ML18033B480

Forwards Response to SALP Repts 50-259/90-07,50-260/90-07 & 50-296/90-07 for Jul 1989 - Mar 1990

ML18033B480
Person / Time
Site:	Browns Ferry
Issue date:	08/08/1990
From:	Kingsley O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9008140203
Download: ML18033B480 (70)

Text

ACi ELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9008140203 DOC.DATE: 90/08/08 NOTARIZED: NO DOCKET g FACZL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power 'Station, Unit 3, Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION KINGSLEY,O.D. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to SALP Repts 50-259/90-07,50-260/90-07 &  !:

50-296/90-07 for Jul 1989 to Mar 1990.

DISTRIBUTION CODE: IE40D COPIES RECEIVED:LTR ENCL J SIZE: 5 S TITLE: Systematic Assessment of Licensee Perfor ance (SALP) Report /

NOTES:1 Copy each to: B.Wilson,S. BLACK 05000259 1 Copy each to: S.Black,B.WILSON 05000260 1 Copy each to: S. Black,B.WILSON 05000296 L

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL KREBS,M PD 1 0 KREBS,M. 1 0 KREBS,M 1 0 PD 1 1 ROSS,T. 1 1 INTERNAL: ACRS 2 2 AEOD/DOA 1 1 AEOD/DSP/TPAB 1 1 COMMISSION 5 5 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LHFB11 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB11 1 1 NRR/DREP/PEPB9D 1 1 NRR/DREP/PRPB11 1 1 NRR/DRIS/RSGB9D 2 2 NRR/DRIS/RSIB9A 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1 EWFILE 02 1 1 RGN2 FILE 01 1 1 R EXTERNAL: L ST LOBBY WARD 1 1 LPDR 1 1 NRC PDR 1 1 NSIC 1 1 D

NOTES 5 5 D

D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 39 ENCL 36

'1y TENNESSEE VALLEY AUTHORITY RUB 08 Pg 6N 38A Lookout Place U.S.. Nucl'ear Regulatory 'Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In .the Matter of Docket Nos. 50-259 Tennessee Vali'ey Authority 50-260 50-296 BROWNS'ERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 INSPECTION REPORT 50-259, 260, 296/90-07 RESPONSE TO THE 1990 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT The preliminary SALP report for BFN .Units. 1, 2, and 3 for the period'f July 1, 1989 to March 31, 1990 was issued by the NRC on June 14, 1990.

Subsequently, a meeting was held, at the BFN Training Center on July 9, 1990 between the .NRC and TVA representatives to discuss the SALP report.

Enclosure l,to this letter provides TVA's response to the SALP report findings and recommendations, including a descripti:on of corrective actions and improvements that have been implemented. or are planned to address these issues.

Enclosure 2 provides a listing of specific commitments being made by this submittal.

.TVA considers the 1990 SALP report to provide .a representative evaluation of BFN's performance during the assessment period. TVA recognizes that significant challenges lie ahead and that further improvement at BFN is important for long-term success. 'TVA considers that the ratings, findings, and recommendations of the SALP Board provide valuable: input to 'the process of improving performance at BFN. Our goal is to operate BFN at a level .well above the minimum regulatory requirements. The many actions described in the enclosure to this letter are intended to, be responsive to that goal.

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PDR ADOCK 05000259 9 PDC ~ygP

.An Equal Opportunity Employer

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Nuclear Regulatory Commission AUli 0.8 1990 TVA will continue .to be. diligent in stressing further improvement at BFN as we work toward safe startup, power ascension and operation of Unit 2. TVA will pursue this goal with increased, critical'elf-examinations and prompt corrective actions. Areas of .particular management, emphasis will be the surveillance program and the mod'ifications area. In the former TVA has already taken steps, to improve proced'ures and the attention to. detail of personnel .performing those procedures.- In the latter area management will emphasize both the quality and quantity of the work performed.

Please feel free to contact me if there are any questions concerning the enclosed response or the actions described in that response.

Very 'tru yours, VAL EY AUTHORITY

'. D. ing ey Senior Vice P de Nuclear Power Enclosures cc: See page 3

I U.S. Nuclear Regulatory Commission gus ()8 8%

cc (Enclosures):

Ms. S. C. Black, Deputy Director Project Directorate II-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 Thierry M. Ross, Project Manager U. S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Project Chief U.S.. Nuclear Regulatory Commission Region II 101,Marietta Street, HW, Suite 2900 Atlanta, Georgia 30323

ENCLOSURE 1 TVA Browns Ferry Nuclear Plant (BFN) Response to 1990 Systematic Assessment of Licensee Performance (SALP)

I. FUNCTIONAL AREA': SHUTDOWN OPERATIONS BOARD 'RECOMME DATIONS The Board recommended continuation of the high level of management

.attention to ensure safe and essentially trouble free startup, power ascension and operation of Unit 2. The Board further noted that a more aggressive involvement and a sense of'wnership by the Operations. staff could have prevented some of the problems in other areas such as post-maintenance/modification testing. In addition, the Board recommended that the effort to minimize personnel error continue to receive increased management attention.

RESPONSE

TVA concurs with the Board's assessment in this functional area and agrees with the need for a high level of management attention. To that end, beginning with approach to criticality and continuing into power ascension activities, senior, plant managers with power operations experience will be assigned full-time shift coverage in the power block. TVA will continue the high level of management involvement and attention in the full spectrum of operational activities. ,For example, with respect to operator performance, the Operator Review Committee periodically reviews operator performance,to assess strengths and weaknesses,, and provides remediation where necessary. In the area of operator training,. the high level'f: management attention continues with the Curriculum Review Committee. This committee revi'ews the operator training program from analysis. through implementation and evaluation.

Additionally, TVA's Operational'eadiness Review (ORR) team and the

,Senior Management Assessment Review Team (SMART), through their assessment of Unit 2 readiness for restart, will provide both experience and TVA senior management involvement.

The operations manager chairs biweekly meetings with the:shift operations supervisors (SOS) and weekly meetings with the operations groups to stress ownership, attention to detail, and In addition, the threshold for incident investigations is procedural'ompliance.

being lowered by the plant manager and .site director to reduce personnel errors. For example, .management will concentrate on areas such as ma'intenance rework. and 'inspection rejections. Senior management monitors these incident investigation reports at the plant management meetings.

E, Enclosure 1 Page 2 of 28 Management has taken many corrective actions and will be implementing additional corrective, actions to address current issues in the operations area, particularly in the area of personnel error. A brief description of some of. those corrective, actions responsive to the Board's recommendations and concerns is provided below.

A. Response to Control Room Instrumentati'on During Normal Shift Operations The report stated that the Operations organization continues to have problems with .performing timely and'dequate actions in response to control room alarms assoc'iated with off-normal conditions.

The operators response to alarms, will be improved. First, management has and will continue to communicate to the plant operators its expectations to,ensure that, alarms are adequately investigated when they are received. Through requalification training, biweekly management meetings with the shift operations supervisors (SOS), and daily management tours of the control room, management has stressed to each operating group .that alarms/indications must be, assumed to indicate actual conditions until proven false. Second, operators are being refreshed in the use of alarm response procedures (ARPs).

During operator simulator training,. TVA initiates off-normal conditions which require the use of ARPs and then evaluates the group on their implementation and use. Third, in the event of an inadequate response to an alarm, operations. personnel associated with the event, now perform a review of the event, independent of the incident investigation process, to provide operations, management with, an independent assessment of the, incident investigation conclusions and corrective actions. This ensures prompt corrective actions by the individuals most knowledgeable of the event and also provides an incentive, through peer recognition of errors, for prevention of future events. Finally, control room instrument failures are placed on the daily emergent- work priority list. This list is discussed during.,the daily plant management meeting.

B. Compensatory Fire Protection Measures The report cited continuing problems with compensatory fire protection (FP) measures, and provid'ed, several examples of technical specification (TS) violations assessed during the assessment period.

