ML20205A301
| ML20205A301 | |
| 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 | |
| 80402-SQN, 80402-SQN-R04, 80402-SQN-R4, NUDOCS 8703270412 | |
| Download: ML20205A301 (10) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80402-SQN f
REPORT TYPE REVISION NUMBER:
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Element Report 4
TITLE:
PAGE 1 0F 9 Management's Interference in Deviation Reporting REASON FOR REVISION:
Re-issued to incorporrte NRC comments; Note:
Sequoyah Applicability Only PREPARATION PREPARED BY:
W. E. Bezanson fM-0 N
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SIG URE DATE '
REVIEWS PEER:
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s0 SIGNAT'URE DATE
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. C TAS:%l 5//5/87 u
' SIGN'ATURE
/ DA7E CONCURRENCES CEG-H : $/lm gkz/fy SRP__
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SIGNATURE DATE S GNATURE*
DATE APPROVED BY:
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N/A ECSP MANAGER DATE MANAGER OF NUCLEAR DATE POWER 8703270412 870319 CONCURRENCE (FINAL PDR ADOCK 05000327 REPORT ONLY)
P PDR 4
- SRP Secretary's signature denotes SRP concurrences are in files.
REPORT NUMBER:
80402-SQN
.y
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REPORT TYPE REVISION NUMBER:
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Element Report 4
TITLE:
PAGE 2 0F 9 Management's Interference in Deviation Reporting 1.0 CHARACTERIZATION OF ISSUE 1.1 Introduction This report pertains to the Quality Assurance Category Evaluation Group's (QACEG) investigation of two (2) employee concerns which were identified by the TVA Employee Concerns Special Program.
These concerns were evaluated for Sequoyah Nuclear Plant (SQNP) because one concern was determined to be Sequoyah specific and the other concern was generically applicable.
1.2 Description of Issue The conditions reported by the concerned employees were:
a.
Supervision had stopped corrective action on an identified quality problem.
(SQM-86-002-004 dated January 24, 1986) b.
Inspectors were not allowed to document deficiencies in a programmatic way.
(XX-85-102-010 dated October 21, 1985) b,,,
These perceived conditions established the basic issue for the evaluation as:
" Management's Interference in Deviation Reporting".
2.0
SUMMARY
2.1 Summary of Characterization of Issue The issue derived from the employee concerns was:
Management's Interference in Deviation Reporting.
2.2 Summary of Evaluation Process 4
During the course of this evaluation, Appendix B to 10CFR50, the TVA Nuclear Quality Assurance Manual (NQAM), Sequoyah Standard Practice, Quality Assurance Section Instruction Letters (QA-SILs),
Quality Assurance Section Letters (QASLs), Division of Quality Assurance Instructions (DQAls), Office of Engineering Operation Instructions (OE-01s) and Engineering Of fice Administrative Instructions (Als), as listed in Paragraph 4.1, and various memorandums were reviewed to determine commitments and requirements as they applied to SQNP and this issue.
Also, the Employee Concern Files including the Confidential File were reviewed for any additional data pertaining to this issue.
That review identified two reports:
Nuclear Safety Review Staff (NSRS)
Report I-86-185-SQN, dated March 5, 1986 (Attachment B) and Generic
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REPORT NUMBER:
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80402-SQN REPORT TYPE REVISION NUMBER:
Element Report 4
TITLE:
PAGE 3 0F 9 Management's Interference in Deviation Reporting Concern Task Force (GCTF) Report dated January 27 and reissued on June 6,
1986 (Attachment C), had been issued for the same concerns.
Those reports were reviewed to determine the scope and results of their investigation.
In addition, the evaluation process included discussions with the Quality Engineering / Quality Control (QE/QC) Manager, Office Supervisor Document Control-Nuclear Engineering, Quality Assurance (QA) Manager-Quality Assurance Group, Assistant QA Supervisor and the investigators identified in the NSRS and GCTF Reports, regarding the reporting and documenting of deviations.
2.3 Summary of Findings QACEG's review of the NSRS and GCTF investigation reports indicated 4
that the issue was unsubstantiated.
