ML20214J161
| ML20214J161 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/13/1986 |
| From: | Mann J, Russell J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214H850 | List:
|
| References | |
| 80404-SQN, 80404-SQN-R02, 80404-SQN-R2, NUDOCS 8612010179 | |
| Download: ML20214J161 (7) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80404-SQN REPORT TYPE REVISION NUMBER:
Element Report 2
TITLE:
PAGE 1 0F 6 Program Implementation REASON FOR REVISION: To incorporate comments by TAS and SRP.
Re-format in accordance with Writer's Guide.
Revision indicators are not shown on each page as the re-formating entailed a complete rewrite.
Note:
Sequoyah Applicability Only PREPARATION PREPARED BY:
J. E. Mann O
h 7 SIGNATURE DATE REVIEWS PEER:
A N
$1GNATURE 6ATC
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TAS:
ll $ h SIGNATURE DATE CONCURRENCES
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//-/2-84 SRP :
SIGNATURE DATE IGNATURE*
DATE APPROVED BY:
Y b)
Y'lb"$.
N/A ECSP '$0iAGER DATE MANAGER OF NUCLEAR DATE POWER CONCURRENCE (FINAL REPORT ONLY)
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- SRP Secretary's signature denotes SRP concurrences are in files.
8612010179 861117 PDR ADOCK 05000327 p
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TVA EMPLOYEE CONCERNS REPORT NUMBER h
SPECIAL PROGRAM 80404-SQN l:
REPORT TYPE REVISION NUMBER:
Element Report 2
TITLE:
PAGE 2 0F 6 Program Implementation
{.
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1.0 CHARACTERIZATION OF ISSUE 1.1 Introduction This report pertains to the Quality Assurance Category Evaluation t
Group (QACEG) investigation of an employee concern which was identified by Quality Technology Corporation (QTC) during the Watts Bar Employee Concern Program.
This issue was evaluated at Sequoyah Nuclear Plant (SQNP) because it was determined to be generically
. applicable to all TVA nuclear plants.
1.2 Description Of Issue The basic issue raised by the concern is the timely is suance of discrepancy documentation.
The concern states that Corrective Action j
Reports / Discrepancy Reports (CARS /DRs) are not issued in a timely T
manner.
The concerned individual (CI) stated that the process whereby CARS are issued has taken in excess of three (3) months. (IN-86-090-002 and IN-86-087-003) 1 2
l 2.0
SUMMARY
t 2.1 Summsary of Characterisation of Issue g
d H
The' issue derived from the concerns is the tin.ely issuance of 1
discrepancy ' documentation.
Although this issue was originally addressed at Watts Bar Nuclear Power Plant (WBNP) by the Nuclear Safety Review Staff (NSRS),
this report describes the QACEG s/
investigation at SQNP.
Jq d
2.2 Summary of Evaluation Process il4 During the course of the investigation, Appendix B to 10 CFR 50, 17A j
Topical Report TVA-TR75-1, the Nuclear Quality Assurance Manual G
(NQAM), Administrative Instructions (AIs), Staff Instruction Letters l.
(SILs), CAR /DR Logs, Corrective Action Report Number NCO-CAR-86-017-R, 1
and various memorandums were reviewed to determine coussitments as they 3'
apply to SQNP.
In addition, discussions were held with the CAR /DR d
Coordinator at SQNP regarding timely issuance of CARS /DRs.
The Employee Concern File (including the Confidential File) was reviewed for additional information pertaining to Sequoyah; no specific information relating to SQNP was found.
2.3 Susenery of Findings s
The results of the NSRS Investigation Report Number I-85-424-WBN substantiated this issue at WBNP;
- however, this issue is not f
substantiated at SQNP.
The QACEG investigation did not revent any L
A-TVA EMPLOYEE CONCERNS REPORT NUP.BER:
SPECIAL PROGRAM 80404-SQN REPORT TYPE REVISION NUMBEIL:
Element Report 2
TITLE:
PAGE 3 OF 6 Program Implementation instances whereby Conditions Adverse to Quality (CAQ) are identified i
and CARS /DRs issued has taken in excess of three (3) months. Although Appendix B to 10 CFR 50 is not specific relative to time frames as to j
issuance of CARS /DRs, SQW-QA-SIL-16.1,
" Corrective Actions and Adverse Conditions", establishes appropriate time frames for the 1
processing of CARS /DRs. A review of the CAR /DR Logs at SQNP indicated 4
that CARS /DRs were initiated promptly and issued in a timely manner.
l 3
3.0 LIST OF EVALUATORS
'}j J. E. Hann l
ij 4.0. EVALUATION PROCESS l
4.1 General Methods of Evaluation k
Researched the Employee Concern File (including the Confidential File) k for additional information pertaining to Sequoyah.
Ihe basic centents l
of the file were the K-Form and NSRS Investigation Report Number I-85-424-WBN for Watts Bar.
No specific information relating to SQNP was found.
