analysis to ensure-bearing condition on one of.the control rod drive moter-generator sets. A vibration analysis was performed, identifying above normal vibration. As a result, an urgent work request was issued, and the bearings were replaced. Predictive maintenance activities analyzing the oil for the turbine-driven auxiliary feedwater pump identified lubrication contamination. -Following replacement of the oil, foaming was successfully eliminated.

There have been numerous other accomplishments by the SQN Maintenance organization worthy of note in this summary. They include the Maintenance benchmarking effort, U2C5 refueling outage performance, control room blackboard efforts, and daily schedule performance. In addition, there were no Maintenance 18

l personnel-induced reactor trips during the assessment period.

The SQN Maintenance organization also successfully coordinated diesel generator outages, provided incident investigation and coordinated Maintenance support, and engaged in Maintenance team training. Goals and performance indicators are positive, the Electrical Power Research Institute (EPRI) packing program is proceeding on schedule, and the in-service record of control room instruments continues to improve.

Areas for Future Fo_c_us The Maintenance organization continues to strive for further improvement in its performance. For instance, as a result of an event associated with control of a jumpers, site-wide training was conducted. The training was presented through the use of a videotape developed by the Sequoyah Training Center, providing examples on configuration control practices. Following the video presentation, tailgate sessions were performed to discuss specific areas, including proper verification techniques. These practices were also reinforced in team training provided to craft personnel. SQN also initiated a new policy allowing only annual craft personnel to perform verifications in Maintenance.

Although training has been completed, additional focus on -

verification is required.

During the investigation of an event associated with an inflatable pipe plug found in the reactor coolant system, deficiencies were revealed in the foreign material exclusion (FME) program. To correct the deficiencies, a review of other industry FME programs was conducted. As a result, the SQN FME procedure is being revised to incorporate information from these programs to provide a more user-friendly procedure that promotes better understanding of individual responsibilities and FME -

control mechanisms necessary for minimizing intrusion of foreign material.

The SON Training department is currently developing videotape training modules that will provide basic introduction to the topic of FME and the importance of good housekeeping and, also, a training module that will be used to train and qualify personnel as FME monitors to assist in the implementation of the procedure.

TVA recognizes that the material condition of the plant must be improved. Areas for improvement include secondary system leaks and ground water inleakage (particularly in the balance of plant (BOP) area), earlier reinstallation of insulation removed during outages, and repair of degraded flocr coatings in the auxiliary building. In addition, numerous temporary leak repairs to plant 7 systems and equipment, many being repeat repairs, must be addressed.

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In June 992, SQN implemented a major recoating effort and during the next assessment period will undertake additional measurec to improve the material condition of SQN. In addition, increased management attention will be focused on holding the nonnuclear plant to standards as stringent as those applicable in the reactor plant. The history of system leaks will be reviewed in order to evaluate the need for long-term repairs potentially requiring design changes. In addition, TVA expects to continue preventive measures for system leakage, such as EPPT packing installation.

The current labeling program backlog stands at approximately 7,548 items. Throughout the coming assessment period, TVA will continue to undertake actions to reduce the backlog in this area.

Maintenance is obtaining additional resources to assist in this _

task. A site standard practice has been approved for the labeling program. It incorporates guidelines from INPO Good Practice 88-009. In conjunction with this effort, Engineering is working to resolve labeling discrepancies on drawings.

During the assessment period, the administrative error rate for SI documentation deficiencies was determined to be high. As a result, nanagement discussed the issue with appropriate personnel and identified necessary performance improvements. Continued performance monitoring at the crew level has proven to be effective. To ensure continued improvement in this area, a Quality Action Team was formed to continue to monitor the effectiveness and determine additional corrective actions, if warranted.

In mid-1991, Browns Ferry Nuclear Plant initiated a project in response to an NRC commitment to investigate and install a screening and evaluation process for Maintenance supervisors similar to the one successfully implemented by Philadelphia Electric Company at Peach Bottom. Recognizing the project's success, TVA elected to implement similar programs at SQN and Watts Bar Nuclear Plant and began pursuing a similar supervisor development training program.

Tbs program, which is being piloted in Maintenance and will be ,

evaluated for implementation in other site organizations, consists of six weeks of training: four offsite and two at the training center. Training concentrates on team building, project management, speaking and writing skills, problem solving, supervisory skills, regulatory requirements, and technical skills. A week of training is devoted to Kepner-Tregoe analytical troubleshooting. The first class at SQN is scheduled to begin this summer, and the final training session is scheduled to be completed in the fall of 1993, following the Unit 1 Cycle 6 refueling outage.

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k This type-of_ training educates SQN. personnel, fosters teamwork, tandLinstills a sense-of ownership and responsibility throughout the organization. Approximately 100 SQN Maintenance supervisors, along with selected planners, engineers, and Maintenance training employees, are-included in the scope of the program.

Although improvements in recent personnel performance have been noted,_there have been several events associated with personnel performance. Controls over and development of subordinates have been established, which include accountability at the crew level.

Team training has also been provided to encourage team building.

On-the-job observation and peer program improvements are planned to promote ownership and accountability at lower levels.

- A Maintenance Functional Review Team was established to evaluate key maintenance processes at six selected nuclear plants. The team was compriced of four TVA Maintenance Managers, a corporate Maintenance Manager, and two craft representatives. Beiore visiting the other plants, the team was trained in IBM benchmarking techniques. Currently, five plants have been visited with one remaining plant to be visited thin month. From this evaluation, recommendations for specific improvements and initiatives will be made. QATs will be formed to address -/

implementation of the recommendations scheduled for completion ]

this fall.

IV. FUNCTIONAL AREA - ENGINEERING / TECHNICAL SUPPORT L Maior Accomplishm_eDis During this assessment period, there have been numerous major I accomplishments. For instance, there have been several improvements in outage support as a result of Engineering and Technical Support initiatives. During the UICS and U2C5 outages,

- there was no lost schedule time because of the unavailability of materials for outage design packages. This is attributed to

--joint review and concurrence by Engineering and Modifications, at 80 percent design, for materials requirements. Materials were tracked from initiation of purch.no request through use by Modifications personnel in_ weekly materials meetings. After Modifications reviewed workplans, Engineering was responsible for final-signoff,and review of design change notice (DCN) materials

-for the. outage. _These improvements in teamwork and organizational interfaces helped correct historical material

, unavailability problems and allowed the organizations to focus on K day-to-day concernse Engineer and contractor system training also contributed to improved outage-support at SQN. Engineering participated in a plant systems' training course during fiscal year (FY) 1991.

