TXX-4696, Responds to Comanche Peak Task Force Rept of Review & Evaluation of Allegations of Intimidation & Harassment of Employees at Facility,Per 851104 Request
| ML20151W600 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/07/1986 |
| From: | Beck J, Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Harold Denton, Noonan V NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20151W585 | List: |
| References | |
| TXX-4696, NUDOCS 8602120104 | |
| Download: ML20151W600 (34) | |
Text
{{#Wiki_filter:- .. Log No. TXX-4696
=
. File No. 10066.5 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER . 400 NORTM OfJVE STREET. I B. 55 . DALLAS. TEXAS 75301 February 7, 1986
."00Jes#SEUS$
Mr. Harold R. Denton Director, Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555
~ ATTN: Mr. Vincent S. Noonan Director, Comanche Peak Project
SUBJECT:
RESPONSE TO THE REPORT OF THE COMANCHE PEAK INTIMIDATION PANEL DOCKET N05. 50-445 & 50-446
Dear Mr. Denton:
On October 18, 1985, the Comanche Peak _ Intimidation Panel provided to the Comanche Peak Task force its Report of the Review and Evaluation of Allegations of Intimidation and Harassment of Employees at Comanche Peak Steam Electric Station, Units 1 and 2 (" Report"). By letter to me dated November 4,1985, Mr. Noonan requested that Texas Utilities Generating Company ("TUGC0") respond to the Report. By letter to me dated January 13, 1986, it was requested that our response be filed by February 7, 1986. This submittal responds to these requests. I. Introduction The Report confirms that a climate of harassment or intimidation did not exist at Comanche Peak, a conclusion with which we agree. While the Report identifies particular incidents that may have constituted harassment or intimidation, the Report concludes that these incidents were not part of a broader climate of harassment or intimidation. The i Report also notes that these incidents apparently have not resulted in poor quality work. Report at 7-8. We agree with the ultimate conclu-sions of the Report, but believe that reasonable arguments can be made as to whether particular incidents did or did not constitute harassment or intimidation. The construction and operation of a nuclear power plant is a complex endeavor involving thousands of people and millions of human contacts and decision points. The leadership and management of personnel in this process in many respects is as challenging as actual plant construction. The Report identifies certain past management practices at Comanche Peak that, according to the Intimidation Panel and Study Team, may not have been conducive to producing a quality product. Accordingly, we have scrutinized this Report to assess current management's dedication to 8602120104 DR 860210 ADOCK 05000445 PDR A usysssou or rexAs ursurses us.scrusc coursur
Mr. Harold R. Denton February 7,.1986 Page 2 assuring that a " quality first" attitude is instilled in the work force involved in the construction and operation of Comanche Peak. We believe that the management and programmatic actions taken during that past.few years demonstrate such dedication and provide assurance that such an attitude exists. We discuss these ' actions in Section III of our comments. A lengthy factual record has been developed on all of the specific incidents identified in the Report. We have reviewed the record and the
, . Panel.'s Report and do not necessarily. agree with the conclusions reached in the Report as to all of these incidents. However, there is ample record on these incidents and we see no merit for purposes of this response to rehearse that record here. We would point out that even if the Intimidation Panel's conclusions regarding the individual incidents are correct, we are satisfied that, while certainly of concern to us, those incidents do not have independent safety significance. We agree with ' the findings of the Study Team, adopted by the Panel, that the
" number of alleged incidents of intimidation, allegers, and named intimidators was small" and "well within the number of events that would
.be expected to occur even under the best of circumstances." . We also agreewiththeultimateconclusionthattheincidentsdonotestaplisha pervasive climate of intimidation. Supplementary Report at 44. This is the finding that we believe is significant in terms of resolving the question of whether the pending license application should be granted.
II. Observations on the Report For purposes of this response, the most significant conclusions of the Report are directed at past " management style". Generally, "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 generated mistrust, suspicion and lack of management credibility." Report at 8. We have taken this observation seriously,'and over the past months have aggressively assessed the " management" issue. We address below our observations on the Report. In Section III we address the management and programmatic actions which we believe respond to the conditions that gave rise to the Report's findings. I The Study Team, a group of consultants to the NRC, issued two reports adopted by the Panel. (See " Comanche Peak Steam Electric Station: Alleged Climate of Intimidation", EG&G Idaho, Inc. (September-1984) ("EG&G Report"); " Comanche Peak Steam Electric Station: Alleged Climate of Intimidation Supplementary Report", EG&G Idaho, Inc. (September 1985) (" Supplementary Report"). The EG&G Report and the Supplementary Report are attached to the Report of the Intimidation Panel transmitted on November 4, 1985.
Mr. Harold R. Denton February 7, 1986-Page 3 Comanche Peak is. the first nuclear project undertaken by TUGCO. It is not overly simplistic to state, nor are we too proud to admit, that we have indeed learned from experience. We believe that our management has always been committed to constructing and operating a safe nuclear power plant. We concur with the Panel and Study Team that, while there have been isolated situations that could have been handled better from the standpoint of employee relations and communications, there is no evidence that prior management directed or condoned any systematic discouragemeat of inspectors to do their jobs. Moreover, we reiterate the observation of the Panel that, even assuming some undesirable management practices, "the environment created by these management practices would not necessarily lead to intimidation or re's ult in improper construction or quality control." Report at 8. We believe that the description of prior " management style" at Comanche Peak presented in the Study Team reports is a fair appraisal, under the circumstances. Some of the Study Team observations most likely would apply at many large construction sites, not only at Comanche Peak. For example, EG&G found a basically conservative style with an emphasis on error prevention and adherence to preset procedures. The atmosphere was found to be " task-centered", with accomplishment of the objective (getting the job done) being "the most important priority (which) consumes much of the attention of supervisory personnel." EG&G Report at. 38. These broad observations could be applied' to many utilities' construction projects and perhaps reflect conditions that are almost inevitable at a construction site the size of Comanche Peak. On the other hand, EG&G more significantly found the atmosphere to be
" tense and stressful due to the complexity of schedules and interfaces which tend to be potentially conflictful." EG&G Report at 38. We acknowledge that this is clearly not desirable. EG&G found that management had "little tolerance for ambiguity or for the questioning of supervisory demands." EG&G also found that communications were primarily downward and afforded "very little opportunity for interac-tion" and "little tolerance for deviating from information communi-cated downward." Id. at 38-39. Similar observations are made in EG&G"s Supplementary Report. Supplementary Report at 37-43. For example, EG&G found poor communications between QA inspectors and their supervisors, a lack of job training and clear job performance standards for QC inspectors and that "the interface between craft and QC is viewed as an adversarial one." Supplementary Report at 40. In sum, EG&G described a management style lacking " attention to the human dimension." Id. at 43.
We take these findings very seriously and believe that the findings reflect a management style that has been less than ideal for handling employee relations in today's complex world of nuclear power.
~.
"Mr. Harold R. Denton February 7, 1986 Page 4 We have considered these findings and evaluated in that light the .important measures previously taken to improve management, enhance employee relations, and reaffirm a " quality first"^ attitude on the part of-all employees. These efforts are itemized in Section III below. We believe that our efforts will enhance trust and communications between employees and management. We further recognize that " management style", a " quality first" attitude, and " trust and communications" between employees and management are not issues which can.be addressed once and forgotten. These subjective matters are dynamic issues which must be addressed and reaffirmed, through word and conduct, throughout the lifetime of a nuclear plant. Our current management team, staffed with individuals- experienced in nuclear power, is committed to continuing self-assessment and self-improvement in these areas. We are convinced that the management improvements and initiatives discussed in the next Section have assured and enhanced a work environment dedicated to safety, reliability, and excellence at Comanche Peak in which employees do not fear reprisals for identifying safety concerns or questioning safety procedures. III. Actions to Assure Quality First
~
We believe that the following actions are evidence of our commitment to quality. These actions include restructuring top corporate nuclear management, restructuring site and corporate quality assurance / quality control management, instituting training programs to inculcate employees with a " quality first" attitude, providing numerous avenues for employees to raise safety concerns, and interviewing employees involved in quality activities prior to the termination of his or her employment in connection with Comanche Peak. In addition to. these programs, we have issued periodic reminders to employees of- our corporate commitment to quality. Further, when appropriate, ad_ hoc actions such as employee surveys and internal inquiries have been conducted. Each of these-actions is discussed below. We believe that these _ actions complement each other. They involve hiring managers with a proven commitment to quality and a track record of excellence, providing a structure in which those managers can effectively carry out their jobs, assuring employee awareness of the corporate commitment to quality and safety, and providing employees with the necessary tools to bring their concerns to manageme'nt. In short, we believe we have created a working environment which has established and is maintaining a " quality first" attitude on the part of those constructing and operating Comanche Peak.
