IR 05000498/1985018
| ML20136E815 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/17/1985 |
| From: | Carpenter D, Constable G, Ireland R, Madsen G, Tomlinson D, Tomlinson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20136E767 | List: |
| References | |
| 50-498-85-18, 50-499-85-16, NUDOCS 8601070128 | |
| Download: ML20136E815 (7) | |
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APPENDIX
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. REGION.IV
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U.S. NUCLEAR REGULATORY COMMISSION
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NRC' Inspection' Report :
-50-498/85-18l Construction Permits:
CPPR-128
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50-499/85-16-CPPR-129
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Dockets:
50-498~
50-499-
Licensee:
Hou_ston Lighting & Power Company (HL&P)
P. O. Box 1700 Houston, Texas 77001
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' Facility Name:. South Texas. Project, Units 1 and 2 Inspection At:
South Texas Project, Matagorda' County, Texas e
Inspection Conducted: ' October 21-25,'1985
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Inspectors:
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C2tav G. L. Madseh,-Project. Inspector, Project Dat6 '
Section C, Reactor Projects Branch
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' 'l r/ m /" h a-o9-95 ti.T P~.'Tomlinson,- Reactor Inspector
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Engineering Section, Reactor Safety Branch
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t 2 - 09-W D.T Carrient'er, Resident Inspector, Project Date
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-Section C, Reactor Proje ts Branch s
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Approved:
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G. L. Constable, Chief, Project Section C.
Date
. Reactor Projects Branch
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8601070128 860102
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PDR ADOCK 05000498 G
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-R. E.. Ireland, Chief, E'ngineering Section Date '
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- Reactor' Safety Branch.
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k, 1 Inspection Summary i,
ff IbspictionConductedOctober 21-25, 1985 (Report 50-498/85-18; 50-499/85-16)
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AreasInspect$d: - Routine,$nannouncedinspection~ofapplicant'spolicies,
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procedures,-and, implementation relating to the HL&P SAFETEAM. programs fcr
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si identifying andfresolvingl concern's resulting from exit, scheduled, and walk-in 0,
interviews with;. applicant and contractor employees. _The' inspection involved h, '
.194 : inspector-hours onsite by 'three NRC inspectors.
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. m[Results:UWit.hin the' areas inspected, no violations or deviations were
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sidentified.
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DETAILS
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1.
Persons Contacted Principal Licensee Personnel-J. H. Goldberg, Group Vice-President, Nuclear
- J. E. Geiger, Manager, Nuclear Assurance
- W. N. Phillips, Program Manager, SAFETEAM
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- T..L.zJordan, Project, QA Manager
- J..W. Williams, Director of Special Projects
- J..T. Westheimer, Project flanager
'*B. L._ Hall, Investigations Supervisor, SAFETEAM
- J. B. Hart, Licensing
- S. M. Head, Lead Engineer, Project' Compliance ~
S. S. Koelzer, Interview Coordinator, SAFETEMi
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NRC
- G. L. Constable, Chief, Project Section C
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- C. E. Johnson, Senior Resident Inspector
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- Denotes individuals attending the exit interview on October 25, 1985.
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2.
SAFETEA!! Program
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a.'. Organizational Structure ( '.
'The HL8P SAFETEA!! program is implemented under the direction of
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W. N. Phillips, Program Manager, SAFETEAM, who reports to
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J. E. Geiger, Manager of Nuclear Assurance, who reports to
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J. H. Goldberg, Group Vice President, Nuclear. As Manager of Nuclear
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Assurance, J. E. Geiger also has managerial responsibilities for the QA site organization, which has the potential to influence the processing of employee concerns within the SAFETEAM organization.
b.
Formality of the Program The SAFETEAM concept was developed by Utilities Technical -Services,
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now SYNDIC 0, a subsidiary of the Detroit Edison Company and initially utilized at the South Texas Project in September 1984. The SAFETEAM handbook and manual were initially utilized in the implementation of the South-Texas SAFETEAM program. On May 1, 1985, HL&P issued a SAFETEAM Procedures Manual which.was revised and reissued on October 4,1985, as the SAFETEAM Instructions Manual. The existing program is essentially equivalent to the initial SAFETEAtt Manual with certain revisions, including:
(1) Preparation and approval of investigation plans.
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- (2') Mechanisms'for following recommendations to implementation.
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c.
Numbers and Qualifications of Personnel
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The SAFETEAM organization is comprised of the Program Manager.
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Investigations Supervisor and one secretary (HL&P employees), and the following contract' personnel:
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('1) 0ne Administrative Technicia'n -LJeanneret and Associates.
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(2) One Iriterview' Coordinator: 'Jeannere't and Associates.
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(3) Four Interviewers - Jeanneret and Associates.
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-(4) One' Investigation Coordinato'r;- National Inspection and Consultants, Inc.
'(5).Seven Investigators - National Inspection and-Consultants, Inc.
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HL&P has prepared job descriptions for the above positions. A review of these job descriptions by the NRC inspectors revealed that the.
requirements'for the investigators and investigator coordinator were minirr.al for the performance of the~ evaluation of concerns.
A review of resumes by the NRC inspecto_rs indicated that the
qualifications of the individuals met the requirements of the HL&P
. job. descriptions. However, the resumes for two of the on-board investigators indicated less than normal levels of education and/or experience for the conduct of the evaluations of technical concerns.
The review of a sample of closed concern files indicated that the two individuals in question where performing in an adequate manner.
Additionally, a review of personnel files revealed individual
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assessments and appraisals for these two investigators indicated favorable performance.
a.
