ML20214Q711
| ML20214Q711 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/18/1987 |
| From: | Bezanson W TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214Q673 | List: |
| References | |
| 80101-SQN, 80101-SQN-R07, 80101-SQN-R7, NUDOCS 8706050125 | |
| Download: ML20214Q711 (18) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80101-SQN
' REPORT TYPE REVISION NUMBER:
Element Report 7 TITLE: PAGE 1 0F 16 Quality Assurance Program Adequacy REASON FOR REVISION: Revised to incorporate NRC comments.
Revision indicators are shown on each page to indicate revision changes.
Note: Sequoyah Applicability Only PREPARATION PREPARED BY: WILLIAM E. BEZANSON
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N/A DATE MANAGER OF NUCLEAR POWER DATE
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, l REPORT NUMBER:
El.EMENT TYPE: 80101-SQN Elemtnt Report REVISION NUMBER:
TITLE. 7 Quality Assurance Program Adequacy PAGE 2 0F 16 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction This report reflects the results of the Quality Assurance Category Evaluation Group (QACEG) investigation of six employee concerns which were identified by the Tennessee Valley Authority (TVA) Watts Bar Employee Concerns Special Program. These concerns were evaluated for the Sequoyah Nuclear Plant (SQNP) as two concerns were determined to be Sequoyah specific with the remaining concerns designated as generically applicable to SQNP.
1.2 Description of Issues The conditions reported by concerned employees (Attachment A), and as noted below, were grouped by issue under this element since they pertain to the adequacy of the Quality Assurance (QA) Program at SQNP.
1.2.1 Issue - Excessive Paperwork and Procedures In the process of emphasizing the importance of " Quality", TVA has interpreted quantity as the meaning, e.g., excessive amount of paperwork and procedures (Concern BFM-86-002-001, dated January 17, 1986)
Amount of procedures and paperwork is the principle concern at Sequoyah not the quality of work. (Concern MRS-85-001, dated June 23, 1986) 1.2.2 Issue - Procurement Requirements Not Invoked TVA Material suppliers are not required to invoke QA requirements on sub-tier suppliers. (Concern IN-86-Oll-003, dated November 12, 1985)
Power Stores / Nuclear Plant Power Operation procurement process (Nuclear Quality Assurance Manual (NQAM), Part III, Section 2.1) does not assure applicable requirements (regulatory, design bases, qualification etc.) are being met. (Concern OE-QMS-1, dated July 26, 1986) 1.2.3 Issue - Nuclear Qual *ity Assurance Manual Requirements Not Complied With TVA Nuclear plants are ignoring the QC Program from the Nuclear Power Office (NQAM) and are writing their own program.
(Concern WBM-86-004-002, dated January 24, 1986)
REPORT NUMBERt ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER:
TITLE: 7 Quality Assurance Program Adequacy PAGE 3 0F 16 1.2.4 Issue - Management Pressure is Restricting The Audit Functions Quality Assurance Management pressures auditors to close audit deviations before the auditor is satisfied that adequate corrective action has been implemented. (XX-85-116-008 dated February 21, 1986)
These perceived conditions noted above established the basic element for this evaluation as " Quality Assurance Program Adequacy".
2.0
SUMMARY
2.1 Summary of Characterization of Issue The employee concerns were grouped into the element of " Quality Assurance Program Adequacy" because the conditions specified in those concerns pertain to the adequacy of the Quality Assurance (QA) Program being implemented at SQNP.
2.2 Summary of Evaluation Process During the course of this evaluation, Appendix B to 10CFR50 and the following TVA documents were reviewed to determine requirements and commitments as they apply to SQNP and this issue: Final Safety Analysis Report (FSAR), Nuclear Quality Assurance Manual (NQAM),
Sequoyah Nuclear Plant Administative Instructions (Als), Sequoyah Quality Control (QC) Program, Division of Quality Assurance Instructions (DQAIs), Office of Engineering Operation Instructions (DE-01s), Engineering, Design, Contruction, and Quality Assurance Procedures (QAFs), Quality Assurance Audit Reports, and various memorandums and letters.
