ML20211Q808
| ML20211Q808 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/16/1985 |
| From: | Herr R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20211Q500 | List: |
| References | |
| FOIA-86-191, FOIA-86-A-53C NUDOCS 8607280012 | |
| Download: ML20211Q808 (1) | |
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Title:
COMANCHE PEAK STEAM ELECTRIC STATION U. S. NRC 0FFICE OF INVESTIGATIONS REVIEW 0F THE COMANCHE PEAK SAFETEAM PROGRAM Licensee: Case Number: A4-85-020 Texas Utilities Generating Company Report Date: October 16, 1985 2001 Bryan Tower Dallas, Texas 75201 Control Office: OI:RIV Status: Closed Assist Reported by: Approved by:
r m l h b%.Q.
k A. Kindt Richard K. He'rr vestigator, OI:RIV Director, 01:RIV Participating Personnel:
Ben B. Hayes, Director, 01:HQ William D. Hutchison, Operations Officer,0I:HQ Richard K. Herr, Director, 0I:RIV H. Brooks Griffin, Investigator 01:RIV Mark E. Emerson, Investigator 01:RIV WARNING The at docun repo h not bee iewed p ua to 10CFR, paragra .790(a mptio , or has a xempt mate been deleted.
Do no in e or 's s it ont ts o side NR . eat as "0FF)CIAL US)d0NLY." 6 K \
8607280012 860717 PDR FOIA GARDE 86-A-53C PDR
m e DETAILS OF ASSIST TO INSPECTION PURPOSE OF REVIEW On July 30, 1985, theOfficeofInvestigations(01),RegionIVField
, Office, received a request to assist in conducting a review of the Comanche Peak Safeteam Program, Exhibit (1), from the NRC Director, Comanche Peak Project, Vincent NOONAN. The other members of this review team were from NRR, IE and Region IV, Exhibit (2). The primary objective of this review was to determine whether the Safeteam Program had properly addressed the i employees' concerns. The review effort was divided into two areas (technical and wrongdoing). Those considered as possible wrongdoing were OI's responsibility. All others, identified as being of a technical nature, were handled by the other NRC team participants. The review was conducted during the week of August 26, 1985.
BACKGROUND ON COMANCHE PEAK SAFETEAM PROGRAM, EXHIBIT (3)
The Safeteam concept was originally developed by the Detroit Edison Company. Its subsidiary, Utility Technical Service, Incorporated (UTS), i has contracted with various utilities including Comanche Peak to acquire and implement its program. The Comanche Peak Safeteam Program which started in January 1985 follows the UTS operational manual with little deviation. Its staff consists of a manager, interview coordinator, seven part-time interviewers, five investigators and two secretaries. The manager, Richard WARNER, is an employee of Texas Utilities Generating l Company (TUGCO). The interviewers are all local part-time hires who j receive twenty to thirty hours of training in interview techniques. The interviewers are housewives, real estate agents, and other individuals whose schedules are flexible enough to be on an on-call basis. The Safeteam investigators are not actually trained investigators. Their prior work experience has been as auditors and QC inspectors at other nuclear facilities.
Since its inception, the Safeteam Program has made a concerted effort to
. obtain employee concerns. For example, they have already conducted inter-views of the site QA/QC personnel to identify any quality concerns. In addition, they have made it a practice to also interview each terminating employee. Their procedure is to offer an individual the opportunity to personally present his allegations in confidence or he has the option to do so by mail or telephone.
The Safeteam considers the alleger's confidentiality essential to the integrity of the program. This includes requiring that the investigators and interviewers be physically separated from one another. The investigator is only to receive the alleger's concern and not the person's identity. If further information is needed, the investigator can request it from the Safeteam interviewer who will, if necessary, recontact the >
alleger.
Once an investigation is completed, the Safeteam review process is an i i
follows: A draft is prepared and reviewed by the Safeteam manager. Then it goes to a three member steering committee for their recommendations.
Case Ho. A4-85020 Page 1
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After that, it is returned to WARNER for review, possible rewrite and his approval. Once the steering conmittee has given a final approval, a response is issued which includes notifying the alleger of the findings.
DETAILS OF REVIEW Since inception in January 1985 through August 21, 1985, the Comanche Peak Safeteam Program has received 655 concerns and closed approximately 553, Exhibit (3). A computerized printout describing these concerns (Safeteam cases) has been reviewed. The printout is a sequential numerical listing with each number having five digits (10000, 10001, etc.). The individual numbers represent a particular interviewee (alleger). Every number also has an alpha sub-listing which identifies each one cf the alleger's concerns (10000A, 100008, etc.). In addition, every concern has a one to three line narrative description with an alpha code that distinguishes whether it is open or closed. Each concern is further coded with what is termed a three digit "Z" code (000 to 699), Exhibit (4). These codes categorize each concern. For example code "115" means drugs. Depending on the allegation, there may be more than one of these numbers assigned to a concern. A listing of these "Z" codes and their definitions was reviewed.
