IR 05000324/1993053

Insp Repts 50-324/93-53 & 50-325/93-53 on 931115-19.No Violations Noted.Major Areas Inspected:Employee Concerns Program & Actions on Previous Insp Findings

ML20059B805
Person / Time
Site:	Brunswick
Issue date:	12/10/1993
From:	Christensen H, Haag R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059B778	List: IR 05000324/1993053 ML20059B775
References
50-324-93-53, 50-325-93-53, NUDOCS 9401040251
Download: ML20059B805 (9)

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UNITEo STATES

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NUCLEAR REGULATORY COMMISSION 3"s 't REGION il  !

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Report Nos.: 50-325/93-53 and 50-324/93-53 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602  :

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Docket Nos.: 50-325 and 50-324 License Nos.: DRP-72 and DRP-62 Facility Name: Brunswick Steam Electric Plant Unit I and 2 t

Inspection Conducted: November 15-19, 1993 Lead Inspector: b /o b v R. C. Haag, Senior /"

/L-/s- 95 Date Signed j

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Resident Inspector - V. C. Summer  !

Inspectors: Oscar DeMiranda, Senior Allegation Coordinator Darr 11 Roberts, Resident Inspector Harris  !

Approved by: 40/ -

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fev- H. O. yhristensen, Chief Date Signed i Projects Section IA  !

Division of Reactor Projects i

SUMMARY  !

Scope:

This special announced inspection was conducted in the areas of employee concerns program and action on previous inspection findings. The purpose of i the inspection was to determine the effectiveness of the employee concerns <

program and to determine whether adequate means exist to resolve safety concerns raised by employee ,

Results:

No violations or deviations were identifie The employee concerns program was adequate to resolve concerns identified by employees. Implementation of the program had expanded beyond the scope of the governing procedure. Also the procedure lacked guidance for several attributes of the program. In general the concern files reviewed by the inspectors were of good quality. A few exceptions were noted with concerns being misclussified and concern evaluation documentation being incomplet Employees were aware of the program and the various methods for submitting concerns. During the interview process, many employees commented on improvements in the current management organization and the current environment that is receptive to employee concerns. Usage of the employee

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concerns program (which is confidential) has increased during the past yea Management involvement and commitment to the program was eviden The program is currently in transition with a major procedure revision underway and recommendations from a recent licensee assessment being reviewe ..

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REPORT DETAILS  ! Persons Contacted Licensee Employees  ;

• J. Cowan, Plant Manager, Unit 1 l

• C, Warren, Plant Manager, Unit 2 '

• Levis, Manager, Regulatory Affairs

• J. Leviner, Manager, Nuclear System Engineering

• J. Davis, Environmental and Radiological Control i L. Loflin, Manager, Nuclear Assessment Department

• H. Casanova, Manager, Quality Check Program

• K. Kirks, Quality Check Program  !

• Calvert, Associate General Counsel '

• R. Godley, Manager, Regulatory Compliance ,

• S. Tabor, Senior Specialist, Regulatory Compliance f Other Personnel Contacted ,

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• P. Byron, NRC Resident Inspector ,

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R. Prevatte, NRC Senior Resident Inspector

• Attended exit interview l Acronyms and initialisms used throughout this report are listed in the last paragrap ; CP&L Employee Concerns Program Program Overview The licensee's employee concerns program is referred to as Quality Check. The program is described in CP&L Nuclear Projects Procedure, Quality Check Program, Revision 4. This procedure, ;

which is used at all CP&L nuclear sites, also provides instructions for implementation of the Quality Check Program. The objective of the program is to ensure that appropriate CP&L ,

management is made aware of employee concerns so that they can be ,

resolved and corrective action taken when appropriate. While employees are encouraged to share any concern they may have with their supervision, there is a recognition that this method may not always resolve the concern. Therefore, Quality Check is intended ,

to provide an alternate method for resolving concern '

The Quality Check Program is applicable to both CP&L employees and contractors. Confidentiality and anonymity of individuals participating in Quality Check is another key attribute of the progra Both current and departing employees are encouraged and given distinct opportunities to use Quality Chec .

