IR 05000445/1985012

Insp Repts 50-445/85-12 & 50-446/85-08 on 850826-29.No Violation or Deviation Noted.Major Areas Inspected:Policies, Procedures & Implementation Re Ombudsman & Safeteam Programs for Identifying & Resolving Personnel Concerns

ML20137S907
Person / Time
Site:	Comanche Peak
Issue date:	02/03/1986
From:	Early C, Haass W, Madsen G, Vietticook A, Westerman T NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20137S883	List: IR 05000445/1985012 ML20137S880
References
50-445-85-12, 50-446-85-08, 50-446-85-8, NUDOCS 8602180143
Download: ML20137S907 (9)

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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

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NRC Inspection Report: 50-445/85-12 Construction Permits: CPPR-126

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50-446/85-08 CPPR-127

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Dockets: 50-4 3 50-44o Licensee: Texas Utilities Gen- ating Company Skyway Tower 400 N. Olive Street Dallas, Texas 75201 Facility Name: Comanche Ped Steam Electric Station Inspection At: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: August 26-29, 1985 Inspectors: -

M~ bd II/N6 A. Vietti-Cook, Project Manager Date

! Comanche Peak Project l Division of Licensing Nuclear Reactor Regulation l

b. kn i 1 /!/5/3 6 C. Early,Jroject Manager Ddte Comanche Peak Project Division of Licensing Nuclear Reactor Regulation YbrhuYW

'W.P. iaass, rendor Program Branch

/6lf6 Date Office of Inspection and Enforcement e &

G.~L. Madsen, Reactor Inspector ff/6l8b Da'te Comanche Peak RIV Group

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/ Approved: 7- s/ D '

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T. F. Westerman, Chief Dat Comanche Peak RIV Group -

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Inspection Sunnary .

Inspection conducted August 26-29, 1985'(Report 50-445/85'-12 and 50-446/85-08)

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Areas Inspected: Reactive, announced. inspection of the applicant's policies,- -

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Lprocedures, and implementation relating to the CPSES site Ombudsman and ,,

- SAFETEAM programs in identifying and resolving site personnel concerns resulting from exit, scheduled, and walk-in interviews with applicant and l contractor employees. - The inspection involved 72 inspector hours on-site and 18 inspector hours at the applicant's corporate offices by two; inspectors and two project manager Results: Within the areas inspected, no violation's or deviations were

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r * i e c DETAIL ,

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i ~ .,.1". C Persons Contacted

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p Principal' Licensee Personnel l , . 1 .

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• W. ! G.# Counsi

" : ' *JJC.' Kuykeri.1, Exe~cutive Vice Presidentdahl, Manager, . Nuclear Operations

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" ' ,1.*R.f A. Werner, Manager, SAFETEAM ~ .

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O i' * ,R. G. Spangler, Supervisor, Quality Assurance Services >

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t ., f"*G.'R.' Rand,-Quality. Assurance. Engineer Q4 1, -

R.fA.'Woodridge, Attorney s 3 *Ai B.LScott, Vice> President,-Nuclear *

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- *T. F. niesterman', Chief, Comanche Peak Task Group, RIV

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, ,3*R. F. Heishman', Chief, Reactor. Construction Program Branch, IE-HQ '

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• Attended exit' int'erview.

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$ Exit' Interview -

An exit interview was conducted on November 5,1985, with personnel as-indicated in paragraph 1 of-this repor ,

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> TUEC's Employee Concern Programs Prior to January 14, 1985 Beginning in October 1983, TUEC . initiated a Hot-Line program and programs "

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' whichLrequired all personnel departing from QA/QC to complete a ,

questionnaire and all. Brown and Root construction employees terminating ~'

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~ employment.to be interviewed. The purpose of this program was to identify concerns related to the quality of plant design and , construction. Persons :

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LU who'had been released from'QA/QC since October 1983 and had not-filled out C an exit questionnaire were located, if possible, and were invited to fill

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out an exit questionnaire. In November 1983, an Ombudsman- from an outside

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,, organization was assigned to the site to participate in the' program :s - 'These TUEC programs were administered _ by TUEC Quality Assurance by

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administrative: memorandum until October 29,~1984, at which time a formalized +

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The TUEC-files resulting from the program are composed of.53 individual

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f.iles. Each file. consists of; allegations made by an individual, as well '

p' . as, ~ documents related to the" allegations. ~ At the time of the inspection; '

51-of:the 53 files indicated ~ completion of investigative followup and -

,1 ' close-out 'of, the concerns. Two files remained ~ope .

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-4-During the NRC inspection, 22 of the 51 closed files were reviewed. The following observations were identified:

' Employee responses to the questionnaires was somewhat sketch The applicant did recontact some of the concerned individual . The program was administered by TUEC QA. This is a poor practice especially for concerns relating to QA management, supervisory confidence, and supervisory involvement, since the individuals responsible for investigating and correcting the concerns could be the same individuals who could be the subject of, or be responsible

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for the concern expressed by the employe ' Some concerns were not fully addressed during the course of the investigation.

