ML20236D613

Comments on Encl Proposed Commission Paper Re Allegation Processing Programs Implemented by Utils.Paper Skirts Issue of Requiring Util to Establish Allegation Resolution Programs.Degree of NRC Involvement Discussed

ML20236D613
Person / Time
Issue date:	07/16/1985
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20236D451	List: ML20236D449 ML20236D613 ML20236D655 ML20236D740 ML20236D771 ML20236D856 ML20236D902 ML20236D938
References
FOIA-87-413 NUDOCS 8710280288
Download: ML20236D613 (16)

Text

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?4 1 JUL 161985 i

MEMORANDUM FOR: James M. Taylor. Director ,

Office of Inspection and Enforcement FROM: Robert D. Martin, Regional Administrator Region IV

SUBJECT:

COMENTS ON PROPOSED COMMISSION PAPER

" ALLEGATION PROCESSING PROGRAMS IMPLEMENTED BY UTILITIES" It is timely that this important matter should be taken before the Commission.

.In our opinion, the approach of the subject paper to dealing with this issue has one fundamental flaw as well as other lesser flaws. The major problem is that the proposed paper skirts the question of whether it should be a requirement for utilities to establish allegation resolution programs (ARPs).

But by establishing an evaluation program of utility-initiated allegation programs, NRC, in effect, establishes de facto requirements for the formation and implementation of such programs, without ever addressing whether the program should be required to exist in the first place.

For an inspection or evaluation program to have any rational efficacy, it must have clearly defined, objective inspection criteria. Unless licensees and permit ,

holders develop or revise their ARPs in such a way as to meet the test of such I criteria, we would simply continue to collect data which shows that licensees

" don't handle allegations the way NRC does them." Without formally requiring allegation programs the Comission, in practical effect, would be using its own inspection program as a means of imposing a requirement on the industry through the "back door" without going through the rulemaking process or the CRGR review process required by Commission policy. We believe this kind of approach to I regulation destroys the credibility of and the confidence in the regulatory i process. In our view, this is not the way to achieve the regulatory goals of  !

the Comission. The logical utility response may well be to simply drop their l voluntary programs, many of which were instituted at the urging of senior NRC managers.

We acknowledge that IE has often developed program guidance to conduct inspections in areas where there was not the clear regulatory requirement necessary to support enforcement. Such actions were often taken to determine l if regulatory requirements or guidance were needed. We believe this case to be ,

special because it is, in effect, telling the industry that when they adopt a '

good initiative, NRC will show its endorsement by making it a regulatory requirement. Absent appropriate requirements, we believe that any formally established NRC inspection or evaluation program may be of questionable consistency at best.

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-2 . l We suggest that the staff first -deal with' the. fundamental . question of whether, i

. or not utility ARPs should be made a: Commission requirement. Then, based on  !

the Consnission's will on that subject, the staff could propose what the requirements should consist of:and an approach on how to inspect these ,

programs.

If, however, circumstances dictate that the staff is unable.to propose a two-step approach to the Comission, and that the Comission wishes to address both the general subject of " requirements" and the detailed subject of 1

- evaluation methods simultaneously, we reconsrend the following as the appropriate degree of NRC involvement with this issue.

'1. .The Comission should formally endorse the idea of ARP and encourage fomation of such programs by utilities.  !

2. NRC staff should sift the current experience of NRC and industry to j' date and delineate the attributes of a successful program. In this-regard, the industry programs should be compared with the published descriptions of the existing NRC allegation and investigation programs.  ;

3. . Senior NRC staff should visit utility managements to discuss 1 and 2, candidly pointing out that should allegations received by NRC force' l us to-review the workings of'their program, a program with lesser '!

attributes could require greater NRC resources before a' finding of adequacy could be reached regarding the disposition of the allegations.

