IR 05000255/2014009
| ML14064A569 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/06/2014 |
| From: | Boland A Division Reactor Projects III |
| To: | Vitale A Entergy Nuclear Operations |
| References | |
| IR-14-009 | |
| Download: ML14064A569 (23) | |
Text
UNITED STATES rch 6, 2014
SUBJECT:
PALISADES NUCLEAR PLANT - PROBLEM IDENTIFICATION AND RESOLUTION FOCUSED INSPECTION (REPORT 05000255/2014009)
Dear Mr. Vitale:
On February 26, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a limited scope Problem Identification and Resolution (PI&R) inspection focused on assessment of your completion, and the effectiveness, of corrective actions to address NRC-identified deficiencies and Safety Conscious Work Environment (SCWE) aspects associated with two Greater-than-Green findings identified in 2011 at your Palisades Nuclear Plant. The enclosed report documents the results of this inspection, which the NRC discussed on February 26, 2014, with you and other members of your staff.
In September 2012, the NRC conducted a Supplemental Inspection in accordance with Inspection Procedure (IP) 95002 (NRC Inspection Report 05000255/2012011), for two Greater-than-Green findings identified in 2011. As documented in the inspection report, Safety Culture deficiencies, in part, contributed to these findings. In 2013, the NRC observed that although your efforts were generally on track with your Recovery Plan, the NRC received several concerns related to SCWE/Safety Culture. Collectively, these issues prompted questions into progress made in the plants Recovery Plan regarding Safety Culture. Therefore, the NRC performed this limited scope PI&R inspection to continue assessment of Safety Culture at Palisades, focusing on SCWE. This inspection focused on departments where NRC observations indicated a potential negative trend in SCWE. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006. The NRCs Regulatory Issue Summary 2005-18, Guidance for Establishing and Maintaining a Safety Conscious Work Environment, dated August 25, 2005, provides guidance for establishing and maintaining a SCWE at commercial nuclear plants.
The NRC inspectors observed that implementation of the SCWE program and overall performance related to identifying, evaluating, and resolving problems related to SCWE within the Mechanical Maintenance Work Group and Chemistry Department was acceptable. The NRC identified a chilled work environment in the Security Department. The NRC concluded that staff within the Security Department perceived that: (1) recent actions to terminate the employment of two supervisors was in retaliation for their raised concerns; (2) the Corrective Action Program (CAP) was ineffective at addressing equipment and other concerns raised by Security staff; (3) the Security management was unresponsive to employees concerns; and (4) the Employee Concerns Program (ECP) could not be relied upon to maintain employee confidentiality.
The NRC inspectors concluded that the Palisades management team did not recognize the extent of SCWE related concerns within the Security Department until they discussed the results of this inspection with you and your staff. In response to these issues, the NRC observed that actions have been developed and are being implemented to address these concerns. Specifically, you have instituted plans to improve communications and monitoring tools, as well as introduced an Ombudsman within the Security organization to address the identified weaknesses in the SCWE. Based on these actions, the NRC will maintain its oversight of the SCWE at Palisades through normal inspection activities. Through our baseline inspection effort, oversight will include a focus on the effective and timely completion of the corrective actions being implemented in response to the SCWE concerns identified in this report and continued improvement in the SCWE at Palisades. In addition, the NRC will review, as part of the May 2014 PI&R inspection, the effectiveness of actions taken to address the SCWE issues within the Security Department and in any additional Palisades identified groups with SCWE concerns; and any additional actions or changes in actions planned and taken to address the SCWE issues within the Security Department. Following the PI&R inspection, the NRC will determine if additional oversight with regards to Safety Culture is warranted.