Certain code numbers that indicated areas of possible 01 interest were identified. These numbers were used to obtain addit'onal computer printouts of all cases coded with such numbers. Sirce WARNER was extremely concerned about maintaining the alleger's confidentiality, none of these printouts could be taken from the Safeteam office. Based on the review of these computer printouts, 43 closed cases were identified as having possible OI investigative potential. Six OI investigators participated in the review and evaluation of these cases.
In general, the review found that the case files were well organized making it easy to locate and evaluate each concern. In 31 out of 43 cases ex-amined, the 01 evaluations with only minor differences concurred with the Safeteam's findings and conclusions. Overall a creditable job had been done in addressing the various concerns. This includes the efforts exhibited both in explaining a concern and in its subsequent handling.
Generally, the investigative report was found to substantiate the findings.
However, in five Safeteam cases numbered 10068A,10104C,10298A,10308A and 10412A, which are discussed later, additional information beyond the Safeteam's reported findings was needed in making accurate assessments.
With regard to the seven remaining cases, they were determined to have little or no OI significance. Nevertheless, three were reviewed and evaluated. One case, Safeteam number 101528, was referred to the NRC technical review staff for their evaluation. The other two numbered 10015A and 10038A were not fully addressed in the Safeteam's reports and needed additional clarification. They, too, are discussed below. Exhibit (5) lists the 43 cases with each being catagorized under one of the above areas. The evaluation sheets that were completed by 0I on each case can be provided upon appropriate request.
]
In the cases mentioned above where the Safeteam reports contained insuffi-cient explanations of the circumstances, the Safeteam manager's and another official's comments were elicited. These comments along with the description and evaluation of the cases requiring additional clarification are as follows:
s Case No. A4-85020 Page 2
m e (1) Safeteam Case #10015A: Alleged favoritism and nepotism shown a supervisor who is the manager's son-in-law. The Safeteam report indicated that the matter had not been investigated because the source wished to remain confidential. WARNER, Exhibit (6),
defined this as a management concern and not a safety related problem. Therefore, according to Safeteam procedures, the allegation was turned over for resolution to the company against whose employee it had been made. WARNER admitted that none of the company's employees were ever interviewed concerning this allegation. However, he did claim that some had been interviewed on other matters but no evidence of any such problem was found.
He said the Safeteam only received positive comments regarding the working environment. WARNER also mentioned that the supervisor against whom this allegation had been made was interviewed about the matter. He said the source was not identified but, based on the circumstances of the allegation, the supervisor was able to guess the individual's identity.
According to WARNER, the supervisor alleges that the source had problems with various individuals and eventually quit.
The Safeteam had not done an adequate investigation in this case.
It is evident by WARNER's statement that the reason used for not pursuing the allegation (protection of the confidential source's identity) was unsupported and feeble at best. The report, at the very least, should have included the Safeteam's procedural requirements on such matters and the results of the interviews they conducted. Furthermore, in this case, it would have done no harm to also question some of the employees about the allegation.
(2) SAFETEAM CASE #10038A: Alleged nepotism and lack of respect by upper management. The Safeteam report showed that the allegation was referred for resolution to the company employing these officials. It also indicated that the Safeteam had not followed up on the company's reply which was vague and generally unrespon-sive to the allegation. WARNER, Exhibit (6), admitted that the Safeteam had not conducted a follow-up investigation. He said the allegation was extremely broad and contained no specifics.
Also, he said it was a non-safety related matter and a company internal management concern. Therefore, they were only following their procedures by turning the allegation over to the company for resolution.
The Safeteam report at the very least should have shown WARNER's explanation. It would have provided the rationale and documenta-tion for their inaction in this case. This, however, does not mean that we agree with their decision. Although it is under-standable why the allegation was referred to the company, they should have still followed up on the company's reply. This 1 would have ensured that this allegation as well as future i allegations would be properly addressed. "e:. I l
Case No. A4-85020 Page 3
(3) Safeteam Case #10068A: Alleged manipulation and suppression of QC program concerns. 01's evaluation of the Safeteam report indicated that the documentation was merely adequate at best in supporting the investigative conclusion. WARNER, Exhibit (6),
agreed with the assessment. He said that since OI's review, the investigator's notes have been added to the report which further support the conclusion.
(4) Safeteam Case #10104C: Allegedly, the son of the project manager is a known drug dealer. The Safeteam report revealed that the interviewer never identified this individual. It also shows that the case was referred to Security, Texas Utilities Services, which declined to investigate. WARNER, Exhibit (7), admitted the interviewer failed to identify the subject although he claims this could be easily determined since there is only one project manager. In addition, he said he conferred on this matter with David ANDREWS, Director of Security, Texas Utilities Services.
It is Security's position that this concern has not met the criteria for investigation. It lacks specifics since the alleger only mentioned that the subject was a known drug dealer.
