ML18032A284
| ML18032A284 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/13/1987 |
| From: | Ellen Brown, Ensworth F, Martin M TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML18032A274 | List: |
| References | |
| 70700, 70700-R03, 70700-R3, NUDOCS 8706040263 | |
| Download: ML18032A284 (72) | |
Text
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
70700 REpORT TYPE:
Management and Personnel Subcategory TITLE; Organization
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REVISION NUMBER:
3 PAGE l OF 20 REASON FOR REVISION:
Incorporation of final TAS editorial comments.
PREPARED BY:
PREPARATION PEER:
c< M TAQ SIGNATURE SIGNATURE REVIEWS DATE DATE SIGNATURE CONCURRENCES SIGNATURE APPROVED BY:
DATE CEG-H:
SRP:
SIGNATURE" 5-(3-8T DATE N/A DATE SP MAN GER MANAGER OF NUCLEAR POWER CONCURRENCE (FINAL REPORT ONLY)
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=SRP Seer'etary's signature 8706040263 870522 PDR
- DOCK 05000259 P
PDR denotes SRP concurrences are in files.
I DATE
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
70700 FRONT MATTER REV:
2 PAGE i OF viii Preface This subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley Authority (TVA).
The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) employee concerns filed before February 1, 1986.
Concerns filed after that date are handled by the ongoing ONP Employee Concerns Program (ECP).
The ECSP addressed over S800 employee concerns.
Each of the concerns was a
formal, written description of a circumstance or circumstances that an employee thought was unsafe, unjust, inefficient, or inappropriate.
The mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, the
- NRC, and the general public.
The results of these investigations are communicated by four levels of ECSP reports:
- element, subcategory,
- category, and final.
Element reports, the lowest reporting level, will be published only for those concerns directly affecting the restart of Sequoyah Nuclear Plant's reactor unit 2.
An element consists of one or more closely related issues.
An issue is a potential problem identified by ECTG during the evaluation process as having been raised in one or more concerns.
For efficient handling, what appeared to be similar concerns were grouped into elements early in the program, but issue definitions emerged from the evaluation process itself.
Consequently, some elements did include only one issue, but often the ECTG evaluation found more than one issue per element.
Subcategory reports summarize the evaluation of a number of elements.
- However, the subcategory report does more than collect element level evaluations.
The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.
This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparent at the element level.
To make the subcategory reports easier to understand, three items have been placed at the front of each report:
a preface, a glossary of the terminology unique to ECSP reports, and a list of acronyms (terms formed from the first letters of a series of words).
Additiona11y, at the end of each subcategory report the reader wi11 find at least two attachments.
The first is a Subcategory Summary Table that includes the following information:
-the concern
- number, a brief statement of the concern, and a designation of nuclear safety-related concerns.
The second attachment is a listing of the concerns included in each issue evaluated in the subcategory.
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2 PAGE ii OF viii The subcategories are themselves summarized in a series of eight category
- reports, Each categoxy report reviews the major findings and collective significance of the subcategory reports in one of the following areas:
management and personnel relations industrial safety construction material contxol operations guality assurance/guality control welding engineering A separate report on employee concerns dealing with specific contentions of intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.
Just as the subcategory reports integrate the information collected at the element level, the category reports integrate the information assembled in all the subcategory reports within the category, addressing particularly the underlying causes of those problems that run across more than one subcategory.
A final report will integrate and assess the information collected by all of the lower level reports prepared for the
- ECSP, including the Inspector General's report.
For more detail on the methods by which ECTG employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employee Concerns Task Group Program Manual.
The Manual spells out the program's objectives,
- scope, organization, and responsibilities.
It also specifies the procedures that were followed in the investigation, reporting, and closeout of the issues raised by employee concerns..
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER'0700 FRONT MATTER REV:
2 PAGE iii OF viii ECSP GLOSSARY OF REPORT TERMS~
classification of evaluated issues the evaluation of an issue leads to one of the following determinations:
Class A:
Issue cannot be verified as factual Class B:
Issue is factually accurate, but what is described is not a
problem (i.e.,
not a condition requiring corrective action)
Class C:
Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the issue was undertaken Class D:
Issue is factual and presents a problem for which corrective action has
- been, or is being, taken as a result of an evaluation Class E:
A problem, requiring corrective action, which was not identified by an employee
- concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.
t collective si nificance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
concern (see "employee concern")
corrective action steps taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence.
criterion lural:
criteria a basis for defining a performance,
- behavior, or quality which ONP imposes on itself (see also "requirement").
element or element. re ort an optional level of ECSP report, below the subcategory level, that, deals with one or more issues.
em lo ee concern a formal, w."itten description of e circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-form,
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2 PAGE iv OF viii evaluator(s) the individual(s) assigned the responsibility to assess a specific grouping of employee concerns'findin s
includes both statements of fact and the judgments made about those facts during the evaluation process; negative findings require corrective action.
issue a potential problem, as interpreted by the ECZG during the evaluation
- process, raised in one or more concerns.
K-form (see "employee concern")
evaluation judgment or decision may be based.
root cause the underlying reason for a problem.
<Terms essential to the program but which require detailed definition have been defined in the ECTG Procedure Manual (e.g.,
- generic, specific, nuclear safety-related, unreviewed safety-significant question),
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2 PAGE v OF viii Acronyms AI AISC ALARA ANS ANSI ASME ASTM AWS BFN CAQ CCTS CEG-H CFR CI COC DCR
'NC Administrative Instruction American Institute of Steel Construction As Low As Reasonably Achievable American Nuclear Society American National Standards Institute American Society of Mechanical Engineers American Society for Testing and Materials American Welding Society Browns Ferry Nuclear Plant Bellefonte Nuclear Plant Condition Adverse to Quality Corrective Action Report Corrective Action Tracking Document Corporate Commitment Tracking System Category Evaluation Group Head Code of Federal Regulations Concerned Individual Certified Materia1 Test Report Certificate of Conformance/Compliance Design Change Request Division of Nuclear Construction (see also NU CON)
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2 PAGE vi OF viii DNE DNQA DNT DOE DPO DR ECN ECP ECP-SR ECSP ECTG EEOC EQ EMRT EN DES ERT FCR FSAR FY GET HCI Division of Nuclear Engineering Division of Nuclear Quality Assurance Division of Nuclear Training Department of Energy Division Personnel Officer Discrepancy Report or Deviation Report Engineering Change Notice Employee Concerns Program Employee Concerns Program-Site Representative Employee Concerns Special Program Employee Concerns Task Group Equal Employment Opportunity Commission Environmental Qualification Emergency Medical Response Team Engineering Design Employee
Response
Team or Emergency
Response
Team Field Change Request Final Safety Analysis Report Fiscal Year General Employee Training Hazard Control Instruction HVAC INPO IRN Heating, Ventilating, Air Conditioning Installation Instruction Institute of Nuclear Power Operations Inspection Rejection Notice
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2 PAGE vii OF viii L/R MAI MI MSPB NCR NDE NPP NPS NQAM NRC NSB NSRS NU CON Labor Relations Staff Modifications and Additions Instruction Maintenance Instruction Merit Systems Protection Board Magnetic Particle Testing Nonconforming Condition Report Nondestructive Examination Nuclear Performance Plan Non-plant Specific or Nuclear Procedures System Nuclear Quality Assurance Manual Nuclear Regulatory Commission Nuclear Services Branch Nuclear Safety Review Staff Division of Nuclear Construction (obsolete abbreviation, see DNC)
NUMARC Nuclear UtilityManagement and Resources Committee OSHA Occupational Safety and Health Administration (or Act)
ONP OWCP PHR QC QCI Office of Nuclear Power Office of Workers Compensation Program Personal History Record Liquid Penetrant Testing Quality Assurance Quality Assurance Procedures Quality Control Quality Control Instruction
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2 PAGE viii OF viii QCP QTC RIF RT SQN SI SOP SRP SWEC TAS TEL TVA TVTLC Quality Control Procedure Quality Technology Company Reduction in Force Radiographic Testing Sequoyah Nuclear Plant Surveillance Instruction Standard Operating Procedure Senior Review Panel Stone and Webster Engineering Corporation Technical Assistance Staff Trades and Labor
.Tennessee Valley Authority Tennessee Valley Trades and Labor Council Ultrasonic Testing Visual Testing WBECSP Watts Bar Employee Concern Special Program WBN WP Watts Bar Nuclear Plant Work Request or Work Rules Workplans
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3 PAGE 2
OF 20 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction The 24 concerns in the Organization Subcategory are statements by employees pointing out disadvantages in the current organizational structures and in certain reporting relations between organizations.
