ML20147F357
| ML20147F357 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/02/1988 |
| From: | White S TENNESSEE VALLEY AUTHORITY |
| To: | Ebneter S NRC OFFICE OF SPECIAL PROJECTS |
| References | |
| NUDOCS 8803070327 | |
| Download: ML20147F357 (50) | |
Text
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1 TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ot 6W 38A Lookout Place MAR 021988 Mr. Stewart D. Ebneter Director Office of Special Projects U.S. Nuclear Regulatory Comission ,
MS 7D2A Washington, D.C. 20555
Dear Mr. Ebneter:
This responds to your letter dated February 3,1988, regarding a report by l' American Nuclear Insurers (ANI) dated December 24, 1987, which discusses the results of an ANI special nuclear liability insurance inspection of the Sequoyah-Nuclear Plant-(SQN). In your letter, you requested that TVA evaluate the ANI report concerns on an item-by-item basis. You also requested that'we provide the April 1987 ANI report and TVA's correctiva actions.
In my February 5, 1988 letter to Ronald Sanacore, ANI, I responded to each of ANI's significant coments, as well us formal recomendations, and provided corrective actions and schedules for implementation (enclosure 1). ~
That letter also provided revised responses to information (identified as unsatisfactory by ANI) that was previously submitted by TVA in response to an' -
earlier ANI inspection and their April 1987 report (enclosure 2). In accordance with your request, TVA's response to the April 1987 report is also enclosed (enclosure 3).
I believe my February 5 letter adequately addresses tl e concerns expressed in your February 3 letter. However, because of the emphasis placed in your t letter on the deficiencies noted by the ANI staff in the functioning of the Plant Operations Review Comittee (PORC). I believe that I need to restate that I view PORC as an important link in the safe operation of any nuclear power plant. As we explained in my February 5 letter to Mr. Sanacore, the functioning of PORC was in a transitional phase at the time of ANI's inspection, and we knew that this area needed improvement. We have taken ,
actions in line with ANI's recomendation to improve this program. For l example, an increased emphasis is being placed on PORC presentations, the training / accountability of PORC members, and the discouraging of last-minute ;
f review items by PORC. Because additional work is needed to bring PORC up to my standards, these efforts to improve PORC will continue. Nonetheless, it is also important to note that. ANI rwidered the decisions made by PORC in the meeting attended by ANI to be appropriate.fht ga. tL l (gr.- c I 8803070327 880302 PDR ADOCK 05000327 t0i 0 - J PDR { An Equal Opportunity' Employer
i Mr. Stewart D. Ebneter ANI has provided TVA by letter dated February 11, 1988, results of a February 3-5, 1988 nuclear liability inspection at SQN in which ANI reviewed safety review oversight responsibility and further discussed with site and corporate management the results of the December 1987 inspections. ANI in that letter stated that it had noted improvements in the functioning of PORC and that it was satisfied with the thoroughness of SQN's operational readiness review. This letter is provided (enclosure 4) for your information. On March 1, 1988, ANI responded to the corrective actions identified.in my February 5,1988 letter and concluded that our responses were prompt and addressed the areas identified by the ANI recommendations. In particular, ANI states that there is adequate overlap between nuclear safety review programs to ensure that nuclear safety issues are addressed and that vor corrective actions regarding PORC are satisfactory. This letter is provided as enclosure 5. Very truly yours, TENNESSEE VALLEY AUTHORITY hQ@ S. A. White l Manager of Nuclear Power Enclosures cc (Enclosures): Mr. K. P. Barr, Acting Assistant Director for Inspection Programs TVA Projects Division i U.S. Nuclear Regulatory Commission l Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects TVA Project Division U.S. Nuclear Regulatory Commlssion One White Flint, North ! 11555 Rockville Pike Rockville, Maryland 20852 Sequoyah Resident Inspector Sequoyah Nuclear Plant i 2600 Igou Ferry Road ; Soddy Daisy Tennessee 37319 . 4
ENCLOSURE 1
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6N 38A tookout Place FEB 051988 Mr. Ronald Sanacore, Vice President American Nuclear Insurers The Exchange, Suite 245 270 Farmington Avenue Farmington, Connecticut 06032
Dear Mr. Sanacore:
Enclosed is our response to Mr. Larson's letter of December 14, 1987, regarding ANI's December 1987 special nuclear liability inspection of Sequoyah Nuclear Plant. We have attempted to respond to the significant comments, as well as the formal recommendations contained in the letter, and we look forward to discussing any further question you might have. Because of the special emphasis placed in your letter on the functioning of the Sequoyah Plant Operations Review Committee (PORC), I feel it might be helpful to provide some additional comments separate from the enclosure. I view the PORC as an important link in the safe operation of any nuclear power plant. One of the areas that we knew needed improvement was the functioning of this group. As part of that effort last fall, we shifted the focus on P0RC's work of procedural review to an operational safety review function. This effort gained added emphasis when Mr. Steve Smith was assigned as the new plant manager at Sequoyah. As you may recall, this transitional phase of the PORC and the corrective actions being taken were related to your investigators prior to their review. Indeed, the problems outlined in your letter concerning the operation of the PORC were essentially the same as those already noted and being addressed by Mr. Smith and Mr. Bynum. Consequently, . we generally agree with your findings that PORC can operate more effeccively. We have taken actions to correct your findings, but additional work is needed to bring PORC up to my standards and this effort will continue. However, it is important to note, as we discussed in our meeting in my office in Chattanooga on January 25, 1988, af ter the inspection and receipt of your latter, you consider the decisions made by PORC in the meeting you attended to l 1 be appropriate and not to be a risk to the safe operation of the plant.
k*
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.2-Mr. Ronald Sanacore FE8 05 s88 TVA's nuclear power program is not yet at the level of performance that I c, expect and intend to achieve.
I appreciate your suggestions to help us better achieve excellence. ' Very truly yours. TENNCSEE VALLEY AUTHORITY S. A. khite Manager of Nuclear Power s 3 i 1 .
't , , re se
.. '.. ATTACHMENT
/. SEQUOYAH NUCLEAR ' PLANT ANI KUCLEAR LIABILITY INSURANCE DECEMBER 8-11. 1987 INSPECTION Response to Recommendations On-Site Safety Review ANI' Recommendation 87-1 The Plant Manager or Assistant Manager should chair all PORC meetings.
TVA Response The Plant Manager has chaired all PORC meetings since assuming his position in November 1987. TVA will continue this practice with the Assistant Manager of ONP as his alternate. In the unlikely event that neither of these individuals is available and a PORC meeting is necessary, a substitute senior manager, appointed by the Plant Manager, may chair a PORC meeting. ANI Recommendation 87-2 ' All PORC members should be required to attend PORC meetings; the use of , alternates should cease. TVA Response The Plant Manager has emphasized to all regular PORC members that they are not , to use alternates except in unusual circumstances such as leave, sickness, or emergencies. PORC meetings will take precedence over other normal work activities. Alternates are being randomly scheduled to attend regularly scheduled PORC meetings as non-voting members so that further experience can be obtained in the enhanced PORC process. t ANI Recommendation 87-3 All unnecessary personnel should be excluded from PORC meetings. TVA Rerponse Unnecessary personnel are excluded from PORC meetings. The PORC chairman enforces this practice. PORS along with senior managers designated to perform PORC oversight (see TVA Response to Recommendation 87-12) will monitor and provide feedback on this recommendation to the PORC Chairman. 9 COC4/2325R
w j . ANI Reco mondation 87-4 Those organizations that typically present items to the PORC should be formally instructed as to their responsibilities and expectations regarding PORC presentation. and ANI Recommendation 87-5 Those who present items to the PORC should be required to give formal presentations to the committee. TVA Response TVA agrees with ANI Recommendations 84-4 and 5 and guidance for presenting items to PORC is being be incorporated into AI-48. "Plant Operations Review co=mittee (PORC) Charter". This revision has been prepared and approval is expected by February 8.1988. ANI Recommendation 87-6 Those who present items to the PORC should be required to have a high level of knowledge of the item being presented. TVA Response The enhanced guidelines for POPC presentations in response to ANI recommendation 87-4 and 87-5 will resolve this recommendation. Presenters are much more aware of the type and level of knowledge required by the PORC than they were during your December 1987 inspection. The PORC Chairman will continue to emphasize this area. ANI Recommendation 87-7 4 Last minute PORC items ("walk-ins") should be minimized as much as possible. TVA Response Last first. minute review items are discouraged by PORC. Agenda items are presented The PORC chairman monitors PORC activitics with regard to "walk in" items meeting. and defers such items until they can be scheduled for a subsequent There may be true emergency or high priority items that the chairman will choose to review. ANI Recommendation 87-8 Expedite the training of PORC members and alternates in their specific committee responsibilities (for example, review of unreviewed safety question issues). O COC4/2325R W m7
. .- O TVA Response All PORC members and alternates are required to take Quallfled Reviewer (QR) and Unreviewed Saft'y Question Determination (USQD) training with all training to be completed by February 29, 1988. This requirement has been incorporated into AI-48 revisions which are expected to be approved by February 8,1988. ANI Recommendation 87-q Increase PORC member accountability for performance during PORC meetings. TVA Response Individual member performance during PORC meetings is monitored by the PORC chairman. Emphasis is placed on individual knowledge and interaction during . PORC meetings with special emphasis on USQDs, Root Cause Analysis and Corrective Action. PORC members will be held accountable for knowledge of safety requirements in their area of expertise. Feedback to the individual " and his manager is provided by the PORC chairman. ' ANI Recommendation 87-10 All PORC meeting participants should be required to review meeting materials, including previous meeting minutes, prior to meetings. TVA Response All PORC members are now required to review pertinent meeting materials; including agendas, previous minutes and other backup material, prior to meetings. This requirement has been incorporated into AI-48 revisions which are expected to be approved by February 8,1988. ANI Recommendation 87-11 All PORC members and alternates should be provided copies of meeting minutes. ' regardless of whether or not they attended the respectivo meeting. TVA Response t All PORC members and alterna,tes are being provided copies of the meeting minutes to review. This requirement has been incorporated into AI-48 revisions which are expected to be approved by February 8,1988. ANI Recommendation 87-12 The regular attendance of non-PORC members who have considerable safety review experience should be required in order to augment the meeting and enhance the 1 quality of interactions and decisions and set examples for others. , t
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COC4/2325R
1 4-e ANI Reconmendation 87-13 Formal critiques of each PORC meeting should be conducted for the purposes of identifying strengths and weaknesses of the group and the individuals involved and to provide for future improvements to the safety raview function. TVA Response Experienced nuclear managers knowledgeable in the arear. of USQDs and PORC operations attend PORC meetings on a periodic basis. The Assistant Manager of Nuclear Power. Site Director, the Assistant to the Plant Manager (Development), and PORS Manager periodically attend PORC meetings. One of these managers attends a PORC meeting weekly. In addition, the PORC Oversight Uection of PORS has committed to have a representative present for each scheduled FORC meeting. PORS will provide feedback, including deficiencies noted and recommendations for improvement, following each scheduled PORC meeting. A,gI Reco =endation 87-14 An action plan should be developed and implemented for the purposes of in,tependently evaluating the effectiveness of past PORC ae.tivities and establishing corrective actions for noted deficiencies. IVA Response The recommendations and cor.ments by ANI appear to be focused on the effectiveness of the PORC process. TVA concurs that the PORC process does need improvements and is committed to accomplishing these improvements. However. TVA believes that an additional independent evaluation of past PORC activities would yield little or no additional benefit in defining these improvements. In the past. PORC had been responnible for reviewing procedures, programs. modifications. Tochnical Specification changes, reviaions to Physical Security Plans, reviwions to Radiological Emergency Planu and a number of other items. All of these items are developed and reviewed by the responsible technical organizaticns as well as other review organizations such as Division of Nuclear Quality Assurance. NSRB UMRC PORS, and Division of Nuclear Licensing and Regulatory Aff airs. For example, a Technical Specification change is typically initiated by the responsible technical organization, reviewed by the Division of Nuclear Licensing and Regulatory Affairs, reviewsd by PORC. reviewed by the Nuclear Safety Review Board and finally reviewed by the NRC. A modification would be reviewed by the originator, as well as organizations responsible for design, construction and operation. These reviewn include in-depth technical reviews. In addition to the technical reviews by the initiating organization and other affected line organizations, the PORC and the NSRB provide additional reviews of the safety evaluations. The adequacy of plant systems and programs to support safe operation has been verified through a number of programs. A very thorough Design Baseline Verification Program (DBVP) has verified the adequacy of design and C0C4/2325R
. o construction including modifications. The Restart Test Program followed the DBVP and demonstrated all safe shutdown and accident mitigation functions.