However, he said Security will keep a file on this information in case of any further allegations. He further stated that the alleger had been notified by mail of their decision and was requested to recontact them if there was any additional information. David ANDREWS, Exhibit (8), essentially confirmed WARNER's statement. Additionally, he stated that, since the alleger was the Safeteam's confidential source, it is their responsibility to get back to him with any further information.
He mentioned also that out of five requests for more information, the Safeteam failed to respond to two of them. He said no reason was given and Security has never checked into the matter to find out why there was no reply.
Initially, the Safeteam interviewer should have been more inquisitive. The basic questions of who, what, where, when and why should have been asked. This may have identified the accused and furnished additional facts and circumstances surrounding the allegation. Even though this was not accomplished, when Security got the information, they should have aggressively pursued the matter. Neither the Safeteam nor Security appeared to show any real interest in this case. Both seem to have taken a passive role.
(5) Safeteam Case #10298A: Allegedly, a contractor employee's friends had been discouraged from cuntacting the Safeteam. The review showed that the " friends" were never identified nor an ,
, explanation given for not pursuing the investigation further.
According to WARNER, Exhibit (7), in their opinion this problem could be resolved in another manner. Similar complaints' through-out the plant had been received during this same period. They felt that there was nothing to gain at that point by making an example out of one person. They wanted to wait until after the employees, including supervisors, had been educated about the Case No. A4-85020 Page 4
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Safeteam program. This has since been accomplished and they are now more than willing to pursue such matters.
Under the circumstances, the rationale used in arriving at this decision is understandable. However, this reasoning should have been documented in the report. It should be further noted that the decision to wait might have cost them the opportunity to identify additional concerns, possibly of a safety related nature.
(6) Safeteam Case #10308A: An alleged unjustified termination. The Safeteam's report was lacking in details. It had not answered the basic question w;.y the company would reverse an employee termination once the Safeta m started investigating the matter.
WARNER, Exhibit (6), admitted that when the termination was reversed, they considered the problem resolved and closed. He also confinned the fact that they had not investigated the reason for the termination. He further mentioned that as a result of OI's interest, he has since looked into the situation. In his opinion, the termination was probably justified but could not be substantiated because the company had not properly documented the employee's actions.
Even though the termination may have been justified, this should have been determined in the very beginning. By not thoroughly examining the reason for an adverse action, the Safeteam takes a chance of missing what could be the real purpose for such action.
It is very possible that an ulterior motive may exist that even a teminated employee might not fully comprehend.
(7) Safeteam Case #10412A: Allegedly two supervisors reported for work intoxicated. The Safeteam's report indicated that the allegation was referred for resolution to the company employing these supervisors. The report also revealed that neither a follow up investigation nor review of the company's resolution was done. WARNER, Exhibit (7),statedthat,underthesecircum-stances, it was not a Safeteam practice to check on a company's reply unless it was a recurring incident. He felt it was unnecessary since the company had an approved management procedure for addressing such problems. He mentioned also that, as a result of OI's interest, he has checked further into this concern and is satisfied that the company's procedure works.
WARNER's explanation indicates that this case was given more consideration than is evident in the Safeteam's report. This additional information would have provided a better understanding of why the Safeteam reacted as they did and should have been included in the report. However, an investigative review of the company's findings would have been the preferred course of action. This would ensure that the Safeteam's referrals are properly addressed, especially when a company knows that their '
reports will be constantly scrutinized.
Case No. A4-85020 Page 5
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FINDINGS In summary, the majority of Safeteam investigations reviewed and evaluated were found to have sufficiently addressed the issues posed. This included the efforts demonstrated in explaining a concern and in its subsequent investigation. For the most part, the investigative reports adequately supported the conclusions. However, as previously mentioned, the investigative findings in some instances were inconclusive. This can generally be attributed to two primary factors: (1) Certain reports had not accurately described the Safeteam rationale for pursuing or concluding an investigation; and (2) some reports had left the original allegation unanswered.
LIST OF EXHIBITS Exhibit No. Description 1 Vincent N00 NAN's Memorandum Dated July 26, 1985 2 R. P. DENISE's Memorandum Dated August 22, 1985 3 Report of Interview With Richard WARNER, August 26, 27 & 30, 1985 4 Categorization of Concerns ("Z" codes) Obtained From Richard WARNER 5 Listing of Safeteams Cases Reviewed and Evaluated 6 Report of Interview With Richard WARNER, September 20, 1985 7 Report of Interview With Richard WARNER, September 6,1985 8 Report of Interview With David ANDREWS, September 19, 1985 t
Case No. A4-85020 Page 6
A4-85-020
,. D AUGUST 26, 27 & 30, 1985 REPORT OF INTERVIEW 0F RICHARD WARNER SAFETEAM MANAGER, COMANCHE PEAK NUCLEAR POWER PLANT GLEN ROSE, TEXAS TELEPHONE #(817)897-4881 Richard WARNER, Manager of the Comanche Peak Safeteam and an employee of Texas Utilities Generating Company (TUGCO), provided the following
, information about the Safeteam during the period of the review (August 26, 27, & 30, 1985):
(1) The Safeteam program started at Comanche Peak in January 1985.