Individual responses previously had been prepared for 9 of the 24 concerns.
Most of the concerns are reactions to reorganizations that have occurred over the last couple of years.
Of the 24 concerns, 20 were generic, while 4 were site specific.
These concerns raised nine issues which are evaluated in this report.
To locate the issue in which a particular concern is evaluated, consult the following attachments:
Attachment A, Subcategory Summary Table Attachment B, List of Concerns by Issue All Management and Personnel Category concerns having a technical component (including all concerns designated Nuclear Safety-Related) are shared with the appropriate technical category for investigation and resolution of that technical component.
Report(s) sharing a
concern with this report are identified in the entry for that concern on Attachment A.
1.2 Descri tion of Issues 1.2.1 Issue 70701 The Role and Independence of Engineering The concerns that raised this issue are general statements that negative effects could possibly result from the (now abandoned) owner/operator philosophy that decentralized control of plant operations and made them the responsibility of each site director, 1.2.2 Issue 70702 - Redundancy in Creation of Nuclear Services Branch in Construction The concerns that raised this issue guestioned why the Nuclear Services Branch was created in the Division of Nuclear Construction (DNC) when the same work was being done by the Modifications Group that reported to the Site Director.
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OF 20 1.2.3 Issue 70703 Too Many Separate Groups and Employees One very general concern stated that fewer groups/managers/employees would make for a better organization, Two others stated that Engineering is poorly organized at Bellefonte Nuclear Plant (BLN),
1.2.4 Issue 70704 WBN Project Control The concerned individual (CI) contends that WBN construction is not run by the manager, but by the Project Control Group.
1.2.5 Issue 70705 Discipline Staffing The CI contends that morale is adversely affected by "discipline staffing,"
a type of matrix organization initiated in the Division of Nuclear Engineering in 1984.
1.2.6 Issue 70706 Discretionary Safety Reviews The two concerns (from one employee) that raised this issue suggest that underfunding of a particular department (unspecified) results in a lack of discretionary safety reviews.
1.2.7 Issue 70707 Manager of ONP Not Independent The concern states, "CI feels that the new nuclear manager is a front as he will not be allowed to remain independent,"
1.2.8 Issue 70708 - BLN Project Management The concern states, "No real project management for BLN, There is no single person onsite who is in charge of all site organizations."
1.2.9 Issue 70709 - Management Control of Personnel Matters
'The concern states, "Management lacks control over personnel matters; merit raises, personnel policies, etc.,
are not under direct control of line management."
Note:
A/
C Or anization Issues The Quality Assurance/Quality Control (QA/QC) category group is evaluating a number of concerns that relate to the organization of the QA, and QC functions.
Within the QA/QC
- category, organizational structure is being considered, in the subcategories on Quality Assurance Independence and Authority
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OF 20 and Quality Assurance Organizational Effectiveness.
These issues are sufficiently independent of the organization issues raised in the concerns assigned to the Management and Personnel
- category, that it is appropriate to evaluate them separately.
2.0
SUMMARY
2.1 Summar of Issues The issues evaluated in this report are based on statements by employees pointing out disadvantages in the current organizational structures and in certain reporting relationships between organizations.
Most are reactions to reorganizations that have occurred over the past couple of years.
2.2 Summar of Evaluation Process The evaluator has reviewed all the information available on the concerns in this subcategory.
The information pertinent to the evaluation of the issues has been considered and incorporated in this report.
During this evaluation, numerous documents were reviewed which describe relevant organizations, changes in them, and the reasons for the changes.
The reports already prepared in response to nine of the concerns were also reviewed.
Interviews were conducted with line managers and personnel specialists having knowledge of the organizational changes referred to in the concerns.
2.3 Summar of Findin s
Based on the evaluation, the following conclusions were made:
A.
The issue of the role and independence of Engineering identified a problem at the time the concerns were expressed.
The organizational philosophy and structure were heavily weighted in favor of short-term operational decisions over engineering concerns for design integrity.
This situation has since been corrected.
The engineering role has been strengthened and checks and balances are in place to ensure that disagreements between engineering judgments and operational considerations are heard and properly resolved.
The evaluations being conducted under the Engineering Category of the Employee Concerns Task Group will ensure that any technical problems caused by the organizational problem are properly identified and corrected.
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OF 20 B.
There is currently no redundancy in the organization of the modifications function in the'Office of Nuclear Power (ONP).
At the time the employee concerns were expressed, there was duplication of functions between the modifications group under the site director and the Nuclear Services Branch in DNC.
This duplication was intentionally built into the organizational structure and was consistent with the management philosophy current at that time, which stressed efficiency through selection and use of competitive resources.
The recent merger of the groups eliminates the duplication and relies on cooperative decision-making by site and engineering managers to attain efficient resource use.
Although these changes in organization have been
- made, no Organization Bulletins have been issued for Division of Nuclear Engineering (DNE) or DNC, This finding requires corrective action.
C.
The concerns about too many separate engineering groups at BLN were previously evaluated and a response was prepared by line management.
The report found that the concerns identified a
problem.
Corrective action was taken on the problem before this evaluation was done.
D.
The issues pertaining to BLN project management and management control of personnel matters had been adequately addressed by previous responses.
A full evaluation was not possible on the other four issues, either because no requirements or criteria could be identified or because sufficient information was not available to identify the situations referred to in the concerns.
2.4 Summar of Collective Si nificance Major organizational changes during.the past several years have caused confusion and uncertainty regarding responsibilities of various organizations.
Recent reversals of past trends and effective implementation of the Nuclear Performance Plan should help create a stable, clearly documented, and easily understood ONP organizational structure.
2.5 Summar of Causes The confusion cited above resulted from the lack of approved Organization Bulletins for Division of Nuclear Construction and Division of Nuclear Engineering.
This deficiency was in turn caused by the relatively low priority given such documents compared to technical procedures and other documents that are reviewed by the NRC.
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OF 20 2.6 Summar of Corrective Action Organization Bulletins are being developed; the final organization charts and brief organization descriptions will be highlighted in ONP's ~UFront newsletter as soon as the process is complete.
3.0 EVALUATION PROCESS 3.1 General Methodolo The evaluation of this subcategory was conducted according to the Evaluation Plan for the Employee Concerns Task Group and the Evaluation Plan for the Management and Personnel Group.
The concern case files were reviewed.
Source documents were researched and interviews were conducted to identify the requirements and criteria applicable to the issues raised by the concerns.
The concerns were grouped according to the issues they raised.
