ML20125C236

Rev 1 to QA Procedure Qasp 19.13, Response Validation

ML20125C236
Person / Time
Site:	Waterford
Issue date:	10/23/1984
From:	Baldwin W LOUISIANA POWER & LIGHT CO.
To:
Shared Package
ML20125C189	List: ML20125C187 ML20125C202 ML20125C219 ML20125C236
References
FOIA-84-507 QASP-19.13, NUDOCS 8506110701
Download: ML20125C236 (17)

Text

_ _ _ .

QUALITY ASSURANCE

- No. QASP 19.13 RESPONSE VALIDATION Rev. 1*

Effective gg Date 10/23/84 Page 1 of 10

1.0 APPROVAL

! Prepared By: / m/ -

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j. '

quality Asprarfce Representative /8 /b /

< Dace Concurred With: __ "

m ine.ering/systeyrDevelopment I # /). S c - 8#/f/p Date

, lity Assurance Manager

/

Concurred With: _ .

mI- A /f' M LPEL Engineer & Nuclear Safety : Y D&te l Concurred With _ Ud dN Nuclear Operatiops

- A /S//c/tv Manager urance Date

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Approved By:V MN--f, -

Corp ate qua /O--/9- SeL rance Manager Date

, Approved By:__ w Seulor

. dent - Nuclear Operations M3 Date TM-(

2.0 PURPOSE 2.1 QASP ovides in isions and change ,

2)

, and 3) for 2.2 'qASP 19.13 also provides direction and outlines responsibilities for validation-of responses to NRC Inspection Reports: Items reported under 10CFR50.55(e)/10CFR21. i i

NO TE:

10CFRSO.SS(e) reporting terminates at Operating ilcense and at that time validation requirements ,

of this item will no longer be required. '

l 8506110701 050222 i ,

GkRDEB 07 PDR  !

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' This procedure has been revised in its entirety. ["

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QUALITY ASSURANCE , ,

i No . QASP 19.13

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RESPONSE VALIDATION ' Rev . 1 Effective EESsM Data 10/23/84 Page 2 of 10 This procedure also provides directions for documenting the internal review process performed by Operations Quality Assurance, and Assembling / Indexing supporting documentation.

3.0 RESPONSIBILITIES 3.1 LP&L Corporate Quality Assurance Manager- The LPEL Corporate QA Manager is responsible for the following:

3.1.1 Designating a Team Leader to coordinate the overall validation of the responses of 2.1.

3.1.2 Assigning each of the questions / conte a

, representative of his staff for ver 2.1.

l 3.1.3 Assuring that the item (s) of sted and I the validation pacha5e(s} are satisfactory.

3.2 Nuclear Operatiods Quali Operations Quality As nager: The Nuclear r is responsible for the.

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followin58 .

l ternal review process defined in'

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N,3.2.1 Ensuri l Sect ormed in accordance with this .

j j, Proc 3'.2. that the validation packages are l factory and have been assembled in accordance i this procedure. ,

3.3 Qua ty Assurance. Analysis Supervisor _: The Quality Assurance Analysis supervisor is responsible for the following:

. 3.3.1 Coordinating the overall vali' datio'n of che responses defined in the above Section 2.2.

3.3.2 Assi ng a quality Assurance Representative to vali te each of the items as defined in the above Section 2.2.  !

3.3.3 Ensurins that the validation packages are j satisfactory and have been essembled in accordance .

i with this procedure for section 2.2. I i s l l

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QUALITY ASSURANCE No. QASP 19.13 RESPONSE VALIDATION Rev. 1 Effective Date 10/23/84 gu g Page 3 of 10 3.4 Team Leader: The Team Leader is responsible for implementing this procedure, providing necessary support, scheduling, and compiling data necessary for implementation of Section 2.1 of this procedure.

3.5 The designated LP&L QA representative shall be responsible for performing specific steps required by this procedure.

3.6 LP&L Project Engineering personnel will provide technical

, assistance when requested by the LP&L QA Team Leader.

l 3.7 Ebasco personnel will assemble the documentation es i

in accordance with the outline in Attachment 7 Sections 5.0 through.5.5.

4.O REFERENCES

\

l 4.1 LP&L Quality Assurance Section Pro Action Request."