4. .The NRC would then exercise disciplined restraint' relative to the formal review of such programs. No planned' inspection would be i conducted. NRC would become involved only for good cause, not i generalized assertions of inadequacy or veiled references to improper

.icensee motives, i L. [This alternative does not appear in the current draft of the Commission paper-andshouldbeadded.] 1 The underlying basis for this approach is our view that NRC does not l fundamentally rely on these programs in making licensing or operating .i decisions. The benefit of these programs to NRC is that they may reduce the l number of allegations NRC has to deal with at a given time. This is a i practical consideration and one which has schedular implications for the licensee. These implications alone should motivate the licensees to assure their programs are working. We believe they would welcome our informal * ***

l guidance. '

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Also, consistent with what we said earlier, we believe the Commission paper should be restructured so that requirement is the first alternative and non-involvement is the last. This permits a full, logical development of the issue and provides a basis for an informed decision on how to proceed. (Inany 1

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event,'we doubt that the Comission will let us get away with not discussing

'the requirement ~ option.) ,

We' have had considerable experience with this matter and would be pleased to work with you in the development of a sound staff position. _ We have prepared a draft revision to the paper which captures these concepts.

Or!ginn1 Sir;ned k

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Robert D. Martin Regional Administrator Region IV i

Enclosure:

As stated cc:-

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ENCLOSURE For: The Commissioners From:

1 . h technica Should NRC conduct formal inspections i g issues E 5. issues and formal 0! oversight of wrongd holders' identified through licensees' and permitd i al'iegation resolution programs up to an

) facets of the programs? these Will an NRC decision to injectss end itself them,into or cause ar g 6.

programs either stifleh decisions their on effe what are the potential impacts of suc NRC? i ements mak Dec NRC promulgate detailed regulatory f licens-requ A. these programs mandatory andreviews providing by Alternatives: inspections of the programmatic i feature investigat and pennit holders' programs l ding of " wrongdoing" issues.

inspections of program implementatio i imir hardware and indepth in therevie lice potential for "last minute" surprises process. features B.

NRC conduct inspectionsf of allegation programm l ting on1 well as a representative sampling o blems on processing files covering e appror ha case-by-case basis.

matters would be reviewed by 01These tobe as investigative technique and conclusion der lic d

would cover all informatio Licensees and pr uld and permit holders' programs. d comple holders seeking credit for such Atprog a

i required to certify thed permit correc minimum, this approach requires f such NRC  !

suitable guidance to the licensees sean t on the minimum acceptable

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them. mt Limit NRC involvement u NRC/ util RC C. discussions on "weaknestes" perc

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nronram reviews conducteinvestigation d -

program

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..n ENCLOSURE i

-For: The Commissioners >

From:- -William J. Dircks 1 4

Executive Director for Operations i

Subject:

ALLEGATION PROCESSING PROGRAMS IMPLEMENTED BY UTILITIES i

Purpose:

To obtain Comission approval of the staff proposal on the i extent to'which NRC should evaluate such programs including i

. .that necessary to support the. licensing process. l Category: .This' paper covers.a significant' policy question requiring-Comission consideration. Resource estimates are Category 2 since, depending on the course of action chosen,  !

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not all resources that could be involved are under the  !

direction of the EDO.-

Issue: Whether the NRC should provide guidance on, and evaluate the effectiveness of, the several utility-initiated- ,

programs at power reactor sites to collect and resolve  !

utility employee concerns.and allegations. l Decision Criteria:= 1. Should NRC require establishment of formal programs by licensees and permit holders to solicit, collect, .;

and evaluate concerns from.present and.former workers  !

to determine safety significance and appropriate- .i corrective actions.in a consistent and acceptable i manner?

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2. If NRC decides not to require such programs, should 4 the NRC become involved at all in any l utility-initiated allegation resolution programs? l

3. Should NRC give credit to pennit holders for such '

programs as a part of the certificationLthat the facility has been built and its staff has been trained .

in substantial agreement with the application? ,

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4. Should NRC involvement be limited to the receipt of certification by licensees and permit holders of the '

results of allegation resolution programs?