2 Procedural Guidance Concerns received by the Quality Check staff are classified into three categories based on their importance. The three categories are:

Case Usually a technical, quality, or nuclear safety-related concern. Can also be related to procedures, management concerns, or fitness for duty, depending on the severity of the concer A Case warrants resolution through investigation and some form of actio MII (Management Information Item) - A concern'not meeting th requirements of a Case, which if not corrected, could possibly lead to a Case. An MII needs management attention and warrants investigatio NOI (Notice of Information) - A concern which may warrant management attention, but does not require an investigation or response. NOIs are forwarded to the. applicable sites for their review and any resulting action The procedure states that the manager of Quality Check will maintain the confidentiality of Quality Check documents. The inspectors reviewed the steps in processing concerns and inspected the Quality Check staff's files. Adequate precautions were in place to safeguard documents maintained by the Quality Check staff. However, the safeguarding of documents associated with concern investigations was questioned by the inspectors. There is no guidance given in this area. The inspectors were informed by individuals who had performed investigations that they were sensitive to confidentiality of documents. However, there did not appear to be a structured method for accomplishing _this tas Instructions for review and evaluations / investigations of concerns are provided in section VIII of the Quality Check procedure. The Manager of Quality Check is tasked to assign an appropriate evaluator / investigator for Cases and MIIs. Nearly all of these concerns are referred back to the organizations involved with the concern, i.e., an issue involving a Brunswick system engineer is sent to the Brunswick Site Director, then generally to the Technical Service manager for investigation. The inspectors did note that a few Cases had an indepe ident evaluator. assigned for the investigation. The licensee stated that it was their polic to refer most concerns back to line management for resolutio They viewed this as a benefit for holding management accountabl for issues.in their organizations. The inspectors viewed thes items as positive benefits, but noted that maintaining an independent / objective viewpoint and confidentiality would be more difficult when using line management to perform investigation in their organization .

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When comparing the Quality Check procedure versus actual program implementation, the inspectors noted the following:

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The scope of the program as described in the procedure is for plant related concerns. In reality, all concerns submitted to Quality Check are being processed. The ,

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inspectors did not view the expanded scope of the program as a problem, however the program description did not agree with the actual program implementatio l

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The procedure did not provide any special precautions or ."

describe how to process concerns involving wrongdoin Also, wrongdoing was not defined in the procedure. The

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inspectors noted that issues involving potential wrongdoing >

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had been processed by the Quality Check progra ;

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Independent investigations of concerns and independent verifications of concern evaluations were performed on a  ;

limited basis. However, the procedure provides no guidance for implementing these practice '

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The procedure did not address a practice employed regarding l referral of employee concern evaluations to line management two levels above the origination of the issue. The reasoning behind the two levels of management referral was '

to protect the. identity of the concerned employee and to '

provide an objective revie The licensee informed the inspectors that the Quality Check procedure was being revised. A draft revision to the procedure  :

was reviewed by the inspectors. Many of the items noted above ,

were being addressed in the revised procedure. The licensee plans to issue the revised procedure in the firstfquarter of 19N ,

P c. Quality Check Program Implementation  ;

Concerns sent out by the Quality Check staff for investigation i normally have a 30 day due date assigne Extensions can be given 6 by the Quality Check staff when requested. A review of 37 '

recently closed Cases and MIIs (requiring a response) identified .

that approximately one third were closed within the due date. At  ;

the time of the inspection there were 21 open Cases and MIIs with i 16 past the due date. While the inspectors noted that more i concerns were recently exceeding their due date, the overall I backlog of Quality Check concerns appeared to be reasonable and the majority of concerns were resolved in a timely manne i The inspectors reviewed the training, experience and qualification  ;

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of the Quality Check staf Based on the amount and-diversity of l the training received, the Quality Check staff is well qualifie ;