In February 1990, the responsibility for FP was incorporated'nto the Operations organization. The day-to-day operation of this group is controlled by a licensed, senior reactor operator (SOS qualified) who reports, directly to the on-shift SOS. During backshift and weekends, the,FP foreman reports directly to the SOS. The SOSs have been trained in their duti'es and responsibilities for FP. The effective

Enclosure 1 Page 3 of 28 integration of FP into the Operations organization has been defined as an element of the SOS and assistant shift operations supervisor (ASOS) performance plans (i.e., it will be part of their performance evaluations). The FP'oreman also participates in shift turnover meetings to ensure current plant conditions are known and shift expectations are properly communicated. Numerous management/staff meetings have been held to foster a close working relationship between shift operations and FP personnel. This is expected to promote an increased awareness of FP compensatory measures. In addition, close controls. over FP compensatory measures have been implemented. This includes a computerized limiting condi'tion for operation tracking system maintained by on-shift personnel.

Management will continue to assess the performance of the fire protection program to ensure that identified corrective actions are effective. Additionally, the Nuclear Managers Review Group conducted a special review of the adequacy of our implementation of TS including FP. Noted areas of improvement will be implemented prior to restart.

As part of the realignment of FP responsibilities, a Technical Support Fire Protection organization was established to consolidate the technical function for the FP program in the Technical Support organization. An upgrade program for FP compensatory action procedures has been initiated to remedy programmatic deficiencies in this area. These procedures will be upgraded by November 29, 1990.

C. Ability of the Operations Organization to Function as a Team in an Operating, Plant The report stated that the ability of the new Operations organization to function as a. team in an operating plant has not yet been demonstrated.

TVA has and will continue to take steps to ensure that the Operations organization is prepared to operate BFN prior to restart. TVA has strengthened operations management expertise by hiring three new unit operations managers with considerable experience in plant operations and restart activities. These new managers complement and diversify existing management experience.

At the time of restart, thi's new management team and the majority of the Operations organization will have been working together for over a year.

Prior to startup the SOSs will have participated in INPO peer evaluations at other utilities; SOSs, ASOSs, and unit operators will have received training at an operating plant. In addition, TVA will send assistant, unit operators to. Sequoyah Nuclear Plant (SQN) to participate in operational activities. This will provide these individuals with an opportunity to observe and learn how operational activities are conducted at other plants. TVA believes that this

Enclosure Page 4 of l

28 training and the many testing, surveillance, and system return-to-service activities prior to startup will provide additional opportunities to further develop and solidify this team.

Recent performance during operator requal'ification training and initial licensed operator .examinations also provide evidence of operational readiness. The requalification program provides the operations groups with an opportunity to work as a team during simulator training. Additionally, the restart test program and power ascension program will provide .plateaus for the operating.

groups to develop teamwork. This performance will provide a positive data point for the operations staff to assess measures implemented'o improve teamwork. In addition, the upcoming INPO evaluation will provide TVA with an independent, assessment of the effectiveness of the operations management team and inter-departmental coordination.

D. Housekeeping and Identification of Material Deficiencies in Less Frequently Traveled Areas of the Plant The report noted that while housekeepi'ng is generally good, housekeeping and identi'fication of material,deficienc'ies in less frequently traveled areas of the plant was poor.

TVA will take steps to improve housekeeping a'nd identification of material deficiencies in less frequently traveled areas as well as all areas, of the plant. First, responsibility for housekeeping and identification of material deficiencies will be shifted from system responsibility to plant area responsibi'lity. That is, individual operations groups will be made responsible for housekeeping in specific plant areas. 'Second, operations procedures covering routine walkdowns and examinations of plant areas and equipment have been revised to specifically include housekeeping and identificat'ion of material deficiencies as items to be addressed during walkdowns and examinations.

Additionally, twice per week, operations management performs the Operations Management Observation Checklist to verify appropriate operating .and housekeeping conditions. As noted above, each operating group has also been assigned'pecific responsibilities for monitoring housekeeping and material conditions in the power block.

Once per week, senior site, management conducts a plant tour with emphasis on housekeeping activities.

TVA will continue these practices as equipment and associated areas are returned'o service. In addition,. as physical work decreases in scope prior to startup, station personnel will have increasing control. over housekeeping conditions.

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Enclosure 1 Page 6 of 28

'TVA agrees with this observation and recognizes its past problems with involvement and ownersh'ip by .the operations staff. TVA will expend considerable effort to instill an operational philosophy at BFN. This. philosophy stresses the development and acceptance of plant ownership by. its operators. It also emphasizes teamwork and communication among plant operators, the responsibility for maintaining cognizance of plant status, and following principles of good operation.

BFN plant management is clearly communicating the need to assume ownership of the plant. For example, meetings are currently being conducted on a biweekly basis with the SOS's and operations management. One item continuously stressed i's the need to assume ownership of the plant. Weekly meetings are held with the operations group assigned to training and with a group on shift, where the importance of involvement and plant ownership are further reinforced for the:entire group. Additionally, one of the senior unit managers will be specifically assigned responsibilities with the ass'istant unit, operators to emphasize their responsibilities for space conditions and'quipment operation. 'As noted above, another action taken involves the assignment of a licensed senior reactor operator (SOS qualified) to the FP group to increase operations.

involvement in FP activities.'FN management has designed the System Preoperability Checklist (SPOC) process to close the modificati'ons effort and subsequent system. return-to-service activities prior to startup. This process will provide add'itional opportunity to demonstrate increasing operations involvement and ownership. System return-to-service requires detailed reviews and walkdowns by operations and other plant organizations prior to system acceptance. Additional emphasis will be placed on this area by, operations management, as the return-to-service, process continues for'lant systems. The operations group will be held accountable for systems as they are accepted for operations.

.G. Personnel Error The Board recommended that the effort to minimize personnel error continue. to receive increased management attention.

TVA concurs with 'the Board's observation and is committed to reduce personnel'rror. This commitment is not limited to the Operations organization but extends to the enti're BFN site.

TVA considers that the personnel error problem has several major causes. Personnel errors have resulted in part from a lack of attention to detail and a lax attitude toward. procedural adherence.

Personnel errors have also been influenced by factors such as inadequate procedures and poor. human factors consid'erations. BFN management has taken and will continue to take corrective actions to address these elements of the problem.

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Enclosure 1 Page 5 of 28 E. Management Involvement and 'Attention The Board recommended that the high level of management attention continue to ensure a safe and trouble free startup,, power ascension and operation of Unit 2'.

TVA will continue aggressive management involvement and attention at BFN. This is. especially, important during startup and power ascension, and will continue throughout operation of Unit 2.

Prior to restart, TVA will conduct two senior management reviews:

one by the ORR team and another by SMART.

The eight-member ORR team is independent of BFN management. Only two of the members are TVA employees. The team is experienced in restart efforts. Five members participated in the SQN Unit 2 ORR team, and six members participated in the SQN Unit 1 ORR team. 'To date, the team has conducted two assessments of BFN Unit 2 .readiness for restart: one. in June 1989 and another in March 1990.

Corrective actions to address concerns identified during the two assessments are in the process of being implemented. The team will return prior to restart to perform an independent review of operations and work control.

Subsequent to the ORR team,, SMART wil'1 perform its assessment of BFN's readiness for restart. The team is chaired by the Vice President (VP) of Nuclear Power Production and is composed of other VPs. reporting. to the Senior VP Nuclear Power with BFN support responsibiliti'es. The team .objectives are to: 1) assess whether there has been adequate resolution of NRC commitments, 2) review compl'etion of programs to establi'sh operability of systems, 3) assess implementation of sel'f-assessment programs, 4) evaluate independent review results, and 5) evaluate performance trends.

Additionally, TVA has established a formal management assessment process for the power ascension test program. Seven management hold points have been integrated into the power ascension test program to ensure a controlled return to full power operation. The program will allow management to monitor the progress o'f the startup and evaluate equipment and personnel performance at specific power plateaus to verify that the plant is ready to proceed to the next'.

power level. During the actual startup activities senior plant managers will be assigned full-time shift coverage. These actions

.are intended to provide the high level of management attention necessary throughout the startup.

