IR 05000250/1990020
| ML17348A397 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/15/1990 |
| From: | Brady R, Butcher R, Crlenjak R, Demiranda O NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17348A396 | List: |
| References | |
| 50-250-90-20, 50-251-90-20, NUDOCS 9007170089 | |
| Download: ML17348A397 (16) | |
Text
9 pA AfQy Cq
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+s4.*<<4'NITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report Nos.:
50-250/90-20 and 50-251/90-20 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.:
50-250 and 50-251 License Nos.:
DPR-31 and DPR-41 Approved By: ic r
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ie Reactor. Projects Section 2B Reactor Projects Branch
Division of Reactor Projects Facility Name:
Turkey Point 3 and 4 Inspection Conducted~une 4g, 1990 Inspectors
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u c er SeniofrResident Inspe tor Tur ey Point Nuclear Plant ra y, ega ions r gram anager Office of Nuclear Reactor Regulation
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e iran a, ior ega ions oor inator Region II
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)s ate gne SUMMARY Scope:
This special, announced inspection was conducted at the Turkey Point Nuclear Plant near Florida City, Florida to evaluate the effectiveness of the Licensee's Nuclear Safety Speakout Program and perform an inspection of selected allegations received by the NRC Region II office.
Results:
The team concluded that:
The licensee's Nuclear Safety Speakout Program is an effective program for identifying and resolving employee concern A Speakout Program strength is the strong management support and dedicated, trained personnel'he identity of concerned individuals is appropriately protected Concerns are being effectively received, processed and tracked.
Coordination with the NRC Residents'ffice is excellent.
Allegations regarding the Speakout Program could not be substantiate REPORT DETAILS 1.
Persons Contacted M. A. Ammerman, HPES Coordinator
- L. W. Bladow, Manager, equality B. L. Brannick, Interviewer, Speakout
- S.
M. Franzone, Engineering J.
C. Gallagher, Investigator, Speakout
- J.
E. Geiger, Vice President, Nuclear Assurance
- K. E. Harris,Senior Vice President, Nuclear Operations
- J.
R. Hartzog, Superviso'r, Speakout (PTN)
J.
K. Luchka, Supervisor, Speakout (PSL)
J.
P. Palshook, Investigator, Speakout
- L. W. Pearce, Plant Manager
- D. R. Powell, Superintendent, Plant Licensing
- G. M. Smith, Manager, Nuclear Services
- J. J.
Zudans, Manager, Speakout
- Attended exit interview on June 8, 1990.
2.
Turkey Point Nuclear Safety Speakout Program a.
Policy and Procedures
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~
'here is no regulatory requirement for licensees to have a formal employee concerns program; therefore, the Florida Power and Light Company's Speakout program is a licensee initiative for providing a
means for employees to voice their concerns.
'This inspection was performed to,determine the effectiveness of the Speakout program in part, for processing allegations that are referred to the licensee for their review and action as the licensee utilizes the SPEAKOUT program for this purpose.
The inspectors reviewed FPL Instruction NSS-1, Rev. 0; Nuclear Safety Speakout Program, effective date, June 1,
1990.
The program, operational since April 2, 1990, was operated under a site procedure and a draft instruction until the issuance of NSS-1.
This instruction is quite comprehensive and, in addition to the standard sections on Responsibilities, Definitions, Procedures, etc.,
includes sections on Training and gualifications for the positions in the Speakout Program.
The Turkey Point site procedure, O-ADM-002, Nuclear Safety Speakout Program and Human Performance Enhancement System, dated April 26, 1990, was also reviewed.
The inspectors noted some inconsistences between the two documents, and several areas where clarification was required.
For instance, in O-ADM-002, at Section 5. 1.4, the reader is left with the impression that the decision on continuing an investigation, which may result in the identity of the alleger becoming known to individuals outside the Speakout Program, will be left to the discretion of the alleger.
Speakout personnel informed the inspectors that this would not be the
case, particularly where the allegation, if substantiated, could be safety significant.
The Speakout manager agreed that some revisions and clarifications should be made.
These revisions, when incorporated into the program documentation, should ade'quately address the concerns the inspectors had in this area.
Resources and gualifications The Speakout Appreciation Center is located onsite, outside the protected area.
