ML20236E282
| ML20236E282 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/28/1987 |
| From: | Frane J, Grill J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20236E191 | List: |
| References | |
| 204.1(B), NUDOCS 8710290154 | |
| Download: ML20236E282 (28) | |
Text
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-TVA' EMPLOYEE [ CONCERNS REPORT. NUMBER: ;204.1 (B)
SPECIAL PROGRAM.
REPORT TYPE: ' SEQUOYAH ELEMENT REVIS10N' NUMBER: '1
~ TITLE:. ORGANIZATION OR' OPERATING PROCEDURES
. Organizational Structure Requires Excessive:
Documentation PAGE-1.0F 15 Reviews / Approvals Procedures.-
Response Time.
a:
REASON FOR REVISION:
.1, Revised format of text to improve clarity, utilized existing Corrective-Action P1an 204.01 NPS-02,-and added Section 10, Corrective Action.
PREPARATION
. PREPARED BY:
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DATE REVIEWS W: . REVIEW COMM TTE -
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ATURE k LO 5- l4-27 DATE TA5:
SIGNATURE DATE CONCURRENCE 5 8710290154 ./[M/// M7[g7 PDR ADOCK071023 05000327c, j <
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SRP:
DATE SIGNATURE
- DATE SIGNATURE APPROVED BY: )
)
DATE MANAGER OF NUCLEAR POWER DATE l ECSP MANAGER CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files, j
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.1 (B)
SPECIAL PROGRAM
REVISION NUMBER: 1 PAGE 2 0F 15
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- 1. CHARACTERIZATION OF-ISSUES:
Concern: Issues:
IN-85-029-002 a. TVA's managerial structure is "TVA's Managerial structure is unwieldy and cumbersome, which unwelding and cumbersome. This sometimes leads to confusion in situation sometimes lead to the design process.
confusion in the design process. l Example: excessive amount of b. Paperwork is excessive and passes-paperwork; too many people in through too many hands. Too many the review cycle for ECN's, people are in the. review cycle for ECR's, memos; too many EP engineering change notices (ECNs),
procedures. EP's need to be design change requests (DCRs), and streamlined. 'The paperwork memoranda.
passes through too many hands'. l CI stated that this concern is c. Too many engineering procedures general and could not provide exist, and they need to be !
any specifics." streamlined. .
- 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by INPO Date 08/14/86 ,
i Document Identifiers: TVA memo from L. L.. Jackson to Those Listed,
" Institute of Nuclear Power Operations (INPO) Corporate Evaluation Responses," (A02 860813 012) l
- 3. DOCUMENT NOS., TAG NOS., LOCATIONS, OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT: ,
No specific identifications.
- 4. INTERVIEW FILES REVIEWED:
Expurgated file IN-85-029 was reviewed, and no additional i unreviewed information was found. l S. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
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~TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.1 (B)
SPECIAL' PROGRAM 4
REVISION' NUMBER: 1 PAGE 3 0F-15 I
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
- 7. LIST REQUESTS FOR'INFORMATION,- MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix /s.
- 8. EVALUATION PROCESS: ,
i
- a. Reviewed hierarchy of documents (e.g.,10CFR50, Appendix B, i ,
ANSI N45.2.ll, TVA-TR75-1A) to determine criteria o requirements.and TVA commitments pertinent to the issues in Section 1.
- b. Reviewed adequacy of engineering department procedures that establish organizational structure and design control. l r
- c. Reviewed other mechanisms for establishing practices and responsibilities, such as quality assurance program and EN DES organization; reviewed reports (e.g., Institute of Nuclear Power Operations [INP0] findings, the Nuclear Performance Plans [NPPs], etc.) relative to the above. l
- d. Reviewed TVA practices for compliance to procedures; reviewed results of program audits. :
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- 9. DISCUSSION, FINDINGS, AND CONCLUSIONS:
Chronology:
Late 1960s: Sequoyah (SQN) plant design begins I
10/15/68: SQN issues PSAR to obtain construction permit 05/70: AEC issues construction permit for Units 1 and 2 l 06/27/70: 10CFR50, Appendix B formally issued 01/70- SQN/QA Manual, through R12, Constitutes Engineering l 12/75: Design Procedures in effect 09/73 - Division of Engineering Design (EN DES) Engineering 06/35: Procedures (EPs) in effect 04960-9 (06/1?/R7)
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.1 (B)
- SPECIAL PROGRAM REVISION NUMBER
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1975:- Topical report TVA-TR75-1A initially issued 06/76: TVA commits to Regulatory Guide 1.64 which endorses 1 ANSI N45.2.ll-1974 1
09/27/80: Operating License (OL) issued for SQN Unit 1 09/15/81: Operating License (0L) issued for SQN Unit 2 04/09/85: TVA Topical Report TVA-TR75-1A, R8, issued l i
05/13/85: TVA receives employee concern IN-85-029-002 ,
06/85 - Office of Engineering Procedures (OEPs) are in'effect;- l
. 06/86: supersede EN DES EPs 03/85: TVA voluntarily shuts down SQN Units 1 and 2
'09/85-to SQN Project Manual (SQEPs and SQEP-Als) i present: in effect l 11/01/85: TVA presents SQN Nuclear Performance Plan (Draft) and I
~ its Corporate Nuclear Performance Plan (Draf t) to NRC I
03/10/86: TVA Corporate Nuclear Performance Plan (CNPP) Volume !
