ML20215F634
| ML20215F634 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/15/1986 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8612240011 | |
| Download: ML20215F634 (7) | |
Text
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~Dna TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Place c'
DEC 15 886
- o U.S. Nuclear Regulatory Cotanission h
Region II g
ATTN:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 1
Atlanta, Georgia 30323 o)
Dear Dr. Grace:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-OIE REGION II INSPECTION REPORT 50-327/86-48 AND 50-328/86 RESPONSE TO NOTICE OF DEVIATION NOS.
50-327, 328/86-48-01 Enclosed is our response to Gary G. Zech's November 14', 1986 letter to S. A. White which transmitted Notice of Deviation Nos. 50-327, -328/86-48-01 for our Sequoyah Nuclear Plant. Additionally, this responso addresses your request for additional information regarding the effectiveness of the Sequoyah Nuclear Performance Plan (SNPP) implementation.
If you have any questions, please get in touch with M. R. Harding at 615/870-6422.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY t
M J. A. Domer, Assistant Director Nuclear Safety and Licensing Enclosures cc (Enclosures):
Mr. James Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Conunission Washington, D.C. 20555 Mr. G. G. Zech, Director TVA Projects U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 A O PDR g\\
Q
/gD An Equal Opportunity Employer S
ENCLOSURE RESPONSE - NRC INSPECTION REPORT NOS. 50-327/86-48 AND 50-328/86-48 GARY G. ZECH'S LETTER TO S. A. WHITE DATED NOVEMBER 14, 1986 NOTICE OF DEVIATION 50-327.-328/86-48-01 Tennessee Valley Authority submitted to the NRC by transmittal dated July 17, 1986, their revised Sequoyah Nuclear Performance Plan. Paragraph II.4.1.3 states that the Maintenance Department has implemented a program of completing written Employee Performance Reports quarterly.
It further states that-the first quarterly evaluations have been completed and the second evaluations are under way.
i Contrary to the above, as of September 12, 1986, the NRC determined that quarterly Employee Performance Reports were not being conducted and had been discontinued in February 1986.
SEOUOYAH RESPONSE There has been a considerable amount of discussion within TVA about what constitutes a commitment and what is actually an intention.
It should be noted that TVA considers commitments to NRC, as well as stated intentions, to be requirements which must be met.
TVA considers a commitment to be clearly identified in correspondence as a commitment (usually on a separate list) and entered into TVA's Corporate Commitment Tracking System (CCTS) and tracked accordingly. Commitments are specific statements about how or when something will be accomplished. The details and completion dates of those commitments may not be changed without l
written notification to NRC.
Intentions are less specific and, while the end result or purpose of an intention will still be achieved, the method of achieving this end may vary. NRC will, however, be informed where the
~ intention as originally stated to NRC is changed.
In the case of the above Notice of Deviation, Sequoyah failed to fulfill the stated intention when the quarterly evaluations were missed. The Employee l
Performance Report (EPR), attachment 1, as used at Sequoyah, is basically an event report.
It was developed to document a specific above or below average performance incident, a violation, a personnel error, or a failure to follow instructions for which a foreman or crew member (or members) are responsible.
Completed EPRs are filed in the _ foreman's performance monitoring folder.
EPRs are collected for one quarter and, at the end of this period, the general foreman reviews the foreman and crew's performance utilizing normal evaluation criteria and the EPRs for that quarter. Attachment 2 is used to document this quarterly foreman evaluation.
l l
The EPR is not intended to be tsed as the mechanism to routinely evaluate l
every employee.
Routine employhe performance is documented by TVA's formal I
evaluation process using TVA foqm 3031, " Employee Service Report."
i.. --,
, All maintenance groups have been using EPRs since September 1985. Mechanical Maintenance has completed approximately 75 EPRs and has never discontinued the preparation of EPRs. However, as identified in the above Notice of Deviation, the Mechanical Maintenance Group did fail to perform quarterly evaluations for
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the February / March / April 1986 quarter. Corrective action was taken by including 'the missed period (February through April 1986) in the next quarterly evaluation ending July 1986. Mechanical Maintenance has now also completed the August / September / October 1986 evaluations.
The subject inspection report also noted that the EPRs were not being completed within the target timeframe of two weeks from the event. However,
. disciplinary action was applied in over 20 of the 75 EPRs prepared by Mechanical Maintenance and in only five cases involving disciplinary action was the two-week target exceeded. The EPR is also used to determine and approve disciplinary action.
In the five cases identified the determination j
and approval of appropriate disciplinary action was complex, which resulted in the two-week target being exceeded.
To ensure the quarterly evaluations are performed and in a timely fashion, Mechanical Maintenance is computer tracking completion of the evaluations.
Additionally, to ensure consistency within the evaluation process, the Mechanical Maintenance Group Supervisor is reviewing the quarterly evaluation reports.
With regard to your request for additional information about the effectiveness of the SNPP implementation, Sequoyah has identified the commitments contained in the SNPP and entered them in the CCTS as described earlier. Additionally, we have reviewed the text of the SNPP in an attempt to identify the stated intentions. The results of this review were then distributed to the appropriate responsible supervisors with instructions to ensure that the intentions are implemented as stated. Furthermore, as a result of this Notice of Deviation, the Site Director has reemphasized.to the plant staffs that statements of intention, as well as commitments contained in the SNPP, must be accomplished and that, if any changes of those stated intentions or commitments are required, NRC must be notified.
0479h t
Attachment i l
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~.-r Confidential EMPLOYIE PERFOR.'tANCE REPORT Above Average Performance Personnel Error Failure to P:llow Below Average Performance Instructior.s Supervisor Immediate Sunervisor Emplovee DATE OF EVENT DESCRIPTION Submitted By INVESTICATION/CO.WENTS t
l RECO.'D!ENDATIONS i
l 4
i 4
l Attachment.
RIR/DNP PRO /DR Sectton Supervisor,3 5 l
TVA 1890 I
OTHER Maintenance Superintendent /Date i
cc:
Supervisor j
l Foreman Employee l
Page 1 of 3
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MANAGEMENT SKILLS Social Security Number SKILL JUSTIFICATION FOR RATING RATING PLANNING AND ORGANIZING NA E
S P
A U
CONTROLLING NA E
S P
A U
SUPERVISION NA E
S P
A Ui COMMUNICATING NA E
S P
A U
TEAMWORK NA E
S P
A U
DECISION-MAKING NA E
S P
A U
i PROBLEM SOLVING / ANALYSIS NA E
S P
A U
_ld
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EEO/ AFFIRMATIVE ACTION NA E
S P
A U
ADAPTABILITY NA E
S P
A U
i l
EMPLOYEE SAFETY AND HEALTH NA E
S P
A U
l
Page 2 of 3
' Su~pervisor's Comments:
Name Social Security Numb:r Employee Comments:
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l Exciptional: Outstanding performance-highest possible rating.
Superior: A commendable performance. Highly effective performance in many key areas.
Proficient: A satisfactory and acceptable performance in all job requirements.
Adequate: An acceptable job performance in that most minimum standards are met but certain job elements need t
l improvement.
! Unsatisfactory: Unacceptable performance. Fails to meet even minimum standards. Management action necessary l
unless positive indications of improved performance are shown.
- o,
_MtN1 MUM QUALIFICATION REQUIREMENTS (continued)Page 3 of 3
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TVA 128 (PD-1144) SHEET lli OF lit. Back
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