ML20155H000
| ML20155H000 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/1986 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20150F698 | List: |
| References | |
| TASK-PII, TASK-SE SECY-86-001B, SECY-86-1B, NUDOCS 8605120056 | |
| Download: ML20155H000 (11) | |
Text
_ m =.. . .--_n-Attachment #3 - Question 42A
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- a s., .....f POLICY ISSUE March 10, 1986 SECY-86-1B For
- The Commissioners From: Victor Stello, Jr.
Acting Executive Director for Operations Subiect: STATUS OF STAFF ACTIONS REGARDING TVA
Purpose:
To provide the Commission with a status report on staff activities in response to issues associated with TVA. This is the third status report on this topic.
Background:
On December 13, 1985 Chairman Palladino directed the staff to prepare periodic written reports summarizing the major NRC plans, schedules, and organizational assignments related to all TVA plants. The first of these reports was provided to the Commission as SECY-86-1 dated January 2, 1986. SECY-86-1A was provided as the second status report on January 31, 1986.
Discussion: The staff has identified a number of major TVA issues requiring resolution prior to the restart of any of the TVA reactors. The staff briefed the Commission on these issues on January 7, 1986 and stated that Sequoyah Unit 2 was expected to be the first reactor ready to resume operation. TVA briefed the Commission on a number of TVA activities on January 9, 1986 and noted the appointment of Steven White as 'the new Manager of Nuclear Power.
Because of this significant management change, TVA requested a 30 day period for Mr. White to reevaluate the ongoing TVA efforts to address the safety concerns needed for the restart or licensing of TVA facilities. The staff briefed the Commission on TVA status on February 7, 1986. On March 11, 1986 TVA is scheduled to brief the l
Commission.
l The staff is developing detailed schedule information for resolution of the issues associated with the TVA
Contact:
H. Thompson, NRR 492-9595 8605120056 860422 PDR COMMS NRCC CORRESPONDENSE PDR
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The Commissioners i facilities. Detailed schedule information, which was i based almost exclusively on staff estimates of the time
- when TVA submittals would be received, were provided to the Commission in SECY-86-1A. These schedules have not changed substantially since TVA has not, as yet, made schedule information available to the staff. Since TVA submittals and schedule estimates have not been received, the staff has slipped their estimates for completing pacing issues about 4-6 weeks. When TVA schedule infor-mation is provided, the staff schedules will be revised as appropriate.
There are five areas where there has been considerable recent TVA activity and which have also received a significant level of staff attention. These areas are equipment qualification, employee concerns, welding, electrical design calculations, and simulator evaluations of Sequoyah licensed personnel. The following paragraphs summarize the current status of these issues, focusing primarily on the Sequoyanh facility.
EQUIPMENT QUALIFICATION As TVA has completed portions of the equipment qualification (EQ) effort the staff conducted on-site reviews, including an audit in November 1985, a two-week inspection in January 1986, and an inspection during the week ending February 14, 1986. The status as of February 14, 1986 is as follows:
o TVA has prepared 85, out of 96, EQ document packages o The staff has reviewed 77 of the 85 packages prepared by TVA and plans to review the remainder of these packages.
4 o TVA has field modifications, hardware changes and additional documentation to complete, affecting about 50 of the document packages. Most modifications will be completed by mid-March.
Discrepancies identified by both the staff and TVA remain to be corrected; however the TVA EQ Program appears to be sound. The staff currently estimates that all EQ' discrepancies will be resolved and TVA will be able to certify that Sequoyah is in compliance with the EQ rule by early April.
We expect that TVA and the staff will face additional effort to assure EQ compliance at Browns Ferry and Watts Bar.
l The Commissioners t i
1 EMPLOYEE CONCERNS Nearly 5,000 TVA employee concerns have been raised; some of these involve safety related and intimidation, harassment, or wrongdoing issues. About 400 of these i concerns apply to the Sequoyah facility. TVA has established a program for evaluating employee concerns and is making the transition from a program administered by Quality Technology Company-(QTC) to a TVA-administered program. The staff has conducted several inspections of the QTC-administered employee concerns program, the most recent of which was during the week ending January 24, 1986.