1, R0, submitted to NRC 07/14/86: Sequoyah Nuclear Performance Plan (SQN NPP), i !
Volume 2, revised and issued as R1 07/86 to Nuclear Engineering Procedures (NEPs) are in effect; present: supersede OEPs TVA CNPP Volume 1, revised and issued as R2 I 08/13/86:
Discussion:
9.1 BACKGROUND
$4quoyah is a two-unit nuclear power plant. Each of the two units employs a pressurized water reactor (PWR) nuclear steam supply system (NSS$), with four coolant loops, furnished by Westinghouse Electric Corporation. The plant has been designed, built, and operated by TVA.
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'TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.1 (B).
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 5 0F 15
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The Sequoyah plant design was begun in the late 1960s when implementation of regulatory requirements was not required to be well documented. The majority of the SQN licensing commitments were made in the late 1960s and early 1970s, and some of the'present day regulatory requirements do not' pertain to=Sequoyah. It is not necessaryfto update'the . .
Sequoyah plant to include all of the new guidance published. i by NRC, unless there are specific requirements or~ commitments
- to do so.
~
Although the Sequoyah Preliminary Safety AnalysisLReport (PSAR) was released prior to issuance of 10CFR50 Appendix B, the Sequoyah' engineering organization began to comply with the apolicable regulatory cr.iteria upon its issue as a draft i document in mid-1969. Upon their subsequent issuance, 10CFR50, Appendix B; ANSI N45.2.ll; and Regulatory Guide 1.64 were also complied with by TVA. l TVA Engineering Quality Assurance program policy directives and Engineering implementation procedures for the Sequoyah Nuclear Plant specify requirements to comply with the applicable regulatory criteria and are comparable to those used by other utilities in the nuclear power industry.
The issues identified in this element address programmatic deficiencies .in TVA's management structure, design control, and engineering procedures.
9.2 REGULATORY REQUIREMENTS The criteria requirement; applicable to this concern are contained in the following:
o Title 10 of the Code of Federal Regulations, Part 50 -
(10CFR50), Chapter 1, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants" (App. A, 6.a),
Criterion Ill, " Design Control"; Criterion V, ,
" Instructions, Procedures, and Drawings"; and Criterion VI, " Document Control" are specifically applicable o ANSI N45.2.11-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants" (App. A, 6.c)
D4960-9 (05/17/87)
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i TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 6 0F 15 I >
i o Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2 (06/76)
(App. A, 6.b), which accepts ANSI N46.2.ll-1974 as .
meeting 10CFR50, Appendix B l o TVA-TR75-1A, Revision 8, " Quality Assurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants" (App. A, 6.e)
The above documents impose requirements to define the ;
organizational structure within which the quality assurance program is to be implemented, and to prepare program procedures which provide design process and document control
. including review, approval, release, distribution, and revision.
9.3 TVA C0f1PLIANCE PROGRAM AND ENGINEERING PROCEDURES' The Sequoyah Preliminary Safety Analysis Report (PSAR -
App. A, 5.f) and Updated Final Safety Analysis Report (UFSAR... ,
- App. A, 6.d) specify compliance with the criteria of 10CFR50, Appendix B and ANSI N45.2.ll-1974 for quality assurance program requirements and design control. !
The evaluation team first reviewed the Sequoyah Nuclear Plant Quality Assurance Manual (SQN-QAM - App. A, 5.1) and then the past and present engineering procedures (EPs, OEPs, and NEPs) to determine which ones dealt with organizational structures, responsibilities, and the control of the design process. The procedures reviewed cover the period of time from the '
development of the Division of Engineering Design Engineering Procedures (EN DES-EPs) in 1973 through the current Division of Nuclear Engineering (DNE) Nuclear Engineering Procedures (NEPs) issued 07/01/86.
All design engineering for the TVA nuclear power plants before 09/73 was performed by the engineering branches.
These engineering discipline groups designed several nuclear plants concurrently, beginning in the late 1960s. In 09/73, l an organization change at TVA resulted in the establishment of the Division of Engineering Design (EN DES). At that time y a project. system was established that assigned engineers from the various engineering branches (Civil, Electrical, and Mechanical) to work exclusively on a specific project, such as Sequoyah. The Sequoyah project engineering team members, under a project manager, were assigned responsibility for maintaining the design activities related to Sequoyah, ,
includ'ng any needed design changes. j i
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Concurrent with establishment of the project system concept, new division-wide procedures, called EN DES-EPs, were established and were in effect from 09/73 to mid-1985. The
.four volumes of EPs were quite detailed and prescriptive, and included many administrative controls, QA requirements, and voided procedures. The EPs that were reviewed in detail for this evaluation are listed in Appendix A, 5.1.
In 06/85, new Office of Engineering Procedures (0EPs) became effective. The new OEPs reduced or eliminated most of the l administrative details previously found in the EPs. In place of a stand-alone procedure with many instructions, the OEPs referred the reader directly to other procedures that l controlled individual activities. The end result was a l series of single sentences that provided anyone unfamiliar with the process minimal direction on how to accomplish a given activity. The OEPs reviewed in detail for this evaluation are listed in Appendix A, 5.m.
