ML20211P056

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Transcript of Commission 861216 Meeting in Washington,Dc Re Briefing on Status of Tva.Pp 1-66.Supporting Documentation Encl
ML20211P056
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Issue date: 12/16/1986
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NRC COMMISSION (OCM)
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REF-10CFR9.7 NUDOCS 8612180376
Download: ML20211P056 (103)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:

COMMISSION MEETING Briefing on Status of TVA l

(Public Meeting) l Docket No.

Location:

Washington, D.

C.

Date:

Tuesday, December 16, 1986 Pages:

1 - sc 861218o376 861216 PDR 10CFR PDR PT9.7 ANN RILEY & ASSOCIATES Court Reporters 1625 I St., N.W.

Suite 921 Washington, D.C.

20006 (202) 293-3950

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D I SCLA I MER 2

3 4

5 6

This is an unofficial transcript of a meeting of the N

7 United States Nuclear Regulatory Commission held on 8

12/16/86 In the Commission's office at 1717 H Street, 9

'ti. W., Washington, D.C.

The meeting was open to public 10 attendance and observation.

This transcript has not been 11 reviewed, corrected, or edited, and it may contain

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12 inaccuracies.

13 The transcript is intended solely for general 14 informational purposes.

As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the 16 matters discussed.

Expressions of opinion in this transcript 17 do not necessarily reflect final determination or beliefs.

No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorire.

23 24 25

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UNITED STATES OF AMERICA l

2 NUCLEAR REGULATORY COMMISSION 3

4 BRIEFING ON STATUS OF TVA 5

6 PUBLIC MEETING 7

8 Nuclear Regulatory Commission 9

Room 1130 10 1717 H Street, Northwest 11 Washington, D.C.

12 13 Tuesday, December 16, 1986 14 15 The Commission met in open session, pursuant to 16 notice, at 9:36 a.m., the Honorable LANDO W. ZECH, JR.,

17 Chairman of the Commission, presiding.

18 19 COMMISSIONERS PRESENT:

20 LANDO W. ZECH, JR., Chairman of the Commission 21 THOMAS M. ROBERTS, Member of the Commission 22 JAMES K. ASSELSTINE, Member of the Commission 22 FREDERICK M. BERNTHAL, Member of the Commission 24 KENNETH M. CARR, Member of the Commission 25

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STAFF AND PRESENTERS SEATED AT TABLE:

2 3

V. STELLO 4

S. CHILK 5

W. PARLER 6

HUGH THOMPSON 7

GARY ZECH 8

BEN HAYES 9

H. DENTON 10 11 12 13 14 15 16 l

l 17 18 19 20 21 22 23 24 25

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PROCEEDINGS 2

[9:36 a.m.]

3 CHAIRMAN ZECH:

Good morning, ladies and gentlemen.

4 Commissioner Bernthal will be joining us shortly.

5 The purpose of today's meeting is to hear from the 6

staff regarding the status of TVA and the staff actions regarding TVA activities, as well as to discuss the 7

8 preliminary NRC lessons learned from the TVA situation report.

9 Regarding the status of TVA, we are interested to j

10 learn from the staff in your view is TVA making progress.

11 Regarding the NRC actions, I believe it is important for the 4

12 staff to address where you see NRC now regarding our review 13 and approval of TVA issues.

Is NRC on a critical path for any 14 issues, and if so, what steps can be taken or are we taking, 15 and are we taking sufficiently aggressive regulatory action at 16 this time and can we be doing more?

17 Those are the things that I think are of primary 18 importance for this morning's discussion.

This is a 19 discussion and a briefing and not a voting day.

Immediately 20 after the open meeting, the Commission will be briefed by the 21 Office of Investigations and the Office of Inspection and 22 Audit on TVA in a closed session.

23 We have a lot to cover this morning.

I would hope 24 that we could conclude this first session at 10:45, if 25 possible.

I understand that slides for the briefing and

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lessons learned from the TVA situation report are available in 2

the back of the room.

3 Do any of my fellow commissioners have any opening 4

remarks?

5 COMMISSIONER ASSELSTINE:

Just a couple, Lando.

I 6

agree with you that I think the fundamental question today is 7

are we really making progress with TVA.

I guess just to 8

sharpen up the question a little bit, when I look back over at 9

the things that have occurred over the past year or so, I have 10 some real concerns about how much progress we really are 11 making, and I would like to mention just a few of them to sort 12 of focus the staff's discussion.

4 13 When I look back over the past year, first we have 14 got the February 1985 TVA certification on Watts Bar l

15 completion.

The staff has told us this past year that in fact i

16 that statement was a material false statement, but I don't 17 think we yet know who was involved in it, how the decisions 1

18 were made and whether that was a deliberate false statement or 19 not.

i 20 Just about a year ago, we were told by TVA's Nuclear i

21 Safety Review Staff that there was a pervasive breakdown in 22 quality assurance in the construction of the Watts Bar plant, 23 listing a whole series of areas where there were QA problems.

l 24 I think except for some areas of welding, where the staff has 25 concluded there was a breakdown, the staff is still unable to I

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say whether there was a breakdown in these other areas or not.

2 In the welding area, TVA testified before the 3

Congress that their program was basically complete and that 4

there weren't any significant deficiencies.

When our staff 5

testified after that that there were significant deficiencies 6

in the welding area, TVA's director of nuclear power came up 7

here and met privately with the Commission and criticized the 8

staff's testimony.

It turned out that the staff was right, 9

and not only was the staff right, but they were right based on 1

10 TVA's own internal analysis.

11 It seems to me over the past year or so that TVA has 12 often been more interested in justifying its pa7t positions 13 than in finding and correcting problems, and I think the 14 welding area is a good example of that.

Our Director of 15 Inspection and Enforcement had to take pictures of welding 16 problems in some of the TVA plants to show to the TVA people that in fact there were significant problems in the welding 17 18 area, and I think the platform in the cable spreading room is 19 a good example of that.

20 on intimidation and harassment, the staff tells us

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21 that there are still continuing problems at TVA with 22 intimidation and harassment. In fact, in a transcript of a 23 recent meeting between the staff management and TVA I

24 management, it was pointed out that there is still a sizable 25 portion of TVA employees who are still to this day afraid to i

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come forward with safety concerns for fear of intimidation and 2

harassment.

3 As far as I can tell, TVA's inspector general hasn't 4

closed out the old intimidation and harassment cases, let 5

alone started to deal with some of the new ones.

I think 6

there are also some questions about the performance of TVA's 7

inspector general based upon their report on the conflict of interest questions that have arisen over the past year or so.

8 9

Almost a year ago, TVA promised us that they would 10 give us cooperation on the technical issues and that they 11 would identify people in each area who would be responsible 12 and accountable for making commitments to us and for providing 13 the information we needed to do our job, and yet when I look 14 over the past year, there have been repeated concerns 15 expressed by the staff on the quality of information we are 16 getting from TVA, TVA's cancelled meetings at the last 17 minute.

It doesn't seem to me that that kind of cooperation 18 that was promised almost a year ago has been delivered in 1

19 many instances, 20 In environmental qualification, one area where it 21 seemed that TVA did have an aggressive program, it now turns 22 out that they failed to identify the fact that they were 23 substituting commercial grade equipment for qualified 24 equipment without doing an analysis of the problem.

25 Those are just a few of the areas where it seems to i

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1 me we have encountered some substantial difficulties over the 2

past year, and at least it raises in my own mind real 3

questions about whether we are really making progress with 4

this organization.

In fact, if anything is constant, it seems 5

to be TVA's effort to continually set up schedules for when 6

they are going to be ready to restart the plants without doing 7

the hard work that is necessary to really address the issues.

8 I think our staff is to be commended over the.past 9

year for making a tough and aggressive effort to try and get 10 the kind of cooperation we need, and I think the November 18th 11 meeting the staff had with TVA's management is a good example 12 of that.

That is a tough, hard-hitting meeting, and I think 13 it reflects some of the frustrations the staff has felt over 14 the past year.

15 I guess I would sort of identify those items as a 16 backdrop to look at this question'of are we really making 17 progress.

That is all I have.

18 CHAIRMAN ZECH:

Any other comments?

If not, please 19 proceed.

20 MR. STELLO:

Thank you, Mr. Chairman.

21 In December, 1985, the Staff asked the Commission to 22 keep them apprised of the activities associated with our 23 review of TVA and to provide you with periodic reports.

We 24 have done that on a schedule of about every two to three 25 months.

The last one was issued to the Commission last week.

s 1

Our last meeting with the Commission was in June, 2

and what we're prepared to do today is to go through and give 3

you a briefing of our understanding of where TVA, the status 4

of the plant, when we expect -- if you will -- a pinch to come 5

in the review process, in direct response to your question.

6 It probably will not be unusual for our review to 7

culminate in a rather intense need for a lot of inspection and 8

activity as the real date for the startup approaches.

We anticipate that that will happen and will do everything in our 9

10 power not to be on the critical path when that time comes.

11 As far as today is concerned, we are not on the 12 critical path and we are mindful that as things move forward 13 and we have an awful lot to accomplish in a short time, and 14 then expect that we will be able to perform those reviews and 15 have a view as to whether it's okay or not, will be fairly 16 intense.

We recognize that and will do everything we can to 17 assure we're prepared to respond as necessary.

18 We also, today, would like to give you a view of 19 lessons learned.

Let me emphasize we're not finished.

It's 20 preliminary and what we would like the commission to focus on 21 is the point that I made of the need to go out and ask others i

22 that we have not had comment on this report, and get their l

23 insights, who are no longer of either NRC or members of TVA.

i 24 I think it's very important to do that, to be able to ask them 25 to look at hcw we viewed things that unfolded at TVA, to i

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really have a better understanding and a better picture of all 2

of the lessons that we've learned.

3 With the commission's permission, I would like to 4

send letters to those kinds of individuals, and have them 5

review the report and provide us whatever comments and views 6

as they see it, reflecting their understanding of what 7

transpired at TVA.

And if the Commission can agree, I can 8

move forward, 9

But we will give you our preliminary view of those 10 lessons learned.

11 I'll ask others to be mindful of the comments you 12 made in asking the question of whether or not we are in the 13 critical path.

Is there more we can do and is real progress 14 being made?

15 And with that, I'll turn it over to Mr. Denton and 16 ask each of the members of the team here, as they respond, to 17 try to deal with that question because it is a very difficult 18 question and one we have to be mindful of, to do whatever we 19 can and not let us be the bottleneck in the process.

20 MR. DENTON:

Thank you.

21 Hugh Thompson will make the presentation today for 1

22 the senior management team.

The members of the senior 23 management team have been devoting about 20 percent of their i

time to this project for some time now, so it's receiving a 24 j

25 lot of high level management attention.

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With regard to progress, however that's defined, 2

we're really being paced by what TVA does.

TVA implements 3

their programs and we're attempting to do a thorough, 4

objective, independent review of the adequacy of their 5

programs.. And when they move forward in an area, we're ready 6

to move forward with them.

I don't think we're on the 7

critical path for any items to date.

I would think as some 8

issues come, as the plants get closer to some of their 9

schedules, it's going to be a real crunch for us to keep up 10 with it, but at the moment, today, we're not on the critical 11 path.

12 The key will be TVA's effective implementation of 13 the programs that they have underway.

There are a lot of 14 issues here.

There are technical issues, there are 15 wrong-doing issues, there are judgment issues.

We're meeting 16 a lot with all levels in TVA.

As you know, the management of 17 TVA is in a state of flux.

It's changing.

And that's why the 18 senior management team met about a month ago with TVA in 19 Chattanooga.

20 The general manager of TVA was there and we covered 21 a great deal of these issues, of the same kind that you are 22 raising.

So Hugh will give a report and we members of the 23 team will participate as needed.

Hugh?

24 MR. THOMPSON:

Thank you, Harold.

25 could I have the first slide?

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[ Slide.)

2 MR. THOMPSON:

As we said, we will focus the 3

briefing on two major areas.

One is the status of the reviews 4

on the corporate, Sequoyah, Watts Bar, and give you an update 5

on our interactions with the TVA's inspector general and with i

6 respect to, also, our interaction with concerned individuals.

7 The preliminary lessons learned, which is SECY a

8 86-334, has been down to the Commission and we will try to 9

address each of those in the time provided.

Again, that is a j

10 report that has been sent out to the Staff to develop 11 priorities and implementation activities and reporting back to 12 Mr. Stello on those activities.

13 TVA has announced a schedule for Sequoyah Unit 2, 14 which is their first unit to restart, which they are 15 projecting in the spring of 1987.

This is a tight schedule 4

16 for TVA to be able to meet it.

They would be fairly much on 17 the critical path in a number of areas, such as employee j

18 concerns and EQ, which we will identify in the briefing.

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19 Unit 1 they project to be starting some three to 8

l 20 four months later.

TVA does not have a detailed schedule to l

21 support that three to four months.

There may be issues that 22 would come up in a detailed review of that effort to restart 23 Unit 1 which might change that date.

4 24 TVA has announced that Browns Ferry Unit 2 would be 25 the unit that would start after the Sequoyah units and it will

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probably start sometime later in 1987.

They, by putting the 2

focus on Browns Ferry and Sequoyah, I don't expect the Watts 3

Bar to be ready to license until 1988, and I don't think they 4

really have a good schedule for that at all, right now.

5 COMMISSIONER ASSELSTINE:

Hugh, based upon what 6

you've seen this year, in terms of products from TVA, getting 7

the technical information to you, is there any reason to 8

believe that they're going to be able to meet those schedules 9

or -- if they do meet them -- is it likely that what's going 10 to happen is that you're going to get a lot of material dumped 11 on you at the very last minute?

It's already December.

12 MR. THOMPSON:

We are now receiving what I would 13 consider the first phase of the dump, in that we are getting a 14 significant number of the employee concerns element reports 15 for review.

We probably received 50 in the last two weeks or 16 so, and that's a significant workload on the Staff.

We're 17 meeting this afternoon with them to provide some initial 18 feedback on what our reviews are.

19 Generally, there are two, that they have given us 20 the ones that are a little easier to address because they're 21 coming out of the pipeline first.

And secondly, there are 22 some of those reports where we believe they should be better 23 articulating their implementation programs and we'll look at 24 those.

25 So we do have feedback, we're trying to give them

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feedback as soon as we can.

But I would say, from my 2

discussions with the Staff, they find that the reports are 3

generally acceptable.