The location is convenient to employees entering or leaving the site.
It is also adjacent to a
number of site administrative offices.
This location should provide an added level of comfort for individuals visiting the Center who may desire confidentiality.
The Center has a
number of private offices which can be used for interviewing and equipment and space to provide video instructions to several individuals at once when the need arises, e.g., for exit interview purposes.
The licensee is attempting to fill several temporary vacancies for investigators at the Turkey Point site to reduce the turnaround time of the outstanding items in the program.
The licensee considers this a temporary condition due to the newness of the program. Until they
're fully staffed, they are using a senior investigator from the Juno Beach site.
The inspectors briefly reviewed the qualifications of the Speakout employees and felt that all were qualified for their positions.
In addition, NSS-1 provides training requirements for all pos'itions in the Speakout Program, on both an initial and annual basis.
These training requirements appear to be appropriate.
All of the individuals working in the Speakout Program are assigned to the program on a full-time basis, i.e.,
they are dedicated exclusively to the Speakout Program with no other duties or functions.
The inspectors determined the licensee's resources and qualification of the Speakout staff were determined to be adequate.
Management Support The FPL Speakout Program is headed at the corporate level by a
manager who reports to the Vice President for Nuclear Assurance.
The Turkey Point site supervisor for Speakout reports directly to the corporate manager.
NSS-1 includes a statement of corporate policy by the FPL President, dated January 2, 1990.
This statement and another by the Executive Vice President, also dated January 2,
1990, document senior licensee management's support for the Speakout Program, and are'rominently displayed throughout the Turkey Point site.
The inspectors met with the Site Vice President and were assured that site management is fully supportive of the program.
Articles concerning Speakout have been placed in the site publication,
d.
To The Point, and Speakout presentations on the site TV system have 7<<
representatives and Turkey Point site management, which included management representatives from virtually every site organization, the Site Vice President reaffirmed management's support of the Speakout Program.
Clearly, one of the strengths of the Nuclear Safety Speakout Program is the support of the program by senior licensee management.
The inspectors determined that management support of the Speakout program was adequate.
Employee Awareness Extensive efforts have been made by the licensee to acquaint employees with Speakout.
The badging and General Employee Training (GET) process includes a video presentation on Speakout.
This -is repeated on an annual basis.
Copies of the licensee's policy on Speakout are posted throughout the site, and report forms and return envelopes for providing concerns to Speakout are available at several site locations.
Additionally, the location of the Speakout Appreciation Center, near the South Gate and the Contractor Entrance Building, is marked by prominent signs.
Finally, the number of concerns received by Speakout is further evidence that site employe. s are aware of the program.
The inspectors determined that the licensee's efforts to inform employees of Speakout was adequate.
3.
Review of Speakout Program Files The inspectors reviewed a -sample of the licensee's files to determine the effectiveness of the procedures for receiving, processing and tracking concerns received by the Nuclear Safety Speakout Program.
The inspectors review consisted of 50 percent of the 36 closed files and approximately
percent of 57 open files.
a ~
Secure Files and Confidentiality The inspectors verified that the licensee maintains'ecure files with controlled access that are physically located in the Speakout Appreciation Center.
Documentation associated with the concerned individual is sanitized to preclude revealing the individual's identity.
The sanitization process includes assigning the concerned individual a numerical identifier rather than using the name of the individual.
Periodic letters apprising the concernee of the status of Speakout's resolution efforts and the final closure letter also refer to the numerical identifier rather than the concernee's name.
The inspectors concluded that the licensee maintains secure and confidential records which are adequate for identity protectio Receipt and Processing of Concerns The inspectors verified that when concerns are initially received by
~ the Speakout Program, they are immediately reviewed for potential safety significance.
Concerns falling into this class are immediately acted upon by the Speakout Supervisor who notifies the Plant Manager and the site NRC resident inspector.
The inspectors verified this process during the receipt of such a concern by Speakout during the inspection and through conversation with cognizant personnel an'd review of documentation.
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Initial receipt also includes the classification of concerns into five classes; class one represents a nuclear safety concern.
The inspectors reviewed the files to determine if the appropriate class had been assigned to the concern and that the required independent evaluation was performed by the manager of Speakout.