The NRC will discuss the results of this inspection and the Safety Culture during the upcoming End-Of-Cycle assessment public meeting. The NRC requests that you be prepared to discuss:
(1) the root cause of the chilled work environment within the Security Department, (2) your progress in addressing the SCWE concerns within the Security Department and (3) any additional actions planned and/or implemented to address the SCWE at Palisades. The NRC requested, and you agreed, to inform the employees of the Security Department, within 30 days of the date of your receipt of this inspection report, of: (1) the issuance, conclusions and content of this inspection report and (2) your planned actions to address the SCWE issues within the Security Department. In accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Anne T. Boland, Director Division of Reactor Projects Docket No. 50-255 License No. DPR-20
Enclosures:
Inspection Report 05000255/2014009 w/Attachments:
1. Supplemental Information 2. Palisades Security SCWE Action Plan
REGION III==
Docket No: 50-255 License No: DPR-20 Report No: 05000255/2014009 Licensee: Entergy Nuclear Operations, Inc.
Facility: Palisades Nuclear Plant Location: Covert, MI Dates: December 9, 2013 through February 26, 2014 Inspectors: G. Hansen, Physical Security Inspector, DRS M. Keefe, Human Factors Specialist, NRR Approved by: Anne T. Boland, Director Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
Inspection Report 05000255/2014009; 12/09/2013 - 02/26/2014; Palisades Nuclear Plant,
Problem Identification and Resolution (PI&R) Focused Inspection.
The NRC conducted a limited scope PI&R inspection focused on an assessment of the SCWE at Palisades. This inspection was led by SCWE specialists from Region III and the Office of Nuclear Reactor Regulation (NRR) and focused on those departments in which previous observations and other information indicated a potential negative trend in the SCWE area.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
The NRCs Regulatory Issue Summary 2005-18, Guidance for Establishing and Maintaining a Safety Conscious Work Environment, dated August 25, 2005, provides guidance for establishing and maintaining a SCWE at commercial nuclear plants.
Safety Conscious Work Environment On the basis of the samples selected for review, the inspectors concluded that although there were no significant SCWE related issues in the Mechanical Maintenance Work Group and Chemistry Department, a chilled work environment was present within the Security Department.
In particular, the inspectors concluded that Security staff perceived that: (1) recent actions to terminate the employment of two supervisors was in retaliation for their raised concerns; (2) the Corrective Action Program (CAP) was ineffective at addressing equipment and other concerns raised by Security staff; (3) the Security management was unresponsive to employees concerns; and (4) the Employee Concerns Program (ECP) could not be relied upon to maintain employee confidentiality.
To address the issues identified through this inspection, the licensee developed the Palisades Security SCWE Action Plan attached as Attachment 2 to this report.
NRC-Identified
and Self-Revealed Findings No items of significance were identified.
Licensee-Identified Violations
No violations of significance were identified.
REPORT DETAILS
.1 Assessment of Safety Conscious Work Environment (SCWE)
Background In September 2012, the NRC conducted a Supplemental Inspection in accordance with IP 95002 (NRC Inspection Report 05000255/2012011) for two Greater-than-Green findings identified in 2011 at Palisades. As documented in the inspection report, Safety Culture deficiencies, in part, contributed to these findings. The licensee continued efforts in their Recovery Plan to address concerns stemming from the Yellow finding in 2011. While the licensee was generally on track with their plan, recent issues brought to the NRCs attention in 2013 had led to some questions on progress in addressing specific aspects of the sites Safety Culture, namely, the SCWE. In general, Safety Culture continued on a stable or improving trend for most departments, but staff concerns within the Mechanical Maintenance Work Group and Security Department had identified weaknesses that needed to be addressed. In Calendar Year (CY) 2013, the number of concerns raised to the NRC from onsite sources increased considerably over the number of concerns received in CY 2012. A majority of these concerns included at least some Safety Culture or SCWE aspects, and some directly alleged a chilled work environment.