The GCTF report indicated that observations (deviations) were, in fact, being documented in the QC Observation Log but that QC supervision had not initiated follow-up action on some of those deviations.
QACEG's investigation also did not reveal any instances where deviations were not properly documented as required by TVA directive r, and there was no evidence of the TVA Management interfering in deviation reporting.
Therefore, this issue is unsubstantiated.
2.4 Summary of Corrective Action This evaluation did not substantiate the subject issue.
Therefore corrective action for this issue is not required.
However, in the interest of tracking and closing the GCTF recommendations dealing with prograc:matic improvements, ECSP Corrective Action Tracking Document CATD No. 80402-SQN-01 (Attachment D) was issued.
The GCTF Report recommendation was for QC Supervision to review the QC Observation Log to assure all conditions entered are adequately addressed.
SQN QA Staff comments to that recommendation (dated January 28, 1986) stated a review had been accomplished and a Section Letter would be issued describing the use of the QC Observation Log.
QACEG's review of twenty-five (25) entries in the log (1985 through the beginning of 1986) indicated a review was performed by the QA Staff.
However, the QA Section Letter had not been issued.
Although part of the recommended-corrective action had been accomplished, the QACEG investigation also identified as a side issue that the site QA implementing instruction QA-SIL-18.1, Revision 7, dated March 1983 had deleted the requirement for the QC Observation Log.
However, the log was still being utilized to document potential deviations.
The usage of the QC Observation Log should be described by an instruction since the log provides for the documentation of deviations.
wIicb~[eNibbd age I)N%seB mora m date November 4,
1986
4 REPORT NUMBER:
80402-SQN
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REPORT TYPE REVISION NUMBER:
Element Report 4
TITLE:
PAGE 4 0F 9.
l Management's Interference in Deviation. Reporting corrective.~ action for CATD 80402-SQN-01.
That proposed action is identified in paragraph 5.2.
3.0 LIST OF EVALUATOR (S)
E E. Bezanson 4.0 EVAULATION PROCESS 4.1 General Methods of Evaluation
'The Employee Concern Files (including the Confidential File) were researched for additional-information pertaining to this ' issue.
The basic content of the files were K-forms, NSRS Investigation Report I-86-185-SQN, dated March 5, 1986, and GCTF Report, dated June 6, 1986, and various memoranda pertaining to the employee concerns.
[G v The following documents' were reviewed for requirements and commitments as they pertained to the issue and were applicable during the concerns time: frame:
i a.
Appendix B to 10CFR50, dated January 20, 1970 b.
Nuclear Quality Assurance Manual (NQAM), dated December 23, 1985 Sequoyah Standard Practice SQM-2 " Maintenance Management System",
c.
Revision 14, dated July 17, 1985 through Revision 20, dated September 11, 1986 i
d.
Quality Assurance Instruction Letter 16.1 " Corrective Action and Adverse Conditions" Revision 15, dated March 31, 1986 including
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previous revisions 14 and 13.
I e.
Quality Assurance Section Instruction Letter (QA-SIL) 18.1 l
" Surveys", Revision 11, dated, March 24, 1986 including previous
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revisions 10, 9, 8, 7, and 6.
j f.
Division of Quality AsJurance Instruction DQAI-502.
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" Surveillance Program" Revision 0,
dated August 30, 1985 and j
Revision 1, dated August 29, 1986.
g.
Office of Engineering - Operation Instructions i
0E-OI-3001, Drawing Originals - Checking Out and Checking h.
In, Revision 0 N
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OE-01-4001, Contract Administration - Handling of Vendor Drawings, Revision 0 3
REPORT NUMBER:
80402-SQN
(:.
REPORT TYPE REVISION NUMBER:
Element Report 4
TITLE:
PAGE 5 0F 9 Management's Interference in Deviation Reporting OE-01-4003, Prints and Microfilm - Routing Distribution, Revision 0 h.
Engineering Office Administrative Instruction (SQNP)
AI-08,
" Drawing and Reproduction", dated September 10, 1985 AI-12, " Adverse Conditions and Corrective Action", dated August 2, 1985 i.