Also, the Employee Concern Files including the Confidential Files were reviewed for any additional data pertaining to this issue. The results of that review indicated two reports (Nuclear Safety Review Staff (NSRS) Report and a Generic Concern Task Force (GCTF) Report) had been issued and pertained to this element. These reports were reviewed by QACEG to determine the scope and investigation results.
In addition, the evaluation process included discussions with Quality Assurance Auditors, Quality Supervisors, Quality Branch Chief, Section Supervisor -
Audit Branch, Past Director of Quality Assurance, Environmental Qualification Project Engineer, Manager of Nuclear Engineering Employee Concerns, and Manager of Operation Engineering Services regarding the Quality Assurance Program adequacy for SQNP.
2.3 Summary of Findings The issue of " Excessive Paperwork and Procedures" was substantiated
REPORT NUMBER ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER:
TITLE: 7 Quality Assurance Program Adequacy PAGE 4 OF 16 and is addressed in TVA's Nuclear Performance Plan dated March 19, 1986.
The issue of " Procurement Requirements Not Invoked", was substantiated in part (Employee Concern OE-QMS-1). This conclusion was based upon QACEG's review of documented problem conditions in the TVA Procurement Program at Sequoyah e.g. NSRS Report, Corrective Action Report and memoranda from the Manager of Nuclear Power.
The issue of " Nuclear Quality Assurance Manual Requirements Not Complied With" was unsubstantiated as the QACEG investigation found no evidence where the Sequoyah site was ignoring their Quality Control Program or that it did not comply with the intent of the NQAM.
The issue of " Management Pressure is Restricting the Audit Functions" was unsubstantiated. QACEG investigation indicated auditors were delinquent in closing audit findings in a timely manner. However, no documented evidence was identified to indicate auditors were pressured to close audit findings.
2.4 Summary of Corrective Action The issues " Excessive Paperwork and Procedures" and " Procurement Requirements not Invoked" were substantiated.
Prior to the QACEG evaluation, the Manager of Nuclear Power had assigt.ed the Division of Nuclear Services to prepare corporate level nuclear standards for developing directives and procedures for each of the headquarters departments. These standards will be used to evaluate and revise all existing nuclear procedures on a site-by-site basis, The action taken by TVA Management pertaining to the issue
" Procurement Requirements Not Invoked" was to:
- a. Revise the NQAM and Sequoyah Site Standard Practice SQA-45.
- b. Staf f a core of trained procurement groups,
- c. Establish responsibilities for procurement of permanent and safety-related spare and replacement parts and to assess those items installed or in storage for compliance with established requirements.
Management has revised the HQAM and SQA-45, also a core procurement group has been established at SQN. The responsibility for procurement has been assigned to the Design Nuclear Engineering (DNE) Division.
They are presently in the process of assessing the material / parts installed or in storage for compliance with the program.
REPORT NUMBER:
ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER:
U 7 TITLE :
Quality Assurance Program Adequacy PAGE 5 0F 16 3.0 LIST OF EVALUATORS
,D. G. Barlow W. E. Bezanson J. J. DeAngelis t
4.0 EVALUATION PROCESS 4.1 General Method of Evaluation The evaluation process consisted of researching the Employee Concern Files, including the Confidential Files, Nuclear Safety Review Staff Files and the Generic Concern Task Force Files to determine if additional data was available which could be utilized in the investigation of this element. The basic contents of those files were the K-Forms (document used for recording employee concerns), NSRS Investigation Report, GCTF Investigation Report, and various memoranda and letters which pertained to the employee concerns and these issues.
Reviews were also conducted of the Federal Regulatory Requirements,
! TVA upper tier documents such as the Final Safety Analysis Report, Topical Report, Nuclear Quality Assurance Manual, Audit Reports, and Nuclear Performance Plan. In addition, lower tier documents such as site standards, procedures, instruction letters, and memoranda were reviewed to determine requirements, commitments and responsibilities.
The review and evaluation of the above documents and discussions held with cognizai:t personnel established the basis for the conclusions reached in this raport.
4.2 Specifics of Evaluation 4.2.1 Issue - Excessive Paperwork and Procedures The research of Employee Concern Files including the Confidential Files for any additional data pertaining to this issue indicated none was available.
