ML20207D568
| ML20207D568 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/31/1985 |
| From: | Bowers D, Kaplan B, Margulies N AFFILIATION NOT ASSIGNED, CALIFORNIA, UNIV. OF, IRVINE, CA, EG&G IDAHO, INC. |
| To: | |
| Shared Package | |
| ML20205D361 | List: |
| References | |
| FOIA-85-799 NUDOCS 8607220141 | |
| Download: ML20207D568 (78) | |
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COMANCHE PEAK STEAM ELECTRIC STATION:
ALLEGED CLIMATE OF INTIMIDATION SUPPLEMENTARY REPORT Bruce L. Kaplan -- Team Leader EG&G Idaho, Inc.
David G.
Bowers Research Scientist Newton Margulies University of California, Irvine Charles M. Rice LRS Consultants, Inc.
William E. Stratton Idaho State University August 1985 EIGHTH EIGHTH EIGHTH DRAFT DRAFT DRAFT 860715 1
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e TABLE OF CONTENTS PAGE ABSTRACT................................................
I 1.
INTRODUCTION.......................................
1 2.
DATA SOURCES.......................................
3 2.1 Depositions...............................
3 2.2 Survey Data...............................
3 3
2.3 NRC Reports 2.4 Prefiled Testimony........................
4 2.5 Hearing Transcripts.......................
5 2.6 Other Information.........................
6 3.
ANALYSIS...........................................
8 3.1 Analysis Using Depositions, Prefiled Testimony & Hearing Transcripts........... 9 3.2 Analysis of the 1979 Management Review Board Survey.............................
20 3.3 Analysis of Additional NRC Reports of Investigation and Inquiry................
25 3.4 Observations on Managertal Practices..... 38 4.
SUMMARY
AND CONCLUSIONS...........................
44 APPENDIX A - 1979 Management Review Board Survey.
Analysis By David G.
Bowers..............
A-1 APPENDIX B - Summaries of Alleged Incidents of Intimidation............................. B-1 1
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ABSTRACT COMANCHE PEAK STEAM ELECTRIC STATION:
ALLEGED CLIMATE OF INTIMIDATION SUPPLEMENTARY REPORT May 1985 NRC contracted with EG&G Idaho, Inc., to continue its investigation of the work climate at Comanche Peak Steam Electric Station (CPSES), and to update its opinion concerning intimidatio9 of QA/QC personnel based on data reviewed from September 1984 through April 1985.
The resulting expert opinion, developed by t9
.same study team that produced the original EG&G report, is present in this supplement.
The study team assessed depositions, pre flied testimony, hearing transcripts, NRC reports, survey data, and other availabic information.
Using a broadened definition of intimidation they formulated opinions on individual incidents of intimidation and tC overall work climate.
Key findings were that some incidents of intimidation did in fact occur.
The overall pattern of incidents, including the numbi of alleged incidents, allegers, and named intimidators, does not support a conclusion that a climate of intimidation exists or existed at CPSES.
It was also found that certain management practices, while not constituting intimidation, may have negative impacted performance of QA/QC personnel.
This investigation resulted in findings that support the conclusions in the original report.
In the judgment of the study team a climate of intimidation did not and does not exist at Comanche Peak Steam Electric Station.
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COMANCHE PEAK STEAM ELECTRIC STATION:
ALLEGED CLIMATE OF INTIMIDATION SUPPLEMENTARY REPORT 1.
INTRODUCTION An initial report (Comanche Peak Steam Electric Station: Alleged Climate of Intimidation) on the issue of intimidation of QA/QC personnel at Comanche Peak was written by this team in September 1984.
Conclusions in that report were based on information that had been received and analyzed by the team up to that time.
This report is presented as a supplement to that initial report
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and is based upon the incorporation of all information received prior to May 1985.
The numbering of the sections in this Supplementary Report generally follows the outilne of the original report to facilitate the comparison of related sections between the two reports.
It is not intended that this report stand alone.
It is a supplepent to the original report and must be read in conjunction with it.
The report is divided into a number of sections as follows.
Section 2 presents listings of the additional Page 1
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o data received and reviewed since preparation of the original report.
Section 3 presents the analyses carried out based on the additional data and includes conclusions based on the entire data set.
This section is divided into subsections dealing with-transcribed data, the 1979 and 1983 surveys, NRC Reports of Investigation and Inquiry, and observations concerning management practices at CPSES.
Section 4 presents a summary of findings and the conclusions reached in the study.
Appendix A is an analysis by David G. Bowers of the 1979 Management Review Board Survey, and Appendix B presents brief summaries of the alleged incidents of intimidation.
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DATA SOURCES Information in addition to that used in preparing the original report was rece ived and ut ilized in arriving at the supplementary conclusions presented here.
This information is listed in the following sections.
2.1 Depositions Depositions of two individuals were received and reviewed after September 1984:
1.
H. Brooks Griffin, NRC Investigator 2.
Evert Mouser, former QC Supervisor, Coatings 2.2 Survey Data No additional survey data were obtained.
However, an additional analysis of both the substance and pattern of responses was performed on the 1979 Management Review Board Survey data by David G.
Bowers, the same expert in survey methodology who previously analyzed the 1983 QA/QC Questionnaire Survey.
2.3 NRC Reports A number of additional NRC Office of Investigation Reports of Investigation and Reports of Inquiry have been reviewed since September 1984:
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4 Inquiry Reports Investigation Reports Q4-82-0005 4-82-012 Q4-82-0011 4-83-005 Q4-82-025 4-83-006 Q4-83-009 4-83-011 Q4-83-011 4-83-016 Q4-83-021 4-84-008 Q4-83-022 4-84-012 Q4-83-023 Q4-83-025 Q4-83-026 Q4-84-001 Q4-84-007 Q4-84-011 Q4-84-014 Q4-84-016 Q4-84-037 Q4-84-046 2.4 Prefiled Testimony Preflied testimony from the following nineteen individuals was also received and reviewed:
1.
Antonio Vega 2.
Gregory Bennetzen 3.
Ne11 Br1tton 4.
William Darby Page 4
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Liford, Johnson, and Callicut I
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8.
Richard Simpson 9.
Gordon Purdy J
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Robert Duncan l-11,12.
James Zwahr and Daniel W11terding 13.
Ronald McBee 14.
Alan Justice i
15.
James Brown f-16.
W!tness "F" I
17.
Samuel Hoggard e
18.
Arthur London 1
19.
David Ethridge e
2.5 Hearing Transcripts
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The following listed transcripts of hearing testimony l
Were received and reviewed:
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9/09/84 14,403-14,771 ID ggmgrg Session: Witness *F"
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9/10/84 14,772-15 171 M. Spence, A. Vega 9/11/84 15,172-15,573 Vega (cont.),
B.
- Clements, i
C. Thomas Brandt 9/12/84 15,574-15,951 Brandt (cont.),
I. Goldstein l
l 9/12/94 15,952-16,389 Brandt-Travelers, G. Purdy l
9/14/84 16,390-16,647 Tolson, Downey on Travelers 9/18/64 16,648-17,008 Tolson, Vega, Brandt (cont.),
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t C. Allen i
9/19/84 17,009-17,740 Allen, Brandt (cont.), Liford, Calicutt, etc.
t 9/20/84 17,741-18.158 G. Eennetzen, D.
Chapman, Duncan 9/21/84 18,159-18,504 In Camer3: two witnesses 10/01/84 18,5C5-19,028 D. Hunnicutt, J. Norris, T. Matheny 10/02/84 19,029-19,262 Norris (cont.). G. Purdy l
11/19-84 19,586-19,846 0.
B. Cannen: J. Lipinsky 11/20/84 19,847-20,179 L1pinsky (resumed), R. Roth 11/21/84 20,180-20,450 Roth (cont.)
11/26/84 20,451-20,774 G. Chaney - Handwriting Expert, Brandt 11/27/84 20,775-21,091 Brandt (resumed) l 11/28/84 21,192-21,405 Brandt (resumed) 12/03/84 21,406-21,748 Brandt (resumed), Roth (resumed) j 12/04/84 21,749-22,006 J. L1pinsky 12/05/84 22,007-22,254 Lipinsky (resumed) 1/07/85 23,112-23,422 J. Norris (resumed) 1/08/85 23,423-23,734 J. Norris (resumed) 1/09/85 23,735-24,032 J.
Norris (resumed),
R.
Trallo 2.6 Other Information t
Two additional documents received in response to NRC requests to 7exas Utilities for specific information were l
i reviewed.
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The Responses of Texas Utilities to the NRC'o h
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Questions Concerning the 1979 and 1983 Surveys of Quality Control Inspectors at Comanche Peak.
2.
A series of organizational charts and a summary table 1
(dated 2-16-85, 2 pages) Indicating the company, organizational unit, and position of alleged Intimidators.
The Licensing Board Memorandum (Concerning Welding l
Issues) LBP-84-54, dated December 18, 1984, was revtewed.
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s 3.
ANALYSIS The analysis which follows presents updated findings of the study team.