The issues were evaluated against the identified requirements and criteria to determine findings.
A collective significance analysis was conducted; causes were determined for negative findings; and corrective action for the negative findings was initiated or determined to have already been initiated.
3.2 S ecific Methodolo Numerous documents which describe the organizations addressed in the
- issues, the changes in them, and the reasons for the changes were reviewed The previous reports prepared in response to nine of the concerns were also reviewed.
Eight interviews were conducted.
Project engineers were asked whether checks and balances exist to ensure that Engineering judgments are not being ignored in favor of Operations considerations.
The Chief of the MBN Modifications Branch described the reorganization of the branch's function and the reasons for it.
Interviews were conducted with personnel officers in Nuclear Personnel,.DNE, and DNC to examine organization changes addressed in concerns.
0 A.
There are no regulatory -requirements that set standards for organizational design in the areas referred to ia the concerns in this subcategory.
A requirement of 10 CFR 50, Appendix B, is that:
"The authority and duties of persons and organizations performing activities affecting the safety-related functions of structures,
- systems, and components shall be clearly established and delineated in writing."
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3 PAGE 7'F 20 B.
NUREG/CR-3215, Or anizational Anal sis and Safet for Utilities with Nuclear Power Plants An Or anizational Overview, prepared by Battelle Memorial Institute for the United States Nuclear Regulatory Commission, 1983.
This two-volume report presents the results of initial research on the feasibility of applying organizational factors in nuclear power plant assessment.
While the report does not uncover any empirical analysis linking organizational factors to the safety of nuclear plants, it does offer a comprehensive literature review and does suggest some key relationships.
The report emphasizes the importance of analyzing management philosophy, or what it calls organizational governance, in addition to organizational
- design, The report also warns of several pitfalls to avoid when conducting an organizational analysis:
Perhaps the most important pitfall results from the combination of three interrelated misconceptions.
- First, each manager logically thinks she/he has an understanding of management and organization based on experience.
What has worked for them will work for all managers.
Organizational analysis may be equated to management, and management may be seen as an applied art where 'good'anagement is simple and the same regardless of what or who is being managed.
If any one finding characterizes modern organizational
- analysis, though, it is that a number of factors, including the goals to be sought, the environment of the system as well as its context, form of governance, and organizational
- design, should be considered jointly.
- Second, many managers see an analysis of management and organization in political terms, since much of their day-to-day experience involves organizational politics.
From a purely political standpoixt.,
independent organizational analysis may be seen as a potential threat to management prerogatives.
We think it is important to distinguish management from organizational
- analysis, and again repeat a central theme in this report it does not now appear appropriate for NRC or industry itself to prescribe common organizational remedies for nuclear utilities.
The third misconception is the natural tendency to equate description with evaluation and then anticipate corrective action. If one presumes there is one best way of managing nuclear utilities, then descriptions are often equated with evaluations, It should be clear our review suggests quite the opposite.
(Volume 1, page 56)
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OF 20 C.
NURFG/CR-3737, An Initial Em irical Anal sis of Nuclear Power Plant Or anization and Its Effect on Safet Performance.
Prepared by ~Battelle Memorial Institute for the United States Nuclear Regulatory Commission, 1984.
One of the findings of this empirical analysis was that plants with more departments tended to have better safety performances
- However, the report stresses "that these relationships are weak and suggestive at best" (page 43).
D.
Institute of Nuclear Power Operations (INPO), Performance Ob'ectives and Criteria for Cor orate Evaluations, August 1985.
While INPO takes care not to recommend an organizational structure, it has established a related performance objective:
Section 1.1 A. Performance Objective The corporate organization is established in such a manner that the functions, assignments, and responsibilities of individuals are clearly defined and understood.
E.
From Tennessee Valley Authority (TVA) Code II Administrative Releases:
Organization Bulletins define the basic organization structure of TVA and the functional areas of responsibility of the Board, the General
- Manager, and offices and divisions. It is supplemented by separate Organization Bulletins which describe the internal structure of offices and divisions and the kinds of functions assigned to their principal components.
(page 1)
Offices and divisions
. maintain current Organization Bulletins for their activities, obtaining necessary reviews and approvals of major changes.
(page 2) 4.0 FINDINGS 4.1 Issue 70701 The Role and Inde endence of En ineerin Discussion Since the beginning of its nuclear
- program, TVA has provided essentially all its own engineering, services.
Before 1984, the power operations function and the engineering design function were
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OF 20 in separate offices.
In February
- 1984, the Office of Power and the Office of'Engineering Design and Construction were merged into a new organization called Power and Engineering.
In June 1984, in announcing the new organizational structure for the merged power and engineering
- program, the manager of Power and Engineering also introduced a management philosophy that he called the owner/operator concept:
The owner/operator will have responsibility for performance of the facilities he operates, He will acquire the services necessary to carry out the owner/operator s responsibilities.
He will acquire these services from TVA organizations to the extent that these organizations can provide those services at competitive costs.
Otherwise services will be contracted from the most competitive outside source.
This concept requires that the operator takes full responsibility for regulatory compliance, quality, performance and total cost, Service organizations, by necessity, will align themselves to perform at competitive costs.
An extensive task force study was conducted to identify the changes needed in financial, budget, cost control, and time reporting systems in order to implement the owner/operator concept.
In May
- 1985, the owner/operator philosophy was reinforced through an employee education effort called "Getting Your Signals Straight."
At the same time the use of written service agreements between the Office of Engineering and the nuclear plant sites was introduced.
Engineering was explicitly told that it was a service organization whose job was to provide the service the operators requested at a
reasonable cost.
The ten employee concerns about the role and independence of Engineering were submitted May through July 1985.
The concerns were all worded to express a possibility of future negative effects from the owner/operator philosophy.
Some were worded as questions:
will the Office of Engineering still have the independence?
Others spoke of what "could" happen under the new organizational arrangement, None of the individuals expressing these 10 concerns submitted other concerns at the same time or provided any specific technical problems or details.
In December
Findings included:
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3 PAGE 10 OF 20 INPO Finding 1.1A-l Responsibility and authority for the various Office of Power and Engineering (Nuclear) organizations have not been clearly defined or sufficiently communicated, As a result, there is confusion in the organizations.
Examples of deficient areas included the following:
a.
Office of Engineering design integrity responsibility INPO Finding 1.1A-3 Current decentralization plans may have adverse effects on the Office of Power and Engineering (Nuclear's) stated goal of 'improved corporate oversight, direction, and support.'xamples of functional areas where decentralization presents a potential problem are as follows:
a.
design engineering (configuration management).
INPO Finding 2.5A-7 Communication and teamwork between the Office of Engineering and Nuclear Operations need improvement, especially at nuclear plant sites.
Lack of credible long-term work priorities and schedules, not resolving misunderstandings, and not identifying resource impacts resulting from schedule changes and short-term requests have contributed to mistrust between the two organizations, and in some
- cases, led to duplication. of effort.
In January
- 1986, Steven A. White became Manager of Nuclear Power.
In March 1986, the new Manager of the Office of Nuclear Power (ONP) issued a revised Corporate Nuclear Performance Plan.
This plan identified "uncertainty regarding lines of authority and responsibility" (page 35) as one of the major problems in TVA's nuclear program.
The plan committed to the following changes in Engineering's relationship with the nuclear plant sites; Over a year ago, a major management decision was made to decentralize TVA's nuclear program.
Site directors were created and more authority was given to the various sites with less being assumed by headquarters.
I intend to alter that concept to some degree.
I will continue to hold the Site director responsible for ensuring that the necessary site activities are performed in a timely manner.
