ML19343D385
| ML19343D385 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/27/1981 |
| From: | Singleton C, Greg Warnick, Wilson L HOUSTON LIGHTING & POWER CO. |
| To: | |
| References | |
| NUDOCS 8105040390 | |
| Download: ML19343D385 (44) | |
Text
{{#Wiki_filter:- \\&W pSW f= k 30 'gcy1 g us.$ 4 ggB\\ P UNITED STATES OF AMERICA StC*N U{-{,'[t, NUCLEAR REGULATORY COMMISSION { b 7 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 0 C6 In the Matter of: 5 i 5 HOUSTON LIGFIING & POWER 5 COMPANY, ET AL. 5 Docket Nos. 50-4980L 5 50-4990L 5 (South Texas Project, 5 Units 1 & 2) 5 5 i l I j TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER CCMPANY, ET AL. l OF t MR. G. THOMAS WARNICK MR. CHARLES M. SINGLETON l MR. LOGAN D. WILSON i ON l THE OPERATIONS OF B&R'S SITE QA/QC PROGRAM AND M,\\j'I 4 ALLEGATIONS OF HARASSMENT AND t INTIMIDATION OF QUALITY CONTROL INSPECTORS r p". M. ol eadz 4 " ' 2 ;J e, 1 vh // p
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1 1 l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l ) i In the Matter of: 5 l 5 HOUSTON LIGHTING & POWER 5 COMPANY, ET AL. 5 Docket Nos. 50-4980L 5 50-4990L 5 l (Secth Texas Project, 5 Units 1 & 2) 5 5 4 APPLICANTS' TESTIMONY ON THE OPERATION OF B&R'S SITE i QA/QC PROGRAM AND ALLEGATIONS OF HARASSMENT AND INTIMIDATION OF QUALITY CONTROL INSPECTORS The following is testimony presented on behalf of Houston Lighting & Power Company, et al. (Applicants) and i addresses: (1) various aspects of the Qaality Assurance / I Quality Control (QA/QC) program at STP as administered by Brown & Root, Inc. (B&R) at the site level; (2) the allegation l l l that Quality control (QC) Inspectors have been subject to a i l l pattern of harassment and intimidation; (3) the allegation l l that pour cards were falsified as a result of an alleged card game in mid-1977 and (4) the alleged thwarting of QC Inspectors' communications with design engineers. The i testimony is part of Applicants' testimony addressing the l following portons of intervenors ' Contention 1: l i i
l t I j Contention 1 i There is no reasonable assurance that the activities l authorized by the operating license for the South Texas Nuclear Project can be conducted without endangering the f health and safety of the public in that: i t (7) Quality Control as per the requirements of 10 CFR Part 50, Appendix B, in particular Sections III and IX, has not been complied with, because: i l a. Efforts by quality control inspectors to i verify that design changes were executed in accordance l with the purposes of the original design were repeatedly and systematically thwarted. i l d. There were numerous pour cards that were supposed to record the correct execution of concrete { pours which were falsified by numerous persons. i e. There has been and continues to be i assaults on the Applicant's quality control inspectors, continual threats of bodily harm to those inspectors, I firing of inspectors, and other acts constituting j a pattern of behavior designed to intimidate the inspectors. As a result of the intimidations, certain inspections were never done because the j inspectors decided to play cards over a period of j four months rather than risk their safety on the plant grounds. i l As a result of the foregoing, the Commission l cannot make the findings required by 10 CFR ll50.57(a)(1) ,6 and (2) necessary for issuance of an operating license i for the South Texas Nuclear Project. 1 i The panel of witnesses presenting this testimony consists l of Mr. G. Thomas Warnick, Mr. Charles M. Singleton, and Mr. i l Logan D. Wilson. I The testimony consists of the following segments: I f i. - _
t (1) Mr. Warnick and Mr. Singleton with respect to the l operation of B&R's site level QA/QC program, the allegation that QC Inspectors were subject to a pattern of harassment and intimidation, the allegation that pour cards were falsified l as a result of an alleged card game in mid-1977 and the allegation that the QC Inspectors' communications with Design Engineering were systematically thwarted; and i (2) Mr. Wilson with respect to the allegation of harassment and intimidation of QC Inspectors. 4 e TH:12:C f f i f i I e t l l l l 6 m
I 1l 21 3' 4l 5j TESTIMONY OF MR. G. THOMAS WARNICK AND g4 MR. CHARLES M. SINGLETON ON B&R'S QA/QC 7i PROGRAM AT THE SITE AND ALLEGATIONS gj OF HARASSMENT AND INTIMIDATION OF QC INSPECTORS 9! 0l Q. 1 Please state your names. l2 A. 1 G. Thomas Warnick (GTW) and Charles M. Singleton L3, L4 (CMS). L5, L6 ; Q. 2 Mr. Warnick, by whom are you employed? L7 i L6 A. 2 (GTW): Public Service Company of Indiana. L9 20 Q. 3 Mr. Singleton, by whom are you employed? 21 Zj A. 3 (CMS): Brown & Root, Inc. (B&R). 2~3 i i Q. 4 Please describe your current position and job 4 25 responsibilities? 26 i 27 A. 4 (GTW): I am the QA Tracking and Trending Supervisor 28 29 ' for the Marble Hill Nuclear Project and am responsible for 30 i 31 i programmatic control of the nonconformance report program and 32 i 33 : Quality Assurance (QA) trending program. 34 I i (CMS): I am the civil Discipline Quality Control 35 36 (QC) Superintendent for South Texas Project (STP), and am 37 38 ; directly responsible for all QC inspection activities in the 3 40 areas of concrete. 41 ! I report to the Quality Control Manager for 42 ! the STP. 43 44 I Q. 5 Please summarize your work background, state when 45 46, you were employed by B&R, and describe your positions held with 47 ! 48 l B&R-49 ! 50 : - t
l! 2. 3I 4i 5 A. 5 (GTW): I have worked in the nuclear quality assur-6l 7! ance area for approximately 10 years. Prior to joining B&R, I 8i 9l was employed by Bailey Controls Inc., a subsidiary of Babcock .0 ' and Wilcox, primarily as a QA Manager. I joined B&R in April f.2; 1978 as the Quality Engineering Superv4.sor at the STP Site. I 3 L4 became Site QA Manager in February 1979, a position I held L5 ; L6 ; until June 1980, at which time I became the QC Manager for the L7 i Lg ! South Texas Project. I resigned from B&R in late February 1981 L9 ; 20 ! to assume my current position with Public Service Cor>pany of 71j~ ; Indiana. 23 ' j4 (CMS): My employment history is set forth in my 25 previous testimony regarding STP concrete activities. 26 27 ! Q. 6 Please describe the purpose of your testimony. 28 29 A. 6 (GTW, CMS): The purpose of our testimony is to 30 31 } describe the QA program at STP as administered at the working 32 ! 33 level. Our testimony will address the alleged incidents of 34 35 j harassment and intimidation of QC Inspectors, alleged falsifica-36 tion of pour cards, and the alleged thwarting of QC Inspectors' 37 3 communications with Design Engineers. Our testimony will show 40 l that the incidents of serious confrontations between QC and 41 i 42 i Construction at STP have been isolated occurrences that were 43 ! 44 handled properly by management. There has been no pattern of 45 46, harassment or intimidation of QC Inspectors and there is no 47 ! 48 ! basis for the allegation that inspections were not performed 49 l 50 l 51 i i
1 2V 3{ 4j 5; due to an alleged card game. Finally, our testimony will show 6' 7l that QC Inspectors have not been " thwarted" in communicating 8: 9l with Design Engineers. Q. 7 Please briefly describe the basic Project-level 12 i organizational structure for the B&R STP QA Program which was 13 14 in effect for the period between the issuance of the construc-15 ; 16 i tion permits for STP in December 1975 and the NRC special 17 i lg l investigation conducted in late 1979 - early 1980. 19 l 20 i A. 7 (GTW, CMS): From September 1975 to February 1979, 29 l 2j the day-to-day on-site operations of the B&R Project QA/QC organization were directed by B&R's on-site Project QA Manager. 25 Mr. Terry Gardner held this position from September 1975 until 26 j 27 ! March 1978 and Mr. Charles Vincent held this position from 28 1 29 l April 1978 until February 1979. In February 1979, the Project 30 ! 31 ! QA Manager was relocated from on-site to the Houston Office and 32 ! 3 33 l a Site QA Manager position was established and filled by Mr. I 34 35 Warnick. The Project QA Manager became responsible for coordi-36 nation of all Project related QA/QC activities, including 37 vendor surveillance, quality engineering and Houston QA coordi-40 nation functions. In addition, the Project QA Manager was 4 1 l, 42 l responsible for management of the Site QA/QC activities through 43, 44 l the Site QA Manager. 45 { 46 This Houston Project QA management function was part of i 47 43 the matrix management system adopted by the B&R senior manage-49 50 51 __.
