IR 05000327/1986052
| ML20211C978 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/16/1986 |
| From: | Joseph Holonich, Hooks K, Jenison K, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20211C948 | List: |
| References | |
| 50-327-86-52, 50-328-86-52, NUDOCS 8610220067 | |
| Download: ML20211C978 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Report Nos.:
50-327/86-52 and 50-328/86-52 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Docket Nos.: 50-327 and 50-328 License No. DPR-77 and DPR-79-Facility Name: Sequoyah 1 and 2
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Inspection Conducted: September 15-19, 1986 Inspectors:
h M
M// eg Ke6deth R. Hooks, IE, Team Leader
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~ D4te d446ph J. Holonich,'NRR
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Law as Gnneth M. Jenison, RII, SRI
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' Approved by:
e R. Le Spessard, pputy Director, DI/IE Date '~
8610220067 861017 PDR ADOCK 0500
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SUMMARY Scope: This special, announced inspection was conducted at TVA's Chattanooga, Tennessee offices and the Sequoyah Nuclear Plant site. The inspection was performed to review and evaluate the implementation of the new Employee Concern Program (ECP) within TVA, with particular emphasis on the Sequoyah Nuclear Plant. The program was discussed with ECP management and the ECP Site Representatives (ECP-SRs) from Knoxville, Chattanooga, and Sequoyah, and selected concern files and investigation reports were reviewed.
Interviews
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were conducted with randomly selected TVA employees at Sequoyah to ascertain their knowledge and opinions of the new ECP. Discussions were held with a member of the TVA Office of the Inspector General (OlG) regarding their planned audit of the new ECP. No inspections of documents or hardware to verify concerns or investigation reports were performed by the NRC inspectors.
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Results: No violations or deviations were identified. Implementation of procedures for the new ECP was generally adequate; however, potential problems regarding tracking and resolution of generic concerns and understanding of the confidentiality provided to concerned individuals were identified.
Interviews with Sequoyah employees indicated that~most employees were aware of the new ECP and stated that they would use it to resolve concerns which could not be
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resolved through their supervisors.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees M. Alexander, ECP-SR, Knoxville
- D. K. Baker, ECP-SR, Chattanooga
- R. C. Birchell, SQN Licensing
- F. Campbell, Nuclear Safety and Licensing
- T. M. Galbreth, ECP-SR, Sequoyah
- R. Irish, 0IG-General Management Branch R. A. Kile, 0IG-General Management Branch G. Kirk, Sequoyah Staff
- L. F. O'Donnell, Consultant
- R. H. Shell, Nuclear Safety and Licensing
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- E. Sliger, ECP Manager
- G. Smith, ECP Staff J. H. Sullivan, Sequoyah Staff
- C. Taggart, Nuclear Safety and Licensing
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Other licensee employees contacted included laborers, engineers, technicians, security office members, and office personnel
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- Attended exit interview.
2.
Exit Interview
'The inspection scope and findings were summarized during an exit interview on September 19, 1986 with those persons indicated by an asterisk in Paragraph 1 above. The NRC inspectors described the areas
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inspected and discussed in detail the inspection findings. No dissenting comments were received from the licensee.
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The following three Inspector Follow-up Items (IFIs) were discussed during the exit interview:
the understanding by concerned individuals of the degree of confidentiality provided by the new ECP (paragraph 4.d); timely resolution of generic concerns (paragraph 4.f); and the adequacy of statements justifying evaluation of a concern as not being generic (paragraph 4.g).
3.
Documents Reviewed a.
The following procedures were reviewed to the extent required to support the inspection:
J ECP Instruction No.1 " Employee Concern Program - Site
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Representative Procedures," Rev. 3, May 30, 1986.
ECP Instruction No. 2, " Employee Concern Program - Reporting,"
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Rev. O, February 28, 1986.
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ECP. Instruction No. 3, " Employee Concern Program - File
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Storage," Rev. O, May 6, 1986.
b.
The following files from the new ECP were reviewed by the NRC inspectors:
(1) Chattanooga ECP-SR files.
ECP-86-CH-003-01 i
ECP-86-CH-024-01 ECP-86-CH-026-01 ECP-86-CH-033-01 ECP-86-CH-040-01 ECP-86-CH-041-01
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ECP-86-CH-042-01 (2) Knoxville ECP-SR files.
ECP-86-KX-001-01 ECP-86-KX-057-01 ECP-86-KX-005-01 ECP-86-KX-058-01 ECP-86-KX-007-01 ECP-86-KX-078-01
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ECP-86-KX-008-01 ECP-86-KX-108-01
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ECP-86-XX-016-01 ECP-86-KX-055-01
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ECP-86-KX-056-01 (3) Sequoyah ECP-SR files.
