ML20205B098
| ML20205B098 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/1985 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20205B103 | List: |
| References | |
| FOIA-87-116, TASK-PINV, TASK-SE SECY-85-231, NUDOCS 8508010464 | |
| Download: ML20205B098 (55) | |
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POLICY ISSUE June 28, 1985 SECY-85-231 FOR:
The Commissioners FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
PROPOSED NRC ACTION WITH REGARD TO TVA PURPOSE:
To inform the Commission of the TVA's recent and long term performance deficiencies in several key areas related to management structure and controls.
To inform the Commission of the staff's long and short term review and evaluation plans for dealing with TVA's performance deficiencies.
To propose that the Commission meet with the TVA Board of Directors to express the seriousness of the NRC's concerns and to elicit from the Board their perceptions and commit-ment to an acceptable plan to correct management related problems.
DISCUSSION:
The staff is concerned about performance deficiencies at TVA's nuclear facilities as indicated by a sustained and consistent history of poor performance and from a number of t
more recent events at the facilities. is a brief review and discussion of major performance areas upon which the staff bases its concern.
While the discussion of these performance areas concen-trates on the negative aspects of licensee performance and does not present the positive aspects, long term and more recent deficiencies taken as a whole give cause for concern and should be brought to the attention of the Commission.
The management deficiencies are reflected in TVA's hand-ling of allegations and employee concerns, in past and I
recent enforcement actions, and in operational history of l
TVA facilities as indicated below.
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In late March and early April, a number of anonymous alle-gations regarding safety concerns and employee reprisals were received from TVA employees. -Most of the allegations involved construction quality issues at Watt's Bar and.the perception that TVA supervisors had either taken or would take adverse actions against those employees raising these
. concerns through the normal channels., Section 1, discusses the staff concerns arising from those recent allegations.
Although TVA has proposed a number of actions to deal better with employee concerns and allegations, the.
nature of the allegations themselves, and the degree to which the employees expressed fear of reprisals from TVA lead the staff to remain concerned about the adequacy of TVA's programs in this area.
In' the enforcement area, since May 1984, six escalated enforcement actions involving five proposed civil penalties and one Confirmatory Order were issued regarding activities at Browns Ferry.
An additional escalated enforcement action is pending for management control breakdowns asso-ciated with several recent events at Browns Ferry including I
overpressurization of the core spray system and inoperable water level instruments and improper operator action during a February 13, 1985 startup.
Licensee activities pertaining to a thimble tube ejection event at Sequoyah that occurred on April 19, 1984, resulted i
in a proposed Civil Penalty.
Also, at Sequoyah, circum-stances surrounding TVA actions regarding handling of quaTification issues of containment pressure transmitters were reviewed by the staff with respect to enforcement.
On June 17, 1985, an Order was issued to TVA directing a review and revision, where appropriate, of the licensee's i
procedures for timely evaluation of potentially significant non-conformance at its operating sites.
4 At Watts Bar, an enforcement action is pending for manage-ment control breakdowns associated with the Control Room Design Review.
Many of the problems identified above for specific TVA facilities also involve activities of off-site organiza-i l
tions.
In addition, a number of issues and problems have been identified with the licensee's Quality Assurance j
program and equipment qualification program; both involve support of off-site offices.
Thus, the enforcement his-tory, reviewed in greater detail in Section 3 of Enclosure 1, evidences problems which are not only site-specific but I
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are corporate wide.
From an enforcement history stand-point, the disproportionate magnitude of violations, the number and severity level of civil penalties, and the management related nature of the violations when compared to other utilities serves to highlight overall management weaknesses at TVA and to be further cause for concern about TVA perfornance.
TVA fares no better when the operations of its nuclear units are examined.
The performance history of TVA's facilities, particularly Browns Ferry, has been poor for the past several years.
This history is documented by a review of past SALP evaluations provided in Section 2 of, and.a review of operational history of TVA plants included as Section 4 of Enclosure 1.
The SALP review shows that TVA performance for Browns Ferry has been weak in six of the nine functional areas rated. The operational history review reveals that TVA has encoun-tered operational problems at a greater frequency than most other utilities'.
In short, TVA's nuclear operations have had a history of problems and little in the way of signifi-cant improvement over the years.
TVA's nuclear facilities are not significantly unique in design or complexity from contemporary light water reactor plants operated by the utility industry at large.
TVA's record of poor performance at its nuclear facilities, therefore, cannot be attributed to the type and design of the facilities it builds and operates.
Rather, its prob-lems appear to be management-related.
In this regard, Section 5 of Enclosure 1 compares the management expe,--
ience profiles, and management structure of TVA to two other utilities.
The staff believes the comparison shows the operating and nuclear experience of TVA management to fall short of that at other utilities.
This, along with the loss of eight high level managers with broad nuclear and operating experience over the last five years, may have contributed to the performance problems being encountered by TVA.
