IR 05000327/1993040
| ML20058P122 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/10/1993 |
| From: | Brady J, Kellogg P, Scott Sparks NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058P116 | List: |
| References | |
| 50-327-93-40, 50-328-93-40, NUDOCS 9312230082 | |
| Download: ML20058P122 (19) | |
Text
I
-. ..
_
i o UNITED STATES
- ~?gn ac % -
!
'
NUCLEAR REGULATORY COMMISSION g, OS REGION tl
- - 3 101 MARIETTA STREET. N.W. SUITE 2900
- ATLANTA. GEORGIA 303234199
'
.....'
Report Nos.: 50-327/93-40 and 50-328/93-40 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah I and 2 Inspection Conducted: August 16-27, 1993 Lead Inspector: / f; hfr ._
J. B. Sracy, Pfoject Engineer
$$ /93 Date Signed Inspectors: S. Sparks, Project Engineer W. Little, Senior Project Engineer
,
'
/
U/d/4%
Approved By: '
/. / _
P. J/. Kel l ooo Nr+ '- % 'Ji Date. Signed Div/s%n nf dts 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 deterinine whether adequate means existed to resolve safety concerns raised.by employee Results:
No violations or deviations were identified. In general, employee concerns were being adequately resolved. However, the CRS threshold for investigatio of technically oriented management issues was overly high resulting in 'some issues being missed. CRS management of the investigation backlog was generally adequate. Although several pre-1993 examples were identified where the independence of employee concern investigations referred to the line were
'
questionable, the inspectors noted that CRS management attention to independence during the past year was improving. Two items were identified (station blackout and feedwater heater shell welds) where the employee concern
, . , sag ..
9312230082 930916 PDR ADOCK 05000327-G PDR u
.
.- .
_
.
- ~
i .-
,
-i_ - ,
2 :
-
investigations needed to be completed so that restart determinations could be made. The conservatism exhibited by the Concerns Resolution Staff in classifying concerns as harassment and intimidation was a strengt Contractor employee concerns programs were still at an early stage from the stand point of safety-related concerns receive f
I i
5
I i
l
)
u
ansv - -
~!
!
!
!
I
_ . _ . _
< .
-l 4 :
-
'!
'
REPORT DETAILS
, Persons contacted ,
,
_
Licensee Employees j a
- R. Alsup, Quality Audit Supervisor 4
- J. Bajraszenski, Licensing Engineer '
- M. Burzynski, Engineering Manager
- T. Cosby, Concerns Resolution Program Manager- :
'
- E. Ditto, Concerns Resolution Site Representative
- Driscoll, Site Quality Manager v
- Fenech, Site Vice President .
- Newby, Concerns Resolution Site Representative ,
- Powers, Plant Manager ,
- Shell, Site Licensing Manager >
- J. Symonds, Modifications Manager
- R. Thompson, Compliance Licensing Manager :
'
- J. Ward,' Engineering and Modifications Manager Other licensee employees contacted included engineers, technicians, and ;
other admin %trative personne Contractor Employees -;
- D. Ellwanger, Bechtel Cor ,
- C, Morgan, Rust, Pullman, Cleveland 1
- C. Cronan, Stone & Webster Engineering Cor '
NRC Personnel
- R. Crlenjak, Branch Chief '
- Holland, Senior Resident Inspector
- S. Shaeffer, Resident Inspector ;
- Attended exit interview j Acronyms used throughout this report are listed in the. last paragrap ~ TVA Employee Concerns Program l
.1 Procedural Guidance
,
The licensee's employee concerns program was described in Nuclear- 1 Power Standard 1.2, revision 2, titled Concerns Resolution, which j was implemented by Sequoyah Site Standard Practice 1.2, revision -l'
3, 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' l concerns. The'first was through line supervision and the second
'
was through the Concerns Resolution Staff (CRS). The standards
.
