ML20209D651
| ML20209D651 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/27/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20209B481 | List: |
| References | |
| 203.3(B), 203.3(B)-R01, 203.3(B)-R1, NUDOCS 8702040523 | |
| Download: ML20209D651 (25) | |
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER: 1 TITLE:
EXPERIENCE FEEDBACK Tracking System for Comitment Inadequate PAGE 1 0F 24 I
REASON FOR REVISION:
1.
Revised to incorporate coments by TAS and SRP and to add Section 10, Corrective Action.
PREPARATION PREPARED BY:
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MANAGER OF NUCLEAR POWER DATE I
CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
i TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 2 0F 24 1.
CHARACTERIZATION OF ISSUES:
Concern:
Issues:
Wi-85-100-034 a.
There is no formal system to track
" Engineering (ENDES) inadequately and assign commitments for problems addresses and considers opera-identified by INP0.
tion, maintenance, testing and construction requirements b.
There is poor tracking of NRC and general industry practices experience infomation.
in the design process. There are not forced interactions c.
There are no forced interactions with other utilities, no fomal with other utilities'for system to track and assign information exchange.
commitment for problems identified to INP0, and poor d.
Feedback to engineering of tracking of HRC experience corrections for problems identified infomation.
is not adequate.
NOTE: The following issues from this concern are addressed in Sequoyah Element Report 203.E.
Engineering inadequately addresses operation requirements in design process.
Engineering inadequately addresses maintenance requirements in design prot ess.
Engine.-ing inadequately addresses construction requirements in design i
process.
Engineering inadequately addresses testing requirements in design process.
Engineering inadequately addresses general industry practices in design process.
06160 (01/15/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 3 0F 24 2.
HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES.X NO Documentation Identifiehs':
o Identified by Nuclear Safety Staff Date May 1985 NSSS Report 8'-02, " Deficiency in Implementation of the 5
Nuclear Experience Review Program" o
Identified by Employee Concerns Task Group: Operations Date 6/5/86 Report 307.09, Element: " Experience Review Program" o
Identified by Employee Concerns Task Group: Other Sites Date 01/05/87 Report SWEC-SQN-48, R1, "SQN Operational Readiness Review" 2.
DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STAltu IN ELEMENT:
None 4
INTERVIEW FILES REVIEWED:
Expurgated file for WI-85-100 was examined, and no additional unreviewed information was found.
5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
l 6.
WHAT REGULATIONS, LICENSING C0694ITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
l l
06180 (01/15/87)
I
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 24 7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELAltu TO ELEMENT.
i See Appendix A.
B.
EVALUATION PROCESS:
a.
Reviewed baseline documents to determine policy and procedures for experience feedback program for operations and engineering at SQN.
b.
Determined the existence and details of the following types of programs at SQN:
o Formal experience feedback program o Review and followup on INPO, NRC, industry experience information Determined programs and methods used to address feedback from c.
8.b for SQN Unit 1 and Unit 2:
o Organization o Communication methods d.
Reviewed the implementation of the existing programs for incorporating experience information into plant design and operation.
9.
DISCUSSION, FINDINGS, AND CONCLUSIONS:
Chronology:
l 10/80:
NUREG-0737 Task Action Plan I.C.5 issued by NRC to require preparation of procedures for feedback of operating experience to plant staff 12/23/80:
TVA responds to NUREG-0737 stating its program is adequate 07/28/81:
TVA Division of Nuclear Power issues Procedure No. DPM N72A39, " Review, Reporting, and Feedback of Operating Experience Items," to implement Office of Nuclear Power Program to meet the specific requirements of
^
NUREG-0737, I.C.S.
11/30/81:
TVA Office of Power Quality Assurance Audit No.
CH-81-SP-04 addresses Feedback of Operating Experience to Plant Staff and identifies deviation 06100 (01/15/87) i
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 5 0F 24 09/82:
NSSS 82A2 Section Instruction letter for Regulatory Enginee, ring Support Section issued to address disposition of experience review material 11/22/82:
TVA SQN Standard Practice SQA 26 issued to implement TVA program for review of operating experience reports at SQN 06/84:
TVA commits to review all NRC Inspection Notices and Circulars issued between 1979-1983 05/85:
Nuclear Safety Staff Report 85-02 provides results of investigation of the nuclear experience i*eview program at BFN 06/04/85:
Procedure DPM N72A39 revised to become procedure 0601.01 in order to reflect TVA reorganization.
11/01/85:
TVA receives concern WI-85-100-034 11/22/85:
Licensing Support Group (LSG) Instruction Letter, LSG 85A1, issued to delineate the procedure to be followed in describing the elements of coordination of experience review material within the LSG.