In any event, the staff believes that Enclesure 1 presents information that indicates that TVA's sustained record of performance problems is due to poor management and management controls.
This information is being sent to TVA for their comments and plans for resolution. contains the staff's long and short term plans for closely monitoring and evaluating TVA's performance and prospective corrective actions.
The short term plan is essentially a list of actions that allow the staff to
complete the licensing of Watts Bar Unit 1 and to evaluate various corrective measures prior to the restart of any Browns Ferry unit.
The licensee has verbally agreed that restart of any of the Browns Ferry units would not be per-formed until corrective actions are completed and appro-priate controls over operations are in place.
The
. licensee is performing an internal operational readiness review afterwhich Region II will assess their readiness to restart.
With respect to Sequoyah, the staff believes that the enforcement history and SALP ratings are not only signi'i-cantly better than Browns Ferry but are comparable to or above the Regional norm.
It is also noted that the SALP ratings have improved over the last two evaluations however, there have been a number of record problems.
The staff believes that strong site management may be a primary factor in this performance record.
Such performance has not been observed at Browns Ferry.
It is proposed that one element in the short term plan is for the Commission to meet with the TVA Board of Directors.
The staff believes this is necessary to express the scope and seriousness of the NRC's concern with TVA's performance and to elicit from the Board its perceptions, plans, and commitments for corrective measures.
Further, the staff believes that the Commission meeting should be held prior to the completion of the short term plan.
Such a meeting is consistent with the Commission's request to be involved in dealing with utilities whose overall performance is continually only marginal.
The staff has also developed a long term plan to closely l
monitor and evaluate the performance of the TVA nuclear program.
The plan is to be in place from the time the short term plan is implemented until the staff concludes that the long term corrective actions have been implemented and are successful in correcting TVA weaknesses.
The core of the plan involves a sequence of special per-formance assessments headee by a board consisting of the Director, NRR, Director IE, and the Region II Adminis-trator. This performance assessment process would supple-ment the normal Systematic Assessment of Licensee Perform-l l
ance (SALP) process.
An initial performance assessment for all TVA facilities and for overall utility nuclear func-tions will be conducted to establish a baseline for licen-l see performance.
Following the baseline assessment, l
followup assessments will be conducted at approximately six 1
month intervals.
The assessments will be structured such that they focus on major identified licensee weaknesses.
The long term plan is presented in Enclosure 2.
In sumary, from a review of certain specific problems at TVA, an evaluation of TVA's enforcement, SALP and nuclear operations histories, and a comparison of TVA's enforcement, SALP and operations histories to those of comparable utilities, the staff has concluded that TVA has exhibited, and continues to exhibit performance deficiencies in key Also, the staff concludes that r.ignificant overall areas.
improvement in performance has not taken place and that TVA's overall performance is only marginally satisfactory.
The staff believes that TVA's performance deficiencies are management related and that TVA's high level management must be made aware of the concerns over TVA's poor perfor-mance in nuclear operations.
The staff, therefore, proposes that the Commission meet with TVA's Board of Directors as soon as possible to convey the seriousness of the concerns over TVA's poor performance and to elicit from the Board its perceptions of the prob-lems and its commitments to formulate an acceptable plan to correct the deficiencies.
RECOMMENDATION:
The Commission meet with the TVA Board of Directors promptly to elicit TVA's plan for the corrections of its performance problems.
The staff further recommends that the Commission include in its discussions the following questions to the Board:
1.
What is their evaluation of TVA's continued poor performance; why hasn't it improved?
2.
What do they believe is necessary and what actions do they plan to enable TVA to develop an improved manage-ment structure and system of controls?
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(L;b,J.Dircks m
William Executive Director for Operations
Enclosures:
1.
Areas of Staff Concern 2.
NRC Short and Long Term Plans y
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Commissioners' comments or consent should be provided directly to the Office of the Secretary by c.o.b. Wednesday, July 17, 1985.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Wednesday, July 10, 1985, with an infor-mation copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
Commissioners OGC OPE OI OCA OIA OPA REGIONAL OFFICES EDO ELD ACRS ASLBP ASLAP SECY
9 9
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9 9
ENCLOSURE 1
ENCLOSURE 1 AREAS OF STAFF CONCERN This enclosure presents a n' umber of areas in which TVA as a whole, and selected sites in particular, are perceived by the NRC staff as showing performance problems.
Also, Section 5 of this enclosure contains information regarding the TVA managerial structure and experience levels.
- 1. 0 ALLEGATIONS AND TVA EMPLOYEE CONCERNS PROGRAM The NRC has received a number of allegations from TVA employees regarding a variety of issues surrounding quality assurance and control at TVA corporate offices and at the TVA nuclear sites.
