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MEMORANDUM FOR:
B. J. Youngblood, Chief
~y Licensing Branch H Division of Licensing j
Office of Nuclear Reactor Regulation
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Walter P. Haass. Vendor Programs Branch Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement i
FROM:
James M. Taylor, Director Office of Inspection and En.forcement
SUBJECT:
YOUR JOINT MEMORANDUM CONCERNING AUDIT OF SAFE TEAM ACTIVITIES AT FERMI 2 I have reviewed you memorandum concerning the audit of Safe Team Activities at FERMI 2.
I appreciate your efforts in support of NRR, IE and Region III.
I did have difficulty correlating your findings of process deficiencies with your conclusion that the " program appears to be generally adequate and is implemented in a generally acceptable manner." Even without specific regulatory guidance at this time, I would reserve that type statement for a program with fewer deficiencies such as you noted.
Most importantly you noted no significant safety problems, a conclusion shared by Region III personnel who also reviewed / inspected the FERMI program.
l J mes M. Tay r, Director l
fice of I pection and Enforcement cc:
J. Keppler, R-III C. Weil, R-III /
T. Novak, NRR J. Partlow, IE l
l B. Grimes, IE bh 0709290560 870924 PDR FOIA MAXWELL 87-413 PDR 4/jg 1
p 1 1985
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July 31, 1985 MEMORANDUM FOR: Ben B. Hayes, Director Office of Investigations FROM:
Harold G. Walker, Senior Investigator Office of Investigations Field Office, Regica !!T THRU:
Eugene T. Pawlik, Director Office of Investigations Field Office, Region III
SUBJECT:
FERMI 2 NUCLEAR POWER PLANT SAFETEAM REVIEW In accordance with RIII Administrator J. G. Keppler's request in his June 13, 1985 memorandum, a comprehensive review of Detroit Edison Company's
'(DECO) Fermi 2 SAFETEAM was conducted by 01:RIII Investigator James N. Kalkman and I, on June 11-13 and June 18-20,1985(seeattachments).
The review took into consideration all aspects of the DECO SAFETEAM investigation effort as they relate to the subject of wrongdcing.
Attachments: As stated Distribution:
. ctf s/f Fermi FAC File HGWalker h,
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NUCLEAR REGULATORY COMMisslON l
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Een E. Fayes, Director, Of fice of Investigations FR3h:
Jenes G. Keppler, Regional Administrator, Region 111 P.'!)ECT:
REQUESTFORPROGRAMREVIEk'0FTHEFERM: StJ t ! El.".......,
As discussed during the conference call of June 10, 1985, the Office of Investigations is requested to conduct a program review of the SAFETEAM at the l
Enrico Fermi Nuclear Plant, Unit,2.
The objective of this' review is to assess the adequacy and effectiveness of the SAFETEAM program and its implementation in the identification, dispositioning and resolution of both the technical and wrongdoing issues.
The region will provide the necessary technical support.
In order to act on the review findings before the scheduled July Comission hearing on a full power license, we believe the fact finding review must be completed by June 21, 1985.
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.Sek S-James G. Kepp#"1er
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H. R. Denton, NRR l
J. M. Taylor, IE I
E. T. Pawlik, OI: Rill I
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October 4, 1985 MEMORANDUM FOR:
James G. Keppler ministrator,&gionIII Re R
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SUBJECT:
REQUEST FOR PROGRAM REVIEW OF THE FERMI SAFETEAM l
PROGRAM In response to your request for a review of the Fermi Safeteam Program, 01 During conducted an analysis of documentation compiled by the Femi Safeteam.
the review this office checked the stipulated program for overall adequacy and j
effectiveness.
In addition, the Safeteam Program was specifically checked to i
determine how issues of potential safety significance and/or wrongdoing were identified, investigated and ultimately resolved.
As a result of the 01 review /Itwasdeterminedthat'theFermiSafeteamProgramwasnotstaffedor l
It was also Psupervised by experienced investigative personnel.
discovered that interviews, in many cases, lacked sufficient information because 01 bases this conclusion on the fact that the of this apparent inexperience.
3 interviews which were reviewed in the investigative files could not provide
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information concerning basic questions such as who, what, where, when, how and r,
l why.
The Femi Safeteam Program therefore did not exhibit the characteristics
- dormallyattributedtoaninvestigativeactivityg Enclosed is the Office of Investigations' (01) completed review of the captioned subject.
Enclosure:
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W. J. Dircks E00
/E.T. Pawlik,01:RIII 4
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October 29, 1985 MEMORANDUM FOR:
Charles E. Norelius,. Director, Division of Reactor Projects FROM:
Charles H. Weil, Investigation and Complian Specialist
SUBJECT:
OFFICE OF INVESTIGATIONS' REVIEW OF THE FERMI SAFETEAM (50-341) (AMS NO. RIII-85-A-0176)
Region III has received the Office.of Investigations report of their review of the Detroit Edison Company's' SAFETEAM at the Femi 2 plant.