'Mr. Harold R. Denton February 7, 1986 Page 5 Restructuring Top Corporate Nuclear Management TUGC0 some time ago - decided that new management should be added to
' enhance top management direction of the nuclear program. Such management would provide a fresh perspective and a depth of proven experience to that program. Consequently, TUGC0 undertook to obtain new management personnel with outstanding' management skills and experience in the nuclear industry.
In April, 1984, Michael D. Spence, President of TUGCO, appointed Mr. John Beck as a special assistant to him on nuclear matters. Mr. Beck has extensive experience in the licensing and management of nuclear power reactors, having served 10 years in various roles with the Yankee Atomic 'c'ectric Company, including activities with respect to the Maine Yankee and Vermont Yankee plants. From 1976 through 1980 he served as Vice President, then as Executive Vice President, with Vermont Yankee Nuclear Power Corporation. He also spent four years as a senior officer with a major nuclear power engineering and consulting firm. Mr. Beck's initial role at TUGC0 was to provide an overview of the Comanche Peak project and apply his expertise to assist management in establishing means to address outstanding licensing issues. In - April, 1985, Mr. Spence announced my appointment as Executive Vice President of Texas Utilities Generating Company with responsibility 'for all nuclear activities, reporting to the President of TUGCO. I was formerly the Senior Vice President for nuclear engineering and operations at Northeast Utilities. In my 18 years with that utility, I served in numerous positions related to the management of Northeast's four nuclear power reactors. This experience included responsibility for engineering, construction, and operation of these power reactors. I , previously served seven years as a commissioned officer in the United States Navy, five of which were in nuclear power. At the time of my appointment, Mr. Beck was appointed Vice President with direct responsibilities for licensing, quality assurance and nuclear fuel onagement, reporting to me. Mr. Beck and I spend a substantial portion of our time at the Comanche Peak' site. In.0ctober, 1985, Mr. Austin B. Scott, Jr. was appointec Vice President-Nuclear Operations, also reporting to me. Mr. Scott recently retired from the United States Navy as Rear Admiral and Commander of the Submarine forces of the U. S. Pacific Fleet. Mr. Scott has 30 years experience in engineering, operation and fiscal management related to nuclear- power, including the supervision of nuclear submarine reactors. Mr. Scott's office is located at the Comanche Peak site. J
ma Mr. Harold R. Denton February 7, .1986 4 Page 6 These individuals' proven track. records in the management of quality construction and ' safe operation of nuclear facilities assures the maintenance of the high standards expected by TUGC0 in the construc-tion and operation of Comanche Peak. Restructuring QA/QC Management TUGC0 has also made several changes to the Quality Assurance manage-ment team for Comanche Peak. These changes were made to provide a fresh management perspective and to assure that the high standards by which
. such activities should be conducted are maintained. These changes are also intended to reemphasize the importance of a " quality first" attitude in the workforce.
TUGC0 appointed new managers over quality assurance activities both in the Dallas corporate offices and at the site. In March 1985, TUGCO. appointed James R. Wells to the new position of Director, Quality' Assurance, reporting to the Vice President responsible for quality assurance. Mr. Wells. was appointed on loan from Duke Power Company where, since 1966, he was directly involved in the implementation and management of construction and quality assurance activities at Duke's nuclear -facilities, including nine years as Corporate QA Manager responsible for the design, construction and operations QA programs for seven nuclear plants during construction and operation. At the same time, TUGC0 also appointed Mr. David McAfee as Manager,~ Quality Assurance -(Dallas) and Mr. Phil Halstead as Manager, Quality Control (CPSES Construction), .both reporting to Mr. Wells. These individuals are on loan from Daniel Construction Company. Mr. McAfee has served in various roles involving indust;ial (including nuclear) QA program supervision and management since 1968, including 12 years with Daniel. Mr. Halstead has 14 years nuclear quality assurance experience at a number of nuclear power reactors. In addition, we recently announced the appointment of John R. Streeter as Director of Quality Assurance, succeeding Mr. Wells. Mr. Streeter came to Texas Utilities Generating Company from NRC Region III, where he served most recently as the Technical Assistant, Division of Reactor Safety. He had been with the NRC for the last 14 years and has 25 years nuclear experience with the NRC, private industry and the U. S. Navy. Orientation Programs In November 1983, and May 1985, two orientation programs were conducted in addition to general training programs, the goal of which was to ' inculcate employees at Comanche Peak with a " quality first" attitude. The _ November 1983 program was an audiovisual presentation that made these points:
~.
Mr. Harold R. Denton February 7,~1986 Page 7
. Quality is expected in all aspects of construction;
. Cooperation between craft and QA/QC is expected and harassment or
" bullying" will not be tolerated;
. If a craft employee. identifies what he believes is a nonconforming condition, he should bring it to the attention of his supervisor, to QA/QC personnel, to TUGC0's management or to the NRC;
. If an employee has a concern about quality, he has the right to voice the concern without fear of retribution; and
. Employees may contact management through a telephone " hotline" (discussed below).
Further, in May 1985, Brown & Root commenced a " Quality Supervisor" training program for supervisors of Brown & Root employees. This program is designed to teach, through an initial 16 to 20 hour course, the principles of good management and introduce proper communication skills to supervisors at Comanche Peak. Included in the course are topics such as cuality, safety, motivation, leadership and problem solving techniques. A series of 4-hour follow-up courses is also offered on a variety of management techniques, including counselling employees, delegating duties and motivation of employees. Programs for Reporting Safety Concerns TUGC0 has put into place a number of programs through which employees may report their safety concerns. The programs include means to assure employee anonymity, if requested. The programs have included a telephone hotline, a site ombudsman and the SAFETEAM program. In addition, formal procedures have been issued governing investigations into quality activities. The telephone hotline program was initiated on October 4,1983, at the direction of Mr. J. S. Farrington, President of Texas Utilities Company (Attachment 1), and remains in place. A description of the program is set forth in a letter from B. R. C'ements, the Vice President Nuclear, dated October 25, 1983. (Attachment 2.) This program was announced through audiovisual presentations to CPSES personnel, posters placed throughout the site and paycheck inserts. This program provides a 24-hour method of receiving, in confidence, employees' concerns. The concerns are investigated under the direction of the Director, Corporate Security. Upon completion of an investigation the results are provided, again confidentially, to the employee. Beginning in November 1983, a site ombudsman was available for employees wishing to raise safety concerns. Mr. Boyce Grier, a former Region I director with the U. S. Nuclear Regulatory Commission, served in the capacity of an independent contractor with direct access to tc p management. In May 1985, the ombudsman program was discontinued following implementation of the SAFETEAM Program.
Mr. Harold R. Denton February 7, 1986 Page 8 Also, in January 1984, TUGC0 put into effect a system to initiate, investigate, document and close quality assurance investigations. Concerns to be addressed -through this system may come to the attention of QC supervisors through exit interviews, personal or telephore contacts or questionnaires.
~
The SAFETEAM program was instituted at Comanche Peak in Janury 1985. The SAFETEAM program is conducted under contract with Syndeco, a subsidiary of Detroit Edison, and has been successfully implemented at other power reactor sites. It establishes several means by which workers can raise
' concerns on any topic and receive a full investigation rea rt in strict confidence. The program is under the direction of a fulltime TUGC0 manager and is organizationally independent of site management. It originally ' reported to the TUGC0 President. Upon my arrival it was changed to report directly to' me. All employees at Comanche Peak were introduced to the SAFETEAM program through small group presentations and paycheck inserts. SAFETEAM posters are placed throughout the site and other notices and forms are routinely made available to workers. The program includes toll free telephone numbers and independent reviewers to interview each employee with a concern. SAFETEAM also conducts an exit program ~ where any employee, upon termination of his or her employment at Comenche Peak, is given an opportunity for. an interview and is provided a package which includes a form for transmitting to.
SAFETEAM any concerns the employee may think of later. Since the inception of the SAFETEAM Program several hundred concerns have been
~ brought to SAFETEAM. These concerns range from questions regarding pay and benefits, to specific inquiries concerning plant safety. All concerns and . investigations results are reviewed by a group of senior advisors who assure that the concerns have been fully addressed before responses are provided. Each employee with a concern receives a written response to his or her concern. .