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Approximately 25 personnel, including contractors, attended the course.

Technical training was'provided to Engineering personnel on

-technical issues pertaining-to-Appendix R and 10 CFR 50.59 requirements. In addition, selected personnel were trained in root cause analysis and'Kepner-Tregoe analysis. Finally,

.porsonnel. development courses were offered as part of the Total QLality-Management Program. Each of the above training initiatives contributed to improved outage-performance at SQN during the assessment period.

Another indication of improved outage support at SQN is the approximate 70 percent reduction in field DCNs (PDCNs) during the assessment period. Specifically, the number of FDCNs was reduced from approximately 848,_during the UICS outage, to roughly 271 during.U2CS. This reduction is attributed, in part, to the incorporation of.Jessons learned from UICS into 12 Unit 2 design packages. Modifications and Engineering personnel also screened

'FDCNs and provided fieldLassistance during-the U2C5 outage.

Contractor field support was limited to a. maximum of approximatelyR20 percent overtime. Timely and accurate

• Engineering support enabled SQN Modifications to-meet schedule and quality goals.

Among the many plant improvements are the early implementation of the annunciator system upgrades and removal of nuisance alarms.

In June 1991, following an event involving failure to acknowledge an alarming window, TVA committed to implement the system upgrades during Cycle 6 for each unit. Nevertheless, TVA successfully.pursucd an aggressive design and procurement schedule and implemented the commitment for each unit during

-Cycle 5.

Another major accomplishment is the-improvement to the auxiliary feedwater system-(AFW)11n the recirculation.~ ode. Prior to the Cycle 5_ outages, there-was high vibration in che AFW-system because of' low-flow induced pump pulsations and vibration.

During the Cycle S refueling outages,-the recirculation capability of the motor-driven AFW pumps was increased. Design objectives included meeting the accident; analysis flow, reducing vibration-induced wear on pumps and other system components (including' valves and hangers), and providing more controllable steady-state flow and low demand flows. The improved recirculation flow capability is approximately six times the original fixed orifice constant bleedoff-design.

In-the past, SQN has experienced numerous leaks in pressurizer safety valves. This situation was remedied Garing the assessment period when Engineering'and corporate Maintenance worked with the

. vendor to improve the valve trim, an initiative that has taken '

SQN to-the leading edge of existing technology. As a result, 22 i

-t Ileak-testing acceptance critoria have been upgraded to 95 percent of setpoint,:the installed valves are exhibiting excellent performance, and other utilities are monitoring the SQN solution for possible' application at other plants.

.SQN also:has a program underway to successfully. implement Gener'c Letter '(GL) 89-10, " Safety-Relatea Motor-operated Valve

-Testina and arveillance." This effort was initiated at SQN, however, cren prior to issuance of the GL. Ownership of the 89-10' motor-operated valve (MOV) program lies with Engineering, who has dedicated an organization that supports program implementation and controls the project schedule and budget through a'well-structured project management process.

-Specialized training is provided for Engineering and Maintenance personnel responsible for MOV maintenance and testing.

Aggressive corrective action and preventivo maintenance programs are in place.

Additionally, there is a strong interface between TVA and the industry on'GL 89-10. Teamwork between SQN, other TVA plants, and corporate personnel in the development an? implementation of the MOV. program has led to the successful re ;1ution of problems

-and issues to date. -For instance, a corporate project manager f has been assigned to ensure that GL 89-10 program requirements j are_ met. Corporate Engineering has developed and issued design-standards identifying the methodology to be utilized in performing. design reviews and calculations, and periodic steering committee meetings are conducted to keep TVA management informed of program status.

Approximately 278 MOVs are included in the scope of the GL 89-10

-program. 1N) date, SQN has completed roughly 78 calculation packages,-approximately 73 MOVs have been set up (by static test) .

to new requirements, more than 35 MOVs have been tested under differential pressure conditions with acceptable results, and

-nearly 20 MOVs were identified'as requiring minor modifications, which were implemented prior to testing. The program was

-inspected.bylNRC Region II in August 1991. Identified " concerns" were minor and several " strengths" were identified, including the MOV engineer's and the MOV coordinator's knowledge of the issues in the GL, the MOV coordinator's knowledge in the use of the basic diagnostic test equipment.- Also noted was the recognition that the standard industry equation and value factors are not totally adequate and the selection and application of alternatives, and the location of Engineering staff onsite.

During-the assessment period, TVA has continued to reduce

-backlogs pertinent to this functional area. There has been a net

. reduction'of roughly 60 open conditions adverse to-quality (CAQs) documents.- Approximately 42 percent-of CAQ documents closed (i.e.,-about 87 ofta total of 206) were " backlog" items. Backlog refers to'CAQ documents initiated prior to February 15, 1991.

23

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Open significant backlog CAQ documents have been reduced to ten documents. Close to 700 engineering change notice (ECN)/DCN packages have been closed since June 1991, reducing the number of open ECN/DCN packages to 168. The completion of the backlog is scheduled for June 1993.

Finally, TVA continues to work off setpoint and scaling documents (SSDs) at SQN. During the current assessment period, 26 volumes of controlled SSD manuals have been issued in accordance with Site Standard Practice ( S S P) -9 .1, " Control and Setpoints." These manuals contain both as-designed and as-constructed SSDs, which are updated as part of the DCN closure process. TVA recognizes the importance of backlog reduction at SQN and will continue to implement measures designed to do so during the coming assessment period. _

Several programmatic /special inspections, specifically related to engineering design, have been conducted during the assessment period. No violations were identified as a result. The inspections included Regulatory Guide 1.97, electrical Distribution System Functio 7ai qspection (EDSFI) follow-up, GL 89-10 (MOV Program), cpe.ational Safety Team Inspection, Electrical Review, and an Engineering / Technical Support ,

inspection. Only one current performance violation was identified during this period by the resident inspectors. This violatJ on was associated with the annunciator upgrade modification which, as previously mentioned, was performed a fuel cycle earlier than originally scheduled.