F. Operations Involvement and Ownership The -Board, as noted above, also generally recommended more aggressive involvement and "sense of ownership" by the operations staff.

Enclosure of l

Page 7 28 BFN management 'is stressing to its supervisors in every organization the importance of communicating the need for procedural adherence and attention to detail. First, the plant manager has had two separate talks with plant personnel (management to craft) to stress the importance of reduced personnel error, procedural compliance, and'ood work practices. Additionally, and as noted above, at the biweekly meetings between the SOSs and operations management, plant ownership, procedural adherence, and reduction of personnel, errors are continuously. emphasized. Weekly meetings are also held with operations shift groups, one by the plant operations manager and one by the operations superintendent, where these items are further reinforced for the entire group. Specific actions in the Modifications, and Maintenance. organizations are discussed in Items A, H and I of the Maintenance/Surveillance functional area. Quality Assurance monitors plant activi'ties to gauge performance in these areas.

As noted above, TVA is aware of instances where personnel have been influenced by factors such as inadequate procedures and poor human factors considerations. BFN management will be self-critical in the evaluation of events through the incident investigation process and is identifying .corrective actions to reduce these impediments. For example, as a direct result of an assessment of events which resulted in ESF actuations,'TVA concluded that the working environment of personnel who generate hold orders was a contributing factor. Consequently, TVA has relocated the operations work control area. The new location is quieter, more private (reducing distractions), contains centralized reference material and provides increased supervision. This area houses the personnel who generate hold, orders (unit operators), personnel who review hold orders (unit managers), and personnel who coordinate work in the plant (shift support supervisors). Personnel who place hold orders on plant equipment (assistant unit operators) al'so work out of th'is .area.

This example illustrates the degree to which TVA will evaluate events in the future. TVA feels that these types of corrective actions will reduce the number of personnel errors.

BOARD RECOMMENDATIO S None

RESPONSE

'TVA's pleased with the Board's appraisal of this functional area.

However, TVA recognizes that. continued and improved performance is necessary in 'the upcoming assessment period in order to maintain the Category l rating. TVA will continue to emphasize a high level, of performance and program development in this functional area.

Enclosure 1 Page 8 of 28 Since mid-April 1990, TVA has taken several initiatives to .reduce personnel radiation exposure. For example, a lifetime radiation dose limit of 1N rem,(where N i;s the individual's age in years) was implemented for BFN workers. in July .1990 based on recommendations of the National Council on Radiation Protection and Measurements and the International Committee on Radiation Protection. A 3.5 rem interim annual administrative dose limit for individuals was also implemented at BFN effective July 12, 1990. Effective January 1, 1991, a new administrative procedure will be in place to restrict dose accrual at BFN.

In addition to the efforts to reduce the individual radiation exposure described above, TVA is implementing measures to minimize collective radiation exposure for the site. A comprehensive source term reduction program is being developed. A. capital project is in progress to clean out the fuel pools for all three units and to chemically, decontaminate the fuel pool cooling heat exchangers. Other elements of the program include cobalt replacement in control rod blades and various system valves, and radiation shield walls around the fuel pool cooling heat exchangers.

ALARA initiatives are also being', incorporated into the planning for Unit 3 recovery. Shielding, decontamination, wipedowns, flushes, and containment devices will be used to minimize personnel exposure.

Portable conti'nuous airborne .contamination monitors will be used where practical to minimize use of respiratory protective equipment. To further reduce personnel exposure video cameras will be used for remote surveillance of work in radiation areas. Generic shield tables are being developed to streamline the process for shielding installation on various components. Shield tables for shutdown and operational conditions, will be completed in Fiscal'ear 1991.

A startup preparation team is being assembled to address radiological controls-specific .concerns associated with the transition from shutdown to operational conditions.. Prior to startup, operations personnel and maintenance craft personnel will be trained in startup and operating radiological conditions. The Radiological Controls organization is, also developing. and implementing a program to aid and encourage radiological controls staff, personnel to become certified by the National Registry of Radiologi'cal Protection Technologists or the American Board of Health Physics.

III. FUNCTIONAL AREA: MAINTENANCE/SURVEILLANCE BOARD 'RECOMMENDATIO S The Board recommended continued management attention in the area of surveillance testing to ensure that the corrective actions taken as a result of escalated enforcement, actions are"effective. The Board also commented that the. maintenance area generally showed significant

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Enclosure 1 Page 9 of 28 improvement but recommended that management attention continue, particularly in areas, not assessed by the NRC's Maintenance Team Inspection. In addition,. the Board noted that implementation of modifications. is a weakness and recommended that emphasis on problem resolution be conti'nued.

~ESPONSE TVA concurs with the Board's appraisal of this functional area. TVA wi.'ll continue to provide'ncreased management attention to the surveillance program in order to monitor the effectiveness of corrective actions already taken and to assure full implementation of corrective actions in progress. TVA is pleased with the improvement in the maintenance area at BFN, but also realizes that several weaknesses remain and,must be corrected. TVA is confident that the changes described below will continue to show improvement. In the modifications .area, TVA will continue the current attention on compliance with programs and procedures, and the completion of older and,more di'fficult workplans. A description follows of actions already taken or planned to address the key weaknesses in this functional area.

A. Modifications Performance The report noted weaknesses in the modifications area, and focused on poor. performance in both the quantity and quality of work output, inattention to detail, poor work practices, and the failure of personnel to follow instructions.

TVA recognizes that performance in the modifications area is a weakness. Accordingly, 'TVA's implementing specific programmatic changes directed to improve the quantity and quality of work and to stress the importance. of reducing personnel errors.

First, TVA is focusing increased attention on the process by which work i's accomplished., TVA concluded that the system was complex.

To correct this problem an increased, effort on streamlining the existing,.program has been emphasized~. Workplans prepared recently are less'han half the size of the workplans prepared one year ago.

Standardization of the. different phases of workplans, computer generation of workplans, and more specific engineering change notices/design change notices have resulted in workplans half the size of work plans prepared one year ago.

Second, TVA management is placing increased attention on compliance with modifications program requirements. As described in Item G of the Shutdown Operations functional area, management consistently emphasizes the importance of procedural adherence. Disciplinary action for repeated or flagrant disregard for procedures can include terminati'on. Face to face meetings between senior management and each craft discipline. are now held to discuss personnel errors and other significant incidents involving modifications personnel.

.I Enclosure 1 Page 10 of 28 Third, to increase accountabili'ty and overall compliance with programs and procedures:and to improve the quality of work performed, the size of work crews has been reduced and standardized to approximately six craftsmen:(within the .technical craft arena).

A Lead Foreman, Quality Control (QC) Inspector(s), and. Field Support Engineer have now been assigned for every two to three crews.

Fourth, TVA reformatted many of the working procedures utilized by modifications personnel and placed them in user friendly formats.

This reduces the burden on craft and QC personnel. Procedure/program orientation sessions have been and continue to be conducted to familiarize workers with program revisions made and with revisions in progress. .Speci'fic areas of orientation include independent verification, second party verification (which was recently initiated as a .management tool') of certain activities to improve the quality of modificat'ions work, and the streamlining of the welding control program. A required reading matrix has also been established for field support personnel as well as craft supervisors.

Finally, TVA recognizes that in the past many projects, were not driven to completion, which caused difficulties in surveill'ance testing and preventive maintenance. To improve in this area, management has initiated an effort to finish- the older and more difficult workplans.

In addition, partially completed modification packages are being researched and forced to completion.

To date, the above changes have resulted in an increase in productivity from 30 percent in total related work at the end of the assessment period to the current level of approximately 50 percent.

In addition, the initial workplan review rejection rate of over 70 percent one year ago has been reduced to less than five percent as of June 1, 1990.

In summary, management attention is centered on total work completion, configuration maintenance, and the research and completion of partially completed modifications. TVA management is focusing on higher standards for employee performance and accountability, which should'mprove performance in the, modifications area.

