ML20235S929
| ML20235S929 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/06/1987 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20235S928 | List: |
| References | |
| NUDOCS 8710090190 | |
| Download: ML20235S929 (15) | |
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f(M /g1, UNITED STATES
. y;- NUCLEAR REGULATORY COMMISSION g WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF SPECIAL PROJECTS ON THE EMPLOYEE CONCERN SPECIAL PROGRAM j q
TENNESSEE VALLEY AUTHORITY SE000YAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327, 50-328
1.0 INTRODUCTION
1 This evaluation documents the staff's review of the Tennessee Valley Authority (TVA) Employee Concern Special Program (ECSP). These procedures ,
and criteria were submitted by TVA on August 29, 1986. The ECSP uas inspected !
by the staff during the periods July 15-18. September 30 to October 4, and October 21-25, 1985; January 21-24, April 8-11 June 10-12, and August 26-28, 1986. There was also an inspection on February 3-5, 1987, that covered only the Industrial Safety Category and the ECSP was subject of.a meeting on June 1, 1987. The ECSP manual has been revised since then, in part because of the I l
findings of the staff's inspections, and its last revision (Revision 5) was l submitted on July 8, 1987.
2.0 BACKGROUND
In the past TVA, NRC and some members of Congress received concerns from TVA employees. These concerns raised questions regarding the quality of TVA's .g nuclear activities. Some employees expressed fear that TVA might take !
reprisals against them if the employees expressed their concerns directly to 1 TYA management. TVA has taken actions to address this type of employee concerns. This report is evaluating one of these actions,.the ECSP.
In 1986, TVA began its efforts to evaluate and resolve employee concerns already identified through previous formal TVA programs. These pro the interviews of TVA employees by Quality. Technology Company (0TC) at grams the were Watts Bar site, the previous or old TVA Employee Concern Program (ECP) and the-recommendations made by the TVA Nuclear Safety Review Staff (NSRS). There were also safety assessments made by Stone and Webster Engineering Corporation (SWEC) and concerns identified by NRC and these were also added to those already identified by the above programs. The ECSP provides the guidelines and procedures for the evaluation and resolution of these concerns including their generic causes and applicabil'ity to other sites.
l The ECSP was developed in 1985 by TVA. TVA hired the independent contractor,
! QTC, to determine employee concerns from interviews of all TVA employee associated with Watts Bar. OTC also solicited concerns from other TVA employees at the other TVA nuclear sites.
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Measures were taken to protect the confidentiality of employees who enressed concerns, and the sanitized records were provided to TVA by QTC. In N85, the l responsibility for conducting or overseeing the investigations of ider.tified employee concerns was with OTC and the N3RS. In 1986, the TVA placed the investigations under the direction of the Employee Concern Task Group (ECTG).
The ECTG implements the procedures and criteria contained in the ECSP maTJal.
The ECSP manual is identified by TVA as the ECTG program manual. The last revision of the ECTG program manual is Revision 5 submitted July 8, 19874 '
The decision to institute an ECTG for certain empicgee concerns was tc. ,
consolidate TVA activities on employee corcerns inty two programsy (1) the {
j ECTG for concerns, regardless of applicability to spedfic nucTear pbnt sites, received prior to February 1,1986, and (2) the "new" iCP for c1) concerns l received on and after February 1, 1986. TVA had inititted. efforts in 1985 to i l
develop a new approach for handling employee concerns and in February 1986, implemented the "new" ECP. The acceptability of the new ECP will be c.odressed in a separate SER.
11 3.0 EVALUATION The ECTG was given the responsibility of addressing all employee concerns identified by TVA prior to February 1,1986. These concerns were applicable to all the TVA nuclear plant sites including Sequoyah and encompassed potentially safety-related issues. Approximately six thousand separate concerns involving all TVA nuclear plants were identified by the various programs.