However, in all functional areas, such as engineering, quality assurance, licensing, and training, I will hold the headquarter's manager responsible for the technical adequacy of activities within their functional areas.
(page 6)
Under this plan within the engineering organization, a project engineer was appointed for each nuclear plant.
Engineering functions were transferred to the project engineer from the
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3 PAGE 11 OF 20 Construction project manager and the site director.
The design services organizations which had been established by the site directors under the owner/operator concept were dissolved, as all engineering work was consolidated in the corporate
- DNE, An April 8, 1986 memorandum from the Manager of ONP discontinued the use of formal service agreements between
- DNE, Interviews with the MBN Project Engineer, Assistant Project Engineer for unit 1, and Assistant Project Engineer for unit 2 indicate that they have clear authority and responsibility for the technical adequacy of all engineering work.
They see Engineering as an equal to Site Operations, with the independence to exercise best engineering judgments.
Disagreements will naturally arise, and they are confident that the Manager of Engineering will strongly present Engineering's perspective to the Manager of ONP, who will resolve disagreements.
Although the project engineers seem clear on their authority and responsibility, no documentation of the current organization is available.
Organization Bulletins, the official TVA delegation documents, are being drafted, but have not as yet been submitted for approval.
That document contains a description of the new Engineering organizational structure and its relationships within the ONP.
The FSAR's will be revise to reflect this new organizational arrangement by referencing the QA Topical Report in its organization chapter.
A full revision of the engineering program directives is underway.
- However, the regulatory-based procedures are being revised first, and the Engineering Organization Manual has been given lowest priority.
Conclusion Based on the above evidence, the lack of Engineering independence was a problem that existed at the time the concerns were expressed.
The organizational philosophy and structure were tilted in favor of short-term operational decisions despite Engineering
- concerns, Engineering was being, told to give Operations what it requested and was discouraged from elevating disagreements between the organizations to a higher level for decision.
This situation has since been corrected.
Engineering's role has been strengthened and checks and balances are in place in the organization to ensure that disagreements between Engineering judgments and operational considerations are heard and properly resolved.
The employees who expressed concern about potential harm from Engineering's lack of independence did not identify any specific Engineering concerns that were ignored.
However, other employees
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3 PAGE 12 OF 20 have identified approximately 300 technical concerns that are currently being evaluated by the Engineering Category Evaluation Group of the Employee Concerns Task Group.
Those evaluations will ensure that any technical problems caused by the organizational problem are properly identified and corrected, The current Engineering organization has not been clearly documented in an approved Organization Bulletin and communicated to employees.
(See TVA Code II, Administrative Releases and INPO Performance Objective 1,1.A.)
This is a problem requiring corrective action.
4.2 Issue 70702 - Redundanc in Creation of Nuclear Services Branch in Construction Discussion The question of who should perform modifications work at TVA nuclear plants is a subject of long-standing organizational disagreement.
The issue initially arose when Construction and Power Operations were in separate offices and had separate reporting channels to the General Manager.
In 1981, the General Manager issued a memorandum-to resolve the conflict. It stated that Construction "shall perform all major modifications work at licensed nuclear generating facilities."
However, conflict continued over the definition of what was not "major" work and, therefore, could properly be done by maintenance personnel.
In February
- 1984, the Office of Power and the Office of Engineering Design and Construction were merged into a new organization called Power and Engineering.
In June
- 1984, when announcing the new organizational structure for the merged Power and Engineering
- Program, the manager of Power and Engineering also introduced a management philosophy that he called the owner/operator concept.
This concept is described in 4.1.
above.
In September 1984, Construction created the Nuclear Services Branch.
Its responsibility as stated in the Organization Bulletin was:
The Nuclear Services Branch provides support services to ONP, after construction permits expire, including approved additions and improvements to existing, plants and structures.
It establishes and maintains an effective client/service relationship with nuclear plant site directors. It organizes and maintains a project management, engineering, and craft supervision core capability to efficiently respond to and execute approved work programs within schedule and according to other requirements established by ONP.
Site project managers perform work within the nuclear power quality assurance
- program, document
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
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3 PAGE 13 OF 20 control procedures, plant radiological, safety, and security procedures, as well as functional and administrative control of the nuclear plant site directors'ccording to Construction, the logic behind establishment of the Nuclear Services Branch was that there would be modifications and/or manpower peaks that the site organization could not handle with its in-house capability.
Therefore, if the Nuclear Services Branch had a ready core of expertise, it would be able to market its services.
The groups at each site were funded on a trial basis to see if they could provide enough services to pay their own way. If there was no market for their services at a particular site on a recurring basis, staff would not be permanently assigned to the site, At the time the Nuclear Services Branch was created, the site directors had reporting to them an organization called "Modifications." Its responsibility, as stated in the Organization Bulletin, was described as follows:
Modifications implements all plant modifications. It provides onsite personnel and other resources necessary to accomplish the Modifications workload through utilization of its own resources, other TVA organizations, or outside contractors, As noted earlier in January
- 1986, Steven A. White was appointed as Manager of Nuclear Power.
Along with numerous other changes, the Manager of ONP discontinued the use of =service agreements between ONP organizations and generally reversed the trend toward decentralization under the owner/operator philosophy, On June 9, 1986, the Modifications Groups that reported to the site directors were merged with the Nuclear Services Branch in Nuclear Construction.
The merger created three branches in Nuclear Construction the WBN Modifications Branch, the Sequoyah Modifications Branch, and the Browns Ferry Modifications Branch, According to Mr. White, "This will consolidate all the units performing modifications work under one division management to ensure continuity of modifications services among the three plant sites.
This will also give us flexibilityto.use the modifications
-resources where they are needed, when they are needed, such as during outages."
Information on the reorganization was widely distributed to employees through employee meetings and office-wide publications, such as the Nuclear Dis etch and
~U front.
A comprehensive operations plan for reorganizing the modifications unit and Nuclear Services Branch was prepared and widely distributed.
- However, the new Modifications Branches have not as yet been documented in formal Organization Bulletins.
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
70700 REVISION NUMBER:
3 PAGE l4 OF 20 Conclusion A,
Based on the evidence presented
- above, the issue was factual but has since been resolved.
There is currently no redundancy in the organization of the modifications function in ONP.
At the time the issue was raised, there was duplication of functions between the Modifications Group under the site director and the Nuclear Services Branch in Construction.
This duplication was intentionally built into the organizational structure and was consistent with the management philosophy current at that time which stressed efficiency through marketing and competition.
Accounting procedures were in place to determine over a period of time whether or not the organization was paying, for itself through service agreements, That time of reckoning never arrived,
- however, because top managers and management philosophy for the entire ONP changed.
The recent merger of modifications functions is consistent with the current philosophy of centralized control of functional areas and eliminates any question of duplication.
B.
The reorganization of the modifications functions has not been documented in an -approved Organization Bulletin.
(See TVA Code II, Administrative Releases and INPO Performance Objective l.l.A.)
This problem requires corrective action.
4.3 Issue 70703 Too Man Se grate Grou s And Em lo ees Discussion Two of the concerns that raised this issue were expressed by the same person and contend that Engineering is poorly organized at the BLN site.
Specifically, the concerned individual believed that "one single engineering group is needed onsite to do everything, instead of separate engineering groups such as Preop, Maintenance, Engineering Test, Site Services, Design Services, etc."
The concerned individual believed that combining these groups would reduce the total number of engineers.
These concerns were evaluated by the line organization and a report was sent to.the concerned individual on February 5, 1986.
The report found the concerns valid and reported that corrective action had been taken.