The conclusions reached are the result of a review of the materials recetved subsequent to the drafting of the original report, analysis of those materials, and integration of that analysis with the work previously done.
The final condlusions in this report were based on the several different types of data available for analysis.
Of central interest was whether or not the analyses of different types of data (e.g. depositions, survey data, etc.) led to the same conclusions.
Similarity among conclusions derived from different data sources enhances the reliability of the overall conclusions.
The following sections of this report deal successively with data from the depositions, preflied testimony, and hearing transcripts; survey data; and NRC investigation and inquiry reports.
In addition to dealing with intimidation the report also addresses other climate factors affecting the quality of work at CPSES that would not be classified as
" intimidating".
These will be discussed later in Section 3.4 of this report which deals with managerial practices.
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.i 3.1 Analysis Using Depositions, Prefiled Testimony, and Hearing Transcripts 3.1.1 The Soggest sf Qtgant;atlog Ell 33te This section analyzes the extent to which a ellmate of intimidation existed at CPSES.
(This concept is defined in detail in Section 1.3 of the original report.) In making e
this determination the study team not only noted the frequency and distribution of incidents of alleged intimidation, but also made some judgments regarding the likely impact of the incidents en individuals in the work setting other than the alleger.
In the original report the study team defined intimidation as a process involving three major components:
- 1) the incident, action, or statement inducing the e f fect,
- 2) the resulting feeling or emotion experienced by the recipient, and 3) the ensuing action on the part of the recipient who, because of fear, is forced into behavior that otherwise would be re jected, or is deterred from actions that would otherwise be taken.
Intimidation was therefore treated as an incident, action, or statement that caused an employee to act contrary to, or refrain from acting in compilance with, written procedures.
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The study teac has now broadened the de finition of intimidation to incivde the impact the incident could be expected to have had en reasonable individuals in the work setting who experienced, witnessed, or became aware of the event, regardless of their actual respcases to the alleged 1
intimidation.
3.1.2 Extent of Allegationi of [g11midatlog At the time of the original report, September 1984, the analysis, and there f or'e the conclusions reached, was based on the data the study team had received and analyzed up to that point in time.
This supplemental report incorporates review and anal ysis of information available through April 1985.
This section analyzes the extent of allegations of intimidation based on depositions, prefiled testimony, and hearing transcripts.
The depositions analyzed were taken from 83 individuals up to September 1984 and from two additicnal f
individuals after September.
A summary list cf these data sources is shown in Table 1 of this section.
In addition to the depositions, 19 individuals Page 10
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?ravided data in the form of peefi' led testimony, and numerou; individuals provided tectiacqy at the hearing (as listed in M ctions 2.4 and 2.S.
For toe mo4t part these individuals ;;upplemented r repeated ir.ici matien pt pvided in the depos(ti.ons.
In some cases these were new data providers elabert:~ing on incidents ide.ntitled en the depotitions.
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4 TABLE 1
SUMMARY
OF DATA PROVIDERS FOR DEPOSITIONS Total Data Providers:
86 QA/QC Managers:
17 QA/QC Empleyees:
26 David Chapman Darlene Stiner Gordon Purdy Meddie Gregory Mark Welch Jack Pitts Thomas Brandt Joe Krolak James Patton Debra Anderson G. S. Keeley Susan Spencer Richard Kahler Albert Boren Robert Spangler Houston Gunn Billy Ray Sne11 grove Deborah Anderson Ronald Tolson Sue Ann Neumeyer Robert Siever Curtis Biggs Dwight Woodyard Greg Fanning Antonio Vega P.andy Whitman James Uehlein Jack Stanford Billie Ray Clements William Dunham Myron Krisher Jimmte McClain Evert Mouser Wayne Mansfleid Larry Wilkerson Noc-QA/QC Managers:
24 Kenneth Whitehead James Callicut Marvin Coates Freddie Leon Powers Linda Barnes Perry Brittain Michael Rhodes Richard Camp William Simms Jimmie Green Melvin Todd Thomas Locke Sherry Burns Ray Yockey Cecil Manning Joe George Robert Messerley Craft Employees:
15 John Blixt Henry Stiner Louis Fikar Mark Wells Doug Frankum Kenneth Luken Michael Spence Lester Smith Ronald Dempsey James Scarbrough I
Kenneth Liford David Ethridge Fred Coleman Ivan Vogelsang John Ha11 ford Dennis Culton Charles Tedder Bobby Murray Hollis Hutchinson Stanley Miles Carmen Baker Gary Krishnan Michael Hall Ronnie Johnson John R. Johnson James Keller Samuel Hoggard Larry Howard Boyce Grier Witness "F"
NRC Personnel:
4 James Cummins Robert Taylor Frank Hawkins H. Brooks Griffin Page 12
The study team reviewed the specific incidents of reported intimidation.
This analysis had two purposes:
- 1) to discern how the incidents were dispersed over time, and 2) to identify which instances appeared to be
" legitimate" incidents of intimidation according to the definition used in the study.
Analysis of the incidents over time indicates that there were 31 reported incidents spanning the period from 1979 to 1984.
(See Appendix B for a complete listing.)
The dispersion is shown in Table 2.
TABLE 2 DISPERSION OF INCIDENTS OVER TIME Year
- Incidents 1979 1
1980 0
1981 4
(3 from one alleger) 1982 6
(5 from one alleger) 1983 11 (5 from one alleger) 1984 9
(6 from two allegers)
Table 2 shows that the reported incidents were concentrated from 1982 through 1984.
In 1981 four incidents were reported by two individuals, one of whom provided three of the reports.
In 1982, five of the six Page 13
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l incidents reported were also from the came Individual who re ported three incider.ts in 1981.
Sc, of these ten I
incidents in 1981 and 4382, eight involve that one individual.
As a result, for the years 1979 through 1982 there we re only four different individuals alleging intimidation.
Table 2 also shows that in 1993, 11 incidents were reported by a total of five allegers.
Of these 11 incidents. five Were reported by one alleger.
In 1984, nine incidents were reported by a tatal of six allegers.
Six of these incidents were reported by two.allegers.
One of the eight incidents involved the termination of three individuals.
Over the time period of 1979 through 1984 the 31 incidents vere reported by a total of 13 Individuals.
Overall, two-thirds of the incidents (21 ef the 31) were reported by only four individuals.
Tn using these data to assess the climate the study team noted that the number of QA/QC personnel employed at the sitt from 1979 to 1984 was between 150 and 250 at any one tine, with a total of perhaps 500 different individu(1s en. ployed over that time period.
If approximately 200 inspectors had worked 250 days each year.doing an average of two inspections per day over the six year period, then there would have been 600,000 opportunttles for confilet or intimidation to occur.
Considering the normal pressures e
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created by scheduling and economic considerations, the
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natural confilets between Craft and QA/QC, some 'nevitable personality clashes, and the number of opportunities for problematic interactions during the course of the work. It wocid be reasonable to assume that even under the best of
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circumstances hundreds of incidents which might have been classified as intimidation occurred over the six year
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period.
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[y' Viewing the situation at CPSES from this perspective, the study team concluded that the small number of incidents, the limited number of allegers, and the few alleged intimidators are insufficient to establish the existence of a climate of intimidation.
There were relatively few reported incidents of intimidation over the, I
six-year period involved, with a substantial majority of these incidents being alleged by a total of only four individuals.
In fact, it would take more than a few additional allegations of intimidation for the study team to change its conclusions based on this approach to analysis of the climate.
Nevertheless, the small number o9 reported incidents can not eliminate the possibility of such a climate.
Depending on the nature of the incidents reported, a conclusion that an intimidating climate existed could be reached even with few reported instances.
If, for example, Page 15
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the incidents reported were perceived to be of a very serious nature, and there was widespread knowledge of the events, and that knowledge persisted for some time in the organt ation, then a conclusion of intimidation might be reached based on a relatively small number of reported events.
This approach to the analysis of climate is considered further in Section 3.2.2 of this report.
The September report indicated that there were relatively few allegations and relatively few named intimidators.
Having now reviewed all the depositional material, the conclusions of the study team do not differ from those original conclusions.
The findings fall to indicate the existence of widespread intimidation at CPSES.
3.1.3 Egvlgw sf SgggljJg JggJdggts gf JntimJdatjeg The analysis presented thus far has made no judgments regarding the validity of the allegations tnemselves.
Each alleged incident was simply counted without judging whether or not it actually involved intimidation.
The study team subsequently reviewed each incident according to its definition of intimidation and made a judgment as to its validity.
These judgments were based on: 1) whether the data supported a clear conclusion as to what actually occurred, 2) the extent to which a clear threat was made or implied, and 3) the likelihood that a reasonable person directly or indirectly involved would have been intimidated Page 16
in the given situation.
It should be noted that a conclusion concerning any one specific incident, in and of itself, would not lead to any conclusion about the climate of intimidation.
The overall pattern of the incidents must be considered for the purpose of assessing the climate.
