IR 05000259/1993043
| ML18037A672 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/05/1994 |
| From: | Brady J, Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18037A671 | List: |
| References | |
| 50-259-93-43, 50-260-93-43, 50-296-93-43, NUDOCS 9401250022 | |
| Download: ML18037A672 (16) | |
Text
AS ~EGA~
+~
~o s
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 30323-0199 Report Nos.:
50-259/93-43, 50-260/93-43 and 50-296/93-43 Licensee:
Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.:
50-259, 50-260, and 50-296 License Nos.:
DPR-33, DPR-52, and DPR-68 Facility Name:
Browns Ferry 1, 2,
and
Inspection Conducted:
November 8-10, November 22-24, and December 6-10, 1993 Lead Inspector:
/zo /~3
.
B.
ra y, Diect ng)neer ate cygne Inspectors:
W. Bearden, Project Engineer W. Little, Project Engineer Approved By:
gg, ect on
>e Divisi n f Reactor Projects a
e sgne SUMMARY Scope:
This special announced inspection was conducted in the area of licensee and contractor employee concerns programs.
The purpose of the inspection was to determine whether adequate means existed to resolve safety concerns raised by employees.
Results:
No violations or deviations were identified.
Employee concerns were being adequately resolved by the TVA Concerns Resolution Staff (CRS)
and TVA's contractors.
'management of the investigation backlog and the referral of harassment and intimidation concerns to the TVA Inspector General was adequate.
CRS oversight of the contractor programs was a strength.
An unresolved item was identified associated with failure to perform craft verification for the adequacy of containment coatings.
(Paragraph 3.b)
940>2SOO22 940X05 PDR AOOCK 050P0259 Q
"PDR
REPORT DETAILS I.
Persons contacted Licensee Employees
- H. Harding, Concerns Resolution Program Manager
- O. Zeringue, Site Vice President
- L. Jones, Concerns Resolution Site Representative
- R. Hachon, Plant Manager
- P. Salas, Site Licensing Manager
- T. Shriver, Nuclear Assurance and Licensing Manager
- R. Wells, Compliance Licensing Manager Other licensee employees contacted included engineers, technicians, and other administrative personnel.
Contractor Employees
- R. McIndoe, Bechtel Corp.
- S. Salowitz, Stone
& Webster Engineering Corp.
- G. Nelson, General Electric NRC Personnel
- J. Munday, Resident Inspector
"Attended exit interview 2.
Acronyms used throughout this report are listed in the last paragraph.
TVA Employee Concerns Program a
~
Procedural Guidance The licensee's employee concerns program was described in Nuclear Power Standard 1.2, revision 2, titled Concerns Resolution, which was implemented by Browns Ferry Site Standard Practice 1.2, revision 2, titled Concerns Resolution.
The Site Standard Practice had almost identical wording to the Nuclear Power Standard.
The standards described the two methods for resolving employee concerns.
The first was through line supervision and the second was through the Concerns Resolution Staff (CRS).
The standards described the importance of creating an environment which supports and encourages the free expression of concerns by employees.
They stated that the resolution of employee concerns by supervisors must be thorough, unbiased, timely, and should directly involve the employee when possible.
The second method (CRS)
was described as an alternative path if the employee felt resolution could not be obtained through the first path.
The
standards stated that employee concerns will be handled in accordance with staff instructions.
.The method of handling employee concerns by CRS was described in Concerns Resolution Staff Instruction 1, revision 3, titled Program Administration.
The instruction dealt with how to process the concern and included all the different receipt avenues, confidentiality, classification, investigation, resolution, closure, and reporting.
Review of Employee Concern Files Of the 206 concerns that the licensee's CRS Program has received since January 1990 all but 12 are closed.
The inspectors selected various CRS Employee Concern Files closed by TVA since January 1990 to determine if concerns were adequately resolved in accordance with the program instructions.
Specifically, the files were reviewed to determine whether procedural guidance was followed, whether the investigation was adequate, whether the investigation substantiated the concern, whether CA( documents were generated when required, whether corrective actions were identified for substantiated concerns, whether the corrective actions resolved the concerns, and whether the concerned individual was informed of the results of the investigation.
