ML20148S249

Response Team Action Plan Item VII.a.6, Exit Interviews. Related Info Encl

ML20148S249
Person / Time
Site:	Comanche Peak
Issue date:	06/21/1985
From:	Bush J, Hassel J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20148S043	List: ML20148S249
References
FOIA-88-62 PROC-850621, NUDOCS 8804180282
Download: ML20148S249 (8)

Text

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t COMANCHE PEAK RESPONSE TEAM ACTION Pl.AN Ites Number: VII.a.6

Title:

Exit Interviews Revision No. O

{. Description Original Issue Prepared and Recoussended by:

Review Team Ieader Date # E/ /M Approved by:

Senior Review Team kQ,k Date (ol1llff Foi4 G 2.

8804100282 000400 PDR C 4NO O 62

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/ Revisien 0 Page 1 of 5 l

l i l . ITEM NUMBER VII.a.6 Exit Interviews

1.0 DESCRIPTION

OF ISSUE IDENTIFIED BY NRC The TUIC exit interview system for departing employees appeared to be neither well structured nor effective, as evidenced by the lack of employee confidence, limited Laplementation, failure to document erplau4tions and rationale, and f ailure to complete corrective actions and to determine root causes.

2.0 ACTION IDENTIFIED BY NRC I Evaluate the TRT findings and consider the implications of these I

. findings on construction quality. ". . . examination of the potential safety implications should include, but not be limited to the areas or activities selected by the TRT."

"Addtess the root cause of each finding and it generic implica tions . . ."

"Address the collective significance of these deficiencies..."

"Propose an action plan...that will ensure that such problema do not occur in the future."

3.0 BACKGROUND

3.1 Information Supplementing NRC Deceription of Issues Prior to January 14, 1985. TUGC0 had procedurally defined programs which required all personnel departing from QA/QC to couplete a quatticanaire and all Brown & Root construction employees tetuinating employment to be interviewed. One of the purposes of the questionnaireb and interviews was to identify "quality concerns." In response to NRC EA No. 83-64, i an Ombudeman from an outside organization (Gilbert / '

Commonwealth) was assigned to the site in November 1983, and personnel released from QA/QC since October 3,1983 who had not filled out a questionnaire were located, if possible, and given the cpportunity to fill out the questionnaire.

On January 14, 1985, TUEC established an independent group called SAFETEAM utilizing personnel from Utility Technical Services, Inc. This group has assumed the responsibility for interviewing personnel and investigating concerns.

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'. / Revision 8 0 Pass 2 of 5 j

. ITM NUMBER VII.a.6 (Cont'd) '

l 3.O BACKGROUND (Cont'd) 3.2 Preliminary Determination of Root Cauce and Generic Implications The problems with the exit interview program as described in the NRC TRT January 8, 1985 letter were identified by the TRT as examples which indicate TUGC0 "lacked

• the comitment to aggressively implement an offective QA/QC program in several areas."

Extensive investigations addressing past history are being carried out by the Comanche Pea'z Response Team to determine the adequacy and safety of the existing station. When specific areas of past concerns involving the exit interview program are identified during this evaluation process, ,

additional concerns in the same generic area vill be evaluated to determine whether a generic probles asists. The purpose of this action plan is to determine if TUGC0 management has now l established an effective prostan which encourages employees to l voice concerns regarding safety and to seriously evaluate these concerne. This determinatien will then be used as input

~ to the overall evaluation of the QA program including TUGCOs current couitment to an effective QA/QC program.

4.0 CPRT ACTION PLAN 4.1 Scope and Methodolony 4.1.1 The scope of this action plan is to evaluate the adequacy of the policies, procedures, and activities of the CPSES Site Ombudsman and the CPSES SAFETEAM in identifying and resolving CPSES site personnel concerns which have potential safety implications. As noted in paragraph 3.2 above, other CPRT investigations will determine the overall adequacy of the installed hardware. This action plan will ensure an adequate program is nov in place.

4.1.2 The specific methodology is as follows:

4.1.2.1 Review the procedures being utilized by the Ombudsman and SAFETEAM to determine their ability to satisfactorily accomplish the following

Aavisions O Page 3 of 5

. ITD( NUMBER VII.a.6 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd)

Identify.esployee evncerns having Fotential cafety implications.

Investigati and evaluate employee concerns to determine potential

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saf ety implications.

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Resolve esploy3e concerns includingt Resolution of safety implications Resolution of the concarn with the employee and management.