TVA's Topical Report TVA-TR75-1A, Revision 8, dated October 12, 1984, and Appendix B to 10CFR50, dated Janaury 20, 1975, specify the requirements for a documented program to be established. The program requires that procedures and paperwork be generated.
TVA's Nuclear Performance Plan (Report submitted by TVA Management to the Nuclear Regulatory Commission (NRC) which defines TVA's Nuclear recovery program) dated March 1986 was also reviewed as it describes management action on this issue.
REPORT NUMBER:
ELEMENT TYPE: 8010 -SQN Element Report REVISION NUMBER:
TITLEt 7 Quality Assurance Program Adequacy PACE 6 0F 16 Personnel interviews and discussions were not deemed necessary by QACEG as the Employee Concerns (as written) are basically the employees' opinion end were non-specific as to requirements, programs procedures, documentation or groups involved.
4.2.2 Issue - Procurement Requirements Not Invoked Reviewed the Employee Concern Files, including the Confidential Files, for any additional data pertaining to this issue. The results of that review indentified additional information in the form of a NSRS Report (R-84-17 NPS) and memorandums which were utilized in this evaluation.
The following documents were reviewed for information and requirements pertaining to this issue.
Appendix B to 10CFR50, dated January 20, 1975.
Nuclear Quality Assurance Manual (NQAM), Revisions dated August 16, 1985, December 23, 1985, and June 20, 1986.
Sequoyah Nuclear Plant Standard Practice, SQA-45, " Quality Control of Material, Parts & Services", Revisions 16, dated July 9, 1985, 17 dated September 27, 1985, 18 dated Novetaber 21, 1985, 19 dated February 13, 1986, 20 dated March 4, 1986, and 21 dated June 23, 1986, were reviewed to determine the site procurement requirements.
TVA Quality Assurance & Audit Staff -
Audit Report CH-8200-14, dated February 17, 1983, was reviewed as it identified problems in the procurement program.
Nuclear Safety Review Staff Report R-84-17 NPS (Attachment C), " Review of Procurement Practices sad Procedures for Operation of Nuclear Power Plants," dated March 12, 1985, and the Manager of Nuclear Power response, memorandum L12850520800, dated May 21, 1985, were reviewed as they pertained to procurement practices and procedures.
Corrective Action Report (CAR) SQ-CAR-86-02-006, dated March 10, 1986, and the following memorandums: L16860723 855, dated July 23, 1986 and S08 800417 801, dated April 11, 1986, were reviewed to assess the action taken on identified procurement problems.
Generic Concern Task Force Report (Attachment B),
" Supplier's Contractors" dated May 16, 1986, was reviewed to assess GCTF's evaluation and conclusion of Employee Concern IN-86-011-003.
REPORT NUMBER ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER:
7 TITLE:
Quality Assurance Program Adequacy PAGE 7 0F 16
.Various memoranda (Attachment D) pertaining to TVA's procurement program and this issue were also reviewed to determine requirements and commitments.
In addition, discussions were held with the Sequoyah Environmental Qualification Project Engineer, Manager of Nuclear Engineering Employee Concerns, Manager of Operation Engineering Services, and Section Supervisor - Audit Branch for information pertaining to this issue.
~
4.2.3 Issue - Nuclear Quality Assurance Manual Requirements Not Complied With Employee Concern Files, including the Confidential File, were reviewed for any additional information relating to this issue. No further information was available.
Reviewed Sequoyah's Administrative Instruction AI-20,
" Inspection Program", Revision 10, dated November 21,1984 and the site Quality Control Program for compliance with the Nuclear Quality Assurance Program requirements.
Discussions were held with Sequoyah's Quality Engineers and their supervisors pertaining to this issue.
4.2.4 Issue - Management Pressure Is Restricting The Audi*.
Function Employee Concern Files and Confidential Files were reviewed for any additional information which could be utilized by QACEG in the investigation of this issue. None was available pertaining to the issue. As a result of the QACEG investigation those documents listed in Attachment E were reviewed for requirements and commitments pertaining to this issue.
Discussions were held with nine QA Audit Branch - Lead Auditors in order to establish the historical background information, pertaining to auditors being pressured to close audit findings, the type of pressure applied, and the reason for that presssure.
