ML20207K486
| ML20207K486 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/12/1986 |
| From: | Halverson R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K384 | List: |
| References | |
| 80401-SQN, 80401-SQN-R02, 80401-SQN-R2, NUDOCS 8701090431 | |
| Download: ML20207K486 (7) | |
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
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SPECIAL PROGRAM 80401-SQN f, m _
zm_ REPORT-TYPE.
REVISION NUMBER:
Element Report 2
TITLE:
PAGE 1 0F 4
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Nonconformance Reporting I
REASON FOR REVISION:
To incorporate com:nents by SRP.
F.
Revisions are denoted in right margins.
1 Note:
Sequoyah Applicability Only
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PREPARATION PREPARED BY:
R. D. Halverson M=
M SIGNATURE
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REVIEWS PEER:
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7 DATE SIGNATURE TAS:
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SIGNATURE DATE CONCURRENCES
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SRP :, EM 2-/2"85 SIGNATURE DATE GNATURE*
DATE APPROVED B MUL&A it-is s rJA ECSP ' MAq$3ER DATE MANAGER OF NUCLEAR DATE POWER 0
CONCURRENCE (FINAL f
REPORT ONLY)
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- SRP Secretary's signature denotes SRP concurrences are in files.
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- r7, TVA EMPLOYEE CONCERNS REPORT NUMBER
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SPECIAL PROGRAM 80401-SQN s-h w REPORT-TYPE-REVISION NUMBER:
E Element Report.
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PAGE 2 OF 4 Nonconformance Reporting
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_ - 1.0 CHARACTERIZATION OF ISSUE
.l.l_ Introduction The issue described in this Element Report was derived from employee C~
concerns generated as a result of the Watts Bar Employee Concern
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Special Program.
The issue was determined to be applicable to the
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Sequoyah Nuclear (SQN) Plant and was investigated and evaluated on that basis.
1.2 Description of Issue
,c The condition reported by the concerned employee was that Management is hesitant or refuses to issue Corrective Action Reports (CAR) and Deficiency Reports (DR), specifically, against procedures which are considered inadequate.
(IN-85-688-002 and IN-85-688-004) 2.0
SUMMARY
2.1 Suasary of Characterization of Issue The Quality Assurance (QA) Department is responsible for the approval and issuance of CARS and DRs and the issue raised by the concerned emp' loyee suggests that QA management is reluctant to issue CARS and 2
DRs.
In one concern (IN-85-688-002),
the concerned employee specifically addressas that Management is unwilling to address procedure inadequacies on a CAR or DR.
2.2 Susmary of Evaluation Process
'The Quality Assurance Category Evaluation Group (QACEG) evaluation consisted of reviewing the Nuclear Quality Assurance Manual (NQAM) and procedures to determine Management's requirements and controls as they apply to the subject matter of this issue.
In addition, discussions were held with supervisory and management personnel at SQN regarding the issuance of CARS and DRs.
The CAR and DR Logs were reviewed as well as the Employee Concern File.
2.3 Sunenary of Finding The conclusions reached as a result cf the QACEG evaluation of this issue are:
a.
The Nuclear Quality Assurance Manual does not prohibit the issuance of CARS or DRs to document program or procedural deficiencies.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
r SPECIAL PROGRAM 80401-SQN 4.,_; _ REPORT _ TYPE REVISION NUMBER:
Element Report 2
a
'____ _ TITLE:
PAGE 3 0F 4 Nonconformance Reporting b.
This issue is unsubstantiated as QA Management is responsive to issuing CARS and DRs to document deficiencies, when neces'sary, in the appropriate manner.
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-3.0 LIST OF EVALUATOR (S)
R. D. Halverson 4.0 EVALUATION PROCESS 4.1 General Methods of Evaluation The QACEG evaluation of this issue consisted of reviewing the NQAM, Administrative Instructions listed on Attachment B, CAR and DR Logs, and conducting interviews with supervisory and management personnel to determine the validity of the issue raised by the concern employee.
4.2 Specifics of Evaluation QACEG evaluation included interviews with supervisory personnel from Quality Engineering (QE) and Quality Control (QC),
the CAR /DR Coordinator, and Sequoyah's Site Quality Assurance (QA) Manager.
All 1985 and 1986 open and closed CARS and DRs were reviewed as well as a random review of revision histories to Sequoyah Administrative Instructions (AI), listed on Attachment B, to determine if inadequate procedures were addressed by a CAR or DR.