The SAFETEAM is Detroit Edison's program for' the processing of allegations brought.directly to their attention.
The Division of Reactor Projects Review of the report should inclu'de as a
. minimum:
Does the OI report invalidate the findings of any of the Region III inspections done in the weeks immediately preceding the licensing of the Femi plant?
Determine if Detroit Edison has implemented their proposed improvements to the SAFETEAM process, those proposals having come as a result of the NRC review of the SAFETEAM.
l The OI report is available' for review from the Region ~III Enforcement and Investigation Coordination Staff.
The Office of Investigations has directed that no part of the report may be reproduced nor can it be made public.
Charles H. Weil Investigation and Compliance Specialist
Enclosure:
AMS Form
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cc w/o enclosure:
RIII:RA0 OI:RIII E. G. Greenman G. C. Wright pB
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01 FERMI 2 SAFETEAM REVIEW
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l Sunnary l
j In March 1983, Detroit Edison Company's (DECO) Internal Audit and Public Relations Departments collaborated in an effort to develop a program created to circumvent the industry-wide problem of lith hour intervenor activity.
I which has traditionally delayed plant full power licensing. The program was
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also designed to satisfy the Connission that all safety-related concerns /
allegations have been addressed and alleviated. That program, dubbed SAFETEAM, was billed as an investigative. group which professed concernee anonymity, s'
corporate independence and investigative proficiency.
During its 21 years existence, the Femi SAFETEAM has addressed approximately i
1,867 employee concerns, not all safety significant, but concerns nonetheless.
Those concerns were categorized, giving investigative priority to the safety-related concerns; however, the categorization did not include wrongdoing.
Those concerns which the SAFETEAM defined as police-type' wrongdoing (i.e.,
theft, forgery, drug and alcohol abuse, etc.) were referred to DECO Nuclear Security for investigation.. Only three such concerns were referred throughout j
the SAFETEAM program.
All other concerns were investigated to the extent and I
depth which the SAFETEAM perceived sufficient to close out the issue of concern. The concernee was subsequently notified by letter of the SAFETEAM findings and response.
In June 1985, NRC Region III requested that 01 conduct a review of the Femi 2 SAFETEAM investigations. OI reviewed 64 investigations, 18 of which had previously been referred to NRC.
01 concluded that 35 of the 64 investi-gations reviewed were not what 01 perceived as satisfactory or acceptable j
investigation, basing that perception on cuality of concernee interviews, lack of corroboration,- or biased sources of corroboration and unsupported responses. O! determined that approximately 17 additional SAFETEAM investigations of the 64 reviewed should have been referred to NRC. Those I
investigations contained concerns relating to harassment and intimidation, falsifications to include forgeries, resume and certification falsification.
and apparent construction deficiency cover-ups.
O! views the Femi 2 SAFETEAM as a concept, which if managed and staffed by
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experienced investigators, could become an effective measure toward combatting
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the voluminous number of employee concerns which tend to result from the high j
visibility and safety significance of nuclear construction. However, the-Femi 2 SAFETEAM appears to have several fundamental flaws in the implementa-tion of their program, i.e., interviewing, investigation, and organization.
1.
The Femi 2 SAFETEAM interviewers, on occasion, conducted group inter-views. Often, the. interviews were not sufficiently probing to the heart.
or. substance of the concern.
Generally, the interviews were regarded as shallow. A review of the backgrounds of the Rensis-Likert interviewers indicates a lack of any previous background in interviewing for in-depth cor
--" dino items of wrongdoing or technical-related concerns.
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indicate a substantial amount of experience related to organizational-review and report oriented endeavors.
The interviews, as a general rule, indicated no apparent probes into the who, what, when, where, how, and why, which is so necessary in an interview of the type required by the SAFETEAM investigators. The apparent attempt to interview in groups was an obvious failure, even on occasion being voiced as such by the individuals being interviewed.
2.
The SAFETEAM investigators, though qualified engineers, had no previous investigative experience as to developing leads, corroborating concerns, or gathering evidence.
3.
The SAFETEAM organization had insufficient procedures for the investi-gators to follow.
SAFETEAM had no concept of how wrongdoing concerns relate to the Code of Federal Regulations or Atomic Energy Act, and more basically, had no clear definition of wrongdoing other than police-type violations. Also, the SAFETEAM, evolving from an internal audit function,,
in most cases, resolved the concerns by citing codes, procedures and policy of Deco and contractor organizations in an apparent attempt to describe how thingt should be taking place rather than directing efforts toward identifying what had occurred and what the motivation was for that occurrence.
During the 0! review, an interesting memo from R. 6. Kunkle, the Director of the SAFETEAM, was found.
Dated May 3 1984, it revealed the levels of review through which the SAFETEAM responses m,ust travel. According to Kunkle, a review committee made up of Peter Marquardt, representing the Legal Department; Bert Heffner,' representing Public Affairs; and Don Wells, representing Quality Assurance, make up the review committee.