- Alert TUGC0 management of root  ;

causea and generic implications of identified concerns.

Protect the anonymity of the interviewees and prevent empicyees that Lave expressed concerns fron  ;

being subjected to inciaidation or '

harassment.

Insure proper coordination between I ombudsman M SAPETEAM.

The review of the program shall includi comparison with other of=11ar programs being effectively 1splemented by other utilities.

4.1.2.2 Evaluate the impicceatation of the procedures being utilised by the Orhteisman and SAFE 7EAM to determine compliance with the procedures and the effectiveness of their implementation. The evaluation of the effectiveness of implementation vill be based I on the same criteria listed in paragraph 4.1.2.1 above.

I Implementation vill, in the case of SAFE 7EAM, be lin3ted to examination of records which.

in the judgement of SAFETEAM, will not I compromise the independence and effectiveness i of their operation.

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. Revision: 0 Page 4 of 5 ,

. ITDi NUMBER VII.a.6 (Cont'd) 4.0 CPRT ACTION PLAN (Cona.'d) 1 4.1.2.3 A review shall be conducted of past items of concern of QA/QC and other employees which  ;

were identified during exit interviews to '

verify all concerns have been properly '

evaluated for potential safety implications.

1 4.1.2.4 An Action Plan Report .iocumenting the results l of 4.1.2.1 and 4.1.2.2 shall be prepared.

The report shall include recommendations for improvement in the program if warranted.

The results of the Action Plan Report shall be included in the final overall evaluation of the ah quacy of the QA program being conduct- 3y the QA/QC Review Team. ,

6.2 Responsibilities 4.2.1 Evaluation Research Corporation (s., This actica plan will be developed and implemented by V Evaluation Research Corporation.

4.2.1.1 Scope The sco,,e of this evaluation is anticipated to include only the current and on-going activities of the Ombudsman and TUEC SAFETEAM.

4.2.1.2 Personnel Mr. Dave Boydston issue ^oordinator 4.3 Personnel Qualificatien Requirese g Personnel participating in the implementation of this action j plan shall be qualified in accordtuca with paragraph III.H. of the TUCCOs Program Plan and Issue-Specific Action Plans.

Revisios 1.

4.4 Procedures Development and implementation of this action plan shall be in accordance with TUGCOs Program Plan and Issue-Specific Action Plans, Revision 1. Checklists will be developed by the Issue Team Leader for use in conducting reviews of policies and procedures and review of at'.ual employee concerne.

Revisient 0 I Page 5 of 5 ITEM NUMBER VII.a.6 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Standards / Acceptance criteria The acceptance paragraph 4.1.2.1. criteria for this action plan are defined.in 4.6 Decision Criteria Not applicable.

5.0 SCHEDULE

\

, The Action Plan Report shall be issued by August 30 ,

1985.

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DOC-SEARCH ASSOCIATES P.O. Box 7 Cabin John, MD 20828 January 21, 1988 Donnie H. Grimsley, Director NDOM OF INFORMATm ACT REQUEST Division of Rules and Records Office of Administration [gygg ,Id b.S. Nuclear Regulatory Comi3sion Washington, D.C. 20555 Ga4Jgjg j '

Dear Mr. Grimsley:

Pursuant to the Freedom of Information Act, I request that you make available, by placement in the Public Document Room at 1717 H Street, N.W., all documents associated with-the NRC review, and evaluation i thereof, cf the Comanche Peak Safe Team by Headquarters and the Region 4 Staff, from 1985 until the present. Please include the review of the Office of Investigations.

For the purposes of this request "document" is defined to include but not be limited to draft: and final versions of memoranda, meeting and trip reports, reports of telephone conversations, transcripts, notes, letters, records, graphs and charts.

Thank you.

Sincerely, t.ynn Connor l

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REGULATORY INFORMATION DISTRJDUTION SYSTEM (RIDO) Q ACCES'SION NBR: 8h02180139 DOC.DATE. 86/02/06 NOT AR I ZED: NO DOCKET O FACIL: 50-445 Comanch e Peak Steam Electric Station, Unit 1, Texas U 05000445 50-446 Comanche Peak Steam Electric Station. Unit 2, Texas U 05000446 AUTH.NAME AUTHOR AFFILIAT,10N JOHNSON E.H. Region 4. Office of Director RECIP.NAME RECIPIENT AFFILIATION SPENCE,M.D. Texas Utilities Electric Co. (formerly Texas Utilities Gene SUsJECT: Forwards Insp Repts 50-445/85-12 & 50-446/85-08 on  !