B. Maintenance 'Backlog The Board concluded that the maintenance backlog at BFN appeared to be excessive. The report also identi'fied a large number of open maintenance requests (MRs)'nd attributed the backlog to inadequate coordination of the work control process, delays caused by the unavailability of spare parts, drawing discrepancies, and incomplete modifications. The report also stated that there appeared to be inadequate coordination between individual maintenance craft groups, and other organizations such as operations, modifications, and planning and scheduling.

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Enclosure 1 Page ll of 28 TVA recognizes that a maintenance backlog exi'sts as identified in the report. BFN is making progress,to address that backlog. At the conclusion of the assessment period'pproximately 2300 outstanding unit 2 startup MRs (now called work orders or WOs) existed. As of the end of July 1990, this number has been reduced to approximately 1400, 350 of which, are for post-maintenance testing only.

Non-restart 'WOs have been, reduced from over 2300 in January 1990 to the current 1200, and late preventive maintenance items which totaled approximately 900 in March 1990 have been reduced to less than 200. A work order review group wil'1 be created to monitor, pri'oritize and reduce the backlog.

Shift managers have been assigned to each shift to provide overall coordination on shift and to ensure accurate turnover to the next shift. This change will increase management's awareness of work status and improves the direct supervision and coordinati'on of work on each shift. The addition of management personnel also ensures the continuity of critical work, and allows management to correct problems expeditiously and remain aware of potential problem areas.

Another improvement i's in the area of work scheduling. Prior to schedul'ing work, each work request is evaluated by the scheduling group for system/component impact. Work schedulers then coordinate work on an individual system/component to reduce outages, maximize accomplishments during outages, and return equipment to service expeditiously. Schedul'ers work closely with the maintenance general foreman who ensures that scheduled. work can be performed.

Management will monitor work completed on a daily basis.

To enhance the scheduling process TVA has,established a scheduling information center that provides the- maintenance general foremen, foremen, and planner access to information. This action will enable the foremen to acquire an understanding of the impact of each maintenance assignment. The information center allows supervisors to identify backlog tasks ready to be worked when scheduled work is completed early, or to determine when work cannot be completed as planned. Additionally, work schedules will be reviewed and accepted by foremen and general foremen to ensure commitment to the schedule.

To address the drawing aspect of this SALP Board finding, the work

,process will be improved. BFN's previous process for implementing MRs/WOs required'hat work be stopped and a drawing deviation (DD) initiated if the as-installed configuration of a component being worked on did not match an as-constructed drawing. Work could not be resumed until the DD was resolved, thus contributing to the MR/WO backlog. To alleviate this problem, Site Director Standard Practice (SDSP) 7.6, "Maintenance Management System,." has been revised to allow reinstallation of components based on Nuclear Engineering (NE) approved drawings, manuals, and specifications. In

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Enclosure 1 Page 12 of 28 addition, SDSP 9.1, "Processing Drawing Discrepancies," has been revised to allow MR/WO work to continue utilizing the DD and a marked-up drawing as long as the MR/WO maintains the exi'sting plant condition (leaves the plant configuration as-found).

F To correct problems with material availability, in early 1990 the Materials and Procurement organization implemented an action plan to achieve a 95 percent service level'n parts and material availability. To support this goal specific actions were defined and, are being implemented. This included identification and listing of material availability deficiencies followed by analysis to determine generic/programmatic problems. This analysis identified the following generic problems with the availability of materials:

1) the quantity and location of materials. is not accurate, '2) stock materials are not reordered in a timely manner, 3) procurement lead.

times are insufficient, and 4) interfaces with other plant

.organizations are ineffective/inefficient.

Upon completion of the analysis actions were developed to resolve these problems and deficiencies. For example, to address the problem with the quantity and location of materials, TVA has performed an inventory of the warehouse located in the protected area, established a dedicated inventory control department, loaded direct charge material into the Materials Automated Management System database, and improved the methodology for returning credit material to stock. In addition, the Materials and Procurement organization coordinated with the ma'intenance and mod'ifications organizations to ensure required items were stocked. Similar actions have been and are being taken to address the remaining generic problems identified above.

Next, a new warehouse outside the protected area with 70,000 square feet of storage space and an additional 20,000 square feet of office space was constructed. This new warehouse provided the Materials and Procurement organization with an adequate facility to address many longstanding problems,. such, as stocking levels, consolidate material location, and centralization of personnel associated, with the procurement process. Since warehouse construction is now complete, the Materi'als and Procurement organization is focusing on completing material relocation to this new facility. This involves specific tasks, such as performing an inventory, verifying contract traceability, relocating needed material into the new facility at adjusted inventory levels, and .surplusing excess or obsolete items.

The inventory is also being evaluated to ensure equipment qualification is maintained.

C. 'Maintenance Data Base The report identified that the maintenance data base had insufficient trending capability and limited operating history.

I Enclosure 1 Page 13 of 28 TVA agrees with this finding and is addressing this concern.. Prior to the end of the assessment period, a new maintenance planning and control (MPAC) computer software program was implemented to improve maintenance planning and scheduling, and to provide retrievable historical data. This new system is linked to,the equipment information system (EQIS) which provides access to equipment information. Maintenance history, previously in the maintenance request computer. program, has been incorporated into MPAC. New work order history data, including balance of plant, is now loaded into MPAC as if it were reportable in, accordance with INPO's Nuclear Plant Reliability Data System (NPRDS). Non-NPRDS data .as well as NPRDS reportable data are therefore readily available for planning and moni'toring,purposes. Updating the history data bases is done

, daily for both MPAC and EQIS. The MPAC software program can readily call up similar jobs for planning, purposes. MPAC also has capabilities for trending failures by several parameters including type, function, and manufacturer.

In addition to the above, the maintenance planning and technical group has a current action item to implement the recording and trending of work request discrepancies into MPAC. This improvement will allow minor problems, such as missing screws and washers, to .be assessed to determine whether they have widespread generic implications or are only isolated instances. This discrepancy trending will be implemented by October 1, 1990.

D. Tagging Practices The report noted unattended, partly disassembled equipment which had not been tagged to identify in-process work. Tagging practices were identified as a weakness during the Maintenance Team Inspection (MTI).

Maintenance and modifications materials were previously controlled by two separate procedures. These procedures specified unique tagging requirements for the affected organization. 'To address this.

problem the two procedures have been replaced by a common site procedure that provides for consistent direction. This new procedure,, which became effective July 2, 1990, standardizes material control at BFN and eliminates redundant and conflicting requirements found in the old procedures. The standardized tagging procedure, in conjunction with the instruction given in that procedure, are .directed at improving, tagging practices.

Management and supervisory control of work in progress has been increased by the addition of several general foremen and shift managers'n the latter part of 1989. These new personnel are improving adherence to procedures for activities such as tagging.

Enclosure 1 Page 14 of 28

Additionally, the maintenance production group recently implemented the periodic use of a comprehensive peer evaluation checklist that includes material tagging. The checklist is reviewed by management and provides areas for corrective action.

E. Staffing Levels in the Maintenance Organization The report noted that, staffing levels in the Maintenance organization were reduced following. completion of the MTI, and that the effect of the. new staffing levels had, not:been .assessed.

The maintenance staff was reduced in early 1990 due to organizational responsibility, changes and to staff the maintenance department consistent with the industry average for maintaining one operating unit. In addition, some duties, (such as system engineering functions and component specialist duties) previously performed by the Maintenance organization were assigned to other organizations. TVA will continue to monitor maintenance performance. TVA considers, however, that realignment of., and reduction in, the maintenance staff will not adversely affect the organization's ability to safely perform maintenance, as evidenced by the decreasing work backlog, lower error rates, and the lower number of late preventive-maintenance items. Additionally, management continues to improve the maintenance processes .and monitors the effectiveness of the maintenance group to scheduled activities.

F. Communication Between Upper Management and Lower Levels of Management and Craft Personnel The report identified' weakness with the communication between upper management and lower levels. of maintenance management and craft personnel in that the existing communication did not appear to be effective in improving the conduct of maintenance.