.2, " Corrective

!' 5.0 PROCEDURE

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5.1 The LP&L QA Representa M review the response and underline each posi ent of fact. He shall then enter an identif referred to h er for each statement of fact, ,

a validation Item, in the right,-hand ma ese Validation Items represent those items whi req alidation. The LP&L QA Team Leader shall,r item g.

th alidation item (s) identified and complete (Act ertification of Validation form, LPL Q-78 Corpo 44 ) .2), and forward the package to the LP&L

A Manager.

NO TE:

More than one Form LPL Q-78 may accompany a response if space limitations and/or repetition of procedure steps requires additions to or re-evaluation of previously completed steps. In the event that a prevacusly validated response is revised, a new form LPL Q-78 shall be prepared and processed in accordance with Section 5.0 of this procedure.

5.2 The LP&L Corporate QA Manager shall review the response and each Validation Item. He shall then complete item 2 of Form LPL Q-78 for each response and forward the package to the LP&L QA Team Leader.

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QUALITY ASSURANCE Eg *g RESPONSE VALIDATION No.

Rev.

QASP 19.13 1

Effective Date 10/23484 Page 4 of 10 5.3 The designated LP&L QA representative shall assure that copies of or reference is made to the necessary support documentation that supports the response. If the documentation supplied by Ebasco is not complete, the LP&L QA representative shall obtain it with the assistance of Ebasco QA if necessary. The documentation will be assembled as outlined in Attachment 7.1. The items to be validated and the supportive reference shall be indicated as follows: .

5.3.1 The sentence (s) or phrases (s) in a reference which support the validation item (s) shall be underlined and a corresponding Validation Item number shall be written in the margin of the reference ad ant to the underline.

5.3.2 Each reference or group of rel d shall

' be identified by a capital n the

! up er right-hand corner r a5e of the

re erence. _,

5.3.3 This same 1 be entered in the margin l in th applicable Validation Item.

.s 5 . 3. 4 ation is complete, the LP&L QA i

> r ve shall complete item 4 of Form LPL l 0 Q- d forward the package to the LP&L QA Tean  ;

I an er. l c

NO TE: l The LP4L QA representative may request technical assistance from LP&L Project Engineering personnel. The LP&L QA representative is responsible for ensuring that personnel providing technical assistance complete item 3 of Form LPL Q-78.

NO TE:

If during the validation process, the QA Representative iderstifies an item which does not invalidate the responses but is on item which may be a noncompliance or require corrective action, he shall initiate a Corrective Action Request (CAR) in accordance with QASP 16.2 (Ref. 4.1).

5.4 The LP&L QA Team Leader will review the assembled package, complete item 5 of Form LPL Q-78, and forward the results to the LP&L Corporate QA Manager,

~

i QUALITY ASSURANCE No. QASP 19.13 RESPONSE VALIDAIION Rev. 1 Effective Date 10/23/84 g,sg Page 5 of 10 5.5 The LP&L Corporate QA Manager shall review the package, complete item 6 of Form LPL Q-78, and return the package to the LP&L QA Team Leader.

5.6 Significant construction Deficiency (scD)/Part 21 Responses and Responses to NRC Violations and Deviations 5.6.1 An assigned QA Representative shall review the response and underline each positive statement of fact.

He shall then enter an identification number for each. statement of fact, (referred to hereafter as a Validation Item)', in the right-hand margin.

These 2.dentification numbers represent a statements which require validation.

Representative shall complete Item Attachment 7.4 and forward the p QA Analysis Supervisor.

i More than one form may ac

\ onse if space

! limitations and/or repat' re steps requires additions to, or re reviously completed steps.

5.6.2 The pervisor shall review the response

- a ation item. He shall then complete I tachment 7.4 for each response and fo he package to an assigned QA Rapresentative D or alidation.

e assigned QA Representative shall ensure that copies of, or ceference is made to, the necessary support documentation and that this documentation adequately supports the response. If the documentation supplied is not complete, the QA Representative shall obtain the necessary documentation with the assistance of the Nuclear Services On-Site Licensing group or the responsible organization. The documentation shall be assembled as outlined in Attachment 7.3. The items to be validated and the supportive > reference shall be indicated as follows:

a. The sentence (s) or phrases in a reference which support the validation item (s) shall be underlined and a corresponding Validation Item number shall-be written in the margin of the reference adjacent to the underline.