QC Observation Log Sheets Discussions pertaining to the employee concerns were held with the NSRS and GCTF Investigators, Quality Engineering / Quality Control (QE/QC)
- Manager, Office Supervisor Document Control Nuclear Engineering, Quality Assurance (QA) Manager - Quality Assurance Group and Assistant QA Supervisor.
4.2 Specifics of Evaluation
-y The QACEG cvaluation indicated that the NSRS Investigator had f'
{N requested additional data from the Quality Technology Company (QTC) who performed the employee interview and documented the concern (SQM,-
86-002-004).
They clarified the concern the Supervisor denied a request by an employee (Documentation clerk on January 9, 1986) to pertorm a vendor drawing audit.
The QACEG evaluation of the Generic Concern Task Force (GCTF) report indicated it addressed six (6) issues.
Only one of those pertained
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to this issue.
As a result, the GCTF Report details were reviewed only as it pertained to concern XX-85-102-010.
The report also clarified the concern as:
" Inspectors were, in fact, documenting observations in the Quality Control (QC) Observation Log".
L The evaluation also included a review of the NQAM, Sequoyah Standard Practice SQM-2, QA Instruction Letter 16.1, QA Section Instruction Letter 18.1, Division of QA Instruction DQAI-502, Administrative Instruction (SQNP) AI-12 which specify requirements for reporting and documenting deviations.
Also, the site QA Orgar.ization implementing instruction QA-SIL-18.1 Revision 7, dated March 30, 1983 deleted the QC Observation Log, requirement, although the log was still in use during the time frame of this investigation.
In addition, the instruction also states:
"Upon completion of the survey the evaluator shall consult with his supervisor or designated personnel to determine the disposition of proposed findings (e.g. invalid, insignificant, or i
issue a Corrective Action Report (CAR) or Discrepancy Report (DR) i in accordance with AI-12)."
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1
i REPORT NUMBER:
80402-SQN
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REPORT TYPE REVISION NUMBER:
Eletrent Report 4
TITLE:
PAGE 6 0F 9 Management's Interference in Deviation Reporting 5.0 FINDINGS 5.1 Findings on Issue 5.1.1 Discussion A.
NSRS Report I-86-185-SQN, dated January 24, 1986 stated the concern was not substantiated.
It was determined that the basis of the concern was the Office Supervisor denied an employee request for overtime to perform an audit of vendor drawings.
Therefore, no corrective action was stopped.
The Office Supervisor clarified the term " audit" as used in this report was actually a
vendor drawing accountability review.
This review was not required by program, but was performed to determine actual vendor drawing status.
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The NSRS Report indicated that the Office Supervisor for the Sequoyah Nuclear Plant (SQN) Engineering Project was appointed to the management position in January 1985.
He stated that the administrative controls in effect at that time for TVA and vendor drawings were not fully adequate.
However, the first priorities for correction were placed on the TVA drawings and on several other critical matters affecting the SQN engineering design effort.
The vendor drawing / audits received a second priority by management.
a The NSRS Report also states:
"The Office Supervisor verified the employee's statement that an audit of vendor drawings was to have been performed at the conclusion of the TVA drawing audit.
The vendor drawing audit was postponed from October 1935 to January 1986 because staff was needed on other projects, but the audit was begun in January and had been in process for three weeks."
The NSRS verified the vendor drawing audit was being performed during the time of their investigation (February 1986).
The QACEG established that the concern was received on January 22, 1986 the same month the vendor drawing audit was initiated.
Therefore, QACEG concurs with the NSRS Report conclusion.
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B.
The GCTF report, dated June 6, 1986 conclusion, in part L
L was:
"QA program limiting QG Inspection from properly documenting defects was determined to be valid based on g
U lack of procedural control of the QC Observation Log.
I
REPORT NUMBER:
80402-SQN f'
REPORT TYPE REVISION NUMBER:
Element Report 4
TITLE:
PAGE 7 0F 9 Management's Interference in Deviation Reporting Some observations were not evaluated by QA Supervision to see if they needed to be corrected through the normal method.