Analysis of the 31 incidents led to nine incidents being judged as cases of probable intimidation.
These are listed in Table 3.
In performing this analysis all available data were utilized, including depositions, pre filed testimony, OI reports, hearing transcripts, and the ASLB Memorandum on welding issues.
Each incident evaluated is listed and briefly discussed in Appendix B.
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f TABLE 3 DISPERSION OF INCIDENTS JUDGED AS INTIMIDATING ltat
{ [qcid agg Dtionigtigg t
1979 0
1980 0
1981 1
D. Stiner - Weave Welding 1982 1
D. Stiner - Circuit Breaker Article 1983 6
Dunham - Intimidation of Coatings Inspectors - Nitpicking Dunham - Termination Neumeyer - Liner Plate Traveler Allen - ALARA and DCA Reviews Allen - Detergent on Painted Surface Allen - Cigarette Filters 1984 1
T-Shirt Incident When judgments about the legitimacy of the incidents are made, the case against a climate of intimidation is even stronger.
There are very few incidents in the opinion of the study team that could be classified as
- Intimidating".
Of the incidents included as probable acts of intimidation, some were not very clear or were counted only because they fit narrowly or technically within the definition as intimidating.
These cases were, however, included in the Page 18
listing above.
These nine incidents involve four different allegers, excluding the T-Shirt Incident which involved some eight
" targets" of potentially intimidating actions.
- Clearly, all of these incidents do not deserve equal weight as significant events in creating a possible climate of intimidation.
The most significant incidents from an overall intimidation climate assessment were the Stiner Circuit Breaker Article incident, the two Dunham related e
incidents, and the T-Shirt Incident.
3.1.4 Conglusjons On IntJmJdatJon Jngjdents In conclusion, review of the available information regarding the number of alleged incidents of intimidation and their dispersion over time, and review of the specif1@
incidents themselves, resulted in no change in the origing findings of the study team.
The data do not support a conclusion that a climate of intimidation exists or exist'G at CPSES.
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3.2 Analysis of the 1979 Management Review Board Survey The original report included a content analysis of a subset of questions from the 1979 Management Review Board Survey.
Additional analysis has now been performed of both the substance and the pattern of responses on an expanded set of questions from that survey.
This analysis was comple ted by the same expert in survey methodology who previously analyzed the 1983 QA/QC Questionnaire Survey, and the results ar~e summarized below.
The complete analysis is attached to this report as Appendix A.
3.2.1 1923 Management Beview agard gyrvey To provide a more complete picture of findings from the 1979 survey, a more exte nded anal ysis o f the data was undertaken.
In addition to the five survey questions to which responses were analyzed in the earlier report, 21 additional questions were included representing all questions which seemed likely to contain information at all relevant to the issue of intimidation.
Appendix A, paget A-17 through A-23, contains a complete listing of these questions.
All 120 respondents were included.
Their responses were content analyzed into code categories developed from initial inspection of a sample of questionnaires.
As in the case of the 1983 questionnaire data, the responses were then analyzed to determine whether either their pattern or substance reflected possible Page 20
intimidation.
Concerning the gattern of response, the principal findings were:
The non-response rate was quite low; on the average, 92 percent of the respondents gave usable responses to any particular question.
The overall paLtern was positive; 78 percent of the responses were positive (favorable).
Although the average favorability was quite high, there was not an absence of negr t ive opinion.
a Approximately one response in four was negative.
The most negative responses were to the most threatening items, not the reverse (which one might expect from a pattern of intimidation).
The conclusion, therefore, is that the pattern of response did not suggest any noticeable amount of intimidation.
The substance of response was another matter, however.
Since the 1979 survey, unlike that in 1983, was not focused upon the issue of intimidation, one would expect that most of the responses would refer to lasues other than that.
Indeed, such was the case.
In general, on those items to which the average response was least positive, the concerns were primarily those of money, lack of formal preparation, or "other* Ca mixture of miscellaneous Page 21
concerns or complaints).
Perhaps an exception to this general pattern occurs for Question 2A ("How would you rate management support of QC?"): 28 percent responded marginal or [qadequate.
Information which perhaps explains or anplifies these responses on Question 2A came from an analysis of all written comment conceivably relating to intimidation.
There were 38 relevant comments of this type, given by 32 persons.
An ana! = sis of these specific comments indicated that the acts of intimidation came almost exclusively from craft / construction, not from QA/QC management or supervision.
For a minority of these 32 persons there was also the perception that QA/QC management had too often acquiesced to craft / construction, rather than backed QC.
3.2.2 A Comgarison of 1979 and 1283 gutver Eesults Consideration of both the 1979 and 1983 survey results jointly presents some interesting and perhaps useful similarities and contrasts.
In neither year did the gattern of response reflect any indication of widespread feelings of intimidation.
Indications of intimidation occurred with any frequency only for the substance of response, and only for the 1979 survey.
That this was true despite the fact that that survey involved face-to-face interviews, rather than anonymous questionnaires, and was i
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generally focused upon issues other than intimidation, seems significant. Had there been pervasive intimidation throughout this five year period, it seems likely that it would have been more in evidence in 1983 than in 1979, simply because the 1983 format made it easier and safer to respond.
This was not the case, however.
Instead, what appears to be the more straightforward explanation is that there was, in fact, intimidation in 1979, that it was felt to various degrees by at least a minority of persons, and that it came almost exclusively from craft / construction.
For a minority of that minority there was a perception that management too often acquiesced to craft / construction.
This explanation would suggest, however, that by 1983 the problems had all but disappeared.
The reason for this change can only be a matter of speculation.
Perhaps programs and actions by management to correct and prevent such instances had the necessary e f fect.
Perhaps there was a shift in the nature of persons doing craft / construction work over the period, e.g.
from rough-and-tumble concrete workers to more skilled crafts such as electricians.
Previously, in Section 3.1.2, the poss ibil i ty was raised that even though few reported instances of intimidating events were found, a climate or intimidation Page 23
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still might have been present.
It could be argued that even a few cases of intimidation widely known throughout the organization might be sufficient to create a climate in which people felt intimidated.
If such were the case then one would expect to find pattern responses indicating feelings of intimidation on the part of the survey respondents and, particularly in the 1983 survey, knowledge on the part of a significant number of respondents of intimidating incidents involving either themselves or others.
Such was hot the case, however.
A minority of the 1979 survey respondents indicated knowledge of intimidating events, and by 1983, even with a survey format under which it was easier to address intimidation issues, such statewants had all but disappeared.
Perhaps more i
significantly, neither survey revealed pattern responses among participants that would indicate they felt intimidated.
What these two sets of survey data taken together do say is that there was no indication of a pervasive climate of intimidation on the part of, or fostered by, management or supervision.
At most, there is a perception (by less than 10 percent of respondents) that management often did not take action on intimidation by craft / construction strongly enough, soon enough.
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3.3 OI Investigation and Inquiry Reports In addition to the three NRC Office of Investigation reports discussed in the initial report, seven investigation reports and seventeen inquiry reports have since been reviewed.
Most of the events triggering these investigations and inquiries were touched on, and in some cases covered in depth, in the depositions, prefiled testimony and hearing records.
Some useful information related to the issue of intimidation was gleaned from these reports.
3.3.1 Inguity Regotts Seventeen inquiry reports were examined by the study team.
Of these, 15 reports were not particularly useful in evaluating the climate.
Of the remaining two reports, one described an instance where the climate was not intimidating, and one described an instance where it was.
The 15 inquiry reports that were not particularly useful and their subject matter were as follows:
Q4-82-0005 Alleged Improper Weld Practices Q4-82-0011 Alleged Improper Termination of a QC Inspector Q4-82-025 Alleged Radiographic Irregularities Q4-83-009 Alleged Inadequacies in As-Built QC Page 25
Inspection Program Q4-83-011
$11eged Poor Construction Practices Q4-83-022 Alleged Improper Implementation of Technical Procedures Q4-83-023 Alleged Poor Management Practices Q4-83-025 Alleged QA Supervisor Discouraging the Use of Nonconformance Reports Q4-83-026 Alleged Deficiencies in Coatings Program Q4-84-007 Alleged Violations of Construction Practices Q4-84-011 Alleged Intimidation of a BOP Inspector Q4-84-014 Preserved Testimony of a Witness Q4-84-016 Alleged Improper Constrcction Practices Q4-84-037 Alleged Threat of " Blackballing" a Former QC Inspector Q4-84-046 Suspected Harassment of a QC Inspector The two inquiry reports which appear to present some information that is useful in evaluating whether a climate of intimidation may have existed at CPSES are discussed below.
Q4:81:Q21
&Lliggd 1011514g112g 21 Elicitical C git t
Ettsennel A former Electrician's Helper contacted the NRC with several concerns regarding practices in the CPSES Electrical Department.
His primary concern related to the lack of training provided to Electrical Department Page 26 m w
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personnel for the fabrication and installation of electrical conduit hangers.
These personnel are alleged to be required to read a 400 to 500 page technical manual, S-0910, the fi rst day on the job and sign a form stating they have read and understand Manual S-0910.