, There was'only limit'ed contact of concerned individuals to inform them of the resolution of their concern In response to,the NRC Technical Review Team finding AQ-133 identified in

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Supplemental Safety Evaluation Report No. 11, TUEC's Comanche Peak Response Plan Item VII.a.6~ commits to additional evaluations of the Comanche Peak employee concern reporting system . TUEC's Employee Concerns Program After January 14, 1985 - SAFETEAM Program , Program Description SAFETEAM is a program to identify and investigate safety concerns of workers at a nuclear power plant site. It-provides an opportunity for all site workers to report concerns they might have as they leave the project. -All quality assurance and quality control employees plus others' involved in the safety, security or operation of the site are given such opportunities, in the form of scheduled interviews, during their employment. In addition, plant wall posters are used to make a " mail in" form available to all workers at any tim ^

On the last day of site employment, workers are invited, by the owner, to the Appreciation Center which is located in a trailer near the main gate. At that time, they are asked if they would share any concerns they have about the project in an interview conducted by an independent firm. If no concerns are identified, the worker is given a postage paid " mail in" form should one be later remembere A toll free telephone number is given for the same purpos All of these interviews are recorded if the worker agree In addition, an interview report form is completed and retained for further review. All records of concerns from this point forward are

" nameless" to help protect the anonymity of the worker. _ - -.

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All concerns are then cla'ssified by the'SAFETEAM into categories for t *i ~ '

followup investigation. The categories include. nuclear safety, security, industrial safety, site management, and miscellaneou The manager then assigns an investigator and an investigation is conducted. Following this investigation,'a report is prepared and

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subsequently reviewed by an owner management team. This team consists of a legal representativesfamiliar with the plant license,_

a public' affairs representative and the quality assurance manage ~

Once the team has been satisfied that the investigation is complete and any required corrective actions planned, a response letter is prepared by the independent firm, to the concerned party, indicating what was found and what was done. This letter will be reviewed by the same owner management. team that reviewed the investigation report before it is sen Included in this mailing is the toll free

~ telephone number and they are invited to submit any other concerns

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- as they may be recalled, Organizational Structure The TUEC SAFETEAM program is-implemented under the' direction of R. A. Werner, Manager - SAFETEAM, who reports to W..G. Counsil, Executive Vice-President. The latter reports to M. D. Spence, President. The SAFETEAM organization is adequately separated from QA/QC and other organizational elements involved in the design and construction of Comanche Peak and therefore is acceptably located within the TUEC organization to assure independence and to minimize the potential for conflicts of interes Formality of Program as Reflected in Instructions The SAFETEAM concept was developed by Utilities Technical Services, now SYNDIC 0, a subsidiary of the Detroit Edison Company and initiall utilized at Comanche Peak on January 14, 1985. The SAFETEAM handbook

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r and manual were utilized for the design and implementation of the

Comanche Peak SAFETEAM program. The NRC found that TUEC generally *

- - followed the manual with minor modification In two significant areas, however, the Comanche Peak SAFETEAM is not implementing the manual as written:

The SAFETEAM manual states that " interviewers should have a (' .

(1)~ knowledge of nuclear principles." A review of resumes of one

'i interview coordinator and seven part-time interviewers employed

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74 , "by the Comanche Peak SAFETEAM do not indicate that these P' personnel have any education, training or experience in a

' ' -technical area related to the design, construction or operation of a nuclear plant. This is a potential weakness which can

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reportable to the NRC, a transmittal should be forwarded to the Director / Manager of Quality Assurance. The transmittal should include the statement of concern and the infomation gathered in E the investigation that supports the conclusion that the concern may be reportable and should request feedback when the item is

. closed by Quality Assurance. The Comanche SAFETEAM does not operate to this guidance with any fomality. The SAFETEAff has internally sent concerns to the QA organization for a 10 CFR 50.55(e)

reportability determination before the investigation by the SAFETEAM was complet In addition, the QA organization is

, assigned the responsibility to review all SAFETEAM investigation reportsand,also, perform 10CFR50.55(e)evaluationsin conjunction with the various corrective action programs such as nonconfomance reports initiated by SAFETEAM. . However, because -

of the informality of the process, it. is not clear that the SAFETEAM investigators consider making the ir.tial determination of reportability. This is a potential weakness in that prompt utilization of the investigators observations may not be acted upon. Additionally, the Comanche SAFETEAM does not request feedback when corrective actions for 10 CFR 50.55(e) reportable r

items have been complete Numbers and Qualification of Personnel The SAFETEAM organization is comprised of the Director and one secretary (TVEC employees), and the following, who are all available-

under a contract with National Inspection and Consultants, In (1) One interview coordinator (2) Seven part-time interviewers (3) One investigator coordinator (4) Four investigators A review of resumes indicated that the investigators appear to be adequately qualified to conduct the technical review of concern However, the interviewers lack a knowledge of general nuclear power plant systems, deficiency reporting systems, and an. understanding of

.the investigative process which can preclude obtaining adequate specificity of the concern from the interviewee. ^

