IR 05000250/1993023
| ML17352A294 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point, Saint Lucie  |
| Issue date: | 11/05/1993 |
| From: | Merschoff E, Sinkule M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17352A293 | List: |
| References | |
| 50-250-93-23, 50-251-93-23, 50-335-93-21, 50-389-93-21, NUDOCS 9311160055 | |
| Download: ML17352A294 (30) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 303234199 Report Nos.:
50-250/93-23, 50-251/93-23, 50-335/93-21, 50-389/93-21 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 License Nos.:
DPR-31, DPR-41, DPR-67, NPF-16 Docket Nos.:
50-250, 50-251, 50-335, and 50-389 Facility Names:
Turkey Point 3 and 4, St. Lucie 1 and
Inspector:
Inspection Conducted:
September 21 - October 15, 1993 VkV~K~
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s-Reactor Projects Branch
Division of Reactor Projects Accompanying Personnel:
S. Elrod, Senior Resident Inspector, St. Lucie T. Johnson, Senior Resident Inspector, Turkey Point E. Herschoff, Director, Division of Reactor Projects R. Schin, Project Engineer L. Trocine, Residen Inspector, Turkey Point Approved by:
ersc o
,
grec Division of Reactor Pr 'ts (is V3 a e 1gne Scope:
SUNNRY This special announced inspection was conducted at the St. Lucie and Turkey Point nuclear plants and at the FPL corporate offices in Juno Beach, Florida, to evaluate the effectiveness of the licensee's Nuclear Safety Speakout Program in addressing safety concerns.
Results:
The team concluded that the licensee's Nuclear Safety Speakout Program was effective in handling and resolving employee safety concerns.
Violations or Deviations were not identified.
9311160055 931105 PDR ADOCK 05000250 Q
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Persons Contacted REPORT DETAILS R.
J.
J.
J.
J.
L.
T.
Acosta, Director, Nuclear Safety Assessment Gallagher, Speakout Investigator, Juno Beach Geiger, Vice President, Nuclear Assurance Goldberg, President, Nuclear Division Labarraque, Speakout Supervisor, Turkey Point Pearce, Plant Manager, Turkey Point Knippe1, Speakout Investigator, St. Lucie Other licensee employees contacted included engineers, technicians, operators, mechanics, and office personnel.
NRC Personnel S.
T.
E.
R.
M.
L.
Elrod, Senior Resident Inspector, St. Lucie Johnson, Senior Resident Inspector, Turkey Point Merschoff, Director, Division of Reactor Projects Schin, Project Engineer Sinkule, Chief, Reactor Projects Branch
Trocine, Resident Inspector, Turkey Point
- Attended exit interview
2.
Employee Concerns Program Survey (TI 2500/028)
The inspectors completed a survey of the St. Lucie and Turkey Point employee concerns program per TI 2500/028.
The objective of the survey was to determine the characteristics of employee concerns programs that licensees have implemented to provide employees, who wish to raise safety issues, an alternate path from their supervisor of normal line management to express these concerns and to encourage people to come forward with their concerns without rear of retribution.
The results of the St. Lucie and Turkey Point surveys are in Attachments 1 and 2.
The survey results confirmed that St. Lucie and Turkey Point have a well established employee concerns program, called the Speakout Program.
Speakout Program Policy and Procedures (92720)
The inspectors reviewed FPL Nuclear Policy NP-800, Nuclear Safety Speakout Program, dated December 30, 1990; FPL Nuclear Division Instruction NSS-1, Nuclear Safety Speakout Program, Rev.
2, dated January 4,
1993; FPL Juno Beach Interdepartmental Procedure IP-802, Nuclear Safety Speakout Program, dated March 30, 1993; St. Lucie Administrative Procedure 0010519, Nuclear Safety Speakout Program, Rev.
9, dated June 18, 1993; and Turkey Point Administrative Procedure 0-ADM-002, Nuclear Safety Speakout Program, dated February 25, 1993.
