ML20247R060
| ML20247R060 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/31/1989 |
| From: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906070125 | |
| Download: ML20247R060 (23) | |
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- j, TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 374o1
-6N 38A Lookout Place P
May 31, 1989.
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.U.S. Nuclear Regulatory Commission L
ATTN: Document Control Desk Washington, D.C.
20555
'Gentiemen:
In'the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority.
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50-328 SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - INSPECTION REPORT NOS. 50-327,-
- 328/89-01 -' RESPONSE:TO THE 1989 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
The preliminary SALP.for.Sequoyah units 1 and 2 for the period of February 4, 1988, to February 3. 1989, was issued b'y NRC on-April 14, 1989. Subsequently, a meeting was held'in Knoxville, Tennessee on May;5, 1989, between NRC and TVA representatives.to~ discuss the SALP report.: -In TVA's opinion, the May 5, 1989. meeting was both useful an,d productive as a forum for the exchange
-of viewpoints and positions; the meeting served its intended function to l-identify'the various issues facing Sequoyah and to clarify the areas.needing Lfurther emphasis end improvement.
TVA believes the 1969 SALP provides a balanced and even-handed assessment of Sequoyah's performance-during the past year. TVA is extremely proud of the steady progress evidenced at Sequoyah over the last two years; however, we dearly recognize that.many challenges still lie ahead and that further improvement-is essential. TVA believes the ratings and-recommendations of the SALP Board are a valuable source of input to the continuing process of eveluating snd improving performance. As indicated during the May 5, 1989 meeting,=TVA e.oncurs with the Board's overall ratings and is responding to the principal areas identified by the SALP Board as needing improvements by providing a description of the corrective actions taken or planned to address these areas.- One of 17A's goals for the next year is improved performance at the Sequoyah plant.- To 1.his end, TVA has initiated a SALP Improvement Program to monitor the progress and effectiveness of corrective actions taken to address SALP-identified weaknuses. Enclosure 1 contains a description of some of the corrective actions that have been taken or are planned in pursuit of this improvement goal. A summary statement of the commitment made in this letter-is contained in enclosure 2.
TVA believes that the corrective actions presented in enclosure 1 are responsive to the concerns of the Board. As part of its SALP Improvement
. Program, TVA will aggressively pursue each corrective action implementation
..during the next assessment period. TVA expects to have a detailed acticen plan developed by July 31, 1989. Programmatic strengths will be monitored through 8906070125 890331 DR ADOCK 0500 7
6 An Equal Opportunity Employer i
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' 'U.S. Nuclear Regulatory Commission May 31, 1989 periodic performance evaluations by the responsible line managers, quality assurance-oversight, and special reviews by responsible offsite evaluation and support groups.- Prior to the next SALP report for_Sequoyah, a report will be provided to NRC describing.the status and results of'these corrective actions.
~Please feel free to call me if any questions arise on these matters or if additional clarification is needed.
Very truly yours, T
VALLEY AUTHORITY
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r Kings Senior V ce Pr Nuclear er Enclosures cc (Enclosures):
Ms. S. C. Black, Assistant Director
.for Projects TVA-Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear' Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 l
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ENCLOSURE 1 TVA SEQUOYAH NUCLEAR PLANT RESPONSE TO 1989 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) r l
I.
FUNCTIONAL AREA: Plant Operations i
BOARD RECOMMENDATION:
"The Board recognized that significant experience was gained through the plant events and activities which occurred during the assessment period and resulted in an improvement in
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l the plant operations area."
RESPONSE: TVA concurs with the Board's assessment of performance in this-functional area. TVA <eknowledges that room exists for continued improvement in plant opera a ns and will continue to emphasize those improvements-over the next year. To that end, a number of corrective actions have been implemented to address current issues'in the plant operations area. A brief description-of some of those corrective actions is given below.
At the request of TVA an Institute of Nuclear Power Operations (INPO) assistance visit evaluating all aspects of day-to-day operations at Sequoyah'is being conducted starting the week of May 22, 1989, to gain from industry--wide exposure and experience.
Issues identified as a result of this visit will be evaluated and actions implemented to correct the problem or deficiency.
A.
Longstanding Hold Orders The SALP report indicated that " longstanding hold orders.
continued to cause an unwarranted number of problems for the operators." TVA acknowledges this observation and agrees problems existed during the assessment period with hold orders; TVA recognizes that a reduction in the number of current longstanding hold orders at Sequoyah is warranted.
Operations management has recently initiated a review of the current hold order log to identify all hold orders that were carried over from 1988 and are still in effect. Action plans and implementation schedules are being developed to disposition these hold orders with the exception of permanent clearances (e.g.,
moveable detector probes) to reach a goal of no more than a few outstanding hold orders.
TVA management intends to provide aggressive oversight in this area to ensure an expeditious reduction in the current number of longstanding hold orders and improved control of hold order duration in the future.
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. l B.
Root Cause Determination The SALP report indicated that " root cause determinations did not involve sufficient first line operations management efforts which resulted in a protracted resolution process." Nuclear Power has established a formalized process for investigating and reporting plant abnormal events and incidents. This process provides for immediate notification of the event / incident to senior plant and corporate management in order to ensure management involvement
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upfront in order to provide the needed direction to control and mitigate the effects of the abnormal event / incident.
Event / incident investigations are now the responsibility of line managers who are most familiar with processes and equipment associated with the event.
