ML20128M033

Affidavit of HR Banks Supporting Util 850709 Application for Withholding Documents,Including Quality Check Rept,Concern/ Allegation Followup & Quality Check Procedure Investigation Rept,Per 10CFR2.790.Related Correspondence

ML20128M033
Person / Time
Site:	Harris
Issue date:	07/08/1985
From:	Banks H CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20128M031	List: ML20128M025 ML20128M033 ML20128M040
References
OL, NUDOCS 8507110535
Download: ML20128M033 (4)

Text

.

4 UNITED STATES OF AMERICA l 4

NUCLEAR REGULATORY COMMISSION 1 l

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket No. 50-400 OL and NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant)

AFFIDAVIT OF HAROLD R. BANKS County of Wake )

) ss.

State of North Carolina )

Harold R. Banks, being duly sworn according to law, de-poses and says as follows:

1. My name is Harold R. Banks and my business address is P.O. Box 1551, Raleigh, North Carolina 27602. I am employed by Carolina Power & Light Company ("CP&L") as the Manager-Corporate Quality Assurance. My statement of profes-sional qualifications and experience is set forth in "Appli-cants' Joint Testimony of E.E. Utley, M.A. McDuffie, Dr. Thomas S. Elleman and Harold R. Banks on Joint Intervenors' Contention I (Management Capability)" dated August 9, 1984 following Tr.

2452. This statement of professional qualifications and expe-rience remains current to this date.

2. This affidavit is made in support of Applicants' ap-plication for withholding privileged or confidential commercial 8507110535850 ADOCK 05 goo PDR 0

s s

information pursuant to 10 C.F.R. S 2.790(b)(1). The documents in question include a Quality Check Report (one page), a Con-cern/ Allegation Follow-up (one page), and a QCP Investigation Report (five pages), which were submitted to the Board by Applicants' counsel by cover of a letter dated May 20, 1985.

3. The documents in question were generated during a Quality Check Program exit interview with an employee, and sub-sequently in investigating an allegation made by that employee.

The information provided by the employee was provided in confi-dence with assurances that his identity and the information would not be disclosed. Certain of the documents identify the employee by name.

4. The CP&L Quality Check Program was described in my testimony before the Board at Tr. 2699-2713. Briefly, the Quality Check Program was established to provide an additional opportunity for Harris site personnel to express concerns to management and to receive feedback on their concerns. As part of the Quality Check Program, each employee working in a safety area who leaves employment at the site (whether by resignation, termination or reassignment) is interviewed by the Quality Check group in order to identify potential safety concerns.

Any concern identified during an exit interview (or during ran-dom interviews or through the initiation of an employee by telephone call to the Quality Check group personnel or by filling-out a Quality Check Form) is investigated by a group of QA specialists and engineers and the results of the i

- . . .- - - - - , . - , . - , , ~ .

s investigation are reported back to the employee. Where appro-priate, corrective action is taken. I review each report of an investigation of any concern raised through the Quality Check Program.

5. Reports of investigations by the Quality Check group are strictly maintained confidential by the Manager-Quality Check. A copy of the reports may be provided to the Vice Pres-ident, Harris Nuclear Project. Certain information in the re-porta may be communicated to managers or supervisors as neces-sary to take corrective actions. However, the reports themselves are closely held by the Quality Check group to main-tain the confidentiality of the source of the~information.

Disclosure of an individual's name and circumstances of his al-legations could cause him embarrassment or adversely affect his future employment.

6. The most recent NRC Construction Appraisal Team inspection found the Quality Check Program to be an effective and viable method of addressing employee concerns. This pro-gram of critical self-appraisal can only succeed if the employees are confident that the information provided to the Quality Check group will be maintained as confidential. Re-lease of these documents could undermine the credibility of the Quality Check Program. Furthermore, candid appraisals in Re-ports of Quality Check investigations are essential to manage-ment for the effectiveness of the program. If these reports were subject to public disclosure, the candid, critical

r 8

analysis in the reports might give way to careful editing for possible disclosure.

7. We believe that this independent critical self-appraisal enhances CP&L's ability to ensure that any con-cerns -- including safety concerns -- are brought to the atten-tion of management. This allows management to correct any sit-uations which could lead to poor construction, inefficiencies, or an unsafe condition. While the purpose and emphasis of the Quality Check Program is to enhance Safet;y at the Harris Plant, the ability of CP&L to complete the construction of the Harris Plant and to operate the Plant safely is vital to the commer-cial success of the Company.

Y.s A G Harold R. Banks Subscribed and sworn to before me this F/l day of July, 1985 1 ). -v NgryPublic Q My Commission expires on [e d e a a ew /P i / 9 9 (.).

t f

_ _ - . . - - _ - - - - - - .