IR 05000498/1985018

Insp Repts 50-498/85-18 & 50-499/85-16 on 851021-25.No Violation or Deviation Noted.Major Areas Inspected: Applicant Policies,Procedures & Implementation Re Safeteam Programs

ML20136E815
Person / Time
Site:	South Texas
Issue date:	12/17/1985
From:	Carpenter D, Constable G, Ireland R, Madsen G, Tomlinson D, Tomlinson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20136E767	List: IR 05000498/1985018 ML20136E761
References
50-498-85-18, 50-499-85-16, NUDOCS 8601070128
Download: ML20136E815 (7)

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, APPENDIX h" U.S. NUCLEAR REGULATORY COMMISSION

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_ . REGION.IV  ;

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NRC' Inspection' Report : -50-498/85-18l Construction Permits: CPPR-128

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50-499/85-16- CPPR-129 Dockets: 50-498~

50-499- 2 Licensee: Hou_ston Lighting & Power Company (HL&P)

P. O. Box 1700 Houston, Texas 77001 -

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' Facility Name: . South Texas. Project, Units 1 and 2 Inspection At: South Texas Project, Matagorda' County, Texas e

Inspection Conducted: ' October 21-25,'1985

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Inspectors: / 6 C2tav

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G. L. Madseh,-Project. Inspector, Project

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Section C, Reactor Projects Branch

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' 'l r/ m /" h ti.T P~.'Tomlinson,- Reactor Inspector .

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• Engineering Section, Reactor Safety Branch a

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/k khh !3r., t 2 - 09-W D.T Carrient'er, Resident Inspector, Project Date

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, -Section C, Reactor Proje ts Branch

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Approved: .,i //4/9(

G. L. Constable, Chief, Project Section Date

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. Reactor Projects Branch

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' 8601070128 860102 PDR ADOCK 05000498 G PDR b-4

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E.. Ireland, Chief, E'ngineering Section

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1  : Reactor' Safety Branc e , 4

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k, i, 1 Inspection Summary

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IbspictionConductedOctober 21-25, 1985 (Report 50-498/85-18; 50-499/85-16)

-g , - s AreasInspect$d: - Routine,$nannouncedinspection~ofapplicant'spolicies,

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4 , .- procedures,-and, implementation relating to the HL&P SAFETEAM. programs fcr

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si identifying andfresolvingl concern's resulting from exit, scheduled, and walk-in 0, interviews with;. applicant and contractor employees. _The' inspection involved h, ' .194 : inspector-hours onsite by 'three tNRC inspector AJ

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l' . m[Results:UWit.hin the' areas inspected, no violations or deviations were

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DETAILS

.. o Persons Contacted Principal Licensee Personnel-J. H. Goldberg, Group Vice-President, Nuclear

• J. E. Geiger, Manager, Nuclear Assurance

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• W. N. Phillips, Program Manager, SAFETEAM

• T..L.zJordan, Project, QA Manager

• J..W. Williams, Director of Special Projects

• J..T. Westheimer, Project flanager

'*B. L._ Hall, Investigations Supervisor, SAFETEAM

• J. B. Hart, Licensing

• S. M. Head, Lead Engineer, Project' Compliance ~

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S. S. Koelzer, Interview Coordinator, SAFETEMi NRC

. *G. L. Constable, Chief, Project Section C

• C. E. Johnson, Senior Resident Inspector

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• Denotes individuals attending the exit interview on October 25, 198 ' SAFETEA!! Program a.' . Organizational Structure ( '.

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- 'The HL8P SAFETEA!! program is implemented under the direction of

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W. N. Phillips, Program Manager, SAFETEAM, who reports to J. E. Geiger, Manager of Nuclear Assurance, who reports to '

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J. H. Goldberg, Group Vice President, Nuclear. As Manager of Nuclear Assurance, J. E. Geiger also has managerial responsibilities for the QA site organization, which has the potential to influence the processing of employee concerns within the SAFETEAM organizatio Formality of the Program The SAFETEAM concept was developed by Utilities Technical -Services, now SYNDIC 0, a subsidiary of the Detroit Edison Company and initially

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utilized at the South Texas Project in September 1984. The SAFETEAM handbook and manual were initially utilized in the implementation of the South-Texas SAFETEAM program. On May 1, 1985, HL&P issued a SAFETEAM Procedures Manual which.was revised and reissued on October 4,1985, as the SAFETEAM Instructions Manual . The existing program is essentially equivalent to the initial SAFETEAtt Manual with certain revisions, including:

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(1) Preparation and approval of investigation plan ,

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(2') Mechanisms'for following recommendations to implementatio '

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The SAFETEAM organization is comprised of the Program Manage '

Investigations Supervisor and one secretary (HL&P employees), and the following contract' personnel:

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('1) 0ne Administrative Technicia'n -LJeanneret and Associate '

(2) One Iriterview' Coordinator: 'Jeannere't and Associate < (3) Four Interviewers - Jeanneret and Associate (4) One' Investigation Coordinato'r;- National Inspection and Consultants, In '(5) .Seven Investigators - National Inspection and

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-Consultants, In ' -

HL&P has prepared job descriptions for the above positions. A review of these job descriptions by the NRC inspectors revealed that the .

requirements'for the investigators and investigator coordinator were minirr.al for the performance of the~ evaluation of concern * *

A review of resumes by the NRC inspecto_rs indicated that the qualifications of the individuals met the requirements of the HL&P

. job. descriptions. However, the resumes for two of the on-board investigators indicated less than normal levels of education and/or experience for the conduct of the evaluations of technical concern The review of a sample of closed concern files indicated that the two individuals in question where performing in an adequate manne .