850826-29. No violation or deviation noted Several areas l identified for improvement of SAFETEAM program.  !

DISTRIBUTION CODE: IE01D COPIES RECEIVED: LTR ENCL SIZE: '

TITLE: General (50 Okt)-!nsp Rept/ Notice of Violation Response l NOTES: LPDR 2cy Amdt,Trans. 2cy 3.Hou. icy-Teledyne,Westernan,Shao 05000445 V.Noonan,Trammell Calvo,Jeng,Early,Norkin,Milhoan.

LPDR 2cy Amdt,Trans. 2cy S.Hou. 1cy-Teledyne, Westerner,Shao 05000446 V.Noonan,Trammell,Calvo,Jeng,Early,Norkin,Milhoan.

l RECIPIENT COPIES RECIPIENT COPIES l ID CODE /NAME LTTR ENCL i n ^^ ^ r '4,'4ME LTTR ENCL PWR-A PD5 PD 1 1 9 "T T -ClOU -- 1 1 INTERNAL: ACRS 2 2 ACRS WYLIE 1 1 AEOD 1 1 ELD /HDS1 1 1 IE FILE 01 1 1 IE/DEPER/EPB 1 1 IE/DI/ORPB 1 1 IE/ES 1 1 NRR ROE,M.L 1 1 NRR/DSRO/RRAB 1 1 EXTERNAL: 24X 1 1 LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NO1ES: 14 g4 ,

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. pr t Log i TXX-4766 File i 10130 IR 85-12 TEXAS UTILITIES GENERATING COMPANY IR 85-08 S K Y W A Y TOWR E

• 4 09 Pv0R TH OtJYE ETB E r?. t+ 9. 8 8

• D AtJAS. TE RA8 '.80 8 May 14, 1986

.7.'FJ^ * .*AY,7.'.S Mr. Eric H. Johnson, Director Division of Reactor Safety and Projects '

O. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Aritngton, Texas 76012

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NO. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORTS INSPECTION REPORT N05.: 50-445/85-12 and 50-446/85-08

Dear Mr. Johnson:

We have reviewed your letter of February 6,1986, regarding the inspection conducted by W. P.

the period August Haass, 26-29, A. Vietti-Cook, C. Early, and G. L. Madsen during 1985.

The inspection concerned the TUEC programs established to identify and investigate safety concerns of workers at CPSES.

We noted that inspection no violations or deviations were identified in your report.

We have elected to address the observations noted and have done so in the attachments to this letter. Attachmerit I is in reponse to the observations noted in Section 3 of your report. Attachment !! is in response to the concerns notad in Section 4.

We would like to emphasize the fact that the SAFETEAM is a program with a specific purpose and scope. It is not a licensing activity but rather a management tool with the purpose of responding to concerns expressed by project employees.

Safeteam. This is the intended nature of the Comanche Peak In addition to our responses as attached, we would like to note the following observations regarding your inspection report:

1.

The Interview Coordinator, part-time Interviewers and a Sectetary/ Receptionist are provided unde subcontract from McIntyre &

Associates, Inc., not National Inspection and Consultants, Inc.

A Dl% 0 'ON OF TEXA S (JTil2TRES Ei2CTRIC CDMPANY Ts l

2.

SAFETEAM now has a forcal docurrent of qualifications for Investigators (Paragraoh 4.d.).

Very truly yours, 0 'r W. G. Counsf1 JWA/arh Attachments c- Region IV (Original + 1 copy)

Oirector, Inspection and Enforcement (15 copies)

U. S. Nuclear Regulatory Comission Washington 0.C. 20555 Mr. V. S. Noonan Mr. D. L. Kelley i

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Attachment !

TUEC's Employee Concern Program Prior to January 14,1985 (Section 3)

At the time of the inspection the NRC found 51 of 53 QAI (Quality Assurance Investigation) flies to be closed. As of this date all 53 QAI files are considered initiated. closed. With the advent of the Safeteam no new QAl's have been The NRC inspectors selected 22 files from the QAI index for their review which resulted in four observations. The following provides our response to the observations:

NRC ITEM 3a - Employee responses to the questionnaires were somewhat sketchy. The applicant did re:ontact some of the concerned individuals.

