ML20012B839
| ML20012B839 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/12/1990 |
| From: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9003160407 | |
| Download: ML20012B839 (23) | |
Text
{{#Wiki_filter:m <w . .. . . .
& F. , ,,
T
]c ,
f , I;;
* ;" , TENNESSEE VALLEY AUTHORITY -
l
~,,
6N 38A Lookout place j Chattanooga.: Tennessee 37402-2801 4 March 12,=1990 j UsS. Nuclear Regulatory Commission !
' ATTN . ' Document Control Desk- 'i 1 Washington, D.c.1 ~20555 , Gentlemen: ,
M In the Matter ofj ) Docket Nos. 50-327 ! Tennessee Valley Authority ) 50-328 ^l;q SEQUOYAH NUCLEAR PLANT (SQN). UNITS 1 AND 2 - STATUS-AND RESULTS OF PERFORMANCE
,O IMPROVEMENT.AT SQN .p InJTVA's May 31, 1989, response to the'SQN Systematic Asses ment of Licensee-j performance (SALP).(Inspection Report 50-327, 328/89-01), TVA described efforts planned to-improve performance. at SQN over the current assessment
. . Period. :The. input provided by NRC in that report was factored into1 ongoing
- performance assessments and improvement ~ activities.~.Many of the. efforts taken 1
;have produced positive results, although areast for improvement remain.
i The past year has also been-one.of change for SQN. The SQN organizational structure was modified to support transition to a fully operational. site.with establishment:of a staffing plan to complement that structure and to support
- completion of.postrestart recovery activities. . The first refueling outage
- following restart of the units was completed, and extensive efforts-have been-ongoing ~ to support preparation for' the Cycle:4 refueling outages- scheduled for
'this year. Those: outages will essentially complete the-postrestart recovery.
. programs,. closeout =various regulatory backlog items,1and implement several-significant plant improvements.
1
.Our goal-is to achieve sustained excellence in performance in all functional'
~
areas: evaluated by ;the NRC. .While we believe that considerable progress'has been made-and that. management systems and processes have been strengthened,fwe clearly. recognize that-improvement.is needednin order to achieve that goal. One of:the key elements;in meeting this goal is good communication of. senior i management's standards to the SQN-organization. We-are working toward thisL ! fobjective through-conduct of performance evaluations, improving' employee l
, communications, . establishing goals : and objectives,' and clearly identifying l
- and, in many cases, posting organization standards. We look forward to
- receipt of your assessment of SQF's performance over the past year.
m Very truly yours, ,
'TENN EE VALLEY' AUTHORITY
){. , . _,
# Kings .
i Senior Vi s de . E Nuclear Powe p l
- Enclosure
- j. ,
- cc: . See page 2 h M
9003160407 PDR 900312 Q I P ADOCK 05000327 1i An Equal Opportunity Employer { l W:, PDC - [p - _ - _ - - - - - . - - - - _ _ _ - - - - - - _ - - - - - - - - - - -
.t i
gg , ' ;c . . u ,. ~ m , .< m" c= m' c: : '. .s : c +e;
- y: ,
~ --- o e,. , e ,
n' *
*- n
>',,c f, v 'e s'L '
y;p..; 0 ; J.M ' - h . . .w _ a l ;G ll
* :f 1l ,
A m '
- -- 1 aklk w 1, .l:(. '-
I I > - p't O r= a . . . J U.SDNuclear Regulatory Commission.' J yg s
- March 12. 1990.
- )
y ,y :; o, . c: < s 1. > :. n :; h . . 4
;j
/ _y ;ccL(Enclosure): . . ._ c . M # Ms. S.1C. Black,. Assistant Director- [' _ -for Projects- > b lj & R
;TVA Projects; Division. :j j
h* '.U.S.. Nuclear' Regulatory: Commission ?j[ ,
~0ne White Flint,' North s
- h. -11555 Rockville Pike ,
~!
' Rockville,f-Maryland :120852 :
h,1 ^ q p . 1 J4 .MrL-B. A. Wilsonf Assistant Director: -l i $ q., for Inspection. Programs-
.TVA' Projects Division
{['m , U.S. Nuclear Regulatory Commission [ p ' Region 111: .
*) -
b 101 Marietta--Street, NW, Suite 2900- . l Atlanta,; Georgia 1{30323.' ] m- . . n< NRC Resident Inspector- , b" >> -Sequoyah Nuclear' Plant n 2600;Igou Ferry. Road-E, > b ~ Soddy: Daisy,' Tennessee 37379
\
t
^$,
g' [ ',Y 'o t i f' ~
, i
/ s .
s ,- t
, - , .c kj 3
'.' s. 4 4 ig '
# 4 yW 1 r i 1..
C e %l.. < g A > s ($ ! 9 e H" J I
+ . s- ' . ,
' ~
1.
,g s
+ ..v... ,
-(
- I ., ..
j , & . ._ - _ _ - . _ _ - - _ _ _ _ _ _ _ _ _ __ 4 ..