Additionally, a review of personnel files revealed individual assessments and appraisals for these two investigators indicated favorable performanc Infonnation Flow

- Publicizing the SAFETEAM program to employees is accomplished through employee orientations, posters, stickers, inclusion of information in pay envelopes, and hand-out literature. The SAFETEAM building is conspicuously located on the plant site and is readily accessibl Five information~ booths are located throughout the site. Concerns come to the attention of the SAFETEAll through exit intervicws, scheduled-interviews, hot-line telephone calls, letters, and walk-in

& interviews. JInterviews are conducted with one interviewer in a closed office within the SAFETEAM building. The-interviewer

< -summarizes the individuals' concerns on a SAFETEAM reporting form and, if the ' individual agrees, the interview is also taped. The

, interviewer protects the identity of the concerned individuals by the '

assignment'of a numerical identifier. Names are revealed to the

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i investigators only when the investigation cannot be, conducted without such knowledge and has been formally authorized. The program manager reviews and classifies the concerns into five categories:

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' Class 11 - Nuclear Safety and Quality

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3* Class 3 - Industrial Safety Class 4 - Security y , -

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' Class 5 - Miscellaneous

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Class I concerns are assigned to the investigation coordinator for

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the preparation of inspection plans, performance of investigations,

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t and preparation of draft investigation reports and response letter to

, .the concerned individual. Investigation reports and response letters receive,the review and approval of the investigation supervisor,

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, . program manager and the SAFETEN4 review committee. The progra ^

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manager signs the response letters to the concerned individual Approved recommendations or suggestions are forwarded to 'he HL&P project manager for actions and a response to the SAFETEAM relative

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to actions tahen. SAFETEAM has an established computerized system'

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for tracking the recommendations and suggesti.ons. As a followup,

SAFETEAM sends a survey -letter to the concerned individual Class 2, 3, 4, and 5 concerns are assigned to the SAFETEAM investigation supervisor for control and coordination of the assigned

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cognizant organization's performance of investigations, preparation o .

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- investigation reports, and draft response' letters to the concerned individual. Final response letters to the concerned individual are .

l signed by the SAFETEAM program manage Followup on recomended  !

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. actions or corrections is controlled by the assigned cognizant '

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!r ;c organizations and are tracked by the SAFETEAM administrative .

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L Implementation of SAFETEAM Program '

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As of October 10, 1985, the SAFETEN1 had received 851 concerns from

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552 individuals. An analysis of the subject matter.by the NR s

. inspectors revealed that 254 of the concerns were related to '

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industrial safety,. personnel practices, etc. Another 85 concerns involving potential wrongdoing issues were identified for future-

!- review. Of the. remaining 512 technical concerns, the NRC inspection team selected 47 closed concerns for a file review. The sample ~,

included 33 class 1,'11 class 2, 2 class 3 and 1 class 5 concern :The= file review revealed the following:

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(1) THE SAFETEAM program is being implemented as planne ..e :

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(2) The classification:of' concerns into five categories (Nuclear jSafety and Quality Management, Industrial Safety, Security, and Miscellaneous) is performed in a conservative manner. The initial classification of a concern can be upgraded but not downgrade (3) The' program was established to protect the confidentiality of the concerned individual. In some cases the investigator was formally given the name of the concerned individual for cases where an investigation could not be accomplished without the name.- The confidentiality of the individuals was appropriately protected and did not appear to distract from the investigator's ability to evaluate the concer (4) Frequent recontacting of the concerned individuals for additional information was observe (5) Management's support of the SAFETEAM program has resulted in cooperation from other organizations in the evaluation of Concern (6) Observed weakness or areas of improvement included:

(a) The computer printout indicated a concern was closed. The concern file contained a letter to the concerned individual requesting additional information; however, no further information was included to provide a rationale for closu re. Discussions and reviews of documentation revealed that HL&P had recognized the need to investigate all concerns to the extent possible with the available information. Their previous review had identified 10 cases where additional information was requested and no response was received and investigations were scheduled. An HL&P reviewer identified five additional similar cases for which documentation for closure was not included in the concern files. During the course of the inspection, HL&P instituted corrective actions for documentation of closure for past files. HL&P's plans for the future includes investigation of all concerns with available information and documentation of rationale for file closur (b) Actions taken by other companies on SAFETEAM recomendations was not clearly documented. The NRC inspector was able to determine actions by looking elsewhere; however, some question exists relative to the SAFETEAM knowledge of the appropriateness of actions take (c) Class 1 concerns are presently a very broad classification

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which includes the entire plant. HL&P should consider establishing a subdivision within class I which identified

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concerns which may have an impact.upon the final licensing decisio ~

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As of August 21, 1985, the HL'&P computer printout-indicate that 94 class 1 and 51 class 2, 3, 4, and 5 concerns are pending investigation. .HL&P has been concentrating on reducing the investigative time for concerns; Presently, the average closeout time for class 1 concerns is about 75 day , Documentation The technical files reviewed were organized and were adequate to facilitate auditin HL&P is maintaining hard and microfilm copies-of concern files. The general control of_ files for the protection of the individual's confidentiality was found acceptabl . Management Notification ,

-Management is provided statistical reports relating to the SAFETEAM activit Additionally, telephone' conversations and meetings are utilized to' alert management of needed assistance and concerns of

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high:importanc , Trending

' Concerns are assigned to a classification (Nuclear Safety and Quality, Management, Industrial Safety,' Security and Miscellaneous)

and also to'a series of subclassifications. The information is-computerized and can be utilized for obtaining statistical data of the existence of similar concerns already within the SAFETEAM syste The ability has been used by the HL&P SAFETEA . Exit Interview An exit interview was conducted on October 25, 1985, with personnel denoted in paragraph 1 of this repor ,

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