The staff evaluation of this program assessed the descriptive material providing the basis for the TVA program to evaluate and resolve the employee concerns at all the nuclear sites. This review evaluated the progtam, icope, organization, and methodology of this program and the controls to have corrective actions identified for the Sequoyah plant corrected before restart.
The staff has reviewed the ECSP manual (also referred to as the ECTG program manual) submitted to the NRC on August 29, 1986. It has reviewed the descrip-tion and its implementing procedures up to Revision 5 which was effective July 8, 1987. Tnere have also been inspections of this program manual and its implementation by the ECTG on July 15-18 and Septem6er 30 to October 4.. ara October 21-25, 1985; January 20-24, April 8-11, June 10-12, and August 26-28, 1986; and on February 3-5, 1987. <
3.1 Objectives of Program The objectives of the ECSP were to evaluate the employee concerno and to provide timely disposition, corrective action and closeous of these concerns for all the nuclear plant sites. This effort provides usurance that nuclear -
plant safety is not adversely affected by any issue raised by these concerns.
Secondary objectives are the evaluation and tiriely correction of the nm-safety re'ated employee concerns that are within the program, fhe staff concurs with TVA's objectives for this program t
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3.2 Scope of Program !
l The scope of TVA's program is those employee concerns which had been identified )
to TVA and not resolved prior to February 1, 1986. These were concerns identified by TVA formal programs and included concerns raised to OTC, NSRS, the "old" TVA ECP and NRC. Employee concerns identified after February 1, 1986, are addressed by the "new" TVA ECP.
The staff does not object to TVA dividing the employee concerns into these two separate programs. The ECTG is expected to be dissolved by TVA once the employee concerns it is evaluating are resolved and the necessary corrective 3 actions are being taken. The "new" ECP would be continued to provide an I atmosphere where TVA employee may express their concerns without fear of reprisals, 3 Intimidation, harassment, or wrongdoing identified under this program were l assigned to the TVA Office of the Inspector General (01G) for evaluation and i reporting and do not fall under this program. The OIG will conduct its own evaluations using OIG procedures and will provide the ECTG with their results.
Welding concerns identified under this program were assigned to the TVA Welding
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q Task Group (WTG) for evaluation and reporting and do not fall under this program. The WTG will conduct evaluations using tiTG procedures and will provide the ECTG with their results.
Outside the scope of the ECSP is the feedback to the TVA concerned employees on the resolution of their concerns. TVA has proposed a method to disseminate the results of the ECSP to all interested parties, which the staff is currently reviewing. The staff's conclusions on this topic will be provided at a later date.
The staff has reviewed this scope of work for the ECTG program and concluded that it is acceptable.
l 3.3 Program Organization and Methodology The progam organization and the methodology being utilized to produce an evaluation of the employee concerns within the scope of the ECTG and their resolution has oeen developed. This is described in the ECTG Program Manual.
The governing organization and methodology are discussed below with staff comments as required.
3.3.1 Organization The program is under the control of the Manager of Nuclear Power and it is under the day-to-day direction of the ECTG Program Manager. The ECTG organization and its relationship to the nuclear site organizations is given in Figure I which is from the ECTG Program Manual.
It is the responsibility of the ECTG staff to determine the validity of the concerns and the need for corrective actions and it is the responsibility of j the TVA line organization reporting to the Site Directors or designated managers to determine specific corrective actions are needed to address l
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4 the concerns. The corrective actions are also carried out by the TVA line organization. These specific corrective actions, however, are reviewed and concurred in by the ECTG program Manager who can raise disagreements on corrective actions to the Manager of Nuclear Power. The Site Directors notify the ECTG, or the new ECP site representative if the ECTG is disbanded, after completion of the corrective actions. The ECTG program has a Corrective Action Program Manager who is responsible for coordinating the resolution of problems identified by the program. This program is audited by the Division of Nuclear Quality Assurance (DNOA) in accordance with the requirements of the Nuclear Quality Assurance Manual (NOAM).