Most of the allegations have been re-ceived anonymously through either a Congressional staff member or by anony-mous telephone calls to NRC headquarters staff members."The staff believes these allegations indicate a lack of confidence in TVA management.
Many allegers have claimed that TVA would take retaliatory actions if these concerns were expressed through the normal TVA process.
Also, several allegations were received asserting that TVA had taken intimidating or reprisal type actions against certain employees.
The allegations raise a number of questions and concerns.
First, some of the allegations themselves raise safety issues that must be reviewed and evaluated.
2 Second, because many of the allegations brought to the NRC reflect previously identified issues which had been resolved by TVA, questions arise about TVA's ability to resolve safety questions for themselves.
Third, because of the alleged reprisals and intimidations taken by TVA, the allegations raise ques-tion about TVA's overall philosophy and programs for dealing with employees while solving these safety concerns.
Based on these concerns, NRC has underway a number of actions.
Each allegation is being evaluated on its merits.
This has involved NRC staff headquarters and Region II efforts.
Also, the concerns have been sent to TVA for their evaluation.
TVA met with NRC staff management to review the apparent ineffectiveness of their employee concern program and to discuss the changes TVA would be making to improve the program.
Although TVA concluded that all concerns that were raised within TVA had been resolved acceptably, TVA proposed to improve the i'
employee concerns program through a number of actions.
i The staff recognizes that allegations from utility employees are not particu-larly unusual, especially for plants under construction.
However the nature of the allegations and the degree to which employees expressed fear of reprisals from TVA, lead the staff to remain concerned about the adequacy of TVA programs in this area.
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2.0 TVA SALP HISTORY The Tennessee Valley Authority (TVA) has five units in operation at two sites and four units under construction at two other sites which were included in the three previous SALP evaluations of management effectiveness.
At the beginning of the most recent appraisal period (1/1/83 - 2/29/84), all of the TVA sites had major weaknesses in certain areas.
Facility evaluations during the most recent SALP assessment period were as follows:
The Sequoyah facility had improved in overall performance with improvement noted in three functional areas.
Problems in emergency preparedness related to a weak organizational structure resulted in the rating decreas-ing from a Category 2 to a Category 3 in this functional area.
Quality assurance weaknesses stemming primarily from problems in the management of the offsite audit organization resulted in this functional area perfor-
.mance rating continuing to be rated as a Category 3.
The Watts Bar overall performance remained consistent from the previous SALP period with improvement in some areas but one major weakness was identified in support systems.
The Bellefonte overall performance improved slightly from the previous SALP period with improvement noted in three functional areas.
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Browns Ferry overall performance remained acceptable, although all of the areas identified in the previous SALP as having major weaknesses (plant operation, radiological concerns, maintenance, security and safeguards, and quality assurance) still had major weakness and still needed addi-tional management attention. Major weaknesses were also identified in refueling operations which required additional management attention. Based on continuing concerns as identified in the SALP process, TVA developed a Regul.atory Performance Improvement Program (RPIP) to address the problems and to focus increased management attention toward identifying and correct-ing the problems.
Increased Regional effort was expended to monitor the progress of the Regulatory Improvement Program.
A third resident inspector was assigned and a Regional supervisor conducted monthly on-site reviews of the licen-see's efforts to affect improvement in performance.
In addition, quar-terly meetings between senior Regional and licensee management were conducted.
In spite of increased attention by management, the performance at Browns Ferry improved only marginally.
It appears that the RIP is not significantly affecting performance as significantly as similar programs have at other Region II facilities (e.g., Brunswick, Grand Gulf and Turkey Point).
A review of the TVA SALP ratings history as indicated in the attached Table 1 shows only a moderate level of overall impi ivement at Sequoyah and Bellefonte with no overall improvement at Watts Bar.
In the case of Browns Ferry, overall
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5 performance downtrend was noted with failure to demonstrate significant improve-ment in any of the areas that had previously been judged to need additional management attention.
A review of the SALP ratings history of two utilities with a comparable nuclear commitment is shown in Table 2 and 3.
These tables indicate that the size of TVA need be neither a contributor to the low SALP ratings nor an inhibitor to improving many function area ratings to a category 2 or 1.
Figures 1 through 4 provide a summary of the number of Region II facilities that received a category 1, 2 or 3 rating in each of the same functional areas.
Comparison of the Region II facilities with TVA SALP HISTORY indicates that, as a utility, TVA has only one facility rating above average (Sequoyah), two facilities rating about average (Bellefonte and Watts Bar) and one facility rating below average (Browns Ferry).
Overall the staff considers that TVA's performance has been marginally satis-factory and has improved in some functional areas while remaining relatively weak in others.
Management involvement is marginally improving with some noticeable effect at Bellefonte, Sequoyah, and Watts Bar, while Browns Ferry has failed to demonstrate significant improvement in any of the functional areas indicating the continued need for a high level of NRC and TVA attention.