As a result, a limited scope PI&R inspection was conducted that focused on an assessment of the SCWE at Palisades. This inspection was led by SCWE specialists from Region III and the Office of NRR and focused on those departments in which previous observations and other information indicated a potential negative trend in the SCWE area.
a. Inspection Scope
The inspectors assessed the licensees SCWE through the review of the ECP implementing procedures, discussions with the manager of the ECP, interviews with personnel from various departments, and review of condition reports (CRs). The review was done to ensure there was a free flow of information and to determine if there was a reluctance to raise nuclear safety concerns.
The inspectors performed a focused inspection to independently evaluate the SCWE that existed within the Mechanical Maintenance Work Group, Chemistry Department, and Security Department at Palisades. The inspection included focus groups with personnel only assigned to the selected departments. In addition, the focus groups did not combine supervisors with craft personnel. The inspectors conducted focus groups with Non-Supervisory personnel from each of the identified groups/departments as follows: 10 participants from Mechanical Maintenance, 8 participants from Chemistry, and 29 participants from Security. The inspectors also conducted focus groups with a total of 4 first line supervisors from Mechanical Maintenance
- (3) and Chemistry (1)combined focus group; and 9 first line supervisors from Security. Additionally, the inspectors interviewed the ECP Manager, Maintenance Manager, Security Manager, Chemistry Manager, General Manager of Plant Operations (GMPO) and the Site Vice-President.
Other activities performed included a review of the licensees ECP, including implementing procedures, and a sample of the ECP records (SCWE related concerns);the sites CAP, including implementing procedures and selected samples of CRs; and a review of site Safety Culture and SCWE surveys and assessments completed after the 2012 IP 95002 inspection conducted by the NRC during September 2012 (NRC Inspection Report 05000255/2012011).
b. Assessment The inspectors concluded that the ECP was accessible to employees and effectively resolved employee issues. The site was performing periodic surveys in different organizations using anonymous computer questions to gauge staff attitudes. Managers took actions to address results that indicated a potential for improvement. The inspection activity verified that the licensee implemented programs designed to promote a SCWE in which individuals can raise issues or concerns without fear of retaliation. All participants in the focus groups conducted were aware of the definition of SCWE and the processes available for raising issues or concerns at Palisades, including verbally through supervisory or management staff, use of the CAP, use of the ECP, or through contact with the NRC. Results of the focus groups identified a positive SCWE in the Mechanical Maintenance Work Group and Chemistry Department; in that participants expressed a willingness to raise issues or concerns without fear of retaliation (specific details are provided in the observation section below). The results of the focus groups conducted for the Security Department revealed a chilled work environment in that all the Non-Supervisory Security Officer participants
- (29) stated they were not comfortable raising issues or concerns without fear of retaliation.
In summary, based on inspection interviews and insights obtained from Safety Culture and other relevant assessments, the conditions at the site were conducive to a SCWE within the Mechanical Maintenance Work Group and Chemistry Department. However, a chilled work environment was identified within the Security Department.
c. Observations Mechanical Maintenance The inspectors identified that the members of the Mechanical Maintenance Work Group (both Supervisors and Non-Supervisors) were familiar with the sites focus on promoting and encouraging a positive SCWE, and they expressed that the Site Vice-President specifically reinforced his commitment to a positive SCWE through his discussions at All Hands Meetings. Additionally, focus group participants stated this focus on promoting a positive SCWE was reinforced through discussions at daily briefs and through site training. The inspectors observed some improvements in Safety Culture within the Mechanical Maintenance Work Group as a result of the licensees Recovery Plan. However, Non-Supervisors in Mechanical Maintenance stated this theme was not reinforced by the actions and communications of the Mechanical Maintenance Supervisors and the Maintenance Department Manager. Despite the disconnect in communications from senior management to the workers (an issue previously identified during the sites most recent IP 95002 inspection), the inspectors concluded that the workers were willing to raise issues and concerns without fear of retaliation either verbally to their supervisors; through the use of the CAP; or through the ECP.
