ML20215H195

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Assessment of Browns Ferry Regulatory Performance Improvement Plan
ML20215H195
Person / Time
Site: 05000000, Browns Ferry
Issue date: 07/30/1984
From: Whitt K
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML082410821 List:
References
R-84-20-BFN, NUDOCS 8706240028
Download: ML20215H195 (16)


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1 TENNESSEE VALLEY AUT110RITY NUCLEAR SAFETY REVIEW STAFF REVIEW NSRS REPORT NO. R-84-20-BFN

SUBJECT:

ASSESSMENT OF THE BROWNS FERRY REGULATORY PERFORMANCE IMPROVEMENT ~ PLAN DATES OF j

REVIEW; MARCH 12.- JULY 20, 1984 l

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REVIEWER:

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4 K. W. WHITT DhTE APPROVED BY:

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7/3o/9y H. N. CULVER DATE I

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I TABLE OF CONTENTS l

Page I. Scope.

1 II. Conclusions and Recommendations.

1 A.

Conclusions 1

4 1

B.

Recommendations 2

III. Details.

2 A.

General Information 2

B.

Management Controls 2

l C.

Programs.

9 D.

Summary 10

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I.

SCOPE This review deals with the NSRS assessment of nuclear activities asso-ciated with the Browns Ferry Nuclear Plant (BFN) Regulatory Perfor-mance Improvement Plan (RPIP).

It is a continuation of the review conducted during the period of January 23, through March 9,1984, and documented in NSRS Report No. R-84-04-BFN.

This report contains a record of review activities from March 12 through July 20, 1984.

II.

CONCLUSIONS AND RECOMMENDATIONS A.

Conclusions 1.

At the inception of the RPIP in January 1984 regulatory performance problems existed and were recognized by a sig-nificant portion of the Office of Power (POWER) management.

The most visible cause of this condition was inadequate pro-grams for performance of regulated activities.

The source cause, however, was inadequate management controls that allowed the weak programs to exist and failed to require strict adherence to the existing programs which would have necessitated program improvements.

This unsatisfactory con-dition persisted and deteriorated while BFN was being operated under and in a high degree of compliance with the management policies of the Division of Nuclear Power.

(See section III.B for details.)

2.

One of the most important efforts to be accomplished to assure complete and lasting success of the RPIP is the pulling together of the personnel resources at the plant so that a team effort is realized. The primary responsibility for accomplishing this task rests with the Plant Manager, but the Site Director will need to provide guidance and direction for the Plant Manager and assure that through the remainder of the site organization the Plant Manager receives the necessary technical and administrative support to accom-plish this goal.

(See section III.B.1 for details.)

3.

An improvement in the relationship between the line and QA organization is needed.

Some progress has been made through reorganization and selection of personnel.

However, signif-icant additional improvement of the overall QA program at the site is necessary to obtain and maintain the desirable confidence level of employees that quality is being served during both the performing and assuring phases.

(See section III.B.2 for details.)

1 4.

Improvements in the programs and management controls are being accomplished through the RPIP.

The work is not pro-gressing as fast or as orderly as NSRS anticipated, but management actions are being taken to assure continuous progress.

(See section III.C for details.)

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5.

The reorganization of POWER and the Office of Engineering Design (EN DES), the establishment of the Office of Nuclear Power, the organizational decentralization to piantsites, and the selection and transfer of personnel have had a short term negative impact on the accomplishment of the RPIP. How-ever,. there - are indications that the long-term benefits of these activities will contribute positively to the lasting success of the plan.

Some positive aspects are already beginning to emerge.

(See section III.C for details.)

B.

Recommendations No recommendations are being made in this report since site and plant management are well aware of concerns of the NSRS reviewer and are working toward meaningful resolution.

III. DETAILS A.

General Information During this review period, the NSRS reviewer attended RPIP over-j sight group meetings on March 26, April 9, April 23, May 21, 4

June 18, and July 16.

In each case, the meeting was held on Monday and the reviewer spent the remainder of the week at the BFN site observing activities and talking with personnel in an effort to assess the progress of the RPIP.

During this period, most RPIP tasks were initiated and many were completed.

By early May the regulatory compliance training was well advanced and the information about the RPIP, the reasons for the RPIP, and how all employees were expected to contribute to the effort to improve regulatory compliance had been disseminated to most of the BFN personnel.

'At this point supervisors were making planned plant tours routinely and observing work activities in their areas of responsibility; and those individuals responsible for upgrading procedures in various areas had begun to recognize the vastness of their undertaking.