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3.0 REVIEW 0F ENFORCEMENT HISTORY A review of TVA enforcement history was performed focusing on management related violations and severity levels over the last' four years (July 1981 to.
June 1985).
A violation or deviation was designated as management related if it matched one of the following general areas:
Inadequate Control Systems / Procedures No Procedure available ('where appropriate to have one)
Quality Assurance Programmatic Problems Inadequate Evaluations Inadequate Design Inadequate Testing Procedures Inadequate Scheduling and Followup of Commitments Timeliness of Corrective Actions Recurring Violations 4
These areas were chosen to indicate programmatic review standards set by management for procedure quality, evaluation and implementation along with the utilities problem followup / resolution intensity.
Figure 5, 6, 8 and 9 compare TVA with only one other utility with a similar nuclear commitment in terms of number of units.
The large discrepancies in the quantitative values presented in these figures may not be as striking if a greater number of utilities were compared.
Figure 7 is an attempt to compare TVA. enforcement history at the site level to a greater number of utilities.
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7 Figure 5 compares the total number of violations at TVA facilities to that of a utility with comparable nuclear commitment.
TVA has received over one thousand violations in the past four years which is greater than twice as many violations as that received by the other_ utility.
Figure 6 provides the same total violations comparison on a unit basis.
Figure 6 also highlights the violation history for each TVA site / unit and denotes Browns Ferry as the weaker site in need of continued management attention.
Figure 7 shows the operations phase violations / utility / site and indicates that 4
TVA operating sites have received three times as many violations as the national average (23) and twice as many as the Region II average (35) during the period of September 1983 to February 1985.
The staff recognizes that this comparison, on a per site basis has a slisht bias against those sites with multiple units.
Nonetheless, we believe'this overall comparison is basically valid.
Figure 8 analyzes the civil penalty history of TVA and compares it to another utility of similar nuclear commitment.
Over the four year time period, TVA had 14 civil penalties with a total dollar value of $910,625 compared to four civil penalties with a dollar value of $134,000 for the other utility.
.I Figure 9 analyzes the civil penalty history of TVA and compares it to another large utility.
TVA has had 39.1 percent of its violations fall into one of the previously described management related areas while the other utility only had 20.7 percent.
The disproportionate magnitude of violations, number and severity level of civil penalties, and management related nature of the violations when compared to other utilities serves to highlight the overall management weakness.
8 4.0 TVA OPERATING EXPERIENCE The staff has performed a review of the operating histories of the Browns Ferry Units 1, 2 and 3 and Sequoyah Units 1 and 2 to determine how the types of events, and frequency of malfunctions reported compared to other plants.
The body of information examined included the precursor study, " Precursors to Potential Severe Core Damage Accidents:
1969-1979 and 1980-1981, hStatus
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Report", reactor trip and ESF actuation compilations from,the AE00 1984 Semi-Annual Reports and previous staff reviews, Abnorr.al Occurrences (NUREG/CR-0900) from 1980 through the third quarter 1984 and recent reports on operating events at TVA plants.
Several measures relating to operating experience for the TVA plants were then compared to those of several other plants of similar type and age.
The aim was to determine if TVA's operating facilities performed differ-ently.
The precursor study stated that two of the most significant incidents in nuclear power plant operating history have occurred at Browns Ferry, namely the fire at Browns Ferry Unit 1 (1975) and the partial scram at Unit 3 (1980).
While other BWRs of a similar age such as Brunswick Units 1 and 2 have had more precursor events, none were judged to have as significant an impact on core melt potential as the Browns Ferry Units 1 and 3 events.
The staff believes that the scram rates and the number of ESF (Engineered Safety Features) actuations are measures of plant reliability and performance.
9 The data on plant trips from 1980 to 1984 indicates that with the exception of 1984, the Browns Ferry units generally are above similar plants and the industry average in the number of automatic reactor trips (scrams) per year.
From 1980 through 1983, the Sequoyah units have demonstrated a scram rate approximately equal to the average for all PWRs.
However, in 1984, both Sequoyah Units 1 and 2 show a higher than average scram rate.
A review of ESF actuations from January 1, 1984 through June 30, 1984 indicates that the Sequoyah units have experienced a much higher number than comparable PWRs.
Similar high numbers of ESF actuations at Browns Ferry did not occur.
The large number of these actuations would indicate that the plant staff was not effectively diagnosing or correcting the causes.
A review of Abnormal Occurrences from 1980 through the third quarter 1984 indicated that two A0s were reported in 1984 at Browns Ferry Unit 1, none at the similar BWR plants.
In addition, very recently (1985) Browns Ferry experi-enced a significant event dealing with an anomaly in the reactor vessel water level instrumentation.
While other plants have reported two A0s, at Brunswick Units 1 and 2 (1981 and 1983) and Quad Cities Units 1 and 2 (1982 and 1983),
only Browns Ferry had two A0s in one year.