The Surveillance Instruction Review Program identified and corrected problems with the plant instructions used to demonstrate compliance with the Technical Specifications. The Operational Readiness Review Team along with the Institute of Nuclear Power Operations has looked at the readinops of the staff to support restart and the NRC has conducted many inspections covering virtually every aspect of plant operations. These efforts, plus others such as Employee Concern Program investigations, indicate that decisions affecting safety have been and continue to be sound. Tour Observations (Radiolor.ical Control) ANI Recommendation 87-15 All personnel entries to Radiologically Controlled Areas should be governed by Radiation Work Permits (ANI/MAELU Criterion 8.9.2) TVA Response Sequoyah plans to implement a computerized access conteni system in late l 1988. At that time we plan to cover all entries into the RCA by RWPs (for work activities and administrative purposes). As you are aware, all personnel entering RCA's are issued dosimetry and subject to TVA's Radiological control program. Until the computerized access control system can be implemented, personnel entries to Radiologically Controlled Areas (RCA) will be covered by a Radiation Work Permit (RWP) under the following conditions:
- 1. Entries into radiation areas where worker exposures are expected to exceed 50 mrem / day wholo body or when extremity monitoring is required.
- 2. Entries into high radiation area. g
- 3. Eatries into contamination areas.
4 Entries into airborne radioactivity areas.
- 5. Activities or operational tasks that have the potential for creating significant radiological hazards.
- 6. Activities or operational tasks that have the potential for creating significant radiological hazards.
- 7. At the discretion of the Radeon Group.
These requirements result in all significant radiological type work activities being governed by an RWP. COC4/2325R
4 The presens program allows for inspection type activities and work on non-contaminated systems to be performed without an RWP, provided that items 1-7 above do not apply. In fact this system captured essentially all our station dose for 1986 and 1987. Eadioactive Waste Manatement ANI Recommendation 87-16 Radioactive of materials should not be stored outside except for a short period time. ( ANI/KAELU Criteria 4.2.33.9) TV,A Response Drums and radioactive waste shipping casks stored outside (near railroad bay) were being prepared for shipment. Normally, they are placed outside just prior to shipment. However, the casks observed by the ANI inspectors involved a situation where shipment of casks containing radioactive waste domineralizer resins was delayed while awaiting characterization and scaling factor determination in order to comply with 10 CFR 61. This has been' completed, and wast.: is being prepared for shipment. LSA boxes stored in the radwaste yard contain excess material from outages. These boxes ars currently being inventoried. The inventory is expected to be completed by May 1988, waste shipped as necessary, and the remaining material appropriately marked and stored in van trailers for use during future outages. l Responses to Sirnificant Comments ANI Comment - page 5 As a result of this evaluation, ANI has concluded that TVA/Sequoyah is moving in a positive direction toward operational readiness for the restart of Sec,uoyah Unit II; however, based on ANI's findings, reevaluation of staff readiness to operate Unit II should be conducted by TVA/Sequoyah management prior to restart. TVA Response The readiness of the staff to restart Sequoyah Unit 2 is being evaluated. In August 1987, the Manager of Nuclear Power initiated formal operational readiness review (ORR) of Sequoyah by assigning a highly qualified team, independent of the line organization, to come onsite and review the qualification and motivation of personnel at Sequoyah Unit 2. This ORR Team was further charged to review the availability of necessary supporting resources for the safe and reliable testing, operation, and maintenaneo of the plant. The prelimfsary findings of the ORR team were made available to the Plant Staff in early October 1987 and the plant immediately began corrective e-COC4/2325R I
~I~
o actions. The formal report was issued on January 5,1988 however, restart issues had been identified in the preliminary report and corrective actions are complete or nearing completion for all restart issues. Operators have been given special training on the need for formality and discipline in operation and shift crews will be receiving special classroom instruction and simulator training, prior to restart, on key issues such as criticality control. A group of Shif t Operating Advisors (SOAs) has been formed to observe and assist shift crew personnel during heatup. These SOA's are managers and forcer SRO's with operating experience. Most also have experience at other utilities. The SOA program is a formal proceduralized program and the SOA's have been trained on'what is expected of them. They will report daily to the plant Manager as well as the Site Quality Manager. ANI Co ment - pane 5 The issue which ANI believes should be reviewed is the standards by which TVA/Sequoyah is measuring its staff operational readiness. It is not evident from this inspection what standards are being used. It is ANI's opinion that TVA/Sequoyah should measure itself against absolute industry standards for operational readiness and not against progress made to date at Sequoyah. These standards should be communicated to all personnel and should become the approved yardstick by which TVA/Sequoyah measures its staff readiness. TVA Response The TVA nuclear power program is being infused with talent from a wide range of backgrounds to provide the standards of excellence for the nuclear program. The Deputy Sita Director, Plant Manager, Assistant to the Plant Manager and Quality Assurance Manager are examples of such talent. In addition, special reviews and assistance by very experienced individuals and groups are being used to compare our activities to atandards of excellence. The Operational Readiness Review (ORR) Team and members of the Institute of Nuclear Power Operation have performed a very detailed review of operational readiness at Sequoyah. They have reviewed Sequoyah against standards of excellence and many improvements October 1987. have been made since the ORR interim report was made available in The restart requirements in the ORR report are substantially ' complete restart of SQ!i Unit will and they 2. be verified during heatup prior to actually commencing Industry standards of excellence are incorporated into procedures and training on an ongoing basis. ANI Corment - pare 6 - Item 1 Radiological boundaries, in many instances, were not fully adhered to. Many roped-off areas in the auxiliary building had water cunning out of the area past the boundary. Other areas had material (hoses, poly, etc.) inside the COC4/2325R
i roped-off areas that breached the vertical plane of the boundary. All of ; these conditions serve to decrease the sensitivity toward radiological !
= boundaries and should not be allowed to continue.
TVA Response There is a significant effort underway to improve housekeeping and reduce .the number of radiological boundaries. Managers are held accountable'for observing and correcting violations of radiological boundaries as wall as-general housekeeping. Attention to detail in these and other areas is being strongly emphasized by senior plant management. ANI Comment - pages 6 and 7 We also observed a number of areas in the radwaste control room that could be improved.
- Hydrogen header supply gage was marked "OOS" in felt tip pen.
- A number of informal markings were made near switches and gages with pen and dymo-type labels.
- A hold (number 1035) was on the gas stripper feed pump and switch since January 5, 1986.
- Temporary alteration 81-11-77 on the cask decon pump and switch appears to be very old.
- Spent resin storage tank level gage was reading substantially greater than 100% full.
TVA Response Informal labeling using felt tip pen and Dymo-tape is specifically not allowed. Operator aids are controlled by administrative procedure SQA-142 and prior to restart, operations management will conduct an audit of control panels to ensure that only controlled operator aids are in use. The year old Hold order on a gas stripper feed pump stud switch was the result of an inoperable pump motor receiving low priority for repair. These motors are not readily available and the motor has been sent off site for rewinding. It should be returned and reinstalled by August 1,1988. This motor is not critical to the operation of the associated evaporator unless the remaining two motors fail. Thare are two temporary alterations associated with the cask decon pumps that ha.*e been converted to design changes but the work plans have not been prepared to make the physical changes. These changes are scheduled to be complete by August 1, 1988. The level gage observed was not operating correctly. A new type of level gage for the spent resin storage tank has recently been chosen. The repair will commence as soon as the new gage and parts can be procured, the design package , e C0C4/2325R
9_ completed and the work plan developed. Since this has the potential to be a high exposure rate job we will carefully look at the ALARA aspects before commencing work. This work will be completed by June 1, 1988. Revised Responses to questions in your letter of April 15, 1987. Question A.1 Please explain the purpose and advantage to the most recent reorganization of the modification groups. TVA Response
- The purpose and advantage of the most recent reorganization of the modifications group was to reduce redundancy in organizations and provide clear accountability for work by consolidating construction functions under, the Division of Nuclear Construction. This will help ensure that design changes are consistently controlled in accordance with regulations and procedures. The changes were made to provide clear lines of authority and responsibility and strengthen consistency between corporate and site
. functions. In the current matrix organization, activities and priorities of the Modification Group are established by the Site Director while the technical direction and support functions for the group are provided by the Division of Nuclear Construction. Site Modifications Groups can serve as resource pools for all sites during periods of high activity such as outages, when engineers and qualified craf tsmen are needed temporarily at other sites.
Question A.2 It is not obvious whether or not sufficient management energy has been expended to address and resolve communications problems between the plant and engineering. Please explain what actions have been taken to solve these types of communications problems, t TVA Response Key managers from Engineering Modifications and the Plant Staff meet face to f ace on a daily basis to resolve problems. These meetings, referred to as Plan of the Day meetings, are for the primary purpose of determining which organization or individual needs assistance in accomplishing scheduled work and to make that assistance available. Key items on the plant schedulo must be explained by the cognlzant manager. This meeting has been very effective in eliminating communications problems, and the daily contact has resulted in a developing teamwork. CDC4/2325R
pu Question B.1 Many temporary modifications incorporated before shutdown remain in place in the plant. Why have these temporary modifications not been converted to permanent modifications? TVA Response
- In the past there has not been adequate attention to eliminating temporary modifications or incorporating them into plant design. Temporary mcdifications are now being closed as rapidly as possible but the workload on the Division of Nuclear Engineering as a result of restart effort has prevented closure of all of the temporary modifications. Continued emphasis will be maintained on the reduction of temporary modifications and the Operations Superintendent is now directly responsible for monitoring and ;
controlling temporary modifications. Requests for temporary modifications are being carefully screened and are being denied for long term changes. This will keep the number of new temporary modifications from growing while the old ones are being closed. Question B.2 The guidelines for issuing a waiver for DCR submittal on a long-standing TACF
-were not clear to those personnel interviewed. It was not evident as to how long this waiver .s good for, nor was it clear as to how rany successive waivers can be granted. What is being done to resolvo these situations?