By serving as team leaders, these managers learn firsthand the mistakes that are being made and are actively involved in determining both the immediate corrective actions taken in response to the event and the long-term corrective actions taken to prevent recurrence. Direct line management involvement is expected to prevent a protracted resolution process and provide line organizational ownership of corrective actions.
Other personnel who will typically serve on investigation teams include Nuclear Assurance and Services personnel and personnel involved with the Nuclear Experience Review program to gain the benefit of industry experience when determining root cause and corrective actions.
In addition, root cause training has been improved and expanded and is required for personnel performing root cause analyses.
In order to identify trouble areas or groups, trending of abnormal events / incidents will be performed to show where further corrective actions may be required.
The investigation and reporting process also requires that preliminary and final event reports be written and distributed to keep both p?. ant and corporate management better informed of the root cause and corrective actions associated with each abnormal event. These reports are also sent to the other TVA nuclear sites to be evaluated for implications at those sites and to share
" lessons learned".
C.
New Operator Pass / Fail Rate The SALP report observed that "the percentage success rate for new operating license candidates was determined to be below Sequoyah's Operations management and the Licensed average.
Operator Training management of Nuclear Training have reviewed the license training program as well as the trainee selection and evaluation processes to determine the cause for the below-average performance. Areas for improvement in performance were identified and will be implemented before the next group of trainees is selected.
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> It is TVA's opinion that Sequoyah's below-average performance on the last examination was primarily the result of an effort to
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markedly increase the number of licensed personnel at the facility 1
in a relatively short period of time without' adequate experienced senior instructor participation and involvement.
In addition, it is now recognized that the trainee selection process and.in-process I
evaluations during training were not sufficiently thorough or critical.
I The following actions are being taken to improve TVA's performance in this area. Operations line management and Nuclear Training are implementing a more rigorous selection process that will provide stronger' assurance on the front end that potential candidates have the prerequisite. knowledge and skills to perform successfully in-the program and later as a licensee. When scheduling training the ratio of trainees to instructors will be limited to ensure that the trainees receive more individual attention from experienced instructors. Senior instructors will be used more extensively in the license training program. The last operator license training class was' conducted for the most part by junior instructors due to senior instructors being used to prepare and provide special r
training to meet startup-commitments. This situation will not be allowed to' recur. TVA will also increase the frequency of performance evaluations conducted by line management and Nuclear Training management during operator license training.
In addition, the sequence of presentation of topics in the operator license training program will be modified to ensure that topics are presented in the most consistent and educationally effective mar.ner.
TVA management will continue to focus attention on this issue to ensure that the performance of operator license candidates is improved in the future.
D.
Control Room Nuisance Alarms The SALP report indicated that " nuisance alarms.
. continued to cause an unwarranted number of problems for the operators." TVA recognizes that a " dark board" annunciator system is the goal of several current industry-wide initiatives and intends to pursue a dark board at Sequoyah where economically practicable.
Recently while at 100 percent power on both units, a total of 30 nuisance alarms were identified in the horseshoe area of the l
control room.
TVA is evaluating these alarms with respect to engineering requirements and the potential benefits to operators.
A dedicated project manager has been assigned and is currently working with Nuclear Engineering to develop a schedule for the design phase of this project.
Implementation of the design changes will be separated into outage and nonoutage phases and is scheduled to be essentially completed by the cycle 5 outages.
4 As a related item. TVA has a program to minimite the number of outstanding control room work requests.
The Maintenance department is establishing control room work request priorities, coordinating the resources to complete the work requests, and expediting their scheduling. The program goal is to expeditiously reduce the current backlog of control room work requests and to establish the work practices needed for more expeditious handling of control room work requests.
E.
Feedwater Control System The SALP report noted that "a poor feedwater control system design and operating philosophy existed." TVA has conducted a review of 11 reactor trips that have occurred on the Sequoyah units since restart. The results indicated that nine reactor trips involved
.feedwater in some manner. Four of these nine reactor trips involved feedwater control problems during startup. TVA has concluded that six of the feedwater-related reactor trips have relevant similarities. Common elements were identified and evaluated to formulate short-term and long-term corrective actions in the areas of operations, mal'tenance, and engineering. This n
information was discussed in more detail during a meeting with the NRC staff on April 23, 1989. A follow-up submittal to NRC was made by TVA on May 5, 1989, to formalize the commitments. A summary of the corrective actions presented in the meeting and discussed in the follow-up letter is provided below.
TVA believes these actions will have a very significant effect on reducing the number of startup-related feedwater reactor trips.
In the operations area, the corrective actions include the standardization of procedures and training for feedwater control methods during startup, reinforcement of the desired operational philosophy to not accept hardware deficiencies, and a long-term operations personnel development program that includes direct association and involvement with industry top performers and INPO evaluators.
In the maintenance area, the corrective actions include the use of dynamic calibration methodologies for feedwater controls and the development of a comprehensive checklist of equipment conditions, calibrations, and test activities to be performed each refueling outage and before unit startup.
In the engineering area, studies are being performed in the following areas:
integrated feedwater control system review, main feed pump turbine speed control system, and feedwater control valve characteristics. Several hardware upgrades will be made in future outages. These upgrades include a standardization of the feedwater bypass valve controllers, protection set replacement with the digital Eagle 21 system, Westinghouse Owners Group startup trip reduction package (environmental allowance modifier and trip time delay for steam generator low-level reactor trip), and permanent improved steam generator level recorders for enhanced startup feedwater control.
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.F.