(2) The program was developed by Detroit Edison Company and distri-buted by contract through its subsidiary, Utility Technical Services, Incorporated (UTS). Comanche Peak, as well as other utilities, is currently using the program. The Comanche Peak program follows closely the UTS operational manual guidelines with little deviation.
(3) The Safeteam staff consists of a manager, interview coordinator, seven part-time interviewers, five investigators and two secretaries.
(4) The Safeteam interviewers are part-time local hires. They are housewives, real estate agents or other such individuals with flexible schedules who are available on an as needed basis. They receive from 20 to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of interviewing techniques.
(5) The Safeteam investigators are not actually trained investigators. They have previously been auditors and QC inspectors at other nuclear facilities.
(6) The investigators and interviewers are physically separated from each other to ensure confidentiality for the alleger which is paramount to the program integrity. The investigator will only receive the alleger's concern and not his identity. If further information is necessary, the investigator can go back to the interviewer who will then recontact the alleger.
(7.) The Safeteam has made a concerted effort to obtain all concerns.
An individual can present his concerns in strict confidence either in person, by mail or by telephone.
(8) The Safeteam has been making an attempt to interview each termi-nating employee. They have also interviewed the QA/QC personnel for any quality concerns.
(9) From January 1985 to August 21, 1985, the Safeteam has taken 655 concerns and closed between 553 and 560.
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(10) Once an investigation is completed, the draft report is prepared and reviewed by WARNER and then forwarded upon his satisfaction to a 3 member steering conwittee for their recommendations. It is subsequently returned to WARNER for review, possible rewrite and his approval. After a final approval by the steering committee, a response is issued including notifying the alleger of the findings.
DATE PREPARED IN DRAFT FROM NOTES TAKEN DURING INTERVIEW:
August 26, 27 & 28,~1985
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Prepared ~by Jack A. Kindt i
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A4-85-020 1
CDMANCHE PEAK SAFETEAM Categorization of Concerns
- 1. All codes are prefaced with Z to allow differentiation
, between code and concern information.
- 2. Concerns may be categorized in more than one category or sub-category.
- 3. Categories indicatect as "(General)" are used, if a _ _ _ ,
sub-category is not available, until an evaluation can be made determining the need f or a new sub-category.
Z CODES DIRECTORY Cgdg_Nymbgt Categgty OOO Calibration (General) 001 to 009 (Open)
O10 Design (General) 011 Changes 012 Legibility 013 Deviations-deliberate 014 to 049 (Open) 050 Inefficiency (General) 051 ,
Waste 052 Communication 053 Rework 054 RFIC's 055 to 074 (Open) 075 Nonconformances (General) 076 - Supression of 077 Direction to commit 078 Falsification / forgery 079 Dispositions 080 Writing of 081 to 099 (Open)
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2 Gede_Numbe- Getraecy .
100 Personnel (General) 101 Terminations 102 Sexual harassment /EEO 103 Pay
-104 Promotions 105 Benefits 106 Hiring practices 107 Job assignment 108 Transfer 109 Unfair / unequal / unjust treatment ____
110 Morale til Any opinion of qualifications 112 DA qual i f i c ati ons /cer ti f i cati ons 413 Harassment / intimidation 114 Polygraphs 115 Drugs 116 On-the-job training 117 Chain of command /Dpen Door 118 Manpower 119 Conditions 120 to 174 (Open) 175 Procedures / Documentation (General) 176 Availability /retrievability 177 Revisions 178 Training 179 Verbal agreements 1 180 Input 181 Implementation T82 Violation 183 to 189 (Open) 190 General Hardware (General) 191 Workmanship 192 Quantity vs. Quality 193
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IRN's 194 Walkdowns I 195 IR's/ Travelers 196 Not in accordance with requirements 197 to 199 (Open)
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200 Civil / Structural Hardware (Gtneral) 201 Concrete 202 to 220 (Open) 221 Reinforcing steel 222 to 240 (Open) l 241 Structural steel 242 to 260 (Open) 261 Soil 262 to 280 (Open) 281 Laatings (paint) 282 to 299 (Open) 300 El ectri cal Hardware (General) . ___
301 Pulls 302 to 320 (0 pen) 321 Terminations 322 to 340 (Open) .
'341 Hangers / trays 342 to 360 (Open) 361 Conduits / cables 362 "C" Tr ai n 363 Grounds .