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if action had been taken in response to these concerns. The ,

licensee agreed that these two QCRs were misclassified. Two other QCRs,18350 and 18840, involving potential programmatic / widespread :

problems with substandard maintenance, and the short-term ;

structural integrity program were classified as NOIs because the concerns lacked adequate details. While N0ls are sent to the plant for review, the lower classification _by the Quality Check *

staff may send the wrong message to individuals reviewing potential programmatic concern * The documentation of investigation results for several QCRs failed ,

to completely address the identified concern. QCRs 17442, 17485, *

18350 and 17921 are examples of concern evaluations which lacked '

adequate depth and detail to fully understand the concern disposition. A lack of consistency was noted in the evaluation of QCR 18800 which contained a list of facts but did not provide _a-conclusion. Also, some QCR evaluations contained action items, however when reviewing these QCR there were no references to what programs would implement the action item The licensee is addressing these identified deficiencie . Employee Perceptions Interviews were conducted with 66 individuals working at the Brunswick ,

site. The objectives of the interviews were to determine employee awareness of and experience with the Quality Check program. The <

inspectors also evaluated the willingness of persons to identify quality or safety concerns to their management without fear of retributio The inspectors randomly selected interview candidates from organization charts. The selected candidates represent a cross section of workers r including craftsmen, technicians, engineers, operators, supervisors, and ;

manaoement personnel. Nearly all of the employees interviewed stated that they would raise a concern through the Quality Check program if t needed. All but one of the employees were aware of the Quality Check program's existence and about 20 percent of the people interviewed stated that they had previously used the program. Of those employees ,

that had used Quality Check, nearly all of them stated that their ,

concerns were adequately addressed or were currently being resolved by the Quality Check program. The confidentiality aspect of the program was mentioned by most of the interviewees as the reason they thought ,

Quality Check was a useful program. The inspectors noted that an increasing number of Quality Check concerns are being received. As of i ilovember 15, 1993, 183 concerns had been submitted as compared to 101 *

concerns in 199 ,

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A greater percentage of the interviewed personnel indicated that they had brought concerns to their management's attention in the past. Many expressed a renewed trust in their current management and that the ,

management chain was the preferred method for resolving issues. Some i expressed comments on how they perceived the Quality Check process had .

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The interview process plays a key role in the Quality Check progra In addition to the exit interview for departing '

employees, continuing interviews are randomly held with site personnel. The objective of the continuing interview process is to provide employees an additional method for expressing concerns i and to provide management with the employee's general perception ,

of the plant and their management. The interview process is a i positive aspect of the Quality Check progra .

3. Review of Selected Quality Check Files The inspectors reviewed the Quality Check Report Status Log for 1992 and current year 1993. Out of the 284 Quality Check Reports (QCRs) received -

during that time period, the inspectors selected 63 QCRs to determine if -

concerns were adequately resolved in accordance with the program - '

instructions. All three QCR classifications levels, Case, MII and NOI were reviewe Specifically, the files were reviewed to determine whether procedural guidance was followed, whether the investigation was adequate, whether the QCR was properly classified, whether adequate ;

corrective action was identified and implemented to resolve the concern, i and whether the concerned individual was informed of the investigation !

results. The inspectors concluded that, for the majority of the QCRs I reviewed, the concerns were adequately addressed. However, some '

deficiencies in QCRs were noted:

• To determine if individuals involved in processing QCRs were !

sensitive to the confidentiality of the concern submitter, the inspectors reviewed the files for excessive usage of individual ,

names and information that could identify the submitter. One file, QCR 16316, contained information in the concern description which helped identify an individual-. This information was unnecessary to express the concern. Except for this one QCR, the i inspectors concluded that the Quality Check staff did a good job i in sanitizing the concern yet still sufficiently describing the '

concern so followup investigations could be performed. In the concern response / investigation results, the same level of sensitivity did not appear to exis In several QCR responses i individual names were included. While the nature of some concerns will identify individuals when performing an investigation, the ;

need to include these names in the written response was questione * Several QCRs appeared to be misclassifie Four QCRs were I

classified as NOI (lowest classification), however, based on the ,

concern description a higher classification level appeared to be warranted. QCR 18699 reported cracks in the walls of the service water intake building and painting over rusted pipe inside the i intake building. QCR 18238 reported postings not being maintained i on bulletin boards. The postings in question were required by NRC

, regulations. The issues in both QCRs appeared to meet the "

j threshold for a higher classificatio Since NOI QCRs do not require a written response, the inspectors were unable to assess

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been abused by employees when it was first introduced in 198 :

Interviewees indicated that some personnel carried out personal ,

vendettas against other employees through the Quality Check proces !