TVA Response Sequoyah Administrative procedure AI-9 which prescribes the temporary modification process, allows the Plant Manager to grant a waiver of the requirement for issuing DCR's on long-standing, temporary modifications as long as they do not degrade nuclear safety. The procedure does not address how many successive waivers can be granted. TVA does recognize the problem associated with long-standing TACFs and expects to c' lose all 72 temporary modifications outage. which were in place before 1984 by the unit 1 cycle 4 refueling Further controls have been placed on more recent temporary modifications including a monthly review by the responsible organizations. The plant manager and staff are carefully reviewing requests for temporary modifications and placing limits on how long they can be used. Close management attention should result in plant personnel having a clearer understanding of the guidelines and is expected to solve this problem. COC4/2325R
F Question B.3 The process for getting a TACF DCR worked on was not clear to those interviewed. What is being done to resolve this? TVA Rcsponse The process for removal of a TACF by making it a permanent change includes processing a DCR which will receive management review as well as Change Control Board Review. The Operations Unit Manager is now responsible for reviewing and establishing priorities for the work needed to safely operate and maintain the units including the reduction of temporary modifications. The daily War Room meetings provide a forum for the resolution of problems and discussion of needed' action. This forum provides the operations organization with the means to elevate priorities and resolve problems associated with temporary modifications. Issues that in the past might have been handled as temporary modifications are now receiving immediate support from Division of
!!uclear Engineering, Systems Engineering, maintenance and modifications organizations in order to achieve permanent solutions. Representatives from all affected-organizations are present and therefore actions on issues are quickly communicated.
9 COC4/2325R
P ENCLOSURE 2
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e NtXLEAR [tGN([ RING DEPARTMENT v tc dJ scm cre.vce Pmd-. SV 74 L - I - SURT C.PfCOM.CKU
% w ps r. - - Czecee April 15. 1987
- i Hr. David H. h rks Division of Purchasing 1575A Chestnut Street Tower II Sixth and Chestnut Streets Chattanooga TN 37401 '
4
Subject:
ANI/MAEl.U Nuclear 1.iability Insurance Inspection f Faciitty: Sequoyah Nuclear Power Station ; Policy Numbers: HF-247/MT-102 Date: February 24-27, 1987 N
Dear Hr. Marks:
Stan Focht. Steve Sagaties, and I conducted a nuclear liability inspection at
~
the Sequoyah facility to review plant modification control, health physics. i plant status, start-up activities, and previous recommendations.
> i One suggestion to post frisking instructions was offered. Past recoc=enda-to tions 85-2 and 86-1 vere close,t. and no new reconnendations were made. Some key Sequoyah staf f members vera not available for initial or follow-up 1 T discussions. Consequently, several of our questions and concerns were not l fully resolved. We would appreciate your written response within sixty (60) ;
9 days to help us close the issues discussed in this letter. l INSPECTION ITEMS O Plant Modification Control * , O l Ve reviewed plant modification procedures and discussed further details with ' Darrell Vidner. Engineering Supervisor; Jim Maddox. Project Administration ! ! Supervisor; Barry V1111s Assistant Plant Manager; and Boyd, Patterson. l Superintendent of Maintenance. This review gave us the opportunity to become t l f amiliar with Sequoyah's modification process. and the changes thaNEMW{S j made. We were particularly interested in the overall c.odification pro g . as ! l veil as the specifics of temporary modifications. drawing control, and , codification package review. gg F f pection The comm.nt
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Mr. D vid H. Marks Pcas 2 April 15, 1987 e The following observatio'os include many noteworthy programmatic improvements and several itema which require additional clarification. Ve have also collected these unresolved issues in the Attachment to aid you in responding to them. , overall Hodification Process Improvements have been made in governing procedures and administrative systema including the formation of the CCB (Change Control Board). DNE (Engineering) is much more involved in the entire process (design through Laplementation). The sequence of performing modifications is more carefully considered than in the past.
- Nore realistic. "do-able" work packages are being generated.
The purpose and advantage of the most recent reorganization of the modifications group are not clear. It is not obvious as to whether or not suf ficient management energy has been expended to address and reselve communications problema between the plant and engineering. An example of this type of problem is the past use of two dif ferent types of drawings by the plant and engineering, and the configuratior. control discrepancies that resulted. : The people we interviewed were not in agreement as to who was i CV ultimately responsible for priorittring and scheduling modifications. p The final DCR (Design Change Request) and ECN (Engineering Change Notice) closeout processes do not appear to formally consider the i user's needs. J Teepora ry Hodifications l
- Increased managemant scrutiny was noted in the TACF (Temporary !
pg
- Alteration Control Form) approval process. ;
Increased DNE involvement. particularly relating to the preparation of r
- 97 USQDs (Unreviewed Safety Question Determinations), was evident.
- A more stringent tracking system is in place, whi~n includes the l M7 requirement of initiating a DCR or obtaining a vniver f rom the Plant Manager after sixty days.
CE
. Many temporary modifications incorporated beforS shutdown remain in CD place in the plant.
4 l The guidelines for issuing a vaiver for DCR submittal en a C) long-standing TACT vere not clear to those personnel interviewed. It was not evident sa to how long this waiver is good. nor was it clear l l as to how many successive waivers can be granted. 1 I The process for getting a TACF DCR vorked on was not clear to those ! inte rviewed. Drawing Control l ;
! Overall improvements have been made in the drawing control process, such as:
1 i
- 1) adopting a one drawing system;
- 2) clarifying responsibilities for drawing control; and
- 3) the commitment to update as-configured drawings within fifteen days of lifting hold orders on modifications.
, Mr. David H. Marks Pago 3 April 15, 1987 o
Modification Package Review
- Periodic reviews during the modification process and team walkdowns are improvements in the review process.
- lt was not evident that the PORC (Plant Operations Review Committee) members feel responsible for reviewing modifiaation package USQDs in great detail to ensure that an Unreviewed Saf ety Question does not exist.
' No agenda is provided to PORC members and alternates before meetings are held.
- Modification workplans are not reviewed by PORC members prior to PORC meetings.
Issues Pacing Sequoyah Ve discussed plant startup and other issues with Larry Nobles. Plant Manager. Ve were provided inf ormation on EQ (Equipment Qualification), the Design Baseline Verification Program, Ampacity, drawing deficiencies, cable splicing l proble=s, Technical Specification surveillance instruction reviews, restart testing considerations. Employee Concerne, the Piece Parts Program, contro?. i room ceiling replacement, small bore pipe hangers, trending program ,1 p? deficiencies, the Operability Lookback Program Appendix R nadifications, E steam generator tube plugging, and the Operations 1 Readiness Program. This discussion helped us understand the amount and scope of work to be ! Ps acccmplished before startup. 4
~~
j u Health Phraics S
~
Ve discussed the Health Physics staf f and organization,with Bob Prince, Y Superintendent - Radiological Cont rol. The Sequoyah Radiological Control P3 section organizational structure and staf f size appear suf ficient to establish and monitor guidelines concerning proper radiological practices as related to
- insurance purposes. Ve believe that the current organization, which has the Radiological Control Superintendent reporting directly to the Plant 57 Superintendent, provides for the most ef fective management.
C? Ve reviewed the generation of RVPs with Jerry Osborne, ALARA Health Physicc C3 Supe rvisor, and John Leamon ALARA Health Physicist. The RWP format meets the requirements of ANI/MAELU Radiation Work Permit criteria, section 8.9 C3 (Revision 2). The RVP program provides suf ficient documentation of the , radiological controls imposed on workers, rad control coverage, identification ' of A1 ARA concerns, and current survey information. Don Crawley, Radiological Control Field Operations Supervisor, described contamination control measures and radiation surveillance at the atte. The performance of these surveys appears suf ficient in terms of f requency, posting, review by supervisors, and document retrievability. The establish:ent and achievesent of the plant c-zone reduction goals were noted. Ve discussed the external radiation desinetry program with Sandy Harrison, Do.ni=ctry Shif t Supervisor, and Al King. Dosimetry Health Physicist. The dosi=et ry program mee ts the = criteria, section 8.4 requirements of ANI/MAELU External Dosicatry (Revision 2). O
Mr. D:vid H. Marks Pago 4 April 15, 1987 o Ve reviewed aspects of r'acords retrieval with Diane Larsen. Corporate Health Physicist. TVA has performad their own self-audit based upon the guidelines , of ANI/MAELU Bulletin 80-1 A. Records Retention. A full 80-1A inspection was 1 not performed; instead an overview of locating documants was conducted. ! Overall, the ability to find records, as listed in 80-1 A is satisf actory. l l Previous Recon =endations We reviewed reco=mendation 85-2 with Mr. Bob Dwyer. Licensed
- 0perator. This ,
recommendation addressed the control of operator aids and the review of the P-250 computer user's canual. and was closed. Ve discussed recoc=endation 86-1. tegarding review of the QA audit progran, with Phil Szczepanaki. We also reviewed NSR3-Pl. "Review and Audit Rasponsibilities", and Revision 12 of the HSR3 Charter. This recommendation was also closed. Declined Licensing Asendment Ve discussed with Tin Andreychek, a Vestinghouse Contractor, a denied Technical Specificatica change concerning auxiliary f eedwater b6rdware modifications. No insurance concerns were identified.
%7 Facility Tour
__ Ve took a facility tour with Victor Taylor and Jerry Osborne. We toured the Auxiliary Building. Radvaste Areas. Radiochemistry Laboratory. Control Room. and Turbine Building. Generally, housekeeping and plant conditions were average to worse than average when compared to other stations we routinely visit. We noticed the effort to reduce the amount of contaminated areas, but continuing effort is ceeded in this area. 37 The posting of standicg RVPs (Radiation Work Pernits) and special RVPs was noted at the radiation control point. Radiation and contamination areas were N7 properly posted and barricaded. The radiation / contamination surveys were ; current in terna of the requirements of plant procedures HPSIL 1 and 2. i
) If, upon f risking, an individual sets of f a f risker alarm, it is v e ry important that notification instructions are readily available. Prisking C3 instructions were not observed, therefore the followieg suggestion is made.
Joggesticn Prisking instructions should be posted at all f risking stations. (ANI/MAELU Criterion 8.7.2.3) We noted the following Radwaste concerns while on the tour.