A summary of recent TVA and staff actions in this area is as follows:
o In late January 1986 TVA initiated contract negotiations with QTC to revise the scope of the QTC effort and provide for the initiation of the TVA-administered program on February 1,1986.
o On Ja'nuary 30, 1986 the NRC issued an immediately effective order to assure preservation of and access to QTC records.
o On February 11, 1986 TVA submitted a summary of the TVA-Administered Employee Concerns Program and the methodology TVA will use for resolution of concerns generated by the Watts Bar Program. The staff responded to TVA regarding this submittal on February 28, 1986, and requested a TVA staff briefing and response to a number of staff concerns.
o The staff is interviewing individuals and following up on allegations brought directly to the NRC by concerned individuals. On February 21, 1986, the staff interviewed Mr. Dallas Hicks concerning a number of his concerns.
i o The staff is developing an integrated data base on )
all safety-related employee concerns, allegations, and NSRS issues. We are currently sorting the data base by various technical categories to facilitate staff review.
o The staff is initiating an effort to review, on an expedited basis, all intimidation and harassment issues and request identification of TVA actions taken on those items determined to be safety significant. This review will include an examination of selected QTC records.
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The Commissioners .
The staff expects to assess the TVA-Administered Program subsequent to its implementation to assure it is effective in identifying employee concerns and has the confidence of TVA employees.
Technical review and resolution of most of the employee concerns by TVA remains to be completed. This may ,
constitute the pacing item leading to the restart of the Sequoyah Facility, As the TVA investigations progress, we will evaluate the technical resolution of many of the
, safety-related employee concerns.
WELDING Recent activities by the staff and TVA are as follows:
o The staff reviewed the TVA Weld Reinspection Plan for Sequoyah and found it acceptable with comments ,
which were provided to TVA.
o TVA completed reinspection of 800 welds at Sequoyah during the week ending February 14, 1986.
t o Members of the staff were at the Sequoyah site February 24-28, 1986, conducting independent inspection of about 300 welds using the NRC's mobile nondestructive examination van.
o The staff is retaining the services of independent welding experts to assist in evaluating the TVA Welding Program.
o TVA is preparing an evaluation report, documenting the results of their reinspection of Sequoyah welds. This report is expected in mid-March and will be reviewed by the staff.
TVA is developing a detailed weld reinspection program for Watts Bar. Staff review of the Watts Bar program and on-site inspections are expected in the next few months.
ELECTRICAL DESIGN CALCULATIONS The current status of activities in this area are as follows:
o The staff conducted an on-site inspection of the l Sequoyah facility in mid-January to evaluate the TVA i program and on-site progress.
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. The Commissicners o TVA has completed the Sequoyah design review and a report of their effort is expecteo in early April 1986.
o Several minor system modifications are expected at '
Sequoyah as a result of this review.
The staff will review the results of the Sequoyah effort I and confirm implementation of modifications prior to (
facility restart.
l SEQUOYAH SIMULATOR EVALUATIONS ;
In response to high failure rates for operator requalification exams at Browns Ferry, the staff has conducted simulator evaluations of Sequoyah-operating personnel. These evaluations were completed during the week ending February 28, 1986 and the results were that 21 out of 24 personnel performed adequately.
The one crew (3 persons) that was weak is receiving additional training and will be reevaluated by TVA. NRC will audit the licensee's retraining and reevaluation.
CONCLUSION To date, no schedule information has been received from TVA. Also, the staff has not received additional submittals in response to the 50.54(f) letter of September 17, 1985. Where activities at TVA facilities have progressed sufficiently to allow meaningful staff review, the staff has committed the necessary resources to facilitate prompt evaluation and feedback to TVA. i The staff is currently conducting normal inspection activities at all of the TVA facilities and conducting special inspections or reviews of particular TVA issues, as described above. More information on activities will be provided in subsequent reports.
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h Victor Stel o, ar.
