ML20205A368
| ML20205A368 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 06/06/1986 |
| From: | Engelhardt J, Huth T, Lagergren W TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082280289 | List: |
| References | |
| 0559T, 559T, NUDOCS 8703270422 | |
| Download: ML20205A368 (9) | |
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ATTACF21ENT C Rzvision 1
- j TENNESSEE VALLEY AUTHORITY l
SEQUOYJJH NUCLEAR PLANT GENERIC CONCERN TASK FORCE GCTF Employee Concern Number:
IN-86-095-001 PH-85-056-001 IN-85-688-002 PH-85-056-X02 IN-85-767-001 PH-85-018-X02 IN-85-767-005 VI-85-086-001 IN-86-087-002 WI-85-086-003 XX-85-102-010 WI-85-086-004 XX-85-069-009 WI-85-090-001 XX-85-113-002 WI-85-090-002 XX-85-113-003 WBN-6-004-001 XX-85-019-X02 WBN-6-004-002
Subject:
Quality Assurance Concerns Date of Investigation: June 6, 1986 Investigator:
LfrC. b, b J. E. Efigelhardt Date Revieued By:
C i
j Date GCTF Hember W_
G-6-3L Approved By:
g W. R. Lagergren Date Yb5
. W' HRG Hember Date t
WBECTG Date 0 5 5 "
' B703270422 870319 PDR ADOCK 05000327 P
Revision 1 I. Background An investigation was conducted at Sequoyah (SQN) to determine th..
validity of expressed concerns,as received by Quality Technology Company (QTC) Employee Response Team (ERT). The concerns were determined to be generic for Seguoyah by other TVA nuclear plant sites.
The concerns of record, as summarized on the Employee Concern Assignment Request Forms from QTC identified as IN-85-767-001, IN-85-767-005, XX-85-113-002, XX-85-113-003, IN-86-095-001, IN-85-688-002, XX-85-069-009, XX-85-102-010 PH-85-018-X02, XX-85-018-X02, IN-86-087-002, PH-85-056-001, PH-85-056-X02, WI-85-086-001, WI-85-086-003, WI-85-086-004, WI-85-090-001, WI-85-090-002, WBM-6-004-001, and WBM-6-004-002 stated respectively:
A.
TVA's top management and line management is ignorant of Quality Assurance Department's functions and importance.
Hanagement is interested in meeting cost and schedules.
B.
TVA management's lack of knowledge in selecting qualified Quality Assurance (QA) programs and ineffective implementation which resulted in abolition of QA Department in August / September 85.
C.
Bellefonte:
TVA corporate management is in the process of decentralizing the Quality Audit Program in an effort to reduce the audit programs impact on the startup and operation of the nuclear plants and also to intimidate auditor personnel thus significantly reducing the effectiveness of TVA's Quality Verification Program.
D.
Browns Ferry:
TVA corporate manecement is in the process of decentralizing the Quality Audit Program in an effort to reduce the cudit programs impact on the startup and operation of the nuclear plants and also to intimidate auditor personnel thus significantly reducing the ofrectiveness of TVA's Quality Verification Program.
E.
Th< Concerned Individual (CI) is concerned that if the NRC allows TVA to decentralize control over the Nuclear Quality Assurance Manual NQAM, then each individual nuclear site will implement changes to the separate QA programs causing a lack of consistency between the different sites.
F.
TVA management (department known) hesitant or refuses to process deficiency reports or corrective action requests concerning inadequate TVA procedures, unless the inadequacy is based on a higher-tier TVA procedure, which itself may be inadequate.
G.
Bellefonte:
Very often, rejected items are accepted by someone other than a supervisor or a higher level (grade). To illustrate the point, the CI stated that the supervisor will send another examiner / inspector with less qualification and experience to re-excmine the once rejected items and will get acceptance.
Page 1 of 7
Ecvision 1 I. Background (continued) e f'
H.
Browns Ferry: The Quality Program at Browns Ferry Limits the proper documentation and, repair of defects.