- 1. The Radvaste Control rocm (669 foot icvel) had several gauges which indicated offscale and/or had bent needles.
- 2. Hold orders for repairing radvaste system pumps were dated as early as January 5. 1986. .
- 3. Inconsistencies in labeling (use of dymo tape and dif f erent numbering systens) were evident on the radvaste control panel.
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l . { Mr. D:vid R. Marks Pego 5 April 15, 1987 ' o
- 4. A radwaste sys'tes temporary hose that was installed in 1982 remains a temperary modification.
- 5. The amount of DAV (Dry Active Waste) to be processed is very large.
We discussed these observations and other items relating to radwaste with John Qualls, Radwaste Control Section Supervisor. He pointed out recent improvements in DAV compaction ration and planned enhancteants to the radwaste program. It was evident from these discussions sud from tho' size of r.he radwaste group that radwaste is a low priority. This is reinforced by the tour observations. Additionally, we learned through discussions with kadiological Controls that liPSIL 36. "Radwaste Segregation", is seldom, if ever, used. Sequoyah should consider raising the priority of radwaste work. Ve may review this area in more detail during future liability inspections. We made several observations while touring the Radiochemistry Laboratory.
- 1. General lab cleanliness and neatness was below average.
- 2. Several expired prepared reagents were present, contrary to station procedures.
- 3. Several prepared reagents were not labeled in accordance with station procedures, lh 4. There was a significant crack in the glass of one of the fuma hoods.
N Ve did not have time to discuss these items with Chemistry personnel. We did state these observations at the exit meeting. We may review these areas in more detail at a future liability inspection. Ve observed the control room to be generally quiet and orderly. We toured the turbine building af ter the exit meeting and found it to be very clean and well maintained. g Environ = ental Monitoring 7 v On Friday. February 27, we presented AN1/MAELU Information Bulletin 86-1 "Environmental Monitoring Programs." to TVA corporate environmental personnel. C Rick Piccolo, ANI Health Physics Manager, joined us f or the presentation, which was well received. The results of that meeting will be forwarded in another letter. O Ve have su==arited our concerns in the enclosed Attachment. Please provide responses to these items and the suggestion within sixty (60) days. We appreciate the cooperation of the Sequoyah staff. Very truly yours.
. Mi' Kurt H. Larson Facility Engineer
- KNL/1gg Attach:ent cc: H. Abercrombie. V. Dudley, J. Hof f can H. Higgins. J r.
l* .
- I
, Attachment Concerns to be Addressed l l
Sequoyah Nucisar Liability Inspection February 23-27, 1987 A. Modification Process .
- 1. Please explain the purpose and advantage of the most recent reorganization of the modifications group.
- 2. It is not obvious vbether or not suf ficient management energy has been expended to address and resolve communications problems between the plant and engineering. Please explain what actions have been taken to solve these typse of communications problems.
- 3. The people ve interviewed were not in agreement as to who was ultimately responsible for prioritizing and scheduling modifications. What is being done to resolve this situation?
4 The final DCR (Design Change Request) and ECN (Engineering Change Notice) closecut processes do not appear to formally consider the user's needs. What actions vill be taken in this arest , bs l B. Temporary Modifications
~~
- 1. Kany temporary modifications incorporated before shutdown remain in place in the plant. Why have these temporary modifications not been l
converted to permanent modifications? l l PO 2. The guidelines for issuing a vaiver for DCR submittal on a , long-standing TACF (Temporary Alteration Control Porm) were not I ~7 clear to those personnel interviewed. It was not evident as to bow i y*. long this waiver is good for, nor was it clear as to how many successive waivers can be grantad. What is being done to resolve ty these situations? l C 3. The process for getting a TACF DCR vorked on ";4 not clear to those interviewed. What is being done tu resolve this? C. Modification Package Revies
- 1. It was not evident that tF , PORC (Plant Operations Review Committee) members f eel responsible for reviewing modification package USQDs (Unreviewed Safety Question Determinations) in great detail to ensure that an Unreviewed Safety Question does not exist. Vhy is this the case?
- 2. No agenda is provided to PORC members and alternates before meetings are held. Please explain why.
- 3. Modification workplans are not reviewed by PORC members prior to PORr meetings. Please explain why.
9
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m _ .m ENCLOSURE 3 r Y l l k e
st ' 15358 Chestnut Street Towers.II, ,
' September 11, 1987 t
-Marsh & McLennan. Inc.. '
l1221. Avenue of the Americas
'New York,?Of 10020 Attention: 1Mr. Luke Sanna
- I CONTRACT 77P66-142911 (f.d! POLICY #NF-247)'- NUCLEAR' LIABILITY INSURANCE -
SEQUOYAH NUCLEAR PLANT - FEBRUARY 24-27, 1987 INSPECTION Enclosed art TVA's comments on the subject inspection report. We note that there were no recommendations in the report and are of the opinion that the. -t types of. concerns expressed would have been better addressed at the exit conference. Therefore, in the future we request that such matters be handled in the exit meeting. 1 Please:cenvey cur cornents to ANI. Very truly yours, !
.. friC'er! dtned by i Dcvid H. Marks David H. Marks. Supervisor- i Nuclear Fuels Section e
e
ATTACHMENT SEQUOYAH NUCLEAA ?!MT (SQN) ANI NUCLEAA LIABILITY INSURANCE PEBRUARY 1987 INSPECT!CN A. Modification Process
- 1. Please explain the purpose and advantage of the most recent reorganlaation of the modifications group.
TVA Response: This concern is addressed in attachment A (Volume 2 of the TVA Nuclear Performance Plan. Sequoyah Nuclear Plant, pages !!-1 and !!-2). Other actions taken by the SQN Modifications Branch in this area are listed below.
- 2. It is not obvious whether or not suf fielent management energy has been expended to address and resolve communications problems between the plant and engineering. Please explain what actions have been taken to solve these types of communications problems.
TVA Response: The SQN Modifications Manager designated Jim Robinson. Assistant IT Modifications Manager. to serve on the staf f of Doug Wilson, troject Engineer. Division of Nuclear Engineering (DNE) as a 11alson between
,, DNE and Modifications. Walter V. Horn. Deputy Modifications Manager, now attenda the daily plant scheduling meetings to coordinate c3 sativities between plant sections and Modifications.
3. The people we interviewed were not in agreement as to who was CD ultimately responsible for prioritising and scheduling modifications. What is being done to resolve this situation? TVA Response: C C' Attachment B was provided to each Modifications manager to discuss with his employees. F' 4 The final DCR (Design Change Request) and ECN (Engineerir.: Change C3 Notice) closeout processes do not appear to fornelly coneider the user's needs. What actions will be taken in this area? ' TVA Response: A procedure. SQEP-60, "Handling of Modifications Using Design Change Notices." is being developed to help correct this issue. . e
J
-B. . Temporary-Modifica'tions~
-1..
Many-temporary modifications incorporated before shutdown remain in Lplace in the plant. Why have these temporary modifications not been converted to permanent modifications? TVA Response: A' commitment'was made to clear pre-1984 temporary alteration centrol forms (TACFs)1by the end of unit 1,. cycle 4 operating period. Temporary modifications are converted to permanent modifications on a priority basis. Currently, the< highest priority is to safely ~ restart and operate both units.
-2.. The guidelines for issuing a waiver for DCR submittal on a long-standing TACF vere not clear to those personnel interviewed. It was.not evident as to how long this waiver is good for, nor was it clear as to how many successive waivers can be granted. What is being
-done to resolve these situations?
TVA Response The guideli,nes for handling TACFs are listed in Administrative Instruction 9_(AI-9). A copy of AI-9 is attached (see attachment C). We believe the existing procedure is adequate.
- 3. The process for getting a TACF DCR worked on was not clear to those interviewed. What is being done to resolve this?
TVA Response: The process for TACF DCRs is identical to all DCRs. Prioritizing work requests was addressed in attachment B. C. Modification Package Review
- 1. It was not evident that the PORC (Plant Operations Review Committee) members feel responsible for reviewing modification package USQDs (Unreviewed Safety Question Determinations) in great detail to ensure that an Unreviewed Safety Question (USQ) does not exist. Why is this the case?
TVA Response: We do not agree with this conclusion. PORC members do receive USQDs in suf ficient detail to ensure that no USQs exist. USQDs for ECNs are prepared by DNE and are received not only in informal PORC meetings, but special attention is given to the USQDs in the final PORC meeting. USQDs are prepared by persons who meet minimum qualifications goals as specified by SQA119 and are certified by the Power Operations Training Center (POTC). e e
9
-3 ,
- 2. No agenda is provided to PORC members and alternates before meetings I are held. Please explain why. j TVA Response:
PORC meetings are generally held twice daily. The morning PORC i . meeting does not use an agenda since each item is discussed in great : detail, including scope, required c.esting, review cycle. USQDs, and f other important items. For the af ternoon PORC meeting, an agenda is ! used to schedule discussion of routine items. In summary, an agenda f is used when appropriate, but discussions are not limited to those $ items listed on the agenda. ;
! 3. Modif! cation'workplans are not reviewed by PORC members prior to PORC {
meetings. Please explain why. p 1 TVA Response: f 1, Most workplans are not reviewed by the PORC members themselves before ( the PORC meeting. To fully understand the answer to this topic, you i f r, must understand the entire PORC review process. A vital part of the PORC process is the informal review performed by various plant , t- sections as detailed by AI-4 and AI-19 before the item is considered i by the formal PORC. This review by cognizant, responsible persons is 4 a vital part of the PORC process. It is not considered feasible for PORC members to personally review every item that come s to the f si CD committee; however, it is important for the plant manager to have a N total PORC process that ensures a proper review. We believe we do. O
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7 (
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- II. CONCUCT OF SECUOYAH ACTIVITIES 1.0 STRENGTHENING SEQUOYAH NANAGEMENT AND ORGANIZATION TVA's revised Corporate Nuclear Performance Plan sets forth the new TVA nuclear pows organization that will correct deficiencies L in corporate support activities. Consistent with the y restructuring of TVA's corporate nuclear organization to provide for effective management of its nuclear activities, the Sequoyah organization has also been restructured. The orcanizational chances discussed in Sections 11.1.1 and II.l.2 have acccmolished E a strenotnenino of corocrate succort and site line activities and acnieved consistency between corocrate and site functions.
b y~ In a number of areas, Sequoyah managers and their organizations i lacked clear assignments of responsibility and authority. i Accordingly, efforts have been undertaken to clarify each 1 manager's area of responsibility, establish accountability and J
- assure resources to perform assignments as discussed in Section II.l.3.