)  !

QUALITY ASSURANCE E.

• RESPONSE VALIDATION No.

Rev. 1 QASP 19.13 Effective ge 6 f 10 M:

The QA Representative may request technical assistance from

- Profect Engineering Personnel. The QA Representative shall ensure that personnel providing technical assistance complete l

Item 3 of Attachment 1.4.

t 5.6.4 When the verification is complete, the QA Representative shall complete Item 4 of Attachment 7.4 and forward the package to the QA Analysis Supervisor. The QA Analysis Supervisor shall review the completed package, complete Item 5 of Attactanent 7.4 and forward the package to the Nuclear Operations QK Mana5er.

r 5.6.5 The Nuclear Operation Quality Assurance shall review the assembled packa58 em 6 a QA of Attachment 7.4 and return t s sor Analysis Supervisor. The Q e Nuclear 3 shall prepare a transmit ta a copy of the [ j Operations QA Manage ensing.  ;

validation packa l

6.0 RECORDS g )

6.1 ,A complet cbge shall be assembled and ne espouse (includin5 the cuestion/

• ma(n art 21 response, violation /c;eviation c on a forwarded to Project Files for retention as d.

1.1 This package shall include the following:

I a) Response b) Certification of Validation forms (Attachment 7.2 or 7.4, whichever applies) l c) Reference to or copies of the documentation which supports the validation effort.

7.0 ATTACHMENTS 7.1 Supportive Documentation Organization.

7.2 Certification of Validation, Form LPL Q-78.

7.3 SCD/Part 21 and Violation / Deviation supportive Documentation Or5anization.

7.4 SCD/Part 21 and Violation / Deviation Certification of i validation. l

QUALITY ASSURANCE No. QASP 19.13 RESPONSE VALIDATION Rev. 1 Effective Date 10/23/84 MM Page 7 of 10 I DOCUMENTATION ORGANIZATION l

F.ncry 4

1 LPEL Response to a specific question / concern 2 Certification of Validation To -78 3 Support Documen D icular docurnent or group of related

, documents) o attachments labeled A-Z, etc. I h.

reference is volumutous or already on file as a QA record,  ;

e pacilage shall contain a single page which identifies the reference completely and directs the reader to its exact location.

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Attachment 7.1 t

.i

l QUALITY ASSURANCE No. QASP 19.13 RESPONSE VALIDATION Rev. 1 Effective gg M

Date 10/23/84 Page 8 of 10 Cartification of Fatidation iterocese s Date: _ _ _

L. Valtdation itan(s)_ REVIEWID ty l (Inter numbers) LF E Team 14ader Date

2. Identification of l validation item (s) 32TIIMD by (Enter maahers) Date

3. Teettalest Assistance Provided by IIAME L' -

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.A\W - ,,.

LPE QAEmy. Data (Sacer evabers)

3. Comptation of verifi-cation of validatino ites(s) REVIEWED $

(2ntar numbers) LFE QA Taas Leader Data i

6. Comptation of verifia )

cation of validaties itan(s) REVIIVED by*

l (Inter ainsbers) LFE Corp. QA tour. Date  ;

. . co. ..a. o ,., o ted . a.i m 7  !

trt, q-7s (9/s+)

i Attachment 7.2

.. l QUALITY ASSURANCE No. QASP 19.13 RESPONSE VALIDATION Rev. 1

. . Effective Date to/u/ 84 glg Page 9 of 10 SCD/PART 21 AND VIOLATION / DEVIATION DOCUMENTATION ORGANIZATION INSP REPORT FOR VIOLATION / DEVIATION For each Violation or Deviation:

1. A Summary which includes the validation points and an analysis of the adequacy of the response including Beneric implication.

2. The response which 11acs the Validation Points.

3. Certification of validation form (s).

4. Supporting Documentation organized in the -

sequence corresponding to the validati p he responses.

NO TE:

I- When a reference is volumino yc shall l contain a single page whi e reference l and directs the tec .

