ML20205A039
| ML20205A039 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 03/16/1987 |
| From: | Bezanson W, Russell Gibbs, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082280289 | List: |
| References | |
| 80101-SQN, 80101-SQN-R06, 80101-SQN-R6, NUDOCS 8703270373 | |
| Download: ML20205A039 (17) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80101-SQN REPORT TYPE REVISION NUMBER:
2 Element Report 6
TITLE:
PAGE 1 0F 15 Quality Assurance Program Adequacy REASON FOR REVISION:
Rewritten to incorporate NRC comments.
Revision indicators are shown on each page to indicate revision changes.
Note:
Sequoyah Applicability Only PREPARATION PREPARED BY: WILLIAM E. BEZANSON st M
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- DATE APPROVED BY:
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dl\\llM0 N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL R3 PORT ONLY)
- SRP Secretary's Signature denotes SRP concurrence are in files.
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REPORT NUMBER:
ELEMENT TYPE:
80101-SQN g
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Element Report REVISION NUMBER:
TITLE:
6 Quality Assurance Program Adequacy PAGE 2 0F 15 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction This report reflects the results of the Quality Assurance Category Evaluation Group (QACEG) investigation of six employee concerns which were identified by the Tennessee Valley Authority (TVA) Watts Bar Employee Concerns Special Program.
These concerns were evaluated for the Sequoyah Nuclear. Plant (SQNP) as two concerns were determined to be Sequoyah specific with the remaining' concerns designated as generically applicable to SQNP.
1.2 Description of Issues The conditions reported by concerned employees (Attachment A), and as noted below, were grouped by issue under this element since they pertain to the adequacy of the Quality Assurance (QA) Program at SQNP.
1.2.1 Issue - Excessive Paperwork and Procedures
([1, has interpreted quantity as the meaning, e.g.,
excessive Jca the process of emphasizing the importance of " Quality", TVA amount of paperwork and procedures (Concern BFM-86-002-001, dated January 17, 1986)
Amount of procedures and paperwork is the principle concern at Sequoyah not the quality of work.
(Concern MRS-85-001, dated June 23, 1986) 1.2.2 Issue - Procurement Requirements Not Invoked TVA Material suppliers are not required to invoke QA requirements on sub-tier suppliers.
(Concern IN-86-011-003, dated November 12, 1985)
Power Stores / Nuclear Plant Power Operation procurement process (Nuclear Quality Assurance Manual (NQAM), Part III, Section 2.1) does not assure applicable requirements (regulatory, design bases, qualification etc.) are being met.
(Concern OE-QMS-1, dated July 26, 1986) 1.2.3 Issue - Nuclear Quality Assurance Manual Requirements Not Complied With TVA Nuclear plants are ignoring the QC Program from the Nuclear Power Office (NQAM) and are writing their own program.
(Concern WBM-86-004-002, dated January 24, 1986) w
o y,
s.
REPORT NUMBER:
ELEMENI TYPE:
80101-SQN
[C4 LElenent Report REVISION NUMBER:
TITLE:
-4 6
Quality Assurance Progrba, Adequacy PAGE 3 0F 15 1n
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~l 1.2.4 Issue -!kanagement Pressure is Restricting The Audit Fun,:tions C
Quality' Assurance Management pressures auditors to close audit deviations before the ' auditor is satisfied that adequate corrective action has been -implemented.
(XX-85-116-008 dated February 21, 1986)
..m.
4 These perceived conditions noted above eslablished the basic element for this evaluation as " Quality Assurance Program Adequacy".
~ 2.0.
SUMMARY
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<2.1 Summary of Characterization of 14s.ue
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V were gryopill; into the element of " Quality I
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The employee concerns Assurance Program Adequacy" bechea de conditions specified in those concerns pertain to the adequacy'of'the Quality Assurance (QA) Program
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being implemented at SQNP.
I 2.2 ' Summary of Evaluation Process
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,_During the course of this evaluation, Appendix ' b to 9)CFR50 and the [
Olo11owing TVA ; documents were review to ddetermine grequirements and <
commitments as they apply to SQNP and this issues Final Safety '\\ ?
Analysis Report (FSAR), Nuclear Quality Assurance Mar:ual (NQAM),
- Sequoyah Nuclear Plant Administative Instructions (lil i),
Sequoyah Quality Control (QC)
- Progrcm, Division of Qualit y Assurance Instructions (DQAIs), Office of Engineering Operatier. ' Instructions (OE-01s), Engineering, Design, Contruction, and Quality A sUrance and (various Procedures (QAPs),
Quality Assurance Audit Reports, memorandums and letters.
x s
i Also, the Employee Concern Files including the Confidential Files were reviewed for any additional data pertaining to this issue.
The results of that review indicated two reports (Nuclear Safety 'Baview Staff (NSRS) Report and a Generic Concern Task Force (ICTF) Report) had been issued ' and pertained to this element.
