ML20205A161
| ML20205A161 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 03/16/1987 |
| From: | Russell Gibbs, Martin M, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082280289 | List: |
| References | |
| 80102-SQN, 80102-SQN-R04, 80102-SQN-R4, NUDOCS 8703270390 | |
| Download: ML20205A161 (13) | |
Text
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6; -g TVA EMPLOYEE CONCERNS REPORT NUMBER:
^ -s SPECIAL PROGRAM 80102-SQN REVISION NUMBER:
REPORT TYPE s
4 Element Report PAGE 1 0F 10 TITLE:
quality Assurance Independence and Authority A
REASON FOR REVISION:
Revised to incorporate NRG comments.
Revision indicators are shown _on each page to indicate revision changes.
Notes Sequoyah Applicability Only PREPARATION PREPARED BY JOHN J. DEANGELIS 3Iulgr Q-- - __._0:
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,GNATuar, REVIEWS PEER:
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'DAfE 9 I SIGNATURE CONCURRENCES r
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SIGNATURE
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SIGNATURE DATE
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APPROVED BYI men.s ennA-slarle1 ECSP HANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Serotary's Slgnature denotes SRP concurrence are in flies.
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4..-
t REPORT NUMBER:
REPORT TYPE:
30102-SQN REVISION NUMBER:
Element Report TITLE:
A
. Quality Assurance Independence and Authority PAGE 2 0F 10
'1.0 CHARACTER 13ATION OF ISSUES
- " ~;L ^,- 1.1 1 Introduction
Independence and Authority.
These concerns were grouped into the Yi fd'f hv.-
following two issues to aid the Quality Assurance Category Evaluation e
$.yyK.,x c " -
Group (QACEG) investigation at the Sequaysh Nuclear Plant (SQN):
'y yr a.
The QA organisational structure as it relates to the independence
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of QA personnel.
1 b.
The lack of depth of QA audits.
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Section 6.0, Attachment A, provides a listing of Employee Concerns identified within this Element Report.
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1.2 Description of Issue n
M:
1.2.1' The QA ormanisational structure as it relates to the Q*cM indeoendence of QA personnel (IN-I l6 - 01,7-002. W5M-84i-004-001.
2
' /lpn PH-85-056-102.
WI-8!'-040-001.
WI-l5 - 01 16-001.
WI-8D-086-004.
a:
XX ' 8-00 XX-8!i.
,9-001.
XX-1 l5-1.,3-001.
WI-8!i-090-002.
WI-85-Ul 66-003 and 15-81-767-005).
1
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The Employee Concerns relate to the organisational structure of the QA Department.
These concerne state that because the QA Site Staff reports functionally to plant management, this
~
'~
reporting relationship would lessen the effectiveness of QA as an independent reviewer.
Also several-Concerned Individuals (CIs) criticised TVA's decision to "Decentralise" the QA audit
~.
i Branch' since they considered this condition would violate regulatory requirements and the TVA approved QA Program.
1.2.2 The lack of depth of QA Audits (XX-85-116-011).
This issue was stated by the CI that SQN Management complained to the Director of QA that audits were too indepth.
The C1 also stated that the Director of QA issued a letter ~ dated November 11, 1985 to the Auditors directing them to increase the number of audit areas per audit.
The CI assumed this directive would restrict the auditors Indepth approach into the activities of the audited organisation.
2.0
SUMMARY
2.1 Summary of Evaluation Process 2.1.1 The evaluation process consisted of the review of Imployee Concern files, Quality Technology company (qtc) and Nuclear
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REPORT NUMBER:
REPORT TYPE:
80102-SQN Element Report:
REVISION NUMBER:
TITLE:
4 Quality Assurance Independence and Authority PAGE 3 0F 10 4
Safety Review Staff (NSRS)
- reports, Federal Regulatory f'
Requirements, TVA Topical Report and the Nuclear Quality Assurance Manual (HQAM).
The review process also included discussions with cognizant personnel in the QA department.
2.1.2 The evaluation process also included the review of the audit files and TVA procedures to provide additional information to s
assist in the evaluation of this issue.
2.2 Summary of Findings
2.2.1 Issue
The QA organizational structure as it relates to the j
independence to QA personnel.
The results of the QACEG investigation pertaining to the organizational structure as it relates to the independence of QA personnel indicate this was not a valid issue.
The reorganization of the QA Department in early 1984 met the requirements of Appendix B to 10 CFR 50, criterion I.
In addition, this reorganizational structure was identified in TVA Topical Report, TVA-TR75-1A, revision 8, and was approved by the Nuclear Regulatory Commission (NRC) on October 12, 1984.