K F g - Finally, in some Sequoyah positions, managers and supervisors did not have the desired level of plant knowledge. As a result, TVA E continues efforts to improve the level of plant operations and - systems understanding among line managers and supervisors as f discussed in Section 11.1.4. h 1.1 Strenothening Functional Succort [ Secuovah nuclear site suoport organizaticns have been E _reorcanizeo into functicnal decartrents___t Jt_g geralfy parallel the functional deoartments in TVA's nuclear E - heacouarters, hhere applicable, each site support organization receives technical direction from its reigective corrneato dapar+ ant the Smc3e St u 5 - J Olrector is responsible for planning, schecuting, coordinating, and providing project direction for the~ ^ activities of the site support organizations. Tables 1 and j J 2 show the revised Sequoyah site and nuclear plant organizations.
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Revision 1 The Secuoyah Site' Olrector approves and controls the activities conducted on site, He has the authority and responsibility for ensuring adecuate staffing of the organization and ensuring the safe, economical, and efficient operation, maintenance, and modification of the facility within the policles and guidelines . established by the Hanager of Nuclear Power, The Site Olrector directs the activities of the site to ensure the site is in compliance with licensing commitments. TVA policles and directives, quality assurance requirements, and applicable local and state requirements. The Site Director develops and implements site programs to ensure the performance and documentation of site activities in accordance with established quality program reautrements and policies. The Plant Manager, Site Services Supervisor, Manager of Projects, Planning and Scheduling Supervisor, Financial Planning Supervisor, and Personnel Services Supervisor report directly to the Site Olrector. The site Project Engineer, Licensing Manager. Site Quality Manager, and wo dification Manager reDort to the Sit _e
- 01 rector for dav-to-dav functional suDervision. The site Olrector maintains an interface witn the Olrectors of Nuclear Enotneering, nuclear Saf ety ard Licensing. Nuclear Quality
" Assurance. Nuclear C0nstructien_ and other IVA organizations to ensure ef f *c tive imDiementatio9 of cercera te Coa ls anQ
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To ensure effective and consist:ent design and engineering control O a t Secuoyah, design engineeringi personnel and functions have teen
) placed under the Otrector of 0FE who reports directly to the ; Manager of Nuclear Pcwer. To ensure that imDiementatten of plant design cmances at Secuoyah is consistent with establisned TVA ,
C 00TY- Oractices, and Drecedures and conforms to applicable Ncc , i anc receral regulations, site modificattens activities at ll ;- Secuoyan nave ceen Diaced under the Olrector of Nuclear ,; Cons treetten wno reports direc tly to the Hanaaer of Nuclea,r
! C .?cwer. Io ensura e(f ac t bre_.and - 1 sient_ app 1"
- Ion of tM i ll cuality assurance program, site quality assurance and Quellty I
ll I) (, control functions have been assigned to the Olrector of Nuclear Cuality Assurance who reports directly to the Manager of Nuclear l- Power. TVA has placed responsibility for TVA nuclear regulation o and licensing functions for Sequoyah under the Site Licensing Manager .no reports directly tc the Olrector of Nuclear Safety and Licensing. The Ofrector of Nuclear Safety and licensing i recorts to the Manager of Nuclear Power. il j Io ensure effective and CCnsistent program and technical I g direc! ion et Secuoyan, the Div1',lon of Nuclear Services has been f assigned corporate responsibilt ty and authority in such areas as radiolcgical control, system operations (fire protection, jf nonradiological environrental control. Industrial safety and j security), emergency preparedness, management systems y 8 (configuration manager ent. Information systems, records managemen t , and offl C e admini', t ra t ion) , the nuclear procedure g system and nuclear fuels.
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-^ in ,% Amen + 8 r April 9, 1987 i All Modifications Managers
Subject:
SEQUOYAH NUCLEAR PLANT (SQN) - ANI/MAELU NUCLEAR LIA INSURANCE INSPECTION OF FEBRUARY 24-27, 2987 During this inspection, there were some co=ments madr to the inspectors by Modifications engineers and managers about prioritizing and scheduling work that concerned them. The following is the way work is presently handled in Modifications:
" 1.
The direction that SQN Modifications receives on how to do work is the responsibility of the Division of Nuclear Const.ruction in Knoxville.
~
2. The direction when it is to be that worked SQNon Modifications is the receives responsibility of on the what SQN toSitework on and y Director. The the SQN workSite in SQN Director.Modifications is prioriti:ed and scheduled as directed by I bbm ~
- R. W. Olson ~~
RWO:VLH ec: H. L. Abercrcuble O&PS-4 Sequoyah
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M ?w ENCLOSURE 4
NUCLEAR ENG NE!::iNG DEDARTMENT v Wu Samocen vee h.cene T i._. S v [i_ O SURT C.PROOM.CPCU heneon one cNef Laeevan omeer February 11, 1988 Mr. David H. Marks Division of Purchasing Tennessee Valley Authority 1575A Chestnut Street Tower II Sixth and Chestnut Stresta Chattanooga, TN 37401
Subject:
ANI/MAELU Nuclear Liability Insurance Inspectio'n Facility: Sequoyah Nuclear Plant Policy Numberat NF-249/MF-102 Date: February 3-5, 1988
Dear Mr. Marks:
Mark Poirier, Paul Krippner and I rscently conducted 2 nuclear liability inspection of the Sequoyah facility. Our primary objective was to determine what safety review oversight responsibilities are held by various site and . corporate groups and how these respCnsibilities are implemented. We also discussed the results of the last Sequoyah nuclear liability inspection with site and corporate management. We observed signs that indicate the 3uclear Performanca Plan is being icplemented onsite, and we also obse rved appropriate support for the recommendations offered in our Decem1er 24, 1987 letter. Several corrective actions are already being i=plementeil. Generally, we noted i=provement in the functioning of the PORC (Plant Operat: ions Review Coesittes). No new recommendations were tr. ads. TVA needs to demonstrate that the changes i=plemented.at TVA vill result in significant i=provecents in Sequoyah's performance in the near future. We intend to continue to monitor the performance of Sequoyah as startup l approaches. In order for this to be timely, we ask that you forward to us, on an ongoing basis, all correspondence that is generated as a result of the l stonitoring of Sequoyah's perfor=ance during this phase, such as the results of l the ORRG's (Operational Readiness Review Group's) monitoring of plant operations. We ask that you forward this information to us the same day that i The Commentsin tnis tetter are casod ucon CCecitient.ptJCt:Cos and p Cpertyobserved orinf orrmation raade avattable ettne time of the inspic Which wat rrede for urCerwriting purpCles, these Comr* enta do n ot t urpCrt to list all haz are s nor to ind!cate th at Other hasarde do not em 11 : I felcorstDility 16 assumed for the CCfrectl09 or C0ntrolof 49y Condit!0'le.prattlCet or property, and no ther the traking of the lospection n0r : red 0ft or correlg0ndence thereon sntil COnStlt6te SS urdertsking,Cn Schalf of or for the benefit Of tPe lasured or Othere,to determine or ner l
- l that the facilitiet, Cperttl0nt or prCretty are sa'e or harmful, or tre in Compflance with any few, ru's or regulellon, or in Compftence whh i techalcal specifjCell0n by any government SWthertty or egency, ,
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Mr. David H. Marks Page 2 it is garterated. The results of these types of performance evaluations will help ANI/MAELU in its decisions regarding Sequoyah. TVA Presentations to ANI
- Dick Gridley, Sill Hannum, and Bob McKay provided us with several
. presentations related to regulatory activities, safety review. and the procedures rewrite' effort. . These presentations were very informative and i= proved our perspective of where TVA has been and is going in these areas.
Coerstional Readiness Review (ORR) Ve discussed the ORR with Frank Fogarty and Joe Bynum. We discussed the purpose of .the ORR the composition of the ORR team,3 the nature of the review,
- the results of the ORR, and the draft respense to the ORR report.
We vera satisfied with tha thoroughness of the ORR. The findings of the group , closely paralleled those of ANI/MAILU, particularly in the area of standards of operation. We have a better understanding of the standards being utilised for evaluating Sequoyah plant restart and subsequent excellence in your hardware, people and programs. As indicated in our December 24, 1987 letter, Sequoyah is moving toward operational readiness. Continued diligence in i=planenting the planned corrective actions is seeantial for achieving operational readiness. We intend to closely monitor the activities of the ORR team during plant heatup. The tea ='s critical avsluation of Sequoyah's perfor=ance during this period will assist us in evaluating our insurance risk at Sequoyah. >
' ?lant Operating Review Staff (PORS)
We =et with John Sullivan and Mike Cooper to discuss the purpose of PORS the 1 group's organization, the backgrounds of the people in PORS, the types of activities FORS is engaged in, and the futura plane for PORS. We were most interested in the type of safety review oversight responsibilities held by the 70RS, particularly with regard to the PORC. l It was apparent from these and other discussions that the charter for PORS has not been fully developed. The POS (PORC Oversight Section) does provide oversight in the area of USQD (unreviewed safety question determination) and procedure change review, but it was not apparent that strict rer,ponsibility has been given to PORS in the area of direct PORC oversight as a staff function to the Plant Manager. This type of oversight responsibility could include itens such as for=al critiques of PORC meetings and evaluations of overall safety review processes currently being used. ANI/MAILU encourages the development of a PORS charter that includes this type of specific oversight responsibility for PORS. The group should be used as ef f ectively as possible to help improve the perf or=ance of plant operations. We ask that you send us a copy of the PORS charter when it is written.
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1 Mr. David M. Marks Pese 3 PORC Meeting ) I attended the Tebruary 4 PORC :eeting i= its entirety. I saw i=provements in the quality of presentations and in the amount and quality of group interactions. Continued improve = ant can still be =ade in the areas of reducing the number of people at the =seting (28 at cne count), better participant preparation for the =esting, ensuring all me=bers are present, and increasing vigorous discussion. We vill continue to monitor these areas for further signe of improvecent. Nuclear Manager's Review Group (NMRG) We discussed the KMRG with Dick Mulles. We reviewed the group's purpose and organization, the experience level of NMRG personnel, the group's method of functioning, and future plans for the NMRG. We were particularly interested in the role the NMRG will play in evaluating Saquoyah's future performance in the areas of weakness indicated by the ORR. It is our undersranding that the NMRC will continue to interview personnel regarding the i=plesantation of ORR corrective . actions, will review all ORR areas in the future, and will perfor= ce=prehensive annual reviews of station perfor=ance. AN /MAILU will =onitor the results of these evaluations and factor them into our decisions regarding Sequoyah. Mr. Mullee agreed to allow us to review the results of NMRG reviews. We ask that you forward these documents to us as soon as they are available.
- Nuclear Safety Review Board _(NSR3)
We discussed the NSR3s with 3111 Mannu=. These discussions included the N5KBa' purpose organization, membership roles, activities, and the types of s recommendations made by the NSR3s. Our prinary concern was the role taken by the Sequoyah NSRB with respect to
. the functioning of the FORC. We reviewed the minutes of NSR3 =seting nu=bers 88 through 97, with particular emphasis on the observations brought before the NSRB and the resulting actions taken by the NSR3 with regard to the PORC.