These ' reports were reviewed by QACEG to determine the scope and investigation results.
In additicn, the evaluation process included discussions with Quality Assurance Mditors, Quali;;y Supervisors, Quality Branch Chief, Section Supervisor t-Audit Branch, Pas t Director of Quality Assurance, Environmental Qualification Project Engineer, Manager of Nuclear Engineering Employee Concerns, and Manager of Operation Engineerind Services regarding the Quality Assurance Program adequacy for SQNP.
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' REPORT NUMBER:"
jQM.d'.LEMElf1l TYPE::
'N 80101-SQN Ug%g % : Element. Report:
= REVISION NUMBER:
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' TITLE:
6 Quality' Assurance Program Adequacy:
PAGE 4 0F.15 3y hk.3-SumabhofFindings q
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-Q 1The rissue of' 'fExcessive: Paperwork.and Procedures" wasTsubstantiated.
and i'sl addressed lin TVA's Nuclear Performance-Plan dated March ' 19, 1986.'
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The p sue of " Procurement Requirements.Not Invoked",-was substantiated h parp (Employee; Concern 0E-QMS-1).
This '. conclusion was based upon
-QACEG'd review of documented problem conditions in the TVA Procurement Program at Sequoyah e.g.
NSRS Report, Corr.setive Action Report. and
[
memoranda froarthe Manager.of; Nuclear Power.
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issue bf ' " Nuclear Quality Assurance Manual Requirements ~ Not j The Complied Wit,'b" was unsubstantiated as the QACEG investigation found no evidence where ' the Sequoyah site was ignoring their - Quality Control 4
Program' or lhat it did not comply with the intent of the NQAM.
I. i a The issue of -" Management Pressure is. Restricting the Audit Functions" QACEG investigation indicated auditors were
[(was' unsubstantiated.
delinquent.in closing audit findings in a timely manner.
However, no Q,
,\\ documented evidence was-identified.to indicate auditors were pressured Nv to close audit findings.
- 2. 4, Summary of Corrective Action
..k Thed issues " Excessive Paperwork and Procedures" and " Procurement iJto tirements not Invoked" were substantiated.
P,tkor to the QACM evaluation, the Manager of Nuclear Power had assigned the Division of Nuclear Services to prepare corporate level s,
nisclear standards.for developing directives and procedures for each of the -headquarters departments.
These standards will be used to evaluate and revise all existing nuclear procedures on a site-by-site basis.
l The action taken by TVA Management pertaining to the issue
" Procurement Requirements Not Invoked" was to:
a.
Revise the NQAM and Sequoyah Site Standard Practice SQA-45.
b.
Staff a core of trained procurement groups.
I c.
Establish responsibilities for procurement of permanent and g%
safety-related spare and replacement parts and to assess those items installed or in storage for compliance with established requirements.
i Management has revised the NQAM and SQA-45, also a core procurement group has been established at SQN.
The responsibility for procurement has been assigned to the Design Nuclear Engineering (DNE) Division.
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Element Report REVISION NUMBER:
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TITLE:.
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i They are presently in the process of assessing the material / parts installed or in storage for compliance with the program.
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3.0 LIST OF EVALUATORS D. G. Barlow W. E. Bezanson J. J. DeAngelis 4.0 EVALUATION PROCESS f:
4.1 General Method of Evaluation The evaluation process consisted of researching the Employee Concern y
Files, including the Confidential Files, Nuclear Safety Review Staf f i
Files and the Generic Concern Task Force Files to determine if additional. data was available which could be utilized in the investigation of this element.
The basic contents of those files were p,
the K-Forms (document used for recording employee concerns), NSRS Investigation Report, CCTF Investigation Report, and various uemoranda v
and letters which pertained to the employee concerns and these issues..
Reviews were also conducted of tu Federal Regulatory Requirements, TVA upper tier documents such ae the Final Safety Analysis Report, Topical Report, Nuclear Quality Assurance Manual, Audit Reports, and Nuclear Perfr nunce Plan.
In addition, lower tier documents such as i
site staneo S.
procedures, instruction letters, and memoranda were reviewed to cet wine requirements, commitments and responsibilities.
The review and evaluation of the above documents and discussions held with cognizant personnel established the basis for the conclusions reached in this report.
4.2 Specifies of Evaluation 4.2.1 Issue - Excessive Paperwork and Procedures The research of Employee Concern Files including the Confidential Files for any additional data pertaining to this issue' indicated none was available.
TVA's Topical Report TVA-TR75-1A, Revision 8,
dated October 12, 1984, and Appendix B to 10CFR50, dated Janaury 20, 1975, specify the requirements fc~r a documented program to be C, -
paperwork be generated.
established.
