ML20207L280

Rev 2 to Element Rept, QA Independence & Authority

ML20207L280
Person / Time
Site:	Sequoyah
Issue date:	12/30/1986
From:	Deangelis J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207K584	List: ML20207K581 ML20207K641 ML20207K723 ML20207K830 ML20207K861 ML20207K986 ML20207L046 ML20207L111 ML20207L128 ML20207L147 ML20207L204 ML20207L207 ML20207L213 ML20207L217 ML20207L222 ML20207L226 ML20207L229 ML20207L251 ML20207L268 ML20207L273 ML20207L280
References
80102-SQN, 80102-SQN-R02, 80102-SQN-R2, NUDOCS 8701120068
Download: ML20207L280 (18)

Text

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

SPECIAL PROGRAM 80102-SQN REVISION NUMBER:

REPORT TYPE 2

Element Report PAGE 1 0F 9 TITLE:

Quality Assurance Independence and Authority REASON FOR REVISION:

Revised to comply with SRP comments.

Revision indicators are shown on each page to indicate revision changes.

Note: Sequoyah Applicability Only PREPARATION PREPARED BY: JOHN J. DEANGELIS A 7f /2 9 gg

// DATE '

SIMATUREV REVIEWS PEER: .g I /,

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DATE SIGNA TAS:

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• 30 ' 8C, SIGNATURE

• DATE SIGNATURE DATE APPROVED BY:

- A b.sW\(, A _ cladh NA.

MANAGER '0F 11UCLEAR POWER DATE ECSP MANAGER DATE i CONCURRENCE (FINAL REPORT ONLY)

• SRP Scretary's Signature denotes SRP concurrence are in files.

8701120068 870102 PDR ADOCK 05000327 P PDR

+

REPORT NUMBER:

REPORT TYPE: 80102-SQN

-Element Report: REVISION NUMBER:

TITLE: 2 Quality Assurance Independence and Authority PAGE 2 0F 10 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction There are twelve concerns in the element Quality Assurance (QA)

Independence and Authority. These concerns were grouped in to the following two issues to aid the Quality Assurance Category Evaluation Group (QACEG) investigation at the Sequoyah Nuclear Plant (SQN):

a. The QA organizational structure as it relates to the independence of QA personnel.

b. The lack of depth of QA audits.

Section 6.0, At tachment. A, provides a listing of Employee Concerns identified within this Element Report.

1.2 Description of Issue 1.2.1 The QA organizational structure as it relates to the indapendence of QA personnel (IN-86-087-002, WBM-86-004-001, PH-85-056-X02, WI-85-090-001, WI-85-086-001, WI-85-086-004, XX-85-118-001, XX-85-119-001, XX-85-113-001, WI-85-090-002, and WI-85-086-003).

The Employee Concerns relate to the organizational structure of the QA Department. These concerns 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 Con:erned Individuals (CIs) criticized TVA's decision to " Decentralize" the QA audit 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 CI also stated that the Director of QA issued a letter dated November 11, 1985 to the Auditors directing them to increase the number or audit areas per audit. The CI assumed this directive would restrict the auditors indepth approach into the activities of the audited organization.

2.0 SUMl!ARY 2.1 Summary of Evaluation Process 2.1.1 The evaluation process consisted of the review of Employee Concern files, Quality Technology Company (QTC) and Nuclear

REPORT NUMBER:

REPORT TYPE: 80102-SQN REVISION NUMBER:

Element Report:

2 TITLE:

Quality Assurance Independence and Authority PAGE 3 0F 10 Safety Review Staff (NSRS) reports, Federal Regulatory Requirements, TVA Topical Report and the Nuclear Quality Assurance Manual (NQAM). 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 in formation to 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

- 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 ind icate s this issue was not valid.

Contra ry to the Concerned Individual re ference to a November 25, 1985 letter being issued by the Director of QA, the QACEG investigation could produce no evidence of such a investigation did, however, find a letter. The QACEG memorandum from the Director of QA to Branch Managers , dated October 24, 1984, which addressed audits and comments by various site and plant repre sentatives . The investigation found where audit modules were comb ined to make audits more comprehens ive , and where possible, audit team members were reduced because of the consolidation of audit modules.