364 Lighting 365 Separation, SBM's 366 to 380 (Open) 381 Components / systems 382 to 399 (Open) 400 Mechanical Hardware (General) 401 Piping 402 to 420 (Open) 421 Welding 422 to 440 (Open) 441 Instrumentation 442 to 460 (Open) 461 Hangers 462 to 480 (Open) 461 Components / systems 482 to 499 (Open) 500 HVAC Hardware (General) ,
501 to 599 (Open)
R1 X 4 'rI 65 0 020
4 Gede_Nuekst Gatteocr 600 SAFETEAM 601 to 649 (Open) 650 Suggestions 651 to 699 (Open)
-ZSAF Safety ZSEC Security ZMIS Miscellaneous i
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^ ~ A4-85-020 SAFETEAM CASES REVIEWED AND EVALUATED (1) 10004C 10147A&E 10015A(3) 10151A 10016E 10152B(3) 10019A 10164A 10038A(3) 10195A 10042D 10212A(2) 10049B 10222A 10050D 10232D 100528(2) 10236A 10061A&D 10261A 10066B 10289A 10068A(4) 10298A(4) 10070D 10308A(4) 10073A 10314A 10078A 10343C 10093A(2) 10412A(4) i 10102A(2) 10447A 10104C(4) 10450A 10115A 10456A 10122A 10461A 10126A (1) Unless otherwise footnoted, the investigation is considered to adequately support the reported findings.
(2) Considered to have no 01 significance.
(3) Considered to have no OI significance but was reviewed and evaluated.
(4) Additional information was needed beyond reported findings to make accurate assessments.
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EXHIBIT (5) k 4 r'8 5 '- 0 2 0
.~ - + A4-85-020 i
SEPTEMBER 20, 1985 REPORT OF INTERVIEW 0F RICHARD WARNER SAFETEAM MANAGER, COMANCHE PEAK NUCLEAR POWER PLANT GLEN ROSE, TEXAS TELEPHONE #(817)897-4881 i WARNER was contacted by phone and he provided the following information on j the Safeteam cases described below:
i . (1) Safeteam Case #10015A: Alleged favoritism and nepotism shown a supervisor who is the manager's son-in-law. The OI evaluation
} indicated that the Safeteam had not investigated the matter because the source wanted to remain confidential.
t WARNER stated that in areas like this where there are no safety i related implications, their procedures define this as a management concern. Therefore, according to procedures, this allegation was turned over to the contractor for resolution. He also admitted there was no follow-up. No one from the Safeteam interviewed any of the other employees working in that area about j the concern. However, he did say they had spoken to some of the employees on other matters and found no evidence of any such problem. They received only positive comments about the working i environment. WARNER admitted that none of the information was i shown in the report. WARNER stated further that they had
! approached the supervisor about the matter without identifying i
the source. Nevertheless, the supervisor was able to guess the source's identity based on the circumstances. Supposedly, this individual had problems with everyone and eventually quit.
Again, this was not in the report.
j (2) Safeteam Case #10038A: Alleged nepotism and lack of respect by upper management. The review showed that the allegation was referred for resolution to the company employing these same upper management officials . It also indicated that the company reply which was vague and unresponsive, had not been followed up on.
1 WARNER admitted that this concern had been referred to the company because, by the Safeteam's procedures, this was an internal management concern and not safety related. He also admitted that there had been no follow-up. In addition, he said the allegation was extremely broad and contained no specifics.
j' (3) Safeteam Case #10068A: Alleged manipulation and su)pression QC program concerns. The OI evaluation indicated tlat the documentation was merely adequate at best in supporting the investigative conclusion.
! WARNER agreed with this assessment. He said the investigator's notes have since been added which further support the conclusion.
He believes this additional information is beneficial to the j report.
1 EXHIBIT (6)
'A 4 8 5 . 020 - . . - . - - -- -.- -.---.-- -
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1 (4) Safeteam Case #10308A: Alleged unjustified termination. The ~ .
Safeteam report indicated that the employee was subsequently s l rehired. However, it contains no details on the company's rea' sori for reversing the tennination. ,
~
i WARNER had no additional information. He said once the person l l was rehired into another job, the problem was considered
} rectified and, therefore, closed. The Safeteam did not -.
- investigate the matter any further including the reason for the termination. Since 01 expressed an interest in this case, WARNER ,.
did check further and found that this employee probably should have been fired. However, since the company had not adequately ,
documented the employee's performance, it was not in a good '
position to fight for the termination. .
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4 DATE PREPARED IN DRAFT FROM 1 NOTES TAKEN DURING INTERVIEW:
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September 20, 1985 .,,
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l A4-85-020 1 1
SEPTEMBER 6, 1985 REPORT OF INTERVIEW 0F RICHARD WARNER ,
SAFETEAM MANAGER, COMANCHE PEAK NUCLEAR POWER PLANT l GLEN ROSE, TEXAS
, TELEPHONE #(817)897-4881 i
WARNER was contacted by phone and he furnished the following information on ,
l
~ the items described below: 1
\
(1) Safeteam Case #10004C: Allegedly a contractor employee was !
transferred from one jcb to another for writing NCRs. l 1
WARNER said that the Safeteam investigated and found the transfer
, to be justified. Due to priority changes, the work and employees 1
were switched from one area to another. At about the same time this was happening, one of the craft workers was injured on the job which further accelerated the work stoppage. The Safeteam investigated the matter and found records verifying that there i had been a priority change. The alleger was advised of these j
results in a letter dated April 22, 1985. He was also told to contact the Safeteam if he was unhappy with the resolution.