(yw. ; A .9- ,
~, ,; '
,[ _
c, i gg ' Enclosura j E TVA SQN Summary.of Performance Improvement Program Results L I. FUNCTIONAL'AREAf Plant Operations > [% We consider that a number of improvements in this functional area have j g occurred during this rating period. In the area of technical specification (TS) compliance significant emphasis has been_placed on
.the development of an improved understanding of the need for strict-
);? procedural compliance and a stronger sense of ownership.of plant TSs. ' The trend of~ personnel errors and procedural noncompliances is h; 4 improving at SQN and. inadvertent engineered safety feature actuations 1 have also significantly declinec. during this period. The' monthly !E -average number of violations attributed to Operations department personnel error has come down from 1.5 to 0.67. We believe this-fiE. reduction in frequency of personnel error can be attributed to a new j philosophy that has-been instituted by the Operations management team put in place in July 1989. This philosophy includes improved communications between Operations management and shift operating personnel along with a lower threshold for investigation of unusual or unexpected operational events. Root causes are now determined at a lower threshold for these events using a new process that governs event investigations. Increased involvement of Operations personnel in incident' investigations has heightened awareness and broadened experience in. thorough root cause evaluations. If these investigations reveal that personnel error was the root cause, the appropriate . corrective actions-are taken, usually including one-on-one counseling by' Operations management and a discussion with all operating personnel
-in training or dur_ing -shif t crew meetings on lessons learned f rom the events. If the investigation reveals that negligence was-the root cause, then appropriate disciplinary action is taken. Of the violations attributable to Operations.in 1989, less than one-third ,
occurred since the July 1989 organizational changes were implemented. Significant progress has been made in the emphasis on ownership of the plant by its operators. This progress is evident in several areas, including plant housekeeping. The operating staffs' sense of' responsibility and diligence in housekeeping has been heightened by management and external reviews. The identification, isolation, and repair of leaks are also improving. In~ general, progress on housekeeping has been made, but continued improvement is needed. Strengthened accountability for shift personnel performance is being accomplished through management ' appraisal and trending' of the number of incidents and events. Continuation of this improvement over the next year is a high priority goal. In addition, expanded training on TSs is being conducted during annual _requalification training. This expanded training stresses the need for personnel to continue to question activities, procedures, and interpretations to ensure that both the explicit requirements and the intent of TSs are being maintained and , implemented. k b f
y V o .- g , ,,' > b <.-. [w > y- Noted progress has also been made in the area of conduct of N :E operations. In July 1989, a new Operations management team was i" established to improve the focus of plant resources in supporting an operating. plant. A new Operations Superintendent was selected, and-Operations was combined with Chemistry, Work Control, Fire Protection,
.and Water and Waste Processing under an Operations Manager. Emphasis W
=has been put on teamwork and communication among plant operators, as f well as the responsibility for maintaining cognizance of plant status and following principles of good operation, y
An Institute of Nuclear Power Ope. rations -(INPO) assistance visit was conducted'during May 1989 to evaluate all aspects of day-to-day operations at SQN. .This evaluation revealed the following problems:
.(1) inadequate supervision of Assistant Unit Operators (AU0s); (2) AUO .l routine logs were being completed only 20 percent of the time; (3) the threshold for investigation of unusual occurrences was too hight and-(4') too many operator aids existed. To correct these problems, Operations has-taken a number of actions. Two Senior Reactor Operators (SR0s) are now being staffed on each unit. One SR0 is responsible for supervision of the control room crew and work authorization. The second SRO is responsible for clearance work and supervision of AU0s in the field. The responsibility for the physical work of establishing-clearance boundaries and hanging tags is being shifted.to the AU0s although the responsibility-for writing clearances and ensuring that they are proper and safe is retained by the Assistant Shift Operations Supervisors (ASOSs). When fully implemented, this will shift a b
significant workload from the ASOSs which will allow them to spend more time supervising AU0s in the field. A policy has been established that q AUO routine logs are an AUO's number one priority on every shift. Since this policy.was implemented, over 99 percent of AUO routine logs have been completed on all shifts. A new procedure for event investigations has also been implemented, which has significantly-reduced the threshold for investigating unusual operational . occurrences. The duty manager for each site organization now has the authority io initiate an event investigation for any event whenever he ' deems it necessary. In addition, a 100-percent audit of operator aids has been conducted by a licensed reactor operator with a significant reduction in the number of operator aids in'the plant.
.As a' result of these corrective actions, the annual INPO plant evaluation did not cite any deficiencies in these areas. However, two deficiencies were cited which need increased emphasis and management attention: (1) the rate at which the Operations' procedures upgrade project is progressing, and (2) the number of control room annunciators that are continuously lit. A schedule is in place for completion of the procedures upgrade project. It is scheduled to be complete by September 1991. The study phase of a project to address, nuisance alarms and to attain a dark board annunciator system is nearing completion. A design and procurement phase and an implementation phase will receive increased priority. Significant progress toward the completion of this project is expected over the next year. During 1990 the following actions are planned for the l
l
pg , --- - - -- VA, . .. . m. m
'. , I. ,
+ ' J- Y .
[f - nuisance alarm project. Nine (9) continuously lighted alarms resulting 0 from abandoned equipment will be cleared.- Fourteen (14) continuously , lighted alarms resulting from setpoint problems will be cleared. Four y continuously lighted alarms will be cleared by other planned Unit 1 b Cycle:4 (U1C4) modifications. The remaining continuously lighted alarmsLwill be studied and a schedule will;be developed to clear these alarms. In other areas, significant progress has been made toward goals involving'long-standing hold orders and long-standing temporary alteration control forms (TACFs). Since June 1989, a 61-percent reduction of- long-standing hold orders- (90 days old or older) and a b percent reduction of long-standing caution orders have been achieved. This program is continuing as planned in fiscal year (FY)
- 1990 with a goal of reducing the open pre-1988 TACF backlog to four by .i N the end of the UIC4 refueling outage.- l 1
~"
While the amount of waste water generated at SQN continues to be high relative to industry averages, it is being managed down. In August of 1, 1989, responsibility for water and waste minimization was assigned to
.the Operations' organization and a full-time manager was dedicated to E that effort. Procedures used to operate water and waste systems have been upgraded to the new writers' guide format and all radwaste operators trained on their use. Major maintenance has occurred on the boric acid evaporators and waste gas header and the result has'been a reduction in the volume of waste water discharge of over 10 percent. 3
- SQN's goal has been reduced from 550,000-gallons per month to 450,000 j gallons per month for FY1990; progress to date indicates this goal is achievable.
SQN.had a water balance study performed to aid in the quantification. ! r- and minimization effort. This study was completed last month and is currently being used as the basis for SQN's inleakage reduction program. The first physical change, an acoustic = leakage monitoring. system pilot project, is scheduled to be in place before the U2C4 c
-outage.begins in September 1990.
Relative to SQN licensed operator training and nonlicensed operator
' training, we consider that SQN's Operations' management is more closely involved with-training activities which include assisting in establishing training topics and approving training material. As a ,
result, requalification training more-closely reflects SQN's . i operational needs. The recent license training effort was successful with 10 out of 11 candidates passing their exams. The requalification-
~
is program has been significantly changed to better equip the operators to s meet requalification exam requirements. Each licensed Operations I personnel will be given at least one complete requalification examination per year. 3 One additional area in which improvements have occurred is the control O of fee'dwater evolutions. In TVA's May 5, 1989, submittal to NRC relative to three Unit 2 reactor trips that occurred during restart from the Unit 2 refueling outage, ten commitments were made. The ! commitments can be characterized as either being philosophy, methods, l l l l
p , C '
,y '
b,' ,
,1 # s fn' ls ae <
_' or trainingC Each of the ten conraitments have been accomplished.