5.0 FINDINGS 5.1 Findings on Issues Based on the evaluations and investigations performed by QACEG, one of the four issues (Procurement Requirements Not Invoked) was substantiated in part and pertained to Employee Concern OE-QMS-1.
Additionally the issue of excessive paperwork and procedures was
REPORT NUMBER ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER:
TITLE: 7 Quality Assurt.nce Program Adequacy PAGE 8 0F 16 substantiated. The remaining issues were not substantiated.
The following addresses both a discussion and conclusion of each issue as identified in Section 1.2 of this report.
5.1.1 Issue - Excessive Paperwork and Procedures Discussion The QACEG investigation identified that TVA had addressed the issue of burdensome paperwerk and procedures which is identified in their " Nuclear Performance Plan" (pages 11, 14, 73, 74, and 75) dated March 1986. That document also identified the root cause for that condition (as noted below) and TVA's commitment to the NRC for resolving that condition:
"In the past, all of TVA departments responsible for nuclear activities have not been unified into a single nuclear organization. TVA's nuclear plants and headquarters departments have, at times, acted autonomously, and authority for functional activities was sometimes divided among several groups. As a result, lines of authority and responsibility have not always been clear and the implementation of TVA's Nuclear Program has not been consistent."
Improvements In Management Systems and Controls "Some of the problems in TVA's nuclear program have involved insufficient programs and procedures, a lack of prior planning and integration of nuclear activities, and a failure to satisfy prior commitments to the NRC. In response to these problems, TVA is reviewing its nuclear procedures and will be establishing centralized programs and procedures to control all TVA nuclear activities; TVA has assigned the Division of Nuclear Services with the responsibility."
In the short-term, "TVA will prepare interim corporate-level nuclear standards for developing directives and procedures for each of the headquarters departments reporting to the Manager of Nuclear Power. These standards will be used to evaluate and revise all existing nuclear procedures on a site-by-site basis and will serve as a basis for preparation of final corporate-level nuclear directives and procedures. Whenever possible, the interim standards will be based upon those provisions of existing procedures which provide effective control of activity in question".
In the long-term, "TVA will prepare and issue Nuclear Power Directives, approved by the Manager of Nuclear Power, to
REPORT NUMBER:
ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER:
7 TITLE:
Quality Assurance Program Adequacy PAGE 9 0F 16 define the specified objectives and responsibilities of the headquarters departments reporting to the Manager of Nuclear Power. Corporate-level directives and procedures will be developed or revised for each headquarters department. Plant-specific procedures will then be reviewed and revised on a site-by-site basis to assure their conformance with the requirements in the corporate-level nuclear directives and procedures".
Conclusion As a result of QACEG's investigation the issue was substantiated. Based on the above stated improvements, assigned to the Division of Nuclear Services for implementation, an ECSP - Corrective Action Tracking Document (CATD) was not initiated. The stated improvements when implemented will reduce the number of procedures / paperwork.
However, the amount of procedures and paperwork required may still be considered burdensome.
5.1.2 Issue - Procurement Requirements Not Invoked Discussien The following reports and documents were reviewed and evaluated during this investigation and re flected the following:
The Generic Concern Task Force (GCTF) Report, dated May 16, 1986 (Attachment B) for Sequoyah, stated the concern 1N-86-011-003 was not valid. Their conclusion was based on additional data furnished by the Employee Response Team (ERT) which obtained additional information from the concerned individual and clarified the concern as:
" Prior to 1982, TVA Class A bolting material was purchased from Dravo Company. Dravo subcontracted with Texas Bolt for this material. The certified mill test report received from Texas Bolt did not indicate that the material was ASME Class I."
The report also addressed two specific issues: "Does TVA require material suppliers to have sub-tier suppliers meet the QA requirements for procurement and did Dravo supply bolting material for Sequoyah?"
The conclusion of the GCTF investigation stated:
l i
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ELEMENT TYPE: 80101-SQN l Element Report REVISION NUMBER:
TITLE: 7 Quality Assurance Program Adequacy PAGE 10 0F 16 "The NQAM, Part III, Section 2.1, does require sub-tier suppliers to meet the same requirements as the contract supplier. Also Dravo Corporation and Texas Bolt Company met the requirements for supplying ASME Code material. Dravo Corporation did not have a contract to supply material for the Sequoyah Nuclear Plant."