According to interviewed personnel, this practice has now been cleaned u . Quality Check Program Audits and Management Involvement '

i Earlier assessment / audits of the Quality Check program were limited in scope and fo'cused on the completion of exit interviews for departing employees. The inspectors reviewed the Quality Check portions of six QA  :

audits performed at the CP&L plants during the 1988-1990 time perio :

The completion of exit interviews was the only attribute of the Quality  :

Check program in these audits. In July 1991, an assessment of the '

Quality Check program by the Nuclear Assessment Department (NAD) ,

reviewed the functions of the program and the options of locating the

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program into different CP&L organizations. The implementation and  !

effectiveness of the Quality Check program was not reviewed during that j assessmen ,

l Recently (August 1993) an independent assessment of the Quality Check

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program by an outside consultant was initiated. A goal of this activity ,

was to formulate recommendations for improving-the Quality Check r program. The assessment included a program review and a survey of employee attitudes and perceptions of the program. The inspectors were given a general briefing of the assessment results, however, the improvements / recommendations had not been finalized when the inspection was performe l Management commitment and involvement in the Quality Check program was  !

apparent by several recent initiatives. A policy statement dated i August 16, 1993, by the Senior Vice President - Nuclear Generation, expressed managements commitment to the program, the need and importance j of the Quality Check program, and that any form of retaliation against l personnel identifying a concern would not be tolerated. A high level of '

management involvement was noted in the investigation and development of

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concern evaluations. A monthly Quality Check report is distributed to CP&L Nuclear Vice President Included in the report are QCRs closed during that month with a description of the concern and the respons The inspectors noted that the QCR writeups in the report use basically the same wording as that contained in the QCR files. Since there are no programmatic guidelines for handling the monthly reports, the inspectors questioned the licensee if these reports are given the same level of safeguards as the actual QCR file Another recent initiative was the one-on-one retraining of all plant

, supervisors by the Quality Check staff. The agenda consisted of a brief

overview on the Quality Check process, how exit interviews are performed, and the handling of sensitive information resulting from the Quality Check process.

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6. Action on Previous Inspection Findings i (Closed) Unresolved Item 325,324/93-42-01, Review Licensee .

Investigation of .Possible Employee Discrimination For Reporting a Safety Concern -

This issue dealt with a former Bechtel employee who had expressed a .

concern related to color vision testing practices by the licensee. When the issue was brought up to his supervisor, the employee alleged that he i

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was cautioned by this Bechtel supervisor to discontinue pursuing the l color vision testing issue or his future employment may be terminate The detailed results of the initial NRC review of this case were i provided in NRC Inspection Report Nos. 50-325/93-42 and 50-395/93-4 !

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This review included interviews with involved personnel and a review of related documents. At the end of that inspection the licensee informed ,

the inspectors of their plans to perform an independent investigation this matte ;

, Dring this inspection the inspectors reviewed the licensee's

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investigation report. The licensee determined that a misunderstanding setween the supervisor and the employee resulted in the employee's view !

that his future employment was in jeopardy if he pursued the color ,

vision testing issue. It was further determined that the supervisor had !

been counseling the employee on a conduct issue. During this counseling, the employee related his concern about the color vision ,

test. Based on the inspectors previous review of this issue and a  ;

review of the investigation report the inspectors concluded that the employee's views of supervisory intimidation were based on a misunderstanding with the supervisor; to help ensure no future misunderstanding, CP&L is revising their procedures based on_ i recommendations from independent review groups to have all badged ,

personnel go through Quality Check process upon terminatio j 7. Exit Interview i l'

The inspection scope and findings were summarized on November 19, 1993, with those persons indicated in paragraph 1. The inspectors described the areas inspected and discussed the inspection finding No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during the inspectio . Acronyms and Initialisms CP&L Carolina Power and Light MII Management Information Item NAD Nuclear Assessment Department

! NOI Notification of Information l NRC Nuclear Regulatory Commission QA Quality Assurance QCR Quality Check Report

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