- ECP-86-SQ-002-01
- ECP-86-SQ-115-01
- ECP-86-SQ-006-01 ECP-86-SQ-124-01
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ECP-86-SQ-010-01
- ECP-86-SQ-138-01 j
ECP-86-SQ-011-01~
- ECP-86-SQ-159-01
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- ECP-86-SQ-017-01
- ECP-86-SQ-233-01
- ECP-86-SQ-020-01 ECP-86-SQ-252-01
- ECP-86-SQ-027-01 ECP-86-SQ-254-01
- ECP-86-SQ-028-01 ECP-86-SQ-253-01
- ECP-86-SQ-045-01
- ECP-86-SQ-289-01
- ECP-86-SQ-046-01
- ECP-86-SQ-397-01
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ECP-86-SQ-112-01
- Not Nuclear Safety Related 5.
-Discussion and Findings a.
Revision 4 of ECP Instruction No. I has been issued and implemented within TVA, but has not been submitted to the NRC. The NRC inspectors used the ECP procedures docketed by TVA via their August 27, 1986 letter to the NRC (listed in 3.a. above) as the basis for the inspection. TVA ECP personnel stated that no significant differences existed between Revision 3 and Revision 4 of ECP Procedure No. 1.
The NRC inspectors did not review ECP Instruction No. 1, Revision 4.
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b.
The Employee Concern Task Group (ECTG) data base is now available on a mainframe computer for reference by ECP. personnel. The data base for the
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new ECP is still on personal computers, but is also available for reference by ECP personnel. According to the ECP personnel, the data base for the new ECP should be input to the mainframe computer in about a month.
There was evidence in some of the ECP-SR investigation reports and associated files reviewed by the NRC inspectors that data from the ECTG program had been used in the investigation of concerns under the new ECP.
Discussions with the ECP-SRs indicated that they expect to use the ECTG
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data base extensively as they become more familiar with the program software.
ECP personnel are developing statistical, tracking and trending data on
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the new ECP from the personal computer data base. Data for the period February-August 1986 was made available for review by the NRC inspectors.
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This data showed 461 concerns identified through August 1986 at all six ECP-SR locations, of which 157 had been classified by the ECP-SRs as nuclear safety-related. The Sequoyah ECP-SR had identified 88 concerns through August 1986, of which 15 were evaluated as being nuclear
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safety-related (Attachment 1).
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c.
The ECP-SR files at the various offices / sites are presently being organized into a standard format which includes an index, sections for employee interview records (EIRs), investigation reports, lists of persons contacted, etc., and page numbering. The majority of the files reviewed by the NRC inspectors had been organized in this fashion. Although the format and content of the files had not been fonnally proceduralized, the requirement in-ECP Procedure No. 1, Section 6.6, that the file contents
... should be indexed, segregated, total pages numbered, and
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maintained in a folder" appears to be generally satisfied. The questions concerning format and content of the files raised in IR 50-327/86-29,
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Section 4.C(1) and Section 5.c are resolved.
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d.
The NRC inspectors went through a simulated exit. interview with the l
Chattanooga ECP-SR. During this simulated interview the NRC inspectors questioned the language in the "TVA Employee Concern Program Confidentiality Understanding" which the interviewees are requested to read and sign if they request confidentiality (Attachment 1 to ECP Instruction No. 1). The NRC inspectors questioned whether the interviewees fully understand that ECP personnel cannot protect their confidentiality once their names are requested by and released to other agencies such as the NRC, TVA Office of the General Counsel, or TVA Office of the Inspector General. ECP personnel agreed to review the " Confidentiality Understanding" statement to determine if it should be revised or explained differently during interviews.
Understanding by concerned individuals of the degree of confidentiality
.provided by the new ECP is IFI 327/86-52-01.
e.
ECP Procedure No. 1 Section 6.2.6. prescribes the methods to be used in identifying and processing Differing Professional Opinions (DP0s). Only one cor.cern in the new ECP had been identified as a DP0 at the time of this NRC inspection. The DP0, which was identified by the Knoxville-5-
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ECP-SR, involves control room human factors design requirements. -The ECP-SR is preparing an investigation report on this concern which will be submitted to the ECP Manager in the immediate future.
Inclusion of a method for identifying and processing DP0's within the new ECP, in conjunction with Appendix 6 of Revision 1 of TVA's Revised Corporate Nuclear Performance Plan (CNPP), appears to satisfy the NRC request in B. J. Youngblood's letter of May 1,1986 to S. A. White that TVA describe the procedure by which TVA employees can approach the TVA Board on differing professional opinions.