The staff has reviewed the organization of the ECTG program and concludes that it is acceptable. There is sufficient independence between the program and the TVA line organization in resolving the concerns and identifying corrections.
The ECTG Program Manager reports directly to the Manager of Nuclear Power _ to resolve any differences between the program and the TVA line organization. The program is audited by the DNOA in accordance with the requirements of the NQAM.
3.3.2 Methodology The methodology of the ECTG program consists of the following:
Sorting concerns into logical categories and further categorizing into individual issues.
Training assigned personnel and verification of their qualifications and independence.
Verifying the preliminary determinations of safety status and generic applicability.
Evaluating the validity of issues relating to assigned concerns.
Determinating the causes of identified deficiencies.
l Identifying the need for corrective actions that will eliminate and l preclude recurrence of deficiencies.
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- Verifying the initiation of appropriate plant deficiency documents by responsible line management as a part of their planned corrective action to quality-related concerns.
Generating or compilating records to provide auditable evidence of the adequacy, logic, and rationale that provided the basis for judgments (findings) made during the evaluation process.
Reviewing concurrences with corrective action responses prepared by l responsible line management.
The concerns were sorted into one of nine technical categories. These categories are identified in Table 1. The intimidation, harassment and -
wrongdoing concerns were transferred to the TVA OIG with the welding aspects
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. 1 going to the TVA WTG for resolution. The ECTG will be provided with the ;
results of the evaluations. i The Management and Personnel and Industrial Safety Categories were determined ) '
by TVA not to be nuclear safety related and element reports on the resolution The NRC reviewed of these concarns were not submitted to NRC for its review.
TVA's determination and agreed to TVA not submitting element reports on Management and Personnel and Industrial Safety.
The staff accepted the nuclear safety-related criteria used in this program in }
its letter dated July 31, 1987, and accepted TVA not submitting element reports on Industrial Safety in its letter dated Aucust 24, 1987. The evaluation by the staff of the Management and Personnel Category will be performed by reviewing subcategory reports in this issue and will be provided at a later date. The staff has determined that a portion of these issues relate to the safe operation of Sequoyah Unit 2, a6d therefore needs to be resolved before restart of Sequoyah, Unit 2.
A set of issues not identified by the program as a category in Table 1 are issues identified in the Stone & Webster Engineering Corporation reports on
" Systematic Analysis of Identified Concerns / Issues at TVA," and as a result of TVA NSRS open investigations that had not been closed out by NSRS. The ECTG evaluated these issues to assure that appropriate corrective actions had been established for each SWEC and NSRS issue. The TVA program for closing SWEC and NSRS issues is considered acceptable by the staff. The staff letter accepting the TVA program on the NSRS issues is dated August 27, 1987.
l The ECTG procedures governing the methodology of the program are listed in Table 2. The reports to be generated by the program are listed in Table 3.
i 3.3.2.1 Categorization of Employee Concerns The program provided criteria (Attachment F to procedure ECTG M.1) to group similar concerns together within each category. The similar concerns formed element reports which were submitted to the staff for its review and approval.
Element reports were submitted only for Sequoyah. Concerns related to the ;
other TVA plants are to be addressed in the subcategory reports submitted by TVA. There were 317 element reports submitted by TVA on Sequoyah. A separate l evaluation will be issued by the staff on its review of these element reports.
3.3.2.2 Safety Classification The program provided criteria (Attachment C to procedure ECTG M.1) to classify concerns according to its safety classification (i.e., safety-related and non- ;
safety-related). The determination of the safety classification of most of the employee concerns in the ECSP was Jone by QTC or NSRS. Those concerns classified by NSRS that were not classified in accordance with Attachment C and those not previously classified were reviewed against Attachment C. These criteria were reviewed ano accepted by the staff in its letter to TVA dated July 31, 1987.