Reviewed the following documents to determine the requirements and commitments at Sequoyah:
a.
Administrative Instructions, AI-12,
" Adverse Conditions and Corrective Actions", Revision 23, dated 7/25/86.
b.
Nuclear Quality Assurance Manual (NQAM), Part III, Section 7.2
" Corrective Action" 1
c.
Appendix B to 10 CFR 50 d.
SQNP Quality Assurance - Staff Instruction Letter - 16.1 (QA-SIL-16.1), Rev. 16, " Corrective Actions and Adverse Conditions".
N e.
CAR /DR Log, SQNP (January 1985 - August 1986) f.
Memorandum, R. J. Mullin to W. E. Andrews, 3/4/85, " CARS and DRs
- Gcals and Objectives" (LO4 850306 296)
J g.
Memorandum, R. J. Mullin to W. R. Lagergren, 3/4/85, "DQA Input for Area Plan" (L99 850402 002) h.
Memorandum, R.
J.
Mullin to "Those Listed", 3/5/85, "Important Quality Problems in NUC PR and Quality Problem Resolution Summary" (L99 850402 001) i.
Memorandum, W. E. Andrews to J. E. Law, 3/29/85, "NQAM, Part III, Section 7.2 -- Proposed Revison" (LO4 850329 829)
Memorandum, W. E. Andrews to R. J. Mullin, 3/29/85, "All Plants -
-DQA Action Plan Outline on Handling of CARS" (LO4 850239 830) k.
Memorandum, W. E. Andrews to "All Plants", 1/21/86, " Handling of CARS /DRs" (LO4 860121 885) r 1.
Corrective Action Report (CAR) Number NCO-CAR-86-017-R.
!~
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80404-SQN REPORT TYPE REVISION NUMBER:
Element Report 2
TITLE:
PAGE 4 0F 6 h
Program Implementation
~
Discussions were held with the CAR /DR Coordinator at SQNP pertaining to the timely issuance of CARS /DRs.
This issue has been determined to be applicable to all TVA nuclear plants that are required by the NQAM to utilize the CAR /DR system and will be evaluated at those plants.
Investigation results at other plants will be contained in their applicable Subcategory and Category reports.
T 4.2 Specific of Evaluation i
1 The basic requirement for the Corrective Action Program is derived from Appendix B to 10 CFR 50 which requires that conditions adverse to j
quality be promptly identified and corrected.
In addition, TVA established the Corrective Action Program in the NQAM and y
Administrative Instruction AI-12 at Sequoyah.
Specific implementing instructions are prescribed in SQNP-QA-SIL-16.1.
This instruction establishes appropriate time frames for processing CARS /DRs.
It should be noted that the time frames outlined in QA-SIL-16.1 are goals i
(not mandatory) to ensure that potential conditions adverse to quality (PCAQ) are reported in a timely manner.
{
In order to strengthen the program at SQNP, the Site Quality Assurance Manager issued a memorandum (" Handling of CARS /DRs" - LO4 860121 885),
dat'ed January 21, 1986) which established guidelines for the timely processing of CARS /DRs.
The following specific guidelines for the processing of CARS /DRs were provided:
1 a.
Immediately assign a unique tracking number within one (1) working day in order to maintain tracability.
b.
Within 10 working days or 14 calendar days of the receipt date of I
a draft CAR /DR:
- 1. Complete and document the evaluation for CAR /DR criteria and determine significance or insignificance.
- 2. If significiant, send a
copy to Compliance for their evaluation of reportability.
- 3. Feed back the results of the evaluation to the employee who initiated the draft CAR /DR.
- 4. Issue the CAR /DR or void with traceability to the documented evaluation.
These guidelines were implemented January 31, 1986.
Discussions with the CAR /DR Coordinator at SQNP indicated that he is cognizant of the guidelines.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80404-SQN REPORT TYPE REVISION NUMBER:
Element Report 2
TITLE:
PAGE 5 0F 6 Program Implementation 1
5.0 FINDINGS i
5.1 Findings on Issue 5.1.1 SQNP Specific I
Discussion The issue of timely issuance of discrepancy documentation derived from an employee concern that was originally addressed to the Watts Bar Nuclear Plant.
A determination was made that the issue was generically applicable to all TVA nuclear plants, therefore, the issue was investigated at Sequoyah.
The Nuclear Safety Review Staff conducted an investigation of the issue at Watts Bar; however, the investigation report does not apply to Sequoyah and is not included as part of this report.
Although federal requirements and upper-tier TVA QA Program document 2, such ao Appendix B to 10 CFR 50 and NQAM, are not specific relative to time frames for the issuance of CARS /DRs, SQNP-QA-SIL-16.1, establishes appropriate time frames for the processing of CARS /DRs at Sequoyah.
[
During the QACEG investigation at SQNP, the ' CAR /DR Logs for i
the period January 1985 - August 1986 were reviewed to i
determine if the CARS /DRs were issued in a timely manner.