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SCD/PART 21 ,

1. which includes the validation points and an f the adequacy of the response addressing the a f the SCD/Part 21 response.

2. The response which lists the Validation Points.

3. Certificaciati of validation form (s).

4. Supporting Documentation organized in the numerical  !

sequence corresponding to the validation pointo in the l

! responses. '

i NO TE:

When a reference is voluminous, the package shall l contain a single page which identifics the ' reference

, and directs the reader to its location.

i Attachment 7.3

Q QUALITY ASSURANCE No. QASP 19.13 RESPONSE VALIDATION Rev. 1 Effective gg Data 10/23/84 Page 10 of 10 3CD/Fert 214 validacian/Devtacion Certifisettee of Valianelon Responeer Dece:

1. Identification of Validation ites(s) Identified by

! (IAter ausbers) QA Empresentative Date

2. Review of identified validation ites(s) Iz?IEWED by (tacar naambers) QA h lysis Sugv. Date

3. Techotcal Assistsace Provided by MAME LINE 113H5 s

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AD gw )

4. Talidation ites(s) sO by*

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• M QA tag. Data 1

s. ,c=r -

east too itsa(s) REVIEWID by*

(Inter numbers) QA Analysis Supv. Date

4. Comp 14tico of verifi-cation of validatico ites(s) RETIEWID bye (Enter nuaners) Ike. Ops. QA Hat. Date To ttte best of my bowledge sad ability.

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Attachutant 7.4

.9 YC l. os - A f' W *d g All concerns brought to the attention of the Quality Team will be pursued. The Quality Team will make every effort to resolve issues' as quickly and thoroughly as possible.

Remember. If you have a quality or safety concern, do not ignore it. If the problem you've found is still not resolved, call:

Quality Team HOTLINE 464-3200 or 1 c800l 621-TEAM Trailer # 181 SBS C OBOdB31VM IV IAIV3.L A.LIlVnO ONIN NIM V BAVH Sn c lE H

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Q ualityis first at Waterford 3 Steam i Electric Station. Nothing is more important than quality and safety. Nothing ~

gets more attention ora higherpriority from those in charge of the project.

W3SES is going to take the quality effort of  ;

!j a lot ofpeople to make it successful. Should

• you have a concem about the way ajob has been done, think it through--and if you're still concemed, contact the Quality Team.

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Explain your concern on the Quality tion, will be scheduled.

Team Hot Line. Your concerns will be heard and they will be heeded. The Quality Team Coordinator will l report back to you on how yourconcem '

7 If you prefer a face-to-face visit on your was resolved. If you have chosen to re-l quality / safety concern, come directly to main anonymous, you may call back in the Quality Team Office, Trailer 181. about ten working days to check on the status of your concern.

i You can call the Quality Team Hot Line 464-3200 any time. The line will be When you call, identify yourself (and

! cnswered by the Quality Team during that's optional), spell out your quality

working hours. On weekends or after or safety concern. (if your call is being

hours, your call will be recorded, then recorded, please give the date and time '

l c follow up to obtain additional Informa- of your call.)

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When you call, give a complete descrip-

] , tion of the problem.  :

Let us know:

• Specific location of concern

• Systein or procedure

• Activity in process

• Day and time

• Construction or operations

+ How the Quality Team can

learn more about the problem

• Whether you've already notified your supervisior or foreman.

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3.3.1.5 Staffing. The reviewers need to be familiar with plant design and operation, control room operations, control room instruments, and human factors engineering. A team review is recommended to bring the appropriate combination of expertise to bear.

3.3.2 Control Room Operating Personnel Survey 3.3.2.1 Objective. The survey is intended to draw out the special knowledge of control room operating personnel about the problems and positive system features that have been noted in the course of operations or preparation for operations. A range of operations staff should be involved, including, for example, auxiliary operators, reactor operators, senior reactor operators, shift technical advisors, shift supervisors, and operations managers.

3.3.2.2 Approach. If administered questionnaires might be used but they are generally not as effective asinterviews for exploratory purposes;either the respondent has to write too much or information is lost. Also, there may be difficulty in interpreting respondents' written, open-ended statements without follow-up interviewing.

