ML20207P459
| ML20207P459 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah |
| Issue date: | 01/07/1987 |
| From: | Russell J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207P399 | List: |
| References | |
| 80402-SQN, 80402-SQN-R03, 80402-SQN-R3, NUDOCS 8701160154 | |
| Download: ML20207P459 (15) | |
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L' TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80402-SQN f
REPORT Ta'PE REVISION NUMBER:
' Element Japort 3
TITLE:
PAGE 1 0F 9 Management.'s Interference 'in Deviation Reporting REASON FOR REVISION:
(2) Re-issued to incorporate SRP and TAS cornnents;
.and Site Director response to CATD.
(3) Re-issued to incorporate the SQN Site Director's res,ponse to the ECSP Corrective Action Tracking Decument (Attachment D).
Note: Sequoyah Applicability Only PREPARATION PREPARED BY:
W. E. Bezanson W6' sa/r/ n SKNATURE DKTE REVIEWS PEER:
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APPROVED BY:
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N/A ECSP 'hMAGER DATE ~
MANAGER OF NUCLEAR DATE POWER CONCURRENCE (FINAL REPORT ONLY)
- 3RP Secretary's signaturc denotes SRP concurrences are in files.
8701160154 870109 PDR ADOCK 05000327 P
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4 REPORT NUMBERi -
'80402-SQN REPORT TYPE.
REVISION NUMBER:
- Element Report 3'
TITLE:
PAGE 1 0F.9 (Management's Interference in Deviation Reporting o
-1.0~~ CHARACTERIZATION OF ISSUE
-1.1 Introduction
. This f report - pertains ' to ' the - Quality. Assurance Category l Evaluation
. Group's. (QACEG) investigation of 'two (2) employee concerns which were identified,by thet 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 Is' sue The conditions reported by the concerned employees were:
~
a.-
Supervision had ' stopped. corrective. action on' ansidentified>
c.
quality problem.. (SQM-86-002-004 dated-January 24, 1986) t b.
Inspe'etors were not' allowed 'to document deficiencies 'in a programmatic way.- (XX-85-102-010 dated October'21,'1985)
);
p These perca,ived conditions established the bas ic' issue, for the
,~j[
evaluation as:
" Management's Interference in Deviation Reporting".=
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2.0.
SUMMARY
4 i,
-2.f1' Sunnmary of Charad$Erization' of las'ye y
The -issue derived from the employee concerns was:-
Management's Interference in Deviation ~ Reporting..
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2.2 Summary of Ev'aluation Process During the course of this evaluation, Appendix. E to -10CFR50, the TVA NLclear Quality Assurance Manual (NQAM), Sequoygh Standard Practice, I
Quality Assurance a Section Instruction Letters (QA-SILs), Quality Assurance Section Letters (QASLs), Division of Quality Assuran'ce 1
i Instructions (DQAls), Office of Engineering " Operation Instructions
- 3 (OE-01s), and Engineering Office Administrative Instructions (Als), as listed in Paragraph
.4.1, and various memorandums were reviewed to determine' commitments Sand requirements as they applied to SQNP and
~ this issue.
Also, the Employee - Concern Files including the Confidential' File were reviwed for any additional dsta pertaining to this, issue.
That
' review identified two reports:
Nuclear Safety Review Staff (NSRS)
-i Report I-86-185-SQN, dated March 5, 1986 (Attachment < B) and Generic
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REPORT NUMBER:
80402-SQN REPORT TYPE REVISION NUMBER:
' Element Report' 3
' TITLE:
.PAGE 3.OF.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 1 of' their
~ investigation.
1 p
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 Sununary of Findings U'
The results'of the NSRS investigation did-~not substantiate the issue.
?
GCTF's investigation-did substantiate the issue-in part, since
. observations (deviations) were being documented -in the QC Observation
. Log, however QCfSupervision had not initiated follow-up action on some of those.. deviations.