Sequoyah Element Report 80404-SQN, Revision 2, was issued documenting
,the QACEG evaluation of timely issuance of CARS and DRs.
This report was reviewed as it relates to the issue of Management's hesitancy to issue CARS and DRs.
5.0 FINDINGS 5.1 Findings on Issue 5.1.1 Discussion The concerns indicate that Management is hesitant or refuses to issue CARS or DRs and Management hesitates or refuses to address procedure inadequacies on a CAR or DR.
QACEG conducted interviews with supervisory personnel in Quality Engineering, Quality Control and Quality Assurance Management Personnel.
The results of these discussions
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
N.1 r ~ !_ 2._
SPECIAL PROGRAM 80401-SQN l
N M E5 FORT _ TYPE ;
REVISION NUMBER
_. Element Report 2
5_.
TITLE:.. -
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PAGE 4 0F 4
' Nonconformance Reporting Up hl.L indicated that QA Management is not opposed to issuing a CAR 1
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or DR documenting deficiencies or procedure inadequacies as 8PPropriate to their significance.
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All 1985 and 1986 open and closed CARS and Das were reviewed as well. as a
random review of revision histories to
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Administrative Instruction.
Four Administrative Instructions, Attachment B, have revision histories which indicate revision f-due to procedural deficiencies identified in Corrective Action or Deficiency Reports.
Five CARS and three DRs isasued in 1985 and 1986, Attachment C,
document NQAM and procedure 2
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deficiencies.
The results of this evaluation do not substantiate this issue as Management is responsive to documenting procedural deficiencies in CARS and/or DRs..
Evidence presented in Element Report 80404-SQN, Revision 2,
concludes CARS and DRs are issued in a timely manner.
The issue of Management being hastitant to issue CARS and DRs is unsubstantiated.
i 5.1.2 Conclusion The concerned employee failed to provide specific examples to support these concerns;
- however, as a
result of this evaluation, QACEG established that this issue was not substantiated.
Interviews with cognizant personnel indicate that Management is willing and does document procedural deficiencies, when necessary, and in the appropriate manner.
Reviews of CARS, DRs, and procedural revision histories also substantiate Management's position on documentating procedural deficiencies.
Additionally, NQAM, Part III, Section 7.2, Revision 0, does f
not prohibit the issuance of CARS or DRs to document program i
or procedural deficiencies.
Attachment A, identified these concerns about non-conformance reporting as potentially safety-significant and safety-2 related.
However, since the concerns were found to be invalid, they do not affect the safe or reliable operation of the Sequoyah Nuclear Plant.
6.0 ATTACHMENTS A.
List of Employee Concern Information Subcategory
- 80401, dated October 3, 1986.
B.
Administrative Instructions Reviewed C.
CARS and DRs Issued Documenting NQAM and Procedural Deficiencies
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'3 SUBCATE10 tYISO401" flbilCorlFbktl liUE'k'E[dihE G" l )',, !.7dof.
- i ATEGOR( QA QA/QC PROGRAMS i KEYHORD A,',
S GENERIC KEYHORD >B KEYif0RDE N; i j H
APPL QTC/NSRS P
i KEYH.RD<C COHCERil SUB R PLT BBSH INVESTIGATI0tl S
CONCERN NUMBER CAT CAT D LOC FLQB REPORT R
DESCRIPTIDH
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!" 203-001 Qi 50'01 " '2 "
" " Y I OS O'7 ;;;;N SS R 84412 HAS HRITTEN TO ADDRESS U DESIGN REVIEHL, f
ER ED ORIFICE PLATES IN SYSTE 7,
PROCUREMENT ^
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MATERIAL UNDERSIZE RIFICE PLATF (PURCHASED P
FROM MERIAI NST. C, CLEVEL AllD, O i
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-1) HITH NEW ORI FICE PLATES. C/
TATES THAT NCR 84 412 HAS BEEN SED UT THE UNDERSIZ ED ORIFICE ATES HER 10T REMOVED F i /
ROM THE STEM.
NO DOC HTATI0tl EX ISTS SUPPORT THE CLOSUR OF NCR 3 44 NO FURTHER INFORMATI0t VAILA NO FOLLOH-UP REQUIRED.