Survey content. The topic areas of the human engineering guidelines presented in Section 6 provide a framework for definition of interview content. It is not recommended that questions address the individual guidelines given in Section 6; other system review processes will make detailed comparisons of control room characteristics to the individual guidelines. However, the guideline topics and subtopics define aspects of control room design that should be examined with operating personnel, in addition, it is recommended that other kinds of human factors concerns, including personnel organization factors, training, procedures, and maintenance be covered in the ,

operator survey, since they may indicate design related problems or solutions to design related problems.

The content areas that should be addressed in the survey of operating personnel are listed below. Major topics of the Section 6 human engineering guidelines have been combined. The additional topics mentioned above are included:

e Workspace layout and environment e Panel design e Annunciator warning system e Communications e Process computers e Corrective and preventive maintenance o Procedures e Staffing and job design e Training.

Each topic area may be defined as a set of human performance factors that can facilitate or impede control room operations. The factors in a topic area may be evaluated differently with respect to different modes af reactor operation and different system events that may occur. For 3-6 f o M -S Y S "l l M  ;

L l

l instance, control board layout may be adequate for one mode but not for another or may be ,

adequate when all systems and equipment are operating within limits but cumbersome when it is necessary to operate with certain outages. The interviews should explore possible differences in human performance factors within the context of different modes and events.

A structured, open-ended approach is recommended, by which personnel are asked to describe ,

specific behavioral episodes that illustrate positive snd negative performance factors in each area.

This approach is along the lines of the critical incident technique (Flanagan, 1949; 1954). Critical

• incident studies attempt to identify essential performance factors (or accident factors, or other) by j focusing on salient success, failure, and near-miss situations, as opposed to routine activities. For the control room design review, critical incidents in the strict sense are of particular interest, but the concept should be broader. Noncritical problems are also of interest. Examples of questionnaire items written with a critical incident orientation follow. A complete interview protocol is provided ,

in Appendix C. .

" Describe at least three aspects of the control room workspace, furniture, equip-l ment layout, or environmental conditions that you find very useful or positive.

I Describe specific incidents or ways in which these have been helpful to effective job performance."

" Describe at least three aspects of the workspace, furniture, equipment layout, or environmental conditions that you find particularly bothersome. Describe specific incidents or ways in which these have been ineffective and have interfered with job performance."

"What do you consider to be the easiest system to operate and why?"* r

{

"What do you consider to be the most confusing or difficult system to operate and why? Give an example of an incident in which there was difficulty in l l operating the system."'

"Can you think of an occurrence when an operator activated the wrong control, activated a control inadvertently, or activated a control incorrectly? (Probes: Why did this happen? What system and panel were involved? How and when was the mistake discovered? What was the consequence? Have there been other such occurrences? If so, describe.)"

" Describe characteristics of the control room preventive maintenance program, ,

fault isolation capabilities, or corrective maintenance procedures that you con-sider highly effective."

l "Can you think of an incident in which a defect of the maintenance program caused an operational problem? If so, please describe what happened and explain .

the problem with the maintenance program. Have there been other maintenance- i l l

! based operational problems? Is there potential for such problems? If so, please l

explain."

l i

• These questions were drawn from the BWR Owners Group Operator Survey, cited in subsection 3.3.2.3. Infor-

. mation Sources.

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" Describe at least three incidents in which your procedures were of insufficient /

detail or unclear and resulted in ineffective or erroneous performance."

" Describe at least three characteristics of your classroom training? simulator training, requalification training, or practice sessions that you feel have been most effective in contributing to your successful performance as a control room operator."

g

" Describe at least three characteristics of your classroom training, simulator training, requalification training, or practice sessions that you feel were inade-quate and ineffective in preparing you for your job responsibilities as a control room operator."

It should be realized that the reviewers are not turning over responsibility to the interview respondents. Operators are not designers or human engineers. Preferences and problems experienced by individual operators and other staff may have as much to do with their backgrounds, work experience, and knowledge as with the objective merits of control room characteristics. The survey is intended only to acquaint the reviewers with the views of those immediately involved in operations. Their views may then be examined in light of principles and existing practices of design, personnel selection, training, manning, the maintenance program, etc.