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k ENCLOSURE j

For: The Commissioners From: ' William J.- Dircks

' Executive Director for Operations  :

Subject:

ALLEGATION PROCESSING PROGRAMS IMPLEMENTED BY UTILITIES

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Purpose:

To obtain Comission approval of the staff proposal on +he -

extent to which NRC should evaluate such programs.inclu Ing j

- that necessary to support the licensing process.  !

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~ Category: This paper covers a significant policy question requiring Commission consideration. Resource estimates are ,

Category 2 since, depending on the course'of action chosen, i not all resources that could be involved are under the direction of.the EDO. I Issue: Whether the NRC should provide guidance on, and evaluate the effectiveness of, the several utility-initiated programs at power reactor sites to collect and resolve ,

utility employee concerns.and allegations.

Decision Criteria: 1. . Should NRC require establishment of formal programs by licensees and permit holders to solicit, collect, and evaluate concerns from present and former workers . '

to determine safety significance and appropriate corrective actions in a consistent and acceptable manner?

2. If NRC decides not to require such programs, should '

the NRC become involved at all in any i utility-initiated allegation resolution programs? j

3. Should NRC give credit to permit holders for such programs as a part of the certification that the facility has been built and its staff has been trained in substantial agreement with the application?

4. Should NRC involvement be limited to the receipt of certification by licensees and permit holders of the results of allegation resolution programs?

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5. Should NRC conduct fomal inspections of-the technical issues and formal.OI oversight of wrongdoing issues identified through licensees' and permit holders' ,

allegation resolution programs up to and including all

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t facets of the programs?.

6. Will an NRC decision to inject itself into these

. programs either stifle their. effectiveness or cause  ;

the licensees and pemit holders to suspend- them and

. .what are the potential impacts of such decisions on- .

NRC?  !

Alternatives: A. NRC promulgate detailed regulatory requirements making these programs mandatory and providing the basis'for inspections of-the programmatic features of licensees' and permit holders' programs, including reviews by OI of the progrannatic aspects of licensee investigations of " wrongdoing" issues. Periodic, consistent, indepth l inspections of program implementation including hardware and indepth reviews of wrongdoing. . -

1 investigations could then be conducted to minimiz'e the 1 potential for "last minute"~ surprises in the licensing j process. )

B.- NRC conduct inspections of programmatic features as. j well as a representative sampling of allegation 3

. processing files covering hardware selecting only controversial and' safety significant problems on a case-by-case basis. Moreover, selected wrongdoing matters would be reviewed by 01 to assure appropriate  ;

investigative technique and conclusions. These  !

sampling inspections, although limited in number, would cover all information developed under licensees' and permit holders' programs. ' Licensees and permit holders seeking credit for such programs would be I required to certify the correctness and completeness j of the program results before licensing. At a  ;

minimum, this approach requires Mtc to provide suitable guidance to the licensees and permit holders s on the minimum acceptable attributes of such programs, I should licensees and permit holders propose to conduct  !

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C. Limit NRC involvement to NRC/ utility management  !

discussions on " weaknesses" perceived by NRC in i arogram reviews conducted to date using NRC allegation landling system and investigation program criteria as  !

guidance. However, licensees and permit holders would l be required to certify the correctness and .

completeness of the results of the allegation  !

processing activities to the NRC if the licensees or j i

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permit holders wish to be given consideration for these actions in licensing decisions. > NRC would then deal only with allegations brought directly to it.-

D. NRC maintain a " hands-off" stance permitting licensees and permit holders to establish and_ implement their own programs with no credit given to these programs for licensing decisions. As an aspect of this alternative, NRC could encourage the industry.and

- interested parties to collectivize and self-police

-such utility programs.