If inspectors observe defects in equipment, which they were not authorized to inspect, they are not allowed to document the deficiency in a programmatic way which assures documented inspection and repair.
I.
QC/QA Audit Program at WBN does not have the organizational freedom to effectively identify problems and to compe) effective corrective action.
J.
QC/QA Audit Program at Bellefonte Nuclear Plant does not have the organizational freedom to' identify problems and to compel effective corrective actions.
K.
TVA QA Department is not sufficiently independent of plant management (known) to perform assigned functions in a proper manner. QA Department Management does as directed by plant management. WBN Management creates and supports negative employee attitudes regarding subject QA departmental functions, which is not good for the plant.
L.
The decision to decentralize the Quality Assurance Audit Branch is the result of retaliation from those within TVA Hanagement who do not wish to hear about site / system discrepancies.
This decision
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violates the TVA commitment to the NRC for stronger corporate f
management.
H.
The decision to decentralize the Quality Assurance Audit Branch is the result of retaliation from those within TVA Hanagement who do not wish to hear about site / system discrepancies. This decision violates the TVA commitment to the NRC for stronger corporate management.
N.
TVA corporate management is in the process of decentralizing the Quality Audit Program, in an effort to reduce the Audit Programs impact on the startup and operation of the nuclear plants, also to intimidate auditor personnel, thus significantly reducing the effectiveness of TVA's Quality Verification Program.
O.
TVA is proposing to decentralize the Quality Audit Program without prior approval of the NRC. This is a violation of 10 CFR 50.54 and the Safety Analysis Report.
P.
The CI stated that the proposed decentralization of the Quality Audit Program is an attempt by upper management to reduce the of f ectiveness of the internal audit process and an eff ort to reduce the morale, security, freedom, and offectiveness of the audit personnel.
Page 2 of 7
Revision 1 I. Background (continued)
Q.
The objective, and result of, the dissolution of the Office of Quality Assurance was to, concentrate the QA function under line management. The site QA manager will report to the site director rather than to a central QA director. This destroys the independence of the QA and audit functions, as there is not independence from line management.
R.
Decentralization of the Office of Quality Assurance aggravates an already n.arginal treatment of configuration management. TVA Line Management has no concept of this function, and does not interrelate the requirements of 10 CFR 50, Appendix B, Criteria III, IV, VI and VII.
S.
TVA Nuclear Plants (generic) have their QC personnel reporting to, and receiving orders from, the Nuclear Plant Management via the Nuclear Power Manager. Office. This effectively strangles TVA QC as an independent reviewer.
T.
TVA Nuclear Plants (generic) are ignoring the QC Program from the Nuclear Power Office (NQAM). The plants write their own programs, and do not follow instructions from the NQAM.
No further information was requested from the ERT follow-up group.
[
II. Scope A.
The scope of this investigation was determined from these concerns to be six specific issues:
1.
Top management and line management are ignorant of QA functions which lead to the abolishing of OQA.
2.
Decentralization of Division of Quality" Assurance (DQA) and the Nuclear Quality Assurance Nanual (NQAM) will reduce the audit program effectiveness and lead to a lack of consistency between sites QA programs.
3.
QA site management is hesitant or refuses to process deficiency reports or corrective actions requests.
4.
Items rejected by Quality Control Inspectors are sometimes accepted by other inspectors without any corrections being made.
5.
The Quality Program limits quality control inspectors from properly documenting and having defects repaired.
Page 3 of 7
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.Ravision 1-
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II. Scope (continued) 6.
The QA/QC audit program does nct have organizational freedom to identify problemt and have them corrected and the plant i
supports negative attitudes towards QA.
7.
NQAM requirements are being ignored with the plants writing their own programs.
B.
To accomplish-the investigation. Site Quality Assurance Managers, Quality Assurance and plant personnel were interviewed. Various plant procedures and NSRS reports were reviewed.
Issue 1 was addressed by the Division of Quality Assurance Director.
III. Summary of Findings Issue 2 and 4 are addressed in NSRS Reports I-85-805-NPS (Reference 2) and I-85-738-SQN-(Reference 4) respectively.