2.3 Corrective Action Since the two issues identified in Section 1.1 of this Element Report were not valid, no corrective action is required.

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REPORT NUMBERt

' REPORT TYPE: 80102-SQN Element Report: REVISION NUMBER:

, TITLE

2 ,

Quality Assurance Independence and Authority PAGE 4 0F 10 3.0 EVALUATORS. I D. G. Barlow J. J. DeAngelis i

4.0 EVALUATION PROCESS 4

i 4.1 General Methods of Evaluation l

The evaluation process consisted of researching the Employee Concern Files, QTC Files, and NSRS Files- to determine if additional l

I information was available to assist in the investigation of this l e lemen t .

1 Reviews were conducted of Regulatory Requirements and Industry Standards together with upper tier documents, such as, TVA Topical l Report and the NQAM, and lower tier documents, such as, procedures and j instructions- to determine requirements, conunitments. and j - responsibilities. QA Auditing Branch Correspondence Files, the QA i Audit Schedules and the QA Audit Status Log were - reviewed to determine audit activities during the time period 1983 through 1935.

Discussions were held with the former Director of QA, the Branch Chief 1

of the Audit Group and the Audit Group Section Supervisor to acquire i additional details pertaining to the Audit Group organizational i structure and auditor's independence.

l 4.2 Specifics of Evaluation i

This section describes the specific methodology used in the investigation of the following issues:

4.2.1 Issue The QA organizational structure as it relates to the independence of QA personnel.

f a. The Employee Concern Files and the Confidential Files were researched to determine if QTC or NSRS had investigated j

and issued a report on this issue. QACEG's review of the

' files indicated NSRS Reports I-85-420-W BN , dated November 19, 1985 and I-85-805-NPS dated November 18, 1985

' were issued and addressed the independence of the QA Department. NSRS Report, I-85-420-WBN, was issued specifically for Watts Bar Nuclear Plant (WBN); however, the Employee Concern Task Group (ECTG) has determined this issue to be generically applicable to SQN. NSRS Report I-85-805-NPS is not attached to this report, as the data contained within that report was not utilized in this report.

4 4

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4 REPORT NUMBER:

REPORT TYPE: 80102-SQN REVISION NUMBER:

4 Element Report:

2 TITLE: PAGE 5 0F 10 Quality Assurance Independence and Authority

b. Reviewed the requirements of Appendix B to 10 CFR 50, Criterion 1; TVA Topical Report, TVA-TR75-1A, revision 8; the approved and. the NQAM, Part III to determine 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 develop background information and other specific details relating to this issue.

4.2.2 Issues The lack of depth of QA audits

a. The Employee Concern Files and the Confidential Files were researched to determine if QTC or NSRS had investigated i

and issued a report on this issue. These files contained

- no further information.

b. Reviewed the QA Auditing Branch Correspondence Files, QA Audit Report Files and the QA Audit Schedule for 1983 through 1985 for additional information relating to this j issue.

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 i

relating to this issue.

t 5.0 FINDINGS The following findings address both a background discussion and a conclusion of each issue identified in Section 1.1 of the Element Report.

The QA organizational structure as it re la te s to the

5.1 Issue

independence to QA personnel.

l l 5.1.1 Background i

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.

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. REPORT NUMBER:

80102-SQN REPORT TYPE: REVISION NUMBER:

Element Report 2

TITLE: PAGE 6 0F 10 Quality Assurance Independence and Authority In February 1984, the Power Operations and the Engineering and Construction functions were merged into the newly fo rmed organization called the Of fice 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 or those facilities which they operated. This the the authority, concept delegated to operator responsibility and accountability for regulatory compliance, engineering services, quality activities, operations and costs. Additionally, this concept was to establish a

" Decentralized" method of operations for each of TVA's nuclear each nuclear plant would function plants. Furthermore, autonomously by developing its own programs and systems to control plant activitie s. These actions were TVA ef fort s 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 as document, was accepted by NRC in October 1984 satisfactorily meeting the requirements of Appendix B to 10 CFR 50. The revised report established the position of the Site Director who was responsible for the quality of work activities at licensed nuclear p lant s . In addition, this i

report established the position of the Operations QA Manager who maintained a Plant QA Staf f at operating plants to perform work functions relative to quality enginee ring, quality control and surveillance activities. The Supervisor of Plant from the Site QA Staff received functional supervision i

Director, but reported administrative 1y to the Operations QA Manager.

