ML18033B460

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Safety Evaluation Accepting Util Assessment of Mgt Problems at Plant & Corrective Actions Described in Nuclear Performance Plan,Vol 3,Rev 2
ML18033B460
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 07/31/1990
From:
Office of Nuclear Reactor Regulation
To:
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ML18033B459 List:
References
NUDOCS 9008080017
Download: ML18033B460 (56)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 ENCLOSURE 2 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION TVA'S COMMITMENTS IN BROWNS FERRY NUCLEAR PERFORMANCE PLAN BROWNS FERRY NUCLEAR PLANT UNITS 1

2 AND 3 DOCKET NOS. 50-259 50-260 AND 50-296 1.0 INTRODUCTIOH This safety evaluation documents the NRC staff's review of the management structure and processes at Browns Ferry.

The review was performed during July and August of 1989 and reflects the management structure in place at that time.

Management changes anticipated by TVA at the time of the review were considered in the evaluation with regard to the significance of potential impact on the organization.

In its Browns Ferry Nuclear Performance Plan (BFNPP)

(Volume 3, Revision 2, of TVA's Nuclear Performance Plan),

TVA made commitments to improve the organization and management structure at Browns Ferry.

As part of its review, the staff evaluated the lines of authority and the internal flow of information between Browns Ferry operations personnel and Browns Ferry manage-ment as well, as the functional effectiveness of the current organization.

The staff also assessed the Browns Ferry management of each organization addressed in the BFNPP by evaluating in-place procedures and management's activities associated with the planning, scheduling,

issuance, execution, tracking, close-out, inspection, and documentation of work.

Improvement of the Browns Ferry plant management is critical to TVA's prepara-tions for restart.

The purpose of this evaluation is to determine whether the planned improvements as described in the BFNPP have been implemented.

2.0 MIANAGEMENT CONTROL AND INVOLVEMENT The TVA Nuclear Power Department is under the management of the Senior Vice President, Nuclear Power (NP).

The Senior Vice President (NP) is a member of TVA corporate management, which has its headquarters in Chattanooga, Tennessee.

TVA has four viable nuclear plant sites at this time:

(I) Sequoyah - two oper-ational pressurized water reactor (PWR) units; (2) Browns Ferry - three shut-down boiling water reactor (BWR) units (Unit 2 is being readied for restart in the fall of 1990, and Units I and 3 are in a laid-up condition); (3) Watts Bar

- two PWR units under construction; and (4) Bellefonte - two PWR units in a deferred status.

2.1 Factors Contributin to the Problems With Mana ement Involvement In the

BFNPP, TVA stated that, in the past, controlling work practices had not been adequate.

It identified the following factors among others as contributing to the inadequacy:

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Absence of an effective organizational structure with clear lines of responsibility, authority, and accountability (2)

Insufficient followup to verify proper implementation of goals and objectives (3)

Failure to adequately

scope, plan for, and apply resources to emerging problems To address these factors, TVA took actions including the following:

(1) It restructured the Office of Nuclear Power and the Browns Ferry site organization to more clearly define organization, responsibility, authority, and accountability.

(2) It developed position descriptions for the management at Browns Ferry to ensure that the managers know and understand the activities for which they are responsible and for which they will be held accountable.

(3) It initiated a management development program within the Office of Nuclear Power to provide the technical and management training necessary for TVA managers to perform their duties.

This program will also provide for the development of TVA managers for higher level positions.

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BFNPP, TVA revised the Browns Ferry organizational structure so that the Browns Ferry Site Director reports to the Vice President, Nuclear Power Produc-tion.

The site organization reporting to the Site Director also was restruc-tured to correct problems and weaknesses in the previous organization.

TVA corrected these problems as follows:

llhere Browns Ferry managers and the organizations reporting to them lacked clear assignments, TVA developed lines of responsibility to clarify the area(s) of responsibility and to establish accountability.

llhere necessary, TVA established training programs and job performance evaluations to improve line managers'nd supervisors'nderstanding of operations and systems.

2.3 Cor orate Su ort In the BFNPP, Section 1.1, TVA stated that it had reorganized Browns Ferry nuclear site support organizations along functional lines that generally par-allel the functional departments in TVA's Office of NP.

TVA subsequently revised the Browns Ferry organizational structure so that all personnel on site report to the Site Director, except those assigned to the guality Assurance, Site Licensing, Security, Human Resources, Medical Services, Employee Concerns, Information System Services, and Site Training organization.

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The corporate support effort provided policy that was implemented at the site level in terms of, for example, an organization chart with each position formally approved at the corporate or site level, as appropriate.

Each position in the site organization is defined as to qualifications, responsibility, and accountability by the site Department of Human Resources in approved position descriptions that are matched to the organizational structure.

Following corporate'policy, the site maintains current systems and procedures for managing the work force and the site workload.

In addition, the corporate support effort provided for extensive continuing technical and management training programs to facilitate operation of the Browns Ferry site under the new organizational structure.

3.0 SITE DIRECTOR AND ORGANIZATION The Browns Ferry Site Director approves and controls all activities conducted on site.

He has the authority and responsibility for staffing the site organization and ensuring that the facility is safely, reliably, and efficiently operated and maintained and is modified in accordance with the policies and guidelines established by the Senior Vice President, NP.

The Site Director directs the activities of the site to ensure the plant is in compliance with licensing requirements, TVA policies and directives, quality assurance requirements, and applicable local and State requirements.

The Site Director develops and implements site programs to ensure the performance and documentation of site activities in accordance with established quality program requirements and policies.

Both the revised corporate Nuclear Performance Plan (Volume 1) and the BFNPP (Volume 3) describe the responsibilities assigned to NP organizations and staffs both on and off site.

Nuclear Power organizations such as Nuclear Quality Assurance (NQA), Nuclear Engineering (NE), Nuclear Services (NS),

Nuclear Licensing and Regulatory Affairs (NLRA), and Nuclear Construction (NC) have the responsibility for developing programs and standards, providing technical direction, and providing technical support for activities within their respective functional areas, including activities at TVA s nuclear plants.

The organization of the Site Director is divided into six functional organiza-tions under individual managers, each with position descriptions approved by

.the Site Director.

The Site Director's management control system is in effect the aggregate of the management controls of the organization under his authority..-The periodic reports - daily to monthly - of each manager are transmitted to the Site Director.

This includes, for example, the Plant t~anager's weekly performance report.

The Site Director also attends the Plant Manager's daily status meetings.

Each of the following sections treats a subordinate organization reporting to the Site Director.

Conclusions reached by the staff are provided at the end of each section.

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The Plant Manager is responsible for conducting the day-to-day plant operations safely, reliably, and efficiently and in compliance with licensing, regulatory, and TYA requirements.

The Plant Manager's organization provides upper-management attention and support to each unit.

At Browns Ferry, the plant staff had been organized according to a unitized concept to support operation of its three units and associated common systems and equipment.

Management's near-term plan is to bring Unit 2 and its common systems and equipment on line first and to maintain Units 1 and 3 and those portions of systems common to Units I and 3 in a laid-up status.

The unitized maintenance and operational concept has been discontinued in favor of direct management responsibility for and control of the plant as a whole.

Host activities are directed toward operation and maintenance of Unit 2 and its associated common systems plus those portions of Units 1 and 3 necessary to support Unit 2 operation.

