ML20151C984
| ML20151C984 | |
| Person / Time | |
|---|---|
| Issue date: | 02/07/1988 |
| From: | Hagedorn H Advisory Committee on Reactor Safeguards |
| To: | Wylie C Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-CT-1916, NUDOCS 8804130313 | |
| Download: ML20151C984 (4) | |
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February 7, 1988 To:
Charles J. Wylie cc:
Members of ACRS Ad Hoc Sub-committee on TVA Reorganization From: Hemer J. Hagedorn Subj: Repor t on Feb. 2-3 !!ee tings on Sequoyah Restart This meno e>:tends the report I submitted on December 6.
The carlier report constituted an opinion on the effects of the TVA corporate reorganization, as well as suggestions on future NRC staff and ACRS involvement in the managerial / organizational aspects of nuclear plant safety.
This memo addresses three questions:
Are there staffing, organizational or managerial barriers to restart at Sequoyah?
m Are safety functions and activities being given adequate scope, resources, independence and authority to provide longer term ausulance of safety at the Sequoyah plant?
- ' What appears to be the effect at Sequoyah of the NRC staff efforts there during the shutdown?
ARE THERE PERCEIVABLE STAFFING, ORGANIZATIONAL OR K.tNAGERIAL BARRIERS TO SAFE RESTART AT SEQUOYAH (OTHER TRAN THOSE THAT HIGHT CAUSE THE PLANT TO FAIb COMPLIANCE TESTS OF THE NRC) ?
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@a Does the recent appointment of new managers (e.g. the g
plant m: nager) at Sequoyah endanger the safety of restart?
In my opinion, it does not, because the new manager is being Om trained by a particularly knowledgeable person able to give Qg, quality time to training, and the site director appears to be a take-charge person very familiar with the job and the n<-
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plant.
Other new managers are all permanent TVA employees, ggd said to have qualifications and experience superior to their mau predecessore.
The biggest remaining staffing question is 4
l the number of vacancies, "actings" and trainees within the plant manager's staff.
Several of these positions (e.g.,
plant shift managers) were represented to be aew posts not yet filled.
They are in the organizational plan as important additions to be recruited cver the next few months.
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2 Is the managen.ent cadre demoralized by the arrival of new people brought in over them?
A few interviews and casual observations and conversations in the plant do not justify sweeping conclusions en the state of managerial morale at Sequoyah.
The more superficial analysis possible under the"circumstances suggests this to be an area,to watch, but not a situation justifying delay of restart.
Morale is reported on the upswing at all levels, a trend that is consistent with signs visible throughout the plant (facial expressions positive, peopic at all levels moving purposefully-generally exhibiting an upbeat mood).
Is there adequate integrity in the chain of operational accountability and adequate horizontal integration among functions and systems?
The NRC staff reported good understanding of their roles and relationships on the part of the line managers at Sequoyah.
The reexamination of procedures and instructions underway, the elimination of one management layer in operations and maintenance, the establishment of plan-of-the-day meetings, the increase in number of field supervisors are all steps that could and should help overcome some of the difficulties reported earlier.
1 Is there closure among the functions of design constructions, operations and maintenance / modifications?
Is operations being given sufficient voice among these four major functions?
The enforcement of there being "one set of drawings" seems to represent a significant step forward.
The establishment of the lower level systems engineering function should also help within narrow limits to assure that individual systems work as they should.
It is not proven that practical, system wide, day-to-day integration will be achieved without considerable continued attention by all middle and upper levels of management both at Segoyah and at headquarters.
1 ARE THE VARIOUS SAFETY FUNCTION BEING GIVEN ADEQUATE EMPHASIS, SCOPE, RESOURCES, INDEPENDENCE AND AUTHORITY TO ASSURE THEIR ABILITY TO DO THEIR JOBP Is it clear where ultimate accountability for safety consciousness is lodged, and is that a satisfactory solution?
Safety consciousness appears cicarly to be lodged with the Manager of Nuclear Power.
This appears to be inevitable.
It appears also to have resulted in considerable clarification of safety roles and responsibilities for the PORCs, ISEGs and the NURG.
There seems also to be some clarification in the right of any employee to raise questions about Conditions Adverse to Quality, and possibly some succesr. in getting many of these i
queries settled constructively by line management in the full light of day.
Finally, the NSRB seems to be working on the basis predicted, with several well-known outside members i
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3 in place, with stated good access to Admiral White', and with freedom to raise what issues it will (though no staff of its own to do investigations.)
I failed to note anecdotal or other evidence, however, that would suggest that the "nuclear ethic" as propagated by the NRC staff, is different from the "compliance ethic," or that TVA management has yet created a culture in which there is a single understanding as to the priority of safety irsues, or unequivocal encouragenent to those who bring up riftty it. nuts other than thorc n1 ready noted by the NEC staff.
liany of the detailed investigations prompted by employee concerns resulted in few or no findings of unsafe conditions.
Furthermore, the number of reported employee concerns about safety (and other matters) has dropped off dramatically.
Therefore, the apparent requirement for a more proactive managerial safety consciousness and further development f the safety conscience concept does not in my opinion crnstitute grounds for deferring restart.
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WHAT APPEARS TO BE THE EFFECT OF THE EFFORTS MADE BY,.
THE HRC STAFF AT SEQUCYAH?
Distinguishing the impact of the NRC staff from that of -
INPO, the ACRS, or the new TVA nuclear power managers is not -
in the strict sense possible..
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z' There seems to be some evidence, as interpreted by those qualified to do so, that the situation at Sequoyah was maybe not that bad to begin with.
There would seem to have been a very good base to build on, at the very least.
I wish to single out one aspect of staff impact that can 1most certainly be traced to their influence, because it continues to represent a basic problem.
It is the l
"compliance mentality" as mentioned in the preceding section.
The "compliance mentality" is the bureaucratically imposed notion that doing what the NRC says is all you have to do to be safe.
It represents a passive, and sometimes an unthinking, approach to safety.
, Even in the commendable NRC staff concept called "the nuclear ethic," there is (at least potential) encouragement for this kind of passivity.
We were told that the nuclear ethic is characterized by a wilingness to examine and fo'llow up on suggestions (whose suggestions?).
Or, in a little more detail, searching for root causes, perseverance, and taking effective corrective actions.
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4 None of this would I criticize--in and of itself it makes sense.
The question is whether the NRC staff was searching for examples of suggestions raised by others.
i So far as the staff itself is concerned, they are necessarily constrained by the same mentality themselves.
For example, one of the major introductory comments made in the staff presentation on February 2 noted the absence of any statutcry ranogerial "te.pletes" vith vhich it would be persible to ccrparc actue) 7 \\*;. organi r.ct ional cnd managerial perforr..unec.
Sche this.g vi th 5:hich to conply!
It is my opinion that in this mentality lies the i
central issue to be resolved in assuring that future NRC staff attention to managerial and organizational matters bears good fruit.
Nuclear safety demands compliance and even regimentation.
But it demands more than that.
Please let me know if you require more detail, have questions you want me to answer.
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