TVA MANAGEMENT (DEPARTMEllT KNCHN)
PROCEDURES NONCONFORMANCE IN 688-002 QA 80401 N HBN YYYY I-85-933-HJf1_
NS ESITAtlT OR REFUSES TO PROCESS DEFICI CONSTRUCTION K-FORM ENCY REPORTS OR CORRECTIVE ACTION RE T50080 GENERAL QUESTS COHCERNING INADEQUATE TVA PRO CEDURES, UNLESS THE INADEQUANCY IS B ASES ON A HIGHER TIER TVA PROCEDURE, NHICH ITSELF MAY BE INADEQUATE. NO FURTHER DETAILS AVAILABLE.
d SS TVA MA!!AGEMENT (NAME KNOHit) PREVENTI DOCUMENTS NONC0!1FORMAtlCE j!';
'IH -8S-688-004 QA 80401 N HBN YYYN I-85-424-HBM ~
NG ISSUAt3CE AND PROCESSING OF CORREC T50080 TIVE ACTION REQUESTS. NAMES AND GTH QUALITY g
K-FORM ER DETAILS KNDHH TO QTC.
DETAILS HI REPORTS mz THHELD TO MAINTAIN CI'S C0tlFIDENTIAL H
ITY.
I" OG 037 003 OA 0 0' 01 N ',;0N
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SS RECTIVE ACTION REQUESTS (CARS)
RECORD GENERATI0!1
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D CIENCY REPORTS (DRS) AREt I
N0 tlc 0tlFORMANCE
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SSUED A TIMELY MANNER, HHI ADVE GENERAL 4 IOrd -
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RSELY AF TS PROGRAM EFFE V EllESS.
REPORTS
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- CI EXPRES THAT THE AYS ARE D UE TO MAtlAGEilE
'S (KN H) RELUCTANC E TO DOCUMENT SIGi AtlT CONDITIONS ADVERSE TO QUALI N EXAMPLE PRO
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VIDED HAS THE C ON T RUARY A ST, HHICH HA 1RITTEtt IN HD HOT ISS UllTIL JULY OR UST.
CI STAT THAT THIS HAS A COMM OC CURRE ON THESE TYPES OF DOCUMEN THER DETAILS KH0H TO QTC,
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ATTACHMENT B W
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A'dministrative Instructions Reviewed L,
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_ l.).AI-7, Revision 41, " Recorder Charts and QA Records" Revisions 39 and 40 caused by CAR-86-04-024
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' 2.)
AI-9, Revision 21,
" Control of Temporary Alterations and Use of the
-Temporary Alterations" r _ - _ 7_ Revision 32 caused by CAR QSQ-A-86-0002 3.) AI-14, Revision 34, " Plant Training Program" 4
g, Revision 32 caused by CAR QAQ-A-86-0004 4.) AI-25, Revision 16, " Drawing Control After Unit Licensing"
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Revision 13 caused by CAR SQ-CAR-85-03-005
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Revision 16 caused by DR NCO-DR-85-007-RSO
' 5.) ~AI-31, Revision 6, " Control of Measuring and Test Equipment"
-Revision 4 caused by CAR 84-06-014 fme e-me4-6 O
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6' ATTACHMENT C
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'CARa and DRs Issued Documenting NQAM and Procedure Deficiencies n,.
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f Corre.ntive Action Reports
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"NQAM, Part III, Section 3.4, Paragraph 3.2.2 not in compliance with SQN NCO-CAR-85-001, dated 2/7/85
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FSAR, Section 12.3."
CAR-86-04-027, dated 5/9/86
" Generic review process specified in OEP-17 contradicts NRC order EA-85-49" CAR-86-05-0303, dated 5/27/86 "M&AI-11 and -1 do not adequately implement the NQAM, Part II, Section 6.1."
CAR-86-042, dated 8/28/86 "RCI-l criteria for establishing an Airborn Radioactivity Area" CAR-86-044,_ dated 10/31/86 "AI-4 does not assure that working copies of Instructions are the latest revision."
Discrepancy Reports SQ-DR-85-02-019R, dated 2/13/85 "IP-17, Revision 7 does not adequately implement the requirements of the REP Manual, Revision 17" SQ-DR-85-05-047R, dated 5/10/85 "ES-SIL-CIO, Revisor. 33, no comparison criteria for accuracy of the results from Laboratory Analysis and Process Instrumentation is provided for accuracy
--determination."-
NCO-DR-85-011-RSQ, dated 8/27/85
" Nuclear Power Standard Procedure No. TS08.08.01.14.03 not in compliance with NQAM, Gamma Ray Spectrometry Systems calibrated every 30 months; NQAM requireIs every 12 months."
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