The Plant Manager's staff is divided into seven organizations, each under a

superintendent or manager and each with position descriptions approved by the Site Director and Plant Manager.

These organizations are Maintenance, Technical Support, Operations, Plant Support, stork Control/Outage, Radiological

Control, and Chemistry and Environmental.

Each of the aforementioned organizations reporting to the Plant Manager is dis-cussed in the following sections in terms of general description, organization, and procedures.

The aggregate of these constitutes the organization managed by the Plant Manager.

The Plant Manager uses summary status reports from each of his managers to track and manage the work of the plant.

3.1. l Maintenance The approved Maintenance organization is responsible for maintenance and for the planning arid coordination of scheduled maintenance work.

This organization is divided into the Niechanical, Electrical, and Instrumentation

groups, each of which is responsible for that discipline.

The work is managed on a shift basis.

Supervisory responsibility is provided for the functional divisions as described in the organization structure.

'Provisions for planning, scheduling, and coordinating work have been established.

The position descriptions define the responsibilities and experience levels required.

Authority is implicit in the organization chart reporting levels.

The qualifications for the Maintenance Superintendent specified in the position description adhere to American National Standards Institute (ANSI) Standard 18.1-1971.

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The Maintenance organization reports to the Maintenance Superintendent.

The superintendent generates schedules,

reports, trend charts, graphic analyses, and status compilations to carry out his duties and responsibi lities.

The workload of the Maintenance Superintendent's organization is generated through, maintenance requests according to Site Director Standard Practice (SDSP) 7.6, "Maintenance Request and Tracking."

This standard practice applies to preventive, predictive, and corrective maintenance; surveillance activities; and all activities associated with placing systems out of service and returning them to service after maintenance has been performed.

It does not cover modi-fications that are approved through engineering change notices (ECNs).

The current issue of SDSP 7.6 is Revision 5, which was approved on July 6, 1989.

This standard practice establishes the procedures and responsibility for iden-tifying, requesting, and authorizing maintenance requests; provides for system-atic tracking and followup; and provides management a computerized program for scheduling and controlling maintenance work.

The scope of SDSP 7.6 allows the Maintenance organization to plan, schedule, and perform requested work asso-ciated with ECNs and those maintenance requests directed to the Maintenance organization.

SDSP 7.6 in conjunction with applicable interface documents pro-vides the description of maintenance as it is performed at Browns Ferry.

3.1.1e2 Procedures Approved procedures are used at Browns Ferry to perform maintenance.

The typical maintenance activity includes the following:

Receivin Workload:

The maintenance request (HR), TVA Form 6436, is used to

~era uate, aut orize, and document maintenance.

Work Breakdowra and Plannin:

Maintenance planners

evaluate, coordinate, and carry out t e p arming or maintenance according to the HR.

Hodifications (formerly called Nuclear Construction) planners prepare HRs associated with ECNs pertaining to modifications.

Releasin Work:

The Work Control group (under the Work Control/Outage Super-inten ent is responsible for scheduling maintenance work appearing on the site daily schedule and the site 4-day look-ahead schedule.

Trackin of Workload:

A computerized listing of HRs and HR status serves as a

trac ing mec anism or MRs and as a maintenance history record and is used by the Maintenance Superintendent.

Work Closeout Ins ection and Documentation:

The HR form has provisions for t e n

owing:

veri ication y t e oreman or organization representative that the maintenance work has been completed, signature of cognizant quality assur-ance representative attesting that the form is complete and is acceptable as a

6 quality assurance

record, and signature of a member of the Operations Control group attesting that the work has been satisfactorily completed and that the item is ready to be returned to service.

3.1.1.3 Conclusion The Maintenance organization at Browns Ferry adheres to the guidelines and com-mitments set forth in the BFNPP.

This organization and the management controls in place provide an effective mechanism for ensuring that maintenance is safely and acceptably performed.

3.1.2 Technical Su ort The approved Technical Support organization is responsible for the planning and coordination of technical support.

This organization is divided into functional groups, as follows:

Reactor Engineering; Nuclear Steam Supply System (NSSS); Balance-of-Plant (BOP) Systems; Electrical/Heating, Ventilation, and Air Conditioning (HVAC) Systems; shift technical advisors; tiechanical Test; Technical Support Programs; and Restart Test.

Each functional group reports to a supervisor whose position description is approved by the Site Director.

Position descriptions define the responsibilities and experience levels required.

Authority is implicit in the organization chart reporting levels.

3.1.2.1

~0r anization The Technical Support organization reports to the Technical Support Superin-tendent.

Its workload is generated through approved procedures.

Procedures followed by this organization principally involve modifications to the plant.

SDSP 8.1, "Plant Vodification/Design Change Approval," Revision 8, approved on January i".8, 1989, and SDSP 8.12, "Plant hiodification-Overall Process,"

Revi-sion 2, approved on September 28, 1988, are typical of the procedures followed by this organization.

3.1.2.2 Procedures The typical technical support activity includes the following:

Receivin Workload:

The workload is generated as a result of surveillance re-quirements, ue management requirements, and plant modifications.

Work Breakdown and Plannin Work is broken down into two broad categories:

Periodic and surveillance testing of systems as required by the Technical Specifications and engineer ing requirements is initially scheduled by the Maintenance Superintendent and the Modifications f1anager, respectively.

The Technical Support Programs Supervisor provides data for the integrated site schedule (P-2) for all technical support organizations.

Post-modification testing, special testing (restart),

and technical sup-port for outages are planned in

a. similar manner.

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organization's detailed planning for modification packages involves the assistance of systems engineers and, where appropriate, special restart tests.

The detailed scheduling for the systems engineers from the Tech-nical Support organization is provided by the Technical Support Programs Supervisor for the integrated site schedule (P-2).

Releasin Work:

The Technical Support Systems group enters all technical support wor schedules into the integrated site schedule (P-2).

All plant work is released through the Work Control/Outage Superintendent.

The Technical Support Systems.Supervisor is responsible for establishing materials and service requirements for assigned activities and provides the requirements to the Materials and Procurement Manager.

Trackin of Workload:

The Tracking and Reporting of Open Items (TROI) report ists eac item or which the Technical Support Superintendent's organization is responsible; this includes a description of the requirements and the sched-uled due date.

Work Closeout Ins ection and Documentation:

The work performed by the Tech-nica Support Superinten ent s organization is covered by procedures that pro-vide for closeout documentation.

For example, SDSP 12.4, "Return to Service and Closure of tlodifications," covers acceptance and closure of modifications.

The basic procedure covering testing, including restart tests, is Project Management Instruction'(Pl~I) 17.1, "Conduct of Testing."

Section 5.8 of PHI 17.1 states, "The Technical Support Superintendent assigns special tests to systems engineers for technical review and walkdown and approves all special tests (SDSP-I Form)."

Test documentation is covered in Section 6.0 of PllI 17.1.

3.1.2.3 Conclusion The Technical Support organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management controls in place provide an effective mechanism for ensuring that technical support is safely and acceptably provided.

3.1.3 3~

The approved Operations organization is responsible for the management of plant operations in accordance with applicable Technical Specifications, TVA proce-

dures, and Federal regulations.

Provisions for supervising,

planning, schedul-ing, and coordinating work have been established.

The organization is divided into the following five functional groups:

Shift Operations and four support groups - Operations

Programs, Unit Operations, Operations Support Procedures, and Water and Waste Processing.

Work is managed on a six-shift basis.