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3.3.2.3 Generic Applicability The program provided criteria (Attachment E to procedure ECTG M 1) to determine the potential for eeneric applicability of (1) a concern at one plant to other TVA plants and (2) a concern on one system, item or process to other systems, items or process within the same plant. This was dore for concerns that were safety-related. Attachment E stated that determinations of generic applicability should be done on a conservative basis with a reasonable factual basis and not merely speculation. The generic applicability decision is reviewed and concurred on by a second person.
3.3.2.4 Evaluator's Independence and Training The evaluators were required to be experienced in the fields of the concerned subject that they evaluated and trained in the objectives, procedures, and evaluation methods of the program. An evaluator's profile was generated and listed the education, areas of expertise and relevant experience. The evaluators were to be independent directly and indirectly of the concern being evaluated, not to have been involved in previous investigations or determinations of these concerns and not to have potential conflicts of interest. The program provided its requirement in procedures ECTG B.1 and C.1.
3.3.2.5 Evaluations, Corrective Actions and Verification f The ECTG evaluators were responsible for the collection, documentation, coordination and analysis needed to evaluate the assigned concerns. The l evaluators were responsible for the following: j
- a. Perform comparisons of " baseline" requirements, documents, and records to ensure consistency and implementation of requirements.
- b. Conduct interviews, both formal and informal, with cognizant personnel to either verify document-based findings or provide nondocument-based evaluation input.
- c. Perform observation of work activities and review of records and other documents to ensure compliance with requirements and 4 instructions. J
- d. Perform inspections and sampling to verify the adequacy of previously accomplished work. ;
- e. Sufficient documentation to support the evaluation results and the judgments made. l A case file checklist (for a complete file) was provided in the procedures.
Corrective action responses are the responsibility of the Site Directors or other designated TVA manacers. Responses to identified items requiring corrective action from the ECTG Program are documented by memoranda and utilize the ECTG Corrective Action Tracking Document (CATD) to verify and document implementation. !
Proposed corrective action responses from the Site Directors are provided to the ECTG Program Manager.
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If concurrence between the Site Directors and the ECTG Program Manager cannot be achieved the ECTG Program Manager documents the impasse and escalates the matter for resolution by the Manager of Nuclear Power.
The responses to quality-related items shall include a copy of the QA deficiency docunent or corrective action document that was initiated and shall include approvals required for the proposed disposition. Corrective actions of quality-related items shall be trac'ked, verified and closed out in accordance with the quality assurance program deficiency document that was initiated to document the deficiency. Tracking, verification, and closeout of CATDs shall be accomplished by the ECTG until it is disbanded after which the new ECP shall be responsible for closeout documentation. The program provided its requirements in procedures l ECTG M.1, 0.2, and C.3.
3.3.2.6 Reports The different reports prepared by the ECTG program are listed in Table 3. The element reports were written for those concerns which were related directly or indirectly (i.e. generically) to Sequoyah. These reports presented the characterization of the issues, a summary, the list of evaluators, the evaluation process, the findings, and corrective actions. The element reports are to be sufficiently complete to " stand alone".
i The subcategory reports will discuss the findings for all TVA plants including Sequoyah. These reports would also discuss any concerns not related to Sequoyah.
All Sequyah element reports except for Industrial Safety and Management and Personnel and a small portion of the Engineering Category have been submitted to NRC for its review and approval. In some cases, based on both NRC review and TVA review of the element reports, revised element reports have been submitted to NRC. TVA is in the process of submitting to NRC all of the subcategory reports, including Industrial Safety and Management and Personnel.
The program provided its requirements on reports in procedures ECTG M.1 and C.2 and in the ECTG Reports Writer's Guide. These reports are reviewed by the Senior Review Panel (SRP), the ECTG program, and the ECTG Program Manager prior to their submittal to the NRC.
3.3.2.7 Protection of Sensitive Information l The program has procedures to establish methods for the receipt, maintenance, management, and control of access to sensitive and nonsensitive information.