; Examples _of these commitments are as follows:- (1) review operating'
- M procedures and incorporate' team concepts or test' director requirements
.for.important critical tasks by June 30, 1989; (2) develop a plan by
- May 30, 1989, to get Operations _ management more involved with industry o
s' top performers and in INPO evaluations; (3). revise Administrative Instruction (AI) 30 by June'30, 1989,-to identify role of senior Operations management support in the main control room during important' plant evolutions; (4) develop specific management requirements to
-reinforce desired operational philosophy by June 30. 1989;-
[ (5), incorporate control lot 4 design and operation into requalification training by December 1, 1989; (6) incorporate standard feedwater startup methods into requalification training by Mcy 19, 1989. As a result-of'the collective effect of these improvements, SQN has not encountered a reactor trip during startup resulting from feedwater ,1 evolutions since April 1989. f Additional work is ongoing relative to control of feedwater evolutions. This, work has included research into industry methods and-feedwater components. As a result of-this additional work improvements ! are plannedlin the following areas: (1)-install Turnbull controllers for Unit 2 bypase regulating valves; (2) establish a checklist to test . and calibrate feedwater controls during UIC4; (3) calibrate main - .< feedwater pump. turbine (MFPT) 2A EH converter; (4) calibrate MFPT 2B LP-i governor _ valve; (5) relocate feedwater components to improve operator interface and use; (6) widen operating margin of steam' generator level with Eagle 21 upgrade; (7) elimination of 60-percent level single loop isolation; and'(8) MFPT electronic control upgrade. In summary, we consider significant progress to have been made in the plant operations area during this assessment period. While we are not ! satisfied, numerous goals have been achieved and new improvement ll targets have-been established. II.- FUNCTIONAL AREA: -Radiological Control 7, We feel significant improvement has been made in the Radiological Control (RADCON) area during this SALP period. Some of these improvements are the' result'of extensive initiatives taken during the period and program changes begun during the previous period. The most ; significant of these improvements has been in the area of plant I contaminated _ area reduction, personnel contamination incident _ 1 4 reduction, and the as low as reasonably achievable (ALARA) program - implementation and exposure management.
^]
Aggressive management attention has been given to the area of plant i contaminated area reduction. This has included the personal -l involvement ~of senior management and a reorganization of SQN q radiological waste activities to improve ownership and accountability )
'for this program area. These changes also included the establishment 0
.d s .
, l
- s. -
S-L u of a dedicated deenntamination crew'within the RADCON organization.-
~
The results of these' initiatives have resulted in an overall reduction s N of'60. percent in the area of SQN that is contaminated. As of this
~
i report, plant' contaminated area has been reduced to 9.5 percent.
- F Additional' benefits derived from this accomplishment are-improved l L worker-efficiency and a reduetion in personnel contaminations. Because
'the majority of solid radiological waste generated is the result of protective measures for work in contaminated areas, we expect that the F reduction in plant contaminated area will yield a proportional ;
L reduction in solid radiological waste generation. , f . In the area of personnel contamination reduction, increased management ' attention, detailed event reviews, and corrective actions plans have resulted in a 57-percent reduction in the incidence of personnel contaminations. The current rate of 0.9 event per 1000 radiation work permit hours will result in the total number of personnel contamination events for the year being within the industry best quartile for , pressurized water reactors. Significant additional benefits have been
- derived in the areas of risk reduction, employee exposure, and work efficiency. To further improve performance in this area, SQN has installed Beta Max whole body personnel contamination monitors at all exits of the plant radiological controlled area (RCA). These contamination monitors provide much improved sensitivity over conventional hand-held friskers nnd improve personnel processing time upon exit of the RCA. In addition, Eberline PCM-1.whole body contamination' monitors have been installed within the RCA near the worksites to improve personnel contamination monitoring and provide early. identification of contamination problems.
Major improvements have also been realized in the ALARA program. These .j include the establishment of a more effective and aggressive ALARA committee, an improved radiological work review process, and a lowering of the threshold for special ALARA reviews of work from five man-rem to one-man-rem. Additionally, the assignment of a project ALARA health physicist from initial planning.through implementation for high exposure work improves the probability.that ALARA initiatives are implemented. 'These initiatives have resulted in the ability to : implement major plant improvements and satisfy restart commitments and still expend less dose than average during this review period. Plant modifications scheduled for the 1990 outage such as resistance temperature detector bypass and upper head injection removal will provide significant personnel exposure reduction benefits for the' life of the plant. N In addition to the major accomplishments made during the year, other
- significant initintives have been completed during the last year that should further improve the effectiveness and efficiency of the health i
physics program. Among these are the development and near-term implementation of the Radiation Exposure System (REXS). This system is a state-of-the-art computerized radiological access and exposure management system. The REXS system integrates the automated functions
- of radiation work permit generation, survey data base, exposure records i
f}_i = ' p, ..: . kg
- 4 q -
h n g F management.-access control, radiological equipment inventory and issue,- p, ; ALARA planning, and quality related, records. management.- REXS purpose p is to iuprove the overall efficiency of the-RADCON program and enhance i > the control of radiological work. p , L Significant efforts have been undertaken at SQN in the area of solid _' radioactive waste minimization. These; include solid radwaste drum weight and compaction improvement to 65 pounds per cubic foot; y' procurement of replacement materials for herculite and other plastic
- items that are more compactible and able to be incinerated; and the L
4
- procurement of protective clothing that minimizes seams and.the need 0 '
for tape. The improvement in solid waste segregation and the establishment of an RCA materials control point have served to minimize
- the volume of waste requiring disposal and the generation of such waste. These initiatives have resulted in a solid waste volume i m reduction of over 40 percent during FY1989 as compared to SQN's last
. full year'of, operation. Our goal for FY1990 has been established at 5.5. percent below FY1989 actual volume. SQN is currently on track to meet this. goal. This program area will continue to receive aggressive management attention'until performance commeneurate with industry best practice is achieved.
We feel major program improvements and-initiatives have been made possible through the~ continued _ commitment of site and corporate _ y
-management to the RADCON program. The RADCON organization is fully ]
staffed and key vacancies are quickly filled. RADCON management and. j technical staff experience averages 14 years per person in professional ' health physics and three of the senior managers have' held superintendent positions at other plants. In addition, two of these ; managers are Certified Health Physicists and one.has a Senior Reactor 1 ' Operator Certification. The RADCON technician staff _has been stabilized and currently consists of technicians with long-term j experience, each of whom has six or more years of health physics ' experience. j
, An area that requires further improvement is our ability to prevent recontamination of decontaminated areas. Additional emphasis is being placed on leak repair and prompt identification and correction of minor )
- spills. This-area will continue to receive increased management j
. attention-until management expectations are achieved. '
In summary, we consider the SQN RADCON program to have been ; significantly improved during this review period. Site and Corporate l management will continue to monitor performance to ensure that ,
~
initiatives are resulting in still further improvements in program l efficiency and effectiveness. t ( _ -=
pp
.g
.n J. ; a 7
p ?* III.' FUNCTIONA1,AREAt' Maintenance / Surveillance
, .We consider that significant progress is being made in improving f performance in the areas of daily' work and outage scheduling.
Itaprovements have resulted f rom a number of initiatives. A special- _INPO assistance visit was conducted during the Unit 2 Cycle 3 refueling E outage. This visit critiqued our outage performance and identified several' lessons learned which have been factored into out outage-t management program. In addition..several key outage management personnel. visited other utilities recognized as having strong programs-to observe first hand outage management and scheduling techniques.- Examples of improvements resulting from these visits are preoutage communication of scope and goals and enhanced daily plant scheduling
- . techniques.