The policy encouraged employees to share any concerns with their supervisors.
Employees not wishing to do that were advised to bring their concerns to the Speakout Program or the NRC.
The policy provided for anonymity and confidentiality of employees who participated in
Speakout and encouraged both current and departing employees to participate.
The procedures were comprehensive and detailed, including 82 pages of instructions and forms.
The procedures clearly addressed:
responsibilities and lines of communication for administering the Speakout Program; who is covered by the program; confidentiality and protection against reprisals; safeguards in the program to ensure that identified concerns are tracked, investigated, evaluated, and effective action is taken; handling concerns involving wrongdoing; followup with concerned individuals; and advertisement of the program to employees and contractors.
Also, the inspectors verified that personnel administering the program were well qualified and adequate resources had been committed to ensure program implementation.
The inspectors made two observations with regard to the Speakout Program procedures:
a ~
b.
The procedures did not describe well how to handle concerns involving Speakout employees or supervisors, the Director of Nuclear Safety Assessment, a Site Vice President, or the Vice President of Nuclear Assurance.
By procedure, if one of these persons were the subject of an employee concern, that person would still be in the Speakout review process for that concern.
The procedures did state that investigations involving Speakout employees would be conducted by a qualified individual not directly associated with or reporting to anyone at FPL.
During subsequent review of Speakout files, the inspectors noted two instances where employee concerns involved persons in the Speakout review/investigation process.
Both instances were adequately documented and reasonably handled and dispositioned.
However, in both instances, the actual Speakout review/investigation process differed from that described in the Speakout procedures.
The procedures stated that Juno Beach safety concerns would be reviewed by the Turkey Point Speakout Review Committee.
The inspectors found that, in practice, safety concerns related to Turkey Point were reviewed by the Turkey Point Speakout Review Committee and safety concerns related to St. Lucie were reviewed by the St. Lucie Speakout Review Committee.
The inspectors considered this practice to be appropriate.
The team concluded that the Speakout Program policy and procedures were generally comprehensive and detailed.
Employee Interviews (92720)
The inspectors interviewed FPL Senior Managers, Speakout Program supervisors and investigators, and 50 other FPL employees, including 20 at St. Lucie, 20 at Turkey Point, and 10 at Juno Beach to assess their awareness and perception of the effectiveness of the Speakout Program.
The 50 other employees included representatives from various levels (i.e. technicians and supervisors)
in various disciplines, including:
engineers; operators; maintenance planning; electrical, mechanical, and
t'
instrumentation and control maintenance; quality assurance; health physics; and chemistry.
The interviews with FPL Senior Managers indicated that they supported the Speakout Program and were aware of its activities.
The interviews with Speakout supervisors and investigators indicated that they were well qualified and were confident of the effectiveness of their program in receiving, assessing, investigating, and resolving safety concerns.
The other (non-Speakout)
FPL employees were all aware of the Speakout Program.
All of those interviewed said that they would report safety concerns.
Five (lOX) said they or someone they knew felt they had been intimidated, harassed, or discriminated against by management for raising safety concerns at the FPL nuclear plants.
Two of the five said the situation they knew of had been satisfactorily resolved one case by Speakout and one case by FPL Senior Management.
One of the five was referring to a case that was under review by the Department of Labor.
One of the five said that their management was at times overbearing, unreceptive, and used offensive language; but that did not deter the individual from reporting safety concerns.
One of the five said that two of their supervisors were overbearing and unreceptive, and that person would turn in safety concerns to other supervisors.
All but one or two said they would go to their management first with a safety concern, and felt that management would generally resolve their concern.
Most said they would go to Speakout second with a concern, if they were not satisfied with management action.
Several said they would go to NRC resident inspectors second with a nuclear safety concern because Speakout was too slow.
Twenty percent of those interviewed had used the Speakout Program, and all but one was satisfied with the Speakout resolution of all of their concerns.