Acting Executive Director for Operations
r GUESTION 42 (CONTINUED) (B) EXPLAIN WHAT NRC BUDGET ALLOCATIONS HAVE BEEN NECESSARY TO COPE WITH TVA ISSUES AND FROM WHERE TH'SE 0 FUNDS HAVE BEEN DIVERTED, ANSWER.
THE STAFF IS CONTINUING TO DEVELOP ITS PROGRAM TO ADDRESS CONSTRUC-TION, EQUIPMENT, OPERATIONS AND MANAGEMENT CONCERNS AT THE TVA FACILITIES. IN ADDITION TO STAFF AND MANAGEMENT EFFORT, t ABOUT $500K OF TECHNICAL ASSISTANCE SUPPORT HAS BEEN ALLOCATED TO !
SUPPORT THE STAFF; THESE FUNDS WERE DIVERTED FROM THE OPERATING REACTORS PROGRAM. GIVEN THE NUMBER OF CONCERNS THAT CONTINUE TO BE RAISED, WE EXPECT THAT ADDITIONAL FUNDS WILL BE REQUIRED. IN TERMS OF PERSONNEL, THERE ARE APPROXIMATELY 60 NRC STAFF MEMBERS WORKING ON VARIOUS ASPECTS OF THE TVA SITUATION ALTHOUGH NOT ALL 60 INDIVIDUALS ARE WORKING ON TVA ON A FULL-TIME BASIS.
QUESTION 42 (CONTINUED) (C) TO WHAT EXTENT IS THE NRC RESPONSIBLE FOR, OR COULD NRC HAVE PREVENTED, TVA'S PROBLEMS? ARE NRC PROGRAMS AND RESOURCES SUFFICIENT TO PREVENT FUTURE REGULATORY BREAKDOWN AT OTHER FACILITIES?
ANSWER.
THE STAFF IS IN THE PROCESS OF DETERMINING WHAT LESSONS WERE LEARNED, AND WHETHER OUR REGULATORY PROCESS CONTRIBUTED TO TVA'S PROBLEMS. IN ADDITION, AS PART OF OUR REVIEW OF THIS MATTER, THE STAFF WILL EXAMINE THE EFFECT OF NRC PROGRAMS AND ITS RESOURCES ON THE SAFE OPERATION AND CONSTRUCTION OF OTHER FACILITIES AS WELL.
AS DISCUSSED IN MORE DETAIL BELOW, NRC PROGRAMS AND RESOURCES ARE NOT SUFFICIENT TO PREVENT FUTURE PLANT SHUTDOWN DUE TO THEIR INABILITY TO COMPLY WITH NRC REQUIREMENTS, IN ORDER TO CLARIFY THE ROLE THAT THE NRC SHOULD TAKE REGARDING THE TVA PROBLEMS, THE NRC REGULATION OF COMMERCIAL NUCLEAR POWER ACTIVITIES IS BASED ON THE PREMISE THAT LICENSEES ARE RESPONSIBLE FOR SAFE, PROPERLY MANAGED, CONSTRUCTION AND OPERATION OF THEIR NUCLEAR FACILITIES. WE MONITOR AND AUDIT THOSE ACTIVITIES BUT THE LICENSEE HAS THE PRIMARY RESPONSIBILITY OF ASSURING THAT PUBLIC HEALTH AND SAFETY ARE ADEQUATELY PROTECTED. THUS, IT IS ESSENTIAL l THE LICENSEE DEMONSTRATE IT CAN MANAGE ITS PROBLEMS.
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T CUESTION 42 (CONTfNUED) IF THE NRC WERE TO PARTICIPATE IN LICENSEE DECISIONMAKING, IT WOULD PLACE THE NRC IN THE UNDESIRABLE POSITION OF HAVING TO REVIEW AND PASS JUDGMENT ON ITS OWN PROPOSALS, REGARDING THE DEGREE OF NRC PAST INVOLVEMENT, SINCE 1980 THE NRC HAS CONTINUOUSLY INCREASED ITS MONITORING AND ENFORCEMENT ACTIVITIES AT TVA FACILITIES. NUMEROUS NRC ENFORCEMENT ACTIONS HAVE BEEN TAKEN AND THERE HAVE BEEN MANY MANAGEMENT MEETINGS AND DISCUSSIONS WITH TVA AIMED AT ACHIEVING IMPROVED TVA PERFORMANCE.