WARNER said that all this had already been documented in the case file.
(2) Safeteam Case #10104C: Allegedly, the son of the project manager is a drug dealer. The report indicates that the Safeteam interviewer never got the identity of this individual. It also shows the case was referred to Security, Texas Utilities Services, which declined to investigate due to a lack of specifics. l WARNER admits the identity of the accused was never obtained. l However, he states that it could be easily determined since there !
is only one project manager. He also states that he had ;
conferred about the matter with David ANDREWS, Director of ,
Security at Texas Utilities Services. He said Security felt that l this concern did not meet their threshold / criteria for l investigation because it lacked specifics. The source only mentioned that the subject was a known drug dealer. The alleger neither provided any personal observations nor described any other third party's observations. According to WARNER, Security i will maintain a record of this incident in case of any further allegations. He further stated that the alleger had been notified by mail of their decision and was asked to contact them i if there was any additional information.
1
..g=85M020
1 f (0) Safeteam Case #10298A: A contractor employee said his friends I l had been discouraged from contacting the Safeteam. The source's i friends were never identified in the report nor an explanation !
given for not pursuing the investigation further. l l WARNER said the investigation was not pursued because they believed it could be resolved in another manner. During this same time period, they had received similar complaints from other
! sources in the plant. They felt they had nothing to gain at that point by making an example of someone. They decided to wait !
until after they had conducted training sessions to educate the employees including the supervisors about the Safeteam Program.
This has since been accomplished and they are now ready and willing to pursue such matters if they should arise.
(4) Safeteam Case #10412A: Supposedly, two contract supervisors ;
- reported to work intoxicated. The matter was referred to the
- contractor which did an inquiry and then reported its findings
- back to the Safeteam. The Safeteam did not do a follow up
- investigation or review of these finding:.
WARNER stated that a review of the contractor's findings was l unnecessary since this company had an approved management
, procedure for addressing this problem. WARNER also stated that i i under such circumstances, it was not their practice to check on i
the contractor unless there was a repeated incident. However, as a result of 01's interest, WARNER did check further into this concern and was satisfied that the contractor's procedure works.
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DATE PREPARED IN ORAFT FROM i NOTES TAKEN DURING INTERVIEW: ,
j l September 6,1985 l
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Prepared by' Jack A. Kindti l
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A4-85-020 SEPTEMBER 19, 1985 REPORT OF INTERVIEW 0F DAVID ANDREWS DIRECTOR OF CORPORATE SECURITY TEXAS UTILITIES SERVICES, IhC.
2001 BRYAN TOWER DALLAS, TEXAS TELEPHONE #(214)653-4664 In a phone conversation with ANDREWS, he provided the following infomation on alleged drug dealings by the son of the Comanche Peak project manager.
The Safeteam referred the allegation (Safeteam Case #10104C) to Security for resolution. ANDREWS said it lacked specifics; therefore, it did not meet Security's criteria for investigation. He said the only information provided was that this individual was a known drug dealer. He has since requested that the Safeteam recontact the alleger for additional information. He said Security did not personally contact the alleger since the Safeteam granted the individual confidentiality. For this same reason, he believes it is the Safetcam's responsibility to get back to him with any further information. He did not have access at the time to the case file, but he does not believe anything has yet been received. He also mentioned that out of about five requests for further infomation, the Safeteam failed to respond on two of them. No reason was ever given and Security never checked into the matter to find out why. In addition, ANDREWS mentioned that Security will maintain a file on this incident in case further information or allegations are received.
DATE PREPARED IN DRAFT FROM NOTES TAKEN DURING INTERVIEW:
_ September 19, 1985 y
- sr I' N P,rypared by Jack A. Kindt
'g4rI 85E020 E M BIT (8)
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A4-85-020
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M 26 E MEMOPANDUM FOR: Darrell G. Eisenhut, Deputy Director Office of Nuclear Reactor Regulation Robert D. Martin, Regional Administrator Region IV James M. Taylor, Director Office of Inspection and Enforcement Ben B. Hayes, Director Office of Investigation )
FROM:
Vincent 5. Noonan, Director Comanche Peak Project i
SUBJECT:
PLAN FOR REVIEW 0F CDMANCHE PEAK SAFETEAM i
Enclosed Peak 5AFETEAM. is the Comanche Peak Project staff plan for the review of the Comanche files at Comanche Peak by a team of representatives from NPR on June 14, 1985.
a similar effort at Wolf Creek.This plan was prepared with Region IV. R. Denise who heade
/
I am planning to implement this plan on August 5,198J. / M i s V o anI r o.anche Pea Prokeet
Enclosure:
As stated cc: R. Denise '
J. Gagliardo J. Axelra~d J. Liebennan D. Hunter m
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X4E85E020 Q:; 3.r. ._ ._.