In 07/86, the reorganized Division of Nuclear Engineering (DNE) Nuclear Engineering Procedures (NEPs) became effective. Although these procedures closely resemble the content, format, and brevity of the OEPs issued a year earlier, there are some exceptions. These current procedures require the active use of other references, including the Sequoyah engineering Project Manual (App. A, 5.o), for full understanding of what is to be done. The NEPs reviewed in detail for this evaluation are listed in Appendix A, 5.n.
9.4 INVESTIGATION Engineering Department Procedures and Practices l Engineering department procedures applicable to the issues were reviewed and determined to provide compliance with the regulatory and TVA program requirements ( App. A, 5.1, 5.m, 5.n, and 5.0). The four volumes of EN DES-EPs were replaced (after the concern was subnitted) by a single volume of
" streamlined" OEPs. The succeeding NEPs also filled just one volume, The evaluation team also found that the review cycle and the amount of paperwork applicable to the design process is not excessive. The amount of paperwork and the number of people in the review cycle, although greater than required for 0496D-10 (05/12/87)
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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 8 0F 15
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fossil fuel plants, are normal for the nuclear power
' industry. The processes and documentation were consistent with nuclear industry practice.
Audit Reports A review of TVA audit reports and memoranda ( App. A, 5.t ,
through 5 y) discloses audit findings and recommendations i that indicate that significant problems existed within TVA EN l DES regarding the TVA managerial structure and design process. However, none of the allegations in Issues "b" and "c" were reported.
SALP Board Reports The NRC Systenatic Assessment of Licensee Performance (SALP) '
Board report fcr the period from 03/01/84 to 05/31/85 (App. A, 5.p) concluded that the lack of improvement in TVA's SALP ratings was due to "the lack of effective management both at the corporate and site levels." None of the SALP Board reports reviewed (App. A, 5.p, 5.q, 5.r, 5.s) mentioned the problems alleged in Issues "b" and "c."
INPO Findings The evaluation team reviewed a TVA memo dated 08/14/86
( App. A, 5.v) dealing with the Institute of Nuclear Power Operations (INP0) corporate evaluation. In this memorandum TVA management accepts as valid the following findings regarding TVA's canagerial structure:
o Finding 1.lA-1: " Responsibility and authority for the various Office of Nuclear Power organizations have not been clearly defined or sufficiently communicated. As a result, there is confusion in the organization."
o Finding 1.lA-2: "Many TVA reorganizations have been implemented without needed policy document revisions with the result that effective communications and smooth coordination are not occurring."
l These findings appear to substantiate the issue that TVA's managerial structure sometimes led to confusion in the design process.
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TVA's acknowledgment of the validity of these findings and- !
. narrative regarding corrective measures is considered as ,
validation of the issue.
Seouoyah Nuclear-Performance Plan (SON NPP)
The SQN NPP (App. A, 6.g) contains the following relevant !
observations:
o "In the past, major site projects could have -
I benefited from improved control and. coordination of functional activities. Also, responsibility was often divided among several groups."
o "In the past, problems and confusion existed within TVA's Nuclear Engineering Program, as both the Engineering Organization and the Sequoyah Nuclear Power Organization performed engineering activities. . ." l,'
While acknowledging the above, the Corporate Nuclear Performance Plan (CNPP - App.A 6.f) and the SQN NPP also contain details of corrective actions which, when completed, should improve the ONP management organization.
Findings:
- a. Investigations by TVA and INP0 confirm that until 1985 the responsibility for nuclear activities was divided among ,
several departments,-none of which reported to a single manager. That organization could be characterized as being
" unwieldy and cumbersome." However, by 07/86 all nuclear activities were consolidated within the ONP, headquarters and site personnel were assigned to newly created departments, and the control of engineering work for SQN was assigned to the site Project Engineer. New nuclear directives and procedures are being issued to define the specific objectives and responsibilities of the ONP directors and managers.
Other corrective actions described in the CNPP are also being implemented to strengthen TVA's management group.
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- b. A review of TVA's engineering procedures indicates review cycles for ECNs and DCRs that are similar to those used by-other engineering firms engaged in the design of nuclear
-power plants. For SQN, none of the investigations examined for this report (SALP, INPO,' TVA) indicated excessive paperwork or too many personnel in the design control review process. !
- c. -There were at least 18 volumes of EN DES discipline guides and standards, as well as four volumes of EN DES-EPs. The. i EPs were " streamlined" and reduced to one volume of 0EPs in 06/85. Most of the OEPs were in turn replaced by a single-volume of NEPs in 07/86. However, in addition to the NEPs, Sequoyah has an engineering Project Manual containing detailed implementing procedures.
Conclusions:
Issue "a" was valid at the time the concern was submitted.
However, TVA's nuclear power organization has since been reorganized and various programs as described in the CNPP and the SQN NPP are under way to improve the management structure. TVA has ,
not fully implemented the corrective actions prescribed in the NPPs.
Issue "b" is not valid. TVA's design control procedures meet I regulatory requirements and are comparable to the procedures of other firms engaged in nuclear power plant design. Furthermore, Issue "b" could not be substantiated by other investigations done at Knoxville and at SQN.
Issue "c" was valid at tho time the concern was submitted.
