ML20151P486

Provides Status Rept on NRC Activities in Response to Issues Associated W/Tva & Requests Comments on Resolution of Corporate Issues.Addition of Addl Project Managers & Inspectors to Facilities Under Consideration

ML20151P486
Person / Time
Issue date:	01/02/1986
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
Shared Package
ML20150F698	List: ML20151P486 ML20155G972 ML20155G982 ML20155G991 ML20155H000
References
TASK-PII, TASK-SE FRN-SECY-86-1, SECY-86-001, SECY-86-1, NUDOCS 8601140414
Download: ML20151P486 (10)

Text

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, Attachment #1 - Question 42A

,ga aeo e e E

January 2, 1986  % ,,,,, SECY-86-1 POLICY ISSUE i Unformation) l l

For:

o The Commissioners From: William J. Dircks l Executive Director for Operations j

Subject:

STATUS OF STAFF ACTIONS REGARDING TVA i

Purpose:

To provide the Commission with a status report on staff activities in response to issues associated with TVA and  ;

to request Commission coments on resolution of Corporate i issues. This is the first status report on this topic. '

Backcround: On December 13, 1985, Chairman Palladino directed the staff to prepare a written report summarizing the major NRC plans, schedules, and organizational assignments related to all TVA plants. This report is the first in a series of status reports on TVA, to be provided to the i Commission on a monthly basis. As requestad in the  !

Chairman's memorandum, we will also be providing biweekly  !

progress reports and summaries of the Senior Management Team's weekly meetings.

On September 17, 1985, the staff issued a letter to the TVA Chairman of the Board of Directors that provided an assessment of the TVA headquarters functions as well as an assessment of the TVA facilities. This assessment was performed as part of the Systematic Assessment of License Performance (SALP) program. As noted in this letter, this assessment indicated significant and continuing weaknesses in TVA performance and ineffective management of the TVA nuclear program. This poor performance was indicated by successive SALP periods with Category 3 performance in Plant Operations at Browns Ferry, Category 3 performance in Quality Assurance and Administrative Controls Affecting Quality for both the Browns Ferry and Sequoyah facilities, Category 3 performance in maintenance at Browns Ferry, multiple escalated enforcement actions, and numerous

Contact:

H. Thompson, NRR 492-9595 gag y LLM C --- -- --- ---- -- --- D

The Commissioners ,

significant events at both the Browns Ferry and Sequoyah facilities. The September 17, 1985 letter to TVA request-ed that, pursuant to 10 CFR 50.54(f), TVA furnish specific information regarding actions taken by TVA to resolve the numerous concerns expressed by the NRC. That letter also confirmed previous TVA commitments to the NRC that the Browns Ferry and Sequoyah facilities, which were in a cold shutdown status, would not be restarted without i NRC concurrence.

Discussion: The Staff has identified a number of major issues regarding TVA, most of which are stated in the September 17, 1985 letter. The staff is developing a preliminary schedule of major staff actions to be completed to support a restart decision at Sequoyah. The '

schedule includes staff actions to resolve corporate i concerns (as related to Sequoyah) and restart actions for i Sequoyah Unit 2 (identified by TVA as the lead unit). I Each major item includes typical subelements, such as: '

review licensee submittal, verify resolution of related employee concerns, inspect implementation and prepare safety evaluation. TVA planning documents indicate that Sequoyah Unit 2 is planned for restart in late January 1986. The staff believes this schedule to be overly  ;

optimistic in that it leaves no margin for contingencies.

In addition, since there are a number of issues that TVA indicates must be accomplished prior to the restart date, t it is~ difficult to identify at this date any single '

controlling issue for Sequoyah Unit 2 restart. The i major issues that the staff is currently addressing include: i l

I. Concerns Regarding TVA Corporate Activities The September 17, 1985 NRC letter requested informa-tion regarding TVA corporate activities. This i information request covered such topics as improved i TVA Board involvement in nuclear plant performance, '

management changes to strengthen TVA regulatory performance, corporate controls of an integrated commitment tracking system, and escalation of j quality assurance audit findings to assure timely resolution of these findings. TVA has provided this information which is currently under staff review. 1 This area represents a number of the most complex '

issues that the staff must deal with regard-ing both the restart of the Sequoyah facility and resolution of TVA problems in general.

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The Commissioners TVA has made or plans to make a number of organiza-tional changes in response to NRC concerns expressed in the September 17, 1985 letter. These changes include the acquisition of a senior nuclear advisor to advise the TVA Board specifically on nuclear matters, the use of frequent Board briefings on the nuclear program, assignment of Nuclear Safety Review Staff senior representatives full-time to each plant site, increased support for the nuclear program by other TVA organizations, creation of the Office of Inspector General, and improvement in compensation to attract and retain experienced p'ersonnel.

Enclosed is the latest organizational chart as of January 2, 1986 for the TVA nuclear program.

Although a number of important personnel changes have been made, few of the key positions in the new organization have been filled with individuals from outside TVA.

