ML20198D559

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Partially Withheld Assessment of Allegation AQ-133 to Allegation Category Qa/Qc 7, QA Scope Re Inadequate Mgt of Personnel Exit Interview Program
ML20198D559
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Wenczel V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59 NUDOCS 8605230326
Download: ML20198D559 (4)
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Text

1. Allegation Category: QA/QC 7, QA Scope

2. Allegation Number: AQ-133
3. Characterization: There is a concern that the management of the Texas Utilties Electric Company (TVEC) personnel exit interview program is inadequate and that the program is not effective.
4. /.ssessment of Safety Significance: On August 29, 1983, the NRC Region IV staf f issued a notice of violation (NOV) and a proposed imposition of civil penalty to TUEC for violating Criterion I of Appendix B to 10 CFR Part 50.

This criterion, which concerns the organizational structure of the quality assurance program, states that persons performing quality assurance func-tions shall have sufficient organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. TUEC responded to the NOV on September 28, 1983, denying the violation, but stating that there was concern that a question had been raised about implementation of a QA/QC program that complied fully with Appendix B.

TUEC committed to several actions in their response to the NOV, one of which was to initiate an exit interview program to ensure that all QA/QC employees would be given the opportunity to state concerns regarding quality prior to leaving the QA/QC department. TUEC also made a commit-ment to evaluate and disposition these concerns. TUEC initiated the exit interview program on October 3, 1983.

On December 14, 1983, TUEC issued a memorandum to all Comanche Peak Steam Electric Station (CPSES) QA/QC personnel, informing them that TUEC had retained a QA consultant who was available to discuss concerns regarding the quality of construction at CPSES with any QC inspector or other employee. In April 1984, TUEC also initiated a " Quality Awareness Program" that included a " hotline" for employees to call in quality concerns.

During the interview with TUEC's QA consultant, the NRC Technical Review Team (TRT) learned that the " Quality Awareness Program" provided for two types of exit interviews at CPSES. One of these, designed for terminating QA/QC personnel, was conducted by the TUEC QA consultant or by the TUEC site QA manager, QA supervisor for operations, or appropriate QA super-visors. The other exit interview, which was designed for craft personnel, was conducted by the Brown & Root (B&R) personnel office or by the B&R assistant project manager. QA/QC-related concerns or comments identified in exit interview questionnaires from craft personnel were forwarded to the TUEC QA consultant for review and for recommendations of appropriate followup actions. QA/QC personnel concerns related to intimidation and harassment were referred to the TUEC corporate security office, and those raised by craft personnel were handled by the B&R assistant project manager.

In assessing this allegation, the TRT also interviewed the B&R personnel manager,.the Director of TUEC corporate security, the TUEC site QA super-visor, and the B&R project manager and assistant project manager. In addition, to evaluate the adequacy of their contents, the TRT reviewed the exit interview questionaires currently in use at CPSES. The TRT also reviewed a sample of questionaires completed by former B&R personnel and

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o all the quality assurance investigation (QAI) files maintained by the TUEC site QA manager. By telephone, the TRT also interviewed several individ-uals about the exit interviews that they had received prior to leaving CPSES.

On April 11, 1984, by corporate QA/QC office memorandom TUQ-2012, all site QA/QC managers and supervisors and others involved with the exit interview program were advised to give QA/QC employees the opportunity to state concerns regarding quality prior to leaving the QA/QC department.

The interviews were to be satisfactorily accomplished and adequately documented. In general, this memorandum directed that the program be implemented as follows:

(a) Prior to releasing any employee from the QA/QC department, the em-playee's supervisor shall ensure that the employee participates in an exit interview. The interviewer would be the TUEC QA consultant, or in his absence, the TUEC site QA manager, QA supervisor for opera-tions, or the appropriate QA supervisor or manager in Dallas.

(b) The results of these interviews are to be documented on the " Question-naire for Persons leaving QA/QC" forms.

(c) The " Request for Assistance in Resolving Quality Assurance Allegations" form is to be used to obtain investigative and/or engineering support as required, and for tracking on going investigations. 3 (d) Personnel who were released from QA/QC since October 3, 1983, without having filled out the questionnaire are to be located by corporate security and provided with the opportunity to fill out the questionnaire.

(e) Completed questionnaires, which have identified concerns, and " Request for Assistance" forms shall be forwarded to the TUEC corporate QA manager.