By the middle of July about 55-60 percent of the short-term action tasks had been completed. Almost every-one at the site was thoroughly familiar with the RPIP effort, but many still referred to it as "their" or " management's" improve-ment plan.

There also continued to be some amount of apprehen-sion on the part of both plant and site personnel about the l

distribution of work activities and the interface between the two groups at various levels.

Throughout the entire review period plant, site, and central office management remained firmly commit-ted to the RPIP and a general conviction that BFN could and would be operated effectively, safely, and in compliance with regula-tions.

B.

Management Controls The various management control problems that brought about or contributed to the final condition at BFN that required the j

initiation of the RPIP have been reviewed, studied, and discussed 2

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by employees and management at all levels throughout TVA.

Fur-ther discussion of ' these factors in this report would serve no-useful purpose.

Rather, this report will be used to document some of the actions being taken to correct the undesirable condi-tions and some of the problems.that represent potential obstacles.

However, for the benefit of clarity, one point should be explained that may not have been put in perspective in some discussions.

BFN did not attain its poor. regulatory performance record by functioning totally autonomously outside the guidance of the central office.

The plant operated within the guidelines and direction of the Director of Nuclear Power to a high level of compliance.

Division management was.well aware of plant manage-ment philosophies, practices, and directions at BFN.

Conse '

quently, the problems at BFN are not unique to BFN, but perhaps just better recognized there than at other operating sites.

1.

Personnel a.

Management and Supervision.

The management and super-vision team at BFN has been continuously upgraded and

  • - improved during the past three years.

The overall management staff in general is competent, sincere, willing, and unselfish in the performance of their responsibilities in the best interest o f TVA.

A few apparent individual weak areas still-exist.

These are under continuous observation and evaluation by top plant management and will be corrected in the appropri-ate manner.

All the managers and most supervisors are intimately familiar with the' RPIP and are enthusiasti-cally supporting the goal of the plan.

b.

Craftsmen.

The regulatory compliance training was received well by the craf t prsonnel.

Discussions with a sample of the craftsmen indicated that they had always known - that. there was an NRC ' and that. certain things had to be done a specified way because of NRC.

However, prior to the training, they had not understood the real reasons for strict compliance, or how the quality of their work could impact on the overall performance of the plant from the regulatory standpoint.

The compliance training helped them to understand the

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overall mission of the plant and how they contributed j

to' that mission.

Many craftsmen indicated that it helped them to feel more like a part of the team.

It also helped them to understand the importance of fol-lowing written instructions and their responsibility to follow procedures and report inadequacies to supervi-sors for correction.

l The morale of the craftsmen appeared to be good.

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Almost all the craftsmen with which discussions were held indicated that they were glad to have a job and q

enjoyed working at BFN.

During approximately 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> of discussions with the craf tsmen and observation of 3

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work activities, _nothing was heard or observed that indicated poor work practices or negative attitudes.

Essentially no complaints were volunteered. When asked about things that bothered them or hampered their work,

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the most common responses were the 11-29 policy which requires the yearly layoff of hourly craf tsmen, sick leave policy, and inconsistent hard hat rules.. Things that delayed work but didn't cause - serious problems because they had learned to deal with them and accept them included improper work preparation and coordina-tion between crafts (i.e.,

inadequate lighting in remote radiation areas) and delays in getting health physics coverage, c.

Engineers. In February 1984 the morale of the engineers at BFN was dismal.

During the past six months, it has improved a good deal, but it still is not good.

It was not necessary to encourage. the engineers to talk about things that bothered them.

They were bothered by i

everything from mental and physical exhaustion from overwork to the doldrums or boredom. The engineers are well aware of the RPIP and what it is trying to accom-plish.

However, they do not consider the plan to be a BFN plan.

It is spoken of as "their" plan referring to 3

management.

Many engineers are not convinced that management will commit the necessary resources to bring.

about consistent regulatory compliance on a long-term basis.

They believe that when the NRC is consoled and management is ready to go back to the old way of doing '

business, the RPIP will fade as many previous improve-ment ef forts have (e.g., the six point program of 1982 for regulatory improvement).

NSRS believes that the RPIP will be fully implemented in close agreement with the present schedule.

A recent, order by NRC will con-tribute to timely and full implementation of the plan.

However, the timeliness and degree of implementation is not the important issue here.

The fact that engineers have developed an attitude that allows them to think in this manner is the root problem. An honest perception is almost as bad as the actual situation from the engineers' perspective.