1 i 2. 3l 45' ment in october 1978 for STP. Under the matrix management 6 7i system, there exists for each discipline (Engineering, Construc-8' g{ tion, Material Management, QA, etc.) a Project Manager who is f0f responsible for all Project-related decisions in the particular 12 discipline. In those instances in which an issue arises on the 13 14 Project which, in the judgement of the Project management, has 15, 16 l broad implications for company-wide policy in a discipline 17 i la l area, there is consultation with the central discipline office 19 l 20 i before the problem is resolved at the Project level. 21 ' 22 In the case of QA for STP, when a Project-related QA issue 23 i 24 ' arises which impacts company-wide QA policy, resolution of such 25 ' issues rests with the B&R Power Division QA Manager. This ~ 36 ; 27 ! individual is responsible for all B&R Project QA programs, 28 i 29, including the QA Program for STP. 30 ' 31 i Under the Site QA Manager, there have been QA Supervisors 32 33 l in charge of QC Inspectors in various disciplines; Quality' 34 l Engineering Supervisors, in charge of discipline Quality Engineers; 35 36 f and QA Records Supervisors, as well as other administrative 37 3 positions. The numbers of personnel in these areas have steadily 40 i increased since construction began in 1976. The average numbt: 41 : 42 of QC Inspectors increased from approximately 15 Inspectors in 43, 44 ! late 1976, to approximately 125 Inspectors in 1979. 45 1 46 ' Q. 8 compare your QA job responsibilities at STP with the 47 i 43 l QA responsibilities you had in other jobs. 49 l 50 ' 51 ' i i 1 l 1 2 3 4 5 A. 8 (GTW, CMS): The basic concepts and organization for 6i 7l QC and QA are the same throughout the nuclear industry, although 8 ! 9 particular technical expertise required to fulfill specific job 0 $1 responsibilities will vary depending on the product or activity h2 involved. In addition, a wider range of knowledge and experience L4; is required as individuals advance into higher positions of QA La i L6 supervision and management. In each of our situations, the QA L7 LE l positions we'have held outside the Project have required very L9 10 I similar knowledge and experience as that required in the positions 11 I g2 we have held for at STP. '3 I j4i Q. 9 Explain generally B&R's process for hiring QA/QC personnel. 27 l A. 9 (GTW, CMS): B&R's qualification requirements for 28 1 29 QA/QC positions satisfy the requirements of NRC Regulatory 30 : 31 ! Guide 1.58 (which endorses ANSI N45.2.6 and SNT-TC-1A) and 32 ! 33 ACl-359/ASME Section III, Division 2, for Civil QC Inspectors. 34 35 Resumes and/or job applications describing an applicant's 36 37 experience and qualifications are reviewed by the applicant's 38 l 39 { potential immediate supervisor. If he or she is being considered 40
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for a technical position, qualifications and experience are l 43 l also reviewed by Quality Engineering personnel recognized as 42 l i 44 being technically competent in the applicant's discipline. If 45 l 46 ' the review of the applicant's qualifications indicates that he 47 48 or she meets the basic job requirements, the applicant is then 49 l 50 i 51 l 1 l
i I 1! 2' 3 4 5li interviewed. Based on the interview and evaluation of the 6i 7 applicant's previous job-related education and experience, a 8 9 decision regarding hiring is made by QA/QC management. f0 Q. 10 What levels of B&R management does a QC Inspector 12 l come into contact with, and with what frequency? Has this 13 ; 14 ' organizational arrangement remained the same since the beginning 15, 16 l of the project? 17 i la A. 10 (GTW, CMS): The QC Inspector interacts daily with 19 20 ; his discipline Lead Inspector and with his discipline QC Super-21 ! 22 : intendent. Those individuals represent first and second line 23 1 24 l management and are a crucial link in the communication chain 25 l from the Inspectors to upper management. The Inspector normally 26 27 interacts with the QC Manager on an e.verage of once a week, and 28 1 29 less frequently with the Project QA Manager. This organizational 30 31 l arrangement has remained the same since the beginning of the 32 l 33, Project. 34 l 35 Q. 11 What is the basic role of the QC Inspector at STP? i 36 ! l 37 A. 11 (GTW, CMS): The basic responsibilities of an 38 39 Inspector are the same regardless of which discipline areas are l 40 involved. The role of the Inspector is to provide documented 41 l 42 l verification that the work performed by construction has been 1 43 i 44 done in accordance with the appropriate procedures, specifica-45 46 tions and other related engineering design documents. Daily 47 48 inspections are performed in accordance with pre-planned check-49 50 ; 51 i l I i
l 2. 4l! 3 5' lists provided by Quality Engineering. These checklists provide 6 7! the QC Inspector with specific requirements for t : performance 8; f his work. 9 f0 ! Q. 12 What do.you view to be the role of Construction in 12 the implementation of the B&R QA program for STP? 13 14 A. 12 (GTW, CMS): Construction has the responsibility to 15 16 l fabricate and erect the plant in compliance with approved 17 i lg ! engineering design documents. 19 j 20 I Q. 13 How does QC interact with Co'nstruction? 79 1
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A. 13 (GTW, CMS): QC Inspectors interact most often at the Foreman and General Foreman level of the Construction 4 25 organization. The Inspector discusses work schedules and 26 j 27 { particular conditions arising in his inspection area with these 28 i 29 Construction supervisors on a daily basis, and works with them 30, 31 i closely to resolve problems. 32 i 33 Q. 14 Describe the QC/ Construction relationship at STP. 34 35 Did tension exist between Construction and QC? Was there 36 37 neern ab ut the level of tension that existed? What was done to mitigate the tension? 3 l 40 l A. 14 (GTW, CMS): Since 1977, there have been periods 41 i I 42 ; when there was concern about tensions between Construction and 43 ! I l 44 QC personnel. It is natural for there to have been tension 45 46 resulting from QC's critical evaluations of certain construction 47 ' t 48 activities. In an ideal world, all such criticism would be l 49 50 51 i i i _11_ l