That is, they are -- we're satisfied 4

with the programs and it's as much our watching their 5

implementation -- it's been an area where we tended to focus 6

on as much as we did the programs -- we're focusing on the 7

implementation.

8 I believe it is reasonable to expect a plant that 9

will be ready to start sometime in the spring, as they 10 implement their programs as they've stated so far.

Whether 11 it's April, I'm not prepared to say.

l 12 CHAIRMAN ZECH:

Let me just make a comment here, 13 too.

It seems to me that we have experienced continual 14 delays in receiving what would appear to me to be adequate 15 information from TVA.

And so I would say that those restart 16 dates would seem, to me, to have to be somewhat in question.

4 17 Also, there's more -- this is a very large and complex 18 problem, involving corporate issues as well as specific plant 19 issues.

And as I think that we all recognize, some of those 20 corporate issues certainly have to be resolved to -- I would 21 think -- the Staff's satisfaction and the Commission's 22 satisfaction before we can proceed.

23 So we're talking about rather serious management and 24 corporate issues that are not insignificant, in my view.

25 They're very important.

So I think it's not really realistic

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to consider an isolation of Sequoyah or any of the plants.

We 2

simply must, in my view, include the whole of the TVA 3

situation.

And therefore, I think that that's something that 4

has to be rather foremost as we look at any schedule.

At 5

least, I think we must be satisfied, all of us in this agency, 6

that the problems have been resolved before we're going to 7

proceed.

8 And I think there's a lot of them to be resolved.

9 MR. THOMPSON:

Yes, sir.

I certainly agree with 10 that and the Staff is looking, and expects to complete its 11 review both of the corporate nuclear performance plan and the 12 Sequoyah performance plan before we would be prepared to 13 recommend any restart activities.

14 If we can turn to the corporate performance area, 15 TVA has made a number of important realignments in their 16 corporate management, in response to the office of Government 17 Ethics over the conflict of interest concern.

They have 18 revised the nuclear performance plan the first of December, to 19 identify these changes.

20 And essentially, it is an effort to eliminate 21 contract managers from supervising their own employees from 22 their own parent company.

And as a result of this, it shifts 23 some of the loaned managers to non-supervisory advisory 24 positions.

25 In addition, TVA has added three assistant managers

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as an important part of this realignment, one for operations, 2

an assistant manager for engineering and construction,'and an 3

assistant manager for administrative support.

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4 COMMISSIONER ROBERTS:

Were these people pronoted 5

form within or brought in?

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6 MR. THOMPSON:

These people, essentially, were 7

promoted from within.

Bill Caudill is the assistant manager l 8

for operations.

Charlie Fox, who was at TVA but had only been

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9 there a short period of time, came in from the Department of

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10 Energy activities at Savannah River.

He formerly worked on-11 the Clinch River Breeder project.

He has been brought in as 12 the manager, assistant manager for engineering and t

13 construction.

So he is not'a long-term TVA employee.

And 14 Larry Jackson, I believe, is the administrative support area.

15 As you know, Steve White has been on administrative 16 leave for the past two months, with Chuck Mason fulfilling the 17 role of acting manager of nuclear power.

Th$s has delayed;a 18 number of TVA submittals, due to lack of understanding of'fhat 19 role Steve White was going to playJ TVA has moved forward' and 20 has made some submittals which may need tc be resolved or

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21 revised, if Steve White is not satisfied that those are the 22 organizational changes that he wants to work with.

23 CHAIRMAN ZECH:

When has TVA informed you as to when 24 they expect the situation to be resolved?

25 MR. THOMPSON:

I believe we were informed on

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November 18th, it's next week.

And then the following -- it's 2

always next week.

The last information I had was that they 3

had met with Steve White over the weekend or last Friday and 4

had provided -- TVA gave Steve White a proposal on a contract 5

and had discussed all issues that remained before them.

And 6

he is considering that proposal now.

And they believe he 7

will, again, make a decision before the end of this week.

8 The proposed realignment does have some issues that 9

we have addressed with the TVA management at Chattanooga on 10 the 18th.

And one is they placed some individuals in TVA into l

11 key positions earlier than their original proposal would have 12 them. TVA had not been able to complete their management 13 training and development program.

And we met with Chuck Mason 14 and his acting TVA managers, so that we would have an 15 opportunity to see them and discuss with them their efforts to 16 be effective in their new roles and to understand how they 17 were going to use the new advisors.

18 We stressed, again, the concern that we have that 19 implementation of the program is a key element.

The new 20 program does reduce the span of control, that was an issue in 21 the earlier organization, from about 20 or so to about 10 with J

l 22 the assistant managers in there.

23 Our future action in this area, of course, is to 24 review the existing submittal that they have given us, to 25 ensure that it's adequate to address our concerns.

Also, to

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look at the QA program and the QA topical that we have.

2 But the key, again, is assessing the effectiveness 3

of TVA in implementing that program. And I think, 4

Mr. Chairman, it goes to your point.

That is a very difficult 5

area.

When we met with TVA management, we recognized that 6

they are facing a fairly big challenge.

And of course, if you 7

looked at the area we are most concerned about is QA.

They 8

have an acting manager in QA.

It's been a program that has 9

not been successful in the past, and is a key one in a key 10 program that we'll vant to make sure that not only the QA 11 program but the line organization supports the QA program in 12 the future.

13 COMMISSIONER CARR:

Would you say those words about 14 span of control again, I think I misunderstood you?

15 MR. THOMPSON:

The span of control issue that the 16 Staff had originally, when Steve White had his proposal, had 17 abcut 25 to 26 people reporting directly to Steve White.

18 Chuck Mason, in running the organization, has established 19 three new positions and these are assistant managers.

And he's reduced the number of people reporting directly to him, 20

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21 from about 25 to about 10.

So the span of control has been 22 reduced, in that the number of people directly reporting to 23 the manager of nuclear power is about 10 instead of about 25.

t 24 COMMISSIONER ASSELSTINE:

Is that an improvement?

25 COMMISSIONER CARR:

At the expense of a layer of

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management?

2 MR. THOMPSON:

At the expense of adding managers.

3 And the Staff believes that is an improvement over the earlier 4

version.

5 COMMISSIONER ASSELSTINE:

Hugh, on the QA point, I 6

agree with your comments about the problems in QA.

If I could go back in time, all the way back to the Browns Ferry fire for 7

8 comments and criticisms of TVA on its commitment and 9

implementation of Quality Assurance.

Why isn't it a fair test 10 of this new management team, to take a hard look at who TVA 11 comes up with for its QA director and how effective that 12 person is, in carrying out his responsibilities?

And do you 13 yet see a strong and effective and capable manager in Quality 14 Assurance that would demonstrate TVA's strong commitment, 15 finally, to having an effective QA program?

16 Do you think their QA program, how it is going now, 17 is a fair test of whether they really are facing up to their 18 problems and dealing with them effectively, and second, do you 19 see the kind of strong and effective leader in the QA job j

20 right now that would demonstrate that TVA really does 21 understand the importance of quality assurance, the pitfalls 22 that they have fallen into in the past, and a strong 23 commitment to effective quality assurance in the future?

24 MR. DENTON:

I think we are still looking for 25 performance in that area.

Everyone recognizes it's

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importance.

The person there says all of the right words, but 2

whether he will be more effective than managers in the past, I 3

think it is still an open question.

Obviously, it's a key l

4 area.

The trouble with all of these judgments of management 5

performance, you have to see them in the job to test, so we 6

are waiting to see what will come out.

7 MR. THOMPSON:

I would say we are certainly 8

sensitive to that area.

Was have identified some concerns on 9

our part to TVA over their selection of individuals in that 10 area and we have discussed that with them as a key element, so 11 I think it's a fair test and again, their ability to hire and 12 select people for this area has been a difficult one in the 13 past.

It's one where I think we are doubly cautious about 14 proving this area before allowing and recommending re-start.

15 (Whereupon, Commissioner Bernthal entered the room 16 at 10:00 a.m.]

17 MR. THOMPSON:

If I could move on to the Sequoyah --

18 I would like to address four of the key issues in Sequoyah.

19 The first one is the employee concerns and we have been 20 working with auditing and reviewing and inspecting TVA's 21 program and approach in this area and we found it to be 22 acceptable.

23 They have about 300 element reports covering over 24 700 concerns, which are going to be submitted to NRC, and we 25 get them in two phases.

We get an initial report and then we

6 20 1

will get a final report which would include the corrective 2

action, if any, that is proposed and approvsd by the line 3

organization.

4 To date, we have received about 100, a little over 5

150 initial reports, and we have received about 100 final 6

reports.

That's what we are~ meeting with them on.

7 The major arcas that they have completed are areas 8

of construction and operational category.

We believe the 9

pacing items are engineering, the NSRS issues and QA, and most 10 of the reports in these areas have not been submitted.

11 Earlier, we received a preliminary report on a 12 ccncern about the traceability of safety material for small 13 bore piping, based on the TVA efforts to date, they would have 14 a report in, submitted to us, in that area about the 29th of 15 December.

It's been a rather confusing one, about what the 16 code of record is for the material control.

TVA has hired 17 some outside experts to clarify that issue and the informal 18 understanding I have now is they feel comfortable that issue 19 will be adequately resolved without a major problem.

20 We expect to receive most of the element reports by 21 the end of this month with some in the engineering area to go 22 out the middle of January.

Again, to date, most of the 23 element reports have been found to be acceptable.

That is 24 they are addressing the issues reasonably well as we are able i

25 to define them.

o 21 1

CHAIRMAN ZECH:

Let me just point out, you know, up 2

there in the third bullet where you say most reports in these 3

areas are not submitted, those are pretty big issues.

I kind 4

of wonder why they haven't been submitted yet.

It seems to be 5

rather tardy.

It places on the staff the burden of trying to 6

expedite a review that is awfully important.

I want you to do 7

it right.

We all do, I think.

So, I'm a little concerned 8

that the final reports aren't in.

I'm a little concerned as 9

to whether we will and up having to take the time, and we 10 should take the time we need to review them properly, so it 11 bothers me a little bit and I kind of wonder when the final 12 reports are going to come in.

13 Have they told you that at all?

14 MR. THOMPSON:

They've told us that their best 15 estimate is the final reports, well, most of them will be in 16 by the end of December with some in the engineering area being 17 as late as January 15th.

18 CEAIRMAN ZECH:

I thought that's what you said.

You 19 know, that's still -- doesn't that bother you a little bit?

20 MR. THOMPSON:

It certainly bothers us to the extent 21 that we don't have adequate time to complete our reviews.

We 22 will completa our reviews adequately.

23 CHAIRMAN ZECH:

You have to take adequate time, 24 that's what I mean.

You just have to do it right.

It kind of 25 troubles me a little bit that perhaps you are not going to --

22 1

you have to take the time.

If you have to take more time, 2

just take it.

It seems to me the burden is on TVA to get 3

those final reports in and not to get them in and ask us to 4

read them overnight.

5 MR. THOMPSON:

Yes, sir.

6 CHAIRMAN ZECH:

You need more time than that.

These 7

are very important complex issues.

So, I submit that when you 8

are talking with them, you might let them know, if you 9

haven't, that those reports are necessary to get in.

You need 10 adequate time to review them.

11 MR. THOMPSON:

Yes, sir.

We have emphasized that.

12 In fact, we are very quick to identify deficiencies and 13 additional information we need from TVA if we see it, even in 14 a praliminary state.

That is one of the reasons we tried to 15 get the initial reports in early.

16 COKKISSIONER ASSELSTINE:

Hugh, on the 700 concerns, 17 how many of those are concerns that were originally identified 18 for another plant, say Watts Bar, that TVA has determined 19 applied to Sequoyah as well, as oppcsed to strictly Sequoyah 20 issues?

21 MR. THOMPSON:

Let me make a guess and then I'll ask 22 B.K. Singh.

I would say the majority, and I'd say the large 23 majority of them were identified as part of the Watts Bar 24 activities and they had some generic applicability.

I'd 25 probably say like 75 percent.

Let me just see.

23 1

CHAIRMAN ZECH:

Will you identify yourself with the 2

microphone, please?

3 MR. SINGH:

I'm B.K. Singh, Coordinator for the 4

Employee Concern Program.

Out of 700, about 300 are Sequoyah 5

especially and 400 are generic to Sequoyah from Watts Bar or 6

Browns Ferry or other plants.

7 CHAIRMAN ZECH:

Thank you.

8 MR. THOMPSON:

Again, on the design and control, which is a very major program that we have been following very 9

10 carefully between I&E and the Region II review activities, we 11 found the program is acceptable to date subject to certainly 12 further inspection efforts to make sure it's implemented 13 right.

An addition in this area, we have accepted the 14 criteria for ultimately analyzed piping and cable tray 15 supports, which was a major issue earlier, to make sure that 16 we were satisfied they were going to be adequate margins in 17 those systems prior to re-start.

We have reviewed that today 18 and found that to be acceptable.

19 We still have some concerns regarding TVA's implementation of the prograns, to verify the plant adequacy 20 21 and complete system evaluations required for re-start.

22 Welding is another key area that we have essentially 23 completed our evaluation and we found that the TVA welding 24 program at Watts Bar is acceptable and identified some 25 recommendations that we made -- I'm sorry.

At Sequoyah.

We

o 24 1

had made some recommendations in our draft safety evaluation 2

report to accelerate some completion dates for the first ten 3

year in service inspection.

4 In equipment qualifications, again, the staff 5

reviewed the program as essentially complete.

We have issued 6

our safety evaluation report.

We have identified a number of 7

issues that remain open that we want to complete our review on 8

prior to signing off, such as a final inspection after the EQ 9

binders are completed and a couple of technical issues.

One 10 key one is the resolution of the high energy line break and 11 its effect on the equipment in the main steam line valve 12 vaults.

TVA has an approach in there that we believe will be 13 acceptable.

We want to see that they implement it properly.

14 MR. TAYLOR:

Hugh, I might add that commissioner 15 Asselstine brought up piece part procurement, commercial 16 grade, and.that is an issue that the staff is following as 17 part of the EQ.

You are right.

We have to be sure none of 18 that qualification was disturbed by piece part substitution, 19 wires and so forth.

20 COMMISSIONER ASSELSTINE:

Wouldn't you have expected 21 TVA's EQ program and the corrective program to have fixed 22 something like that, and why didn't they?

23 MR. TAYLOR:

I don't know that we have identified 24 yet in any specific EQ items that they have listed.