The inspectors determined that the licensee appropriately classified the concerns received and "performed the required independent review, including a
monthly report to the Vice President for Nuclear Assurance which delineates the classification of concerns received.
The inspectors verified that there was an Investigation Plan Format Guideline completed in the files for the assigned investigator to perform followup.
The investigation plans were approved by the Speakout Supervisor or Manager as appropriate.
The inspectors verified that class one concerns are reviewed in a
timely manner commensurate with the safety significance of the concern.
The inspectors verified that the interviewers received the required training in interviewing techniques which included role-playing and video taping of the role-playing exercise.
The inspectors verified that the interview process was adequate for gathering the appropriate information, clarifying issues and re-stating Speakout's understanding of the individual's concern.
The inspectors verified that for the files reviewed the depth of investigation and followup was adequate for the concerns.
The inspectors reviewed procedures, interview notes with concerned individuals and applicable documentation associated with the files and determined that appropriate actions were taken.
The inspectors verified that following identification of a substantiated significant concern, the concern report was reviewed by gA for assessment of the adequacy of the determination of the root cause, generic implications and corrective action.
The inspectors verified that the Speakout Review Committee (SRC)
reviewed all class one concerns for closure.
This was evidenced by a
form with the appropriate signatures and notes attached when the SRC determined additional actions were required.
The recommendations/corrective actions approved by the appropriate Vice
President are entered in a tracking log and are tracked unti 1 reported complete.
The inspectors verified that concerns that were older than 30'days from initial receipt were appropriately acted upon by notifying the concernee of the status of the concern.
Accordingly, there were also letters to concernees for matters than were older than 60 days, etc.
The inspectors verified that there were closure letters to concerned individuals, when they were not anonymous, which contained the results of Speakout's investi gation and verified that the letters to the concernees were reviewed by the SRC, if the concern was a class one.
The inspectors also noted that the letters to the concernees invited them to contact Speakout if they had any questions or comments regarding the response.
There were cases where the information contained in the files could not be completely disclosed to the concerned individuals due to the. propriety or sensitivity of the information, e.g.,
a fitness for duty concern.
. The inspectors concluded that the licensee adequately receives and processes employee concerns.
4.
Allegations RII-90-A-00066 a.
Region II received an allegation regarding the adequacy of the
'1icensee's Speakout Program in general.
Since the information received did not provide any specific information or names of individuals who allegedly were reluctant to utilize the licensee's program for voicing concerns, the inspectors'eview of the licensee's program for receiving and processing employee concerns was inspected and determined to be adequate.
This concern was not substantiated and is considered closed.
b.
Region II received an allegation, that several unnamed individuals voiced concerns to the Speakout Program and their concerns were not adequately addressed.
The inspectors reviewed the 'icensee's Speakout files, had discussions with cognizant personnel and found no evidence to substantiate the concerns.
The inspectors verified that all closed cases included a letter to the concerned individual stating the results of the licensee's inv'estigation which included a statement that if the concerned individual had any questions or desired additional information to contact Speakout.
The inspectors did find examples where concerned individuals were provided closure letters that did not detail certain information due to the sensitivity of the information or due to the privacy of named individuals.
However, the inspectors'eview of these files
indicated that the licensee had performed a thorough review of the matter.
This allegation could not be substantiated in that, even in cases where the licensee could not provide a detailed response, nonetheless a
response was provided and there was no evidence the individuals receiving such a response made an attempt to re-contact the Speakout Program and request additional information or clarification of their response.
This allegation is considered closed.
5.
Observations Identified in NRC Inspection Report 50-250/89-13 and 50-251/89-13 NRC Inspection Report 50-250/89-13 and 50-251/89-13 contained five observations concerning the licensee's Employee Concerns Reporting System (ECRS).
Briefly, these observations were:
No written procedures exist for handling wrongdoing allegations.
No dedicated resources for ECRS.
No specified training requirements for individuals with ECRS responsibilities.
No provisions for exit interviews.
No mention of ECRS in GET.
The inspectors found that these areas are adequately addressed in the Speakout program, and these observations are closed.
6.
Exit Interview The inspection scope and results were summarized on June 8, 1990, with the licensee.
The inspectors described the areas inspected and discussed in detail the inspection results.
Proprietary information is not contained in this repor tI