11/27/85:
NRC receives employee letter regarding concerns about TVA's nuclear program 02/18/86:
NRC letter forwards copy of concerned Employee's letter to TVA for review and response 02/21/86 HRC investigative interview with concerned individual 03/10/86:
In its Corporate Nuclear Perfonnance Plan (NPP) TVA commits to implement an operating experience review program 06/05/86:
Report 307.09, TVA WBN Employee Concerns Task Group Operations CEG on Subcategory:
Nuclear Power / Site Programs / Procedure, Element: Experience Review Program 06/23/86 NRC forwards transcript of interview with concerned individual to TVA 1981-1985: 0A audits of all TVA plants note deficiencies in TVA Operating Experience Review (OER) Program 0618D (01/1E/8h)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 6 0F 24 1981-1986:
INP0 evaluations note deficiencies in TVA OER program 1984-1986: NRC ins'pections note deficiencies in TVA OER program 12/86:
Program Management Procedure 0601.01, pre-release copy of Revision 0 procedure completely revised to establish new Nuclear Experience Review (NER) program as comitted to in the NPP Discussion:
9.1 BACKGROUND
AND PROCEDURES:
All of the issues identified in this concern relate to the acquisition, distribution, and tracking of nuclear power industry experience. The typical sources of this information are identified in the concern and are:
(1) Institute of Nuclear Power Operations (INPO), (2) the Nuclear Regulatory Commission (NRC), and (3) other nuclear utilities.
All of the issues can be grouped under the single heading of Operating Experience Review (OER) and may be addressed together.
Note that at TVA this activity has generally been called the OER program.
However, it was sometimes referred to as the Nuclear Operating Experience Review Program (N0ERP) or the Nuclear Experience Review (NER) program. With the most recent revision of the controlling procedures TVA is now officially calling this the HER program.
This report will adopt the term OER when discussing this program prior to the most recent changes and will use NER when referring to the new TVA program.
In October 1980, the NRC issued NUREG-0737, " Clarification of TMI Action Plan Requirements."
In Task Action Plan I.C.5, which only addresses feedback of operating experience to operators, the NRC states the requirement that:
"Each applicant for an operating license shall prepare procedures to assure that i
operating information pertinent to plant safety originating both within and outside the utility organization is continually I
supplied to operators and other personnel and is incorporated into training and retraining j
programs."
061PD (01/15/87)
TVA EMPLOYEE CONCERNS REPORT M ER: 203.3(B)
SPECIAL PROGRAM REVISION M ER: 1 PAGE 7 0F 24 TVA responded to this NRC requirement on 12/23/80 indicating that their program is adequate ( App. A, S.rr). On 07/28/81 TVA issued area procedure DFt1 N72A39 for the review, A, 5.ss)g, and feedback of operating experience items ( App.
reportin At the Sequoyah site the procedure governing the OER program is Standard Practice SQA 26, " Review, Reporting, and Feedback of Operating Experience Items" ( App. A, 5.cc). The date shown on this procedure for Revision 0 is 11/22/82 and the present version, Revision 7, is dated 11/20/85. Although SQA 26 is first dated 11/22/82 it must have been in use earlier because a QA audit performed in November 1981 identified deviations in both SQA 26 and DPM N72A39.
The essence of these deviations is that DPM N72A39 did not sufficiently address all the requirements of NUREG-0737.
This procedure did not provide for TVA experience at one TVA plant to be reviewed for applicability at other TVA plants, nor did it assure that important information is handled with dispatch.
The Sequoyah procedure SQA 26 was also faulted because it merely duplicated h72A39 and did not contain any specific instructions for plant personnel.
The present version (R7) of SQA 26 now includes a list of specific responsibilities for the Sequoyah Regulatory Engineering Section (RES).
In addition to review and dissemination of experience information, the RES is required to ensure that any action resulting from the review item is completed.
When a modification or other action results from the review of an experience review iter. the OER procedures require that the OER staff ensures that the appropriate organization is assigned responsibility. The OER staff then maintains a record of the item untti the responsible organization reports i
it as closed. For the tracking of the actions necessary to l
implement a correction a computerized tracking system is used.
l In September 1982, the Regulatory Engineering Support Section (RESS) of the Reactor Engineering Branch (RE8) issued Section i
Instruction Letter (SIL) NSSS82A2 ( App. A, 5.h).
The scope of this SIL provided directions for the handling and i
reviewing of experience review material within RESS and expanded on the Division Procedure N72A39.
This SIL was the corporate equivalent of site procedure SQA 26 and was the governing document for the RESS during the period when the l
OER program was administered as a centralized program.
00100 (01 /15/87) l
TVA EMPLOYEE CONCERNS REPORT NtmBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 8 0F 24 In June 1985, each TVA site and division was given responsibility for its own OER. Area Procedure 0601.01,
" Review, Reporting,)and Feedback of Operating Experience Items" (App. A, 5.u issued on 06/04/85, described the new responsibilities resulting from this reorganization and replaced the fomer procedure DPM N72A39. This new procedure identifies the experience information sources which are to be reviewed and delineates the requirements and responsibilities in the divisions / branches for performing their reviews.
This procedure requires the plant site to establish procedures to ensure that recommendations resulting from the reviews are addressed and that proper action is taken.
This reorganization introduced difficulties in the OER program. The mechanics of the OER program after January 1, 1985 were changed to transfer the OER responsibilities to the plants.
The RESS became only an OER items clearinghouse with no review or filtration function ( App. A, 5.0).