Periodic Reminders of Quality First Corporate Policy There .hava bem a number of reminders to employees of our " quality first" corpw c..e policy. These reminders have- taken the form of personal preNntations to employees by corporate officers and policy announcements issued to employees. For instance, in April 1984 ar.d again in Aprii 1985, Mr. Spence, President of TUGCO, conducted meetings with site QC Iersonnel to reemphasize management's commitment to quality and . support for the performance of their jobs in a " quality first" manner. . Eve, prior to Mr. Spence's meetings, Mr. Clements, then the TUGC0 Vice President, Nuclear, held a series of meetings with the workforce at Comanche Peak. Mr. Clements first met with QC inspectors to emphasize their right and responsibility to report safety concerns to either ~ TUGC0 or Brown & Root management or to the NRC. Mr. Clements also met with Brown & Root employees who were foreman or higher to emphasize TUGC0 and Brown & Root management's support for the principles addressed in the audiovisual presentation (discussed above). n- .,, - -r- - n-- . - , , , , , , - - . . , , - ,a - - - ~ - , ,,.,:--v-- . . - - -w ---, ---- -
Mr. Harold R. Denton February 7, 1986 Page 9 In addition, numerous announcements from corporate management have been made to workers at Comanche Peak regarding the policies concerning . reporting of safety defects and harassment or intimidation of workers. For example, in December 1983, Mr. Spence issued two policy statements to all personnel assigned to Comanche Peak. Mr. T. L. Austin, Jr., President of Brown & Root, separately transmitted these statements for Brown & Root employees at Comanche Peak. (Attachments 3-5.) The first reemphasized the obligation of every employee to identify, document, and report any safety deficiency they believe exists at the plant. It emphasized that acts of harassment or intimidation were prohibited and any employee who commits such an act would be subject to disciplinary action, up to and including discharge from employment. The second policy dealt expressly with harassment and threats, noting again that such acts by an employee would subject the employee to disciplinary. action, including termination. There have also been several letters and notices to employees from management reaffirming management's commitment to safety and quality and prohibiting acts of intimidation or harassment. Most recently, in July 1985, both Mr. Austin and I transmitted letters both to supervisors and employees at Comanche Peak. (Attachments 6-9.) The letters to supervisors reiterated the importance of assuring an atmosphere where everyone feels free to report safety concerns, and that any action or conduct on their part to the contrary will not be tolerated. The letters to the employees emphasized that it is everyone's responsibility to report safety or quality concerns and that management will not tolerate any interference with the reporting of safety concerns. Other Actions TUGC0 has also performed various reviews and investigations to provide greater management awareness of the attitude of employees or facts surrounding specific incidents. For instance, in 1983 a survey of approximately 150 non-ASME QA/QC inspectors was conducted. The purpose of the survey was to give management a better understanding of employee attitudes and opinions about their jobs, supervisors, the work environ-ment and management philosophy. Partly as a result of this survey some QC supervisory changes were initiated. As a final point, I recognize that regardless of the existence of numerous programs and processes designed to establish and maintain a " quality first" attitude and " trust and communications" between employees and management, the most important factor in assuring safe construction and operation of Comanche Peak is the creation of a safety ethic on the part of every employee. It is my deep conviction that such an ethic be instilled in the entire Comanche Peak organization. To this end I have prepared e brochure to be distributed to every employee within my organizatior. (Attachment 10.) This brochure presents excerpts from a speech I delivered last sumer at Stanford University as
~
Mr. Harold R. Denton February 7, 1986 Page 10 part of a course sponsored by the United States Department of State entitled " Management of National Nuclear Programs for Assured Safety." In that speech. I presented my philosophy regarding the creation of a safety ethic. To me, a nuclear safety ethic is a state of mind that-affects the entire organization. The foundation of that ethic is the insistence that nuclear plants be constructed, operated and maintained with the highest standard of excellence. All employees should be dedicated to doing the job right the first time and pay close attention to details and question what might go wrong. I intend to dedicate myself and the persons under my direction to assuring that such an ethic exists at Comanche Peak. IV. Conclusion Management at Comanche Peak has always .been committed to quality and to - safety. Nevertheless, we have thoroughly considered the observations of the Panel with respect to past management style. As discussed above, subsequent to virtually all the incidents discussed in the Report, we have taken aggressive measures with the objective of reinforcing a
" quality first attitude" at the plant. We have implemented major changes in the management *ganization to increase nuclear experience, and have instituted several specific programs to improve the management-employee relationship, QA inspectors' job performance, and the attitude and morale throughout the organization. We believe these measures have addressed and will successfully address all of the Panel's observations on past ' management style and practices.
Yours very truly, u> . c . M W. G. Counsil Executive Vice President Texas Utilities Generating Company By: ( Jdt d. b >_ Joh(/4. Beck Vice President WGC:tj Attachments cc: See Next Page
~
cc: Nicholas S. Reynolds, Esq. Ms. Billie Pirner Garde Bishop, Liberman, Cook, Citizens Clinic Director Purchell & Reynolds Government Accountability Project 1200 Seventeenth Street, NW 1901 Que Street, NW Washington, D.C. 20036 Washington, D.C. 20009 Robert A. Wooldridge, Esq. David R. Pigott, Esq. Worsham, Forsythe, Sampels & Orrick, Herrington & Sutcliffe Wooldridge 600 Montgomery Street 2001 Bryan Tower, Suite 3200 San Francisco, California 94111 Dallas, Texas 75201 Anthony Z. Roisman, Esq. Mr. Robert E..Ballard, Jr. Trial Lawyers for Public Justic Director of Projects 2000 P. Street, NW Gibbs and Hill, Inc. Suite 611 11 Penn Plaza - Washington, D.C. 20036 New York, New York 10001 Nancy E. Wiegers Mr. A. T. Parker Spiegel & McDiarmed Westinghouse Electric Corporation 1350 New York Avenue, NW P. O. Box 355 Washington, D.C. 20005-4798 Pittsburgh, Pennsylvania -15230 William A. Burchette, Esq. Renea Hicks, Esq. Heron, Burchette, Ruckert & Rothwell Assistant Attorney General Suite 700 Environmental Protection Division 1025 Thomas Jefferson Street, NW P. O. Box 12548, Capitol Station Washington, D.C. 20007 Austin, Texas 78711 Mr. James McGaughy-Mrs. Juanita Ellis, President Southern Engineering Company of Georgia Citizens Association for Sound Energy 1800 Peachtree, Street, NW
.1426 South Polk Atlanta, Georgia 30367-8301 Dalla's, Texas 75224 Administrative Judge Peter B. Bloch Ms. Nancy H. Williams U.S. Nuclear Regulatory Commission CYGNA Washington, DC 20555
.101 California Street San Francisco, California 94111 Dr. Kenneth A. McCollom, Dean Division of Engineering, Architecture Resident Inspector / Comanche Peak and Technology Nuclear Power Station Oklahoma State University. c/o U.S. Nuclear Regulatory Commission Stillwater, Oklahoma 74074 P. O. Box 38 Glen Rose, Texas 76043 Dr. Walter H. Jordan 881 W._ Outer Drive Regional Administrator, Region IV Oak Ridge, Tennessee 37830 U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 R. P. Lessy, Jr. Arlington, Texas 76011 1800 M Street, N.W 7th Floor N. Receptionist Larry A. Sinkin Washington, D.C. 20036 3022 Porter Street, NW #304 Washington, D.C. 20008 T. G. Dignan Ropes & Gray 24th Floor 225 Franklin Street Boston, MA 02110
Attachment 1 TEXAS UTILITIES COMPANY 2001 BRYAN TOWER
- DAL.LAS. TEX AS 75208 October 4, 1983 J. S. FARRINGTON sussemeer Mr. D. L. Andrews
. Director, Corporate Security Texas Utilities Services ~Inc.
2001 Bryan Tower Dallas, Texas 75201 HOT LINE PROGRAM As part of a program to reaffirm the corporate commitment to an effective, independent QA/QC program, Texas Utilities Generating Company has initiated a number of actions. One of those actions involves the establishment of a Hot Line Program to encourage the reporting of quality concerns and the timely investigation and resolution of those concerns. To provide this program the desired independence from the nuclear organization, I am assigning the responsibility for the Hot Line Program to the Director, Corporate Security. Specifically, the Director, Corporate Security will:
- 1. Install a hot line telephone in his office and . set up procedures to answer / record calls from concerned persons.