BLN consolidated all site engineers i+to a single organization.
This consolidation eliminated redundancy while providing an improved method for coordination of activities, The total number of engineers in this organization is significantly less than the number previously employed.
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
70700 REVISION NUMBER:
3 PAGE 15 OF 20 The other concern in this issue states, "Construction and operation of the facility could be more economically accom'plished with fewer separate groups/managers/employees and less competition between groups,"
This concern is so general and broad that no baseline can be established against which to do an evaluation.
In fact, one empirical study cited in Section 3,1 suggests (but does not prove) that nuclear power plants with more departments have better safety performance, Specific examples of redundancy were given in the BLN engineering concerns and the modifications/construction concerns addressed in Section 4.2.
These specifics have been evaluated and corrective action taken.
Conclusion This issue was factual but corrective action had been taken prior to this evaluation.
4.4. Issue 70704 - WBN Pro'ect Control Discussion The CI contends that MBN Construction is not run by the Manager, but by the Project Control Group.
The Project Control Group reports to Project Management Services which reports to the MBN Project Manager.
This reporting relationship existed at the time the concern was expressed and has not changed.
This concern appears to address the extent of personal influence the Project Control Group had with.the Project Manager, rather.than.the reporting relationship itself.
Conclusion No baseline can be established against which to judge the proper extent of influence a project control group should have on a construction project.
The individual who was Project Manager at the time the concern was expressed has since retired and been replaced.
Therefore, this issue cannot be verified as factual.
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
70700 REVISION NUMBER:
3 PAGE 16 OF 20 4.5 Issue 70705 - Disci line Staffin Discussion The CI contends that morale is adversely affected by "discipline staffing,"
a type of matrix organization initiated in the DNE in 1984.
This is the only concern that addresses discipline staffing.
Under discipline staffing, engineers administratively report to discipline branches:
Mechanical Engineering, Civil Engineering, Nuclear Engineering, etc.
They are then assigned to project managers who are not within the branches and report separately to the Manager of Nuclear Engineering.
The individual engineer is responsible both to his or her discipline branch chief and to the project manager.
This "two-boss" relationship is the distinguishing feature of a matrix organization, According to organization
- experts, matrix organizations take several years to mature.
Different behaviors are required and it takes time for individuals to adjust.
During this time of adjustment the morale of some employees may be affected, even though the organizational design is itself sound.
Conclusion The long term morale effects of discipline staffing cannot be determined until the period of transition is over.
Other aspects of the engineering organization are being evaluated as a separate element within this subcategory.
Consequently, this issue cannot be verified as factual, 4.6 Issue 70706 - Discretionar Safet Reviews Discussion These two concerns from one employee suggest that underfunding of a particular department results in a lack of discretionary safety reviews.
Conclusion Insufficient information is available from the K-forms to determine what organization the employee is referring to.
Both QTC and NRC masked the information to protect confidentiality.
Since no further information is available, further evaluation of the concerns is not possible.
If this situation still exists, the employee is encouraged to repeat the concern to the permanent Employee Concern Program.
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
70700 REVISION NUMBER:
3 PAGE 17 OF 20 4.7 Issue 70707 - Mana er of ONP Not Inde endent Discussion "CI feels that the new nuclear manager is a front as he will not be allowed to remain independent."
Although no baseline can be established on how "independent" a top executive should be from the Board of Directors that hired him, public statements were made by both the Board and Mr. White when he was hired concerning his independence.
A review of documents and statements made by Mr. White after six months as TVA's Manager of Nuclear Power result in the following findings:
A.
The legally binding Memorandum of Understanding between Steven A. White and the Board of Directors of the Tennessee Valley Authority states in part:
The Manager of Nuclear Power will have direct authority and responsibility for the management, control and supervision of TVA's entire nuclear power program, including but not limited to, the design, construction, maintenance and operation of all existing or planned TVA nuclear power plants.
The Manager of Nuclear Power shall have the authority to establish management and operating policies and procedures related to TVA's nuclear power program.
The Manager of Nuclear Power shall also have the authority to hire,
- remove, assign,
- reassign, or direct any personnel supplied by outside contractors, and subject to the approval of the Board of Directors with respect to senior level TVA managers in accordance with existing reservation of authorities by the TVA Board, any TVA personnel engaged in nuclear power program activities as he may deem necessary or desirable to implement such policies or procedures.
B.
On June 12, 1986, Mr. White gave the following testimony before a committee of the United States Congress:
Mr. Shelby:
The Board has not tried to intimidate you
- yet, have they?
Mr. White:
No sir, they have not.
Mr. Shelby:
And if they did, would you leave?
Mr. White:
In a second.
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
70700 REVISION NUMBER:
3 PAGE 18 OF 20 Hr. Shelby:
Do you need more latitude from the Board?
Hr. White:
No I do not, Mr. Shelby.
I have the authority and the responsibility that goes with it and that was one of the several conditions that I made sure of before I took the job.
C. It is difficult to establish baseline criteria to judge the amount of independence the Manager of Nuclear Power needs or actually has.
- However, the Memorandum of Understanding appears to give Hr. White a wide scope for independent action.
Conclusion Based upon the evidence presented
- above, this issue could not be verified as factual.
4.8 Issue 70708 - BLN Pro'ect Hang ement Discussion "No real project management for BLN.
There is no single person onsite who is in charge of all site organizations."
This concern was evaluated by the line organization and a report was sent to the concerned individual on February 5, 1986.
The response states that the ONP management also recognized this problem and corrected the situation by appointing James P. Darling as Site Director for BLN.
Hr. Darling is now responsible for all activities associated with the design, construction, and operation of the Bellefonte facility.
Hr. Darling's appointment to this position was effective October 7, 1985.
Conclusion The concern identified a problem that existed when the concern was filed.
Corrective action has been taken.
4.9 Issue 70709 - Mana ement Control of Personnel Matters Discussion "Management lacks control over personnel matters; merit raises, personnel policies, etc.,
are not under direct control of line management."
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
70700 REVISION NUMBER:
3 PAGE 19 OF 20 This concern was evaluated by the line organization and a report was sent to the concerned individual on February 5, 1986.
This response acknowledges that in many cases line management has very little flexibility in personnel matters.
Line managers as well as personnel managers are controlled by TVA regulations and the General Agreement and Articles of A reement negotiated with recognized labor organizations.
In many cases these regulations are designed to ensure fairness for individual employees and consistency across organizations.
Numerous employees have expressed concerns about favoritism in personnel matters which indicates a need for some controls on a line manager's flexibility in personnel matters.
Those concerns are being evaluated in other Management and Personnel subcategories.
Conclusion No baseline requirements can be identified for determining the correct balance between control and flexibility in personnel matters.
Therefore, this concern is factually accurate, but it does not identify a problem requiring corrective action.
5.0 COLLECTIVE SIGNIFICANCE TVA's nuclear power program has undergone numerous major organization changes during the last several years.
This organizational instability has caused many employees confusion which was made worse by the lack of clear statements of the responsibilities of the new organizations.
The major decentralization move in 1985,.in particular, created most of.the concerns evaluated in this subcategory.
The most recent organization changes have reversed the move toward decentralization and corrected the specific concerns.
The general concerns about organization can only be put to rest by effective implementation of the Nuclear Performance Plan.
The intent of that plan is to create a stable, clearly documented, and easi'ly understood ONP organizational structure, 6.0 CAUSES The confusion about organization resulted.from the failure to have approved Organization Bulletins for DNC and DNE.
The cause of this failure to document organization changes as they occur is that, while generally accepted as useful, such documents receive a lower priority than the revision of technical procedures.