They are 25 going back through all the purchase documentation.

There will

25 1

be an answer to that, but I don't have it today.

I understand 2

the question.

3 MR. THOMPSON:

The next area ja operational 4

readiness.

5 COMMISSIONER ASSELSTINE:

Before you leave that one, 6

on the welding area, did you say you were satisfied with the 7

welding program for Sequoyah, obviously I think the staff has 8

not yet reached that same conclusion for the welding program 9

at Watts Bar.

10 MR. THOMPSON:

That's correct.

11 COMMISSIONER ASSELSTINE:

How is it that you are 12 able to sign off on the welding program for Sequoyah but not 13

-- while there are still some open issues on Watts Bar?

14 MR. THOMPSON:

I'd like Dr. Liaw to respond to that 15 in some detail, since he led the teams that have evaluated 16 both Sequoyah and Watts Bar.

17 DR. LIAW:

B.D. Liaw.

In reviewing the Sequoyah 18 welding program, we took a look, not just on the important 19 concern and TVA's resolution of those important concerns, but 20 also in the very beginning, we asked TVA to come up with some 21 kind of a re-inspection program to supplement their paperwork 22 review.

As a result, TVA was able to finish the project 23 earlier and also we are able to condu7t our own independent 24 review of what TVA was doing.

25 In addition, we also looked at additional samples

26 1

ourselves in Region I and Region II.

We made a call.

For 2

example, the basic conclusion we have reached, number one, the 3

deviant welds are suitable for service, acceptable under the 4

ASME code.

The second major conclusion is the QA aspect of 5

the welding program was adequate except in the area of 6

inspection where we have identified a lot of deficient welds 7

that should have been picked up by the inspector, had the 8

program been turned out effectively during construction.

9 By saying that we completed our review, we did not 10 mean it is completely home free.

We continue to evaluate 11 the employee concern program and also to see what happened at 12 Watts Bar. Obviously, if something significant has been 13 identified at Watts Bar, we will go back to look at it, 14 whether or not it has any relevancy to Sequoyah.

15 COMMISSIONER ASSELSTINE:

Is the deficiency rate 16 that you are finding on welds at Sequoyah lower o.?

17 considerably lower than the deficiency rate they are finding 18 at Watts Bar?

19 DR. LIAW:

Reasonably the same.

However, Sequoyah, 20 the significant deficiencies are much less, about 15 percent 21 or so.

At Watts Bar, it will run something like 42 percent of 22 significant attributes that were found to be deficient.

23 For example, again at Sequoyah 184 deficient 24 attributes were due to arc strike or spatter.

To us that is 25 not very significant at all in terms of safety of the piping,

27 1

just to give you an example.

2 COMMISSIONER ASSELSTINE:

Is the sample size smaller 3

for S quoyah than for Watts Bar?

4 MR. LIAW:

Yes, much smaller at Sequoyah since so 5

many important concerns were raised at Watts Bar, and besides, 6

through the construction period there were so many changes at 7

Watts Bar.

Sequoyah was much more straightforward, so we were 8

able to isolate the situation at Watts Bar, so we were not 9

able to do that.

I'm sorry, correction.

We were able to do 10 it at Sequoyah but not able to do it at Watts Bar.

11 COMMISSIONER ASSELSTINE:

Okay.

Are you confident 12 enough, given what you have seen, that the sample size at 13 Sequoyah is big enough that it gives you a good representation 14 of what the plant as a whole looks like, that you are not 15 missing significant deficiencies in the other portions that 16 aren't being reinspected?

17 MR. LIAW:

In terms of how comfortable I feel, I think I am very comfortable, but in terms of sufficiency, no, 18 19 the answer would be no.

We would not recommend the 20 acceleration of the inspection program, a ten-year inspection 21 program, but engineering judgment was applied when we approved I

22 and selected the sample at Watts -- at Sequoyah.

23 MR. DENTON:

B.D., you might mention the consultants

{

24 that you had available when we made that decision.

It wasn't 25 made just by a small group.

i 28 1

MR. LIAW:

Yes.

When we applied the judgment and we 1

2 consulted with our consultants, they in essence said, well, if 3

something was going to be bad, those areas were the most i

4 likely you were going to have because a lesser degree of QC 5

was applied in those systems, for example in piping, and 6

structural welds, they are the same, safety related.

7 COMMISSIONER ROBERTS:

B.D., who were the 8

consultants?

9 MR. LIAW:

In the structural area, Bob Stott, former 10 Dean of Engineering from Lehigh University; Professor Muncie 11 from the University of Illinois; Do Dougherty from U.S. Steel 12 Research Laboratory; Paul Master, a welding expert, formerly 13 the AWS Chairman; and Carl Habauer, a former chief welding 14 engineer at the Federal Highway Administration; plus one 15 consultant from Brookhaven to handle overall coordination.

16 COMMISSIONER ROBERTS:

Thank you.

17 COMMISSIONER ASSELSTINE:

When are you suggesting 18 that the ten-year ISI be done?

19 MR. LIAW:

I recommend that they finish 100 percent 20 of all fuel welds that are already in the first ten-year 21 program, to be completed in two consecutive refueling outages 22 after restart.

23 COMMISSIONER ASSELSTINE:

After restart.

24 MR. LIAW:

Right.

25 COMMISSIONER ASSELSTINE:

So you would let them

29 1

start up, and then they do the ISIS in the next two outages.

2 MR. LIAW:

Right.

And some of this could be 3

stretched up to five or six years.

I just want them to finish 4

it in the first two refuelings to give us further confidence.

5 COMMISSIONER ASSELSTINE:

Thank you.

6 MR. THOMPSON:

If I could go on to the operational 7

readiness program, that is an area whe,re Region II has been 8

putting a lot of effort into it.

In particular they have 9

identified a couple areas that needed increased inspection 10 activities with the tech spec surveillance instruction.

TVA 11 has now expanded their review of the procedures to 100 percent 12 review based on some of the problems they found to date.

13 Maintenance activities are also a major area where 14 both the NRC inspection activities and the Nuclear Managers 15 Review Group has identified some deficiencies that need 16 follow-up inspections.

With post-modification testing, the 17 Region has identified some deficiencies in the process that 18 TVA was using that will require further staff review and 19 evaluation.

20 There is some good news with the emergency 21 preparedness.

In the recent drill that they had and exercise 22 in November, there were no major weaknesses identified, and in 23 the training area there seems to be good progress there, and 24 there is an operator exam going on this month.

25 If we can turn to Browns Ferry.

30 1

MR. GARY ZECH:

If I could, I had a couple items in 2

the operational readiness area.

3 MR. THOMPSON:

Yes.

4 MR. GARY ZECH:

Mr. Chairman, you asked whether or 5

not they were making progress and whether or not we were the 6

critical path or TVA was.

I think, as Hugh pointed out, there 7

are a number of areas in addition to those as well that we are 8

looking at in Region II that relate to those areas.

For 9

example, we are looking at the drawings, controls and 10 updates.

We are looking at the QA involvement.

This is what 11 Commissioner Asselstine was referring to with the line 12 organization.

It is not only the QA organization itself but 13 it is how well they relate to the organization and how well 14 they work out findings from the QA inspections or audits.

15 As far as critical path is concerned, I think the 16 way we look at it, as was pointed out, there is a lot of implementation that still needs to be accomplished by 17 18 Sequoyah, and these various programs that they have under way, 19 like the design baseline verification program and others, have 20 to come to some closure and they have to be satisfied that 21 they have met their commitments, the Nuclear Performance Plan, 1

22 that their systems are ready, they have been tested, the 23 surveillance is completed, and that their corporate overview 24 of the site gives them a green light based on their review.

25 We do understand that they have corporate plan that

t 31 1

they are working on that will look at Sequoyah and 2

subsequently Browns Ferry to see that they have, in fact, met 3

their commitments and that from a TVA standpoint they feel 4

that they are ready to restart.

5 Now, we will be looking at that process ourselves.

6 We in the Region will ask, I am sure, for assistance from 7

headquarters and perhaps other regions when we get into the 8

startup phase at Sequoyah, and we will monitor their closure 9

of the systems, the valve lineups and their escalation to 10 criticality and so forth; but before they get to that point, 11 I guess my point is that there is a great deal they need to do 12 to satisfy themselves, and then we likewise have to look at 13 what they have done and can come to you and say we believe 14 they are ready to restart.

15 That is a lot to do in the few months that we are 1

16 speaking of.

17 CHAIRMAN ZECH:

A lot to do is right.

l 18 MR. THOMPSON:

On Browns Ferry, one of the key 19 programs their, probably the pacing item that we see right now 20 is the design baseline verification and configuration 21 management program at TVA.

They are doing a walkdown of about 22 54 of the 100 systems there, and pending completion of that l

23 walkdown effort, almost all the plant modifications have been i

l 24 suspended in order for them to really understand what the 25 baselina of the systems are before they start making any

32 1

changes.

2 To date, less than ten systems have been verified, due in part to a lack of TVA's ability to hire system managers 3

4 in order to do these walkdowns and get the plants under 5

control.

TVA estimates about 60 percent of the work has been 6

done to date in this area, with the estimated completion by 7

the end of January, which is a very aggressive approach there, 8

which is a very optimistic date.

l 9

With respect to fire protection, we have completed 10 our draft safety evaluation and have issued it, and TVA has i

11 responded to it on November 21st.

We still have some 12 technical areas that need to be reviewed and approved by NRC, 1

13 such as agreeing to the definition of the fire areas where 14 they deviated from the Appendix R.

15 The testing of the fire detection and suppression 16 systems, I think, has been completed, and we also want to 17 understand and agree with the feasibility of the large number 18 of manual actions that are required to reach safe shutdown 19 from outside of the control room in the event of a fire 20 situation.

Right now this program is running about two to 21 three months behind the schedule that TVA had been working on.

22 Environmental qualifications is another very 23 important issue at Browns Ferry.

We did a pre-audit visit in 24 November, as we did with Sequoyah, to make sure that we knew 25 where the program was and where we were headed and to give

33 1

them some advice.

The procedures appear to be well organized 2

and valid.

It is very similar to Sequoyah.

3 They are having a fairly large number of 4

replacements of electrical and use equipment.

This was based 5

on part of their changeout as well as a lack of equipment 6

qualification.

They are having a much better control now over 7

the cable issue.

At one time we thought they may have a real 8

major problem with cable qualifications.

Through testing at 9

the Wylin Lab and some similarity approaches they have now 10 significantly reduced the EQ cable problem.

i 11 Again, the operational readiness program.

As Gary 12 talked about, this is another area that the Region is also 13 following very closely at Browns Ferry.

We met with them in 14 November to get an outline of their operational readiness 15 plan.

This is very similar to what they are doing with the 16 Sequoyah.

17 They have developed this program based on the 18 Nuclear Performance Plan which has been submitted to the 19 staff.

They identify and evaluate performance objectives --

20 these are based on INPO, SALP, their own line management 21 criteria for what needs to be done prior to restart -- and 22 then a program to systematically identify these requirements 23 and document their completion to both satisfy their management 24 as well as any audit that we would like to do.

l 25 Their licensed operator training and requalification

=

34 1

program are proceeding adequately.

There are requal 2

examinations for the operators, and I guess some initial exams 3

for operators going on this month.

This, again, is a very key 4

area, and it may well be a pacing area for our review and 5

. approval for startup.

6 In Watts Bar, one of the key areas that we have been 7

discussing for some time is welding.

We recently identified a 8

number of significant Code-unacceptable weld defects found --

9 COMMISSIONER ROBERTS:

Can you give me some sense of 10 uhat you mean by significant, as a percentage?

11 MR. THOMPSON:

We can, I guess, talk about the 12 piping welds of about 10 percent, but Jim?

13 MR. TAYLOR:

The staff talks about significant in 14 structural welding to be defects such as lack of fusion, 15 cracks and so on that are covered by code.

Then there are 16 attributes that TVA appropriately is looking at that reflect 17 on workmanship: weld splatter, arc strikes.

Those are more 18 workmanship attributes.

19 So the significant thing in a structural weld is to 4

20 have a crack, lack of confusion, maybe complete undersize l

21 weld or missing weld, as examples where clearly that is code 22 covered. Those are the significant type of issues.

23 Staff has done the numbers several different 24 ways. These are changing numbers.

We took exception to the 25 way they were combining all attributes and getting percent

35 1

deficient because we in the staff felt like a weldment was 2

rejectable under the code if it had a single or multiple major 3

deficiency like a crack or being completely undersized or 4

being missing, and they agree that that is another way of 5

looking at your compliance with the code.

6 The number has been running in the area of, if you 7

take the significant things -- the staff has run the numbers 8

that way, and TVA has, too.

They have reported recently in 9

that line.

It is about 16 to 18 percent of the structural 10 welds looked at.

Now, many of the structural welds are good, 11 and there are certain areas where there are more defects than 12 others, in some of the supports structures, as an example, 13 where some of the other structural welding is quite good. So 14 it is mixed.

I hope I have answered your question.

15 In pipe welding, significant defect would be either 16 that visually by dye penetrant or visual inspection, or just 17 as importantly, in the radiograph, where radiograph has a code 18 rejectable defect.

The code is very specific in ASME about 19 what is a rejectable radiograph deficiency.

Sometimes they i

20 are --

21 COMMISSIONER ROBERTS:

Well, that is true, but you 22 can sure get into some interesting arguments about 23 interpretations.

24 MR. TAYLOR:

No question about that.

No question 25 about interpretations.

But I think the prevalence of defects

36

'l that they are seeing in reviewing radiographs -- I looked at 2

some.

I'm not a qualified person. There were calls that 3

should have been made.

Even when an interpreter makes a call 4

and he may be wrong, he should be recording his interpretation 5

on the sheet.

6 In other words, he looks at porosity and he may 7

miscall it, but he usually notes his call.

Some of that has 8

not been done.

9 COMMISSIONER ROBERTS:

Let me ask you this.

There 10 are unacceptable welds and there are unacceptable 11 radiographs.

12 MR. TAYLOR:

Right.

There is a big --

13 COMMISSIONER ROBERTS:

Do you have both?

14 MR. TAYLOR:

In the structural area there are 15 unacceptable welds where they have actually analyzed to date 16 and the weld won't carry the structural load capability.

That 17 is not widespread, but it is there.

18 And the radiographs, they're not acceptable by code 19 to the radiograph standards, I don't think, because there is l

20 slag in the weld and I could prove to you that weld is going

21 to fail.