Work Control group management changes were also implemented to strengthen daily work scheduling and coordination functions. The Work I Control group organization was made part of the Operations Group to strengthen 0perations group input and control of schedule and schedule
~
priorities. A, formal program of seven-day fixed schedules with j performance accountability to line management has been implemented, j Previous unpredictable schedule performance has been significantly .{
. improved, wi,th nearly 80-percent of scheduled work executed as {
scheduled. , Significant improvements have also been made in surveillance scheduling
.and performance. The number of late surveillances has been reduced-and surveillance procedural adherence has also improved.
~
To improve daily schedule execution, structured daily line management j turnover meetings were established. Schedule performance critiques and i problem solving are also emphasized at that time. Additionally, n' ~! comprehensive outage performance critique-program was instituted-before, during, and after the Unit 2 Cycle 3 refueling' outage. -A-
- number of critique' lessons learned were developed along with corrective action and factored into the outage management program. A structured planning process has been instituted that schedules / manages preoutage activities and identified preoutage milestones, i.e., design issue ';
targets, material procurement goals, scope freeze. The'UlC4 outage- l preparations have not fully' met' expectations and continued emphasis is ! required in this area. We consider.that an effective forced outage-program has been added through the implementation of INPO guidelines. ' An up-to-date forced outage plan'is'always in place. In addition, preplanned power reductions have been utilized to facilitate secondary 1 plant equipment outages for preventive and corrective maintenance to
, enhance plant reliability. Standardized rampdown, shutdown, up power e and startup sequences are now utilized for all planned outages.
Even though scheduling has been improved, TVA will continue to strive to enhance the work scheduling processes and strive to improve responsiveness to plant needs. ; ( i i l
g . . p CLu* t ,'j Continued improvement has also been seen in the maintenance area. An in-deptia maintenance'self assessment was conducted with the assistance : of. peers from other TVA plants and from the Corporate Maintenance-organization.- The results of this assessment were factored into our Maintenance program. The following are examples of a few of the-improvements resulting from this assessment: (1) enhanced control of I the physical work documents, (2) eliminating the backlog of. completed 4 work orders in the review process, (3) enhanced process for field feedback to planners, and (4) improvements in the qualification matrix i, used to assign work. In addition, an INPO assist visit was conducted' to assess Instrument Maintenance surveillance performance, procedural-compliance, and line management" effectiveness. The recommendations from this assessment have been incorporated across the Maintenance organization. The following are examples of actions taken: (1) increased line management's involvement in field activities. (2) simplification of the procedure process, and (3) training on the effects of test equipment warm up in relation to accuracy of readings. Active particfpation in the INPO Peer' Evaluation Program and' plant ) visits by_line management and technicians to " top performer" utilities has resulted in an appreciation of the level of excellence that the' ;jj industry has achieved and where SQN needs to improve to meet or exceed- i those standards. l l We feel that the material condition of the plant has continued to improve as the result of a number of efforts. A valve packing program, i.e., application of live load packing to mitigate leakage has been inplemented. A program and funding has been established that allows
'for expeditious resolution of obsolete equipment concerns and requires that long-standing equipment problems be resolved. Using a systematic approach, an aggressive coatings progrnm has been implemented to-upgrade deficient areas. Preplanned equipment outages have been ;[
' effective in improving the material condition of long-standing '
equipment deficiencies, such as the essential raw cooling water (ERCW) pumping station strainer outages, condensate demineralizer system 'l outages, and area cooler replacement outages. Enhanced requirements to
~
protect' plant equipment have been specified 1n the new work' order program, which when coupled with improved line management involvement , in and ownership of field activities has corrected the practice of J inadequately protecting plant equipment. Indicators show that productivity and efficiency have improved as a result of initiatives put in place this. year. The age of deficiencies in our work order backlog has been reduced and is in line with the-INPO ] W best industry quartile. Implementation of the new work order process ;
-has resulted in improved work order quality, clarity, and accuracy.
Improvements have been made in the flow of material, (i.e., replacement q p parts) to the work site. Periodic time studies have been conducted to identify and troubleshoot productivity problem areas involving work i execution. These periodic time studies indicate that additional improvement is needed. The visibility of performance indicators of ; goals and objectives has increased personnel awareness of performance expectations, and organizational objectives. [ [c j j u -
+ ,.
W my ;c -
^-
y _9.- , k , ? Improvements-have been.made in training...Line management working with ;
' training personnel developed a detailed annual training plan defining ,
training expectations. Structured periodic critiques of training. k performance, i.e., pass / fail rates, schedule deviations, attendance 0 L problems have been initiated.' The concept of'" block training" was ' initiated ~to provide for uninterrupted training in order to enhance the i'
'overall' effectiveness'of training.. Blockitraining consolidates'needed -
' is _ training:into given time periods such that it is logically grouped for
' qualification development and simplified'to improve scheduling and ., ;c , management.. [
A number of significant actions were taken to reduce personnel errors and improve accountability. -Quality Assurance (QA)/ Quality Control (QC) rejections were trended to first line supervisors. These trends reflect improvements in the' quality and attention to detail by' ! personnel ~as we approach the 95 percent acceptance level. Schedule l performance was trended to first line supervisors. Each foreman is monitored with respect to his performance, and his performance is , i posted and critiqued. As discussed earlier, schedule performance has greatly improved. A new personnel error evaluation effort has been instituted to ensure that accountability for personnel errors receives i proper emphasis and is administered at the appropriate level. Expansion of the application of predictive maintenance techniques such. l as. vibration monitoring has afforded opportunities to correct equipment .i degradations before equipment failure has impacted plant reliability. Examples..are planned power reductions to replace a heater drain pump element.and a condensate demineralizer pump bearing. Through improved ; management attention, enhanced preventive maintenance deferral 'j controls, and: approved schedule accountability, overdue preventive ~ maintenance tasks have been reduced from approximately 50 percent of -f all scheduled tasks to less than 10 percent.
. . We feel.that management efforts, such as the major equipment problems )
list, support-the resolution of problems that challenge the Maintenance 1
. group's ability to adequately maintain the plant. Maintenance personnel involvement with maintenance self-assessments, utility visits..and the INPO peer evaluation program have assisted in_ improving the standards applied at SQN along with enhancing worker understanding of industry efforts to improve maintenance performance. i In summary, we consider that steady progress.has been made in the !
4 maintenance and surveillance functional areas during the assessment ! period as a result of continuous effort and management focus. Diagnostic, predictive, preventive, and corrective maintenance activities all show notable improvements and positive trends. SQN is i not satisfied with current performance and will continue efforts toward. > 1mprovements in the conduct of maintenance. ; l i s l
"y s. ,
T M y .
- s. m*
A *
' s <
g 1 IV. : -FUNCTIONAL'AREAt Emergency Preparedness-(EP)'
, o
(?
* -The Radiological Emergency. Plan.(REP)! training program'has been
- Jupgraded and enhanced during this assessment-period. REP training.