- 2. Docu=ent all allegations; based on a review of each allegation, conduct an investigation, if appropriate.
- 3. Maintain records of the disposition of each allegation received.
- 4. Inform the Vice President, Nuclear TUGC0 of:
All allegations received, requirements for technical assistance to support an investigation, status of on going investigations, and the final results of each investigatien. In the event the Vice President, Nuclear is the subject of an allegation, the Director, Corporate Security will report the results of the investigation to the Executive Vice President, Texas Utilities Generating Company.
Mr. D. L. Andrsws __,.
. Pcge 2 October 4, 1983 By copy of this letter, the President, Texas Utilities Generating Company is requested to direct the Vice President, Nuclear to:
Insure that the hot line number is given wide dissemination to personnel working at CPSES and that persons are encouraged to report their concerns; Upon his request, provide technical assistance to the Director, Corporate Security; Review the results of each investigation and take the necessary action to close out the allegation; and Forward a report of 'the action taken to the Director, Corporate Security. The Hot Line Program has an important role in corporate efforts to reemphasize the importance of quality in construction, inspection, testing, and operations of CPSES and to enhance our implementation of the Corporate Quality Assurance Program. I expect the full support of all concerned in establishing and carrying out the program. 3 S. Farri ton JSF:cp c: P. G. Brittain M. D. Spence R. J. Gary L. F. Fikar B. R. Clements J. B. George D. N. Chapman J. T. Merritt l l l r
Attachment 2 TEXAS UTILITIES GENERATING COMPANY OFFICE MEMORANDUM D. L. Andrews To D. N. Cha pman DaHae, Texas October 25. 1983 Sd>Jeet Quality Hot Line Program This letter is being written to provide an outline of the Quality Hot Line Program which is being initiated to comply with Mr. Spence's letter to me of October 4,1983. A basic description of the program, the TUGC0 Nuclear responsibilities, and the interfaces with Mr. David L. Andrews is as follows:
- 1. All personnel associated with CPSES will be shown an audiovisual presentation reaf firming TUGCO's commitment to an effective, independent QA/QC Program. The Quality Hot Line Program will be introduced during this presentation. QA and Engineering and Administrative Services are responsible for this activity.
- 2. Posters will be placed throughout the site and information will be distributed with the paychecks of all pe:Jonnel involved in construction activities describing how to report concerns with quality. There will also be a brief description of the program, informing them of the hot line number, providing a form to fill out if they would rather write down their quality concerns instead of calling the 800 number, and stating that their names will be kept confidential and known only to Corporate Security. They can remain anonymous if they so desire. For those who wish to remain anonymous, the program information will indicate that we will not be able to provide feedback on the results of investi-gations of their quality concerns. QA and Engineering and Administrative Services are responsible for this activity.
The posters and pay envelope inserts will state that all concerns, whether in writing or via a phone .all, are to be brought to the attention of the Director, Corporace Security in Dallas, who will be resoonsible for the investigation.
- 3. Personnel leaving QA/QC will have an interview by a Supervisory QA/QC individual to determine if they.have any quality concerns. Their concerns will be documented and forwarded to the Director of Corporate Security in Dallas for investigation. If they prefer, they can provide information on their quality concerns by the method described in item 2 above.
- 4. It is my understanding that D. L. Andrews will be responsible for all investigations ~and will be the interface with all persons who have quality concerns. If the quality concerns are safety related and if technical assistance is required in conducting the investigation, D. L.
Andrews will contact me. I will assign an individual or group of individuals to provide assistance, working under the direction of D. L. Andrews. ~
a It is also my understanding that Corporate Security will maintain the anonymity of persons.who indicate quality concerns, should the individual desire. They will maintain all files concerning the hot line program and will maintain-a tracking system. They will also provide a monthly
, report to M. D. Spence and J. S. Farrington.
- 5. D. L.. Andrews will provide me a copy of the results of each investigation of safety related concerns. I will review them for significance and take appropriate action. All results which concern QA/QC will be transmitted to D. N. Chapman who will make a determination of reportability per 10 CFR 50.55e.
}T ! -
B. R. Clements BRC:kh cc: P. G. Brittain J. S. Farrington M. D. Spence R. J. Gary L. F. Fikar J. B. George J. T. Merritt O I I I
, . . _ . . _ , . . _ . . , ._. - , _ ~ - - , - -- , - - -- - " ~ ' - - ' ' " " * ~ ~ - ' ' ' ' - - ~ ~ ~ ^
Attachment 3 TEXAS UTILITIES GENERATING COMPANY 200 BRYAN WWER . DALLAS. TEXAS 7620s MICHA SPENCE December 20, 1983 TO: All Personnel Assigned to Comanche Peak Steam Electric Station CPSES POLICY REGARDING INVESTIGATION AND REPORTING OF QUALITY MATTERS RELATED TO NUCLEAR SAFETY It has been and remains the highe'st priority' of CPSES management to ensure the quality and safety of the plant. To that end, all employees and supervisors are required to identify, document and report as soon as possible any conditions that they know, or have reason to believe, could compromise the safety and integrity of the plant. Any failure to report such conditions, knowingly with-holding information regarding such conditions, failure to cooperate fully with other personnel investigating such conditions, or any attempt to harass or intimidate any employee attempting to report such conditions is regarded by management as a gross breach of employment respon-sibilities and may constitute a violation of law. Any. employee or supervisor who commits any of the foregoing acts shall be subject to disciplinary action, up to and including discharge from employment. ad W A_. MDS:In
Attachment 4 TEXAS L'TILITIES GET7 RATING CO.TIPANY 3001 BRYAN TOWER > ~. %S. TEXAS 76201 - emCM4 D.5 PENCE December 20, 1983 TO: All Personnel Assigned to Comanche Peak Steam Electric Station CPSESPOLICYREGARDINGINTIMIDATION, HARASSMENT OR THREATS All personnel assigned to the Comanche Peak project, whether employed by the Texas Utilities System or con-tractors, are expected to conduct their activities in a professional manner. Accordingly, acts of intimidation, harassment or threats on the part of construction, Quality Assurance / Quality Control or any other functional organization personnel, will not be tolerated. Personnel engaging in acts of intimication, harassment or threats shall be su:jact to disciplinary action including termination. The ao::rcariate level of disciplinary action will be ce: ermined on an indivicual case basis. t
/ .
MDS:In lQ &- _ _ _ _ , , - , . _ _ --a " " *
- Attachment 5 j -
=~_.
s - Brown & Root,Inc. east arrice Box 1arce, souston, rexas 7700i A Halliburton Company T. Louis Austin, Jr. a.is1xs President (713) 676-3431 _.__ @ December 27, 1983 Mr. Doug C. Frankum Projectfianager Brown & Root, Inc. . P. O. Box 1001 Glen Rose, TX 76043
Dear Mr. Frankum:
The attached letters from Mr. Michael D. Spence, President of Texas Utilities Generating Company, are self-explanatory. Please post these two policy letter:; in areas of high visibility immediately. Very truly yours, llj u -Q is cc: J. T. Gossett W. M. Rice attachments
* =. w TEXAS UTILITIES GE"' RATING CO.TIPANY
. 2001 BRYAN TowrR . . ss. TEXAS 76201 40BCM&EL D. SPENCE
. ... 4.o December 20, 1983 TO: All Personnel Assigned to Comanche Peak Steam Electric Station CPSESPOLICYREGARDINGINTIMIDATION, HARASSMENT OR THREATS All personnel assigned to the Comanche Peak project, whether employed by the Texas Utilities System or con-tractors, are expected to conduct their activities in a professional manner. Accordingly, acts of intimidation, harassment or threats on the part of construction, Quality Assurance / Quality Control or any other functional organization personnel, will not be tolerated. Personnel engaging in acts of intimication, harassment or threats shall be sucject to cisciplinary' action including termination. The ,
ac:recriate level of disciplinary action will be cetermined on an indivicual case basis. b '
/
MDS:in /Q M y -
.,e ---e w - ~.