TVA recently reassigned several managers and supervisors to improve communications between and among upper maintenance management,, lower maintenance management, and craft personnel'. The plant manager and the maintenance production manager hold monthly and weekly meetings, respectively, with the job stewards to provide a forum for open communications. Ideas, problems, and complaints are discussed freely at these meetings. The maintenance production manager and the supervisors who report to him also have monthly meetings with maintenance craftsmen to discuss plant issues and provide personnel with the opportunity to communicate directly with management. These changes should improve commun'ications.

WI, Enclosure 1 Page 15, of 28 G. Training of Maintenance Personnel The report noted that electrical maintenance personnel required to

.perform, Surveillance Instructions (SIs) had not received training in SI,performance. Further, the report stated that instrumentation and control (I&C) maintenance personnel received little or no refresher training, and- that few onsite mockups for I&C training existed.

TVA acknowledges that electrical maintenance personnel are not currently trained in SI performance in the same manner as the I&C technicians. TVA will, however,, implement an SI performance training program for electrical maintenance personnel. This SI training program, which will be limited to infrequently performed SIs, will be implemented by February 1, 1991. In the interim, maintenance electricians that perform SIs receive systems and component training through TVA's training programs, and are also task-certified in accordance with a program that meets INPO guidelines. In addition, prior to performance of a task, the SI is reviewed in a pre-job briefing to familiarize personnel with plant conditions and any procedural changes that may have occurred.

Regarding training of I&C maintenance personnel, additional I&C mockups will be incorporated into the I&C training program by July 1, 1991. I&C personnel currently complete a 'two-year training program and receive SI performance training prior to performing SIs. In addition, prior to performance of a task, the relevant SI is reviewed in a pre-job briefing intended to familiarize technicians with. plant conditions and any recent procedural changes.

H. Management Attention in the Maintenance Program The Board recommended continued management attention be focused on the maintenance area, particularly on areas not assessed by the NRC's Maintenance Team Inspection.

TVA .is committed to continued management, attention on the maintenance area. 'Many specific examples have been previously discussed; additional. management actions are .provided below.

TVA has initiated several changes and enhancements to improve accountability, increase productivity, and improve the quality of work. First, maintenance uses peer evaluations as a teaching .tool, to assess performance, and make improvements. Second, maintenance

, has implemented changes for planning and execution of work activities that trace. responsibilities 'to individuals. This permits monitoring'ndividual performance of work activities. Third, maintenance program support. personnel are providing work monitoring, tracking,, and'tatusing; these personnel also coordinate corporate support. Fourth, increased, attention by on-shift managers will provide the direct involvement necessary to identify. and correct, problems and to ensure that maintenance is performed as desired.

Enclosure 1 Page 16 of 28 Another example of TVA's attention to this area is an emphasis on a

'"no excuses" philosophy in the areas of safety,,quality, housekeeping, and procedural adherence. As a result, safety performance in maintenance activities has improved and will continue to have high priority. The quality of workmanship and documentation is being monitored closely by the maintenance production manager and the maintenance programs support group. BFN plant management wil'1 continue its attention on housekeeping and procedural adherence.

TVA adopted INPO recommended performance indicators that are commonly used in the nuclear industry and other industries. These indicators enable maintenance to make rel'ative performance comparisons with the industry and other TVA plants. The maintenance organization also implemented a system of performance goals and objectives commensurate with plant and corporate goals, and objectives. This system tracks 18 critical parameters, including personnel errors and procedure violations. Using, these programs, maintenance issues monthly status reports to communicate progress to maintenance employees.

Self-assessments of maintenance performance are periodically performed using INPO guidelines such as INPO 85-038, "Guidelines for the Conduct of Maintenance of Nuclear Power Stations," and INPO 85-001, "Performance Objectives and Criteria for Operating and Near-Term Operating License Plants." Areas needing improvement are ,

identified and corrective actions developed and tracked to completion.

TVA also is continuing its efforts to ensure that maintenance personnel are highly qualified. All three maintenance disciplines electrical, mechanical, and ISC are certified in accordance with INPO guidelines. Managers and supervisors are being trained in such areas as TVA policies and practices, job-specific supervision, and personnel guidelines to enable them to perform their jobs more effectively. Managers are participating as peer evaluators on INPO evaluation teams and plant visits.

I. Surveillance Program The report discussed problems with BFN's surveillance program, including TVA's abil'ity,to correct 1'ong-term. deficiencies involving unclear, difficult to use procedures and insufficient attenti'on to detail by personnel performing procedures. The report also stated that program changes had been instituted, but demonstration of significant and sustained progress was not evident when the assessment period ended. Further, the Board recommended conti'nued management attention to ensure that corrective steps taken as a result of. escalated enforcement actions are effective.

Enclosure 1 Page 17 of 28 TVA has previously acknowledged problems with,the BFN surveillance program. 'Toward the end of the assessment period, TVA. initiated a broad range of actions to address these problems and to address the NRC's enforcement action. BFN management will continue to monitor the corrective actions discussed below to ensure improved performance in the next assessment period.

As an example, Revision 10 to Plant, Managers Instruction (PMI) 17.1, Conduct of Testing, and new procedure PMI-17.12, Implementation of the Surveillance Program, will clarify many of the testing requirements that had previously resulted in performance problems. Training will be held, to ensure personnel involved in testing are familiar with the new procedural requirements for the testing and surveillance, programs. This training will be completed by August 31, 1990.,

BFN is also correcting long-term deficiencies in its surveillance program involving unclear, difficult-to-use pxocedures, and insufficient attention to d'etai'1 by personnel performing procedures. A style guide and a writer's guide utilized for the preparation of surveillance instructions, (SI) ensure human factors are considered during the SI development process. TVA also established the Verification and Validation (V&V) program which provides for a walkdown during the procedure approval cycle and also provides for a detailed validation by a qualified individual, as designated by.'the respons'ible supervisor, during scheduled first use performance. This approach should ensure that SIs are clear, concise, and understood by the performer.

Measures have been taken to increase management attention and involvement in the TS surveillance program. Specifically, TVA has established requirements for management involvement in field observations, in documentation, and in feedback of the results. TVA has also mandated management involvement in the V/V process so that management must review deficiencies that have been identified and must concur with changes.

Programmatic deficiencies in the surveillance program have been addressed by actions such as improvements in the programs and procedures governing the implementation and control of procedures and work at BFN-. These improvements include a restriction on the use of nonintent changes and, as discussed above, a revision to the procedure governing procedure reviews to require preapproval walkdowns and walkdowns by, the cognizant/system engineer with the procedure implementor.

In summary,. TVA management has taken significant .actions to improve the surveillance testing program at BFN., Nevertheless, TVA recognizes that additional progress is necessary, and will continue increased management involvement in surveillance testing until the problems are resolved.

II a

Enclosure 1 Page 18 of 28 BOARD RECOMMENDATIONS None

RESPONSE

TVA concurs with the Board's assessment of this functional area. TVA agrees that there has been improvement in the Emergency Preparedness area at BFN. Nevertheless, TVA is mindful that further improvement is necessary. As a result, TVA has taken actions that should improve performance in the upcoming assessment period. First, five of six deficiencies identified in TVA's critique of the November 1989 emergency preparedness exercise have been resolved. Resolution of the sixth deficiency, which involves an unreliable plant radio repeater communication system, will be completed prior to Unit 2 startup.

Second, TVA will complete installation of Phase I of the safety parameter display system in the Technical Support Center and the control room prior to Uni't 2 restart. Third, responsibility for development of emergency plan exercise .scenarios, has been transferred to the site emergency preparedness organization. Scenario development will be further enhanced by the addition of in-plant chemistry/radiological data models, which will provide a greater array of data.

At the SALP meeting conducted July 9,. 1990 at BFN, the NRC identified a weakness with the timeliness of implementation of measures to improve notification and evacuation .of personnel from high noise areas. TVA has committed to upgrade BFN's public address and alarm system prior to restart from the. Unit 2 Cycle 6 refueling outage. This schedule has been approved by the NRC. TVA will implement Phase I of the upgrade project prior to Unit 2 restart. This phase involves upgrading the plant radio repeater and antenna system.