It just does not meet code acceptance standards, 22 that's all.

23 And what you do is you normally fix it.

You reshoot i

24 it to make sure it's still there.

But if it's still there, 25 then what you do is you say, hey welder, you have too much

37 1

porosity in that weld.

And what they do is grind it out.

And 2

there are cases where you can make a code case if it's in the 3

containment and buried, that you do a fracture analysis 4

application to that defect.

5 I actually saw one radiograph that had a crack that 6

got through.

They picked out some examples and you could tell 7

it was cracked and you could see the tail, the age-old tail.

4 8

I'm not qualified, but everybody agreed that it was cracked.

9 MR. DENTON:

We think these are two areas where 10 there has been a breakdown in the QA program and we'll be 11 responding to them before the month's out, giving them our views in the structural steel welding and the radiograph.

12 13 COMMISSIONER ROBERTS:

Do they do their own 14 radiograph or do they subcontract it out?

15 MR. TAYLOR:

I believe they did their own 16 radiography.

Most places do.

One thing they did do is they 17 used what we -- there's Level 1, 2, and 3 of NDE 18 interpreters.

They used Level 2, which many people do, to 19 accept the first acceptance.

20 When I was at the meeting in Chattanooga, I said did 21 you ever have a Level 3 or a completely independent Level 2 go 22 back and audit the acceptance?

And they told me they did not.

23 That's because you keep the Level 2 guys on their 24 toes by using somebody to overview the acceptance of 25 radiographs.

That's the way you should do it.

You go in with

38 1

a Level 3.

That doesn't mean he's brighter or better, but he 2

puts that independent check.

It doesn't mean every weld, but 3

you keep the interpreters close to the line by doing that.

4 They never did that.

5 COMMISSIONER BERNTHAL:

I don't know whether you 6

mentioned this before I got here today or not, but I noticed 7

that point two here still appears to be written in the ongoing 8

sense, that they're still in the process of evaluating further 9

the findings and need for additional inspections.

Can you 10 give us a capsule summary, aside from what people breakdowns 11 there may have been, where the hardware stands, the level of 12 confidence that exists right now, that sample size is 13 adequate, that they're not going to need further significant 14 inspections?

Where are we?

15 MR. TAYLOR:

Well, they are expanding the sample 16 size in structural area, as an example, they are expanding the 17 sample size.

They're going further.

They had one particular 18 individual who contributed significantly to some of their 19 problems, and blatant acceptance of welds that should never 20 have been -- even I would never, you know, they're that bad.

21 In the NDE -- in the radiograph area, they informed 22 the Staff just this past week, that on Unit 1 they're 23 expanding their review of radiographs to 100 percent of the 24 radiograph quality welds.

So they'll pick up the review.

25 I presume since some of the people who contributed i

9 39 1

to the problem on Unit 1 were on Unit 2, they may ultimately 2

come to the same conclusion there.

The bottom line is they're 3

still looking, so we have not bounded the degree of the 4

problem, nor have they bounded where analysis may be 5

appropriate -- and many things can be analyzed.

6 COMMISSIONER BERNTHAL:

So it sounds like it would 7

be premature, at best, for you to estimate when they really 8

would bound the problem?

That is, understand the full 9

dimension of the problem, let alone when that plant might be 10 ready for licensing?

11 MR. TAYLOR:

I think it's going to be months of 12 reinspection in certain areas and reinterpretation of 13 radiographs, as an example, until that problem is bounded.

14 I'd say at least months.

15 MR. THOMPSON:

Commissioner Bernthal, we mentioned 16 earlier, before you got here, that it looks like with the 17 emphasis now on Watts Bar would not be licensed until sometime 18 in 1988.

19 MR. STELLO:

I think what you meant to say, Hugh, is 20 that the effort that they're putting in is aimed at getting 21 Sequoyah first, Units 1 and 2.

22 MR. THOMPSON:

Sequoyah, right.

23 MR. STELLO:

And then Browns Ferry and then Watts 24 Bar.

25 COMMISSIONER BERNTHAL:

I read 1988 for Watts Bar,

40 1

but it sounds like, at this point, that's an educated guess?

2 MR. DENTON:

That's right.

3 COMMISSIONER ASSELSTINE:

Jim, does TVA now 4

acknowledge that there are significant deficiencies on that 5

platform, the welding of that platform, that call into 6

question the ability of the platform to carry out its l

7 function?

8 MR. TAYLOR:

Yes, I don't know that they stopped 9

analyzing.

We did ask them, at the meeting, why don't you 10 just fix it?

Because it can be fixed.

They said, well, we're 11 going to fix it.

But they had applied -- an original analysis 12 showed an overloadage of uncertain numbers and they were still 13 looking at -- it's a big structure, so those numbers, whether 14 the whole thing would stand without those cross-supports or 15 not is an engineering question.

That's what they were looking 16 at.

17 Hugh, do you know whether they've stopped that and 18 decided --

19 MR. THOMPSON:

I really don't know --

20 MR. TAYLOR:

I don't know that today they're down 21 there rewelding those cross-members, but they said to us at 22 that meeting --

l 23 MR. THOMPSON:

They did say that they are going to 24 fix it and repair it.

In fact, we got a clarification now 25 this morning, with respect to the questions about Section 3

41 1

versus Section 11, which is their response to Question 14, 2

which was a very confusing answer to the Staff.

Dr. Liaw met 3

with a TVA welding group this past week.

And based on that 4

discussion, and our concerns, they have clarified their 5

response now to, I think, address that more accurately.

6 MR. DENTON:

This whole are of fix versus analysis 7

came in for a lot of discussion and we certainly tried to push 8

them towards the idea of fixing it, rather than more 9

analysis.

Now only does that provide an assured fix to it, it 10 cuts down the room for argument over lab or fracture mechanics 11 analysis, and that sort of area.

12 But I think there is some residual feeling among a 13 lot of the TVA people, that they can ultimately show that what 14 they had would serve.

But that's not really the issue anymore 15 and we try to get them to meet the code the way everyone else 16 does.

17 COMMISSIONER ASSELSTINE:

Do you get a sense that, 18 at least at your management level, that that message has 19 gotten through, that people are finally recognizing that the 20 simplest, easiest way to deal with the problems where you can 21 get at these things, is if they don't meet code just fix them 22 so that they do meet code, rather than spending months and i

23 months and months trying to come up with some elaborate 24 analysis that justifies what was there to start with?

25 MR. DENTON:

I don't think they're fully in

___-,_.n

42 1

agreement with that yet, at all levels.

We certainly would 2

like to see it go that way, and there may be some limited i

l 3

number of areas where it would warrant doing something.

But j

4 that was an area we discussed.

I don't know where they stand i

5 on that matter today.

l 6

MR. TAYLOR:

We should separate the ASME pipe 7

pressure boundary welds from structural, because the AWS code 8

does say that where there is a defect, analysis can be 9

applied.

Our issue with them was they should have applied it 10 the first time the weld was made and accepted.

That's a 11 quality issue as against a technical issue.

12 Many of the structural defects that they're finding, 13 because of the preponderance of margin in the structural 14 areas, will go away by analysis.

That undercut, or that lack 15 of fusion, when an engineer looks at it, will be found to be 16 acceptable and that's okay, per the code.

But they should 17 have noted the conditions way back, in the structural issue.

18 Some of this, that platform, really ought to be 19 repaired.

20 COMMISSIONER ASSELSTINE:

How much of that attitude 21

-- I don't know if you can answer this or not -- is driven by 22 the fact that TVA has made these pronouncements in the past, 23 not only to the Commission, but in some instances to the 24 Congress, about the quality of what was there.

And now 25 they're bound and deternined to try and justify those 1

I

t x

43 s

1 pronouncements rather than get at the p oblens and get them 2

fixed?

t-.

3 MR. STELLO:

I think you'll hava;to ask them.

4

[ Laughter.)

5 CHAIRMAN ' ECH:

Let's move along.

/

6 MR. THOMPSON:

Another, as I mentioned earlier, is the area of Quality Assurance'at Watts Bar, which we received '

7 8

the topical on November 14th and that is currently under the 9

Staff review.

That's both the QA, as it applies'to the 10 corporate, as well as it's implemented at the site.

11 And this is an area we certpinly, again, want to 12 ensure that we inspect before signing pff and have a good

,s n 13 continuumofinspectionstomakesureth{sareaisimplemented 14 properly.

m 15 I also wanted to brief the Commission with respect 16 to our interactions with the TVA's Inspector General's office 17 and his request that we follow up and ask some of these 18 concerned individuals to release their names to him, so he can 19 contact them for follow-up for wrongdoing 1 concerns.

20 We've been giving priority to those individuals who 21 were identified in the intimidation and harassment letter that 22 the Chairman sent out, I think back in June.

And also, with T

23 the Sequoyah plant.

We've sent out over 270 letters to date 24 and 70 some-odd of them have responded.

Typically, 80 percent 25 or so of those who respond are giving agreement to hava their

.~

44 1

names identified to the TVA Inspector General for follow up 2

activities.

3 We are identifying and reviewing the files on the 4

others, to determine whether or not sufficient safety issues 5

have been addressed and if there's intimidation and harassment that we should send to Ben Hayes and his people to follow up 6

7 and review and close out.

8 We've been meeting with the TVA IG and auditing some

)

9 of his activities.

They have been slow.

We were not 10 satisfied when we went down there on November 17th and 11 expressed our concerns to TVA.

They had then identified some j

12 additional information needs that they had from us in helping 13 identify and locating the individuals of concern.

And we 14 provided that information to them.

15 We have now asked and are receiving a weekly status 16 report on where he stands in completing his review of these 17 cases.

18 COMMISSIONER ASSELSTINE:

How many intimidation and

)

19 harassment cases are there, now?

And how many of them have 20 been completed?

21 MR. THOMPSON:

These are the ones that we have 22 through the employee concern program or --

i 23 COMMISSIONER ASSELSTINE:

Total?

24 MR. THOMPSON:

What they have?

What we have?

How 25 many of them are there?

m 45 1

MR. HAYES:

Commissioner, I'd have to stop and 2

analyze our inventory to come up with that.

I could give you 3

a ballpark figure, if you give me a moment, of my current 4

inventory.

S COMMISSIONER ASSELSTINE:

Or even just a 6

bracketing.

Are there tens of them, hundreds of them?

7 MR. HAYES:

If I'm not mistaken, approximately 30 8

percent of the Inspector General's inventory is I&H type, but 9

I' don't know what his universe is.

I just remember the 10 statistic, approximately 28 to 33 percent.

'll COMMISSIONER ASSELSTINE:

Okay.

12 MR. HAYES:

And OI, at least initially, we had many, 13 many -- 40 or 50 percent.

And in some instances, we had 14 deferred to the Inspector General some of those cases.

So 15 we're slowly coming down.

But some of our even material false 16 statement or false document cases have an element of I&H in

(

17 those cases, and we're addressing all of those issues within 18 one case.

19 COMMISSIONER ASSELSTINE:

I'll tell you what, if 20 it's going to take you a few minutes, rather than take the 21 time now, what you can just do is let me know first what the

(

22 total universe is, how many I&H cases thare are.

How many 23 have been completed.

24 I'd also be interested in knowing how many involve 25 corporate personnel.

And I guess the other question is are

a

~

46 a

1 you going to insist that all of those involving corporate 2

people are resolved before the first plant restarts?

3 MR. HAYES:

If I may, from the OI perspective, we 4

took a position earlier this year that I&H existed, at least 5

from 1980 through 1985, the pre-White era, as we call it.

I 6

believe the staff basically has concurred in that, but the 7

numbers, I'd be glad to get for you, Commissioner.

8 COMMISSIONER ASSELSTINE:

Okay; great.

9 MR. THOMPSON:

Again, this is an area that we are 10 following, auditing the Inspector General's activities, both 11 the line organization and Ben Hayes' staff is following that.

12 COMMISSIONER ASSELSTINE:

I guess my last question 13 really goes to the senic: management teams, whether you can 14 answer it now or later, but whether you are really looking to 15 the resolution of all those cases that involve corporate 16 people before the first plant starts up.

17 MR. DENTON:

Let me discuss that with the senior 18 management team and we'll provide you an answer.

19 COMMISSIONER ASSELSTINE:

That's fine; great.

20 MR. THOMPSON:

With respect to the resources that we 21 are applying to the TVA review activities, they are being 22 expended at the rate of 60 to 70 professional FTE's per year.

23 The rate actually started orr earlier this year about 60, the 24 last quarter of the fiscal year moved it up to about 70 25 professional full time equivalence, and of course, that

47 e

1 doesn't include the overhead, so it is a considerable number 2

of people charging to get that level of resources, and still 3

over one half of the resources continue to be charged and 4

applied to this from Region II, so they are carrying a major 5

effort in this review activity.

6 COMMISSIONER BERNTHAL:

Is that over and above what 7

our normal activities would be or does that include our normal 8

activities?

9 MR. THOMPSON:

That includes all professional hours 10 charged to TVA, some of them, for instance, a project manager 11 would be -- a normal project manager would be on the case.

We' 12 have added extra project managers.

The reason, I believe, we 13 have added extra inspections at the site, so we do have some 14 number above the normal.

15 COMMISSIONER BERNTHAL:

It seems to me it would be 16 worth knowing what the extraordinary costs are that are being 17 incurred by this Agency.

18 MR. STELLO:

Do you have what the number would be 19 normally?

There are eight plants, and average FTE's per 20 plant?

21 MR. THOMPSON:

I just don't have it right now.

22 MR. GARY ZECH:

I can speak from the Region's 23 standpoint.

We looked at numbers for regional based 24 inspectors and residents.

In 1986, I think it was about 22 25 would be normal for those plants and the status they wera in,

48 1

going up to about 29 in fiscal year 1987.

We expanded at a 2

rate this past fiscal year over and above the normal number by 3

about six FTE's.

It's a little bit less than we thought we 4

were projecting last Spring, but with the various dates missed 5

and slow downs and basically being a reactor type inspection, 6

we did not expand as much.

We anticipate it will be at the 7

rate we estimated for 1987, which is some 12 to perhaps even 8

20 over and above the normal rate for the Region.

9 COMMISSIONER BERNTHAL:

That's in the Region?

10 MR. GARY ZECH:

That's in the Region, of course.

11 COMMISSIONER BERNTHAL:

It doesn't include 12 Headquarters.