The program requires that procedures and
REPORT NUMBER:
ELEMENT TYPE:
80101-SQN
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Element Report REVISION NUMBER:
' TITLE:
6 Quality Assurance Program Adequacy PACE 6 0F 15 TVA's Nuclear Performance Plan (Report submitted by TVA Management to the Nuclear Regulatory Commission (NRC) which defines TVA's Nuclear recovery program) dated March 1986 was also reviewed as it describes management action on this issue.
Personnel interviews and discussions were not deemed necessary by QACEG as the Employee Concerns (as written) are basically the employees' opinion and were non-specific as to requirements, programs procedures, documentation or groups involved.
4.2.2 Issue - Procurement Requirements Not Invoked Reviewed the Employee Concern
- Files, including the Confidential Files, for any additional data pertaining to this issue.
The results of that review indentified additional information in the form of a. NSRS Report (R-84-17 NPS) and memorandums which were utilized in this evaluation.
The following documents were reviewed for information and g
requirements pertaining to this issue.
v.
Appendix B to 10CFR50, dated January 20, 1975.
Nuclear Quality Assurance Manual (NQAM), Revisions dated August 16, 1985, December 23, 1985, and June 20, 1986.
Sequoyah Nuclear Plant Standard Practice, SQA-45, " Quality control of Material, Parts & Services", Revisions 16, dated July 9, 1985, 17 dated September 27, 1985, 18 dated November 21, 1985, 19 dated February 13, 1986, 20 dated March 4, 1986, and 21 dated June 23, 1986, were reviewed to determine the site procurement requirements.
TVA Quality ' Assuranc. & Audit Staff - Audit Report CH-8200-14, dated February 17, 1983, vas reviewed as it identified problems in the procurement program.
Nuclear Safety Review Staff Report R-84-17 NPS (Attachment C), " Review of Procurement Practices and Procedures for Operation of Nuclear Power Plants," dated March 12, 1985, and the Manager of Nuclear Power response, memorandum L12850520800, dated May 21, 1985, were reviewed as they pertained to procurement practices and procedures.
Corrective Accion Report (CAR)
SQ-CAR-86-02-006, dated
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March 10, 1986, and the following memorandums:
L16860723
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855, dated July 23, 1986 and 808 800417 801, dated April 11, 1986, were reviewed to assess the action taken on identified procurement problems.
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80101-SQN Element Report REVISION NUMBER:
TITLE:
6 Quality Assurance Program Adequacy PAGE 7 0F 15 Generic Concern Task Force Report (Attachment B),
" Supplier's Contractors" dated May 16, 1986, was reviewed-to assess GCTF's evaluation and conclusion of Employee Concern IN-86-Oll-003.
Various memoranda (Attachment D) pertaining to TVA's procurement program and this issue were also reviewed to determine requirements and commitments.
In
- addition, discussions were held with the Sequoyah Environmental Qualification Project Engineer, Manager of Nuclear Engineering Employee Concerns, Manager of Operation Engineering Services, and Section Supervisor - Audit Branch for information pertaining to this issue.
4.2.3 Issue - Nuclear Quality Assurance Manual Requirements Not Complied With Employee Concern Files, including the Confidential File, were reviewed for any additional information relating to this issue.
No further information was available.
Reviewed Sequoyah's Administrative Instruction AI-20,
" Inspection Program", Revision 10, dated November 21, 1984 and the site Quality Control Program for compliance with the Nuclear Quality Assurance Program requirements.
Discussions were held with Sequoyah's Quality Engineers and their supervisors pertaining to this issue.
4.2.4 Issue - Management Pressure Is Restricting The Audit Function Employee Concern Files and Confidential Files were reviewed for any additional information which could be utilized by QACEG in the investigation of this issue.
None was available pertaining to the issue.
As a
result of the QACEG investigation those documents listed in Attachment E were reviewed for requirements and commitments pertaining to this issue.
Discussions were held with nine QA Audit Branch - Lead Auditors in order to establish the historical background information, pertaining to auditors being pressured to close audit findings, the type of pressure applied, and the reason for that presssure.
REPORT NUMBER:
ELEMENT TYPE:
80101-SQN s
Element Report REVISION NUMBER:
TITLE:
6 Quality Assurance Program Adequacy PAGE 8 0F 15 5.0 FINDINGS 5.1 Findings on Issues Based on the evaluations and investigations performed by QACEG, one of the four issues (Procurement Requirements Not Invoked) was substantiated in part and pertained to Employee Concern OE-QMS-1.
Additionally the issue of excessive paperwork and procedures was substantiated. The remaining issues were not substantiated.
The following addresses both a discussion and conclusion of each issue as identified in Section 1.2 of this report.
5.1.1 Issue - Excessive Paperwork and Procedures Discussion The QACEG investigation identified that TVA had addressed the issue of burdensome paperwork and procedures which is identified in their " Nuclear Performance Plan" (pages 11, 14,
<1 73, 74, and 75) dated March 1986.