Prom our review of this =aterial and the discussions with Dr. Hannum, it is evident that the Sequoyah NSRB vas aware of deficiencies in the functioning of PORC and has been active in working to resolve thes.e deficiencies. We strongly encourage the continued NSRB monitoring of PORC activities and the subsequent issuance of NSRB recoz=endations to ef fect i= prove =ence in the PORC process, as appropriate. We will continue to follow the NSRB's activities in this area. We ask that you forward to us copies of NSRB correspondence regarding PORC, as well as Sequoyah SSRB minutes co=mencing with meeting nu=ber 98. F e w-- -1 m . - -, - - , , w-_w y----- , - - +------ - - - _ . - - - - . - . _ _ - - - - - - . . - - , . - - w,,,,,a-.r r,- - - - - ,-.-,6, - . - - , , -----,--5
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m Mr. David H. Marks . Page 4 . Shift operatina Advisor (SOA) Program Paul Krippner reviewed the SOA program and the accompanying administrative instruction AI-50 with Joe Benum and Larry Jackson. The SOA position was established to =onitor the effectivaness of implementacion of AI-30. Nuclear Plant Conduct of Operations. ANI has noted the creation of similar positions at several utilities. We recognize the advantages of the SOA position, and we encourage its use at least through Unit 2 startup. Paul reviewed the AUO (Auxiliary Unit Operator) Watchstanding Proficiency Certification Program for content and co=pletion status. The quality of the potential questions used in testing and the minimum acceptable performanca criteria used in the evaluation of students appears to be adequata. Successful completion of the certification process by the AUOs should adequately address the ORR findings in that area. Perhaps more importantly. it should result in a highly qualified group of AU0s which will aid in Unit 2 startup. Sutmary of Requested Informatio_n Again, we ask that you forward' to us, on an ongoing basis where appropriate, the following material as soon as it is available.
- 1. Subsequent ORR evaluations and associated responses
- 2. FORS chartar
- 3. NMRG review results and associated responses
- 4. NSR3 correspendence regarding PORC, and NSRB minutes starting with meeting nu=ber 98
- 5. All other correspondence and reviews associated with Sequoyah's performance prior to startup.
l We offer our appreciation to the corporate and site staffs for their l availability and cooperation. Very truly yours,
/ e Kurt N. Larson
, Facility Engine.er I KNL/1gg cc: H. Abercrombie V. Harklarcad H. Higgins, Jr. C. Mason L. Sanna e
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) ENCLOSURE 5 1 e 0 I
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[ Mr. Steven U ite H&:4larofEuclear20Ver I s*.tsseeYalleyAuthority ^ 6N 38A tookaut Place Chattanoces. TN 37401
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UEA Re laquoyah Nucisar Plant MM MI NT 247/MI-102 L ,, Nu:ltar I.iability Insurs:ce hs;ectica cf Dece:ht: ! 11,19!7
&& B b; DearMr.'s'hital w Thank you for TVA's response to vvr December 24. 1987 reco cendation letter.
Cur evaluations of each ites are outlined in the enclosed Attach:ent. f h su=ary, MI/XA!!U finds TVA's respetses'to he prc:;t ahd I: addren the W aren identified by our rece=endatic::. TVA ed BI/XAIW have additicui
. ver's to do, hcVever, is order to cc:plately rescive all cf the issues raisti by the rec:::stdatic: . In particular, we vish you to c:: sider the :::ltar M. insurasu issues a!!resud i: rece=endation 6711.. The ufsty reviev pr:ceu i: eur judge:ent hn adequately addusud :: clear safety inuu, hcvivir MI/XAILU :nds to gain a htter appreciatics for the :a=tr 1: which insurance inues have been ruolved. To this a:d, vs have pre;:nd that we
~ batterundersta:dy:Urtechnicalprogra:sasvillasselt:tivelyrevievi:3
.. a past ?OrLC sativities to verify the inplementation of your progrs=s.
For several of the reco: endations, additional infor=ation is required which describes in detail RYA's preposed actions. Va an's that you provide written C0=tr.tl t3 cur IV&hiti .: cf 70ur !ts;0:lil Vithin s1Xty d4ys. Yarytrulyyours, w-Ronald sanatore RS/ lab Attachment ecs !.. sanns
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m 1e88 44193*C140t'e4 erSAF 0*** e s.,e t.e 2.s/ m , ,'afasse ~ / ,.., a.tnenty es speaty. , :.:n / =." = . v- " m c.~> -
i.sh. ;~: p' Mr. David H. Marks
'R Tennessee falley Authority
__ Page 2-
- n d.gn u ATTACET g SequoyahNuclearPlantIiabilityIns;setic:
Date:hsr811,1957
@, MI/MA!!.U's Evaluatie:s of WA's Res; :ses @d ,w Recetsteditien 87-1 The Plant Manager or Assistant Manager. CNP. should chair all PORC nestinte.
{. T7 Alesse:: M: The Plant Manager has chaired all P010 zestings since assuming his position in R MIC 3ove:bar 1987. TVA vill cc:tinus this practi:e with the Assista:t Xa: ster of ONP as his altsrasta. In the unlikely event that neither of these individuale
?p(.' is available ad a P010 senti: is necessary a substitute as:ior mauter.
ap;01stst by the Fla:t Manager, my chair a 701C :seting. R* :
+., ANIEvaluati::
f
~, TVA's respone is satisfactory. A:y substitute se:1er 2:ager appoi:ted to be aP01Calter:stechair:A: should be ex; erie:: d in ceducting P010 : eti:p ar.! cegnizant :d su;;crtive of the changes being sade 1: the way PC1C C;efitti.
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Reeemeendation 87-2 A11 PORC 3esbere should be required to attend 701C seatinssi the use of alter:tteslh0uldCoals. 9' -:. TYAlis;C:54 1 The Pla:t Manager has asphasized to all regular PORC meshere that they are not 8 to uss alternates except in unusual circumstascos such as leave, sicknees, or emergencias. 70R0 seatings vill take precedence over other nortal work j activities. Alternates are being randesly scheduled to attend regularly scheduled PCRC 244tital at f.cn votica teshers 80 that further experience tan bechtai:adinthea:ha::sdPORC; recess. ANIEvaluati::
' TVA's response to this recoscendation is satisfactory. Alternates should not atte:d 7010 :eeti:ss until the esetings have improved to the point where the PCRC process is working well.
Reconnendetton 87-1
- All unnecessary pareennel should be excluded fres PORC seatings.
TVA Response ( t r Unneessaary personnel are excluded f res FOR seetings. The P0EC chairsan enforces this practice. POR3 along with senior senagere designated to perfors W
p Mr. David H. F. arks II:seste Valley Authority Page3 70K; oversight (seeTVAResponsetoRe:02etdation 87-12) vill : :itor g:d --e3, w pr0VidefildbachC:thisrtCC:nondationtothePCRCchairman, w.:
. .e ANIlvalutt10:
y IVA's res;::se is utisfactory; h:vever, approxt:stely 26 people, :asy of w did :et a:tively participate, atts:ded the Tehrcary 4,1985 ?010 : siting. Ihtrewastochstryabitatte:;tduri:3 the testi:3 to deter:1:a if these vi$ 1:divihals:tededtohapresent. .@; .3
' The ittt t of this rec =stdation in to help create a meeting environment that di-2.
to eenducive to professtenal interactione. Positive action needs to be taken by ths ?01C chair:a: at the begitting of meeti:gs to e:sure that all M unt:tssary;tric=elareexcluded. g qui leC00e:dati0: 87-4 . C .: s Those organizatione that typically present items to the FORC should be fer: ally i:structed as to their respe:sibilities a:d ex;actatiens regarding PC10 present6tions. 4 and Rec:=e:datic: 87-3 Thesewho;;est:tita:stothe7010shouldberequiredtogivefor:a1 prett:taticas to the C =ittle. TVAliste:St 1;f IVA Igrets with AN11 ace =endatie: 87-4 and 5 and guidance for presentir.: ittas to PORC is being incorporated into A1-48. "Plant operations Review C:=ittee (PORC) Charlsr". This revisie: has bes:;tepared a:d ap;:: val is
, , , , u;ected by Pehr:4ry6,1936.
AX1 Ivsluttie: In tilition to =edi'ying A!-48. training should be providad to 701C saubers. Alternates, and presenters. Please provide a revised AI-48. as well as a description of the training P01C nenbers, alternates. and presenters will rtCliV4. Recemendatien e7-6 Thoes who present iters to the PotC should be required to have a high level of knowlsige of the ites being presented. TVA Rooeree The enhanced guidelines for PCRC presentations in response to ANI reco:sendetter.e e7-6 and e7-5 vill resolve this recessandation. Presenters are much more avere of the type and level of knowledge required by the PORC than they were during your Dece=ber 19 7 inspection. The FCR0 Chairman vill continue to esphasite this area.
, Mr.Ot"id1.v.atis Ten:essee 7411sy Authority 3], ?sge4 ANr ! valuation M Yrecedural guidance regarding this issue is important. but again presentare ? steuld be :ade directly avare that a high level of i::vledge of the presented 4 ite:is required. We did observe a:1: prove:ent h the level of kncvledge of pi the prese:ters duri:g the february 4,1988 PORC :eetir.g. Continued , it;teve:ent is necessary. .q.
y
.,gg Rece=a:datie: 87-7 p;. _
s M~ last :i:ute 7010 review ite:s ("valk i: ") should ha :inimised as much as pssible, t TVA Response m g' .' - Last :hute review ite:s are discouraged by PORC. Agends items are presented first. The P010 chair:::c:iters P010 attivities with reprd to "valk in" ite:sanddeferssuchitemsu:tiltheycanbescheduladforasubsquent
- eeti:2. There:aybetruea:ergencyorhighpriorityitemsthatthechairssa villch::setoreview.
ANI rvelvatten This res;;:se is satisfactory. ANI/MAILU vill verify this practice through
. review of :eeti:g si:Utes 4:d cut attendance at future :eeti:gs.
L Ree:=e:datie: 87-8 . Ixpedite the traini:g of PCRC :::hers 1:d alter:ates i: their specific ce=ittee resp::sibilities (for ext:ple, review of c: reviewed safety questice issues).
.,., g T7A Response All PCRC members and alternates are required ts take Qualified Reviewer (QR) and (*nreviewed Safety Questics Determination (USO:) training with all training to ht cCQ1sted by Ishruity 29,1988. This requira:ent has been incorporated 1:tc Al-48 revisicas which are expected to be a;; roved by Tehr:gry 8,1988.