13 MR. STELLO:

We'll get an answer.

My recollection 14 is it is on the order of doubling what we normally have, 15 roughly.

16 COMMISSIONER BERNTHAL:

If that's the case, by 17 normal reckoning, 60 or 70 FTE's is $6 to $7 million of 18 Agency's resources and if even half of that, even a third, is 19 extraordinary, we are looking at a significant impact on our 20 budget here, $2, $3, $4 million.

l 21 MR. STELLO:

It is clearly that much and more.

We 22 have contractor dollars.

23 COMMISSIONER BERNTHAL:

That is right.

24 MR. THOMPSON:

Again I would say the resource 25 expenditure is going to increase now that we are starting to

s 49 1

get these element reports in and TVA is going to be ready for 2

additional inspections.

3 COMMISSIONER ROBERTS:

That is significant for us to 4

know, to do battle with Congress and OMB about our budget.

5 MR. THOMPSON:

Yes; it certainly is.

A lot of 6

resources involved; an awful lot.

7 MR. DENTON:

I think this concludes our plan 8

presentation.

I guess the points I would want to make at the 9

end, from here out, we are going to be driven a lot by the 10 adequacy of TVA's implementation of their programs.

We have 11 tended to review all the programs.

He have tended to concur 12 in programs.

Where we have done that in the past, the 13 programs weren't carried out.

I am talking years ago.

The 14 real test here will be TVA's ability to carry out these 15 programs that they have started effectively and our monitoring 16 of them.

17 The timing of programs is going to depend on 18 resolution of these employee concerns and the implementation 19-of whatever resolutions come out of them.

When we show the 20 reports, that's just prcviding a report.

It doesn't 21 necessarily say what is going to be done in the plant to 22 resolve the concerns.

That. whole employee concern area is 23 still going to be a pacing item.

24 Finally, these harassment and intimidation issues j

25 are going to have to be worked through.

They are the big

. _ =

w

.50 1

three topics that are going to require a lot of our attention 2

in the next few months.

3 COMMISSIONER BERNTHAL:

I just want to say on this 4

cost business, to prolong the point one step further here, t

5 that we will, and I think the public should understand, we 6

will bill to the extent that we are able to, we will bill TVA 7

for some of these extraordinary charges.

Is that correct or 8

am I misunderstanding?

9 MR. STELLO:

As I understand, we charge them for 10 actual FTE uses, I think up to a cap, and I can't think what 11 the cap is.

12 COMMIOSIONER ASSELSTINE:

Probably way over the cap.

13 COMMISSIONER BEENTHAL:

Let's find out what the cap 14 is.

The point is t. hough, as everyone here knows, that money 15 goes into the treasury --

16 COMMISSIONER ROBERTS:

That doesn't help us.

17 COMMISSIONER BERNTHAL:

It does not explicitly come 18 back into the health and safety programs of this Agency, and 19 to the extent that happens, and to the extent that we are 20 devoting extraordinary resources to this problem, that comes i

21 out of the hide of our other public health and safety 1

22 activities.

I think everybody needs to understand that.

23 That's a point we need to make on the Hill this year.

24 MR. THOMPSON:

If we could, we'd like to address the 25 preliminary lessons learned, activities and reports, if we are i

l

51 1

ready to move over to that area.

2 CHAIRMAN ZECH:

We don't have as much time for this 3

as I'd like, but please go ahead and do what you can.

I think 4

perhaps this is such a significant topic, that we may want to 5

address it at some time in the future.

I recognize they are 6

preliminary, but I think it's worth at least this morning, 7

giving us what you can.

8 MR. THOMPSON:

What is my time again?

9 CHAIRMAN ZECH:

Well, take whatever you need.

10 COMMISSIONER ASSELSTINE:

You know, it might be l

i 11 worthwhile breaking this one out as a separate matter.

12 CHAIRMAN ZECH:

I agree.

I had the same feeling.

I 13 don't know how you all feel about it, but maybe we ought to 14 give them just a few minutes to touch on what he has and 15 recognizing and agreeing we would have another session on it.

j 16 MR. STELLO:

Nor are we finished.

We are not 17 finished ourselves.

18 CHAIRMAN ZECH:

We know it's preliminary, but I 19 think it might be worth just a few minutes.

We'll try to give i

20 you maybe five minutes or maybe a little more, but not much, 21 and recognizing we are going to spend more time on this.

I

)

22 think there is much to be learned from this experience.

Go 23 ahead.

24 MR. THOMPSON:

Again, I'd like to emphasize at the

{

25 outset, we looked at this particular part of the report as

i 52 1

programmatic.

If I looked at it in one sense -- there were 2

two major areas we focused on.

One is our ability to identify 3

poor performers and what was our experience at TVA, and the 4

second one is what action did we take once we have identified 5

it.

I think all the lessons are really focused on that 6

particular area.

I think maybe if I just address the first 7

two, it will kind of give the flavor of where we are, where we 8

are going and then we will come and address these in some 9

additional detail.

10 The first one really is what we saw when we looked 11 at the record before us earlier, and that is we had SALP 12 reports.

We had indications of poor performance at the 13 utility, as early back as 1980.

Based on our experience 14 during that time, our staff, which was the source of writing 15 this up because it did not go outside the Agency, to do a 16 major contractor review, was NRC needs to further develop and 17 implement a systematic process for identifying poor 18 performers.

19 Once that is identified, we think it is important 20 to elevate that information up in tha utility's organization 21 itself.

That is, we often times find ourselves interfacing at 22 the licensing level or the management nuclear power level, and 23 have issues that don't seem to be resolved and not raise that 24 up to the chief executive officer or even the Board of 25 Directors, and in this case, the TVA Board.

53 1

That is one of the lessons we think we have learned, 2

that we really need to have a program in place.

3 As you knos, the EDO has implemented a program which 4

every six months he now meets with the Regional Administrators 5

and the key office directors to assist us in identifying those 6

plants that need increased attention, and we have developed 7

performance indicators as another tool in this area.

These 8

items, we think, will be very effective in assisting the 9

Commission in addressing and identifying the performers that 10 need increased attention.

11 COMMISSIONER BERNTHAL:

Let me make a comment, 12 before we go on.

This looks bad on the surface of it.

It is 13 bad on the surface of it.

14 MR. THOMPSON:

I believe it is bad.

15 COMMISSIONER BERNTHAL:

Browns Ferry, SALP Level 16 III, operations every year since 1980, maintenance every year 17 since 1981.

It is reasonable to think and to expect that is 18 unusual.

It is only going to stand out if it is truly is 19 unusual when you compare it with other plants.

I think that 20 is one of the values of the performance indicator program.

We 21 are finally getting this stuff in one place where we can do a 22 comparison.

23 Do you know offhand whether this will stick out like 24 a sore thumb?

One of these statistics, the one you have on 25 top there right now, clearly sticks out like a sore thumb.

If 1

54 1

they got six of the ten SALP ratings of three given to i

2 construction plants since the start of the SALP program in 3

1981, that would clearly suggest it sticks out like a sore i

4 thumb.

5 I want to know about the others, though.

Would we 6

have seen them?

7 MR. THOMPSON:

As part of our charter, we didn't try 8

to go beyond the data that was available for us on TVA.

I do 9

know that right after Davis Besse, when we looked at the data 10 that was available for us at other plants, we did identify 11 other plants for increased regulatory attention, because they 12 had SALP ratings that stood out like this.

The one that comes 13 to mind is Fort St. Vrain, which I believe has been identified 14 as part of the area for Commission attention.

Rancho Seco.

I 15 think we have identified those at some time.

16 MR. STELLO:

What we have in place today, I am

(

17 confident that this plant would have been recognized as a 18 problem.

What I am less sure of is that we really would put 19 into place and make sure we had a program to get it resolved.

20 That's the more difficult issue, to make sure we have made it 21 clear to the management what the problem is, and I think we 22 could do that, but then assure ourselves they have the kind of 23 changes needed and sustained and it really is turned around.

i 24 COMMISSIONER BERNTHAL:

I agree that is the more 25 important thing but you won't do that unless you have the I

l

55 1

early signal.

2 CHAIRMAN ZECH:

Right, it is one step at a time.

3 First of all you have to get the signal and then you have to 4

look into it, and then you have to make a decision as to what 5

you are going to do.

I think we are taking the first step.

6 MR. STELLO:

I think the first step is okay.

I am 7

confident with what we have in place.

4 8

COMMISSIONER BERNTHAL:

The thing that I find 4

9 personally surprising is I remember very well that in the 10 Spring of 1985, it was the staff of this Agency at some levels 11 at least, that had become attentive to a growing problem of 12 TVA.

There simply was no widespread perception of a 13 significant problem down there as late as early 1985.

I 4

14 remember that very well.

Interestingly enough, we are seeing 15 statistics here that should have waved a red flag and sent 16 alarm bella sounding a lot earlier than that, and there wasn't 17 j

anybody here that had really focused on TVA in early 1985.

18 MR. THOMPSON:

My memory is we always talked as if i

19 there were three different TVA's.

There was the Browns Ferry j

20 part that was bad and the other two were pretty good.

I think 21 what we are saying is there was a bigger breakdown than we 22 were able to identify at that time.

That is one of the 23 important things, that we have to continue to look at while we 24 go through the licensing process, to identify what were the 25 signals that were available to us, to give us a broader i

l

- 56 1

perspective on the issue.

i 2

MR. TAYLOR:

The staff became greatly concerned J

[

3 during 1984, with some significant operating events at Browns 4

Ferry, irrespective of the SALP's, and we began studying this 5

situation.

We didn't have performance indicators as such, but 6

we began putting the information together, because we were 7

concerned.

The severity of some of the events was what was 8

driving us.

9 COMMISSIONER BERNTHAL:

I'll grant you maybe in 10 1984.

11 MR. TAYLOR:

This is h'. story.

We didn't envision 12 the total TVA problem by any means.

We were greatly concerned 13 about Browns Ferry's operational performance in late 1984.

14 COMMISSIONER BERNTHAL:

I also remember that in the 15 midst of those events, there were rearrangements of management 16 and what not and various people at very high levels in this 17 Agency went down and came back with rather optimistic views 18 that was going to go a long way to solving the problem, and i

19 clearly there was no sense of how long this whole thing had 20 been going on.

l 21 MR. THOMPSON:

I am just going to cover two more, 22 Mr. Chairman, unless you would like me to stop right now.

23 CHAIRMAN ZECH:

No, just go ahead, a couple more i

24 would be fine.

i 25 MR. THOMPSON:

The next one really was that NRC

l 57 i

1 needs to develop, I guess, increased skills in identifying 2

management problems in itself.

We are trained as engineers.

3 You know, we look at pumps and valves and nuts and bolts and 4

we feel very comfortable identifying a bad pump and those 5

areas.

We probably have not focused on our training for either our managers or our resident inspectors or our project 6

i 7

managers to be sensitive and alert to the issues on J

8 management.

9 I think the Commission has rightly given some 10 concerns about how far we delve into the management area and 11 we need to have in place better guidelines as to what we need 12 to be looking for and what we are doing.

4 13 Specifically, we want to make sure to reemphasize 14 and provide guidance to the specific NRC managers who will be 15 responsible for and held accountable for the oversight of 16 licensing management.

This is an area that is part of the 1

17 current EDO's program where we identify areas for increased 18 regional administrator attention and, subsequently, if it is 19 sufficient enough, it gets increased attention by the l

l 20 agency-wide activities.

21 Wa need to assure that there is a hierarchy of 22 activities that is available for responding to management 23 issues as we started off just escalating it up in the 24 management organization, the utility organization, so that 1

25 their senior managers are aware of it, as well as making sure w--v--g

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r 4 W"WMFe 9------'""="-"re-'"?N--""'--C---7wrew'

-N-*ew-km w w-W e-"""-"'

c.

4 58 1

that the EDO as well as the Commission is aware of problem 2

plants.

3 Then finally, I would say that one other thing we 4

need to do is better document and provide a basis for 5

_ identifying management issues. We have a lot of inspection 6

reports, we have the capability for individuals to integrate 7

their own views who were there at the plants of where 8

deficiencies are being identified, and we should take 9

advantage of that information and have those inspections, both 10 individual inspectors and team inspectors, integrate their 11 overall activities.

12 So I think with those as the kind of overview, there 13 are a large number of others in the QA program and making sure 14 our inspection activity during construction is more 15 effective.

I think these are ones that have earlier been 16 identified in other reports.

We certainly confirm that as an 17 area that the Commission can improve on.

18 CHAIRMAN ZECH:

All right.

Does that finish the 19 briefing?

20 MR. STELLO:

We propose to stop there, Mr. Chairman, 21 and I would request that if the Commission doesn't object, I 22 would like to move forward and send this report out to a bunch 23 of individuals who are not now part of either the NRC or the 24 agency that I think could provide significant review and 25 comment and help us to better frame and understand what

59 1

lessons we have really learned from all of this. With the 2

Commission's concurrence, I would like to go forward and get 3

that additional information.

4 CHAIRMAN ZECH:

What I would like you to do on that 5

is send us a real brief note so we can take a look at it and 6

think about it a little bit.

I think personally it sounds 7

like a very reasonable thing to do, but I think my fellow 8

commissioners might like to think about that a little bit.

9 So can you give us something, a short memorandum 10 that we can reflect on?

We will get back to you as soon as we 11 can.

12 MR. STELLO:

Be happy to.

13 CHAIRMAN ZECH:

Are there any other questions before 14 we go to the closed meeting from my fellow commissioners?

If 15 not, let me just say I thank the staff for a very fine 16 presentation.

We are dealing with a very complex and important matter, and we have covered it even rather hurriedly 17 18 this morning.

On the other hand, I know there is constant 19 coordination and action going on between the staff and TVA 20 organization.

All of us on the Commission are well aware of 21 the daily activity as well as from the region and headquarters 22 as well as periodic review by senior staff of the TVA 23 situation.

24 So I think we are reasonably comfortable that Pae 25 staff is staying on top of everything, but 1 do think these

60 a

1 briefings as well as your continually keeping the commission 2

informed of the TVA situation is extremely important to us.

3 I am a little concerned about, frankly, TVA's 4

submitting, as we touched on briefly, some of this information 5

and things to us rather late.

Perhaps there is good reason 6

for that so I don't want to press it, but I just want the 7

staff to recognize that you need to take the time, when you 8

get the programs and the issues coming to you, to review them 9

carefully and thoughtfully and to give yourself and your other 10 people a degree of confidence that you are making the best 11 possible judgments.