A forty-hour training course is given on the manual.
However, since it is voluntary, unpaid, and off-duty, the alleger estimated that less than three percent attend the course and that most electrical personnel have inadequate working knowledge of S-0910.
The alleged intimidating aspects of this training problem are that the TUGCO Work Sampling Group lists referring to S-0910 as idle time, so electrical supervisors tell the electricians they should not get caught reading the manual, thereby discouraging its use.
Another concern was poor morale of electrical craft workers resulting from threats of firing and harassment by the Electrical Department superintendent.
As a result of this, it was alleged that some electrical personnel had commented that they might commit acts of electrical equipment i
sabotage.
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These allegations, although not specific to QA/QC, indicate a climate of intimidation may have existed in the electrical construction department.
The inquiry did not delve into the specific allegations sufficiently to confirm or deny their veracity.
However the alleger sounded credible.
Even though the facts did not support a conclusion of intimidation, the allegations point to poor supervisory skills and management practices in training, work sampling, and personnel relations.
Gi;8 d;991.
Elliggd lmetaget Eggsttggliga Etaggists Several specific allegations were contained in this report.
In two instances, one involving disassembling pump couplings without authorization and the other involving work on an air accumulator without the proper paperwork, a QC incpector caught the violations and stopped the work until the proper paperwor"k was obtained.
These incidents are examples of QC inspectors acting independently, with appropriate authority, and without being intimidated.
Two other incidents alleged that workers were threatened with dismissal if they did not meet production demands and were told they were not to i
come back to work the next day if they did nct finish a specific job.
In neither instance did anyone lose Page 28
o his job.
In the final incident the alleger refused to sign off maintenance cards inappropriately despite being instructed to do so by his superior.
No threat was involved in this situation, and no adverse action was taken against the employee.
These three events tend to indicate a somewhat autocratic and insensitive management style, but do-not support a climate of intimidation.
3.3.2 lgvestigatlog Reportg The NRC investigation reports generally went into considerably more depth than did the inquiry reports.
These reports are discussed briefly below together with the conclusions drawn in each.
A:Es:911 bil2Sgd Elggtrical Qgfigigggigg A former Electrical Department worker identified four areas of alleged deficiencies, which had purportedly occurred in the 1980 time frame:
Use of a 750 MCM lug that was drilled to accept a 1000 MCM cable in the circulating water system motor control center.
Use of the wrong size lug on a terminal block in the Auxiliary Building of Reactor No.
1.
Use of the wrong size lugs on terminal blocks in the Switch Gear Room of Reactor No.
1.
Page 29
Improper cable splicing and wiring to the wrong side of lugs in the annunciator logic panels of the Reactor No. 1 Control Room.
The NRC Senior Resident Inspector personally inspected each of the above areas in August 1982 and found no improper wiring in any of them.
No implications for the issue of intimidation were apparent in this report.
d;81;ggi
&llgggd ImECEEtt EEGstrgg11gg Etaggigts A former CPSES supervisor provided allegations of improper practices and procedural violations in several areas of mechanical and civil construction, including unauthorized cutting of rebar, main steam line overtensioning, use of a cutting torch on hanger material, and failure to purge stainless steel piping during welding.
Ten individuals alleged to have knowledge of improper rebar cutting provided sworn statements to the effect that all rebar cuts were made with proper authorization.
Four witnesses testified that the relocation of the main steam line was done under the direction of engineers to remove stress on the line.
Page 30
Six witnesses testified to having no knowledge of improper use of cutting torches on hangers.
Two witnesses testified to the scrapping of a hanger due to procedural violation, with replacement by new material.
In addition, a former employee, who came forth in January 1984 after reading of these allegations in the newspaper, refuted several of the allegations as
. reported in the Inquiry Report Q4-84-007.
The weight of evidence appeared to disprove the allegations and did not support the existence of a climate of intimidation.
4-83-00g Alleged Falsificatlon of QC Records A QC inspector alleged that a signature had been forged on an NCR that had previously been an i
issue before the ASLB.
The former QC inspector who had identified the nonconforming condition was interviewed as was the former Quality Assurance supervisor.
There was testimony that the NCR had been handled appropriately and the investigation disclosed no evidence of forged I
i signatures.
l l
l Page 31 l
There was insufficient evidence in this report to indicate intimidation or a climate of intimidation.
4-83-011 guspected Falsification of QC Records A QC inspector alleged that records of some of his inspections had been altered or falsified.
He suspected this had been done by reviewing supervisors.
Of three other inspectors interviewed, two indicated that this particular inspector was deficient' in completing his reports and one stated that he had heard rumors that other inspection personnel regularly helped this inspector by completing his paperwork.
This paperwork situation was confirmed by a document clerk, while two clerks testified they did not know of any falsifications of inspector checklists.
QA/QC supervision and management denied knowledge of alteration or falsification of coatings records.
Upon re-interviewing, the investigator found that the alleger had been unaware that earlier inspection practices permitted the copying of records.
The alleger knew that making copies was now a violation of procedures and he had assumed that reviewing supervisors must have improperly made the copies he originally alleged had been changed.
Page 32
Much of the testimony developed in these interviews related to various other allegations that have been considered in other portions of this supplement and in the original study *.eam report.
As it relates specifically to the issue of intimidation. the data de not indicate intimidation nor support the possible existence of a climate of intimidation.
d;11 91E ElltEtd ElEEElGlEation against QC Inscectors The allegation was that a QC lead inspector was fired for complaining in a meeting about int!midation by a supervisor and about lack of support for QC inspectors, and that this termination had an intimidating effect on the QC coatings inspectors.
There is much testimony and many depositions that relate to this particular event with a clear difference of opinion between management and the alleger as to the reason for his ter m ina ti on.
It is apparent that there was some reason for the alleger's concerns about the supervisor, and it tu probable that the alleger had been disruptive to some extent in the QC meeting.
It is also quite clear that the reasons for termination were not communicated well to supervision or inspectors.
Consequently, the study Page 33 7-a.-- - -.
-~
e-
team concluded that the incident could have had an intimidating effect on the coatings inspectors by leaving them with the impression that complaining about lack of management support for inspectors could result in termination.
A:EA:299 hlltS2$ 191151421129 Sf og Egrsoggg1 This report covered several instances of intimidation alleged by a QC inspector.
The specific allegations were that the inspector was subjected to a series of eight meetings intended to intimidate and discourage her in the performance of her work follcwing her appearance before the ASLB.
It appears t ha.t. In fact, the company provided informaticn on naternity benefits six weeks bef ore her ASLB appearance as well as approximately six weeks after.
Many management actions alleged to be discrimination against her were in fact attempts to accommodate her special needs and produce a more agreeable work situation for her.
Soon after her ASLS appearance the alleger's work duties were changed from field to shop inspections.
An office was arranged near the fabrication shop., and special arrangements were made for parking and transportation to and from her work area.
Finally, at her request, she was allowed to terminate by an RGF rather than Page 34
take a leave cf absence, in order to be eligible for unemployment compensation.
The study team feels that CPSES management gave her more than normal consideration, perhaps because of the i
alleger's appearance before the ASLB.
These incidents do not support the existence of a c11eate of intimidation.
l
$1Ei: Ell
&lltSid LG1111dallEG Ri 3tidlG9 EEEEE Au tronworker alleged that an ironworker superintendent regularly threatened and intimidated his subordinates.
Interviews with fifteen individuals determined that seven either had personal knowledge or knew of this superintendent's reputation as an intimidator.
In a specific incident investigated, it was alleged that the superintendent forced the ironworker to chip concrete in a room in which safety system welding was being performed.
It is likely that this was a case of intimidation of the ironworker by the superintendent.
With regard to intimidation of QA/QC personnel, a QC inspector, when advised of the problem, shut the welding job down until the chipping was stopped and the dust settled.
This shutdown occurred despite its i
Page 35
going against the orders of a superintendent known to many as an intimidator. This incident, while showing intimidation of a craftsman, also is another example of a QC inspector acting independently within the authority of his role and without being intimidated by the crafts.
3.3.3 Cgqqlusiqqs Eggm [qvestigatlog and Inquirv Reggtti Analysis of 24 NRC Reports of Inquiry and Investigation resulted in four incidents that provide some indication of intimidation in both Craft and QA/QC at CPSES.
One of these incidents (4-83-016) involved the termination of a lead QC inspector, and one (4-84-008) consisted of a series of events involving one QC inspector.
These two events are included in Table 3 as the Dunham-Termination and the D. Stiner-Circuit Breaker Article incidents.
The third report (4-84-012) dealt with a possible climate of intimidation in a crdft department; it was also an example of a QC inspector acting independently and utilizing the authority of his role.
A fourth report (Q4-83-021) dealt with Craft intimidation by Craft sucervision, but provided too little information to confirm or deny whether intimidation actually existed.
In the total of 27 inquiries and investigations, including the three utilized in the original report, a preponderance of allegations of intimidation were Page 36
unsupported.