The site RE section became the initial point of review. Also, procedure 0601.01 specifies that the % clear Licensing Branch (NLB) will maintain a file for all OER material received prior to January 1,1985, and the sites shall maintain a file for OER material received after January 1,1985. To further fragment the program, Office of Engineering (OE) discontinued routine coordination of the investigations of NRC Bulletins, Circulars, and ins for operating license (OL) plants.
The OE continued, however, to coordinate and initiate OE investigations into these items for construction pemtt (CP) plants (App. A, 5.q).
The Licensing) Support Group Instruction Letter (GIL) LSG 85A1
( App. A, 5.ee was originally issued on November 22,1985 and addresses the disposit< on of experience review material.
This GIL expands the Office of Nuclear Power (ONP) procedure 0601.01 but is limited to the activities of the Licensing Support Group.
It reflects the decentralized operation of the OER program and specifies that the Regulatory Engineering Section at each site is responsible for the accuracy and completeness of expertence review material.
It does, however, provide for distribution of internal review material and for a generic experience review in addition to the review of externally generated experience information.
061PD (01/15/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM j
REVISION NUMBER: 1 PAGE 9 0F 24 1
Documentation was examined (e.g., App. A, 5.ccc) to detemine i
extent of TVA involvement with others in the industry. There was ample evi'dence of TVA participation in professional societies (e.g., ASME, IEEE) and Owners Group activities for SON.
Participation was at chairperson and other committee level s.
TVA has participated in NSSS Owners Group Activities since the mid-1970s, becoming more active following issuance of NUREG 0737 in 1980.
Participation with other Utilities (e.g., Duke Power) and other industry groups (e.g., EPRI) was also noted. This involvement is presented in more detail in Sequoyah Element Report 201.1.
9.2 OTHER INVESTIGATIONS:
1 From 1981 into 1986 the TVA OER program has been evaluated i
numerous times by the NRC and INPO and audited by TVA QA (see j
App. A, INPO, NRC, and QA references).
Each time the program was examined, findings or deviations were identified and improvements were recommended. Most of the findings were i
related to the dissemination of in-house experience infomation between the many TVA divisions and sites.
Additionally, the program was described as fragmented, and the procedures were criticized for not sufficiently delineating responsibility and directing performance. 1hese i
evaluations also identified a lack of management su) port for l
the OER program and a lack of staffing to perfom tie i
necessary reviews in an efficient and timely manner.
(
A review of the transcript of the NRC interview with the l
concerned individual (CI) reveals only a minor clarification i
of the issues in that he felt the experience infomation was made available to only a limited number of individuals.
He felt that the engineers who were implementing the design were doing so with hearsay information rather than with their own l
personal direct knowledge of the experience of other plants as identified by NRC or INPO.
The QA, NRC, and INPO reviews that the evaluation team examined generally focused their comments and findings on the activities of licensing personnel and management.
The only coments found relating to this specific point to which the CI referred were in an NRC internal memo in December 1585 (App. A, 5 99).
The NRC staff was concerned that operator learned." programs at SQN may not include appropriate " lessons training This point was resolved, however, when the NRC inspector sampled the processing of several operating experience resorts and verified that the information was provided to tie operators (App. A, 5.aaa). This point is now specifically addressed in SCA 26.
N1PD (01/15/87)
TVA EMPLOYEE CONCERNS REPORT NLM8ER: 203.3(8)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 10 0F 24 This issue has also been identified by the Employee Concerns Task Group, Operations Category, in Report SWEC-SQN-48, R1 (App. A, 5.iooo). That report identified a failure by TVA to disseminate recent industrial accident experience infomation to lower echelon workers. The SQN Safety Section has been instructed to ensure that applicable industrial safety experience is disseminated to all plant sections.
The status of SQN'.s response is being tracked under CATO 90100.
In 1984 TVA identified a design deficiency at Browns Ferry Nuclear Plant (BFN). Subsequent investigation by TVA revealed that this item had previously been identified in NRC Infomation Notice (IN) 79-32 but had not been. adequately evaluated by TVA at the time because the NRC had not required a response to IN 73-32. As a result, TVA committed to the NRC to review all ins and circulars issued between 1979 and 1983 inclusive. The results of this review were summarized in February 1985 (App. A, 5.r) and eight items were identified as being the responsibility of the Office of Engineering (OE).
The perfomance of the TVA OER Program was examined by the TVA Nuclear Safety Staff (NSS) in 1985 (App. A, 5.s) and by the Operations Category of the Employee Concerns Task Group in 1986 ( App. A. 5.tt). The NSS review was mainly concerned with some specifics at Browns Ferry but identified several areas of weakness in the dissemination of TVA's own experience throughout TVA.
In responding to a deviation in QA Audit QBF-A-85-0016, the Director of Nuclear Services stated his opinion that the root cause was that "TVA has at least seven different experience review programs.
These seven programs are one for each site (four), the Nuclear Central Office (NCO), the Power Operations Training Center (POTC), and the Office of Engineering (OE)."
In a January 1986 memo (App. A, 5.jj) when discussing the same deviation, the Manager of Licensing restated that the OER progran is in need of total revamping.