EXHIBIT (1)
2 Plan for Review of Comanche Peak SAFETEAM 1
The general approach to a review of the SAFETEAM program will be that the NRC conduct a review of programmatic features as well as a sampling of allegation processing files covering hardware and wrongdoing matters under the licensee's prograe.
1982 The team shnuld be made up of at least one representative from NRR, DI, IE.
and RIV. Region IV will assume lead responsibility.
S'hedule c
Oek of August 5-9, 1965.
Review 1 Review of program description documentation to determine intended objectives, responsibilities, organization, organizational relationships, infcmation flow, qualifications of personnel, etc.
- 2. Review of program practices as they relate to the items noted in number 1 above, and note any differences between stated intentions and actual practices.
- 3. Evaluation of intentions and practices as the NRC sees them. This would
- be a general coTparison of TUGC0 practices to hRC practices if the NRC had received the worker concern as an allegation. This evaluation would include the consideration of concern classification, confidentiality, investigation / inspection completeness, documentation completeness, identification of corrective actions, corrective actions taken, consideration of root cause and generic implication when the allegation was substantiated, timeliness of actions, and feedback to the concerned werker.
- 4. Selection and review of a sample of about 101 of SAFETEAM files in the classification Plent safety to detemine whether appropriate inspection / investigation corrective action and closure was taken. The samples should be selected based on the summary description of the concern.
- 5. Selection and review of a sample of about IO! of SAFETEAM files in the crea ,o_f wrongdoing to detemine whether appropriate action was taken, using the hRC definition of wrongdoing (i.e., concerns related to intimidation / harassment, falsification, unjust temination, etc.).
X 4 =I 85E020
3 l
Although the SAFETEAM does not have a classification of wrongdoing, a !
subset can be sorted from the computer listing of concerns. The Intimidation / Harassment Panel will review the subset sorted from the {
computer listing and it is anticipated that O! will also review this
~
subset.
- 6. In addition, the team will look at other such utility sponsored programs
. that have existed on site (e.g. Ombudsman Hotline). All files of concerns collected by the Ombudsman program will be reviewed in the same manner as number 4 above. A determination of whether a review of Hotline files is necessary will be made once the team is on site.
Following this initial review, the staff should evaluate the information i' collected end inform the utility of our observations.
Follow-On Review Any follow-on review will be determined at a later time. I Documentation The reviewers should document the results of the review in a report issued by Region IV, a standard form containing evaluation points and comments will be used during the review, and a record kept of all files reviewed.
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X 4 ':5 85EIO20
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- "'6 UNITED STATES
, y- , NUCLEAR REGULATORY COMMISSION i
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AUG 2 21985 l 1
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- MEMORANDUM FOR: V. Noonan, Director, Comanche Peak Project l 1
FROM: R. P. Denise, Director, Division of Reactor Safety and l Projects, Region IV I
SUBJECT:
PLAN FOR REVIEW 0F COMANCHE PEAK SAFE TEAM l In accordance with your memorandum of July 26, 1985, same subject, Region IV I
, has obtained a listing of the Comanche Peak Safe Team concerns with a status as of August 16, 1985. The listing indicates that 506 workers have submitted a total of 641 concerns. A review of the printout revealed that about :
200 concerns were involved with industrial safety, personnel practices, etc.,
and are not cuisidered to be primary candidates for NRC review. Additionally, some 55 concerns were identified for consideration by 01 for sampling and evaluation. Approximately 390 technical concerns remain of which 218 have i been closed, or are only lacking recontacts of the alleger.
I Enclosed is a modified review plan for the Comanche Peak Safe Team. In that j the review will be of a program which has no NRC defined requirements or criteria, the team members must exhibit considerable experience and judgement in determining NRC actions based on the review.
I have selected Glen Madsen to represent Region IV and serve as the Team ,
Leader.
W i
' r ;
R. P. Denise, Director Division of Reactor Safety .
and Projects l 1
Attachments:
As stated cc w/ attachments:
R. D. Martin, RIV T. F. Westennan, RIV Q a y) , q/o %
J. M. Taylor, D/IE j _
- W ~
% QQ' a.=ae=noa . . . . . - ... ,
Plan for Review of Comanche Peak SAFETEAM The general approach to a review of the Safe Team program will be that the NRC '
conduct a review of progrannatic features as well as a sampling of concern processing files covering hardware and wrongdoing matters under the licensee's program. The identification of weaknesses and areas needing improvement is a fundamental objective.
Team Representatives from NRR, 01, IE, and Region IV. l Schedule l I
Week of August 26, 1985.
f Initial Review
- 1. Review of program description documentation to detennine intended objectives, responsibilities, organization, organizational relationships, information flow, qualifications of personnel, etc.