Survey procedure. Selection of personnel for interviewing should emphasize direct, day to-day interfaces with the control room equipment. Ideally, all operating shift personnel should be among those interviewed. The survey objectives can,,however, be accomplished using only a sample of operating shift personnel, if sampling is used, at least half of the operating shift personnel should participate. The sampling objective should be to include the full range of operator experience. Exhibit 3 2 shows categories of experience which might give different perspectives on the control room. At least one person in each category should participate in the survey, if possible given the personnel backgrounds.

Other concerns of survey conduct are listed below:

] Methods should be used to assure respondents that they may speak openly about problems.

it may be difficult for employees to speak freely to personnel above them in the organizational structure.

If nrnon interviews are used, each group should include no more than three respon-dents. The groups should be formed on the basis of employee level-i.e., supervisors in one group, operators in another. Those to be interviewed should be asked whether they would rather participate in a group session with peers or in individual interviews.

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e e Interviews should also not be excessively long. It is more difficult to set a time limit for an /

exploratory interview, since respondents vary in interest and insight. As a guide,it appears that no more than an hour should be required for an individual interview. Group sessions may take longer, e if self-administered questionnaires are used, they should be as short as possible. As a guideline, it should take no more than an hour to complete the questionnaire. Space should be provided for respondents to write in comments.

3.3.2.3 Information Sources. ' Other questionnaires have been developed by industry and research groups in previous projects. Refer-ences include: the BWR Owners Group (1980); Mallory et al. (July 1980); Seminara et al. (March 1977).

The examination of operating history documentation (subsection 3.3.1) may identify questions that should be included in the survey of operating personnel.

The literature on applications of critical incident methodology may be of interest. References include: American Institutes for Research (1953); Chapanis (1959); Fitzpatrick, Dysinger, and Hansen (1968); Fogli, Hulin, and Blood (1971); Krumm, Fitzpatrick, and Schwarz (1959); Tarrants (1963).

3.3.2.4 Results. Responses should be examined for clustering and summary tables or charts prepared if appropriate. Positive control room features and problem areas identified by the respondents should be written up for furthe'r examination during subsequent system review processes. Completed interview protocols should be retained as backup materials which may need i to be consulted later. A description of the survey procedure should also be retained as backup material (including survey mode-e.g., individual / group interview; survey procedure; number and proportion of respondents; respondent years of experience by type, job category, educational background, and shift).

3.3.2.5 Staffing. The interview protocol or questionnaire should be prepared by or reviewed

_ hv staff with human factors engineering expertise and experience in the development and use_

_,,0f,,sugyr.ys. Staff with knowledge of the control room instrumentation, controls, and other equip-ment, operations, procedures, personnel organization, and training are needed to advise on content.

Those who perform the survey should carticioate in or be familiar with the rectitt of the review of

[available rinmmantitinn (see subsection 3.3.1). Interviewers should have appropriate experience or training and should be outside the plant / licensee /utilitu nnrsonnebstrueture -

.4 EVIEW OF SYSTEM FUNCTIONS AND ANALYSIS OF CONTROL ROOM OPERATOR TASKS For the purposes of the function review and task analysis _a system function or subfunction is defined as a kind of activity (or a static role) performed by one or more system constituents (people, mechanisms, structures) to contribute to a larger activity or goal state. A task is defined as a specific action performed by a single system constituent-person or automated equipment-that contributes to the accomplishment of a function. Functions are reviewed in this process so that the organization of control room operator tasks can be laid out clearly, k

3 10

' #' SSINS Ns.: 6835

, IN 84-08 He 5 UNITED STATES NUCLEAR REGULATORY COMMISSION \

p OFFICE OF INSPECTION AND ENFORCEMENT -

WASHINGTON, D.C. 20555 i

February 14, 1984 IE INFORMATION NOTICE NO. 84-08: 10 CFR 50.7, " EMPLOYEE PROTECTION" Addressees:

All nuclear power reactor facilities holding an operating license (OL) or construction permit (CP); nuclear steam system suppliers; and architect-engineers.

Purpose:

This information notice calls attention to 10 CFR 50.7, which prohibits dis-crimination against an employee for engaging in certain protected activities, such as providing the Commission information about possible violations of requirements imposed by the Atomic Energy Act or the Energy Reorganization Act.