A specific area of concern identified by Mechanical Maintenance Non-Supervisors was the perceived emphasis on production over safety demonstrated by the Outage Control Center (OCC) and Work Planning. Individuals identified instances where work orders did not always comply with site procedures, and when individuals questioned the work orders, they would receive feedback that they were wrong and they should follow the procedures in the work orders. Senior workers (more experienced) stated they were comfortable stopping work and questioning safety concerns, including the errors in work orders, and they would not continue work until the issue was resolved to ensure compliance with procedures. However, less experienced workers stated while they were comfortable raising issues and concerns, they may lack the knowledge required to identify work orders that failed to follow site procedures, which could result in performing maintenance activities that are not in compliance with site procedures.
Chemistry The inspectors identified that both Supervisors and Non-Supervisors within the Chemistry Department were familiar with the sites focus on promoting and encouraging a positive SCWE through the Site Vice-Presidents discussions at All Hands Meetings; and they stated this message was reinforced by the Chemistry Department Manager and Supervisors during discussions at daily briefs and through site training. Non-Supervisors specifically identified the Department Manager and Supervisors as being actively engaged and communicating with the staff. Members of the department stated the site promoted raising issues and concerns without fear of retaliation either verbally, through the use of the CAP, or through the ECP. Additionally, members of the Chemistry Department stated that their use of the CAP was effective in resolving issues and concerns. The NRC inspectors observed improvement in Safety Culture within the Chemistry Department as a result of the licensees Recovery Plan.
Security Based on the feedback received during the initial Security Department focus group conducted with 12 Non-Supervisory Security force members, the NRC inspectors conducted an additional focus group to expand the number of participants and the response database in order to effectively formulate their assessment of the SCWE within the Palisades Security Department. The inclusion of the second focus group resulted in the participation of an additional 17 Non-Supervisory Security force members for a total of 29 Non-Supervisory Security force members representing a cross section of all four Security shifts at the Palisades Nuclear Plant. The inspectors noted that the focus group response to the inspectors questions was not dominated by one or two individuals; it was the collective view of the focus group.
The inspectors identified that the Non-Supervisory members of the Security Department were familiar with the definition of SCWE and were aware of the programs available for raising issues or concerns, i.e., CAP, ECP, and notification of the NRC. However, the Security Non-Supervisors expressed reservations about raising issues or concerns to personnel in the position of Security Shift Supervisors (SSS) and above for fear that they would be the subject of retaliation. Additionally, they were not comfortable using the ECP in that they felt it did not maintain the confidentiality of the individuals identity upon raising an issue or concern through the ECP process.
Individuals stated that unless an issue or concern was associated with a significant nuclear safety issue or could result in a potential injury to personnel, they would not raise the issue or concern for fear of retaliation. Individuals highlighted the fact that in the past they would use the CAP to document issues or concerns, but had recently begun doing so anonymously and, in the future, would be hesitant to raise issues or concerns through the CAP.
Non-Supervisory personnel expressed a lack of trust, in department Supervisors and the Security Department Manager, specifically stating the Security Manager did not support them or advocate for them and was not receptive to their raising concerns. Additionally, the Security Officers stated when they raised issues or concerns with Security Operations Supervisors (SOSs) and above, they received responses that demonstrated a lack of support for identifying issues or concerns and created a hostile work environment. Individuals highlighted the fact that two supervisors, who they trusted and felt were proactive in raising issues and concerns on their behalf, recently had their employment terminated through the sites Human Capital Management (HCM) process.
The termination of these two supervisors was perceived by Non-Supervisory Security personnel as retaliation against the supervisors for raising issues and concerns, and their termination had contributed to reluctance on the part of Security members (Non-Supervisory) to raise issues or concerns for fear of retaliation. Individuals specifically stated they feared retaliation if they raised issues or concerns and that there was a chilled work environment within the Security Department.