1 2 3; 4, 5 given and taken in a tactful and constructive manner. Unfortu-6 7 nately, this is not always the case in the course of construc-8' g tion of a large project. 10 ' gy B&R Project management was concerned about such tensions, f2 3 and continually emphasized the need for cooperation and teamwork. 14 We think that as the Project has developed, the tensions that 1: 16 existed during certain early periods have been greatly reduced. 17 : 16 We also think that the apparent perceptions by some that there 19 20 was a pervasive " intimidation and harassment" of QC by Construction 21 22 are completely out of proportion, and not well-founded. We know 23 24 nly two instances over the past five years that tensions f 25 resulted in physical contact between a Construction worker and 26 n ~' a QC Inspector. We think it is significant that of the thousands 23, 29 of QC inspections that have occurred, there have been only 30 31 these two incidents. 32 3 33 On these occasions, B&R Project management was aware of, 34 i 33 ' and concerned about the incidents, and in each case, took 36 37 ' immediate and strong corrective action. To the best of our 38 39 ; knowledge, QC personnel were never negligent in carrying out 0! their inspection duties. 42 i Q. 15 Have you witnessed any situations in which physical 43, 44 I contact has occurred between a Construction worker and a QC 45 i 4 6 ', Inspector? l 47 ! ) 48 I 49 i 50 51 ! ! I
1 2, i 2 3l 4l 5l A. 15 (CMS): Yes. I did witness one situation in which 61 7j a disagreement led to physical contact between a Construction 9l 8 Foreman and a QC Inspector. On June 30, 1977, a confrontation l occurred between a Concrete Foreman and a Civil QC Inspector in 12 which, after a heated argument concerning the relocation of a 13, 14 : concrete slick line, the Concrete Foreman grabbed the Inspector 15 l 16 l by the shirt and shoved him backward. The utspector fell into 17 i 13 l an erected section of rebar for a slab placement which was 19 l 20 : directly behind him and the Foreman fell on top of him. After 21 I 22 they got up, the Foreman walked away from the placement location 23 and the Inspector was taken to the site medical center for 24 ; l examination. Both Construction and QC management were summoned 27 by radio and arrived shortly after the incident occurred. They 28 l 2? investigated the circumstances surrounding the situation and 30 31 assured that the work was continuing on the placement in a 3 32 I 34li 33 proper manner. The Concrete Foreman left the site immediately .) 35 l after the incident and was subsequently discharged by B&R. 36 l 37 This incident was investigated by the NRC and reported in I&E 0 Report 77-08. 3 4 (GTW): Yes. I witnessed one situation in which a disagree-42 ! ment led to physical contact between a Construction Engineer 43 ; 44 ' and a (,C Inspector. On March 7, 1979, these individuals were 45 l 46 I working on a concrete pour and had a dispute over pour cleanli-l 47 l 48 ness. The dispute went on for several hours. I was summoned 49 l 50 i l 51 l
i 1 2 3 4' 5 to the placement location, along with Construction management, 6, 7, t resolve the disagreement. While I was there, the QC Inspec-4 8-i g tor called the Construction Engineer a liar and the Construction f f0 l Engineer swung at the QC Inspector, just grazing his shoulder. 12 The Construction Engineer immediately realized his mistake and 13 14 ceased to fight. The QC Inspector was reprimanded for his 15 i 16 unprofessional behavior and the construction Engineer was 17 ' 13 ' removed from the site. 19 1 20 + Q. 16 Are you aware of situations involving verbal threats 29 ; 2} ' between Construction and QC? If so, how were such situations 71 g** handled by B&R management? 25 A. 16 (GTW, CMS): Construction and QC personnel often 26 27 have had verbal disagreements about job related issues. These 23 ; 29 ' verbal exchanges, however, have rarely amounted to what we 30 31 would call " verbal threats", which we define as statements 32 33 presenting serious possibilities of physical confrontation. 34 l 35 ' QA/QC management has urged the Inspectors not to argue with 36 Construction, but rather, to elevate any unresolvable disagree-37 l 3 ments to their Supervisors for resolution. 40 : (GTW): I have never witnessed a situation involving 42 verbal threats between Construction and QC personnel. In my 43 44 ! capacity as Site QA Manager, I investigated personally or had 49 I 46 ' others investigate a few specific clai - of verbal harassment 47 48 ! which were brought to my attention in the latter half of 1979. 49 50 51 :.
I b i 1. 3l4i!! As discussed in Mr. L. D. Wilson's testimony, these investigations 3 l 7I were normally carried out with HL&P's involvement. In most 8j 9i cases, the threats resulted from a specific dispute in which 0 1l one or more parties lost their tempers.. While unprofessional, 2i these verbal exchanges were not serious threats in my opinion. ~, 4 (CMS): Since December 1976, I have only witnessed one 3 6 situation which could be characterized as a " verbal threat". 7i Il This situation involved an exchange between a Concrete General 9! O Foreman and a QC Inspector over a concrete placement problem I i i 2' where the Concrete General Foreman misinterpreted a statement r 3l 4, made by a QC Inspector and lost his temper at the post-placement 5' 6! meeting. ,e' 8 :i On November 1, 1979, I discussed with the Lead QC-Civil 9, Inspector and two of his Inspectors, the problems associated 0' 1I with the concrete placement of the east secondary shield wall, 2l 3l steam generator block-out area which had been made the previous 4! 5 i day. The two QC Inspectors mentioned that construction had 6' cut off the tremies (chutes used to direct the flow of concrete) 7 8i ,g j too short thus resulting in concrete free-fall of about 10 feet l
- 0 l instead of the maximum permissible free-fall of 42 inches.