- Sumary: Since 1983, the majority of power reactor licensees or pemit holders with'a unit under construction have instituted some type of program to receive and disposition concerns expressed by segments of their work force about construction or operation activities. Several of these programs were instituted at the urging of senior NRC managers', consistent with the philosophy published on the NRC Form 3; i.e., workers are encouraged to discuss their concerns with their management before coming.to NRC. The present programs vary extensively with regard to degree of ,

formality, the training and background of the involved staff members, the methods by which issues are dispositioned, and the placement of these programs within j the licensee's organization. 1 This paper sumarizes the NRC experien:e with such programs to date and discusses whether NRC should require licensees to institute such programs, and to prescribe.the basic features of such programs. The paper also discusses lesser -l alternatives to the formation of regulatory requirements.

The staff recomends against requiring these programs, but recognizes that such programs deal with issues that could become allegations directly to NRC. Therefore, the staff recomends that it.be directed by the Comission to have senior NRC managers discuss NRC concerns about these i programs with utility management, but that NRC allow the i utilities to run their programs without NRC involvement. l (Alternative NRC actions would be limited to those

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necessary to disposition allegations given directly to NRC.) , ,

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Background:

Since about 1983, several utilities constructing nuclear i I

plants have established and implemented programs directed toward the identification and resolution of improper activities at  ;

construction sites that could affect safety or other areas of importance to the utility.

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1 These programs are in' addition,to the quality control .

j inspections and quality assurance audits required by their j g" , approved QA Programs.. These' additional programs are -  !

primarily' directed towards receiving and/or soliciting I individual concerns from workers', staff members, and/or the )

public. (In general, the largest number of improper '

activities'are alleged primarily by construction workers who are being tenninated due to the completion.of plant q

~ construction.) The programs established to resolve these i

. allegations are voluntary in nature;.there is no NRC requirement to conduct such programs. The management of several facilities.having such programs have indicated 'l their intention ~ to continue them after completion of construction as long as they continue to receive j

allegations, but expect the staff associated with the continuing program to be much smaller than'during. :i construction.

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1 In response to a 2.206 petition submitted by GAP in May,1985, an NRC team (Region'IV IE, NRR, and 01)  ;

conducted a detailed review of all the allegation files I accumulated by KG&E under the Quality First program for the  !

Wolf Creek Nuclear Station to determine whether the ~j allegations were properly investigated and resolved. Prior to this activity,: Region IV with assistance. from IE had. -

performed a review of the Quality First programmatic :l attributes and had monitored progress in resolving )

allegations. ' Up until the special'May,1985, effort, d approximately 40 percent of the files had been reviewed to l some degree by NRC. Consequently, for the Wolf Creek facility, NRC has conducted a fairly extensive review of the Quality First allegation processing program.

With regard to other nuclear plants NRC has perfonned a review of allegations processed by PG&E for Diablo Canyon Unit 1 and by LP&L for Waterford Unit 3, a sampling review of the Safeteam program for Fermi Unit 2 as established by Detroit Edison,'and presently plans a. detailed progrannatic review and sampling of allegation processing for the Comanche Peak facility in support of its upcoming OL licensing activity.

The programs of other. utilities with plants under 3 s ,*, '

construction have been reviewed to varying: degrees as'noted in the Attachment to this paper. A review of the information in the Attachment will also show that the programs that exist vary widely in certain attributes:

Scope: Programs vary from availability of "Hotlines" to interviews of selected l crafts or disciplines to extensive l l

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" outreach" programs including former employees at a site.

Implementation: Programs vary in degree of procedures to assure consistent handling; selection

-of individuals assigned to various 1 aspects of the program; and the methodology and organizational entities ,

used to followup and resolve concerns.

i Accountability: Programs vary as to the level of i management to whom the directors of '

these programs report. Several . report  ;

to the.CEO of the utility and several  !

are used as logical extensions of the  !

QA organization of the utility. Other reporting channels also exist.

A consistent feature of all-of these programs is that each I involved' utility has been quite willing to provide NRC- )

access to these files.