This and similar perceptions keep the engineers from participating as full team members.

This is also what management must cope with in the effort to overcome the regulatory and other problems at BFN.

To realize the goals of the RPIP everyone at the site must work together as a cohesive unit.

This unity does not exist at the present, and important measure of the success the RPIP and the one fully effective recovery ability of BFN to produce a will be the degree to which all the resources can be managed into a functioning unit working together for common goals.

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To resolve the morale problem, one of the early ques-tions to consider is whether or not there is a basis for the bad feeling that can be dealt with through the existing management-employee communications process.

Some of the things that seem to be most troublesome to the engineers and that were mentioned most frequently and with the greatest force include the merit pay system, management insensitivity to people problems, personnel policy in general, lack of involvement of engineers in the plant decisionmaking process, shift work for shift technical advisors (STAS), failure of management to listen, not enough interesting work, concern about the division of work between the site and plant staff, relationship between site and plant man-agement, and not being able to complete work in a timely manner because of change in priorities or for some reason what was important yesterday is unimportant today.

None of these items alone are indicative of a severe nuclear safety problem, but taken together they represent an obstacle to the successful implementation of the RPIP.

If the RPIP is unsuccessful, regulatory problems will continue and nuclear safety could be compromised.

j The question of whether the concerns on thin list are l

real or only perceived by the engineers needs some attention.

If they are all just perceptions, a serious problem confronts management because the engineers must be convinced to change their way of thinking.

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d must in some way convince the engineers to conclude that there are really no problems at BFN that should 1

not be expected in the routine pursuit of an engineer-ing career in the nuclear industry.

On the other hand, if some of the concerns are real and can be resolved in a responsible manner that is beneficial to the engi-l neers and TVA, the confidence of the engineers may be improved and the RPIP could be more successful.

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The NSRS reviewer has spent almost 50 percent of his onsite time talking with and observing the engineers at BFN. He has become convinced that some of the concerns are valid and deserve serious management attention.

These include the merit pay system, involvement of engineers in problem solving and technical decision making, 8-hour shifts verse 12-hour shifts for STAS, and a lack of interesting work for engineers. The reso-t lution of all of these may not result in favorable actions for the engineers, but the reasoning for the actions should be well defined and reasonable.

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merit pay system was by far the most frequently stated cause of poor morale and negative attitudes.

No single individual had any good to say for the merit pay system.

For this reason the merit pay system is being given

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J special attention here. A representative sample of the undesirable aspects of the system and associated prob-

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lems stemming from the system that were presented by the engineers will be presented in the following para-graphs.

The engineers have been told that the merit pay system was designed to reward good performance.

Most of them 1

do not really understand the system.

They do not know how it is determined how many individuals are eligible or who will get the available merit increases.

It has been concluded by the majority that about 15 percent of j

engineers will receive a merit increase each year.

They are quick to point out that if only 15 percent of 1

the engineering staff are good performers and worthy of

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reward, there should be no surprise that BFN has prob-lems.

j Each supervisor has a designated amount of money to allocate to merit pay.

When these funds are gone, presumably to reward good performers, there is nothing left to reward other good performers.

Unlike the MAS for managers which provides for the appraisal of all J

managers at the same time, engineers are appraised at j

different times depending on the TVA service start date.

This causes a number of problems.

It assures concinuous discontent throughout the year, year after l

year.

It puts an added burden on the supervisors.

People that are appraised early in the year must be compared with future performance of others that will be appraised later.

If the early appraisees receive a merit increase, those that will be appraised later know I

they will not get a raise and question how the supervi-sor knows they will not perform better than the earlier appraisees.

If the early appraisees get a good appraisal but no raise, they question how the supervi-sor knows that later appraisees will perform better.

The engineers have the perception that there is no systematic approach to the administration of the sys-tem.

According to them, some supervisors give the raises to the first employees that are appraised satis-i factory and then blame the system during the remainder l

of the year by declaring that there isn't any money available; some alternate the raises for different personnel each year; some give raises to their favor-ites; and some administer the system in ways that are indeterminable, i

It was pointed out by the engineers that TVA is prob-ably not saving any money with the existing system as compared with the previous one.

They believe that the

% supervisors spend on written justifications for those few engineers that do get raises cost more than i

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the raises for the additional engineers would cost.

This is probably somewhat exagerated, but the time spent for each justification could equal the merit pay justified according to data received f rom the engineers and supervisors.