ANIEvaluatien This response la satisfactory. Please info m us of the status of this training. Rete =nendation e7-9 Increase Potc member aceovatability for perforsance during PORC se, tins ** TVA Response Individual nocher perforsance during PCRC testings to tonitored by the FORC cheittan. rephasis is placed on individual knowledge and interaction during PORC seatings with speelal esphasia on UsQDs. Root cause Analysis and
Mr. Dtvid H. Marks a Ter.essee Valley Authority Page 5 a .' Corrective Actie",, icic n: bats vill bt held accountails feri in:vlid t of
- sIfttyItquittituttintht!!I!ttOfIX;trtist. Ittdback to the 1*.dividual
- i ., 1*.d hit tanager is providad by the PORC chairman.
k A.v! Evaluation
',- This response is satisfactory however, we emphasise the importance of previdit.3 feedback ditattly to PCRC menbare regarding their performance during
~D K meetings. Mathere should also be infor.e4 that their sgf tty Itvity res;C:sibilitits are Cf para: cutt i:pertance. Typically, ?CR0 :t:ht!I art --J. htid ACC0tatible !ct their ICRC perfor.a:Ct through rarfortante avaluations. .;34; R,s set =endatien 87-10 All POIC stating participants should be required to review seatin5 materiale, incit.fi:g previ:Us etsti:g situtts, prior to :tttings.
.w
'NA 1meest A117010 :t: bars are ::V required to revity ;trtist:t :ttti:3 uterials i::193!:3 age:das, previcus :itutes and othar backup uteri:1, prior to
- ttti:gs. This require:ttt has best incer; orated into AI 48 raviniens which art 4I760(41toh48;;r0Vidbylib!uary8,19!$.
ANI IVsluat10r. This res; case is satisfactory. Ve vill verify this practice in the future.
- 4. KtC0::taditie 87-11
.c All 20I0 ".ithtts a:d altitutit sh0uld he pr0Vidad cepiss of : sting minutes.
regardless of erhether of not they attended the respective meeting. TVA Reerense All ?010 :t:htrs a:d altartatas art being previded eeples of the =settes ti:UttstoItvity. Ihis requirt:stt has best incer;0ritti it.t3 AI-!8 revisi::s which are ex;tited to be approved by Tehrury 8, li!!. ANI!valuatiet This response is estisfattery. Ve vill verify this practice in the future. Reces eedation 87-12 The resular attendance of non-PCRC netbare who have considerable estety review experience should be required in order to avstent the esotteg and enhance the quality of interactione and docieione and ser- examples for others. and Rece=endatien 87-13 For al critiques of each PCRC costing should be conducted for the purpenas of
p' i g.. E!. DaV M H. Marks Tenneseie valley Authority Fait 6 M
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' idlatify!al stritgths a:d Vtaksasses of the group ad the idividualt :Volygd 1 AL ad to provide for futurt 1".prCY4:4 ts t0 the safety rtVilV functiet.
c; TVA Rossense j-m, Experienced nuclear managere knowledgeable in the areas of Olq36 and PCKC y c;tratio:s atte:d P010 aathgs ca a seriedi: basis.
- he Asetet.nt xauser of Nuclear FCver,3itt Ditteter, the Assista:t to the Plant Xa:
Altr T, (Development) sed F013 Katager ;tri dically atte:d ?010 :sethgs. 0:e of thess :a: agers atte:ds a F010 :sethg vesily. In additi::, the POR Sectie: of POIS has cc:=itted to have a represe:tative prest:t for each athaduledPCICsaating. 7011 vill provide feenack, including deficiencise CM "T" :Sild and rete:lmandatices for improvement following each echeduled FCRC seating. ANIIVLltatiC TVA's response to recommendation 47-12 is eatisf actory if et least ou ax; erie: ed tar.ager with broad safety review background attende every resularly scheduled PCRC meeting. Ve suasset that they participate dirsetly in the testing discuselone in order to stimulate group interactions and set an ext:;14 for the P01C :a:hars. The participatien of these 34usere le
- cessary i: addit 10: to 1015 at this point. Please identify which (I;trie:ctd :uclear :anagers D'A has selected for this role ad what their respetsibilities vill be.
As ve discussed during the inspection, the intent of reco:nnendation 47-131e ICr TVA to censider havi:3 the.P0a0 chairun conduct a forsal critique af ter each yCRC meeting in order to discues perceived strengths and weaknessee of the group a:d the hdividuals 1:Volved. The :sst effective :sthed perhaps t - v:uld be to have the attire ?01C actively i:volved i: a ec:stru:tive critique 188810:, i:cludi:3 the prestatars. This :sthed of prcvidhg i::adiata, dire:t faldhati (both positive ad algative) is a prove: teel for e!! acting changa
* ~ * # act recessinics good perfor:a:ce. These critiques vould also provida tha opportunity for the chairun to addreas the group and uke his expectatione ans :sthods of eparation t. ara clearly known.
ItCO::tadati0 87-14 A: attica plan shC113 he dtV410;43 4:3i:;14:sttedfortha;;r;osasof independently evaluating the effectivenese of past PCRC activities and establishing corrective actions for noted deficiencies. TVA lesoonee The recommendatione and consente by AMI appear to be focuead on the effectiveness of the FORC process. TVA concure that the PCRC protese does need improvemente and is committed to accesplishing those taprovosents. However. TVA believes that an additional independent evaluatten of past F01C activities would yield little or no additional benefit in defining these improvements. In the poet. PORC has been responetble for reviewing
' procedures, prograas, modificatione. Technical Specification chassee.
revisione to Physical Security Flene, reviatone to Radiological Isergency Plans and a number et other items. All of these ites are developed and M -
a F.r. David H. Y.aris Te =essee Valley Authority Fase 7 gg IsVieVed by the resp 0:sible technical ctga izatic:s as well $ ethat rt y erginitations suh as Divitica of Nuclear Quality Assurance, NSR 4td Division of Nucien Lice: sics a:d Regulatory Affaire, rer exas,1 . a gl4 Technicalspecificationchangeistypicallyinitiatedbytheresponsible g tachaical ottatitatics, reYieved by che Divielen of Nucisar Licensing and melulatory A!! irs, reviewed by PORC, reviewed by the Nuclear Safety Ra w
& Board ud fi: ally ravitved by the X10. A nodificaties vould be reviewe the origi: ster, as well as orga:izatiens responsible for design, ecustructin and cptrati:t.
, Ihtse reviews include in-dt)th technical reviava. In addition 7 to the technical reviews by the initiating orgaattation ud other affected line oraanizatiene, the Po1C and the Nlta provide additional reviews of the Q y safety svaluaticcs.
g
- The adequacy of plast syste:s ud pregica to support safe Operatic 2 hat heta verified threcgh a tu hor of progrua. A very thorough Desigs laseli:a j[
Verification Pr: gras (D3VP) has verified the adequacy of design ud g cc:struction 1:cInding :edificatie:s. The Restart Test Prosran followed the carranddemonstratesatteareshutdownandaccictatsitigaticsf::cr10:s. The Surveilla:ce Instructin Review Presram identified and corrected probiese
~'
with the plant instructione used to dasonstrate compliance with the rechnical Specificatione. The Operational leadineer Review resa alona with the Institute of .tclear rever Operatie:s has Iceked at the readi:ess of the staff to su;; ort testart ud the NRC has cc:htted muy inspectie:s ccvsting virtually every aspect of pla:t c;eratters. These efforts, plus cthers sa:h il It)10yes CC: tern Irctru itVestigatiets indicate that detiefcas affecting saftty have hets ud cc:tinue to he scu:3. ANI tvaluati:n w ANI/MA!W helitys that thera is adaquate overlap httvean :uclear safety C review programs to aoeurs nuclear safety tenuse are addressed. ANI will cC3:1 VetoworkwithTVAtobettera;;reciatethenuclearsafatyreviev
, picctil.
tece = edaties U-15
. . . I All;trs:nel attries to Radiolegically Cc: trolled Areas shculd he gover:ed by j
Radiatien 'a'cri Per:its. (ANI/MAllU Criteries 8.9.2). TTAISI;0tse Sequoyah plane to implement a computerised access control systen in late 19es. At that ti:t Ve plan to C0ver all entries 1:to the RCA by l'e7: (for verk ' utivities ed alti:istrative purp ses). As you are svare, all pers:=e1 enteries MA's are issued destaatry and subject to r7A's Radioloaical control program. Until the computerised access control systes can be implemented, personnel entries to Radielegite11y Centrolled Areas (1Ca) will be covered by a l Radiation Verk Peruit (RVP) under the following conditiones
- 1. Intries inte radiatten areas where worker exposures are expected to
. excesa 30 ares / day whole body or when extremity sonitoring to reguired.
I I W -
Mr.DaVidleMarks fat:tssetValleyAutherity a Pagt8 7 2. latries into high radiation area.
- 3. Intries into contamination areas.
Ab _ i. Entries into airborne radioactivity arose. T
~ 3.
ActiVitit$CrOpergti0:lltasksthathgygthepegggtigl{ggggggg(;g sipificant radic1cgical hatards. 6.
'. s I Activities or operational tasks that have the potential for crettLag significant radiological hasards. (sic]
. {[6/s 7. At the distrit1C3 Of thi Kid 03Gr0tp. g p:I Thest require:tsts result is all sig:ift:ast radiological tyn verk activities
'Q2 being scVerted by an M.
- The presett program allevs for inspection type activities and work Cs c:: ce:ts:inated systt:s to be ; trier:td without as l'a7, providtd that itt:s 1-7 ahCV4 d0 tot I;)ly. In f8Ct thi8 Iystes :1ptured esse:11111yallcur station dose for 19s6 and 1917.
AMI EvaluatiC3 TVA's plans to track all 1CA entries by WP usins a new computerised systes should address this recommendation. :he details of this systes will be SV11Ultidd4!it!Ifuturt135pectiOS. Xiatti:t, vs :tti::rt infor:atien to evaluate the currest interi: cc: trol of ICA entry and Rk7s, such as:
^ 1. The process used to concluda that essentially all station dose for 1986 and 1987 vas captured usina the existing system.
~' '
- 2. The C Stroll Ulld to 4:sure all tasks perfcr:td in the RCA Art evtluttad by(Ullifiedyt!!C::tlf0!theliXCrittritl!IttiitIYA'8!!I;0Alti es;stially :u:htra 1,5 a:d 7, htfart the task besi: .
- 3. X4th0dl ussi te varify that tasks is progress in the RCA are being goversed by WP vhen required.
Rac:=tadatten 6716 Radioactive satoriale should not be stored outside except for a short period of time. (AN1/MAILU Criteria 4.2.33.9) TVA tessense Druse and radtosctive weste shipping tasks stored outsida (tear railroad bay) were bains prepared for shipsent. Formally, they are pisted outside just prior to shipment. However, the cask.a obser*3d by the ANI tespectors involved
' a attuation where shipsent of casks containu, radiosetive weste desimetaliter resine was delayed while avaittag charetterisation and scaling fatter W
e
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)
1 s Mr. David I. Marks i Tan:essesValleyAuthority Page 9 l W l
;i.g. J determination in order to comply with 10 CTR 61. This has been completed, and vaste is beina prepared for shipsent.