That document also b
identified the root cause for that condition (as noted below) and TVA's commitment to the NRC for resolving that condition:
"In the past, all of TVA departments responsible for nuclear activities have not been unified into a single nuclear organization.
TVA's nuclear plants ac' headquarters departments
- have, at
- times, acted autonomously, and authority for functional activities was sometimes divided among several groups.
As a result, lines of authority and responsibility have not always been clear and the implementation of TVA's Nuclear Program has not been consistent."
Improvements' In Management Systems and Controls "Some of the problems in TVA's nuclear program have involved insufficient programs and procedures, a lack of prior planning and integration of nuclear activities, and a failure to satisfy prior commitments to the NRC.
In response to these problems, TVA is reviewing its nuclear procedures and will be establishing centralized programs and procedures to control all TVA nuclear activities; TVA has assigned the Division of Nuclear Services with the responsibility."
In the short-term, "TVA will prepare interim corporate-level nuclear standards for developing directives and procedures for each of the headquarters departments reporting to the Manager of Nuclear Power.
These standards will be used to evaluate and revise all existing nuclear procedures on a site-by-site
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- Quality Assurance Program Adequacy PAGE 9 OF 15-basis. and will serve as a basis for preparation of final corporate-level nuclear directives and procedures.
Whenever possible, the interim standards will be based upon those provisions of existing procedures which provide effective control of' activity in question".
In the loeg-term, "TVA. will prepare and issue Nuclear Power Directives,. approved by the Manager of Nuclear Power, to define the specified objectives and responsibilities o f - the headquarters departments ceporting to the Manager of Nuclear Power Directives.
Corporate-level directives and procedures will be developed or revised for each headquarters department.
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Plant-specific procedures will then be reviewed and revised on site-by-site basis to assure their conformance with the a
requirements in the corporate-level nuclear directives and procedures".
Conclusion
.- As a
result of QACEG's investigation the issue was
.p substantiated.
Based on the.above stated improvements,
\\~a assigned to the Division of Nuclear Services for implementation, an ECSP - Corrective Action Tracking ' Document (CATD) was not initiated.
The stated improvements when implemented will reduce the number of procedures / paperwork.
However, the amount of procedures and paperwork required may still be considered burdensome.
5.1.2 Issue - Procurement Requirements Not Invoked Discussion The following reports and documents were reviewed and evaluated during this investigation and reflected the following:
The Generic Concern Task Force (GCTF) Report, dated May 16, 1966 (Attachment B) for Sequoyah, stated the concern IN-86-011-003 was not valid.
Their conclusion was based on additional-data furnished by the Employee Responst Team (ERT) which obtained additional information from the concarned individual and clarified the concern as:
" Prior to 1982, TVA Class A bolting material was purchased from Dravo Company.
Dravo subcontracted with Texas Bolt for this material.
The certified mill test report received from Texas Bolt did not indicate that the material was ASME Class I."
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The report also addressed two specific issues:
"Does TVA
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require material suppliers to have sub-tier suppliers meet
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the; QA requirements for procurement and did Dravo _ ' supply -
bolting material for.Sequoyah?"
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The conclusion of.the GCTF investigation stated:
"The NQAM, Part III, Section 2.1, does require sub-
.f tier suppliers to meet the same requirements as the p
contract supplier.
Also. Dravo Corporation and Texas 4
Bolt Company met the requirements for supplying ASME Code' material.
Dravo Corporation did not have a contract to supply material for the Sequoyah ; Nuclear k
P lan t.
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Based on'our review and evaluation, QACEG concurs with'the E :
GCTF report conclusion.
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7.
QACEG's review ' of the NSRS Report R-84-17,NPS, " Review of Procurement Practices And Procedures For Operating Nuclear Power Plants", dated March 12, 1985, identified various
$1 problems (as noted below) in the TVA Procurement Program h
which are related to this concern:
" Procurement-system is too cumbersome, and not well known by the users.
].
There is insufficient documentation for transferred
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material.
i 10 CFR 21-requirements incorrectly linked to Nuclear Power (NUC PR) QA requirements.
Commercial grade items (QA Level I and II designation) were purchas'ed with little or no QA requirements invoked.
No quality verification performed (receipt inspection) for commercial grade items."
[
QACEG's review of Corrective Action Report SQ CAR 86-02-006,
.i dated March 10, 1986, identified the following conditions in k
part:
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" Office of Engineering (0E) is supplying QA material for M
ASME Section III and Class lE application with
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insufficient or nonexistent documentation."
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"On requisitions for QA Materials, the statement, 'Does g
10 CFR Part 21 Notice Apply? yes ( ) no ( )'
is being
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marked out or lined out by OE.
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" Office of Engineering" (OE) is purchasing "QA" material for Class 1E application as "No QA" from the vendor and upgrading this material
..o "QA" on a transfer requisition from the Power Stores Distribution Center".
" Material descriptions do not adequately describe the item being supplied."