BOARD RECO ATIONS The Board recommended. that special attention be placed on maintenance of existing security system equipment until full implementation of the

.major security system upgrade project.

RESPONSE

TVA concurs with, the Board's assessment of this functional area. To ensure continued improvement, TVA is undertaking a number of programmatic efforts.

I Enclosure 1 Page 19 of 28 A. Upgrades to Resolve Long-Term Compensatory Posts The SALP report noted that slippage of scheduled completion dates on interim aecurity system upgrade project items has resulted in the continued use of long-term compensatory measures.

Completion of the interim security system upgrade will result in the removal of most long-term compensatory measures. Representative of TVA's commitment to resolving long-standing security system deficiencies which have resul'ted in compensatory measures is the initiation of an add'itional closed circuit television (CCTV) upgrade project, which will enhance alarm assessment capabilities on the south and west sides of the protected area (PA) barrier. This project, coupled with 'the CCTV modifications to the- north and east perimeter accomplished as part of 'the interim upgrade project, will provide improved alarm assessment capabilities for the entire PA barrier and remove all such compensatory, posts.

B. Maintenance of Existing Security Systems The SALP Report recommended that special attention be, placed on maintenance of existing equipment until full implementation of the

-major security system upgrade project.

TVA will emphasize an effective security maintenance program at BFN. For example, a security system supervisor and maintenance request specialist on the site security staff are assigned to provide attention to the maintenance of security systems. A generic maintenance request system ensures maintenance is performed on system components when they fail; when component failures result in the, establishment of compensatory posts, high priority is assigned to restore the component to service and remove the compensatory measure at the earliest opportunity. Additionally, TVA's trending and corrective action program noted by NRC in the 'SALP Report identifies recurring system deficiencies so that proactive preventive maintenance and corrective actions can be taken on appropr'iate system components.

C. ,Special Nuclear Material Inventory The report noted problems with the control of special nuclear material (SNM) inventories.

On November 4,, 1989'VA discovered several SNM items. that were determined to be unaccounted for in BFN's SNM inventory. Subsequent investigation uncovered discrepanciep in the SNM inventory. This resulted in an escalated NRC enforcement action. Corrective actions, characterized by direct management involvement, were immediately initiated. These actions included searches and development of an SNM action plan.

D Enclosure 1 Page 20 of 28 TVA's, plans on thi's issue provide further short- and long-term corrective actions. Short-term actions included root cause analysis and physical searches of certain plant areas. Long-term actions include training personnel on identifying SNM items, additional searches, of plant areas, and identification of remaining discrepancies by a comparison of inventory to the results of the searches. Training on identification of SNM items has been implemented; the remaining actions will be completed by Unit 2 restart. In addition,,:administrative changes were made to label and assign unique identifiers to new-found SNM, establish a temporary SNM disposal storage area, implement a disposal plan for SNM, develop a new SNM program based on industry practices and TVA's lessons learned, and initiate QA oversight of the SNM program.

Completion of the actions described above will result in a more accurate and reliable SNM inventory and improvements in the SNM program.

VI. FUNCTIONAL AREA: ENGINEERING/TECHNICAL SUPPORT BOARD RECOMMENDATIONS None

~RES ONSE TVA concurs with the Board's assessment of this functional area. A number of continuing programmatic efforts have been initiated to provide continued improvement in this area. A brief discussion of these efforts, and a response to specific Board observations and concerns,, is provided below.

A. Timeliness of Followup on Identified Issues The report stated that timeliness of followup on identified issues could be improved.

TVA has experienced difficulties addressing engineering, issues in a timely manner primari'ly due to the large number of such issues that have emerged. The large numbers during the past .assessment period were the result of the many discovery programs being conducted at BFN. With discovery activities concluding, the number .of issues is

, expected to decline as BFN approaches restart and TVA expects that there will be improvement in this area.

TVA has also made changes in the conduct of NE activities to address the timeliness concern. NE now schedules resolution of inspection findings and NRC commitments in its detailed .schedule, which is monitored weekly by the Project Engineer. Other emerging issues are discussed at daily NE staff, meetings where the actions are assigned and tracked. These actions, and the associ'ated management involvement,,should'mprove the timeliness of responses to individual items.

a Enclosure 1 Page 21 of 28 B. Drawing Deviations The report stated that the, number of drawing deviations increased during the assessment period. The report also observed inconsistencies in the procedural time limits for revision/correction of primary drawings significant to plant operational safety.

To clear this backlog, drawing deviations will be resolved on a system return-'to-service basis to allow better control of the cumulative impact of a large number of drawing, changes on each system and to reduce the number of drawing revisions required during the restart effort. Subsequent to system return-to-service, new drawing deviations will be expeditiously evaluated, and the resulting drawing revisions will be issued in a timeframe which is consistent with the drawing's: importance to safety. Additionally,, TVA has contracted engineering series to reduce the backlog and support system return-to-service.

SDSP 9.1, '"Processing Drawing Discrepancies," has been revised to establish the plant system engineer as the focal point for the evaluation of potential drawing deviations. Previously, NE was required to, review and disposition drawing, deviations even if corrective action by NE was not required (i.e., the plant configuration was in error and a maintenance request was required to reconfigure the plant to comply with the design configuration), thus, creating a backlog of drawing deviations within NE. SDSP 9.1 as revised also requires prompt categorization of the potential drawing deviation's impact on plant operation and safety. This categorization establishes the priority for resolution of the potential drawing deviation.

TVA agrees that the drawing deviation backlog needs improvement and that the previous program to correct the backlog was ineffective and contained procedural inconsistencies and administrative inefficiencies. TVA considers the changes described above have improved the program, made it less cumbersome, and provide control for the expeditious resolution of drawing deviations.

C'. Engineering 'Calculations The SALP report stated that a detailed review, by an NRC inspection team of the BFN core spray system indicated that the calculations and modification controls areas required additional TVA attention and'RC followup.

TVA has committed substantial attention to calculation problems and

, to the modifications control area. Th'is is discussed in the Safety Assessment/Quality Verification functi'onal area (see Item D regarding calculation problems) and in the Maintenance/Surveillance functional area (see Item A related to modification controls).

iS Enclosure 1 Page 22 of 28 D. Simulator Problems The report noted fidelity problems with the simul'ator.

TVA recognized the;problems associated with the. existing BFN simulator. This led to the previous decision to completely replace the simulator computer system, modeling software,, and as part of the simulator upgrade project. This project will instructors'tation upgrade the BFN simulator computer equipment software to satisfy the criteria for certification of simulation facilities delineated in 10 CFR 50.55 and'NSI/ANS 3.5-1985, as endorsed by Regulatory Guide 1.1'49. This upgrade project is currently 40 percent complete and will be completed by November 30, 1991.

TVA also understands the importance of maintaining the existing simulator to, high standards for operator training until the upgrade project is completed. Accordingly, modifications to the existing simulator due to pl'ant changes or simulator problems, if judged to be significant, continue to be worked even though the existing simulator software will be scrapped at the end of the upgrade project. Examples of modifications to the existing simulator include integration of 56 out of 105 plant modifications that impact the simulator which include the Phase I Control Room Design Review modifications. In addition, four of the .six new control panels which are part of the upgrade project are expected to be operational~

on the existing simulator after the next simulator outage.

E. Adequacy of Emergency Operating Instructions The report stated that the emergency. operating instructions (EOIs) were not user friendly, although adequate for Unit 2 restart. In addition, the report identified a need to revise the EOI Writer' Guide to reflect the. specific human factors concerns previously identified in NRC Inspection Report 88-200.

The .BFN EOIs are currently being upgraded'o implement Revision 4 of the Emergency Procedure Guidelines (EPG). The upgrade process, which will be. completed by December 31, 1991, will change the EOIs from a prose format to a flow chart format, which will enhance user friendliness> TVA obtained the services of a contractor to develop the EOIs and',program materials for implementati'on of EPG

'Revision 4. This contractor was chosen based on significant industry experience, including experience with flow chart development and human factors engineering.