. lesson plans are now in place for specific EP position training. All F
REP training is conducted by EP staff members. Craftsmen emergency
- response and damage contro11 team training has been formalized and Limplemented.- Key site management receives one-on-one training.
( Training sessions are periodically upgraded to include current issues a[; " such as Nuclear-Experience Review items and lessons learned from drills
" and-exercises. Drills and exercises are scheduled monthly to ensure continued. training of the three rotating response teams along with new personnel. We feel that increased site and corporate management overview, interaction, and participation in the site EP program has raised the level of awareness.and preparedness of the onsite' emergency' l response organization.
Establishment of personnel accountability has been greatly enhanced by the implementation of the Personne1' Radiological Emergency
. Accountability System (PREAS). .PREAS is a significant improvement over the manual method of personnel accountability and has been used during ?!
several drills and exercises with very reliable results. In addition, the: prompt notification system (PNS) has been enhanced and expanded from'a five mile to a ten mile radius around SQN. Tests have indicated a positive response, with the Federal Emergency Management Agency reporting the greatest public awareness of any area within plants 4 located in NRC Region II. The Technical Support Center (TSC) and Operations Support Center
-response capabilities have also been enhanced. The installation of a communications circuit allows ree.1 time data input from the control i- room to the. centers and the Central Emergency Control Center by a {
radiotelephone and headsets. Statusboard writers and logkeepers have been: upgraded to technical rather than clerical' personnel.
-Statusboards have been revised and relocated to more accurately reflect ,
events and actions and improve visibility. Minimum staffing 1 l requirements have been identified and a system.for quick staffing status determination is used. A safety parameters display system i enhancement is in progress which will include the addition of
. radiological release point graphics and measurements.
We consider our policy of conducting a thorough critique by performers and management following each drill or exercise has resulted in program 4 improvements. Any exercise, audit, or report items are assigned to a ., responsible manager with due dates and followed to closure, i Actions were taken during this assessment period to improve performance
.in REP activations, particularly for lower threshold events. Emergency Plan Implementing Procedure (EPIP) 1, " Emergency Classification Flow Chart," has been rewritten and reformatted to clarify wording and remove ambiguity. Formalized mandatory checklists have been included in the EPIPs to ensure quicker response actions and emergency center f
h C.
pp ;, m . b; . .. . p .- ,
-11
. # t,
?
. .. Lt' g
' -activation.- Standardization;of the EPIPs.with other sites has enhanced.
l , their.usefullness and clarity.through human factorss considerations.. The SQN' simulator-is used for drills and exercises. . Dynamic real-time L data is' generated on the simulator and displayed in the emergencyL b centers to_ increase realism.' Consequently, drills and exercises can be b ' conducted without impacting control room operations. _INPO recently
-gave a favorable response to an observed " casualty control" drill
-{
citing use of.the simulator'as a strong point. To address a weakness,. operator training on event recognition and classification during. ant;ual- ; requalification has been expanded. On-shift event classification "exercisea'with the shift senior reactor operators and shift technical advisors are being conducted on a continuing basis to promote consistent and conservative judgment in the evaluation process, leading . to event classification. In summary, we consider that the emergency preparedness functional area-at SQN has received close management' attention during the assessment period and significant improvements are being made. Enhancements to-the training program, improvements in event classification procedures and emergency _ response procedures, implementation of'PREAS, PNS, TSC improvements, and improved performances during the annual graded , exercise and INPO assistance visit are all good-indicators of continuing progress in this functional area. V. FUNCTIONAL AREA: Security During this assessment period, we consider the site security organization to have achieved greater stability and to have been able to better focus on improved performance. Improvements are evidenced by the low number of safeguard Licensee Event Reports (LERs) that have been written during this assessment period. During this assessment _ period, one cited violation and two noncited violations were identified. he believe the two noncited violations show the results of more aggressive management philosophy.to identify and resolve problems. In addition, corrective _ actions were implemente' d , resulting ;
'in immediate compliance ~for the cited. violation.-
The present age'of the existing security equipment and the reduced
. configuration of the powerblock protected. area have resulted in problems which need to be corrected. This situation has resulted in several-long-term'and some short-term compensatory measures during the
. assessment period. The effectiveness of these compensatory actions is evidenced by the low number of safeguard LERs and the singular cited ,
security violation; however, TVA will continue to give priority attention to these compensatory posts. TVA will implement a major security system upgrade in 1992 thereby eliminating the need for these compensatory posts. Implementation'of this upgrade will result in a state-of-the-art security system at SQN. Until the security system E upgrade is completed, Nuclear Security will continue to utilize existing systems, personnel, and procedures to ensure the security of the plant. Increased attention will be given to the maintenance of the existing system to minimize compensatory posts. The current security force is adequately staffed to support required compensatory measures and current work load in a manner consistent with NRC requirements and
.TVA's QA program. ,
e e
gw - - VU ' . 2h. eV 4
) 1 ,
.9
[* 7' ~ f, 9[3d* ' ; Further_ improvements-in~ security capability'are expected to result from .
' actions currently underway such-as new equipment procurement andi s
' increased training. New weapons have been purchased and a contract has si .been let-for new cotton utility uniforms. These uniforms, scheduled M for delivery this_ summer,- will' be' less sensitive to airborne .
t contamination thanlthe present, uniforms-and will provide officers with + more-durable and functional work attire.- Training courses have been attended at both the Department of Energy Central Training Academy and the Federal-Bureau of Investigation. Joint training exercises have v -also been conducted with city, country, state, and federal law Sc enforcement agencies, j m In summary, we consider continued progress is being made in the area of , f -training and qualifications to maintain the high standards of the security force. Progress is being made toward implementing the major security-system upgrade. Appropriate compensatory measures to ensure ; the security of the plant are in place and constantly being assessed for effectiveness. The maintenance of the existing security system . will' receive increased attention. VI. FUNCTIONAL AREA:- Engineering / Technical Support .; Nuclear-Engineering-(NE):has developed and implemented a comprehensive ; improvement plan over the last year to address those areas needing ; improvement while also maintaining programmatic strengths. Improved performance under this organization has been-evidenced by significant-accomplishments such as meeting the FY1989 3oal of a 40-percent reduction _in_the backlog of condition adverse to. quality reports
~(CAQRs) and significant . improvement in NE's responsiveness to the plant needs by supporting Plan of the Day meetings, participation in event i investigations, and providing 24-hour duty manager coverage. These actions have also resulted in a general improvement in communication between NE and the plant.
