IR 05000440/1985087

Insp Rept 50-440/85-87 on 851009-11 & 1112-15.No Violations or Deviations Noted.Major Areas Inspected: Call for Quality Program

ML20136G420
Person / Time
Site:	Perry
Issue date:	12/20/1985
From:	Kaufman P, Knop R, Vandel T, Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136G351	List: IR 05000440/1985087 ML20136G345
References
50-440-85-87, NUDOCS 8601080175
Download: ML20136G420 (8)

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U. S. NUCLEAR REGULATORY COMMISSION REGION 111 Report No. 50-440/85087(DRP)

Docket No. 50-440 License No. CPPR-148 Licensee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Unit 1 Inspection At: Perry Site, Perry, OH-Inspection Conducted: October 9-11 and November 12-15, 1985 Inspectors: C. H. Weil Date RFidt%-

R.C.Krop* }Z-26-75

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, . Date h,bth?

T. E. Vandel /2-/ 9 -dS Date G n \Q~-

P. D. Kaufman /2-20-85-Date RFh)wu'ck Approved By: R. F. Warnick, Chief /2 -fd-Ff Reactor Projects Branch 1 Date Inspection Summary Inspection on October 9-11 and November 12-15, 1985

., (Report No. 50-440/85087(ORP))

Areas Inspected: Special inspection %o examine the " Call For Quality" Program at the Perry Nuclear Power Plant. The inspection involved a total of 42 inspector-hours. onstie by four NRC inspectors and 'O inspector-hours during

u kreasreviewedindicatedanumberofimprovementsthatthelicensee i could make to improve the program. No violations or deviations were identified.

l A summary of the inspection follows.

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8601080175 851220

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SUMMARY This special inspection was requested by the Regional Administrator, NRC Region III, to examine the Cleveland Electric Illuminating (CEI) Company's

" Call For Quality Program" at the Perry Nuclear Power Plant. The Call For Quality Program was created in 1984 to solicit the concerns with plant quality of employees terminating their employment at the Perry Plant, and approximately 1400 interviews had been conducted with 52 cases opened as a result of these interviews. Staffing consisted of the Call For Quality " Ombudsman" and the Call For Quality Investigator. The investigator was the only full-time member of the Call For Quality staff and reported to the Ombudsman. The position of Dmbudsman was not full-time in that the assigned individual had the dual responsibilities of Ombudsman and Quality Assurance Audit Unit Supervisor. The Ombudsman reported directly to the Nuclear Group Vice President while fulfilling his Ombudsman roll; otherwise, his supervisor was the Quality Assurance Manage The Call For Quality Procedure specified that the procedure applied to all Perry Plant employees, including contractors; however, in practice the scope of the program was directed primarily to the employees of CEI and contractor quality assurance and engineering department Therefore, by practice, the involvement in exit interviews of departing craft workers was limite It was found that

" mass exits" or group interviews were utilized. Tne Call For Quality Investi-gator considered these group interviews an effective investigative technique, and had used the group interviews on 3 or 4 occasions to interview approximately 100 departing employees. The Call for Quality Procedure also permitted supervisors to conduct the exit interview. The NRC review of the Call For Quality Files indicated that this was being done. The use of supervisors to interview departing employees raises questions of the potential candor of the

. . _, exiting employee, as well as the preservation of the confidential identity of that employe A review of the Call For Quality case files showed that the Call For Quality concerns were closed in a technically acceptable manner. However, the Call For Quality Program did not always analyze all potential aspects of the concern to establish a complete cause, effect, or other areas of possible concer The Call'For Quality Program was considered to be very limited in scope and effect.iveness. It lacks many of the attributes which the NRC would expect to find in a fully acceptable investigative program, such as the protection of the identity of the source of the information, independence of the program, interview and investigative techniques, available resources, and limited solicitation of potential problem Notwithstanding these limitations, the program did identify and correct some technical and hardware problems outside the normal corrective action system.