In addition to those issues that the staff reviews as part of the normal licensing process, in the case of TVA, individual Commissioners have raised

' a number of additional issues which are usually

~~' outside the scope of normal staff review. These issues include: 1) the degree of reliance by TVA on contractor personnel to fill key positions,

2) the adequacy of TVA efforts to address employee relations problems and in particular those issues identified by the employee concerns program, 3) the role of the TVA Nuclear Safety Review Staff (NSRS) in relation to the TVA line organization, 4) the NRC's role with respect to TVA's selection of key personnel and other important TVA management decisions, 5) NRC's views on the role and responsi-bility of the TVA Board and General Manager in the resolution of important safety issues, 6) NRC's role with respect to resolving interoffice communication problems at TVA, particularly between the Engineer-ing organization and the Quality Assuance and Operations staff, and 7) a decision whether the NRC should direct TVA to request NUMARC (or another organization) to become involved in helping TVA overcome identified management deficiencies.

Additionally, the staff understands that INP0 has -

recently completed a review of TVA Corporate activities. The report on this review will be ,

forwarded to the Commission when received by the staff.

The Commissioners The NRC review of management and organization issues has always been difficult for the agency. Unlike technical issues, there are no regulations, ,

Regulatory Guides, Standard Review Plans or other Commission approved guidance as to what management philosophy and organizatic7.a1 structure produces a safe facility. Obviously, there is not a unique structure that is acceptable. The question is:

what should the agency's response be to a management and organization that has been unsuccessful in correcting previous performa,nce deficiencies?

Clearly, NRC desires that more of TVA's upper management have nuclear experience, that TVA adopt a management philosophy that encourages employees to come forward to TVA with safety issues without fear of reprisal and which produces employee trust, that TVA utilize a strong and effective QA organization, and that TVA have good communications between TVA organizations such as engineering and operations.

TVA has stated that they are committed to change, but change takes time and results from those changes take even longer. In the past, TVA has made changes in the interest of improving their C". j aanagement and organization, but they have not 1

solved the problems.

'NRC Action: The staff has made an initial review of the TVA response to the September 17, 1985 letter and questions regarding TVA corporate changes have-been submitted to TVA. Region II has conducted special inspections of the TVA QA escalation procedures, the commitment tracking system and the Employee Response Team Program. The staff will continue its increased oversight of TVA corporate activities including recent TVA changes as part of TVA's response to the September 17, 1985 letter.

While the staff's review of these issues is under-way, the staff requests that any specific comments the Commission may have for addressing the corporate issues, and the degree of resolution of these issues required prior to restart of the Sequoyah facility, be provided to the staff as soon as possible.

II. Review of Actions Necessary to Return Sequoyah Facility to Operation -

The issue that led to the shutdown of both Sequoyah units on August 21, 1985 (Unit 2) and August 22, 1985 (Un" 1.), was the inadequacy of 'he ervironmental l

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< 1 The Commissioners  !

qualification information for various safety-related components. Subsequent to this shutdown, other issues have been raised through NRC headquarters review and regional inspection efforts, TVA identification of deficiencies at the Watts 8ar facility that may be applicable to the Sequoyah facility, and the TVA Employee Concern Program.

These issues together with a brief discussion include:

A. Employee concern Program: A number of employee l concerns that have been identified may be i applicable to the Sequoyah facility. As of December 7,1985, approximately 200 employee ,

concerns that may be potentially applicable to the Sequoyah facility had been identif ad by )

TVA (out of a total of about 4,200 employee l concerns for all of TVA). TVA has developed  !

an evaluation plan for these concerns which in-cludes an evaluation by the TVA line organiz-ation and an independent evaluation by the TVA Nuclear Safety Review Staff (NSRS). Additionally, several inspections have been conducted of the s Employee Concerns Program and a NRC contractor 2

is collecting information on these employee concerns. Based on these two evaluations, a prioritized list of employee concerns is to be formed and a listing of corrective actions to I be accomplished prior to startup of the Sequoyah facility will be developed.

l NRC Action: In order for the staff to develop a program to evaluate TVA's resolution of employee concerns, we have requested that TVA provide the criteria for evaluating employee concerns. The staff will review these criteria together with the listing of specific corrective actions to be accomplished prior to restart. j The staff will also verify the adequacy of resolution of certain concerns through the inspection process prior to unit restart.

B. Equipment (ualification: TVA has established an Equipment (!ualification program that will consolidate pertinent information into a quali-fication file that will fulfill all requir.ements of the equipment qualification rule (10 CFR 50.49). An Equipment Qualification (EQ) Audit was conducted November 19-22, 1985. This inspection identified additional effe " - that needee tc ,a ascomplished to compi=.. e.

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The Commissioners packages. The TVA schedule indicates that equipment qualification items for Sequoyah Unit 2 will be complete by January 23, 1986.

This effort covers about 90 equipment packages, all of which will be reviewed by the staff.

NRC Action: Based on TVA schedules, an Equip-ment Qualification inspection is planned at Sequoyah for January 6-17, 1986. Since based on TVA's progress to date, the TVA completion target appears optimistic, it is expected that an additional inspection will be required after TVA completes the remaining packages (expected in February 1986).

