ML20207D918
| ML20207D918 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/18/1985 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM) |
| Shared Package | |
| ML20205D361 | List: |
| References | |
| FOIA-85-799 NUDOCS 8607220221 | |
| Download: ML20207D918 (1) | |
Text
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- TECHNICAL TRAINING CENTER No #0*
oSBoRNE OFFICE CENTER, SUITE 200 CHATTANOOGA, TN 37411 00T 181995 MEMORANDUM FOR:
Comanche Peak Intimidation Panel FROM:
J. E. Gagliardo, Director, TTC, IE
SUBJECT:
BRIEFING 0F SENIOR MANAGEMENT Our briefing October of senior management is now scheduled for 2:00 pm on Monday,.
21, 1985 in Vince Noonan's office or Darrell Eisenhut's office.
Pleaselocation.
exact check with Vince's office (492-8446) Monday morning to determine the
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,k. E. Gagliardo, Director Technical Training Center Office of Inspection and Enforcement cc: R. Martin, RIV D. Eisenhut, NRR V. Noonan, NRR B. Griffin, RIV T. Ippolito, AE0D i
J. Scinto, OELD
- B. Kaplan, EG&G L. Chandler, ELD -
E S. Treby, ELD E. Jordan, IE l
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[ CHATT ANooGA, TN 37411 DCT 181985 MEMORANDUM FOR: Vincent S. Noonan, Project Director Comanche Peak Task Force FROM: James E. Gagliardo, Chairman Comanche Peak Intimidation Panel
SUBJECT:
REPORT OF COMANCHE PEAK INTIMIDATION PANEL The enclosed report documents the results of the review and evaluation of intimidation and harassment issues at the Comanche Peak Steam Electric Station (CPSES). This review was performed by the Comanche Peak Intimi-dation Panel (Panel) and by a Study Team composed of a group of consultants.
The Study Team performed an in-depth review and evaluation of alleged )
incidents of intimidation and harassment (Attachments 1& 2 of the l Report). Both the Study Team and the Panel concluded that some instances !
of intimidation did occur. These are described in the Study Team's report. However, the Study Team concluded, and the Panel concurs, that there was no " climate of intimidation" at CPSES. j In their reports, the Study Team addressed the management style and interface problems as reported in depositions and in the surveys. The Study Team noted that a number of management practices existed which may ;
not have been conducive to good job performance and which may have l generated mistrust and suspicion and contributed to a lack of management credibility.
The Panel shares the concern of the Study Team that certain management practices at CPSES could create a work environment in which the chemistry would exist for actual or perceived intimidation to occur, given the right set of circumstances. The Panel recognizes that the environment created by these management practices would not necessarily lead to intimidation or result in improper construction or quality control.
Indeed, neither the Study Team nor the TRT findings suggest that poor quality work resulted from the incidents of intimidation that did appar-ently occur. The Panel is aware that projects have been built effec-tively by entities with an autocratic management style. The Panel is also aware that recent changes in management personnel have been made at Comanche Peak that could result in changes in the management practices of concern.
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\ o Vincent S. Noonan Nonetheless, the Panel recommends that the licensee address itself to the questionable management practices identified by the Study Team to deter-mine whether additional changes are necessary to ensure that its manage-ment style is conducive to producing a quality product. We recommend that TUEC's management take an objective look at the incidents described in this report, as well as the current situation at the site, and take whatever steps are necessary to assure the estc.tslishment of a " quality first" attitude by its management and employees. The overall effort should be directed at establishing trust between the employees and management which will minimize fear of reprisals for identifying safety concerns or questioning safety procedures.
The Panel and the Study Team's review were based upon materials in the hearing record and OI reports completed by June 28, 1985. The Panel is aware that OI is investigating other allegations of intimidation and harassment and that the hearing on the Lipinsky issues is not completed.
Accordingly, the Panel and the Study Team may need to review additional materials that pertain to these issues to determine whether their overall conclusions need to be changed as a result of new information. The Panel requests that you notify them when the record is sufficiently complete to close out this issue. 9
/ ,L 'd U pames EL Gagliardo, Chairman Gomanch;. Peak Intimidation Panel
Enclosure:
As stated cc: R. Martin, RIV D. Eisenhut, NRR E. Jordan, IE J. Axelrad, IE J. Lieberman, ELD D. Hunter, RIV Panel Advisors (6)
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t OCTOBER 1985 J
REPORT OF THE REVIEW AND EVALUATION OF ALLEGATIONS OF INTIMIDATION AND HARASSMENT OF EMPLOYEES AT COMANCHE PEAK STEAM ELECTRIC STATION j UNITS 1 AND 2 by COMANCHE PEAK INTIMIDATION PANEL (NRC COMANCHE PEAK TASK FORCE)
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- 2. THE COMANCHE PEAK INTIMIDATION PANEL AND ITS ADVISORS AND CONSULTANTS Panel Members Gagliardo, J. -
Technical Training Center, IE, NRC (Chairman)
Axelrad, J. -
Enforcement Staff, IE, NRC Hunter, D. -
Reactor Safety Branch - RIV, NRC Lieberman, J. -
Regional Operations Enforcement Division, ELD, NRC Panel Advisors Chandler, L. -
Hearing Division, ELD Griffin, B. -
OI Field Office, RIV, 01, NRC Ippolito, T. -
Office for Analysis'and Evaluation of Operational Data, NRC Kaplan, B. -
EG&G Noonan, V. -
Comanche Peak Project, NRR, NRC Scinto, J. -
Hearing Division, ELD, NRC Treby, S. -
Hear ing Division, ELD, NRC The EG&G Study Team and Its Consultants:
Andognini, G. -
LRS Consultants (September 1984 Report Only)
Bowers, D -
Rensis Likert Associates Kaplan, B. -
EG&G Margulies, N. -
Graduate School of Management, University of California at Irvine Rice, C. -
LRS Consultants Stratton, W. , Idaho State University
9 O
September 1984
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i COMANCHE PEAK STEAM ELECTRIC STATION ALLEGED CLIMATE OP INTIMIDATION EGa6 Idaho, Inc.
A- . .. s IDAHO NATIONAL ENGINEERING LABORATORY
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s COMANCHE PEAK STEAX ELECTRIC STATION: ALLEGED CLIMATE OF INTIMIDATION Bruce L. Kaplan--Team Leader EG&G Idaho, Inc.
Newton Margulies University of California, Irvine Charles M. Rice LRS Consultants, Inc.
William E. Stratton Idaho State University Published September 1984 EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Responsible NRC Individual and Division T. A. Ippolito/ Division of Licensing Docket No. 50-445 Prepared for the U.S. Nuclear Regulatory Commission
, Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6819 i , op%An ss;7 2
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s CONTENTS ABSTRACT .............................................................. 11
- 1. IN'RODUCTION ..................................................... 1 1.1 Overall Task ............................................... 1 1.2 Team Assembly .............................................. 2
, 1.3 Problem Focus .............................................. 3 1.3.1 Specific Problem Focus ............................. 3 1.3.2- Definition of Terms ................................ 4 1.4 Precedures Followed ........................................ 6
- 2. DATA SOURCES ................................ .................... 8 2.1 Depositions ................................................ 8 2.2 Survey Data ............................ ................... 8 2.3 Reports and Correspondence ................................. 9'
- 3. ANALYSIS ......................................................... 10 3.1 Organizational Climate--Conceptual- Framework . . . . . . . . . . . . . . . 10 3.2 Analysis of Climate ........................................ 10 3.2.1 Analysis of Climate Using the Definition ........... 13 3.2.2 1979 QC Management Review Board Survey .. ......... 24 3.2.3 1983 QA/QC Questionnaire Survey ........,............ 30 3.2.4 Historical Climate ................................. 35 3.3 Management Style ........................................... 37
. . 3.3.1 The Concept of Management Style .................... 37 3.3.2 Management Style at CPSES .......................... 38 4.
SUMMARY
AND CONCLUSIONS ........... .............................. 41 111
w COMANCHE PEAK STEAM ELECTRIC STATION: ALLEGED CLIMATE OF INTIMIDATION
- 1. INTRODUCTION This introductory section presents the overall purpose of this study and the team assembled to conduct it. The specific problem focus, definitions of key terms, and the procedures followed are also described.
1.1 Overall Task The Nuclear Regulatory Commission (NRC) contracted with EG&G Idaho, Inc. to investigate and dev'elop an expert opinion as to whether or not a climate of intimidation was created by management at the Comanche Peak Steam Electric Station (CPSES). Many individuals involved in the Quality Assurance / Quality Control (QA/QC) area put forth allegations that management created a climate of intimidation during construction of the plant, inhibiting Quality Control (QC) inspectors in the performance of their duties according to written standards and regulations, to.the extent that the safety of the plant might be compromised.
In the context of issuing an operating license to this plant, the NRC has taken depositions from those individuals alleging irregularities and from the applicant utility. This was done in anticipation of a formal Atomic Safety Licensing Board (ASLB) hearing. These depositions as well as several NRC Office of Investigations reports, a Comanche Peak Special Review Team Report, internal reports and reviews conducted by the applicant utility (including surveys of QC inspectors), and other reports and data seen as potentially relevant to judging charges of management intimidation constitute this data reviewed by the Study Team. A comprehensive listing of these data is presented in Appendix A of this report.
The Study Team reviewed the available material in order to advise the NRC as to whether or not, in their expert and independent opinion, there appeared to be a climate of intimidation created by management among the QA/0C personnel at CPSES.
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As a part of their review, the study team chose to analyze responses from a 1983 survey regarding work climate at CPSES. The survey was conducted by the applicant utility among their QA/QC personnel. An additional outside expert was sought to render an independent analysis of these survey responses. Dr. David Bowers of the Institute for Social Research at the University of Michigan was selected to perform this analysis. He is a nationally recognized expert in surveying organizational climates and in analyzing survey questionnaires.
I Extensive resumes of all team members are included in Appendix B.
1.3 Problem Focus The basic issue with which this study was concerned was whether or not management created a climate of intimidation among QA/QC personnel at CPSES. In order to make such a judgement, a number of terms were defined and the charge to the study team elaborated.
1.3.1 Specific Problem Focus The central question the study team attempted to answer was: Did management by its actions create a climate of intimidation for the QA/QC personnel at CPSES such that they performed their duties in a manner resulting in some likelihood of adverse impact on the safety and quality of the plant. The intent was to establish if a pattern of int,imidation by management existed. Several clarifications are pertinent here.
1.3.1.1 Climate of Intimidation Versus Individual Intimidation. The intent was to establish if a pattern of intimidation existed. This is distinct from whether or not certain individuals were, in fact, intimidated
, at one time or another. The team was concerned with an overall climate of intimidation indicating a systemic problem.
1.3.1.2 Intimidation by Management Versus Other Sources. The concern was whether or not management actions, or possibly inaction, 3
r 1.3.2.2 Definition of Climate of Intimidation. The existence of a climate of intimidation could be evidenced by the following symptoms:
e Widespread allegations of intimidation indicated by a large number of cases, the inclusion of areas other than QA/QC, or allegations occurring over an extended period of time would point toward a climate of intimidation. This would involve many different individuals alleging intimidation and would identify many different intimidators.
e A pervasive atmosphere of fear on the part of the allegers related to testifying or deposing, to answering questions that might be traceable to the individual, or to naming specific individuals as intimidators would be indicative of a climate of intimidation.
e Failure of top management to take prompt and effective action to investigate allegations of intimidation and/or failure to take prompt measures to deal with the behavior of individuals demonstrated to be intimidators would constitute possible evidence of a climate of intimidation.
e Failure of management to protect the job security of individuals who allege intimidation while employed at CPSES would be indicative of a climate of intimidation. ,
e A general concern on the part of employ 9es that not complying with inappropriate demands of supervision may result in the use of negative sanctions against them would be indicative of a climate of intimidation.
All of these indicators do not have to be present for a climate of intimidation to exist. If several, or even a few, are present to a significant degree then such a climate may be present.
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records were not available to the study team. As a result, there were limitations in the nature and extent of available data. However, even within these limitaticns, the team was confident in making a judgement.
The remainder of this report presents the data utilized, the analysis performed, and the conclusions reached by the team.
O e
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r and the interviewers noting the answers of respondents on the questionnaire. These data were available to the study team; both the industry experts and the organization scientist made independent analyses.
A second survey of QA/QC personnel was conducted by the utility in 1983. This survey consisted of a questionnaire with nineteen items concerning aspects of the work environment. The questions required a "mostly yes" or "mostly no" response. The twentieth question which was open-ended, required a written response on any aspect of the QC job which the respondent felt should be changed or improved. The responses to this survey were sent to.an outside expert in survey methodology and questionnaire analysis for an opinion.
2.3 Reports and Correspondence In addition to the depositions and survey data the Study Team reviewed several NRC Office of Investigations reports, a Comanche Peak Special Review Team report produced by the NRC, several internal reports and reviews prepared by the utility, and a number of items of internal memoranda and correspondence from the applicant utility.
A comprehensive listing of the data reviewed is included in this report as Appendix A.
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o e What triggering behaviors have pre::1pitated that i. nit of ,
int,imidating behavfor? That 13, what co".diticht or situations initiate suc'n behavier?
e To what extent is intimidation 2 product of tha receiser's -
, perception? It is possible t1at variations ir, perceptions ar.d -
individual stylot wculd lead one person to interpret the specific ,
behavior quite differently frem another, e Wnat is the outcow of intimidating behavior? If a person feels ;
threatenad, but continues te perforn his or her function, i harassment may exist. fiowever, by defiti$ tion, intir.idation maj not have occurred. In the evert a climate of intimidation exists, a full range of responses from ignoring potentially
- intimidating actions to being intimidated can occur on the part ;
of different employees. '
Some understanding of how people interpret incidents should be explained. For example, Figure 1 demonstrates how behavior is likely to be interpreted differently by different people due to the uni 4ue perceptions e
of each individual. One kind of management behavior (Behavicr 1), cight or might not be interpre'ed as intimidating. The interpretation made is ;
largely a product of the intensity of the management behavior and the perception of the individual. On the other hand, another management .
behavior (Behavior 2), may be more explicit in that the man,ager or ,
supervisor uses threats, coercion, or negative sanctions as ways of inducing particular responses from employees. In this instance, it is much clearer that behavior of this sort is intimidating. The difficulty in making this determination should be noted. First, there is the general problem of perception (who said and heard what) and the difference of >
opinion concerning events and occurrences. Second, it is diff1 cult to '
ascertain whether negative sanctions were appropriate in specific instances, or if there were filegitimate abuses of power.
i The data available to make these assessments were limited, All ,
relevant documentation was not available at the time of the study, the 11
depositions often pursued paths of inquiry unrelated to the question of intimidation, and information that might have been more relevant to the ,,
investigation could not be accumulated due to the legal processes unde rway. The set of data available is largely from allegers and management. A survey of an accurate sample of individuals randomly selected would result in more representative data which would permit more definitive conclusions to be drawn.
In general, the team's approach to analysis focused on two major aspects of the data. First, available information was reviewed to identify those reported actions which might be construed as intimidation. An attempt was made to understand the circumstances under which this perception could exist and to determine whether the instances were isolated
) or part of a more general management climate problem at CPSES.
4 Second, an attempt was made to quantify the analysis to determine, for example, how many depositions or other documents specifically dealt with intimidation. Counts were made of the number of allegers and the number of accused intimidators. As an additional consideration, the management
{ response to complaints was considered to be very important, and specific actions taken in this regard were noted.
3.2.1 Analysis of Climate Using the Definition An examination of the work climate was performed utili, zing the various
] data sources described in Section 2 and the definition set forth in Section 1.3.2.2 which involved widespread allegations, a pervasive atmosphere.of fear, management failure to take prompt and effective investigative action, and failure to protect allegers. Each section in the following discussion is preceded by the related element of this definition.
3.2.1.1 Extent of Allegations of Intimidation.
I Widespread allegations of intimidation indicated by a large number of cases, the inclusion of areas other than QA/QC, or allegations occurring over an extended 13 4 ,
.-._- ,. , ,._._, , _ _ . - , _ _ , ,_m. - . _ - . . _ . . . _ , , . _ _ . . . _ , _ - . _ _ _ , _ __ _ _ _ . . _ , . _ . _ _ _ _ ._ _ _ . , . , , _ _ _ . _ . _ . _ _ , .
s .