The a
review indicated that the average time between reporting a i
CAR /DR and issuing the CAR /DR was 14.16 days; the longest case l
took 46 days to issue.
This was not due to reluctance or F
hesitancy to issue the CAR /DR, but an effort to ensure that l
the CAR /DR was clear and accurate.
Since the logs do not j
indicate how long it takes to prepare a draft CAR /DR once a
?
problem is found, discussions with the CAR /DR Coordinator
)
indicated that this had not been a problem to the best of his j
knowledge.
I Conclusion ii Although the NSRS Investigation substantiated this issue at Watts Bar, it is not substantiated at Sequoyah.
}
The investigation did not reveal any instances where it has taken in excess of three (3) months to identify and issue j
CARS /DRs as stated by the concerned individual.
A
]
Some of the process times may extend beyond the guidelines
]
established in SQNP-QA-SIL-16.1 and may appear excessive.
However, such time lags were considered acceptable since the t
I TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80404-SQN REPORT TYPE REVISION NUMBER:
Element Report 2
TITLE:
PAGE 6 0F 6 Program Implementation average time between reporting a CAR /DR and issuing a CAR /DR was 14.16 days.
Time differences occured when efforts were expended to ensure that adverse conditions were clearly, accurately and completely described.
Adequate guidelines are in effeet at SQNP to assure that conditions adverse to quality are promptly identified and i
corrected.
l Failure to meet time commitments regarding processing of I
CARS /DRs could be a valid basis for a safety concern; however, there was no violation at Sequoyah.
I 6.0 ATTACHMENTS A.
List of Employee Concern Information W
kAN f**'~'l EFEREllCE
- ECPSIROJ-ECPSI2IC TENNESSEE VALLEY AUTHORITY PATE IEQUEllCY
- REQUEST OFFICE OF NUCLEAR POWER RUN TIME - I2: FMP EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE - 10/(J iP - ISSS - RHM LIST OF EMPLOYEE C0flCERN INFORMATI0tl i
7 ;]
TEGORY: QA QA/QC P.".0GRA!;5 SUBCATEGORY: 80404 PROGRAM IMPLEMENTATION S
GENERIC KEYHORD A H
APPL QTC/NSRS P
KEYHORD B e
CONCERN SUB R PLT BBSH INVESTIGATION S
CONCERN KEYHORD C
.-}
NL'MBER CAT CAT D LOC FLQB REPORT R
DESCRIPTION KEYNORD D 1 090-002 QA 80404 fl HBN YYYN I-85-42I-NBN SS CAR'S/DR'S ARE NOT ISSUED IN A TIMEL RECORD GENERATION T50120 K-FORM Y MANNE
R. PROCEDURE
FOR CAR'S (A.I.
HONCONFORMANCE C 4A 7.3) PROVIDES FOR A DRAFT CAR TO G0 GENERAL el.a !
THE INITIATOR'S SUPV, TEN TO THE AFF REPORTS WS
}
ECTED ORGANIZXATION, THEN BACKTO THE CJM INITIATOR FOR " FINAL DRAFT" BEFORE
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@4 l
TYPING. THIS PROCESS HAS TAKEtt IN E XCESS OF 3 MONTHS TO GET A CAR ISSUE U/N D.
EXAMPLES GIVEN TO QTC HITHELD DU QL'c p
E TO CONFIDENTIALITY. CI HAS NO ADD ITIONAL INFORMATION. NUCLEAR POWER CONCERN. UNIT I & 2 SYSTEMS-VARIOU I."I S, NON-SPECIFIC TIME _ FRAME _DNGOTHG-r.
-~
l 08/-003 QA 80401 N HBil YYYH I-85-424-HBN SS CORRECTIVE ACTION REQUESTS (CARS) AN RECORD GENERATION LJ, T50120 K-FORM D DEFICIENCY REPORTS (DRS) ARE NOT I NONCONFORMANCE I,% -
SSUED IN A TIMELY MANNER, WHICH ADVE GENERAL 7+?
RSELY AFFECTS PROGRAM EFFECTIVENESS.
REPORTS 1X CI EXPRESSED THAT THE DELAYS ARE D yh UE TO MANAGEMENT'S (KN0HN) RELUCTANC W'fE'"H E TO DOCUMENT SIGNIFICANT CONDITIONS y.
E ADVERSE TO QUALITY. AN EXAMPLE PRO V -;'.
VIDED HAS THE CAR ON THE CSSC "Q",LI ff.'K ST, WHICH HAS HRITTEN IN FEBRUARY A ND NOT ISSUED UNTIL JULY OR AUGUST.
- 7. R /
t w.
CI STATED THAT THIS HAS A COMMON OC E';Alf
" 'i CURRENCE ON THESE TYFES OF DOCUMENTS e
FURTHER DETAILS KN0H TO QTC, Wl-h:[ i:I f,~ '.O "4
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