Dallas quality engineering was assigned the responsibility for logging and tracking these concerns as QAIs. The exit interview questionnaires com-pleted by craft personnel identifying QA/QC concerns for safety-related hardware were forwarded by the B&R assistant project manager to the TUEC QA consultant for followup.

The exit interview questionnaire contained three questions, which the em-

, ployee answered by checking "Yes" or "No," If the employee's answer was "Yes," the employee was requested to provide specific details. If a large number of employees was terminating employment at one time, such as related .

to a reduction of force, the questionnaire was handed to the individuals by their direct supervisor with a request that the form be completed. If only a few employees were terminating employment, they were interviewed, a 1 in some cases the questionnaire was completed by the interviewer and then signed by the employee. The terminated employees were asked to respond to the following three questions:

1. Are you aware of any problems in the implementation of the quality assurance / quality control program?

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2. Are you aware of any defects in the design, manufacture, fabrication, placement erection, installation, modification, inspection, or testing of safety-related/nonsafety-related components and/or structures?
3. Are you aware of any other matters related to the design, con-struction, or quality assurance program which should be brought to the attention of management?

In a TRT review of the exit interview questionnaires and QAls maintained by the site QA manager, the TRT found that of 226 exit interview question-naires completed during the first 9 months of the program, only 25 indi-cated concerns. It was also noted that, in general, those individuals who had made allegations directly or indirectly to the NRC did not make -

comments on their exit interview questionnaires.

Based on telephone interviews with QA/QC personnel and craft personnel who had recently terminated employment at CPSES, the TRT found that:

(a) Some individuals may have had concerns regarding the quality of plant construction, but the circumstances surrounding the interviews, in their view, did not motivate them to express their concerns. They felt that they were not given an interview; they were handed a questionnaire to fill out with little, if any, discussion regarding the questionnaire.

(b) As one person pointed out, there were Spanish-speaking craft personnel who could only get by on the job because some procedures were w'ritten in Spanish, but could neither read the questionnaire nor make written responses.

(c) One individual did not make any comments during the exit interview because he did not want to confide in the interviewer.

With regard to maintaining confidentiality in the program, some TUEC managers told the TRT that none of the terminated employees had ever requested confidentiality during the exit interviews. These managers also stated, however, that employee confidentiality would be difficult to maintairi if specific comments or concerns were to be investigated.

With respect to the resolution or disposition of concerns expressed in the exit interview questionnaires, most of the comments were deemed (by the interviewer) to provide insufficient specific information to enable followup actions. In this regard, the interviewers performing the exit interviews determined whether the expressed concern or the issue raised should be pursued further. If so, the interviewer would obtain additional information for the possible issuance of an QAI for a third party review and dispositioning. In some cases the attempt by the interviewer to ob-tain more specific information from the employee was unsuccessful; however in other cases, some investigative efforts appeared to be superficial. Of the 25 exit interview questionnaires that indicated concerns, only 7 had followup by QAls or interoffice memoranda, and were closed out for one of the following reasons:

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  • The concern or allegation lacked specificity.

Based on interviews with supervisors and co workers, the concern or allegation could not be substantiated.

The comments reflected a negative attitude and need not be pursued further.

The concerns lacked sufficient merit for further investigation.

5. Conclusion and Staff Positions: The TUEC exit interview program was initiated in October 1983. However, the program began and was implemented in its current scope and format in about April 1984, when TUEC initiated its quality awareness program. The concern regarding the adequacy and effectiveness of the exit interview program was substantiated. Although still in its infancy, the exit interview questionnaire and followup, which were reviewed by TRT, do not appear to meet the program objective.

The source of this concern was not a specific individual; therefore, no exit interview was conducted.

7. Attachments: None.

Reference Documents:

1. Notice of Violation and Proposed Imposition of Civil Penalty to TUGC0 (EA 83-64), dated August 29, 1983.
2. TUGC0 response to EA 83-64, dated September 28, 1983.

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3. Memorandum to distribution from D. N. Chapman, TUGCO, Corporate QA Manager,

Subject:

QA Allegation / Concerns, dated April 11, 1984.

4. Menorandum C. H. Welch, TUGC0 Site QA Supervisor to J. D. Turner, B&R Assistant Project Manager, subject: Exit Interviews, dated June 15, 1984.
5. CPSES Exit Interview Questionnaire.
6. Exit Questionnaire for QA/QC personnel.
8. This statement prepared by: k, W dd V. Wenczel,"TRT Date Technical Reviewer Reviewed by: Wultt&l/

H. Livermore, d 6

, bate Group Leader Approved by:

V. Noonan, Date Project Director 0-260

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