However, the four volumes of EN DES-EPs were replaced in 06/85 by a i single volume of OEPs, which were in turn superseded in 07/86 by a-single volume of NEPs. The NEPs and supporting site engineering procedures are comparable to those used by the private sector of '
the industry.
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- 10. CORRECTIVE ACTION TVA has submitted a corrective action plan (CAP-App. A, 5.u) to address Finding "a" identified in Section 9 of this report.
CATD 204 01 NPS 02 (formerly 204 01 WBN 02)
CATO Description. TVA has not fully implemented the corrective actions specified in the CNPP regarding restructuring of TVA's Organization.
Committed Action. CAP TCAB-333 (03/18/87)
Upon the arrival of S. A. White, newly appointed Manager of Nuclear Power, .TVA started to consolidate . responsibility for its nuclear activities within one central organization and to divest that organization of any responsibility for non-nuclear activities.
That process was significantly advanced through the approval of the organizational structure through the four reporting levels within the Office of Nuclear Power (0NP) on 05/23/86, and again with the inclusion of these charts in the ONP organization and policy manual in 12/86. This organizational action completes the initial commitment. Organization refinements and adjustments continue to i be reviewed, which is considered to be an ongoing process.
Leading up to the 05/23/86 organization action, ongoing improvements have b'een made in the ONP organization ~, including the extensive recruitment of experienced nuclear managers in the executive and mid-grade level and the preparation of position descriptions for all nuclear managers which clearly states the !
accountability for each position. Extensive recruitment efforts are continuing and this effort has been consolidated in ONP, along with a consolidated manpower planning and forecasting system and an extensive management development program.
The ovelyation team has reviewed and concure with the above TVA corrective action plans.
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e TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.1 (B) i, SPECIAL PROGRAM REVISION NUMBER: 1 ,
PAGE 12 0F 15 APPENDIX A .
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- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. Title -10 of the Code of Federal. Regulations, Part 50 (10CFR50), Chapter 1, Appendix B, " Quality Assurance Criteria ;
for Nuclear Power Plants and Fuel Reprocessing Plants"
- b. Regulatory Guide 1.64, " Quality Assurance Requirements for the Design of Nuclear Power Plants," R2, (06/76)
- c. ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants"
- d. ANSI N45.2.ll-1974, " Quality Assurance Requirements for the Design of Nuclear' Power Plants," Section 9, " Corrective Actions"
- e. ANSI N45.2.10-1973, " Quality Assurance Terms and Definitions" i
- f. Sequoyah Preliminary Safety Analysis Report (PSAR) 1
- g. Sequoyah Updated Final Safety Analysis Report (UFSAR) through Amendment 3 (04/86)
- h. TVA-TR75-1A, " Quality Assurance Program Description for the Design, Construction, and Operation of TVA Nuclear Power Plants," R8, (04/09/85) ,
- 1. Sequoyah Nuclear Plant Quality Assurance Manual (SQN QAM):
SQN-0AP-lll-1.2, R1 " Control of Design Documents" (08/13/71) j, TVA Corporate Nuclear Performance Plan, Volume 1, R2 (08/13/86)
- k. TVA Sequoyah Nuclear Performance Plan, Volume 2, R1, (07/17/86)
- 1. TVA EN DES Engineering Procedures Manual, EP 4.03, R16 " Engineering Change Notice," (07/23/84) ]
EP 4.18, R4 " Design Clarge Requests," (05/22/84) 0496D-9 (05/12/87)
1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 204.1-(8)
SPECIAL PROGRAM REVISION NUMBER: 'l i
PAGE 13 0F 15 f :
' APPENDIX A (Cont'd) m.. TVA Office of Engineering (OE) Procedures Manual, i OEP-il, R0 " Change Control," (04/26/85) {
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NEP 6.1, R0 " Change Control" (07/01/86)
- o. Sequoyah Engineering Project - Project Manual, R0, (O9/27/85) i
[B45 850919 826], (09/17/85)
[ NEB 840614 612], (06/12/84) i
[A02 830415 001], (04/13/83)
[A02 820823 010], (08/20/82) t.
TVA Audit No. 000-A-84-0005, " Program Management - Quality Assurance Procjram and Organization," for audit conducted April 9-27, 1984
- u. TVA letter from G. R. McNutt to G. L. Parkinson, Bechtel,
" Employee Concern Evaluation Program - WBN - Corrective Action Plan" (TCAB-333), (03/18/87)
- v. TVA memo from L. L. Jackson to Those Listed, " Institute of Nuclear Power Operations (INP0) Corporate Evaluation Responses," [A02 860813 012], (08/14/86)
- w. TVA memo from E. Gray Beasley to F. W. Chandler, " Audit '
Deviation Report No. 051-A-84-0006-00ll," (805 850402 004]
- x. TVA memo from E. Gray Beasley to R. W. Cantrell, " Quality Management Staff Assessment of Problems Associated with Discipline Staffing," [B05 850402 005] l
- y. TVA memo from E. Gray Beasley to G. L. Dilworth, " Quality Management Staff Assassment of Problems Associated with Discipline Staffirig," [B05 850417 003]
04460-9 (05/12/87)
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SPECIAL PROGRAM REVISION NUMBER: ~1 PAGE 14 0F 15 APPENDIX A (Cont'd)
- 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
- a. 10CFR50 Chapter 1, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"
- b. Regulatory Guide 1.64, " Quality Assurance Requirements for 3 the. Design of Nuclear Power Plants," R2, (06/76)
- c. ANSI N45.2.ll-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants"
- d. Sequoyah UFSAR through Amendment 3, (04/86)
- e. TVA Topical Report, TVA-TR75-1A, " Quality Assurance Program -
Description of the Design, Construction, and Operation of TVA Nuclear Power Plants," R8, (04/09/85)
TVA C'.rporate Nuclear Performance Plan, Volume 1, R2
( f.