NRC REGION II AND HEADQUARTERS PERSONNEL FREQUENTLY ARE IN CONTACT WITH TVA TO DISCUSS THE ACCEPTABILITY OF TVA PROPOSALS. THE COMMISSION ITSELF HAS BEEN, AND WILL CONTINUE TO BE, KEPT ABREAST OF TVA'S PROGRESS.
GIVEN THAT TVA DID NOT MAKE IMMEDIATE SUFFICIENT IMPROVEMENTS AND CONSEQUENTLY SHUT DOWN ITS PLANTS, IT IS PROPER TO QUESTION WHETHER THE NRC COULD HAVE TAKEN MORE TIMELY AND AGGRESSIVE ACTIONS. IN RESPONSE TO THAT CONCERN, WE APE ANALYZING WAYS TO PROVIDE A MORE TIMELY REACTION TO PLANTS WITH MARGINAL AND DECLINING PERFORMANCE.
NRC PROGRAMS AND RESOURCES ARE NOT SUFFICIENT TO PREVENT PLANT SHUTDOWN DUE TO DECLINING LICENSEE PERFORMANCE AT OTHER FACILITIES. TRANSIENTS, INCIDENTS AND EVEN SOME MINOR ACCIDENTS, ALTHOUGH NOT CONDONED, WILL OCCUR AND MUST BE EXPECTED. NRC PROGRAMS ARE CONSTANTLY BEING MONITORED TO ENSURE THAT THOSE PROGRAMS MONITOR PERFORMANCE TO AN EXTENT THAT CORRECTIVE ACTION
QUESTION 42 (CONTINUED) l l
CAN BE CALLED FOR TO ENSURE MINIMAL MARGINS OF SAFETY IN PLANT DESIGN, CONSTRUCTION AND OPERATIONS, NEVERTHELESS, NRC PROGRAMS AND RESOURCES ARE CONSIDERED ADEQUATE TO PROVIDE REASONABLE ASSURANCETHATTHEPUBLICHEALTHANDSAFETYCANBEADEdUATELY PROTECTED. (ALSO SEE RESPONSE TO QUESTION 14B CONCERNING PLANT
' SHUTDOWN.)
COMMISSIONER ASSELSTINE HAS THE FOLLOWING COMMENTS:
TVA'S NUCLEAR MANAGEMENT BREAKDOWN REPRESENTS A FAILURE NOT'0NLY OF TVA'S NUCLEAR PROGRAM BUT ALSO OF NRC'S REGULATORY PROGRAM. AN EFFECTIVE REGULATORY PROGRAM SHOULD HAVE AS ONE OF ITS PRINCIPAL OBJECTIVES THE EARLY IDENTIFICATION AND CORRECTION OF SAFETY PROBLEMS BEFORE THEY RESULT IN SERIOUS OPERATING EVENTS OR OPERATIONAL DIFFICULTIES. NRC'S REGULATORY PROCESS CLEARLY HAS FAILED TO MEET THIS OBJECTIVE IN THE CASE OF TVA. WHEN THERE HAS BEEN WIDESPREAD MANAGEMENT FAILURE THROUGHOUT THE TVA NUCLEAR
) ORGANIZATION LEADING TO THE INDEFINITE SHUTDOWN OF ALL FIVE OF ITS OPERATING UNITS BECAUSE THE LICENSEE AND THE NRC LACK REASONABLE ASSURANCE THAT THOSE UNITS CAN BE OPERATED SAFELY, ONE CAN HARDLY ARGUE THAT THE NRC REGULATORY PROGRAM HELPED IDENTIFY AND CORRECT PROBLEMS IN A TIMELY MANNER.