1 Based on our review and evaluation, QACEG concurs with the GCTF report conclusion.
QACEG's review of the NSRS Report R-84-17-NPS, " Review of Procurement Practices And Procedures For Operating Nuclear Power Plants", dated March 12, 1985, identified various problems (as noted below) in the TVA Procurement Program which are related to this concern:
" Procurement system is too cumbersome, and not well known by the users".
There is insufficient documentation for transferred material.
10 CFR 21 requirements incorrectly linked to Nuclear Power (NUC PR) QA requirements.
Commercial grade items (QA Level I and II designation) were purchased with little or no QA requirements invoked.
No quality verification performed (receipt inspection) for 4
commercial grade items."
QACEG's review of Corrective Action Report SQ CAR 86-02-006, dated March 10, 1986, identified the following conditions in part:
" Office of Engineering (OE) is supplying QA material for ASME Section III and Class IE application with insufficient or nonexistent documentation."
"On requisitions for QA Materials, the statement, "Does 10 CFR Part 21 Notice Apply? yes ( ) no ( )" is being marked out or lined out by OE.
" Office of Engineering" (OE) is purchasing "QA" material for Class lE application as "No QA" from the vendor and upgrading this material to "QA" on a transfer requisition from the Power Stores Distribution Center".
" Material descriptions do not adequately describe the item
wm . REPORT NUMBER ELEMENT TYPE: -
80101-SQN Element Report REVISION NUMBER:
TITLE: 7 Quality Assurance Program Adequacy PAGE 11 0F 16 being supplied."
The above items were identified as examples only, and reflect a problem in that the Office of Engineering procedural requirements were not in agreement with the NQAM requirements.
QACEG reviewed NQAM, Part III, Section 2.1 " Procurement of Materials, Components, Spare Parts, and Services", revisions dated April 1, 1985, December 23, 1985, and June 20, 1986, for requirements pertaining to this issue. The QACEG's review of the NQAM indicated the later revisions dated December 23, 1985, and June 20, 1986, were revised in part to reflect organizational changes and reviews to assure procurement requirements are specified in the procurement documents.
QACEG's review of Memorandum (R. B. Kelly, Director, Nuclear Quality to W. C. Drotleff, Manager of Engineering) dated July 23, 1986 (L16 860723 855) stated the following in part:
"As a result of the reorganization, a number of activities which are subject to Part II and III of the NQAM are now being performed by DNE personnel. Apparently some of these personnel are unaware of their responsibility to comply with the NQAM and continue to do business as they have in the past.
Please provide for procedure revision and/or training as may be necessary to ensure that DNE coordinate material transfers at Sequoyah Nuclear Plant comply with the NQAM."
QACEG's review of the Sequoyah Site Standard Practice, SQA-45 indicated this document describes the methods and requirements for controlling the procurement of materials, components, spare parts and services. It also establishes and assigns responsibilities for the preparation, review and approval et procurement documents. The revisions (dated July 9 and November 21, 1985, and February 13 and June 23, 1986) reviewed indicated SQA-45 was revised in part to reflect the later requirements of the NQAM.
Discussions were held with the Environmental Qualification Project Engineer, Manager of Nuclear Engineering Employee Concerns and Manager of Operation Engineering Services who were cognizant of this issue. They stated action was being taken to resolve the procurement problems, but the Replacement >
Item Program (RIP) has not been fully implemented. This program was initiated by TVA partially as a results of NSRS report R-84-17-NPS and NRC Inspection Reports 50-327 and 7 328/86-81 citing similar deficiencies. The scope of The Program Plan, including a list of committments related to this
REPORT NUMBER:
ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER:
TITLE: 7 Quality Assurance Program Adequacy PAGE 12 0F 16 issue was addressed in a letter from TVA to NRC dated April 1, 1987 (L44 870401 807). The pre-and post-restart scope of The Program Plan addressing seismically sensitive equipment within the boundaries of the Phase I Design Baseline and Verification 7 Program and 10CFR50.49 equipment will be evaluated prior to restart.
