ML20207D777

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Advises That Listed Addl Effort Needed from Intimidation Panel,Including Review of Allegations Referred by Board & Rept on Review of Plant Ombudsman Program
ML20207D777
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 11/01/1985
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Noonan V
Office of Nuclear Reactor Regulation
Shared Package
ML20205D361 List:
References
FOIA-85-799 NUDOCS 8607220183
Download: ML20207D777 (3)
v • d • e


Text

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af/er MEMORANDUM FOR: Vince Noonan, Chief. EQB, DE. NRR FROM: James E. Gagliardo, Director. TTC, IE

SUBJECT:

ADDITIONAL EFFORT AND INPUT NEEDED FROM THE I&H PANEL The following additional effort is needed by the Intimidation Panel:

o Complete the review of the two allegations referred to the Panel by the Board, and include the result of the review in the supplemental report. These allegations were made by Mr.

Mouser earlier this year.

o Complete the report (part of supplemental report) on the review of the Omsbudsman Program at Comanche Peak.

o Complete the review of the reports of the special RIV task force and OI regarding their review of the SAFETEAM effort at Comanche Peak, o Complete the review of 01 Investigation Reports 4-84-039 and 4-84-050, and report the results of the review in the supplemental report, o If the Hearing Board continues its review of the Lipinsky incident, the Panel should complete the review of this effort and report its evaluation in the supplemental report.

If you have any questions on this effort I would be happy to discuss it.

8607220183 860715 J. E. Gagliarco, Director PDR FOIA Technical Training Center CARDE85-799 PDR Office of Inspection & Enforcement c"'"Q~Cl,[I,G.. . . ............. . ..... ....... . ... . .... ......... ..... .. . ..... . ...... ..... ... .. . ... . .... .

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Draf t 2 - 5/22/65 The intimidation panel concludes that the facts presented in this investigation report do not support a finding that other workers were intimidated by the firing of Mr. Atchison.

e. 01 Investigation Report 4-84-006

%b e 's-i w -

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VI Investigation Report 4-83-001 documented the OI investigation of the alleged intimidation of Mr. William Dunham's supervisor (Harry Williams) who had threatened to pull the certification and in effect terminate QC painting inspectors who continued to

  • nit pick." The investigation report added nothing to the.other .

k' information that was made available to the study team regarding this event. The study team and the intimidation panel have concluded that this event did constitute an act of intimidation }

and the above investigation report supports that conclusion. 'i 3.3 TRT Findings In Those Areas Where Intimidation Occurred On March 21, 1985 the intimidation panel met with the team leaders and other selected members of the TRT to determine if technical concerns had been found in those areas in which the panel had found intimidation events to have occurred.

The following is the list of identified events of intimidation as reported in Attachment 3 followed by the TRT findings for each of the areas in which the intimidation occurred:

o Cemanche Peak SSER 13

)

Draft 2 ~ 5/22/85 H

(1) 'D. Stiner - Weave Welding on Pipe Supports.

f.,,

This area was examined by both Region IV and the s TRT. Neither group could substantiate the technical allegations made by Ms. Stiner. ,/

0$. $. -

(2) D. Stiner - Circuit Breaker Article There is no technical area associated with tilis intimidating event.

(3) W. Dunham - Jntimidation of Coatings Inspectors The TRT Coatings Group found that the inspection procedures in this area were inadequate and that the QC inspectors had missed the big picture and were not finding the pinholes in the roatings.

They did fin;f a higher than normal percentage of

( faulty coatir.gs, but cculd not conclude.that it could ,

be attributed to the inspectors iuiving been intimidated.' .

(4) W. Dutiham - Terminatfor.

The higher the.n horral percentage 'of faulty coatings at CPSES may bo linked to this intimidating event, but there is insuf ficient information to indicate that this was a major or contributing cause.

(5) 5. Neuneyer - Liner Plate Traveller incident The QA/QC Team of the TRT did find a concern in the documentation of this area (see writeup on ,

AQ-55 and AQ-78 in SSER-11), but the ' Civil /

Structural Grcup found no significant problem in liner plate welds (see AC in SSER-8).

Comanche Peak SSER 13

~

[ _

J Draft 2 - 5/22/85 (6) C. Allen - ALARA and DCA Reviews This issue was addressed in AQC-36 cf SSER-9. The Coatings Team of the TRT found approximately aight discrepancies were significtnt. The generic fr.p'li-cations of the allegation are being reviewed as part

~

of the applicant's corrective action plan for TRT findings.

(7) C. Allen - Detergent on Coateo Surface i The TRT Coatings Team resiewed this issue and deter-mined that the detergent on the coatings a s not a detriment to the coatings.