In addition, organization descriptions for use within TVA are given lower priority than updating the descriptions in documents, such as Technical Specifications, that are reviewed by NRC.
The negative result of this delay is that employees are left insecure and confused about organization changes and the reasons for them. It is the responsibility of the Manager of ONP to have Organization Bulletins prepared for each of the divisions within the ONP.
pg C
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
70700 REVISION NUMBER:
3 PAGE 20 OF 20 7.0 CORRECTIVE ACTION AS A RESULT OF THIS EVALUATION The Nuclear Procedures Staff and the Nuclear Personnel Staff are jointly implementing an action plan which will develop approved organization charters.
Once the charter statements are approved, they will be converted to Organization Bulletins and forwarded to Knoxville.
In addition, the finalized organization will be highlighted in ONP's
~U Front newsletter with pictorial organization charts and brief organization synopses
{CATD No, 707-NPS-Ol).
8eo ATTACHMENTS Attachment A, Subcategory Summary Table Attachment B, List of Concerns by Issue
V l
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".EREtlCE ECPS132J-ECPS132C
=QUEtlCY REQUEST ISSS RWM
"=GORY:
MP MGT. 8 PERS.
ISSUES AT ENT A TEHtlESSEE EY AUTHORITY OFFICE OF NUCLEAR POllER EMPLOYEE COtlCERN PROGRAM SYSTEM (ECPS)
EMPLOYCE COtlCERtl IWFORt1ATIOtl BY CATEGORY/SUBCATEGORY SUBCATEGORY: 707 BLN PROJECT MAHAGEMEtlT PAG 1
RUtl TIME - 10:04:39 RUtl DATE - 03/10/87
)tlCERtl WUt1BER CAT S
H SUB R PLT CAT D LOC 1
REPORT APPL 2 SAF RELATED BF BL SQ WB HISTORICAL CONCERN REPORT ORIGIN COHCERtl DESCRIPTIOH REF.
SECTIOtl CAT 11P SUBCAT 707 lOHPLC002 01 MP 70708 tl BLtl 1 tl tl tl ll 2 llA tlA HA NA OECP HO REAL PROJECT MAtlAGE11EtlT FOR BLtl.
THERE IS HO Otl"SITE SIllGLE PERSOtl tt HO IS TOTALLY It( CHARGE OF ALL SITE ORGANIZATIONS.
"lOttPEC006 Ol MP 70709 tl BLN 1 tl tl tl tl 2
WA tlA ttA HA
>tOHPEC009 Ol MP 70703 tl BLtl 1
N tl N
tl 2
WA HA tlA HA OECP OECP LACK OF CONTROL OVER PERSONNEL MATTE RS - MERIT RAISESp PERSONtlEL POLICIE Sp ETC.
ARE tlOT UtlDER DIRECT COtlTROL OF LltlE MAtlAGEMEWT.
POOR ORGAtlIZATIOH OF EtlGItlEERItlG RES OURCES OHE SItlGLE EHGIWEERIHG GROU P IS tlEEDED Otl SITE TO DO EVERYTHING
'lOWPEC010 Ol 1'1P 70703 W BLH 1
N H
H H
2 HA HA WA tlA )19-00301 thP 70702 S
1'lBtl 1
H H
H H
T50 195 2
WA tlA tlA HA 02 t1P 71813 S
WBtl 1 tl tl tl W
2 tlA tlA HA HA 030-00101 t1P 70701 tl WBtl 1
H tl H
H T50006 2 tlA tlA tlA tlA OECP QTC QTC TOO MAtlY EtlGItlEERS - C011BIHIHG GROUP S
tlOTED It( BLHOtlPEC009 WOULD REDUCE TOTAL NUMBERS.
NUCLEAR SERVICES BRANCH SERVES tlO PU RPOSE WHICH COULD tlOT BE PERFORMED B
Y CONSTRUCTION CRAFT OR MODIFICATION S
BRAtlCH.
FAVORITISMp tlEPOTISM IS B
EItlG PRACTICED IH THE HIRItlG PRACTIC ES OF WSB.
CI HAS HO FURTHER ItlFORM ATIOW.
COHSTRUCTIOtl DEPT.
CONCERN.
THE UtlIFICATIOW OF EtlGItlEERItlG AWD S ITE OPERATIONS COULD LEAD TO A CotlDI TIOH WHERE ECONOMIC DECISIOIIS COULD PREVAIL OVER ENGItlEERItlG REQUIREtlEtlT S.
-85"071"00101 T50078 MP 70701 tl WBtl 1
tl tl H
N Itl-85-071-001 2 tlA tlA HA WA QTC CI IS COtlCERHED WITH HAHAGEMEttT POLI CY OF THE SITE DIRECTOR BEItlG RESPOtl SIBLE FOR BOTH THE OPERATIOtl AtlD EtlG IHEERItlG Otl SITE.
OE PERSOtlHEL ARE BEItlG TOLD THAT NUCLEAR POWER IS THE CLIEtlT AtlD COtlTROLS THE
'PURSE STRI NGS'WD OE IS TO PLEASE THEMp IF OE DOEStl'Tp THEY (IlUCLEAR POWER)
HAVE THE OPTIOtl TO CONTRACT OUT THE WORK TO OUTSIDE EtlGIWEERItlG FIRMS.
COtlCERtlS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY tlUtlBER.
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FEREtlCE ECPS132S-ECPS132C "QUEllCY
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8 PERS.
ISSUES TEtlNESSEE EY AUTHORITY OFFICE OF NUCLEAR POllER EHPLOYEE COtlCERN PROGRAH SYSTEH (ECPS)
EtlPLOYEE COtlCERN ItlFORtlATIOtl BY CATEGORY/SUBCATEGORY SUBCATEGORY: 707 ROLE AtlD ItlDEPEtlDENCE OF EtlGItlEERIWG PAG
2 RUtl TINE 10: 06: 39 RUtl DATE 03/10/87 3ttCERtt NUHBER SUB CAT CAT S
H R PLT D LOC 1
REPORT APPL 2 SAF RELATED BF BL SQ ttB HISTORICAL REPORT CONCERN ORIGIN CONCERN DESCRIPTIOW REF.
SECTION CAT HP SUBCAT 707 072-00101 T50082 HP 70701 W HBN 1 tl tl tl tl 2
NA tlA tlA tlA IW"85"072"001 QTC tlUCLEAR POHER OFFICE Itl CHATTAtlOOGA DOES tlOT HAVE TO HAVE THE OFFICE OF ENGINEERIWG DO ITS DESIGtl HORKp HHIC H tlEAtlS THAT IF Atl OUTSIDE A/E FIRth DOES BAD l<ORK> THEtl IT HOULD RUItl OE
'S REPUTATIOtl.
C/I HAD tlO FURTHER I tlFORHATIOtl.
"85-074-00101 MP 70701 T50066 tl HBtl 1 tl W
tl N
2 NA NA NA tlA Itl-85-07 ci-0 01 QTC HILL THE OFFICE OF EtlGItlEERItlG (OE)
PERSOWtlEL ASSIGtlED TO AtlD llORKIWG AT IlATTS BAR BE INDEPENDENT FROW DIVIS IOW OF POHER PRODUCTIONS (DPP)
SCHED ULES AWD OVERALL IWFLUEtlCE?
CI IS C
OtlCERtlED THAT DPP llILL PRESSURE SITE OE PERSOtltlEL ItlTO HAKIttG UtlSOUtlD Etl GItlEERItlG DECISIOtlS DUE TO DPP'S SCH EDULE CONSTRAINTS.