Civil penalties were levied for both Browns Ferry A0s.
Brunswick and Quad Cities each received a civil penalty for one of their two A0s.
Deficiencies in management were specifically identi-fied in one of the Brunswick and Quad Cities A0s.
10 No A0s have been reported at Sequoyah during its operating life.
However, the incore probe seal table leak event in 1984 has been identified as a significant concern involving a major breakdown in administrative controls which is under-going continued staff evaluation.
Of the other comparison PWRs, only Farley had an A0 reported (1982) and received a civil penalty.
An assessment of the A0 compilation does not indicate that either Browns Ferry or Sequoyah are very different from similar plants.
However, because both Browns Ferry A0s and the Sequoyah seal table event occurred in 1984, it is apparent that the TVA plants experienced greater operating difficulties of a significant nature that year than_in previous years.
No other utility has had this number of significant events in one year.
The staff notes that there have been a host of other operational events that have occurred at TVA plants that serve to further illustrate their operational problems.
These are briefly described in Table 4.
In summary, it appears TVA has encountered operational problems at a greater frequency than most other facilities.
5.0 Management Structure and Experience The NRC staff has developed an experience profile of TVA management by position and compared this TVA profile with the experience profile in similar positions in two other utilities that have a comparable nuclear cnmmitment.
These
11 comparisons are illustrated in Tables 5 thru 15.
These profiles generally indicate that even though TVA was an early leader in commitment to nuclear power, the current management both at " corporate" and at individual plants is weak in total nuclear experience and in actual operating experience in a nuclear plant.
Even though Regulatory Guides and ANSI Standards provide little guidance on management qualifications, the NRC staff is of the view that there is a relationship between plant performance and the nuclear operating experi-ence or background of key managers.
Corporate leaders with a strong nuclear background insure that enough key positions both at the plant and corporate have sufficient nuclear experience to be successful in the position, and to be able to use their personal experience in analyzing problems and making deci-sions.
During the past 5-6~ years, TVA has lost a number of key managers (eight)
(Assistant Plant Superintendent and above) with extensive nuclear and operating experience.
TVA has also lost a number of licensed reactor operator and SR0's to other utilities.
The key managers generally would meet the experience profile that we associate with an above average plant or utility.
As a result of private discussions with some of these individuals, we believe this loss of key personnel was due to a combination of salary limits and other fringe benefits as a result of being federal employees, and TVA previous policies which result in promotion of persons to middle and upper level management i
positions regardless of their nuclear experience profiles.
Past TVA policy that prevented onsite engineers from being licensed as R0/SR0's also appears to have contributed to the loss of personnel with nuclear experience.
Previously all R0 and SRO candidates were selected from nondegreed individuals.
12 A review of TVA organizational structure when compared with the other sample utilities indicates significant differences.
The two major differences involve span of control and assignment of essential technical support services such as engineering design and construction.
These technical support services are not an integral part of the line organization.
Accordingly, this support is not under line management's control.
It is not until the TVA structure reaches the senior vice president level (i.e., Manager, Power and Engineering) that all required technical services are centralized.
At this level the office func-tions include both nuclear and non nuclear activities.
This structure could be a prime factor in the apparent lack of timely response and effectiveness for resolution of potentially significant safety issues.
The staff notes that TVA has recently undertaken reorganizations at each of its operational sites (including Watts Bar) to effect more timely resolution of potential safety issues.
This action is essentially a decentralization of j
plant-specific engineering staff deemed necessary to support the operating staff.
TVA may not have yet had time to demonstrate this as a viable option to solve management's problem.
The staff is cautiously encouraged by this action.
TVA has initiated some policy changes that in time should correct the weak-nesses in nuclear and operating experience of some of the lower levels of management.
TVA has changed the salary structure for licensed R0's and SR0's to be competitive with the nuclear industry.
This has reduced turnover of this group.
They are slowly rebuilding their core of R0's and SR0's at Browns Ferry, but extensive overtime is still required during certain evolutions.
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13 Both Sequoyah and Watts Bar have a sufficient number of R0 and SR0's to meet work demands without relying an excessive overtime.
TVA has initiated a program that will result in.some Shift Technical Advisors (STA) and other engineers being licensed as an SRO, and be fully qualified as an assistant shift engineer.
The first small group is scheduled to complete this program in mid 1986.
A similar program is underway for current SR0's to obtain a degree.
Compensation for R0's and SR0's has been increased.
The total compensation of a few SR0's at Browns Ferry with overtime pay was on par with the Plant Manager's salary the last two years.
Salaries of middle level managers have also been increased, however, the limits on federal salaries continues to limit TVA's ability to competitively recruit and retain both middle and upper level managers
~for key positions.