Kunkle's memo indicates that the
. Legal Department wants the response to stand alone and support the company in a legal or quasi-legal action.
Public Affairs needs the answer to be palatable to the public. Quality Assurance, according to ~Kunkle, wants the
- response to be. acceptable according to the re'quirements of the FSAR, Project Procedures QA standards, etc. According to Kunkle, it is suggested that some philosophies may need to change.
(Attachment 91) 01's overall conclusion from the SAFETEAM review can best be described as an audit program which failed as an effective investigatory program. The safety.
significance of the SAFETEAM shortcomings, if any, is not for OI to analyze; however, the investigation aspect of that program is an unacceptable substitute for 01's regulatory function.
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FERMI 2 SAFETEAM CONCERNS 1867 WRONGDOING INVESTIGATIONS WRONGDOING INVESTIGATIONS REFERRED TO Deco NUCLEAR SECURITY REFERRED TO NRC:01 3-18 SAFETEAM INVESTIGATIONS REVIEWED BY 01 4
01 PERCEIVED ADDITIONAL REFERRABLE UNSATISFACTORY TO O!
35 17 i
q CATEGORIES OF WRONGDOING ONCERNS CERTIFICATION H&I FALSIFICATION.
FORGERY QUALIFICATION COVER-UP 11 15 4
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- FGR g gpIATE RELEASE January 8, 1987
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CLNTACT:
Shirley Steinman (SECLk) f.c 313-242-2088 i
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Mary Johnston (SEC0h) s-K
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313-477-1670
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PRESS CONFERENCE ANh6UNCEMENT h18 730- 533 Jennifer Puntenney (SEC0k) 313-477-3441 r
,FErtNI _2, SAFETY INVES'iIGATION RESULTS ANNOUNCED
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BY NATIONAL,PUBLIC INTEREST GROUP i,
Monrce---The Safe Energy'boalition of Michigan (SECOM) will hold a press conference to an: owceithe' Government Accountability Project's results of a 6-month prel3dinary investigation into safety issues at the Fqrmi 2 nuclear pow'ar plant, which is 35 miles southeast of De-troit.
The press conference will be:
h'EDNESDAY, January 14, 12)2 9:30 a.m.
Fr.rmington Hills Community Library 32737 W. 12 Mile Road (west of Orchard Lake Rd.)
Farmington Hills, Michigan 313;552-0300 Representatives from SECOE.and GAP will speak at the press conference.
Spokesperson, Jennifer Puntenney, of the Safe Energy Coalition of l
Michigan, long-time opponents of Dc t' oit Edison's Fermi 2 nuclear r
incility, stated, "The problems at Fermi 2 are not subsiding but con-
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i inue-to grow in complexity rN1 n'ainbar.
'j t It is reckless and irrespon-1 si'cle for the Nuclear Regulatory Commission (NRC) and the Detroit
' Edison Company to continue on this dangerous course.
The Government Accountability s (GAP) report substantiates our concerns and documents l
7 worke rs' safety allegations.
As a result of the GAP investigation, t
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SEClk Frsos Announcement Pag 2 Two-SECOM will announce its intended course of action.9 In May,1986, SECOM and the Sisters, Servants of the Immaculate Heart L
of Mary (IHM), a religious order established 140 years ago in konroe, retained a non-profit public interest law firm based in Washington, D.C. after workers asked for help in publicly disclosing problems at l
Fermi 2.
This firm, the Government Accountability Project, began an investigation into Fermi 2 workers' concerns and allegations about safe ty.
GAP's Midwest project director, Billie Garde, stated.
- GAP has com-pleted the preliminary investigation begun last spring regarding Fermi 2.
The conclusions of this probe confirms what many in the Detroit area have come to believe, that is, something drastically wrong-occurred during the engineering, construction, and inspection of the Fermi 2 project.
Members of the workforce, most of them now located at other plants around the country, believe that Fermi 2 is unsafe in its current condition."
Garde explained further that, O It is GAF s belief that the only way i
to determine the root cause and therefore the extent of the problems of the plant is for the U.S. Nuclear Regulatory Commission to take control of the SAFETEAM files and conduct inspections and investigat-tions into the issues raised by workers.
Something must be done about these problems.
The NRC is caught in its own ridiculous bureaucratic hiding place.
This is not an acceptable solution where issues of health, safety,and cost are so important.N Detroit Edison started the SAFETEAM program, that GAP refers to, in 1983.to allow workers to voice concerns internally to the company.
The concept is now patented and has been sold to other utilities, but not without similar problems that have occurred at Fermi 2.
SEC0k pro-tested early on to the NRC about the use of the SAFETEAM program.
The NRC only examined 10 percent of 1,867 worker allegatio'ns in 1985
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In July,1986, the NRC's Office of Investigations released a report l
criticizing the program as fundamentally flawed and on the whole useless.
