ML20207Q002
| ML20207Q002 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/12/1987 |
| From: | Deangelis J, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207P998 | List: |
| References | |
| 80102-SQN, 80102-SQN-R03, 80102-SQN-R3, NUDOCS 8701210047 | |
| Download: ML20207Q002 (18) | |
Text
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1; TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80102-SQN REPORT TYPE REVISION NUMBER:
Element Report 3
TITLE:
PAGE 1 0F 10
(
Quality Assurance Independence and Authority
?
REASON FOR REVISION:
Revised to add Employee Concern IN-85-767-005.
Revision indicators are shown on each page to indicate revision changes.
Note:
Sequoyah Applicability Only PREPARATION i
PREPARED BY: JOHN J. DEANGELIS hm
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REVIEWS I
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SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
/WOhrAlb l-/2 47 AtA ECSP MANAGIM DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Seretary's Signature denotes SRP concurrence are in files.
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1 REPORT NUMBER:
REPORT TYPE:
80102-SQN Element Report:
REVISION NUMBER:
TITLE:
3 Quality Assurance Independence and Authority PAGE 2 0F 10 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction Tnere are thirteen concerns in the element Quality Assurance (QA) 3 Independence and Authority.
These concerns were grouped into 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, Attachment 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 independence of QA personnel (IN-86-087-002, WBM-86-004-001, Pil-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, 3
WI-85-086-003 and IN-85-767-005).
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 Concerned 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 of audit areas per audit.
The CI assumed this directive would restrict the auditors indepth approach into the activities of the audited organization.
2.0
SUMMARY
2.1 Summary of Evaluation Process 2.1.1 The evaluation process consisted of the review of Employeo Concern files, Quality Technology Company (QTC) and Nuclear
REPORT NUMBER:
REPORT TYPE:
80102-SQN Element Report:
REVISION NUMBER:
TITLE:
3 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 information to assist in the evaluation of this issue.
2.2 Summary of Findings l
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 Issues The lack of depth of QA audits The results of the QACEG investigation indicates this issue was not valid.
Contrary to the Concerned Individual reference to a
November 25, 1985 letter being issued by the Director of QA, the QACEG investigation could produce no evidence of cuch a letter.
The QACEG investigation did,
- however, find a
memorandum from the Director of QA to Branch Managers, dated October 24, 1984, which addressed audits and comments by various site and plant representatives.
The investigation found where audit modules were combined to make audits more comprehensive, 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.
j l
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' REPORT' TYPE:
80102-SQN Element Report:
REVISION NUMBER:
' TITLE:
3
-Quality Assurance Independence and Authority PAGE 4 0F 10 3.0' EVALUATORS D. G. Barlow J. J.--DeAngelis 4.0 EVALUATION PROCESS 4.1 General Methods of Evaluation The evaluation process consisted of researching the Employee Concern Files,- QTC Files,- and NSRS Files to-determine if additional information was available to assist in the investigation of this element.
j Reviews 'were conducted of Regulatory Requirements and Industry Standards together with upper tier documents, such as,. TVA Topical Report and the NQAM, and lower tier documents, such as, procedures and instructions to determine requirements, cosssitments and
)
responsibilities..
QA Auditing Branch Correspondence Files, the QA
)
Audit Schedules and the QA Audit Status Log were reviewed to determine audit activities during the time period 1983 through 1985.
Discussions were held with the former Director of QA, the Branch Chief of the ' Audit Group and the Audit Group Section Supervisor to acquire additional details pertaining to the Audit Group organizational structure and auditor's independence.
]
4.2 Specifics of Evaluation This section describes the specific methodology used in the investigation of the following issues:
4.2.1 Issues The QA organizational structure as it relates to the independence of QA personnel.
The Employee Concern Files and the Confidential Files were a.
researched to determine if QTC or NSRS had investigated and issued a report on this issue.