The acceptance of this document shows NRC approval of the organizational structure including the intent of QA independence and organizational freedom.
2.2.2 Issue The lack of depth of QA audits The results of the QACEG investigation indicates this issue was not valid.
Contrary to the Concerned Individual reference to a
November 25, 1985 letter being issued by the Director of QA, the QACEC investigation could produce no evidence of such a letter.
The QACEG investigation
- did, however, find a
memorandum from the Director of QA to Branch Managers, dated October 24, 1984, which addressed audits and comments by various site and plant representatives.
The investigation found where audit modules were combined to make audits more comprehensive, and where possible, audit team members were reduced because at the consolidation of audit module 9.
2.3 corrective Action Since the two innues identified in Section 1.1 of this Elemont Report were not valid, no corrective action is required.
r REPORT NUMBER:
REPORT TYPE:
80102-SQN Element Reports REVISION NUMBER:
TITLE:
4 Quality Assurance Independence and Authority PAGE 4 0F 10 l
3.0 EVALUATORS D. G. Barlow J. J. DeAngelis l-l=
4.0 EVALUATION PROCESS 4.1 Ceneral Methods of Evaluation The evaluation process consisted of researching the Employee Concern
- Files, QTC Files, and NSRS Files to determine if additional information was available to assist in the investigation of this
(
element.
Reviews were conducted of Regulatory Requirements and Industry Standards together with upper tier documents, such as, TVA Topical Report and the NQAM, and lower tier documents, such as, procedures and instructions to determine requiremente, commitments and responsibilities.
QA Auditing Branch Correspondence Files, the QA l
Audit Scheduies and the QA Audit Status Log were reviewed to determine audit activicies during the time period 1983 through 1985.
Discussions were held with the former Director of QA, the Branch Chief of the Audit Group and the Audit Group Section Supervisor to acquire additional details pertaining to the Audit Group organizational structure and auditor's independence.
4.2 Specifics of Evaluation l
l This section describes the specific methodology used in the l
Investigation ot the following issuest 4.2.1 Issue The QA organizational structure as it relates to the independence of QA personnel.
a.
The Employee Concern Files and the Confidential Files were researched to determine if QTC or NSRS had investigated l
and issued a report on this issue.
QACEG's review of the files indicated NSRS Reports 1-85-420-WBN, dated November 19, 1985 and 1-85-805-NPS dated November 18, 1985 were issued and addressed the independence of the QA Department.
HSRS
- Report, 1-85-420-WBN, was issued specifically for Watts Bar Nuclear Plant (WBN); however, the Employeo Concern Task Group (ECTG) has determined this issue to be generically applicable to SQN.
NSRS Report 1-85-805-NPS is not attached to this report, as the data 4
contained within this report is basically historical data that is included in the evaluation of this issue by QACEG.
The results of the NSRS Report was determined to be
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' REPORT TYPE:
80102-SQN
-l Element Reports.
REVISION NUMBER:
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4 i
Quality Assurance Independence and Authority PAGE 5 0F 10 I
3 4
unsubstantiated based on.the reasons given by the CI for the decentralization of the QA functions.
It was further r
stated that the. decentralization was just another
[-
reorganization under the newly. formed owner-operator j '
concept of TVA's plant management..
The NSRS Report. was t
reviewed by QACEG, but adds no further information to the l
QACEG Element Report.
b.
Reviewed the requirements of Appendix B to 10 CFR 50, f
Criterion 1; TVA Topical Report, TVA-TR75-1A, revision 8; f
and the
- NQAM, Part III to determine the approved organizational, structure, the authority of. QA personnel, and the scope and responsibility of the QA Auditing Branch during the time the issue was expressed.
c.
Reviewed the QA Auditing Branch Correspondence Files for additional information relating to decentralization of the auditing functions.
d.
Discussions were held with the former Director of QA, the Branch Chief of QA Audit Group and Section Supervisors to k
develop background information and other specific details relating to this issue.
4.2.2 Issue
The lack of depth of QA audits 4
The Employee Concern Files and the Confidential Files were a.
researched to determine if QTC or NSRS had investigated and issued a report on this issue.
These files contained
)
no further information.
b.
Reviewed the QA Auditing Branch Correspondence Files, QA I
Audit Report Files and the QA Audit Schedule for 1983 through 1985 for additional information relating to this issue.
3 i
c.
Discussions were held with the former Director of QA, the Branch Chief of QA Audit Group and Section Supervisors to develop background information and other specific details relating to this issue.