~
I As-a part of this improvement plan a review was performed of NE's organization and mission. As a result, organizational changes were made that included the elimination of a' layer of management, thereby driving. responsibility and accountability-lower in the organization. Also, several engineering disciplines were combined to reduce interfaces between discipliness The lead engineer positions-were upgraded, thereby strengthening management involvement in engineering activities. In addition, the lines of responsibility were clarified . with more authority and responsibility being vested at the site. The y vast majority (approximately 90 percent) of the engineering work for SQN is now done at the. site. Work performed off site is formally issued at the site.after review and acceptance by site personnel. NE has also started conducting night classes for system and discipline , engineers to further improve their knowledge of plant operation. 4 I I
.s
/ '$ .-
r
~~
' ~
,4 -
~
Q The FY1989 goal-to reduce the older (pre-7000) series' engineering
~
1 1 change notices / design change notices:(ECNs/DCNs) in' field complete
status by.50 percent lwas met and significant progress was,also:made on-
-a'similar post-7,000 series ECN/DCN project. This has'resulted in over 575: ECNs/DCNs being closed in Calendar Year 1989. Another improvement
~
was achieved when the Design Change Document' Tracking System (DCDTS). became fully' operational in July 1989. This system is used for collecting design changes.related,_to plant: configuration and posting those changes until primary and secondary drawings are updated.- This
. results in the designers being able to identify unimplemented b.ut N issued. designs as well as constructed changes not yet incorporated on.
drawings'along with helping plant engineers identify constructed changes not yet incorporated on drawings. At this same time, engineering made a decision to accelerate the elimination of the old and transitional design processes by eliminating the field change requests process and replacing it with the current F-DCN process that requires-full engineering evaluation. Pre-7000 series ECNs were frozen and-are being closed with-the exception of 70 that are prudent to work, such as those that are involved with TACF elimination or Cycle 4
-" refueling outage work.
NE has:also made considerable progress on a project to upgrade the SQN vendor manual program. An extensive reevaluation of this, program was- - completed during the assessment period and several program enhancements were initiated, including an expanded manual accessioning process and a scheduled vendor recontact program. On October 1,.1989, contractor
~
support of' vendor manual work was eliminated and NE assumed full implementation of this program. To address specific feedback and communications problems between NE and plant personnel in the area _of vendor manuals, a joint-vendor manual user task force-has been formed 3 with representation from various organizatious within the site to 1 ensure user problems are. communicated and-resolved. t Y Progress has also been made on.several projects to increase the automation of engineering procurement support. An automated j procurement system to electronically capture the quality, technical,- 1 and commercial. requirements for procurement of inventory stock items'is l currently being developed. Initial system operation is planned during i FY1990. As a temporary measure prior to full implementation of the i automated system, a semiautomated system has been put in place for j high-use baseline specifications that puts generic commodity j specifications in both site and purchasing computers with an assigned , inventory population. I Action has been taken to improve the engineering support for outages. While some improvements lhave been made in this area, engineering , s deliverables for the Unit 1 Cycle 4 outage have not been as timely as j~ desired. Additional improvement in early design issuance and material procurement will be effected for the Unit 2 Cycle 4 outage. t r i N
am , n
,~ n . .
7
- P s!= , ,
b-i
, -i I'
In addition toLthe management attention that has been given to NE,.
-programmatic'and management changes have been made.in the plant f Technical Support group. Weaknesses in the current Technical Support organization.were identified as part of the reorganization and'
, assessment conducted at SQN in the summer of'1989. To further evaluate the system _ engineering area, a peer evaluator was-requested as part of the INPO plant audit. team. As part of the System Engineering upgrade,
~
a new experienced manager was~ recruited for the Technical Support group. The new manager performed a special assessment of the Technical Support group and provided specific recommendations in January 1990 to management; these recommendations are currently being implemented. These recommendations include organizational changes to improve efficiency, establishment of a lead engineer concept to shore up less i experienced engineers, recruitment of more experienced engineers, and the formal. reassessment of manager and engineer performance. .l
'P Additional _ improvements have already been implemented to improve performance in the Technical Support group. For example, monthly.
management meetings have been instituted between the Technical Support group and other onsite organizations to improve communications. Regular meetings between_the Technical Support Section Manager and both management and Technical Support engineers have also been established 3 to improve understanding of standards and. expectations. A weekly 't system walkdown program has also been established with specific
~
, instructions. _ Management is now participating on walkdowns with specific System _ Engineers to enforce standards on a weekly basis. In addition, trending of important system parameters to detect problems , and establish proactive action plans is being given increased emphasis. ; These. improvements are being implemented to enhance the plant's ability to better identify problems and drive.these-problems to final solution
~and-are intended to further strengthen and reinforce the system engineering concept previously introduced. While it is too early to measure the effects of these changes, the initial indications'such as )
the increasing number of work-requests initiated by the systems- ! engineers'as a result of system walkdowns are positive. Another sign ; of improvement is that the threshold-level for acceptable plant I material conditions has been raised as evidenced by the type'of work requests being written by the systems engineer. System Engineering personnel:are spearheading development of corrective action plans for identified _ equipment deficiencies.- In addition, more emphasis has been placed on_the interface between System Engineering and NE in the final evaluation and development-of these plans. In summary, we consider that performance in the NE and Technical Support functional areas has shown improvement,during this assessment period; however, we are not satisfied with the current performance of these groups and will continue to strive for exec 11ence with these. critical functions. c
.m_
pc V
,o +
e gy, p' + r .- =
;i s <
T ;VII. LFUNCTIONAL' AREA Safety A'ssessment/ Quality-Verification ~ l
. As the NRC staff is aware, the 50.59 program has been significantly y upgraded during this assessment period by standardizing implementing L
procedures, clearly defining and increasing safety evaluation preparer l L' qualifications, and enhancing 50.59 training content and requirements. The revised program is based extensively upon the guidance.of Nuclear K Safety Analysis Center Publication 125. Changes'to the plant, procedures, or. conduct of test or experiments receive an assessment to determine if the activity is safe, if a change to TSs in required, and if an unreviewed safety question exists or could' result from the C change. The safety atsessment also provides the determination as to p whether a safety evaluation is required. A qualified Level I preparer, fD who has completed required 50.59 training, performs-safety assessments I; . and evaluations. In addition, an' independent qualified Level II~ 4 reviewer who has demonstrated a background in the 50.59 process, plant systems knowledge, and FSAR requirements and assumptions checks the safety assessment and evaluation for both technical adequacy and
-documentation and must concur with assessment or evaluation conclusions. ;
LU Implementation of the new program has been and continues to be monitored both by line management and internal assessment and review organizations such as site QA, Plant Operations Review Committee, and Nuclear Safety. Review Board (NSRB). TVA's review to date of the new-10 CFR 50.59 program indicates that implementation is generally resulting in appropriate assessment and evaluation of changes, although some weaknesses have been identified. . Further enhancement:and-refinements to the. process are accordingly being made, with special- ' focus on human factors considerations that could affect consistency in the application of the~ process. TVA will implement corrective actions ' to address concerns identified in:a recent NRC inspection report end will continue to closely monitor Lenhance, and improve the process:as 3 necessary.