The QA Supervisory staff conducted the questionnaire for persons leaving QA/QC and attempted to obtain as much specific information as the person would volunteer. As the questionnaires show, the success of this effort was highly dependent on the frame of mind of the person leaving QA/QC, Brown and Root craf t exit questionnaires were forwarded to QA leaving any followup effort to QA. Where the concern lacked sufficient specificity to conduct a reasonable investigation, an attempt by either Corporate Security or the site Ombudsman was made to recontact the individual. The solicitation of additional laformation i was not always successful and some QAI's were closed as being too vague or '

general to reasonably investigate.

NRC ltem 3b - The program was administered by TUEC QA. This is a poor practice especially for concerns relating to QA management, supervisory confidence, and supervisor / involvement, since the individuals 1 respcnsible for investigating and correcting the concerns could be the same individuals who could be the subject of, or be responsible for, the concern expressed by the eeployee.

While it is true that the program was administered by QA, the extent of involvement of TUEC personnel and management went beyond the boundaries of QA. 3 Depending on the QAl, investigations were conducted by the Ombudsman, an l

independent contractor, and/or by Corporate Security which is a function that is '

provided by Texas Utilities Services Inc. and as such is responsible to a management chain separate and distinct from TUGC0 or TUEC. Furthermore, all QAl's prior to closure were reviewed by three levels of management, the highest level of this review being the Vice President, Nuclear Operations.

NRC ltem 3c - Some concerns were not fully cadressed during the course of '

this investigation.

This observation appears to indicate that while all concerns were addressed, the inspectors were either not satisfied with the depth of the investigation or the documentation of the investigation. The depth and extent of any 1nvestigation

Attachment ! - page 2 is a subjective judgement and in many cases is dependent on the general level of understanding or knowledge of the particular circumstances in question of the individual making the judgment.

management all concurred in closure It should befiles.

of QAI noted that three levels of TUEC it was not intended that QAl files should be stand alone files.WithThat regard is,tothe documentation, QAl file would only reference other administrative systems such as the NCR system and would not contain all details concerned with the disposition and closure of the NCR.

appropriate corrective QAl's were closed based on the initiation of the action.

NRC ltem 3d - There was only limited contact of concerned individuals to inform them of the resolution of their concerns.

The QAl system was not designed to pro /ide written feedtsck to the concerned ind'. v idua l .

Normally, if the individual expressed a desire to know the resolution, a followup contact would be made. Again the implementation of the Safeteam was, at least in part, motivated by a desire on management's part to better control the investigation, resolve employee concerns, and provide feedback to the employee.

Attachment II TUEC's Employee Concern Program After January 14, 1985 SAFETEAM Program (Section 4' INTERVIEWERS QUALIFICATIONS [4.c.(1)) .

The subject of interviewer qualification was discussed at length with the NRC during the inspection.

The statement in the SAFETEAM manual that "interviewers should have a knowledge of nuclear principles" is from the early days of the i Feral 2 program. The experience from all five of the SAFETEAM programs suggests j that this statement should be changed. All of the SAFETEAM programs have an  ;

engoing pregram to monitor the quality of interviews. This monitoring program j has shown that some of the best interviews have been by non-technical people'  :'

i trained to be effective communicators in the one-on-one interview. Some of the 4

least effective interviews have been done by technical persons.

The interviewers must build a rapport with the interviewee so the interviewee  ;

will be candid and express concerns. We have found non-technical people to be better at this. The non-technical interviewers are trained in specific questions to ask to get the type of details necessary to d.o a complete investigation.

" There is a backup to get additional information not reported on the interview form. This can be done by listening to the tape or by recontacting the concernee

• 1 either during the investigation or in the response letter. We believe that the l interviewers do have the necessary communication skills to get an individual to  :

express a concern, thus making it possible to obtain backup information. t i

i We are confident interviewers has resultedthat the in selection and trainin of the Comanche Peak SAFETEM good interviews, j he CPSES SAFETEAM has made a recommendation to SYNDICO that the SAFETEAM n: annual be revised, i 1 FORMALITY IN REPORTING POTENTIAL 50.5S(e) C4.c.(2)] t The matter of SAFETEAM's reporting items potentially reportable under 10 CFR 50.55(e) was also discussed at length during the on-site inspection. To maintain  ;

independence from the project and to operate efficiently Comanche Peak SAFETEAM i

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conducts its program such that it would not be necessary,for it to make formal i

notification of potential reportable items under 50.55(e). SAFETEAM does not do  ;

l inspections, the project. engineering evaluations or any functions that are a normal part of i If the investigation of a concern requires an inspection SAFETEAM j requests that QC inspect and report results to SAFETEAM. Likewise, if an

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engineering evaluation is required SAFETEAM requests that engineering do an '

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evaluation and inform SAFETEAM of the results. By investigating in that manner '

j problems are discovered (at SAFETEAM's prompting) by the normal site processes ,

and are evaluated and reported under existing procedures. Conducting the program i

in this manner is consistent with the nature of SAFETEAM, as noted in the cover

letter.