All were confident that Speakout would protect their identity, but some were concerned that if they turned in a specific issue it could be tracked to them.
St. Lucie personnel said they could contact Speakout by going to the Speakout office on site or by telephone.
About 90X of the St. Lucie personnel were not aware that Speakout forms were available in the plant, at bulletin boards.
The team concluded that the FPL employees perceived the Speakout Program to be effective.
Speakout Program Files (92720)
The inspectors reviewed 20 Speakout Program Concern files, including some at St. Lucie, Turkey Point, and Juno Beach.
The quality of the Speakout reviews and investigations was good and each was adequately documented.
Names and addresses of individuals expressing the concerns to Speakout were not in the files, but were kept in a separate locked storage to protect the individuals'dentitie The team concluded the Speakout Program files were well handled.
Exit interview The inspection scope and findings were summarized on September 24, 1994, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection results.
Proprietary material is not contained in this report.
Dissenting comments were not received from the licensee.
Violations or Deviations were not identifie e ATTACHNENT 1 ST UCI MP OYE CONC RNS PROG SURVEY T
500 028 PLANT NAKE:
St. Lucie, Units 1 and
LICENSEE:
Florida Power and Light DOCKET NOS:
50-335 and 50-389 A.
PROGRAM:
1.
Does the licensee have an employee concerns program (ECP)?
Yes The Speakout Program.
2.
Has the NRC inspected the program?
Yes.
NRC Inspection Report No. 50-250,251/90-20 focused on Turkey Point but addressed St. Lucie also.
B.
SCOPE:
1.
Is it for:
a.
Technical Issues?
Yes.
b.
Administrative Issues?
Yes.
c.
Personnel Issues?
Yes.
2.
3.
Does it cover safety as well as non-safety issues?
Yes For non-safety issues, the cognizant department performs the investigation; however, Speakout handles all of the correspondence and interfacing with the concernee.
Is it designed for:
a.
Nuclear Safety?
Yes.
b.
Personal Safety?
Ye c.
Personnel Issues Including Union Grievances?
No It will handle personnel issues but will not interfere with union grievances.
4.
Does the program apply to all licensee employees?
Yes.
5.
Contractors?
Yes.
6.
Does the licensee require its contractors and their subcontractors to have a similar program?
No The licensee requires them to exit through the Florida Power and Light Speakout Program.
7.
Does the licensee conduct an exit interview upon terminating employees asking if they have any safety concerns?
Yes.
1.
What is the title of the person in charge?
2.
3.
St. Lucie Speakout Supervisor.
Who do they report to?
Director, Nuclear Safety Assessment.
Are they independent of line management?
Yes.
4, Does the ECP use third party consultants?
Yes, not routinely but only if they decide they need outside assistance.
5.
How is a concern about a manager or vice president followed up?
The site Speakout Supervisor notifies the corporate Director of Nuclear Safety Assessment, who in turn notifies the corporate Vice President of Nuclear Assurance.
They then select a qualified individual to perform the investigatio D.
RESOURCES:
1.
What is the size of the staff devoted to this program?
Three staff members at the site (supervisor, investigator, and interviewer), with a corporate staff investigator available to help.
2.
What are ECP staff qualifications (technical training, interviewing training, investigator training, other)?
Technical training Interviewing training Investigator training Human Performance Enhancement System (HPES) training E.
REFERRALS:
1.
Who has followup on concerns (ECP staff, line management, other)?
The ECP staff investigates safety-related concerns, and assigns most others to line management for investigation.
The site Speakout Review Committee (corporate Director of Nuclear Safety plus experienced site personnel from management, licensing, and nuclear assurance)
reviews and approves all safe'ty-related investigation reports and recommendations.
The Director of Nuclear Safety Assessment forwards the SRC-approved recommendations to the Site Vice President for final approval.
Speakout tracks the recommendations until a written response is received from the appropriate organization regarding resolution.
F.