Intervious were conducted with ten craftworkers in the maintenance and modifications sections to determine if the management supports negative attitudes toward Quality Assurance. The craft workers all agreed that the plant management would not tolerate any negative attitudes toward Quality Assurance.
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b Fifteen QC inspectors were interviewed to determine:
(1) Does the QA programs limit proper documentation and repair of defects?
4 (2) Are rejected items accepted by lower qualified personnel?
(3) Does management refuse to process deficiencies?
(4)
Does QC/QA have enough organizational freedom to correct defects?
1 Twenty percent of the inspe'etors, though the first three questions were 3
tree.
Twenty-seven percent of the inspectors thought the fourth guest ion-was true. The reason for the positive answers in questions one and three is due to QC observation log. This log is for QC inspectors i
to write down any possible problems observed while they are in the field. The log is then reviewed by the shift supervisor, who determines what type of corrective action needs to be taken. In the past, some items were never addressed for possible corrective actions. This is what led to the positive answers in guestions one and three.
Seguoyah QA department does not have a section procedure for the use of this log.
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Page 4 of 7
,.1 Revisien 1 i
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III. Summary of Findings'(Continued)
The positive answers given in question two were due to the lack of explanation given to the QC 1 spectors of why their rejections were 3
later accepted by other inspectors.
In no case was this due to'the person being of lower qualifications. The positive answers to question four'were due to a feeling that the inspectors had and not due to any
-concrete evidence. The 15 QC inspectors interviewed did not have a problem with the management processing Corrective actions, other than the problems identified in the observations log.
Nine Quality Assurance Engineers and Quality Surveillance personne1'were interviewed to determine:
1.
.Has management refused to process corrective action reports?
2.
Does-QA/QC have enough organizational freedom to correct defects.
All the personnel answered that they did not have a problem with managers processing corrective actions or the organizational freedom of QA.
NSRS Report I-85-420-WBN (Reference 3) gives further information on QA independence and plant attitude. Sequoyah Corrective Action Report SQ-85-03-004 (Reference 5) deals with the plants slow implementation of e-NQAH cnd Area Plan upper-tier requirements (within 90 days) in violation h
of Sequoyah Procedure SQA138. This corrective action report was escalated to the Director of Quality Assurance due to the plants request:
for two extensions of the deadline to correct the implementation problems.
A memorandum from the Director of Quality Assurance to the Site Director of Sequoyah (L20 860121 994) datri January 21, 1985.(Reference 8) affirms his belief that TVA top management are aware of and support the functions of Quality Assurance.
In 1982 the QA functions in TVA were centralized by creating the Office of Quality Assurance (0QA). The organization was made up of branches in the Office of Engineering (EN DES), Office of Construction (OC),
Operations QA, Systems' Engineering and Quality Improvement Staff.
In 1
1984,Ilugh Parris was made the Manager of Power and Engineering in TVA.
He decentralized the QA sections by transferring them back to their divisions. This only left the Systems and Improvement sections left'in OQA. In September 1985, OQA was desolved leaving the Quality Assurance functions to be done by the individual branches. The Division of Quality Assurance in Nucicar Power maintains the audit functions over the other branches.
V I.
i k
Page 5 of 7 L
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Rsvisien 1
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IV.
Conclusions Issue one on the elimination of OQA due to management ignorance was determined not to be valid by this investigation based on:
1.
The memorandum (Reference 8) from the Director of QA.
2.
The Office of Quality Assurance was decentralized to the individual divisions this still meets the 10 CFR 50 Appendix B Requirements for Quality Assurance.
Issue two on the decentralization of DQA is addressed in NSRS report I-85-805-NPS (Reference 2).
Issue three onsite management refusing to process deficiencies was determined not to be valid by this investigation based the interviews done in the site QA. Tiaeir was a problem in QC with the observation log due to a lack of procedure to control the log but all the individuals interviewed did not feel that the managers would not process corrective actions.