This includes expurgated QTC employee concern interview and evaluation files, unexpurgated files relating to previous TVA programs transferred to the ECTG, employee concern files which do not contain sensitive information, and ECTG administrative files. Sensitive information is defined as data developed during an interview process that could identify the interviewee. A determination would be made by the ECTG Program Manager that access to sensitive information is necessary for the performance of official, contractual or other duties of employment. These program requirements are in procedures ECTG M.1 and A.2.
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J 3.3.2.8 Senior Review Panel (SRP)
The SRP was established to provide an independent and objective oversight of efforts to resolve employee concerns identified by the ECTG program. This <
oversight is to ensure that (1) the scope and depth of the evaluation effort l are adequate, (2) findings are correct. (3) the proposed corrective actions adequately address identified probieras, and (4) the final report adequately describes the evaluation effort, evaluation findings, and measures taken to resolve the identified concerns.
The SRP members were selected by the Manager of Nuclear Power to provide highly qualified personnel with a background in matters related to nuclear power plant design, construction, and operation. The SRP members report directly to the Manager of Nuclear Power.
The SRP is composed of the following:
The former Director of Engineering at Oak Ridge National Laboratory; The former Startup Readiness Consultant for Three Mile Island; The former Vice-President of Quality and Technology for B & W, and The former Nuclear Project Manager for Sargent & Lundy.
3.3.2.9 Review, Concurrence and Approval Reouirenents The requirements for the review and approval of the different ECTG report types l
are given in Procedure C.2 and summarized in Table 4. These requirements apply I both to report types that contain corrective action requirements and to those that do not. Procedure C.3, Corrective Actions, provides the means for affected Site Directors or designated managtrs to review, concur, and approve the corrective actions contained in the ECTG reports.
I The staff concludes that this review process is sufficient and adequate for the ECSP reports and for the Corrective Action program. This conclusion is l based en the NRC inspection of the actual process and its results.
The element reports for Sequoyah have been submitted to the staff. These reports have been prioritized by the staff and those considered related to restart will be reviewed by the staff before the restart of Sequoyah Unit 2.
The criteria being used by the staff are the restart criteria presented in Section 3.3.2.10 and approved in the staff's letter to TVA dated June 9, 1987.
The staff's review of restart Sequoyah element reports includes (1) all reports where TVA has considered a corrective action is needed before restart of Sequoyah Unit 2 and (2) other reports not having corrective actions which the staff concludes must be reviewed before restart because of safety considerations.
3.3.2.10 Restart Criteria The criteria used to decide if a corrective action must be. completed before restart are the restart criteria in Table 7 of the Sequoyah Nuclear Performance Plan. This is applied by the TVA line organization when corrective actions determined by the ECTG program are reviewed by the line organization. The staff approved this restart criteria in the staff's letter dated June 9,1987.
3.3.2.11 Tracking and the Employee Concern Program Computer System The purpose of the Employee Concern Program Computer System (ECPCS) is to provide a compilation of ECTG concerns and related data, provide a historical sunnary of each concern for future use in the new ECP and provide an index to aid in retrieval of records. This is documented in procedure ECTG A.3 of the ECTG program.
The ECTG program is responsible to track the status of all corrective actions to close out concerns. The mechanism for tracking these actions is the Tracking and Reporting of Open Items (TROI) tracking system. This is TVA's corporate computer system for tracking conditions adverse to quality (CAQ).
The ECTG program corrective actions, including the corrective actions for quality-related items, are considered to be CAQ and, thus, are being tracked in the appropriate system.
4.0 CONCLUSION
The staff has reviewed the ECTG program, up to Revision 5, which is being used by TVA to evaluate employee concerns which were raised prior to February 1, 1986, and provide n timely disposition, corrective action and closecut of these concerns. This includes the SWEC assessments and NSRS recommendations, presented in Section 3.3.2. The staff has reviewed the program procedures listed in Table 2, conducted inspections of the early phases of the program, reviewed all the elements reports submitted for Sequoyah and discussed the program in the meeting of June 1, 1987. Based on this review, the staff concludes that the ECTG program as discussed above is an acceptable program for evaluating and providing corrective actions to the employee concerns addressed by the program. The new ECP which will address employee concerns received after February 1, 1986, will be addressed in a separate evaluation by the staff.