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DETAILS

' Persons Contacted

• C. M. Shuster, Quality Assurance Manager

• T. A. Boss, Call for Quality Ombudsman and Audit Unit Supervisor

• F. R. Stead, NED Manager C. E. Hill, Call for Quality Investigator

• Indicates those personnel who attended the exit meeting on October 11, 198 . Review of the " Call for Quality" Program Beginning in 1983 many NRC licensees initiated programs to solicit the concerns with the quality of nuclear plant construction from their employee In 1984 The Cleveland Electric Illuminating Company (CEI)

initiated a " Call For Quality" program at the Perry Nuclear Power Plant as a result of tha development of these programs at other nuclear-facilitie Purpose and Scope of Review The purpose of the Region III review of the Perry Flant's Call For Quality Program was to obtain a thorough understanding of the program and its operation. In order to obtain that understanding, the Region III review consisted of interviews with the Quality Assurance Manager; the

. Quality Assurance Audit Unit Supervisor, who was also the Call For Quality supervisor (Ombudsman); and the Call For Quality Investigator. The Region III Staff reviewed the Call For Quality Procedure and all of the closed Call For Quality Investigations. The NRC also reviewed the corrective actions taken in the _ Call For Quality Investigations in which i deficiencies were found and corrective action. require History The Call For Quality Program was initiated in mid 1984 as a result of'

the institution of programs to review the concerns of departing employees at other nuclear power plant construction sites. The Call For Quality Program was developed after CEI reviewed those other programs. Their reviews at the other facilities determined that most craft worker concerns were primarily limited to terms of compensation; therefore, CEI elected to limit the scope of the exit interview program primarily to departing engineering and quality assurance workers. The Call For Quality Program has interviewed 1300 to 1400 departing employees and 52 Call For Quality case files,. consisting of approximately 100 concerns, were opened as a result of those interviews.

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't Organization i

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~i The Call For Quality staf f consisted of the Ombudsman and one investigato The Ombu'dsman was also the supervisor of the Quality Assurance Department Audit Unit, and as such, acted as the.0mbudsman on an as needed basis. He

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reported to the CEI Nuclear Group Vice President in his Ombudsman rol His supervisor in his auditor role was the Perry Plant Quality Assurance Manager.

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The investigator was.the only full-time staff member in the Call For '

Quality Program, and as such the investigator reported to the Ombudsman.

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The investigator stated that his background was in quality assurance, and 1 he has worked in nuclear quality assurance since the early 1970s. Prior to

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that he was employed in quality assurance in the printing industry. He

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began his employment with the Call For Quality Program in May 1985, having  ;

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previously worked for a similar program, SAFETEAM, at the Clinton Power Station. (Note

On December 6, 1985, the Ombudsman informed the Region i III staff that two additional investigators had been added to t M Call

For Quality staff.)

Procedur Perry Plant Operations Procedure 0212, " Call For Quality Program" was the j procedure applicable to the Call For Quality Program. Revision 0, dated '

. July'22, 1985, was in force at the time of'this inspection. The Ombudsman

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was asked why it took from June 1984 (the time the program was established)

until July.22,1985 to issue the procedure. The Ombudsman answered, "we

knew what we wanted" and did not feel it necessary to quickly write the l procedur Scope of Procedure l Paragraph 2 of the procedure stated, " Scope. This procedure applies to

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all Perry Nuclear Power Plant (PNPP) personnel. It further applies to actions performed under the direction of a Corporate Ombudsman to i investigate and resolve quality concerns received under the Call For Quality Program which may impact the safe and efficient construction or operation of Perry Nuclear Power Plant." Therefore, the procedure was

. applicable to all Perry personnel, and not just those employees of the quality and engineering departments (see History Section above).

Interview Process

. The Call For Quality Investigator advised that he conducted the interviews

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of all employees of the quality and engineering dep'artments,'as well as

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contract administrators, as they exited the site. The investigator.also advised that he has conducted three or four " mass exits," and approximately l 100 departing employees were interviewed during those " mass exits." The Call For Quality investigator stated that he considered the " mass exits"

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to be an effective interview technique since he " closely watched the reactions" of the audience. The investigator stated that if he " sees

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someone hesitate" while signing the Call For Quality Form, he will ask that person if they have a problem. The investigator also stated that

"no one has ever been selected for individual interview" as a result of the " mass exits."