Infonnation Flow
- Publicizing the SAFETEAM program to employees is accomplished through employee orientations, posters, stickers, inclusion of information in pay envelopes, and hand-out literature. The SAFETEAM building is conspicuously located on the plant site and is readily accessible.
Five information~ booths are located throughout the site.
Concerns come to the attention of the SAFETEAll through exit intervicws, scheduled-interviews, hot-line telephone calls, letters, and walk-in
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interviews. JInterviews are conducted with one interviewer in a closed office within the SAFETEAM building. The-interviewer-summarizes the individuals' concerns on a SAFETEAM reporting form
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and, if the ' individual agrees, the interview is also taped. The
, interviewer protects the identity of the concerned individuals by the assignment'of a numerical identifier. Names are revealed to the
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i investigators only when the investigation cannot be, conducted without such knowledge and has been formally authorized. The program manager reviews and classifies the concerns into five categories:
t Class 11 - Nuclear Safety and Quality
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Class.2 - Management
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Class 3 - Industrial Safety
Class 4 - Security
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' Class 5 - Miscellaneous J.
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Class I concerns are assigned to the investigation coordinator for
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the preparation of inspection plans, performance of investigations,
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t and preparation of draft investigation reports and response letter to
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Investigation reports and response letters
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receive,the review and approval of the investigation supervisor,
. program manager and the SAFETEN4 review committee. The program.
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manager signs the response letters to the concerned individuals.
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Approved recommendations or suggestions are forwarded to 'he HL&P project manager for actions and a response to the SAFETEAM relative
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to actions tahen. SAFETEAM has an established computerized system'
a for tracking the recommendations and suggesti.ons. As a followup,
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SAFETEAM sends a survey -letter to the concerned individuals.
Class 2, 3, 4, and 5 concerns are assigned to the SAFETEAM investigation supervisor for control and coordination of the assigned cognizant organization's performance of investigations, preparation of.
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investigation reports, and draft response' letters to the concerned
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individual.
Final response letters to the concerned individual are l
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signed by the SAFETEAM program manager.
Followup on recomended
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. actions or corrections is controlled by the assigned cognizant
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!r ;c organizations and are tracked by the SAFETEAM administrative
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technician.
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Implementation of SAFETEAM Program
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As of October 10, 1985, the SAFETEN1 had received 851 concerns from 552 individuals. An analysis of the subject matter.by the NRC.
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- . inspectors revealed that 254 of the concerns were related to
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industrial safety,. personnel practices, etc. Another 85 concerns
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involving potential wrongdoing issues were identified for future-
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review. Of the. remaining 512 technical concerns, the NRC inspection team selected 47 closed concerns for a file review. The sample
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included 33 class 1,'11 class 2, 2 class 3 and 1 class 5 concerns.
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- The= file review revealed the following:
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(1) THE SAFETEAM program is being implemented as planned.
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(2) The classification:of' concerns into five categories (Nuclear jSafety and Quality Management, Industrial Safety, Security, and Miscellaneous) is performed in a conservative manner. The initial classification of a concern can be upgraded but not downgraded.
(3) The' program was established to protect the confidentiality of the concerned individual.
In some cases the investigator was formally given the name of the concerned individual for cases where an investigation could not be accomplished without the name.- The confidentiality of the individuals was appropriately protected and did not appear to distract from the investigator's ability to evaluate the concern.
(4) Frequent recontacting of the concerned individuals for additional information was observed.
(5) Management's support of the SAFETEAM program has resulted in cooperation from other organizations in the evaluation of Concerns.
(6) Observed weakness or areas of improvement included:
(a) The computer printout indicated a concern was closed. The concern file contained a letter to the concerned individual requesting additional information; however, no further information was included to provide a rationale for closu re. Discussions and reviews of documentation revealed that HL&P had recognized the need to investigate all concerns to the extent possible with the available information. Their previous review had identified 10 cases where additional information was requested and no response was received and investigations were scheduled. An HL&P reviewer identified five additional similar cases for which documentation for closure was not included in the concern files. During the course of the inspection, HL&P instituted corrective actions for documentation of closure for past files. HL&P's plans for the future includes investigation of all concerns with available information and documentation of rationale for file closure.
(b) Actions taken by other companies on SAFETEAM recomendations was not clearly documented. The NRC inspector was able to determine actions by looking elsewhere; however, some question exists relative to the SAFETEAM knowledge of the appropriateness of actions taken.
(c) Class 1 concerns are presently a very broad classification which includes the entire plant. HL&P should consider
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establishing a subdivision within class I which identified
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concerns which may have an impact.upon the final licensing
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As of August 21, 1985, the HL'&P computer printout-indicate that
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94 class 1 and 51 class 2, 3, 4, and 5 concerns are pending investigation..HL&P has been concentrating on reducing the investigative time for concerns; Presently, the average closeout time for class 1 concerns is about 75 days.
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Documentation
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The technical files reviewed were organized and were adequate to facilitate auditing.
HL&P is maintaining hard and microfilm copies-of concern files.
The general control of_ files for the protection of the individual's confidentiality was found acceptable.
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. Management Notification
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-Management is provided statistical reports relating to the SAFETEAM activity.
Additionally, telephone' conversations and meetings are utilized to' alert management of needed assistance and concerns of high:importance.
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Trending
' Concerns are assigned to a classification (Nuclear Safety and Quality, Management, Industrial Safety,' Security and Miscellaneous)
and also to'a series of subclassifications.
The information is-computerized and can be utilized for obtaining statistical data of the existence of similar concerns already within the SAFETEAM system.
The ability has been used by the HL&P SAFETEAM.
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Exit Interview An exit interview was conducted on October 25, 1985, with personnel denoted in paragraph 1 of this report.
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