Further, the requirement for this exacting justification indicates a lack of confidence in the supervisors by management.

Under the old system there were probably a few engineers that received raises that did not deserve them, but management should deal with these few rather than penalizing the large majority of good performers.

The final point that will be made at this time is the matter of bonuses.

The engineers are aware that man-agement personnel get site differential pay and opera-tors get licensing pay while they don't get even a small merit pay increase.

They do not understand the managing philosophy that fosters this situation.

The engineers have concluded that the only path to career success and advancement leads out of TVA.

The NSRS

- reviewer interviewed four terminating employees during this review period.

Many of the concerns listed in this section were given as reasons for leaving TVA, but in each case the overriding and most conclusive reason was the merit pay system.

This has not exhausted the problems that BFN engineers and supervisors had with the merit pay system, but the information presented should be sufficient to indicate a need for consideration of comprehensive changes in j

the system.

No formal recommendation is being made to i

management in this report because plant and site man-agement are well aware of the situation and are working

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toward a resolution.

1 Before the general topic of engineers' problems and performance,is left, the point needs to be made that the attitudes are not entirely due to poor working conditions and relationships with policies.

There are a number of engineers, some of whom are talented and capable individuals, that have become habitual com-plainers.

While there are a number of actions that management can and should take to improve general i

working conditions for engineers, some of them need to be kept busier.

Those individuals that perform satis-factory but have additional capability should be extended to the full limit of their ability.

2.

Quality Assuring During the early stages of the RPIP, the roles of most of the various quality assuring groups were relatively well understood by the people involved with quality activities.

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With the reorganization of quality assurance and the -dis-persion ' of the Office of Quality Assurance (0QA), and the establishing of quality assurance (QA). organizations in a number of the offices within Power and Engineering, the l

roles of all these QA organizations have become somewhat nebulous and~ difficult to define at the site Prior to June, the Quality Engineering (QE) and Quality Control (QC)

Groups were a part of' the line organization and performed a j

verifying function for the performing line.

All the quality assuring functions ' performed outside the line.were the responsibility of OQA.

Now it is not clear who within TVA is responsible for the quality assuring function, or whether it is to be a function of the line or an independent group or a combination of line and independent groups. This will j

all get worked out in time, but the present speculation and uncertainty in the area of QA is not conducive to the. fast-and smooth implementation of the RPIP.

The relationship between the QE/QC Groups and the Maintenance / Outage Groups has not. been good at any point during the RPIP implementa-tion, including the present.

One of the primary reasons for the poor working relationship between QE/QC and the performing groups is the assignment of responsibility through upper-tier documents developed in the.

Central Office.

Through these documents (primarily the i

Operational Quality Assurance Manual), the performing groups have been divested of many of the responsibilities tradi-tionally assigned to the performing organizations.

These documents ~ appear to have been written in an 'ef fort to control plant management through the quality assuring func-tion.

This was probably done because Central Office man-agement believed it was necessary in order to relieve regu-latory pressure during various periods of regulatory compli-ance confrontation with regulatory agencies and internal review groups.

Personnel ' within the QE/QC organizations i

have become convinced that the responsibility and authority i

delegated to them through the upper-tier documents represent j

the balance between production and quality.

Without such delegation they believe plant management would allow quality i

and nuclear safety to deteriorate significantly in' favor of j

production.

There may have been a time when management did not pay as-much attention to quality and safety as they should.

This may exist to some extent even today. However,.it is widely recognized that quality and safety cannot be regulated into practice to the degree necessary to ensure the confidence level desired and required within the nuclear industry.

The only way to get the desired confidence is for the people doing the work to want to do it right and to know they have time to do it right.

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AL.BFN an attempt is being made to reduce the QE/QC review of some functions from 100 percent review to some sample type review.

The old question of whether the chicken or the I

egg came first has developed.

This particular discussion deals with whether QE/QC should reduce the review frequency and allow the line to perform on its own or whether the line must get its act together and perform to the satisfaction of QE/QC before the frequency of the reviews is reduced.

The NSRS position is that the line organization is responsible for establishing quality assurance requirements.

The line organization is responsible and accountable for performing the work in a quality and safe manner.

QA is responsible for sampling the work and identifying work activities that are not being performed in a quality manner and increasing the frequency when the deficiency level increases. -If 100 percent inspection is necessary, neither the line nor QA has performed their responsibility satisfactorily.

BFN should have a strong quality assuring organization with official stop work authority.

The present unofficial stop i

work practice through the withholding of signatures during a review should be deleted.