Comanche Peak SAFETEAM had no formal documentation of' personnel qualification requirements other than the brief statement in the-SAFETEAM manua Information Flow Publicizing the SAFETEAM program to employees is accomplished through company literature, posters and stickers. The SAFETEAM building is conspicuously located at the, plant site and is readily

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• -accessible. ' Concerns come to the attention of the SAFETEAM through 3 >

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- ; terminatio'n exit interviews, scheduled interviews, hot line telephone v calls, letters, and walk-in ~ interviews. ~ Interviews are conducted ,

[* with one' interviewer in a closed office in the SAFETEAM buildin [< _

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The interviewer summarizes the' individual's concerns on a SAFETEAM

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• reporting form'and if the concerned individual agrees, interviews are

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, alsostape_d. The SAFETEAM manager reviews and classifies the concerns

• into one'of five classifications (plant safety, security, management, f industrial safety, and miscellaneous). The SAFETEAM manager then assigns an investigator. The investigator may conduct the investiga-

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tion or refer the concern to an ad hoc grou (Concernsassociated

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with criminal activity are referred to security for investigation and response.)' If a concern is substantiated, the SAFETEAM follows up on a' concern until action .to resolve the concern is identified. The

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SAFETEAM .does not verify that the resolution of the concern is .

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implemented. Whe~n an investigation is completed, an investigative

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report is prepared, reviewed by.the Manager SAFETEAM, and referred to p

a three-person affair representatives steering). committee The report (composed of legal, is finalized and then QA, sent and to a public technicalJeditor who prepares a response letter to be sent to the concerned individual. The letter is reviewed.by.the steering

, comittee and signed by the SAFETEAM manager, at which point the

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concern is considered closed by the SAFETEA '

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f.: Implementation of the SAFETEAM Program

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As of August 16, 1985, the SAFETEAM had received 641 concerns from

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506. individuals. 'An analysis-of the subject matter during the NRC:

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' inspection, revealed that 200 of the concerns were related'to indus-r '-

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' trial safety, personnel practices, etc. -Another 59 concerns ~ involving

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potential wrongdoing issues were referred for review to the NRC

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Officeiof Investigations. Of the' remaining 382 technical .

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, concerns, the SAFETEAM statistical printouts indicated the.following x . status: (1) 125 concerns closed, (2) 170 concerns :for which the

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had not been contacted regarding.the resolution of ,the concern, and '

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(3) 87 concerns being investigated.,

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g The NRC insp'ection team selected 62.of the'295 technical concerns tha . had been investigated for file review. The' file review revealed the

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(1)'. The SAFETEAM program is generally being implemented-in

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.u accordance with the SAFETEAM manual with the'two exceptions y

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(2) The" classification of'the concerns into five categories (plant

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(a) Interviews lacked specifics. With experience, recontacting the concerned individuals for additional details had increase (b) Some files revealed that the investigator did not attempt to obtain adequate information sufficient to establish the specificity of the concer (c) The program does not call for follow-up resolutions to work completio In one case, a concern regarding the disposition of the NCR raised by an individual was not addressed by SAFETEA (d) Resolutions provided corrective actions for the present and future; however, the impact on the past was not always clearly addresse (e) The SAFETEAM does not comply with the manual w' 's.egard to formally reporting conditions discovered by the SAFETEAM investigators that may be reportable to the.NRC in accordance with the requirements of 10 CFR 50.55(e).

g. Documentation The technical files reviewed were organized and appeared adequate to facilitate auditing of the records. The files included references to various drawings, procedures, and other documentation which were not included in the files but would be traceable. In some cases, the file did not contain a clear discussion of what the investigator did to evaluate the concern, and it was difficult to infer what the investigator did from the contents of the file. The general control of the files and the protection of the individual's confidentiality was found to be acceptabl h. Management Notification Management is provided statistical reports relating to the SAFETEAM activities on a biweekly basis. Additionally, telephone conversations and nieetings are used to further advise upper management of needed assistance and program statu P

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. Trending and Assessment of Trends Concerns are assigned ~to a classification (plant safety, security,

. management, industrial safety, and miscellaneous) and also to appli-cable subclassifications. The information is computerized and can be utilized for obtaining statistical data or determination of the '

existence of similar concerns already within the SAFETEAM syste This capability has.been used to a limited degree by the CPSES SAFETEA ' SAFETEAM Review by Office of-Investigations During the week of August 26,.1985,- the Office of Investigations (01),

Region IV Field Office, conducted a review of the 43 closed SAFETEAM concern files that were considered as possible wrongdoings. The OI assessment of the SAFETEAM program is documented in 01 report A4-85-02 The 01 findings are as follows: "In summary, the, majority of SAFETEAM investigations reviewed and evaluated were found to have sufficiently addressed the issues posed. This included the efforts demonstrated in explaining a concern in its subsequent investigation. For the most part, the investigative reports adequately supported the conclusions. However,

-the investigative' findings in'some instances were inconclusive, This can generally be attributed to two primary factors: (1) Certain reports had not accurately described the SAFETEAM rationale for pursing or concluding an investigation; and (2)~ some reports had left the original allegation unanswered."

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