In the extensive investigations and interviews a large number, approximately 202, of present and past employees refuted the charges of the allegers, and approximately 48 supported the allegations.
Of the 48, nearly half were craft, supporting the claims of intimidation of craft on the part of craft supervision.
Hence, approximately 26 individuals, among a total of about 250 persons, supported claims of intialdation of QA/QC P
personnel.
Fourteen of the 26 were related to two specific incidents, the Dunham-Nitpicking and Dunhan-Termination incidents.
Seven other claims were unsubstantiated by persons other than the alleger, leaving five other substantiated claims.
Based on this analysis of OI reports there did not i
appear to be widespread allegations, numerous incidents, a pervasive atmosphere of fear, or other evidences of a climate of intimidation at CPSES.
The analysis of these additional NRC Office of Investigation Reports of Inquiry and Investigation resulted in no findings that modify the j
conclusions of the study team in their original report.
Page 37
't 6
J T
e
~
3.4 Observations On Managertal Practices The study team stated in its discussion of management style in the September report (Section 3.3, pages 37-40) that there are many factors which contribute 'to individual performance on the job.
Intimidation, or the existence of an " intimidating climate", is only one such factort
[
One problem that the study team f. aced in making its assessment 'was the fact that organizations are complex mechanisms of interacting systems, procedures, and behaviors.
This makes it illogical to azzume that any Dnp factor can be isolated in drawing cause-and-eff.ect conclusions.
In the study of organizational phenomena, often the best that can be done is to show that certain outcomes seem to be correlated with, that is to occor in conjunction with, the presence of certain other facters.
This correlative relationship does not prove the existeytce of any causal relationship, nor can the direction of any possible causation be inferred from mere correlation alone, Inspection of data from all the sources led 'he study t
team to conclude that factors contributing to the performance of QA/QC personnel at CPSES included: the ir j ob skills and competencies, the quality of their motivation, the levels of compensation and the perceived equity of the compensation system, the structure of the organization i
~
Page 38 i
s
Ipeluding the e f fect ive management of interfaces with other functions or departments, the establishment and companication of cicar s tandards for the ir parf ormance, and supbrvitory style.
It is the opinion of the study team that m a c a g e ni e h t issues such as these may have had an impact et the performance of work at CPSES.
I 2.4 1 Jak sgitis and Camps;mnglss The dcta Iqdicate that a number of inspectors may have felt laadequately prepared to perform their work.
The Inadequacy of training and the poor communication between inspectorn and management were clearly identified as areas cf concern in the 1979 servey.
In resporse to a question on ' problems at CPSES", technical training of inspectors bas the second most mentioned item.
In addition, in both the 1979 and 1935 surveys, there were some concerns exprested about the lack of feedback on jeb performance.
To the extent that inadcquace j ob tralr. ing end Infrequent feedback on perforaance are gharacteiisti: ef a job, they cat inhibit the development of job sx111s with a resulting imp 3ct on per formaace.
3.4.2 Cleat Per,fertagge Standard,s C*osely r; lated to lhe congerns in rolv ir.g j ob sk ills ar.d competencies are Jssues regarding peeformance standards.
In the surveys, depcsitions, ar.d 01 Prports I
there were concerns about the clarity of stands.rds, the Pace 39
usefulness of some procedures, the frequent changes to procedures, and the seeming lack of consistent appilcation of these procedures.
Procedures are obviously designed to accomplish certain results.
However, when coupled with consistent concerns about communication, there is the possibility that the procedures themselves, or their usefulness and purposes, may not have been fully understood.
There is some evidence in the depositions and in some of the alleged " intimidating incidents" identified, that procedures may have been applied rather mechanically, 1
or that inspectors were asked te perform operations without fully understanding what was expected and why certain procedures were to be performed in particular ways.
3.4.3 Comgensatlon and Wage [qtgulties The perception that there are inequities in the administration of wage and salary programs and the general dissatisfaction with compensation could have a demotivating effect on individuals and on the subsequent performance of i
their jobs.
This issue was the most mentioned item on the l
1979 survey.
Complaints about wages were also dominant in the 1983 survey.
As an example, one complaint was that inspectors working for different employers on the site received different wages.
3.4.4 Interface Mana,qemtnt There should be 'little doubt that there are multiple, Page 40
complex, and difficult interfaces which must be effectively managed in the CPSES environment.
There does seem to be some concern that these interfaces are a continual source of conflict and problems.
It also appears that tnese resulting difficulties are accepted as given in the situation, as a reality to be lived with rather than effectively managed.
The entire body of the data reviewed point to difficulties in the QC-Craft Interface.
Complaints about lack of cooperation, the inability of management to deal adequately with these difficulties, the perceived lack of QC management support of inspectors, the problems with
" personalities", and the impression that the Craft personnel don't " understand the role of QC", all lead to the conclusion that the interface management processes do not seem to be very effective.
The interface between Craft and QC is viewed as an adversarial one.
Intimidation internal to the Craft organization may have exacerbated the
~he nature of the working relationship situation.
While t
must include checks and reviews by QC of work performed by Craft, little attention is devoted to improving or managing the interface to foster a more cooperative working relationship.
Managing these interfaces requires special skill and sensitivity, an ability to see the whole and to understand the various nuances of personal and technical f
issues that arise, t
Page 41 L
Another factor influencing the interface between Craft and QA/QC is the role and working telationships of the NRC which create some ambigu:*y.n managing interfaces among the re'evant parties.
ifv i t e t he.re is very little information specific to this ss.bject, there are some comments in the depositions and s t'rveys that indicate the NRC is a primary player and daes influence the overall working relationship between Craft and QC.
As an example, responses to the 1979 survey seem to indicate that management was not clear concerning what issues or when it was legitimate for employees to communicate to the NRC, or whether they would, in fact, encourage such communication.
Evidence irca the transcribed material and from the surveys leads to the conclusion that CPSES is not without significant interface management problems in the QA/QC area, and that these problems are worthy of attention.
3.4.5 ju2erytsory gtyle Another factor affecting performance is supervisory style.
There was some discussion of its importance in the September report.
One of the factors discussed briefly was that of management philosophy and the manner in which the prevailing philosophy might influence organizational behavior.
The style of supervision at CPSES is related to issues identified above in this section of the report.
Page 42
i i
3,.
1 The supervisory methods utilized at CPSES reflect an operating philosophy commonly found in construction and utility organizations.
These organizations are often impersonal, viewing good human relations as unnecessary, and in fact maintaining that such practices simply impede the rapid accomplishment of tasks.
Loyalty and compliance a:.ae cons idered important requirements for effective functioning, and unquestioned loyalty and compilance are therefore often d'emanded by such organizations.
- However, because of the impersonality and lack of management attention to the human dimension, these organizations often generate mistrust, suspicion, and lack of credibility of manag'e me nt.
Accounts of management actions found in the a:
depositional data support a conclusion that this description is fairly characteristic of management at CPSES.
The study team classified a number of events as intimidating not because of management's intent to threaten people er cause them to act inappropriately, but because of the manner in which they handled a situation or communicated with those involved (e.g. the Dunham -
J Termination incident, the T-Shirt Incident, and the D.
Stiner Circuit Breaker Article incident).
s.
l The degree to which this style of supervision affects the work performance of any individual at CPSES is difficult to assess.
This style can negatively influence Page 43 E.-
s e
morale and motivation, and these factors may affect job outcomes.
In summary, there were a number of managerial practices which, while not intimidating, may not have been conducive to good job performance.
The job skills of inspectors may have been negatively impacted by poor communication with their supervisors, inadequacy in their job training, and infrequent feedback on performance.
There was some evidehce that inspectors were asked to perform tasks without adequately understanding what was expected or why the work was performed.
Difficulties in dealing with crafts were apparently accepted rather than managed, with little attention devoted to fostering more cooperative working relationships.
A lack of clarity was seen regarding appropriate employee interfaces with the NRC.
The general lack of supervisory attention to the human dimension may have generated mistrust, suspicion, and some lack of credibility with employees.
4.
SUMMARY
AND CONCLUSIONS Information reviewed by the EG&G study team after the issuance of their September 1984 report, Comanche Peak Steam Electric Station: Alleged Climate of Intimidation, Page 44
formed the data base for this supplemental report.
These data included depositions, prefiled testimony, hearing transcripts, NRC Office of Investigation reports, survey data, and other information.
The data base continued to be limited, primarily re flecting information from allegers, managers, and related individuals focusing on specific incidents of intimidation.
A summary of the findings and conclusions follows.
The number of all-eged incidents of intimidation,
'allegers, and named intimidators was very small.
Approximately 31 incidents reported by 13 individuals occurred between 1979 and 1984.
A substantial majority were concentrated between 1982 and 1984.
Four individuals accounted for 21 of the 31 allegations made.
Of the 31 alleged incidents, only nine were judged by the study team to meet the criteria for intimidation.
This seems well within the number of events that would be expected to occur even under the best of circumstances.