5.0 FINDINGS I
I The following findings addrons both a background discussion and a conclusion of each issue identifled in Section 1.2 of the Element Report.
i
5.1 Issue
The QA organizational structure as it relaten to the independence to QA personnel.
y REPORT NUMBER:
- REPORT TYPE:
80102-SQN Element _ Report:
REVISION NUMBER:
TITLE:
4 Quality Assurance Independence and Authority PAGE 6 0F 10 P"
'5.1.1
Background
S This background information is provided to discuss the history of the reporting relationship of the QA Department and the Operation Site Director of SQN during the time 1984 through 1986.
In February 1984, the Power Operations and the Engineering and-4 Construction-functions were merged into the newly formed organization called the Office of Power and Engineering.
Under the new organizational structure originating in 1984, TVA introduced the management philosophy of the Owner / Operator concept.
The Owner / Operator was to be fully responsible. for
~
the performance of those facilities which they operated. _This concept delegated to the operator the authority,
' responsibility and accountability for regulatory compliance, operationsestablish,nd engineering
- services, quality activities, a
costs.
Additionally, this concept was to a
" Decentralized" method of operations for each of TVA's nuclear
'p plants.
Furthermore, each nuclear plant would function I
autonomously by developing its own programs and systems to control plant activities.
These actions were TVA efforts to effectively interface various disciplines at each site to meet site-specific conditions.
The Topical Report, revision 8, was revised by'TVA to define the Owner / Operator concept, which included " Decentralization".
The Topical Report, which is TVA's highest tier program
}-
- document, was accepted by NRC in October 1984 as satisfactorily meeting the requirements of Appendix B to 10 CFR 50.
The revised report established the position of the k
Site Director who was responsible for the quality of work activities at licensed nuclear plants.
In addition, this report established the position of the Operations QA Hanager who maintained a Plant QA Staff at operating plants'to perform work functions relative to quality engineering, quality control and surveillance activities.
The Supervisor of Plant QA Staff received functional supervision from the Site Director, but reported administratively to the Operations QA Manager.
Note:
TVA's usage of the terms " functionally" and
" administrative 1y" are reversed in relation to their use by other organizations.
The QA Audit Branch under the new "Decentrallzed" structure for SQN was in the transition phase in December of 1985.
A i
memorandum from the Director of QA to "Those Listed", dated December 12, 1985, indicated that the decentralization of the
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REPORT TYPE:
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REVISION NUMBER:
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4 Quality Assurance Independence and Authority PAGE 7 0F 10 QA Auditing functions for operating plants had not been fully implemented at that time.
The results of this investigation indicated the Operations QA Audit Group's plans to decentralize never did materialize.
The program to decentralize the audit group ended during the reorganization of the QA Department in early 1986.
A number of CIs expressed their concern that organizational structure relative to the independence of QA personnel was a requirement violation.
The term " independence" as referenced in the Code of Federal Regulations 10 CFR 50, Appendix B, Criterion I,
requires that persons and organizations performing QA functions shall have sufficient independence from cost and schedules as opposed to safety considerations.
The acceptance of TVA's Topical' Report by the NRC in October 1984 as satisfactorily meeting the requirements of Appendix B to 10 CFR 50 endorses the approval of TVA's organizational structure, including the intent of QA independence and I
organizational freedom.
Since early
- 1986, TVA has been involved with the reorganization of the Nuclear QA functions (as well as other functions) under a
single or central department.
- The, responsibility for all Nucicar QA functions in the Office of' Nuclear Power, including Quality Assurance / Quality Control (QA/QC) activities relating to engineering, construction, and operations, has been consolidated under the Director or Nuclear QA.
TVA has developed a standarized Nuclear QA Program described in the revised Topcial Report, revision 9, and also the revised NQAM which includes QA/QC activities relating to plants under construction and plants holding an operating license.
These programmatic measures eliminate the
" owner / operator" and " decentralization" concepts.
This will allow TVA to attain a centralized responsibility for Nuclear QA/QC functions which will report to a high level of management in accordance with a standard program.
The revised l
Topical Report has been submitted to the NRC for their review and approval.
Final NRC approval of the Topical Report revision is still pending at the writing of this Element Report.
5.1.2 Conclusion Based on the above evidence, this issue is not valid.
TVA's decision to decentralize the QA Department was part of an overall program to decentralize all activities including QA.
This plan was approved by TVA's Board of Directors and NRC in October 1984.
NRC approval of the TVA revised organizational structure also endorses the " independence" as described in g
Appendix B to 10 CFR 50, Criterion I.
Presently, TVA's L
l
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4 Quality Assurance Independence and Authority PAGE 8 0F 10 nuclear QA/QC functions have been unified under a single department with a consistent nuclear QA program and procedures for all TVA nuclear sites.
This plan is described in TVA's revised Corporate Nuclear Performance Plan dated March 1986.