The above items were identified.as examples only, and reflect a problem in that the Office of Engineering procedural requirements were not in. agreement with the NQAM requirements.
QACEG reviewed NQAM, Part III, Section 2.1 " Procurement of Materials, Components, Spare Parts, and Services", revisions dated April 1, 1985, December 23, 1985, and June 20, 1986, for requirements pertaining to this issue.
The QACEG's review of the NQAM, indicated the later revisions dated December 23, 1985, and June 20, 1986, were revised in part -to reflect organizational changes and reviews to assure procurement
. requirements are specified in the procurement documents.
(,
V QACEG's review of Memorandum (R.
B.
Kelly, Directer, Nuclear Quality to W.
C.
Drotleff, Manager of Engineering) dated July 23, 1986 (L16 860723 855) stated the following in part:
"As a result of the reorganization, a number of activities which are subject to Part II and III of the NQAM are now being performed by DNE personnel.
Apparently some of these personnel are unaware of their responsibility to comply with the NQAM and continue to do business as they have in the past.
Please provide for procedure revision and/or training as may be necessary to ensure that DNE coordinate material transfers at'Sequoyah Nuclear Plant comply with the HQAM."
QACEG's review of the Sequoyah Site Standard Practice, SQA-45 indicated this document describes the methods and requiruments for controlling the procurement of materials, components, spare parts and services.
It also establishes and assigns responsibilities for the preparation, review and approval of procurement documents.
The revisions (dated July 9 and November 21, 1985, and February 13 and June 23, 1986) reviewed indicated SQA-45 was revised in part to reflect the later requirements of the NQAM.
Discussions were held with the Environmental Qualification Project Engineer, Manager of Nuclear Engineering Employee Concerns and Manager of Operation Engineering Services who were cogniz. ant of this issue.
They stated action was being b
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taken to - resolve the procurement problems, but' had not -been fully implemented.
c.
Conclusion p
TheJ issue of
" Procurement Requirements Not Invoked" is substantiated in part for Employee Concern OE-QMS-1.
As a renuit QACEG issued an ECSP - Corrective Action. Tracking Document (CATD) 80101-SQN-01 (Attachment F).
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5.1.3 Issue - Nuclear Quality Assurance Manual. Requirements Not o
Complied With i
0 Discussion i{
The QACEG investigation found no evidence where the Sequoyah 6
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' Site had.not incorporated the NQAM requirements into-their.QC f.
Program.
.QACEG's review of ~ all Corrective Action Requests and p
' Deficiency. Reports issued in 1982-1986, against the Sequoyah's j.
F-Nuclear.
Quality Assurance Organization (pertaining to Sequoyah's Quality Contrcl-Inspection. Program) ~ found.- no evidence. that the QC organization had ' failed to incorporate the NQAM ' requirements into the SQN plant instructions. (e.g.
c AI-20 " Quality Control' Inspections", or AI-34 " Training. and
_ Qualifications of QC and. Nondestructive.Examiniation (NDE)
Personnel").-
I.
4 QACEC's investigation of Sequoyah's-Corrective Action and 0
Deficiency Reports (for the life of the plant) with regard to to the - Quality Control Program, not complying with Nuclear Quality' Assurance Manual, found no evidence where deficiencies l'
were written against this issue.
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Conclusion j
ij As a result of this investigation, QACEG found no evidence that the Sequoyah site was ignoring their QC program.
The 4
evidence reviewed indicated the NQAM requirements were being l'
implemented in the Sequoyah QC program, therefore, the concern was unsubstantiated.
g.
5.1.4 Issue - Management-Pressure Is Restricting Audit Functions Discussion y
The concern was considered to be generic for all TVA sites, (Browns Ferry (BFN), Watts Bar (WBNP), Sequoyah (SQNP), and Bellefonte (BLN)).
QACEG established that a total of 133 s
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6 Quality' Assurance Program Adequacy PAGE 13 0F 15 audit reports (an audit report could include one (1) or more audit modules) were issued for these sites for 1984 and 1985.
Of those 133 reports, QACEG reviewed a sample of 23 reports which were issued during the same time frama that the employee concarn was generated.
Those 23 audit reports were reviewed for information pertaining to this issue.
In addition to the audit reports, the documentation and audit files identified by the individuals during the interviews were also reviewed.
The QACEG investigation was performed in three phases i.e.,
review of audit reports, interviews with audit personnel and review of related documents.
The scope of the investigation was limited to the evaluation of two areas:
a.
Were the corrective action methods used in compliance with the requirements of Appendix B to 10CFR50, Criterion XVIII, " Audits", and NQAM, Part III, Section 5.1 " Audits"?
b.
Was there documented evidence that Division QA Management had applied pressure to the Auditors to close deviations
(,,
prior to the implementation of completed corrective
-@c action?
Two (2) of the Multi-Site Audit Reports (CH-8500-01 and CH-8400-18) were reviewed specifically because they were referred to QACEG by an individual during the interview process as containing information to substantiate the concern of pressure being applied to close out audit findings.