This small number of Incidents, while not eliminating the possibility that a climate of intimidation could have existed, falls short of positively establishing that such a climate did exist at CPSES.
Analysis of the 1979 survey, when coupled with that done on the 1983 survey, showed no indication of a pervasive climate of intimidation.
Neither the pattern nor Page 45
content analyses of the survey data indicated widespread knowledge of intimidation.
At most there was a perception by less than 10 per cent of the respondents to the 1979 survey that management did not take action on intimidation by craft / construction strongly enough, soon enough.
NRC Office of Investigation reports indicated 26 people supporting claims of intimidation of QA/QC personnel and 202 individuals refuting such claims.
Analysis of these reports did reveal some isolated cases of intimidation, but resulted in no findings that would modify the conclucions of the study team in their original report.
If a climate of intimidation had existed at CPSES one would expect to find knowledge on the part of a significant proportion of employees of intimidating incidents involving either themselves or others.
Furthermore, one would expect those making allegations to relate multiple valid examples of such incidents.
Analysis of the transcribed material, surveys, and OI reports demonstrated that such was not the case, and thus failed to support a conclusion that a climate of intimidation existed at CPSES.
Some management practices at CPSES, while not constituting intimidation, were of concern to the study team because they are generally not conducive to good job performance.
Poor communications, inadequacy of training l
l Page 46
'i and infrequent feedback on performance were found.
Inadequate attention devoted to cooperation between QA/QC and Craft and a lack of clarity regarding appropriate employee interfaces with the NRC were observed.
This general lack of attention to the human dimension may have created mistrust and suspicion of management by some employees and reduced management credibility.
Overall, a good deal of compatibility was found in what the data from different sources indicated.
Analysis of data from the transcribed material, analysis of both the content and pattern of responses from the 1979 and 1983 surveys, analysis of the NRC Office of Investigation Eeports of Investigation and Inquiry, and the analysis of the individual incidents alleged to have been intimidating all lead essentially to the same conclusion.
These findings taken together lead the study team to reaffirm the conclusions reached in their September report.
In the judgment of the study team the data reviewed do not l
Indicate that a climate of intimidation did, or does, exist i
l at CPSES.
i l
f a
Page 47
APPENDIX B SUMMARIES OF ALLEGED INCIDENTS OF INTIMIDATION EIGHTH DRAFT EIGHTH DRAFT EIGHTH DRAFT Page B-1
SUMMARIESOFALLEGEDINCIDbNTSOFINTIMIDATION This appendix to the Supplementary Report contains a brief summary and analysis of each of 31 incidents alleged to involve some aspect of intimidation.
The table below provides a list of the incidents, the individuals making the allegations, and the year in which each incident occurred.
Those incidents identified with an asterisk (*)
are those the study' team judged to actually be intimidation.
TABLE B1 ALLEGED INCIDENTS OF INTIMIDATION Xiat 6LleSit
[qcid gt i
1979 Messerley Foreman Intimidating QC Inspector (no alleged incidents) 1980 1981 H. Stiner Termination
- 0.
Stiner Circuit Breaker Article D. Stiner Office Relocation D. Stiner Meetings Related to Pregnancy D. Stiner Harassing Letter D. Stiner Weld Symbols Miles North Valve Room Page,B-2
1983
- Dunham Intimidation of Coatings Inspectors
- Dunham Termination
- Neumeyer Liner Plate Traveler Allen Joe Interview
- Allen Detergent On Painted Surface
- Allen Cigarette Filters Barnes Valve Disk Incident
^
Witness
'F" Building Manager Threat Over SWA Witness
- F" ES-100/RG-1.75 Conflict 1984 Witness "F"
Threat to " Pull Your Chain" Witness "F"
Ferro-Resonant Transformers Witness "F"
Problems / Quantity of Work Comment Neumeyer Stanford Incident Gregory Pressure On N-5 Reviewers Gregory QES Review Sheet Gregory Reduction of Force (ROF)
T-Shirt Incident Hamilton,Krolak,Shelton Refusal to Inspect Coating Summaries of each of these incidents are presented in the remaining pages of this appendix.
Page B-3
1979 - Eu desseriez - Eotegan [qtimidatino QC insgector Mr. Messerley claimed that a QC inspector was verbally and physically intimidated by a much larger general foreman for red tagging too many cable tray supports.
This purported incident had occurred five years before it was brought out by Messerley and had not been mentioned in testimony or statements by him on three prior occasions in sworn-testimony or depositions.
There was no testimony supporting the contention, despite the claim that the a
altercation was very loud, lasted for 10 or 15 minutes and was witnessed by a crowd.
In addition, several other Messerley allegations related to improper workmanship and handling of hardware were contradicted by a number of individuals who had worked for Messerley at the time of the alleged incidents (See discussion of Investigation Report 4-83-005 in Section 3.3.2 of the Supplementary Report).
In the opinion of the stucly team, Mr. Messerley's allegation regarding the red tagging intimidation incident was not proven.
i l
1981 - um Sttgen - Ietainatian Mr. Stiner alleged that he was fired for reporting a gouge in a pipe to a QC inspector, Ms. Neumeyer.
The weight of evidence, including the ASLB Memorandum on welding issues of December 18, 1984, appears to support the appilcant's assertion that Stiner was terminated for absenteeism.
The Page B-4
study team does not believe this incident met the criteria for intimidation.
1981 - Q Etiget - Weave Welding og Pige guggott Ms. Stiner testified that she observed weave welding being performed on a hanger in violation of welding procedures.
She claims to have told her supervisor, Mr. Williams, about the event and stated that he supported her in writing an NCR.
Stiner also claimed that later Williams discussed the
~
matter with craft and directed her to sign off on the weld
~
with a threat of firing her if she didn't.
No NCR was found, but the finding of an IR signed by Stiner indicating she had inspected and accepted some weave welding on a hanger provides some support to her allegation.
No specific instances of weave. welding violations were substantiated.
However, Ms. Stiner could have felt a lack of management support or even threat in this alleged incident.
The study team has, therefore, classified this as a possibly intimidating event in that the threats and
~
1ack of management support, if they in fact occurred, were reasonably likely to have influenced Ms. Stiner to refrain from performing work in accordance with requirements.
1981 -Q
@ginet - Oltsel Ettetatot Ekids Ms. Stiner, a QC inspector, alleges she was harassed and intimidated by her supervisor when he assigned her to conduct inspections on welds on the diesel generator skids, Page B-5
a even after she protested that she was unqualified to conduct these inspections.
The preponderance of evidence seems to indicate that she was asked to help another inspector on the diesel generator inspections.
She had trouble reading drawings and may have felt uncomfortable with the assignment.
When it became apparent to supervision that she was not doing the job, she was reassigned.
This is not considered to be an incident of intimidation.
1981 - 92 @ tiger - Polar Crage NCR Ms. Stiner alleged that an NCR she wrote regarding a hole in the polar crane rail was improperly voided and the hold tag on the instrument panel was improperly removed.
No evidence of a hole or repaired hole was found.
A Stiner NCR for about the right time period on the polar crane bus bor was found.
This NCR was volded appropriately because the bus box was non-Q and outside the scope of the QA I
program.
The study team does not consider this to be an incident of intimidation.
l t
l l
1982 - Du Etinen - Ci tcult B eaket A ticle t
t l
Ms. Stiner testified at a public ASLB hearing in 1982.
l l
Although her testimony had received wide publication in the l
local press, the applicant focused unfavorable attention on Stiner through an article in the site newsletter, the
" Circuit Breaker".
As a result of this article, Stiner l
Page B-6 L
claims she was refused a ride to the plant on a private bus that she rode occasionally, that she was ridiculed by people on the bus, and that she was threatened with being beaten up by two women employees at CPSES.
There was no supporting evidence for the bus incident.
In fact, all the available testimony from witnesses to the event refuted Stiner's testimony.
There was also no support for the alleged threats by the two fellow employees.
Despite these specific refutations of specific claims, there is a broader aspect of this event that is pertinent to a climate of intimidation.
Although the hearing testimony was given wide play in local newspapers, the fact that management called additional attention to her position in the Circuit Breaker article may have exacerbated the adverse reaction of her peers and resulted in threats against her, even though such threats were not confirmed.
Highlighting the fact that an employee testified against the company could deter other employees from coming forward in a public way to identify safety problems.
The study team concludes that this event meets the criteria for an event of intimidation both to Ms. Stiner and to other employees who could get the message that the company focused unfavorable attention on employees who testified against it.
Page D-7 r.
-,-m.
1982 - 92 Stlner - Qffice Belocatjon t
Ms. Stiner claims she was harassed by being moved four times over a two-day period and finally being placed in a small, dirty shack with a broken air conditioner, right on the road.
It appears that in fact she was moved in one day to two temporary locations because her new office was not cleaned up and there was no air conditioner.
While awaiting correction of these de ficiencies Ms. Stiner was moved to a crowded' trailer for a couple of hours and then in with her supervisor for several hours.
Finally, she was moved to the office adjacent to the fab shop.