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NRC reviews of these programs thus far indicates that allegations can_be categorized into the following general areas:

Nuclear Safety Management' i Industrial Safety- '

Miscellaneous (including Security)

Our reviews showed some weaknesses in processing were -

evident; however, most purely technical allegat'ons seemed to be resolved in a manner consistent with what NRC would require if we had made the original finding.

Those concerns which involved wrongdoing intimidation, '

harassment, forgeries, drugs, theft, etc.) can be identified I within any of.the above categories. Reviews of the implementation'of the programs by 01 at Wolf Creek and -

Ferai Unit 2 on these kinds of issues indicated that the resolving of wrongdoing concerns is not done using the investigative approach that 01 views as. appropriate for the issue. In many cases, these programs'do not define wrongdoing in the same context as NRC nor do they pursue that issue as an entity itself ' deserving of attention.

Rather they of implications focus, to varyingIt (degrees, the issues. should be on thethat noted hardware the general issue as to whether licensees were required to report wrongdoing instances to NRC was the subject of correspondencebetween01andOGC.)

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-l Discussion: In October 1984 IE perfomed a survey of all utilities -l constructing nuclear plants to catalog-the extent of i utility-initiated allegation programs such as. Quality First

, and Safe-team.

[ NOTE: 'IE .should insert infonnation as to why and how this . ,

.- . survey was conducted to; demonstrate conformance to' established.

controls under the Paperwork Reduction Act.]

The.results of this survey are shown in the Attachment to

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.this paper and indicate that all such' utilities are in one '

stage or another of. developing and implementing such.

programs of this type.

Despite the extent to which NRC has already monitored the performance of a number of these' programs, the fundamental policy issue at this point is whether it is appropriate for NRC to involve itself to any degree in these voluntary .

licensee and permit holder programs. Should the Connission decide against Alternative A presented below, the subsequent:

alternatives' provide various options NRC could establish to address the various utility programs, recognizing that no ,

NRC requirement presently exists for such licensee activities. '

It is' reasonable to anticipate that any NRC review of

, ' utilities' allegation files will result.in the identification of a small number of violations and wrongdoings that had not been reported to NRC.

The alternatives are evaluated as follows:

Alternative A NRC promulgate. detailed regulatory requirements making these programs mandatory and providing the basis for inspections of the progransnatic features of licensees' and pennit holders' programs, including reviews by OI of the programmatic aspects of. licensee investigations of

" wrongdoing" issues. Periodic, consistent, indepth inspections of program implementation including hardware and indepth reviews .of wrongdoing' investigations could then be conducted to minimize the potential for "last minute" surprises in the licensing process.

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PRO: NRC could rely to the maximum extent upon the .

results of the program and attest to their correctness and completeness.

CON:

With NRC initiating specifically planned inspections '

in this area, licensees could cancel their voluntary programs.

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NRC would 'discourageLthe ' adoption of. initiatives by. -

licensees.and permit holders with some fear of their "

h . conversion to "de facto" requirements.

• 'Any employee concerns about loss'of their:

" confidential" status would be maximized. '

RESOURCE ESTIMATE:

. Present estimates would place the resource requirements to:

implement these inspection programs (Alternatives A and B) over a-range of 10-2 p-yr/ licensing effort. ..These are 4 unbudgeted resources .and if applied to units under  !

l construction would have to be reprogrammed over the next two years. It must be noted that when inspections or. ,

evaluations are conducted, effort is expended at- a rate ~ ,

. until sufficient information has been drawn to form a- _i

. conclusion on adequacy. In the experience.to date, absent 4

specific NRC guidance and evaluation effortson suchbeen have programs..

variedthe but~virtually inspection' al l-efforts have identified deficiencies when compared to the way. NRC would 'have handled the: concerns. If the decision

- of the Cossnission is ito involve NRC in these programs and to issue prescriptive: requirements or detailed guidance.

then these resource. estimates- could be refined. Absent of -

such requirements or. guidance, the agency ' runs- the risk of substantive' resource comitments, although probably less than if all.these concerns were provided directly to NRC.