The upper-tier documents should be revised to give the responsibility for performing work properly back to the line.

The line should then be held accountable for proper performance.

C.

Programs The programs that will be discussed here consist of the lower-tier procedures that are used to accomplish the work while imple-menting the guidance and requirements of all the higher docu-ments.

A program typically would consist of the written proce-dures necessary to conduct the activities of-a given functional area.

It was these programs that provided the greatest visible weaknesses and' led to the recognition of the unusually poor regulatory performance which triggered the initiation of the RPIP.

The weak programs were indicative of the earlier philoso-phy regarding adherence to procedures.

The functional areas initially identified as having poor regula-tory compliance history and deserving priority attention included health physics, radwaste management,

security, modification activities, and chemistry. Within a short period fire protection and mechanical maintenance were added.

A special project manager representative from the Central Of fice was assigned to each of

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these areas (except modification activities) to evaluate and upgrade the procedures.

The Central Office personnel were to review the procedures, revise or rewrite the procedures as neces-j sary, work through the activity to be performed by the procedure j

to assure satisfactory performance, revise the procedure as necessary, and submit to PORC and the Plant Manager for review and approval respectively.

Significant numbers of program defi-l ciencies were quickly identified.

Several program representa-Lives determined that the work needed to progress in phases 9

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rather than attempting to correct all deficiencies in one step.

Consequently, for about half of the programs an assessment phase and an implementation phase were designed.

These phased programs included health physics, fire protection, and security.

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early stages of the RPIP this process appeared to slow down the j

actual procedure upgrading.

However, the assessment phase was completed and by the end of this review period the recommenda-tions had been evaluated and most approved by the Plant Manager.

The assignments for implementation were being made and work was starting to progress more smoothly.

The procedure evaluation and upgrading workload was more signifi-cant and the progress was slower than anticipated.

This was aggravated by the numerous unanticipated organizational changes and associated actions that occurred during the early stages of the RPIP.

Most of the people involved in the procedure work and other RPIP actions found that they were being considered for jobs in various locations due to the reorganization.

It was difficult for them to concentrate fully on the immediate assignments and look out for their interests in the reassignment and transfer arena. "Further, the responsibility for procedure upgrading had been assigned to the Central Office personnel.

With the estab-lishment of the Site Director and his onsite organization, the responsibility for procedures became uncertain.

Most of the problems associated with procedure programs improve-ment have been resolved.

Ilowever, there are still a larger number of procedures at BFN that do not provide complete instruc-tions necessary to accomplish the intended function in the i

intended manner.

This renders BFN vulnerable to regulatory compliance violations.

Improvements in procedure systems result in immediate benefits to the image of the RPIP and to operational activities of BFN.

Therefore, continual and increased emphasis in this area is encouraged.

D.

Summary During the final week of this review period, several individuals indicated that the activities associated with the RPIP appeared to be slowing down.

NSRS also independently observed indications of slower progress,

There are several reasons for this percep-tion including the transfer of several key individuals to other jobs not associated with the BFN RPIP, involvement of personnel in some aspect of the reorganization, reassignment of personnel to different jobs that have dif ferent degrees of responsibility for RPIP functiont~, and temporary burnout from overwork on RPIP.

However, the most direct reason for slowing down is probably the fact that the tasks that could be concluded quickly are mostly done and the remaining tasks are the more difficult ones that require more time and effort by all involved personnel.

While the accomplishment of specific tasks may appear to be progressing slower, NSRS is convinced that BFN site and plant management are determined to accomplish the RPIP in an expeditious manner. They 10

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will also insist on support from any TVA organization or.individ-ual as necessary to assure safe operation of BFN in essentially full compliance with regulations.

A brief summary of some of the i

short-term objectives from an independent overview perspective is presented for general information:

1.

Increase management awareness of their responsibiltiy, i

authority, and accountability for. strict adherence to regu-latory requirements.

This objective has been largely completed.

All management and supervisory personnel at the site are aware of and indicate agreement with the regulatory compliance policy.

Some amount of training and retraining will continue in this area for some time.

2.

Increase time available for plant supervisors to be involved in workplace activities.

Most of the work planned for this objective has been com-pleted.

Good improvement has been realized as a result of the actions taken.

However, additional tasks may be neces-sary to gain the full results desired.

The findings and recommendations of studies made by outside consultants may result in further efforts in this area.

3.

Increase employee awareness of their responsibility and accountability for strict adherence to regulatory require-ments.