9' An attempt was made to tabulate the data sources,used and the findings reached in order to address the problem of the extent to which a climate of ;
intimidation was present at CPSES. The team calculated at one point that 65 depositions, 4 investigative reports, and 3 special reports, including 2 QC surveys, had been reviewed. Of the 65 depositions, it was concluded that only 47 provided relevant data; this means 18% of the depositions provided information that was not germane to this investigation.
Table 1 summarizes the analysis of this information along several I
dimensions. Data were provided by 114 individuals; 96 provided information judged relevant. Of the 96 sources, 23 were management and 73 were non-management personnel. In general, the information provided by management and supervisory people. tended to be rebuttals and explanations regarding specific events and instances. Nine different organitational units were mentioned in the course of the discussion of allegations of intimidation.
x N :
It was not always possible to cQrrelate individuals from depositics to deposition and thus obtain a precise count of accused intimidators or of ^
claimed victims of intimidation. As can best be determined, the total -
number of allegers was 10 and the total number of those identified as intimidators was 12. Also, there was only a limited number of individuals, fewer than 10, who claimed in excess of one or two specific incidents of harassment or intimidation. Above the level of supervisor, there are only '
about five managerial individuals accused of intimida' ting or harassing actions. ,
In summary, there are a relatively small numoer of allegations of intimidation that appear to be reasonably well substantiated, a small '
number of allegers and a few management personnel that have been accused of '
intimidation. When considering the size of the work force, the total number of inspectors, the length of time the project has been underway, and the normal pressures to complete any job, the extent of QC inspector allegations of intimidation does not suggest that a climate'of intimidation exists or existed at CPSES.
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_ _ . _ _ _ _-m. _ _ . _ _ . _ _ - . _ _ . _ _ _ . . _ _ _ _ _ _ _ . - _ _ _ _ _ . _ _ _ _ . _ _ _ . _ _ _ _ _ _ . _ _ . _ _ _
3.2.1.2 Emotional State of Work Force.
A pervasive atmosphere of fear on the part of the allegers related to testifying or deposing, to answering questions that might be traceable to the individual, or to naming specific individuals as intimidators would be indicative of a climate of intimidation.
. A climate of intimidation on a work site would be reflected by a large percentage of the work force being afraid to jeopardize their jobs or other benefits because of personal association with charges of intimidation. As such, they would be afraid to depose on behalf of the intervenor, they would wish to retain their anonymity, they would be extremely cautious in their response to questions, and they might ce reluctant to name specific individuals as intimidators.
The NRC Report of Investigation dated August 24, 1983, appeared to support a climate of fear on-site. This was due to the deletion of many portions of individual interview records and indications by a number of those interviewed that confidentiality had been requested. However, it is noted that the identities and other details regarding even those not requesting confidentiality must be masked to protect those making such a request. Also, in the interview of the direct supervisor of the individual accused of intimidation, it became clear that the coating inspectors had previously brought the same accusations of intimidation to him personally.
Consequently, it appears that issues of confidentiality or fear of identification were not major factors in the environment. This conclusion is further supported by the investigation reports dated November 3, 1983, and March 7, 1984, in which requests for confidentiality were extremely limited (4 of 55 in the former, and 2 of 22 in the latter).
The 1983 QA/QC Questionnaire Survey results also support the willingness of people to respond. A very high percentage of the questionnaires were returned (93%) and the response rate was quite high 17
l Each of these elements cf management response to allegations of intimidation is examined below.
3.2.1.3.1 Promptness of Reaction to Allegations--Based on the various data reviewed, the team concluded that CPSES management has been relatively prompt in its response to allegations of intimidation. An example of this responsiveness was the establishment of an investigation committee, which produced the Keeley, Spangler, and Kahler report dated August 19, 1983, to investigate claimed intimidation of a QA auditor. In other instances, it was clear that QA supervision interacted in a timely manner with construction management in response to alleged intimidation of inspectors. Several terminations of craftspeople resulted from these actions.
The Texas Utilities Generating Company (TUGCO) initiated a Quality Assurance Management Review Board in 1979, which interviewed QC inspectors from a variety of areas in order that problems in the relationship between QC and supervisory personnel might be identified. The existing conflicts between production and QA/QC personnel were noted in the results of this effort. In addition, inspectors noted feelings about losing credibility, and difficulties in their relationship with QA supervisory personnel.
Interviews were extensive, documented, and indicated a strong interest and concern on the part of management to deter any intimidating behavior and to try to resolve such issues.
3.2.1.3.2 Independence of Investigators--The independence of investigators is demonstrated through the use of personnel from TUGC0 headquarters in Dallas to investigate allegations by QA auditors of QA management cover-up at the site. This particular investigation led to an accusation of intimidation. Both the cover-up and intimidation investigations were conducted expeditiously and resulted in a report dated August 19, 1983, which concluded that there was no evidence to support allegations of cover-up or intimidation.
An individual contract employee (not a TUGC0 employee) was hired in November 1983 to serve as an independent ombudsman for employees to utilize 19
in pursuing complaints and allegations in some detail, to try to understand the basis of those complaints, and to provide a basis for taking action.
In other documents, including minutes of a September 12, 1983 meeting between Mr. Clements and QA personnel, the management position identified above is reiterated.
3.2.1.3.4 Relationship Between Safety and Schedule--In a December 20, 1983 memo to all personnel, Michael Spence, President of TUGCO, explicitly notes quality and safety as the highest priority of the company. He also states that compromises in safety and quality will not
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and could not be tolerated by the company and, indeed, he notes the consequences for any employee not reporting any such conditions that affect safety and quality at CPSES.
There is also a corporate policy and attitude with respect to the relationship between building a top quality, safe plant and the monetary impact of delay that was expounded by Mr. L. F. Fikar in his deposition of July 11, 1984. Examples were given of cost and schedule tradeoffs that had been made to assure building a safe, quality plant. It was stated explicitly that the company would not jeopardize its 3.9 billion dollar investment for a delay of a day or two, a week, or even a month or two.
3.2.1.3.5 prompt and Appropriate Management Action--In cases involving claimed or demonstrated intimidation of QC inspectors by craft journeymen, prompt action, including cerminations, appears to have been taken on several occasions.
One case in which a craft person was accused of and admitted having grabbed the coat of an inspector and yanked her, should have been followed with immediate termination. However, the inspector is alleged to have persuaded management not to terminate the offender.
The NRC Office of Investigations report dated August 24, 1983, dealt with an alleged incident by a QC supervisor. The supervisor's manager had 21
deponents and those interviewed in April 1984, expressed the feeling that
, one's job was more secure after becomi'ng an alleger because of " whistle blowing" regulations. On the other hand there were deponents who believed they had been terminated because they had alleged intimidation, harassment or other potential quality problems.
3.2.1.5 General Fear of Misuse of Negative Sanctions. This final element in the definition of climate of intimidation deals with a general climate of misusing negative sanctions to force compliance with supervisory demands:
A general concern on the part of employees that not complying with inappropriate demands of supervision may result in the use of negative sanctions against them would be indicative of a climate of intimidation.
The best available evidence regarding this element of the climate is found in the survey data collected in 1979 and 1983.
The 1983 QA/QC Questionnaire Survey provided very little evidence of such behavior on the part of supervisors. The complaints expressed were generally of a moderate tone and focused on " normal" work issues and problems. Only three of 139 respondents made comments that would fall into the intinidation category.
The 1979 Management Review Board Survey provided data ,from an earlier time period that were subjected to a similar analysis. There were a number of complaints about supervisors and management (issues dealing with communication, the craft /QC interface, pay inequities, etc.), but very few, if any, related to negative sanctions being applied inappropriately.
, Analysis of the available data leads to the conclusion that there is no evidence of any widespread climate of fear on the part of employees that supervisors misuse negative sanctions to force inappropriate behavior.
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interviews was made following complaints about pay that had been received by management and an NRC report indicating they had been receiving allegations about low morale in the QA/QC organization.
The interviews were carefully structured to provide anonymity through the following:
e
~
An interview team that was outside the direct chain of command on site was used e All those interviewed were advised that the information provided
, would be confidential and their names would not be provided to anyone on site e An alpha numeric designator was used to identify each set of notes with nobody on site receiving a copy of the cross-reference key e Concerns manifested were to be presented to site management in a way that would not compromise any individual's confidentiality.
The review team was told to obtain all the information that was on the minds of the QC personnel without trying to analyze the information obtained.
As part of the study team's task, copies of the 1979 interview protocols were obtained. Two different approaches to analysis were undertaken and are described below.
3.2.2.1 1979 Survey--Content Analysis. The purpose of the survey appeared to be exploratory in nature inquiring into the feelings and perceptions of QC personnel about their jobs, quality of supervision, and the support of QC management. It was a general investigation into problems, experiences, or observations at the CPSES site.
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However, in an intimidating climate where a pervasive attitude of " cutting corners" exists, it would be expected that more discomfort with procedural violations would be indicated by the responses than was the case.
Analysis of Questions 2a and 2b--These questions ask specifically about perceived supervisory support and the quality of supervision. On the support question, the responses from 99 individuals who responded wers split almost half and half. There were 48 positive responses and 51 negative ones, indicating that about half of the respondents felt that supervisory support of QC inspectors was not what it could or should be. The qualitative inputs indicated that there was a relattenship problem between supervisors and inspectors. Inspectors felt that quality and judgment of supervisors was low, their ability to motivate and deal with personality problems was poor, and that they did not manage the interface with craft very effectively. Note the similarity of these responses to those fron the previous question analyzed.
Analysis of Questions Sa and Sb--These questions asked generally what problems existed in the QC organization, and what solutions were suggested. It was expected that responses to all these questions would overlap to some extent, and in fact, the responses correlated quite well.
Again, all items were listed, synthesized, and categoriz2d to simplify the data. Eleven categories emerged with the predominant problems being in the areas of pay inequities, communications, interface with craft, and technical training of inspectors. Once again the quality of management and supervision was a concern as reflected in high-frequency categories related to management capability. Low-frequency items were " fear factor",
" procedural difficulties," and " organizational structure."
It would be expected in a general question such as Question 5 that the opportunity to identify incidents and events reflecting an intimidating climate would occur. There was, in fact, very little information of this sort present, however. Two or three incidents were mentioned briefly, but there was clearly no prevasive reporting of such an attitude or intent.
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e The responses to each of the five questions from each of the 121 total interviews were reviewed and categorized according to the classifications outlined above.
e All questionnaires that had one or more answers to the five
, questions with either intimidating or potentially intimidating responses were evaluated for degree of possible intimidating climate.
Upon completion of this process, it was found that nine individual respondents indicated some perception of intimidation by falling into one of the first two categories. Of this number, five were in category two,-
and four respondents, amounting to 3% of those surveyed, were in category one. It appears then, that data available from five years ago (1979) when analyzed, do not reflect a pervasive climate of intimidation.
In summary, two approaches were utilized to analyze the 1979 Management Review Board Survey data. Both approaches, undertaken independently from one another, reached the same conclusion. A content analysis of the responses to selected relevant questions identified some issues of possible concern to management, but yielded no indication of any pervasive climate of intimidation. A second approach, involving the overall categorization of each respondent based on answers to relevant questions reached the same conclusion. Only a very small percentage of employees surveyed described or complained about intimidati,ng incidents.
Although the task of the Study Team did not include evaluating whether or not actual intimidation occurred in specific instances at CPSES, the team concluded that some of the alleged cases of intimidation probably were cases where people perceived some pressures but were not really intimidated into professional misconduct. This problem of perceived pressure is related to the management style prevalent at CpSES and will be discussed in detail in Section 3.3.
29 1
l A total of 19 forced-choice questions requiring a checked response were included. There was also one open-ended question (Question 20) requiring a written response on any aspect of the QC job which the respondent thought could or should be changed in the service of improvement.
This survey was an important source of data for it provided wide coverage of QA/QC personnel and elicited responses which could be identified as their attitudes and opinions on various aspects of their ;
overall job environment.
The following paragraphs briefly describe and summarize the analysis of the 1983 questionnaire survey. The analysis proceeded on two levels:
Level 1: Simple Analysis of Responses--Direct Measures The questionnaire permits specific identification of the attitudes and concerns of people in the QC organization. For example, the questions, focus directly on feelings and perceptions of various work-related factors (supervision, environment, etc.). In addition, responses to the open-ended question can be categorized and tabulated in terms of the concerns evidenced.
Level 2: Complex Analysis of Responses--Indirect Measures An analysis of item responses was performed to infer whether or not QA/QC personnel were reacting to a climate of intimidation at CPSES at the time of the survey. Analyses of the pattern of favorable and unfavorable responses to certain questions, and noting the degree to which more threatening questions are left unanswered or are answered more favorably or cautiously, are examples of this more complex analysis. Responses to the open-ended question were also examined for what they might reveal about the organization climate.
The focus and purpose of this study requires this second level of analysis to be performed to provide an additional perspective on the question under study. While the substance of individuals' attitudes and 31
questionnaire compared to less threatening items. That is, an examination was performed to determine whether or not respondents overcompensated positively on items they felt would be examined.
" Threatening items" were defined as those questions which, if a critical response were given and the respondent identified, could
, potentially lead to punitive action taken against the respondent.
A detailed report of this analysis is presented in Appendix C of this report. It was performed by Dr. David Bowers of the University of Michigan, a nationally known expert in Survey Research and Survey Analysis. The following summary analysis s derived from his report.
Response rates on all items in the questionnaire was judged to be relatively high. That is, on almost all items, the response rate varied from 96 to 99%, indicating that people were clearly not reluctant or reticent to respond to any of the items. Further, one might infer that there is relatively little doubt about or concern with the protection and confidentiality of respondents.
Dr. Bowers categorized items based on the relative degree of threat perceived by the respondent (see definition above). He categorized each item as high threat, intermediate threat, or low threat.
On all items, regardless of relative degree of perceived threat, the response rate was high (approximately 96%). Therefore, one might infer that people were able and willing to respond to perceived high-threat items, much as they would to. perceived intermediate- or low-threat items.
A more detailed description and analysis of these item by item categories is presented in Appendix C.
The analysis indicated that, in general, across all five subgroups, negative (or unfavorable) responses were common in about the same proportion. This means that negative attitudes could not be identified as predominant in any one sub group, but indeed were scattered among most respondents. Moreover, the unfavorable profile was deemed to be " normal."
33
intimidation. Three quarters (71%) of the participants in the survey did respond to this question, yet only three responses suggested anything akin to intimidation or an atmosphere of intimidation.
Dr. Bowers' conclusion was arrived at independently and without benefit of other sources of data. His interpretation of his analysis is as follows: "The findings ... disconfirm the existence of intimidation as a major factor in the survey results. The overall pattern is one of favorability, with normal and considered variation by question or issue.
Insofar.as the questionnaire survey results reflect real conditions, there is little or no evidence of intimidation as anything but a relatively rare, coincidental occurrence."
3.2.4 Historical Climate Much of the data, with the exception of the Management Review Board report and a few depositions, are related to incidents occurring in the last two or three years. Therefore, it is not clear that a definitive evaluation of the climate that existed at CPSES prior to 1979 can be made.
However, it is possible to infer what the climate might have been through several indirect means.
e Continuity of management. A number of the management personnel presently associated with CPSES have been with the project for many years. It is unusual for managers to change their style of management after they have reached a reasonably high level in any organization, and it is unlikely that their style would change in the middle of a specific project. Thus, if the climate created by the present management does not appear to be intimidating, then it is reasonable to conclude that the climate before 1979 involving many of the same managers was probably not intimidating either.
e Extrapolation. The 1979 survey elicited responses in a number of specific areas that would tend to lead the respondents to think in longer terms than simply that day's. problems. (e.g.,
35
instances mentioned at each time does not appear to be growing. All these arguments, then, lead to the conclusion that at no time is it probable that a climate of intimidation existed at CPSES.
3.3 Management Style 3.3.1 The Concept of Management Style As noted earlier, one factor that must be considered when discussing work climate is management style.
Management style can be characterized as the " personality" of the organization. It is critical, both in the way employees feel about the organization and its operating philosophy, and in the specific procedures used to manage various issues and dilemmas common to the organization and its tasks. The construction industry environment is more blue collar, manual, physical, and assertive relative to other organizations. The result is an emergent management style that appears to be aggressive, forceful, confronting, and insensitive. It is possible that some employees might interpret this behavior as intimidating and might even describe the organizational climate as intimidating, and indeed for some, it probably is.
Research indicates that in a more complicated technical environment (that is, one in which functions are non-repetitive, where various disciplines and technologies are required to interface, and where the environment is relatively unstable), a more participative and interpersonally-oriented management style seems more effective and appropriate.