In summary, while some efforts appear to have been made to improve TVA's lower level management recruitment and compensation, we believe there is a signifi-cant lack of nuclear operations experienced key managers and this deficiency could be a prime cause for the problems being encountered throughout the TVA organization.
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Rating Category Wa tts Ba r Bellefonte (SALP CYCLE)
III IV lil IV Soils and Foundation NR 1
NR NR Containment, etc.
NR 2
2 2-Piping Systems and Supports 2
2 3
2 Safety Related Components 2
NR 2
2 4
Support Systems 2
3 NR 2
i Elect. Power and Dist.
2 2
2 2
Inst. and Control Systems 2
NR 2
1 Licensing Activities 2
2 2
NR i
Quality Assurance Program 3
2 2
2 2
2 3
2 Preop / Construction Testing 4
Rating Category Browns Ferry Sequoyah i
(SALP CYCLE)
Il fil IV lit IV j
Plant Operations 3
3 3
2 2
i Radiological Controls 3
3 3
2 1
Maintenance 2
3 3
2 1
Surve I I I once 2
2 2
1 1
fire Protection 3
2 NR HR 1
Emergency Prepa redness NR 2
2 2
3 Security and Sareguards 2
3 3
3 2
2 1
Refueling 2
1 3
s Licensing Activities NR 2
2 2
2 Quali ty Assurance Program 2
3 3
3 3
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NR - Not Rated i
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TABLE 1
COMPARABLE UTILITY SALP HISTORY Rating Category Site 1 Site 2 (SALP CYCLE) 11
.Ill 1,V 11 Soils and Foundation NR NR NR NR Containment etc.
1 2
2 NR Piping Systems and Supports 2
1 2
1 Sarcty Related Components 2
NR -
NR NR Support Systems NR NR 2
2 Elect. Power Supply and Dist.
2 2
2 I
.I Inst, and Control Systems NR 2
2 1
Licensing Activities 2
2 2
2 Qua li ty Assurance Program 1
1 Ra ting Category Site 2 Site 3 (SALP CYCLE)
Il ill IV 11 Ill IV Plant Operations 2
1 3
2 2
1 Radiological Controls 1
1 2
2 2-2 Maintenance 1
1 2
1 1
1 Surveillance 1
2 2
2 3
1 Fire Protection 2
2 NR 2
NR NR J
1 1
1 2
1 Security and Sareguards 2
1 2
1 1
1 Rerueling 1
1 1
1 1
1 Licensing Activities 2
1 2
2,.2 2
i 2
2 Qua l i ty Assurance Program 2
1 4
NR - Not Rated i
I 4
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i TABLE 2-t
.1 COMPARADLE UTILITY sal.P 413 TORY i
Rating Category Sito 1
' Site 2 (SALP CYCLE)
Il 111 IV
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11 111 IV Solls and foundation NR NR NR NR NR NR Containment etc.
1
.2 2
2 2
2 Piping Systems and Supports 2
2 2
2 2
3 Safety Related Components 2
3 2
2 3
3 Support Systems NR 3
.2 2
3 2
Elect. Power Supply and Dist.
3 3
2 2
3 2
Inst. and Control Systems 2
NR 2
2 NR.
2 Licensing Activities 2
1 2
2 1
2 Qua li ty Assurance Program 2
3
-2 3
3 3
Preop /Const. Testing 2
3 3
NR 3
2 Envir. Proj./indep Measure NR 2
NR Radiological Cont.
2 2
2 NR 2
2 Reinspection Program NR NR 1
fire Protection NR NR 3
Security NR NR 2
Emergency Preparedness NR NR 2
Site 3 Site 4 (SALP CYCLE) 11 til IV 18 lit IV Plant operations 3
2 2
1 2
3 Radiological Controls 3
2 3
2 2
2 Maintenance 2
3 3
2 2
2 Surveillance 2
2 1
2 1
1 firo Protection 3
2 2
2 1
2 Emergency Prepa redness 1
2 1
2 2
1 Security and Safeguards 1
1 2
2 1
1 Refueling 1
1 1
1 1
.1 Licensing Activities 1
1 2
1 1
1 Quality Assurance Program 3
2 2
NR NR 2
4 Site 5 Site 6 (SALP CYCLE) il lil IV 11 til IV Plant Operations 2
2 2
NR 2
3 fladiological Controls 3
2 2
2 2
2 Maintenance 2
2 1
2 1
2 Survei l lance 2
2 2
3 3
2 firo Protection NR 2
2 2
2 2
t tmergency Preparedness 2
2 2
'2 2
2 Securi ty and Safegua rds 2
2 3
3 3
2 Refueling 1
1 1
NR 1
1 i
I.icensing Activities 2
2 1
NR 2
2 Qua l i ty Assurance Program NR NR 2
2 NR 2
Proope ra t iona l Test /SU Test NR 2
2 l
NR - Not Rated TABLE 3.
i
S ff TABLE 4-RECENT OPERATING EXPERIENCES Inspection Report Event Browns Ferry -
3 80-24 Inadequate heat transfer on straps for.
reactor level lines lead to erroneous
'~
indications.