The training developed to accomplish this objective was very effective.

It was developed and presented in a skillful manner.

The employees (especially craftsmen) learned much about the requirements for doing their work in a specific way that they had not known or been particularly interested in before.

They appreciated the-effort made to inform them -

of the reasons for the extra care necessary at nuclear

  • plants. The training has been essentially completed for the personnel employed at this time.

The training will be provided for new employees on a continuing basis.

4.

Reorganize the plant to better manage control of plant

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activities.

The reorganization proposed here plus much more was, or will be, accomplished in the reorganization and decentralization of Nuclear Power.

J 5.

Assign division program manager representation onsite to provide independent management review of program implementa-tion.

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The assignment of ' personnel has been made and the work is

. progressing.

Some. of. the accomplishments and problems

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associated with this obj ective are discussed in section III.C of this report.

og 6.

Upgrade licensed operator training and requalification

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training.

<... s Most 'of this ~ work has been completed with good results as

@ 'Y indicated by the achievement of BFN operations personnel on a,

requalification examinations administered by ' NRC - in March 1984.

7.

~ Evaluation of regulatory compliance history.

This~ objective has been completed. The information obtained

.from the evaluation is still being studied to determine actions that can be taken to minimize the deficiencies in

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the areas identified as being most vulnerable to the various organizations performing reviews, audits, inspections, etc.,

of plant activities.

Similar progress has also been made for the long-term objectives, but since they are more difficult and time-related, presentation of an itemized status will not be attempted at this time.

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} UNITED STATES GOVERNMENT

  • Memorandum TENNESSEE VALLEY AUTHORITY G N S 'B n 2 0 7 o 5,

J,. A. Cof fey, Site Director, Brovos. Ferry Nuclear Plant To PROM

'll. N. Culver, Director of Nucleat Ga fety Review St.a f f, 249A IIBBK

'l DATE December 7, 1984

SUBJECT:

BROWNS FERRY NUCLEAR-PLAh'T (BFN) - NUCLEAR SAFETY REVIEW STAFF (NSRS)

INVESTIGATION INTO PROBLEMS CONCEhNING CATEGORY l SUPPORTS - NSRS REPORT NO. 1-84-30-BFN On October 2, 1984, you requested NSRS to investigate allegations by a former steamfitter foreman at BFN that (1). category I supports had w

been improperly inspected, (2) personnel had utilized drawings improp-erly, (3) work had been performed without proper authorization, and (4). he had informed modification personnel of allegations 2 and 3 and no corrective action was taken.

The attached report examines the allegations and the conditions asso-ciated with the allegations.

It is NSRS' conclusion that there is sufficient information to support the first and third allegations made by the steamfitter foreman.

We concur that a category I support with 1

deficiencies in weld quality and physical measurements was inspected and certified acceptable and that work was performed without proper authorization.

As for the allegations concerning improper use of drawings and inappropriate action by modification management, no evidence was discovered during the investigation to substantiate these allegations.

Also, it was. coactuded that the program for support.

installation inspection in use during the identified time period was marginally adequate to have done the job properly.

However, the work was not completed in accordance with the procedure since the quality control inspectors and cograizant engineers did not follow procedures.

Additionally changes in responsibility were made without changing the

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procedure.

It is further the conclusion of NSRS that the corrective actions j

already taken by the site:

repair of the category I support, rein-spection of' the implicated inspector's work and of randomly selected supports, and revisicn of the procedure for inspection of category I supports were app rop riate.

In addition, the site was planning to revise the work control procedure to ellow needed flexibility in the work control process.

NSRS will informally follow-up on this action to assure timely resolution.

MSRS HLE l

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i.s b.. I ' e e,...;.... e Rne ale Ih.onlowin n>> the Pnvrnli Savinos Plan

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'J. A. Coffey December 7, 1984~

BROWNS FERRY NUCLEAR PLANT (BFN) - NUCLEAR SAFETY REVIEW STAFF (NSRS)

INVESTIGATION INTO PROBLEMS CONCERNING CATEGORY 1 SUPPORTS - NSRS REPORT NO. I-84-30-BFN If you have any questions concerning the contents of this ' report, cplease contact A. G. Debbage at extension 4813 in Knoxville, H. N. Culver 14 o

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.AJ' CMK:LML Attachment ec (Attachment):

C. W. Crawford, 670 CST 2-C 4, :

J. P. Darling,.1750 CST 2-C R. J. Mullin, 1735 CST 2-C KEDS, W5B63 C-K i