Note: TVA's usage of the terms " functionally" and

" administrative 1y" are reversed in relation to their f

(- use by other organizations.

l

" Decentralized" structure The QA Audit Branch under the new for SQN was in the transition phase in December of 1985. A memorandum from the Director of QA to "Those Listed", dated Dec ember 12, 1985, indicated that the decentralization of the QA Auditing functions for operating plants had not been fully implemented at that time. The results ofGroup's this investigation plans indicated the Operations QA Audit to The program to decentralize never did materialize.

decentralize the audit group ended during the reorganization of the QA Department in early 1986.

n

• REPORT NUMBER

, REPORT TYPE: 80102-SQN Element Report: REVISION NUMBER:

TITLE: 2 Quality Assurance Independence and Authority PAGE 7 0F 10 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 re ferenced 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 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 Nuclear 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 of Nuclear QA. TVA has developed a standarized Nuclear QA Program described in the revised Topeial 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. 'Ihe revised 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.

l 5.1.2 Conclusion l Based on the above evid ence, 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.

j This plan was approved by TVA's Board of Directors and NRC in October 1984. NRC approval of the TVA revised organizational l structure also endor se s the " independence" as described in Appendix B to 10 CFR 50, Crite rion I. Presently, TVA's l

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.

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REPORT NUMBER:

REPORT TYPE: 80102-SQN Element Report: REVISION NUMBER:

TITLE: 2 Quality Assurance Independence and Authority PAGE 8 0F 10 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 of 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 forme r Director of QA we directed our attention to 1984 rather than 1985 since the subject of audit frequency, numbers of auditors on site, and organizations performing audits was a concern to Sit'e 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 o ther topic s) audits and comments made to the Director of QA by various site and plant representatives on his visits to WBN, SQN and Browns Ferry (BFN) during the week of October 14, 1984. This memo stated under " Watts Bar" that " twenty-four audits a year is conside red by the plant and site staffs 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 p'arsuing, planning and scheduling practices that will provide for both an e f fec tive audit program and minimize unncessary adverse impact on the orgainzations.

The Director of QA went on to atate that the audit group was required by the Technical Speci fication (Tech Spec) requirements to perform a given number of audits (modules) and

• REPORT NUMBERg REPORT TYPE: 80102-SQN Element Report: REVISION NUMBER:

TITLE: 2 Quality Assurance Independence and Authority PAGE 9 0F 10 that he agreed that a smalle r numbe r of audits would lessen the impact at the plants but could still be accomplished e f fec tively. "By November 30, 1984, we will have a plan which reduces the number of times addit teams appear at a given location. This will be accomplished by combining standard audit modules into a given audit." He fur ther stated ..."We will strive to work more efficiently and conduct fewe r but more comprehensive audits this year while still ve ry e f fectively addressing the scopes de fined 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 module s 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 pos sib le) . 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 decreare by three audits. We also found in our review of the individ.41 audits that depth of coverage and numbers of audit personnel were in no way reduced which would restrict the depth, as the CI stated.

5.2.2 Conclusion Based on the above evidence, the emp loyee conc ern is not valid. We can only assume that the CI was incorrect in stating that the Director of QA issued a le t te r dated November 25, 1985 and that tie is re ferring to the

" ADMINISTRATIVELY CONFIDENTIAL" memo dated October 24, 1984.

Based on our investigation using the above document as a basis to identify any impact that memo had on the audit function and the actions taken by the Quality Audit Branch to reduce the number of audit areas, we find the conc e rn to be unsubstantiated.

5.3 Attachment A identified the concerns as being potentially either Sa fety-Related or Sa fe ty-Signi ficant. Since the two issues of this report were unsubstantiated, the concerns are not considered to have an impact on sa fety.