' 80-32
-Failure of rods to fully insert o'n reactor scram-Unit 3.
80-35 Misoriented fuel bundles during operation.
81-28 Flooding of "A" RHRSW pump room.
81-14~
Primary leak Unit 3.
181-17 Personnel Overexposure.
82-23 Loss of Secondary Containment leads to all units shutdown, major problems found.
82-46 Unisolable feedwater leak, Unit 1.
83-02/82-48 Loss of shutdown cooling event.
83-05=
Reactor vessel head lifted during safety injection, drywell flooded with 44,000 gal, of primary coolant.
83-18 Fuel loaded in fuel racks that were not tested for boral.
83-27 Backup Control Center operability not verified since original construction.
82-40 IGSCC identified by inspectors; not the licensee, licensee had already completed inspections as satisfactory.
I 83-33 APRM gain adjustments made incorrectly, R factor out of spec.
83-36 Use of inadequately designed MSRV tailpipe vacuum relief valves during operation.
83-43/83-46 Failure of SDIV level switch due to inadequate design and surveillance.
2 Inspection Report Event 83-44 Personnel overexposure.
83-55 EECW/ Diesel generator HEX inadequate design.
84-02 Improper reactivity control, RSCS/RWM inoperable.
84-07 Non-conservative Kf factor in computer, used for MCPR calculations.
84-07 Both CAD systems inoperable, used for LOCA.
84-07 Failure of shutdown cooling suction valve, prevented cooling down reactor.
84-20 Cable separation problem; ADS /HPCI systems.
84-20 Diesel Generator parallel operation not possible due to inadequate design.
84-20 Shutdown board room cooling inadequate design during accident scenario.
84-34 Core spray overpressurization event.
85-13/85-15 Reactor water level problem - Unit 3.
84-45 RWM inoperable on startup, Unit 3.
84-52/84-53/85-15 Numerous limitorque valve failures.
85-06/85-12 HPCI valve inoperable; timing problem and PCIS valve inoperable for core spray system.
85-25 HPCI torus suction valve motor incorrectly wired.
85-21/85-26 Inadequate torus mods; hangars and supports and snubbers, Inadequate 79-02 and 79-14 inspections.
Massive re-work required.
Sequoyah -
84-24 Seal Table Event.
NRC ORDER Containment Pressure Transmitters.
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36 36 29 Vice President Construction 38 38 8
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42 35 12 Vice President Prod. Support h.
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36 36 18 Vice President Nuclear Prod."
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38 38 8
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18 18 18 15 yes
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11 4
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9 9
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NON-TVA ENFORCEMENT HISTORY ANALYSIS m ism - = ism h
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O ENCLOSURE 2
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ENCLOSURE 2 NRC SHORT AND LONG TERM PLANS General
.This enclosure presents the staff's short and long term plans in dealing with the questions surrounding TVA.
The short term plan is aimed at completing a number of fairly specific actions in order to complete the licensing of Watt's Bar Unit I and to evaluate various corrective measures prior to the restart of Browns Ferry.
The long term plan is aimed at performing a more integrated and broader evaluation of TVA and at following the corrective actions of TVA to ensure they are properly implemented and the performance is improved.
Short Term Plan The short term plan items. listed below and the associated dates may change subject to ongoing evaluations or new information.
I.
Watts Bar (Licensina) (Lead NRC Manager:
Hugh Thompson)
A.
Routine Licensing / Inspection Activities 1.
Complete resolution of remaining SER and Tech Spec issues 07/12/85 t
2 2.
Resolve 94300 letter issues that must
-be complete prior to fuel load Week of 07/29/85 3.
RII complete inspection of sis for Modes 5 and 6 Week of 07/22/85 B.
Allegation 1.
TVA/NRC meet with ACRS subcommittee on Quality and Quality Assurance in Design and Construction 06/26/85 (Complete) 2.
'!VA/NRC meet with ACRS full committee 07/12/85 3.
Dedicated review group complete review of Watts Bar IDVP 07/19/85 4.
NRC completes evaluation of allegations that require resolution prior to fuel load 07/19/85 (other items will be complete prior to FP license)
C.
TVA Employee Concern Program (ECP) 1.
TVA/NRC meet to discuss status of ECP findings 07/18 or 07/19/85
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NRC determines adequacy _of implementation of the enhanced program 07/19/85 D.
Decision on low power license issuance based on review of A, B, and C supporting a basis for low power licensing.-
T80 II.
Browns Ferry (Lead NRC Manager:
Nelson Grace)
A.
RII conduct operational readiness inspection and determine acceptability of return to power with augmented shift staffing.
mid-July 1985 B.