Alternative B NRC conduct inspections of programmatic features as well as a representative-sampling of allegation processing files" covering hardware selecting only controversial and safety significant problems on a' case-by-case basis. Moreover, selected wrongdoing matters would be reviewed by 01 to' assure appropriate investigative technique and conclusions.

These sampling inspections, although~ 1imited in number, >

would cover all information developed under licensees' and permit holders' programs. Licensees and permit holders seeking credit for.such programs would be required to certify the correctness and completeness of the program results before licensing. At a minimum, this approach ,

requires NRC to provide suitable guida~nce to the licensees and permit holders on the minimum acceptable attributes of such programs, should licensees and permit holders propose to conduct them.

PRO:

• The PRO for Alternative A applies here though to a lesser degree.

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J NRC could conserve.the amount of resources requiring .

reprogramming to a-greater degree than required for Alternative A. R CON:

Same as in Alternative A.

RESOURCE ESTIMATE: y

' Essentially the s'ame as for Alternative A.

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Alternative C Limit NRC. involvement to NRC/ utility management discussions  ;

on." weaknesses" perceived by NRC in program reviews. conducted :l' to date.using NRC' allegation handling system and investigation

' program criteria as guidance. However, licensees and permit holders would be required to certify the. correctness and completeness of the results of their allegation resolution-activities if they wish to be given consideration for these-actions in licensing decisions. NRC would then deal only with allegations brought directly to it.

PRO:

_NRC could rely to a limited extent upon,the results of any certified program though less than I that provided by. Alternative B.

The licensee would.have the benefit of the experience and perspective of NRC in dealing with-such issues.

NRC would require less resources to be reprogrammed than Alternative B.

NRC posture would be consistent with that published in NRC Fonn 3.'

CON:

Without inspection or evaluation on a sampling basis, NRC could not firmly attest to the' adequacy of resolution of utility allegations.

Allegations of wrongdoing within this program or public concerns could lead us to full scale

, evaluation of program results if the programs are not conducted in a fashion compatible with NRC@in staff and managerial views. There is an '

unpredictable resource commitment risk associated with this alternative.

• This alternative would require disciplined restraint by NRC managers to avoid evaluations except those prompted by adequate cause.

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l i RESOURCE ESTIMATE:

1NRC'would not have to' reprogram an approximate range of; 2-10 p-yr of effort per licensing action from other agency activities.

l Alternative D -

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NRC maintain a " hands-off" stance permitting licensees and' l

. permit holders to establish'and implement their own-programs j with'no credit _given to these. programs.for licensing  ;

decisions. As an option to this alternative, NRC could encourage the industry and interested parties to collectivize.

and self-police such utility programs. j j

t PRO: NRC would not have to direct resources to evaluate the program. (The staff perception is that these'. j programs have conserved additional resources that.

might have otherwi.se been spent to resolve  :

allegations that are now resolved by the licensee.)

NRC would still, under present utility attitudes, have ready. access to all program files. l i.

Any utility employees' concerns about loss of. ,

their " confidential" status would'be minimized. j NRC would minimize risk of utilities suspending these' voluntary programs with attendant . increase of allegations directly to NRC.

CON:

Essentially the same as for Alternative C. 1 Allegations of wrongdoing within this program or public concerns could lead us to full scale evaluation of program results if the programs are not conducted-in.a fashion compatible with NRC staff and managerial views. There is an unpredictable resource commitment risk associated with this alternative.

l-NRC would not have programmatic guidance available l when ad hoc inspections are required.

l ze, RESOURCE ESTIMATE: .

1 No impact on staff resources, except if, for.cause, full scale evaluation is necessary. The evaluation would be 2-10 p-yr per required evaluation.

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Recommendation: That the Commission. .