. Longstanding Temporary Alteration Control Forms (TACFs)
The SALP report noted that " operator awareness and control of long standing TACFs in relation to their effect-on plant configuration... continued to be an-issue during the assessment period. TVA has recognized the problem of longstanding TACFs and has initiated a corrective action program.
In October 1988, a total of 89 TACFs existed'that were issued before 19.88. Currently-the backlog has been reduced to 57 pre-1988 TACFs. Action plans to.
eliminate each of the remaining 57 TACFs.have been developed and scheduled and have been assigned to a responsible project manager.
The goal for Sequoyah is to reduce the backlog of pre-1988 TACFs to-27 by October 1989 and to have all but four of these TACFs closed by the end of.the unit 1 cycle 4 refueling outage. The four-exceptions are on the Unit 2 upper head injection system which is scheduled to be removed during the unit 2 cycle 4 refueling outage.-
To avoid recurrence of.the problem with longstanding TACFs, actions have been taken to limit the use of TACFs. The current program requires that new TACFs and extensions for existing TACFs be approved by the Plant Manager. Review by the Plant Operations Review Committee (PORC) is also required before implementing a TACF on critical structures, systems, and components. Management attention in this area will be maintained to ensure continued progress.
G.
Water and Waste Processing Group (WPG)
The SALP report noted and accurately reported weaknesses in WPG training, procedural adherence, and mana6ement. TV4 determined that the root cause of the WPG weaknesses discusseu in the SALP was the lack of management attention in the area of water and waste L
processing. During the concentrated and extensive efforts to restart Sequoyah, the WPG organization and radiological waste systems were not as closely scrutinized as other areas because they were not within the typical restart scope (i.e., these systems and activities were not required for safe shutdown or accident f~
mitigation). Another contributing factor was that although WPG I
was part of the Operations organization, it generally functioned as a separate entity; this contributed to a lack of implementation of overall operations upgrades and initiatives by the WPG organization. This contributed in some cases to a less than appropriate attitude in personnel regarding use of procedures and acceptance of procedural and hardware deficiencies.
Upon recognition of this situation, Sequoyah management initiated comprehensive actions to resolve identified problems and generate an overall upgrade in the conduct of operations and other l
activities in the water and waste processing area. Actions include strengthened management oversight, extensive personnel training, i
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, procedural upgrades, and design deficiency reviews. Details of the corrective actions and plans were provided in TVA's response to violation 50-327, 328/88-50-01, dated May 10, 1989. This information is summarized below.
In the management oversight area, WWPG management is now actively involved in day-to-day operation of WWPG activities. Managers are walking their spaces, observing work activities in progress, and continually stressing compliance with procedures.
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In the training area, an in-depth training program for WWPG employees has been established. This training is intended to provide WWPG management and employees with a thorough understanding of how the radiological water and waste systems work and the logic behind.the methodology of current procedures. The training is also intended to stress the importance of strict adherence to procedures and to reinforce that work should be stopped and procedures revised if they are discovered to be inadequate.
In the procedures area, a detailed review and validation of procedures used by the WWPG have been performed to ensure existing procedures are technically adequate to conduct current activities.
In addition, these same procedures will be revised to enhance the -
performance of WWPG activities and to reflect any improved methods of operation. Training will also be conducted on the enhanced procedures.
In the design deficiency area, a review of outstanding and cancelled design change requests (DCRs) related to the radiological waste processing system will be performed to reevaluate the need for the change and any impact on operation.
TVA is also evaluating existing equipment to determine what, if any, additional enhancements or modifications are needed to ensure adcquate control is maintained during system operation.
Close management attention will be maintaired in this area to ensure the needed progress and improvement.
II.
FUNCTIONAL AREA: Radiological Controls BOARD RECOMMENDATION: None
RESPONSE
TVA agrees with the Board's evaluation of this functional area.
It should perhaps be noted that the violation discussed in the first paragraph on page 29 pertaining to two auxiliary unit operators unknowingly working in a high radiation area was denied by TVA in the response to violation 50-327, 328/89-05-04 dated April 17, 1989.
This matter is still under consideration by NRC.
TVA acknowledges the Board's observations on the percentage of the total plant area that is controlled as radioactively contaminated and will concentrate efforts on reducing this percentage. This effort is
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. i expected to reduce personnel exposure and contamination as well as
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l improve access to plant' equipment.- TVA appreciates the observations in this functional area and intends to use this feedback to further improve performance in the radiological control area in the future.
III. FUNCTIONAL AREA: Maintenance / Surveillance i-BOARD RECOMMENDATION: "The Board recognized that improvements in the maintenance area were the direct result of initiatives instituted by.
the new maintenance management. The Board also recognizes that an aggressive PM program has been developed, but is not fully implemented, and that benefit to the equipment has not yet been realized."
RESPONSE: TVA concurs with the Board's findings in this functional TVA remains dedicated to continued improvement in the
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- maintenance / surveillance area and the development and implementation of an aggressive and effective preventive maintenance program. A description follows of corrective actions already taken or planned to address the key issues in this functional area.
A.
Outage and Maintenance Schedules The SALP report indicated that " outage and maintenance schedules rarely had any. realistic relation to the actual work being performed in the plant and exhibited continual and predictable schedule slips." TVA agrees with the NRC's characterization and our assessment of this problem area indicates the following contributors.
Maintenance schedules transitioned from being produced by the Planning and Scheduling Group to the new Work Control Group (WCG) established early in the assessment period. This change has experienced some implementation problems but ultimately improved the maintenance scheduling process. One of the problems experienced was that no baseline existed for testing or work activities to be utilized during schedule development.