NRC complete assessment re: NSRS HPCI' evaluation (and transmit followup reply (to Commission) to Udall letter) 06/17/85 (Done)
C.
Escalated enforcement on management control (Maintenance and surveillance) early-July III. Commirsion meet with TVA Board of Directors to discuss staff's perception of TVA continued marginal performance.
4 TVA Long Term Plan I.
Introduction.
The staff has conducted an overall evaluation of TVA's performance and concludes that as a utility with four different nuclear sites (two in operation and two under construction), the overall performanc'e has been only minimally satisfactory.
This conclusion is based on the information contained in Enclosure 1 of this paper.
The staff's long term plan is-described below.
Unlike the short term plan, the long term plan is aimed at a broad based, more in depth analysis of utility as well as site specific weaknesses identified in or coming from Enclosure 1.
The long term plan is intended to closely monitor and evaluate the performance of the TVA nuclear program.
The plan is to be in
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effect until the staff concludes that the TVA weaknesses have been success-fully corrected.
C II.
General Description Review of TVA's performance history has shown significant weaknesses that involve all sites and headquarters functions in five key areas.
These areas are:
1)
Handling of employee concerns 2)
QA program implementation
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3)
Management controi of headquarters activities, 4)
Corrective action systems j
5)
Control of operating activities
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To address the above generic and specific site problems, the long term plan outlines a variety of staff actions.
These actions include the detailing of additional staff resources to supplement ongoing programs to provide more indepth evaluation of the above areas.
Also, the actions include a sequence of special performance assessments.
These performance assessments would supplement the normal Systematic Assessment of Licensee
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Performance (SALP) process.
Details of the plan are provided in the following paragraphs.
III. Plan Description
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A.
Special Program Evaluation Activities t
The major resource for theis evaluation will be through ongoing i
licensing and inspection activities. To supplement these activities, special staff attention is planned for the five key areas where significant weaknesses have been identified. Special staff attention is planned as follows:
6 1.
Handling of Employee Concerns Assessment of the quality of the TVA program to address its employee's concerns, including protection from harrassment, reprisal or other actions.
The assessment will include evaluations of the enhanced TVA program along with the NSRS report evaluating the TVA Employee Concern Program.
2.
0A Program Implementation The TVA QA organizational effectiveness following recent changes will be evaluated in detail.
The MAC report on overall QA at TVA and TVA's followup will be reviewed, along with an assess-ment of the various QA organizations within TVA and the clarity of their various roles and responsibilities.
3.
Management Control of Headquarters Activities The overall effectiveness of TVA utility management will be the subject of a special evaluation.
The review should include any available assessment., or other relevant reviews.
PAT reviews can be factored in, as appropriate.
The results of the recent Sequoyah pressure transmitter evaluation should be considered since it was found that managerial breakdowns of a headquarters office occurred.
Also, the plant operations experience of all off-site managers should be assessed.
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4.
Corrective Action Systems The utility programs for timely resolution of problems will be the subject of special evaluations.
For example, the TVA Equipment Qualification and Fire Protection programs will be assessed.
5.
Control of Operating Activities The routine inspection programs focus substantial resources in this area as a matter of practice.
This effort will be supplemented by a readiness inspection at Browns Ferry prior to plant restart and special inspection attention to analysis and onsite followup of events.
B.
Special Performance Assessment Process The normal SALP process focuses on site performance in selected areas and provides only a general evaluation of overall utility performance.
The special performance assessment process will con-tinue to evaluate individual site performance.
However, special emphasis will be directed at evaluation of areas of overall utility performance.
The major elements of the special performance assess-ment process include:
8 1.
Expedited completion of a baseline assessment.
The assessment will include evaluation of the site functional areas in accor-dance with the normal SALP process plus the special program evaluations identified in Item III, above.
2.
Following completion of the baseline assessment, conduct of special assessments at a frequency of every six months.
The short time interval is considered necessary to provide respon-sive feedback to the licensee and NRC for necessary program adjustments.
3.
The SALP boards will be formed by regional and headquarters management.
The results of the assessments will be presented to a Senior NRC Executive Board consisting of the Director, NRR (Chairman), IE, and Region II.
The Senior Executive Board
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will provide the capability for expedited response to any significant issues identified.
IV.
Coordination / Schedule The long term plan involves a number of NRC offices.
Significant Region II input will be relied on for assessing the licensee's performance. Other NRC offices will also be required to provide assessments.
Since the ED0 has directed that the Director of NRR take the lead in the TVA assessment, NRR will be the central coordinator for the long term plan.
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-To support the individual detailed evaluations, senior NRC managers familiar with the particular evaluation areas will be assigned respon-sibility for assuring actions necessary to support the plan are implemen-ted.
Region II will be responsible for coordinating the special performance assessment, which is vital in support of the long term plan.
Overall, the long term plan'should take 18-24 months to complete.
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