i
-
- :-
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 instruction 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 reportin The investigation of employee concerns was addressed in Section 4.5 of the staff instruction. Section 4.5.2, Assignment of Issues for Investigation, identified that investigations may be conducted by an organization or team different from the CRS. The program guidance indicated that CRS should be-an alternate approach to concern resolution when the employee concern can not be resolved through the line function. The inspector concluded that the investigation referral must ensure adequate independence from the employee's prior resolution efforts to ensure an objective investigation is performed. Improper referral to the line ;
organization responsible for the described condition could also adversely impact the concerned employee, resulting in a loss of credibility for the employee concern progra The licensee considered that in some cases referral to the line organization responsible for the concern would be acceptable. The staff instruction identified certain attribute points that were to be considered prior to referring issues for investigation. Those points were qualifications and expertise needed to adequately evaluate the issue, protecting confidentiality when requested, being able to achieve adequate independence, the level of involvement of the organization with the concern, the organizational level to which the concern applied, and employee views and requests during discussions. Revision 3 included a recent improvement that any investigation referral to the organization responsible for the concern could only be made with the concurrence of the concerned individual. The inspectors concluded that change to be good since several files reviewed below appeared to have an appearance of independence problem Procedural guidance was considered to be goo Review of Employee Concern Files The inspectors selected 11 out of 67 safety-related CRS Employee Concern Files closed by TVA since January 1991 to determine if
> . . . ~ , . ,. . _ _ - m . . . . .. _
-
.
A
'!
- a
, ,
3 i
concerns'were adequately resolved in'accordance with the program 1
- instructions. Specifically,-the files-were reviewedLto-determine -l whether procedural guidance was followed whether-the investigation was adequate, the investigation substantiated the concern, CAQ _ !
documents were generated when required,-corrective actions were' 1 identified for substantiated concerns, whether the; corrective j actions resolved the concerns, and the concerned individual-was- i 1 informed of the results of the investigatio The following_ files a were reviewed and considered fully adequate:
.
^
ECP-91-SQ-615-F1 ECP-91-SQ-831-F1
'
ECP-92-SQ-020-F1 ECP-92-SQ-143-F1 4 ECP-92-SQ-168-F1 ECP-92-SQ-311-FI' 3 ECP-92-SQ-313-F1 ECP-92-SQ-438-F1 l
!
The following files contained deficiencies in the investigation '
,
'
!
and resolution process:
. ., i
-
ECP-93-SQ-159-F1, The CRS review of the concern identified - j technical issues related to erosion / corrosion and control- :}
air problems at Sequoyah.- The CRS investigation of the- !
technical issues consisted of reviewing licensee Incident j Investigations 11-5-92-078, II-S-92-094,~and'II-S-93-009.- ,
The inspectors noted that root causes for two of the three a Ils were identified as-hardware. issues-and preventive-
-
O maintenance techniques, and the third'II documented the root- 7 '
chuse'as management-inattention and oversight. CRS ..
considered the remainder of the concern to be beyond the :
scope of the CRS program, because the comments were general :!
in nature and related to a lack of management support for :
the programs addressed by the technical issues., CRS did :
not identify the management aspect'as a separate issue no 'I address it with.the technical issues, but instead considered 5 y them as only comments from the concerned employe j The CRS file contained a copy of the .TVA:Sequoyah Restart - :
Plan, Rev.'1, as relevant information.to the general management connents contained in the concern. A CRS file' .
handwritten note stated that the Restart Plan shows the work' i done to fix problems properly and restart safely. The CRS: !
also noted that there was no intent to provide closure to . a the general comments by inclusion.of the' Restart Plan in the !
CRS fil .1 CRS Staff Instruction 1, Section 4.4.1: required each issue ~ )
to be categorized into.one of ten categories. One category R was identified as Management and Personnel' (MP), Land-wast !
defined. in Appendix A as concerns related to the adequacy..of > i policies, management attitude'and effectiveness, organization structures, personnel management,:and personnel q
.
training and qualification, except those covered by the ;j QA/QC categor Section 4.4.4.4 and 4.4.4.5 further- clarify - .j
.
b
'-
-
, ,
- -
.