(8) C. Allan - Cigarette Filter Incident This issue was reviewed by tAe TR1 Coatings Team (see AQO-17 in SSEP-9) and they concluded that sas11 amcunts of wier and til in:the. paint would htve had no impact on its adhentoce properties. ,

large quantities of water and oil.would tave been obvious to a trained QC inspector.

(9) T-Shirt Incident The T-Shirt incident was addressect by the QA/QC Team (see AQ-45 in $5ER-11) and the Electrical Team (see Electrical Category Ns. 5 in SSER-7). Neither team could find any indication that the incident had a negative irract on their nreas.

4 Comanche Peak SSER 13

~

. Draft 2 - 5/22/85 (10) S. Neumeyer - Stanford Incident ,

The TRT found no problem with the docurnentation 4 g .,j . , ,

of the welds in question in this allegation, but there was a question as to whether or not the non-destructive testing of the welds had been performed.

4. Management Implications 4.1 Climate of Intimidation In Attachments 1 and 3, the' study team concluded that there.was no climate of intimidation at CPSES. ,

Based cn the definitfonsf " Climate of Intimidation" used by the study temt, the intimidation panel agrees with that conclusion.

(s The panil agrees that the small.tumiber.cf intimidation events at a large site like CPSES suggests that intimidation was not pervasive. The intimidation panel is concerned, however, that thelsanagement styk at CPSES (to be addressed in Section 4.2) establishes a work environment in which the right chemistry exists for intimidation (actual or: perceived) to occur given the right set of .

c rcumstances. This ?ls an ama that needs innediate attention and is addressed j in Section 5.

l 4.2 Management Style

! In Attachments 1 and 3, the study team addm.ssed.the management style and inter-face problems (See Sections 3.3 and 3A respectively) as indicated by the l

depositional data and the survey data. The intimidation panel is also con-cerned about the apparent autocratic / bureaucratic style in the behavior of

! CPSES r.anagement.

l l

f l Comanche Peak SSER 13 l

, Draft 2 - 5/22/85

. ir9 the interchanges with TRT personnel (Section 3.3) the panel was informed

. t. tue HT personnel observed an atmosphere characterized by the employees' rea of management at CPSES. Since CPSES is a non-union project there is 1

a::a ently no internal grievance system, so that each employee holds his or her position at the whim of management. If there is such a system, there is

no incication from the record that it was effectively used.

In sum, it is the panel'.s view that the atmosphere created by the management

, style at the CPSES facility does not necessarily lead to improper construction or quality control. hie assume that many projects have been built with an unquestioning autocratic management style. However, it is the view of the panel that an important ' ingredient for an effective QA program to monitor the quality of construction -is an atmosphere where employees may freely raise safety related concerns to an intemsted management. 4Ihile it is clear that employees ,

did raise concerns, even those 1 making allegations of intialation, there was a perception, whether valid or not, that some management individuals did not truly want to hear concerns nor did they always provide adequate explanations to questioning employees. This is not to sqy that every employee has valid concerns.

t The utility hims,-trairs, and diacts the activities of the employee, but if it is going to keep the employee in a responsible : position, it must be satisfied that the employee understands his .or her job. It cannot keep the employee in a responsible position and not provide adequate explanations regarding his/her concerns. Failure to do so invites an employee attitude of not caring which will result in -the employee not rarrying out the expected job. The panel cannot conclude, however,, that the company's management style contributed in any way to the quality assurance issues at Comanche Peak. Poor procedures, training.

management direction could also have caused or. contributed to the quality

  • assurance issues.

1 Comanche Peak SSER 13 L

E

', ^ ! .

Draft 2 - 5/22/85

5. Action Recommenceo

,6 arcerns expressec oy son.e TRT participants and the collective findings of the study team and the intimidation panel suggest a need for action by TUEC r s;eme nt. The panel rectmmends that action should be taken to assure that ine managem4nt style of the TUEC organization is conducive to assuring a quality project. There is no one course of actior, such as the replacement of one or more managers, or a reorganization, or changing procedures to develop an internal grievance procedure that is recommended for changing the attitt. des and perceptions of the past. Licensee's mEnagement should take an objective look at the past incidents described in this"SSER as well as the current situation at the site and take steps as necessary to assure a quality first attitude by its management and employees. The use of- outside independent consultants may be appropriate and should be rensidered. The overall efforts should be directed at establishing ,

trust $etween.the anployees and management to eliminate any fear of reprisals ,

for anyone who identifies safety concerns or questions safety procedures.

In making these recommendations it is important to reiterate that the panel is not saying there is a pervasive climate of fear or that the licensee's manage-ment style in fact: contributed to quality issues. But given the examples des-cribed in the record and perceptions of some TRT members the panel believes that a concerned vanagement would take aggressive and dynamic action to avoid and erase any question of a potential problem of intimidation or harassment)

Comanche Peak SSER 23

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