The l r1 I '2 l Inspectors had mentioned this problem to the Concrete Foreman r3 i I i4 l twice, but he failed to correct the situation. They also had iS I 16; mentioned the problem to the Concrete General Foreman, however, l 17 i l gg ; he did not attempt to correct the condition until they threat-l 19l 10 : 51 ; ! l
1, 2. 3l 4' 5; ened to walk off the pour. I told them that they only need to 6i 7 i tell a Foreman once to correct a situation and that if he 8} gl doesn't correct the condition prior to continuing the pour, f0 they have "Stop-Work" authority. I told them that I would 12 i attend the post-placement meeting and would try to get things 13, 14 straightened out. 15 16 - At the post-placement meeting, the excessive free-fall of 17 i 18 ' concrete and the apparent lack of construction action to correct 19 i 20 the matter was discussed. I informed the Concrete Superintendent ,,jj that the Inspectors had been instructed to stop the pours if 23 4 they had any difficulty in getting items of concern corrected. 25 l The Concrete General Foreman said that based on what he was 6 27 ! told about the problem, he took immediate corrective steps. 28 i 29 one of the QC Inspectors said that he disagreed with the Concrete 30 31 i General Foreman. The Concrete General Foreman replied, " Don't 32 ' 33 call me a liar or I will come across that table after you." At 34 ! 35 i that point, I told the Concrete Superintendent that unless we 36 : changed the attitude of this meeting real quick, we would 37 l 8
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""*9*#'* ^' *# "" 9 40 41 { the topic, we all agreed that better communication was needed 42 i between Construction and QC. Later that day, Construction 43 44 l management met with the Concrete General Foreman to discuss the 45 { l 46 : unacceptability of his attitude and actions at the post-placement 47 l 43 meeting. 49 ; 90 ' 51 i I I l l L
I 1' 2 3l 4, 5, In addition, on one occasion in 1979, a QC Inspector 6 7! informed me that a carpenter had threatened him with a wrench 8i 9 because the Inspector kept turning on a water hose to keep 10 ' yy moist a concrete pour that was curing. The carpenter was 12 i strippir.J forms from the pour and the hose being on made his 13 14 work wet and cold. I went back to the area involved with the 15 16 QC Inspector, but the carpenter was gone. The QC Inspector was 17 i 16 l not able to identify the carpenter, so the Inspector and I 19 t 20 agreed to drop the matter. 21 22 Q. 17 In your view, did there at any time exist "a pattern 23 24 ; f behavior designed to intimidate the inspectors?" 25 A. 17 (GTW, CMS): No. Although there were job gripes by 26 i 27 ! Inspectors, together with natural QC/ Construction tensions, as 28 i 29 ' discussed above, these never amounted to any " pattern of intimida-30 ; 31 l tion." In the five years of construction, there have been only 1 32 ! i 33 j two situations of physical contact between QC and Construction 34 1 35 l personnel, and although everyone viewed these instances as 36 l 37 l highly unfortunate, they do not amount to any pattern of assaults 38 i 39 l on QC Inspectors. Even those directly involved in these situa-40 tions have explained them as isolated emotional exchanges 42 rather than a part of a pattern of harassment. 43 44 l Q. 18 Do you know of any case in which an Inspector was 45 l 46, fired as part of a " pattern of behavior designed to intimidate 47 i 48 l the Inspectors?" 49 l 50 ; 51 l
1 4 2 3' 4; 5 A. 18 (GTW, CMS): Absolutely not. Inspectors were 6' 7; terminated for different reasons, including such things as 8 9, excessive tardiness, excessive absenteeism, insubordination, or 10 false information on an application form. We know of no incident 12 in which a QC Inspector was fired in order to intimidate that 13 14 Inspector or other Inspectors on the Project. 15 16 Q. 19 What technical knowledge is required for a QC 17 Ig i Inspector to competently perform his duties? 19 20 A. 19 (GTW, CMS): The technical knowledge required of an 2}9 Inspector varies depending on discipline. In general, an 3 23 24 Inspe tor does not need the level of engineering expertise 25 required to design a structure, but must have sufficient technical 26 1 27 ! knowledge of his particular discipline to understand technical 23 - 29, terminology and to understand and interpret the design / con-30 ' 31 i struction requirements established by the Engineers. On the 32 > 33 l other hand, an Inspector will often be more familiar with, and 34 l 35 i experienced in, judging the adequacy of construction practices 36l' than the original designer would be. l 37 l 30 Q. 20 Would there be situations in which an Inspector 39 40 ! would need additional engineering quidance in order to fully 41 42 perform his work? 43 l 44 l A. 20 (GTW, CMS): Although an Inspector would have the 45 l i 4 6 ', basic skills necessary to read and apply various design /construc-l 47 i 43 ! tion requirements, there are situations in which an Inspector's 49 ' 50, 51 : l i _
1 2, 3l ~ ~ 4' 5t interpretation may differ from a constructor's interpretation, 6' 7; and a higher level of quality or design engineering clarifica-8i g! tion is required. f0 f Q. 21 Mr. singleton, in light of the panel's response to 12 l question 20, please explain the intent behind a memo, dated 13, 14 April 18, 1979, from you to all Civil QC Inspectors, limiting 15 16 communications between QC and Design Engineering to "a level no 17 i lg ' lower than the Lead Inspectors." 19 i 20, A. 21 (CMS): I wrote that memo after receiving comments 29 gj from both Construction personnel and QC management that inspec-23 ' 24 tors were spending too much time out of their assigned inspection 25 26 ; areas discussing design issues with Design Engineers by telephone. 27 The primary intent of that memo was to assure that the Inspectors 23 29, were available at all times to perform their required field 30 i 31 ' activities. It was not intended to prevent a QC Inspector from 32 33 obtaining design engineering clarifications. The memo was 34 ! 35 i consistent with the QA organizational structure, and the func-36 37 j tional job description for QC Inspectors and Lead Inspectors. 38 ! The Lead Inspector generally has equivalent or greater technical 40 l expertise than an Inspector working under this direction, and 41 42 in addition, he has first line supervisory responsibility for 1 43 ' 44 l the Inspectors assigned to him. Furthermore, similar questions 45 1 46 often arise with respect to design documents used throughout 47 1 48 l the plant, and I felt it was important to try to have consistent 49 ; 50 51 ! i k 1! 2: 3l 4l 5; QC resolution of such questions, by assuring that resolution ~ 6; 7 was achieved at the management level. In short, I felt that 8 9, the best distribution of responsibility was to have Inspectors f0 take up design interpretation questions with Lead Inspectors 12 i who would then decide, with Engineering input as needed, the 13 ! 14. resolution of such Inspector questions. 15 ! - 16 ' In retrospect, we might have done a better job of com.muni-17 i 18~ ! cating to Inspectors the resolution of the design questions 19 i 30 ' raised by them. However, one of the difficult problems in 21 : 2] ! supervising QC Inspectors is that there is a natural tendency 23 for a motivated Inspector to want to make individual judgments 25 ' as to engineering adequacy, as opposed to performing the more 26 i 27 i limited function of verifying compliance with engineering 28 i 29 ! design documents as he is supposed to do. It is the task of 30 ! 31 ! the discipline QC Supervisor to make sure that the Inspector 32 I 33 understands the scope of his review. 34 35 j Q. 22 Mr. Warnick and Mr. Singleton, who in the organiza-36 j tion is responsible for verifying the design, if it is not the 37 0 Inspector? 40 A. 22 (GTW, CMS): Once the design is completed by the 41 42 designer, it is submitted to another individual in B&R design 43 1 44 Engineering with equivalent technical expertise who was not i 45 1 46 involved in the original design. Through the use of alternate f 47 48 or simplified calculation methods or by the performance of a 49 50 51 i 1i 2: 3l 4j 5! suitable testing program, this reviewer checks and verifies the 6, 7i adequacy of the original design. These documents are then 8i g{ transmitted to the appropriate HL&P Design Engineering group LO i for their review and concurrence. gy 12 ) Q. 23 How are nonconformances identified and resolved? L3 14 A. 23 (GTW, CMS): The procedures for handling nonconform-La 16 ances have been changed in some details a few times over the L7 LE ' life of the Project, but they have generally been handled as 19 ; 20 ; followsi Nonconformances are usually identified by QC Inspectors 2~1 g during final inspections, and are documented on a Nonconformance 23 24 ; Report (NCR). Valid NCR's are forwarded for Engineering disposi-25 I 26 ; tion and the Engineer usually will make one of the following 37 dispositions: (1) use-as-is (the departure has no adverse 28 i 29 ! impact on a safety margin and Construction may proceed as is); 30, 31 ' (2) rework (the condition is not acceptable as is, and must be 32 < 33 l changed by Construction to bring it into conformance with the 34 i 35 j design document); (3) repair (the condition is not acceptable, 36 37 j cannot be reworked, and must be made acceptable by some approved 38 3g j alternate method, such as grouting of concrete voids or removing 40 l defective weld material and rewelding); or (4) scrap (the 4 42 { condition is not acceptable and is not able to be reworked or 43 ! 44 f repaired, and must be removed). 45 i 46 I t After the NCR is dispositioned, it is sent to Construction 47 i i 48 l or to another discipline as appropriate, for implementation of 49 ' 50 l 51 ! l i ! l