The responsibilities and experience levels required as well as the functional work are described in the position descriptions.

Authority is implicit in the organization chart reporting levels.

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qualifications for the Operations Superintendent adhere to ANSI Standard 18.1-1971.

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The Operations organization reports to the Operations Superintendent.

The superintendent provides input data for the integrated site schedule of opera-tional activities, generates status compilations, and analyzes operational data.

The Operations organization follows the procedures in PHI 12.12, "Conduct of Operations."

This instruction together with applicable interface documents provides the description of the operations function as performed at Browns Ferry.

3.1.3.2 Procedures Approved procedures are used at Browns Ferry to carry out the operations func-tion.

The typical operations activity includes the following:

Receivin Workload:

The Operations Superintendent prepares a weekly schedule t at prov>

es etai led shift assignments by individual name for the Shift Oper-ations aroup.

The detailed assignments include, for example, "Onshift - super-visors (SOS [shift operating supervisor3),

break-in SOS, clerks, Offshift-tagging and labeling, refuel floor."

The Operations tlarager, who reports to the Operations Superintendent, prepares daily iristructions for the onshift operating crew.

A typical daily instruction entry is, "...at shift turnover, oncoming SOS should brief oncoming operators only on items reouiring cognizance by a'll shift personnel."

The Operations Superintendent provides the operating crew the list of current mode limiting conditions for operation, abnormal conditions, and equipment.

With three units shut down, operations personnel are being assigned specific tasks to facilitate restart.

These tasks are enumerated in the weekly action item list.

An example is, "Develop Enhanced Method To Track SI Lsurveillance instruction] Status."

The Operations Superintendent's operation action plan lists long-term tasks.

An example is, "...achieve two ASO's [assistant shift operators]

per shift crew prior to restart...."

Work Breakdown and Planning:

PHI 12.12, "Conduct of Operations,"

is used for uorWbreaBown and pTanning.

This instruction references 65 other procedures, standards, and regulatory documents.

It covers the philosophy and principles of good operation, general ruies of practice, authorities, staffing and station operating complements, shift turnover, communications, limiting conditions for operations, Technical Specifications, and emergency conditions.

The current issue is Revision 16, which was approved on June 26, 1989.

The work assignments are extremely detailed so that organization and planning are greatly facilitated.

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Peleasin Work:

The workload is released to the shift operators in the weekly sc e

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o rowns Ferry operations.

Work categories include shift assignment (six-shift operation), float assignment,

training, and days off.

Personnel on shift assignment are assigned work responsibility by name.

The weekly action item list and the operation action plan name specific individuals or super-visors for each task.

Scheduled due dates are included in the task lists.

Trackin of Workload and Work Closeout and Documentation:

The Operations Manager an t e Operations Support Manager provi e

ai y instructions to oper-ators.

All oncoming shift personnel are required to read and initial these instructions.

The Operations Superintendent uses the Browns Ferry internal tracking system, among other techniques.

An action item traveler assignment sheet is created, which describes the task; lists the person responsible, the date assigned, and the due date for completion; provides for the statement of resolution; and provides signature and concurrence blocks for closeout of the work.

3.1.3.3 Conclusion The Operations organization at Browns Ferry adheres to the guidelines and com-mitments set forth in the BFNPP.

This organization and the management controls in place provide an effective mechanism for ensuring work related to plant operations is safely and acceptably performed.

The approved Plant Support organization includes the Plant Assessment

group, the PORC (Plant Operations Review Committee) Oversite group, and the Fire pro-tection group.

Supervisory responsibility for directing and managing the work is shown in the organization chart and defined in the position descriptions.

Authority is implicit in the organization chart reporting levels.

Provisions for planning, scheduling, and coordinating work have been established.

The Plant Support organization reports to the Plant Support Superintendent.

The superintendent generates schedules and status input, reports trends, and provides graphic analyses of plant operations and incidents.

A principal responsibility is providing the Plant Manager with timely status information.

The standard practices arid procedures used by the Plant Support Superintendent include PHI 15.9, "Plant Incident Report," Revision 0, approved on March 9, 1989; PHI 15.6, "Licensee Event Report," Revision 1, approved on January 4, 1989; SDSP 27.4, "Plant Operations Review Committee," Revision 4, approved on July 17, 1989; and SDSP 27.1, "Evaluation of Changes, Tests and Experiments-Unreviewed Safety guestion Evaluation," Revision 5, approved on June 13, '1989.

The Plant Support Superintenderit provides work schedules for the Plant Support organization based on the workload resulting from site adherence to the pro-cedures cited above.

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10 3.1.4.2 Procedures procedures such as those cited above are used at Browns Ferry to carry out the plant support function.

The typical plant support activity includes the following:

Receivin Workload:

The PORC Oversight group's workload is generated as a

resu t o samp e reviews of safety evaluations and procedures, pre-PORC reviews of conditions adverse to quality reports (CA(Rs),

and coordination of the resolution of PORC action items.

The workload of the Plant Assessment group, under the Plant Assessment Super-visor, is generated as a result of Browns Ferry CA(Rs emanating from any organ-ization in TYA's Office of Nuclear power and transmitted by the guality Assurance organization, licensee event reports generated by onshift SOS, incident investigations, and actions emanating from plant/site and corporate management.

For the fire protection crew and ambulance, the primary workload is assigned by shift.

l!ork Breakdown and plannin and Re~leasin Work:

An example of this management unction is t e o

owing.

Tie plant Assessment Supervisor's group is respon-sible for incident investigations.

Once an event is identified, it is screened and, if confirmed by the Plant tlanager, an event manager is assigned by the Plant Hanager.

This constitutes work release.

An inspection team from the Plant Support organization prepares a preliminary event report, which is submitted to the Plant Manager within 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.

The Plant Hanager transmits the preliminary event report to the Site Director and Vice President, Nuclear Power Production within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the event has been identified.

An investigation team from the Plant Support organization develops an investigation plan, collects and evaluates

data, and prepares the final event
report, which is transmitted to the. Plant Hanager within 5 days after the event has been identified; the Plant Hanager transmits the final event report to the Site Director and Vice Presi'dent, Nuclear Power production, within 7 days after the event has been identified.

Trackin of Workload and Work Closeout Ins ection and Documentation:

The ant upport oper>nten ent tree s wor

>n a trend repor an prov~ales narra-tive, tabular, and graphic displays using indicators of work output.

The procedures used by the Plant Support organization provide for documented closeout and inspection of work.

3.1.4.3 Conclusion The Plant Support organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management con-trols in place provide an effective mechanism for ensuring that work related to plant support is safely and effectively performed.

3.1.5 Work Control/Outa e

The approved Work Control/Outage organization manages the planning,

conduct, and assessment of plant outages to ensure that outages are executed in a timely and effective manner in accordance with approved schedules and scopes of work.

The position descriptions for the managers and supervisors delineate the assignments for and management of the specific groups of this organizatio'n.

The organization is divided into the following six groups with supervision pro-vided to each group:

Outage Scheduling, Work Control/Outage Shift Manager, Units I and 3 Work Control, Unit 2 Work Control, Periodic Test Program, and Work Control Support.

Work is managed on a single-division-outage basis; that is, work on plant systems or work requiring plant systems to be shut down to obtain access to the item requiring attention is performed while the associated division is shut down.

All possible work orders pertaining to that division are then implemented to take advantage of the shutdown.