However, deviations were being recorded in the QC Observation Log."
The Summary Section of the report also stated, that those individuals interviewed (15) did not feel this was an issue at Sequoyah.
The QACEG evaluation results did not agree with the GCTF conclusion as stated above.
QACEG found that the QC Inspectors were reporting (documenting) deviations in the QC Observation Log.
The actions taken by supervision on those deficiencies noted in the log is another issue and does not pertain to this issue.
QACEG's review of the NQAM and applicable site procedures indicated Management had specified an appropriate programmatic system for documenting deviations.
Excerpts from that programmatic system are provided below to support the QACEG conclusion:
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1.
"uclear Quality Assurance Manual (NQAM), Part III, Section 7.1, dated December 23, 1985
" Nonconforming
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Materials, Parts or Components", Paragraph 1.1 states:
"It shall be the responsbility of the plant site director to indoctrinate plant personnel in the need to be alert for any nonconformance.
The responsiblity must be shared by supervisors and those actually performing receipt inspection and plant maintenance activities."
2.
NQAM, Part III, Section 7.2, dated September 1, 1983
" Corrective Action",
paragraph titled
" Purpose" states:
"The purpose of this procedure is to provide measures which assure that conditions adverse to quality are identified and corrected."
3.
Sequoyah Nuclear Plant (SQNP)
AI-12
" Adverse Conditions and Corrective Action", dated August 8,
1985 paragraph 5.1 states:
"... plant personnel are responsible for promptly reporting any suspected abnormal plant condition adverse to quality."
"All plant personnel shall report any suspected abnormal plant condition adverse to quality in the
REPORT NUMBER:
80402-SQN
[~
REPORT. TYPE REVISION NUMBER:
Element Report 4
TITLE:
PAGE 8 0F 9 Management's Interference in Deviation Reporting performance of their regular work duties and shall take note of any need for corrective action in their regular review of operating
- logs, surveillance test results, material nonconforming reports," work requests (WR) and other similar reviews.
"Also, personnel may report such conditions verbally to their Section Supervisor, the Plant Operating Review Staff (PORS),
or the QA Organization."
" Supervisors are responsible for evaluating each reported Condition Adverse to Quality (CAQ) and initiating corrective action in a manner consistent with their importance to safety."
4.
Division of Quality Assurance Instruction - DQAI-502 Revision 0,
dated August 30, 1985 and Revision 1,
dated August 29, 1986 paragraph 6.4.1 states in part:
" CARS or DRs resulting from the surveillance findings shall be issued in accordance with the plant's implementing instruction."
5.
Quality Assurance Section Instruction Letter QA-SIL-18.1 Revisions 10 and 11 dated October 17, 1984 and March 24, 1986 " Surveys", paragraph 6.4.1 states in part:
"Upon completion of the surveillance, the evaluator shall consult with his supervisor or designated personnel to determine the disposition of proposed findings (e.g.,
declare the findings
- invalid, insignificant, or issue a CAR or DR in accordance with AI-12)".
This investigation also verified that the documents specified in the above management directives for reporting deviations were being utilized when specified.
5.1.2 conclusion As a result of this investigation which included discussions with individuals identified in the NSRS and GCTF reports and 1
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the review of those reports, the issue was not substantiated.
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This conclusion is based on the following facts:
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REPORT NUMBER:
80402-SQN
[,
REPORT TYPE REVISION NUMBER:
L Element Report 4
TITLE:
PAGE 9 OF 9 Management's Interference in Deviation Reporting A.
The NSRS report concluded that supervision was aware of the need to audit vendor drawings and only denied a request for overtime.
Corrective action on the vendor drawing problem was not stopped, but was rescheduled until higher priority items were accomplished.
The audit was initiated in the same month (January 1986) that the concern was received.
It is presently forty percent completed.
The QACEG investigation results substantiated the NSRS conclusions.
B.
It was verified by the QACEG investigation that Sequoyah personnel were required by applicable management directives (NQAM, procedures and instructions) to document deficiencies when noted.