what MP issues are. Section 4.4.4.5.3 stated that Management and Personnel (MP) issues with a clear connection to a possible significant technical poblem should be accepted by CRS. It further stated that the significance of these issues will be in the judgement of the CRS-SR'and will be the basis for acceptance or rejection. Section 4.4.4. stated that the MP aspects of technical issues should be addressed as part of the resolution of the technical issues as appropriate. The inspectors concluded the contention in the concern was a contributing cause to the significant events identified was due to management lack of attention as meeting the definition and descriptions abov The inspectors held several discussions with the CRS regarding the disposition of the above management issue The inspectors concluded that substantive concerns existed relative to management policy, attitude, and effe.ctiveness on the subject issues that CRS should have evaluated this information. Specific information existed regarding the lack of funding and priorities which contributed to a recent control air water intrusion event, overall lack of attention to the control air system resulting in the loss of control air when an air compressor sequence selector switch failed (causing a dual unit runback), and technical program ,
inadequacies due to lack of resources. The inspectors concluded that the CRS did not adhere to Section 4.4.4.5 of the CRS Staff Instruction in that the technical oriented management area was not identified as an MP issue for investigation nor was it included in the investigation of the technical issues identified. CRS management did not' .
agree with the inspectors * conclusions, and maintained that treating the management aspect as comments was a management decision made at.the corporate leve *
Although the CRS did not investigate the management concerns, the informal inclusion of the Sequoyah Restart Plan (with reference to the Sequoyah Post-Restart Plan)
addressed the concerns regarding the contribution that management policies, effectiveness, and attitudes, had on recent events at Sequoyah. The' inspectors considered that the actions taken and to be taken as a result of the Restart and Post-Restart Plans were sufficient to address the management issue ECP-92-SQ-030 The issue concerned closing CAQs by. rolling the issue into design documents (DCNs/ECHs). This process apparently had allowed some DCN/ECNs to be placed on a low ,
priority with the potential for those DCN/ECNs to never be i completed due to funding re.itraints. For those cases where that occurred, no corrective action would have taken place to correct the CAQ condition. Some conditions were i identified that were several years ol w
]
?
.
-
a-
_
The CRS response to the concerned employee described the design change process, its relation to the CAQ program, and stated that the subject practices were permitted by plant procedure In addition, the response stated that the unimplemented work was reviewed to determine if any were required to be completed by a specific date. The response stated that no adverse conditions were identified. The licensee concluded internally that no corrective action was necessary. The inspectors noted that the CRS response to the concerned employee was ambiguous and did not clearly ,
state whether the issue was substantiated. The inspectors were only able to make that determination after careful review of the file and further discussion with the license The CRS investigation did not address whether the subject
'
CAQ roll-over process was fully effective from the stanopoint of timeliness of corrective action in resolving deficiencies, in addition, the investigation didn't evaluate the significance of the cumulative effects of unresolved plant deficiencies. The inspectors noted that CRS had referred the investigation of the issue to the Site Engineering Manage An independent site evaluation approximately one year later (and unrelated to the CRS investigation), identified this CAQ roll-over process to be an area of concern. As a result of this concern, Site Standard Practice SSP-3.4, Corrective Action, was revised such that CAQs requiring hardware corrective action cannot be closed until the field work is'
complete. In addition, as part of the Sequoyah Restart Plan activities, the licensee evaluated the backlog of DCNs against the restart criteri Implementation of the Restart Plan has received significant NRC inspection attentio The inspectors concluded that the prior CRS investigation of this issue had not been fully effective, and resulted.in an inadequate response to a concerned employee. The inspectors concluded that a lack of independence of the Site Engineering organization may have been a contributing cause to the ineffectiveness of the CRS investigation. The inspectors noted that revisions to the CRS Staff Instruction in July 1992 and again in July 1993 which improved requirements for the independence of investigations have underscored CRS attention to the area of independenc ECP-92-SQ-224. The CRS written response addressed only two of the three issues contained in the fil The issue not addressed related to a management decision to implement a
" team concept" at the Area Dispatch Control Center, which could allow simultaneous grid adjustments that could potentially cause a station blackout at Sequoya Discussions with the CRS indicated that the third issue was
- .- . . _ -. . -
.
.
i
- - ;
'-
.
not addressed because it was a Management and Personnel-(MP) I issue, which CRS considered outside the scope _of the CRS progra I
CRS Staff Instruction 1, Section 4.4.1 required each-issu .i to be categorized into one of ten categories.. One categor i was identified.as Management and Personnel (MP), and was j '
defined in Appendix A as' concerns related'to the adequacy of policies, management attitude and effectiveness,. _ .i
. organization structures, personnel management, and personnel training -and qualification, except. those covered by.the !