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1. Atarove Alternative C: Limit NRC involvement to-NIC/ utility management discussions on " weaknesses" perceived by NRC in program reviews conducted to date using NRC allegation handling system and investigation  ;

program criteria as guidance. NRC would then deal l only with allegations brought directly to it. '

. 2. Direct the staff to proceed with the preparation of suitable management guidance on an expedited basis I making the necessary Headquarters and regional staff l assignments to assure management level interactions with licensees and permit holders by October 1, 1985.

l Scheduling: This paper should be scheduled at an open session. It is '{

requested that Commission, action be accomplished by  !

August 15, 1985, to assure maximum conservation of agency  !

resources for upcoming licensing actions.

l William J. Dircks Executive Director for Operations i

Enclosure:

Allegation Processing 4 Programs for Utilities '

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l ATTACHMENT 1

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NRC Plant Est. F.L. Date Allegation Program Inspection

' REGION IV: -

Comanche-Peak 1- Mid-1986. A Safe-team program A team visit (100% complete) comprised of-2 full- on 6/14/85:

2- 1986 time and 7 part-time surveyed the.

(65% complete) interviewers and 5- program and investigators was sampled activities implemented.1/85. in some selected 1 The Safe-team manager cases. l E.

reports directly to  ;

the TUGC0 Executive VP.

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The program allows for-  !

recei)t of allegations by 6 telepione, mail,and exit interviews. The program also periodically-solicits input from randomly selected i individuals. 'There were about 400 concerns 1 received between 1/85 and 6/85. Allegations l received prior to 1/85- l were handled by a TUGCO.

consultant ~and.apparently have not been evaluated under the current program.

River Bend 1 8/85 A formalized " quality Special inspection q (97% complete) concern" program was of the programmatic established in early aspects and imple-1984. Prior to this mentation conducted the utility had been 3/85. This conducting exit included a review interviews with all of completed l- departing QA/QC 'qvestigations.

personnel. New program A Nrther review require's exit was conducted 7/85.

interview with QA/QC t persons, construction j foremen, and welders.

I Posters are used to publicize the program and indicate that concerns may also be brought to NRC. A hotline is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

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-4b-a day. Mail-in concerns are encouraged. Recent changes to the program have been made for stronger control of confidentiality and the utility will followup 1 with each alleger on the results of investigations.

i South Texas 1 12/86 Safe-team established Looked at sampling ,

(60% complete) 9/84 using 4 full-time- of concerns and  !

2 12/86 interviewers. Safe- resolutions; no .

(30% complete) team reports to the specific l Manager Nuclear programmatic  !

Assurance. Allegations. review but i concerning nuclear . suggestions were  !

safety are investigated made.

by 14 full-time ,

independent. investigators.  :

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The findings are turned over to the normal organizational entity for corrective action and then reviewed by a oversight comittee of senior managers. A ,

hotline is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. All QA/QC personnel on site have been interviewed by Safe-team and'other scheduled interviews are conducted as necessary.

Followup with allegers

, and former employees on results of investigations

! is part of the program.

About 260 concerns have been received to date, j.

! Waterford 3 12/84 " Quality Team" NRC reviewed.

(100% complete) established in 1/83 program and to interview QA/QC found weaknesses; J.

I personnel onsite by information was' J j' outside consultants; requested by identified 72 safety- 6/13/84 letter related concerns; exit and responded in interviews of QA/QC 8/10/84 LP&L personnel comenced letter.

in 1/84 (19 more concerns); no documented l

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-4c-procedure initially available (first issued in 7/84); ind: pendent  :

interviewers to be used; 1 will interview all exiting l personnel in. future. l Wolf Creek 3/85 " Quality First" program; NRC has conducted (100% complete) " hotline" and exit 6 random sampling interviews; documented inspections of procedures; established the Quality-early.1983. Firs t: Program, and finally a j 100% inspection by (

a 17 person team in 5/85.

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