• REPORT NUMBER:

REPORT TYPE: 80102-SQN Element Report: REVISION NUMBER:

TITLE: 2 Quality Assurance Independence and Authority PAGE 10 0F 10 6.0 ATTACRHENTS 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.

l ATTACHMENT A

1. E* TENNESSEE VALLEY AUTHORITY PAGE -

REFERENCE - ECPS120J-ECPS121C RUN TIME - 12:19:18

- REQUEST OFFICE OF NUCLEAR POWER

• FREQUENCY EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 10/03/86 ONP - 1555 - RitM LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: QA QA/QC PROGRAMS SUBCATEGORY: 80102 QUALITY ASSURANCE INDEPENDENCE AND AUTHORITY KEYWORD A S GENERIC KEYHORD B H APPL QTC/NSRS P CONCERN KEYHORD C CONCERN SUB R PLT BBSH INVESTIGATION S AEYHORD D HUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION NNYY I-85-420-HBN NS TVA QA DEPARTMENT IS NOT SUFFICIENTL INSPECTION

. IN -Q6-087-002 e QA 80102 N HBN NDHCONFORMANCE T50120 REPORT Y INDEPENDENT OF PLANT MANAGEMENT (K NDHN) TO PERFORM ASSIGNED FUNCTIONS QUALITY IN A PROPER MANNER. QA DEPARTMENT M ANAGEMENT DOES AS DIRECTED BY PLANT MANAGEMENT. HBNP HAHAGEMENT CREATES AND SUPPORTS NEGATIVE EMPLOYEE ATTI

~

TUDES REGARDING SUBJECT QA DEPARTMEN TAL FUNCTIONS, HHICH IS NOT GOOD FOR THE PLANT, NUCLEAR PDHER CONCERN.

CI HAS NO FURTHER INFORMATION.

j YYYY NS THE DECISION TO DECENTRALIZE THE QUA QA PROGRAM

• PH 056-X02 + QA 80102 N HBN

~

K-FORM LITY ASSURANCE AUDIT BRANCH IS THE R NONCONFORMANCE V50270 ESULT OF RETALIATIDH FROM THOSE HITH QUALITY IN TVA MANAGEMENT WHO DO NOT HISH TO CONST MANAGEMENT HEAR ABOUT SITE / SYSTEM DISCREPANCIE S. THIS DECISION VIOL ATES THE TVA C OMMITMENT TO THE NRC FOR STRONGER CD RPORATE MANAGEMENT. THE CI REQUESTS QTC INVESTIGATE THIS CONCERN. NUCL EAR POWER DEPAP.TMENT CONCERN.

YYYY NS TVA NUCLEAR PLANTS (GENERIC) HAVE TH NONCONFORMANCE c HBM-86-004-001. QA 80102 N NPS EIR QC PERSONNEL REPORTING TO, AND R QA PROGRAM T50259 REPORT QUALITY ECEIVING ORDERS FROM , THE NUCLEAR P

• LANT MANAGEMENT VIA THE NUCLEAR PDHE GENERAL

- R MANAGER OFFICE. THIS EFFECTIVELY i

l STRANGLES TVA QC AS AN INDEPENDtNT R EVIEHER. No FURTHER INFORMATION IN l FILE. ANONYMOUS CONCERN. NO FOLLOW

-UP REQUIRED.

NS TVA CORPORATE MANAGEMENT IS IN THE P QA PROGRAM

! #HI 086-001

• QA 80102 N HBN YYYY NONCONFORMANCE T50186 K-FORM ROCESS OF DECENTRALIZING THE QUALITY AUDIT PROGRAM, IN AN EFFORT TO REDU QUALITY CE THE AUDIT PROGRAMS IMPACT ON THE CONST MANAGEMENT

"" STARTUP AND OPERATIDH OF THE NUCLEAR PLANTS, ALSO TO INTIMIDATE AUDITOR PERSONNEL, THUS SIGNIFICANTLY REDUCI NG THE EFFECTIVENESS OF TVA'S QUALIT Y VERIFICATION PROGRAM. NUCLEAR P0H ER CONCERN. CI HAS NO FURTHER INFOR MATION.

l .