Provisions for planning, scheduling, and coordinating work have been estab-lished.

Authority is implicit in the organization chart reporting levels.

The Work Control/Outage organization reports to the Work Control/Outage Super-intendent.

The superintendent manages the process of requesting, reviewing, planning, scheduling, authorizing, and executing work on site plant equipment during both outage and non-outage periods.

The superintendent generates sched-

ules, status compilations, reports, and trend charts and performs graphic analyses of work as it is accomplished.

The workload is processed according to SDSP 7.9, "Integrated Schedule and Con-trol," Revision 2, approved on August 15, 1989.

This standard practice estab-lishes the organization's responsibilities, the methods to be used for the development and approval of schedules, and the work control process at Browns Ferry.

It applies to all field work that changes or has the potential to change a plant component, sy'tem, or unit configuration.

It applies to work that is done while the unit is on line as well as during forced and planned outages.

It provides the controls to ensure that work is defined, scheduled, and completed.

3.1.5.2 Procedures Approved procedures are used at Browns Ferry to carry out the work control/

outage function.

The typical work control/outage activity includes the fo 1 1 owi ng:

Receivin l.orkload:

The workload is generated through modifications requests, surveys ance requests, and periodic and preventative maintenance work orders.

Work Breakdown and Plannin The Outage Scheduling Supervisor reports to the or Con ro utage upersntendent.

The Outage Scheduling group develops and

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12 maintains the overall outage schedule and identifies and schedules major plant milestores.

The Work Control/Outage Shift Manager, who reports to the Work Control/Outage Superintendent, monitors and coordinates shift-to-shift outage activities and resolves schedular or resource conflicts pertaining to daily work activities.

The Unit 2 Work Control h1anager, who reports to the Work Control/Outage Super-intendent, develops and maintains 4-day and 28-day integrated schedules.

The Periodic Test Program Supervisor, who reports to the Work Control/Outage Superintendent, provides programmatic direction for the plant surveillance testing progran and monitors the schedules and performance of testing to ensure compliance with the Technical Specifications.

Releasin Work:

The Unit 2 Work Control J~sanager and the Work Control/Outage S i t aanager schedule assigments by issuing the 4-day and 28-day integrated schedules.

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~Wor Control/Outage Superintendent, performs the administrative scheduling and tracking function for the plant surveillance test program.

Items or events that are tracked include permits, holds for assignment, labeling or tagging, daily schedule

meeting, 4-day-schedule assignments, and impact evaluations.

Work Closeout Ins ection and Documentation:

The Work Control Support Super-visor trac.s t e status o

wor roug i s completion and is responsible for clerical data entry and document control.

The guality Control organization is responsible for inspecting the work.

3.1.5.3 Conclus ion The Work Control/Outage organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management controls in place provide an effective mechanism for ensuring that work related to work control/outage is safely and acceptably performed.

3.1.6 Radiolo ical Control The approved Radiological Control organization is responsible for the planning and coordination of scheduled radiological control work.

This organization is divided into subdivisions as follows:

Administration and Health Physics, Radiological Protection, Radiological Health, and Field Operations.

Supervisory responsibility is provided for the functional divisions of the organization.

The position descriptions define the functions and responsibilities for each division of this organization.

Provisions for planning, scheduling, and coordinating work have been established.

Authority is implicit in the organization chart reporting levels.

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13 3.1.6.1 Or anization The Radiological Control (RADCON) organization reports to the Radiological Con-trol Superintendent.

The qualifications specified for the Radiological Control Superintendent adhere to ANSI Standard 18.1'-1971.

The Radiological Control Superintendent generates schedules,

reports, trend
charts, graphic analyses, and status compilations to carry out his duties and responsibilities as defined in the approved position description.

The

'organizational workload is generated through work requests and shift routine checklists.

The principal instruction used by this organization is RADCON 1, "Radiological Control Program," Revision 19, approved on July 14, 1989.

It provides a

general description of the Browns Ferry radiological control program and contains instructions for this organization s conduct of operations.

The Browns Ferry radiological control program, which applies to all site personnel, addresses radiological surveillance and controls that minimize the unnecessary exposure of personnel and the environment to radioactive materials.

The program applies during both normal and emergency conditions.

3.1.6e2 Procedures Approved procedures are used at Browns Ferry to carry out the RADCON function.

The typical RADCON activity includes the following:

Receivin Workload:

Work requests for RADCON services received from other p ant organlzatlons and shift routine checklists are the two main sources of workload.

Work Dreakdoun and Plannin:

The Radiological Health Hanager and Field Opera-Iil' p

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d in the planning of work.

They schedule assignments for RADCON personnel to implement shift'and work orders according to the integrated site schedule (P-2).

The RADCON work status

sheet, which lists all work requests and scheduled start and expiration times, is used as a planning and status tool.

Releasin Work:

Procedures established for releasing work include Browns Ferry ea t i P ys>cs Technical Instruction Letter No. 12, which provides schedules and specific routines for the performance of RADCON activities, and Browns Ferry Health Physics Dosimetry Section Instruction Letter No. 4, which lists work routines for dosimetry personnel.

Tracking of Workload and Work Closeout Inspection and Documentation:

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, t%e RAOCCC managers and supervisory personnel use tue shift routine checklists; schedules that are laid out to facilitate tracking; and the RADCON status

sheet, which provides the daily status of each RADCON wor k order.

Signed control points/worklogs and quality assurance/quality control closeouts constitute closure of a job.

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14 3.1.6.3 Conclusion The Radiological Control organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management controls in place provide an effective mechanism for ensuring that work related to radiological control is safely and acceptably performed.

3.1.7 Chemi str and Environmental The approved Chemistry and Environmental organization directs and manages plant activities associated with process chemistry, corrosion control of plant sys-

tems, gaseous and liquid radioactive effluents, and the environmental monitor-ing program to assess the operational impact of the'plant on the immediate site environment.

The functional divisions of this organization are Process Control, Chemistry Technical Support, Chemistry Control, and Environmental.

Supervisory responsibility is provided for the functional divisions of the or-ganization.

Provisions for planning, scheduling, and management control have been established.

The position descriptions explain the thrust of the func-tional work, the responsibility is defined, and the authority is implicit in the organization chart reporting levels.

The qualifications specified in the position description for the Chemistry and Environmental Superintendent adhere to ANSI Standard 18.1-1971.

The Chemistry and Environmental organization reports to the Chemistry and Envi-ronmental Superintendent, who exercises management control through formally approved procedures.

Schedules are developed for tasks, and progress in the accomplishment of tasks is tracked as required by procedures.

Open items are tracked in the integrated site schedule (P-2).

Open items of significance are highlighted in the weekly open item status provided to the Plant Manager.

The principal procedure followed by the organization is PHI 244, "Conduct of Chemistry," Revision 4, approved in August 1989.

It establishes the chemistry program and how it is implemented and provides specifications to maximize long-term'plant availability and minimize environmental impact and worker dose.

3.1.7.2 Procedures Approved procedures are used at Browns Ferry to govern the activities of this organization.

The typical chemistry and environmental activity includes the following:

Receivin Workload:

The chemistry workload is generated through established rou snes inc u sng the following:

15 Weekly work schedule, which lists 44 activities or items to be identified, for example, reactor water, sample point, analysis or action required, frequency, limits or action requirements (Chemistry Laboratory Instruc-tion Letter Wo.