This eliminated the need for her to walk uphill between one half and one mile to her new work location from either the new offices of her group or her old office.
The evidence does not support the harassment accusation, and the study team finds this event did not meet the criteria for intimidation.
1982 - Q Stinet - Meetings Eelated to P egnancy t
Ms. Stiner alleged that she was subjected to a series of eight meetings intended to intimidate and discourage her in performance of her work following her appearance be fore the ASLB.
In fact, it appears that the company provided information on maternity benefits six weeks before her ASLB I
appearance and approximately six weeks after, for a total I
of only two meetings.
There is a lack of corroborating i
l Page B-8 i
evidence to support Ms. Stiner's contention.
As considered in more detail in Section 3.3.2 of this report in the discussion of Investigation Report 4-84-008, the study team does not view this event as intimidating.
1982 - D Stlnet - Hatassing Lettet u
Ms. Stiner alleged that a letter sent to Ms. Ellis of CASE accused her of stealing and lying, and threatened termination if caught.
In actuality, a telegram was sent to Ms. Ellis suggesting that she was improperly encouraging Ms. Stiner to copy and remove documents from on-site.
The study team, under its criteria, does not find this to be an intimidating event.
1982 - D gtiner - Weld gymbols 2
Ms. Stiner claims she was told by Mr. Brandt to improperly accept doors which had not been properly welded in accordance with weld symbols on design drawings.
The evidence fails to support the allegation and it is not clear that Ms. Stiner understood the drawings, which showed the type of welds required and indicated that the lifting lugs themselves were not nuclear safety related.
At worst there may have been a failure to communicate well with Ms.
Stiner as Brandt may have failed to provide adequate explanation before directing her to accept the work.
The study team concluded that this was not an incident of intimidation.
Page B-9
1982 - $2 Miles - North Valve Boom Mr. Miles alleged, in a deposition in July, 1984, that stainless steel welding was being done in the North Valve Room in early 1982 while are gouging was going on overhead.
A young QC inspector was purported to have left in a rush to stop the work, then returned and ignored the are gouging and the welding that was going on " contrary to procedures" for clean air.
Miles believed the inspector had been intimidated by someone.
There was no corroborating testimony.
Miles had provided the following: a deposition on July 2, 1982; testimony to the Board shortly thereafter; supplemental testimony a few days later; an interview with an NRC investigator a year later; an affadavit in the fall of 1983; and a handwritten statement dated January 22, 1984.
In none of these had the alleged incident been mentioned.
The study team concluded that the evidence was not sufficient to indicate this was an incident of intimidation.
1983 - W Dunham intimidation of igigegtors - Nitglghing u
As a result of a specific inspection by coatings inspectors in the skimmer pump room, Mr. Williams, the coatings QC supervisor, called two meetings of his inspectors to discuss uniformity of inspection criteria.
Williams admitted he threatened the inspectors with retraining or pulling their certifications if they were found repeatedly Page B-10
s making inspection errors.
Williams used the term
- nitpicking
- to describe some of the rejectable findings.
The study team believes that the statements could have been and, in fact, were interpreted by some QC inspectors as instructions not to inspect in accordance with procedures.
Williams later conceded that his statements could have been viewed as intimidating even though that was not his intent.
e I
The study team believes that his statements were reasonably likely to influence employees to refrain from performing their work in accordance with requirements, and thus this the criteria for being judged as an incident meets intimidating event.
1 4
j 1983 - W Dunham - Iermjnatjog 2
Mr. Dunham attended a meeting of QC inspectors and supervision, the purpose of which was to have two coatings experts explain proposed technical changes in coatings specifications and procedures.
During the course of the meeting, Dunham apparently spoke out'regarding intimidation of inspectors and lack of support from supervisors.
It is not clear to what extent the c or other Dunham comments were disruptive.
However, there is no evidence that any management action was taken during the meeting to respond to Dunham, to control his purported
" disruptiveness" or to keep the meeting to its express purpose, if Dunham was in fact being disruptive.
)
i Page B-li
Subsequent to the meeting a counseling session was arranged with Dunham to discuss his behavior in the meeting.
During this session Dunham's employment was terminated, either by his quitting or being fired--it is not clear which.
This termination was considered by most of the QC coatings inspectors that attended the meeting to result from Dunham's complaining about intimidation during the meeting.
Regardless of the facts regarding Dunham's conduct in the meeting or the cause of his termination during the counseling session', the study team finds that his termination was reasonably likely to influence other QC inspectors to refrain from reporting intimidation concerns, and thus meets the criteria to be classified as an intimidating event.
1983 - su as stuntzst - Linte ettig Iggygtte Mc. Neumeyer alleged she was instructed to sign off a number of weld hold points on some old liner plate travelers that she felt were inadequately documented.
According to her, she was threatened with loss of a weekend off if she failed to obey.
Ms. Neumeyer voiced to her supervisors and co-workers her concerns about the impropriety and signed off on some of the work under protest.
The actions of her supervisor, including the use of threats, were reasonably likely to influence her and other employees to perform work they believed was not in accordance with requirer.ents.
Thus the study term Page B-12
concludes that this incident meets the criteria for being intimidating.
1983 - Cs allen - Elvt 611eged ingidigts Mr. Allen was hired as a coatings inspector despite having significantly more education than was required for that position.
He has an undergraduate degree in chemistry and a master's degree in polymer chemistry.
1 -leb LaittritE Mr. Allen felt that during his job interview he was told that despite his expertise he was not to question QC procedures or engineering judgments.
The study team feels that this was an effort by management to make clear to Allen what his job function as an inspector would be and IE not viewed as an intimidating event.
1 - &(&E& and QGE Eggityg Mr. Allen raised questions about ALARA reviews and Design
~
Change Authorization (DCA) reviews to the training coordinator, who was unable to answer the questions and took him to Mr. Tolson's office for an explanation.
A day or so later, Mr. Brandt called him in to discuss the same matter.
The study team feels these repeated meetings with senior QC supervisors could have been intimidating.
3 - Srgft fgramag Page B-13 t
4 Mr. Allen alleged in a letter that he was ordered by a craft foreman to reinspect work in an area reachable on scaffolding.
In the same letter he listed problems he had within the space of a week with a general foreman and three other different foremen.
These purportedly included
" shouting matches" with the three.
Brandt's reaction to this complaint was to discuss the matter with construction management, Allen, and Allen's supervisor.
QA apparently was not intimidated by craft as Brandt formally responded to Allen's complaint as follows: "This type of harassment a
must cease.
Construction has assured us that they will implement corrective astion (as necessary) lamediately.
As we discussed verbally, if the situation does not improve, please notify me again."
The study team believes that Brandt's actions were appropriate and does not see this as an intimidating set of events.
3 - 9212I9eD1 90 231D12d ESI 3SS f
As a consequence of writing an NCR regarding use of detergents to wash down coated surfaces, Mr. Allen was sent to Brandt's office to defend his action.
This probably tended to make Allen refrain from writing NCR's of a technical nature in situations where he felt one should be written.
The study team finds this incident to meet their critorja for intimidation.
1 - Gisatttte gity,ett Page B-14
3
.Mr.' Allen-learned that'cigare te fliters were being used by-painters in the cheater valves of spray guns to assure i
passing the air acceptability test.
Mr.
Allen was s
dissuaded from writing an NCR because his m(nagement felt-i i
the use of cigarette filters was not a viciation of any i
procedural requirement.
Management also felt that. final
-inspections would pick up the prrsence of oil cr water in the paint.
The study team assesses this event as having-1 been intimidating because apparently the cigarette filters should not have been used and an NCR should have been i
written.
A reasonable person in Mr. Allen's situation in this incident would feel pressure to perform in a manner not in conformance with requirements.
2 i
1983 - 0 3arata - Egige Digt [geldggi 2
Ms. Gregory, a trainee, is purported to have brought a i
traveler to Ms. Barnes which had a disk nun.ber that did not match the disk number in tne Data Report.
It is alleged that Barnes' supervisor, Mr. Eennetzen, told her it didn't matter and would ccst too much noney to check.
- Finally, 1
Gregory was purportedly told she could sign the t
documentation off If she stated tc, but that Barnes wasn't going to.
Despite this statement, Barnes alleged that i
Gregory signed off the traveler.
Gregory did not provide t
corroboration cf this event.
The study team concluded that i
{
this incident was not substantiated as an instance of intimidation.
4 i
Page B-15
a 1983 & 1984 - Witnga.s;F2 - jeveral Allegatjons This witness provided a number of technical allegations as i
prefiled testimony shortly after he quit his job at CPSES.
The witness also stated that he had been subjected to harassment and intimidation by bringing his concerns to his 4
supervisors and others.
Witness "F" described five incidents which he believed were examples of intimidation-or threats against him, as follows:
1 - EElldlGC MiGEEtt Ihtigt Oggt SWA - 1983 Witneco F alleged that a TUGCO building manager told him,
'You're treading on thin ice," in response to Witness F's refusal to sign a startup work authorization (SWA) because of his belief that there was an inconsistency between ES-100 and Regulatory Guide 1.75 (RG-1.75).