Throughout the assessment period, the SQN Technical Support group continued to improve the support it prov for maintenance and operational activities. For instance, ma. y .ent has increased its emphasis on the use of trending by system engineers as a -

proactive means to prevent problems. Trending has been employed, -

for example, to address RCS leakage, cold leg accumulator inleakage, and condenser air inleakage.

TVA began implementing the Plant Engineering Database System (PEDS) for use by systems engineers. It supplements systems troubleshooting by using the capabilities of the plant process computer to obtain a large cross-section of parameters and thereby allow faster problem resolution. In addition to providing real-time monitoring of plant processes, the PEDS supports reactor trip investigations.

Safety s/ stem unavailability is tracked and evaluated by system engineers. They are fully supported in doing so by Maintenance and Operations. Action plans are initiated on adverse trends.

Another improvement is the System Engineering Certification Program. Established in 1991, it entails eight weeks of classroom / simulator instruction (including practical system walkdowns), required reading, and botn written and oral exams.

24

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_(

e Ownership of system outages was implemented at SQN prior to the U2C5 outago. This improvement enhanced personnel performance during the outage _and allowed for detailed, advance preplanning.

There have been several improvements in Reactor Engineering at SQN during the assessment period. A site fuel integrity assessment program, coordinated by Reactcr Engineering, is in place to prevent, evaluate, and mitigate the consequences of failed fuel. Reactor Engineering has also developed, jssued, and is in the process of fully implementing'a site standard practice on reactivity management, as well as a core-related parameter trending program.- Staffing of Reactor Engineering was improved, in part, through the transfer of a Nuclear Instrumentation System (NIS) . system engineer to Reactor Engineering.

Several training improvements were made. SQN-specific Reactor Enginebring training, presented by Westinghouse, has been successfully completed by the four reactor engineers and the supervisor. Technical Support system training is scheduled for one reactor engineer in the fall of 1992. On-the-job training, technical staff and technical staff manager's training, special toyic training, a seminar, visits to other plants, and development of-a reactor engineer certification program are ongoing or currently scheduled. In addition, low-power physics

. testing training was performed on the simulator for the last two core reload start-ups and is scheduled to be repeated for upcoming core reload start-ups.

Several of the.NRC inspections described previously also focus on Engineering support of the plant and no violations were identified from these inspections. Strengths and improvements were also noted.

Areas for Future Focus Throughout the ensuing assessment period, SON will continue in its' efforts to further reduce the backlog of CAQ documents and-drawing deviations. An improved management report, identifying and tracking ECN/DCN closures, has been initiated. Such closures also have been given higher visibility through their inclusion as a standard item for discussion in the Engineering Manager's weekly status meeting.

The obsolete equipment committee prioritizes equipment for replacement that is no longer being manufactured. Items already

, replaced at SQN include the reactor building floor and equipment l . drain sump level transmitters, steam generator blowdown header I

flow transmitter, and Nos. 3 and 7 heater drain tank level bypass control valves. TVA plans-to replace the No. 3 heater drain tank level control valves during the Cycle 6 outages. Items for which DCNs have been completed, although not yet implemented, include I 25 ,

4-microwave normal and spare battery chargers and thermoverters for main generator watt and var meters.

-Approximately 63 temporary alterations were closed at SQN in 1991. Roughly 33 additional items have been closed to date in

-1992. TVA intends to continue these reduction efforts during the coming assessment period. The goal is to reduce the number to approximately eight by late 1992.

V. FUNCTIONAL AREA - EMERGENCY PREPAREDNESS Maior Accomplishments During the assessment period, TVA completed two very successful graded exercises. Participants were aggressive, realistic, innovative, and worked well as a team. There was excellent leadership and command by-personnel in the Technical Support Center (TSC) and simulator. Personnel accountability was achieved within 30 minutes. The use of mockups for realism and the use of the Operations Support Center (OSC) conference bridge were considered strengths. The exercise critique was considered

a. program strength. Overall emergency response team performance wasEcharacterized by NRC as being "very good," and no violations, deviations, or weaknesses were identified by NRC.

In May 1992, TVA completed implementation of several improv;.ments to'the OSC. The OSC was relocated to a larger facility, about three times larger than the preexisting locale. The larger facility is not only better from a human factors perspective, but also increases the number of communication lines.

A REXS terminal was installed in the-OSC in order to provide timely access to personnel Radcon histories and self-contained breathing apparatus-(SCBA) qualifications. A public address system was also installed in the OSC in' June of this year, further facilitating communications between the emergency facility-and.other response personnel. In addition, TVA installed a surrogate tour system in the OSC for use during damage control and repair team briefings. The system is

. comprised of approximately 105,000 photographs of SQN and allows personnel to engage in a pictorial walkdown prior to entering the plant to perform repairs or other work activities.

During the assessment period, TVA implemented several hardware and software enhancements to emergency response centers at SQN in order to further. improve communications within and between centers. For example, in May-1992, TVA installed FAX machines in the control room and simulator in order to transmit written data to the operations duty specialist (ODS) and Central Emergency Control Center (CECC) in. Chattanooga for notifications. This is 26

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_an improvement,-from both a human factors and accuracy g standpoint, to the preexisting means of oral communication.

In addition,__the CECC VAX computer was upgraded in May 1992,

-increasing its previous capacity. The result has been a significant_ reduction in data processing time necessary, for example, in the use of the safety-parameter display system f(SPDS). -_Another improvement is the installation of a ringdown line between the ODS and the SOS. This dedicated communication line_provides for better transmission of and response to calls

>between the-ODS and the SOS.

Throughout the assessment period, TVA has made a concentrated effort to upgrade the emergency response organization training at SQN. The resulting upgrades touch upon many aspects of performance. For instance, TVA has_ reviewed and upgraded all lesson plans to incorporate lessons learned and ensure plant safety.