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Concerns ECP-86-CH-040 on improper substitution of replacement parts, ECP-86-CH-041 on unqualified QA personnel, ECP-80-KX-007 on improper documentation of quality material in storage, and ECP-86-KX-056 on inaccessible local control panels / stations had been evaluated by the ECP-SRs as potentially generic and memoranda had been sent to the ECP-SRs
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at the other TVA Office of Nuclear Power (0NP) locations. Although notification of the other sites appeared to be in accordance with Section 6.2.3 of ECP Procedure No. 1, tracking of responses / actions by the other sites did not appear to be proceduralized or otherwise prescribed.
The NRC inspectors questioned the adequacy of tracking and resolution of these items.
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Discussions with the Sequoyah ECP-SR determined that he creates "open files" for the generic items identified to him by other sites, and then
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directs the concerns to the Sequoyah line organization for investigation
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and resolution. The Sequoyah line organization generally considers the statements of concern too vague for investigation and puts the concern in suspense awaiting further information (i.e., investigation report from the site which identified the concern).
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The NRC inspectors did not consider that this system would ensure timely resolution of generic nuclear safety-related problems.
ECP personnel agreed that potential problems existed in tracking, assignment of
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responsibility and timely resolution of generic concerns. They stated that these potential problems had been recently identified by ECP personnel and were being resolved. Timely resolution of generic concerns is IFI 327/86-52-02.
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Concern ECP-86-SQ-253 involving improperly recorded heat numbers and ECP-86-SQ-112 involving damage to quality equipment during outages were evaluated as not being generic concerns, however, the justifications for these decisions was considered inadequate by the NRC inspectors.
ECP Procedure No. 1. Attachment 6, " Instructions for Review of Employee Concerns for Generic Applicability" states that the explanation for determination of generic applicability "... shall provide enough detail to clearly communicate the basis or reasoning for drawing the conclusions." The Sequoyah ECP-SR agreed to reevaluate the statements provided in the investigation reports to justify non-generic concerns.
The adequacy of statements justifying evaluation of a concern as not being generic is IFI 327/86-52-03.
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h.
The NRC inspectors reviewed the ECP-SR final investigation reports and associated files to determine whether the reports accurately represented the mat? rial in-the files, whether concerns subsidiary to the primary stated concern had been identified, whether appropriate classification of nuclear safety-related concerns had been made, and whether the reports fully supported the conclusions and corrective actions without reference to TVA personnel and the associated files. Questions regarding these Section 4.c.(4), (5), and (6) previous NRC inspections'(see IR items had been identified in 50-327/86-29, and IR 50-390/86-15, Section 4.b.(2)).
In general, the sample of ECP-SR final investigation reports which were evaluated by the NRC inspectors during this inspection were adequate in these areas and these items are closed.
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The ECP personnel stated that the " Data Base Sheets" being developed for their computer data base (or their equivalent) will be submitted to the
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NRC in the future -in place of the statement of concern forms presently being submitted. The new forms, which are in the standard files now being implemented by the ECP-SRs and were reviewed by the NRC inspectors, appear to be adequate for NRC initial review. The NRC inspectors judged that the ECP-SR final investigation reports and associated -files are adequate in quality.
Formal submittal of the new ECP final investigation reports and associated files to the NRC is not necessary (see IR 50-327/86-27, Section 5.c).
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j. lAmemberoftheTVAOIGteamwhichwillbeauditingthenewECPdiscussed with the NRC inspectors the TVA OIG current plans for their audit. They will review and evaluate procedures and files, and interview ECP-SRs and other ECP personnel. The OIG team intends to evaluate compliance with procedures, effectiveness of the program, and the efficiency with which the program is performed.
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The TVA ONP has just completed a survey of GNP personnel perceptions of ~
the new ECP. About 1600 survey forms were distributed, and about 1300 were returned. The results are being analyzed by personnel at the
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University of Tennessee and were not available for review at the time of this NRC inspection.
ECP personnel indicated that the results would be fomally submitted to the NRC when. completed.
1.
Interviews were held by the NRC inspectors with 30 TVA personnel assigned to the Sequoyah Nuclear Plant. The personnel were selected from a list of plant personnel provided by the Sequoyah Personnel Office; approximately 100 names were randomly selected by the NRC inspectors and circled on the list. The first 30 people determined by the Sequoyah Personnel Office to be available on the morning of September 18, 1986 were interviewed.
A set of questions was developed by the NRC inspectors to guide the interviews (Attachment 2). The Sequoyah personnel were interviewed one at a time by individual NRC inspectors.
