IR 05000220/1989021

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Insp Repts 50-220/89-21 & 50-410/89-16 on 890821-25.No Unsafe Conditions Noted.Major Areas Inspected:Licensee Programs & Practices for Addressing Employee Concerns
ML17056A296
Person / Time
Site: Nine Mile Point  
Issue date: 09/06/1989
From: Wiggins J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17056A295 List:
References
50-220-89-21, 50-410-89-16, NUDOCS 8909220095
Download: ML17056A296 (16)


Text

U.S.

NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos.:

Docket Nos.:

50-220/89"21 50-410/89-16 50-220 50-410 DPR-63 License Nos.:

NPF-69 Licensee:

Niagara Mohawk Power Corporation 301 Plainfield Road Syracuse, New York 13212 Facility:

Location:

Dates:

Nine Mile Point, Units 1 and

Scriba, New York August 21 through August 25, 1989 Inspectors:

W. A. Cook, Senior Resident Inspector R.

K. Christopher, Enforcement Specialist L.

M. Kolonauski, Project Engineer, DRP D.

H. Oudinot, Licensing P oject Manager, NRR Approved by:

Jam T. Wiggins, Chic Reactor Projects Branch No.

Division of Reactor Projects Date Ins ection Summar A~I:

i i

i <<h programs and practices for addressing employee safety concerns and whether employees are harassed or intimidated for raising safety concerns.

This inspection involved 106 hours0.00123 days <br />0.0294 hours <br />1.752645e-4 weeks <br />4.0333e-5 months <br /> by the four inspectors.

Results:

The inspection identified no unsafe conditions.

The inspectors noted that the employees interviewed expressed no reluctance in reporting concerns to management and were sufficiently familiar with the numerous reporting mechan-isms available for reporting employee concerns.

In addition, the inspectors identified no evidence of harassment or intimidation of employees who had raised safety concern TABLE OF CONTENTS l.

Objective...

2.

Methodology.

~Pa e

3.

Overall Assessment.....

.4.

Summary of Findings........

5.

Program Review 5.1

"Tell It to the Superi 5.2 Quality First Program AORS ntendent" Program...........

~..

(Qlp)

6.

Allegation.

7.

Operator Assessment....

8.

Exit Meeting.

DETAILS Objective The objective of this special assessment team inspection was to gather sufficient information to assess whether licensee programs, policies and practices for addressing employee safety concerns are acceptable and do not result in any discrimination against, harassment or intimidation of the employees raising those concerns.

Methodolo To gather the necessary information to make this assessment, the Team con-ducted a

limited review of the programs and policies established for handling safety concerns and focused a majority of their efforts on inter-viewing Nuclear Division employees.

The employee interviews were struc-tured to determine the following information:

has licensee management adequately established and communicated the mechanisms available to the employee tc idertify and raise safety concerns for resolution; have the employ es used these various mechanisms and is the climate within the licensee's organization conducive to raising concerns; and once concerns have been identified to licensee management, have the concerns been addressed in a timely and effective manner, and has the initiator of the concern been provided a status or resolution of the concern.

The Team conducted both scheduled interviews and random interviews during tours of ths faci'iities.

The scheduled interviews were a

mixture of employees preselected by the Team, employees selected by the licensee and volunteer interviewees solicited by the Team.

After being made aware of the Team's presence on site and that request for volunteers for inter-views, the Mechanical Maintenance Shop extended an invitation to be inter-viewed as a group.

The Team accepted the invitation and interviewed the shop staff following their 7:00 a.m.

morning meeting on August 25.

Other shops on site extended similar offers to be interviewed as a group, but could not be accommodated by the team because of time constraints.

Overall Assessment The Team concluded that there is currently no reluctance of employees to report concerns (safety or otherwise),

to their management.

Also, the Team concluded that there is no evidence of any discrimination, harassment or intimidation of employees who have raised concerns.

guite to the con-trary, a

large percentage of the interviewees stated that they were strongly encouraged to bring concerns forward and in some instances praised for this actio.

Summar of Information Identified Durin Em lo ee Interviews The inspectors interviewed 97 station employees individually, ranging from line workers to managers and conducted one group interview consisting of both line workers and supervisory staff.

The summarized interview results are listed below.

b.

The inspectors found that station employees have no reluctance in bringing identi,fied concerns forward to their immediate management.

The employees also expressed

'no reluctance in taking the concerns to succeedingly higher levels of management until the issue was resolved to their satisfaction.

The interviewees expressed no fear in having their identities associated with the raising of concerns, and had felt no need to premise their raising of concerns upon the receipt of confidentiality.

To the contrary, many employees stated that they wanted to be identified with their specific safety concerns because it is now viewed as a positive employee contribution.

Also, many wanted to be involved in determining the solution to their concern.

The employees were sufficiently fami liar with the numerous methods available for reporting concerns.

These methods

'ncluded their nor-mal chain of command, the Quality First Program (Q)P),

"Tell it to the Superintendent" program, problem reports, corrective action reports (CARs),

and if necessary, reporting concerns to the NRC.

C.

Most employees noted an improvement in recent years in the resolution of employee concerns.

Most attributed tie improvement to increased management reception and responsiveness to employee concerns.

Many also noted that communications between management and workers had much improved, pointing to the town hall meetings conducted by the Executive Vice President as an example.

Many cited increased emphasis on teamwork.

Others were appreciative of the increased mechanisms now available for reporting and tracking employee concerns'.

A minority of those interviewed at the worker level, indicated that conditions for reporting and resolving concerns had always been sat-isfactory, and therefore, they did not feel that conditions had improved, but remained steadily acceptable.

e.