An-upgraded-training tracking database has been installed to track all emergency responders' qualifications. Previously, SQN L Emergency Preparedness could not easily track everyone at SQN who received emergency response training. Now, SQN Emergency Preparedness is doing so and can immediately determine whether or not a responder is qualified. In addition, Emergency

. Preparedness ~ developed and implemented a comprehensive emergency responder access list during the assessment period. Thus, in the event of a radiological emergency, the emergency response organization can quickly identify and allow plant access to personnel trained _and qualified to respond to the event.

Emergency Preparedness also assisted in the development and conduct of a containment equipment hatch emergency closure drill

_w ith-the Maintenance organization at SQN in October 1991. This drill,_modeled after an accident at Plant Vogtle, involved a simulated loss of power. Apart from the fact that TVA was able

-to-demonstrate that the-hatch could be closed-in a reasonable amount-of time, hardware problems were-identified and corrected,

and the emeroency response organization realized considerable training-benefits from the exercise.

.In December 1991, TVA conducted a full participation i transportation accident drill with state, county, and local officials. It was the first-time TVA conducted such an exercise and.it was a complete success. Aside from the opportunity for dialogue-and interaction offered by the drill, TVA also came away

-from the exercise with some valuable-lessons learned.

~

For l . instance, it was' discovered that shipping papers were hard to use and did notLfacilitate cargo identification.

-On January 30, 1992, TVA conducted an unannounced off-hours augmentation drill at SQN. The results of the drill were 27 l:

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, satisfactory,:a conclusion echoed in NRC Inspection Report (IR) 92-08 (April-6, 1992). At the present_ time, TVA management

.is considering performing three such drills in order to test all three emergency response teams at SQN. Finally, TVA upgraded training of drill and exercise controllers and evaluators from a 2-_to 4-hour module. This alcaws time for a plant area and mockup walkdown, as well as position-specific training.

TVA's performance in this functional area is greatly enhanced by corporate and-plant management's involvement in emergency preparedness exercises. For example, corporate support of site emergency preparedness activities is provided through monitoring and_ maintaining the Prompt Notification System (PNS), a system comprised of approximately 107 fixed sirens, a computerized data logger, and feedback system. -PNS operability was maintained at approximately 98 pe~ cent during the assessment period.

Additionally, corporate management coordinates a cooperative effort between site and corporate Emergency Preparedness staffs to develop and implement challenging emergency exercise scenarios for graded exercises and dress rehearsals. These scenarios test the organization's capability to satisfy 100 percent of NRC regulatory requirements. -A related effort involves the development and installation of a computer program at SQN to

-generate in-plant Radcon-and Chemistry data for drills.

. Installed in February 1992, the program, which was under development for three years,-provides radiological data in a format usable in drills and exercises and reduces preparation time by about 90 percent.

Corporate Emergency Preparedness management also continues to participate.in periodic site meetings with site management to exchange information, relate lessons learned, and engage in joint problem resolution. These periodic meetings foster an attitude lof cooperation, provide _ additional resources and-perspectives, and improve working relationships. Corporate management also frequently calls on' emergency response personnel from other TVA

, sites to assist in drills at SQN.

During the assessment period, TVA'has focused increased management attention on further improving emergency responue performance during drills and exercises. Some of the improvements implemented as a result of this increased level of i attention,. discussed in-greater detail above, include improved

-data ~ transfer and communications capabilities, the CECU VAX computer upgrade, and various training improvements.

4 TVA has_taken-steps-to increase the sensitivity of SQN personnel to their emergency response responsibilities.- For example, TVA 2

will continue to conduct unannounced off-hour augmentation 6 kills for duty teams. Prior to the assessment period, TVA installed a new Emergency Paging System (EPS) at SQN. EPS is an automated 4- 28 s

3 J

)

ton phono 11no (channel) paging system to be used to automatically  !

pago key personnel in the event of a nuclear omergency. The  !

oystem can be activated from the shift supervisor clerk's offlen in the control room or by the operationu duty upocialist from the .

CECC. l When Eps is activaced, all personnel designated au first responders are paged. Tho system continues to page each person for ono hour or until the pLgo is inswered. On an average, it ,

takes approximately eight minutos to complete all of the pages j and two minutoo for ersonnel to acknowledge the mossage with a tolophone respoaso. In Deconbor 1991, TVA instituted higher- i Jovel management review, by the site Vice President and plant Manager, of cmergency pagor test results. The purpose underlying the latter initic.tive in to footer a greator level of responsibility within the organization.

TVA has taken nescral steps during the aasessment period to '

improve omorgoney proceduros at SQN. T1,2no include detailed testing of Emergonny Response Pacility (ERF) electronic equipment i in August 1991, to ensure operability and availability.

Activation and notification proceduras were upgcaded in May 1992 i '

to onouro accuracy of offsito notifications of stete and local authorition.

In addition, from November 1991 throuch March 1992, the Emerguncy  ;

, Classification Logic at SQN teos reviewed by a QAT, a multi- ,

disciplinary group comprised of individuals from involved sito i organiaations. The purpose of the QAT review was to ensure consistent understanding, training, and implementation of the Emergency Classification Logic at all TVA sites. As a result of thic review, the wording of cortain procedures was clarificd, and .

training was modified to focus on unusual event classifications  !

during simulator training.

In November 1991; the kadiological Accident Code (DAC) was inctalled onsite at SON for uen pending staffing of the CECC. ,

RAC-allows for timely-knowledge of offaite doso. It la a method >

of estimating offri.to dose around the site boundary and_radinses

- of two, five, and ten miles, based on a straight line Gaussian ,

. projection. TSC Radcon managers were. trained in the uuo of RAC to project offsite done.

I h.Ipao far_ Dt.tptLEgan During thi. essment period. TVA will focus on further improvement. . this functional area. For example, TVA is in the proccas of.implomonting an-onorgency response: data system (ERDS)

' at SQii, & scheduled completion date is ir. August 1992. TVA is

= currently c micing NRC approva: for installation of the-phone lic.es.

29

..--.-.--n..---. - _ - . . -. . . . .,,.,,..-.w,.-_.. -,.-,,.,,m,. ,a, - , _ , , . , . , , , .,.w.,,, ,+c.n ...y.,g, ,en..n,.,,.,nvw.w,-w,,-,. ,

4 I

As part of TVA's ongoing commitment to incorporato industry  ;

advances into the Emergency Preparednass program at SON, TVA will 1 be developing revised plant-specific emergency action levels '

.(EaLt) for SQN. Thoca revised EALs will bo based on the NUMARC '

Emergency Action Lovel methodclogy, when approved by the NRC. .