1l 2, 3l 4; 5i the Engineer's disposition instruction. The QC Inspector then 6: 7t reexamines the work against the Engineer's instruction, and if 8 9t the work is found acceptable, closes out the nonconformance and 10 I i records this on the NCR. If not acceptable, he notes this on yy 12 l the original NCR and writes a second NCR, and the above cycle 13 ; 14 is repeated. 15 16 ; Q. 24 was there a concern by Inspectors that Nonconformance 17 i 13 ' Reports were not being properly resolved, in the time prior to 19 i 20 i the order to Show cause? 21 ! 22 : A. 24 (GTW, CMS): Some Inspectors were concerned over 23 i 24 : the number of nonconformances that were dispositioned "use-as-is." 25 ' Unfortunately, a number of Inspectors apparently viewed the 26 i 27 ' "use-as-is" disposition as a conclusion by Engineering that 28 i 29 there was no basis for the original nonconformance. In other 30 31 l words, the Inspectors fel,t they were being told that their 32 i 33 i conclusion was wrong. 34 l l 35 l However, Site QA management understood that the "use-as-is" l 36 : resolution was not a criticism of the Inspector's nonconformance 37 l 38 i l 3g j report, and tried to make the Inspectors understand this. It 40 l was stressed by QA/QC management that the Inspectors should 42 i continue to identify all nonconformances without concern that 43 44 similar nonconformances may previously have been dispositioned 45 46 "use-as-is." As previously stated, we believe that Inspectors i 47 i 48 { did just that, and that all nonconformances were identified. l ~49 i i 50 i 51 l l -
1 2: 3! 4l 5; Q. 25 Was Construction critical of the number of noncon-6i 7: f rmances issued by QC Inspectors? 8! A. 25 (GTW, CMS): As already stated, there is a natural 9, 10 l tendency for some Construction workers to be unhappy when their L1 : 12 ! work is subjected to unfavorable review by Inspectors, and this 13 ' 14 was the case with some Construction workers at STP. Furthermore, 19 i 16 j some Construction workers viewed Engineering's "use-as-is" 17 i 1g ' dispositions as evidence that Inspectors were being overly to ' gg ' critical of Construction, and made this known to the Inspectors. 2}1 2 Q. 26 Regarding the criticisms discussed above, do you '3 24 i think the Inspectors were satisfied that they had adequate 25 backing and support from their QA management? 26, 27 ; A. 26 (GTW, CMS): With respect to the "use-as-is" situa-23 : 29 : tion discussed above, it was important to the Inspectors that 30 ' 31 ! their Site QA management defend the nonconformances being 32 33, written and support the Inspectors when construction was critical. 34 I 35 l In this area, the QC Inspectors generally viewed QA management i 36 37 j as supportive of their nonconformance reporting practices. 30 However, to the extent that the Inspectors themselves were 39 i 41 l unhappy with the number of "use-as-is" Engineering dispositions 40 l 42 ' l as discussed above, there did persist the feeling by some i 43 1 t 44 Inspectors that somehow B&R management should reduce the number l 45 46 of "use-as-is" dispositions and that the failure to do so 47 i i l 43 l represented "a lack of management support." QA management's 49 i 50 i 51 !
1 2 3! 4' 5 position was to keep stressing that Inspectors should continue 6 7, to identify all nonconformances. We believe Inspectors con-8 g, tinued to perform all required inspections and to identify all f0 ; nonconformances. 12 i Q. 27 13 Was Construction critical of the QC Inspectors for 14 reasons other than alleged excessive writing of nonconformances? 15 16 A. 27 (GTW, CMS): Yes. There were, from time to time, 17, lg criticisms expressed to QA management that Inspectors were not 90 30 available at the proper time to perform required inspections, 212j and that this unavailability of Inspectors resulted in unneces-23 24 ' sary delays, and in cost and schedule impacts that could have 25 been avoided with no adverse impact to the QA functions. In 26 27 addition, there were some complaints that Inspectors were not 33 29 always as tactful as they should have been in communications 30 31 with their peers in Const.ruction during inspection activities. 32 ' j 33 To the extent that those criticisms were well-founded, such j 34 i 35 j actions by Inspectors resulted in a worsening of the natural 36 tension that existed between QC and construction. QA management 37 l 30 was of course, concerned about such criticism, and stressed to g 40 i Inspectors that they should make every effort to perform thorough 42 inspections as efficiently and in as timely a manner as possible. 43 44 Q. 28 Were there criticisms of QA management by QC Inspectors 45 \\ 46 ' other than those discussed above? 47 48 : 49, 50 ' 51 4 I l A. 28 (GTW, CMS): Yes. QC Inspectors have complained I l that they were not being given adequate salaries and other job benefits. Although these Inspectors were initially satisfied enough with Inspector salaries and benefits to cause them to accept employment c.s Inspectors, once they were on the Project, they tended to feel that remuneration and other recognition was not increased sufficiently over time. In fact, however, salaries have been substantially increased. Other than salary, common Inspector complaints centered on [{ the need for such things as pick-up trucks, field radios, field shacks (as opposed to smaller metallic " gang boxes" similar to l! those used by craft personnel), and gold-colored construction i hats (denoting management status). Without these benefits, Ii i-Inspectors felt that they appeared to have "second class status." l .i QA management worked to obtain upper level B&R and HL&P authori- !I i. zations for such benefits, and these have been instituted over i ! 5j time although not as fast as some Inspectors would have liked. 4 l In addition, on occasion a QC Supervisor would have to I! overrule an Inspector's decision on a particular issue. While ) fl this rarely happened, it may have been perceived by some Inspectors .i as a lack of management support. In reality, however, it was 3l 8 I simply part of the Supervisor's job to correct errors made by 5 5 his Inspectors or exercise judgment based on his experience. 3 I\\ 3; 3 i 3 l 1 i l' 2 3l 4; 5, Q 29 With reference to the QC Inspector criticisms 6t 7i discussed above, to your knowledge, did the Inspectors feelings 8 9 and attitudes which caused such criticisms to be made ever f0 adversely affect an Inspector's job performance? 12 l A. 29 (GTW, CMS): No. We are not aware of any situation 13, 14 in which an Inspector's dissatisfaction with management resulted 15 ' 16, in a failure to properly and fully perform all required inspec-17 4 l g ', tions. 1C go l Q. 30 Mr. Singleton, it has been alleged that certain QC 2 22 i inspections were not performed beginning in July 1977 because 23 certain Inspectors decided to play cards rather than " risk 29 l their safety on the plant. grounds". Do you know of any instances 26 ; 27 I in which required inspections were not performed because of 28 i 29 i card playing, fears about personal safety, or for any other 30 ! 31 ! reason? 32 l 33 i A. 30 (CMS): This charge is totally without basis, and I 34 I 33 l believe the NRC Staff has fully investigated such charges and 36 l concluded the same. There had been from time to time, during 37 l 33 periods of especially low construction activity, some card 40 playing among QC Inspectors during working hours. I recall a 41 42 l period between December 1976 and January 1977 when this occurred. 43 i 44 Subsequently, there has been no card playing except during 45 46 lunch breaks. Although I have been accused of being one of the 47 ! 43 l card players during mid to late 1977, I have no knowledge of 49 l l 50 l 51 l i t these alleged card games. In no case was there a failure by a QC Inspector to perform a required inspection because of card j playing. l Q. 31 Mr. Warnick and Mr. Singleton, what is your overall i assessment of the effectiveness of the STP QA program during your association with STP? i i A. 31 We are confident that all significant structural i deviations have been identified by QC. We are aware of the i welding and concrete problems that have come to light in the i course of the project. What we are saying is that the QA/QC i program has identified these matters. We take personal offense at any suggestion that QC on this job was not performed properly. The QC program was working as j evidenced, in part, by the problems that have been identified through thy NCR's written in the course of carrying out the QC program. As stated several times already, there was no pattern j of harassment or intimidation of QC Inspectors, nor are we l l aware of any QC Inspectors who have failed to perform assigned 1 l inspections as a result of attempted intimidation or harassment. i l I l T. Hudson:11:02:F t i l l,
l I; i; Testimony of Mr. Logan D. Wilson ii On Allegations of Harassment and Intimidation of QC Insoectors P l 1l Q. 1 Please state your name, occupation and work loca- ) I;' tion. 1 I
- i A. 1 L. D. Wilson.