The GCTF and QACEG investigation results indicated deviations were in fact being documented by the QC Surveillance Group in the QC Observation Log and other documents as directed by the applicable management directives.
However, as a side issue of the investigation it was identified that the site implementing instruction
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QA-SIL-18.1 no longer required the usage of the QC
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Observation Log, as a result a CATD (Attachment D) was issued.
5.2 Sequoyah Site Director's response to CATD 80402-SQN-01 (Attachment D) stated:
On October 11, 1986, the preparation of the draft Section Letter describing all aspects of the QC Observation was completed.
Presently, the draft is being reviewed and should be formally issued by November 28, 1986.
Attachment A,
identified the concerns as potentially Safety-Significant and Safety-Related.
However, since the concerns were unsubstantiated they would not be detrimental to the safe or reliable operation of the Sequoyah Nuclear Plant.
6.0 ATTAC1DfENTS A.
List of Employee Concern Information Subcategory 80402, dated October 16, 1986.
B.
Nuclear Safety Review Staff (NSRS) Report I-86-185-SQN, dated March 5, 1986.
C.
Generic Concern Task Force (GCTF) Report, dated June 6, 1986.
D.
ECSP Corrective Action Tracking Document (80402-SQN-01)
ll ATTACletEtiT A REFERENCE
- ECP3120J-ECPS121C TEll!1ESSEE VALL EY AUTHORITY PAGE 19 OFFICE OF flDCLEAR Poller Rut! TIME - 13:48 15-FREQUEllCY
- REQUEST EMPLOYEE CD:lCE8tl PROGRAH SYSTEM (ECPS) rut! DATE - 10/16/86 OllP - ISSS - Ru!1 LIST OF EMPLOYEE CollCERil INFOR!!ATION CATEGORY: QA QA/QC PROGRAMS SUBCATEGORY: 80402 REVIEll/DISPOSITIO!!IllG OF DEVI ATIoll REPORT. DOCMitT.
KEYHORD A S'
GEllERIC
.QTCniS.c P
KEYl10RD B H
APPL C0tlCERN SUB R PLT B B S 11 IllV E sil't" w8 S
CONCERN KEYll0RD C tiUMBER CAT CAT D LOC FLQB REPCf?
x DESCRIPTI0il KEYl10RD D SQM-86-002-004 QA 80402 11 SQti il 11 N 11 I-86-185-SQfi SS SPECIFIC SUPERVISI0tl STOPPED CORRECT ll0HC0HFORMAllCE TS0254 K-FORM IVE ACTIGH Oil A QUALITY PROBLEH THAT CORRECTIVE ACTI0tt flAD BEEll IDEllTIFIED N0tlTils EARLIER.
QUALITY (HAMES/ DETAILS Kil0 Hit TO QTC, HITHH FOREMAft EtD TO MAltliAlti CONFIDEllTIALITY.) Il 0 FURTHER IllFORMATI0tl MAY BE RELEASE D.
HUCLEAR Poller CollCERN. CI HAS 11s 0 FURTHER IllFCRHATION.^ 110 FOLLoll-UP REQUIRED.
XX 102-010 QA 80402 H BFH YYYY I-8 5-7 4 4-B Fil 11 5 Ex0HH'S FERRY: THE QUALITY PROGRAM A QA PRC6 DAM T50172 K-FORM T BRolni's FERRY LIMITS THE PROPER DO H0 llc 0!!FORMAtlCE CullE!!TATIOff AtlD REPAIR OF DEFECTS.
QUALITY IF IllSPECTORS OBSERVE DEFECTS IN EQU GEllERAL IPMENT HHICH THEY llERE HOT AUTHORIZE D TO INSPEQT, TilEY ARE 110T ALLollED T O DOCUMElli THE DEFICIENCY IN A PROGR AHMATIC'llAY llHICH ASSURES DOCUMEllTED IllSPECTI0tl AND REPAIR. IlVCLEAR P061 ER CollCERN. CI HAS 110 ADDITI0tIAL In FORHATICH. Il0 FOLL0ll UP, REQUIRED.
2 CONCERHS FOR CATEGORY QA SUBCATEGORY 80402
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