ML20117A582

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Provides Response to Initial SALP Repts 50-327/92-26 & 50-328/92-26 for Period 910602-920801.Considers Rept to Constitute Fair Assessment of Performance Over Period & Consistent w/self-assessment Conclusions
ML20117A582
Person / Time
Site: Sequoyah  
Issue date: 11/23/1992
From: Medford M
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9211300189
Download: ML20117A582 (4)


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.e n.,w w u ca,., - r t v, qmr November 23, 1992 U.S. Nuclear Regulatory Connission ATTN:

Document Control Desk Washington, D.C. 20555 Gentlemen In the Mutter of

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Docket Nos. 50-327 Tennesseo Valley Authority

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50-328 SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - INSPECTION REPORT NOS. 50-327, 320/92 RESPONSE TO THE 1992 SYSTEKATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

By letter dated October 19, 1992, the NRC staff transmitted to TVA the initial SQN SALp Report for the period of June 2, 1991, through August 1, 1992.

Subsequently, on October 26, 1992, NRC and TVA representatives met to discuss the report findings. This letter provides TVA's response to that report.

TVA considers the report to constituto a fair assessment of SQN-performance over the subject. perloa and is consistent with our own self-assessment conclusions. Accomplishments, challenges, and improvement initiat.1ves were discussed with the staf f in our July 1, 1992, self-assessment meeting with NRC and addressed in the-August 15, 1992, follow-up letter. While overall performance has been good and accomplishments realized, this effort is offset by declines or weaknessos in performance in the major functional areas of plant operations and Maintenance /Surveillanca.

Improvements in the two major functional areas have also been discussed with the staff on several occasions; while not complete, we believe that those initiatives are effecting improvements. We are clearly not satisfied with the icvel of performance over the past SALP period; the potential and expectations for SQN are substantially beyond " good" performance.

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November 23, 1992 We have examined thu initial SALp report very closely to ensure that identiflod avons for improvement have boon captured within our own self-ausessment and performanco improvement program initiatives.

Detailed action plans have been developed for each functional area. - We are working to make these programs ongoing, living efforts to ensure that long-term, continued improvement to achieved in all functional areas.

Even in the areas of Emorgency preparedness and Security for which SALp ratings of "1" woro achloved, challengen lie ahead.

The more general challengo includos sustaining program and implementation excellence, coincident with industry improvements and site faellity changes.

The ongoing major Sito security upgrade is an example of such chango and is receiving careful management oversight to ensure Security program effectiveness is maintained during the traesition period.

We are pleased with the inProvements that have been realized in the Radiological Controls and Engineering / Technical Support areas and the staff's recognition of those improvements; however, we recognize the vital role that-the associated organizations and activities play in supporting and contributing to the success of plant operations and are connitted to further improvement. proactive identification and resolution of system hardware and performance problems, and ef fectivo prioritization and support of. hardware upgrades will remain the key creas of focus.

Effective minimization os personnel dose will remain a primary objectivo_in the Radiological Controls area with continued focus on wo?kor radiologieni practices and careful planning and control over autage activities.

A number of ongoing process inprovement initiatives are targeted to elevate organization effectivonoss in.both the plant Operations and Maintenance / Surveillance areas.

Key ef forts in tho Operations area include:

overall upgrados in the configuration control and clearance processes; work control and control room. environment improvements resulting fcom implementation of the new. operations control Conter adjacent to the main control room area for work authorization;-nonlicensed operator qualification upgrados and development of additional guidance for conduct of assistant unit oporator rounds; and personnel participation und ownership'in improvement ef forts through the A70S Improvement plan and Operations Advisory Committes.

Key-Malntenance efforts include completion of the ongoing supervisory development training; postmaintenance testing and verification program improvements including extensive training, augmented-review and expanded application of end-devico-testing; and strengthening of the Rollability Centered Maintenance program through integration with ongoing trip reduction and hardware reliability impro' ament effcots, P

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i U.S. Nucinar Regulatory Conimission Pago 3 November 23, 1992 Significant effort is being applied at optimizing overall plant material condition and ro11 ability.

In addition to enhancements to tho Hollability Contored Maintenance program, a detailed analysis of secondary plant reliability is also being performed.

This analysis will take into considoration conmonent failure modes, preventivo and predictive maintenance applications, corrective maintenance improvements, and design upgrades to effect an overall improvement in reliability. prioritization and scheduling of outstanding hardware upgrades are being carefully eynmined.

Existing hardwaro troubleshooting and problem investigation techniques are being reviewed for further strengthening.

The resolution of outstanding fire protection hardware deficiencies is being aggressively pursued, which will lead to a significant reduction in compensatory measures ever'the current SALP period.

Performance weaknessos identified in the Natutensnce/ Surveillance and Operations functional areas are considered to be directly related to the principal observation noted in the Safety Assessment / Quality Verification functional areas; management has not been fully offectivo in communicating expectations for and bringing about consistent implementation of requisite high standards of personnel performanco. Wo clearly considor this area to constitute the most significant challonto to SQN achieving its potential _.fot overall operational excellence.

Extensive actions _are being taken to clearly defino and reinforce managenen.

expectations and performance standards; improve management.and supervisory offectivnness; assess employou performance against those expectations on an ongoing banis; and establish consistent performance feedback.and accountability.

Expectations and accountability against those expectations have been established and communicated both verbally and in writing.

Cascading and sitewido face-to-face communications sessions are being conducted by the Vice' President, Nuclear Operations;-Site Vice president; Plant Mane. gor; and/or department heads to repeatedly reinforce expectations and standards and communicato performance assessment against those standards. - Both managwment effectiveness at.4 personnel performance are being closely monitorea, actions have hgua C On and will continue to be taken where necessary, to reinforce accountest ih y against expectations sud effect=the desired change.

In summary, TVA appreciates.the staff's assessment-regarding SQN's performance and has verified that the SALP report's'fladings'are being appropriately addressed within the SQN performance-improvement program initiatives. _While much has been accomplish;d at SQN, there are significant 1

challenges remaining. TVA will schedule a meeting'with the staff by f

March 15, 1993, to review SQN's progress in these efforts. We are committed to continued improvement 'and_ achievement of operational excellence. -

We, too.fagree that effective management action'is necessary to achieve this-direction.

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.i U.S. Nuclear Regulatory Commission Pago 4 November 23, 1992 if you have any questions concerning this submittal, plesso telephono M. A. Cooper rt (615) 843-8924.

Sincerely, Mark O. Medford cc:

Mr. D. E. LaBargo, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Piko Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear ?lant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 i

Mr. B. 4. Wilson, Project Chief U.S. Nuclear Regulatory Commission Reglon II 101 Marietta Stecot, NW, Suito 2000 Atlanta Coorgia 30323-0199 i

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