ATTACHMENT A .

TEtitlESSEE VALLEY AUTHORITY PAGE -

REFERENCE - ECPSI20J-ECPS121C RUll TIME - 12:19:18

- REQUEST OFFICE OF NUCLEAR PDHER FREQUEllCY EMPLOYEE CollCERN PROGRAM SYSTEM (ECPS) RUN DATE - 10/05/B6.

DNP - 1555 - RiaM LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: QA QA/QC PROGRAMS SUBCATEGORY: 80102 QUALITY ASSURANCE INDEPENDENCE AND AUTHORITY KEYHORD A S GENERIC KEYll0RD B H APPL QTC/NSRS P KEYlIORD C CONCERN SUB R PLT BB$H INVESTIGATION S C004CERN KEYHORD D flUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION ,

NS TVA IS PROPOSING TO DECENTRALIZE THE IOCFR OTHER

'HI 086-003 e QA 80101 N H5N YYYY QA PROGRAM K-FORM QUALITY AUDIT PROGRAM HITHOUT PRIOR T50252 APPROVAL OF THE 11RC. THIS IS A VIO QUALITY LATION OF 10 CFR 50.54 AND THE SAFET GENERAL Y ANALYSIS REPORT. HUCLEAR P0HER CO NCERN. NO FURTHER INFORMATION IN FI LE. _ . . _ . ..

D NS CI STATED THAT THE PROPOSED DECENTRA QA PROGRAM c/ III 086-004 8 QA 80102 N HBN YYYY NONCONFORMAtiCE K-FORM LIZATIDH OF THE QUALITY AUDIT PROGRA QUALITY T50252 M IS AN ATTEMPT BY UPPER MANAGEMENT TO REDUCE THE EFFECTIVENESS OF THE I CollST MAtlAGEMENT NTERNAL AUDIT PROCESS AND AN EFFORT TO REDUCE THE MORALE, SECURITY, FREE DOM, AND EFFECTIVEt4ESS OF THE AUDIT

' PERS0llNEL . NUCLEAR P0HER CONCERN.

NO FURTHER INFORMATION IN FILE.

I , i

~ NS THE OBJECTIVE, AND RESULT OF, THE DI QA PROGRAM V HI 090-0014 QA 80102 N HBN YYYY ORGANIZATION K-FORM SSOLUTION OF THE OFFICE OF QUALITY A T50252 SSURANCE HAS TO CONCENTRATE THE QA F QUALITY UNCTION UNDER LINE MANAGEMENT. THE GEllERAL SITE GA MANAGER HILL REPORT TO THE S ITE DIRECTOR RATHER THAN TO A CENTRA L QA DIRECTOR. THIS DESTROYS THE IN DEPENDENCE OF THE QA AND AUDIT FullCT IONS, AS THERE IS NO INDEPENDENCE FR OM LINE MANAGEMENT. HUCLEAR P0HER D EPARTMENT CONCERN. NO FURTHER INFOR

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MATION IN FILE. CI REQUESTS THIS CO I NCERN TO BE INVESTIGATED BY QTC.

.  ! ,  : i ,

' j } t , i i i YYYY NS DECENTRALIZATION OF THE OFFICE OF QU QA PROGRAM

'll! 090-002 e QA 80101 N HBN ALITY ASSURANCE AGGRAVATES AN ALREAD ORGANIZATIDH 150252 K-FORM QUALITY Y MARGINAL TREATMENT OF CONFIGURATIO N MANAGEMENT. TVA LINE MANAGEMENT H GENERAL AS NO CONCEPT OF THIS FUNCTION, AND DOES NOT INTERRELATE THE REQUIREMENT S OF 10 CFR 50, APPENDIX B, CRITERIA III, IV, VI AND VII. NUCLEAR P0HER DEPARTMENT CONCERN. NO FURTHER INF ORMATION It! FILE. CI REQUESTS THIS CONCERN TO BE INVESTIGATED BY QTC.

5

ATTACHMENT A

• Page 3 of 3 .