I am employed by Houston Lighting i I & Power Company (HL&P) at the South Texas Project (STP) con-I i struction site as Project QA Supervisor, Mechanical /NDE. t, [l Q. 2 Please describe your educational background and ) ) work history prior to your employment at STP. l A. 2 I graduated from Sam Houston State University in i 1968 with a Bachelor of Science degree in Industrial Arts. I I From 1967 through 1971, I was employed by Todd Shipyard's a, 7 Nuclear Division and worked on the nuclear ship U. S. Savannah. ) i My assignments included: drafting, conceptual design of 3, facilities and equipment, prototype testing, procedure and L 3 welder qualification, welding engineering and stress analysis. .f! I was in charge of the work crew performing the modification 3 I 2Il of the Savannah's reactor core II. This work required i 3' extensive involvement in we.lding design and construction and ) ! ) quality control requirements. L g In 1971, I joined Southwestern Gas Pipeline. My assign-3 g ments included (1) the drafting of specifications and proce-dures for pipeline construction, testing, operation and 2 i maintenance; (2) qualification of welders; (3) calculations g 31 3i lI , k
i I and design of pipelines; (4) construction projects, including gas handling, compressing and metering stations. I also was i l in charge af the company's safety program and its compliance l with applicable state and federal regulations. In 1974, I joined the HL&P Quality Assurance (QA) i Department. I worked extensively on a fuel oil pipeline project which involved surveillance of welding activities. f In the course of this work, I supervised and assisted in the interpretation of approximately 40,000 radiographs of various welds. I also worked on the Allen's Creek Nuclear Generating Station QA program in an off-site capacity. Q. 3 Please describe your work history at STP. l A. 3 I came to the STP site in March 1976 as Lead i Specialist-Mechanical Section in HL&P's QA department. In j this capacity I was primarily responsible for implementation of the QA program as it related to the mechanical disci-pline. I reported to Mr. S. A. Viaclovsky, the HL&P Site QA l Supervisor. In November 1978, I became the Site QA Supervisor for HL&P with administrative responsibility for the overall i site QA program. Following the NRC's Show Cause Order of April 30, 1980, HL&P reorganized the QA department by re-I moving several layers of off-site management and moving the I head of the program to the site. I became the Project QA Supervisor, Mechanical /NDE in the reorganized QA department. I s23-
i li 2 3] 4! 54 My group provides programmatic and technical direction in 6, 7; the formulation and implementation of B&R's QA/QC program 89l for Mechanical /NDE activities. 10 lI yy Q. 4 What is the purpose of your present testimony? 12 A. 4 I will describe, from the perspective of the HL&P 13 14 site QA personnel, HL&P's review and participation in the is ' 16 resolution of concerns regarding harassment.and intimidation 17, 16 ! of Quality Control (QC) Inspectors by Construction forces. 19 i 20 t Q. 5 Have there been instances at STP of physical 21 23 ' confrontations between QC Inspectors and Construction personnel 23 ' or verbal threats directed at QC Inspectors by Construction 24 i '5' personnel? 26 ; 37 ! A. 5 Yes, there have been several such instances. 28 29 i While the number of cases has been small, these were matters 30 ' 31 : deserving of management attention. The evidence does not 32 l 33 indicate that there was ever any widespread pattern or plan 34 35 of harassment designed to intimidate QC, nor has the quality l 36 I of construction been adversely affected. We believe that 37 j 38 ' 39 ; appropriate measures have been implemented on the Project to 40 l minimize the likelihood of similar cases occurring in the 41 i 42 i future. 43 i 44 ! Q. 6 When did you first become aware of any physical 45 46 confrontations or verbal harassment involving QC Inspectors? 47 ! 48 ! 49 ! 50 l 51 ! i t A. 6 From the time I arrived at the STP site in March i. l 1976 until mid-1977, I saw r.athing, nor was anything brought i l to my attention, indicating that Construction forces were l harassing or attempting to intimidate QC inspectors. I I first became concerned about the degree of tension between the Brown & Root (B&R) Construction and QC personnel following a physical confrontation between Mr. James Marshall (B&R QC) and Mr. Joe Bazea (B&R Concrete Foreman) on June 30, 1977, which is described in the testimony of Mr. Singleton. l l Q. 7 How did HL&P become aware of the Marshall inci-dent? i A. 7 We did not witness the event, but were promptly I informed by B&R. Q. 8 How did HL&P respond to this incident? h. 8 We were concerned and I instructed one of my inspectors to investigate the situation. As a result of the l investigation, I wrote a memorandum which Mr. Viaclovsky l f sent Mr. Phillips, the immediate off-site supervisor of HL&P's STP QA department, setting forth our concerns. i Although the Marshall incident was an isolated incident involving QC and Construction personnel, we were concerned i j that the quality of work on the Project would be jeopardized if QC Inspectors were intimidated in the performance of i their inspection duties. We felt that a strong response by 1 [ +l l l -o1-L
1 2 3l 4! 5, B&R would help to clear the air and to set a proper standard 6, 7i for future Construction-QC relationships. 8' 9l Q. 9 Did Mr. Phillips take any action upon receipt of your memorandum? 12 A. 9 Yes, he and Mr. Asbeck, HL&P's Site Construction 13 14 Manager, met with Mr. Carl Crane, B&R's Construction Project 15 16 ; Manager, to discuss our concerns. Mr. Crane subsequently 17 i is ! reported to Mr. Asbeck that B&R had taken the following 19 ; 20 actions: 2"' 2 (1) held a meeting at which QC and Construction Super-visors were told (i) that disagreements in the 24 25 ' field shall be passed up the line of command for 26, 27 ! resolution in a business-like manner and not 28 4 29
- resolved by arguments in the field and (ii) that 30 !
