Text

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
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SYSTEM (RIDS)ACCESSION NBR:9008140203

DOC.DATE: 90/08/08 NOTARIZED:

NO FACZL:50-259

Browns Ferry Nuclear Power Station, Unit 1, Tennessee 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 50-296 Browns Ferry Nuclear Power'Station, Unit 3, Tennessee 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 TITLE: Systematic

Assessment

of Licensee Perfor ance (SALP)Report NOTES:1 Copy each to: B.Wilson,S.

BLACK 1 Copy each to: S.Black,B.WILSON

1 Copy each to: S.Black,B.WILSON

DOCKET g 05000259 05000260 05000296!: S/05000259 05000260 05000296 L RECIPIENT ID CODE/NAME KREBS,M PD KREBS,M ROSS,T.INTERNAL: ACRS AEOD/DSP/TPAB

DEDRO NRR/DLPQ/LHFB11

NRR/DOEA/OEAB11

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NRR/DRIS/RSIB9A

NUDOCS-ABSTRACT

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'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 Tennessee Vali'ey Authority Docket Nos.50-259 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.900Sie0203

W0080:-PDR ADOCK 05000259 9 PDC~ygP.An Equal Opportunity

Employer

IP.P

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 procedural'ompliance.

In addition, the threshold for incident investigations

is 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 l Page 4 of 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.

!P I

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.

)

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 l Page 7 of 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

,~il h i

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.

I I

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

I'J

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 instructors'tation

as part of the simulator upgrade project.This project will 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 l Page 23 of 28 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

ML18033B480

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