CI COULD tlOT PRO VIDE AtlY SPECIFICS/DETAILS. 076-00101 T50066 thP 70701 N l'1Btl 1 tl W
tl W
2 tlA WA tlA tlA Itl"85-076-001 QTC WITH THE WEH OlltlER-OPERATOR COllCEPT AtlD OFFICE OF EtlGItlEERItlG (OE)
PERSO WtlEL LOCATED AT THE SITE> llILL THE 0 FFICE OF EWGItlfERIWG STILL HAVE THE TECHNICAL EXPERTISE AND ItlDEPEtlDEtlCE TO ACCOHPLISH THEIR REQUIRED IIORK L OAD It( A TItlELY tlAtltlER?
CI FEELS TH AT OE PERSOtltlEL SHOULD tlOT BE UNDER AWD REPORT TO NUCLEAR PojtER PRODUCTI OW AT HATTS BAR OR OTHER TVA SITES.
NO SPECIFIC PROBLEHS/DETAILS HERE P
ROVIDED BY THE CI.
COtlCERtlS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY tlUHBER.
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'=EREHCE ECPS132J-ECPS132C
':-QUEtlCY
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- ISSS Rlltt EGORY: llP ttGT.
8 PERS.
ISSUES TEtltlESSEE EY AUTHORITY OFFICE OF NUCLEAR POllER EttPLOYEE COtlCERN PROGRAM SYSTEM (ECPS)
EMPLOYEE COHCERtl IttFORHATIOtt BY CATEGORY/SUBCATEGORY SUBCATEGORY) 707 ROLE AtlD ItlDEPEWDEtlCE OF EWGItlEERItlG r
PAG 3
RUtl TItlE 10: 06: 39 RUW DATE " 03/10/87 "JWCERH tlUHBER CAT S
H SUB R PLT CAT D
LOC 1
REPORT APPL 2 SAF RELATED BF BL SQ llB HISTORICAL COtlCERN REPORT ORIGIN CONCERN DESCRIPTIOH REF.
SECTIOtl (
CAT t1P SUBCAT - 707 077-00101 T50078 097-01601 T50223 ttp 70701 W HBtt t1P 70702 tl HBH 1
tl tl tl H
2 tlA tlA tlA HA 1
H tl tl tl 2 tlA HA tlA HA IH-85-077-001 Itl-85-097-016 QTC QTC UNDER THE HEll ORGAtlIZATIOtlp OFFICE 0
F EtlGItlEERItlG IS BEING TREATED AS A
CLIEtlT OF tlUCLEAR POllER.
TVA UPPER tlAWAGENEtlT HAS SAID THAT tlUCLEAR POll ER HAS THE "PURSE STRItlGS" AWD ttHAT tlUCLEAR POllER HAtlTS IS llHAT OE llILL DO.
IF Atl OE STUDY FINDS A PROBLEthp THEW VERY POSSIBLY THE FUtlDS TO OE 1<ILL BE CUT OFF.
THIS llAY CAUSE LOS S Of CHECK AHD BALANCES BETllEEW WUCL EAR POHER AtlD OE DEPARTtlEWT.
C/I CO ULD HOT PROVIDE AtlY SPECIFIC PROBLEH S
OR EXANPLES.
TVA'S EXECUTIVE"LEVEL HAttAGERS EtlGAG E IN INTER-DIVISIONAL POHER STRUGGLE S
RATHER THAt) HORK FOR THE BEST OUTC OME FOR TVA.
EXANPLE: DEPARTtlEtlT (K HOIIW) HAS CREATED TO ttAIWTAIH UNIT 1
UtlTIL IT HEtlT OPERATIOtlALp BUT tlOt'l THE DEPARTNEHT DOES CONSTRUCTION NOR K AHD IS REDUNDANT TO THE COHSTRUCTI OW DEPARTHEtlT.
THE DEPARTtlEWT IS NO T HEEDEDp BUT IS tlOT DISBAtlDED BECAU SE DOItlG SO HOULD REDUCE Atl EXECUTIV E-LEVEL HAttAGER'S (KllOHW) POllER BASE CI HAS tl0 NORE IttFORNATIOtl.
CONS TRUCTIOW DEPARTHEWT CONCERN.
"85-101" 00101 thP 70701 H I<BH 1 tl H
tl tl T5000it 2 tlA NA HA HA 105-00101 NP 70701 H ttBN 1
H W
H W
T5000cj 2
HA HA tlA NA QTC QTC MOVIHG OE TO NUCLEAR PLANT SITES COU LD RESULT Itl SOHE LOSS OF IWDEPEtlDEtl CE AWD SINCE OE HORKS DIRECTLY UNDER THE ORGAtlIZATIOtl OPERATItlG THE PLAtl Tp PRESSURE COULD BE BROUGHT TO BEAR TO OVERLOOK SAFETY PROBLEHS.
OE SH OULD REt1AIW IWDEPEtlDEtlT FROH tlUCLEAR POHER tlUCLEAR OPERATIOtlS tlAY BE ABLE TO EA SILY CONPROttISE DESIGN ENGINEERS NHO ARE LOCATED OW-SITE AT l'lBHP FOR SAK E
OF THEIR EXPEDIEtlCIES OF OPERATION S
CONCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY ttUI<BER.
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FEREtlCE ECPS132J-ECPS132C EQUEllCY REQUEST ISSS - Rlltt EGORY:
MP tiGT.
8 PERS.
ISSUES TEtltlESSEE EY AUTHORITY OFFICE OF NUCLEAR POHER EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
EMPLOYEE CONCERN IHFORMATIOtt BY CATEGORY/SUBCATEGORY SUBCATEGORY) 707 l<BW PROJECT CONTROL PAG Cj RUtl TItlE - 10:06:39 RUtl DATE 03/10'/87 OtlCERH HUtlBER CAT S
tt SUB R PLT CAT D LOC 1
REPORT APPL 2 SAF RELATED BF BL SQ llB HISTORICAL COHCERN REPORT ORIGIN COHCERtl DESCRIPTIOH REF.
SECTION f.
CAT MP SUBCAT 707 293-02<101 T50267 MP 70706 N llBtl 1 tl tl tl tl 2 tlA HA tlA tlA QTC THE llATTS BAR NUCLEAR PLAtlT IS HOT R
Utl BY THE ttAttAGER BUT BY THE PROJECT COtlTROL GROUP.
tlAMES/DETAILS Ktl0llH TO QTCp HITHHELD TO ttAIHTAItl COtlFID EtlTIALITY.
tl0 FURTHER IttFORtlATIOtt M AY BE RELEASED.
COtlSTRUCTIOtl DEPART MEttT COtlCERtl.
CI HAS tl0 FURTHER DET AILS. 799"00201 MP 70702 W
HBW 1
W H
H W
T50071 2 tlA tlA tlA tlA QTC THE CREATION OF ORGAHIZATIOttS HITHIH TVA (llBtlP) TO EITHER PROTECT OR EST ABLISH HEM POSITIONS IS QUESTIOtlABLE EXAMPLE:
OUTAGE GROUP TO FIELD S ERVICE TO MODIFICATIOW TO HSB.
WO A
DDITIONAL INFORMATION AVAILABLE. 992"00301 T50101 009-00201 T50108 02 MP 70702 H llBH 1
N tl H
H IN-85-992-003 2 tlA tlA tlA tlA MP 70601 S
HBW 1 tl tl tl tl Itl-86-009-002 2
WA tlA tlA WA MP 70703 S llBH 1 tl tl H
tl 2
Hn WA ttA ClA QTC QTC DEPARTMENT (Ktt01<H) llAS FORMED TO FIL L
A FUtlCTIOHAL AREA IH ltHICH TVA HAD ALREADY ESTABLISHED ADEQUATE COVERA GE.