Coordination between groups responsible for work and testing was less than adequate and contributed significantly to schedule delays.
Several corrective actions were taken with the new WCG to improve the maintenance scheduling process. WCG roles and responsibilities were better defined and interrelationships with other groups, such as Radiological Control and Operations, were refined. Another improvement was to physically route work requests that require impact evaluation, tagging, or radiation work permits (RWPs) through the WCG to hold until the appropriate clearances and permits are issued.
In addition, baseline schedules based on
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. actual performance are now being maintained and used as reference for schedule development.. As a further improvement, the WCG and Operations are being put under a single manager.
Improved coordination should result since prioritization and scheduling will become the responsibility of the manager who is also responsible for establishing plant and equipment conditions.
Even with the aforementioned actions TVA feels that the maintenance l
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scheduling process still needs improvement; Sequoyah must improve-in the areas of detailed schedule preparation and schedule
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execution.. Increased attention is being placed by plant management and corporate management on, schedule performance in the form of accountability thorough preparation, schedule execution, and use of lessons learned by schedule performance critique. A complete evaluation is planned for the entire work control and maintenance performance areas during the summer of 1989. TVA intends to use
-this evaluation to make additional improvements.
B.
Per'sonnel Errors / Inadequate Procedures The SALP report noted "the large number of personnel errors or I
inadequate procedures which resulted in Engineered Safety Feature or. reactor protection system actuations." TVA recognizes the importance of reducing personnel errors and correcting inadequate procedures and is taking actions to achieve this goal.
As-previously committed, the surveillance and maintenance procedure enhancement effort is underway with the goal of incorporating human factors improvements into maintenance procedures and correcting identified inadequacies. TVA agrees that there was an abnormal incidence rate of maintenance personnel errors in the beginning of the assessment period. A significant amount of training, coaching, and discussion with the maintenance / surveillance staff has taken place with the effect being a reduction in personnel errors.
Personnel errors and inadequate procedures are trended and reviewed monthly through condition adverse to quality reports (CAQRs),
potential reportable occurrences (PR0s), licensee event reports (LERs), and stand-alone, root-cause analysis reports. Other cause code categories, such as lack of immediate supervision, numan factors, training, and equipment failure are also trended and reviewed.
Incident critiques and trend reports will be discussed with appropriate site organizations to highlight problem areas and define corrective actions.
TVA does not intend to initiate a new prograra to correct these deficiencies; however, TVA management will continue to actively pursue improvements and will maintain attention required to ensure continued progress.
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4 C.
Surveillance Procedure Adherence The SALP report noted that " surveillance procedural adherence problems continued throughout the assessment period, although improvement in this area was noted." As addressed above, failure to follow procedures was a significant problem early in the assessment period.
Management action in the form of coaching, procedure revision, disciplinary action, and training has been successful in reducing the problem of procedural adherence. This topic is very important to plant management; the importance of following procedures or stopping work on the activity if the procedure cannot be followed has been conveyed to plant employees.
Procedural noncompliance problems are also trended monthly through the CAQR, PRO, LER, and stand-alone, root-cause analysis report reviews for potential adverse trends. Other cause codes, such as lack of immediate supervision, equipment failure, and training are also trended in this monitoring process.
TVA management will continue to monitor these trends and will maintain the coaching, training, disciplinary action, and organizational meetings as discussed in B. above to ensure the current improving trend of procedural compliance continues.
D.
Open/ Unattended Work The SALP report indicated " work in progress was often left open, uncovered, and unattended during work crew breaks and turnover periods."
TVA acknowledges this assessment and agrees there is a need for improved work housekeeping practices. With both units back in service, maintenance initiatives are being planned to establish cleanliness " zone" controls from a maintenance perspective with dif ferent zone levels based upon the system or area af fected (e.g., zone 1--open primary system, zone 2--open critical system, zone 3--open system, zone 4--plant in general). Additionally, signs to post at jobsites identifying who is responsibic for jobsite cleanliness have been procured for use by all maintenance foremen and will be used initially on a selective basis. TVA management will continue to be vigilant in this area. The practice of leaving systems open and unattended during breaks and between shifts will not be tolerated.
I E.
Delinquent Preventive Maintenances (PMs)
The SALP report noted a " number of outstanding delinquent PMs, and the existence of a significant percentage of recently developed PMs that had never actually been performed on plant equipment."
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, TVA is aware of this situation and is taking action to address it.
The large number of delinquent PMs during the assessment period resulted primarily from two factors.
First, the number of PM tasks has grown from approximately 2,500 in 1987 to approximately 4,200 presently. Second, due to the extended unit shutdown and layup, PM efforts were redirected toward unit recovery versus operating plant preventive maintenance.
Special studies were commissioned for each unit to determine the necessary preventive actions (e.g.,
inspections) to ensure equipment condition to support unit operation in light of extended layup. These studies resulted in numerous activities performed in lieu of nornal preventive maintenance or performance of preventive maintenance on an accelerated schedule.
In part, the delinquency of the PM tasks resulted from a conscious administrative delay by taking credit for layup recovery equivalent work performed and from.the complexity of accessing the machinery history data base to research equivalent work. The access to machinery history will be improved with implementation of the Automated Maintenance Management System scheduled for August of 1990.
Management recognizes the need to improve the scheduling and execution of PM tasks. With the growth in the number of PMs, a lack of scheduling and work coherence developed as evidenced by multiple equipment outages for PMs that could have been consolidated or grouped and multiple PMs that accomplished the same or nearly the same function. To correct these problems, TVA surveyed PM practices in the nuclear industry and in other industries as well. Aspects of the proposed New Maintenance Rule were also considered as it applies to PM.