)

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AREAS OF IMPROVEMENT (4.f.(4))

i (a) Interviews lacked specifics. With experience, recontacting the concerned d individuals for additional details has increased.

j As mentioned before, the quality of interviews is continually monitored.

)

While we believe that even the earliest SAFETEAM interviews were adequate, with more i experience and continued evaluattun, considerable improvement has been shown, i

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. Attachment !! page 2 (b) Some files revealed that the investigator did not attempt to obtain adequate information sufficient to establish the specificity of the concern.

We believe that in all plant safety concerns each investigator attempted to '

obtain the specifics of a concern. In a few cases where specifics were not given and could not be obtained, the concern was addressed generally. In some management type concerns, specifics were not pursued in order to protect the confidentiality of the concernee. In these cases, the concern was pursued in general terms.

(c) The program does not call for follow-up resolutions to work completion. In one case, a concern regarding the disposition of the NCR raised by an individual was not addressed by SAFETEM.

The SAFETEAM program investigates a concern to determine if it is an actual problem rather than a misunderstanding or miscommunication. If it is determined that the identified problem is real, the investigation is not complete untti corrective action is identified. This corrective action '

must be verifiable in the project program (an NCR, CAR, etc.). Identifying corrective action in this manner allows SAFETEAM to respond to the concernee without delay if the completion is a lengthly process.

In the example cited, the concernee received the details of how the NCR's were dispositioned. However, the NCR's were still open because the I

corrective action was in process.

(d) Resolutions provided corrective actions for present and future; however, the impact on the past was not always clearly addressed.

Unlen specifically part of tne concern, evaluation of past impitcation of 9roblems is not within the scope of the SAFETEAM program. If such a past evaluation needs to be performed, other project departments have and will continue to perform this function.

(e) The SAFETEAM does not comply with the manual with regard to formally reporting conditions discovered by the SAFETEAM investigators that may be l' reportable to the NRC in accordance with the requirements of 10 CFR 50.55(e). '

See response to (4.c.(2)).

g. Documentation - In some cases,...it was difficult to infer what the investigator did from the contents of the file.

Because of discussions with the NRC during the inspection, it is believed that the problem was that while certain concerns were dispositioned in accordance with SAFETEAM policies, these policies and proceJures were not restated in each file. These procedures were properly documented and understood by program personnel and this was explained to the inspectors.

5. SAFETEAM Review by Office of Investigations 01 commented that, "...the intestigative findings of some instances were inconclusive."

Attachment !! page 3 This observation by O! is correct. It was explained to the NRC Inspectors that the investigations they questioned had been referred by procedure to TUGCo Corporate Security. '

because they did not meet the criteria of CorpordteCorporate Security.T Security requires that the allegation received from a single source meet one of the following criteria:

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(1) be of such specfficity and detail as to clearly estabitsh its reliability; (2) besource; corroborated by information received from another independent (3) be of a nature permitting corroboration by independent investigative methodologies, i

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Fi,1cd January 21, 1987 3

%15.IV I

'87 JMI 27 P1 :25

- 1 S

y'. Bae a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISS 7N J..

h* . I f,. 4*

• before the ATOMIC SAFETY AND LICENSING BOARD

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C,. i mmme

)

In the Matter of. )

) Docket Nos. 50-445-OL TEXAS 11TILITIES ELECTRIC )

50-446-OL ,

COMPANY et al. ) l

) (Application for an (Comanche Peak Steam Electric ) Operating License)

Station, Units 1 and 2) )

)

ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)

Regarding Action Plan Results Report VII.a.6 In accordance with the Board's Memorandum; 1

Proposed Memorandum and order of April 14, 1986, the Applicants submit the answers of the Comanche Peak Response Team ("CPRT") +a the 14 questions posed by the l

Borrd, with respect to the Results Report published by the CPRT in respect of CPitT Action Plan VII.a.6, Exit Interviews.

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