C. Desian Control Survey: One of the items requested in the NRC letter to TVA of-September 17, 1985, was a detailed description of the survey being conducted of the TVA design  !

control program. A detailed description of this survey, which is being performed by i Gilbert Commonwealth, has been submitted and was initially reviewed by the staff. Based on dialogue between TVA and the staff TVA sub-g mitted additional information on December 20, 1985. Additionally, the staff will review a report of an independent industry evaluation in this area.

NRC Action: Complete review of the survey  !

submitted by TVA and complete appropriate I onsite verification inspections. Further inspections will be required after TVA completes their review of past design controls.

D. Cable Tray Support Analysis: In the September 17, 1985 letter TVA was requested to provide analyses that demonstrate that the cable tray supports in several applications at the Sequoyah facility complied with the appro-priate seismic design criteria. TVA has responded to this request and this response is currently under staff review.

NRC Action: Complete review of analyses submit-ted by TVA. .

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I The Commissioners i E. Operational Readiness Plan: In the  !

September 17, 1985 letter, TVA was requested  ;

to provide a detailed description of the  ;

operational readiness plan developed by TVA to assess the readiness for resuming operation of -

either of the Sequoyah units. This description has been submitted by TVA and includes actions taken by TVA is the areas of emergency prepared- i ness, quality assurance, regulatory improvements t management involvement, operating experience,  !

and maintenance activities. The staff has  !

expended considerable effort to date in  !

performing inspections of various aspects  !

in this area. i i

NRC Action: Complete review of TVA Operational Readiness Plan. The Staff will also confirm by j additional inspection selected aspects of the Plan. Based on current TVA information, Region II expects to conduct these inspections two weeks prior to projected restart.

^ III. Review of Actions Necessary to Return Browns Ferry ,

__ Facility to Operation 1

l The Staff has focused the majority of the resources assigned to the TVA effort on the restart of the Sequoyah facility and has not yet prepared a detailed plan for actions necessary for restart of-the Browns Ferry facility. This plan will be in-cluded in subsequent status reports when they are developed. A substantial amount of information regarding the Browns Ferry facility has been requested from TVA, as part of the September 17, 1985 letter pursuant to 10 CFR 50.54(f), and their response is expected to be submitted in February 1986.

IV. Review of Actions Necessary to Complete Construction j

and Licensing Process for the Watts Bar and Bellefonte Facilities As previously noted, the staff is preparing detailed action plans for the licensed plants, particularly Sequoyah, on a priority basis. A number of staff actions are underway regarding the Watts Bar facility, such as inspections of the Employee Concerns Program, as well as a review of welding problems identified through the TVA employee concerns program and a i requ;st tc TVA for a listing of open .tems that need l

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, The Commissioners to be addressed prior to licensing of the Watts Bar l facility. The earliest that TVA expects to provide detailed schedular information is February 1, 1986.

i Staff action plans regarding the Watts Bar and

' Bellefonte facilities will be included in subsequent status reports as the TVA schedules are identified.

V. NRC Manacement Methods Regarding TVA The NRC has devoted increased management attention to TVA facilities in order to deal with the identi-fied TVA issues in the sh' ort term and to prevent recurrence of TVA prob 1 m . The Senior Management Team is receiving weekly briefings on key issues related to staff review of issues at TVA. The support staff to this team, as well as headquarters and regional line staff reviewers and managers, are making regular visits to TVA facilities in order to provide increased oversight of resolution of various issues. Greater emphasis is being placed on reviewing NRC and TVA staff plans and schedules for activities associated with the restart of the Sequoyah units. The Senior Management Team will evaluate what longer term actions are appropriate to provide TVA oversight and prevent recurrence of TVA problems. These actions will be provided in

-later status reports. Nevertheless, it should be clear that TVA remains responsible for identifying their problems and developing and implementing solutions to the identified problems.

VI. NRC Resources Beine Devoted to TVA

' The staff has committed higher resources to TVA than for most other operating reactors and is currently reevaluating the adequacy of these re-source commitments. In April 1985, I appointed a senior management team, chaired by the Director of NRR, and consisting of the Director of IE, and the Region II Administrator, to coordinate and manage the NRC efforts at TVA. The Director of the Office of Investigations has recently joined this senior management team to assure coordination of staff actions with 01. Additionally, I have appointed a full-time senior SES member (Hugh Thompson) to assist the senior management team..

Mr. Thompson and a small support staff will provide appropriate oversight and coordination of staff actions and assure the senior management l

I The Commissioners -

9-t team is informed. The Directors of the respective offices will continue to direct their individual staff activities relating to TVA and periodically report to me on progress.

In recognition of the need for additional resources i devoted to TVA, we are considering adding additional t project managers and inspectors to TVA facilities i on a full-time basis.

While these plans are under evaluation by the staff, the Commission should be aware that such resource ,

reassignments have potential negative impacts on '

other NRC programs.  :

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/# WilliamJ.DircIs  !

d e7 Executive Director for Operations  :

Enclosure:

S TVA Organization Chart as '

__) of January 2,1986 I

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