QACEG's review of the flies indicated NSRS Reports I-85-420-WBN, dated November 19, 1985 and 1-85-805-NPS dated November 18, 1985 were issued and add ressed the independence of the QA Department.
NSRS
- Report, 1-85-420-WBN, was issued specifically for Watts Bar Nuclear Plant (WBN); however, the Employee Concern Task Group (ECTG) has determined this issue to be generically appilcable 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.
I
I REPORT NUMBER:
REPORT TYPE:
80102-SQN Element Report:
REVISION NUMBER:
TITLE:
3 Quality Assurance Independence and Authority PAGE 5 0F 10 b.
Reviewed the requirements of Appendix B to 10 CFR 50, Criterion I; TVA Topical Report, TVA-TR75-1A, revision 8; and the
- NQAM, Part III to determine the approved 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 Issue
The lack of depth of QA audits The Employee Concern Files and the Confidential Files were a.
researched to determine if QTC or NSRS had investigated 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 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 relating to this issue.
5.0 FINDINGS The following findings address both a background discussion and a conclusion of each issue identified in Section 1.2 of the Element Report.
l3
5.1 1saue
The QA organizational structure as it relates to the independence to QA personnel.
5.1.1
Background
This background information is provided to discuss the history of the reporting relationship of the QA Department and the Operation Site Ditector of SQN during the time 1984 throuth 1986.
REPORT NUMBER:
REFORT TYPE:
80102-SQN Element Report:
REVISION NUMBER:
TITLE:
3
. Quality Assurance Independence and Authority PAGE 6 0F 10 In February 1984, the Power Operations and the Engineering and Construction functions were merged into the newly formed organization called the Office 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 of those facilities which they operated.
This concept delegated to the operator the authority, 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
-plants.
Furthermore, each nuclear plant would function autonomously by developing its own programs and systems to control plant activities.
These actions were TVA efforts 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
- document, was accepted by NRC in October 1984 as 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 nucicar plants.
In addition, this report established the position of the Operations QA Manager who maintained a Plant QA Staff at operating plants to perform work functions relative to quality engineering, quality control and surveillance activities.
The Supervisor of Plant QA Staff received functional supervision from the Site 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 use by other organizations.
The QA Audit Branch under the new " Decentralized" structure for SQN was in the transition phase in December of 1985.
A memorandum from the Director of QA to "Those Listed", dated December 12, 1985, indicated that the decentralization of the QA Auditing functions for operating plants had not becn fully implemented at that time.
The results of this investigation indicated the Operations QA Audit Group's plans to decentrallzu never did materialize.
The program to decentralize the audit group ended during the reorganization of the QA Department in early 1986.
c
t REPORT NUMBER:
~ REPORT TYPE:
80102-SQN Element Report:
REVISION NUMBER:
TITLE:
3 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 4
requirement violation.
The term " independence" as referenced in the Code of Federal Regulations 10 CFR 50, Appendix B, Criterion I,
requires that persons and organizations performing QA functions e, hall 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 satisfactority 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 r
operations, has been consolidated under the Director of Nuclear QA.
TVA has developed a standarized Nuclear QA Program described in the revised Topcial 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.
The revised Topical Report has been submitted to the NRC for their review and approval.
Final NRC approval of the Topical Report 1
l revision is still pending at the writing of this Element Report.
9 5.1.2 Conclusion Based on the above evidence, this issue is not valid.
TVA's decision to decentralize the QA Department was part of an t
overall program to decentralize all activities including QA.
This plan was approved by TVA's Board of Directors and NRC in October 1984.
NRC approval of the TVA revised organizational structure also endorses the " independence" as described in Appendix B to 10 CFR 50, Criterion I.
Presently, TVA's nuclear QA/QC functions have been unified under a single department with a consistcot 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.
I s
i I
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REPORT TYPE:
80102-SQN Element Reports REVISION NUMBER:
TITLE:
3 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 former Director of QA we directed our attention to 1984 rather than 1985 since the subject of audit frequency, numbers of auditors on site, and organisations performing audits was a concern to Site 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 other topics) audits and consnents made to the Director of QA by various site and plant representatives on his visits to WBN, SQN and Browns Ferry a
(BFN) during the week of October 14, 1984.