QACEG's investigation. did not reveal any' y
. instances.where. deviations were not properly documented as' required by TVA-directives, and there was no. evidence of 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 -
d interest of' tracking and closing'the GCTF recommendations dealing with:
programmatic ~ improvements, ECSP Corrective Action Tracking Document CATD No. 80402-SQN-01 (Attachment D) was issued.
The CCTF Report recommendation was for QC Supervision to review the QC
'{
Observation Log to assure all conditions entered are adequately y
addressed.
SQN QA Staff comments to that recommendation (dated i]_.
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 A-QACEG investigation also identified as a side issue that the site QA implementing instr.sction 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.
The Site Director responded to CATD-80402-SQN-01, and issued a Memorandum dated November 4,
1986 which identified the proposed t-
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-5, I
REP 0RT NUMBER:
80402-SQN
' REPORT TYPE-REVISION NUMBER:
Element Report ~
'3.
' TITLE:
PAGE.4 0F 9 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)
W..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.
The following documents were reviewed for. requirements and commitments as they pertained to the. issue and were applicable during the concerns time frame:
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 d.
Quality Assurance Instruction - Letter 16.1 " Corrective Action and Adverse Conditions" Revision 15, dated March 31, 1986 including previous revisions 14 and 13.
e.
Quality' Assurance Section Instruction Letter (QA-SIL) 18.1
" Surveys", Revision 11', dated, March 24, 1986 including previous revisions 10, 9, 8, 7, and 6.
f.
Division of Quality Assurance Instruction DQAI-502.
" Surveillance Program" Revision 0,
dated August 30, 1985 and Revision 1, dated August 29, 1986.
g.
Office of Engineering - Operation Instructions OE-OI-3001, Drawing Originals - Checking Out and Checking In, Revision 0 OE-01-4001, Contract Administration - llandling of Vendor Drawings, Revision 0
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n REPORT NUMBER:
80402-SQN REPORT TYPE REVISION NUMBER:
Element Report.
3 TITLE:
PACE 5 0F 9 Management's Interference'in Deviation Reporting OE-dI-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, Qual.ity Assurance (QA)' Manager - Quality Assurance Group ar.d Assistant QA Supervisor.
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' 4'. 2 Specifics of Evaluation The QACEG evaluation' indicated that the NSRS Investigator had 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 perform 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 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, d
- ing observations in the Quality Control (QC) Observation Log".
The. evaluation also included a review of the NQAM, Sequoyah Standard Practice SQM-2, QA Instruction Letter 15.1, QA Section Instruction Letter 18.1, Division of QA Instruction DQAI-502, Administrative 3
Instruction (SQNP) AI-12 which specify requirements for reporting and documenting deviations.
Also, the site QA Organization 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 addit Un, the instruction also states:
"Upon completion of the survey the evaluator shall consult with 2
his supervisor or designated personnel to determine the disposition of proposed findings (e.g. invalid, insignificant, or issue a Corrective Action Report (CAR) or Discrepancy Report (DR) in accordance with AI-12)."
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A REPORT NUMBER:
80402-SQN REPORT TYPE REVISION NUMBEFt
. Element Report 3
TITLE:
PAGE 6 0F 9 Management's Interference'in Deviation Reporting-5.0 -FINDINGS 5.1.-Findings on Issue 5.1.1 Discussion
-A.
NSR.c Lport 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.
The NSRS Report indicated that the Office Supervisor for the Sequoyah Nuclear Plant.(SQN) Engineering Project was appointed to the management position in January 1983.
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 mant,gement.
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 1985 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.
B.
The GCTF report, dated June 6, 1986 conclusion. in part was:
"QA program limiting QC Inspection from properly documenting defects was determined to be valid based on lack of procedural control of the QC Observation Log.
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REPORT-NUMBER:
80402-SQN REPORT TYPE REVISION NUMBER:
Element Report 3
TITLE:
PAGE 7 OF 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:
1.
Nuclear Quality Assurance Manual (NQAM), Part III, Section 7.1, dated December 23, 1985
" Nonconforming 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
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REPORT NUMBER:
80402-SQP REPORT TYPE REVISION NUMBER:
Element Report 3
TITLE:
PAGE 8 0F 9
, Management's Interference in Deviatica 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 Instructicn - 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 alao verified that the documents specified in the above management directives for reporting deviations were being utilized when specified.