1 ffonthly work schedule, which lists 30 activities Monthly surveillance inspection schedule (provided by Work Control/Outage organization)

Preventative maintenance sheets (provided by Work Control/Outage organization)

Workload is also generated through special requests such as the following:

Request for analysis RADCON counting request Specially scheduled (conditional frequency) analyses as a result of inoperable equipment or abnormal conditions (limiting conditions for operation (LCO) tracking log)

Work Breakdo<<n and Planr~iin:

The shift work schedule is prepared according to em>ca a oratory Instruction Letter No. 1, "Rules and Regulations,"

Revi-sion 21, approved on flay 15, 1989.

The workload input is arranged in terms of time, sequence, priority, and per-sonnel assigned.

A shift turnover checklist is used to transfer scheduled work from ore shift supervisor to the next.

Peleasin Work Tracking of Workload and Work Closeout and Documentation:

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2 ~yt shift work schedule and the shift turnover checklist.

The shift work schedule and the LCO tracking log provide for the tracking, closeout, and documentation of work performed.

3.1.7.3 Conclusion The Chemistry and Environmental organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management controls in place provide an effective mechanism for ensuring that work related to chemistry and environmental management and control is safely and acceptably performed.

2.2 E

2 l

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~Rt td The approved Engineering and Yiodifications Restart organization provides for a manager to whom both the Site Project Engineer and the ffodifications tlanager report.

In the approved position description, the Engineering and

16 Modifications Restart Manager is charged with providing overall management of the assigned functional entities in order to accomplish restart at Browns Ferry.

The basic responsibility of the Engineering and Modifications Restart Manager is to provide direction to subordinate managers for the project management of assigned activities and responsibilities relating to restart of Browns Ferry, including modifications and engineering and other areas assigned.

3.2.1 Site Project En ineerin The responsibility for engineering at Browns Ferry is assigned to the Site Proect Engineer.

The Site Project Engineering organization assigns the engi-neering resources to perform the plant-specific engineering work.

The engineerirg project team consists of engineers from each of the engineering disciplines.

The organization is divided into five groups with supervision assigned to each group.

Provisions for planning, scheduling, and coordinating work have been established.

The position descriptions define the responsibilities and experience levels required.

Authority is implicit in the organization chart reporting levels.

The Site Project Engineering organization reports to the Site Project Engineer and is divided into four engineering groups and one Project Engineering Control group under a manager.

The position descriptions are approved by the Site Director.

The principal procedures covering the work of the Site Project Engi-neering organization are SDSP 8.1, "Change Control Board," Revision 9, approved on May 2, 1989; SDSP 9.1, "Processing Drawing Discrepancies,"

Revision 7, approved on March 14, 1989; SDSP 7.1, "Planning and Estimating Process,"

Revi-sion 2, approved on June 1, 1988; and SDSP 8.10, "Plant Review of ECN/DCNs,"

Revision 7, approved on May 9, 1989.

3.2.1.2 Procedures The procedures given above establish the methods for identifying and author',zing the work of this organization.

They enable the organization to plan, schedule, and track engineering work.

The typical site project engineer-ing activity includes the following:

Receivin llorkload:

The work documents that result in the majority of the wor oa are esign change requests (DCRs) and design change notices (DCNs).

DCRs are sent to the Change Control Board in accordance with SDSP 8.1.

If the DCR meets the criteria of SDSP 8.1, it is approved.

Once approved by the Change Control Board and funded through the Financial Services group, the DCR is sent to the Site Project Engineering organization as part of its workload.

GCHs (engineering),

which are processed according to SDSP 8.11, "Design Change Notices," involve drawing changes only or changes to systems that must meet the threshold criteria enumerated in SDSP 8.11.

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17 Work Breakdown and Plannin:

Planning is covered by procedures that involve severaTorganlsailons on sste

. OCNs ~ covered by SOSP 8.1, must be approved by the Change Control Board.

Once approved, a disposition is obtained from the Plant Manager.

A project manager is then assigned from the Project Controls and Financial Services Manager's organization to do the planning necessary for turning the DCN package over to the Site Project Engineer.

The Project Engineering Control Manager, who reports to the Site Project Engineer, assigns the'CN package to the appropriate group in the Site Project Engineer's organi-zation according to Project Instruction PI-86-03, "Preparation and Control of Engineering Change Notices Modification Packages."

Releasin Work:

The Project Controls Manager releases the work packages accor sng to a schedule, established to complete the work as specified by the Plant Manager.

Trackin of Workload:

The Design Control Manager follows PI-86-03 to monitor t

e progress o

engsneering work according to an established schedule.

The Project Engineering Control flanager transmits completed modification packages to the PORC according to SDSP 8.10.

The Site Project Engineer is provided the status of work in progress in the Site Performance Report, which is issued by the Project Controls and Financial Services Manager.

This report provides the quantitative status of ECN/DCNs to be issued, the backlog status of ECN/DCNs, the status of drawing updates, and official plant acceptances of completed work.

Work Closeout Ins ection and Documentation:

Approval by the PORC of ECN/DCNs an t e comp etymon o

rawlng up ates constitute the closeout of the engineer-ing tasks.

SDSP 8.10 provides for the documentation of work packages.

The signatures on the drawing title block of the drawing checker and the Site Proj-ect Engineer or designee document the completion of drawing updates.

The revised drawing is the final documentation.

The guality Assurance organization reviev.s the documents generated by the Site Project Engineering organization.

The Site Project Engineer recently instructed his lead engineers that drawing

checkers, who are now designated as full-time checkers, be provided all asso-ciated drawings used for the development of the design as well as additional reference drawings required to perform a detailed review.

As part of the checking process, the drawing checker will be required to confirm that all the associated and reference drawings have been provided.

The drawing checker also will be responsible for the review and signoff of all as-constructed drawings and configuration control drawings issued by the Nuclear Engineering organization.

3.2.1.3 Conclusion The Site Project Engineering organization at Browns Ferry adheres to the guide-lines and commitments set forth in the BFNPP.

This organization and the management controls in place provide an effective mechanism for ensuring that the work related to project engineering is safely and acceptably performed.

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18 3.2.2 Site tlodifications The approved Site t'lodifications organization is respons'ible for plant modifica-tions, including the planning and coordination of scheduled work.

This organi-zation is divided into six groups:

t3odifications Engineering; Shift Supervisor; t)anagers for Areas A, B, and C (i.e., civil, mechanical, and electrical, respectively);

Planning; Estimating; and Cost Control.

Each func-tional group has an assigned supervisor with a position description approved by the Vice President, Nuclear Construction.

Provisions for planning, scheduling, and coordinating work have been established.

The position descriptions and responsibilities defined are consistent with the organization chart.

3.2.2.

~0 The Site Modifications organization reports to the Modifications tlanager, who manages the activities of this organization, including field engineering and craft services, related to the modification of existing facilities and the con-struction of new facilities.

The procedure used by this organization is SDSP 8.4, "hlodification Workplans,"

Pevision 16, approved on September 21, 1989.

3.2.2.2 Procedures Modifications are made at Browns Ferry through the use of approved procedures, principally SDSP 8.4, Revision 16.

SDSP 8.4 describes the method for implementing modifications at Browns Ferry when the Nuclear Engineering (NE) crgarizaf.ion issues an engineering change notice or design change notice.

This procedure provides instructions for the preparation and processing of work plans.