12 We are talking about QA.

It is a very important 13 issue. It certainly brings it to the forefront.

My personal 14 feeling is quality across the board in this industry is so 15 important, in not only construction but in training, i

16 operations, maintenance, all the other activities that are so I

17 crucial to public health and safety; so quality, quality, 18 quality is the name of the game.

Here there looks to be a 19 problem that we really have got to address very carefully.

20 Involving employee concerns, there is nothing more important than our people involved in this industry, and 21 22 again, those are things we have got to look into thoughtfully, 23 not only by the staff but by the investigating group under 24 Mr. Hayes and so forth.

So employee concerns are important.

25 Intimidation and harassment is all part of this.

It is a very

61

+

1 important issue.

2 So it is a very ccuplex situation here, and I just 3

want to make sure we are acting as responsibly as we can, and 4

it seems to me that the staff is indeed staying on top of it.

5 I think it is important that the Commission feel that that is 6

going on, and if there is anything the Commission should or 7

needs to be doing, that the staff will make such 8

recommendations as they deem appropriata.

9 If there are no other questions from my fellow 10 commissioners -- yes, Mr. Bernthal.

11 COMMISSIONER BERNTHAL:

Let me just ask one broad 12 question.

I hope it wasn't asked or addressed at the outset.

13 I would like to know whether you folks here -- you know, this 14 is sort of the best we have to offer in the NRC, and pretty 15 darned good, at that.

I think it is worth noting that it is a 16 pretty blue chip crowd here that is sitting on the other side j

17 of the table.

18 In your judgment, organizationally and 19 programmatically, in terms of the people that have been put in 20 place down there, has that organization down there, the 21 Tennessee Valley Authority now, got something in place that, 22 in your judgment, will solve the problems, is moving in the 23 right direction?

Do you see significant flaws or are you 24 fairly comfortable with what you are seeing down there now?

25 MR. STELLO:

Let me give you a short answer.

I i

)

62 o

1 think the uncertainties that go with who is going to be their 2

leader, Steve White or not, that has got to come to pass and 3

get behind us so that we know that whoever this leadership is i

4 going to be down there is in place and that everyone else 5

falls in step and it moves.

Until that step is taken, I think there is going to be and will remain a sense of instability.

6 7

COMMISSIONER BERNTHAL:

Well, leave out Steve White 1

8 for a moment.

9 MR. STELLO:

You really can't.

t 10 COMMISSIONER BERNTHAL:

Do you believe that the 11 prcgrams and the organizational structure, the people, sans 12 Steve White, basically is the right kind of system that you 13 are comfortable with and that is going to move this program in 14 the right direction?

15 COMMISSIONER ASSELSTINE:

Particularly as they have 16 performed over the past year.

17 MR. STELLO:

I think they have a lot of very good 18 people that if they are properly motivated, properly led and 19 managed, they can clearly do the job.

They have got enormous 20 resources and a lot of very, very good people.

21 COMMISSIONER BERNTHAL:

I don't disagree with that.

22 I don't think I'm going to get an answer.

23 MR. STELLO:

But ycu can't answer it -- you say 24 leave Steve White out, but that is the leadership.

25 COMMISSIONER BERNTHAL:

They are going to have to

63 1

leave him out in another year or so.

That is the whole point.

2 MR. STELLO:

Great.

Let's do that in a year or so, 3

and get him in there and have him be their leader now, if that 4

is the case, or get him out of there now and put the 5

institution that is going to be in place and say that's it, 6

now let's move with it.

The uncertainties that are created by 7

not answer that question, I think, pervade an awful lot of 8

thinking everywhere.

9 COMMISSIONER ASSELSTINE:

I think your question is 10 the right one.

I would like to hear the views of the senior 11 management team, as well, on whether they think, given the 12 performance of this crew over the past year, that these people 13 can do the job.

14 COMMISSIONER BERNTHAL:

I guess we hear so much 15 about problems here that I am interested in hearing about the 16 solution if we possibly can.

17 MR. DENTON:

We sat down there last month thinking 18

-- we thought we could work with the team that they have 19 there.

They have some very qualified people in some slots.

20 In other areas there are people who have worked in those areas 1

21 who had problems who are back still working in those areas.

22 Now, whether or not they have "gotten religion" and will do it 23 much better in the future remains to be seen.

24 We are not as enthusiastic as, say, we were about 25 the Davis-Besse management team.

We are not down here saying

64

+

1 they have gotten those kindsaof people who we are confident 2

are going to address the problem.

I think to some extent the 3

jury is still out on whether the team that they have assembled 4

is up to the task, but we are willing to let them try and we 5

will judge them on the basis of performance, but I think it is 6

fair to say -- I don't know that we have ever really polled 7

the staff -- we are not enthusiastic but we think they can do 8

the job and we are willing to see if they can.

9 CHAIRMAN ZECH:

I think that is probably as good an 10 answer as we are going to get.

11 MR. STELLO:

Nelson Grace, Regional Administrator, 12 wanted an opportunity to respond to that question, if ha 13 could.

14 CHAIRMAN ZECH:

Yes, go ahead, Nelson, very briefly, 15 please.

16 MR. GRACE:

I think that is a very important 17 question that has been asked as to whether we are going to be 18 satisfied with their performance.

I think a corollary 19 question which is equally important, perhaps more important, 20 is the degree of confidence that their own staff has in the 21 management.

Now, we have had some indications there that make l

22 us rather uncomfortable.

We discussed it at our management 23 meeting in Sequoyah last month, and I think we are all 24 concerned about it.

We are not quite sure what to do about 25 it.

i

..~-.g___

65 6

1 Now, they did do a survey of their employees, some 2

1600 employees, a couple of months ago, and the results were 3

not good.

They indicated that typically 75 percent of their 4

employees still lack confidence in middle and upper 5

management, middle management in particular, and they 6

expressed concern about lack of communication, lack of 7

cooperation, lack of trust and so forth.

8 Now, this, of course, is the root cause of all of 9

TVA's problems dating way back.

That was the source of all 10 the problems, the failure to communicate and respond 6

11 appropriately.

Now, in contrast, Bill Cain was down to Region 12 II a few weeks ago to address our residents -- from Region I 13

-- and he told me that a similar survey had been done at 14 Niagara-Mohawk, and in contrast to the 75 percent negative 15 answers that were found at TVA, they had typically 90 pcrcent 16 positive answers among the employees surveyed concerning their I

17 attitude towards management and their faith and confidence.

18 So I don't know whether another survey is 19 indicated.

Of course, it is going to take a long time to turn j

20 that around.

It is a problem that has existed for many 21 years.

But I would feel more comfortable and we all would if I

22 we saw some indication that they turned the corner in that 23 regard.

We have one data point, this latest survey.

Maybe they will do another survey.

Maybe we should ask them to do 24 l

25 another survey.

i

)

l

6 66 1

Thank you.

2 CHAIRMAN ZECH:

Are there any other comments from 3

Commissioners?

4

[No response.]

5 CHAIRMAN ZECH:

Thank you very much.

The meeting is 6

adjourned.

7 (Whereupon, at 11:07 a.m. the meeting was 8

concluded.]

]

9 10 i

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

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2 REPORTER'S CERTIFICATE 3

4 This is to certify that the attached events of a meeting of the U.S. Nuclear Regulatory Commission entitled:

5 6

7 TITLE OF MEETING:

Briefing on Status of TVA (Public Meeting) 8 PLACE OF MEETING:

Washington, D.C.

9 DATE OF MEETING:

Tuesday, December 16, 1986 10 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the Commission taken 13 stenographically by me, thereafter reduced to typewriting by i

14 me or under the direction of the court reporting company, and 15 that the transcript is a true and accurate record of the 16 foregoing events.

17 18 Ann Riley 19 20 i

21 22 Ann Riley & Associates, Ltd.

23 24 25 l

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O REVISEO 12/11/86 STAFF BRIEFING TVA NUCLEAR PLANTS DECEMBER 16, 1986 l

f

A INTRODUCTION o

RECENT STATUS OF STAFF ACTIONS REGARDING TVA FACILITIES IN SECY 86-1F.

o FOCUS OF THIS BRIEFING IS PRIMARILY:

1)

STATUS OF TVA AND STAFF ACTIVITIES IN AREAS OF:

- CORPORATE i

- SEQUOYAH

- BROWNS FERRY

- WATTS FAR

- CONCERNED INDIVIDUALS AND TVA IG ACTIVITIES 2)

PRELIMINARY LESSONS-LEARNED REPORT o

TVA EXPECTS SEQUOYAH UNIT 2 TO RESTART IN SPRING 1987 AND UNIT 1 TO RESTART THREE OR FOUR MONTHS LATER o

TVA EXPECTS BROWNS FERRY UNIT 2 TO BE READY TO RESTART AFTER SEQUOYAH UNITS o

TVA EXPECTS WATTS BAR TO BE READY FOR LICENSING BEFORE THE END OF 1988 I

1

CORPORATE AREA o

TVA MANAGEMENT REALIGNMENT IN RESPONSE TO OGE CONCERNS

- CORPORATE NUCLEAR PERFORMANCE PLAN REVISED ON 12/05/86

- ELIMINATES CONTRACT MANAGERG SUPERVISING EMPLOYEES FROM THEIR PARENT COMPANIES

- SHIFTS SOME LOANED MANAGERS TO NON-SUPERVISORY ADVISORY ROLES

- CONTINUES USE OF OUTSIDE FIRMS TO SUPPLY SERVICES AND EQUIPMENT 0

S. WHITE ON AN ADMINISTRATIVE LEAVE OF ABSENCE, C. MASON IS ACTING MANAGER OF NUCLEAR POWER 0

NRC CONCERNS WITH PROPOSED MANAGEMENT REALIGNMENT INCLUDE:

- SPAN OF CONTROL

- KEY TVA MANAGERS NOW IN " ACTING CAPACITY"

- ROLE OF ADVISORS

- TRAINING OF SUCCESSORS TO EXISTING MANAGERS 0

FUTURE ACTIONS INCLUDE:

- EVALUATING REVISED CORPORATE NUCLEAR PERFORMANCE PLAN

- ASSESS TVA MANAGEMENT EFFECTIVENESS IN IMPLEMENTING PROGRAMS

- CONTINUE MANAGEMENT MEETINGS BETWEEN TVA AND SMT

- EVALUATE TVA PROGRESS IN REDUCING H a I i

1

s SE000YAH 0

EMPLOYEE CONCERNS (LEAD RESPONSIBILITY - NRR)

TVA PROGRAM AND APPROACH IS ACCEPTABLE 300 ELEMENT REPORTS COVERING APPROXIMATELY 700 CONCERNS TO BE PREPAREDJ ABOUT 150 REPORTS SUBMITTED TO NRC PACING AREAS ARE ENGINEERING, NSRS ISSUES, AND QA.

MOST REPORTS FOR THESE AREAS NOT SUBMITTED POTENTI ALLY SIGNIFICANT CONCERN INVOLVES TRACEABILITY :0F SAFETY-RELATED MATERIAL FOR SMALL BORE PIPING EXTENSIVE STAFF EFFORT EXPECTED IN EARLY 1987 TO COMPLETE REVIEWS; ELEMENT REPORTS RECEIVED TO DATE GENEPALLY s ACCEPTABLE

\\

O HESIGN CONTROL (LEAD RESPONSIBILITY - IE)

- TVA PROGRAM ACCEPTABLE TO STAFF, SUBJECT '70 FURTHER INSPECTION

- ACCEPTANCE CRITERIA FOR ALTERNATELY ANALYZED PIPING AND CABLE TRAY SUPPORTS HAVE BEEN RESOLVED

- STAFF CONCERNS REMAIN REGARDING TVA IMPLEMENTATION OF PROGRAMS TO VERIFY PLANT ADEQUACY AND COMPLETE SYSTEM EVALUATION ON SYSTEMS REQUIRED FOR RESTART

SEQUOYAH (CONTINUED) t 0

WELDING (LEAD RESPONSIBILITY - NRR)

STAFF EVALUATION ESSENTIALLY COMPLETE AND TVA PROGRAM ACCEPTABLE DRAFT SAFETY EVALUATION REPORT ISSUED NOVEMBER 14, 1986 TVA REQUESTED TO CONSIDER ACCELERATING COMPLETION DATE FOR FIRST 10-YEAR INSERVICE INSPECTION 0

EQUIPMENT QUALIFICATION (LEAD RESPONSIBILITY - IE)

STAFF REVIEW ESSENTIALLY COMPLETE.

DRAFT SER ISSUED DECEMBER 5, 1986; PROGRAM ACCEPTABLE WITH OPEN ISSUES TVA CERTIFICATION EXPECTED IN MARCH 1987 WHEN MODIFICATIONS WILL BE ESSENTIALLY COMPLETE RESOLUTION OF HIGH ENERGY LINE BREAK AND THE EFFECTS ON EQUIPMENT IN THE MAIN STEAM LINE VALVE VAULT MAY BE PACING ISSUE FOR RESTART 4

I l

SEQUOYAH (CONTINUED) l j

0 OPERATIONAL READINESS (LEAD RESPONSIBILITY - REGION II)

I i

TECH SPECIFICATION SURVEILLANCE INSTRUCTIONS TVA REVIEWING FOR TECHNICAL ADEQUACY (772 0F 923 COMPLETED)

PROCEDURE CHANGES IN PROGRESS; ELEVEN LERS GENERATED TO DATE FOLLOWUP INSPECTIONS PLANNED MAINTENANCE ACTIVITIES NUCLEAR MANAGERS REVIEW GROUP EVALUATION AND STAFF INSPECTIONS IDENTIFIED MAINTENANCE DISCREPANCIES TRACKING AND TRENDING OF OUT-OF-CALIBRATION DATA NOT PERFORMED WEAKNESSES IN CORRECTIVE ACTION PROGRAMS AND MANAGEMENT INVOLVEMENT FOLLOWUP INSPECTIONS PLANNED 5

SEQUOYAH (CONTINUED) POST MODIFICATION TESTING WORK PLAN INADEQUACIES IDENTIFIED BY TVA AND REGION 11 FURTHER LICENSEE AND STAFF REVIEW IN PROGRESS EMERGENCY PREPAREDNESS ANNUAL EXERCISE HELD IN NOVEMBER 1986 - NO MAJOR WEAKNESSES IDENTIFIED TRAINING INSPECTIONS INDICATE THAT QUALIFICATION AND TRAINING OF PLANT STAFF ADEQUATE OPERATOR EXAMS BEING GIVEN IN DECEMBER 1986 6

BROWNS FERRY 0

DESIGN BASELINE VERIFICATION PROGRAM (DBVP)/ CONFIGURATION MANAGEMENT PROGRAM (CMP) (LEAD RESPONSIBILITY - IE)

WALKDOWN PROGRAM PLAN AND PROCEDURES APPEAR TO BE ACCEPTABLEJ PROGRAM SIMILAR TO SEQUOYAH ALMOST ALL MODIFICATIONS SUSPENDED PENDING COMPLETION OF SYSTEM WALKDOWN AND VERIFICATION TO ESTABLISH ACCURATE BASELINE TO DATE, LESS THAN TEN SYSTEMS VERIFIED DUE TO A LACK OF SYSTEMS ENGINEERS MAY BE PACING ITEM FOR UNIT 2 RESTART 0

FIRE PROTECTION (LEAD RESPONSIBILITY - NRR)

DRAFT NRC SAFETY EVALUATION ISSUED 10/29/86 AND TVA RESPONDED ON NOVEMBER 21, 1986.