5.1.2 Conclusion
[3 As a result of this investigation which included discussions with individuals identified in the NSRS and GCTF reports and the review of those reports, the issue was not substantiated.
This conclusion is based on the following facts:
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REPORT.' NUMBER:
80402-SQN' REPORT TYPE REVISION NUMBER:
-Element Report-3 TITLE:
PAGE 9 0F 9 Hanagement'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,1but was rescheduled until-
.nigher priority items were accomplished.
The audit was initiated in the same month (January 1986) that the concern was received.
It is presently forty.percenti completed.
The QACEG investigation. results substantiated the NSRS conclusions.
B.
It was verified by the QACEG 1 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 QA-SIL-18.1 no longer required the usage of the QC 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 3
Letter describing all aspects of the QC Observation was completed.
Presently, the draf t 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' ATTACHMENTS 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) l
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ATTACIDiENT D
, Page 1 of 6 ECSP CORRECTIVE o
Actior. Tracking Document
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INITIATION n
1.
Immediate Corrective Action Required:./Y_/,Yes /[/ No 2.
Stop Work Recommended: /;/ Yes /Xf.No ~
3.
CATD No.
80402-SQN-01 4.
INITIATION DATE 10/6/86 S.
RESPONSIBLE ORG,AUlZATION:
SQN-QA Staff 6.
PROBLEM DESCRIPTION: /X] QR /;/ NQR Concern XX-85-102-010 QA-31L-18.1 Revision 11 (dated 3/24/86) does not reference (purpose / scope) the "QC Observation Log" use.
This form was deleted in Revision 7, dated 3/30/83 but is still being utilized.
Section Letter describing the purpose and scope of the' QC Observation Log has not been issued as stated in the QA Staff comments identified in Attachment C.
/ /ATTACIDiENTS 7.
PREPARED BY: NAME W. E. Bezanson DATE:
10/6/86 8.
CONCURRENCE: CEG-H R. K. Maxon
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DATE: /o 8G 9.
APPROVAL: ECTG PROGRAM MGR: /V//fu/offe DATE:
/O-7-EG CORRECTIVE ACTION Seeattached(Af6MccANDv4 10.
PROPOSED CORRECTIVE ACTION PLAN:
'S O S S GI o 2 'A 9lF5 DMED O M ~23.19 d M,
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DIRECTOR /My: /3'b /p/ /jftM(tud DATE: p/(//s 11.
PROPOSED BY:
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CONCURRENCE:
DATE:
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VERIFICATION AND CLOSE0UT
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Approved corrective actions have ' been verified as satisfactorily implemented.
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S03 861027 802
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U I El TES GOVEltNMENT Memorandum TENNESSEE VALLEY AUTHORITY To W. R. Brown, Program Manager, Employee Concerns Task Group, ONP, Watts Bar Nuclear Plant ritoM H. L. Abercrombie, Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant DATE November 4, 1986 SUI!J ECT:
SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) ELEMENT REPORT 804.02 SQN - QUALITY ASSURANCE CATEGORf - CORRECTIVE ACTION PLAN (CAP)
Reference:
Your memorandum to me dated October 7, 1986, " Watts Bar Nuclear Plant - Employee Concerns Task Group (ECTG) Element Report 80402-SQN - Review and Disposition of Deviation Reporting" (T25 861007 909)
I acknowledge receipt of your element report and in accordance with your request (see reference). Element Report 804.02 SQN has been reviewed for applicable corrective action.
By way of this memorandum I am endorsing the site line organization CAP, returning your Corrective Action Tracking Document No. 80402-SQN-01, and attaching the CAP for your review / concurrence. This CAP is not a restart requirement.
If you agree with the proposed CAP, please sign the ECTG concurrence space below item 9 on the CAP tracking checklist and return the CAP tracking checklist.