CI EXPRESSED THAT THIS DEPARTflE HT llAS ACTUALLY FORttED TO EXTEND THE EtlPLOYHEttT OF SOME COWSTRUCTIOtl PER SOtltlEL AtlD MAHAGEthEttT INDIVIDUALS (H AMES tlOT KtlOllH).
CI STATED THAT THI S TYPE OF IHCIDEtlT IS SELF DEFEATING TO TVA'S POLICY OF STREAMLItlIWG".
DETAILS KHOlltl TO QTC.
CI HAS tl0 FUR THER IHFORMATIOtl.
HO FOLLOH UP REQU IRED.
CotlSTRUCTIOH AHD OPERATION OF THE FA CILITY COULD BE MORE ECOHOttICALLY AC COMPLISHED i<1TH FEllER SEPARATE GROUP S/tlAWAGERS/EMPLOYEES p AtlD LESS "COt1P ETIIOtl" BETllEEtl GROUPS.
CI HAS tlO F
URTHER IHFORMATIOH WO FOLLON UP REQU IRED COtlCERWS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY NUMBER.
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FEREtlCE ECPS132J-ECPS132C FQUEWCY REQUEST ISSS Rwtt EGORY-.
t1P tlGT.
8 PERS.
ISSUES TEWtlESSEE EY AUTHORITY OFFICE OF tlUCLEAR POllER EMPLOYEE COWCERtl PROGRAM SYSTEfl (ECPS)
EtlPLOYEE CONCERN IttFORttATIOtt BY CATEGORY/SUBCATEGORY SUBCATEGORY< 707 ROLE AtlD IWDEPEWDEtlCE OF EtlGIWEERItlG PAG RUtl TItlE 10: 06: 3g RUtl DATE 03/1P/87 JtlCERtl NUt1BER CAT S
lt SUB R PLT CAT D
LOC 1
REPORT APPL 2 SAF RELATED BF BL SQ llB ltISTORICAL COtlCERH REPORT ORIGIN CONCERN DESCRIPTIOtl REF.
SECTION CAT HP SUBCAT 707. 030-00101 T50091
'HP 70701 H HBH 1 tl W
tl tl 2
WA WA HA tlA QTC SItlCE THE TVA REORGAHIZATIOW A YEAR AGOp OE HAS tlOT HAD THE ORGAtlIZATIOtl AL FREEDOM AtlD IWDEPEtlDEtlCE TO EXPRE SS COttCERt<S OR TO IDEtlTIFY AllD RESOL VE EtlGINEERIWG PROBLEtlS AT TVA tlUCLE AR PLANTS
( INCLUDING HATTS BAR).
OE IS HOH FUWCTIOWIWG AS A CONTRACTOR TO THE tlUCLEAR PLAtlTS AtlD OtlLY RESPO HDS TO DIRECTIONS PROVIDED BY THE PL AtlTS.
OE IS tl0 LOtlGER ALLOllED TO IW DEPENDENTLY IDEtlTIFY AtlD RESOLVE EtlG IllEERIWG PROBLEHS AS THEY COULD PREV IOUSLY.
FEllER PROBLEtlS 1<ILL BE IDEtl TIFIED AWD RESOLVED.
AtlOtlYHOUS-
'1-86" 006-00201 HP 70705 W HBH 1
W N
tl tl T50266 2
HA tlA tlA tlA
~"86-020-00101 llP 70706 H llBW 1 tl H
tl H
T5026 707 DISCRETIONARY SAFETY REVIEHS r
~
6 RUtl TIt1E - 10: 06: 39 RUtl DATE 03/II%87
)ttCERtt tlUtlBER CAT S
H SUB R PLT CAT D
LOC 1
REPORT APPL 2 SAF RELATED BF BL SQ tlB HISTORICAL CONCERN REPORT ORIGItl CONCERN DESCRIPTIOW REF.
SECTION a
CAT
- tlP SUBCAT 707 P-86-020-00301 T5026<i HP 70706
'tl llBtl 1 tl W
W tl 2 ttA WA NA tlA QTC DEPARTHEWT (KWOHW) IS WOT CONDUCTING DISCRETIONARY SAFETY REVIEWS AS PER THEIR CHARTER DUE TO A LACK OF BUDG ET.
A SAFETY REVIEH SECTION HAS CRE ATEDp HOtlEVERp tl0 BUDGET llAS ALLOCAT ED FOR A STAFF.
SO EVEtl WITH At( ATT EtlPT AT CORRECTIVE ACTIOWp Atl EFFECT IVE ItlDEPEtlDEtlT SAFETY REVIEll PROGRA H HAS WOT BEEtl ESTABLISHED AtlD IttPLE HEtlTED.
DETAILS KtlOllW TO QTCp l<ITHH ELD DUE TO CONFIDENTIALITY.
WO FURT HER ItlFORHATIOW HAY BE RELEASED.
'-86 "022-01901 t P 70707 tl llBtl 1 tl W
tl tl T50269 2 tlA tlA tlA WA QTC CI FEELS THAT THE tlEll tlUCLEAR HAtlAGE R IS A "FROtlT" AS HE HILL WOT BE ALL OllED TO REtlAItl ItlDEPEtlDEtlT.
COtlSTRU CTIOtl DEPARTHEWT COWCERtl.
CI HAS WO FURTHER ItlFORHATIOtl. 067-00101 T50070 ttp 70701 N
BFW 1
W tt W
W XX-85-067-001 2 tlA NA NA WA QTC GEtlERAL COtlCERtl HHETHER OPERATIOtl Etl GIWEER OR tlUCLEAR POHER SHOULD HAVE RESPONSIBILITY FOR DESIGN INTEGRITY OF BROlltl'S FERRY THROUGH THE LIFE OF THE PLAtlT. Cp'I QUESTIONS tlUCLEAR PO llER'S ABILITY AtlD COHPETEtlCE TO DETE RHIttE HHAT DESIGN ISSUES ARE CRITICA L TO PLANT SAFETY.
Zit COtlCERNS FOR CATEGORY tlP SUBCATEGORY 707 CONCERNS ARE GROUPED BY P'IRST 3 DIGITS OF SUBCATEGORY ttUHBER.
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ATTACHHENT B ORGANIZATION List of Concerns by Element/Issue The Organization Subcategory (70700) is comprised of 24 concerns which were evaluated as nine issues, 70701 Role and Xndependence of Engineering IN-85-030-001 IN-85-071-001 IN-85-072-001 IN-85-074-001 IN-85-076-001 IN-85-077-001 XN-85-101-001 XN-85-105-001 PH-85-030-001 XX-85-047-001 70702 - Redundancy in Creation of Nuclear Services Branch EX-85-119-003 XN-85-097-016 IN-85-799-002 XN-85-992-003 70703 Too many Separate Groups and Employees BLN-ONP-EC009 BLN-ONP-EC010 IN-86-009-002 70704 WBN Project Control ZN-85-293-024 70705 Discipline Staffing WBM-86-006-002 70706 Discretionary Safety Reviews WBP-86-020-001 WBP-86-020-003 Page 1 of 2
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ATTACHMENT B (continued) 70707 Manager of ONP Not Independent WBP-86-022-019 70708 - BLN Project Management BLN-ONP-EC002 70709 Management Control of Personnel Matters BLN-ONP-EC004 Page 2 of 2