SOME TECHNICAL ITEMS ARE:

DEFINING ALL FIRE AREAS TESTING OF FIRE DETECTION AND SUPPRESSION SYSTEMS NUMBER OF MANUAL ACTIONS FOR ALTERNATE SAFE SHUTDOWN l

MEETING TO DISCUSS FIRE PROTECTION PROGRAM HELD 12/10/86 SCHEDULE FOR RESOLUTION SLIPPING BY ABOUT TWO MONTHS OVERALL IMPACT ON RESTART SCHEDULE NGT YET APPARENT 7

i BROWNS FERRY (CONTINUED) 0 ENVIRONMENTAL CUALIFICATION (LEAD RESPONSIBILITY - IE) 11/20/86 - EQ PRE-AUDIT VISIT AT BROWNS FERRY.

RESULTS INDICATB:

PROCEDURES APPEAR TO BE WELL ORGANIZED AND VALID BASED ON EARLIER PROGRAMS AT SEQUOYAH E0 CABLE SIMILARITY PROBLEM NOW EFFECTS ABOUT 100 CABLES (SUBSTANTIAL DECREASE)

PROBLEMS MAY DEVELOP BECAUSE OF THE SUBSTANTIAL NUMBER OF MODIFICATIONS TO BE MADE O

OPERATIONAL READINESS PROGRAM (ORP) (LEAD RESPONSIBILITY -

REGION II)

DURING THE NOVEMBER SCHEDULE MEETING, TVA PRESENTED TO THE STAFF A BRIEF OUTLINE OF THE ORP.

THIS PLAN COVERS:

NUCLEAR PERFORMANCE PLAN IMPLEMENTATION IDENTIFICATION AND EVALUATION OF PERFORMANCE OBJECTIVES PROGRAM TO IDENTIFY RESTART REQUIREMENTS AND DOCUMENT THEIR COMPLETION LICENSED OPERATOR TRAINING AND REQUALIFICATION PROCEEDING ADEQUATELY l

l TVA FINAL OPERATIONAL READINESS REPORT EXPECTED ABOUT 6/87 MAY BE A PACING RESTART ITEM 8

}

WATTS BAR 0

WELDING (LEAD RESPONSIBILITY - NRR)

TVA REINSPECTIONS AND STAFF REVIEW CONTINUES TVA EVALUATING STRUCTURAL WELD F1NDINGS AND NEED FOR ADDITIONAL INSPECTIONS A SIGNIFICANT NUMBER OF CODE UNACCEPTABLE WELD DEFECTS FOUND DURING REVIEW OF ORIGINALLY ACCEPTED PIPING RADIOGRAPHS NRC LETTER OF 10/14/86 PROVIDED STAFF CONCERNS REGARDING ADEQUACY OF STRUCTURAL WELDING AND REQUESTED TVA TO REASSESS WELDING ASPECTS OF THE QA PROGRAM TVA RESPONSE OF 12/05/86 ACKNOWLEDGED "SIGNIFICANT DEFICIENCIES IN THE WELDING QA PROGRAM" IN WELDING OF ONE STRUCTURAL PLATFORM AND INTERPRETATION OF CODE REQUIRED RADIO-GRAPHS.

TVA RESPONSE UNDER STAFF REVIEW STAFF INSPECTIONS ARE ONGOING 0

QUALITY ASSURANCE (LEAD RESPONSIBILITY - IE)

QA TOPICAL SUBMITTED NOVEMBER 14, 1986; UNDER REVIEW BY STAFF INSPECTION OF IMPLEMENTATION IS PLANNED

CONTACTS WITH CONCERNED INDIVIDUALS AND TVA IG ACTIVITIES o

IN RESPONSE TO TVA IG REQUEST, STAFF CONTACTING SELECTED CONCERNED INDIVIDUALS TO OBTAIN PERMISSION FOR DIRECT CONTACT BY TVA IG TO RESOLVE WRONGD0ING CONCERNS o

INDIVIDUALS ASSOCIATED WITH H & I MATTERS OR ASSOCIATED WITH SEQUOYAH RECEIVE PRIORITY o

APPR0XiMATELY 270 LETTERS SENT; APPROXIMATELY 70 RESPONDENTS o

APPROXIMATELY 80 PERCENT OF RESPONDENTS AGREE TO BE l

CONTACTED BY TVA IG; OTHERS WILL REQUIRE ADDITIONAL STAFF ACTION

~

l o

TVA IG EVALUATING H & I CASES TO RECOMMEND APPROPRIATE LINE l

ACTION TO BE TAKEN REGARDING INDIVIDUALS ACCUSED OF H & I o

STAFF WILL AUDIT TVA ACTIVITIES IN EARLY 1987 N

9 a

10

l RESOURCES

SUMMARY

o NRC RESOURCES BEING EXPENDED AT RATE OF 60 - 70 PROFESSIONAL FTE o

OVER 1/2 0F RESOURCES COMING FROM REGION II l

l o

SCHEDULING OF FUTURE RESOURCES DIFFICULT DUE TO UNCERTAINTIES i

IN TVA SCHEDULE o

TVA EXPECTED TO REQUIRE A HIGHER RATE OF RESOURCE EXPENDITURE IN FY 1987 1

11

PRELIMINARY LESSONS-LEARNED REVIEW 0 PURPOSE

-T0 IDENTIFY MEANS BY WHICH THE NRC COULD HAVE RECOGNIZED THE SEVERITY OF TVA'S PROBLEMS EARLIER AND TAKEN MORE EFFECTIVE ACTION

-FOCUS IS ON IMPROVING NRC'S REGULATORY PROCESS 0 SCOPE

-LESSONS ARE GENERALLY PROGRAMMATIC AS REVIEW OF DETAILED TVA TECHNICAL ISSUES IS NOT COMPLETE

-TVA RESTART REVIEW IS SEPARATE FROM THE LESSONS-LEARNED PROCESS 0 NEXT STEPS

-LESSONS WILL CONTINUE TO BE LEARNED AS REVIEWS CONTINUE

-SUPPLEMENTAL REPORTS TO BE ISSUED AFTER SEQUOYAH RESTART AND SUBSEQUENT RESTARTS /STARTUPS

-INTERVIEWS WITH PARTICIPANTS PLANNED l

l 12

TVA PRELIMINARY LESSONS-LEARNED o

IMPROVE NRC IDENTIFICATION AND RESPONSE PROCESS FOR P00R PERFORMANCE.

INVOLVE LICENSEE EXECUTIVE MANAGEMENT EARLY l

0 IMPROVE NRC SKILLS IN ASSESSING LICENSEE MANAGEMENT l

PERFORMANCE o

IMPROVE NRC ASSESSMENT OF PROGRAMMATIC AND CUMULATIVE SIGNIFICANCE OF DEFICIENCIES I

o IMPROVE NRC VALIDATION OF LICENSEE SELF-INSPECTION PROGRAMS FOR DESIGN AND CONSTRUCTION o

IMPR0'vE TARGETING OF NRC RESOURCES NOT JUST FOR P00R PERFORMERS BUT TO SPECIFIC AREAS OF CONCERN AT A FACILITY o

IMPROVE LONG-TERM NRC MONITORING 0F LICENSEE CORRECTIVE ACTION PROGRAMS l

0 IMPROVE NRC MONITORING OF LICENSEE RESPONSE TO LONG-TERM, RESOURCE-INTENSIVE REQUIREMENTS AND COMMITMENTS 13

CONCLUSIONS o

TVA CONTINUING TO RECEIVE HIGH PRIORITY BY NRC STAFF o

EXTENSIVE INVOLVEMENT BY SENIOR NRC MANAGEMENT TEAM AND FREQUENT COMMUNICATIONS ARE MAINTAINED BETWEEN STAFF AND TVA o

CONFLICT OF INTEREST ISSUES AND MANAGEMENT REALIGNMENT CONTRIBUTED TO DELAYS IN TVA ACTIONS AND RESULTING STAFF REVIEWS o

RESOLUTION OF EMPLOYEE CONCERNS AND DESIGN CONTROL ISSUES EXPECTED TO BE PACING ITEM FOR SEQUOYAH o

RESOLUTION OF DESIGN CONTROL, OPERATIONAL READINESS, FIRE PROTECTION AND EQUIPMENT QUALIFICATION ISSUES EXPECTED TO BE PACING AT BROWNS FERRY o

MAJOR ISSUES FOR WATTS BAR INCLUDE DESIGN CONTROL, QA, AND EMPLOYEE CONCERNS ISSUES o

PRELIMINARY LESSONS-LEARNED ANALYSIS AND IMPLEMENTATION ACTIONS ARE IN PROGRESS l

o TVA EFFORT WILL CONTINUE TO IMPACT NON-TVA STAFF ACTIVITIES 14

4 h

WA PRB IMINARY LESSONS-tEAN DECEN ER 16, 1986 LL-1

1 l

1.

IDENTIFICATION OF POOR LICENSEE PERFORMING LESSON:

NRC NEEDS TO FURWER DEVELOP AND IPPLEE NT A SYSTEMATIC PROCESS FOR IDENTIFICATION OF POOR PERFORMING LICENSEES AND FOR FOCUSING AGENCY-WIDE ATTENTION ON POOR PERFORMING LICENSEES. AS PART OF THIS ATTENTION, AT EARLY STAGES OF DEGRADING LICENSEE PERFORMANCE, Tm REGIONAL ADMINISTRATOR SHOULD EET WITH SENIOR LICENSEE MANAGEE NT TO IDENTIFY PROBLEMS USING WHATEVER E ANS REQUIRED TO BE SURE THAT THE MESSAGE IS CLEARLY UNDERSTOOD.

DISCUSSION:

O SALP IDENTIFIED DETERIORATING PERFORMANCE AT WA AS EARLY AS 1980, O BROWNS FERRY SALP LEVEL 3 IN QUALITY PROGRAMS EVERY YEAR SINCE 1979.

- SALP LEVEL 3 IN OPERATIONS EVERY YEAR SINCE 1980.

- SALP LEVEL 3 IN MAINTENANCE EVERY YEAR SINCE 1981.

O SEQUOYAH

- SALP LEVEL 3 IN QUALITY PROGRAMS EVERY YEAR SINCE

1980, LL-2

I 0 WATTS BAR RECEIVED 6 0F THE 10 RATINGS OF SALP LEVEL 3 GIVEN TO CONSTRUCTION PLANTS IN REGION ll SINCE START OF CONSTRUCTION SALP IN 1981.

l 0 NO CONCERTED NRC RESPONSE TILL 2/85.

RECOPTENDATIONS:

0 USE FORMAL NRC SYSTEM TO IDENTIFY, ADDRESS AND MONITOR POOR PERFORERS.

O REFINE TOOLS TO IDENTIFY POOR PERFORERS.

O IffRO'E PROGRAM TO ALLOCATE NRC RESOURCES ON THE BASIS OF LICENSEE PERFORMANCE.

l l

I LL-3

II.

RESPONSE TO POOR llCENSEE PERFORMANCE LESSON:

NRC NEEDS TO DEVELOP A PROGRAM AND TE SKILLS FOR ASSESSING OVERALL LICENSEE MANAGEM NT PERFORMANCE AND l

IDENTIFYING INDICATORS OF MANAGEENT AND ORGANIZATIONAL DEFICIENCIES.

DISCUSSION:

0 AFTER TVA PROBLEMS BECAME OBVIOUS, NRC DID NOT PROMFT.Y ELEVATE ISSUE TO WA BOARD OR NRC EADQUARTERS MANAGEE NT.

O NRC RESPONDS FASTER AND MORE STRONGLY TO HARDWARE OR OPERATIONAL PROBLEMS THAN TO LICENSEE MANAGEENT PROBLEMS.

1 0 REQUIREMENTS CLEARER AND NRC STAFF MORE CONFIDENT IN l

HARDWARE AND OPERATION AREAS.

O DIRECT CAUSAL LINK BETWEEN MANAGEENT DEFICIENCIES AND l

PUBLIC HEALTH AND SAFETY LESS CLEAR.

LL-4

II RECOPHENDATIONS:

O SPECIFIC NRC MANAGERS RESPONSIBLE FOR OVERSIGHT OF LICENSEE MAPMGEMNT, O ESTABLISH HIERARCHY OF REGULATORY RESPONSE TO MANAGEENT DEFICIENCIES.

O RE-EVALUATE ADEQUACY OF NRC STANDARDS FOR ASSESSING MANAGEENT PERFORMANCE.

LL-5

Ill.

EVALUATION OF LICENSEE PROGRAM ATIC DEFICIENCIES LESSON:

NRC INSPECTION DOCLPENTS NEED TO INCLUDE A CLEAR ASSESSENT OF THE PROGR#tiATIC AND CLMILATIVE SIGNIFICANCE OF THE SPECIFIC DEFICIENCIES AND VIOLATIONS IDENTIFIED.

DISCUSSION:

0 NRC INSPECTIONS IN EARLY 80'S IDENTIFIED MOST OF PRESENT WA DEFICIENCIES BUT NOT TEIR SCOPE OR SERIOUSNESS.

O NRC INSPECTION DOCtfENTATION EPPHASIZED SPECIFIC DEFICIENCIES AND GENERALLY AVOIDED JUDGEENTS ON WA PROGRAM EFFECTIVENESS.