-.~%.-
TEXAS , UTILITIES GENERATING COAIPANY 2001 BRYAN TOWER e DALt AS. TEXAS 7520s MICHAE D SPENCE December 20, 1983 TO: All Personnel Assigned to Comanche Peak Steam Electric Station CPSES POLICY REGARDING INVESTIGATION AND REPORTING 0F QUALITY MATTERS RELATED TO NUCLEAR SAFETY It has been and remains the highest priority of CPSES management to ensure the quality and safety of the plant. To that end, all employees and supervisors are required to identify, document and report as soon as possible any conditions that they know, or have reason to believe, could compromise the safety and integrity of the plant. Any failure to report such conditions, knowingly with-holding information regarding such conditions, failure to cooperate fully with other personnel investigating such conditions, or any attempt to harass or intimidate any employee attempting to report such conditions is regarded by management as a gross breach of employment respon-sibilities and may constitute a violation of law. 'Any employee or supervisor who comits any of the foregoing acts shall be subject to disciplinary action, up to and including discharge from employment. A Y(%
.., e MDS:In t
Attachment 6 Brownf5Rootlnc. A Halliburton Company east arrice eox Taree, souston, Texas 77001
. T. Loui, Austin, Jr.
p, ;d . (713) 676 3438 3 July 9, 1985 Brown & Root, Inc. Comanche Peak Steam Electric Station P. O. Box 1001 Glen Rose. TX 76043
Dear Brcwnbuilder -Supervisor:
Please pardon this fann letter because I wish I could sit down and talk with every one of you personally. You have done a great job on the construction gets in the press. of Comanche Peak in spite of the criticism that this project One of these days, people will u'nderstand that this is one of the greatest and best construction proje:ts in the world. It is vitally important, however, that we continue to do our job well and that report requires that we assure an atmosphere where everyone feels free to safety concerns. later on emphasizing Brown & Root's ccanitmentThis to sa is a further effort to assure that all employees feel free to report their concerns about safety and quality. It has ccme to cur attention that some of our employees concerns. believe that it is not a part of their job to report safet Several have expressed the belief that their job would be in jeopardy cor cern. if their supervisor were to learn that they had reported a safet This is absolutely cc,rcrary to Brown & Root policy. they are free to report their concerns about safety a It is important that we maintain and preserve a work environment in which . there is no question that employees are free to come forward with their concerns. built safely.This is absolutely essential to insure that Ccmanene Peak is You are reminded that any action or conduct on your part that in any manner discourages em31oyees from reporting safety and quality concerns.will not be tolerated. Moreover, any manager or supervisor who engages in such discharge from emoloyment. actions will be subject to severe disciplina bility, please be guided by the following:So there will be no doubt abo
Brownbuild;r Supsrvisor -- Comanche Peak Steam Electric Station July 9, 1985 page 2
. l. Communicate with your employees that. they are free, without fear of reprisal, and at any time, to report any concern that they have regarding plant safety, either to you, to Safeteam, to Quality Control, or to the Nuclear Regulatory Comission. Make sure that they know it is not only their right but their oblication as a Brown & Root employee to make plant safety or hignest priority when performing their duties.
- 2. Take each and every concern seriously and be sure to-communicate back to your employee the resolution of each concern.
- 3. Encourage your employees to report safety concerns to you, even if they may have been responsible, in wnole or in part, for the safety problem they are reporting on. Employees should not be encouraged to hide their mistakes. Rather, they should be encourageo that it is their duty to report concerns so that they can be corrected at the very earliest opportunity.
4 However, do not discourage any employee from reporting their concerns to Safeteam. More specifically, do not question an employee either before or after he or she goes to Safeteam
.about what was reported there. Do not insist that an emoloyee recort his or.her safety concerns to you first ratner inan reporting to Safeteam, QC, or the fiRC.
- 5. Do not, by word or deeo, lead your employees to :elieve that the reporting of safety concerns is up to OC and not a responsibility of craft. This is not so.
I know that all of you are comitted to building a cuality plant. Safety and quality are keys to the success of the Ccmancne Peak project. While we are all proud of the work se have done, there is alaays room.for i=crovement. It is essential that we make sure that all su ervisors, as well as all emoloyees, are aware of, and practice daily, their individual res this 0nsibility plant goes to into assure that all safety ccncerns are accressec tefore aceration. meeting this challenge. I very mucn appreciate jour ef forts in Sincerely yours, .
, * *p-. 1
Attachment 7 Brown &RootJnC. A Hathburton Cornpany Post orrice Box Three, Houston, Texas 77001 T. Lod Av.t% J,. d Pe J.ae plJ) 676 a438 ' July 11, 1985
~
Dear Comanche Peak Brownbui1 der:
.0ver the history of our company, "Brownbilt" has come to mean quality in construction and "doing it right the first time." In building this reputation- -process.
we have relied upon craft to be the first line at quality in the construction It has recently come to my attention that several of you have exoressed the belief that it is not your duty to reoort safety concerns and that you might believe you would regret it if you did. This is certainly not tne case. As you know, we nave maae many efforts over the cast several years to orovide the means by which all_ employees working at Comanche Peak could freely reoort any concerns they may nave concerning quality matters and can do' so without fear that their job would be adversely affectea. I want to re-emphasize to each of you the following:
- 1. ~It is your resconsibility to report any safety or quality concern which you discover.
Ine responsibility for reporting safety concerns does not rest solely with quality control personnel. It is a duty that each of you share in insuring the safe operation of Comanche' Peak. 2. If you~recort a safety concern and do not receive a reoly to that conce.rn within a reasonable time, do not hesitate to use one of the several other avenues that are available to you. If your sucervisor oces not take your concern seri_ously, then go to nis or her supervisor ur anager. If for scme reascn you have a proolem with reporting a ccncern, tase that concern - higner up the chain of cc:miand if necessary. 3. Feel free to report any of these concerns either to your surervisor, or to CC, to Safeteam, or to the NRC. 4 Anyone interfering with your coligation to take tne act:cn described above will be violating Brown & Root policy and will be su: ject to severe disci-plinary action. In this connection, each- emolcyee is reminded of the poli, letter on harassment dated Dece.nter 20, 1933, di rec ta.: to all site personn., at Comanche Peak. Should anycne attemot to in.er#e's uita your reporting << safety wise beconcerns, reported. such conduct recuires i=eciate at:2"ti:n anc snould like-You are doing a gocc job in building this plant. imoortant to all of us. I encourace you to cant:nue Re i ccasi af this croiect worv. ; hat you have core, a'la I ask .a nave cride in tne good re-emon3sizea by this lettcr. "'at eacn of ycu sa:::crt fuli/ tMe colicies Sincerely yours, f b"
- nJ - . _ . - .
. Attachment 8 t
.~
- TEXdS UTILITIES GENERATING CO.TIPANY
.m s 1. .w.m . .. . s o rn . .u u o r m. i.... . . nu.u. 1ru, m,..
w .um.,=
- w. c.o..v ii.= . . . July 23, 1985
Dear Cc:
ranche Peak Superviscr: of.the criticism that this project receives.You have done a good jo ; important that we continue to do our jcb well, and to do so requiresHoweve that we assure an atmosphere wherein everyone feels free to report safe concerns. Attached to this letter is a letter that will be sent to all e:roloyees later, en=hasizing our cc:ratrent to safety and quality. effort to about safety assure and that gaality. all employees feel free to report their concernsThis'is a further believe that it.is not part of their job to report safety concerns.It has ca Scme have expressed the belief that their job would be in jecpardy if their supervisor were to learn that they had reported such concerns. Bis beliefs. is absolutely centrary to cc:py policy as well as my cwn personal As supervisors, you should assure the employees working under your surer-visica that they are free to report their concerns atcut safet/ and gaality at any time.- It is i= cr: ant tnat we maintain and preserve a war.< enviren=e:d in wnica there is no cuestien that enployees arc. free to
, cece foreard with their cencerns.