'During this assessment period, TVA-formalized and3 implemented an ,
upgraded process for performing-incident and event investigations. ;i i ~;- Under :this process, detailed investigations are conducted by
-multiorganization teams led by responsible line managers. ;
Investigations consist of a detailed review of the sequence of events,
~
r -including personal interviews to ascertain the root cause(s) of:the
~
event, close examination of personnel performance, analysis of safety implications, and establishment of detailed corrective actions. The more structured process with extensive management oversite and e involvement. facilitates the determination of the true root cause'of ,
+ associated events, thereby improving in line quality verification of- !
associated activities. Tracking and trending of these investigations ff has been implemented to further the assessment of the effectiveness of
~
established corrective actions or to identify specific functional area problems.- Recent management actions have been taken to change personnel attitudes about problem reporting and to encourage problem identification to supervisors. Two site dispatches promoting these expectations have , been issued by the Vice President, Nuclear Power Production. e
-- w - - ---x - ---.-- - _ _ _ - - - - - _ _ - - . _ _ - . - -
~
u.. [:> , t
- {t Q:.*.
Q[ < 4 This' topic was also emphasized in the-recent Site Director's quarterly p meetings held with over 1,300 SQN employees (16 meetings). The CAQR ; c management review committee!has been restructured to include senior 9: . site management to assess the extent to which the message regarding problem reporting.As being. understood, to ensure prompt corrective actions.to identified problems,.and:to ensure quick resolution of ;
~
y potential problems. A multisite task force was formed in early t November 1989 to evaluate the implementation and structure of the-problem' identification' process and recommend improvements. The Vice President Nuclear. Power Production, was briefed on the_ team - k" recommendations in January 1990. The planned changes to this program ! include utilization of a single problem reporting document, a lower threshold;for incident investigations, and the establishment of
~
p criteria to ensure the appropriate resolution of' potential. problems. ,
- g. The change to utilize a single problem reporting document will be H'l completed by June 1, 1990.
The Site Quality organization continues to be more aggressive and proactive in identifying and correcting quality issues. Management has focused attention-on improving the Site Quality organization over the last year by directing _ audit and surveillance activities toward review of technical. adequacy and effectiveness as opposed to compliance reviews. The recent transition and integration of Engineering Assurance functions into' Nuclear Quality Assurance has expanded the ability of the Site Quality organization to effectively evaluate the adequacy of engineering programs and deliverables. The trending program-has been improved by increasing both the line and Site. Quality organization involvement in identifying, atalyzing, and correcting adverse trends.. Communication and rapport between the line and Site
-Quality organizations continue to improve. This_ relationship is essential to_a successful quality program. Recent independent evaluations conducted by the Nuclear Manager's Review Group:(NMRG) and
~
NRC clearly indicate that the Site Quality' organization has improved
-its effectiveness.in identifying and-resolving quality issues _.
#: Specifically, NMRG Report No. R-90-01-NPS concluded, "that the; review of engineering products was enhanced through effective Nuclear ~ Quality Assurance monitoring . . .. " The NMRG technical evaluations of-previously monitored engineering products did'not reveal,any significant unidentified deficiencies. In addition, the results of the
~NRC' Resident Inspector's monthly exit meetings (Inspection Reports 90-03 and 90-06) acknowledged the Site Quality organization's f aggressiveness and trend toward identification of technical findings.
The NSRB was recently restructured and new management put in place as part of an effort to improve NSRB review and the handling of NSRB concerns. The TVA senior line management board member assignments have been revised to provide more operational experience and to bring experience to the boards from other TVA sites. The advisor membership has also been changed to increase operational experience and to have advisors serve on the boards for more than one TVA site. These changes
- are directed to ensuring that the NSRB will have a broad programmatic perspective with an emphasis on operational concerns. The changes are also intended to provide another forum for communication of problems and solutions between TVA sites.
^
fy tr t .;3 3 % ;.;
, , 75 , -17 .
NSRB has also been active in monitoring the~50.59 safety evaluation-
-program. :A-standing unreviewed safety question determination p/l -
subcommittee reviews a sample of the. safety evaluations prepared and-reports on the results to-the NSRB'and back to line management. The: [i ' s NSRB has also taken a-very active role in the review of SQN technical specification changes. In particular, 29 changes were reviewed in the last year and 12.of the reviews resulted in modified change' packages or changes to the implementation plan.. ) ' In addition to-the actians noted in the previous paragraphs, Site [ Licensing has continued the improvements in the' timeliness and quality of submittals noted in the last NRC assessment report. Licensing has L ;been tasked with improvement in overall NRC commitment performance; we. [' consider that significant-improvement has been made between 1988 and 1989. L In summary, the-safety assessment and quality verification functional l; areas have experienced some problems during this assessment period. We 6 do. feel that extensive corrective action has been taken and improved performance has been noted in many areas. Performance improvements E .have continued in the Sits Licensing and site quality areas and overall in site in-line quality verification. Further improvements and enhancements will continue to be made to the'10 CFR 50.59 program to ib strengthen performance in the safety assessment area. TVA recognizes 1 the vital-role =this functional area plays in the overall performance of the plant.-_We consider that the foundation has been laid for continued b progrt.is in these areas and improvement is expected over the next-year. l
.VIII.
SUMMARY
From an;overall assessment, we consider that SQN has made progress in
.many areas during this assessment period. We have worked very hard to institute.important fundamental improvements in several areas, yet we.
know there are.still problems in other areas and work remains ahead to ! solve =these problems. One key improvement is that line management has ' made increased use of critical ~self assessment. We feel this' foundation will support the progress.made to date and provide a solid-focus for future improvements. 1 A P Y
)
'r' k
g-' 9 ': p: -, : $~ o LICENSING TRANSMITTAL TO NRC
SUMMARY
- AND CONCURRENCE SHEET DATE TRANSMITTED TO MJR. 03/08/90 L'
THE PURPOSE OF.THIS CONCURRENCE. SHEET'IS TO ASSURE THE ACCURACY AND COMPLETENESS OF TVA SUBMITTALS TO THE NRC. j DATE DATE DUE NRC 1/31/90 - A ' ACTION NO. {C- SUBMITTAL PREPARED BY Geof A. Hipp NO X FEES REQUIRED YES
, PROJECT / DOCUMENT I.D. Sequoyah Nuclear Plant (SON) Units 1 and 2 - Status and Results of the Performance Improvement Program for the Systematic Assessment 9
._qf Licensing Performance (SALP) ,
p PURPOSE /
SUMMARY
To provide a report to NRC describing the status and results of' corrective actions described in~the SALP response.