- 2. Review of program practices as they relate to the items noted in No.1 above, and note any differences between stated intentions and actual practices.
- 3. Evaluation of intentions and practices as the NRC sees them. This would be a general comparison of TUGC0 practices to NRC practices if the NRC had received the worker concern as an allegation. This evaluation woulo ,
include the consideration of concern classification, confidentiality, investigation / inspection completeness, documentation completeness, ;
identification of corrective actions, corrective actions taken, l consideration of root cause and generic implication when the allegation was substantiated, timeliness of actions, and feedback to the concerned worker.
- 4. Select and review about 20% of technical concerns which TUGC0 has closed or are only lacking recontacting of the worker. The sample should be base.d on the sunnary descriptions of the concerns and should not include items relating to industrial safety, labor relations, industrial health, etc.
- 5. Select and review a sample of the wrongdoing concerns which TUGC0 has closed or are only lacking recontacting of the alleger. (Concerns related to harassment, intimidation, drugs, falsification, unjust tennination, etc.)
)(i=I 85E020
- 6. The reviews prescribed in items 4 and 5 above will be conducted in accordance with the attached SAFETEAM review protocol and data sheets will be prepared for each concern file reviewed (Attachments 1 and 2).
Follow-on Phases The follow-on phases would involve periodic reviews of new files opened since the last review using the general approach outlined above. The reviewer would be directed to review additional closed files of high interest which were not reviewed in previous inspections, with the goal of having reviewed at least 50% of all high interest files before a scheduled licensing decision; we may aim at a higher level of review based on later developments.
Documentation The reviewers (s) will document the results of the review in inspection reports issued by RIV. A standard form containing evaluation points and comments would be used during the inspection, and a record will be kept of all files reviewed.
X47'= 85E020
Attachment 1 NRC TASK FORCE - TUGC0 SAFETEAM -
Team Members l
Objectives
)
To review TUGC0 SAFETEAM files to determine whether TUGC0 has properly dealt ;
with the concerns brought to this organization by the employees of TUGC0 and )
its contractors. i
- As a result of the review, to determine what NRC actions are required.
l l
General Protocol NRC review will be (generally) based on a review of the files, independent investigations and inspections are not anticipated during this effort.
There are to be no in-process discussions with TUGC0 personnel regarding the process, I concerns, results, documentation, etc. An exit discussion will be held.
No material is to be given to TUGCO.
1 No material is to be taken or reproduced from the TUGC0 files without team leader approval.
All reviews are to be documented on the task force record of review forms; l these are to be retained by the team leader.
Do not record the names of persons expressing concerns - protect confidentiality.
Conduct reviews using the general standard of: Did TUGC0 handle the matter like the NRC would have handled it? This includes proper followup with person concerned.
Bring significant issues to the attention of the team leader at once.
X4'rI85E020
.z.
Alert the 01 members to any significant issues involving intimidation /
harassment or wrongdoing.
Be alert to signs of modified files, incomplete work, ignoring of leads, etc.
Give priority to health and safety issues, but also to management integrity issues. Get the non-NRC issue interest out of the way quickly with minimal time spent.
't
~ ' '
X 4 -= 8 5 E 0 2 0
Attachment 2 NRC TASK FORCE - TUGC0 SAFETEAM Record of Review NRCReviewer(s):
Date of Review:
File Data:
Open Date: Close Date:
TUGC0 Identifier:
Nature of Concern:
TUGC0 Concern Classification:
Security: Management: Industrial Safety:
Plant Safety:
Miscellaneous:
TUGC0 Inspector / Investigator:
TUGC0 Reviewer / Approver: Was it 50.55(e) Reportable: l l
Was it Reported: Was the Alleger Recontacted:
NRC Evaluation:
Are File Contents Complete: Comnents:
)
Does context of initial alleger contact reflect proper depth of information for followup?
Yes: No:
Comments:
Concern Properly Classified: Comments:
Does this concern relate directly to nuclear safety? Yes: No:
'g4':(85'ri020
I Did confidentiality considerations and withholding of names inhibit the inspectors /
investigators evaluation or conclusion?
Yes: No: Comnents:
Yes: No:
Do you agree with TUGC0 action / resolution?
" If Yes, Coments:
If Not, Why:
i Recommendations:
f No:
Field Check Yes: No: Additional Info Yes:
]
Suggested Yes: No:
Independent NRC Inspection / Investigation:
i Details:
f I
Coments:
I If you do not agree with the TUGC0 actions, are the unresolved / unacceptable matters sufficiently significant to public health and safety to recomend against power operation of Comanche Peak until fully resolved?
Yes: No:
i !
Signature (s):
t X 4"(8 5 E 0 20
3 Team Leader Review:
Concur with Evaluation and Reconsnendations?
Yes: No: Date:
Discussion /Coments:
Resolution:
Acceptable for Full Power?
Yes: No:
Signature (s): .,
t l
1 l
I X 4 '= 8 5 E 0 2 0 l
L- )