In the performance of relatively stable, routine, and repetitive organizational functions, a certain degree of " Autocratic / Bureaucratic" behavioral style seems appropriate. Moreover, such a management style is often associated with the most efficient and effective organizations of that type. To some organizational members, however, this management style may be perceived as intimidating.
l 37 i
l
Deci sion-Ma king: Decision-making is characterized as involving many people at the top of the organization and very few at the bottom.
Decisions are primarily routine following very careful procedural and policy guidelines. As a result, there is very little deviation from preset procedures.
Communication: The management style with regard to communications is primarily downward. There is very little opportunity for interaction and, given some of the above descriptions, there is little tolerance for deviating from information communicated downward.
While this description may not be the most ideal and certainly seems to require some modification given new perspectives on managing in complex environments and the new demands and values of the work force, there are few data available here which would demonstrate a pervasive climate of intimidation at CPSES. This authority-oriented style often creates resistances and special motivational problems, but in and of itself, would not lead to an intimidating climate or to specific instances of intimidation.
3.3.2.1 Managerial problem-Solving Style. Management response to problem situations is another aspect of management style. Where there is a discrepancy between the existing management style and the requirements of the technology, task, and mission of the organization, there seems to be one of two general responses in most organizations:
- 1. Fix the System: In some instances, the management of an organization may elect to modify and change its own management style and organizational processes such that their methods conform more appropriately with the organization's task and mission.
- 2. Fix the Problem: For the most part, management in large organizations is rigid and static. Thus, problems are not addressed as a set of systemic and cultural issues, but are 39
- 4.
SUMMARY
AND CONCLUSIONS A detailed review of the 1979 QC Interview Survey, the 1983 QA/QC Questionnaire survey, NRC inspection reports, depositions, and miscellaneous data outlined in Section 2 was completed. An analysis, insofar as limitations of the data permitted, of the work climate, management style, and historical climate was completed.
~
It is recognized that the depositional data was limited, reflecting information from complainants, managers, and related individuals. The reports reviewed generally focused on investigations of specific allegations. The questionnaire information, while more generally applicable to this investigation, was still not focused enough to draw unequivocal conclusions. A summary of fact findings are:
- 1. The extent of allegations with regard to the organizational units involved and the number of allegers and intimidators identified is very small .
- 2. The employees at CPSES did not appear to be unduly afraid to answer questions or to name individuals they felt were intimidators or were attempting to intimidate them.
- 3. The response of management to intimidation allegations appears to have been prompt, and investigators utilized were relatively independent. Management repeatedly stated its dedication to quality and generally followed confirmed intimidation or harassment incidents with prompt corrective action.
- 4. Insufficient evidence was available to determine the extent to which allegers were protected. The company has urged individuals to take concerns to management or the NRC, and some individuals expressed the feeling that allegers became more secure because of 4
" whistle blowing" regulations. Others, however, felt they had been terminated for making allegations.
41 i
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APPENDIX A COMPREHENSIVE LIST OF DATA REVIEWED l
l A-1
APPENDIX A COMPREHENSIVE LIST OF DATA REVIEWED A large volume of data was available for review by the study team.
The comprehensive list below is divided in separate categories to include the deposition and transcripts, survey data, NRC reports, and internal reports, office correspondence and memoranda of the applicant utility that were reviewed by the study team.
DEPOSITIONS AND TRANSCRIPTS Date Witness Transcript Pages 7/09/84 G. Xeeley 36,187-216 R. Spangler 36,128-187 R. Kahler 36,000-127 J. Green 35,000-078 F. Coleman 35,079-125 M. Krisher 37,000-138 J. Johnson 39,000-062 A. Vega 36,500-659 D. Chapman 35,500-730 J. Patton 37,561-712 L. Wilkerson 37,500-560 J. Callicutt 38,000-110 K. Liford 38,111-187 35,535A-535F T Conference 38,500-542 7/10/84 B. Clements 40,000-192 43,500-568 43,000-077 42,500-546 G. Purdy 41,000-272 T. Locke 41,503-606 R. Tolson 40,500-669 B. Sne11 grove 44,000-136
- W. Mansfield 44,500-566 G. Krishnan 42,000-016 A-3
Date Witness Transcript Pages 7/20/84 "F"* 339-546 "L"* 56,500-509 R. Dempsey 70,500-514 J. McMain 71,000-019 7/23/84 T Conference 38,567-654 7/24/84 D. Woodyard 56,500-605 7/25/84 J. Blixit 57,000-706 R. Stever 58,000-139 D. Culton 58,500-591 J. Stanford 57,500-587 7/28/84 L. Barnes 59,000-246 7/30/84 Panel 1 C. Biggs G. Fanning R. Whitman J. Vehlein 71,500-659 Panel 2 M. Rhodes W. Sims M. Todd S. Burns 73,000-160 7/31/84 T Conference
- 36,655-689
-* 54,559-718 i Panel 3 Anderson Spencer Goren 72,500-681 D. Anderson 73,000-042 J. Pitts 73,500-553 8/01/84 H. Gunn 75,000-008 S. Hoggard 74,000-016 J. Scarbrough
& D. Ethridge 74,500-521 F
S. Neumeyer 59,500-683 A-5
SURVEY DATA 1979 MANAGEMENT REVIEW BOARD SURVEY--Interview protocols from 121 residents who were asked a total of forty questions each (5 multi part questions with a total of 40 different items).
1983 QA/QC QUESTIONNAIRE SURVEY--Questionnaire responses from 139 QA/QC personnel in five groups, referred to as " White Paper Report" at CPSES.
NRC REPORTS Comanche Peak Plan for the Completion of Outstanding Regulatory Actions, NRC, July 1, 1984.
Comanche Peak Steam Electric Station: Intimidation of Coatings QC Personnel, Report of Investigation 4-83-001, NRC Office of Investigations, August 24, 1983.
Comanche Peak Steam Electric Station: Alleged Intimidation of QC Personnel, Report of Investigation 4-83-013, NRC Office of Investigations, November 3, 1983.
Comanche Peak Steam Electric Station: Alleged Intimidation of QC Personnel, Report of Investigation 4-84-006, NRC Office of Investigations, March 7, 1984.
Comanche Peak Special Review Team Report, NRC report on a limited, unannounced review, April 1984.
Document 38EX 3841; Protocols from 26 interviews conducted in conjunction with the Special Review Team Report.
Partial Initial Decision in the matter of Duke Power Company, et. al, (Catawba Nuclear Station, Units 1 and 2), NRC, ASLB, June 22, 1984, (ASLBP No. 81-463-06 OL)
A-7 1
4 INTERNAL REPORTS, OFFICE CORRESPONDENCE AND MEMORANDA To From Subject Date A. Vega J. M. Roberts Records Verification 05-30-84 Concerns QAI-0014 Chris Boyd Boyce H. Grier Employee Concerns with 05-04-84 Harassment D. N. Chapman R. G. Tolson Margaret Lucke 11-03-84 Personnel File C. T. Brandt Magaret Lucke 10-31-83 NCR C-83-02965 Margaret Lucke 11-01-83 Inspection Report Margaret Lucke 10-28-83 PC108073 Jr. Haley Mike Barr Message 10-28-83 Personnel File R. G. Tolson QC Inspector Mark Reed 11-03-83 Badge No. D--798 File G. R. Pardy 35-1195, CPSES 11-11-83 Counseling of M. Reed File R. G. Tolson Mr. David Dial 02-09-84 Report of Interview David L. Andrews Ronald James Jones 03-15-84 Report of Interview David L. Andrews Cecil Manning 04-12-84 Report of Interview David L. Andrews Stan Vore 04-18-84 Report of Interview David L. Andrews J. B. Leutwyler, 04-18-84 Quality Control C. Vega Ronald Jones 03-16-84 Recertification Report of Interview David L. Andrews Gordon Purdy 04-11-84 Report of Interview David L. Andrews Bill Ford 04-18-84 Report of Interview David L. Andrews Ray Vurpillat 04-11-84 Report of Interview David L. Andrews Al Smith 04-11-84 Thomas Miller David L. Andrews (Registered letter) 04-10-84 l
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To From Subject Date File Les Taggart Notification of 01-12-84 !
absenteeism Ron Jones les Taggart Ron Jones Message 01-13-84 Paulette Wilson W. H. Ford Message 01-09-84 W. H. Ford Ron Jones Absentees 04-08-83 Bill Ford Ron J. Jones Message 12-29-83 Les Taggart W. H. Ford Message 12-09-83 (hand written W. H. Ford Ron Jone 12-09-83 letter)
Time Office Brenda Papenthien Message /Ron Jones 08-08-83 Time Office Brenda Papenthien Message /Ron Jones 08-05-83 Stan Vore Ron J. Jones Message 07-25-83 "Paulette Wilson Stan Vore Message 08-03-83 Stan Vore & Ron Jones Message 06-27-83 J. B. Leutwyler Stan Vore & Ron Jones Message 05-09-83 J. B. Leutwyler To Whom It May Cathy Erwin Ron Jones GED Scores 4-12-83 Concern Jane P. Jones Ron Jones GED Scores 03-21-83 Arlington Heights Paula Gilleland Requesting Verification 02-24-83 High School of Education /Ron Jones Training Ronald J. Jones Education & Work Time
. Coordinator Verification Ron Jones Resume' 03-21-83 Bell Helicopter Paula Gilleland Requesting Verification 02-01-83 Inc. of Previous Employment Western Executive Paula Gilleland R. J. Jones 02-01-83 Search A-11
To From Subject Date Harry Williams File Susan Spences Memo D. N. Chapman Harry O. Williams Letter 03-17-82 D. N. Chapman B. R. Clemerts Allegations by 09-19-83 W. A. Dunham Gordon Purdy Curtis L. Poer William A. Dunham 10-18-83 D. N. Chapman Antonio Vega Investigation into 10-26-83 allegations made by W. A. Dunham Curtis L. Peer Fredrick J. Killion Letter 10-27-83 John Collins R. J. Ga ry Investigations into 12-13-83 File No. 10066 DLA A. Vega Message 02-27-84 Stephen L. Hoech Curtis L. Poer Billie Orr V. Brown & 04/06/8u Root Inc.
ONC A. Vega Troy Amos Allegations 03-02-84 Distribution A. Vega Request for Assistance 12-20-83 in Resolving Quality
. Assurance Allegations QAI #0001 Supplement #1 Distribution A. Vega Request for Assistance 12-20-83 in Resolving Quality Assurance Allegations QAI #0001
- Telephone call w*ith 01-06-84 Troy Amos Distribution Jerry C. Walker Resolution of QAI-0001 03-09-84 !
I Chapman Jerry C. Walker Memo 03-05-84 f A. Vega Boyce H. Grier Investigation of 02-22-84 Allegations QAI #0001 Distribution A. Vega Request for Assistance 1
in Resolving Quality Assurance Allegations QAI #0001 Supplement #2
[
i A-13
To From Subject Date Distribution A. Vega Request for Assistance 04-30-84 in Resolving Quality Assurance Allegations QAI #0013 Interview with 04-30-84 Varlon Cummings A. Vega Boyce H. Grier Allegation of 06-19-84 Harassment
-QAI-0012 Interview with 05-01-84 John Winckel J. D. Hicks A. Vega Allegation of 05-16-84 Harassment J. T. Merritt A. Vega Allegation of 05-10-84 Harassment Distribution A. Vega Request for Assistance 05-01-84 in Resolving Quality Assurance Allegations QAI #0012 Interview'with 04-24-84 Rick Henricks Distribution A. Vega Request for Assistance 04-23-84 in Resolving Quality Assurance Allegations QAI #0011 Purdy Handwritten , 08-23-83 Investigation Distribution D. N. Chapman Request for Assistance 04-11-84 in Resolving Quality Assurance Allegations QAI #0006 File of C. H. Welch QA/QC Interview 04-10-84 Teresa Whittlesey Distribution D. N. Chapman Request for Assistance 04-17-84 in Resolving Quality Assurance Allegations
- QAI #0008 A-15
8 4 l
APPENDIX 8 RESUMES l
B-1 e
RESUME Bruce L. Kaplan Mr. Kaplan is an Organization Development Specialist for EG&G, Idaho.
His work involves consulting, counseling, coaching and training. He deals with issues of management and organization effectiveness in areas which include organization design and transition management, human resources and management development, interpersonal and intergroup conflict, team building, survey feedback, and business research. In his five years with EG&G Idaho, whose mission is providing research and development services for the government, Kaplan has consulted to scientific, technical, administrative and service organizations on such issues as problem solving and decision making, team-building, work climate assessment and improvement, productivity and quality of working life.
Kaplan holds a Master's Degree in Organization Development from Pepperdine University, where he studied the relationship between organizational climate and task accomplishment. His courses included Consultation skills, Organizational Systems Diagnosis and Action Strategies, including Management Development and Human Resources Planning.
His prior education included graduate studies at Case-Western Reserve University in Organizational Behavior, and a Bachelor of Arts in Chemistry from the University of Cincinnati. His previous work experience was in adult and secondary education, where he held teaching, consulting, and administrative positions.
b 4
B-3
RESUME Newton Margulies, Ph.D.
Dr. Margulies is Dean and Professor of Management in the Graduate School of Management at the University of California at Irvine. He previously served as a professor there from 1972 until 1984. Prior to
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moving to Irvine, he was on the faculty of the Division or Organization Sciences at Case Institute of Technology, and in the Department of Management at the University of Miami.
Dr. Margulies received his Ph.D. degree in Behavioral Science from the University of California at Los Angeles (UCLA) in 1965. Prior to that he earned a B.S. degree in engineering from Brooklyn Polytechnic Institute, and received a M.S. degree in Industrial Management from the Massachusetts Institute of Technology.
In his professional life Dr. Margulies has had the opportunity to consult in the area of organizational development and team building with a variety of organizations including TRW Systems Group, the California Department of Water Resources, Northrup Corporation, the National Emergency Medical System, and others.
Dr. Margulies has written and lectured extensively in the field of organizational behavior. In addition to many articles publ,ished in professional journals, he is the co-author of the following books:
Organizational Development: Values, Process, and Technology (1972)
Organizational Change: Techniques and Applications (1973)
Conceptual Foundations of Organizational Development (1978)
Organizational Development for Health Care Organizations (1982)
Human System Development (forthcoming in 1985)
B-5
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- 5. Program Manager for the Army Gas Cooled Reactor System Program including design and fabrication of the ML-1, (the first complete
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system prototype'), the Gas Cooled Reactor Experiment, the closed cycle gas turbine power plant and all related research and development.
- 6. Reactor Engineering Department Manager responsible for development and installation of several uriversity training reactors, consulting contract support to the AEC for central station power plants, maritime applications of nuclear power, metallurgical research and food irradiation applications.
Pasented a Variable Moderator Controlled Boiling Water Reactor.
- 7. Herf of the Atomic Power Engineering Group for an architect engineering firm responsible for the design of the first boiling water nuclear power plant.
- 8. For four years served as a Physicist with the Oak Ridge Operations Office of the U.S. Atomic Energy Commission.
AB Physics MS Physics Oak Ridge School of Reactor Technology Fellow and Charter Member, American Nuclear Society
' e i
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-.--- ,.-- - .. - , ,-, _ ~ - , - . , , , - _ . - - ,~. .
A member of the American Society of Mechanical Engineers, American Nuclear Society and the Edison Electric Institute's Nuclear Power Executive Advisory Committee.
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1
-l APPENDIX C 1983 QA/QC QUESTIONNAIRE SURVD ANALYSIS BY DAVID G. B0WERS C-1
Report to EG&G Idaho, Inc.
by David G. Bowers, Ph.D.
Research Scientist August 2, 1984 C-3
Uniform, intra-respcndent positiveness e A pattern of prevalent negative opinion e A clustering of negative opinion within a significant minority of persons e Written comments suggesting intimidation e An almost complete absence of written comments, suggesting fear of identification by test of handwriting.