Conclusion The issue of " Procurement Requirements Not Invoked" is substantiated in part for Employee Concern OE-QMS-1. As a result QACEG issued an ECSP - Corrective Action Tracking Document (CATD) 80101-SQN-01 (Attachment F).
5.1.3 Issue - Nuclear Quality Assurance Manual Requirements '
Complied With Discussion The QACEG investigation found no evidence where the Sequoyah Site had not incorporated the NQAM requirements into their QC Program.
QACEG's review of all CARS and Deficiency Reports (DRs) issued in 1982-1986, against the Sequoyah's Nuclear Quality Assurance Organization (pertaining to Sequoyah's Quality Control Inspection Program) found no evidence that the QC organization had failed to incorporate the NQAM requirements into the SQN plant instructions (e.g. all the requirements of AI-20
" Quality control Inspection" and AI-34 " Training and 7
Qualifications of QC and Nondestructive Examination (NDE)
Personnel" were reviewed by QACEG against the NQAM).
QACEG's investigation of Sequoyah's CARS and DRs (for the life of the plant) with regard to to the Quality Control Program, not complying with NQAM found no evidence where deficiencies were written against this issue.
Conclusion As a result of this investigation, QACEG found no evidence that the Sequoyah site was ignoring their QC program. The evidence reviewed indicated the NQAM requirements were being implemented in the Sequoyah QC program, therefore, the concern was unsubstantiated.
5.1.4 Issue - Management Pressure Is Restricting Audit Functions Discussion The concern was considered to be generic for all TVA sites, (Browns Ferry (BFN), Watts Bar (WBNP), Sequoyah (SQNP), and
REPORT NUMBER ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER:
7 TITLE:
Quality Assurance Program Adequacy PAGE 13 0F 16 Bellefonte (BLN)). QACEG established that a total of 133 audit reports (an audit report could include one (1) or more audit modules) were issued for these sites for 1984 and 1985.
Of those 133 reports, QACEG reviewed a sample of 23 reports which were issued during the same time frame that the employee concern was generated. Those 23 audit reports were reviewed for information pertaining to this issue. In addition to the audit reports, the documentation and audit files identified by the individuals during the interviews were also reviewed.
The QACEG investigation was performed in three phases i.e.,
review of audit reports, interviews with audit personnel and review of related documents. The scope of the investigation was limited to the evaluation of two areas:
- a. Were the corrective action methods used in compliance with the requirements of Appendix B to 10CFR50, Criterion XVIII, " Audits", and NQAM, Part III, Section 5.1 " Audits"?
- b. Was there documented evidence that Division QA Management had applied pressure to the Auditors to close deviations prior to the implementation of completed corrective action?
Two (2) of the Multi-Site Audit Reports (CH-8500-01 and CH-8400-18) were reviewed specifically because they were referred to QACEG by an individual during the interview process as containing information to substantiate the concern of pressure being applied to close out audit findings.
Based on the review of the twenty-three (23) audit reports, QACEG found that a considerable amount of time was being taken to close audit deviations. In most cases, a year was average and in other cases, 18 months to 3 years had elapsed before a report of corrective action was verified as complete. Since it was standard practice that an auditor who found a deviation was responsible to see it through to the verification of corrective action, the Quality Audit Branch and auditors would be under pressure to review and verify the corrective action, even though the sites were delinquent in responding to the audit findings, in a timely manner. From a cursory review of the documentation to support closings of deviations, it was identified that the sites held little regard for the audit deviations found. The Site Directors would either request extensions to reply to the deviations or ignore the audit reports entirely. From this, one could draw a conclusion that in the period of 1984-1985, the audit program was not being supported by TVA Management. A memorandum from H.G. Parris to Site Directors, in June 1984, made mention that the NRC, on numerous occasions, criticized TVA for a lack of timeliness in
REPORT NUMBER:
ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER:
7 TITLE:
Quality Assurance Program Adequacy PAGE 14 0F 16 responding to audit deviations and directed them to take a more positive part in responding and closing deviations.
During the review, QACEG found four (4) instances where deviations were escalated to a higher authority for resolution. These escalations were done in accordance with TVA procedures in effect at that time (DQAI-310, superseded by DQAI-313, superseded by DQAI-104).