This memo stated under
" Watts Bar" that
" twenty-four audits a
year is considered 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 connnents 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, i
B.
Work closely with the staff and management at each location in aggressively pursuing, planning and scheduling practices that will provide for both an effective audit i
program and minimize unneessary adverso impact on the orgainzations.
I The Director of QA vent on to state that the audit group was required by the Technical Snecification (Tech Spec) requirements to perform a given nuraber of audits (modules) and
t REPORT. NUMBER:
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REVISION NUMBER:
TITLE:
3 Quality Assurance Independence and Authority.
PACd 9 0F 10'
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'that he agreed that a smaller number of audits would lessen the impact at the ~ plants but could still be accomplished effectively.
"By November 30, 1984, we will have a plan which reduces the number of times audit teams appear at'a given location.
This will be accomplished by combining standard audit modules into a given audit."
He further stated... We will strive to work more efficiently and conduct fewer but more comprehensive audits this year while still very effectively addressing the scopes defined 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 modules 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 possible).
Our review of the number of audit modules indicated they did not decrease, however, eight audits envered 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 l
areas in 1985 did not change; however, the number of audits performed at SQN did decrease by three audits.
We also found in our review of the individual 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 employee concern is not valid.
We can only assume that the CI was incorrect in stating that the Director of QA issued a letter dated November 25, 1985 and that he is referring 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 concern to be unsubstantiated.
5.3 Attachment A identified the concerns as being potentially either Sa fe ty-Rela t ed or Safety-Significant.
Stoce the two issues of this report were unsubstantiated, the concerns are not considered to havn an impact on safety.
4 REPORT NUMBER:
REPORT TYPE:
80102-SQN REVISION NUMBER:
Element Report:
TITLE:
3 Quality Assurance Independence and Authority PAGE 10 0F 10 6.0 ATTACHMENTS' A.
List of Employee Concern Information Subcategory:
80102 Quality Assurance Independence and Authority B.
Nuclear Safety Review Staff (NSRS) Investigation Report #1-85-420-WBN, dated 11/18/85.
C.
List of References And Documents Reviewed.
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j HO FURTHER INFORMATI0ll Ill FILE.
l til 090-0 014 QA 80102 H HBil YYYY NS THE DBJECTIVE, AND RESULT OF, THE DI T50252 K-FORIt SSOLUTION OF THE OFFICE OF QUALITY A ' QA PROGRAll t
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DEPENDEllCE OF THE QA AllD AUDIT FullCT l
IDilS, AS TilERE IS HG IllDEPEllDEllCE FR j
OH LIllE HAHAGEMEllT. HUCLEAR P0HER D EPARTHEiti CONCERN. HD FURTHER IliFOR l
HATION IN FILE. CI REQUESTS THIS CO' 1
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.4 NCERN TO BE INVESTIGATED BY QTC.
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i l.' III -8 5-090-002 e QA 30101 H HBil YYYY NS DECENTRALIZATION OF THE OFFICE OF QU QA PROGRAN T50252 K-FORil ALITY ASSURANCE AGGRAVATES AN ALREAD ORGAllIZATIDH l
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-QUALITY l
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TVA LINE HAHAGEHEllT H GEllERAL AS Ho CollCEPT OF THIS FUllCTION, AllD -
DOES NOT INTERREL ATE THE REQUIREHEllT 1
S OF 10 CFR 50, APPENDIX 'B, CRITERI A i
III, IV, VI-AND VII.
NUCLEAR Poller DEPARTHENT CONCERN.- NO FURTHER INF-i I
ORMATIDH IN FILE, CI REQUESTS THIS-
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CollCERN TO BE IllVESTIGATED BY QIC.