This research resulted in the development of a hybrid Reliability Centered Maintenance (RCM) program.
In order to ensure the validity of this RCM approach, a pilot program was initiated on one system. While the results of this pilot program are still being assessed, preliminary findings indicate a successful output for streamlining PM scheduling, combining similar PMs, identifying new PM needs, and analyzing / adjusting PM frequency. The RCM program is also expected to yield an effective performance indicator termed "mean time between failure" that will allow Sequoyah to assess PM program effectiveness. Based on the pilot program results to date, the new RCM program appears very promising in terms of enhancing PM program effectiveness.
In another initiative, Sequoyah has merged the predictive maintenance effort with the preventive maintenance effort. This allows the use of performance monitoring and predictive maintenance techniques to validate PM performance necessity.
PM performance is trended and assessed on a weekly basis by plant management and on a monthly basis by corporate management. Current efforts are producing a downward trend in FM delinquency. Each l
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Maintenance section manager is being held personally responsible J
and accountable for their section's timely performance of PMs and other backlog items.
TVA recognizes the value of a well-run PM program and will continue to develop an aggressive program.
I V.
FUNCTIONAL AREA: Emergency Preparedness BOARD RECOMMENDATION: None RESPONSE: TVA agrees with the Board'c appraisal of this functional area and has implemented corrective actions in response to the identified weaknesses as described below. The principal negative finding in the emergency preparedness area was the timely classification, declaration, and reporting of unusual events.
In response, an Emergency Classification Logic Review Team composed of representatives from operations, training, and the emergency preparedness (EP) staff was established to evaluate and strengthen the unusual event declaration and reporting system. The Sequoyah emergency classification logic, defined in Emergency Plan Implementing Procedure (EPIP)-1, " Emergency Plan Classification Logic," was compared with similar industry procedures. As a result, a functional review of EPIP-1 was conducted to remova ambiguities, inconsistencies, and duplications. This effort is expected to result in an improven.ent of EPIP-1 by making it more specific defining events that require E
emerg y classification. Other EPIP procedures have been revised to clearly define which procedure steps are required under varying stages of emergency plan implementation. Reporting reo",irements in accordance with EPIP-1 have been clearly stated. These actions should reduce the unusual event declaration and reporting inconsistencies encountered during the assessment period.
TVA believes determination of emergency plan classification must be made by use of the logic procedures combined with the sound judgement of the shif t operations supervisor (SOS) and/or Site Emergency Director. While that judgement is vital to safe operation of the facility, it inherently introduces potential for inconsistency. TVA believes requalification training is an appropriate forum to discuss and train on these types of events in an attempt to standardize judgements between SOSs and ensure implementation of appropriate 5
conservatism in those judgements. To implement this philosophy, the EP staff has been used to instruct the EP portion of operator requalification training. Currently, a two-hour class discussion of the 1988 graded exercise report was held during operator requalification training. A four-hour class is scheduled beginning in September 1989 that will include an overview of the Radiological Emergency Plan (REP) and a detailed review of the emergency plan classification logic in EPIP-1. The training for emergency response organization members has also been expanded in duration and focused y
more clearly on specific position duties and responsibilities rather e
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e than teaching a generic training course. These actions, coupled with an increase in the visibility of site EP management and its level of interaction and dialogue with plant and operations management, have resulted in an increased level of awareness and understanding of the REP.
In addition, the duty plant r.anager position provides 24-hour coverage by senior plant managers who are available to the Shift Operations Supervisor for consultation as necessary to assist in the classification of unusual events.
TVA will continue to monitor progress in this fnnetional area and intends to directly involve EP management in operations and training where appropriate to ensure the improvements made in this area are maintained.
V.
FUNCTIONAL AREA:
Security BOARD RECOMMENDATION:
"The Board recommends that the licensee review it's security upgrade priorities at all three facilities to ensure that the Sequoyah security program continues to reduce its long term reliance on compensatory measures in lieu of reliable security equipment and systems."
RESPONSE: TVA concurs with the Board's assessment of this functional area and has taken the initial steps toward a major security system upgrade at Sequoyah with the approval by the Senior Vice President, Nuclear Power to proceed with this upgrade.
Implementation of this upgrade will result in a state-of-the-art security system at Sequoyah by repiccing the outdated security computer system, upgrading the protected area perimeter and alarm system, replacing guard towers with closed-circuit televisions, and installing new keycard readers. Also included in the upgrade is a new protected area access control portal.
The current schedule for completion of this project is October 1991.
l Completion of this capital project should reduce the number of logged
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security incidents attributable to failed equipment and reduce compensatory measures.
i Until the security system upgrade is completed, Security will continue to utilize existing systems and personnel to ensure the security of the plant. Security is also continuing the efforts noted in the SALP l
report to improve training and procedural knowledge as well as improving weapor.s qualifications of response teaa members. TVA management will continue to monitor these areas to ensure the adequacy l
of plant security while reducing to the fullest extent possible the l
reliance on compensatory measures.
l VI.