QACEG conducted interviews with nine (9) QA Audit Branch-Lead Auditors. The results of these interviews indicated that implicit pressures were applied by Q.A. management to close audit deviations prior to the full satisfaction of the auditor.
Conclusion While it would appear, based on the interviews conducted, that auditors may have been pressured to close deviations before they were satisfied that adequate corrective actions had been implemented, QACEG evaluators were not able to substantiate the concern based on the audits, and correspondence provided and reviewed. The investigator also found correspondence to "All Audit Personnel" where they were instructed in handling
" pressure". (Note: Based on this investigation, the word
" pressure" was used in the context of closing audit deviations in a timely manner as required by applicable procedures.)
There was no objective evidence that pressure had been used or implied, to close deviations which were considered unsatisfactory by the auditor. In addition, the review of the twenty-three (23) audit reports indicated no evidence of violations to the requirements of Appendix "B" to 10CFR50, Criterion XVIII, " Audits" or the NQAM, Part III, Section 5.1,
" Audits".
Based on the correspondence available during the investigation, it was concluded that the issue of "...QA management pressures auditors to close deviations..." was unsubstantiated.
5.2 QACEG's evaluation concluded that two issues " Excessive Paperwork and Procedures" and " Procurement Requirements not Invoked" (employee concerns BFM-86-002-001 and MRS-85-001, and OE-QMS-1) were substantiated. The evaluation of concerns BFM-85-002-001 and MRS 001 indicated the TVA program in effect did propagate excessive procedures which resulted in excessive paperwork. The evaluation of concern OE-QMS-1 indicated the Power Stores / Nuclear Plant Power Operations procurements process (NQAM) did not assure applicable requirements (regulatory, design base, qualifications, etc.) were being met. These issues are being evaluated by the Manager of Nuclear
REPORT NUMBER:
ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER:
TITLE: 7 Quality Assurance Program Adequacy PAGE 15 0F 16 Power to determine required corrective actions and any potential impact to safety. The remaining employee concerns were unsubstantiated and even though designated potentially sa fety-significant or safety-related in Attachment A, they were not considered detrimental to the safe or reliable operation of the Sequoyah Nuclear Plant.
5.3 Corrective Action TVA Management has taken the following corrective action on the issue
" Procurement Requirements Not Invoked".
The NQAM and Sequoyah Site Standard Practice SQA-45, " Quality Control of Material, Parts, and Services", were revised in part to reflect changes required to improve the TVA Procurement Program. Also, the Design Nuclear Engineering (DNE) Division has been assigned the responsibility for:
- a. Procurement of all spare and replacement parts and materials for permanent and safety-related equipment.
- b. Establish a Staff core of trained procurement groups at each site by June 30, 1986, to prepare, review, and approve procurement documents and assure compliance with the NQAM requirements.
The above improvements are still being implemented by TVA Management.
Based on the QACEG review of available documentation it could not be substantiated what action was being taken on equipment, components, material, spare or replacement parts already installed or in storage.
As a result, Employee Concern Special Program (ECSP) Corrective Action Tracking Document (CATD) 80101-SQN-01, (Attachment F) was issued.
The SQN Site Director's response dated January 6, 1987 (Attachment G) to CATD 80101-SQN-01 stated a Replacement Items Task Force had been assigned on November 17, 1986. The primary function of the Task Force is to develop measures to control future procurement, issuance of items currently in Power Stores, and to verify acceptability of installed items. These actions are presently being implemented by the Task Forca. Implementation of those actions will be verified at a later date.
6.0 ATTACRMENTS A. Listing of Employee Concern Information Subcategory 80101-SQN.
B. Generic Concern Report - Suppliers Subcontractors, dated 5/9/86 C. NSRS Report R-84-17-NPS D. Documents Applicable to IN-86-011-003 and OE-QMS-1 E. Documents applicable to XX-85-116-008 l
i r
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ELEMENT TYPE: 80101-SQN Element Report REVISION NUMBER:
TITLE: 7 Quality Assurance Program Adequacy PAGE 16 0F 16 F. ECSP Corrective Action Tracking Document 80101-SQN-01 G. SQN Site Director's response to ECSP Corrective Action Tracking Document 80101-SQN-01 dated January 6, 1987.
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