/-
gyq l$AbeXtBlloradintheradvaateyardcontainexcessmaterialfromoutagne. l Thess bezes are currently being inventeried. The inyantcry is expecttd 10 he { f[* cc:;lettibyF.ay1988,vasteshi;;tdastacessary,andtherassinistastarial 7- 1 appropriately marked and stored in van trailers fer use during futura outages. O ANI Evelvation The situatica surrounding these radietetive sateriale van described to se
$; duti:lthe1:Spectics by 1.ttry Jacksc: and John Qualls, k's also underst::d m
7 vhat verk van required befers this tattrial could it either shi;;ed er stored undercover. Our centar:is that controls need to be estabitshad to anvent this situtics fre: eccurring again, g Co m aat - Fate 5 As a result of this evaluation. ANI has concluded that TVA/$equoyah le f.oving in a positive direction toward operational readinese for the restart of SequoyahC:it2;h:vever,basedc: ANI'sfi:di:38,raavalati:sofstaff res!!: ss te e; state V:it 2 should be cenducted by ifAlsetuerah cuassunt prior to restart. TVA Reasongs The readiasse of the staf f to restart Seguoyah Unit 2 is being evaluated. In
^ August 1937, the Manator of Nuclear Pcvar initiated formal eparational realittat Itview (011) of faqueyah by assigning a highly qualified taa=,
indt;tedent of the line organitatien, to cete entite and review the tualificationandmotivaticaof;srsonnelatSequoyahfl nit 2. This ou Team
! Vas further charged to review the availability of nattestry supporting resources for the este and reliable testina. operation, and saintenance of the plant.
t The preliminary findings of the C11 tasa were made available to the Plant staff in early Oeteher 1987 and the plant i==ediately began corrective atticti. Thefor:alreportwasissuedesJa:uary5,1988heviver, restart ! issues had been identified in the pralininary ra;ert and corrective actions j are cenplats or tsaring cerpletica for all restart issues. Operators have been given special training en the r.eed for formality and dieeipline in operation and ehlf t creve will be receiving special claenroos Lnetruction and etavletor training, prior to restart on koo feeves auth as criticality control.
'A aroup of Shif t Operating Advisore ($0Ae) has been formed to observe and seeist shift crew personnel during heatup. These lea's are managere and former 510's with operating esperience. Most also have experience at other
' utilities. The SCA pregram is a forsal proceduralised prograa and the SCA's have been trained on what is expected of thes. They will report daily to the i W .
Ml l Mr. David I. Marks l Tennessee Valley Authority
.D Fase 10 '
b; '
.g Pit:tF.a:ageraswellastheSiteQualityF.a:ager.
3
. and sa Cen:ent - Pate 5 DN Iht illut Vhich ANI believes should be reviewed is the standards by which m..
TVA/Sagooyah is sesouring its staff operational readiness. It is not evident [D fTCt this inspottien what standards are being used. It is ANI's opinien that TVA/Seguoyah shguld neaIurt it8tif BIL1Est s'J8014tt (Edultry 8tandards for Y,
"2 operational readiness and not against progress r.ade to dets at legssyah.
g These attedards should be censunicated to all personnel and should become the Mi approved yardettch by which TVA/Sequoyah sessures its staff readiness.
>% TVA Resoones R..
4 The TVA nuclear power program is being infusti 1 th talent frC2 a Vidt rat l:
' - Of baChgrCutd8 to pr0Vidt thi Itandards of excel 'nce for the nuclear progras.
the te;uty Site Director Plant Manager. Assista/s to the plant Manager and
' Quality Assurance M uager are exa: pits of such t.'t:t. Inadditien,specisi reviews and assistance by very experienced indivt ula and groups are being tatitoc:;aracura:tivitiestostar.dardsofax:' laces. *he Operational Readitess Revity (011) Itu :d :sthers of the Inst.!ute of Nuclear Power 0;eratien have perfer:ed a very detailed review of :;sratie:a1 readi: sis at
$squoyth.
They have revisved sequoyah against standards of excellence and many improvenante have been nade since the CIA Interin report was nade available in October 1987. The restart requiremente in the CL1 report are substantially cosplete and they will be verified during heatup prior to actually consencing restart of SQN Unit 2. Industry standards of excellsace are incorporated into
. preceduras and training en as c:3oing basis.
ANIEvaluaties In addition to TVA's resposse to these cessante. AN!/XAILU also evaluated the Operational leadiness Review and the associated TVA tanasonest response, the istcr:sticsgatheredduringtheFebruary 3 5. 1988 cuelaar if ability inspection and supplemental information provided te us since the time of this its;s:ti:n. including AI-30. "Nuelser Plant Cc: duct of Ciersticas" and AI-30
"$hif t 0;trating Advisor."
ANI/F.AllU has deter itti that preparatics for !aqueyah Unit 2 restart is occurring by addressics lay deficiencias in hardware. prograns and people. Other deficiencies in thest areas, which have been dessed secondary to Unit 2 restart, are being deferred to poet-reetart action. Concurrently, there is an ongoing effort to address the complex systeste deficiencies which have historically hindered the effectiveness of TVa and $4gueysh tanagstest and operations. Ytratly. AN!/Ma!LU finde that the standards being ut111:ed to guide sad sessure readiness for r$ start of Unit 2 are developed and sensured by key corporate and site sanagere as well as independent groups eush as the 0:1 (0perational Readiness Review) group and F)OLC (Nuclest Managere Review Croup). M -
N ! l 4 37 $% kr.DavidI. Marks Tennessee Ys11ey Authority
&,.g#+>e Page 11 @ The lower threshold of these standards is equiisient to industry norts. The 1, effort to develop standards to guido and sessure the corrective actions for fbg OA$- The standards to be utilised in this effort are standards of .
gg wh. p cs - Secondly, ANI/MAILU finds that the TVA seasurement of Seguoyah staff rendit fCr the festart of Unit 2 is based on the Sequoyah staff's apparent level of Wi readinese coupled with direct corporate managesent involvement, casite gg} contractor example, 30A,support, and CRa. and several long and short ters overeight groups (for NMRG). g .C ANI/MAILU concludes that the supplemental staff described above is secoggary @# to support the c;tratics of Siqueyah I' tit 2 at this ti: w,- integrati:s of hardvart, ;regra:s and ;tepit, a:4 to assure the contin development of high standards. prograze and people. ANI/MAILU does notu tudCral the C0tCt;t of supplesental staff over the long ters, and we vill sonitor the effectiveness of its utgi Ceutat Page 6 - Itan I lladielegical boundaries, in many instances, i,ere not fully edhered to. xany i TCind*0tf areas in the auxiliary building had water running out of the area past the boundary. Othat areas had asterial (hoses, poly, etc.) inside the roped-off areas that breached the vertical plane of the boundary. All of these conditions serve to decrease the senettivity toward radiological boundaries and should not be allowed to continue. TVA tasponse
- Thirl 18 a li$tif! Cast iff0rt unitTVay to i:; rove houssissping and toduce the number of radiological boundaries. Managere are held accc.atahls fct ChitrVitta*.dCoffittingViolationsofradiologicalboundariessewellas
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general h m eist;1ct. Attention to detail in these and other areas is bets: stronaly e:;hasited by sanier plant n.anagement. ANIf.valuatien AII/MAllU agrees that a eignificant effort is warranted to reduce the number of contasiasted areas of the plant which require boundaries. For example. the high nutber of roped off gage paoets suggests a generic issue which should ha resolved. We will be monitoring your ef forts to reduce the number of contasinated areas. Our primary concern, however. Le secaitivity to the control of radiological boundaries. ANI/MAELU believes that more eggreselve action by SQ3 management te necessary to taprove employee sensitivity to radiological boundaries. Comment - Feaes 6 and 7 ve eleo observed a nunber of areas in the radvaste control room that could be improved. a W -
w G i Mr. David H. Mar'n Tennessee Valley Authority Page12
@p y hk J f *Idf0gt3htidtr 8;;3171884 Vas sar'ud "001" in felt.itp pee.
N __ - Apen number of ir.forn.a1 and drac. markinge vera 2444 near evitches and gages with type labels. ,
.:g.a - AJasuery Isid (n:.: l s :7 5,ster 1986.1035) was on the gas atripper feed pump and switch eiace
- te=porary to it very :14. alt.rati.. s1 tt.n on the enes decon pump au switch appears
-5;tst:
4, 481: storagt tt:1 invil 8 :56 via 18411:3 substastiillygrea this 100! 511. Trc:. M. m i-w:, - IVAles:0:le h, - Inforsal labeling usins felt tip pen and Oyso-tape is specifically not M
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allowed. Cperator side are controlled by administrative procedure SQA-142 and 1 prior to restart, e7erations managesent vill conduct an audit of control
.N: *; panele to ensure that only controlled operator side are in use. (
Iht yttf Old E0ld O!dt! C3 4 [4B stri;;tg fasd put) and avitch vae the resu of an inoperable pp *0ttr ttt1Vi*g 10V priggity f;g rg;gi;, These notare are net readily available and the actor has basa sent off sits for rewinding. It should he returned and reinstalled by August 1.1988. This actor is not crititel to the operatics of the associated evaporator unless the remainial two cct::s f ail. Iht: 0 are tVo tt:;;:ary titiratic: assetiatti Vith the Cask deces pumps that htYt heln ::SYtttti !c filip Cha:gis but the Vork plats havt tot htts pre;ared to *.aka tit ;hysical Cht ges. Thest Changes are scheduled to be cosPlots by August 1.1988.
. f0f tht lyt:t rili;!!C 8st ta:The level gage observed was not o A his !tcently hets Ch0 gen, Iht gt; gig vill CD:14tCt il 30 3 33 the :tv gage 3:d parte can he procured. the design package
. . . i sospleted and the v:r's plan developed. Since this has the potential to be a
~
hith exposufe rate feb ve vill carefully look at the ALA3A sapocte before CC"".ltC1:3 VCft. *his veri Vill be completed by June le 1988. ANI Evaluatica DWEU ::!arstath that ._autherised labele vill be removed before At CI CuI C 0Ctftl!$th11Vidtlp!lldUllOfunauth0ritedlabellatmethods was alleved to devolep, please doestine TVA's plans to sneurs that U$auth0!!!!$ llhtl!"3 Of C05tt01 bCards vill he provosted in the future. Our other tescarn to that it appeare that repaire, temporary alterations and design chtmate for 1: operable radioactive vaste processing etvipment have not been receiving less than appropriate management attention ans priority. plasse deteri)e TVA's plate to ensure that radiosetive weste processtag systene interruptions receive sufficient is the future. priority to support full operability with sintaal e
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C.' Mr. David H. Marks l Tennessee Valley Authority Pese 13 e b Additie::al TVA Responses to ANI Itass Al, A2, 31, B2, and M in Ax A.I Letter dated April 1), 1951 T;/!
.pj ; ANI Evaluation Sti . ' ~g*
These five itene of concern related to the purpose of the Modifications Group reorganiastion resolving communication problene between the plant and Control Forne). engineering, and actions to reduce the number of TACFe (Temporary A (J-w: .c. lach of thtl4 3dditier.gl ggi;0f. stb 18 81tlifactory. rYY,
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