FUNCTIONAL AREA:
Engineering / Technical Support l
BOARD RECOMMENDATIONS:
"The Board is encouraged by the initiative and efforts expended by TVA to improve the quality and effectiveness of its engineering support for the Sequoyah Nuclear Plant. The Board l
recognizes that a significant amount of complex engineering work was l
completed. Since considerable NRC effort and input was needed to
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.j.< ~ obtain acceptable engineering resolutions, the Board concluded that TVA has not yet demonstrated independent performance at a level greater than that necessary to meet minimum regulatory requirements. The-Board recommsnds that management attention to this area continue, that those long term commitments made to assure continued improvement af ter the -
initial restart of both units be completed as scheduled, and that adequate long term staffing and funding be maintained to support completion of the long_ term commitments."
-RESPONSE TVA agrees with the Board's assessment that engineering needs additional improvement. TVA is in full agreement with the Board's observation that a significant amount of complex engineering work has been completed during both the basis and assessment periods. The Nuclear Engineering organization at Sequoyah has undergone a maturing process during the past two years that, as noted in the SALP report, resulted in improved performance during the latter portion _of the assessment perioda The improving trend noted by the Board _is supported
'by the smoother and faster completion of restart work for unit 1 than
' for unit 2 and the prompt handling of emergent engineering work during the unit 2 cycle 3 refueling outage. Weaknesses and corrective actions' have been identified by Nuclear Engineering management, further indicating a degree of self sufficiency.
TVA clearly recognizes that continued improvement is needed.
Corrective actions.have been implemented or planned to address a number of current issues in the engineering / technical support functional area. A brief discussion of some of these actions follows:
'g A.
Management Attention / Involvement The SALP report noted that inadequacies exist in the quality of some engineering functions and specifically listed design analysis, modification control, engineering documentation, design basis utilization, and design verification as weaknesses. The SALP report also noted that the level of plant support that Nuc1 car Engineering is providing has not been of a consistently high level although recent improvements were noted.
Nuclear Engineering has changed organizational structure to eliminate a layer of manageocnt and has significantly simplified interfaces and procedures over the past three years. Other organizational changes are being evaluated for further improvement.
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- *. t m p The results of a recent assessment of engineering performance at-Browns Ferry Nuclear Plant are being applied at Sequoyah. The
-engineering management structure is being streamlined, as discussed above, and the planning and scheduling system will be enhanced to focus on deliverables.
Increased emphasis on common approaches between plants and improved plant interfaces will also be instituted as a result of the Browns Ferry assessment.
To improve Nuclear Engineering's responsiveness to plant support needs, a goal-oriented process has been established to focus the organization's energies tcward management-directed priorities.
Several corporate-level goals being implemented this year will strengthen the operational support provided by Nuclear Engineering.
Improvements include instituting a three-phase work crder process (i.e., study, detailed design, and implementation),
establishing a list of deliverables and productivity performance process measures, and enhancing engineering procurement support by using electronic procurement methods to streamline'the process. To i
further strengthen Nuclear Engineering's support of operations, an
" operational support unit" will be implemented at Browns Ferry.-
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After evaluating and refining this support unit's performance in handling emergent work and responding to high priority issues, implementation of the concept will proceed at Sequoyah.
At the time of this submittal, Nuclear Engineering is participating in the development'of the five-year integrated living schedule to facilitate long-term planning. Engineering has improved planning activities in concert with the plant by identifying outage scopes with sufficient-leadtime to allow timely delivery of engineering
-designs and materials. Nuclear Engineering is also actively involved in the screening and prioritizing of design change
' requests (DCRc) for future plant improvements and modifications.
As the Board noted, the quality of the output from engineering is acceptable and improving. One indicator is that the number of CAQR corrective action rejections and commitment completion rejections has decreased.
In addition, improved procedural compliance since January 1988 has resulted in fewer CAQRs and audit findings.
However, TVA believes that quality can still be improved and should come about with smaller span of control of the work, better short and long range planning, and the aforementioned changes to structure and reporting _ relationships within Nuclear Engineering.
Engineering is currently playing a more visible and involved role in the day-to-day operation of the plant. _ Duty engineering managers are availabic seven days per week with increased coverage during outage periods. A call-in duty staff is established and available during weekends and holidays.
4,ddition, Nuclear Engineering has been made a part of reactc trip assessment teams that are formed and is now a voting, member of PORC.
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. Nuclear Engineering management has initiated action to mandate reviews of functional changes to critical documents such as criteria, specifications, design basis calculations, diagrams, and selected licensing submittals. The review process will be revised to specify review attributes. The execution of the process will be monitored through the review of completed packages.
In addition, Nuclear Engineering management will ensure that the review process used in preparing change packages is effective in eliminating errors and incomplete evaluations in these packages.-
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In summary, TVA believes considerable progress has been achieved in the area of Nuclear Engineering management attention / involvement and intends to continue focusing management attention on this area to ensure continuation of the improving trend noted in the SALP report.
B.
Engineering / Plant Staff Interface on Vendor Manuals l
The SALP report noted "an interface problem was also identified between engineering and the plant in relation to vendor manuals having conflicting data and resulted from a lack of communication between the two organizations." TVA acknowledges that several problems have been identified in the current vendor manual program mainly in the implementation of the overall program. The need for further improvements is clearly recognized.
Completion of a TVA ascessment of identified problems and possible program improvements is currently pending. Actions being considered include procedure' changes intended to address identified program and interface weaknesses. The procedure changes are intended to clearly define organizational responsibilities, establish the appropriate mechanisms for the plant staff to provide feedback and obtain engineering support for vendor manual utilization, and define how deviations from vendor recommendations should be addressed or dispositioned. Additional actions may be identified upon completion of TVA's assessment.