- ECPS120J-ECPS121C TEttHESSEE VALLEY AUTHORITY PAGE - -

OEFEREt4CE RUN TIME - 12:19:18 FRE QUf flCY - REQUEST OFFICE OF NUCLEAR P011ER Ct4P - 1555 - R11rt EMPLOYEE CONCERil PROGRAM SYSTEM (ECPS) Rut! DATE - 10/05/86 LIST OF EllPLOYEE CollCERil INFOR!1ATI0tl CATEGORYa QA QA/QC PROGRAMS SUBCATEGORY: 80102 QUALITY ASSURANCE IllDEPEtIDENCE AIID AUTHORITY S GEtlERIC KEYHORD A H APPL QTC/IISRS P KEYll0RD B SUB R PLT B B S 81 INVESTIGATION S CONCERN KEYl10RD C CCHCERN KEYi10RD D NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTI0tl YYYY I-85-805-S M SS SEQUDYAH TVA CORPORATE MANAGEMEllT I QA PROGRAM V XX 113-001 # QA 801!t2 N SQN J N0t3C0!1FORMANCE T50186 K-FORM r S IN THE PROCESS OF DECENTRALIZING T HE QUALITY AUDIT PROGRAM IN AN EFFOR QUALITY

• hm [ T TO REDUCE THE AUDIT PROGRAMS IMPAC CutlST MAllAGEMEllT T ON THE STARTUP AllD OPERATION OF TH

+ E NUCLEAR PLANTS AND ALSO TO INTIMID ATE AUDITOR PERS0titiEL THUS SIGNIFICA flTLY REDUCING THE EFFECTIVENESS OF T VA*S QUALITY VERIFICATION PROGRAM.

14UCLEAR Poller CONCERil. CI HAS 130 FU RTHER IllFORMATION.

SS SEQUDYAH - MANAGEMEllT (KilollN) COMPLA II0 tic 011FORMANCE 5 XX 116-0117 QA 80101 S SQti YYYY AUDIT

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T50271 QA 80102 K-FORM INED To THE DIRECTOR OF THE DIVISI0tl OF QA ABOUT AUDITS HHICH HERE TO Ili QUALITY

-DEPTH. THE DIRECTOR OF QA ISSUED A REPORTS LETTER 11-25-85 TO AUDITORS DIRECTI HG THEtt TO ItiCREASE THE NUMBER OF AU DIT AREAS PER AUDIT, THUS EFFECTIVEL Y RESTRICTIllG THE DEPTH OF THE AUDIT S. IluCLEAR PONER CollCERil. 110 ADDIT

~. 10HAL INFORMATI0H AVAILABLE. CI REQ UESTS THAT QTC PERFORM THIS ItiVESTIG ATION.

I-!!P2 "M SS CI STATED THAT THE GIVIllG OF THE NUC QA PROGRAM

/ XX -8 5-118-0018 QA 80102 N NPS YYYY AUDIT T50204 K-FORM gM 5

LEAR QUALITY ASSURAtsCE 11AtlUAL AUDIT FUNCTION TO THE INDIVIDUAL PLAllT SIT QUALITY GENERAL p t 35 g ES AND SITE DIRECIORS HILL REDUCE TH e E EFFECTIVEllESS OF THE PROGRAM, llILL ELIMINATE IllDEPENDEllCE, AND LIILL SU BJECT AUDITORS (QA SPECIALISTS) TO S

~

EVERE HARASSMENT AND INTIMIDATION.

140 CLEAR P0HER Cat 4CERN. CI HAS 110 FU g RTHER INFORMATION.

SS THE DECEllTRALIZATION OF THE ' AUDIT PR QA PROGRAM

/ XX 119-001 8 QA 30102 14 NPS YYYY  ! "5 0% "PS 110HCONFORMANCE T50205 K-FORM 0 GRAM HILL CAUSE THE ItiDIVIDUAL PL AN T SITES TO EFFECTIVELY DIMINISH IN T QUALITY HE AUTHORITY AND ORGAtiIZAT10tlAL FREE GEllERAL DOM TO IDEt4TIFY AND REPORT QUALITY P ROBLEMS. IluCLEAR Pol ER CONCERil, CI HAS NO FURTHER IliFOR11ATION.

d C0r! CERT:5 FOR CATEGORY QA SUBCATEGORY 80102 s-

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ATTACIDfENT B Page 1 of 4 TENfJEEEEE VALLEY AUTHORITY TJUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATIO!J REFORT NO. I-85-420-WEN .