The.NUMARC methodology, conta,.ned in NRC Draf t Regult tory Guida  !

, DC-1022, " Emergency Planning and Preparodness for Nuclear Power Plants," clarifies and stream 11nos NUREG-0654.

The revised EALs will provido updatoJ information to be used in i

, the classification of emergencies. Use of revised EALs is l oxpected to reduce the number of unusual events declared at EQN.

Following NRC approval of the NUMARC Methodology and issuence of ,

the final regulatory guido, TVA vill incorporate the revised EALs into the radiological emergency plan.

VI. FUNCTIONAL AREA - GECURITY MAi9 LAM 91npliabAe11m  :

Throughout the ovaluation period, SQN Site Security hau continued to demonstrato solid, superior performance in many areas. ,

Recognizing the-vintage and status of the overall current ,

security system hardwar.e, we consider tne accomplishments particularly noteworthy. Through aggressive management of the i program and resources, SQN has achieved a high level of security capability.and effectiveness.

A; key area _where the results of these efforts has continued to be very-evident is with regard to manning of compensatory posts.

The strong relationship between Site Security and Maintenance has continued, repairs aro performed in a timely' manner and, thus, compensatory post manning duration is minimized. At this time,

.SQN has no compensatory posts manned becauco of maintenance problems.

During the assessment period, site Security supported two major outages totaling over 140 days, along with the accompanying e . increase in site population, workload, and responsibilities, with no one-hour notifications-to NRC and no violations. This was ac.hieved through effectivo management, training, and shift augmentation, using temporary employces to offset heavy workloads requiring additional manpower or extensive overtime.

As for-performance indicators, the annual 1992 Quality Assurance audit did not result ~in the issuance of.any CAQs against-Site Security. In addition, several Site Security compliance audits were-conducted during the assessment period, none of which resulted in significant findings. Corporate Security compliance #

was.significantly involved in self-audit programs at SQN.

30

.- y-- -,---, .d. y w yy o ei.arg.-v p m y -gi g- 9.- y-- -y,asg ei p

. .- -.>,-1-e3-$m.'

Throughout the assessment porlod, Sito Security managemont conducted regular security /maintenanco/upgrado interface meetings to offect timely corrections of Site Security maintenance problems. Attendens. included personnel from Huclear Engineering,

Burns and Roo, Rust Engineering, Nuc4 ear Construction, Project Management, Planning and Work Control, the Site Security maintenanco staff, and the Site Security organization. The overall purpose of these mootings is to ensure the most effectivo and efficient implementation of the security upgrades described below.

Training *hc

. SQN Site Security force during the assossment period hat :luded both in-house and outsido programs. In-house training and qualification courses included respr-ae exorcisos, room entry, and combat / stress firing. Rosponse inir7 wan ,

further improved through realistic scenarios in"atelny the use of paint guns, Milos equipment, stun grenades, and */ ,an.ic entry

-tochniques.

Outsido training initiativos were abundant during the a4sossment period. They included training in hostage negotiations, long-rango_ weapons,=and Tactical Responso Training (TRT) teams. For instance,-in October 1991, two_ Site Security officers attended a 40-hour courue on hontage negotiations conducted by the Federal Bureau of Inveutigations. Also in October 1991, two staff members attended an e.dvanced course in hostage negotiations taught by recognized expert Frank Boltz.

In March 1992, a key supervisor participated in a two-day seminar on: worldwide terrorism, sponsored by the American Society for Industrial Security. Four staff personnel completed the 40-hour Physical Protection Systems Training Course, offered by BE, Inc.,

and sponsored locally by the TVA Corporate Security office. TRT training, focusing, in part, on the use of long-range weapons, -

, was conducted at the National Guard-treining facility jn Catoosa, Georgia. Negotiations are currently ongoing with the Department of Defense to utilize Ft. McClellan, Alabama's response team

- training facility, to further train the SQN Security forca.

Shift supervisors and specialists have visited several nuclear facilities to review' programs and procedurcs. In addition, SQN Site- Security;persunnel have contint'ed to participate in joint training exercises with city, county, state, and federal agencies.- Site' Security has remained active in the Southeast Nuclear < Security Association (SENSA). As a result of these-activities, many valuable ideas have been brought back to the,SQN Site Security organization. Goals for 1992 include additional visits by shift supervisors to nuclear facilities outside of the

~

-TVA system and continuation of_ joint training exercises-and SENSA

. participation in order to further realize the benefits from these valuable forms of information exchw.ge.

31 e

7 9everal weapons upgrades transpired during the assessment period that have further improved the response capability of SQN Site Security. In January 't992, TVA completed the transition from use of Smith & Wesson .38 caliber, six-shot revolvers to Sig-Saur 226 pistols (9mm, 15 round, semi-automatic handguns). In addition, TVA is transitioning from the use of Remington Model a70s to the new Benelli Super 90 shotgun. MP-5 submachine guns have been purchased-for use by foot patrols as a response weapon. All three Weapons are considered to be more reliable and provide more firepower than the predecessor weapons. They arn ergonomically designed to facilitate comfortable and instinctivo shooting and provide SQN Site Security officers with weapons that incorporate design improvements that meet or exceed regulatory requirements.

Overall performance of the SQN Site Security organization _

continued to improve during the assessment period. For instance, the quality of-Site Security tracking and trending programs continued to improve for safeguards event logs, shift ,

performance, safeguards event reports, maintenance activities, radiological exposure rates, accident-rates, and TVA thefts.

Performance charts summarizing the data in each of these areas are forwarded on a monthly basis to the Site Vice President and all Site Security force members for review.

Regular shift response drills continue to be conducted using performance-baued scenarios to more accurately test response force capabilities. For example, these drills include hostage negotiation and sniper scenarios. In addition, Site Security successfully supported the annual Radiological Emergency Preparedness (REP) exercise. For the first time, a security

.sunt was used to initiate a REP during the " dress rehearsal."

Accountability results satisfied REP exercise objectives.