ANALYSIS AND RESULTS The 139 questionnaires, clustered into five subgroups ~, were collectively examined to test for the existence of these patterns. The following paragraphs describe what was done and the results:
e The 19 closed-end items were examined for response rate, to determine whether non-response rates would suggest intimidation on certain questions. There was no such effect. For all items b;t one, response rates ran between 96 and 99%. On that one item (Q. 5) the response rate was 89%. (See Table 1) e Threat was defined as a situation in which, if a , critical response were given and known, it could conceivably lead to l punitive, negative, or disadvantaging action being taken against the respondent.
e Next, threat was judged in terms of whether, in my opinion, they l
i were high, medium, or low potentially personally threatening in their centent. The categories were:
t l
l t
C-5 l
l l
t
e ,
I High Threat Medium Threat Low Threat (Items) (Items) (Items) l 2 1 3 4 13 5 9 16 6 10 18 7 11 19 8 12 15 14 17 e It was noticed that the high threat items were all worded in the negative; that is, a response of "Mostly No" would be considered favorable. The low threat items, on the other hand, were all worded in the positive; a response of "Mostly Yes" would be considered favorable. The medium threat items were of mixed wording, two in the positive, one in the negative. any acquiescence response tendency would' therefore tend to bias in favor of the two opposite ends of the threat diment. ion, that is, a tendency on the one hand to agree with the negatively worded high threat items, and with the positively worded low threat items. The results were:
Percent Favorable (i.e., "Mostly No") to negatively 79.5 worded high threat items Percent Favorable to (mixed) medium threat items 66.7 l
l Percent Favorable (i.e., "Mostly Yes") to positively 83.3 l worded low threat items i
In fact, therefore, despite any acquiescence response set, an j overwhelming majority or respondents tended to disagree with the l
negatively worded high threat items. Any acquiescence response i
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o -
Since the confidence band for the overall favorable response percentage would be approximately 68-88%, all groups except Williams fall within that band.
e Looking at the Williams group separately, the following was found:
Category percent Favorable Response
. High threat 60.5 Medium threat 50.0 Low threat 65.8 Because this was the smallest group (N = 12), the difference between these percentages and those for the overall percentages amounts to at most two persons, e Although there was not time to do a complete item analysis, a casual check in two of the largest groups was undertaken to see whether unfavorable response tended to be consistent for particular respondents. The results suggested that this tended not to be true:
Q. 2 "Yes" Q. 4 "Yes" = 11 (N = 21) Q. 4 "No" = 9 Q. 4 " Don't Know" = 1 Q. 2 "Yes" Q. 11 "Yes" = 8 Q. 11 "No" = 13 In other words, unfavorable responses seem to have been scattered generally among most respondents, not concentrated among a few.
e The responses to Q. 20, the oper,-ended or write-in question, were content-analyzed into five possible categories. Where more than one category was mentioned, the category discussed most was coded. Where equal space was given to more than one category, the first mentioned was coded. However, any mention in categories 4 or 5 was coded there.
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". . . On a personal level, I would like to see a less antagonistic, threatening, and insecure attitude from management; i.e., I"m tired of being told to ' hit the gate' if I don't like it here. That type of comment is usually a response to some inquiry as to prospects of a weekend off or getting paid on time."
" . . . Many of us have worked at several additional nuclear plants, and we are appalled with the shoddy program here which largely consists of cover ups, smokescreens, intimidation, and harassment."
" . . . How can there be any Quality Control when there is pressure from management to get turnovers completed. Would the NRC approve?!?"
e C-11
e o' considered variation by question or issue. Insofar as-the questionnaire survey results reflect real conditions, there is little'or no evidence of intimidation as anything but a relatively rare, coincidental occurrence.
O C-13
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h -
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/daho September 1985 National Engineering Laboratory COMANCHE PEAK STEAM ELECTRIC STATION:
ALLEGED CLIMATE OF INTIMIDATION SUPPLEMENTARY REPORT 3
4 4 EGnG-l
~; =
No. DE AC07-7&D01570
%.g A> < i v-
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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 Published September 1985 EG&G Idaho, Inc.
Responsible NRC Individual and Division V. S. Noonan/ Division of Licensing Docket No. 50-445/2 and 50-446/2 Prepared for the U.S. Nuciear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6819
e CONTENTS PAGE ,
ABSTRACT................................................ i
- 1. INTRODUCTION....................................... 1
- 2. DATA S0URCES....................................... 3 2.1 Depositions................................... 3 2.2 Survey Data.................................. 3 23 NRC Reports .................................. 3 2.4 Prefiled Testimony............................ 4 2.5 Hearing Transcripts.......................... 5 2.6 Other Information............................. 6 3 ANALYSIS........................................... 8 3.1 Analysis Using Ddpositions, Prefiled Testimony & Hearing Transcri. pts............... 9 3.2 Analysis of the 1979 Management Review Board Survey................................. 19 33 Analysis of Additional NRC Reports of Investigation and Inquiry.................... 24 3.4 Observations on Managerial Practices......... 37
- 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
o
, ABSTRACT COMANCHE PEAK STEAM ELECTRIC STATION:
ALLEGED CLIMATE OF INTIMIDATION SUPPLEMENTARY REPORT September 1985 The U.S. Nuclear Regulatory Commission (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 intimidation of Quality Assurance / Quality Control (QA/QC) personnel based on data reviewed from September 1984 througn August 1985. The resulting expert opinion, developed by the same Study Team that produced the
, original EG&G report, is presented in this supplement. The original EG&G report, dated September 1984, is entitled
" Comanche Peak Steam Electric Station: Alleged Climate of Intimidation."
The Study Team assessed depositions, prefiled testimony, hearing trcnscripts, NRC reports, survey data, and other available information. Using a broadened
- definition of intimidation, they formulated opinions on individual incidents of intimidation and the overall work 4 climate.
l Key findings were that some incidents of intimidation 1
e did, in fact, occur. The overall pattern of incidents, including the numbers of alleged incidents, allegers, and named intimidators, does not support a conclusion that a climate of intimidation exists, or existed, at CPSES.
Certain management practices, while not constituting .
intimidation, may have negatively 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, the data reviewed do not indicate that a climate of intimidation did, or does, exist at Comanche Peak Steam Electric Station.
O h
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COMANCHE PEAK STEAM ELECTRIC STATION:
ALLEGED CLIMATE OF INTIMIDATION SUPPLEMENTARY REPORT
- 1. INTRODUCTION An EG&G Idaho initial report entitled " Comanche Peak Steam Electric Station: Alleged Climate of Intimidation,"
on the issue of intimidation of Quality Assurance / Quality Control (QA/QC) personnel at Comanche Peak was written by .
this Study 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 and is based upon the incorporation of all infor=ation reviewed prior to September 1985.
The numbering of the sections in this Supplementary Report generally follows the outline of the original report to facilitate the comparison of related sections between the two reports. This report is not intended to stand alone. It is a supplement to the original report and must be read in conjunction with it.
This Supplementary Report is divided into a number of sections as follows. Section 2 presents listings of the i
n __. .
additional data received and reviewed since preparation of -
the original report. Section 3 presents the analyses based on the additional data and includes conclusions based on the entire data set. This section is divided into
- subsections dealing with transcribed data, th'e 1979 and 1983 surveys, NRC Reports of Investigation and Inquiry, and observations concerning management practices at CPSES.
Section 4 presents a summary of the 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.
2
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- 2. DATA SOURCES Information in addition to that used in preparing the original report was received and used 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 Survcy 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 Several additional NRC Office of Investigation Reports of Investigation and Reports of Inquiry have been reviewed 3
since September 1984 They are listed below: .
Incuiry 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 Prefiled testimony from the following nineteen individuals was also received and reviewed:
- 1. Antonio Vege
- 2. Gregory Bennet::en 3 Neil Britton 4
_- __-_-______-__m. _ _ _ _ _
- 4. William Darby 5,6,7. Liford, Johnson, and Callicut
- 8. Richard Simpson 9 Gordon Purdy l
- 10. Robert Duncan 11,12. James Zwahr and Daniel Wilterding 13 Ronald McBee
' 14 . Alan Justice
- 15. James Brown
- 16. Witness "F" 17 Samuel Hoggard
- 18. Arthur London
- 19. David Ethridge 2.5 Hearing Transcripts The following listed transcripts of hearing testimony were received and reviewed:
l DATE PAGES SUB JECT 9/09/84 14,403-14,771 In Camera Session: Witness "F" 9/10/84 14,772-15,171 M. Spence, A. Vega 9/11/84 15,172-15,573 Vega (contd), B. Clements, C. Thomas Brandt 9/12/84 15,574-15,951 Brandt (contd), I. Goldstein 9/12/84 15,952-16,389 Brandt-Travelers, G. Purdy 9/14/84 16,390-16,647 Tolson, Downey on Travelers 9/1S/84 16,648-17,008 Tolson, Vega, Brandt (contd),
C. Allen 5
9/19/84 17,009-17,740 Allen, Brandt (contd), Liford, .
Calicutt, etc.
9/20/84 17,741-18,158 G. Bennetzen, D. Chapman, Duncan 9/21/84 18,159-18,504 In camera: two witnesses -
10/01/84 18,505-19,028 D. Hunnicutt, J. Norris, T. Matheny 10/02/84 19,029-19,262 Norris (contd), G. Purdy 11/19-84 19,586-19,846 0. B. Cannon: J. Lipinsky 11/20/84 19,847-20,179 Lipinsky (resumed), R. Roth 11/21/84 20,180-20,450 Roth (contd) 11/26/84 20,451-20,774 G. Chaney - Handwriting Expert, Brandt 11/27/84 20,775-21,091 Brandt (resumed) 11/28/84 21,192-21,405 Brandt (resumed) 12/03/84 21,406-21,748 Brandt (resumed), Roth -(resumed) 12/04/84 21,749-22,006 J. Lipinsky 12/05/84 22,007-22,254 Lipins.ky (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 Two additional documents received in response to NRC requests to Texas Utilities for specific information were reviewed.
- 1. The Responses er Texas Utilities to the NRC's Questions Concerning the 1979 and 1983 surveys of 6
Quality Control Inspectors at Comanche Peak.
- 2. A series of organizational charts and a summary table (dated 2-16-85, 2 pages) indicating the company,
. organizational unit, and position of alleged intimidators.
The Atomic Safety Licensing Board (ASLB) Memorandum (Concerning Welding Issues) LBP-84-54, dated December 18, 1984, was also reviewed.
I 4
7
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 received subsequent to the drafting of the original report, analysis of those
- materials, and integration of that analysis with the work previously done.
The final conclusions in this report are based on the several different types of data available for analysis. Of central interest was whether 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 would enhance the reliability of the overall conclusions.
The following sections of this report deal successively with data from the depositions, prefiled testimony, and hearing transcripts; survey data; and NRC investigation and inquiry reports. l 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 are discussed in Section 3 4 of this report which deals with managerial practices.
8 I l
1
31 Analysis Using Depositions, Prefiled Testimony, and Hearing Transcripts ,,
3 1.1 Organization climate
~
This section analyzes the extent to which a climate of intimidation existed at CPSES. (This concept is defined in detail in Section 1 3 of the original report, pages 3-5.)
In making 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 on 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 effect, (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 rejected, 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 compliance with, written procedures.
In this supplementary report, intimidation is defined as incidents, statements, or other actions that are reasonably 9
likely to influence employees to refrain from performing work ,
in accordance with requirements or identifying or reporting quality discrepancies or safety problems. The Study Team has thus broadened their definition of intimidation to include .
the impact the incident could be expected to have had on reasonable individuals in the work setting who experienced, witnessed, or became aware of the event, regardless of their actual responses to the alleged intimidation.
3.1.2 Extent of Allecations of Intimication At the time of the original report, September 1984, the analysis, and therefore the conclusions reached, was ,
, based on the data the Study Team had analyzed up to that point in time. This Supplementary Report Incorporates analysis of all information reviewed through August 1985.
l 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 additional individuals after September. A summary list of these data sources is shown in Table 1 of this section.
In addition to the depositions, 19 in'dividuals provided data in the form of prefiled testimony, and 10 1 6
numerous individuals provided testimony at the hearing (as listed in Sections 2.4 and 2.5). For the most part, these individuals supplemented or repeated information provided in the depositions. In some cases these were new data-providers elaborating on incidents identified in the depositions.
i r
4
?
9 I .
L I
h l
1 11
. , . - , , - - , - - - . , - . , - , , . - - - - - - - - - - - , - , . - _ - - . . - - - . , . -,n,,,-- ., . . , , - - , - ~ - , , - - . . , . , - , - , - ,,
TABLE 1.
SUMMARY
OF DATA PROVIDERS FOR DEPOSITIONS
~
Total Data Providers: 86 QA/QC Managers: 17
~~
QA/QC Employees: 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 Snellgrove Deborah Anderson Ronald Tolson Sue Ann Neumeyer Robert Siever Curtis Biggs Dwight Woodyard Greg Fanning-Antonio Vega Randy Whitman Jack Stanford James Uehlein Billie Ray Clements William Dunham Myron Krisher Jimmie McClain Evert Mouser Wayne Mansfield Larry Wilkerson Non-QA/QC Managers: 24
~~
Kenneth Whitehead James Callicut Marvin Coates t 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 l Michael Spence Lester Smith l Ronald Dempsey James Scarbrough Kenneth Liford David Ethridge
! Fred Coleman Ivan Vogelsang <
John Hallford Dennis Culton Charles Tedder Bobby Murray l Hollis Hutchinson Stanley Miles l Carmen Baker Gary Krishnan
! Michael Hall Ronnie Johnson l John R. Johnson James Keller i Samuel Hoggard Larry Howard Boyce Grier Witness "F" NRC Personnel: ~
4 James Cummans Robert Taylor Frank Hawkins H. Brooks Griffin 12
The Study Team reviewed the specific incidents of reported intimidction. 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 31 incidents were reported, spanning the period from 1979 to 1984. (See Appendix B, Table B1, for a complete listing.) The dispersion is shown in Table 2.
TABLE 2. DISPERSION OF INCIDENTS OVER TIME Year Number of; Incidents 1979 1 i
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) 1
- Table 2 shows the reported incidents were concentrated l from 1982 through 1984 In 1981, four incidents were i
reported by two individuals, one of whom provided three
- reports. In 1982, five of the six reported incidents were also fro = the same individual who reported three incidents 13 l
4
. . . . _ _ . _ . _ _ _ _ . . ___ _,__m_ . . . _ , . _ __,___.-__._-.,_x._m_ ____ _ _ _ _ _.___. . _ _ . . ... _- ..__.-- __.,_- _ . _ _ . _ _
in 1981. So, of these ten incidents in 1981 and 1982, -
eight involve that one individual. As a result, for the years 1979 through 1982, only four different individuals alleged intimidation. '
In 1983, 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. Six of these incidents were reported by two allegers. One of the nine incidents involved the termination of three individuals, and another involved eight electrical
%nspectors wearing nit-picker T-shirts. Over the period 1979 through 1984, the 31 incidents were reported by a total of 13 individuals, excluding the eight T-shirt-wearing inspectors. Overall, two-thirds of the incidents (21 of the 31) were reported by only four individuals.
In using these data to assess the CPSES climate, the Study Team noted the number of QA/QC personnel employed at the site from 1979 to 1984 was between 150 and 250 at any one time. If approximately 200 inspectors had worked 250 days each year doing an average of two inspections per day over the six-year period, then 600,000 opportunities were available for conflict or intimidation to occur. Given the normal pressures created by scheduling and economic considerations, the natural conflicts between craft and QA/QC, and some inevitable 14
personality clashes, there was a large number of opportunities for problematic interactions during the course of the work.
Viewing the situation at CPSES from this perspective, the Study Team concluded 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. Relatively few incidents of intimidation were reported over the six-year period involved, with a substantial majority of these incidents being alleged by four individuals.
The September 1984 report l'ndicated relatively few allegations were made and relatively few intimidators were named. Having now reviewed all the transcribed material, the conclusions of the Study Team do not differ from those original conclusions. The findings fail to substantiate the existence of widespread intimidation at CPSES.
Nevertheless, the small number of reported incidents cannot climinate 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, the reported incidents were perceived to be of a serious nature, and widespread knowledge of the events existed, and that knowledge persisted for some time in the organization, 15
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. '
3.1 3 Review of Specific Incidents of Intimidation The analysis presented thus far has made no judgment regarding the validity of the allegations themselves. Each alleged incident was simply counted without judging whether 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 of 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 in the given situation. 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 to assess 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 ant. lysis, all available data were used, including depositions, prefiled 16
testimony, OI reports, hearing transcripts, and the ASLB Memorandum on welding issues. Each incident evaluated is listed and briefly discussed in Appendix B.
TABLE 3 DISPERSION OF INCIDENTS JUDGED AS INTIMIDATING Year Number of; Incidents Description 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
=ade, the case against a climate of intimidation is even stronger. Few incidents, in the opinion of the Study Team, could be classified as " intimidating." Of the incidents included as probable acts of inti=idation, some were not clear or were counted only because they fit narrowly or 17
technically within the definition of intimidation. These -
cases were, however, included in the listing above. The nine incidents involve four different allegers, excluding the T-Shirt Incident which involved some eight " targets" of -
potentially intimidating actions.