(08/13/ '6)
- g. Seq loyah NucNr Performance Plan Volume 2, R1, (07/17/86)
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT:
- a. Telecon from D. Popham, R. Wolters, Bechtel, to T. Clift, TVA, IOM 517, (11/7/86)
- b. Meeting of D. Popham, Bechtel, with T. Clift and P. Duncan, TVA, in Knoxville, Tennessee, regarding Sequoyah Engineering Policy and Quality Assurance documents, IOM 517, (11/20/86)
- c. Meeting of D. Popham, Bechtel, with D. Williams, TVA, in Knoxville, Tennessee, regarding Sequoyah PSAR, IOM 517, (11/20/86)
- d. Meetir g of W. E. Troutt, TVA, with D. Popham, Bechtel, rega ding audit reports pertaining to communications and j interface control, IOM 517, (11/20/86) l l
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l CATD LIST The following CATD identifies and provide's corrective action for the findings included in this report:
CATD 204 01 NPS 02 (formerly 204 01 WBN 02)' Issue "a"; .
03/13/87:
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c's(Ten sTurcs c< wens.u.vr g()3 8 G]218
- 8 0 2 l LM emorandton TENNESSEE VALLEY AUTHORITY-l To . W. R. Brown, Jr., Program Manager, Employee Concerns Task Group, ONP, Watts Bar Nuclear Plant FilO.%I . H. L..Abercrombio, Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant DATE .
December 19, 1986 SUDJECT: SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) -
ENGINEERING CATEGORY REPORTS - NONRESTART JUSTIFICATION CONCURRENCE i
- - ~ ~ ' '
ffoferences: 1. Your memorandum to me dated December 4, 1986, " Watts Bar RECEIVED Nuclear Plant - Employee Concerns Task Group -
Engineering Category Concerns - Review of Elements to DEC1 ) 86 Determine if They are Restart Items" (T25 861204 942)
Wyf.jby # 2. Your memorandum to me dated December 5, 1986, "Watto Bar Nuclear Plant - Employee Concerns Task Group -
.. j'#- Se'll Engineering Category Concerns - Review of Elements to hp-T-]P* Determine if Tbov nra Restart Items" (T25 861205 954) g.
As l~'l 3. Your memorandum to me dated December 8, 1986, " Watts Bar ,
$id.h,,,1'T.~.T.~.I-
_<,.-..- Nuclear Plant - Employee Concerns Task Group -
i-- Engineering Category Concerns - Review of Elements to
-~ Determine if They are Restart Items" (T25 861208 970)
O% h_l-- y,l.~ ;--
m
.g 1, .,__ p. 4. Your memorandum to me dated December 8, 1986, " Watts Bar L- .- - . _ - - Nuclear Plant - Employee Concerns Task Group -
@S- - - - Engineering Category Concerns - Review of Elements to Determine if They are Restart Items" (T25 861208 972)
E-- - ' -
@ lh I m ~ : r ~ @Inn response
~' m (L to your requests (see above references), the following element report nonrestart justifications have been reviewed. I concur that these reports are not required for restart:
241.3 204.2 204.5 204.8 201.6 R1 207.3 R1 232.9 204.3 204.6 204.9 203.2 R2 207.4 R1 204.1 204.4 204.7 204.11 205.3 R1 229.5 R3
/ $
% H. L. Abercrombie RCD:JDS:JB:CS cc: RIMS, HR 4N 72A-C (B25 '861211 001, B25 '861211 004, B25 '861215 020, B25 '861215 021, B25 '861215 025, B25 '861216 021)
T. C. Price, 5-212 SB-K 0471T
i t i
3
, e m os., v , w . m . n din:n wr.m:s corcasu.+r-T 25 870 82 0 si S.
TExxEssEE VALLEY AUTHORITY Meinorand uin: .,.
t TO-
- ' George, Toto, Sit'e Director, ONP,: Watts Bar Nuclear' Plant
~
FROM- : - W, R.' Brown.,Jr... Program Manager. Employee Concerns Task Group, ONP,. Watts Bar, Nuclear Plant.
< cDATE. :
, : AUG 2 01987 L
SUBJECT:
,' WATTS'BARl NUCLEAR PLANT (WBN) - EMPLOYEE CONCERNS TASK GROUP (EC LELEMENT' REPORTS - ENGINEERING CATEGORY-- CONCURRENCE-WITH CORR ACTION PLAN'(CAP)-
We have reviewed your response (CAP)~to the-following Corrective Action Tracking Documents.-(CATDs) and_ find them acceptable:
CATD 20401-NPS-01 CATD 20401-NPS-02 Please inform me when your corrective actions are-complete and you are ready for me,to close out the CATDs.