The typical site modifications activity includes the following:

Peceivin Workload:

The Site Hodifications organization derives its workload rom essgn c ange notices issued by the Site Project Engineering organization.

The major ECNs cover complex changes to the plant structure as well as systems or equipment; DCNs cover changes that are not complex and any change that is not covered by a major ECN.

ECN/DCN packages are received from the PORC secre-tary.

The status of the package is recorded on the integrated site schedule (P-2).

Work Breakdown and Plannin The Engineering Supervisor, who reports to the

<o s scatsons t'anager, reviews the packages and assigns a responsible engineer to implement the work.

The responsible engineer ensures that the work plan is

adequate, that the materials are ready for approval, and that plant access requirements are met.

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19 Releasin Work:

The work plan is approved by the Modifications Manager.

The etas e

sc e ule for the work is set by the Work, Control/Outage Superintendent's organization.

Trackin of Workload:

The Craft General Foreman within the Site Modifications organization an t e assigned Craft Manager to whom the foreman reports super-vise the work.

The Modifications Manager uses the integrated site schedule (P-2) to determine the status of the work.

Work Closeout Ins ection and Documentation:

The responsible engineer report-ing to e

Mo i scat>on Engsneersng Manager and a second-party reviewer document and sign off the work when it is completed.

The guality Control (gC) organization performs the gC inspection and determines if the work is satisfactory.

The responsible engineer notifies the Site Project Engineer if incorporation of the work into the affected drawings is required.

The Modifications Manager issues status reports to be used by his organization, the Plant Manager, the Site Project Engineer, and the Site Director.

These reports are in both graphic and tabular form.

Examples of the reports include: (I)

Project Bar Chart - Manhours, Scheduled and Actual, by Project Identification Number; (2) Trades and Labor Manpower Utilization - Direct and Indirect-Actual Manhours [as percent of total scheduled];

and (3)

ECN Scheduled Hours Remaining [to be completed].

The Modifications Manager issues 14 reports that provide detailed and analytical information for all management personnel on site associated or involved with modifications.

3.2.2.3 Conclusion The Site Modifications organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management controls in place provide an effective mecha'nism for ensuring that modifications are safely and acceptably performed.

3.3 Project Controls and Financial Services The supervisors of the Project Controls and Financial Services organization are assigned according to the organizational structure.

Provisions for planning, scheduling, and coordinating work have been established.'his organization is divided into four groups:

Finance, Financial Services, Integrated Scheduling, and Scheduling Methods and Project Management.

The position descriptions, which are approved'y the Site Director, define the responsibi lities and experience levels required.

Authority is implicit in the organization chart reporting levels.

.3.1 0~i The Project Controls and Financial Services organization reports to the Project Controls and Financial Services Manager.

The manager generates schedules,

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reports, trend charts, graphic analyses, and status compilations for the entire site as provided for in his position description.

3.3.2 Procedures The Project Controls and Financial Services Manager's workload is generated through design change requests according to SDSP 8.1 and design change notices according to SDSP 8.11.

This work covers capital expenditures for modifications to the plant that are necessary to ensure compliance'ith regulations.

In addition, changes deemed desirable and necessary by TYA to protect its investment or to facilitate plant operation are included.

SDSP 7.1, "Control of Work Scope and the Planning and Estimating Process,"

Revision 2, approved on June I, 1988, is the principal governing procedure followed by the Project Controls and Financial Services organization.

Approved procedures are used at Browns Ferry to govern the activities of this organization.

The typical activity of this organization includes the fol lowing:

Receivin Workload:

The Project Controls and Financial Services organization per orms a wi e variety of work.

The Project Management group, which reports to the Project Controls and Financial Services

Manager, receives design change requests and design/engineering change notices.

The scheduling

groups, which report to the same manager, receive information on the initial or updated status of work to be integrated into the site master schedule (P-2), which is issued periodically.

All departments at Browns Ferry use the P-2 schedule to establish the initial schedule,

status, and control of their work.

The Project Controls and Financial Service Manager provides overall direction for scheduling, while the specific manager provides day-to-day control.

This ensures uniformity and consistency of information while maintaining sensitivity to the particular organization's needs.

Each organization provides input to the Project Controls and'inancial Services Manager to ensure planned activities are incorporated into the site master schedule.

Work Breakdown and Plannin The Project Management group does project plan-ning accor sng to roJect Instruction 86-03, which deals with the preparation and control of engineering change notices and modification packages.

t The Finance group, which reports to the Project Control and Financial Manager, does the planning for the Financial Services group.

This involves operating budget breakdowns and planning payroll cash flow as well as capital acquisitions and travel expenses.

Releasin Work:

The project managers under the Project Controls and Financial Services anager process work according to SDSP 8.4, "Modification Work Plan,"

by submitting work plans through the site approval cycle, including the PORC.

Trackin of Workload and Work Closeout Ins ection and Documentation:

rac sng an status reports are comps e

an issue ws t sn t e ProJect Controls

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21 and Financial Services Manager's organization.

In addition, periodic meetings with the Site Director and his senior managers are held to review the site master schedule, identify reasons for any deviations, and prescribe corrective actions.

The Site Performance Report is transmitted on the authority of the Site Director to the corporate Vice President, Nuclear Power Production, and to top managers under the Site Director.

This report provides the measure of the effectiveness of the plant, including the electric power output parameters for operation.

It also includes, for example, the equipment availability factor, safety system unavailability, emergency ac power unavailability, net electrical generation, liquid radioactive effluents, licensee event reports fuel reliability, and violations; these are but a few of the 67 items provided and monitored ir this report.

This report provides the documertation of the inspection and closeout of workload.

3.3.3 Conclusion The Project Controls and Financial Services organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management controls in place provide an effective mechanism for ensuring that the work of this organization is safely and acceptably performed.

3.4 Materials and Procurement The Materials and Procurement organization is responsible for the procurement and managment of materials.

The organization is divided into four functional groups:

Power Stores, Procurement

Services, Materials Coordination, and Tool Room and Measurement and Test Equipment.

Provisions for planning, scheduling, and coordinating work have been established.

The position descriptions describe the thrust of the functional work and the required experience

levels, and the organization chart shows assigned personnel responsibility and authority.

The Materials and Procurement organization reports to the Materials and Procurement Manager.

This manager directs the provision of materials and'rocurement services for site organizations; manages assigned site programs and procedures pertaining to the planning, requisitioning, receiving, storing, and issuing of parts and material to ensure that the supply is sufficient; establishes and controls tool and warehouse inventories; and ensures effective control of measuring and test equipment, welding material, and tool room operation.

The Materials and Procurement Manager uses Site Director standard practices as the basis for management control in his organization.

Inventory control tech-niques that are not necessarily reduced to a standard practice have been

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22 determined by specialists hired to devise and install the inventory control system.

After a detailed flowchart analysis of existing systems and procedures related to the procurement and warehousing of material and its release to the plant, the Haterials and Procurement hanager devised the system for storing and retrieving material in the materials warehouse constructed in 1989 at Browns Ferry.

The analysis determined reorder points for long lead replacement parts and miscellaneous small parts and for expendable material, including welding materia 1.

3.4.2 Procedures Approved procedures are used at Browns Ferry to govern the activities of this organization.

The principal standard practice used by this organization is SDSP 16.2, "Procurement of Material, Components, Spare Parts and Services,"

Revision 2, approved on September 7, 1989.