Issue four on rejected items accepted by other inspectors is addressed in site specific NSRS report I-85-738-SQN. The problems found during the QC inspector interviews were due to a lack of communication and not done intentially by QA managers.
/
Issue five on QA program limiting QC inspectors from properly documenting defects was determined to be valid based on the lack of procedure control of the QC observation log. Some observations were not evaluated to see if they needed to be corrected through the normal plant corrective action methods.
Issue six on the QA/QC program not having organizational freedom was determined not to be valid by this investigation based on the interviews done in the plant and QA.
Issue seven on NQAM requirements being ignored was determined to be valid based on the findings in CAR SQ-85-03-004 (Reference 5).
The validation was not based on the plant ignoring the NQAM but their inability to incorporated changes into plant procedures in the required 90 days.
o k
Page 6 of 7
P, Ret 131 m 'I
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"4 V.
Recommendations.
'1.-
Regular meetings should be held between the QA groups (QC inspectors, QA engineers, and quality surveillance personnel) both together as a section and seperate as individual groups to give thepersonnel a chance'to express any problems and to exchange information. Answers should be given back to individuals expressing the concerns, when the answers are found.
2.
The QC observation log should be proceduralized to assure that all problems entered are being adequately addressed and answers returned to the inspector. These problems should also be read in~
the section meetings.
3.
When a QC inspector rejects a holdpoint which is later accepted without rework, a meeting should be held with the inspector to explain why the holdpoint was accepted. If the inspector still does not agree, a path should.be made available to satisfy his concerns, such as a meeting with QC training personnel to get an independent opinion.
4.
Corrective action to CAR SQ-85-03-004 (Reference 5) should be completed as soon as possible to implement upper-tier requirements.
VI. References n
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1.
NSRS Report I-85-933-WBN dated December 18, 1985 2.
NSRS Report'I-85-805-Nps dated March 17, 1986 3.
NSRS' Report I-85-420-WBN dated November 18, 1985 1
4.
NSRS Report I-85-738-SQN dated February 18, 1986 5.
Corrective Action Report SQ-CAR-85-03-004 dated March 11, 1985 6.
Sequoyah Administrativo Instruction-12. Adverse Conditions and Corrective Actions, Revision 22 7.
Seg'uoyah Quality Assuiance Section Instruction Letter 16.1, Corrective Action and Adverse Conditions, Revision 15 8.
Memorandum from R. J. Mullin, Director of Quality Assurance, to H. L. Abercrombie, Site Director Sequoyah, dated January 21, 1985 (L20 860121 994)
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Y ATTACHMENT D i.
ECSP CORRECTIVE Action Tracking Document
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9e (CATD)
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INITIATION 1.
Immediate Corrective' Action Requiredt /_Y/ Yes /[/ No 2.
Stop Work Recommended: //
3.
CATD No.
80402-SQN Yes /X/. No 47 INITIATION DATE 10/6/86
- 5. '
RESPONSIBLE ORGANIZATION:
SQN-QA Staff 6.
PROBLEM DESCRIPTION:
/I,/ QR /[/ NQR concern XX-85-102-010 QA-SIL-18.1 Revision 11 (dated 3/24/86) does not reference (purpose / scope) the "QC Observation Loa" use.
This form was deleted in Revision 7. dated 3/30/83 but is still beinz utilized.
Section Letter describina the purpose and scope of the QC Observation Los has not been issued as stated in the QA Staff comments identified in Attachment C.
// ATTACHMENTS
-7.
PREPARED BYs NAME W. E. Bezanson DATEt 10/6/86 8.
CONCURRENCE: CEG-H R. K. Maxon DATE:
9.
APPROVAL:
ECTG PROGRAM MGR DATE:
CORRECTIVE ACTION
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10.
PROPOSED CORRECTIVE ACTION PLAN:
?
/ / ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGRt DATE!
12.
CONCURRENCE:
CEG-H' DATE:
SRPt DATE:
ECTG PROGRAM MGRt DATEt VERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLC DATE
'd 3y