In addition to the upgrade process discussed above, other changes have been made to the EOIs and associated Writer's Guide to address defici'encies 'identified in Inspection Report 88-200. For example, the EOIs and Writer's Guide have been- revised to increase emphasis on logic statements, as recommended by NRC. The EOIs and Writer'.

Guide have also been revised to clearly define conditions under which logic diagrams are to be used, rather than the .previous method of using multiple logic terms.

I Enclosure Page 23 of l28 BOARD RECOMMENDAT 0 S None

RESPONSE

TVA concurs with the Board's assessment of performance in this functional area. A number of improvements have already been made in this area and are ongoing. These improvements wi'll address many of the issues and observations raised in the SALP report. A brief description of some of these efforts follows.

A. Timeliness. and Thoroughness of Submittals and Responses The report noted weaknesses in the timeliness and thoroughness of submittals and responses to the NRC.

TVA is addressing the timeliness and thoroughness of submittals and responses to the NRC with increased management attention through the use of the Project Plan. This plan identifies major commitments and programs required'o be completed prior to and fo'llowing Unit 2 startup. It includes NRC inspections; technical specification amendments; closure of NRC bulletins, generic letters, and TMI items; and other TVA submittals. Responsible TVA and NRC personnel are identified for each issue, and established milestones are provided for TVA actions. The plan is updated weekly and provides TVA upper management with an overall summary and action plan for resolution of regulatory issues and commitments. Key issues in the plan are also included in the restart schedule.

With respect to the mechanics of preparing submittals to NRC, actions are now initiated as soon as a particular issue is identified (e.g., NRC exit meeting). This includes meeting with appropriate plant management 'to discuss and,obtain concurrence. on the plan of act'ion to be taken, and followup meetings to evaluate progress on the action plans. These actions enhance communication among TVA "organizations with responsibilities for technical input and provi'de management with early opportunity to assess the thoroughness of the information.

B. Escalation of Items to Management for Corrective Actions The report noted that management feedback was obtained through the semiannual audits of the Correction of Deficiencies Program; however, the NRC expressed a concern regarding the large number of items that must be escalated to management prior to corrective action 'being taken.

I Enclosure 1 Page 24 of 28 TVA has taken several actions to resolve this condition. One example is that the Site Director now schedules weekly meetings to discuss escalated items. At these meetings the responsible managers are required to report the status of each escalated item, and also any actions taken or planned to correct the problem. As a result of the added management attention, the number of escalated items has decreased from 71 in February 1990 to 23 in June 1990. The site quality organization also continues to monitor escalations in the monthly trend report for adverse trends. In addition, escalations remain a high visibility issue with upper management and the BFN Site Director.

C. Implementation of Corrective Action Programs The report noted problems with implementation of corrective act'ion programs.

TVA recognizes that difficulties exist with the successful implementation of corrective action programs. These include failures to develop proposed corrective actions. in a timely manner, failures to implement corrective actions, and a lack of ownership of problems.

To address this concern, regular Management Review Commi'ttee meetings are conducted to resolve questions regarding corrective actions and unresolved items, and to assign responsibility for specific actions. Following an assignment of ownership of a problem in this manner, plant procedures require, the responsible organization to identify and implement corrective actions to address the item in a timely fashion. If corrective actions are not promptly identified or implemented, the item is escalated to upper management.

Improvement has been made in the timeliness of actions required under the conditions adverse to quality (CAQ) program. As a result of trending timeliness of CAQ corrective action implementation, an overall timeliness problem was identified. and resolved in conjunction with the escalations issue noted in, Item B (above). As a result of the corrective actions taken, BFN has shown an overall improvement for the CAQ process from a high of 41 percent delinquent actions in February of 1990 to the present 14 percent in July 1990.

D. Correction of Identified Deficiencies with Engineering Calculations and Melding Record Retrievability The report stated that several examples were identified of the failure to take prompt effective action to correct deficiencies related to problems with engineering calculations and welding record retrievability.

Encl'osure 1 Page 25 of 28 Previous errors in the core spray, calculations were caused by the failure of a contractor to rigorously apply a check function to these calculations. During internal quality assurance audits conducted in August 1988 and October 1989, TVA discovered that the calculations containing errors were limited to mechanical calculations performed by a particular engineering contractor. This problem was corrected by the. contractor's development of a plan to perform another check function review on BFN Mechanical Engineering calculations. In addition, TVA committed to review essential mechanical calculations performed by the contractor for errors, and to correct. any errors discovered.

TVA also investigated the possibility of similar problems existing in the essenti'al calculations of the civil and electrical disciplines. The investigation. determined that the problems were unique to mechanical calculations performed by the identified contractor..

With regard to actions taken to correct .previously identified deficiencies with the retrieval of welding records, TVA recognizes that the corrective actions taken were inadequate., However, TVA

,subsequently developed. a systematic method for retrieving test records. This method, allows records to be retrieved utilizing a mini'mum of basic information. Verification of this corrective action was demonstrated'y selecting ten wel'ds from the residual heat removal system and locating the affected certified material test reports in an expeditious fashion with a minimum, of effort.

'While TVA has now taken thorough corrective actions to address the calculational problems and welding records retrieval deficiencies discussed above, TVA recognizes that .these actions should 'have been initiated in a more timely fashion. TVA is aware of NRC's emphasis on the prompt resolution of deficiencies and, as described in Item A of the Engineering/Technical Support functional area, will be working to improve in this area for the, next assessment.

E. Identi'ficati'on of Hardware Deficiencies, During Walkdowns The report cited TVA's failure to identify hardware deficiencies during a walkdown on the core spray system whi'ch was performed before .the NRC's vertical slice inspection.

A site procedure provides guidance to system engineers .conducting

. routine- system walkdowns in accordance wi'th schedules approved by their supervisors. TVA has conducted additional field training for system engineers, and has increased management attention on the conduct of walkdowns. This should 'increase the attention to detail and lower the threshold for recording deficiencies.

D Enclosure 1 Page 26 of 28 In addition, TVA is developing a special area walkdown procedure for restart. The area walkdowns are intended to detect existing that resulted from past practices. The walkdowns will field'eficiencies be performed by, a multi-discipline group that shall consist of at, least the following: system engineering representative, qualified operations representative, modifi'cations engineer, and civil/

structural engineer.

The area walkdowns will be a detailed exam'ination of an area after modifications work in the area is complete., Any, findings of the walkdown group will be evaluated for impact on suitability of equipment/structures for startup. If any finding impacts operability, the. matter will be corrected prior to rel'easing the area as ready for startup.

In addition to the routine and special area walkdowns, TVA is also committed to a strong System Plant Acceptance Evaluation (SPAE)/System Preoperability Checklist (SPOC) process. During the SPAE/SPOC process for the core spray system, TVA found that the process was. uncovering new issues in addition .to being a verification of work completion. Consequently,, XVA is performing a detailed evaluation of open items on a system-by-system basis. This evaluation looks at drawing deviations, change documents, essential calculations, conditions adverse to quality, restart test program items, .programmatic punchlist items, design criteria, and primary and critical drawings. This is used to ensure identification of the open items on each system. With the open items identified, the SPAE/SPOC process to be conducted at the time of system return-to-service will be used to verify closure of open items as intended'..

F. Instrument Sense Line and Control Room Emergency Ventilation System The report i'dentified several examples of TVA's responsiveness to

,certain issues. .Specifically, the report noted that the schedule for correction of the instrument sense line was delayed at least twice and,correction of a long-known deficiency in the control room emergency ventilation, system had not been completed by the end of the assessment period., The report also cited'VA's recent Operational Readiness Review (ORR) which indicated that BFN's response to NRC Bulletin 88-04, "Potential Safety-Related Pump Loss," may, reflect a lack of technical and critical review.