~
{ A W."R. Brown,' Jr.
GRM:GB l Attachments
.cc (Attachments):
.Phil Brackins, FSB ONP, Watts Bar (
I 1
Drue Chesney, ECTG Bldg., ONP,'. Watts Bar (2) 8
' Jack'Howard, ECTG Bldg., ONP, Watts Bar G.'R. McNutt, ECTG Bldg., ONP. Watts Bar i
7
! 6180T l
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- 'r 4 1 870309 07 3 UNITED STdTES GOVERNMENT TENNESSEE VALLEY AUTHORITY Memorandum f
1 1
4 l
J W. R. Browa, Jr., Program Manager, Employee Concerns Task. Group, (
TO Watts Bar Nuclear Plant ONP [
James L.-McAnally, Corrective Action Program Manager, Watts Bar FROM :
-Nuclear Plant,0NP DATE : 3. cg. 3 y
SUBJECT:
WATTS BAR NUCLEAR PLANT (CATD)
(WBN) - TRANSMITTAL OF ECSP CO ACTION TRACKING 00CUMENT(S)
ECSP Fact Sheet Number: Ao 4o n - N o c - n i ECSP CATD(s) Numbers The above listed, completed CATD(s) are being returned according to
- your instructions.
W )// 4- G . . .
James L. McAnally JLMc:NLC ~
m Attachments c.ECEl'/ED l
cc (Attachments):
RIMS, MR 42 72A-C li 'ti Emp.' yec C:- -
- r.:,7:39 C aue W?s' l gwelvm ;
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. CATG REVIEW F.OR TECHNICAL ADEQUACY
-'CATD No ...
d d <w Shf7 te.e M- j JL Date R. 1e. ... 1
- M Review Panel
Date-
' 73 =w 3//!k ) VBIF o Det.
Other.
- Date.
Other Date.
.Other Date Other ,
j Date
) Other
- Date O k-b MM N - AU t :
. Comments: v /.
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'1 .
I' WBEP-2281d
~2/5/87 i
, ECTG C.3 A t t a c hroe n t A f
Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Attice Tracting Docu. ment (CATD) i l
INITIATION )
- 1. Imediate Corrective Action Required: D Tes Y No
- 2. Stop Worr. Recomended: D Tes p No I
- 3. CATD No. ,$/W O/ A/P5 O/ a. INITIATION DATE J2 !MA/47
- 5. RESPONSIBLE ORGAhI7.ATION: DA/f / /
l
- s. PROBLEM DESCR1P:10N: D QR ,5 NQL FFFct*TIVf*(?t>mmerginarioy an i nm=wnm Owrapt vos mr mAwrxiurn PY <Dv Ms . RrvAwsiniuries,
_M r//optrie s un nps. An t?Avens inrep rner_n tDen? spiro nv ppeceD U/ vn A4 ^R GMri t > st ri e>e (4/Mr*, feA Des /SN i? *vD Mv,t6 At e stag onirket wree ner Re vise =0 ni A ymezv menwrA ra DeTtwArn-ce& An/ tif77eivM JhTre);"Ae*rn AAIO bA!r? 6* @e m a eni c.47sexg.
59 ?*fdf*O th A P dr 6f 6 ANJ2 A'7/ONr L lIN NM/e" e~ \e jrp c As y- 5"rtj pfp (At g 7"/M Fl.Y ffMA/A6"A . Nk'6%MTc RA eDJfi/h M/NA /A'FhAAwryoitj wa-kt-O AC A;HMENTS n W h=GfhNDRO Til /k A ??mk1N /144/MJE7t
- 7. PREPARED BY: NA.MI D. A A9 4#4/td b!W (h / DATE: A -Q o-87
- 8. CONCURRENCE: CEG-H % ht.12At- NT /fV DATE: _ 2 2.4 -tr 7
- 9. APPROVAL: ECTG PROGICLM MGR. V OW h aC. DATE: '2 -tr- E 9 I*)P. REC IVE ACTION
- 10. PROPOSED CORRIOTIVE A;~ 0N PLAN:
5 ex 4-Hrvhed c4W( Revan [
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A // ,-. M W ACMMENTS l
- 11. PROPOSED BY: DIF.ICTOR/M" F Msw DATE: 1. -/o / P7 )
- 12. CONCURRENCE: CEG-H: . 's
/2'JA //W DATE: P 10- 37 l SRP: dA/ / /4- _a , JATE :
ECTG PROGR.AM MGE: fe'M/J # DATE: Weg#7
(,/ / '
VERIFICATION A.No OLO3EOUT
- 13. A;; roved corrective actices have been verified as satisfactorily i t:;1 eme n t e d .
)
S:GsA:uRE TITLE DATE 1
l
C. A %
- APP '. . e LEY. 3 ATTACM C T A N95
(.AT D N O. 204. U Ud:IQ1 Jrt t, (p,,,.b dm47/YI .
- 10. PROPOSED CORRECTIVE ACTION Pl.AM:
1he issues descr ibed in this C AT'T vef1ct a number of the root nroble,c tbar TVA has fnroulate ultiraately resulted in the r.hutdsm nf 1VA's nuclear pinnts.
the areas of organizarton and is implementing currective.. action plans in structure, manancment r,taffing/ responsibility /necountabilitv, and desten / char.n The actien pinns have been der.cribed to
- ontrol to disposi.tica these matters.