The following files were reviewed and considered fully adequate:
ECP-90-BF-A80-F1 ECP-90-BF-A83-F1 ECP-90-BF-A87-F1 ECP-90-BF-A89-F1 ECP-90-BF-F63-F1 ECP-90-BF-G11-F1 ECP-90-BF-G48-F1 ECP-90-BF-H03-F1 ECP-90-BF-H04-F1 ECP-90-BF-L18-FI ECP-90-BF-N35-F1 ECP-90-BF-N53-F1 ECP-90-BF-H03-F1 ECP-91-BF-120-F1 ECP-91-BF-313-F1 ECP-91-BF-940-F1 ECP-92-BF-010-F1 ECP-92-BF-038-F1 ECP-92-BF-062-F1 ECP-92-BF-169-F1 The inspector also reviewed several inquiry record forms contained in the CRS Inquiry File.
An inquiry was defined in CRS Instruction 1 section 2. 11 as other information or requests which do not meet the definition of an issue requiring further CRS action or is outside the scope of CRS responsibilities that is
deferred to other organizations for handling, and does not require further CRS action.
No concern file was opened for these cases and the discussion was documented on a single form maintained in the file.
Examples of inquiries might be a visit by an employee to ask a question about TVA policy or a TVA supervisor requesting guidance on dealing with a personnel issue.
Inquiries are handled with the same level of confidentiality (when requested)
as concerns.
If the inquiry involves a referral to another organization that referral is referenced on the inquiry record form.
The inspector randomly selected several inquiries received since 1990 and did not identify any issue which appeared to require fur ther action by the CRS staff.
The CRS concern files reviewed by the inspector appeared to be adequately resolved.
Evaluations and other supporting documentation contained in the files were thorough and technically adequate.
Files contained sufficient documentation or references to other supporting documentation which would enable an independent reviewer to reach the same general conclusion as the CRS had.
For those closed files reviewed, all required responses to the CI had been made and those responses clearly stated whether the issue(s)
had been substantiated and described any corrective actions required.
The investigation and technical resolution of issues was adequate.
Concern Resolution Backlog The inspector reviewed the licensee's employee concerns database to determine the adequacy of the licensee's-program for insuring that employee concerns were resolved in a timely manner.
The inspector determined that the licensee had a total of 13 open concerns of which 7 were received during 1993.
The remaining
concerns included 1 received in 1988 and 5 received in 1992.
All open concern files received prior to 1993 were reviewed by the inspector with the CRS to determine why the files were open and whether the issues were resolved.
These 'were:
ECP-88-BF-414-01, ECP-92-BF-028-F1, ECP-92-BF-043-F1, ECP-92-BF-080-F1; ECP-92-BF-119-FI, and ECP-92-BF-224-Fl.
All concerns were resolved with only the completion of corrective action remaining.
All were being actively worked except the 1988 concern.
The 1988 concern had corrective action complete for Unit 2 and was awaiting action on Unit 1.
All Unit 1 work was on hold. This concern did not affect Unit 3.
The inspector found the backlog of open concerns acceptable.
Repetitive Issues The repeated use of the CRS program by any licensee employee can be an indicator of employee satisfaction.
However receipt of a concern which is the'same or very similar to one of the employee's previous concerns could indicate some level of dissatisfaction.
The inspector considered that repetitive concerns from the same
individual could indicate a weakness in getting employee conce}ns resolved.
The inspector selected from a list of present and former employees who had identified more. than one concern under the licensee's employee concerns program since the original program was implemented in 1986.
The inspector reviewed the concern descriptions for the top eight individuals who had provided more than one concern.
The inspector noted no apparent repetitiveness of concerns for the eight individuals reviewed.-
e.
Harassment and Intimidation CRS Staff Instruction 1 defined intimidation and harassment as actions taken by someone to prevent the timely or proper execution of assigned tasks or responsibilities or to attempt to achieve by use of undue pressure a goal unrelated to assigned tasks or responsibilities.
The inspector reviewed the concern descriptions from January 1990 until June 1993 to determine if the Concerns Resolution Staff (CRS)
had properly identified employee concerns involving potential harassment and intimidation (H&I), and had referred those identified to the TVA/IG for investigation.
A memorandum from the Senior Vice President, Nuclear Power, to the TVA managers, dated October 22, 1990, transmitted the booklet
"Intimidation and Harassment in the Workplace" and provided new guidelines that all items which met the booklet definition of H&I would be referred to the TVA/IG for investigation.
The inspector determined through discussion with the licensee and by reviewing the employee concern files that H&I had been properly identified and that all H&I files, after the October 22, 1990 memorandum, had been properly referred to the IG for investigation.
There were no TVA/IG investigation substantiations for H&I.
No violations or deviations were identified.
Employee concerns were being adequately resolved.
H&I concerns were being conservatively referred to the TVA/IG.
CRS management of the investigation backlog was generally adequate.