He went on to say that untf1 guidance is received from upper-level management, (e.g. the ONP policy, directive, and standard) the licensing group instruction letter LSG 85A1 will be used to adninister the OER program.
06180 (01/15/87)
1 TVA EMPLOYEE CONCERNS REPORT NLMIER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 110F 24 s
Operations Category Report 307.09 contains a summary of the reviews and findings by INPO, NRC, and TVA QA. The report summarizes the findings that the TVA OER program is not as effective as it should be, that it does not receive adequate management attention and concern, and the procedures do not 3
A support the requirements nor their intent.
The report identifies the following specific deficiencies:
c" '
"o Failure to follow procedures as written.
"o Lack of upper-level control and responsiveness to written identification of problem areas and request for guidance.
N "o
Insufficient perfonnance standards.
', ~
"o Written policies and actions contrary to procedures that contributed to fragmentation of responsibilities and authority and corporate distrust.
"o Lack of clearly defined procedures that outlines [ sic) what documents will be formally added to the OER data base and by whom.
./
"o Corporate perturbations (i.e.,
decentralization) used as excuse for substandard performance for an excessive timeframe.
"o Repetitive disregard to suggestions for improvement."
The evaluation team has examined the documents listed in J
..r Appendix A and concurs with the findings expressed in Operations Report 307.09.
s 9.3 NEW TVA PROGRAMS:
- 7. I -
TVA management is aware of the continuing problems with the OER program ( App. A, 5.hh, 5.kk).
Consequently, in the Corporate Nuclear Performance Plan (CNPP) ( App. A. 5.uu, 5.vv) TVA described a Nuclear Experience Review (NER) program where:
Of:IPO (01/15/87) w
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M tvd'EMPLOYEECONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM s
REVISION NUMBER: 1 PAGE 12 0F 24 w
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" Licensing personnel, under the direction of r?
tiiDirdcter of Nuclear Safety and Licensing,
+ wi.ll' be* responsible for managing the TVA
,m, Maclear Oper_ating Experience Review program
'tystem for internally and externally
. identified problems or events. Under this system, significant problems or events s
a
, identified at other nuclear plants by the NRC, INP0, NSSS vendors, and others, and significant problems (events) identified at
-TYA's nuclear plants will be made the subject of experience review reports."
j The Sequoyah_ site responsibilities for the NER program are further desciibed in the Nuclear Performance Plan, Volume II, Sequoyah ( App. A, 5.ww) as follows:
V
,"The Site Nuclear Operating Experience Review program (N0ERP) has been established as part
'~
of the TVA Corporate Program managed by Nuclear Safety and Licensing.
The site licensing organization will establish procedures to implement and interface with the corporate N0ERP to:
-o Receive information into the site N0ERP and disseminate that information to the appropriate departments responsible for operations, training, engineering, and other plant activities.
I-
"o Ensure that recommendations from external site organizations are factored into the appropriate department programs.
"o Ensure Inspection and Enforcement (IE)
Bulletins and Generic Letters are reviewed from both a regulatory and an experience review point because of their dual role.
t "o
Implement an in-house experience review program to communicate significant site operational events, maintenance and design problems to other TVA plants and the industry through corporate N0ERP."
061 P0 i01/15/s.')
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 13 0F 24 i;
In Revision 1 of the CNPP, this Program is listed as commitment item No. 21 with completion required before restart ofithe Sequoyah plant. This cannitment is also shown in the Corporate Commitment Tracking System (CCTS) as commitment No. NC0 860156109 (App. A, 5.qq) and as a restart i tem.
In conjunction with this NER program, the CNPP also cannits to establishing a corporate nuclear operation experience database that will provide a management tool and TVA-wide access to all experience review items. This comitment is listed as commitment item No. 22 but the due date is shown as long tem. The CCTS control number for this commitment is NC0 860156 063 (App. A, 5.pp).
To govern the functions of the Office of Nuclear Power (ONP),
a hierarchy of Nuclear Procedures System was issued on 07/10/86 ( App. A, 5.zz). This hierarchy shows five levels of documents which are required for any given program. For the NER program, only two of the required procedures have been issued. For the Sequoyah site, Standard Practice SQA 26 is available and the corporate licensing group has the GIL LSG 85Al although both of these procedures will require revision to properly reflect the recentralization of the NER program. The required directives manual must be prepared, along with the necessary instruction manual for the site licensing section and the procedure manual for the corporate licensing division. The ONP policy has not been issued as of this date but exists in draft fom (App. A, 5.bbb).
For the corporate standards manual, Area Plan Procedure 0601.01 has been completely rewritten and is now known as the Program Management Procedure (PMP) 0601.01 (App. A, 5.yy).
This procedure is part of the ONP interim procedures system and specifies that the Manager of Nuclear Safety has the overall responsibility for the perfomance of the NER program. The sites and divisions are responsible for providing internal experience infomation to the central office and for implementing corrective actions as applicable. The general requirements of this procedure state that:
06180 (01 /15/87)
- i
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 14 0F 24 "The experience review function is a process by which industry and internal experience is screen'ed, an assessment performed, and lessons learned are factored into 7.A's sites and divisions.... TVA is also responsible for ensuring that the nuclear industry is aware of items that could affect the safety of nuclear plants."