Description of Circumstances:

In recent months the Department of Labor (DOL) has received a number of discrim-ination complaints. Some might have resulted because not all employers are aware of their responsibilities under 10 CFR 50.7.

In 1978, The Energy Reorganization Act of 1974 was amended to include Section 210 " Employee Protection." This section was enacted into law because of a strong feeling in Congress that employees of the Nuclear Regulatory Commission (NRC) licensees and applicants and of their contractors and subcontractors should be protected from discharge or other acts of discrimination for contacting the NRC. In 1982, the NRC amended its regulations (10 CFR Parts 19, 30, 40, 50, 60, 70, 72, and 150) to implement Section 210; 10 CFR 50.7 implements it for nuclear reactors.

Section 50.7 prohibits employers from discharging or otherwise discriminating against any employee who contacts or seeks to contact the NRC, and indicates that 00L may award an employee reinstatement, back pay and compensatory damages if discrimination has occurred. Any employee who believes discrimination has occurred may file a complaint with DOL but must da so within thirty (30) days of the date the employee became aware of the discrimination. In a memorandum of understanding dated October 25, 1982, NRC agreed to cooperate fully with 00L in investigating discrimination complaints (47 F1 54585). In addition, the NRC may take enforcement action for violation of Section 50.7.

l 84011 0039

\ A M-/ + CD 1 O

d IN 84-08 February 14, 1984 Page 2 of 2 Th re can be no question that public health and safety require that employees b] free to raise safety issues to licensee management and to the NRC. NRC has n:ticed a recent increase in the number of Section 210 complaints, some of which may have been preventable. Protected activities such as providing information to the NRC often occur when employers do not have an effective program for soliciting and resolving safety concerns of employees. AJJ:

titHfthsafety" concerrte' W beertaken^.tr the NRC: because' the . concerned employee was3 aware that- an-firsua_ca.isad-prev.ious4y-uittt_the. employer .had been resolve &ulf. problems.. ara. openly identified and resolved before an. employee.

fcals compelled to contact the NRC, fewer safety concerns will become alle-g;tions.to.the NRC and there should-be_ fewer.. instances of real or perceived discrimi nati.on..

h you to review your activities to ensure tnat (1) a mechanism exists for employees to raise safety issues free from discrimination and (2) employees are n:tified about this mechanism. Your contractors also should be aware of this catter.

If you have any questions regarding this matter, please contact the Regional Administrator of the appropriate NRC Regional Office, or this office.

Edward Jordan, Director Divisi of Emergency Preparedness and gineering Response Office of Inspection and Enforcement Tcchnical

Contact:

W. L. Fisher, IE (301) 492-8073

Attachment:

List of Recently Issued IE Information Notices

l' Attachment

.? IN 84-08 Februtry 14, 1984 LIST OF RECENTLY ISSUED IE INFORMATION NOTICES Information Date of Notice No. Subject Issue Issued to 84-07 Design-Basis Threat and 02/03/84 All power reactor Review of Vehicular Access facilities holding an OL or CP; and certain fuel fabri- .

cation & processing facilities using or possessing a formula quantity of SNM 84-06 Steam Binding of Auxiliary. 01/25/84 All power reactor Feedwater Pumps facilities holding an OL or CP 84-05 Exercise Frequency 01/16/84 All power reactor facilities holding an OL or CP 84-04 Failure of Elastomer Seated 01/18/84 All power reactor Butterfly Valves Used Only facilities holding During Cold Shutdowns an OL or CP 84-03 Compliance with Conditions 01/18/84 Licensed operators &

and Notification of Dis- facility licensees ability by Licensed Operators 84-02 Operating a Nuclear Power 01/10/84 All power reactor Plant at Voltage. Levels facilities holding Lower than Analyzed an OL or CP 84-01 Excess Lubricant in Electric 01/10/84 All power reactor Cable Sheaths facilities holding an OL or CP 83-84* Cracked and Broken Piston 12/30/83 All power reactor Rods in Brown Bovery Electric facilities holding Type SHK Breakers an OL or CP 83-83 Use of Portable Radio 12/19/83 All power reactor Transmitters Inside Nuclear facilities holding Power Plants an OL or CP OL = Operating License CP = Construction Permit