Contractor Employee Concerns Programs SSP 1.02, Section 3.2, Contractor Responsibilities for Resolving Concerns, provides guidance and expectations for contractors'esponsibilities in the employee concerns area.
The SSP exempted staff augmentation contractors from the requirements of Section 3.2.
The SSP stated that the normal process for resolving issues is through line management.
The SSP required that contractors providing technical support have further responsibilities which included providing a
mechanism for their employees and subcontractors to report safety and quality issues and provide orientation for the employees on the program, investigate and resolve the safety and quality issues identified to them, keep the licensee informed of technical issues and allegations of H&I received, and maintain documentation of the resolution of safety and quality issue e The inspector reviewed with the CRS site re'presentative the list of all contractor organizations on site to determine their status and classification.
The inspectors determined that the only contractors on site that were not staff augmentation were those listed below and their subcontractors.
The inspectors sampled the contractor safety-related concern files to determine if concerns were adequately resolved in accordance with the program instructions.
Specifically, whether procedural guidance was followed, whether the investigation was adequate, whether the investigation substantiated the concern, whether CA(} documents were generated when required, whether corrective actions were identified for substantiated concerns, whether the corrective actions resolved the concerns, and whether the concerned individual was informed of the results of the investigation.
a ~
Bechtel b.
Bechtel Corporation provides contract engineering services.
The Bechtel employee concerns program was described in Bechtel Project Procedure BPP-4. 12, Employee Concerns Resolution Program, Revision 3, dated October 13, 1993.
Bechtel had received 19 employee concerns of which 14 were closed.
The inspectors reviewed closed concern file numbers 5, 7, 12, and 13 and determined that they had been adequately resolved in accordance with the program instructions.
The inspector noted that concern files prior to number 12 did not always contain evidence to show that the concerned individual was informed of the results of the investigation.
The inspector determined that Revision 1 to BPP-4. 12 had not required the contractor to document this feedback to the concerned individual but later revisions had required that action.
The inspector noted that all later closed concern files contained copies of feedback letters or other evidence to show that the proper feedback to the concerned individual had occurred.
Stone and Webster Engineering Corporation (SWEC)
SWEC provides maintenance and modification support services.
The SWEC employee concerns program was described in the SWEC Maintenance Management Manual No. 2.2, Employee Concerns Program, Revision 3, dated September 21, 1993.
SWEC had received 102 employee concerns in 1992 and 1993.
The inspector noted that the large majority of concerns were not safety-related.
The inspector reviewed the below listed sample of closed safety-related employee concerns:
92-01 92-09 93-64 The inspector determined that the above concern files were adequately resolved in accordance with the program instruction However, during the review of Concern File 93-72 the inspector noted that the issue was a'ssociated with failure by craft and craft supervision to enter the drywell to perform verification steps on datasheets for Workplans WP3815-92, WP3816-92, WP3561-92, and WP3986-92 in accordance with HAI-5.3, Protective Coatings.
The work involved the first and second party verification steps for assurance that containment protective coatings had acceptable sur'face condition, curing, continuity, and dry film thickness.
Those steps had been signed as complete by the craftsman and craft supervisor based on existing entries on the October 16, 1993, Daily Drywell Priority List rather than an actual visual inspection.
A portion of the work had been rejected by the gC inspector after the datasheets had been signed by the craft and craft supervisor on October 17, 1993.
The reason for gC rejection was inadequate curing and unacceptable dry film thickness.
As a
result of this event the craft supervisor had been counseled for not meeting management's expectations (entering the drywell to personally check the adequacy of the work) however the issue had not been considered by the contractor or TVA CRS personnel as a
falsification issue or as a violation of plant procedures.
Additionally, the licensee considered this issue as an isolated case with no generic implications (training of other personnel).
This item is identified as URI 259, 260, 296/93-,43-01, Failure to Perform Craft Verification for Adequacy of Containment Coatings.
This item will remain open pending additional review of this problem.
Rust, Pullman, Cleveland (RPC)
RPC was performing the site security system upgrade.
The RPC employee concerns program was described in the RPC Site Procedure titled Employee Concerns Procedure, Revision 2, dated September 15, 1993.
The RPC contract on site was at completion (depart site approximately December 21, 1993)
and the only employees still on-site (8) were management related.
Copies of the RPC files were going. to be kept by the CRS site representative.
There had been a
total of six concerns filed since the contractor implemented their program.
None of those involved work on safety related equipment.
The inspectors reviewed 1 closed concern file from February 1993 and determined that it was adequately resolved in accordance with the program instructions.