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CONCERN KEY 110RD C HUMSLR CAT CAT D LOC FLQB REPORT R. DESCRIPTION KEYl10RD D XX 113-001 7 QA 80102 N SQN YYYY I-85-805-694 SS SEQUOYAHi TVA CORPORATE HAllAGEMENT I QA PROGRAll 150146 K-FORM S IN Tile PROCESS OF DECENTRALIZING T llullC0!!FURHANCE b
HE QUALITY AUDIT PROGRAM IN AN EFFOR QUALITY l
T TO REDUCE THE AUDIT PROGRAHS IllPAC CONST HAllAGEHEHT T DH TIIE STARTUP AllD OPERATIUH OF Til E HUCLEAR PLANTS AND AL Su 10 INTIMID ATE AUDITOR PERSollHEL Titus SIGNIFICA HILY REDUCING THE EFFECTIVENESS OF T VA'S QUALITY VERIFICATI0H PROGRAH.
HUCLEAR P0HER CONCERil. CI IIAS llu FU RTHER INFORMATI0ll.
L XX 116-011# QA 80101 S SQil YYYY SS SEQUOYAH - HAHAGEHENT (KHolilO COMPL A Il0llCollFORilANCE 150271 QA 80102 K-FORM IHED 10 THE DIRECTOR OF THE DIVISION AUDIT OF QA ABOUT AUDITS HHICH HERE TO IN QUALITY
-DEPTil. THE DIRECTOR OF QA ISSUED A REPORIS LETTER 11-25-85 TO AUDITORS DIRECTI HG 1 HEN TO INCREASE THE HUMBER OF AU DIT AREAS PER AUDIT, THUS EFFECTIVEL Y RESTRICTING THE DEPTH OF THE AUDIT 5.
HUCLEAR P0HER CONCERN. HQ ADDIT 7
10NAL INFORMATI0H AVAILABLE. CI REQ UESTS THAT QTC PERFORM THIS INVESTIG ATION.
t XX 118-001 8 QA 80102 H NPS YYYY I-! 5 a 42
'"'S SS CI STATED THAT THE GIVING OF THE HUC QA PROGRAM 150204 K-FORM ft M LEAR QUALITY ASSURANCE HAHUAL AUDIT AUDIT FUNCTION TO THE INDIVIDUAL PLANT SIT QUALITY pd 88 g
ES AND SITE DIRECTORS HILL REI,UCE TH GEllERAL e
E EFFECTIVENESS OF THE PROGRAM, llILL ELIMINATE IllDEPENDENCE, AND HILL SU BJECT AUDITORS (QA SPECIALISTS) TO S EVERE HARASSHENT AND INTIMIDATI0ll.
HUCLEAR P0HER CONCERN. CI HAS HD FU-RTHER INFORMATIon.
/ XX 119-001 6 QA 80102 H HPS YYYY I-S S ^ % :T";-
SS THE DECENTRALIZATIoll DF THE ' AUDIT PR QA PROGRAM 150205 K-FORH OGRAM HILL CAUSE THE INDIVIDUAL PLAll H0HCONFORHANCE T SITES TO EFFECTIVELY DIMIllISH IN T QUALITY HE AUTHORITY AND ORGANIZATIDHAL FREE GEHERAL DOM TO IDENTIFY AHD REPORT QUALITY P
.)
RDBLEMS. NUCLEAR Poller COHCERN, CI is
'/9/E7 HAS Ho FuRTHER IHr0RMATIDH.
T COHCERHS FOR CATEGORY QA SUBCATEGORY 80102
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-ATTACHMENT B Page 1 of 4-TErJrJEEEEE VALLEYJAUTHDRITY rJUCLEAR SAFETY REVIEW ETAFF t
NSR5 INVESTIGATIOfJ REFDRT NO..I-E5-420-WBN-EMPLOYEE CONCEF:N IN-E6-OE-000 ~
MILESTOf1E 5 J
.EUEFICT:
GA INDEPElJDEr4CE A140 PLArJT ATTITUDE
. DATES C IrJVESTIGATIDfJ:
Octsber I E-rJovemb er 10. i?S5
_EAD IrJVEETIGATOR:
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1JFROVED BY:
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ATTACHMENT B
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--e Page 2 of'4 cACnGROUND T(
/2 g M NERS. has : nvesti gotad Emcl oyee ' C.cncern --IN-Ba 057 0
'by'Ouality Technology Company on August'I?.