EVEN IN THOSE CASES WHERE THE NRC IDENTIFIED PROBLEMS WITH TVA, THE AGENCY DID NOT CAREFULLY EVALUATE THE PROPOSED TVA CORRECTIVE PROGRAMS TO ENSURE THAT'THEY WERE ADEQUATE. FURTHER, THE NRC DID
- NOT FOLLOW UP ON AND MONITOR THE CORRECTIVE PROGRAMS TO ENSURE j THAT THE PROBLEM HAD REALLY BEEN SOLVED. THE AGENCY HAS ALSO
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l OVESTION 42 (CONTINUED) i FAILED TO UNDERSTAND THE ROOT CAUSES GF THE TVA PROBLEMS AND THUS, CORRECTIVE PROGRAMS OFTEN ADDRESSES ONLY THE SYMPTOMS AND IGNORED THE REAL PROBLEM.
I THE AGENCY HAS HAD SIGNIFICANT INFORMATION AVAILABLE TO IT FOR SEVERAL YEARS WHICH SHOULD HAVE ALERTED IT TO THE NATURE AND DEPTH OF TVA'S MANAGEMENT PROBLEMS. BUT, THIS INFORMATION WAS IGNORED AND WAS NOT COMMUNICATED UP THE MANAGEMENT CHAIN S0 THAT EFFECTIVE ACTION COULD BE TAKEN TO DEAL WITH THE SITUATION.
IF THE COMMISSION IS TO AVOID A REPETITION OF THE TVA REGULATORY FAILURE IN THE FUTURE, WE MUST DO SEVERAL THINGS:
- 1. WE MUST CONDUCT A CRITICAL AND OBJECTIVE EVALUATION OF THE REASONS FOR OUR PAST FAILURE TO ADEQUATELY REGULATE TVA.
- 2. WE MUST STRENGTHEN OUR REGULATORY PROGRAM IN THE AREA 0F l FAILURE EXPERIENCE BY TVA--MANAGMENET. ;
- 3. WE MUST DEVELOP MORE FORWARD-LOOKING REGULATORY INITIATIVES. THESE SHOULD BE AIMED AT IDENTIFYING i PROBLEM PLANTS EARLY ON, BEFORE THE OCCURRENCE OF A MAJOR MANAGEMENT BREAKDOWN LEADING TO AN EXTENDED PLANT A
SHUTDOWN.
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p QUESTION 42 (CONTINUED) !
'l AM NOT, HOWEVER, OPTIMISTIC ABOUT THE LIKELIHOOD OF SUCCESS IN THIS AREA FOR SEVERAL REASONS:
- 1. FORWARD-LOOKING PROGRAMS APE BEING CUT OUT, RATHER THAN EXPANDED, BECAUSE OF BUDGET REDUCTIONS.
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- 2. THE RC'HAS BEEN UNWILLING TO flECOGNIZE THE SIGNIFICANT CONTRIBUTION THAT UTILITY MANAGEMENT MAKES TO SAFETY.
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IN PROBLEM CASES, WHERf;', MANAGEMENT HAS OBVIOUSLY BEEN ,
THE CAUSE OF THE PROBL,EM, THE NRC HAS OFTEN BEEN UNWILLING TO DEAL WITH THIS ASPECT OF THE POOR PERFORMANCE, PREFERRING INSTEAD TO FOC'US ON HARDWARE I FIXES. l
- 3. THE NRC SEEMS TO BE RELUCTANT TO ADMIT THAT THE AGENCY HAS TO ACCEPT A PART OF THE RESPONSIBILITY FOR THE TVA FAILURES, GIVEN THIS RELUCTANCE, IT IS NOT CLEAR THAT f
THE NRC WILL--BE WILLING TO CONDUCT A FAIR AND CRITICAL *
.EVALUATI'0V 0F'ITS OWN PERFORMANCF AND TO DEVELOP i
" LESSONS LEARNED" SO AS NOT TP TEF AT THE SAME MISTAKES.
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