2/U2nN b -
H. L. Abercrombie RCD:JDS:JB:CS Attachments RECEIVED cc (Attachment-):
RIMS, MR 4N 72A-C (S08 861023 833) pTf 3 86 A. G. Debbage, ONP, ECTG Building, WBN Empicyce Cnur; ian 0234T
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- S O S 861023 833 Memorandum TENNESSEE VALLEY AUTHORITY m
R. C. Donney, Employee Concerns Special Project Manager, ONP, DSC-P, Seg TO
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Nuclear Plant W. E. Andrews, Site Quality Manager DQA, O&PS-3, Sequoyah Nuclear Plani.
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OCT 231986 nATe SEQUOYAHNUCLEARPLANT(SQN)-HMPLOYEECONCERNSTASKG SUBJccT:
REPORTS - REPORT 804.02 SQN - REVIEW AND CORRECTIVE AC INITIATION Referance: Your memorandum to me dated October 16, 1986 (S03 861015 801)
In response to the referenced memorandum, attached are the completed trackin checklist. CATD form, and requested attachments.
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W. H.' Endrews JLH:ALV:JMS:RJZ Attachments cc (Attachments):
c HIHS, HR 4N 72A-C G. N. Duchanan, ONP, O&PS-3, Sequoyah - (Please remove activities listed in the referenced memorandum from restart schedule.)
w EFQ;JoVAH tlLICLEAR PLANT H.n.RANXtN MAvter r,t ren ects i
00T 23'86
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~Pags 4 of 6 RESPONSE TO ECTG ELEMENT EVALUATION REPORT 804.02, SQN CAID NO. 80402-SQN-01 Proposed Corrective Action Flan: This CATD was issued to track the incomplete commitment made in response to Concern XX-85-102-010. Therefore, this
- response will only report the status of the commitment and wl11 not propose any new corrective action.
On October 11, 1986, the preparation of the draft section letter describinr_,,
all aspects of the QC Observation was completed. Presently, the draft is being reviewed and should be formally lasued by November 28, 1986.
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Standard Practica Pags 8.
SQA166 Revision 8 Attachment A Page 1 of 2-
' Corrective Action Plan.of Employee Concern Investigation Tracking Checklist
- - To t/o ?, -59N-D I
'ECTG Report /CATD Number M09'02-S 9N C D
-Lead. Organization = Responsible for Corrective Action-Plan
@ u / t//>' A W 44 f^'C f Initiation Date
/o - N-F 4, CORRECTIVE ACTION PLAN (CAP),,
Yes X
No
-1.- Does this report required corrective action?
L(If yes, describe corrective action to be taken, if no,'ptovide justification)
See attached 2.
Identify any similar item / instances and corrective action taken.
N/A
- 3. Will corrective action preclude recurrence of findings?
Yes X
No
- 4. Does this report contain findings that are conditions adverse to quality (CAQ) as defined by AI-12 or NEP 9.l?
YES No X
N/A
- 6. Which site section/ organization is responsible for corrective action?
SON Site QA
- 7. Is corrective action required for restart?
Yes No X
(This determination-is to be made using Attachment C of SQA166.)
- 8. P2 zone number for restart corrective action? Zone N/A
- 9. Estimate completion date for correction action.
11/28/86 Completed By J.M.StitJO77]$2/-
- Date, t o /2 3 / pro Approved By f [ (Z 2 _- Q,A Date so/23/f4 ECTG Concurrence -12E/]/A M V" Date
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Standard Practice Page 9 SQA166 Revision 8 ATTACHMENT A l' age 2 of 2 CAP CLOSURE I
- 10. Was your corrective action initiated and completed in accordance with step 17 f
Yes No
- 11. If step 10 is no, describe the correctiva action taken.
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- 12. Is the corrective action implementation complete?
Yes No
- 13. Is the corrective action documentation closed?
Yes No s,
- 14. What documents were used to implement the corrective action?
i Compl'ted By:
Date e
Verified By:
Date-ECTG Closure:
Date I
(Step No.)
Description t
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