All of these incidents do not deserve equal weight as significant events in creating a possible climate of intimidation. The most significant incidents, based on their potential to influence many employees, were the Stiner Circuit Breaker Article Incident, the two Dunham related incidents, and the T-Shirt Incident.
3 1.4 Conclusions on Intimidation Incidents Review of the available information regarding the number of alleged incidents of intimidation and their dispersion over time, and review of the specific incidents themselves, resulted in no change in the original findings of the Study Team. The data do not support a conclusion that a climate of intimidation exists, or existed, at CPSES.
18
32 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 completed by the same expert in survey methodology who previously analyzed the 1983 QA/QC Questionnaire Survey, and the results are summarized below. The complete analysis is attached to this report as Appendix A.
3.2.1 1979 Management Review Board Survey
~
To provide a more complete picture of findings from the 1979 survey, a more extended analysis of 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 f
( questions which seemed likely to contain information relevant to the issue of intimidation. Appendix A, pages A-18 through A-24, contains a complete listing of these l questions. All 120 respondents were included. Their responses were content analyzed into code categ5" ries 1
developed from initial inspection of a sample of questionnaires. As in the case of the 1983 questionnaire
- data, the responses were analyzed to determine whether either their pattern or substance reflected possible 19
intimidation. .
Concerning the pattern of response, the principal findings were: -
o The nonresponse rate was quite low; on the average, 92% of the respondents gave usable responses to any particular question.
o The overall pattern was positive; 78% of the responses were positive (favorable).
o Although the average favorability was quite high, negative opinions were submitted. Approximately one response in four,was negative.
o The most negative responses were to the most threatening items, not the reverse (which one might ,
expect fro'm a pattern of intimidation).
The conclusion, therefore, is 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 most of the responses would refer to issues 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" (a mixture of =iscellaneous concerns and complaints).
20
I i Perhaps an exception to this general pattern occurs for Question 2A ("How would you rate management support of QC?"): 285 responded marginal or inadecuate.
Information which perhaps explains or amplifies these responses on Question 2A came from an analysis of all written comments conceivably relating to intimidation.
Thirty-eight relevant comments of this type were submitted by 32 persons. An analysis of these specific comments indicated the acts of intimidation came almost exclusively from craft / construction, not from QA/QC management or supervision. A minority of these 32 persons also perceived QA/QC management had too often acquiesced to craft / construction, rather than backed QC.
3 2.2 Comparison of 1979 and 1983 Survey Results Consideration of both the 1979 and 1983 survey results j jointly presents some interesting similarities and contrasts. In neither year did the pattern 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. Significantly, that survey involved face-to-face interviews, rather than anonymous questionnaires, and was generally focused upon issues other than intimidation. If pervasive intimidation had occurred 21
= -_. -. - . .-. - - _ _ _ _ _ .
throughout this five-year period, it should have been more .
in evidence in 1983 than in 1979, simply because the 1983 for=at made it easier and safer to respond. This was not the case, however.
- The most straightforward explanation is intimidation in 1979 was felt to various degrees by a minority of persons, and it came almost exclusively from craft / construction. A minority of that minority perceived management too often acquiesced to craft / construction. This explanation would suggest, however, that the problems had all but disappeared by 1983.
The reason for this change can only be speculated.
Perhaps programs and actions by management to correct and prevent such instances had the necessary effect. Perhaps a shift occurred 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 i
electricians.
l i
Previously, in Section 3 1.2, the possibility was raised that even though few reported instances of l intimidating events were found, a climate of intimidation still might have been present. A plausible argument is that even a few cases of intimidation widely known
- throughout the organization might be sufficient to create a l
l climate in which people felt intimidated. If this were the 22 L
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. This was not 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 intimidation issues could be addressed easily, such statements had all but disappeared. Perhaps more significantly, neither survey revealed pattern responses among participants that would indicate they felt intimidated.
These two sets of survey data, taken together, reflect no indication of a pervasive climate of intimidation on the part of, or fostered by, management or supervision. At most, less than 10% of the respondents perceive management often did not take action on intimidation by craft / construction strongly enough or soon enough.
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. . - - - . _ - . . _ . . . . _ _ _ _ . . _ _ . . _ - - - _ . _ _ . . - - - _ . - ~ _ . - _ _
33 oI Investigation and Inquiry Reports In addition to the three NRC Office of Investigation reports discussed in the initial EG&G Idaho 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.
331 Inquiry Reports Seventeen' inquiry reports were examined by the Study Team. Of these, 15 reports were not 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 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 Inspection Program Q4-83-011 Alleged Poor Construction Practices 24
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 Construction Practices Q4-84-037 Alleged Threat of " Blackballing" a Former QC Inspector Q4-84-046 Suspected Harassment of a QC Inspector u.
The two inquiry reports which contained useful infor=ation for evaluating whether a climate of -
intimidation existed at CPSES are discussed below.
Q4-83-021, Alleged Intimidation of Electrical Craft Personnel. 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 personnel for fabricating and installing electrical conduit hangers. These personnel are alleged to be required to l read a 400- to 500-page technical manual, S-0910, the first day on the job and sign a form stating have read and understand Manual S-0910. A forty-hour training course is 25
given on the manual. However, since reading the manual is voluntary, unpaid, and off-duty, the alleger estimated that less than 35 attend the course and that most electrical personnel have inadequate working knowledge of S-0910.
The alleged intimidating aspects of this training ,
problem are the TUGC0 Work Sampling Group considers 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, some electrical personnel were alleged to have commented that they might commit acts of electrical equipment sabotage.
These allegations, although not specific to QA/QC, indicate a climate of intimidation may have existed in the Electrical Construction Department. In the opinion of the Study Team, the inquiry did not delve into the specific I~ 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 s"pervisory skills and management l practices in training, work sampling, and personnel relations.
26
Q4-84-001, Alleged Improper Construction Practices.
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 inspector caught the violations and stopped the work until the proper paperwork was obtained. These incidents are examples of QC acting independently, with appropriate authority, and without being intimidated.
Two other incidents alleged that workers were threatened with dismissal if they did not =eet production de= ands, and were told they were not to come back to work the next day if they did not finish a specific job. In neither instance did anyone lose his job. In the final incident, the alleger refused to violate procedures in signing off maintenance cards despite being instructed to do so by his superior. It was not alleged that the supervisor made any threats in this situation, and no adverse action was taken against the employee. In the i
l Judgment of the Study Team, these three events do not support a climate of intimidation.
i 332 Investigation Reports The NRC investigation reports generally went into considerably more depth than did the inquiry reports.
I
These reports are discussed briefly below, together with the conclusions drawn in each.
4-82-012, Alleged Electrical Deficiencies. A former Electrical Department worker identified four areas of ,
alleged deficiencies, which had purportedly occurred in the 1980 time frame:
o Using a 750 MCM lug that was drilled to accept a 1000 MCM cable in the circulating water system m,otor control center.
o Using the wrong size lug on a terminal block in the Reactor No. 1 Auxiliary Building.
o Using the wrong size lugs on terminal blocks in the Reactor No. 1 Switch Gear Room.
o 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 the above areas in August 1982 and found no improper wiring in any of them.
.!he implications for intimidation were apparent to the l study team in this report. g h-83-005, Alleged Improper Construction Practices, j A former CPSES supervisor provided allegations of improper
- practices and procedural violations in several areas of 28
mechanical and civil construction, including unauthorized cutting of rebar, overtensioning main steam line, using a cutting torch on hanger material, and failing 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.
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, and with replacing the deficient hanger with an acceptable hanger, 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 l
in the Inquiry Report Q4-84-007.
1 In the opinion of the 'tudy s team these allegations did not involve intimidation and did not support the existence of.a climate of intimidation.
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_ . . _ _ _ . _ _ . - _ _ . _ . . , , . - _ , __,._,,__,__,.__.__.m. _ . -.. .__ ._ , _ , , , . , _ _ , _ . - _ . - _ . _ , _ _ _ . , _ . _ _ _ _ . , - _ _ _ _ _ . - . - . _ _ _ , _ _ , _ , - _
4-83-006, Alleged Falsification of QC Records.
A QC inspector alleged that a signature had been forged on -
an NCR that had previously been an issue before the ASLB.
The former QC inspector who had identified the nonconforming condition and a former Quality Assurance ,
supervisor were interviewed. They testified that the NCR had been handled appropriately, and the investigation disclosed no evidence of forged signatures.
This report contained insufficient evidence to indicate intimidation or a climate of intimidation.
4-83-011, Susoected Falsification ci gC Recorcs.
A QC inspector ' alleged that records of some of his inspections had been altered or falsified. He suspected this had oeen 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 ins,ection personnel regularly helped this inspector by completing his paperwork. This paperwork situation was confirmed by a document control. center 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.
30
Upon reinterviewing, the inv,estigator found that the
, alleger had been unaware that earlier inspection practices permitted records to be copied. The alleger knew that i
- making copies was now a violation of procedures, and he had 1
assumed that reviewing supervisors must have improperly made the copies he originally alleged had been changed.
Much of the testimony developed in these interviews related to various other allegations that have been considered in other portion.1 of this supplement and in the original Study Team report.
1 a
As it relates specifically to the issue of intimidation, the study team concluded the data do not 3 indicate intimidation nor support the possible existence of i
a climate of intimidation.
l 4-83-016, Alleged Discrimination Against QC Inspectors
.i l The allegation was that a QC lead inspector was fired for for complaining in a meeting about intimidation by a supervisor and about lack of support for QC inspectors, and that this termination had an intimidating effect on the QC i
coatings inspectors.
J l
Much testimony and many depositions relate to this i
particular event with a clear difference of opinion between i management and the alleger as to the reason for his termination.
I 4
f I 31 l
i
The Study Team understands that the alleger attended a -
meeting of QC inspectors and supervision, the purpose of which was to have two coatings experts explain proposed i technical changes in coatings specifications and procedures. During the course of the meeting, the alleger ,
apparently spoke out regarding intimidation of inspectors and lack of support from supervisors. It is not clear to what extent these or other comments by the alleger were disruptive. However, it is not evident that any management action was taken during the meeting to respond to the alleger, to control his purported " disruptiveness,"
or to keep the meeting to its expressed purpose, if the alleger was in fact being disruptive.
i i
Subsequent to the meeting a counseling session was arranged with the alleger to discuss his behavior in the the meeting. During this session the alleger's employ =ent l
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 who attended the meeting to result from the alleger's complaining about intimidation during the meeting.
Consequently, the Study Team concluded that the incident could have had an intimidating effect on the l
l coatings inspectors by leaving them with the impression that complaining about lack of management support for l
l 32
inspectors could result in termination.
4-84-008, Alleged Intimidation of QC Personnel.
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 performing her work following her appearance before the ASLB.
Many management actions alleged to discriminate against her were, in fact, attempts to accommodate her special needs and produce a more agreeable work situation for her.
The company provided information on maternity benefits six weeks before her ASLB appearance as well as'approximately -
six weeks thereafter. Scon after her ASLB 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 a reduction in force rather than take a leave of 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 alleger's appearance before the ASLB. These incidents do not support the existence of a climate of intimidation.
33
4-84-012, Alleged Intimidation of Welding Crews.
An ironworker alleged that an ironiorker superintendent regularly threatened and intimidated his subordinates.
Interviews with fifteen individuals determined that seven either had personal knowledge of intimidation or knew of this superintendent's reputation as an intimidator.
In a specific incident investigated, the superintendent allegedly forced the ironworker to chip concrete in a room in which safety system welding was being performed. The study team feels this was probably a case of intimidation of the ironworker by the superintendent.
Regarding intimidation of QA/QC personnel, a QC inspector, when acvised of the problem, shut the welding job down until the chipping was stopped and the dust settled. This shutdown occurred despite its going against the orders of a superintendent known to many as an intimidator. This incident, while showing intimidation of a craftsperson, also is another example of a QC inspector acting independently within the authority of his role and without being intimidated by the crafts.
333 Conclusions From Investigation and Inquirv Reports ,
Analysis of 24 NRC Reports of Inquiry and Investigation resulted in four incidents providing some 34
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 o'ne (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 craft department; it was also an example of a QC inspector acting independently and using the authority of his role. A fourth report (Q4-83-021) dealt with craft intimidation by craft supervision, but did not provide enough information to determine whether intimidation actually existed.
Of the 27 inquiries and investigations, including the three used in the original report, a preponderance of allegations of intimidation were 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 who supported the claims of intimidation of craft by craft supervision. Hence, approximately 26 individuals, among a total of about 250 persons, supported claims of
! , intimidation of QA/QC personnel. Fourteen of the 26 were i
related to two specific incidents, the Dunham-Nitpicking l
S and Dunha=-Termination Incidents. Seven claims were unsubstantiated by persons other than the alleger, leaving i
! 35
l five substantiated claims.
Based on this analysis of OI reports, there did not appear to be widespread allegations, numerous incidents, a pervasive atmosphere of fear, or other evidence of a climate of intimidation at CPSES. The analysis of these .
additional NRC Office of Ir.vestigation Reports of Inquiry and Investigation resulted in no findings that modify the conclusions of the Study Team in their original report.
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34 Observations On Managerial Practices The Study Team stated in its discussion of management style in the September 1984 report (Section 3 3, pages 37-
- 40) that many factors contribute to individual performance on the job. Intimidation, or the existence of an
" intimidating climate," is only one such factor.
One problem that the Study Team faced in making its assessment was that organizations are complex mechanisms of interacting systems, procedures, and behaviors. This makes it illogical to assume any one factor can be isolated in drawing cause-and-effect conclusions. In the study of organizational phenomena, often the best that can be done is to show certain outcomes seem to be correlated with (occur in conjunction with) the presence of certain other factors. This correlative relationship does not' prove the existence 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 the Study Team to conclude factors contributing to the performance of QA/QC personnel at CPSES included the following items:
(1) their job skills and competencies, (2) their
! motivation, (3) levels of compensation and perceived equity of the co=pensation syste=, (4) structure of the organization including the effective management of 37 k
interfaces with other functions or departments, .;
(5) establishing and communicating clear standards-for .
performance, and (6) supervisory style. The Study Team feels that management issues such as these probably had an impact on the performance of work at CPSES.
3.4.1 Job Skills and competencies The data indicate a number of inspectors may have felt inadequately prepared to perform their work. The inadequacy of training and the poor communication between inspectors and management were clearly identified as areas of concern in the 1979 survey. In response to a question on " problems at CPSES,". technical training of inspectors was the second most mentioned item. In addition, in both the 1979 and 1983 surveys, some concerns were expressed about the lack of feedback on job performance. To the extent that inadequate jo'b training and infrequent feedback on performance are characteristic of a job, they can inhibit the development of job skills with a resulting impact on performance.
3.4.2 clear Performance Standards Closely related to the concerns involving job skills and competencies are issues regarding performance standards. In the surveys, depositions, and OI Reports, ,
concerns surfaced about the clar.ity of standards, the usefulness of some procedures, the frequent changes to procedures, and the seeming lack of consistent application 38 1
of these procedures. Procedures are obviously designed to
. accomplish certain re.sults. Hewever, when coupled with consistent concerns about communication, the procedures, or their usefulness and p"rposes, may not have been fully understood. Some evidence is reflected in the depositions and some of the alleged " intimidating incidents" identified, that inspectors were asked to perform operations without fully understanding what was expected and why certain procedures were to be performed in particular ways.
343 compensation and wage Inequities The perception that inequities exist in the administration of wage and salary programs and the general dissatisfaction w'ith compensation could have a demotivating effect on individuals and on the subsequent performance of g.
their jobs. This issue was the most mentioned item on the 1979 survey. Complaints about wages were also dominant in the 1983 survey. As an example, one complaint was inspectors working for different employers on the site received different wages.
i 3.4.4 Interface Management No doubt, multiple, complex, and difficult interfaces must be effectively managed in the CPSES environment. Some concern exists that these interfaces are a continual source of conflict and problems. These resulting difficulties are accepted as given in the situation, as a reality to be 39
i l lived with rather than effectively managed.
1 .
The entire body of the reviewed data points to cifficulties in the QC-craft interface. Complaints about j .
lack of cooperation, inability of management to deal
, adequately with these difficulties, perceived lack of QC .