The employees were all aware of the new Employee Concern Program. The majority of them had been at Sequoyah before February 1, 1986, and had received fomal training concerning the new ECP. Those who had joined Sequoyth since February 1, 1986 had not received (or did not remember-7-
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receiving) formal training. The sample of people in this category was too limited to provide an accurate indication of the new employee training on the new ECP, but the NRC~ inspectors believe the training should be reviewed by ECP personnel to ensure its effectiveness. Most of the personnel had seen the ECP posters and mailers which are at various locations throughout the site, although few could recall details of these items.
Most of the people interviewed felt that the new ECP was protecting confidentiality of people expressing concerns, and stated that they would go to the ECP-SR if they had a concern which could not be resolved with the supervisors.
Although many of the interviewees knew of someone who had contact with the new ECP, only a few stated that they had had direct involvement. The majority felt that management was more receptive to employee problems, and
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the interviewee's perception of the program was generally good.
Roughly one-half of the interviewers stated that the new ECP was or could be misused by people who had no nuclear safety-related problems. The data in Attachment 1, which shows that 207 of the 461 concerns were classified as Management and Personnel (M&P) and 55 percent of these are not nuclear safety-related, tends to support this perception.
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Conclusions a.
Implementation of procedures for the new ECP, development of data for tracking and trending the progress of the program, use of the data base from the Employee Concerns Task Group program (Watts Bar Special Program),
and content of the investigation files and reports have all substantially improved since the previous inspections.
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b.
A potential problem regarding tracking and timely resolution of generic
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concerns were ideni;ified by the NRC inspect'on team. TVA was aware of the potential problem regarding generic concerns and was in the process of determining and assigning responsibility for its resolution, c.
The NRC inspectors identified a possible area of misunderstanding related to protection of the confidentiality of concerned individuals who contact the ECP-SRs.
ECP personnel agreed to review the " Confidentiality Understanding" statement to determine if it should be revised or explained differently during interviews, d.
A survey by the NRC inspectors of 30 randomly selected TVA employees at Sequoyah indicated that most employees are aware of the new ECP, believe i
that it protects confidentiality, and would use it to resolve concerns if
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they did not get satisfactory resolution from their supervisors. Many of the interviewees believe the new ECP is being overloaded with non-nuclear safety concerns of questionable importance, a perception which appears to be supported by the data available to date.
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JGUST DESC/ SITE WBN CFN BLN SON KNOX CHAT TOTAL RECEICE YTD 205
31
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461 INV COMPLETE
55
51
12 221 REPT TO LINE
46
20
9 121 CLOSED YTD
37
12
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OPEN(REC-INV)
137
13
9
240 RECEIVE NSR
31
23
5 157 IG REFERRAL
1
5 O
O
CATEGORY WBN BFN BLN SON KNOX CHATT TOTAL-RECEIVE YTD OA
8
3
2
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MC
2
0
1
38
49
19 207
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IH
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15 O
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OP
19
7
0
0
O O
12 CO
9
3
0
SF
6
8
0
3
21 TOTAL 205
31
26
461
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NUCLEAR WBN BFN BLN SON KNX CHA TOTAL SAFETY RELATED RECEIVE YTD
31
23
5 157 INV COMPLETE
17
8
4
REPORT TO LINE 7
4
5
38 CLOSED
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3 4.
23 IG REFERRAL
1 O
O O
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OPEN (REC-INV) 58
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5
98
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CATEGORY WBN BFN BNP SON KNOX CHATT TOTAL RECEIVE YTD %
9
3
9
MC
2
0
4
43
56
83
IH
5
17 O
O
OP
22
8
0
0
0
4
CO
10
3
0
,5 SF
7
9
0
3
0
TOTAL 100 100 100 100 100 100 100 Attachment 1
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t 99nnt190_ Set:1: Employee Knowledge of the Program Are-you aware of the ECP7 How -did.you become aware of the ECP7 Did you receive training which covered what the ECP was and how it functioned?
Have you seen the posters and mailers at different locations throughout the site?
If you just joined the Sequoyah organization, were you given fliers that described the ECP?
Were these fliers clear and understandable?
pygglign_Sgt-2: Confidence in the ECP.
If you had a concern, would you take it to the ECP7 Why or why not?
Do you think that the ECP is accomplishing the job it was formed to do?
Do you feel that the ECP protects the confidentiality of concerned employees?
999H1190.6g1:2: Use of ECP Do you know of anyone who ever had contact with the ECP7 As a result of the ECP being formed, do feel that line management is more receptive to concerns raised by employees?
If you have gone to the ECP, after your discussion with the ECP site representative, did you still identify a concern to the site rep or did you return to your direct manager?
What do you think the general perception of the ECP is among the various workers at Sequoyah?
Elcal_Guent190 Do you have anything else you would like to add 7 Attachment 2