CONFIDENTIALITY:
l.
Are the reports confidential?
Yes.
2.
Who is the identity of the alleger made known to (senior management, ECP staff, line management, other)?
The identity of the alleger is made known to the ECP staff only on a need to know basis.
The investigator file does not include the name of the concernee.
3.
Can employees be:
a.
Anonymous?
Ye e b.
Report by phone?
Yes.
G.
FEEDBACK:
l.
Is feedback given to the alleger upon completion of the followup?
Yes - A letter is sent to the alleger's home address providing a summary of the concern resolution.
2.
Does program reward good ideas?
No.
3.
Who, or at what level, makes the final decision of resolution?
The Speakout Review Committee, with Site Vice President approval (see E.l)
4.
Are the resolutions of anonymous concerns disseminated?
No.
5.
Are the resolutions of valid concerns publicized (newsletter, bulletin board, all hands meeting, other)?
No.
H.
EFFECTIVENESS:
How does the licensee measure the effectiveness of the program?
Effectiveness of the program is measured via monthly performance reports with indicators, and occasional independent surveys conducted by a contractor.
There is a monthly meeting with the Site Vice President and a semi-annual presentation to the Company Nuclear Review Board.
2.
Are concerns:
a.
Trended?
Yes.
b.
Used?
Ye.
In the last three years, how many concerns were raisedT 524 total, including safety-related and non-safety.
Of the concerns raised, how many were closed'87
"
What percentage were substantiatedT 45X 4.
How are followup techniques used to measure effectiveness (random surveys, interviews, other)T Post-outage surveys, occasional surveys by an independent contractor.
5.
How frequently are internal audits of the ECP. conducted and by whom'o regular schedule, but there have been two to date - one self-assessment and one audit.
I.
ADMINISTRATION/TRAINING:
l.
Is the ECP prescribed by a procedures Yes 2.
How are employees, as well as contractors, made aware of this program (training, newsletters, bulletin boards, other)V Employees are made aware of the Speakout Program via the following avenues:
Training General Employee Training Newsletters Television Instant News Bulletin Boards
.
Staff Plant Tours Speakout Appreciation Items
S (Including characteristics which make the program especially effective, if any.)
There is high level management support for the Speakout Program and involvement with the implementation of recommendations.
The ECP staff is respected by licensee personne ATTACHMENT 2 TURKEY POINT EMPLOYEE CONCERNS PROGRAM SURVEY T
2500 028 PLANT NAME:
Turkey Point, Units 3 and
LICENSEE:
Florida Power and Light DOCKET NOS:
50-250 and 50-251 A.
B.
PROGRAM:
1.
Does the licensee have an employee concerns program (ECP)?
Yes The Speakout Program.
2.
Has the NRC inspected the program?
Yes.
(Refer to the special announced inspection documented in NRC Inspection Report No. 50-250,251/90-20.)
SCOPE:
1.
Is it for:
a.
Technical Issues?
Yes.
b.
Administrative Issues?
Yes.
c.
Personnel Issues?
Yes.
2.
3.
Does it cover safety as well as non-safety issues?
Yes For non-safety issues, the cognizant department performs the investigation; however, Speakout handles all of the correspondence and interfacing with the concernee.
Is it designed for:
a.
Nuclear Safety?
Yes.
b.
Personal Safety?
Ye II
c.
Personnel Issues Including Union Grievances?
No - It is designed for personnel issues with the exception of union grievances.
4.
Does the program apply to all licensee employees?
Yes.
5.
Contractors?
Yes.
~
c.
6.
Does the licensee require its contractors and their subcontractors to have a similar program?
No - The licensee requires them to exit through the Florida Power and Light Speakout Program.
7.
Does the licensee conduct an exit interview upon terminating employees asking if they have any safety concerns?
Yes.
INDEPENDENCE:
1.
What is the title of the person in charge?
Turkey Point Speakout Supervisor.
2.
3.
Who do they report to?