02 wh2ch was recelvec 19C3 wh;ch
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ctatec:
TVA OA department 'is not
- lant_ management.to perform asc:gnedsuf ficiently indepenoent l
of f unctions in a proper manner.
.by plant-management.OA department. management does as cirected WBNP management functions, negative emoloyee attitude regarding subject creates and sussorts DA ceoartmental which i s not good for the plant.
concern.
Nuc, lear Power i.
- 12.
ECOPE
[L Locumentaticn related to the cuality assurance
.and ressonsibilities was researched tc establish th functicns, duties.
. (OA)
I, i ncac encenc'a. for reporting chains and res e TVA recuirement for
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managsment contrci s on. ouali ty assurance. ponsi b fiti es, anc for NRC. and Division cf Assurance emcicyees -erePl ant emol cyees. ~ manag Quality cetermine actual performance of interviewee to the onsite OA organication.
I Lt,. - EUM:1ARY OF FINDINGE A.
1 OA Decartment Not Incependent L
of Plant Management There are no documented recuirements f or site management.
The Coce of Fedenal DA ince endence from plant' B,
states:-
Regul ati ons, ICCFR5
.Appencin "Organications cerf orming quality assurance +0 shall report 3
to a management l evel such uncti ons anc organicational freedom. including.sufficientthat 'thi s recuirec authority coct. and schedule when opposed to saf ety consideratiindependence from crevi ced.
ons. are the organicational structure for assurance program may take various f orms provided thenecuting the quality
.and recuired authority andorganications assigned the cuality assurance f unction at the persons organic ati onal freecom."
The s have this
-identif y quality oroblems;f reecom ref errec to in the above quote t
euthority and to initiate, to the ability to sol uti on s; and to verif y impl ementation ofrecommend. or provide sol uti ons.
In interviews with a cross-section of ten management. Di vi si on of Onl y one indicated Quality Assurance, individual s f rom plant NRC. and plant employees i
above.
any prcblem with Thi s 'indi vi dual DA indepencence as defined
-identified se brought believes that dominance plant to management cuality center'ns may not be attention because of i
management has over CA the identifisc that management.
i related to the perf ormance of No problems were
}
plant GA (f unctions defined f uncti ons assi gned in TVA Toolcal Report. Sec ti on 17.0.2.1.0).
One ce to the OA suoervi sor's peers beli eves that 3snues would be raised by a strenger more beliEve that OA orcserl y ioentifioc. personality.
All cthers correcti cn cf CA problems.
recommenac, and c h e c l's crocram at Wstts E.er The e i s a general i s imoroving as time goes byf eeling that the OA several months One eerson since the appointment and has been for of i n t er vi e,we,d, b e l i e ved the present DA sucervi sor.
p oi n t that it thould be yet.
that DA has not progresced to the L'
m s.
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ATTACHMENT B
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i Ee:ti n 17.0.0.!: ' "The c:ts darseter is rece nn:-Is fer the cuality-
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Th e M,O AF.. Fsrt 1.
Sect:en 0.1.
.earagrach.4.4 s,tc;33
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l sucl::V assurance staff :s rencensicle t -serform su=lity eng: nearing. cualit.
- ntrol. &nd surveillonce f untt:cns to assi st the ci te ::rectorc i n achi evenient of cuality."
Als: Far&Orash 4.4
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ne ergtn;:at,.cn &nd
-.o om uses the w=-
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m... y e m e.... " "4eems
' ant man &gement adv Bed of." and "thr ugh line &&nagEment."