31 : failure to follow the policy would result in 32 I 3 1 33 ! disciplinary action; l 34 ! 33 l (2) held a meeting with all concrete personnel to 36 explain the policy described above; and 1 37 30 (3) informed the QC Inspectors that disciplinary j 40 l action would be taken against anyone who was 41 > 42 threatening then. 43 ' 44 i Q. 10 Was HL&P satisfied with the actions taken by 45 1 46 ! B&R? 47 ' l 48 t 49 ' l 90 i 51, i l l
f A. 10 Yes. Such action was adequate in light of the events that had occurred at that time. We had investigated l the matters thoroughly, made recommendations to B&R and saw that the problems were addressed by B&R. Our interviews I indicated that the QC Inspectors were not being intimidated, i that no quality problems were being overlooked and that the Marshall incident did not amount to, or evidence, a pattern of harassment or intimidation directed at QC Inspectors. Our findings were confirmed by the NRC's investigation which included interviews with all Civil QC Inspectors and was reported in I&E Report 77-08. Q. 11 Have there been any other physical confrontations i between QC Inspectors and Construction personnel since the Marshall incident in mid-1977? l A. 11 I know of only one incident that has occurred i since then. This incident occurred on March 7, 1979, and I involved a B&R Construction Engineer, Gary May, and a Civil i i i QC Inspector, Jerry Lacey. These individuals were working I on a particular pour and a disagreement started over the cleanliness of the pour. The disagreement started early, continued during the morning and became more heated as the day progressed. Eventually Mr. Lacey indicated that Mr. May I i !l was a liar and Mr. May took a punch at Mr. Lacey, grazing i: his shoulder. Mr. Lacey grabbed Mr. May who regained his I ! ) composure and the incident ended. I i . i -au-
i B&R took the following actions within two days of the incident: l (1) removed Mr. May from the site; '{ (2) reprimanded Mr. Lacey for his unprofessional i I conduct; and (3) gave the Inspector's Supervisor, who was present i, throughout, a three day suspension for allowing the situation to deteriorate to a physical i; confrontation. I personally investigated this matter for HL&P by interviewing eye-witnesses. B&R's response was appropriate !l and demonstrated strong support for the QA/QC program. The i, '{ NRC also investigated this incident and reached the same Ii ) l conclusion in I&E Report 79-04. Il Q. 12 Did you sense friction between B&R Civil QC and i !*l Construction personnel in 1977-78? A. 12 There is always some friction between construction s I! and QC, if QC is performing its job, and the level varies fi I I! from time to time. The nature of the relationship between ) ) Construction workers and the QC Inspectors who review their t; work assures that there will be some degree of tension 3i g' between the two organizations. In fact, as a QA man, I would be suspicious if there were no disagreements, or g friction, between QC and Construction. It appeared to me, 3 : 3 i L \\
k 1< 2 3i 4' 5 however, that there might have been more friction than 6, 7; necessary at STP in 1977 and 1978. It is ironic that this S9{ QC-Construction friction is cited by some as evidence of a 10 l " breakdown" in the QC program, because the friction that 11 12 ' existed actually evidences just the opposite. This greater 13 14 than normal friction would not have existed at all if QC had 15 16 not been doing its job and doing it well. A " breakdown" in 17 ig QC would have resulted in little or no friction with Construc-19 ' 20 tion. 29 2} Q. 13 Was the existence of QC-Construction friction 23 the same thing as " harassment and intimidation" of QC? 24 25 A. 13 Absolutely not. We were concerned about this 26, 27 friction because it could cause harassment, abuse, or attempted 23, 29 - intimidation, which could result in non-conformances being 30 ' 31 overlooked; but QC-Construction friction is not the same 32, 33 thing as harassment or intimidation. Most QC and Construction 34 i 33, personnel have properly performed their jobs under pressure 6 and with some friction between themselves, but without abuse 3 38 or harassment from either side, that is, they have performed 39 40 as professionals should. 41 42 I&E Report 77-08 found that in one instance threats had 43 44, been made by and to a QC Inspector and that minor harass-45 ! 46, ments, such as offensive comments on the radio, had been 47 - 48 directed at some of the QC Inspectors. During the period 49 ' 00 51 ! 1 2. 3! 4, 5; 1977 through mid-1979, however, neither HL&P nor the NRC, as 6i 7 evidenced by the I&E Reports, was receiving specific allega-8 tions of serious threats or abuse being directed to QC 9 f0 Inspectors. The Inspectors' principal complaints in this 12 time period related to inspection burdens and problems they 13 14 perceived with QA/QC management rather than Construction. 15 16, Thus, while we were concerned that the QC-Construction 17 i lg l friction could lead to abuse or attempted intimidation, we lo l {0 ; received no indications from the QC Inspectors that there 29gj were problems in this regard. }'3' Q. 14 Would you have known if B&R QA/QC was receiving 4 25 any specific complaints of harassment or intimidation? 26 ; 27 ! A. 14 Yes. We were in daily contact with B&R QA/QC 23 1 29 ; management and they were equally sensitive to the issue of 30 ', 31 i possible harassment of QC Inspectors. We had meetings on a 32 l 33 ' more or less weekly basis to discuss QA/QC matters and they 34 w uld have raised this issue had they received complaints of 35 36 i this nature. In addition, HL&P had QA personnel in the 37 30 l field quite often and nothing spread faster on the Project than 39 l 40 news of any type of confrontation between workers. l 41 42 : Q. 15 Since the Marshall incident in mid-1977, has 43 1 44 HL&? had any other occasions to be concerned about potential 45 46 harassment or intimidation of QC inspectors? 47 48 { 49 l 50 i l l t
l l A. 15 Yes, as discussed in Dr. Broom's testimony, Mr. Swayze was fired on August 22, 1978. Mr. Swayze claimed that his firing was a form of intimidation and the NRC i immediately initiated a site investigation. In light of [ this allegation, the unusual circumstances of Mr. Swayze's firing, and the NRC investigation, we were concerned that some QC Inspectors might improperly interpret the firing as an attempt at intimidation. To guard against any deterioration in QC, HL&P increased its formal and infornal surveillances of concrete placements in September 1978 and for several i months thereafter. The formal surve illance, i.e, a surveillance which is documented on a checklist, was normally done once a month, but in September we performed five such surveillances. Ii ) We performed at least two in each of the next eight months. In addition, the informal, undocumented surveillances were I.
- i substantially increased in September 1978.