1 1
management support of inspectors, problems with
- " personalities," and the impression that the craft
, personnel don't " understand the role of QC," all lead to I the conclusion that the interface management processes are
, not very effective. The interface between craft and QC is viewed as an adversarial one. Intimidation internal to the craft organization may have exacerbated the situation.
i j While the nature of the working relationship must include t
- checks and reviews by QC of work performed by craft, little i'
attention is devoted to improving or managing the interface i 9 to foster a more cooperative work'ing relationship.
- Managing these interfaces requires spe,ial skills and sensitivity, an ability to see the whole, and an understanding of the various nuances of personal and
- technical issues that arise.
i I
- Another factor influencing the interface between craft and QA/QC is the role and working relationships of the NRC which creats some ambiguity in managing interfaces among .
l the relevant parties. While little specific information exists on this subject, some comments in the depositions j and surveys indicate the NRC is a primary player and does i 40 i
1_____- __ _ .~ _.. _ . - _ _ _ ~ . _ . _ _ _ _ _ . . . _ . - _ . _ _ _ _ , _ _ _ _ _ __
influence the overall working relationship between craft and QC. As an example, responses to the 1979 survey indicate management was not clear concerning which issues the employees could legitimately communicate to the NRC, or whether they, in fact, encouraged such communication.
The Study Team concluded from the transcr. bed material and surveys that CPSES has significant interface management problems in the QA/QC area, and that these problems are worthy of attention.
3.4.5 Supervisory Style Another factor affecting performance is supervisory style. Some discussion of its importance is included in the September 1984 report. One of the factors discussed briefly was management philosophy, and how 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.
The supervisory methods used 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 are considered important requirements for effective functioning, and unquestioned loyalty and compliance are, 41
therefore, often demanded 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 management credibility. Accounts of management actions found in the transcribed material support the conclusion that this -
description is fairly characteristic of CPSES management.
The Study Team classified a number of events as intimidating, not because of management's intent to threaten people or cause them to act inappropriately, but because of the way they handled a situation or communicated with those involved (e.g., the Dunham Termination Incident, the T-Shirt Incident, and the D. Stiner Circuit Breaker Article Incident).
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 s
morale and motivation, and these factors may affect job
~
outoCmes. ,
In summary, a number of managerial practices exist 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. Some evidene,e exists that inspectors were asked to perfor= tasks without 42
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 prevailed 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.
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t l 43 i
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- 4.
SUMMARY
AND CONCLUSIONS Information reviewed by the EG&G Study Team after issuing their September 1984 report, " Comanche Peak Steam Electric Station: Alleged Climate of Intimidation," 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 reflecting information from allegers, managers, and related individuals focusing on specific
, incidents of intimidation. A summary of the findings and conclusions follows.
The number of alleged incidents of intimidation, allegers, and named inti=idators was small. Approximately 31 incidents, reported by 13 individuals, occurred between 1979 and 1984. A substantial majority were concentrated l between 1982 and 1984. Four individuals accounted for 21 of the 31 allegations. Of the 31 alleged incidents, only nine were judged by the Study Team to meet the inti=idation criteria. This is well within the number of events that would be expected to occur even under the best of circu= stances. This small number of incidents, while not .
eliminating the possibility that a climate of intimidation existed, falls short of positively establishing that such a climate did exist at CPSES.
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44
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 content analyses of the survey data indicated widespread knowledge of intimidation. At most, less than 10% of the respondents to the 1979 survey perceived management did not take action on intimidation by craft / construction strongly enough, soon enough.
NRC Office of Investigation reports indicated 26 people supported claims of intimidation of QA/QC personnel and 20.2 individuals refuted such claims. Analysis of these reports did reveal some isolated cases of intimidation, but resulted in no findings that would modify the conclusions 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 this was not the case, and failed to support the conclusion that a climate of inti=idation existed at CPSES.
Sc=e =anage=ent practices at CPSES, while not 45
constituting inti=idation, were of concern to the Study Team because they are generally not conducive to good job '
performance. Poor communications, inadequacy of training and infrequent feedback on performance were found.
Inadequate attention was* devoted to cooperation between QA/QC and craft, and a lack of clarity regarding -
appropriate employee interfaces with the NRC was 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 Reports of Investigation and Inquiry, and the analysis of the individual incidents alleged to have been intimidating all lead essentially to the same conclusion.
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These findings taken together lead the Study Team to reaffirm the conclusions reached in their September 1984 report. In the judgment of the Study Team the reviewed data do not indicate a climate of intimidation did, or l
does, exist at CPSES. -
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46
9 e
APPENDIX A 1979 MANAGEMENT REVIEW BOARD SURVEY ANALYSIS by DAVID G. BOWERS e
A-1
9 REPORT TO EG&G Idaho, Inc.
by David G. Bowers, Ph.D.
Research Scientist l
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February 19, 1985 A-3 Y Q L,'9 0 % 4 %pp.
- 1. .
INTRODUCTION This report contains an analysis of the responses of 120 persons to a survey entitled QC personnel Intervieu.
The survey was conducted by interview in 1979. As in the case of the 1983 survey results, previously analyzed, the focus of the analysis was whether there was evidence in either the substance or the pattern of responses of the respondents having been intimidated. The same definition of intimidation used in the earlier report was used in the present report.
As before, the possible patterns for which the data were examined were the following:
- A pattern of " false positiveness," that is, an overwhelmingly positive response pattern in combination with one or more of the following:
- An almost total a5sence of negative opinion.
- A high non-response rate.
- Morepositiveresfonsestomorethreateningitems.
- Skipping of items,[ especially more threatening items.
- Uniform intra-respondent positiveness.
- A pattern of prevalent negative opinion.
- A giustering of negative opinion within a significant minority of persons.
Specific comments suggesting intimidation.
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2.
ANALYSIS AND RESULTS The interview protocol employed in the survey contained 39 questions or sub-questions. Thirteen of these were omitted from the present analysis on the grounds that they were largely irrelevant to the issue at hand (e.g., "Have you ever seen an organization chart of QC at CPSES?") :
Questions la, b, c, e, f, g, h, 3a, b, c, d, e, and h.
The remaining 26 questions were those focused upon in the present analysis. Although there was some minor variation in wording across various sets of protocols, the wording of the questions was for the most part identical. Some of the questions were entirely open-ended; many posed closed-ended .
(i.e., fixed alternative) response categories. However, all of the latter presented space for comments of. elaboration.
In the remainder of this section of the report, the patterns listed above will be examined one by one.
Overall Response Pattern Table 1 presents basic response pattern data for the 26
, questions. The data show that the overall pattern was, t
indeed, overwhelmingly positive. On the average, 78.5%
of the' responses were positive (favorable).
l I
Prevalence of Necative Opinion Although the average favorability was quite high, the frequency of negative opinion was quite varied and ranged from a low of 4% to a high of 84%.
i Non-Response Rate On the average, 92% of the respondents responded to any particular question. The range of response rate was from a low of 77% to a high of 100%.
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3.
Table 1 RESPONSE RATES TO ITEMS Proportion of Question No. Responding Percent (of 120) Negative Responses
- 1. D1 106 88 --
D2 120 100 .78 I 114 95 .25 J 115 96 .37 K 117 98 .12 L 98 82 .09 M 107 89 .12
- 2. A 94 78 .30 B 111 93 .12 C 111 93 .10 D 114 95 .07 E 104 87 .05 F 112 93 .12 G 113 94 .19
- 3. F 108 90 .10 G 110 92 .17
- 4. A 115 96 .08 B 117 98 .22 C 118 98 .16 D 113 94 .18 E 112 93 .13 F 117 98 .44
- 5. A 120 100 .84 B 106 E8 .51 C 92 77 .04 D 108 90 .04 A-6
4.
More Positive Responses to More Threatenine Items As with the 1983 survey, the questions were classified into Most, Medium, and Least Threatening categories.
Table 2 presents basic data by category and indicates which questions were classified into which category.
Comparisons to the 1983 data are included; however, it should be noted that the 1979 High Threat items approximate, in severity or tener of wording, those of the 1983 Medium Threat category. (See Table 3.)
The principal points are the following: 6 There is a lower favorability response percentage to High Threat items in 1979 than in 1983.
- There is a louer favorability response percentage to Low Threat items in 1979 than in 1983.
l The Medium Threat percentages favorable are almost identical in the two years.
- The overall average favorability response percentage was 78.5 (versus 77.5 for 1983).
- The conclusion, therefore, is that the two years were about the same, with 1979 showing a greater tendency to respond favor,tbly in the Medium Threat category.
- The different fo:rmat of the 1979 survey (i.e., often open-ended, versts 1983 all closed-ended) led to a greater prevalenca of neutrally-worded questions. The l greatest prevalence of neutrally-worded questions was in the High Threit category (88%), next highest in the Medium Threat ca tegory (64%), lowest in the Low Threat category (43). Positive-wordedness runs in the reverse direction (0, 27%, 57%).
A-7
Tabla 2 .
1979 SURVEY -
QUESTIONS CLASSIFIED BY LEVEL OF THREAT .
Most Threatening Items N Favorable ID2 26 2A 50 2B 95 2C 93 7 worded neutrally -
2D 103 1 worded negatively 2E 40 2F 62 4C 94 Mean = 70.3 Percent (of 120) = 58.5 Medium Threatening Items N Favorable IL 74 IM 80 2G 84 4A 102 4B 80 w rded neutrally 4D 94 1 w rded negatively 4E 92 3 worded positively 4F 59 5A 91 5B 49 5C 86 Mean = 81 Percent (of 120) = 67.5 Least Threatening Items N Favorable IDl. (Inapplicable)
Ii 73 Ij 68 Ik B2 3 worded neutrally 3F 102 4 worded positively 3G 74 SD 50 Mean = 74.8 Percent (of 120) = 62.3 Comparison to 1983 1979 1983 Most Threatening 58.5% 79.5%
Medium Threatening 67.5 66.7 Least Threatening 62.3 83.3 A-8
Tabis 3
~
I:IM5 3r CTCM2 Cr "HP :C un versus 1sa: 6.
un - aigh hreat 1sa - aig . ~r.at
- .*. What makes yt: t feel tru zahr.able about yam job? 2. Do yut feel rabctant to approacft pur irrwitata rqar-v2.sor wath tac r.acal ;r:blems?
2a. acw woulf ycu rate an:ugunant sw . cf QC7 4. 23 yua feel eat upper managerum Cu Pas a hostila =r m:=mplimentary at 1=a:ia tourd ir.rpec-isn perscermi?
2b. How would you rata yar s.partim:r's am of your 9. Do yua feel that by procat..-s yua are f.a . Lad discreti:n, ac-avittaa? sound jusqueen., or ccrec:t sarse & =w.s in your inspec '.ons?
. 2c. acw well does your age: visor ace.ar your ques"cas? 10. Do you feel that agarrisica was yaa d. Lac =eti=n scund jts'.garse.t, cr ccreen sense * ="4 in your inspec-4=rs?
- 21. Ecw avallanla is ya= superrimsr *mt you amm! him? 11. On yut faal craft constantly canomals da.fmets fran CC?
2a. kw effectively dcas ya= sper. tact advise you of pur 12. 23 yua *eal that Cra*: p=posely atm to violata irspec.:.cn ac-avstems in a ti::aly ser.nar? proemhmus armi da%n doc:.:mants?
- 22. scw wil does a:nstr.ction p:wida you with advance rsstifi- 14. nave you evs baan t:sid by your e.:r et r:partisor :=
caticrt ci ac ivities W.ica ruguire 3l: m: sport? accept samening yua felt us re;ectaa.e cr gasticra:la?
4c. Do yu:
- mal you are shject to ammansive pressures from ccrat=uc.icri *.ila dcang pur inryactions?
1979 - sendisaa '5 treat 1983 .h :hreat II. acw adurasta is em accpe of ya f -" == ? (soplain 1. Do yua
- eel that pz: 1:rradiata st a visor (ret laad) wae.ar it is tz:o anall, too much, ..et=.) prevides adagante technical backim t:s your irspe:-acrt M e4rwgs?
- L Ikw adagate is em escrasis on ac-4vitias that have a 13. Ds you usually tr.tst wat journefnen an2 hranen rela a beartag on qualir/? (T::o ana:h, or ret artma;h) (Are we to ytaa abcnt 0: rat:rac imn activities?
Iccaitur at act;vities that are trivial, too nas:h?)
M. Ikw was1d you rata the ccrai.starcy of par sparviscr's LE. Do you feel ym:r r.argentiana are ignored or given rd.cr 4=r = "*m ? attantion?
4a. 22 you feel yaz have enough time to par *ct=t your inspec"cns? 13. Os ygu feel that est::inistrative .='-ies c= sate a sustrictive attittsda?
4b. Bo., was1.1 you rata yez:: wzkimed? 13. On ycu feel that ycu may have to writa a 2:n:=:r.f:c a ce w to get your comer =s in frer:t of maragenerst !=r ac. inn?
4d. !kw woul.2 y:u rata erai-rmet realla.bi.lity t:s surfor:
your irsps:.icra or ;ch?
4e. So. w:uld yua rate the aut?crity given to you to parfaz=t your inspe:tims?
4f. Who &s pu *eal bears the ulti:sta resp:naibility *ar your irs;me acra? :Jante._*yt Sa. What &s yas feel are the sm or prus1m:s in QC at CPSI5?
ib. What do pu feel is an adaqants schmien to these probla.s?
Sc. Do su feel eat yas have adaraa.a w .icaticri with e.a ccastr;rtian !=ruman trat you ctre M contact with?
1S79 - Du trust 1983 - icw ht
- 31. WPat anxas ycu feel ccz:d:rta:Le akcu yaz job? 3. Do ;n:u have ccr. fide ce that your sqe:vas:: will purr a prtcle a you su:r.it tas car:t eat retai:s .=e :
ressluacn?
- 11. Ecw ader ata is t:'e ird:=at.;::rs ;;.am. =s yas ::s ,23 per ::.::? 5. Da pu ccr.s; Jar pesa!.i battar gaalified e.an craf t?
I;. h rea .:.n;tal are ya:: ;r r =r' -ss? *av= 4 ' = - '
- rf, 6. Ds ;wu trz'.arstani c.e pse =f rarncrm; activttaas?
m'.a.stsnia ::.;if)
- x. h rean:nghi are ; cur 1..s:sta=n plars or e.acxiists? 7. Ds pa .:ruiarstard ce f.ireca:ns ca . are ;;ve 1 t'y Tr.:
- .rtnadiato r.:pa:v:.scr?
2!. h adegaata ars exa:.; rata :".s 4tr. 6 o em jan pu 8. De pu feel e.at es irmemett:n :.r.5 r;:asna p;rrida acraail/ pe::f:r.? cimar am adoraats 11_wr.;:ns?
3g. Da ;eu feel em
- n t m ;ce traar.;:1; is adoraate f:r em 13. :o yt:u haw ;rtf assa:ral resN f:: 0:3.f t r =e:v a;:n?
ars;me ;mn es: ;ia:at.:.cn ; .J
- 54. 23 ,cu an;;f :C :.nspecar: .crt? U Ds p u feel p ha.e adsmate e s tm ef MM Of
?.:.alarf Maraceu .t?
A-9
- 7. .
- There were slight item referent differences among the three threat categories: High Threat items referred largely to job and to organizational issues; Medium
~
Threat referred to job, organization, supervision, and craft. Low Threat items referred to job and organi-zation. The whole 1979 survey was much more job-general focused than was the 1983 survey.
Substance of Written Comments Any comments or responses even remotely suggesting fear or intimidation as defined in this analysis were recorded verbatim. They are presented in Table 4.
In all, 41 responses were extracted as possibly reflecting intimidation. Three of these were either non-specific or referred to other issues (catering to NRC, " errors in inspection reports," pressure experienced previously, when employed in craft).
All of the remainder occurred either in response to manage-ment-oriented questions (18), or in response to craft /
construction-oriented questions (20).
All responses with possible management or supervision implications were found in response to questions id(2) (one response), 2a (15 responses), 2b (one response), 2g (one response). For these 18 responses, three referred to craft /
construction only; four referred to management only; 11 referred to management acquiescing to craft / construction.
Those referring to craft / construction were all found in -
response to question 4c (20 responses). None of the 20 contained references to management. Four respondents appeared A-10 l
4 Table 4 RESPONSES SUGGESTING INTIMIDATION Questionnaire Question Number and Evidence j J8 Ij. Ilow meaningful are your procedures? (availability, understandability) l "TUGCO says don' t worry about - don' t document anything - find somebody who's worried about. Tried to put in repas, said he wouldn't sign off on anything wrong so they put him back in ead. T. catering to the NRC -
what we say and do are dif ferent."