IV.3, TV.C. IV.E.
~,8C in the Nuclear Performance Plan. Volume 1 (Sections III.
and VI.E.4). Additiont.1 deta13s on the denien/ change control program as it
'. .nnce Plan relates to E l will be included in Volone 4 of the Mucleat Also, DT Policy Memorandum (acheduled for issuance on April 10, 1987).
M has been issued to clarify the comparative range of responsiH11 ties
~')
between branch chief s, project engineers , klead engir.eers. _
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fo/ currently Does the corrective acts.on plan rely on orYes' take credit X HQ identified or previously completed work? ecc.)
If yes list parent documents (e.g. NRC, SCR, CAR, Audit, 1_,
nng A. D:T Poliev 'temornndun PM 87-35 '
'.'o ln m Performance Plans.
' Does the problem described consitute -a cen314-n adverse to qua Yes No _
X -
If yes CAQ No.
Schedule for completica of corrective action (schedule da e, if know ,
r.11estone (e.g. \A EFL1, etc.) c.chedules
- defined in rho,, NDk.A-,/ ,/ '
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A_
froposed'oy/Date j,
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- l' 1 dNITt!D STATI:SGOVI IsNMi:NT i
Memorandum TENNESSEE VALLEY AUTHOIUTY' D .4 L
TO :- W. R. Brown' Jr.,: Program Manager, Employee Concerns Task Group, Watts Bar Nuclear Plant i f FROM : P. D. Brackins : Project Manager, ONP,' Watts Bar Nuclear Plant DATE' *-
/Q G
SUBJECT:
WATTS BAR' NUCLEAR PLANT (WBN) - TRANSMITTAL OF'ECSP CORRECTIVE ACTION TRACKING DOCUMENT (S) (CATD)-
ECSP; Fact Sheet Number ECSP CATD(s) Number MOyD/ - /V P'S - v/ g/ y i
1' ;
+
l The above listed, completed CATD(s) are being returned ~according to your instructions.
1.,
P. D. Brackins PDB:NC Attachments cc (Attachments):
RIMS, MR 42 *12A-C i RECBVED .
.. l (Mii'87 f l e=m uu, Creum e t f***'Ak erlReply !
ki~umn tMk
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REY. O ATTACHMENI A a.
-CATis No. 204.0lNPS01 l
- 10. PROPOSED CORRECTIVE ACTION PLAN: j% ,; g 3,3 / ,
The issues described in this CATD reflects a numbetof the root problems that_
ultimately result 6d in the shutdown of TVA's nuclear plants. TVA has formulata y
and is implementing corrective action plans in the areas of organization structure, manageirent staffing /respo6dibility/ accountability, and desien/changt control to disposition these matters. The action plans have been described to NRC in the Nuclear Performance , Plan, Volumb 1 (SectionsIII,IV.B,IV.C.IV.E.d
-.and VI.E.4),.; Volume 2 (Sections 11.1 and'11.3), and Volume 3 (Sections II.1 an:
III.h). Mditiori$1 details on the design /changs control program as it relates to WBN will be incluind in Volume 4"of the Nuclear Performance Plan. Also, DN:
Policy Memorandui PM-87-35 has bcen issued to clarify the comparative range of responsibilities between branch chief s, project engineers, and lead engineers.
- 5. _: -
l *
]
j ,
I Does the corrective action plan rely on or take creditNO'f or currently identified or previously completed work? Yes'*X If yes list parent documente (e.g. NRC, SCR, CAR, Audit, etc.)
. l
- ' Nuclear Performance Plans, Volumes l'. 2.' and 3i' DNE PoHrv Memormdum DM-87 n
i i
' Does the problem described consitute a condition adverse to quality (CAQ)? ;
Yes No X
., l If yes CAQ No. .
Schedule for completion of corrective action (schedule date, if known. or I milestone (e.g. 'L1, etc.) Schedules as defined in the NPPs.
~
~
- 11. . A ff '
Ecfl6(ed/by/Date 7"7 Proposed by/Date 0320V L
- ~ _ . _ _ _ _ __
(L y ,, .go.m.no. -"an T 4 1: 870313:,2[
'4' .
' unit'ED STATES cOVERNMENT
.Memoran d um: rsxwessts vittsr Aurnonirr h
TO) : LW. R.' Brown,'Jr;, Program Manager. Employee Concerns Task Group..
Watts Bar Nuclear Plant ONP
'FROM :- James ~L. McAnally, Corrective Action. Program Manager, Watts Bar .,
'I f
' Nuclear-Plant,0NP DAT E ,. : 3 - / g-W
SUBJECT:
WATTS BAR NUCLEAR PLANT (WBN) - TRANSMITTAL OF ECSP CORRECTIVE-ACTION TRACKING DOCUMENT (S) (CATD) b ECSP Fact Sheet Numberi
.ECSP CATD(s) Numbers : 2 O% Sl NPS OZ A
~
The above listed, completed CATD(s) are being returned according to your instructions.
7 c,..,.