In addition to reviewing and disseminating nuclear experience materials, procedure PMP 0601.01 requires:
"The Manager, NER, or designee shall ensure all significant plant events are reported on the Nuclear Network System. The Director of Nuclear Services or designee shall ensure that equipment failures are reported on the NPRDS [ Nuclear Plant Reliability Data System] system.
"The Manager, NER, shall develop an NER status report on a monthly basis which shall contain:
o A list of all open NER packages o
A list of NER items added or closed during the month o
An evaluation of the use of effectiveness of the NER program including an assessment of problem areas "The purpose of the status report is to infonn TVA management of any areas of good or exceptional performance and areas requiring management attention withir, the ONP."
The Manager, NER, is also required to track corrective action resulting from an experience review item until implemented, and to update the Tracking and Reporting of Open Items (TROI) computer system and NER data base accordingly. NER action items shall not be closed until all corrective actions are completely implemented and documented.
06180 (01 /15/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAE 15 F 24 Findings:
The evaluation tedn review of the operating experience review program at TVA shows that in 1981 TVA implemented an OER program as required by NUREG-0737. This program has, however, been inadequate as exemplified by the continual occurrence of deviations and findings when examined by NRC, INP0, and TVA QA. The program has been fragnented with no central coordination for the multitude of individual and separate programs.
TVA has recognized these inadequacies and has so stated in the Nuclear Perfonnance Plan. TVA is attempting to remedy this situation by implementing a centrally directed syst'ern for operating experience review and for internal and industry-wide dissemination of TVA experience. TVA has the core procedure (PMP 0601.01) of the new NER program prepared but has yet to issue it, the necessary upper-tier governing documents, and the lowest level implementing procedures. This conunf tment is presented in the NPP and is included in the CCTS data base as NC0 860156109.
==
Conclusions:==
i The issues expressed by this employee concern are valid in that the OER program as practiced by TVA has been inadequate in general.
The specific tracking of INP0 items has frequently been poor, and the feedback of TVA experience to the INP0 data systems has been all but neglected. Tracking of NRC infonnation has, for the most part, not suffered as much, but the dissemination among the sites of TVA's own in-house experience has repeatedly been criticized by reviewers.
The procedures for the OER program have been available since 1981 but have been both lacking in detail and not followed by personnel. The existence of the procedures demonstrates management's awareness of the need for an OER program, and the procedures essentially reflect the regulatory requirements.
However, there is a gap between the procedures and their implementation.
TVA management has recently placed more emphasis on the NER program and has committed in the CNPP to implement an effective program l
prior to the restart of the Sequoyah Plant. Although the complete hierarchy of required procedures is not yet prepared, the core procedure (PMP 0601.01) has been prepared and is presently under review for the necessary approvals. When complete and adequate procedures are prepared and the program is properly and effectively implemented, the NER program should be sufficient to resolve these issues.
0618D (01/15/87) i t
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 16 0F 24
- 10. CORRECTIVE ACTION:
TVA has submitted (App. A, 5.nnn) a Corrective Action Plan (CAP) for each of the four CATDs associated with this report. These CAPS, as described below, have been examined by the evaluation team and have been found acceptable.
The CAP for CATD - 203.03 - SQN-1 states that The Office of Nuclear Power (ONP) Procedures Staff has and will be generating an ONP Policy and Directive that will require a Nuclear Experience Review Program (NER). The procedures staff has indicated that the policy has been approved and is in the process of being issued. The directive will be issued in approximately one year."*
The CAP for CATD - 203.03 - SQN-2 states that Standard Practice SQA-26 will be revised to reflect the requirement of the Standard (PMP), Directive, Policy, and the Division of Nuclear Safety and Licensing procedure to implement the NER program at Sequoyah.
SQA-26 will be revised to implement PMP 0601.01, Nuclear Experience Review, and the Division of Nuclear Safety and Licensing procedure prior to Sequoyah Unit 2 restart (mode 4).
The CAP for CATD - 203.03 - SQN-3 states that a temporary procedure PHP 0601.01, Nuclear Experience Review has been written to implement the NER requirements within ONP and is in the final approval stage. The Division of Nuclear Safety and Licensing has written a procedure that describes the requirements and actions that will implement the NER Program as described in PMP 0601.01.
This procedure is still in its initial draft form. Both of these procedures are to be in place prior to Sequoyah Unit 2 restart (mode 4).
The CAP for CATD - 203.03 - SQN-4 states that the NER Program will be implemented under temporary procedures before Sequoyah Unit 2 restart (Mode 4) as committed. This NER program, under temporary procedures, will be in place prior to Sequoyah Unit 2 restart (mode 4).
0618D (01/15/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NIMBER: 1 PAGE 17 0F 24 ADDENDIX A 5.
DOClMENTS REVIEWED RELATtD TO THE ELEMENT:
a.