F4 II. Ilow adequate is the scope of your inspections? (explain whether it is too small, too much, ..etc.)
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t
" Errors in inspection reports."
l C5 2a. Ilow would you rate management support of QC?
" Construction has too much influence. Would like to know who " buys off" some of the placement."
D3 " Infighting-between construction /QA."
i D7 " Document control personnel do not want to help unless you're a friend."
p E2 " Poor overall construction-get the hell out of the way."
i F6 "TUGCO has an excellent support programs for Q. Ilowever, sometimes they are hesitant to take strong action against construction activities to provide required 0."
F7 " Construction gets what they want. They don't fix the problem."
G2 " Problem with construction people because we wouldn't accept something, construction came to our management and being overruled. In some cases material control problem - QC transferring heat l's they did not want QC to transfer heat is - wanted them to disregard part of procedure -
verbal order from llawkins - not documented - in of hangers - looked bad." '
G7 "...QC inspe/ craft Gen. Foreman-problem with craft pers __ __ Craft Gen.
Foreman threatened to whip everybody-QC inspe. requested rights-lie's quit now-Gen. Foreman still here. Ilas made threats to life-QC management
{ should have backed QC Inspec. General Foreman-welder popped him in eye l and not fired-Gen. Foreman still." p G9 " Foreman don't know procedures. Construction oriented job. Will do anything to get around 0."
G11 " Construction has upper hand over QC in this particular job. (Ex. procedures come out until craft is told to implement them QC finds out about new procedures."
Questionrnire Question Number and Evidence 2a. Ilow would you rate nurnganent support of QC7 G17 " Plenty of support as long as oormtruction is not held up."
G34 "QCI doesn't feel marngement supports then, but rathbr supports wnstruction (crafts) i people wlo nake waves are no longer here. Get the construction done is the Oxsne."
G39 " Supervisor told Inspector if a thickness below min. by 2 or 3 use good judgement. But don't record good jtglgenent."
G52 " Clarke and Itawkins don't stand behind field QC. Tells QC thirvJs onit problans when QC feels that there are such, as bad marks on pipe."
I4 "Oonstruction ins upper hand over QC; wiele site is prodtotion oriented over quality.
No consistency-sone weeks ' Live by production', others 'get production regardless of quality'."
2b. Ilow would you rate your supervisor's stpport of your activities?
L6 "llas been' stepped on' by managanent."
[ 2g. Ilow would you rate the wnsistency of your supervisors decisions?
II6 " Supervisors threaten inspectors with overtime. Gives it to sane an1 won't give it to others."
! 4c. Do you feel you are subject to excessive pressures fran construction wl.ile doirvy your inspections?
D1 " Inspection threatened on site. (Ouck Irdy) 3 nos. ago (or 4) arvi as recently as 3 wks. ago by Geo. Planirvj. Ile was in a fist fight with a welder 3 wks ago. Gereral forunan - langer tab stop (Geo. Planing) llis son went to welder's louse-threateral him with a gun."
16 " Changing report."
E2 "tbt if you don't allm it - lxntd of inspector being threaterni."
HS " nut personnel are frecpontly lesitant to resporv1."
F6 "Ifpper const. nymt. tried to Inve man fired for holding up po6r when 6 antnis were w missed. Ilas lnd life threateixx1 by construction general forunan." -
P12 " Pressure was applied sone time back but row it's better."
t m_
! Questionnaire Question Number and Evidence
(;9 4c. Do you feel you are subject to excessive pressures fran construction while doing your inspections?
G9 "'Ibey raise ' Sam 11111' alxut QC not buying off work. Very of ten."
! GIO "At time Ibbbie Robinson (Gen. Foranan) physically threaten him. assignal to him-you went to nights-told it would be taken care of-but never told alout resolution.
Silverborne? hmel.-went all tie way putting on hold tag-start kickf ry ass-put on l nights-General foranan still there."
G13 "Different times different craft supervisor you feel pressure. BR is more construction oriented than quality oriented definitely."
G28 "Sometimes yes, gives than supervisors phone nunber and walks away. Problan solved."
G33 "Ticy try though."
G39 "J.ll. said we have too many inspectors we are going to have to get rid of sane."
p G52 "But they do try."
b 19 "Paula cited incident with Glenda. Glenda told him he couhin't do sonething. Ile (Jim Smith) get mad, came and lif ted her up-was rude, said something he simuldn't have said. Ile is not like that anynore. Ile doesn't sixw any disrespect anymore.
Five to 6 people knowing about it. 'llas blown confidentiality. Sie is worrial."
J7 "S'IP-inspec. were int., beat up, and for 5 mos. didn't do any insp."
K1 "During Jan., Feb., March there was excessive pressure-definitely."
K4 "Not excessive, but there is pressure."
1 i.1 " Franklin direct all pkgs together, if he working on they'll get him alone."
f.6 "Did previously."
In "At times."
i O
e
Questionnaire Question Number and Evidence D2. What makes you feel uncomfortable about your job?
G17 "One craft supervisor threatened OC inspectors. Craft thinks OC is against them."
This response is not to a question, but is a note at the bottom of page 11 G4 "When in craft-short cuts were taken from pressure-he has changed his opinion-knows where to look also. His general foreman put pressure-he had no choice but to pass pressure on to those working for him."
>e H
A a
t' H
9 9
8 9
12 in both the " craft / construction" and " management" lists.
In addition, two persons gave responses on more than one item. A totill of 32 persons gave such responses, therefore.
H0 wever, the two lists are relatively independent.
By work group, the distribution of all respondents giving such responses is as follows, with percentages of total questionnaires indicated:
% of Group N of Respense Respondents C 1 25 D 4 100 E 3 75 F 5 38 G 17 39 E 1 12 I 1 10 ;
J 2 18 .
K 2 15 L 3 27 .
Selective tests of differences bet'aeen independent proportions were done among extremes And adjacents. In general, what they showed were that the groups ftell into two .
clusters:
Composite t '.
Groups D, E, F, G (High Frequency) 44 Groups C, E, I, J, K, L (;.ow Frequency) 19 ,
Clusterine of Necative Opinion The analysis of written co:mner.ts reflecting possible intimidation suggests that negative opinion was, indeed, clustered within a significant minority of persons.
Thirty-two of the total of 120 persons gave such respenses.
l A-15
- 13. .
DISCUSSION AND CONCLUSIONS As was the case in the 1983 survey data, the pattern was positive or favorable overall, and by about the same '
proportion. Approximately one respondent in four was negative.
There was not, therefore, an absence of negative opinion. In
- addition, the response rate was quite high, nearly as high as in 1983, despite the somewhat more threatening format of the face-to-face interview.
On other issues of the pattern of response, the ! scat favorable response was to the most threatening items, not the other way around, as one might expect from a pattern of intimi-dation. As in 1983, there was no prevalent pattern of skipping or not responding to items, even more threatening ones.
However, the latter may be of reduced significance, given that a face-to-face interview demands at least some response.,
Finally, negative responses seemed to be broadly scattered.
One would conclude, therefore, that the pcteern of response does not suggest intimidation.
The substance of responses is another matter. Since the 1979 survey, unlike that in 1983, was not focused upon the issue of Latimidation, one would expect that most of the responses wocid refer to issues other than that, and, indeed, that is the case. With one exception (question 2a), the questions eliciting the least favorable responses had little to do with # ear and intimidation. However, on question 2a
("How would ycu rate management support of QC?"), 28% responded marginct or inciequate.
Perhaps information m:re directly relating to the issue of fear and intimidation came from an analysis of written A-16
14.
comments. Thirty-four of the 38 relevant comments involved intimidation coming from craft / construction. Of these, 11 also involved the perception that management acquiesced to craft / construction and did not back CC.
The conclusion, therefore, appears to be that, in the eyes of a significant minority of these respondents in 1979, there was, indeed, intimidation. It came almost exclusively from craft / construction, not from management or supervision, but in a sizable minority of cases involved acquiescence by these latter persons or groups.
4 A-17
APPENDIX A OVERALL SCORES FOR 1979 CPSES QUESTIONNAIRE INTERVIEWS N = 120 ,
I DI Mnt unkes yol feel ocanfortable about your job?
Godes: 1 Fornni preparation received (tests / certification, experience, enough backgrourvl, etc.)
2 Irviepenlence arxl Responsibility 3 Does or doesn't (qualifled) 4 Self-confidence / personal notivation 5 Miuwjonent (positive) 6 Other (comfortable, good people, security, answers, plenty of work, good working corvlitions)
Scores: 1 = 44 2 = 11 3=0 4 = 16 5=4 6 = 31 D2 Mut nnkes you feel unocunfortable about your job?
Oxles: 1 Money 2 Iack of formal preparation 3 C6nflictiary directions, lack of clarity 4 Argtanents, etc., frun craf t/ construction
> 5 Maruganent (negative) b 6 Other (inadequate supervisor, contact with people, turnover, snide ranarks when not busy, no privacy, responsibility delegated without authority, pressure to give to United Ptn], discipline omloyees, nore variety in job, pass the buck to QC, job security, sex discrimination, poor aiut unent, t layoffs, always behind) 7 Iack of self confidence -
8 Safety 9 Morale
- 10. Iliring procedures ,
Scores: 1 = 16 2=6 3 = 26 4=9~ 5 = 19~ 6 = 39~- 7=2~ 8=1 ~
9=0 - 10 = 1-Deviations 3&3 = 2_ '4s6 = 2_
4
e OVERALL SCORES CONTINUED I i IN adequate is tle information given to you to do your job?
Oiles: Irwiequate (I) Marginal (M) Satisfactory (S) Good (G) Excellent (E)
Scores: E=4 G = 27 S = 42 M = 22 I=6 tm = 6 M&S = 1 S&G = 2- I&E = 1 ILS = 1-M&G = 1 I&M = 1-
~
j Ikw neaningful are your procedures? (availability, urxlerstarvlability)
Codes: Sane Codes as i_. above Scores: E=6 G = 37 S = 25 M = 23 I = 18 NA = 1 S&E = 1 I&G = 3 M&G = 1 k Ilow neaningful are your inspection plans or checklists?
Otries: Same codes as i_ above Scores: E=7 G = 46 S = 29 M=7 I=7 tm = 21 1 Ilow adequate is the scope of your inspections? (explain whether it is too snall, too noch, ...etc.)
>a e Codes: Same Codes as i above e
Scores: E = 12 G = 39 S = 23 M=7 I=2 NA = 13 I&G = 1 Vary (V) = l_
m Ilow adequate is the enphasis on activities that have a bearing on quality? ('Ibo inch or not enot 3h)
(Are we looking at activities that are trivial, too much?)
Codes: Sane Codes as i_ above Scores: E = 15 G'= 43 S = 22 M = 10 I=3 NA = 11 G&E = 1 M&S = 1 M&G = 1 w
OVERALL SCORES CONTINUED
- 2. a Ilow would you rate management support of QC?
Codes: Inadequate (I) Marginal (M) Satisfactory (S) Good (G) Excellent (E)
Scores: E=6 G = 18 S = 26 M = 24 I=4~ NA = 5~ DK = 4 ~
NC = 1 ~
M&S = _2 S&G = _2 I&S = _1 ,I&E = _1
- b. Ilow 'would you rate your supervisor's support of your activities?
Codes: Same as a above
~
I 1
Scores: E = 47 G = 38 S = 10 M = 12 I=1 DK = 1 NA = 1 NC = 1
- c. Ilow well does your supervisor answer your questions?
Codes: Same as a above Scores: E = 39 G = 38 S= 16 M=6 I=5 NA = 5 DK = 1 I&E = 1
- d. Itow available is your supervisor when you need him?
g, Codes: Same as a above o
Scores: E = 46 G = 34 S = 23 M=7 I=1 NA = 1 M&S = 2
- e. Ilow effectively does your supervisor advise you of your inspection activitics in a timely manner:
Codes: Same as a above Scores: E = 16 G = 15 S=9 M=3 I=2 NA = 58 I&G = 1 I&S = 1
[. Ilow well does construction provide you with advance notification of activities which require Oc support?
Codes: Same as a above Scores: E= 13 G = 30 S = 19~~ M=5 -
I =7~
NA = 33-I&M = 1 ~
M&S = 2 ~
S&E Tl I&E T 1 9 Ilow would you rate the consistency of your supervisors decisions?
Codes: 1 = Very consistent 2 = Good, Satisfied, Consistent 3 = Inconsistent Scores: 1 = 20 2 = 64 3 = 20 M= 1 NA = 5 DK = 2 NC = 1 0
0
o OVERALL SCORES CONTINUED j 3. f. Ilow adequate are examinations with respect to the job you actually perform?
Codes: Inadequate (I) Marginal (M) Satisfactory (S) Good (G) Excellent (E) l Scores: E = 20 G = 38 .S= 16 M=7 I = 4 NA = 23 i
l
- q. Do you feel the "On the Job" training is adequate for the inspection certification program?
Codes: Same as f above Scores: E= 13 G = 25 S = 12 M=9 Yes = 17 I = 10 NA = 24
- p
- I BJ H
I I ,
b
OVI2mt.T SODRFS 00tfrINUED
- 4. a. Ib you feel you have enough tine to perfoin your inspections?
Oories: Yes (Y) tb (N)
Scores: Y = 102 N = 9_ Vary = l_ Y&N = 1 Smetimes = 1 in = 1 ,
- b. Ilow would you rate your workload?
Godes: Light (I.) Enough- (E) Too thch ('IN)
Scores: L = 12 E = 68 'IM = 26 Vary = 6 INIM = 3_ EE'IM = l_ L&E = l_
- c. Ib you feel you are subject to excessive pressures fran construction while doing your insp(x:tions?
Ocxles: Yes (Y) No (N)
Scores: Y = 19 N = 94 PM = l_ Y&N = l_ Sonetims = 3,
- d. Ilaw would you rate equipnent availability to perfonn your inspections or jobs?
Godes: Inadetplate (I) Marginal (M) Satisfactory (S) Good (G) Excellent (E) y Scores: E = 21 G = 32 S = 20 M = 9_ I = 11 NA = 20 w :
N e. Ilow would you rate tJe autinrity given to you to perform your inspections?
Coles: Same as d above Scores: E = 26 G = 42 S = 24 M=8 I=6 NA = 6
- f. Win do you feel bears the ultimate responsibility for your inspections?
Ccxles: 1 = Self (with or without others) 2 = OC Supervisor 3 = Icad Inspector 4 = MaruwJunent/0wner 5 = Site ervjineer (G&II)
Scores: 1 = 59 2 = 31 3=3 4 = 16 5=1 ta = 5 1&4 = 1 2&3 = 1 4 O v
OVERALL SCORES CONTINUED
Codes: 1 = Monetary policy (or pay, pay scale, etc.) I 2 = Turnover 3 = Morale 4 = Miscellaneous organizational conditions 5 = Working Conditions 6 = Safety 7 = Fear, intimidation, etc.
D.= Procedures 9 = .Toba - openings, progression, etc, selection, programs 10 = Inadequate job proficiency 11 = Craft foreman pressure; ignorant of requirements 12 = Communication between departments / management 13 = Construction pressure / quality 14 = Bad Press Scores: 1 = 50 10 = 23 2 = 10 11 = 8 3 = 25 12 = 21 4 = 40 13 = 5 5=6 -
14 = 1 6=6- 7=2~ 8 = 25 9=5 T
9
- b. What do you feel is an adequate solution to these problems?
w codes: 1 = Change monetary policy 2 = Change job progression, hiring, etc.
3 = Change pay or pay policy 4 = Training 5 = Treat employees better 6 = Formal systems (print rules changes, rules & requirements, etc.)
7 = Change organizational or supervisory practices 8 = Stop constant turnover 9 = Improve safety 10 = Improve working conditions Scores: 1 = 18 2=8- 3=7~ 4 = 15- 5=6~ 6 = 18
~ 7 = 29~- 8=2- 9=1~
1 0 = 7_ NA = _1 O
. ine m. . . _ _ _ _
)
OVERALL SCORES CONTINUED
- 5. c. Do you feel that you have adequate communication with the construction foreman that you come in contact with?
Codes: Yes (Y) No (N)
Scores: Y = 86 N=4 NA = l_ Y&N = 1
'I . Do you enjoy QC inspection work?