The staff review of the 317 TVA Sequoyah element reports and the TVA subcategory and category reports will be the subject of separate NRC safety evaluations.
5.0 REFERENCES
l 1.0 Inspection Report Nos. 55-390/85-49 and 50-391/85-49 dated August 8, 1985, inspection July 15-18, 1985.
2.0 Inspection Report Nos. 50-390/85-57 and 50-391/85-57 dated December 13, 1985, inspection September 30 to October 4, and October 21-25, l 1985.
3.0 Inspection Report Nos. 50-327/86-08 and 50-328/86-08 dated February 20, 1986; inspection January 21-24, 1986.
4.0 Inspection Report Nos. 50-327/86-29 and 50-328/86-29 dated May 15, ,
1986, inspection April 0-11, 1986. j 5.0 Inspection Report Nos. 50-390/86-15 and 50-391/86-15 dated July 7, 1986; inspecu cn June 10-12, 1986.
6.0 Inspection Report Nos. 50-327/86-51 and 50-328/86-51 dated September 19, 1986; inspection August 26-28, 1986. ,
1 7.0 Letter, B. J. Youngblood (NRC) to S. A. White (TVA), TVA Employee l Concern Program, dated February 13, 1986.
I 8.0 Letter, J. A. Zwolinski (NPC) to S. A. White (TVA), Sequoyah and Browns Ferry Restart Criteria, dated June 9,1987.
9.0 Minutes of June 1,1987, Meeting on Licensee's Special Employee .y Concern Program, Meeting Summary, dated June 19, 1987. j 10.0 Letter, J. A. Zwolinski (NRC) to S. A. White (TVA), Employee Concern Special Program Nuclear Safety-Related Criteria, dated July 31, 1987. j i
11.0 Letter, J. A. Zwolinski (NRC) to S. A. White (TVA), Transmittal of Safety Evaluation for the Industrial Safety Category of the Employee Concern Program for Sequoyah, dated August 24, 1987.
12.0 Letter, J. A. Zwolinski (NRC) to S. A. White (TVA), Evaluation of Nuclear Safety Review Staff Concerns Requiring Resolution Before
i Restart, dated August 27, 1987.
Principal evaluators: J. Donohew, M. Fields Dated: October 6, 1987 I
Table 1 CATEGORIZATION OF CONCERNS !
The following nine categories of concerns, as defined below, were utilized by j ECTG:
- 1. Quality Assurance /Ouality Control (0A/0C) - Concerns related to the acequacy of 0A/0C Programs and procedures (e.g., document control, records, deficiency reporting and corrective action, inspection except NDE i and weld inspection, auditing, etc.) and the training, qualification and certification of QA/0C personnel.
- 2. Material Control - Concerns related to the adequacy of material including their procurement, receiving, har.dling, and storage and to the associating controlling procedures.
- 3. Management and Personnel - Concerns related to the adequacy of policies, management attitude and effectiveness, organization structures, personnel management, and personnel training and qualification, except those covered by the 0A/0C category, i I
4 Intimidation, Harassment and Wrongdoing - Concerns related to personnel conduct that interferes with employees' ability to fulfill their assigned responsibility, unauthorized actions taken against employees for fulfilling their assigned responsibility, and illegal activities or l violations of TVA policies and regulations. Concerns belonging to this )'
category are transmitted to the TVA Office of the Inspector General (0IG) for evaluation.