At $ 4.23 billion, Fermi 2 is currently operating below 20% of full power due to the problems at the plant and the NRC's determination that Edison's personnel do not have enough operating experience.
These delays are costing Detroit Edison over $ 1 million a day in interest alone.
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id:ntify worker concems that may have been missed.
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. instituting the SAFETEAM' program at your i
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fu;l load and commercial operation by detecting problems early - often before normal inspections and reviews would find them, o Off;r a diiect savings in labor, materials and legal costs by reducing the chance of a problem surfacing A
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I o Reduce the likelihood that employes will air their OdS...
concems to people and organizations outside the proj:ct.
SAFETEAM' takes over whero other QA programs o Show appreciation to both contractor and utility leave off. The key is simple - confidentiality. The cmployes for the fine work they have done, and as SAFETEAM' program is:
I important members of the construction team.
Comfortable - Confidentialinterviews - held by trained SAFETEAM" is a tum-key operation that provides interviewers who are not utility employes - permit your GAFETEAM" manager all of the necessary construction, engineering and quality assurance personnel and materials. It can be up and running at personnel to voice concerns and receive credible your f cilityin a matter of weeks.
responses in a comfortable setting.
SAFETEAM' is a comp;ete, well-tested package that Versatile - SAFETEAM' identifies concems two savao you the time and money you might otherwise ways. Eicit interviews afford construction trades workers spend trying to develop a similar program of your own.
an opportunity to identify any safety or cor:struction,th practice concems. Regularly scheduled interviews wi
, Thomugh investigations of the workers'concems are on-site engineering and quality assurance personnel
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- Provide all necessary informational and on site SAFETEAM' OWers project workers the opportunity pmmdional materials.
to express their concems in confidentialinterviews.
- Thoroughly orient your management on E ch concemis thoroughtyinvestigatedanda SAFETEAMs operation.
tesponse is then mailed to the worker.
- Install a computerized tracking system with all necessary software and hardware -including the Computers.
- Fumish support personnel to assist with the program start up and provide additional assistance.
Anonymous - The workers are assured that their and direction to management as needed, concerns will be identified only by number. Not even the investigating team knows who voiced the concems.
- Hold P'riodic P'rformance reviews with management.
Credible - The independent team investigates and files a written report on each concern. The results of each investigation - and a summary of any corrective a
e TeH You actions - are then sent to the worker who filed the concem. The results also are reported to management.
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Who Handles For more information on how the industry proven Th DUtEaai SAFETEAM' program can help your project's n
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eae quality and safety, please call or write. We'll be glad to provide whatever assistance you need.
Liks any business activity, SAFETEAM' requires facilities, equipment snd personnel. The SAFETEAM' SAFETEAM' program can be installed at your Suite 2300,660 Plaza Drive ficility in a short time, with all major materials and Detroit, IWichigan 48226 support personnel provided to your SAFETEAM' (313)237 7167 o Provede trainea interviev.srs and investigators.
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8 8 8 Ong nally developed by Detroit Edison for use at its Fermi 2 nuclear power plant. SAFETEAM' has On a nuclear power plant construction project, proven highly effecthre there and at other nuclear workers can contribute more to quality assurance power plant projects across the country. Savings as th:n any engineering program devised. Yet, despite a result of SAFETEAM' at the Fermi 2 power their best efforts under stringent quality assurance plant alone are estimated at more than $30 million.
ruts, flaws can occur. Whether from design errors, Direct sub standard components, assemb:y or construction SAFETEAM' is a one-on one communications problems or human mistakes - the eartier a flaw is discovered and corrected, the less chance there is for program that encourages contractor and utility employes to report their concems and allegations costly delays, to the utility early enough for timely correction No matter how good your employe relations are, there rather than to outside organizations on the eve of are always situations where employes are reluctant to licensing.
speak up for fear of reprisal. A program that provides Recognized workers with a " safe" release, while identifying The SAFETEAM' program has received the problems skrfy and accurately, can save a project support and encouragement of the Nuclear valuable time and money-and preserve the Regulatory Commission (NRC) the Atomic reputation of the sponsoring company, industrial Forum and the Institute of Nuclear Power Today. such a program is available. It is a unique Operations. In 1983, the NRC commended Detroit promote the safe construction, cperation and SAFETEATE program wn:ch aggressively eventualpublic acceptance of a nuclear power plant.
pursues employe safety concerns."
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I On June 11. 1985, at approximately 12:00 noon, 01:RIII Investigators James Kalkman and Harold G. Walker met at the Fermi 2 Nuclear Power Plant
- located in Monroe, Michigan, Paul Byron, Senior Resident Inspector.
11.S. Nuclear. Regulatory Commission (NRC); Stuart H. Leach, Director of Nuclear Security, Detroit Edison Company (DECO); Walter J. Kaczor Director of the SAFETEAM, Deco; and Dr. Wayne Jens, Site Project Manager,. Fenni 2, DECO.