By having our I people out in the field more often, we were able to evaluate i I the QC Inspectors' reaction to Swayze's firing and its i; I' impact on their job performance. 3 ) Q. 16 What was the conclusion of your evaluation? L A. 16 Mr. Swayze's firing had no adverse impact on the g 3' QC Inspectors' job performance. It appeared to us that the l Inspectors were continuing to do a good job. Our observations 2 I i confirmed statements made by the individuals interviewed by 3 i 9 3 i 1
I l I, the NRC as reported in I&E Report 78-14. All of these i r individuals, except Mr. Swayze of course, doubted that i Sway:e's firing would adversely affect the job performance I of other Inspectors. I Q. 17 Were any other steps taken at this time to 1 I insure that QC Inspectors would not misinterpret Mr. Sway:e's I i termination? I y A. 17 Yes. B&R's Site QA manager issued a memorandum ) ) to all QA/QC personnel confirming management support for i { their activities. The memorandum reiterated that QC Inspectors f did not have to put up with verbal abuse from any level. QC e 3 Inspectors were instructed not to react to verbal abuse, but 3 7, rather, to report any incidents to management. The memo-3 3 randum also confirmed that Inspectors were not to corpromise 3 i the design requirements by overlooking violations of Codes 2-or Standards during their inspections. 3 .f Q. 18 Has HL&P taken seriously any threats made against l 5. QC Inspectors and verbal abuse of Inspectors? 7,. 3' A. 18 Yes, we have always investigated any complaints 9 3-of this type and taken appropriate action. This problem, however, is much tougher to deal with than physical confron-l ~ 3 4 tations because language at a construction site that consti-i a, ~l tutes verbal abuse to the listener may be the speaker's s' i normal and natural way of expressing disagreements. When a l i 9 l o! 1, 1 l -se-l t
1, 2, 3i 4' 5. Construction worker tells you that he disagrees with a 6l 7 criticism you have made of his work, he is not likely to use O the terms of a lawyer, i.e, " Sir, I beg to differ with you 10 on that point." Instead, the Construction worker is likely 11 12 ! to be loud, direct and possibly profane in communicating 13 14 that you are wrong. Unfortunately, to some QC Inspectors 15 16 this type of conversation may constitute verbal abuse, even 17 ig ; when it was not so intended by the speaker. 9e ; }} I want to stress that I do not approve of using 21 abusive or profane language in work situations. Nor am I 22 23 suggesting that all allegations of verbal abuse result from 24 25 misunderstandings of this type. There have been a limited 26 : l 27 i number of instances of true verbal abuse of QC Inspectors. 28 4 gg, But not every comment a QC Inspector finds offensive constitutes 'O verbal abuse. It is reasonable to demand, and we do demand, 31 : 2 that no person lose his temper to the point of striking 3 3o ! 34 another person, but it is unreasonable to require that every 36 Construction worker conduct himself so as to not offend any 37, i 1 38 l QC Inspector, and vice versa. We and B&R investigate all i 39 40 i complaints of verbal abuse or threats and action is taken 494j, when warranted. The actions taken have included reprimands, l 4}'l suspensions without pay, and firings in extreme cases involving 4 45 serious threats. l 46 47 l 48 ! 49 l l 50 ' i 51 ; -J7-L
I Q. 19 What actions has HL&P taken with respect to the allegations of physical confrontations with or verbal abuse f and harassment of QC inspectors? l [ A. 19 As I noted earlier, there were no specific allegations of this sort brought to our attention prior to mid-1979, other than the Marshall and Lacey incidents and Mr. Swayze's termination of employment. After both the Marshall incident and Mr. Swayze's termination, the QC l inspectors were informed that they did not have to take verbal abuse or threats from anyone and that these matters should be reported to management for resolution. The actions j taken by B&R after the Lacey incident in March 1979 demon-strated again that such events were taken seriously and that sanctions would be applied when warranted. i While no specific allegations of harassment or abuse that could be investigated had been made to us, we were i aware of the friction between QC and Construction and in-I creased our surveillance of concrete pours in an attempt, in part, to control this situation. Beginning in early 1979, EL&P QA personnel covered almost all major concrete pours. l i l These personnel were instructed to be particularly alert to t l any harassment or intimidation of QC Inspectors and to l report such incidents to me. Since concrete placements had i been the scene of past controversies, we thought our presence 1 l I i -4v-
l i 1l l 2, 3l 4l 5; would tend to preclude such behavior. I also worked out an 6! 7' arrangement with Mr. Warnick at B&R whereby he would inform 8 9 me as soon as he became aware of any such allegations and 10 11 l enable HL&P to participate in the initial investigations. I 2 i did this so that HL&P would have a better understanding of 14 any allegations and to demonstrate to any QC Inspector la 16, making an allegation that HL&P, as well as B&R, was concerned 17 lE ! and involved in the resolution of his or her concerns. 19 i 20 i Q. 20 Have HL&P and B&R jointly investigated any 21 ' 22 allegations of abuse or threats directed at QC Inspectors? 23 i' A. 20 Yes. The first specific allegation of this 24 20 nature since the Marshall incident of which I am aware 6 27 ! occurred in August 1979. Mr. Warnick and I jointly investigated 28 i 29, allegations made by two QC Inspectors that five Construction 30 ! 31 ' Superintendents or Foremen had threatened them. HL&P also 32 ; 33 : reported this allegation to the NRC. While we generally 34 1 35 l confirmed that the Construction personnel had made the 36 ' statements attributed to them, or similar statements, it was 37 38 39 j very difficult to determine whether these statements were 40 truly serious threats. Because the statements represer.ted, 42 i at a minimum, unprofessional conduct by relatively senior 43 ! 44 Construction personnel and were interpreted as serious 45 46 threats by the QC personnel, the Project Manager reprimanded j 47'! 48 L 49 i F 50 51 -
the Cons truction personnel and warned the= that any repeat would result in dis =issals. In late Nove=ber 1979, I spoke with both QC Inspectors and sc=e of the Construction 7ersonnel and neither group reported any subsequent proble=s. Since {' then I have seen one of the QC Inspectors on several.cccasions and have inquired about harass =ent/ abuse prcblems. On each l occasion the answer has been that no proble= existed. I' Q. 21 Eave there been any other allegations of harass-6 i =ent or abuse since the August 1979 incident described ~ above? A. 21 Yes. Between August 1979 and year-end there I were several allegations, one of which involved the incident t t witnessed by Mr. Singleton and described in his testi=cny. I I All allegations were investigated and the actions taken ) included reprimands and terminations. Q. 22 What actions were taken by EL&? and B&R as a 1 esult of the cc= plaints investigated in late 1979 and the 3 i 3 NRC investigation during the same peried? 7 I l A. 22 As described in EL&P's May 23, 1980 Tesponse to l ) l 3 the NRC Notice of Violati:n, many actions were taken by EL&P l and B&R to provide positive support by management and eli=inate l 3 ( l any harassment, intimidation and threats to inspection l 2 3 yersonnel. The revision of procedures for handling Non-1 l 3 Conformance Reports as well as the adeption of new precedures l 2 1 o l L 1 ! 1
-i L, Ii i ! for resolving disputes between Construction and QA/QC personnel i 7j were aimed at eliminating confrontations which could result in harassment and at improving perceptions of the " fairness" Ii of decisions reached. Steps have been taken to improve !i morale of B&R's QA/QC personnel through job reclassifications, I' I salary reevaluations, more frequent contacts between QA I' management and site QA/QC personnel, emphasis on the B&R il y "open door" policy for all employees and refresher training ) courses. HL&P has increased its involvement in the QA/QC ) l program at the site and taken steps to improve HL&P QA I' visibility in the field and thus lessen the probability of I: i. harassment and intimidation. Accordingly, in addition to i' 7l attending virtually all concrete placement meetings as well I, as concrete placements since early January 1980, HL&P personnel ) have been instructed to spend more time in the field, have s been provided "high-visibility" hard hats, have received Il I extra radios so as to better monitor B&R radio traffic, etc. I l Ij Q. 23 Have these measures been successful? 7l 1l A. 23 Yes, we believe they have. I am aware of only ) l l } two substantiated instances of threats or confrontations [ between QC and Construction since the Show Cause order was !I issued. In one instance both the QC Inspector and t he
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!l Construction man were at fault and both were suspenced for 3 Ii days without pay. In the other incident, a construct.on 1i j ) ! l 3! l Li l I { t
l worker made an idle threat, apologized immediately, but was i disciplined anyway. In addition, B&R surveys and NRC inter-i views have confirmed that the Civil Mechanical and NDE QC i i Inspectors do not perceive that they are being harassed. I l l See I&E Report 80-25. The possibility of future conflicts between Construction and QC personnel cannot be precluded at STP anymore than at i i any other large censtruction site. Construction forces, however, now have a much better appreciation of QC's role and the importance of that role. Moreover, both Construction and QC personnel understand that neither B&R nor HL&P will I tolerate fighting on the job or other forms of harassment or l l intimidation. i Q. 24 Have the incidents of harassment and attempted intimidation resulted in any non-conforming conditions being overlooked? i i A. 24 We have asked this question in every investigation i and the answer always has been negative. There is no evidence indicating that these problems have resulted in deficiencies l which compromise the quality of the work completed to date. This fact was confirmed by the NRC in I&E Report 79-19. i l I 'r. Hudson : 06 : D I i i i "$N"}}