In reviewing this issue, TVA has also evaluated whether adequate feedback exists between the plant and engineering organizations regarding the acceptance of deliverables in general, such that assurance is provided that the deliverables are correct, useable, and nmintained as such. The results of this evaluation indicate that interfaces and feedback mechanisms between these organizations are generally good, although occasional examples of improper program implementation or less than adequate communication have been identified. TVA remains keenly aware of the importance of timely and quality engineering support of plant operations and will continue to monitor existing interfaces to ensure adequate feedback exists to verify the quality of plant support.
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,4 2 C.
Open Plant Change Package Backlog The SALP report noted that "there were approximately 1300 engineering design change workplans remaining open, some dating
-back to 1980." 'TVA recognizes the need to reduce the backlog of open plant change packages and has initiated action to accomplish this objective.
An overall backlog reduction program for CAQRs, engineering change notices (ECNs),' design change notices (DCNs), and employee concerns is underway; significant progress is being made. More than 630 ECNs/DCNs have been closed at Sequoyah since mid-1988. Management l'
has provided direction to close work-complete ECNs/DCNs within 60 days rather than within six months as required by current' procedures. Procedures are being revised to incorporate this requirement.
As noted in the'SALP report, primary control room drawings have been upgraded and are being kept current.
In addition, ECNs related to the FSAR in the backlog of " field implemented" have had their.FSAR drawings updated and included in the April 1989 FSAR-update. FSAR drawings will be kept current.in cach subsequent.
annual update as well.
Updates are in progress to the Design Change Document Tracking System to enhance its use as the drawing configuration control tool as.well as the master drawing log. This updating also provides the basis for drawing updates and will enhance and accelerate ECN/DCN closure. Work is nearing completion on a review of "old process" ECNs' intended to speed up the elimination and closeout of that process. The review is intended to identify those ECNs for which completion under the'old process is not required for plant safety.
At closure, these ECNs will have-their scope reduced. Any remaining work'will be repackaged in a new process DCN if required. A similar evaluation will be performed on the transitional process ECNs.
T % management is clearly not satisfied with the backlogs addressed I
carlier and will continue to focus attention on this area to ensure h
continued reduction.
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Resource Levels te Meet NRC Commitments The SALP report recommended that " adequate long term staffing and funding be maintained to support completion of the long term commitments." As stated in the May 5, 1989, SALP meeting with NRC, TVA policy will ensure that the necessary support to meet its commitments will be provided.
TVA recognizes the challenges of sustaining this policy and realizes that very close management attention will be required to complete its commitments in a timely manner. Development efforts
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.. are continuing on a five-year Integrated Living Schedule that will ensure an adequate planning horizon to schedule resources to meet corporate commitments.
In addition, administrative requirements were instituted during.the assessment period that reqaired resource estimates and funding approval before any new major commitments are made unless a significant safety problem was identified.
TVA management will monitor progress in this area very closely.
VII. FUNCTIONAL AREA: Safety Assessment / Quality Verification BOARD RECOMMENDATION: None RESPONSE: TVA concurs with the Board's assessment of performance in this functional area. TVA recognizes that improvements in some aspects of the safety assessment / quality verification area are needed and has initiated corrective actions to achieve these improvements. A brief description of some of these corrective actions follows.
A.
10 CFR 50.59 Program The SALP report noted four weaknesses in TVA's 10 CFR 50.59 program:
(1) "non-conservative translation of regulatory requirements into procedures," (2) " lack of qualification requirements for the performance of screening reviews," (3) " lack of definition for when interdisciplinary reviews were required,"
and (4) " coordination of the reviews between groups." The SALP report also noted that "these weaknesses indicated minimal management involvement in assuring the quality of this function."
TVA recognizes that problems exist in the 10 CFR 50.59 program and has initiated corrective actions. Nuclear Power Standard 6.1.3,
" Reviewing and Evaluating Changes, Tests, and Experiments," was issued on March 31, 1989, using selected material from the Nucicar Utilities Management and Resources Council (NUMARC) guidelines.
This new standard defines terminology used in the Code of Federal Regulations and provides improved detail to the preparers and reviewers of safety evaluations so that the desired level of quality can be achieved.
TVA intends to incorporate NUMARC/NRC guidance more fully when a final version is published.
Other recent enhancements to TVA's 10 CFR 50.59 program iaclude a required two-day training program and a requirement that personnel performing or approving safety evaluations be trained managers, senior engineers, or the equivalent.
In addition, the total number of personnel certified to perform 10 CFR 50.59 evaluations is administrative 1y limited to ensure that those individuals who are l
certified are sufficiently knowledgeable of plant systems, the l
plant FSAR, and technical specifications. Moreover, the process l
now requires PORC review of the safety evaluation and the personal approval of the Plant Manager or a specified designee of the Plant j
Manager.
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TVA is still not satisfied with its implementation of 10 CFR 50.59 requirements and recent events which occurred before implementation of improvements rtated in the above paragraphs have validated that additional improvement is needed. As a result TVA will conduct a complete reassessment of its 10 CFR 50.59 program to assess the effectiveness of recent improvements and to identify and correct other weaknesses.
TVA management and the Quality Assurance organization will aggressively monitor implementation of the improved safety evaluation program to ensure improved performance in this area.
B.
Relationship Between Quality Assessment Organizations The SALP report commented that the "the NSRB has continued to show a low profile with respect to onsite activities." TVA acknowledges this comment and agrees it would be constructive to clarify the relationship between the several TVA quality assessment organizations. TVA intends to continue assessing this area to identify ways to improve the interrelationships of the four
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principal quality assessment organizations: Nuclear Safety Review Board (NSRB), Independent Safety Engineering Group (ISEG), Nuclear Manager's Raview Group (NMRG), and Nuclear Quality Assurance (NQA).