that Cc anene Peak is built to cperate safely.nis is absolutely essential to insure You are reminded ina any actica or conduct en your part that in any manner will not be disccuraces rolerated.c.nleyees frcm reporting safety and gaality ccncerns in such acticns will he subject to severe disciplinar/ action up to a including disenarce frca c nicy ent. your rescensibility, please he guided So by there will be no doubt accut the folicwing: 1. Cc-- un:.cate with your c:olcyees that tney are free, witncut 4 ci rcer .:n, and at r.v ti e, to reccr any concern that ntyfear have rectreing pir.: safety, ettnar to you, Oc Saf00C33-Cen:rcl cr : tna .ucl2ar Peculatory Cc- ncs:.cn. .E0 Sur2 " Ec D3 lit'/ tn2*/ knc _: is ne: calv their rign: but tncir calicat:cn u inat an c.~oic wncn cw to per:...... 9 :m.etr a.-:ecuties. niant cafety and gaality or nignest pr:critf
,,,,,,,,,,xa, err w **rre*rur~ redcr'*"'co w v
w July 23,1985 Page ~2-2. Take each and every concern seriously and be sure to cm:icate back to your employee the resolution of each concern as soon as possible. 3. Encourage your enployees to report safety concerns to you, even if they may have been responsible, in whole or in part, for the problem they are reporting. to hide their mistakes. Rather, B:ployees.should not be encouraged they should be encouraged that it is their duty to report concerns so that they can be corrected at the very earliest opportunity. 4. However, do not discourage any enployee frcm reporting their concerns to Safeteam. More specifically, do not gaestion an what was reported there. after he or she goes to Safeteam about enployee either before or Do not insist that an emoloyee report his or her. safety to Safeteam, QC or concerns the NRC. to you first rather than reporting 5. Do not, by word or deed, lead your emoloyees to believe that ity of craft.the reporting of safety concerns is up to QC and not a responsibil This is not co. gaality into our plant in the first place.I rely on our crafts to build I knew that' all of you are cc=itted to building a gaality plant, datory and gaality are keys to tne success of the Cc anene Peax cro?:ct. .611a we are all' prcud cf the worn we have done, dere is always rccm fcr 1 n:c fe-ment. It is essential that we rake sure that all super /iscrc, as wi.
~
as all e:tricyees, are aware of, and practico dail'/, tnelr indr.id;al - this plant gces into cperaticn.respcasibilitytoassurethatallsafetyccncerns in reeting this challenge. I ver/ much appreciate yc"- e~ta Ver/ traly ycurs,
//
o e -* s
. ,f. .ff j<Y, *f,/aan .'. u.# a, S'. G. Ocun311 ?:GC: 9.h Att:cnrent
DRAFT TEXAS ~ UTILITIES GENERATING CO.11PANY mMYWW Te>WEM
- 4 pen NatitTpt 4 Dt.tV D: 9* TH EET. L.ts. es t
- DA LLAm.193T. ? MH B WILLIAne EL COUteSIL anscureve wiss possesseur
Dear Comanche Peak Erployee:
'It has recently ccne to my attention that some ernployees at the site have expressed the belief that it is not their duty to recort safety concerns is certainlyand notthat the they case.believe they would regret it if they did. -This As you know, we have made many efforts over . the past several years to provide the means by which all employees working at Ca:anche Peak could freely report any concerns they may have concerning quality matters and can do so without fear that their job would be adversely affected.
I want to re-e::=hasize to each of you the follcwing:
- 1. It is your resocnsibility which you discover. to report any safety or c*.:ality cencern The resocnsibility for reconing safetf concerns does not rest solely with quality centrol acrcennel.
It is a duty that eacn of you sture in insuring :nc cafe cporatien of Ccranche Peak. 2.. If you report a safety concern and do not receive a reply to' that ccncar-. within a reascnable ti. c, do not hesi ::e te us2 one of t.c several avenues tnat are available to ycu. !! . cur supertiser does not take your ccncarn sencusly, : .:n ':c c n:.s or ner v. sutereiser cf ransger. If for ccre r:asca 702 n ./; 3 .
. - - . - . . ...;t . m.
c . 4 . . a ec._. , _ - , s.
. . . , ._, . c... .- .
the ennn cf cer:a .d if necessary.
- 3. Feel free :
to CC, : Safetear. cr to he GC.repen any of these ccnc rnc el-.cr Oc ycur 2;terf 4. Anycne interfering with your ecligan:.cn to tae:e n2 abcte will b2 violating Ccrar--a Ca' - site Eclicy :naact'. itli ce n d:sen cd sucject : severe disciplinar/ actien. Shculd an;cn2 at:= .: to in:crfare with your retcrting cf 2.atc:7 ccncarn:, au . ;;.nue r-scuir:s :. : ediate att:n::.cn an: 2nc.: d 1:.< :wl:e ce r:;cn:c.
'YCu are dcing t p ,. v3 .. u 1a.e ~.
. ..ea .1..... %. r...--...- , -
pr0gCC: :c i.~ncr pnc2 L:. _ne g .:.: . c.:rse .. - all of us. .'I enccuraca feu :: ---
- 1. c a - c 2 cq .
3- .ccu . 3.j3 6 3, .;.; . succc n f.:. . ,: c ; ;d.3_; [3_; n331,.m c.
, , - - , - .;r
. . ;; , g ;r,
, , . . 3.
,. s . - .
W. G. Ccunsil hCC:?.h
,,,,.....,...m.,-...-..-
Attachment 9 g.= TEXAS UTILITIES GENERATING CO31PANY pis(YW4Y TOWER
- 400 NORTH OLIVE 24TMEET. L.G. set
- DA LLAm. TEXAm 13:20L July 30, 1985 .
W9LLIAtt G. COufeSIL Basevvwe west resseeen?
Dear Cemanche Peak D:
ployee: It has recently cc=e to my attention that seme ertployees at the site have expressed the belief that it is not their duty to report safety. concerns and that they believe they would regret it if they did. 'Ihis is certainly not the case. As you know, we have made many efforts over the past several years to provide the means by which all enployees working at. Comanche Peak could freely report any concerns they may have concerning quality affected. natters and can do so without fear that their job would be adversely I want to re-enphasize to each of you the following: 1. It is your which you rescensibility discover. to report any safety or quality concern The responsibility for reporting safety concerns dces not rest solely with quality control personnel. It is a duty that each of you share in insuring the safe cperation of Caranche Peak. 2. If you report a safety concern and do not receive a reply to that concern within a reascnable time, do not hesitate to use ene of the several avenues that are available to you. If / cur superviser does not take your concern seriously, then go to his or her suoerviser of Ianager. If fcr scre reasca you have a prcblem with reocrting a ccncarn, take tnat concern nigner up the chain of ccarand if. necessary. 3. Feel to CC, freeto te. report any Safeteam er toofdethese
!G:'.ccncerns either to ', cur sucervicor, 4.
;.nycne interfering with ycur celigatica to ta%a 2e actica d escrib:d abcVe will ba violating Cc ancn2 Pe2 :
sub;ect to severe disciplinar/ act.cn. site colic / r.d will b2 Shculd anycne at =pt to interfare with your recc ning cf cafet cencarna, cucn conduc ; recuires i:- ediate at Oncica r.d sncu'd likcwice w rc;cr ad. Ycu are dcing a g:cd :cb in buildin: :ni: -i re t . ~ ~. : : :::: ' .: .u prc;e= is i ccr:r.: :o all of us. pr.d2 in tne gccc ..crz: that ;cu ! :necura:2 .cu :: utn:::'. 2 .: t reo
.a /2 2:na r.d : a z e. nr.: c - mu Suppc~~; f.:lly :~.2 7. Clin :5 :--C na a l:2 J Q. ' ^. '. '. E!!r.
. arc :rul. coura, p
**y *&
.!.a.ecunatt, hCC: ?.h s vors rus or reso s rss.srurm o u.s.crnse roses <xr
, , . - , - +
%.a Attachment 10 a' ,
t 4
Dear Fellow Employee:
You are in a position to help ensure the safe operation of Comanche Peak. ' My thoughts on nuclear safety are ; contained 'within . the attached. pamphlet, and Iinvite you to read and , consider them. By working together 1 as a team, we can develop this ' Safety i Ethic'. 3 I 9 9 T
)
s rP - p + =e, cy.~www +eTem.-w* - - - - ew ss g p.gw+ y rw s-m --+>5g--.qm- 9f%e -- .y p 9se -.yem-y y -- r-^-*r+ y w-9"'$7+' y
^l l
l
', i .
% 1 1
I I c . . . . . < i "Nuclearsafetyisan: l l t ettiit::tlTatmustpenvadeH ' l J.anentireorganization' l ilti'spohjustacollectiam,A ; ofcodesarid criteriaL" i I *e-- ..... ,- . . . . _ . ,
, ., , ., j )
E'-' , , . j g w, w a ,. : .. , g
~y:.', ' ,- -
it
~. f h ; .. ' ' ~e .
i t ,..u
-j ,
.<.r.1 .. - ' -
s . 4
- j. **[,I / - - - . .- U
.*e .-
]
1 ' # ${ ' ; . . i .' ... b. T**s::a._ - 4 ,. ', . : y
., s' . r%
a g ) glf }7_ . . .' :,. l
. "j , w, f ' -- , ;- ,
1 .. a. . , , _ _ -, .. . _ _- .. s~~-
,j
- m . ' ."' 3 J,e n { '.'9.N' ' ,.'