Et1PLOYEE COlJCEF:N IN-06-OS*'-OO2 t11LEST0!1E 5 o

E*.!E:J ECT : OA INDEPElJDEtJCE AllD PLAtJT ATTITUDE DAT ES OF INVESTI G AT I CIJ:

October 15-tJovember 10, 1905 LEAD ItJVET.,TIGATOR: 9 _ ___ . __. ____

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R. fi. Runnell Date 1NVESTIGATOR _ ;_' . l.l.'$' _

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Date P. G. fiann .

A REVIEWED BY: _ _ ,

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_ [/_"/l.*IC Biantley Date p G. u.

i,FFROVED BY: -h _ _, .f;c _'_ _ _ - ___ // /8 ((

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ATTACHMENT B M M UJI 2 ."M T l 7i Page 2 of 4 ai 4- BACKGROUND

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NERS han investigated Emol oyee Concern IN-86-OS7-OOC ..hi ch was received by Duality Technology Company on August 19, 19C3 which ctored:

TVA OA department is not sufficiently independent of plant management to perform assigned functions in a proper manner.

by plant management. OA department management does as cirected

• WBNP management creates and supports negative employee attitude regarding subject GA departmental functions, which is not good for the plant.

concern. Nuc,l e ar Power II. ECOPE ,

Documentation enlated to the cuality assurance (OA) functions, duties, and resoonsibilities indecencence, was :esearched for reporting chains and to establish the TVA recuirement for responsibtfities, management anc for NEC, contro1n on cuality assurance. . Plant employees, management, determine and Divi sion of Quali ty Assurance amoloyees were interviewed to actual performance of the oncite OA organi:ation.

111.

SUMMARY

OF FINDINGS i A.

DA Department Not Independent of Plant Management There are no documented requirements f or DA indeoendence from plant site management.

B, states: The Code of Federal a Reguistions, 10CFR50, Appendin  !

"Organi:stiony shall report to a management level perf ormTng quality assurance f unctions such that this reautred authority and organt:stional freedom, including sufficient independence cost from  ;

orovided.

and schedule when opposed to saf ety considerations. are

. . . the organi:stional structure for enecuting the quality assurance program may take various f orms provided that the persons  ;.

And organi:ations assigned the cuali ty assurance f unctions have thi s reouired authority and organi:ational freedom." The authority and 1

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freedom referred to in the above quo,tes appl y to the ability to identify quality problems; to initiate, recommend, ce provide 7 nol uti ons; and to verif y implementation of solutions.

In interviews with a cross-section of ten individual s f rom pl ant management, Division of Duality Assurance, NRC, and plant employees only obove.

one indicated any problem with OA independence as defined

• This individual believes that ouality concer'ns may not be identified or brought to management attention because of the i dominance plant management has over DA management. No problems were  !

identified that related to the performance of functions assigned to  ;

plant 04 (f unctions defined in TVA Tooical Report, Section 17.0.0.1.0). One of the OA suoervi sor's peers believes that morn inuue6 would be ra1Ded by a Utronger personality. All otherG t believe that GA orcoerly identif f en. recommends, and checi:n correction of OA problems.

program at Watts Bar There i n a general feeling that the OA ,

l is imoroving as time goes by and has been for l nevoral months since the appointment of the present DA nuoervisor.  ;

pointoarson One that it interviewed should be ye believed

. that GA has not progresced to the

Nf ATTACHMENT B

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/A[ I B. E6_LMEhC32501_U205GEOf01_E95H_61_EiC2EEEE_U2_ElbOl_UhEnGi&901 The T'.'A Tccical Raccet (TA-TR75-! A) f:r cualit. assuranca Dtates in Ee=t:cn 17.0.0.~: "Tha site daracter in raccons :le f or the cuality of work activi ties. . . .

The t: CAM. Fart 1.