During this meeting, the purpose of the Office of Investigations' (01) presence was relayed to the Deco representatives.
01's presence was characterized as an assist to the NRC Region III staff and was not characterized as an 01
- investigation.
Paul Byron, the Senior Resident Inspector for tb WDr =+
Fermi 2, at this time briefly explained the SAFETEAM concept to the investigators as understood by the NRC.
The process by which exiting employee concerns, or employees who are not exiting, but who have concerns, are made known to the SAFETEAM was addressed by Mr. Walter Kaczor, the Director of DECO's SAFETEAM.
According to Kaczor, employees are interviewed by a contract firm from Ann Arbor, Michigan.
Mr. Kaczor stated that the finn of Rensis-Likert was contracted by Deco for
-that specific purpose. The interviews, according to Kaczor, are tape recorded when possible, and forwarded to the SAFETEAM investigators. Anonymity is a major concern of Deco in this regard, and each employee who expresses a concern is promised anonymity. This is accomplished through the assignment of an identification' number to each employee who expresses a concern. That number can only be matched with the identity of the employee through the interview team of Rensis-Likert.
The SAFETEAM investigators work from the iaped interview an'd/or a safety concern memo originated:at the time of the interview by the Rensis-Likert interviewer.
Upon receipt of the. concern by the Director of the SAFETEAM, the concerns are categorized in accordance with SAFETEAM Operation Criteria dated
.lenuary 2,1985'(Attachment 1). The SAFETEAM investigators are required by procedure to forward to the Director of Nuclear Security DECO (who in this case is Stuart Leach), any items of " wrongdoing" which was defined by Kaczor, in general terms, as those concerns which require professional investigators, e.g., forgery, theft, breaches of security, etc.
At approximately 12:30 p.m. on June 11, 1985, the meeting was concluded with the Deco representatives pledging full cooperation with 01 in the forthcom.ing review. On June 12, 1985, at approximately 9:00 a.m., 01 Investigators James Kalkman and Harold G. Walker met with Arnold J. Benes, the General Auditor for Deco and the individual to whom Walter J. Kaczor, the Director of D,Eco SAFETEAM~directly reports.
Mr. Benes related the history of DECO's SAFETEAM to Investigators Kalkman and Walker.
Mr. Benes stated that because he reports directly to the Chief Executive Officer of DECO, he feels the independence of the SAFETEAM is assured. Benes also stated that the SAFETEAM is the outgrowth of DECO's previous Quality Concern Report Program, which was characterized by Benes as more of a public relations program, managed by the Public Relations l
Department of DECO.
l l
l 4
However, according to Benes, the SAFETEAM is a serious effort by DECO to obtain concerns of employees and address t or as referred to by DECO, the 'concernee, hose concerns before the employee,
" goes public with information which may not be accurate.
Mr. Benes indicated that in this regard, the number of allegations made public about the Fermi facility has been drastically reduced and Deco has now been afforded an opportunity to better address the concerns,
of employees.
Mr. Benes further related that the interviewers employed by Rensis-Likert are trained essentially by DECO since, according to Mr. Benes, Rensis-Likert is a public relations finn out of Ann Arbor, Michigan.
Mr. Benes assured both Kalkman and Walker of his complete cooperation, which was echoed by Mr. Kaczor.
Benes further stated that he pioneered the "onsite" presence of resident auditors, and in that capacity had, in the past, uncovered many problems, which amounted to approximately 50% of the electrical person 1979 time period.
the centext of fraud or contract administration theft.Mr. Benes defined hi Mr. Benes further stated that areas of concern forwarded to the Nuclear Security Unit, which is forgery, duress, harassment and. intimidation, and " police typ investigations."
On June 12, 1985, at approximately 2:00 p.m., 01 Investigators James Kalkman and Harold Walker were escorted to the Rensis-Likert interview trailer and sat through the presentation exiting employees are required to attend.
The presentation consisted of a. video taped appeal by the Chief Executive Officer of DECO for employees with concerns relating to the construction of the plant or any concern of health and safety to be presented during the exiting interviews.
The CEO also indicated that the employee identities would remain At the conclusion of the video presentation an interviewer extends anonymous.
the opportunity to any concerned employee. to voice their concerns.
The concernae is always asked to allow that the interview be tape recorded; however, if for'some reason the concernee is uncomfortable with a tape recording, the interview is recorded by memo dn a " Safety Concern Report" (Attachment 2).
The concernee identifying data is maintained by Rensis-Likert, and any further contact with the concernee by the SAFETEAM investigators is through Rensis-Likert.
Emm 9 c-
%ethod by"which concernee interviews are conducted. )menenHI prior to her becoming employed by Rensis-Likert, she~was h
l
-- - _ training in interviews consisted of actually conducting inte and, as Freuult of on the job experience, becoming more proficient. Y~rviews,
stated that additional interviewers were called when necessary to accommodate nstantes when there are increased numbers of exiting employees.