General Electric was performing various turn-key jobs such as recirculation piping replacement.
The GE program was described in GE Procedure for Resolving Employee Concerns at the Browns Ferry Site, GE-BFN-CR-l, Revision 2, dated September 9,
1993.
GE had received 9 employee concerns.
The inspectors reviewed 2 closed employee concern files (CR93-04 and CR93-05)
and determined that they were adequately resolved in accordance with the program instruction.
No violations or deviations were identified.
The inspectors concluded that the contractor employee concerns programs were being used by employees and were adequately resolving employee concerns.
Communication between the contractors and the CRS organization was good.
CRS oversight of the contractor organization was also good.
Employee Perceptions Interviews were conducted with 327 persons working at the Browns Ferry site for TVA and the various contractors.
The objectives of the interviews were t'o evaluate the willingness of persons to identify quality or safety concerns to their supervision or management without fear of retaliation, and to evaluate the awareness and use of the licensee and contractor employee concerns programs.
The sample size was selected to include approximately IOX of the persons working at Browns Ferry.
The inspectors selected the persons to be interviewed from an alphabetical computer listing of the employees for each major contractor, and for TVA.
The method used was to select a
starting point, which was varied for each group, and then selecting every tenth person thereafter.
Persons were selected from the TVA, SWEC, GE, and Bechtel organizations.
The interview questions and results are summarized in the following table.
In interpreting the interview results, if a person was unsure about the extent of his or her employer's program, this was counted as not being aware that the program existed.
SUMMARY OF INTERVIEWS CONCERNING USE OF ECP AND CRS Aware of Contractor ECP Aware of TVA CRS Would Use Either ECP or CRS Have Used ECP or CRS Would Use ECP or CRS A ain Would Not Use ECP or CRS Would Raise Concerns to Su ervisor ECP Independent of Line Mana ement Needed Number of Persons Interviewed Total Persons On Site TVA 154 151
118
125
10 NA NA 124
126
127
1710 178 BECHTEL
25
.NA NA
26
371 SUM 150 314 320
321 317 327 4460
A review and evaluation of the interview results by the inspectors resulted in the following conclusions:
Everyone interviewed, except one, stated that if they had a
significant safety or quality concern that they would report it, if not to their supervision or through the ECP or CRS, then directly to the NRC.
The one exception was a person
.interviewed on his first day at BFN.
Very few of those persons interviewed have used either the ECP or CRS - 9X for TVA and 8X for SWEC.
Interview results, compared with a survey conducted by TVA in March 1993, indicated that the awareness and knowledge of the ECP and CRS programs had increased since that time.
No violations or deviations were identified.
Employee Concern Program Audits and Management Involvement The guality Assurance organization performed an audit (SSA92204) of Corrective Action/Correction of Deficiencies which was issued July 14, 1992.
The audit included a review of the Concerns Resolution program to ensure the employee concerns were documented and resolved in a satisfactory manner.
The audit reviewed six employee concern files at Browns Ferry.
The audit concluded that the investigations and actions were appropriate and adequate to satisfactorily resolve the identified issues.
A recommendation was made to include a chronological listing or table of documents and actions in the employee concerns closeout packages for the Concerns Resolution Staff reviewers and investigators to ensure all actions had been taken.
The audit details indicated that file organization sometimes made it difficult for the auditors to verify concerns were adequately investigated and that appropriate corrective
'ctions were taken.
The audit team did not find any corrective actions that had not been taken.
In discussing the audit recommendations with the CRS manager, the inspector learned that the recommendation had not been completely implemented.
CRS agreed with the audit that some improvement of file organization was needed.
However, CRS also felt that applying additional manpower to reorganizing old closed files was not appropriate.
CRS internal discussions were focused on improving new file organizational quality'without initiating any new organizational methodology such as recommended in the gA audit.
The CRS was studying whether further organizational methodology was needed.
This approach was reasonably effective based on the results of the file review discussed above and the lack of TVA/IG audit findings on file organization (see below).
The inspector reviewed an audit conducted by the licensee's CRS of the contractor employee concerns programs for all of TVA.
The audit was issued April 8, 1993.
A review of the audit plan showed that the audit included a program review (procedure review), implementation review (review of investigation files),
and an employee knowledge of program
survey.
The audit plan was sufficiently broad in scope to provide an adequate assessment of the contractor programs.
The audit reviewed
SWEC closed employee concerns,
RPC closed employee concerns,
GE employee concern, and ll Bechtel employee concerns.