' *,i T . ly Q}
k-i; .;" '7
.,'..,..5-.'..; .>'.
~~
' k
,4,.[. r. a. I' [ #
.f M,y
.' '.'.,'*~f..'
t-f _,K-
;^-
4-
] -
s gr,
. . g.. . . s . ., t -- .. .
L-. : Ayv6 -"?',.>
- c. . L -w -- .:... . . -' . ( , ,; . , '. ; v . -
r, p' *."+ N4 #,y%'p ' ;s..,f 'i - - r .
. 4
. - . . . ,'
- 7}*g r,,
y Y~$
% h_'.<4' ,w..,khr g ( . i ;h f~l
, '. 9, , ? .t
, , *-:f. . ,. ~, or , .
.'~Q,"6
' i' iN A
- jrp
' . '.y.0,$'k9Ms,h 5%. : .,".'.'-}.3,-?j.&R_..f.'
A ' ? ~d- / L
, 'd , . ,
t . .
. U6-1 . : w ',e .Q' %,.>. -,c.7e /f:A Aan*
.> n: q ' 9
&n .--ci"&
. d, T.L-.;. .y@ s.
4R A *
-),'
.m b,E$ . ,) . A h '
$'x(N 11 4 ve
& h $, . '
3
'q
~
. l,ks-?_'(
- ,fu '. .. f^' # ..
- r . ;
. l,i.)$.kt- . ;S i? %\
?,%. .r .' d. e6 (. . . .-- *
~,.,g
. ~W 4 -
8 Q* Q)-- j >.
' . M{ , ly[, 4 5
" E'.er .
- n :1[rL 9 y y Q ,
,- et., , ......a.... . .. - . =y-ffri%?@'5?i?Yb$hh.-i.*_ 5 1
i e F j i
l
\
~
d ( i Nuclear safety. The reason for the entire l federallicensing and regulatory process and the construction procedures and all the
. . . . r, quality controlinspections at a nuclear
' ' ' ~
' ' ' ~ . .. plant. The reason why reactor operators .
spend the equivalent of four years in a college classroom preparing for a federally administered examination. In twenty-five , years of operating experience, the commer- \ cial nuclear power industry's attention to safety has resulted in a good safety record. l . - There is no reason why that safety record I cannot continue. ' Since beginning the Comanche Peak project Texas Utilities Electric Company has been dedicated to operating a safe plant. l ; ,. As the start-up and operation of the two
- {; 2 - F .
nuclear units approach, we want to define i yy~^ l ' ". safety"more precisely.
\ JJ; = ' Strict compliance with all commitments '
i &' :; .h and regulations should provide reasonable I, ^ ~W
- assurance that the health and safety of the i
Q f^;b public is protected dunng operation of a l i hhyh:..Q ::: . . . . nuclear power plant. For Bill Couns 1
- \
executive vice president of Texas Utilities , s' a: . .. .: . Generating Company. this is not enough.
. ~% :: W -
" Strict compliance"is at best the minimum l
l , '_ D'.&; ,s ! .W:.:.z n ._ . . , . .
.w requirement. For Counsil, who will be {
- f. ,W directly responsible for the operation of e q.,y %c. c:~
' . . . [. ; ;
Comanche Peak, safety means, in addition l' L-~ i" 'l ~ to compliance, an attitude, an ethic. that is Qg; \ ? q_ ( - ,f' ' l I shared by the entire operating organization. y
%.Ac;*. , ?. 2 -. . -f i ~ _ ; J:
~
From tne perspective of eignteen years in \ commercial nuclear power a career that
, U*%
* - ' ? *: ~ . .';.,: includes responsibility for the operation of f 4p..r s. y;,q , .;,,'. , *
k.h '- ~W. . -
.:p ;
- ::. : :.:' ~
three nuclear units and one under con-struction, Counsil recently shared his
' v; W .; ' ' ~ :Q ' . :.NN;'?
.. ~
j.Y;j..;z
< ;. . p ;.
thoughts on the safety etnic at Stanford University l s ; ; ,N 1 , . l l W. %q_, %, _ f, e .
' ?y [. .. '
'*'Qtf'.2 - The occasion was a two ween course at \
Stanford sponsored by the Un: led States 1-
" .;f:r}y lW-;~ g ?Y.W.v;:, g.3_,3 , , -e.
a ' Department of State entitled "?.ianagement l \ g
~ .- Wh';yf.?y!! 4tsy,. of National fluclear Programs !:r Assurea
- . Safety" Santor-level aaministratcra from
*..? h* K. >L ;r , :-
- % * . countnes in the orccass c! c!awian
- nci.
,Q expanding, or senously consiaennr; nuc; ear
}? . . , . ~.7 . ..
power pronttms cartic:aatca m m cantnr-i ence. Mr. GO-inSil. recoGn'.*eu as 3n dultior. ' ty in the sate manaCement O! CUCiear e, l ~~h} us
}i power systems. wds an inVitOd Sce3^er j '.E'l,$' '
,7,r=Y!. _WM, _.'.4,
,. /, t '
- y. *ec ,
%v ,
*',. A . , .,
1 l l I i
\ . I i
% safety >ethes)a state.ot mind that affects'the entiret organizationt Eacht
, persotrin:the: organization reakzest
- thathetop shetisiasr.important pamoti fety is not written into the Code i - thedgypetures of Federal Regulations, it is only partia!!y specified. Federal regulations specify at best only the minimum requirements that,if
, , "O'rganizationstwith'a strong safetF met, should provide reasonable assurance 1 l Methic :dependrupornthempeopletor that the public health and safety will be I' f dCEth9lotBngbtithafirSttimeE . . . pay
- protected. How, then, does one truly ensure
..l* dQS@atteDtlOCUtG,detallSlanCtqueSE+ that organizations operating and maintain-ing nuclear power plants are doing so 4
.> tlOmwhatmightrgo:wronCf, . safety?
"[- "
The way is to infuse the organization with i
- . s.
a safety ethic. A safety ethic is a state of i Q;ep ' ' mind that affects the entire organization. It is ' t0? . a sense of responsibility and a very strong v.- ~ .
~
professional attitude. Each person in the
,,M 5.[ 1; ~ .' ). - .; organization realizes that he or she is an
??N - . -'
important part of the big picture. [ ._ ,l ~. ' l Within such organizations. each person i feels responsible for ensuring that each step ' 1q y ^, y - .
, .. ... c . - . . . ~
of every activity is performed in a first-class, go.*m,: n' professional, and quality manner. People
'4
., Wf : ? - . , c. , . . ..
. .. should understand that any mistake can be ;
very costly, both financially and personally. x- ~ .. .
- Q.i : ? . x:'.aY (;Wf.t:;9pr. . Q. j r
( .- Organizations with a strong safety ethic j ry.g ; Vr .
. s. train their personnel well, insist upon a e- g.a r.. s; 1,.:. .
knowledgeable, participating management. i t.' v ..-!/. W o 3..
' ., - and depend upon their peop!e to do the job l 3 . ; 34 Dg j J . *' - .: y L, right the first time.
$Mki 1~,> _I 9,q h .jj.h7~[, These organizations expect their people y, .g-fJ,g .. .y..j,6 7p. '- to pay close attention to details and ques-
.4- pgyyy;' e ' 4 -. .:.f -
tion what might go wrong. Operations
~"
$6 h. personnel are alert and continually ques ,
9" *Q.p giQ.U)h f 1 - .a h/.' M;j sh;. i .' tion what equipment might maifunction. en. l k 3w,fNgej)gtg., 4d - .s a,. h. grneers, when making design modificat;ons. I E.$ ; W g s. ' s' ask "what if the component breaks? ' ano ] j~ ,h gg
- then look at the consecuences of that failure.
.~ g. My p ?. /j ! e.
Studies have shown that 30 ta ua percent
~
. V (* **7 h'$ V of people interviewed af ter acc: cents or e4 S. d hM various types say mcy d un t th:ns er
~
'd.dn t realize the consecuences o' ther l
4 i *- f, gttr ' *^ a*5 -, . , . -
% $s
- .y <. ., -
,O
_ h .,"':. , y - ,'.,.: X
) .