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The Honorable Nunzio J. Palladino F..'.~'..., , ,,, hQ ,- } h Chairman U.S. Nuclear Regulatory Comrission hashington, D.C. 20555 D;3r Chairman Palladino:

I would like to express my concern with regard to the Commission's policies  !

cnd procedures for consideration of recent allegations that have been circulatang cbout the quality of construction of Louksiana Power & Light Company's Waterford

!!! ("LP6L") nuclear plant. The purpose of this letter is to request your assist-ance in disclosing to LPit the nature of the allegations that have been made to th? Nuclear Regulatory Commission, so that LP&L can determine their merits and take any necessary corrective action in a timely manner. ,

LP4L remains dedicated to its objective of ensuring that the Waterford plant is constructed safely. We have made every effort to follow up genuine concerns raised about the quality of plant construction. LP4L's sole source of informat u, about the recent allegations has been second-hand information contained in a sert" of articles printed in The Gambit newspaper. LP6L has written to the only naaeq scurce in the articles in an attempt to get first-hand identification of the ccncerns. In reply, this named source has informed us that he has provided NRC investigators with a 237-page sworn statement containing all his allegaggons end he has declined to provide that information to 1.P&L. NRC Region ly aggg have acknowledged that they have received such allegations. Thev. t oo , have '

declined to prnvide the details of the allegations to us. In addition to th*

Cc: bit allegation, there may be others of significance.

The Waterford !!! Station is nearing completion. 'PGL ant.espa:e3 g ,, , g ',

fuel in the spring. We are extremely / concerned that ou: inabilitv to obts details of the allegations could prevent 1.PGL from making any necessary f' cations in a timely manner. We would not want the unavailablity of de h tion to present a threat either to the safety of the plant or to the ;res

lant completson schedule.

l As chief exceutive, I am fully amare of mv personal respen % .,3., ; '"

t'.: the hat erford I!! Stat son is const ruct ed properly and in ns m a m (; ['.'

ap;'l teable NRC regulat ions. I also have an obli gat ion t o t.P'l. rat epn ers s..iicholders to make every effort to t' ring haterford til on ;gny ,, %,,, , ,na ,

pou t ble, once all genuine safet y concerns bas e been addresseil. In OrJe? ?.

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IMN.& !M e,a The lionorable Nunzio J . Palladino mect both of these obligations, I need to have all concerns and allega:.

specifically identified as promptly as possible so that we can focus L T resources accordingly.

NRC regulations and practice support the development and implementatice of procedures which encourage workers We to report any allegations of nonconforn-have taken great effort to encouraga ances to the NRC and/or.to licensees. Where they such reports by our employees and by our contractors' employees.

report such concerns directly to LP&L, we promptly look into such matters, take corrective action, where appropriate, and report significant matters, at required, to the NRC. Ironically, where the concern is reported directly to the NRC, however, the informarion seems to be withheld by the NRC from the construction permit holder until the conclusion of sometimes extended inses-This, tigations. This could result in unnecessary delays in plant completions. I understand. 5y I believe, is imprudent and unnecessary policy justified only.

elsins that it is intended tu protect .he snongsity of infer:ers ind/nr to avoid In our instance, the anonymity of the irspairing the conduct of investigations.We know from The Cambit articles and, indeed, informer claim is irrelevant. to NRC. (

from the alleger himself that he has provided a 237-page sworn statement LP&L is not As to any anonymous informers, if there be any, let me be clear.

interested in their identities. The laws protecting against ret al iat ory dismissals are clear and I assure you that LP&L would not countenance any wrongful dismissals. Here, too, however, the concern appears to be irrelevant because The Cambit informer is no longer employed at Waterford.

I frankly do not understand the claim that disclosure of the allegation

• now might impede an NRC investigation. In any event, we are p.epared to provide the NRC with a detailed report of our inquiry into the allegations and the correct ive actions taken, if there be any. There will be no impediment to anf NRC investigation at Waterford, a?

hath these circumstances in mind, I would like to encourage you, Chairman of the NRC, to direct the prompt release to LP&L of our specific concerns and allegations relating to Waterford !!! nom being reviewed by NRC staf f.

In:snk you.

incerely. .

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