The Organi:& tion now in force has the OA sussevicer tal:ing functi nal dirc:tien*from the cats tiractor.
This a r. A n g s.T.E n - is in KEED:ng with tnE MCAM &nd T*.'A 70 10&1
.C. G r.
Theref re, tha slant GA desartment management doen and is recu: red to.taka cirecti:n from cita managament.
a.
M__a n_ a.. ze m e n t ' O r a z.~s c r a n d-----Et:
o e
L Scrt_n Nrest'v=---a--u-- Attituda-------- Re:
_-------u-din:---- Oa Ar C U.0-*O
zL-ns No avidance of ns;&tive attitudes was shewn in the cersennel 4
in:Erviewed.
The same individual that indacendenta believes that morale and e::orensed reservations over at*itude t: ward DA are not gt:d.
- However, there is avidants that the OA organi:stien is being use: m::t an si val v.
The trend t ward using OA as a t:cl i s gr: wing and bring encounagsd by slant management.
Plant mcnagement stated that they may be using DA f or merg sress of work than they shoule.
O:1. i cns E::=rersad by Clant Euservi zien were ges: Centerning the wert sene by OA en surveill anca instruct; n revi sw.
"O" list review.
End Otner s:scial Or Je ts handled.
D*
C23
= - 2 = s* s' a' s u z a= a= u dE='-u"sumea=u2ua' Thi s amoleyee : n=ern had &n imoliad : n=sen over the ef f ecti veness Of the t:0 OA ensite mtnagement.
Intervient with managers indica e tht; the CA man &qsr is &n antivtical yce.ndividual.
He is very careful :: ensure that Orrect wori: i s being cut out.
This tendency on his cart gives the imoreraien t some Of his cutordinates that he i s withhslding er b=ttlenecking Cuali*v issues.
NSRS Recert NO.
1-SE-401-WBN documents some creblems En:Cuntered with the CAR /DR svrtem of recor*ing deficiEncias that were originated bv the OA managsr's coli ci es.
H wever, there is no evidence of the celiberata withhelding of aefic:encies.
The OA manager rsca:vsd high crA:se fr:m nLits management, downtown
'OOA) msnAgement. an: a majority of the suborcinates interviewed.
It is balisvrd that he is d.irEctly rates Lible for devel:Cing &
- Ei ti ve cite attitucc scout OA.
One cersen interviewed believes that ths OA manager's eersonal:ty nee:s te be strenger so that he Can stand us &nd Lav "N="
- f nEccEsary.
S
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COtJC'.USIOrJS AtJD FeECOMMENDATIOtJE CEn?.l.MEL90.5 The majority of this-. allegation is unsubstantiated.
The cart of the contesn that_.. states that "OA msnagement does as directed bv. plant management" i s true.
However, f uncti onal directicn by site management i s ar. crgant:stional and upper-tier document requirement.
'The reasons for unsubstantiation of the remainder of the concern f ollow.
A.
The Ccde of Federal Fiegul ation s def i nes. independence.
T'*A do:uments and intervi ews with personnel do not indicate personnel
=r orcaniz ati on viol ati on of thi s definition or concern over the perfcrmance of assigned iun:tiens.
3, Attitudes at Watts Bar concerning the use and effectiveness of the
'rgani stion are panerally positive.
Use'of the OA organization OA o is en:curaged by site management.
Plant sumervisors use the OA organi:sti on e::tensively.
C.
CA management is given high.Tarks by both site and downtown DOA management and by a majority of subordinates intervi ewed.
R_e _ c.m._m_e _n _c _a _t _i.o.n..s.
None.
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,v ATTACHMENT C References
' A.~.
TVA Topical Report, TVA-TR75-1A, Revision 8 B.
cCode of Federal Regulations, 10CFR50, Appendix B C.
-Memorandum from the Diredtor of QA to' Branch Managers dated-10/24/84~
6 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 Qua'lity Assurance Audit Status Logs,-Fiscal years 1983, 1984, and 1985' G.
t 4
0 4
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