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hs 0b James L. McAnally JLMc:NLC RECEIVED Attachments ec (Attachments): SE II b7 V' RIMS, MR 42 72A-C Emplovec Concems Task ,
Group WBN Note Acion Recly
- e g% a ows en usu o-aw PS m
WBEP-2286d _
2/6/87 sJ FOA G EN 2 M&P
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CATG REVIEW FOR TECHNICAL' ADEQUACY tj 'CATDNo.hO O ' 'O
% 691Yf W 3//f/27 t eae duf W ah? s, ie,1e Pane 1
' Date 8 A a-' // 8/ ~8P Review Panel Date L x_ I# 3 N - Y-7 WBTF p Dato Other Date Other Date 7
Other Date -
I Other 47T Date
.:)
Other ,
Date Comrnents :
s WBEP-2281d 2/5/87 e
s J
4 L_: --- _ - _
3 -' '
J b
< 1; .ECTG C.3 l Attachment A- :
,- .PageL1-of.1_ -,
4 '
Revision 7 - A' ,j A .. .
j ICSP CotitCTIVE Attion Trottini Document ~ ]
1EAII.1
.2NITIATION. p 4
7 1 Imediate Corrective Action tequired:' O Tes: GVSo
-7 ~5 top Wort ecomended: 0 : fes de . . . . .
- 3. CATD No. o9 d/ Af#.5 ~ (FA -e..INITIATIONDATE'ANhP7-5, RESPONS!8L.E ORGAN 37.&710N: DA/8 /'
6', PROBLEM 'DESCRIPi!ON:. Q QR g NQt _74W //R ArAT #d// y Af19/Wh1G~N7TO T2/e~ CnPe x t?t12' N c M nAll W ew s ci r o J/V Yh/e~- CARWRDrte N PP -KM4PDiN6
_ Re'S TktxN > R idd s t: TVA> of 6 Arf / 2 977m/
s: j
.1 A- 0 AnaCMM1NTs
.7. ' PREPARED BY: - N A.ME M N A PN#/M EP ( All DATE: 4-4MV
- 8. CONCURRENCE:. CEG.H W W E W 5 W F' DATE: 2-t4-t f 5 APPROVAL: ECTG PRodTLAM MIiR. " ' DATE:
y CORP.EC7:VE ACT10N. . -l
- 10. , PROPOSED CORRECTIVE- ACT:0N PLAN: _ _ - -
- - ' ga e- /4 7T-AcH/77 cN , ap w ;
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j O A MACHMENTS DATE: .# h 7/ # ~7
- 11. PROPOSED BY: DIRECTOR De-% /dGK:
V/ / IALW T7#d-. & DATE: 4_.26 a 7
- 17. CONCURRENCE: CEG-N:
SRP: 7J7& e e DATE:
ECTG PRDGRAM.MGR: ##ACll & DATE: _'< f2re/57 i /
g
, VERIFICATION AND ClostoVT .
- 13. Approved corrective actions have been verifieci as satisf acteri!T implemented.
TITLE DATE SIGNATURE L .-. _ _ _ _ _ _ _ _ _ _ . _ _ _ _
c J
.w 14: 59 ;..-ANAFAX ~1109196 03-L[ .- [t1987-03 * ..
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C 4 TTA c M 9 T . $' %g CA P 1.0 pp p iJ F S 'O ' a sION o A A ENT A CATD NO. in4bkuM-02
}0. . PROPOSED CORRECTIVE ACTION PLANT Upon tha' arrival of n. A White. naulv anna 4ntad Manamnr of Nuciaar Power. TVA startad to ennan14date vannonaf b(11rv for its nucinar activittee within one i- central oraandmat4an and en d4vant that ormanimarten of any raanonsibility I
'for non-nuciaar-activ41ina. That nrncana was adeniffeantly advanced through-the~anoroval af tha nenan4mattanal structura thraumh the fourth emnertina l
1aval v4 thin the off4em of Muelaar Power (0)TP)<on May 23. 1986. And ammin ,
.d With the inelum4nn af thama charte in the OND armandmation anf noliev manual in paenmhar. 1986. This neoantmattanal action eamniatma the initial commnment. .k Organization rafin==nes and ad4uatmenta cantinue to be reviewad which ta cona4dsend en'ho an anno 4ne nea"=an-Teading up to the May 23, 1986 organization action, ongoing improvements have
'been made in the ONP organization which has included - the extensive recrun=*at of- experienced nuclear managers -in the mid and executive grade level and the
' preparation of posit' on descr*.ptions for all nuclear managers which clearly :
states the accountab:.lities f or each_ position. 7.xtensive recruitment eILortsf i
are continuing and this eff ort has been conso_1tcated in unr,- along with a I
'E. consolidated manpower planning and_ forecasting system, and an extensive management development program. , jj l
nyf+9 Yt*:g
. Does the' corrective action plan rely on or take needit for currently
- identified or previously completed workt Yes No l
If yes, list parent documents (e,s., NCR, SCR, CAR, Audit, etc.) J
-l Does the problem described constitute a condition adverse to quality r
(CAQ)? Zes _ No _ q
)
If yes, CAQ No. 1 4
schedule for complation of corrective act' ion (schedule date, if known, or )
milestone (s. , M.1, etc.) _ _ _ m i 2.! 11. - / !
Preparti by/Date Proposed'by/Date 8
9 e
WBEP - 23'67d 02/09/87
. - - - - - - - - . - - - - - - - _ _ _ __