INP0 Report of Sequoyah Nuclear Plant,11/81 Evaluation b.
Foremost Safety and Reliability Issues, Identified through INP0 Plant Evaluation and the Significant Events Evaluation and Infonnation Network Program (SEE IN), (12/81) c.
Recurring Findings and Recommendations and Good Practices, INP0, (01/82) d.
Letter from E. P. Wilkinson, INPO, to H. G. Parris, TVA, concerning recommendations and good practices identified during INP0'.s assistance visit to WBN during week of 01/18/82, (02/10/82) e.
TVA memo from H. J. Green to A. W. Crevasse, " Quality Program Audit Report No. OPQAA-CH-81SP-04 ( A24 820112 001),"
(Ll6 820219 893), (02/25/82) f.
TVA Office of Power, Quality Program Audit Report from A. W.
Crevasse to H. J. Green, et al, Audit No. CH-8200-10,
" Operating Experience and Feedback Control," (A24 821006 005), (10/04/82) g.
TVA memo from H. J. Green to G. W. Killian, " Quality Program Audit Report No. CH-8200-10 (A24 821006 005)," (Ll6 821118 812), (11/19/82) h.
TVA Division of Nuclear Power, Reactor Engineering Branch (REB), Section Instruction Letter, from J. Hutton to NSSS Engineering and Analysis Group, " Disposition of Experience Review Material - REB No. NSSS82A2," (11/03/83) 1.
INP0 Report of Sequoyah Nuclear Plant TVA, 02/84 Evaluation J.
TVA memo from J. P. Darling to R. W. Cantrell, " Institute of Nuclear Power Operations (INPO) - INP0 Publications," (L33 840413 802), (05/17/84) k.
INP0 Report, " Recurring Recommendations and Good Practices from NT0L Assistance Visits," (05/84) 1.
INP0 Report, " Browns Ferry Nuclear Plant," (10/84) i 06180 (01 /15/87) l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 18 0F 24 APPENDIX A (Cont'd) m.
TVA memo frain G. W. Killian to H. L. Abercrombie, " Division of Quality Assurance Audit Report No. CH-8400 Operating Experience and Feedback," (Ll7 841016 804), (10/16/84) n.
TVA memo from D. E. McCloud to M. J. Burzynski, " Review of Significant Operating Experience Reports (SOER) for Watts Bar Nuclear Plant (WBN), (11 /19/84) o.
TVA memo from J. P. Mulkey to J. E. Gibbs, " Operating Experience Review Trip Report," (T15 841213 848) (12/06/84)
Letter from D. M. Verelli, NRC, to H. G. Parris, TVA}," Report p.
Nos. 50-390/84-82 and 50-391/84-56," ( A02 841217 015 (12/12/84) q.
TVA memo from J. A. Raulston to J. W. Hufham, " Handling of NRC Bulletins, Circulars, and Infonnation Notices for Plants with an Operating License (OL)," (NEB 850220 251), 02/20/85) r.
TVA memo from J. A. Raulston to Those Listed (R. O. Barnett, et al), "Bellefonte, Browns Ferry, Sequoyah, and Watts Bar Nuclear Plants - Review of NRC-0IE Circulars and Infonnation Notices Issued between 1979 and 1983 (Inclusive)," (NEB 850228 290), (02/28/85) s.
TVA Nuclear Safety Staff Report 85-02, " Deficiency in Implementation of the Nuclear Experience Review Program Browns Ferry, Sequoyah, and Watts Bar Nuclear Plants,"
(L42 850517 801), (05/85) t.
TVA memo from H. B. Rankin to J. P. Vineyard, "Sequoyah Nuclear Plant (SQN) - Handling of Operating Experience Review (0ER) Infonnation for SQN," (06/04/85) u.
TVA Division of Nuclear Power, Procedure No. 0601.01 (fonnerly DPM No. N72A39), " Review, Reporting, and Feedback of Operating Experience Items," (06/04/85) v.
TVA memo from R. W. Cantrell to J. P. Darling, " Institute of Nuclear Power Operations (INP0) - INP0 Publications," (B4585 0606 261), (06/06/85) w.
OE Draft Input to WBN INP0 Evaluation, " Disposition of SOERs within the Office of Engineering (DE)," (06/07/85), TTB #059 (06/24/86) 0618D (01/15/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 19 0F 24 APPENDIX A (Cont'd)
Letter from O. M. Verelli, NRC, to H. G. Parris, TVA, " Report x.
Nos. 50-390/85-36 and 50-391/85-36" ( A02 850621 006),
(06/19/85) y.
INP0 Report, " Evaluation of Sequoyah Nuclear Plant," Second Draft,(07/02/85)
INP0 Report, " Evaluation of Watts Bar Nuclear Plant," Second z.
Draft,(09/03/85) aa.
TVA memo from J. Hutton to F. A. Szczepanski, " Browns Ferry, Sequoyah, and Watts Bar Nuclear Plants - Nuclear Experience Review Program," (L44 850919 812), (09/23/85) bb.
TVA memo from G. W. Killian to H. L. Abercrombie,
" Transmittal of QAB Audit Report No. QSQ-A-85-0012," (L17 851101 801), (11/01/85) cc.