Codes: Same as c above -
i Scores: Y= 102 N=4- NA = 1- Y&N = _1_
i l
- p to
- m l
l l
y O
e .
S O
r e
. APPENDIX B SUMMARIES OF ALLEGED INCIDENTS OF INTIMIDATION t ,f f-
..,e f
,o r
/
/
3-1 f
SUMMARIES OF ALLEGED INCIDENTS OF INTIMIDATION 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 tbe Study Team judged to actually be intimidation.
TABLE B1 ALLEGED INCIDENTS OF INTIMIDATION Year Alleger Incident 1979 Messerley Foreman Intimidating QC Inspector 1980 --------- --------- (no alleged incidents) 1981 H. Stiner Termination
- D.~Stiner Circuit Breaker Article D. Stiner Office Relocation D. Stiner Meetings Related to Pregnancy l D. Stiner Harassing Letter D. Stiner Weld Symbols Miles Nor'th Valve Room 1983
- Dunham Intimidation of Coatings Inspectors B-3
Dunham Termination -
- Ne meyer Liner Plate Traveler Allen Job Interview
Allen Craft Foreman
- 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 l Gregory Reduction of Force (ROF) l
! * --------- T-Shirt Incident Hamilton Refusal to Inspect Coating Krolak Shelton Summaries of each of these incidents are presented in the ,
remaining pages of this appendix.
B-4
1979 - R., Messerley - Foreman Intimidating QC[ Inspector Mr. Messerley claimed that a QC inspector was verbally and physically intimidated by a muc.1 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 1 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 Study Team, Mr. Messerley's allegation regarding the red tagging intimidation incident was not proven. ,
i 1981 - H. Stiner - Termination Mr. Stiner alleged that hs was fired for reporting a gouge in a pipe to a QC inspector, Ms. Neumeyer. The weight of l evidence, including the ASLB Memorandum on welding issues f of December 18, 1984, appears to support the applicant's assertion that Stiner was terminated for absenteeism. The l Study Team does not believe this incident met the criteria i
! B-5
for ir:timidation. -
1981 - D. Stiner - Weave Welding on Pipe Support 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 o.n a hanger provides some support to her allegation. No specific instances of weave welding violations were i substantiated. However, Ms. Stiner could have felt a lack i
of management support or even threat in this alleged j
incident. The Study Team has, therefore, classified this as a possibly intimidating event in that the threats and lack of management support, if they in fact occurred, were reasonably likely to have influenced Mr. Stiner to refrain from performing work in accordance with requirements.
1981 - D. Stiner - Diesel Generator Skids Ms. Stiner, a QC inspector, alleges she was harassed and intimidated by her supervisor when he assigned her to t
l conduct inspections on welds on the diesel generator skids, 1
even after she protested that she was unqualified to conduct these inspections. The preponderance of evidence B-6
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 by the Study Team to be an incident of intimidation.
1981 - p. Stiner - Polar Crane'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 box was found. This NCR was voided appropriately because.
the bus box was non-Q and outside the scope of the QA program. The Study Team does not consider this to be an incident of intimidation.
1982 - p. Stiner - Circuit Breaker Article Ms. Stiner testified at a public ASLB hearing in 1982.
Although her testimony had received wide publication in the local press, the applicant focused unfcvorable attention on l
l Stiner through an article in the site newsletter, the
- j. " Circuit Breaker." As a result of this article, Stiner I
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 l
B-7 i
L
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 managemero 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 was a significant event of inti=idation 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.
1982 - D. Stiner - Office Relocation Ms. Stiner claims she was harassed by being moved four times over a two-day period and finally being placed in a B-8
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 deficiencies 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 - D. Stiner - Meetings Related to Pregnancy 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 before the ASLB. In fact, it appears that the company provided information on maternity benefits six weeks before her ASLB appearance and approximately six weeks after, for a total of only two meetings. There is a lack of corroborating 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.
B-9
1982 - D. Stiner - Harassing Letter 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. Stiner - Weld Symbols 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.
1982 - S. Miles - North Valve Rocm 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 B-10
to stop the work, then returned and ignored the are gouging o 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 pr;vided 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 that intimidation was involved in this incident.
1 1983 - W. Dunham - Intimidation of Inspectors - Nitpicking 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 1
pulling their certifications if they were found repeatedly l
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 i
j and, in fact, were interpreted by some QC inspectors as instructions not to inspect in accordance with procedures.
Willia =s later cenceded that his statements could have been viewed as inti=idating even though that was not his intent.
B-11 1
1
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 incident meets tne criteria for being judged as an ,
intimidating event.
1983 - F. Dunham - Termination 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 these or other Dunham comments were disruptive. However, it is not evident that any management action was taken during the meeting to respond to Dunham, to control his purported i
! " disruptiveness" or to keep the meeting to its express purpose, if Dunham was in fact being disruptive.
1 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 ter=inated, 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.
B-12
Regardless of the facts regarding Dunham's conduct in the o 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 - S. A. Neumeyer - Liner Plate Traveler Ms. 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 requirements. Thus the Study Team concludes that this incident meets the criteria for being intimidating.
1983 - C., Allen - Five Alleged Incidents Mr. Allen was hired as a coatings inspector despite having significantly more education than was recuired for that position. He has an undergraduate degree in chemistry and a master's degree in polymer chemistry.
B-13
1 -Job Interview 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 is not viewed as an intimidating event.
2 - ALARA and DCA Reviews Mr. Allen raised questions about ALARA reviews and Design Change Authorization (DCA) reviews to the training coordinator, who was unable to answer the questiens 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.
1 - Craft Foreman 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 mana5ement, Allen, and Allen's supervisor. Brandt formally responded to Allen's complaint as follows: "This type of B-14
l harassment must cease. Construction has assured us that
, they will implement corrective actica (as necessary) immediately. 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 believe that a reasonable person would have been intimidated under these circumstances.
4 - Detergent On Painted Surface 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 criteria for intimidation.
5 - Cigarette Filters Mr. Allen learned that cigarette. filters were being used by painters in the cheater valves of spray guns to assur,e passing the air acceptability test. Mr. Allen was dissuaded from writing an NCR because his management felt the use of cigarette filters was not a violation of any procedural requirement. Management also felt that final inspections would pick up the presence of oil or water in the paint. The Study Team assesses this event as having been intimidating because apparently the cigarette filters should not have been used and an NCR should have been B-15
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.
j -
1983 - 12. Barnes - valve Disk Incident .
Ms. Gregory, a trainee, is purported to have brought a traveler to Ms. Barnes which had a disk number that did not match the disk number in the Data Report. It is alleged
.; that Barnes' supervisor, Mr. Bennetzen, told her it didn't
?
matter and would cost too much money to check. Finally, t
Gregory was purportedly told by Barnes that she could sign the documentation off if she wanted to, but that Barnes wasn't going to. Despite this statement, Barnes alleged i
that Gregory signed off the traveler. Gregory did not provide corroboration of this event. The Study Team I concluded that this incident was not substantiated as an instance of intimidation.
} 1983 & 1984 , Witness"F" - Several Allegations
\ -
l This witness provided a number of technical allegations.as
, prefiled testimony shortly after he quit his job at CPSES.
t
- The witness also stated he had been subjected to harassment j and intimidation by bringing his concerns to his supervisors and others. Witness F described five incidents .
which he believed were examples of intimidation or threats against him, as follows:
i B-16
-, . , , _ , , - , , , , , . . _ . . - ~ , , , - , , . - _ _ . _ _ - - . - , . . . . - - . . . , , . - _ , _ - - . - - - - , - , - -_ -.._ , . - - -------. , - - -~- - - - - --,-
9 1 Building Manager Threat Over SWA - 1983 Witness F alleged a TUGC0 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 there was an inconsistency between ES-100 and and Regulatory Guide 1.75 (RG-1.75). The witness, after having agreed to sign the SWA during a meeting where the procedural problems were resolved, then refused to do it until he received further technical information on the subject from Gibbs & Hill in New York. The position of management was that established procedures permitted signing of the SWA prior to resolution of the technical issues. This position appears to have been correct and the ensuing disagreement should not have discouraged the
)
witness from performing his job properly.
2 - ES-100/RG-1.75 conflict - 1983 Witness F alleged a startup manager tried to discourage him from calling the NRC on the ES-100/RG-1.75 conflict.
It appears that management preferred to resolve the technical matter in-house prior to any notification of the NRC, and was pursuing resolution of the witness's concerns appropriately in accordance with established procedures.
The Study Team concluded Witness F was not intimidated by management from calling the NRC on this matter. In fact, the witness admitted he continued to call the NRC, Region Five, regarding ES-100.
B-17
l 1 - Threat Tcl " Pull Your Chain" - 1984 Witness F alleged the project electrical engineer threatened he would get a superior to " pull his chain."
According to testimony of the alleged threatener, Mr. .
Vogelsang, which was corroborated by Mr. London, Vogelsang felt Witness F was becoming a nuisance, was creating confusion, and was badgering him to issue a Part 21 report on the ferro-resonant transformer problem. Vogelsar:g's use of the term " pulling in your reins" was meant by him, and so interpreted by London, as meaning to get Witness F back into line to do his job and let other people do theirs.
Management does not appear to have been attempting to discourage Witness F from performing his proper job function, but was attempting to discourage him from further involvement outside his job function. The Study Team concluded this was not an incident of intimidation.
fl. - Ferro-Resonant Transformers - 1984 Witness F claimed a startup supervisor harassed and threatened him in connection with the proble= with ferro-resonant transformers. There is some evidence the witness was using the ferro-resonant transformer situation and, specifically, filing of a 50.55(e) report to harass one of ,
his supervisors, Mr. Luken, who.was a Westinghouse employee.
Luken believed Witness F accused him of trying to cover up B-18
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, a safety issue, which is a Federal crime. In response, Luken became very angry, walked away, and a few minutes later called out to Witness F as he passed Luken's office, "You will never accuse me of trying to cover up a safety issue again."
This warning, or claimed threat, was not mentioned by Witness F in his June 27, 1984, affidavit, not was it subsequently mentioned by him in his July 18, 1984, or July 19, 1984, depositions, which included extensive questions regarding this incident and perceived intimidation. The Study Team concluded that Witness F was not intimidated in this incident.
5 - Problem Finding and Quantity of Work Comment - 1984 I The startup supervisor, Mr. Luken, told Witness F if he had enough time to find problems (such as the ferro-resonant transformer problem and the purported conflict between ES-100 and RG-1.75), then he had time to do more work. Based on the history of these two matters, including the continuing attention being directed toward them by Witness F, the criticism appears to have been a justifiable management comment and not intimidating.
The witness also claims his for=er employer at CPSES has continued to engage in harassment and intimidation against him by blacklisting him with other companies. Insufficient evidence exists to assess this allegation.
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As indicated in the five specific incidents, in the opinion of the Study Team the evidence failed to support the
~
allegations of *ditness F that he was intimidated.
v 1984 - S.A. Neumeyer - Stanford Incident 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 found 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 left her feeling uncomfortable after 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 l as intimidating.
1984 - M. Gregorv - Pressure on N-5 Reviewers
- 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 l that an allegation of intimidation was substantiated in this incident since:
l B-20 1
i
t o Gregory was not a document reviewer and there was no o
substantiation that the reviewers felt excessively pressured.
o The use of job shoppers was suggested by higher management as additions to the N-5 reviewers, and Bennetzen was trying to avoid bringing in shoppers by increasing the group's output.
o Bennetzen apparently did make some comments related to company loyalty on a day that two people quit without notice and to job security related to a specific individual. It is felt that Gregory took these comments out of context as a warning to her. There is no substantiation for her interpretation 1984 - M., Gregory - QES Review Sheet 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 incident resulted from the fact that a package to be vaulted had been returned from the Authorized Nuclear Inspector (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 package to make sure the documents included were listed on the QES review sheet and sent it to the vault. This was in B-21
2 accordance with procedures. The Study Team finds ,
sufficient evidence to conclude this was not an incident of intimidation.
1984 - M. Gregory - Reduction of Force (ROF)
Ms. Gregory alleged that there was something wrong with the way employees were selected for a BOF in that more qualified people were ROF'd while less qualified were retained. The applicant responded that there is a comprehensive, mainly objective method for ROF selection that includes assessment of clearance capability, certifications, and absenteeism. The Study Team did not feel that adequate information was available to assess this allegation.
1984 - T-Shirt Incident A number of electrical inspectors showed up on site on two days one week wearing T-shirts indicating they were
" Comanche Peak Nitpickers--We're In the Business of Picking Nits." On the second occasion eight inspectors were sequestered in an office and ultimately sent home after their desks were searched and some personal and company property seized. Most of the eight involved were subsequently transferred or terminated.
This incident occurred about the same time thet allegations t had been voiced by craft of destructive testing by electrical inspectors. The inspectors' T-shirts could have B-22
l I
been read to convey a message that their job was to report b
safety concerns described by craft or coatings foreman Williams as " nits." Management's response was inappropriately severe to an occurrence 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 - Hamilton,Krolak,Shelton - Refusal to Inspect Coating Three QC inspectors, Hamilton, Krolak, and Shelton, were terminated for refusing to inspect coatings on the Rotating Access Platform Rail in Reactor Building No. 2. There was scaffolding in position from which the painters had worked, and a lifeline safety system was properly in place.
Apparently the three inspectors had not'actually climbed up S
to look at the rail or scaffolding.. Testimony from several 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 initial refusal to perform the inspection, the three inspectors were advised that supervision and the Safety Depart =ent had evaluated the area and found it safe.
The three were then offered the opportunity to reconsider their stance. When they refused to reconsider, they were B-23
1 7
terminated for refusing to perform their assigned tasks. ,
The Study Team feels that management acted properly throughout this incident, and that this was not a case of -
inti=idation.
t ee e
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O Government Accountability Project 1555 Connecticut Avenue, N.W.. Suite 202 Washington, D.C. 20036 (202) 232-M50 Itallie Garde Director, Enwronmental Whist!cblower Ginic December 3, 1985 l
FREEDOM OF INFORMATION ACT REQUEST
- cl> v s .y w , ,, ,
Director ^'
- Office of Administration p p . p g . /) p y Nuclear Regulatory Commission Washington,'D.C. 20555 d284 d M ff l
To W1.om It May Concern: l Pursuant to the Freedom of Information Act ("FOIA"), 5 U.S.C. 9552, the Government Accountability Project (" GAP")
requests copies of any and all agency records and information, including but not limited to notes, letters, memoranda, drafts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, interview reports, procedures, instructions, engineering i
analyses, drawings, files, graphs, charts, maps, photographs, agreements, handwritten notes, studies, data sheets, notebooks, books, telephone messages, computations, voice recordings, computer runoffs, my other data compilations, interim and/or final reports, status reports, and any and all other records t
developed by the harrassment and intimidation panel report issued November 4, 1985.
This request includes all agency records as defined in 10 I C.F.R. 99.3a(b) and the NRC Manual, Appendix 0211, Parts 1.A.2 and A.3 (approved October 8, 1980) whether they currently exist in the NRC official, " working", investigative or other files, or at any other location, including private residences.
If any records as defined in 10 c.F.R. $9.3a(b) and the NRC Manual, supra, and covered by this request have been destroyed and/or removed after this request, please provide all surrounding records, including but not limited to a list of all records which have been or are destroyed and/or removed, a description of the action (s) taken relevant to, generated in connection with, and/or issued in order to implement the action (s).
fj ,f.ppi n -_ 7 e.7 ,- 1 y PD.4-
~~
4 GAP requests that fees be waived, because " finding the information can be considered as primarily benefitting the general public," 5 U.S.C. 552(a)(4)(a). GAP is a non-profit, non partisan public interest organization concerned with honest and open government. Through public outreach, the Project promotes whistleblowers as agents of government accountability.
Through its Citizens Clinic, GAP offers assistance to local public interest and citizens groups seeking to ensure the health and safety of their communities. The Citizens Clinic is currently assisting several citizens groups, local governments and intervenors in Tennessee concerning the construction of the Watts Bar nuclear power plant.
We are requesting the above information as part of an .
ongoing monitoring project on the adequacy of Region II and the NRC's efforts to protect public safety and health at nuclear power plants.
For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portions of documents withheld. The index should provide a detailed justification of your grounds for claiming each exemption, explaining why each exemption is relevant to the document or portion of the document withheld.
This index is required under Vaughn v. Rosen (I), 484 F.2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1974).
We look forward to your response to this request within ten t days.
Sincerely, EC Billie Pirner Garde Director Environmental Whistleblower Clinic