Site Security officer and-line management involvement in correcting human errors continues to improve at SQN through the use of INPO's Human Performance Evaluation System (HPES). All Site Security human errors are evaluated by a HPES committee consisting of a nuclear security officer, lieutenant, shift supervisor, and staff manager for root cause analysis and recurrent control.

Finally, training and qualification weat as scorce have improved for marginal shooters who have been placed in the firearms improvement program. This program requires a 10 percent improvement in marginal scores. Additional training and qualification' attempts are required pending demonstration of the required level of improvement.

Site Security has maintained organizational stability at the site throughout the assessment period. This has been the result of various initiatives. For instance, stabi-lity has been achieved 32 l

l

_ _ _ ._ __.__._..__-______.---_._...m _ _ - _ _ _

by way of cross-training senior Site Security management through i rotational 1 assignments. Security roundtable meetings, conducted by the Site Security Manager and security shift cupervisors, have  ;

continued throughout the assessment period. As a result, all  ;

members of the Site Sucurity force have an opportunity to  !

communicate with' site Security management on a frequent basis.

Improved communications and more effective management have reduced the number of open employee items during the assessment '

period, e.g., grievances, empinfue concerna, Office of Inspector General complaints, and NRC complaints. Similarly, turnover rates and attritton within the organization remained stable.

, Throughout the assessment period, Site Security has maintained an i employee career devolepment program. It enables high-potential personnel, who have indicated an interest in promotion, to be -

temporarily promoted from the positions of nuclear security officer to lieutenant, or lieutenant to shift supervisor. Shift supervisors are cross-trained in other staff positions within the SQN Site Security organization. These temporary promotions not only develop the ability and potential of existing Site Security personnel, thereby building depth within the organization, but -

a.1pc heighten the individual's potential for promotion.

This, along with other factors, has contributed to an improvement in overall morale within the Site Security organization during the assessment period. Other factors include new weapons and equipment purchases, improved opportunities for in-house and outsido developmental training, and progress on the new system i upgrado, all of which are described in the area for future focus.

-In addition, in February 1991, the Site Security workforce schedule was revised, in direct cooperation with bargaining unit

-personnel, to eliminate rotating chifts and place security officers on straight 12-hour shifts with reduced overtime rates. '

The latter has not'only contributed to improved officer morale <

but also led to greater shift continuity during the assessment period.

The Site Security awards program also is relevant to thia  ;

discussion.- . Monthly, quarterly, and annual awards in the form of plaques are awarded to Safe Worker, Best Squad, Safe Squad, and Best Supervisor. Annual awards are also made to those with the highest training and qualification scores, both weapons and academic. This program instills pride in security officers, generates a competitive atmosphere, and1thereby improves both-morale and performance indicators.

L During the assessment period, Site Security has continued to

streamline the storage of safeguards-information (SGI) by l reducing the number of containers onsite. Currently, the number l of onsite storage containers is 28, an almost 50-percent ,

reduction in number since May 1991. Audits of SGI c:utinue to be 33 1

- -. .= -- ..- . - - - - - - .

1 conducted at SQN in order to further reduce the number of SGI containers and avoid the overclasnification of documents, thereby-  :

reducing the volume of SGI. In addition, Site Security has reduced the number of persons having access to SGI by limiting the number of persons who can sign out or approve sign-out of SGI.

AreeLg_f.ogiljure Fpmut The dasign and procurement of a now security system for SQN have been completed. The construction contract was awarded on June 16, 1992. Actual construction activities commonred on July 6, 1992. The tentative completion date for the project is late 1993.

The Site Security upgrade project will improve and enhance the overall security program when complete. State-of-the-art security equipment to be installed as pt4rt of this project includos new central and secondary alarm stations equipped with closed-circuit television-(Cf;TV) monitors, protected area perimeter barriers and associated intrusion detection and CCTV assessment systems, upgrados to the alarm monitoring and access control computers, and access control equipment for vital area portals. In addition, new gatehouse and access facilities will be constructed and an alarm station training simulator will be installed on which to train SQN Site Security personnel on the now automated system. Other non-hardware-related aspects of the effort include a review and upgrade of plans, procedures, and eite instructions, as well as improvements in the self-audit program.

VII. FUNCTIONAL AREA - SAFETY ASSESSMENT / QUALITY VERIFICATION lia. jor AgenplishmeDj;.E TVA considers that the commitment in this area has been particularly well-demonstrated over the current evaluation period in terms of problem' identification and investigation, prudent operational decisions and event response, critical seli-assessment, and programmr'ic' improvements.

In last year's SALP, NRC noted some lack of management initiative in promptly addressing potential problems (freeze protection and fire protection). While we may have preferred not to have had such opportunities, there are many strong examples where operational decisions and response to adverse conditions or events have been particularly prudent, conservative, in-depth,

! 34

i and timely. These examples include the decision to immediately shut down Unit 1 when the ice condenser door binding problem was identified, even though not driven by the technical specifications and the decision to hold mode change and conduct further testing of the Unit 1 main steam isolation valves (MSIVs) to fully understand and verify valve performance when questions were raised in review of test data. In several cases, mode changu or restart escalation was halted until issues were properly understood and bounded suen as the review of outage maintenance activities when the MSIV jumpers were discovered and review of valve lineups when the cavity spraydown and containment spray suction valve events occurred on Unit 2. outage activities were suspended in one case when a number of unexpected events occurred to allow evaluation and controlled resumption of activities. Again, these examples clearly demonstrate prudent and timely management response to problems.

Hand-in-hand with a strong safety culture is strong problem identification and investigation. This held true in our identification of the ice condenser door binding by a general foreman, which rapidly led to further inspection and unit shutdown as previously discussed. This was likewise demonstrated by the investigations that led to discovery of the MSIV jumpers.

Nearly a third of the LERs over the current evaluation period resulted from SQN's investigation and identification of problems, in many cases "old" problems such as the breaker coordinaticn -

issues, the DC Cook potential loss of sump inventory outside containment scenario, the recent anticipated transient without scram mitigating system actuation circuitry (AMSAC) logic issue, and a number ot fire protection improvement plan review findings.

SQN has looked very closely and aggressively at itself and issues.