In addition,
' stated that informaton was also accepted from " walk-ins" and telephone calls."
I 5
i
The following documents were received from the SAFETEAM Director, in response to requests from 01 Region III:
1.
SAFETEAM O Services, peration Manual, Copyright 1984, Utility Technical Inc. (Attachment 3).
This document consists e j
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a-II.
Memo dated January 2,1985 to Wayne H. Jens and Frank E. Agosti from W. J. Kaczor, Director of the DECO..SAFETEAM (Attachments 1 and 4). The subject of this memo is: Normal and Emergenc Operation Criteria for Handling Nuclear Safety-Relstad."y SAFETEAM Only).
evaluations of concerns into the following categories:
1.
Related to specific items of equipment or systems.
~
2.
Related to a procedure, test, process QA standard, practice, etc.
3.
A management problem, attitude, and general concern.
4 Industrial safety.
5.
Miscellaneous.
or 2 shall be investigated first and have priority o or 5.
A notation indicates that a " wrongdoing" allegation will be so site (Paul Byron). stamped by the SAFETEAM Directo.r and sent to the N This memo also addresses emergency SAFETEAM operation criteria for handling nuclear safety-related QA I only concerns during an i
emergency situation.
The classification remains the same as the previously indicated criteria regarding normal SAFETEAM operation.
Memo dated November 29, 1984 to Mr. W. H. Jens from A. J. Benes regarding the subject of an Allegations Task Force.
alerts selected individuals that they may be called upon to assist This memerandum the SAFETEAM.
be called up in tThose indicated personnel would, according to the memo, adversary groups.he event of a last minute surge of allegations from i
III..
Fermi 2 SAFETEAM Paper Flowchart (Attachment 5).
indicates the process by which a concern is addressed by the This document SAFETEAM from the concernee.the interview stage to the concern being mailed to 1
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IV.
Enrico Fenni Unit 2 Project Quality Assurance Report received f rom
>/
, % Interview Manager of the SAFETEAM (Attachment 2).
It
'is numbered 00674 and is a report which is filled out by the inter-
)
viewer when a concern is brought to their attention.'f fSEf552NMENifDANENM63535d.l
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V.
Concern Report (Attact. ment 6), which is given to individuals exiting the plant who are unwilling to address a concern with the interviewer; however, who may feel that they could write their concern out ar.d mail it back to the SAFETEAM. 'According to the Interview Manager,
[N;each individual receives a postage paid envelope with a document referred to as a Concern Report, which can be mailed back to the Deco SAFETEAM, VI.
SAFETEAM Brochure (Attachment 7), which describes what the SAFETEAM will "do for you." The brochure indicates that savings as a result of the SAFETEAM at the Fermi 2 power plant alone are estimated at more than S30,000,000.
VII.
SAFETEAM Investigator Duties (Attachment 8). This document indicates that the SAFETEAM Investigator is charged with the responsibility of resolving the concern of exiting employees by investigating all avenues of the concern and arriving at an equitable solution to the satisfaction of all parties involved.
The parties involved are listed as follows:
1.
Director, SAFETEAM Investigations 2.
The SAFETEAM Steering Cormfittee, which includes:
T. A. Alessi - Director, Project Quality Assurance H. F. Heffner - Director, EF2 SAFETEAM P. A. Marquardt - Senior Attorney, Environmental and Nuclear Regulatory Affairs D. A. Wells - Manager, Quality Assurance Interviewee VIII.
Personnel Job Descriptions and Critical Functions regarding the SAFETEAM Manager (Attachment 9).
Approximate date of this document is June 12, 1984.' In this category, it is indicated that the SAFETEAM Manager, in this cae that would be Walt Kaczor, reports to the General Auditor (Benes).
Regarding the job des-cription and critical functions, it is indicated that the manager works with site contractors, site operation, site security, and site engineering.
It is also indicated that he works with the NRC on investigations and with the public and press on media contacts.
In regard to the manager's function, " freedom to act" is addressed.
"the SAFETEAM operation is a function outside the license of the NRC and concerns can be investigated without procedures reviewed t
H' 7
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4 -
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^
by the'NRC." No reports to the NRC are required until and unless a
investigation shows a violation of procedures, etc. However, 1
wrongdoing must be reported to the NRC Resident Inspector as soon as recorded." Approximate date of this document is June 12, 1984 IX.
SAFETEAM-Future-Now Until Comercial Operation dsted May 17, 1985 (Attachment 10): This document contains the role of the independent consultant of the SAFETEAM interviewer, the role of the SAFETEAM investigators, the SAFETEAM program, and the continued support and i
interest of top management regarding the SAFETEAM.
X.
" Interface Between SAFETEAM and Nuclear Security" dated June'18, 1985 (Attachment 11). This document is from Mr. W. J. Kaczor, the Director of the SAFETEAM, to S. H. Leach, Director, Nuclear Security.