5.2 Issue : The lack of depth of QA audits 5.2.1
Background
In this concern, the CI states that the Director of QA issued a letter (November 25, 1985) to auditors to increase the number
'o f audit areas per audit, which the CI felt would restrict the depth of audits.
Having reviewed the Correspondence Logs, RIMS and individuals' personnel files, QACEG could not locate this letter.
Af ter a discussion with the former Director of QA we directed our attention to 1924 rather than 1985 since the subject of audit frequency, numbers of auditors on site, and organizations performing audits was a concern to Site Directors and managers in 1984.
We did locate an " ADMINISTRATIVELY CONFIDENTIAL" memo from the Director of QA to Branch Managers dated October 24,
- 1984, which did address (among other topics) audits and comments made to the Director of QA by various site and plant representatives on his visits to WBN, SQN and Browns Ferry (BFNJ during the week of October 14, 1984.
This memo stated under
" Watts Bar" that '" twenty-four audits a
year is considered by the plant and site stafts to be more than necessary.
They would like to see this reduced by a factor of about 2."
Under the comments for "Sequoyah", Site and Plant Managers made the comment that -- " Auditors need to be sure when they do or do not have a finding and, when possible, the number of audit team members should be reduced."
On August 7,
- 1984, the Nuclear Central Office Industrial Engineering Section issued a report, " Audit and Inspection Analysis",
regarding the frequency and duration of those audits and inspections conducted during fiscal year 1983 at SQN and BFN.
The August 22, 1984 Memorandum from The Director of QA to "Those Listed" replied to that analysis and stated the direction he had given to the Division of Quality Assurance Audit Group Heads was to:
A.
Be very sensitive to and dedicated to eliminating any unnecessary adverse impact on audited organizations, B.
Work closely with the staff and management at each location in aggressively pursuing, planning and scheduling practices that will provide for both an effective audit
' REPORT' NUMBER:
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4 Quality' Assurance Independence and Authority PAGE 9 0F 10-program and' minimize unncessary adverse impact on the orgainzations.
The Director.of QA went on to' state that the audit group was required by the Technical-Specification (Tech. Spec) requirements to perform a given number of audits,(modules) and that he agreed that a smaller number. of' audits would lessen the' impact at the plants but-could still be accomplished effectively.
"By November 30, 1984, we will.have a plan which reduces the number of times audit teams appear at a given location..
This will be accomplished by. combining standard-audit modules into - a given audit."
He further stated..."We will strive to work more efficiently and conduct.- fewer but more comprehensive audits this year while still very-effectively addressing 'the scopes defined by our' audit modules."
An indepth' review of Audit Status Logs (Sequoyah) for the Fiscal years 1983, 1984,~and 1985 was made along with a review of actual ' audits. performed during those years, _ (total of 42 '
audits) to determine' length of. time onsite, number of audit modules addressed, depth of audits and number-of audit personnel-involved in each audit.
Contrary to the CI's concern, we found that 'the audit function was not restricted in ~ Fiscal year 1985 (the period following the. direction - to consolidate where possible).
Our review of the number of audit modules indicated they did-not decrease, however, eight audits ' covered two or more modules, which was an improvement over-1983 and 1984 where only single. audit modules were performed.
This condition indicates that the required audit areas in 1985 did not change; however, the number of audits performed at SQN did dccrease by three audits.
We also found in our review or the individual audits that depth of coverage and numbers of audit personnel were in no way reduced which i:
would restrict the depth, as the CI stated.
5.2.2 conclusion Based on the above evidence, the -employee concern is not valid.
We can only assume that the CI was incorrect in stating that -the Director of QA issued a letter dated November 25, 1985 and that he is referring to the L
" ADMINISTRATIVELY CONFIDENTIAL" memo dated October 24, 1984.
I Based on our investigation using the above document as a basis to identify any impact that memo had on the audit function and l
the actions taken by the Quality Audit Branch to reduce the l
number of audit
- areas, we find the concern to be unsubstantiated.
L
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80102-SQN Element Report:
REVISION NUMBER:
TITLE:
4 Quality Assurance Independence and Authority PAGE 10 0F 10 5.3 ' Attachment A identified the concerns as being potentially either Safety-Related or Safety-Significant.
Since the two issues of this report were unsubstantiated, the concerns are not considered to have an impact on safety.
6.0 ATTACRMENTS A.
List of Employee Concern Information Subcategory:
80102 Quality Assurance Independence and Authority.
B.
Nuclear Safety Review Staff (NSRS) Investigation Report fI-85-420-WBN, dated 11/18/85.
C.
List of References And Documents Reviewed.
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