Most interviewees who had recently reported concerns to their manage-ment were satisfied with both the timeliness and thoroughness of man-agement in resolving their concerns, Two specific examples noted by the inspectors were the resolution of a

concern raised by security guards of radon gas contamination of their trousers while watchstand-ing in certain areas of the plant; and, the recent improvement in

Ct

engineering staff reviews of local leak rate testing results, as well as, their generally more frequent site visits and interactions with station workers.

Most acknowledged that the priority that they would give thei r concerns, was not necessarily the same as that given by their management, but recognized that management had to deal with a broader scope of concerns in varied areas.

Few employees interviewed had direct experience with the guality First Program (pip).

With the exception of one individual, all interviewees stated that they would use the program if necessary and had no reservations about its effectiveness or ability to adequately resolve concerns.

The one individual who took exception had no direct dealings with (}1P, but stated that he was aware of another individual who had gone to glP with a concern,'nd to the inter-viewee's knowledge, that individual had not received feedback on resolution of the concern.

A significant number of the supervisory-level personnel interviewed communicated to the inspectors that it was their understanding that a

precondition to utilizing the 01P was to exhaust the normal chain of command to get a concern resolved.

A',though the NRC team agrees that the use of the chain of command should be encouraged and utilized whenever possible, this supervisory-level employee concept has a

potential for undermining the independence and confidentiality of the glP.

None of the worker-level personnel shared this mi sconception.

Of the contract personnel interviewed, all stated that they were af-forded the same mechanisms to raise safety concerns as their Niagara Mohawk counterparts and felt free to make any concern known without fear of harassment or intimidation for doing so.

From one interviewee, the inspectors received information that there were incidences of three other employees being harassed and/or intim-idated as a result of 'concerns they raised.

The Team subsequently interviewed these individuals and could not substantiate that these employees were harassed, intimidated or otherwise rebuked for their actions.

The Team accepted an invitation to attend the morning shop meeting of the Mechanical Maintenance Department on August 25.

guestions and answers were exchanged between the Team members and employees for approximately one hour.

The Team members participating concluded there to be generally candid and uninhibited communications between the workers and shop supervisio e

The Team conducted a, limited review of some of the programs available to employees to raise safety and personnel-related-concerns outside the nor-mal chain of command.

Specifically, the Team reviewed the guality First Program (g1P)

and the "Tell It to the Superintendent" Program, and this review confirmed, to the extent possible, the comments received during the interview process regarding the use of these programs and the results achieved.

'. 1

"Tell It to the Su erintendent" Pro ram This program provides an anonymous, if desired, means to communicate in writing a concern to the General Superintendent for his personal consideration.

In a relatively short period of time the General Superintendent will notice the concern at various locations on site and provide his response.

The Team concluded that this program is frequently used (approximately 70 concerns in the past year),

and is generally well received by the station employees.

The preponderance of concerns are personnel-related.

5.2 ualit First Pro ram IP The glP provide's a

24-hour p'er day service to Nuclear Division employees for addressing any type concern which may impact the safe operation of the nuclear facilities.

The glP also conducts exit inter views with all employees and contractors who have completed their activities at the site.

Concerns may be addressed to glP with confidentiality, if desired.

The inspector verified that the l}1P was widely advertised on site and easily accessible to all station personnel.

A review of active and closed concerns indicated the following:

There has been a decline in the total number of concerns over the years; 1986 (71),

1987 (22),

1988 (18) and 1989 (9 to date).

Confidentiality appeared to be adequately maintained by the glP manager.'oncerns received appropriate prioritization for review, based upon their safety significan'ce.

Issues involving wrongdoing were properly referred to the Secur-ity Department.

Concerns involving the equality Assurance organization were properly handled to ensure independent overview by senior managemen Concerns were reviewed and closed out in reasonable time periods (the goal is 4S days and the current average is approximately

days).

Of the four harassment and intimidation (HINDI)

concerns addressed by the Q1P to date, one was substantiated by the licensee.

The inspector determined that the conclusions in all cases were well supported by investigation facts and detailed interviews.

In the case of the one substantiated HE I concern, the inspector concluded that appropriate management action was taken to address the problem.

The Team concluded that

= QIP provides a

viable alternative to employees for the independent and confidential assessment of a safety concern.

6.

~Alla ation During the interview process, the Team received one allegation.

The Team reviewed the specifics of the allegation and the context in which it was prov"'dad in the interview.

It was concluded that the allegation. is of a technical nature and its detailed followup was outside the scope of this inspection.

Followup of this allegation will be conducted during a subse-quent routine inspection.

The Team interviewed the alleger to determine if the concerns involved in the matter had been communicated to licensee management.

The

>ll,cger indicated that the concerns had been discussed with management and had been addressed.

However, the disposition of these concerns was not to the individuals's satisfaction.

The Team questioned whether the individual had pursued the alternate methods available for reporting concerns, such as

.through the Q1P.

The individual indicated that because the concerns were not considered safety issues and because of a lack of confidence in the Q1P process, these con-cerns were not provided.

The Team concluded that the individual's lack of confidence in the QlP process was not based on facts, but rather on supposition.

The Team therefore concluded that this individual represents an isolated case among the other interviewees and the individual's lack of confidence in Q1P did not adversely affect the Team's conclusions regarding the adequacy and effectiveness of this proces.

0 erator Assessment As part of the ongoing NRC review of licensee readiness for restamp,,

the inspectors have closely monitored operator performance and behavior.

Dur-ing this inspection the team received excellent cooperation from the. oper-ators and the entire station and Engineering Department staffs.

Employees interviewed were helpful and candid in their responses.

8.

~Ei N

At the conclusion of the inspection, a meeting was held with senior sta-tion management to discuss the scope and findings of this inspection.

Based on the NRC Region I review of this report and discussions held! with licensee representatives, it was determined that this report does not contain Safeguards or

CFR 2.790 informatio l