SQN Standard Practice, SQA 26, " Review, Reporting, and Feedback of Operating Experience Items," R7, (11/20/85) dd.
TVA memo from J. Hutton to G. W. Killian, " Response to QAB Audit Report No. QBF-A-85-0016," (L44 851120 802), (11/20/85) ee.
TVA ONP Nuclear Licensing Branch, Group Instruction Letter, from D. E. McCloud to Licensing Support Group, " Disposition of Experience Review Material - LSG No. 85A1, Revision 3,"
(08/04/86) ff.
Letter B. J. Youngblood, NRC, to S. A. White, TVA, "TVA Employee Concern Program," (L44 860224 774), (02/13/86) gg.
Memorandum from G. M. Holahan, NRC, to B. J. Youngblood, NRC,
" Staff Review of TVA's Response to 50.54 (f) Letter,"
l (12/30/85) l hh.
TVA memo from A. R. Meller to Files, " Nuclear Safety Monthly Top Management (NSMTM) Meeting Held January 3,1986,"
(L42 860228 804), (01/03/86) 11.
TVA memo from G. W. Killian to R. L. Gridley, " Evaluation of Corrective Action Response - Audit Report No. QBF-A-85-0016 -
Deviations D02 and 003," (L17 860128 801), (01/28/86)
(
061PD (01/15/87)
J TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM j
REVISION NUMBER: 1 PAGE 20 0F 24 APPENDIX A (Cont'd) jj.
TVA memo fraii R. L. Gridley to G. W. Killian, " Response to QAB Audit Report No. QBF-A-85-0016," (L44 860129 810),
(01/29/86)
- kk.
TVA memo from A. R. Meller to Files, " Nuclear Safety Monthly Top Management (NSMTM) Meeting Held January 24,1986," (L42 860228 803), (01 /30/86) 11.
Letter from D. R. Hicks to NRC, Comittee on Energy and Connerce, Committee on Interior and Insular Affairs,
" Concerns Regarding the TVA Nuclear Program,"*(11/27/85) mm.
TVA memo from R. L. Gricley to R. B. Kelley, " Actions to Close Outstanding QA Audit Deviations - Nuclear Licensing Branch (NLB)," (L44 860221805), (02/21/86) nn.
Letter from NRC to S. A. White, TVA,
Subject:
" Transcript of Interview of Dallas R. Hicks," (06/23/86) oo.
NRC NUREG-0737, " Clarification of TMI Action Plan Requirements, Item I.C.5," (11/80) pp.
Corporate Commitment Tracking System Commitment Update Report, Operating Experience Review, Control Ntaber:
NC0-86-0156-063 qq.
Corporate Commitment Tracking System Connitment Update Report, Operating Experience Review Program, Control Ntsnber:
NC0-86-0156-109 l
rr.
Letter from L. M. Mills, TVA, to H. R. Denton, NRC, " Response to D.G. Eisenhut'.s Letter dated October 31, 1980, Post TMI Requirements, Browns Ferry Nuclear Plant, Docket Nos. 50-259, 50-260, 50-296," ( A27 801223019), (12/23/80) i ss.
DPM N72A39, " Review, Reporting, and Feedback of Operating Experience Items," (04/05/83) tt.
TVA WBN ECTG Operations CEG, Subcategory: Nuclear Power / Site Program / Procedure, Element Review Program Report No. 307.09, (06/05/86) uu.
Corporate Nuclear Perfonnance Plan, Volume I, R0, (03/86) 06180 (01 /15/87)
f TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 21 0F 24 APPENDIX A (Cont'.d)
Corporate Nuclear Perfomance Plan, Volme I, R1, (07/22/86) vv.
Sequoyah Nuclear Perfomance Plan, Volme II, R1, Final ww.
Concurrence hansmitted July 14,1986, (L44 860714 800)
Tennessee Valley Authority, Nuclear Quality Assurance Manual, xx.
(N@M), (10/21/86) l yy.
PHP 0601.01, " Nuclear Experience Review," prerelease copy, (undated)
TVA memo from S. A. White to Those Listed, (LO2860709839),
zz.
" Policy Establishing the Nuclear Procedures System,"
(07/10/86)
TVA Memo from J. Hutton to F. A. Szczepanski, " Browns Ferry, aaa.
Sequoyah, and Water Bar Nuclear Plants, Nuclear Experience Review Program," (L44 860919812), (09/28/85) bbb. Office of Nuclear Power Policy 6.1, " Nuclear Safety," draft (12/06/86)
TVA memo from S. A. Shipman to Those Listed, (R. O. Barnett, ccc.
et al), " Professional Society Committees and Industry Activities," (802 860 903 001), (08/25/86)
Employee Concerns Task Group, Other Sites, Element: Design Pi ddd.
eee. Employee Concerns Task Group, Other Sites, Element: NRC Notification Inadequate, Report Naber SWEC-SQN-23, (10/07/86) fff. Employee Concerns Task Group, Other Sites, Element:
Non-Confomance Reporting, Report Neber SWEC-SQN-31, (09/09/86) ggg. Employee Concerns Task Group, Other Sites, Element: TVA Comparison to Industry Medians, Report Number SWEC-SQN-12, R1, (01/05/87) hhh.