As already discussed, significant progress continues to be made in developing the use of risk management in both day-to-day and outage contexts. Clearly, TVA's decision not to conduct any

" hot" midloops during the Cycle 5 refueling outages again demonstrated strong management commitment to minimizing risk and served to provide a good vehicle for communicating this type of safety-first philosophy to our employees.

While there are a number of areas requiring continuing focus in the incident investigation process to further increase effectiveness and efficiency, SQN has continued to demonstrate strong commitment to thorough, critical investigations and comprehensive corrective actions. Additionally, during the last evaluation period, NRC identified weaknesses in the post-trip reports. A total upgrade of that process was performed and has yielded very good results in implementation over this period.

Utilization of a predetermined dedicated team with a very structured review process has enabled SQN to quickly conduct a thorough asseusment of plant trip response and ensure both a safe 35

. i and timely return to power. The NRC resident inspectors have continued to monitor implementation of these processes and have  ;

called both the incident investigation and plant trip review  ;

processes strengths in their monthly inspection reports.  !

As discussed,-TVA is committec to long-term continuing improvement. SON will continue to utilize self-assessments and

• performance benchmarking to ensure clear understanding of ways to  :

further improve. The site has continued to utilize oversight groups in conduct of independent and in-house assessments, e.g.,

outage-schedule-reviews and reviews of switchyard activities. l While SON clearly considers personnel performance and management offectiveness to be the single most important area for elevating overall site performance, SON has seen several important successes that we will be building on in the future. The success realized during the recent U2C5 refueling outage was directly related.to the ownership, attention to_ detail, and effective performance of our personnel, and, to a very large extent, with -

much less senior management intervention. A large number of ,

activities were accomplished safely and on schedule to bring about that success. In an area where weaknesses have been identified in the past, overtime use was carefully monitored and  ;

offectively controlled. Development and sometimes rotational personnel assignments were effectively utilized to enhance overall organizational objectives and to provide a vehicle for

-personnel development. While the recent-TVA employee survey _ '

indicates this an an area for continued focus, increased emphasis on. management / employee communication can_be evidenced by the reduction in employee concerns. As has already been discussed .in -

several functional areas, TVA'hes and will be continuing to invest significant resources in technical,_ supervisory, and

-quality-related training.- '

I The current SQN Corrective Action Program was-implemented in February 1991. This was largely the transition from the old condition adverse to quality reports to the use of simpler problem evaluation reports for_most issues and significant

corrective action l reports for the issues determined to be ,

l s.ignificant.. -over'the past year, several11mprovements have been-l realized in implementation of the corrective action program, such L as1 reduction in; backlog items as earlier discussed and ,

significant improvements in corrective action timeliness.

Improved trending and analysis of data, combined'with the l improved QA-trend reports, have resulted in. earlier identification of adverse trends. A site-wide corrective action e

~tasksforce,--somewhat similar to-a management review committee, wap'put1 1n place with Site Licensing, Site Quality, plant, and Engineering representatives, and has been effective in improving 36 l

L _._ _ . _ . _ . . _ _ . _ . - , _ , _ _ _ _ _ _ _ . . _ . - , _ _ , - . ,. . _ , . . __ ._. _.

consistency of program implementation and providing coaching to line managers and oversight of program effectiveness.

We have continued to utill e INPo experience exchange as another vehicle to promote improvement consistent with industry-best initiativos. SON was selected for a second consecutive year to hont a senior managers' training class. This provides an l opportunity for SQN to 3 carn from these participants as well as l for them to learn from SQN. SQN managers have participated on  ;

assist visits to other plants as peer reviewers, and SQN has requested and utilized assist visits to obtain independent l evaluation and industry-best perspectives.  ;

Over the current evaluation period, SON experienced further reduction in reportable events despite the additional  ;

contribution of reportable events resulting from the Fire Protection Improvement Plan review efforts. As stated earlier, nearly a third of the reportabic events occurring over the current evaluation period resulted from aggressive investigation and review efforts. Along those same lines, while the number of violations received increased slightly, only a little over a ,

third woro NRC-Identified issues as_ opposed to over one half from 3 the previous evaluation period. The final SQN post-restart

-commitments were also completed during the Cycle 5 refueling outages. ,

In terms of generic safety issues, SON has been in line with the I industry averages, with four completed during this period and four Icft outstanding. Those remaining include the Category 3

• control room design review HEDs for both units and station blackout-for both units. Additionally, NRC recently conducted an

.RG 1.97 inspection for SQN, found implementation acceptable (implemented during the Cycle 4 outages), and will close the item.

Several technical specification line item improvements have been submitted and approved, such as the snubber inspection frequency relaxation cuul surveillance extension 3.25 limit elimination.

Several bulletin and GL actions have been completed, including GL 88-10 molded case circuit breaker replacements, IEB 88-04 AFW +

pulsation and residual heat removal discharge check valve modifications, GL 90-06 low temperature overpressure and PORV

- setpoints and technical specification changes, and generation of.

GL'88-11 new-reactor coolant system pressure temperature limits.

Further, SQN recently supported an NRC team'for review and i collection of information and data to support overall staff review of Generic Issue 143, " Availability of Chilled Water System and Room Cooling."

A problem area.for TVA'and SQN in' years past has been 10 CFR 50.59 evaluations. Over the evaluation period, 37

• P e r,v,-m ,,+wn E -~d . - - , -- - , , , , . * --m- rw-p.m-, = mere . -+ ~-t w tw=- -r---* r*

implementation has continued to be good, with a successful inapection conducted by URC carly this year. Program enhancemento have been and continue to be made such as the updated refresher training conducted early this year for 10 CFR S0.59 reviewers. SQN has additionally implemented a new justification for continued operation or nonconforming item procedure to provide additional evaluation and assessment guidance for nonconforming conditions consistent with the methodology and flowchart provided by HRC's GL 91-18.

There have been a number of nonresident NRC inspections conducted over the current evaluation period with largely positive results and minimal findings. Only two of the 21 violations received over this perjod resulted from current performance weaknesses identified from these inspections. Several special inspections _

conducted in response to site events / conditions, e.g., electrical issues associated with the breaker coordination issue, ice condenser door binding, feedwater line cracking and fire protection, have generall found the actions we were already ,

taking to be prudent and appropriate. SQN rcsponsiveness to NRC interest and concerns has been strong through timely and effective inspection support and technical meetings and ,

teleconferences.