Based on the review of the twenty-three (23) audit reports, QACEG found that a considerable amount of time was being taken to close audit deviations.
In most cases, a year was average and in other cases, 18 months to 3 years had elapsed before a report of corrective action was verified.
Since it was standard practice that an auditor who found a deviation was responsible to see it through to the verification of corrective action, the Quality Audit Branch and auditors would be under pressure to review and verify the corrective action, even though the sites were delinquent in responding to the audit findings, in a tinely manner.
From a cursory review of the documentation to support closings of deviations, it was identified that the sites held little regard for the audit deviations found.
The Site Directors would either request extensions to reply to the deviations or ignore the audit reports entirely.
From this, one could draw a conclusion that in the period of 1984-1985, the audit program was not being supported by TVA Management.
A memorandum from H.G. Parris to Site Directors, in June 1984, made mention that the NRC, on numerous occasions, criticized TVA for a lack of timeliness in responding to audit deviations and directed them to take a more positive part in responding and closing deviations.
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Quality Assurance Program Adequacy PAGE 14 0F 15-b h
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During the review, QACEG found four (4) instances where s
-deviations were escalated to a
higher authority for k
resolution.
These escalations were done in accordance with
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TVA procedures in effect at that time (DQAI-310, superseded by-g DQAI-313, superseded by DQAI-104).
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QACEG conducted interviews with nine (9) QA Audit Branch-Lead j
Auditors.
The results of these interviews indicated that.
f implicit pressures were applied by Q.A. management to close audit deviations prior to the full. satisfaction of the auditor.
conclusion I
t While it would appear, based on the interviews conducted, that
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auditors may have been pressured to close deviations before j'
they were satisfied that adequate corrective actions had been f
implemented, QACEG evaluators were not able to substantiate L
the concern based on the audits, and correspondence provided and reviewed.
The investigator also found correspondence to "All Audit Personnel" where they were instructed in handling i
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" pressure".
(Note:
Based on this investigation, the word
" pressure" was used in the context of closing audit deviations in a timely manner as required by applicable procedures.)
There was no objective evidence that pressure had been used or
- implied, to close deviations which were considered unsatisfactory by the auditor.
In addition, the review of the twenty-three (23) cudit reports indicated no evidence of violations to the requirements of Appendix "B"
to 10CFR50, Criterion XVIII, " Audits" or the NQAM, Part III, Section 5.1, i
" Audits".
j Based on the correspondence available during the investigation, it was concluded that the issue of
"...QA management pressures auditors to c1tse deviations..." was unsubstanciated.
k 5.2 QACEG's evaluation concluded that two issues " Excessive Paperwork and j
Procedures" and Procurement Requirements not Invoked" (employee
'j concerns BFM-86-002-001 and MRS-85-001, and OE-QMS-1) were substantiated.
The evaluation of concern 6 BFM-85-002-003 and MRS $
001 indicated the TVA program in effe.t did propagate excessive procedures which resulted in excessive pape nork.
The evaluation of gf concern OE-QMS-1 indicated the Power Stores / Nuclear Plant Power g
Operations procurements process (NQAM) did not assure applicable requirements (regulatory, design base, qualifications, etc.) were a
being met.
These issues are being evaluated by the Manager of Nuclear Power to determine required corrective actions and any potential impact to safety.
The remaining employee concerns were E
unsubstantiated and even though designated potentially safety-
REPORT NUMBER:
ELEMENT TYPE:
80101-SQN Element Report REVISION NUMBER:
TITLE:
6
. Quality Assurance Program Adequacy PAGE 15 0F 15 significant_ or safety-related in Attachment A,
they were not considered detrimental to the safe or reliable operation of the Sequoyah Nuclear Plant.
5.3 Cctrective Ac; ion TVA Management has taken the following corrective action on the issue
" Procurement Requiremente Not Invoked".
The NQAM and Sequoyah Site Standard Practice SQA-45, " Quality Control of Material, Parts, and Services", were revised in part to reflect changes required to improve the TVA Procurement Program.
Also, the Design Nuclear Engineering (DNE) Division has been assigned the responsibility for:
a.
Procurement of all spare and replacement parts and materials for permanent ar.d safety-related equipment.
I b.
Establish a Staff core of trained procurement groups at each site by June 30, - 1986, to prepare, review, and ' approve procurement C
documents and assure compliance with the NQAM requirements.
b,L The above improvements are still being implemented by TVA Management.
Based on the QACEG review of available documentation it could not be substantiated what action was being taken on equipment, components, material, spare or replacement parts already installed or in storage.
As a result, Employee Concern Special Program (ECSP) Corrective Action Tracking Document (CATD) 80101-SQN-01, ( Attachment F) was issued.