Employee Concerns Task Group, Other Sites, Element: High Failure Rate for Auxiliary Feedwater ( AFW) System, Report Number SWEC-SQN-43, R0 (11/15/86) 111. Employee Concerns Task Group, Other Sites, Element: SQN Operational Readiness Review, Report Naber SWEC-SQN-48, R1, (01 /05/87) 0618D (01/15/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 22 0F 24 APPENDIX A (Cont'.d) jjj. TVA memo W.' R. Brown to H. L. Abercrombie, " Watts Bar Nuclear Plant Employee Concerns Task Group (ECTG) - Elenent Report SWEC-SQN-40, (T25 861009 925), (10/09/86) kkk.
Institute of Nuclear Power Operations, " Plant Program for Industry Operating Experience Review," (Preliminary Good Practice TS-403), INPO, Atlanta, Georgia, (11/83) 111.
Institute of Nuclear Power Operations, " Plant Progran for In-House Operating Experience Review," (Preliminary Good Practice TS-406), INP0, Atlanta, Georgia, (11/83)
Institute of Nuclear Power Operations, " Monthly Synopsis of mmm.
Operating Experience," (Preliminary Good Practice TS-404),
INPO, Atlanta, Georgia, (06/84) nnn. TVA memo from H. L. Abercrombie to W. R. Brown, "Sequouah Nuclear Plant (SQN) - Employee Concerns Task Group (ECTG)
Element Report 203.03 SQN - Engineering Category - Corrective Action Plan (CAP)," (S03 870106 802), (01/07/87) 6.
WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA 7 NUREG-0737, " Clarification of TMI Action Plan Requirements,"
a.
Task Action Plan I.C.5," Procedures for Feedback of Operating Experience to Plant Staff" b.
TVA Nuclear Performance Plan, Volume I, Corporate R0, R1, R2 c.
TVA Nuclear Perfonnance Plan, Volume II, Sequoyah d.
Commitments.NCO 860156 063 and NCO 860156109 on the Corporate Commi$ ment Tracking System to implement an operating experience review program and an experience database l
e.
Standard Practice SQA 26, " Review Reporting, and Feedback of Operating Experience Items" f.
Section Instruction Letter NSSS82A2, " Disposition of Experience Review Material" g.
Area Procedure 0601.01, " Review, Reporting, and Feedback of Operating Experience Itsus"
(
06180 (01 /15/87) i
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 23 0F 24 APPENDIX A (Cont'd) h.
Program Management Procedure PMP0601.01, " Nuclear Experience Review" 1.
Group Instruction Letter LSG 85A1 " Disposition of Experience Review Material" 7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT:
Telecon from W. E. Purcell, Bechtel, to D. T. Clift, TVA, (IOM-449)
(12/02/86)
Telecon from D. Zwicky, E. Purcell, Bechtel, with D. T. Clift and W. Ludwig, TVA, (10M-450) (12/09/86)
RFI SQN-754 (12/12/86) 06160 (01 /15/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 203.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 24 0F 24 CATD LIST The following CATDs identify and provide corrective action for the findings included in this report:
203.03 SQN(B)-01 (01/05/87) 203.03 SQN(B)-02 (01/06/87) 203.03 SQN(B)-03 (01/05/87) 203.03 SQN(D)-04 (01/05/87)
I 1
i 06180 (01 /15/87)
-4 e;s.
~;,7;y, n -.
.- s
. 49 PAGE REFERENCE
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY RUN TIME - 12:57:19 OFFICE OF NUCLEAR POWER RUN DATE - 12/02/86 FREQUENCY
- REQUEST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
ONP - ISSS - RRM LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 20303 TRACKING SYSTEM FOR COMMITMENT INADEQUATE 3
KEYHORD A I
S GENERIC KEYHORD B H
APPL QTC/NSRS P
KEYHORD C CONCERN SUB R PLT BBSH INVESTIGATION S
CONCERN KEYNORD D
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NUMBER CAT CAT D LOC FLqB REPORT R
DESCRIPTION
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HI 100-034 EN 20302 S HBN YYYY SR ENGINEERING CENDES) INADEQUATELY ADD DESIGN PROCESS RESSES AND CONSIDERS OPERATION, MAIN-NONCONFORMANCE T50213 EN 20303 REPORT TENANCE, TESTING AND CONSTRUCTION RE ENGINEERING
.D QUIREMENTS AND GENERAL INDUSTRY PRAC GENERAL I
TICES IN THE DESIGN PROCESS. THERE ARE NO FORCED INTERACTIONS HITH OTHE R UTILITIES, NO FORMAL SYSTEM TO TRA
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CK AND ASSIGN COMMITMENT FOR PROBLEM
)
S IDENTIFIED TO INPO, AND POOR TRACK ING OF NRC EXPERIENCE INFORMATION.
CI HAS NO FURTHER INFORMATION. ANON
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