This memo, for the' record, is to establish a procedure that clarifies the interface role between SAFETEAM and Nuclear Security regarding concerns of " wrongdoing" and information to be-withheld from the public. - The document addresses violations of law-by stating "whenever, during the course of-a SAFETEAM investigation, it becomes apparent to the investigator that a violation of the law is an issue, the investigator will infonn the SAFETEAM Director.
The SAFETEAM Director will make a review and notify the Director of Nuclear Security where there is a violation."
A clarifying footnote to the above paragraph states that "this may include violations of the 10 CFR 50, Code of Federal Regulations particularly.as related to nuclear safety and health concerns.
Key words which may aid in discerning a violation would include duress, forgery, back dating documents, unqualified, retribution, falsi-fication, threats plus other words which would imply an' intent of a wrongdoing situation which may be unlawful."
INVESTIGATOR'S NOTE: The 40 CFR 50 notation as it appears in this document was not part of the SAFETEAM's operating. concern prior to investigators Kalkman's and Walker's review and meetings of June 11-13, 1985 with DECO representatives.
XI.
Fermi 2 SAFETEAM Weekly Status Report dated Week Ending June 14, 1985(Attachment 12).
This document indicates that the concerns received to date totaled 1867.
The total concerns closed through investigation were 1841.
Those concerns in review were noted as 13, and those concerns under investigation were noted as 13.
X11.
SAFETEAM Exit Interview Process dated April 22, 1985 (Attachment 13).
On June 18, 1985, Walter Kaczor, the current Director of Deco SAFETEAM, was requested by Harold G. Walker, Senior Investigator, NRC:01, Region III, to provide a list of all past and present SAFETEAM investigators, and to also make available the SAFETEAM investigators' educational and professional backgrounds and additional' or previous work assignments with Deco or other contractors operating at Fenni 2.
On June 20, 1985, the following information was provided as requested.
(Attachment 13A) 8
. Detroit Eoison ENRICO FERMI UNIT 2 FROJECT SAFETEAM Date:
May 3, 1984 SIG 84-176 To:
M. G. Sigetich', Asst. to Director Project Design From:
R. d. Kunkle
[ 11 W
6 Director, SAFETEAM
~
Subject:
Concern No. 1304-C Attached are copies of a meno and a response prepared from the memo to Concern No. 1304-C.
I'm sending these to you so that you can get a feel for the requirements of the Review Committee. The committee is Peter Marquardt, representing the Legal Deparment; Bert Beffner, repre-senting Public Affairs; and Don Wells, representing Quality Assurance.
Each of these individuals is concerned that the answers will satisfy the needs of the company from their perspective. As an example, Legal wants the response to stand alone and support the company in a legal or quasi legal action. Public Affairs needs the answer to be palatable to the public. Quality Assurance wants the response to be acceptable to the requirement of the FSAR, project procedures, QA standards, etc.
Recognizing the above needs, please revidw the attached docunhnts.
The response to 1304-C needs to be reworked.
It also suggests that some philosophies need to change. Perhaps you'll want to review the comments with your staff. In any case,.I'm trying to help you satisfy the demands of the requirements of SAFETEAM. If I can be of further assistance don't hesitate to call.
RCK/asr cca Chron file File 1304 ATTACHMENT 91 4
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Their designs aren't bed, 6dt they could have come p with some better designs.
- e.g. RHR complex susp-lines.are frosen solid.
- Fusps were rated at 24 gals /sinute;-they are putting 2 and
-4.
I
- These are not QAl-but it does sake you wonder.
/s Cfif0*SSt-In regards to the freezing of the reservoir, a feMt (No.111) exists on this problesc Meetings have been held and it has been determined i
that this proble.s must be resolved before fuel load.
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1 rn #2 above, regarding RHR complex susp lines being frozen wyt.m,M. N eolid, SUEA, Field Engineer, Project Design were not made svare of
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this probles. If the concernee feels that it is still a probles that J
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will not be addressed by the resolution of 5055E #111, he should I;///FJ#^
document the probles in the ' appropriate paperwork (S.F.R.) and forward l,ggy it to Engineering.
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n regards to the " pumps being rated at 25 gals / minutes yet putting l
only 2-4 gals / sin." during the evolution of the RHR complex design, out
[If #
- there was the possibility that one or more service water pumps would M/f 3 gs be located in the pits.
Susp pumps capable of handling stuffing box
'gl( leak off, floor washdown, etc. were selected. As the design was
- CA
' 7 brought to a concivaion, no service water pumps er any other equipment i,
.7.
was located in the pits.' The susp pump sising was not revised.
Start-Up issued SFR 1224 which said the sump pumps were delivering 5 CPM instead of 25 GPM. The discharge piping was temporarily-disconnected and the pump retested. The pump performed eatisf actorily, and the discharge piping resistance identified as the cause for the low flows originally observed. Since there wasn't any safety related equipment in the piping pits and the existing susp pumps would only be expected to handle inadvertent water spills the 5 GPM systes capability was acceptable to Engineering. The SFR and F2583-2416 warti issued to that aff ect.