This standard practice-establishes the requirements and methods and assigns the responsibilities for the prepara-tion, review, approval, and control of procurement documents initiated at Browns Ferry.

The typical activity of this organization includes the following:

Receivin l<orkload:

The workload of the Power Stores group includes receiving mater>a

snspect~ng,
storing, and updating inventory records; retrieving material from storage and delivering it to users; and procuring material when required for stock.

The workload of the Procurement Services group includes receiving and processing requests for the procurement of materials, plant equipment, tools, and test equipment and processing orders for the repair of tools ard equipment.

llork Breakdown and Plannin and Releasin llork:

Planning is done in con)unction wit cognizant managers in t e p ant to prepare for outages, add new items to the inventory, procure new maintenance

material, and meet unanticipated needs for parts or replacement equipment.

Tracking of Workload:

The workload is tracked by dynamic inventory management 3p,dip ii,digphd,,pl d

rial inspections, and checkout and return of tools and test equipment.

Work Closeout.

Ins ection and Documentation:

Provisions for inspecting and recor

~ng t e ispos>t>on o

maten a s~too s, and test equipment have been provided.

3.4.3 Conclusion The Materials and Procurement organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management controls in place provide an effective mechanism for ensuring that the work related to materials and procurement is performed safely and acceptably.

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23 3.5

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The Site Programs organization is responsible for the planning and coordination of scheduled work in each of its functional divisions.

The organization consists of six service groups, each having its own planning and work control system.

The functional divisions include Site Procedures, Corrective Action

Program, Document Control and Records, Site Information Systems (data processing),

Configuration Management, and Training.

Supervisory responsibility is provided for each functional division.

Position descriptions describe the thrust of the functional work and the responsibilities.

3.5.1 P~i The Site Programs organization reports to the Site Programs Manager.

The man-ager requires from< his subordinates monthly reports of work completed and the status of the incomplete work and submits these reports to the Site Director.

TVA plans to transfer the Site Information Systems function to a newly created corporate organization called Information Services.

The positions in the Con-figuration M<anagement group are vacant.

Configuration management is a function performed under the Site Project Engineering organization.

The Site Document Control Manager reports to corporate management directly.

The Site Programs Manager provides local administrative supervision as required to facilitate site functions.

However, that part of document controls custodianship handling Browns Ferry plant drawings wi 11 be under the jurisdiction of the Site Project Engineer.

The Site Training Manager reports to the Vice President, Nuclear Assurance and

Services, and administratively reports to the Site Programs Manager.

All functions within the Site Programs organization arc covered by procedures that prescribe the manner in which the respective divisions of this organiza-tion are to operate.

The principal procedures applicable to this organization are SDSP 2.1, "Site Procedures and Instructions," Revision 11, approved on September 7, 1989; SDSP 2.5, "Controlling and Processing Records,"

Revision 9, approved on April 25, 1989; SDSP 2.10, "Controlling Drawings," Revision 0, approved on June 29, 1989; SDSP 2.12, "Controlling Documents,"

Revision 1, approved on June 29, 1989; and SDSP 4.9, "Training Program for Technical Staff and Managers,"

Revision 1, approved on April 4, 1989.

3.5.2 Procedures Approved procedures are used at Browns Ferry to govern the activities of this organization.

The typical activity of this organization includes the fo 1 1 owing:

Receiving Workload:

The Corrective Action Program Manager deals principally w~<< t CA<<R~s, emp oyee concerns, and operational readiness.

The Site Procedures

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24 Manager's workload stems from the processing of new procedures and reviewing revisions to existing procedures pursuant to SDSP 2.1 and SDSP 2.11, "Site

'rocedures and Instructions,"

and "Implementation and Change of Site Proce-dures" respectively.

The Document Control and Records fianager's workload stems from receiving, storing, photographing, revising, reproducing, and distributing documents,

records, drawings, microfilm, and other stored data as described in SDSP 2.12, "Controlling Documents."

The Site Training Manager's workload stems from the training needs of the Browns Ferry site organizations.

liork Breakdown and P1annin~Re1easing Work T~rackin of Workload and Work C oseout an Documentation:

For each function under tTte Site Programs llanager, the met o

s use or management control vary only slightly one from the other because of the end product of each function.

The Corrective Action Program Mlanager tracks work and ensures that closeout of the work is documented.

Work breakdown,

planning, and release are executed according to applicable procedures for CA(Rs, employee
concerns, and operations.

The Site Procedures Mianager follows procedures for all steps in the management control of his organization.

The Document Control and Records Management Manager also follows procedures for all steps in the management control of his organization.

The Site Training Manager is responsible for work breakdown and planning per-taining to the implemlentation of training classes by creating schedules for classes and rosters listing trainees attendinig each class session.

hew curri-cula require new lesson plans, preparation of lecture notes, and visual aids.

If hardware is involved in the training, it must be obtained and its use inte-grated into the lesson plan.

hhen the classes are under way, attendance lists and grading certificates are used for tracking and closeout documentation.

3.5.3 Conclusion The Site Programs organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management con-trols in place provide an effective mechanism for ensuring that the work related to site programs is safely and acceptably performed.

3.6

~Site Su crt The Site Support organization under the Site Support Manager is divided into seven

groups, each under a manager whose position description is approved by the Site Director and/or a TVA Vice President.

This organization manages activities in the areas of industrial safety

services, onsite radiological emergency preparedness, and facilities and provides onsite manaoement and oversight of activities in the areas of human resources, medical services,
security, and employee concerns.

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25 3.6.l

~0 The Site Support organization reports to the Site Support Nanager.

The organi-zation is divided into functional groups whose managers generate schedules, report trends, and provide graphic analyses as well as status compilations.

The Site Support tlanager assists the Site Director by ensuring that the neces-sary services are provided to the site and are responsive to schedules, priori-

ties, and requirements.

3.6.2 Procedures Approved procedures are used at Browns Ferry to govern the activities of this organization.

The typical activity of this organization includes the fo 1 lowing:

Receivin Morkload and as a

ro riate Work Breakdown and Plannin and Re easin or T e Site Support organization per orms numerous unct7ons.

Some examp es of the functions and planning procedures are the following:

The Site Radiological Emergency Nanager coordinates and implements the Radiological Emergency Preparedness Program on site.

The principal proce-dure used is SDSP 22.2, "Emergency

Response

Organization,"

Revision 1, approved on September 9, 1988.

This standard practice establishes the minimum requirements for the response to an emergency situation and includes the reporting structure and responsibilities, expected response

times, and guidance for members of the emergency response organization.

Vith regard to non-emergency situations, it includes information on the duty list.

The Facilities Services Hanager controls facility work requests and nuclear construction craft support.

The Industrial Safety t1anager performs safety inspections and implements safety improvement campaigns.

The principal procedure used is SDSP 14.34, "Occupational Health and Safety Program,"

Revision 0, approved on August 3, 1989.

The purpose of this standard practice is to implement the Occupatic.nal Health and Safety Program at Browns Ferry.

The source document, listed in the reference

section, describes the. applicable requirements of this program.

The workload consists of safety investigations; reviewing workers compensation claims; organizing safety meetings and attending national safety meetings; and reviewing, designing, and installing safety signs.

The Security Yianager controls and directs site security support.

The principal procedure used is SDSP 11.3, "Nuclear Security Operation,"

Revision 0, approved on September 12, 1988.