The witness, after having agreed to sign the SWA during a meeting where the technical problems were resolved, then unreasonably refused to do it until he got a call from New York.
The position of management in the incident appears to have been correct and the ensuing altercation should not have discouraged the witness from performing his job properly.
.2
_ES-1992E9.:1_22 9snillst 1983 Witness F alleged that a startup manager tried to discourage Witness F from calling the NRC on the ES-100/
RG-1.75 conflict.
It appears that the technical resolution Page B-16
E d
of the witnes's's concerns was being pursued appropriately and that the problem was one of technical misunderstanding on the part of Witness F.
Because of this the study team feels that he was not intimidated by management from calling the NRC on this matter.
3 - IUCtat. Ig ;Egli lggt (bain" - 1984 4
Witness F alleged that a TUGCO plant electrical engiceer threatened that he would get a superior to " pull his chain."
More credence is given to the testlaony of Mr.
Vogelsang, the alleged threatener, that he was being bothered excessively by Witness F regarding a Part 21 report on the ferro-resonant transformer problem.
Vogelsang admits to having threatened to have Witness F reined in by his manager to get him out of Vogelsang's business.
The words he recalls using were " shorten your reins, pull in your reins."
Management does not appear to have discouraged Witness F from performing his proper job function, and thus this incident is not judged to have been 4
intimidating to Witness F.
d - Estrs-Esaggant Iransisraars - 1984 Witness F claimed that a startup supervisor harassed and threatened him in connection with the problem with the J
ferro-resonant transformers.
There is some evidence that the witness was using the ferro-resonant trans f o rme r situation and, specifically, filing of a 50.55(e) report to Page B-17
?
harass one of his supervisors, Mr. Luken, who was a Westinghouse employee.
Witness F also was believed to have accused Luken of trying to cover up a safety issue, a very serious charge.
On the basis of the testimony it is concluded that Luken was very angry and did indirectly threaten the witness.
However, the study team did not
[
conclude that the w.itness was intimidated.
i t'
4 5 - Problem Finding and Quantitr of Work Comment 1984 Witness F stated that the startup supervisor, Mr. Luken, told him that if he had enough time to find problems (such e
as the ferro-resonant transformer problem and the purported confilet between ES-100 and RG-1.75), then he had time to l
do more work.
This event apparently did happen.
- However, based on the history of these two matters, including the T
i.
continuing attention being directed toward them by Witness F,
the criticism appears to have been justifiable j
f l
management comment and not intimidating.
1 The witness also claims his former employer at CPSES has t
l continued to engage in harassment and intimidation against 7
him by blacklisting him with other companies.
Insufficient I
evidence exists to assess this allegation.
i t
As indicated in the five specific incidents, in the opinion of the study team the evidence failed to support the t
2 allegations of Witness F that he was intimidated.
Page B-18
1 e
t 1984 - $2A Neumeyer - Stanford Incident 2
Ms. Neumeyer wrote an NCR which she believed was required.
Management supported her in writing it and conducted the necessary investigation as a result of it.
Management fcund no problem and therefore voided the NCR in an appropriate fashion.
Neumeyer continued to be concerned because she felt the records used to void the NCR were re-created after the fact and were not valid.
Management's failure to communicate adequately with Neumeyer apparently le f t her feeling uncomfortable af ter the event.
The evidence indicates that management handled this situation in accordance with good practice and, according to the study team's criteria, the event should not be classified as intimidating.
1984 - M G egotr - P essute on N-5 Reviewets t
t Ms. Gregory alleged that undue pressure was applied to QA/QC document reviewers in that her supervisor, Mr.
~
Bennetzen, demanded 40 ISO's a week, threatened the use of job shoppers and commented on company loyalty in line with keeping one's job.
It does not appear to the study team that an allegation of intimidation was substantiated in this incident since:
Gregory was not a document reviewer and there was no substantiation that the reviewers felt excessively pressured.
Page B-19
6 The use pf job shoppers was sugges ted by t,igher manager.ent as additions to the N-3 re v iewers, and i
Bennetzen was try?ng te avoid bringing in shop,oers by increasing the group's output.
Bennetzen apparently did make some comments relates to company loyalty on a day that two pe ople quit without notice and tc job secorit/ related to a specific individual.
It is fSit that Gregory toet these comments out of context as a warning to I
her.
There is'no substantiation for her interpretation 1984 - du Qttgorg - QES Eerilew Sheet 3
Ms. Gregory alleged that her supervisor ordered a reviewer.
W.
Darby, to sign off a Quality Engineering Systems (QES) review sheet without doing the review.
This incide.;t resulted from the fact that a package to be vau'.ted had been returned from the Authorized Nuclear Inspec?.cr (ANI) with the cover sheet (QES review sheet) missing.
In view of the fact that the ANI's will not review the package without the QES review sheet attached, and an ANI had signed off, it was apparent to Darby that the cover sheet had been lost after ANI review.
He checked the pccRage to i
make sure the documents included were listed on the QES review sheet and sent it to the vault.
This was in accordance with procedures.
The study team finds sufficient evidence to conclude this was not an incident of Page B-20
O d
t Intimidation.
i 1954 - Ms quegorg Rgdy,ctigo,cf Eocce LEQEl Ms. Gregory alleged that there was something wrong with the way e mployees were select.ed for a ROF in that more qualified people were ROP'd while lecs qualified were r e ta i n.ed.
The appitcant responded that there is a comprehensive, nainly objective method f6r'RC7 selection that includes assessment of clearance capability, certifications, afid absenteelse, The study team did not feel that a dequate information was available to assess this allegation.
1984 - T-ghir; Jng,1,dspt
(
Apparently as a result of the Williams "n i tp i C< 1 ns
- e ve nt,
a number of electrical tasnectors stowed up on g(te un two days one week wearing T-shirts indicating they were g
nitpi9 ers because e. hey picked nits.
On the second k
occ3stan eight inspectors were s e q ue,s t e re d in an office and t
ultimately s nt home a f ter the ir desks were searched and some perscoal and cempany pe'opert,y seized.
Most of the eight insolved were subsequently tran.ferred or terminated.
This incident occurred (ocut the same time that allegations r
had been voices by craft af hastructive testing by electrical inspectors.
The inspe ters' T-shirte could have been read to convey a message that their job was t,
repcrt t
Page B-21
4 i'
k safe ty concerns described by Craf t or coatings foreman Williams as " nits".
Management's response was inappropriately severe to an occurrerice that possibly was intended as a joke.
That response, highly visible to other employees, was reasonably likely to dissuade employees from identifying or reporting some safety concerns or otherwise making waves.
The study team has concluded that this incident was one of intimidation.
1984 - Ug3115992fr31gy,Sbgl599 - Egfgsal tg 195gsg5 Sgatigg Three QC inspectors, Hamilton, Krolak, and Shelton, were termi.nated for re*!using to inspect coatings on the Reactor j
Building No. 2 rotating access platform rail.
There was scaffolding in position from which tne painters had worked, and a lifeline safety system was properly in place.
Apparently the three inspectors had not actually cijsbed up to look at tt:e rail or scaffolding.
Testimony from reveral Individuals who climbed to the rail indicated it was safe to perform the inspection and that the three inspectors had made no attempt to determine conditions of the rail or scaffolding.
After their iniClal refusal to perform the, inspection, the three inspectors were advised that supervision and the Safety Department had evaluated the area and found it safe.
The three were then offered the opportunity to reconsider their star.ce.
When they refused to reconsider, they were J
Page B-22
\\
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?
i.
terminated f or re f using to pcrf orm the ir ass Igned tasks.
The study team feels that management acted properly throughout this incident, and that this was not a case of intimidation.
~
I Page B-23
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20.0 22788 1
JUDGE BLOCH:
We are done.
2 MR. TREBY:
But my concern a'nd the reason I 3
raised the objection so the record is complete is that 4
there is a possibility at some point that people may ask 5
that this whole record be put into this -- this deposition 6
record be put into the evidentiary record.
7 JUDGE BLOCH:
Would you object to that?
E MR. TREBY:
I would think that this subject here 9
appears to me to be outside the intimidation matters.
10 JUDGE BLOCH:
I haven't rul'ed on that.
11 MR. ROISMAN:
Okay.
Because I think the only 12 arguable matter is whether it's outside the scope of the 13 deposition.
I think it's the heart of the intimidation 14 issues before the board.
- ((
15 vuuus mLOCH:
I hope the Staf f working jintimidationfw)illconsiderwhatMr.Mouserhassaidand 16 17 his f amiliarity with these questions.
h i
18 )
MR. WATKINS:
I'm confused about what that means.' )
19 What information?
fYrh 20 JUDGE BLOCH:
The last few pages of this AggJ 21 transcript.
22 MR. TREBY:
I understand what the Chairman is 23 asking is that we make sure that the _ technical review team 24 is aware of the information that's being developed in this 25 deposition.
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