- f. ,. .; . . . . ,
[ I ,, l
i l l 1nsistOn'arruncomprom:stng cOmu actions. Good organizations with a very ' mitment to.f ollowing directions' anct strong safety ethic take the time to do things procedores' nght the first time. The excuse "I didn't know" cannot be tolerated. The Institute of Nuclear Power Operations and the Nuclear Hawng;a.successtut safety ethic- Regulatory Commission have found that requires!thea strongest kinctofileadg many accidents involving personnel error ership:frotTrthettopf .- ccur because of lack of attention to details [ or because of improper practices.
; When you enter the nuclear power field,
". . . SupeEVisOIS'aret not'Only. mana.- 2 develop and implement comprehensive gerS;butfalsO leader 5an(ttrainerSrOff procedures for all aspects of the operation.
--e thelopeopleETfiepmastberoutin:theE Insist on an uncompromising commitment to following directions and procedures. One of
_ . . plaatimuCLEOfith& day; lead 1DgianCh the biggest quality assurance problems I ] f ':'trairnng;theitrpeople6' have found is that of people not following I .- - procedures. A strong management insists , ,.as . . . that people follow procedures, or: I :: . . if the procedure is wrong, stop, have it l a ):{.. , . _ changed and then restart the work. j n. I
}.Ql
~
ifimprovement is possible, follow the i L ; L.. procedure and then have it changed. l 9:W ~ - ~ ~ g. . Another ingredient that is essential to
- f. #8[-
1 .
._. 7{ ~ t j - . .
maintaining a position of leadership in i . W, r . .k . . A 1 i
<? safety is the total commitment of the entire
.} . f: yp ' 4 'J z t .,d' organization to safe designs and intense c je;f; D'-
W h. . g' .'. : i . 's ';-e,. design reviews; to putting safety first-no shortcuts. no deviations from the first-class 43,g%#t5j::V.E.&.g ff@*v 4 3 way. Putting safety first recuires a system l h
.ih]kh; ?vy Qi4W e . , * ' .: ' -W/j. 7 i.D M of many checks and balances. It requires
' diligent U r'../.. investigation of all accidents ano near misses. Peopie do not easily adaat to y .g* 7 fNr%9W$g 'Np g . ..s',M .c-n- ? 5y $.7 i p0 ' -. . .
such a stringent atmosphere. Having a suc-
,[" ,c *'w z
f /(-{>) $ . . d, .
+lM c. : j fe:- ,'
cessful safety eth;c re':wres the stroncest kind of leadershio from the tco. That Mad. h? = -JQ ,; ership must stress teamwork cecause ony i a n@r %p,v c
.th* pcg" w.
teamworx mu ensure tra!,,xn me una e - detail has been addressed. g _ ; , .Q-. Each emC:oyee snnUd knot.' tM! r'~ . , . -
..pyrg ? , % entearal tacto :n me pornu.t of scrom 2
.N , #
I~ Checks and balances are dOhn !WV l'OW:".
, .< ,TfD .,
., , - e, .s ,
- h. , ;.
and so e,learntna from me rnmif4es at a ne,s. u , _h , t
l
' 1 1
1 , l l 1
. ' Wercan:expectour.personnet ta fot- When developing your safety ethic, follow l these guidelines:
IOMCOUDieadli# Wet aSimanagerflentT. , l accepkouaresponsjbslity andumpte" Remember that regulations are minimum ment 2safetytethcthatinsists that. requirements. pusnucleasplantsbeloperated angh
- Insist on good procedures and train your 1 mamtained'at'the people t t tiow them.
' otexcettenw ."highestistandardy ,
Insist your personnelfollow your l
. procedures. '
I .
^ '
Develop teamwork throughout the
....,s. ' . Organization.
- v. ,-
Obviously, supervisors must assign their l
- ' f.~ _.
employees work, allocate other resources to meet corporate commitments, and provide
~ '
l '? : - ' - - early warning when commitments cannot be , met. Sometimes we forget that supervisors : J ,4 i L.' ~ are not only managers, but also leaders and f'- Cpa hE.cM. [,: .s. : . . . trainers of their people. Supervisors must , .fKi2,hd f .7 .-; [ ; ?? . ,h ' n .i ...
.;y; ensure that the job is done correctly anc accept responsibility for what goes verong.
.g.L g :.f l *)-T yd f f'~~ { '{.t ' p M. .'D '??. M 3 . _
Supervisors in a nuclear plant cannot do g Q,g. . *re D E '. e . -
.,,:.,.P i
,fN,. this while sitting in their offices. They must be out in the plant much of the day, leacing l ? p.h.t,b I' yx
., #Iih f.:5 M ~ ! NA 'O '- -': C '
and training their people. j.w 3@iS%:.f.,W. . '.,..'-1-"
; . , , . ,f . . / '.7 We can expect our personnel to follow our
- s lead if we, as management, accept our !
~"ere.1'@,,<.,,L'...74.p'Jg:
c aTfa, c .'.,1 f; - ~ . . ' ~ responsibility and imp!cment a safety eth:c ( ) f YE%pN.2 . ., */(^% ' that insists that our nuc! ear plants be M/ g' .s. f _f. 2: ' p. operateo and maintained at the hignest
, ~
standard of excellence. Nuclear safety is an l
.- f.g. ,q- -
9 -
.* F My%'-$
. . ?.3 di.d.N, '.;ih, ., i !
ethic that must pervade an entire organiza. tion. It is not just a co!!ecton of cc00s and
;? **$ ?'%f;7 ei:r'
,...A_. g r.q.r m % ,J'~. .n;ga v.di entena.
p.Mf%%e;Ws
? i*y ,
3 ,, t y c.g ' . y s.k .
- . g: . - . *
? ,y-
?'
,4
, " W ' p; 4M5 , ,
l I w.az
. . , . a.' .. 6.* :
]
,, y v. .h _ w
\ n; ' -w s f ~.b'./ a t i
i. i . - - . - i y , >. j, < w.
~ ;. . -
i
\ ..< <.
,e-o.),l
. m \
?- ,
i yc
,:e4.q.u..
..,.n., .=
,m
.g z. , l
! 15$2!.hII@n I, "
f j 7 ! . ig r h,rt n i!
.q_.
.N;']4% r.ssm%.
.,-1,. . g . : : . .A 'h L_ -
4'?'.
%,, i, . ..
.- v.
&. . . .Q jt !. pJ "4 $ wy.ollp :O.
'Qiph:;s. Q . 'p q k %' .I./ /,;/S
~ Q l'
,=at.trS h .~\t u .r i /2
.i ' L~' -
.3.2:eQ '
** t t
.;f ..y % : w . . . . ...: - .-
. . f, 1
t
\*- . i..k,k Y.4.s . . . . .. , ..
1
..'f N'(Why:.M. ..;. 5 ; r ~ ~.
1
-i l illiam G. Counsit is executive l.h,%y j'Mg;,w : '..w ..g. Ahl
'df
) vice president-Nuclear Engineenng and . t Operations for Texas Utihties Generating Company. He has a B.S. degree in engi- Jg $y,[$ g; .. ..? p.; g,p y: g' ~ r
~f,- . , .
l 3 neenng from the U.S. Naval Academy and 3y ,- I _ . ._ .. ._, ._...y.. , served aboard nuclear submannes for five ,:g. !qp.l~ . ;. ,g ' . . years. His expenence includes positions as
..f l j
,y." 4 .y -
g ,,,, ,
, q c. . , ,j j operations supervisor plant supenntendent. 7 .
j 3 ' f r .:.. . q - and project manager at Northeast Utaties' . P.4py .; Jy, .4.o..
* ' 'f. ?g.a - i. ' , .y n.M,.J . -
J
,4.4;*
&,7 m;p; ' ~.;s. ~
. . ,v,. :
4 three Mdistone nuclear units in Connect: cut. .
.+t.- ; -
.,y,,'
He also was vice president and senior vice
'2?g . ?fflyp H, z7 ',;. . (v j S
~.&.4 e !
, president for nuclear engineering and opera- Le , 4 '., -. 4M7yg , j g/
'gry; s f (,
tions for Normeast Ut:hties four nuclear :N.f V
! L-' '
! facmt;es. Counsd jo:r.ec Texas Utmt:es E 3
, 8 ,%F i fr-Q 4 .+
l Generating Company in May of 1985. -lf.yj)!?# ? 'YkPj*p, MbM g ' .h
,La
.:re{
l 3, q j
':. v.;
*b) e
. .e- b 4 d* ' *
._hb .. .?:l $ . .!Ah 4
4
.}}