I In last year's SALP report, NRC noted a weakness in the analysis supporting an LER. As we have already discussed, continued improvement has been achieved in conduct of incident investigations that support LERs. Additionally, an improvement initiative implemented over this period included implementation of an improved format for LERs. TVA undertook an LER improvement project in late 1991. The overall goal was to identify methods by which to improve the preparation of LERs. In order to accomplish that objective, TVA conducted a thorough review of the processes it employs to generate and submit LERs. The project (a -

team effort) was supported by SQN, BFN, and Corporate Licensing personnel. As part of this effort, the team reviewed most 1991 LERs from BFN and SQN, identifying issues requiring further analysis. This review was conducted on the basis of NRC regulatory requirements, guidance in NUREG-1022 and its supplements, and LERs from other utilities identified by the NRC Office for Analysis and Evaluation of Operational Data as being superior in quality. As a result, the team decided to substantially revamp the format of TVA's LERs to simplify the preparation and improve accuracy and clarity. TVA believes that the LER improvement project has resulted in a significant enhancegent in the preparation and quality of SQN LERs. In fact, NRC recently identified the improved LER format as a strength in IR 92-06.

To enhance the performance-based aspects of the audit program and take advantage of experience from other sites and utilities, increased priority has been placed on the use of both internal 38

.. ._ .. _ _ _ _ ~ . _ _ _ _ . _ _ . _ _ _ . . - _ _ _ _ _ . _ _ . _ _ _ _ _ . _ _

and.outside industrial expertise as team members on specific l audits and assessments. For example, the last Maintenance audit j included team members from corporate Maintenance and BFN, as well  :

as two contract technical specialists. l To ensurt .at management standards are being mot, the Audit Oversight Board (AOB) was created. The AOB consists of upper QA management including SQN, BFN, and Bellefonte Nuclear Plant Site Quality managers. The AOB reviews tne executive summary, audit findings, and effectiveness statements to ensure that they are well-founded and clearly communicate the audit results. r The Inspector of the Day (IOD) program was developed to increase Quality control (QC) daily involvement in maintenance, modification, and plant activities that do not require QC inspection or holdpoint. It includes walkdowns of various plant areas and observing work in progrens, plant housekeeping, and hardware conditions. QC personnel assigned IOD duties have completed observation training. ,

Site Quality has taken-steps to improve its approach to the f identification and resolution of plant problems by enhancing communications with plant organizations and the NRC staff. For instance, in April 1991, Site Quality enhanced communications with other SQN organizatione through the introduction and use of a standardized quarterly assessment format organized to correspond with SALp functional evaluation areas. Standardized '

criteria also have been developed to ensure consistent evaluatjan of performance. The revised format provides a more effective tool for evaluating plant performance. Site Quality holds monthly meetings with the Site ~Vice Presidant and Site Licensing management to discuss current issues. In an effort to improve _,

the exchango of information with NRC, monthly meetings are being held . _ Currently, scheduled audits and Site Quality management's perspective of how each plant organization and the overall site are performing are discussed. Details of audit results are also provided.

A-new format was developed for-the Trond Analysis Report. This format utilizos the visual impact of colored annunciator windows to display problem areas. The report is arranged by SALP category, and the windows are broken down to display performance changes in'each functional area. Each colored window is explained in the text of the report, along with corrective actions. The development of this report was a cooperative effort of.DFN, corporate,_and SQN_ quality organizations and is a direct output _from the_ site: quarterly assessment.

Site Quality has been responsive to specific plant requests for assistancc. For example, Site Quality performed an independent valve lineup check (sample) before the last Unit 1 start-up. In

, 39 l-l

. ,A - . . ..~..._.m . - - _ . . _ - . . - , - . . , _ - . . - . - - _ . . - . - - _ - - - -

l l

l recent months, Site Quality has also performed independent reviews of jumper usage control, fuse control, transient load control, minor maintenance program, and radwaste managen.cnt. Dy supporting plant requests, teamwork is enhanced, problem areas are identifi'd, and corrective action, if warranted, is taken in a timely manner.

Site Quality hau become ..sre proactive in getting out front on suspected problem areas. By reviewing such documents as "Inside NRC," Nuclear Network printouts, and NER documents, problems identified at other utilities can be assessed at SQN; and if problems are found, corrective action can begin prior to their being identified by others. Examples of this are the review of operator rounds, contractor control, and FPIP monitoring.

Tirca s f o r f tttu r e_1'o_cu s Notwithstanding the improvements and accomplisnments discussed, TVA considers that the key to further improverent at SQN lies in improving pornonnel performance, ownership, and accountability.

Many of the vehicles through which we are and will be continuing to address this area have already been discucced. While discust ions have shown strong evidence of the inclination and ability to identify and resolve problems, SQN recognizes the need for continued improvement at identifying issues before they become significant problems and quickly and effectively resolving these issues. Focus in these areas will naturally bring about desired improvements in regulatory performance.

A number of continuing initiatives are ongoing or planned to further enhance the ofIiciency and offcctiveness of the corrective Action Program. These include both process improvement enhancements and implementation improvements. The overall site initiatives concerning process simplification and individual ownership and accountability marry well with the intent of these improvements.

Site Quality has initiated a new performance evaluation program with Operations as the first area to be evaluated. This program will une NRC inspection critoria and INPO Guidelines / Good Practices to compare the plant with current industry standards.

Plant management will be briefed monthly on observation activitica and iy identified weaknesses. This type of program has been successfully used at other utilities and provides a more in-depth evaluation of performance based on field observations.

A baseline performance level is established and subsequent performance is compared with the baseline. 4 A Gite Quality task team was established in April 1992 to recommend improvements to the oversight functions performed by 40

o Sito Quality. The methodology being used is to interview Site Quality's cut.tomera and determine, both from the customer's an.1 Sito Quality's pornpoet.ivo, what improvements can be achieved.

The expected resultu are a set of enhancements to be implemented that will inprova sito Quality'a ability to identify significant probioms and Sito Quality's acility to communicate with cite and senior management. The reaults are scheddled to be presented to management by the end of August, y

\

41 w

I

_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ __ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ,