ML20136B731
| ML20136B731 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/23/1984 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20136B196 | List:
|
| References | |
| FOIA-84-779 EA-83-132, NUDOCS 8511200274 | |
| Download: ML20136B731 (19) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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[]cde coted; In the Matter of ) Docket Nos. 50-445 'l5JJ 06
) 50-446 1 . TEXAS UTILITIES GENERATING )
. 1 COMPANY, et al. ) Permit Nos. CPPR-126 l
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) CPPR-127 l (Comanche Peak Steam )
Electric Station) ) EA No.83-132 l.
LICENSEES' RESPONSE TO NOTICE OF VIOLATION
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.i I. Introduction Pursuant to 10 C.F.R. 2.201, Texas Utilities
--j Electric Company,1 et al. (" Licensees") hereby respond to the Notice of Violation ("NOV") issued on December 22, 1983, in the captioned enforcement action. Set forth below is a written statement providing (1) a denial of the alleged violation and (2) responsive steps which have been taken to reaffirm Licensees' commitment to an effective "
quality assurance program.
II. Denial of Alleged Violation
. The NOV alleges that a quality control supervisor
, N intimidated quality control personnel working for him as
. coatings inspectors. It recites that the supervisor
" threatened the QC personnel with withdrawal of QC certifications if they continued to write ' nitpicking' -
1 Please note that CPPR-126 and CPPR-127 were amended on December 30, 1983, to reflect the substitution'of Texas Utilities Electric Company for Texas Utilities Generating Compan'( as a licensee.
8511200274 PDR FOIA 851025 GARDE 84-779 _ P.DR. -
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l Nonconformance Reports which had been the subject of complaints from craft management personnel."2 According to the NOV, this constituted a violation of 10 C.F.R. Part i
50, Appendix B, Criterion I.
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Licensees are at a distinct disadvantage in
,l' responding to the NOV because of the very limited facts 4 , set forth in the NOV. We have sought that information t
through a Freedom of Information Act request, but the'NRC j
i has not yet timely responded to that request fully. Based upon the facts we have before us, Licensees respectfully i deny that a violation of NRC requirements' occurred as set
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{ forth in the NOV and Proposed Imposition of Civil Penalty.
We maintain first that the NRC applied an incorrect legal standard When determining whether a violation of Appendix B,
Criterion I occurred and second that NRC failed to allege a sufficient factual basis to establish that a violation of such requirement occurred.
A. Legal Standard.
In assessing whether a violation of Appendix B, Criterion I occurred, the NRC inquired into Whether a QC j.
supervisor made the statements alleged and Whether- QC i
inspectors interpreted those statements to be intimidating. Thus, based on Licensees' review of the NOV -
2 NOV at 1-2.
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l and the Report of Investigation,3 it appears that the
,[ legal standard NRC applied to identify a violation of i
Appendix B, Criterion I was whether the alleged statements I,i , were in fact made and whether the QC inspectors believed 2
! the statements were intimidating. This latter test is 1
i improper because it is purely subjective. Licensees l
subnit that the correct legal standard should be an objective test, viz., whether given the totality of the circumstances it was reasonable for the QC inspectors to perceive the supervisor's remarks as intimidating.
7 As discussed in greater detail below, because NRC applied a subjective standard when determining whether a violation of Appendix B, Criterion I occurred, there were numerous matters which it should have considered but which, based on Licensees' review of the " record" in this proceeding, were apparently ignored. Perhaps the most important of these matters is whether the supervisor in question was trying to ensure that QC inspectors satisfied i
their responsibilities under the quality assurance program and whether the statements in question were simply an expression by the QC supervisor of the need for QC inspectors to apply the applicable standards correctly during their inspections. -
3 Report of Investigation, Comanche Peak Steam Electric Station, Intimidation of coatings QC Personnel, Case I No. 4-83-001, August 24, 1983 (" Report of Investigation").
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- 4-The failure of NRC to consider this and other matters in this enforcement action is difficult to understand in light of Appendix B itself. Criterion I of Appendix B l provides in pertinen't part that "
the persons and 1
j organizations performing quality assurance functions shall
<. have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or
, provide solutions; and to verify implementation of i
! solutions." Criterion II of Appendix B states that the I. }
quality assurance program "shall provide for fj indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained" and that
" applicant shall regularly review the status and adequacy of the quality assurance program."
Together, these provisions require that licensees establish a balanced' quality assurance program both in which OC inspectors have sufficient organizational freedom to perform their jobs and in which licensee management exercises sufficient supervisory authority over those inspectors to assure that quality assurance functions are' performed correctly. Thus, if OC inspectora are using incorrect criteria or are not properly applying pertinent -
criteria, the licensee ~under Appendix B has an affirmative
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obligation to assure that this situation is corrected and l.
that the quality assurance program is implemented properly.
I j The failure of NRC to consider this and other matters i
is-also significant in view of the fundamental difference
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I J between enforcement actions based on claims of harassment i
and other enforcement actions taken by NRC. Most enforcement actions involve technical issues such as whether a technical specification was violated or whether
] procedural requirements were satisfied fully. In con-trast, en.orcement actions involving harassment raise 3
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" people" issues, viz., the reactions of individuals to a particular statement or action. As a result, before NRC decides that an incident of harassment took place contrary to Appendix B,. Criterion I, it should consider more than the alleged incident itself, the claims of the people in-volved, or the underlying cause of the alleged violation.
Accordingly, Licensees submit that the legal test used by NRC to identify a violation of Criterion I (whether a statement was made which QC inspectors believed was threatening) ignores two fundamental areas of inquiry.
The first is an inquiry into the totality oj[ the circumstances surrounding the alleged harassment. The -
second is an examination of whether the QC inspectors i reasonably perceived that the statements in question were j l
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threatening. The specific facts NRC should have considered When inquiring into these two areas are set forth below.
Totality of Circumstances. When considering the totality of the circumstances surrounding the alleged l' violation of Appendix B, Criterion I, NRC should have censidered whether there could have been underlying reasons for an inspector to allege that he was a victim of harassment Which would indicate that no violation of Appendix B, Cri'.erion I occurred. At a project the si=e and complexity of a nuclear power plant, hundreds of OC inspectors are employed performing a variety of tasks.
Most of those inspectors diligently perform their jobs.
Nevertheless, disputes involving such employees will arise for any number of reasons, including efforts by the Licensee to assure that QC inspectors perform their 4
inspections in accordance with the correct criteria and ,
that they properly apply the applicable criteria. As a .
result, a claim of harassment could in fact stem from actions by the licensee to exercise legitimate management control over its quality assurance program, as required by criterion II of Appendix B. Similarly, a claim of harassment could be the result of labor disputes involving -
such' matters as an inspector's work output, or other terms and conditions of employment.
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W For e:: ample, a Or a nervisor is obliged to correct an inspector if the inspector fails to identify a rejectable
- condition. A QC supervisor also must take corrective 4
action if improper inspection techniques are being used by 4
QC- inspectors . Similarly, if OC inspectors are not performing adequate and timely inspections, it is perfectly appropriate for the supervisor to warn such inspectors that recertification will be required unless their level of performance improves.
In each of these examples, an inspector could claim that he was being threatened and deprived of his organizational freedom. Yet in all of these examples, the the supervisor's action would be mandated by Appendix B,
, Criterion II.
i These examples illustrate Why NRC must consider more than the subjective perceptions of the QC inspectors '
claiming they were threatened. The examples also illustrate Why it is essential for NRC to consider in addition the intent of the supervisor When making his alleged statement in question. If'the statements were meant-to achieve an entirely proper result, i.e., to
, correct the improper inspection techniques of certain inspectors, then they cannot logically be deemed by NRC to -
violate Appendix B, Criterion I.
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8-Numerous other matters should be considered by NRC when evaluating the totality of the circumstances surrounding a claim of intimidation, all of which are intended to assure-that such claim doss not disguise an ulterior motive or reflect a labor disagreement not relevant for purposes of Appendix B. These matters include, among others, whether quality assurance activities relating to construction are nearing completion; the experience and performance level of the individual alleging harassment; possible motives the alleging individual might have; whether there were personality conflicts underlying the allegation; the level i
of responsibility, demeanor, and personality of the individual allegedly engaged in harassment; and what actions were initiated by the licensee as a result of this
]) or similar allegations. In short, NRC should consider the
, totality of the circumstances surrounding an alleged claim of harassment. Because the NRC failed to do so in this case, it should not find that a violation of Appendix B, Criterion I occurred.
Reasonable Man Standard. Licensees submit that NRC should also consider whether it was reasonable for a QC l inspector to perceive that an alleged statement is -
threatening. NRC should not simply confirm that a statement was made and then accept the view of a QC
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inspector that he believed the statement was threatening.
Were NRC to adopt this latter approach (and the Report of Investigation suggests that in this case it did),
- inspectors would be able to hold the quality assurance program virtually hostage whenever a dispute between labor and management arose. Moreover, any supervisory action, even if required under Criterion II of Appendix B, could f
provide inspectors with a basis to claim that they were
! " threatened," provided the inspectors were willing to state that they felt intimidated by the action. In short, t
4 it would place the management and control of the quality assurance program in the hands of the inspectors, given
- the leverage they w'uld obtain over management through the threat of NRC enforcement actions. The end result would be a serious erosion of the ability of licensees to i
f' administer an effective QA/QC program.
i The " reasonable man" approach Which NRC should have used in this case has been adopted by another federal agency Which, much like NRC, must determine whether I
actions or statements unlawfully threaten individuals engaged in certain activities protected by federal law.
Section 7 of the Labor Management Relations Act ("LMRA")
provides employees with the right to self-organization;-to -
form, join or assist labor organizations; and to engage in other concerted activities for the purpose of collective I, - , . - s . ~ .. . , , .
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bargaining.4 Section 8(a)(1) of the LMRA prohibits employers from interfering with, restraining or coercing employees in the exercise of those rights.5 Section 8(b)(1) imposes a similar prohibition on labor organizations.6 As part of its duties under the LMRA, the National Labor Relations Board ("NLRB") is called upon regularly to l
decide whether employers or labor organizations were engaged in acts of coercion or intimidation or otherwise 4 threatened those engaged in activities protected by Section 7, contrary to Sections 8(a)(1) or 8(b)(1) of that Act. When making its findings, the NLRB has long held that whether coercion or harassment exists is not determined from the testimony of those allegedly harassed I
but rather from an examination of whether, based upon all of the objective circumstances, it reasonably appeared that there had been deprivation of the freedom of choice guaranteed by Section 7.7 Licensees submit that NRC 4 29 U.S.C. $ 157.
5 29 U.S.C. $ 158(a)(1).
6 29 U.S.C. $ 158(b)(1).
7 See, e.g., N.L.R.B. v. Berger Trans.' & Storage Co., -
~6Td FT679, 689 (7th Cir. 1982); . ..R.B. v. Service Employees International Union, Loca! 234, 335 F.2d 1335, 1337-38 (1st Cir. 1976). Cf. International Ladies' Garment Workers' Union anE Georcetown Dress I
Corporation, 214 NLRB 706, 706 n.1 (1974); James Lees and Sons Co., 130 NLRB 290, 291 n.1 (1961).
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should have adopted a similar " reasonable man" approach when evaluating claims of harassment within the context of Appendix B.8 Its failure to do so invalidates the finding that Appendix B, Criterion I was violated.
x B.* Factual Allegations.
Licensees submit that the NOV and the Report of Investigation fail to allege facts which constitute a violation of Appendix B, Criterion I because no basis was provided upon which to conclud'e that, given the totality of the circumstances, it was reasonable for the QC inspectors to perceive that they were being threatened.
For example, neither document sets forth in full what the QC supervisor said during the two meetings he scheduled; when and where these meetings took place; what craft management complaints were received by the supervisor and whether those complaints were valid; ;
whether there were instances of QC inspectors rejecting >
8 Licensees recognise that the NLRB is concerned with assuring that rights statutorily granted to employees are not infringed, whereas NRC is concerned with assuring the safe construction and operation of power .
reactors through its requirement that licensees guarantee those employed to perform quality assurance functions sufficient organizational freedom to do so.
However, in both cases the obligation not to engage in acts of intimidation or harassment is statutorily -
premised. Moreover, the type of faces' disputed in both cases is similar. Therefore, Licensees submit that the type of inquiry undertaken by the NLRB, and sanctioned by the courts, regarding violations of Sections 8(a)(1) and 8(b)(1) of the LMRA is equally appropriate where the NRC must investigate claims of harassment.
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, acceptable conditions; and whether there were instances in which inspectors failed to identify rejectable conditions.
i Nor do they indicate Whether all inspectors attending the
- . . meetings in question believed that they were being
, threatened or Whether only some of them perceived the remarks of the supervisor in a threatening light, and, if a
so, Why this disparity of opinion existed.9 Similarly, while the Report of Investigation states the conclusion l that one QC inspector did not report defects he identified for fear of reprisal, no information is provided as a I
s.
9 Apparently to corroborate the claim of harassment, the Report of Investigation indicates that the QC supervisor and his manager stated to NRC that the alleged remarks of tha inspector "could have" or "may have had" an intimidating effect on the inspector. As set forth above, the issue is. Whether the remarks ,
reasonably could have been perceived to be threatening, not simply Whether such "could have" been the case. In !
addition, the Report of Investigation does not disclose ,
r the basis for these conclusions, does not set forth the overall context in which they were made and does not account for the pressures the supervisor could have felt as a result of What was, no doubt, a searching interrogation by NRC investigators. Moreovg;, Counsel for Licensees has learned that the supervisor involved in the events alleged in the NOV had not even perceived
" that his statements could have been interpreted as intimidating until that notion was introduced by an NRC investigator. Counsel for Licensees has also learned that the NRC investigator did not take a written statement from the supervisor's manager and that the -
- statements attributed to that manager were based on an informal discussion with the investigator. See note 10, infra. At bottom, the statements by the supervisor and his manager do not provide any independent support to conclude that the alleged violation of Appendix 3, Criterion I occurred.
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basis for that conclusion. Further, no information is J
!' provided as to whether in any event the QC inspector acted I'
reasonably in view of the supervisor's statements.
Finally, there is no indication in either the NOV or the i.
Report of Investigation that NRC considered in any way the ,
totality of the circumstances surrounding the alleged incident, such as the fact ^that construction is nearing completion or that inspectors were failing to perform their duties properly.
j The failure of NRC to provide this information is L significant. Licensees investigated an incident which
! involved a QC supervisor reprimanding QC inspectors for i
- " nitpicking."10 The results of that investigation showed i
that two-QC inspectors had spent twelve manhours to inspect the floor of a ten foot by twelve foot room and l rejected some conditions which were in fact acceptable. k
- i-i The QC supervisor used these as examples of " nitpicking" l 3
l 10 Although Licensees investigated this incident, that '
i inquiry was not focused on learning how NRC viewed the incident or uncovering any information within the possession of NRC. Rather, it was intended to identify what actions Licensees should take, whether or not this incident constituted unlawful harassment, to assure
- i. that incidents of harassment did not occur. .Moreover, as discussed in section III of Licensees' Answer to i< Civil Penalty in EA No.83-132, NRC did not disclose '
- l. the underlying factual' basis for the NOV. As a result, it is impossible for Licensees to respond to the NOV
{: with a factual analysis of the incidents in question.
l If NRC releases such information to Licensees in
! response to our FOIA request, we-will respond promptly, as appropriate, in view of that information.
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by the inspectors because it took the inspectors far too s.
long to perform their job, and at that their performance was not satisfactory. Further, that investigation showed .
that the inspectors had overlooked some unacceptable conditions. It was in these contexts that the QC supervisor admonished the inspectors that if they continued to perform inadequately he would revoke their i
certifications. If in fact this incident is the basis for the instant enforcement action, Licensees strongly deny i
the violation. Clearly what is alleged to be a threat is nothing more than a QC supervisor acting properly to i
assure that QC inspectors perform at an adequate level of proficiency.
At bottom, NRC should have alleged and documented
- j. facts sufficient to establish that a statement was made which, given the totality of the circumstances, inspectors h l:
could reasonably have perceived as threatening. Rather i j than making this showing, NRC claimed based primarily on ,
the statement of those allegedly harassed that they were threatened and thus deprived of their organizational Because this showing falls short of that which freedom.
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should have been made to establish a violation of Criterion I of Appendix B, Licensees respectfully deny the -
I charges set forth in the Notice of Violation and Proposed l- Imposition of Civil Penalty.
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III. Responsive Actions While Licensees deny that the NOV sets forth a t.
n violation of Appendix B, Criterion I, nevertheless, a h i
. number of responsive actions have been initiated since the 7
- alleged incident took place. These actions were brought to the attention of NRC in Licensees' Response to Notice of Violation in EA No. 83-64.11 Licensees would not normally provide them in detail a second time here.
, However, even though they were initiated before this t enforcement action was taken, NRC apparently did not ,
i acknowlege and account for them in this action. In addition, these responsive actions constitute a t
significant reaffirmation of Licensee's total commitment to an effective, independent QA/QC program and should i ,
- prevent incidents such as that alleged here. Therefore, n!
Licensees set forth below the responsive actions commenced hi 2.1 four months ago to reassure the adequacy of the QA/QC E P
- program at Comanche Peak
o First, Licensees have developed an ;~
audio visual program to reemphasize the commitment to quality at Comanche Peak. The program stresses that ,
quality is the business of everyone at Comanche Peak, that all QA/QC personnel are required to report non-
- conforming conditions, and that no I interference (such as harassment) with -
l proper performance of QA/QC functions 11 Texas Utilities Generating Company, et. al. (Comanche Peak Steam Electric Station), Docket Nos. 50-445 and 50-446, Licensees' Response to Notice of Violation, EA No. 83-64, September 28, 1983, at 15-18.
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at Comanche Peak will be tolerated.
Over 6,000 individuals involved with quality-related work at Comanche Peak 4
(including QC inspectors and craft) have been required to view this k program. The program will continue f throughout the duration of '
construction, and all future employees will be required to view the program.
This program has been underway since '
early November.
o Secoqd, Licensees' management has met i
I and will continue to meet with selected personnel at Comanche Peak to emphasize its commitment to quality.
- During the meetings management has stressed that it will continue to I implement an effective QA/QC program at Comanche Peak. Management will further re-emphasize that the quality 1
of plant construction has been and always will be of the highest priority.
o Third, Licensees' management has and will continue to re-emphasi=e during these meetings, as well as through other means described below, its desire that all employees bring their ;
concerns regarding quality matters to i Licensees for resolution. Toward that end, Licensees will reiterate for 4 their employees and their contractors' i employees the numerous official
- channels available to them for doing
so. These channels include:
- 1. QA/QC inspectors.
1 2. QA/QC supervisors;
- 3. Construction management; and
- 4. Texas Utilities Generating -
Company management.
Licensees will continue to emphasize to employees and their contractors' l'
employees that they are required to bring quality assurance concerns to
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Licensees' attention and that no adverse consequences with respect to the terms and conditions of their employment will be tolerated due to t their identification of problems.
Finally, employees will be advised 3 that they are free, as always, to contact NRC regarding quality assurance matters, o Fourth, Licensees have initiated a program to encourage the immediate reporting of quality concerns.
Employees are able to voice .
anonymously their concerns with quality at Comanche Peak via a telephone contact. The telephone is answered 24-hours a day by designated individuals or by an automatic i~ recorder. Licensees' personnel with sufficient authority and resources to assure resolution of any matters a#fecting quality review all concerns identified by this means. Appropriate records are maintained as to the disposition of concerns identified.
o Fifth, Licensees reminded employees in writ.ing of Licensees' commitment to quality at Comanche Peak and of -
managements' encouragement of prompt [
identification of concerns regarding ;
4 , , quality. This written reminder was i given to Comanche Peak employees with -
their paycheck. Licensees are also considering other means of (
reemphasizing to employees Licensees' commitment to quality.
o Sixth, Licensees.have posted new '
notices throughout the plant encouraging employees to bring to
- ' their attention any concerns regarding
- quality. These notices reiterate the available means for doing so, as -
described above.
o seventh, Licensees have initiated a program to ensure that all CA/QC employees are given the opportunity to
- state concerns regarding quality prior
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1 to disassociation with the QA/QC department. Stated concerns are evaluated and dispositioned by Licensees.
s o Eighth, Licensees have counseled selected QA/QC personnel on employee '
relations and the need to accommodate considerations of both labor law and atomic energy law, recognizing that the overall objective is construction
- and operation of a safe power reactor.
i In addition to these actions, Licensees have retained I an independent technical advisor with extensive management and technical experience in directing nuclear reactor '
A. r j power plant inspection progra.ns. His responsiblity is to provide outside expertise in Licensees' investigations of quality assurance related activities at Comanche Peak.
The independent advisor reports directly to the i Supervisor, Construction Quality Assurance. In addition,
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} he has total access to any level of Licensees' management he deems necessary to carry out his assigned function.
The advisor will routinely conduct independent investigations to determine the adequacy of quality assurance related activities. Such investigations may be requested by Licensees' management or by any individual employed at Comanche Peak.
Employees may contact the
- advisor directly. In addition, the advisor assists in the investigation of allegations received through Licensees' e i i
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. " hot line." All QA/QC personnel on the job site were advised in writing of the availability of the advisor and how to contact him. .
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Licensees believe that these actions, taken prior to ,
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issuance of the NOV, are responsive and extensive and that they demonstrate convincingly Licensees' total commitment to quality. -
Beyond these generic actions, Licensees took certain specific actions when they became aware of the allegations ,0 ,
i of harassment involving the QC supervisor. These actions . ,
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included investigating internally the claims of ;
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harassment.12 Our investigation concluded that no N intimidation -- either actual or intended -- had occurred.
Licensees also investigated the alleged incident involving harassment to assess the technical significancs, l if any, of the alleged violation. Based on the results of -
this investigation, Licensees concluded that the incident had no technical significance.
IX. Conclusion In light of the foregoing, Licensees deny in full the alleged violation set forth in the NOV and request that this enforcement action be withdrawn.
January 23, 1984 12- see note 10, suora.
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