Director, Nuclear Safety Assessment.
Are they independent of line management?
Yes.
4.
5.
Does the ECP use third party consultants?
Yes, when necessary to augment the work force.
The licensee has Florida Power and Light staff.
How is a concern about a manager or vice president followed up?
Speakout notifies the Director of Nuclear Assur ance, and the Director of Nuclear Assurance notifies the Vice President of Nuclear Assurance.
They then select a qualified individual to perform the investigatio D.
RESOURCES:
1.
What is the size of the staff devoted to this program?
There are three staff members on site devoted to this program, with a corporate staff investigator available to help.
2.
What are ECP staff qualifications (technical training, interviewing training, investigator training, other)?
Technical training Interviewing training Investigator training Human Performance Enhancement System (HPES) training E.
REFERRALS:
F.
1.
Who has followup on concerns (ECP staff, lin'e management, other)?
The ECP staff investigates safety-related concerns, and assigns most others to line management for investigation.
The site Speakout Review Committee (corporate Director of Nuclear Safety plus experienced site personnel from management, licensing, and nuclear assurance)
reviews and approves all safety-related investigation reports and recommendations.
The Director of Nuclear Safety Assessment forwards the SRC-approved recommendations to the Site Vice President for final approval.
Speakout tracks the recommendations until a written response is received from the appropriate, organization regarding resolution.
CONFIDENTIALITY:
Are the reports confidential?
Yes.
2.
Who is the identity of the alleger made known to (senior management, ECP staff, line management, other)?
The identity of the alleger is made known to the ECP staff only on a need to know basis.
The investigator file does not include the name of the concernee.
3.
Can employees be:
a.
Anonymous?
Ye b.
Report by phone?
Yes.
G.
FEEDBACK:
1.
Is feedback given to the alleger upon completion of the followup?
Yes - A letter is sent to the alleger's home address providing a
summary of the concern resolution.
2.
Does program reward good ideas?
No.
3.
Who, or at what level, makes the final decision of resolution?
The Speakout Review Committee, with Site Vice President approval (see E. I)
4.
Are the resolutions of anonymous concerns disseminated?
No.
5.
Are the resolutions of valid concerns publicized (newsletter, bulletin board, all hands meeting, other)?
No.
H.
EFFECTIVENESS:
How does the licensee measure the effectiveness of the program?
Effectiveness of the program is measured via independent surveys conducted by a contractor and monthly performance reports with indicators, 2.
Are concerns:
a.
Trended?
Yes.
b.
Used?
Yes.
3.
In the last three years, how many concerns were raised?
168 nuclear safety-related and quality-related (1195 total)
Of the concerns raised, how many were closed?
163 nuclear safety-related and quality-related (1178 total)
What percentage were substantiated?
45K nuclear safety-related and quality-related (36X total)
4.
How are followup techniques used to measure effectiveness (random surveys, interviews, other)?
Post-outage surveys, occasional surveys by an independent contractor.
5.
How frequently are internal audits of the ECP conducted and by whom?
FPL guality Manager performs internal audits of the ECP at the discretion of the guality Assurance Vice President.
The NRC also performs random inspections of this program.
t I.
ADNINISTRATION?TRAINING:
l.
Is the ECP prescribed by a procedure?
Yes 2.
How are employees, as well as contractors, made aware of this program (training, newsletters, bulletin boards, other)?
Employees are made aware of the Speakout Program via the following avenues:
Training - General Employee Training Newsletters Television Instant News Bulletin Boards Staff Plant Tours Speakout Appreciation Items CI ADDITIONAL COSINE S:
(Including characteristics which make the program especially effective, if any.)
t There is one central focal point to resolve any type of employee/contractor concer The identity of the concernee is kept confidential.
There is high level management support and involvement with the implementation of recommendations.
The Speakout Program is independent of line management.
The Speakout Program provides feedback to the concernee.
The ECP staff is respected by licensee personnel.