The SQN Site Director's response dated January 6, 1987 (Attachment G) to CATD 80101-SQN-01 stated a Replacement Items Task Force had been assigned on November 17, 1986.
The primary function of the Task Force is to develop measures to control future procurement, issuance of items currently in Power Stores, and to verify acceptability of installed it ems.
These actions are presently being implemented by the Task Force.
Implementation of those actions will be verified at a later date.
6.0 ATTACHMENTS A.
Listing of Employee Concern Information Subcategory 80101-SQN.
B.
Generic Concern Report - Suppliers Subcontractors, dated 5/9/86 C.
NSRS Report R-84-17-NPS D.
Documents Applicable to IN-86-011-003 and OE-QMS-1 E.
Documents applicable to XX-85-116-008 F.
ECSP Corrective Action Tracking Document 80101-SQN-01 C.
SQN Site Director's response to ECSP Corrective Action Tracking Document 80101-SQN-01 dat.ed January 6, 1987.
- P:giv 1' of c 2' ATTACllMENT'A-
.IRENCE
' - ECPS120J-ECPS121C.
TENNESSEE VALLEY' AUTHORITY.
.,---P A2 E
.. 3' PIENCY J-REQU2ST '
OFFICE OF flUCLEAR P0HER
~RUN TIME - 13:48:2Si
- ISSS - AllM '
EMPLOYEE CollCERN PROGRAML SYSTEM. (ECPS)
RUN DATE
'10/16'/56 LIST OF EMPLOYEE CollCERN.IllFORMATI0li
'ORY: QA QA/QC PROGRAMS SUBCATEGORY: 80101 QUALITY ASSURAtlCE. PROGRAM' ADEQUACY S1 GENERIC.
-KEYHORD A
+
H
. APPL
. QTC/flSRS P
KEYHORD B O!!CERN SUB R. PLT B B S 61.
INVESTIGATION S
CollCERil KEYl10RD C wMBER CAT CAT D LOC.
FLQB REPORT R
DESCRIPTI0tl KEYll0RD. D.
26-002-001 QA 80101 !! BFil Y ll Y Y -
Ill Tile PROCESS OF ' EMPHASIZING THE IM PERS0tlNEL-FEELIllGS -
50246 REPORT.
PORTANCE OF " QUALITY" TVA HAS INTERP-QA PROGRAM RETED "QUAllTITY" AS THE MEANING, E.G
' GENERAL EXCESSIVE AMOUllT 0F PAPERHORK ANDE
-GENERAL PROCEDURES. THE PROFESS 10tlAL CAN R EDUCE AND SIMPLIFY THE PAPERHORK AND PROCEDURES HITHOUT REDUCING "QUALIT.
Y".
HUCLEAR P0llER CONCERN. CI HAS NO FURTHER INFORMATION.
56-011-003 QA 80101 N HBN YYYY lls TVALDOES 110T REQUIRE MATERIAL SUPPLI QA PROGRAMI 10188 K-FORM ERS-TO IllVOLVE QA' REQUIREMENTS ON SU s ORGANIZATION' B-TIER SUPPLIERS. -(DETAILS Kl10HN TO QUALITY-QTC, HITHHELD TO MAINTAIN CaliFIDEllT
' GENERAL
+
IALITY). CONSTRUCTION DEPT CONCERN.
UllIT 1 & 2.
CI HAS NO ADDITIONAL INFORMATION.
. THE AMOUNT OF PROCEDURES AND PAPERHO K-FORM RK HAVE BECOME.THE PRIMARY PRINCIPLE OF C0llCERN AT SEQUDYAH AND NOT THE-OUALITY OF THE HORK.
THE ATTITUDE 0 F MAtlY PEOPLE IS TilAT IF QA APPROVES IT, THEN THAT IS GOOD ENOUGH.
I TH EREFORE CONCLUDE THAT THE SAFE OPERA.
TOR OF THE PLANT IS OVERSHAD0HED BY THE AMOUNT OF PROCEDURES AND.PAPERHO RK TO BE DONE.
5-1 QA 80101 N NPS YYYY SS THE PROCUREMENT'0F NUCLEAR PLANT:SAF K-FORM ETY RELATED MATERIAL,-COMPONENTS, DE.
VICES, EQUIPMENT, SYSTEMS, ETC. BY T-HE POWER STORES /llUCLEAR. PLANT PDHER-OPERATI0tlS PROCESS-(NQAM,PART III, S ECTION 2.1) DOES NOT ASSURE THAT APP LICABLE REGULATORY REQUIREMENTS, DES IGil BASES, QUALIFICATIONS AND OTHER REQUIREMENTS ARE BEING MET.
86-n04-002 QA 80101 N NPS Y.Y Y Y SS TVA flUCLEAR PLANTS (GENERIC) ARE IGN NONC0liFORMAllCE E0259 K-FORM ORING THE QC PROGRAM FROM THE NUCLEA-QA PROGRAM R P0HER.0FFICE CHQAM). THE PLANTS H QUALITY RITE THEIR OHit PROGRAMS, AND DO NOT-GENERAL FOLLOH INSTRUCTI0tlS FROM THE HQAM.