- RESPONDS TO N/A (RIMS NO.) COMPLETE RESPONSE YES X NO
~ PROBLEM OR DEFICIENCY DESCRIPTION The SALP' response committed to a Performance f[ Improvement Program at SON and to provide a report to NRC describing the status and'results of the corrective actions described in the response before
~
the next SALP report for SON. CORRECTIVE ACTION / COMMITMENT This report fulfills the commitment to provide a report:to NRC. INDEPENDENT REVIEW DATE
. A concurrence signature reflects that the signatory has assured that the
. submittal is appropriate and consistent with TVA policy, applicable i
commitments are approved for implementation, and supporting documentation for 4 submittal completeness and accuracy has been prepared. CONCURRENCE NAME ORGANIZATION SIGNATURE DATE-
'J. R.-Bynum VP NPP file copy signed 03/08/901_
F. L. Moreadith -VP Nuclear Engineering file copy signed 02/07/90 M. O. Medford VP Nuclear-Tech Director file copy signed 03/08/90 D. R. Nichols Office of General Counsel J. V. Gluicci signed 02/15/90 W. L.' Byrd For SON Interim Site Director file' copy signed 02/09/90 C. A. Vondra SON Plent Manager file copy signed 02/09/90 P. G.-Trudel SQN Proiect Engineer file copy signed 02/03/90
.F. J. Burzynski SQN Site Licensing Mgr file copy signed 02/06/90 APPROVED DATE NLRA MANAGER 0677h E.
;7 L~
".: o ,-
y., f LICENSING TRANSMITTAL TO NRC DATE TRANSMITTED
SUMMARY
AND CONCURRENCE SHEET TO MJR 03/08/90 E -THE PURPOSE OF THIS CONCURRENCE SHEFT IS TO ASSURE THE ACCURACY AND f2 -COMPLETENESS OF TVA SUBMITTALS TO THE NRC.-
- h. DATE' DATE DUE NRC 1/31/90 - A ACTION NO.
7 NO ' X SUBMITTAL PREPARED BY Geof A. Hipp FEES REQUIRED YES PROJECT / DOCUMENT I.D.- Sequoyah Nuclear Plant (SON) Units 1 and 2 - Status and Results of-the Performance Improvement Program for the Systematic Assessment b of-Licensing Performance (SALP) PURPOSE /
SUMMARY
To provide a report to NRC describing the status and results of corrective actions described in the SALP response. RESPONDS TO N/A (RIMS NO.) COMPLETE RESPONSE YES X N0__ PROBLEM OR DEFICIENCY DESCRIPTION The SALP response committed to a Performance Improvement Program at SON and to provide a report to NRC describing the status and results of the corrective actions described in the response before the next SALP report for SON. , CORRECTIVE ACTION / COMMITMENT This report fulfills the commitment to provide a report to NRC. l i INDEPENDENT REVIEW DATE ) A concurrence signature reflects that the signatory has assured that the submittal is appropriate and consistent with TVA-policy, applicable commitments are approved for implementation, and supporting documentation for submittal completeness and accuracy has been prepared. , CONCURRENCE 'i
'NAME ORGANIZATION SIGNATURE DATE J. R. Bynum' VP NPP file copy signed 03/08/90 ,j u
F. L. Moreadith VP Nuclear Engineering file copy signed 02/07/90 , I M. O. Medford VP Nuclear Tech Director file copy signed 03/08/90
'D. R. Nichols ' Office of General Counsel J. V. Gluicci signed 02/15/90 W. L. Byrd For SQN Interim Site Director file copy signed 02/09/90 j C.'A. Vondra SQN Plant Manager file copy signed 02/09/90 P. G. Trudel SQN Project Engineer file copy signed 02/03/90 M. J. Burzynski SON Site Licensing Mgr file copy signed 02/06/90 4
APPROVED DATE NLRA MANAGER o 0677h I
)
7
.. ~
- .; a ,
J' Sequoyah Site Lic^nsing
- 7 '
[L Concurrence Sheet l-t DUE TO NTD. DATE DUE NRC 1/31/90 - A PROJECT / DOCUMENT I.D. Sequoyah Nuclear Plant (SON) Units 1 and 2 - Status and Results of the Performance Improvement Program Incident Investigation No.. N/A f Cross Reference Documents (PRO, CAQR, etc.) N/A CONCURRENCE -i SIGNATURE OR 1 NAME ORGANIZATION LETTER REFERENCE DATE G. A. Hipp SQN Licensing Engineer file copy signed 02/01/90 M. A. Cooper SON Compliance Lic Mgr file copy signed 02/06/90 J. S. Smith SON Site Licensing ~ fil'e copy signed 02/01/90 W. L. Byrd SQN Proi Cont / Fin Svs Mgr file copy signed 02/07/90 .! 1 W. R. Lagergren SQN Operations Mgr file copy signed'01/30/90
'M.1T. Sullivan SON Radiological Control Supt Charles Kent signed 02/07/90 N. S. Catron' SQN Emergency Preparedness file copy signed 01/31/90 R.-L. Lumpkin Jr. -SON Site Quality Mgr T. A. Flippo signed 01/30/90 R. J. Beecken SON Maintenance Supt file copy signed 02/01/90 J. K. Gates SQN' Tech Support Supt file copy signed 01/31/90 l file copy signed 02/01/90
[ O. L.'Kelley- SQN Security Mgr
'i
{ M. R. Harding Protective Svs Mgr file cooy signed 02/01/90 , l NRC response'or approval required? Yes X No
*** NOTE: This sheet should be removed by Corporate Licensing upon receipt.***
0677h
y - c, 7, f Sequoyah Site Lic nsing
- i. - '
K Concurrence Sheet t, 1 h I: DUE'TO NTD DATE DUE NRC 1/31/90 - A V t l PROJECT / DOCUMENT.I.D. Sequoyah Nuclear Plant (SON) Units 1 and 2 - Status and-P Results of the Performance Improvement Program t t I Incident Investigation No. N/A i < Cross Reference Documents (PRO, CAQR, etc.) N/A i L CONCURRENCE SIGNATURE OR NAME ORGANIZATION LETTER REFERENCE DATE' __ G. A. Hipp SQN Licensing Engineer file copy signed 02/01/90 M. A. Cooper SON Compliance Lic Mgr file copy signed 02/06/90 J. S. Smith SQN Site Licensing file copy signed 02/01/90 > W. L. Byrd SON Proj Cont / Fin Svs Mgr file copy signed. 02/07/901 W. R.'Lagergren SON Operations Mgr file copy signed 01/30/90 M. T.'Sullivan SON Radiological Control Supt Charles Kent signed 02/07/90 N. S. Catron SON Emergency' Preparedness file copy signed 01/31/90 R. L. Lumpkin,~Jr. SQN Site Quality Mgr T. A. Flippo signed 01/30/90
.R. J. Beecken SQN haintenance Supt file copy signed 02/01/90 J. K. Gates SQN Tech Support Supt file copy signed 01/31/90 C. L. Kelley- SQN Security Mgr file copy signed 02/01/90 M. R. Harding Protective Svs Mgr file copy signed 02/01/90 NRC response or a'pproval required? Yes X No
*** NOTE: This sheet should be removed by Corporate Licensing upon receipt.***
0677h
,}}