O WA INTERNAL REPORTS IDENTIFIED GENERIC PROGRAM DEFECTS BUT WERE NOT USED EFFECTIVELY BY NRC.

O SERIOUSNESS OF WA PROGRANiATIC PROBLEMS, THOUGH NOT EXPLICITLY STATED, COULD HAVE BEEN INFERRED FROM NRC INSPECTION DoctPE4TS.

i l

O TEAM INSPECTIONS SEEED MOST EFFECTIVE IN IDENTIFYING WA PROGRAPNATIC AND GENERIC DEFICIENCIES.

LL-6

III

_2-REC 0ft1ENDATIONS:

0 VIOLATION NOTICES INCLUDE ASSESSfEffT OF GENERIC OR CLMJLATIVE SIGNIFICANCE.

O INSPECTION REPORTS ASSESS EFFECTIVENESS OF LICENSEE PROGRAMS IN AREAS INSPECTED.

O INCREASE USE OF TEAM INSPECTIONS.

i LL-7

9 IV.

ASSURING QUALITY OF CONSTRUCTION LESSON:

SINCE THE NRC IS HEAVILY DEPENDENT ON EFFECTIVE LICENSEE DESIGI, CONSTRUCTION, AND SELF-INSPECTION PROGRAMS FOR PROVIDING A BASIS FOR CONCLUDING THAT A PLANT IS DESIGNED AND CONSTRUCTED SAFELY, THE NRC NEEDS TO DO MORE TO ASSURE TIE VALIDITY OF THOSE PROGRAMS AND THEIR IPPLEMENTATION.

DISCUSSION:

0 NRC INSPECTIONS DID NOT DETECT SCOPE AND SEVERITY OF TVA CONSTRUCTION PROBLEMS.

O TVA CONSTRUCTION PROBLEMS SIMILAR TO THOSE DISCUSSED IN FORD REPORT.

O NRC CONSTRUCTION INSPECTION RESOURCES VERY SMALL l

RELATIVE TO OVERALL CONSTRUCTION /QA EFFORT.

l l

0 NRC mST THEREFORE VALIDATE LICENSEE SELF-INSPECTION EFFORTS AND THIS W ST INCLUDE MORE DIRECT VERIFICATION OF HARDWARE.

O NRC EFFORTS HAVE FOCUSED LARGELY ON REVIEW OF LICENSEE PAPERWORK.

LL-8

9 IV 0 HIGHLY STRUCTURED ACTIVITIES WITH " THIRD-PARTY INSPECTION" UNDER ASE HAD FENER PROBLEMS AT WA.

O IN AREAS Ol}iER THAN ASE ACTIVITIES, WA USED ITS OWN RATHER THAN INDUSTRY STMOARDS.

O THIRD-PARTY INSPECTION IS A COST-EFFECTIVE WAY FOR NRC TO VALIDATE LICENSEE ACTIVITIES.

O WA QA PROGRAM DID NOT EVALUATE OVERALL SIGNIFICANCE OF INSPECTION FINDINGS.

O INVOLVEE NT OF LICENSEE MANAGEE NT IN ASSESSING QA RESULTS WAS LACKING.

O READINESS REVIEWS FORCE THIS MANAGEE NT ASSESSMENT.

RECOPtENDATIONS:

0 EVALUATE NEED FOR MORE THIRD-PARTY INSPECTIONS IN LIGHT OF READINESS-REVIEW ACTIVITIES.

O DEVELOP INNOVATIVE INSPECTION TECHNIQUES TO USE LIMITED NRC RESOURCES MORE EFFECTIVELY.

O EXAMINE VIGOROUSLY LICENSEE DEPARTURES FROM INDUSTRY STANDARDS.

9 IV 0 MORE NRC VERIFICATIONS OF AS-BUILT QUALITY (INCLUDING THIRD-PARTY VERIFICATION).

0 MORE FORCEFUL ENFORCEENT POLICY FOR CONSTRUCTION INADEQUACIES.

0 EMPHASIZE ROOT-CAUSE AND CORRECTIVE ACTION SECTIONS OF LICENSEE RESPONSES TO INSPECTION FINDINGS.

D 9

l LL-10

9 b

V.

ALLOCATION OF NRC RESOURCES LESSON:

NRC NEEDS TO ASSURE THAT SUFFICIENT RESOURCES ARE PROVIDED NOT ONLY TO CARRY OltT PROGR#NATIC EFFORTS AS WELL AS INCREASED EFFORTS AT P0OR PERFORMING LICENSEE BUT ARE DEVOTED TO THOSE AREAS OF GREATEST IDENTIFIED CONCERN.

DISCUSSION:

0 NRC INSPECTION RESOURCES FOR PROBLEM AREAS AT TVA NOT SIGNIFICANT1.Y DIFFERENT FROM OTHER PLANTS.

O " REQUIRED" INSPECTION PROCEDURES, IWLEE NTATION INSPECTIONS AND GENERIC INFORMATION-GATHERING ALL REDUCE RESOURCES THAT CAN BE ALLOCATED TO SPECIFIC PROBLEM AREAS.

O TECiti! CAL REVIEW RESOURCES ARE GENERALLY ASSIGNED WITHOUT CONSIDERATION OF SPECIFIC PLANT PROBLEMS, REC 0fHENDATIONS:

0 INCREASE NRC MANAGERS' FLEXIBILITY IN ALLOCATING RESOURCES.

O RE-EXAMINE NEED FOR GENERICALLY REQUIRED RESOISCES AND INSPECTIONS.

LL-11

9 VI, itASURING EFFECTIVENESS OF LICENSEE CORRECTIVE ACTION LESSON:

EFFORTS, SUCH AS THOSE MADE IN THE QA PROGRAMS AT TVA, TO CORRECT MMOR PROBLEMS SHOULD NOT HAVE BEEN CONSIDERED C0&LETE UNTIL SPECIFIC, DELIBERATE INSPECTIONS AND EVALUATIONS OF RESULTS OVER AN EXTENDED PERIOD INDICATED THAT SIMILAR PROBLEMS WERE NOT STILL OCCURRING AND THAT THE PREVIOUS PROBLEMS HAD BEEN CORRECTED.

DISCUSSION:

0 AFTER SEVERAL PROBLEM AREAS WERE IDENTIFIED BY THE NRC IN THE EARLY 80'S, TVA INSTITUTED MMOR CORRECTIVE ACTION PROGRAMS.

O THESE INCLUDED QA, OPERATOR TRAINING, PIPE SUPPORTS, AFD HAPASSENT AND INTIMIDATION.

O PROGRAMS, AS DESCRIBED, SHOULD HAVE WORKED.

l 0 PROGRAMS WERE REVIEWED BY NRC AND THEIR IWLEMENTATION INSPECTED.

l 0 IN GENEPAL, THEY WERE NOT SUCCESSFUL.

O RESULTS OF PROGRAMS WERE NOT FORMALLY MONITORED BY NRC OVER AN APPRECIABLE LENGTH OF TIME.

LL-12

O O

VI 0 SINCE NRC DEFINED THE NEED AND, SOMETIES, THE CCNTENT OF THE PROGRAMS, TVA MAY HAVE ACQUIESCED WITHOUT BELIEVING 11EY WERE NECESSARY OR APPROPRIATE.

RECOP9ENDATION:

0 INSPECT RESULTS OF CORRECTIVE ACTION PROGRAMS.

O USE THIRD-PARTY INSPECTIONS TO CONSERVE RESOURCES.

O DEFINE ENFORCEMENT ACTIONS FOR USE WHEN CORRECTIVE ACTION IS INEFFECTIVE.

O REVIEW PROPER ROLE OF NRC IN FORPULATING CORRECTIVE ACTION PROGRAMS.

LL-13

VII.

MEASURING LICENSEE REGULATORY PEPFORMANCE LESSON:

PERFUNCTORY RESPONSES TO LONG-TERM, RESOURCE-INTENSIVE REGULATORY REQUIREENTS, LIKE FIRE PROTECTION, AND EQUIPENT QUALIFICATION AND A POOR RECORD IN SURVEILLANCE AND MAINTENANCE WERE INDICATIVE OF A LACK OF WA MANAGEMENT'S EFFECTIVE OVERALL COPNITMENT TO SAFETY. NRC NEEDS TO EXERT DILIGENCE IN REQUIRING LICENSEES TO PR0ffTLY COPPLETE ACTIONS IN RESPONSE TO REGULATORY REQUIREENTS AND COPNITENTS.

DISCUSSION:

0 WA RESPONSE TO MAJOR REGULATORY REQUIREENTS SLOW AND PERFUNCTORY.

O EXAPPLES INCLUDE TMI ACTION PLANS, EQ AND FIRE PROTECTION.

O WA'S RESPONSES WERE ORIGINALLY SET UP WITH ADEQUATE RESOURCES AND CAPABILITIES FOR TIELY COPPLETION.

O DURING OPERATION, THEY SUFFERED FROM LACK OF MANAGEENT ATTENTION.

O NRC DID NOT AGGRESSIVELY MONITOR PROGRESS AND MAY HAVE ACCEPTED PROGRM PLANS AS ENDS IN THEMSELVES.

LL-la

O VII 0 SIMILAR LONG-TERM RESOURCE-INTENSIVE EFFORTS AT TVA LIKE MAINTENANCE AND SURVEILLANCE HAD SIMILAR PROBLEMS.

O THIS SORT OF PROBLEM OCCURS AT MANY POOR PERFORMING PLANTS.

RECOPtENDATIONS:

0 MORE SOPHISTICATED LICENSEE TRACKING SYETEMS.

O ENHASIZE REGULATORY REQUIREENTS PERFORMANCE IN SALP.

O ALLOCAu NRC RESOURCES FOR PRONT REVIEW AND INSPECTION OF NEW REQUIREMENTS.

O RESPOND PROMPTLY TO LICENSEE SUBMITTALS.

O SCHEDULE PROGRESS REVIEWS AND INSPECTIONS OF REQUIREENTS.

O SCHEDULE VERIFICATION INSPECTIONS PROMPTLY.

LL-15

o POSSIBLE RITURE LESSONS O

ADEQUACY OF APPENDIX B AS AN ENFORCEE NT TOOL.

O USE BY NRC 0F LICENSEE INTERNAL DOCLNENTS.

O IMPROVED NRC INSPECTION REVIEWS OF SPECIALIZED TECWICAL AREAS.

O BETER GUIDANCE ON BASIS FOR CERTIFICATION OF READINESS FOR LICENSING.

O MORE EFFECTIVE LICENSEE SENIOR MANAGEMNT PARTICIPATION IN QA.

O MORE EFFECTIVE NRC RESPONSE TO WIDECPREAD HARASSENT AND INTIMIDATION.

O MORE EFFECTIVE NRC HA!E.ING OF EN LOYEE SAFETY CONCERNS.

O BETTER INTERNAL NRC COORDINATION IN DEALING WITH " PROBLEM" lITILITIES.

i LL-16

s s

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s w

LESSONS LEARNEDtCHRON0 LOGY

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04-08/85 TVA SHUTDOWNS

.i N

f v

01/86 COMMISSION DIRECTIVE TO UNDERTAKE LESSONS-LEARNED I

N' REVIEW AFTER SEQUOYAH RESTART 2

04/86 TVA MAKES FIRST OF SERIES OF ELIPS IN SEQUOYAH

\\

RESTART SCHEDULE s

08/86 STAFF ADVISES COMMISSION OF PLANS AND SCHEDULE FOR LESSONS-LEARNEDsREVIEW t

s 09/86 COMMISSION REQUESTS PRELIMINABY LESSONS-LE'ARNED't REPORT BY NOVEMBER 4

11/86 PRELIMINARY LESSONS-LEARNED REPORT DELI)/ERED i

t 11/86 IMPLEMENTATIONJPLANNING AND INTERVIEWS OF PARTICIPANTS UNDERWAY s

12/86 BRIEFING 0FCOQMISSION

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LL-17

GENERAL CONCLUSIONS OF PRELIMINARY LESSONS-LEARNED REVIEW A.

OBSERVATIONS:

o NRC IDENTIFIED SIGNIFICANT PROBLEM AREAS IN THE EARLY 1980'S o

TVA INSTITUTED VARIOUS CORRECTIVE ACTION PROGRAMS o

PROGRAMS WERE NOT EFFECTIVE AND TVA PERFORMANCE CONTINUED TO DETERIORATE o

SHUTDOWNS REPRESENTED CULMINATION OF A SERIES OF PROBLEMS 3,;

S00TCAUSES:

Q LACK OF LEADERSHIP BY TVA MANAGEMENT o

PERVASIVE BREAKDOWN IN TVA MANAGEMENT'S CONTROL OF AND COMMUNICATION WITH EMPLOYEES o

STEMMED FROM INEFFECTIVE TVA MANAGEMENT AND FRAGMENTED ORGANIZATIONAL STRUCTURE C.

NRC'S ROLE:

o CORRECTIVE ACTION PROGRAMS ADDRESSED SPECIFIC AREAS OF DEFICIENCY-SYMPTOMS AND NOT ROOT CAUSES o

DEPTH OF NRC CONCERN NOT EFFECTIVELY COMMUNICATED TO EXECUTIVE MANAGEMENT OF TVA OR NRC UNTIL EARLY 1985 o

NRC'S ACTIVE ROLE IN DEVELOPING SPECIFIC CORRECTIVE ACTION PROGRAMS LED TO EXCESSIVE TVA RELIANCE ON NRC AND A LACK 0F TVA COMMITMENT TO EFFECTIVELY S0LVING THEIR PROBLEMS o

NRC MAY HAVE PARTIALLY RECOGNIZED THE FUNDAMENTAL TVA MANAGEMENT PROBLEM BUT NEVER DEALT WITH IT DIRECTLY AND FORCEFULLY UNTIL EARLY 1985 LL-18

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Document Control Desk, 016 Phillips l

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The Public Document Rocm 3!

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FROM:

SECY Correspondence & Records Branch l

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Attached are copies of a Comission meeting transcript and related meeting 3 ll document (s). They are being fontarded for entry on the Daily Accession List and

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placement in the Public Document Room. No other distribution is requested or a

required.

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Meeting

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S i Meeting Date:

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1. TRANSCRIPT 1

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C&R Branch files the original transcript, with attachments, without SECY jli papers.

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