The role of the NSRB with respect to onsite activities continues to be refined. Recently, the composition of the NSRB was altered to include more senior site managers in order to ensure better communication and more direct resolution of NSRB concerns. The impact of the NSRB on onsite activities is also being enhanced by placing greater emphasis on subcommittee investigations.
TVA will continue to refine the roles of its quality assessment organizations in pursuit of an optimal balance between onsite and offsite activities that will enhance the quality of the overall assessment process.
C.
Quality of Communications with NRC i
In addition to generally favorable cocments on the timeliness and quality of submittals, the SALP report noted some problems with incomplete or late submittals. TVA has taken a number of actions to improve the quality and timeliness of communications with NRC.
TVA conducted a review of procedures governing submittals to NRC in order to ensure that proper guidance was provided regarding completeness and accuracy. A number of improvenants were made to strengthen the submittal process. Changes were made in the areas of assignment and documentation, certification of information, signature responsibilities, and reconcurrence guidelines. TVA believes that the changes made to Nuclear Power Standard ONP-STD-6.1.4, " Managing TVA's Interface with the NRC," will improve both the quality and timeliness of TVA submittals.
The review process and improvements were more fully described in TVA's letter to J. Lieberman, NRC, dated March 24, 1989.
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, The SALP report noted some problems with TVA preparations for meetings. The changes to Standard ONP-STD-6.1.4 also strengthen the guidance regarding preparations for meetings.
Specific responsibilities and duties are outlined for meeting preparation.
These changes are intended to provide more thorough preparations for TVA/NRC meetings.
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The SALP report noted weakness in the commitment management program regarding scope and schedule changes. Sequoyah has' strengthened
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the process for authorizing commitments. Sequoyah Standard Practice SQA-135, " Commitment Management. Tracking, and closure,"
was revised in December 1988 to include upfront resource estimates. The front-end estimates are intended to ensure that scope, resources, and schedule are better defined at the time the e.ommitment is made. This process is expected to lead to better commitment performance and eliminate the need for many scope and schedule changes. Major scope or schedule changes for significant commitments will be discussed with NRC before implementation.
This process was reviewed by NRC during the recent quality verification inspection and found acceptable (Inspection Report 50-327, 328/88-50, dated April 10, 1989).
In addition to the actions discussed above, Nuclear Power has instituted a licensing project management role within the Licensing organization for significant regulatory issues. The licensing project management process involves several steps from initial identification of significant issues through documented clouure.
Key activities in the process include assignment of a licensing project manager, preparation of an issue summary for upper mana;ement, development of strategic and detailed action plans, and documentation of completed actions to support closure. Performance monitoring goals have also been established for both timeliness of submittals and commitment performance. These actions are being implemented in order to bring about improved regulatory performance.
D.
Organization Interfaces for Quality Verification The SALP report commented that "the use of interfaces between groups... to verify and accept quality when deliverables were i
transferred was not emphasized as a quality verification tool."
TVA acknowledges this comment and agrees that greater emphasis is needed on the use of organizational interfaces for quality verification.
Although not referred to in these terms TVA has been successful in using organizational interfaces in some areas to verify and accept quality. This process has been implemented through review and feedback mechanisms in such programs / areas as the verification and validation process used in the surveillance instruction review program, Licensing review and quality assurance verification of NRC commitment closure documentation, physical walkdowns of design packages by modification implementors before implementation, and
. the surveillance instruction document closure group example referenced in NRC's Quality Verification Inspection (Inspection Report 50-327, 328/88-50, dated April 10, 1989). A broader use of interorganizational interfaces at Sequoynh is in outage schedule preplanning, in-process outage reviews, and postoutage critiques.
TVA recognizes that the fundamental requisites to using organizational interfaces for quality verification are well-established communication and fevdback mechanisms and clesr
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lines of responsibility and accountability. The interface problems in the area of vendor manuals discussed ir.Section VI resulted primarily from weaknesses in these fundamental areas.
TVA will reassess organizational interfaces where past corrective action has not proven effective and will emphasize the use of these interfaces as a quality verification tool to a greater degree in the future.
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VIII. SUMMt.RY TVA appreciates the open and candid relationship that exists with the NRC. The assessments made in the SALP report are valuable input to the continuous process of evaluating and improving our overall performance. We believe that the corrective actions described in this letter address the concerns of the Board and will enhance the nuclear safety of the Sequoyah plant.
TVA management will continue to focus increased attention on the areas needing improvement and will strive to
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maintain current programmatic strengths through periodic evaluations and reviews. TVA considers the SALP Improvement Program to be a commitment to NRC and will use this program to monitor the progress and effectiveness of the corrective actions discussed in this letter. This commitment is restated in Enclosure 2 to this letter. TVA will provide an update to NRC on the status of these corrective actions before the next SALP report for Sequoyah.
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ENCLOSURE 2 LIST OF COMMITMENTS 1.
TVA commits to a SALP Improveme
'rogram that will monitor the progress and effectiveness of corrective Lions discussed in this letter. TVA will aggressively pursue each corrective action implementation during the next assessment period. TVA expects to have a detailed action plan developed by July 31, 1989. A report will be provided to NRC describing the status and results of these corrective actions before the next SALP report for Sequoyah.
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