Section 0.1. Paragrach 4.4, staten: "A clant

=uali:V e.asurance staff 1s resccnsible to cerfccm cuality eng:naaring, cuality control, and surveillance f unct2 cns to assi st the cite d:recter c in achievement of cuality." Alse Paragrash 4.4

- identifian many functisns cf the CA ceganization.and unau the words "assi sts slant management." "Leeos slant management advised of." and "thecugh line management." The cegani:stion now in f or:e has the OA cusarvircr tahing functional dirc: tion'from the cite ciractor. This

. ar r an g s.t.s n t is in kaaoing with the rJOAM and T'.'A T est : a1 Faccet.

Therefere. tha =lant DA da:artment management does and is recuired to take directi:n femm sita management. ,

C. OSOEEEGE01_GERE1EE_nQu_EMEEEC1E_UEGillEE_011L1UdE_CSEECsiGE_99_

EutE1 Leon 4 No avidanca of negative attitudas was shown in the persennel interviewed. The name individual that encreased reservations over indacendance talieves that morale and attitude tcward CA 'are not gc:d. Hcwever, there is avidence that tha OA crgani:ation is being

.used an t an si val v. The trend tcward using OA as a tcol is gecwing and being en:cunaged by plant management. Plant menagement stated that they may be using DA f or morg areas of work than they should.

0 inicns successad by clant auservision were good centerning the werk ocne by CA on surveillance instru=tien review. "C" list review, and ether asacial crojects handled. -

D. gfiggliggG133_gi_Ga_dLD3;3sgui This amoloyee ecncern had an imolied sncarn over the of f ectiveness cf the tes OA onsite management. Interviews with managers indicate p that the CA managar i s an analytical-tyce indivi dual . He is very careful to ensure that correct work is being out out. This tendency on his cart gives the Amoresaien te scme of his subordinates that he is withhc1 ding or bcttlenecking cuality issues. NSRS Reccet No.

I-D5-401-WDft dccuments ncme orcblems encountered with the CAR /DR avstr.m of reporting defician:les that were originated by the DA manager's poli ci es. However, there is no avidence of the deliberate withhciding of deficiencies. .

The CA manager received high craise fecm ensite management, downtown (DOA) management. and a majcrity of the subordinates antarviewed.

It is believed that he is directly rassensible fer develocing a

. cositive cite attitude abodt 04. One oersen interviewed believen that the CA manager's perscnality needs to be otronger so that he can stand u: and nay "Nc" if necessary, i

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ATTACHMENT B 'Y- Od M U7di .5 OF.E Page 4 of 4~ . a-g t M I V. COtJC: USICtJS AtJD RECO!1:1EtJDATICtJS EGOElWEl905 The majority of this allegation is unsubstantiated. The cart of the concern that states that "OA management does as directed by plant management" i s true. However, functional directicn by sito managemer.t is ar. crgani:stional and upper-tier document requirement. The reasons for unsubstantiation of the remainder of the concern f ollow.

.A. The Code of Federal Fiegulations defines. independence. TVA documents and ir.terviews with personnel do not indicate personnel er oroani:ation violation of this definition or concern over the perfccmar.ca of assigned functions. .

.B. Att,itudes at Watts Bar concerning the useUse'of and effectiv$nesc of the the OA crganization OA organi:stien are generally positive.

i s en:curaged by si te management. Plant supervisors une the OA organization a::tensively.

C. DA manegement in given high ma'rks by both site and downtown DOE

• management and by a majority of subordinates interviewed.

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ATTACHMENT C-References A. TVA Topical Report, TVA-TR75-IA, Revision 8 B. Code of Federal Regulations, 10CFR50, Appendix B C. Memorandum from the Director of QA to Branch Managers dated 10/24/84 D. Nuclear Quality Assurance Manual (NQAM), Part III, revision dated 12/31/84 E. Memorandum from the Director of QA to "Those Listed" dated 12/12/85 F. Nuclear Central Office Industrial Engineering Section Report, " Audit and Inspection Analysis" dated 8/7/84 C. QuElityAssuranceAuditStatusLogs,Fiscalyears 1983, 1984, and 1985 f

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