- 5. Operations - Concerns related to operational activities including operator j qualifications, maintenance or equipment maintenance needs, security, health physics, and ALARA (as low as reasonably achievable) implementation, and to preoperational and surveillance testing. ;
6, Weldino - Concerns related to any aspect of welding including welder or weld procedure qualification, weld inspection / nondestructive examination (NDE), heat treatment, weld quality, filler material quality, and weld documentation.
- 7. Construction - Concerns related to the adequacy of construction practices, the quality of as-constructed facilities (excluding welding and as-designed features), in-storage and installed maintenance prior to turnover to operations, measuring test and handling equipment used during !
construction, and construction testing activities.
- 8. Industrial Safety - Concerns related to the working environment and controls which protect the health and safety of empir,yees in the workplace (excluding health physics and ALARA in Operations).
- 9. Engineering - Concerns related to the adequacy of the design process and the as-designet % nt features. The design process is the technical and management pr sesses that commence with the identification of design inputs and lead to and include the issuance of all design output documents.
Table 2 ECTG PROGRAM PROCEDURES ECTG M.1 Program Description Attachment A, Employee Concerns Task Group Organizational Chart Attachment B. Senior Review Panel (SRP) Charter Attachment C, Criteria for Evaluating Concerns to Determine Those That are Nuclear Safety Related for Use as Applies to Employee Concerns Attachment D, Criteria for Evaluating Safety-Related Employee Concerns to Determine if a Safety-Significant Ouestion or Safety Hazard Exists Attachment E, Instructions for Review of Employee Concerns for Generic Applicability Attachment F Criteria for Subcategories Concerns ECTG M.2 Program Plan for SWEC and NSRS Issues ECTG A.1 Processing of Generically Applicable Employee Concerns i l
ECTG A.2 Filing and Protection of Sensitive Information !
ECTG A.3 Employee Concerns Program Computer System Data Processing ECTG A.4 Program Procedure Revisions 1 ECTG B.1 Evaluator Training and Indoctrination ECTG C.1 Receipt, Processing and Evaluation of Concerns ECTG C.2 Analysis and Reporting of Evaluation Results ,
ECTG C.3 Corrective Actions Reports Writer's Guide l
Table 3 ECTG REPORT HIERARCHY Element Reports Element reports that have been generated are only for the Sequoyah plants and sumarize one or more employee concerns dealing with one or more closely related issues. The element report should contain sufficient detail to make it unnecessary for a reader to examine case files for the concerns summarized.
Subcategory Reports Subcategory reports summarize the evaluations of a number of elements and include the evaluations made on the other TVA plants (i.e., Browns Ferry, Watts Bar,Bellefonte). The subcategory report does more than collect element level evaluations. The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.
This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparent in the individual element report. Sub-category reports should contain sufficient detail to make it unnecessary for the reader to examine element reports or case files for the issues summarized.
Subcategory reports should include both the generic and site-specific results of the entire evaluation process for-a subcategory.
Category Reports Category reports summarize the subcategory reports. Each category report reviews the major findings and collective significance of the subcategory reports within a given area. The category report integrates the information assembled in its subcategories, addressing particularly the underlying causes of those problems that run across more than one subcategory. Category reports form the basis for preparation of the ECTG Final Report.
ECTG Final Report The ECTG Final Report integrates and assesses the entire ECTG effort, including the separate Inspector General's report on intimidation and harassment and the Welding Task Group's report on welding concerns. Additionally, this report describes the entire ECTG process and the process to be used for corrective action tracking, followup, and closecut.
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l Table 4
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REVIEW AND APPROVAL 0F ECTG REPORTS f
l ECTG MGR, REPORT TYPE PEER TAS CEG-H SRP PM ONP Element X X 0 X l
- l Subcategory X X 0 0 Category X X 0 0
- 0 0
ECTG Final X= Reviews 0= Concurs *= Approves PEER = Peer Review TAS = ECSP Technical Assistance Staff CEG-H = Category Evaluation Heads SRP = Senior Review Panels ECTG PM = ECTG Program Manager MGR ONP = Manager of the Office of Nuclear Power 1
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