Non-Supervisors within the Security Department stated they had limited interaction with Security Management staff unless they were being disciplined. Individuals stated the Security Manager did conduct quarterly meetings with the Security staff which he stated he was required to do by Senior Site Management as a performance improvement requirement. However, despite having these meetings, individuals expressed there was a lack of information sharing by Security management staff and stated personnel within the Security Department in the positions of SOSs and above did not care about the issues or concerns identified by the Security Officers.
Participants in the SSS focus group were also familiar with the definition of SCWE, and were aware of the programs available for raising issues or concerns. They were comfortable raising issues or concerns without fear of retaliation and felt the site promoted and encouraged raising concerns.
The SSSs stated communication and interaction from the Security Manager and Security Superintendent was an area that needed improvement. One of the corrective actions implemented to address Safety Culture issues within the Security Department was a requirement for the Security Manager to have routine meetings with the Security crews.
The NRC inspectors interviews revealed that the meetings were started, but cancelled without an evaluation to determine if the meeting purpose had been accomplished.
The Manager and Superintendent were not regular participants of shift briefings and the SSSs mentioned they hadnt had a meeting with the Security Manager since May 2013.
However, the SSSs stated action was taken by management when the SSSs raised concerns. The SSSs also believed the recent termination of the two SSSs as part of the HCM process had an adverse impact on the Security Department. Specifically, managements failure to effectively communicate the intent of the HCM process and how it worked created concerns among Security Officers as to the uncertainty of their employment and who could be terminated in the future.
During 2013, the departmental pulse surveys conducted by the site indicated a positive work environment within the Security Department. However, when the inspectors reviewed the survey results, very low participation was noted. From the inspectors interviews, it appeared that Security Supervisors, who believed there was a positive work environment within the Security Department, were the primary participants in the surveys due to site managements failure to encourage all members of the Security staff to participate in the survey. This lack of communication contributed to survey results that did not accurately reflect the collective view of the entire Security Department.
Security Officers (Non-Supervisors) informed the inspectors that they were not notified of the surveys, not encouraged to take the surveys, and/or not provided the survey results.
Interviews with Palisades site senior management personnel revealed they believed the lack of trust and confidence in the Security management staff was limited to a few Security Officers. They were not aware that a significant number of the Security Officers were afraid to raise issues or concerns for fear of retaliation and that there was a chilled work environment within the Security Department at the Non-Supervisory employee level.
Senior management did acknowledge communication within the Security Department, specifically between Security management and Security Officers had been identified as an area for improvement. As part of the HCM process, a new Security Manager had been selected for Palisades and Site Senior Management intended to focus on improving communication and interaction between Security management and Security Officers.
In response to the NRC inspectors observations, the licensee developed the Palisades Security SCWE Action Plan. The licensee instituted plans to improve communications and monitoring tools, as well as introduced an Ombudsman within the Security organization to address the identified weaknesses in the SCWE. The Action Plan is provided as Attachment 2 to this report.
The Action Plan was designed to address the chilled work environment in the Security Department and was structured using four success criteria:
- (1) employees are free to raise concerns,
- (2) management effectively resolves issues and otherwise effectively responds to events that challenge the work environment,
- (3) the ECP remains effective, and
- (4) management effectively detects, prevents and manages concerns of retaliation.
The Action Plan also contained multiple action items within each of the above performance success criteria. Each action item had an assigned owner and a specific completion due date.
Management Meetings
.1 Exit Meeting Summary
On February 26, 2014, the inspectors presented the inspection results to Mr. A. Vitale and other members of his staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- A. Vitale, Entergy/Site Vice-President
- A. Williams, Entergy/General Manager Plant Operations
- O. Gustafson, Entergy/Nuclear Safety Assurance Director
- B. Dotson, Entergy/Licensing Specialist
- T. Davis, Entergy/Licensing Specialist
Nuclear Regulatory Commission
LIST OF ITEMS
OPENED, CLOSED AND DISCUSSED
None Attachment 1