Sump capacities of 5 CPM are still considered acceptable as of this date.
If the concernes has any further questions he can feel free to contact the gAFETF.AH for further review.
Concer 3
-D ntates: "Other contracts 1.
Found 24" circular piece of plywould in pipe twice - E1100 systen.
i 2.
Someone left a welding blanket in pipe."
This concern is being addressed by management.
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March 8,1964'
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.STC 84-pago 3 L
2.
Their designs aren't bed. but they could have cose up with some better designs.
e.g. RHR complex susp--lines are frosen solid.
~'
Pumps were rated at 24 gals / minute; they are putting 2 and 4.
These are not QAl-but it does aske you wonder.
In regards to the freezing'of the reservoir, a h5No.111) exists.5Mr@)
on this probles. Meetings have been held and it has been determined that this proble,a must be resolved before fuel load.
In concern #2 above, regarding RHR souplex sump lines being frozen solid, SUEA, Field Engineer, Project Dodgn were not made aware of this problem. If the concernee feels that it is still a problem that will not be addressed by the resolution of @ #111, he should d'O 8 document the probles in the appropriate paperwork (8.F.R.) and forward 7
it'to Engineering.#
gg 6A k In regerds to the " pumps being rated at 25 gals / minute.yet putting out only 2-4 gals / sin." during the evolution of the RHR complex design, there was the possibility that one or more service water pumps would be located in the pits. Sump pumps capable of handling stuffing box leak off, floor washdown, etc. were selected. As the design was brought to a conclusion, no.' service water pumps er any other equipment was located in the pita. The sump pump sising was not revised.
Start-Up issued SFR 1224 which said the sump pumps were delivering 5 CFM instead of 25 CFM. The discharge piping was temporarily-d disconnected and the pump ratested. The pump performed satisf actorily, and the discharge piping resistsace identified as the cause for the low flows originally observed. Since there wasn't any j
safety reisted equipment in the piping pits and the existing sump pumps would only be expected to handle inadvertent water spills the 5 CFM systes capability was acceptable to Engineering. The SFR and F2883-2416 were issued to that affect. Sump capacities of 5 CPM are still considered acceptable as of this date.
If the concernes has any further questions ha can feel free to contact the SAFETF.AH for further review.
Concer 3
-D states: "Other contracts T
.S Found2p\\" circular p'iece of plywo'uld in pipe twice - E1100 1.
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system.
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gen omrtaTc s veldt :; u-a-e in nipe."
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fI ENRICO FERMI UNIT 2 PROJECT ENGINEERING RECEIVED Dates March 20, 1964 Mg g g To:
- N3 h-I
$AFETEAM Investisaeor From:
Louis Bertani Supervising Engineer-EG45 W.H. Street M v
Supervising Engi aer-EGl4 Re ference s Memorandum STG 84-072, dated March. 5,1984 1
Subject:
Response to SAFETEAM Interview No. 1304-C. Part2 As a result of Interview No. 1304, a concern was espressed which stated,
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" Troy said that reservoir would not freeze. If it did, no damage would occur.
- at one point we had 4" of ice.
(
- we wrote an NCR."
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' The FSAR stated that the reservoir was not " expected to freeze.
g Our cal-
-culations indicated that approximately 5" of ice could form in the worst i
scenario, i.e., a record cold snap during an extended shutdown and no Y
input to the reservoir.
The structure has been analysed for 1g" of f.hestice, and the results indicate no damage would occur.
We had a record cold snap during an extended outage and did in fact get 4" of ice and no damage.
\\f 1.
The FSAR is currently being updated to reflect this occurance.
^
'd As a result of Interview No. 1304, a concern was expressed which stated,
/
"Their designs t bed, but they could have come up wa6u. q better designs. - e.
RHR complex sumps - lines are frozen solid. j
. were rates at a gat.fninu6, 6ncy us ruu lag 4 and 4.
~
- These are non QAI - but it does make you wonder."
We have conducted an investigation relative to the above stated concerns and find the concerns are not a problem and there is no evidence that in-dicates there has been a deviation from established requirements. The fol-loving points were established as a result of the investigatient 1
s,
)
4 Memo t o r
.WN '
M2rch 20, 1984 I
f i
SUEA, Field Resident' Engineering and Project Design are not i
e M
avere of freeze problems in the RiiR Complex sump lines.
Preoperational testing determined that the discharge flow e
from pumps X4103C025 and X4103C026 did not exceed 5 GPM.
(
SUEA accepted th%s condition because no substantial input to the sump is possible and accordingly the approximate 5 GPM capacity is sufficient.
Nuclear operations is aware of this condition and accepted the o
system when it was turned over..
RJA/pa ocs R. A. Varre 4
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