The audit identified that all contractors had programs in compliance with the requirements, that all contractor personnel displayed a desire to establish and maintain an atmosphere free of intimidation and harassment in which quality and safety issues can be identified, and that STD 1.2 was being adequately implemented.
The audit identified the following deficiencies:
Documentation of interviews was being stored in each individual's personnel record.
This practice could result in a loss of confidentiality and in allegations of reprisal in future personnel decisions.
2.
Administratively confidential internal EC progr am memoranda were transmitted with the name of the concerned individual (CI)
appearing in the subject.
This practice could have resulted in a loss of confident'iality had the CI requested confidentiality.
3.
The contractors'mployees did not have sufficient awareness of the contractors'C programs or that they may use the TVA program as an alternate.
4.
Documentation of exit interviews was not being maintained by one contractor.
Contractor response to the above deficiencies was identified in the audit as immediate.
Each contractor received a copy of their portion of the audit.
The NRC reviews from paragraphs-
and, 4 above indicate that the corrective actions taken were reasonably effective.
The inspector reviewed an audit conducted by the Office of the Inspector General, audit 92-0580, Nuclear Power's Concerns Resolution Program, issued July 30, 1993.
The audit was conducted to satisfy a commitment to the NRC to report periodically on the effectiveness of the CRS program.
The stated objectives were to determine if CRS complied with its policies and operating procedures, closed investigative cases in a timely manner, and added value by operating in an effective manner.
The audit was conducted of all TVA sites.
There were no audit findings specific.to Browns Ferry.
The audit found that:
CRS generally complied with its policies and procedures.
2.
3.
On the average, CRS and TVA management appeared to resolve concerns in a timely manner.
CRS's effectiveness at resolving employee concerns could not be determined because (1)
NRC would not provide details related to concerns expressed directly to NRC, (2) views
varied widely concerning the program's effectiveness, and (3) the results of TVA/IG surveys were inconclusive.
The inspector considered that individually the audits did not cover the entire employee concerns program.
The gA audit reviewed closed files for technical effectiveness of corrective action.
The CRS contractor review audited only the contractors.
The TVA/IG audit evaluated the overall CRS program except for technical effectiveness.
However, collectively they adequately addressed the scope of the employee concerns programs.
The audits were considered reasonably successful in providing management a tool to assess the employee.concerns programs.
The inspector interviewed licensee senior management to determine their level of involvement and support for the employee concerns programs.
The inspector found the senior line management to be supportive of the program and resolution of issues, and also supportive of the program's independence from line management in taking concerns.
The inspector determined that management involvement and awareness of,the employee concerns program at the corporate and site level was'adequate.
No violations or deviations were identified.
Exit Interview (30703)
The inspection scope and findings were summarized on December 10, 1993 with those persons identified in paragraph I.
The inspectors described the areas inspected and discussed in detail the inspection findings.
The licensee did not identify as proprietary any of the material reviewed by the inspectors during the inspection.
Dissenting comments were not received from the licensee.
Proprietary information is not contained in this report.
Inspection Findings:
No violations or deviations were identified.
Employee concerns were being adequately resolved.
CRS management of the investigation backlog and the referral of harassment and intimidation concerns to the TVA Inspector General was adequate.
CRS oversight of the contractor programs was a strength.
~T e
Item Number Status escri t'on URI 50-259,260,296/93-43-01 Open Failure to Perform Craft Verification of Adequacy of Containment Coatings.
(Paragraph 3.b)
List of Acronyms and Initialisms
ASME CAP CAQR CAQ CATD CI CRS CRS-SR DCN DOL ECN EC ECP ECSP DCN HEI II MAI MSC
,
NP QA QC QE RI I RPC SSP STD SWEC TI TVA TVA/IG-URI American Society of. Mechanical Engineers Corrective Action Plan Condition Adverse to Quality Report Condition Adverse to Quality Corrective Action Tracking Document Concerned Individual Concerns Resolution Staff
'oncerns Resolution Staff Site Representative Design Change 'Notice Department of Labor Engineering Change Notice Employee Concern Employee Concern Program Employee Concern Special Program Design Change Notice, Harassment and Intimidation Incident Investigation It Modifications and Additions Instruction Miscellaneous Nuclear Power Quality Assurance Quality Control Quality Engineering NRC Region II Rust, Pullman, Cleveland Site Standard Practice Nuclear Power Standard Stone and Webster Engineering Corporation Temporary Instruction Tennessee Valley Authority TVA Office of Inspector General Unresolved Item
T
,