The purpose of this standard practice is to outline and identify the structure of the Nuclear Security organization at Browns Ferry.

It defines the assignment of responsibili-ties, the lines of supervision, and the interface between the Nuclear Security organization and the nuclear Power group.

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26 The Site Human Resource Services Manager controls hiring and administers personnel improvement and affirmative action programs.

The principal procedure used is SDSP 32.2, "Personnel Policies and Procedures,"

Revision 6, approved on September 19, 1989.

This standard practice establishes guidelines to provide a uniform method of handling personnel actions throughout the site and outlines procedures to be followed when performing any type of personnel action.

The Employee Concerns t1anager processes newly identified issues and conducts employee exit interviews.

The principal procedure used is STD-1.4.90, "Employee Concern Program,"

Revision 0, interim, approved on April 19, 1989.

This procedure describes the process for receiving, eval-uating, processing, resolving, and responding to employee concerns made known to the Employee Concern Program (ECP) staff at the TVA nuclear sites and corporate offices (NRC commitment NCO-86-0156-085).

It applies to all TVA nuclear activities and is intended to comply with 10 CFR 50.7, "Employee Protection,"

and other Federal laws and regulations with which TVA must comply.

The Administrative Services Supervisor controls and administers document reproduction ard office supply orders.

The Medical Services Manager performs alcohol and drug screen testing and physical examinations and provides a comprehensive occupational medical arid related health program for the site.

Track~in of Workload and klork Closeout and Documentation:

The Site Support manager uses a system of mmontmly reports rom e c

su ordinate marager for tracking the progress and closeout of work.

3.6.3 Conclusion The Site Support organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management con-trols in place provide an effective mechanism for ensuring that the work related to site support is safely and acceptably performed.

3.7

~Si 0

The Site Quality organization is responsible for site QA, QC, and quality engineering (QE) and performs Browns Ferry site audits.

The organizational structure provides for a Technical Support group within the Site Quality organization to plan and coordinate the scheduling of QA, QC, and QE work and the reporting of the Site Quality organization s accomplishments.

Supervision is provided for each. group within the Site Quality organization.

Position descriptions approved by the Vice President, Nuclear Assurance and

Services, define the responsibilities and experience levels required.

Authority is implicit in the organization chart reporting levels.

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27 3.7.

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The Site Quality organization reports to the Site Quality Manager.

It consists of one line group, two audit groups, and one staff group.

The line group is Quality Control, the audit groups are Quality Assurance and Quality Engineering, and the staff group is Technical Support.

The Technical Support group, which reports to the Site Quality Manager, provides management with statistical reports on site quality for all departments at Browns Ferry.

The principal procedure used by this organization, Quality Monitoring Program 102.1, "Quality Monitoring Program-Site," Revision 5, approved on September 18, 1989, establishes the methods and responsibilities for planning, scheduling, performing, documenting, approving, following up, and reporting the results of quality monitoring activities.

Quality monitoring activities are scheduled monthly.'.7.2 Procedures The Quality Control group inspects the work products and operating equipment at the site.

It also conducts a comprehensive inspection program under which modifications, maintenance, and inservice inspections in all the technical areas are examined.

The Quality Assurance group monitors plant activities and programs.

It evalu-ates the Gperations, Modifications, Maintenance,

Testing, Procurement, and Engineering groups.

The Quality Engineering group performs quality assurance and programmatic reviews.

This includes site and project engineering, wor k control documents, special test data review, receipt inspection, and quality engineering monitoring.

The Technical Support group administers the Site Quality Administrative

Program, under which budget forecasts are made, position descriptions are
provided, the Technical Library is operated, and word processing and graphics are provided.

The group also provides administrative control of the site CAQR program.

The typical activity of this organization includes the following:

Receivin Workload:

The workload stems from the respective schedules for the site work t e Site Quality Manager's organization inspects or audits.

Wor k Breakdown and Plannin and Releasin Work:

Work schedules and activity sc e

u es o

ot er site organizations are use to perform detailed work break-downs and planning for the Site Quality organizations..

Trackin of Workload:

The Quality Assurance Manager issues the monthly Quality Survei ance Summary Report, which tracks QA time spent on surveillances, and the monthly Surveillance/Monitoring Schedule and Activities Report.

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8V h S3, 28 Work Closeout Ins ection and Documentation:

The Browns Ferry Site guality Surveys ance Honstorang Report ss a ate, stamped gA record that is signed by the responsible gA auditor or supervisor.

It contains a report number identifying the subject, the date and time of the surveillances, and the preparer's and the reviewer's signatures and describes the surveillance and the results.

If a CARR is issued as a result of the surveillance, it is attached to the report.

3.7.3 Conclusion The Site guality organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management con-trols in place provide an effective mechanism for ensuring that work related to site ouality is safely and acceptably performed.

3.8 3~iLi The Site Licensing organization is responsible for nuclear licensing and regulatory affairs to support enginieering, construction, and operation of the plant.

It is divided into three functional groups:

Licensing Support, Regulatory Licensing, and Compliance Licensing.

Supervisory assignments for directing and managing these groups are laid out in the organizational structure.

Provisions for planning, scheduling, and coordinating work have been established.

3.8.3

~8 The Site Licensing organization and each of the three groups report to the Site Licensing Hanager.

3.8.2 Procedures Approved procedures are used at Browns Ferry to govern the activities of this organization.

The typical licensing activity includes the following:

Receivin Workload:

The Site Licensing organization's workload stems from regu atory requirements, licensee commitments to the NRC, and revisions of the Final Safety Analysis Report and the Technical Specifications.

Work Breakdown and Plannin:

Work is distributed according to the functional responsi i >ty o t e su ordinate groups.

Pele~asia Murk:

A licensing engineer is assigned to each specific licensing action.

Tliese assignments are provided as input to the TROI report.

Trackin of Workload:

The TROI report is used to track and give the status of wor. It ss issue each week and lists items that are due within 15 to 30 days after it is issued.

The report provides the manager with a weekly status sum-mary of all work in progress.

The Site Licensing hanager issues a weekly Site

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29 Licensing Department Activities Status Report, which contains an explanatory narrative of work in progress.

Work Closeout and Documentation:

The signature signifying final approval and t e transmitta o

comp eted work constitute the closeout of work items.

The TROI report lists all items completed, and final documents are filed by the Site Licensing organization.

3.8.3 Conclusion The Site Licensing organization at Browns Ferry adheres to the guidelines and commitments set forth in the BFNPP.

This organization and the management con-trols in place provide an effective mechanism for ensuring that work related to site licensing is safely and acceptably performed.

4.0 OVERALL CONCLUSION In the BFNPP, Revision 2, TVA describes problems found in the Browns Ferry site management and organization.

The staff has evaluated the changes made by the

BFNPP, and the existing site organization and management structure resulting from the instituted changes.

The staff evaluated the authorities, responsibilities, and structure of the site organization, as depicted in the organization chart and the position descriptions for managers and supervisors shown on the organization chart.

The staff evaluated the management control system in terms of authority, responsibility, and approved position descriptions and procedures.

It examined management systems in place with respect to the planning, release, and tracking of work.

The staff concludes that the Browns Ferry onsite organization and management control system were consistent with the commitments set forth in the BFNPP.

Furthermore, this organization and its control systems could direct the activities necessary to restart and operate the plant.

Principal Contributor:

D.

H. Moran Dated:

duly 31, 1990

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