ML20149L479

Corrected Pages 4 & 5 to Insp Rept 50-346/88-04

ML20149L479
Person / Time
Site:	Davis Besse
Issue date:	02/17/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20149L443	List: IR 05000346/1988004 ML20149L440 ML20149L479
References
50-346-88-04, 50-346-88-4, NUDOCS 8802240249
Download: ML20149L479 (2)

See also: IR 05000346/1988004

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,' Ensuing attempts by both the Production and Quality

departments at resolving QAD's coments were unsuccessful,

and, on April 27, 1987, the draft Revision 27 was

submitted to the site Safety Review Board (SRB) for

resolution.

The SRB met on May 8, 1987, and, as indicated in the

Procedure Development Fonn (PDF) for Revision 27, determined

that NG-AV-115 would have to be revised to reflect the

reduced level of QAD involvement in procedures and procedure

changes before Revision 27 to AD-1805 could be approved and

issued. The PDF was not signed by the QAD Director at this

time because the requisite changes had not been made to

NG-AV-115. The draft Revision 27 with SRB comments and the

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PDF without the QAD Director's signature were returned to the

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site Technical Support Group for continuing coordination of

the revision process. On May 13, 1987, the Technical Support

Manager signed the Revision 27 cover sheet indicating that

the revision was ready for issuance. The Plant Manager also

signed the cover sheet on May 13, approving its iss w e and

implementation. This signature process was reperfs. m c on

May 19, 1987. The second signatures by the Plant aM Technical

Support Managers were not required, and their purpose could

not be determined. At the time of both signings, NG-AV-115

still required QAD approval of the revision. This approval

had not been obtained as indicated by the lack of the QAD

Director's approval signature. The failure to obtain required

QAD Director approval prior to issuance of Revision 27 to

AD-1805 was a violation of existing controlling procedures

and was contrary to 10 CFR 50, Appendix B, Criterion V

(346/88004-01(DRP)).

(b) During the interviews conducted regarding the circumstances

surrounding the inappropriate approval and issuance of

Revision 27 to AD-1805, the following pertinent information

was identified:

1. The Technical Support Manager signed the cover sheet

on May 13, 1987, based on verbal confirmation that all

coments had been resolved.

ii. The Plant Manager signed the cover sheet on May 13,

1987, believing that the SRB had resolved QAD comments.

He further stated that at the time he signed the cover

sheet, he was unaware that a prerequisite revision to

NG-AV-115 was required.

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,. iii. On May 13, 1987, during the administrative processes

supporting implementation of Revision 27 to AD-1805,

including updating the T&PI, the fact that QAD had not

approved the revision was brought to the attention of l

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the Document Control (DC) Group, which was responsible '

for further processing and distribution, and the  !

SystemsandProcedures(S&P) Group,responsiblefor

updating the T&PI. DC returned the procedure to  ;

Technical Support for resolution of this discrepancy

prior to distribution. ,

iv. On May 14, 1987, an S&P Group supervisor signed the

PDF with the notation to proceed with processing  :

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without QA concurrence.

v. Technical Support determined that QAD was not prepared

to accept the necessary changes to NG-AV-115 to support

implementation of Revision 27 to AD 1805.

Based on the results of interviews as discussed above, the

lack of QA approval had been identified to at least three

organizations assigned key functions in the procedure

implementation process. Netwithstanding, Revision 27 to

AD-1805 was issued on May 19, 1987.

(c) On May 19, 1987, QAD discovered that Revision 27 to AD-1805

was issued without its approval. Further attempts to resolve

the concerns with Technical Support failed and, on June 26,

1987, QAD issued Potential Condition Adverse to Quality

Report (PCAQR) 87-0322. This PCAQR was still open at the

time of the inspection. A memorandum proposing escalation

to a Management Corrective Action was prepared by the

Director, QAD, on August 6, 1987. The purpose of this

memorandum was to bring this issue to the attention of the

Nuclear Group Vice President for resolution. This memorandum

was not issued. The failure to take prompt and effective

corrective action for the identified violation is a violation

of 10 CFR 50, Appendix B, Criterion XVI (50-346/88004-02(DRP)).

(d) QAD indicated during interviews that it is currently

reviewing all procedures and changes issued under '

Revision 27 to AD-1805 to ensure that quality requirements ,

were not deleted from site procedures. To date, no safety

issues have been identified.

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(2) Conclusions: Based on the above infomation, the following  !

conclusions were reached:  :

(a) The changes made to AD-1805 by Revision 27 reduced I

the level of QAD involvement in the procedure control

process.

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