Correction of the design deficiency in the control room emergency ventilation, system was ident'ified to NRC as a startup commitment for Unit 2 Cycle 7 operation. This schedule was reviewed and approved by NRC as documented in a September 18, 1989 letter approving TVA's request. TVA's current pl'an to evaluate CREVS by Unit 2 Cycle 7 is consi'stent with this commitment. Regarding the instrument sense line issue, TVA acknowledges that the schedule for correction of

Enclosure 1 Page 27 of 28 this issue has been delayed. These delays were due to the factors that have affected the restart schedule in general. As BFN begins power operations, TVA will'e able to focus attention on issues since major programs will be completed and will no longer affect the

.ability to perform work.

Regarding BFN's response to NRC Bulletin 88-04, BFN's May 25, 1990 response to the referenced ORR report documents the re-evaluation performed to address this issue. This evaluation notes that site specific calculations were utilized in conjunction with industry information in responding to the Bulletin. The re-evaluation also identifies 'that industry operating and maintenance history, along with BFN specific information, was used to determine the adequacy of existing miniflow line flow rates. In addition, the re-evaluation specifies that, although they are outside the scope of Bulletin 88-04, non-safety-related pump configurations were also reviewed and no configurations which could permit adverse pump-to-pump interaction as discussed in the Bulletin were identified. The re-evaluation concludes that BFN's original response to Bulletin 88-04 is still acceptable and has received sufficient technical and, critical review.

G. Procedural Compliance The report confirmed that .procedural compliance continued to be a problem. The report offered that this was a result of inadequate training and line organization interfaces.

TVA has committed substantial management attention to procedural compliance at,BFN.. While this issue. underlies many of the areas addressed in the report and is accordingly discussed throughout this enclosure, procedural compliance is specifically addressed in the Maintenance/Surveillance functional area (see Items A and I).

H. Quality of Procedures The report stated that there are still'uality problems with some procedures.

BFNhas upgraded a significant number o'f procedures as .part of a dedicated'pgrade .program, both before and during the assessment period. These upgrades will continue as part of the long-term effort. The validation process described in the Maintenance/

Surveillance functional area (see item I, Surveillance Program) was also established'n. response to the problems identifi'ed during the assessment period'nd will improve the quality'f the procedures and ensure their usability.

4 Enclosure 1 Page 28 of 28 TVA will continue to. emphasize prompt identification and correction of procedural inadequacies and is closely monitoring events and incidents related to procedural content and compliance. While the number of events caused by procedural non-compliances and procedural inadequacies has decreased during, the latter part of the assessment period, TVA acknowledges .the need for continued improvement.

I. Human Factors Deficiencies in Procedures and Writer's Guides The report noted'hat a TVA assessment identified human factors concerns,, similar to those identifi'ed by NRC in Inspection Report 88-200, in a wide variety of procedures:

cj and'ssociated guides.

In early 1987 BFN established writer's guides and style guides which were incorporated into plant procedures. The purpose of these guides .was to provide specific direction to procedure and instruction writers on the format and content of plant procedures.

In addition, guidance on addressing human factors concerns was also provided. Following the establishment of the writer's guides and style gui'des, and as part of the Nuclear Performance Plan near-term upgrade effort, many plant procedures were revised to incorporate this guidance. Other plant maintenance procedures, which were not revised at that time, will be revised as part of the long-term upgrade effort. The estimated completion date for this effort is September 1992.

TVA acknowledges that the deficiencies identified in TVA's Phase II Operational Readiness Review Report exist. The identified procedures had not been revised to address human factors deficiencies because they are part of the NPP long-term upgrade effort.

In the future, plant procedures. that are part of the NPP long-term upgrade process will be revised using the guidance provided in the pl'ant style guide and writer's guides. The style guide was recently revised to address the specific concerns identified in TVA's Phase II Operational Readiness Review Report, and also to incorporate INPO Good Practices. Guidance is also provided to correct human factors deficiencies during .the two-year review process.

ENCLOSURE 2 LIST OF COMMITMENTS

1. Senior plant managers with power operations experience will be assigned full-time shift coverage in the power block beginning with approach to criticality and continuing into power ascension activities.

2. Fire protection compensatory action procedures will be upgraded to correct programmatic deficiencies. by November 29, 1990.

3. Areas needing improvement identified in the Nuclear Managers Review Group review of the adequacy of TS implementation will be implemented prior to restart.

4,. Prior to startup the shi'ft operations supervisors will have participated in INPO peer evaluations at other utilities.

5. Prior to .startup .shift operations supervisors, assistant shift operations supervisors, and unit operators will receive training at an operating plant.

6. Pri'or to startup, TVA will send assistant unit operators to Sequoyah Nuclear Plant.

7. Responsibility .for housekeeping and identification of material deficiencies will be. shifted from system responsibility to plant area responsibility.

8. Prior to startup TVA will conduct two senior management reviews: one by the ORR team and another by SMART. The ORR team will perform an independent review of operations and work. control.

9.. A senior unit manager will be assigned responsibilities with the assistant unit operators to emphasize their responsibilities for space conditions and equipment operation.

10. Effective January 1, 1991, a new admini'strative procedure will be in place to restrict dose accrual at BFN.

11. Shielding, decontamination, wipedowns,, flushes, and containment devices will be used to minimize personnel exposure during Unit 3 recovery

,activities.

12. Portable continuous airborne contamination monitors will be used where practical during Unit 3 recovery, activities to minimize, use of respiratory protective equipment.

13. During Unit 3 recovery activities video cameras will be used for remote surveillance of work in radiation areas.

14. Operations personnel and, maintenance craft personnel will be, trained in startup and operating radiological conditions, by Unit 2 startup.

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Enclosure 2 Page 2 of 3

15. Generic shield tables for shutdown and operational conditions will be developed in Fiscal Year 1991.

16. A work order weview group will be created to monitor, prioritize, and reduce the maintenance backlog.

17. The recording and trending of work request discrepancies will be impl'emented into the 'maintenance planning and control computer software program by October 1, 1990.

18. Electrical maintenance personnel that perform surveillance instructions

.(SI) will be trained on infrequently performed SIs by February 1, 1991.

19. TVA will incorporate additional ISC, mockups into the ISC training program by July 1, 1991.

20. Training will be conducted to ensure personnel involved in surveillance testing are familiar with the new procedural requirements found in PMI 17.1, Revision 10, and PMI 17.12. This training will be completed by August 31, 1990'.

21. The plant radio repeater communication system will be upgraded to address the findings of TVA's critique of the November 1989 emergency preparedness exercise. This will be completed by Unit 2 startup.

22. TVA will complete installation of Phase I of the safety parameter display system in the Technical Support Center and,the control room by Unit 2 startup.

23. Additional searches of plant areas for SNM will be completed by Unit 2 startup.

24. Identification of remaining SNM discrepancies by comparison of inventory to the results of the additional searches wi'll be completed by Unit 2 startup.

25. Drawing deviations will be resolved on a system return-to-service basis to allow better. control of,the cumulative impact of a large number of drawing changes on each system and to reduce the number of drawing revisions required during the restart effort.

26. Subsequent to system return-to-service, new drawing deviations will be expeditiously evaluated, and the resulting drawing revi'sion's will be issued in a timeframe which is consistent with the drawing's importance to safety.

27. The simulator upgrade,pro'ject will be completed by November 30, 1991'.

28. .BFN emergency operating instructions will be upgraded to implement Revision 4 of the Emergency Procedure Guidelines by December 31, 1991.

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Enclosure 2 Page 3 .of 3

29. The special area walkdown procedure being developed for restart will require walkdowns to be performed by a system engineering representative, a qualified operations representative, a modifications engineer,, and a civil/structural. engineer.

30. The area walkdowns will be a detailed examination of an area after modifications work in the area is complete. Findings will be evaluated for impact on. suitability of equipment/structures for startup. If any finding impacts operabil'ity, the matter will be corrected prior to releasing the area as ready for startup.

31. Plant maintenance procedures that are part of the long-term upgrade process will be revised usi'ng the .guidance provided in the plant style guide and writer's guides.