Il0 FURTHER INFORMATI0ll AVAILABLE:IN FILE. Att0HYMOUS C0tlCERN. 110 FOLLOH
-UP REQUIRED.
g,52 '
g ar
~(:
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l.
A
PACE 2 ef 2 LREHCE
- ECPS120J-ECPS121C TEllllESSEE VALLEY AUTit0RITY FAGE 4 --
(UEllCY
- REQl'EST OFFICE OF flUCLEAR P0HER Ruti TIME - 15:48:25
- ISSS - 2HM EMPLOYEE CollCERil PROGRAM SYSTEM (ECPS)
RUll DATE - 10/16/86 LIST OF EMPLOYEE CollCERil IllFORMATI0tl CURY: QA QA/QC PROGRAMS SUBCATEGGRY: 80101 QUALITY ASSURAtlCE PROGRAM ADEQUACY S
GENERIC KEYNORD A H
APPL QTC/flSRS P
KEYHORD B
- OilCERil SUB R PLT BBSH IllVESTIGATI0li S
CollCERil KEYl10RD C huMBER CAT CAT D L OC FLQB REPORT R
DESCRIPTI0tl KEYHORD D
.!;-086-002 03 3 0 LCL-4-H&!!
YYYY NS TVA IS PROPOSENC TO OCCCUTRALIZE INC 10e.
150252 po i o 7L K-FORM QUALITY AUDIT PROGRAM llITHOUT PRIOR ROGRAM APPROVAL OF THE ilRC.
THIS I QUALITY LATI0tl 0F 10 CFR 50.54 HD-TH SAFET GEllERAL Y AllALYSIS REP CLEAR P0HER CO THER INFORMATI0!! Ill FI 3 0 ^ 0 - 0 0E--9 A--8 0101 N HBN YYYY NS DECCNTRAt-fi"ATION OF TiiC GFFICE GF QU QA FROG W 120252 gono 2.
K-FORM ALITY ASSURAllCE AGGRAVATES AN ALREAD IZATI0li Y MARGIllAL TREATMEllT OF C0tlFIGURATIO QUALITY ll MAllAGEMEllT.
TVA LIllE MAtlAGEMEt GEllERAL AS 110 CONCEPT OF THIS FUllCT
, AllD DOES HOT IllTERRELATE 1H UIREMEllT S OF 10 CFR 50, APLEND X B, CRITERIA III, IV, VI MD"VII. IlVCLEAR Poller
/
DEPARTMM W OHCERil.
HD FURTHER IllF ORMAEctf Ita FILE. CI REQUESTS THIS
- COR ERN TO DE IllVESTIGATED BY QTC.
c3-116-008 QA 80101 il SQti YYYY SS DIVISI0tl 0F QUALITY ASSURANCE MANAGE AUDIT I50271 K-FORM MEllT PRESSURES AUDITORS TO CLOSE AUD CORRECTIVE ACTI0tt IT DEVIATIDHS (SEQUDYAH) BEFORE THE QUALITY AUDITOR IS SATISFIED THAT ADEQUATE C GENERAL ORRECTIVE ACTI0tl, AS STATED Ill APPEll DIX B AllD THE QA MAllUAL, HAS BEEH IM PL Et1ENT ED.
DETAILS Kil0 Hit TO QTC, HI THHELD DUE TO CollFIDENTI ALITY. Il0 F URTHER IllFORMATI0tt MAY BE RELEASED.
CI REQUESTS THAT QTC PERFORM THIS I tiVESTIGATION. IlUCLEAR P0HER DEPARTH EllT C0tlCERN.
"rH /, 011 OA
- ^'^'
({0102) SQN S
YYYY SS SEQUDYAtt - f4S Ha nFMFUT T YHnpH) PnMPI A HnHrnHFnDMaHPF _
50271 QA K-FORM IllED TO THE DIRECTOR OF THE DIVI 1
AUDIT OF QA ABOUT AUDITS HHICH HER 0 Ill QUALITY
-DEPTH.
Tile DIRECTOR OF QA-fSSUED A REPORTS LETTER 11-25-85 TO AUQl @ RS DIRECTI flG THEM TO IllCREASE,,,TtlE ilUMDER OF AU DIT AREAS PER AU I-T, THUS EFFECTIVEL Y RESTRICTIll E DEPTH OF THE AUDIT S.
IlUCL E -
OHER CollCERH. 110 ADDIT 1011AL ORMATIO!1 AVAILABLE. CI REQ 6
]
j(*gg; r UE TilAT QTC PERFORM THIS IllVESTIG nH.
.,,it C0!!CERHS FOR CATEGORY QA SUBCATEGORY 80101 i
\\.y
.