The Call For Quality Investigator was asked about the seemingly small number of cases (52) opened as a result of the Call For Quality progra The Call For Quality Investigator stated that "CEI's management attitude -

openness," was the reason for the low number of cases developed. According to the Call For Quality Investigator, " people exiting (the site) are as happy as people just starting out." The Call For Quality Investigator stated that he believed the Call For Quality program was " effective for us and the organization involved."

The Call For Quality Investigator also stated that the Call For Quality Program had not been audited by CEI, and the program was answerable only to the Nuclear Group Vice Presiden The Call For Quality Program was designed to use the " exit interview" of terminating employees as its interview forma Paragraph 6.2.3 of the Call For Quality Procedure states that.the exit interviews were conducted by either the " Call For Quality Representative or the Responsible QE'l (QE meaning Quality Engineer). Paragraph 6.2.5 of the procedure stated "The interviewer, upon completing the form, signs as ' Interviewing Supervisor'

and forwards it to the Corporate Ombudsman."

From the review of the procedure it appeared that persons other than the Call For Quality Representatives were permitted to conduct the interview This was confirmed as a common practice during the NRC review of the Call For Quality files. The practice raised several questions of investigative independence of the Call For Quality Program by allowing a person outside the Call. For Quality Program to conduct the interviews. Are the inter-viewees inhibited by the presence at the exit interview of their former supervisor? How does the Call For Quality Program audit the quality of those interviews if a Call For Quality Representative is not present?

How does the Call For Quality Program maintain the confidentiality of the interviewees' identities? During a subsequent conversation between the Ombudsman and the Region III staff, the Ombudsman agreed to revise the Call For Quality Procedure. This revision will specify that only a Call For Quality Representative would conduct the interviews or would be conducted by an independent representative of the Qur.7.ity Assurance Department if the Call For Quality Representative was not availabl The Call for Quality Procedure did not specifically provide for maintaining the interviewee's identity in a confidential manne Paragrach 6.5 of the procedure noted "all records listed above (the exit interview sheet, inves-tigation report, and status report) are proprietary and confidential."

Although that paragraph specified that records were confidential, se procedure did not specify the methods by which the identity of people furnishing information to the Call For Quality Prog ~ ram would be protected from disclosur .

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Further, it is questionable how an interviewee's identity can be maintained in a confidential manner if his name was known to the supervisor conducting the exit intervie During the NRC resiew of the Call For Quality Files it was noted that inter plant mail was used to contact the interviewees still employed at the Perry Plant. The use of inter plant mail could easily identify the current employee with the Call For Quality Program, thus allowing a ready method for the release of the interviewee's identity to persons .not associated sith the Call For Quality Program. The Ombudsman stated that in the cases where inter plant mail was used, the letters had been sent in one envelope wrapped inside an outer envelope. The Ombudsman agreed to contact the interviewees to determine if the letters had been mailed in this manner. The Ombudsman subsequently advised that the letters had been double wrappe The Call For Quality Procedure specified that " Concerns may be reported via telephone...via a mail-in form available at locations site wide, or via an exit interview with a Call For Quality representative" (paragraph 6.1,.' Call for Quality' Policy). Although a few current employees were interviewed, the procedure did not specifically provide for a process to personally interview current employee Investigative Methodology The Call For Quality Investigator's methodology was to read a concern in order to gain a complete understanding of it. Then, in conjunction with the Ombudsman, they would obtain the technical expertise to resolve the concerns. The Perry Plant' Project Organization was tasked to supply that expertise. Normally, the concern was investigated by a team consisting

.of the Call For Quality investigator and the assigned Project Organization technical expert. According to the investigator, rarely, if ever, was the organization at which a concern was directed tasked with resolving the concer Files The Ombudsman stated that the Call For Quality Program had opened fifty-two separate files. Twenty of the files were opened as a result of exit interviews. Another-twenty files were opened after receiving " hotline" telephone calls. The remaining twelve files were opened as a result of either mailed-in concerns or the concerns of current employees. Twelve of the fifty-two files were still open. The NRC reviewed the forty closed Call For Quality Files and made the following observation from those files:

File Maintenance The information in the files was in disarra The source of the information could not be determined in several instances. In other instances the " Concern Sheet" was missing from_the files; therefore, it was not possible to determine the substance of the concer Some files were opened as a result of findings documented in NRC Inspection Reports which indicated that the 52 Call 'For Quality files were

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opened from sources other than the interview processes described in the Call For. Quality Procedure. Duplicate and triplicate copies of the same document were maintained in the file, thus making the audit of the file a complicated task. An unissued nonconformance report was found in one fil (Region III determined that the items identified in the nonconformance report were processed through other quality assurance controls).

At least four of the files did not pertain to the quality of construction of the Perry Plant. The four covered such areas as vandalism, tool thefts, labor disputes, and speeding in the plant parking lo File Closeout Files were closed whenever the concern was not substantiated or when a concern was substantiated and a " quality document" (such as noncon-formance or action request report) was generated. The final closeout of the issue could act be readily determined frcm the Call For Quality Files as the Call For Quality Program did not track the nonconformance report / action request through its closure. Therefore, of the forty

" closed" Call For Quality Files it was not possible to determine if all of the issues requiring corrective action were in fact correcte Region III selected four of the forty files and found that the closecut was documented in files maintained elsewhere at the Perry Plant (e.g., Quality Assurance Department nonconformance report and action request files).

Concern Analysis Five of the cases dealt with alcohol or drug use on site. Although the Call For Quality Program used narcotics detection dogs in the work area, the Call For Quality Program did not make the effort to analyze the quality of the individual's work. The Call For Quality Ombudsman later stated that this analysis had been done, but the information was recorded in records other than those maintained by the Call For Quality Program (e.g., security department records).

The Call For Quality Program did not always examine all of the potential aspects of a concern. As an example, one concern dealt with a toppled crane. The Call For Quality Program file only indicated that an accident, involving a defective crane, had occurred. The file did not contain any information to indicate whether safety-related/non safety-related systems had been involved in the accident. In questioning the Ombudsman about this file it was learned that a crane had fallen against the exterior of the l Service Building. While it was noted that the Service Bailding was considered to be a non-nuclear safety-related' structure, it did contain the Technical Support Center. The Ombudsman later explained that an engineering analysis of the structure had been conducted after the crane accident and that the results of that analysis were l maintained in files elsewhere on the sit .

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Concerns were dismissed with statements that codes or procedures were in place to prevent an occurrence or that the codes / procedures allowed something. As an example, a concern dealt with " stack" welding and answered by the call for quality program task stack welding was permitted by the code. The Call For Quality Program did not take into consideration that a welder may have violated his thickness range. Therefore, while the Call For Quality's response to the concern may have been technically correct, the concern was narrowly interpreted and not all of its consequences were identified and examine Followup on File Closeout-Three concerns referred to the Call For Quality Program were reviewed by Region III inspectors to determine technical adequacy of the resolution of the concerns. All evaluations reviewed were found to be technically adequat (Refer to Inspection Report No. 50-440/85077 for further details.)

Conclusion The Cleveland Electric Illuminating Company appears to have made conscious decisions, fro ~m what they considered to be the best sources of information, to deal with possible quality problems in designing the Call For Quality Program. Their methodology and techniques used to solicit information resulted in the identification of some problems. The Call For Quality Program lacked specific provisions for the protection of the identities of their sources of information, lacked a careful analysis of the concern presented, and lacked a method to assure corrective actions were takcn. In conclusion, the Call for Quality Program needed a number of improvements to make the program acceptable, and CEI committed to making modifications to the Call For Quality Progra . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

on October 11, 1985, to discuss the scope and findings of the inspection. The licetsoa acknowledged the statements made by the inspectors with resper.: to items discussed in the repert. The licensee did not identify any items discussed as being proprietary in nature.

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