QA/QC category. Sections 4.4.4.4 and 4.4.4.5 further
~
j clarify MP issues. Section 4.4.4.5.3 stated that Management: ;
and Personnel (MP) issues with a clear connection to a possible significant technical problem should be Laccepted,by ;
CR It further stated that the significance;of:these 1 issues will be in the judgement of the CRS-SR and will be ' ;
the basis for acceptance or rejection. Section 4.4.4~. stated that the MP aspects of technical issues should be
~
addressed as part of the resolution of the technical issues ;
as appropriate. The inspectors concluded that the CRS ,
failed to adhere to the CRS Staff Instruction by not _
addressing concerns related to a potential blackout ati j Sequoya ,
A written response was provided to the concerned employee on :
two of the three concerns, and then the file was close The inspectors noted that the written response to the -
concerned employee did not clearly inform the individual ~ if z l the issues were substantiate .;
~
The concerned employee contacted CRS several months'after !
receipt of the written response because of dissatisfaction :;
with the response. The cone ~ . employee noted inaccuracies, provided cla 6.t w in, and some. additiona ,
information regarding the 3 in ;es addressed in the '1 response. The' inspectors i W that CRS reevaluated the ? '
-
information and concluded t...t the previous conclusion'and- 4 response were adequat In addition, the concerned - '!
employee: inquired about.the unaddres' sed issue related to a station blackout. The. interview record indicated that a '
dialogue occurred on the-blackout issue pertaining to tho'
CRS positio ~
'
y i The inspector determined from discussion with the CRS-- . . - -.
interviewer that the interviewer. had considerable knowledget and background in the_ area of the unaddressed issue:(control: ') ~
of grid voltage by the load dispatchers).- The interviewer had concluded, based on previous. knowledge'and experience in this area, that the hypothesized station blackout situation would not occur solely as a result of the team concept,
'
since back shifts had used that concept for at least severa q u
-
. - 1
-
.
._ t
~
^
,
L 7 l
,
years without the type of communications problems or the
'
hypothesized results. The inspector concludec sed on this
. discussion with the interviewer that the intervh. r's i background and knowledge had been used to conduct un r
.
informal investigation of the concerned employee's issu !
l However, that investigation was not documented in the employee concern file. In discussion ~with the inspectors, CRS agreed that the informal investigation should have been
-
documented, proceeded to do so, and intended to respond on the unaddressed issue to the concerned employe The inspectors noted that CRS identified the followup contact by the concerned employee as an " Inquiry" and that the concern file had not been reopened. An Inquiry was defined as contacts made to the CRS which do not meet the o definition of an issue, are adequately addressed elsewhere, or are outside the scope of the program. A closed issue was defined as one in which no further CRS action is required.
, As discussed above, CRS took action based on the interview when they reassessed their investigation results and .
evaluated the unaddressed issue. The inspectors concluded that the CRS actions did not meet the definition of an-Inquiry or for a closed issue. The inspectors concluded- ,
that the file should have been reopene ;
i The inspectors also noted that no specific guidance was-given in the CRS Instruction for the processing of employee responses of dissatisfaction with the CRS result The inspectors held discussions with the CRS regarding how CRS '!
dispositions employee responses. CRS acknowledged the lack of policy regarding how concerned employee response i information was to be dispositioned, that some guidance in '
that area was necessary, and that it would be adde l
!
With the exception of the above deficiencies and comments, the CRS~-
files reviewed by the inspectors were adequately resolvedL i
Evaluations and other supporting documentation contained in tho' !
'
files were thorough and technically adequate. Files contained sufficient documentation or references to other supporting .
documentation which would enable an-indep:.ndent reviewer to reach the same general conclusion as the CR Concern Resolution Backlog !
Tho inspector reviewed the licensee's employee concerns database to determine the adequacy of the licensee's program for insuring i that employee concerns were resolved in a timely manner. Thor- ;
inspector determined that the licensee had a total of 7 open- '
l l-concerns of which 3 were received during 1993. The remaining:4 concerns consisted of one received in 1992, two received in 1991,
,
i and one received in 1990. All open concern files received prior-to 1993 were reviewed by the inspector with the CRS to determine- 'l
L l _ _
-i
.
, . .
-
'
<-. , why the files were open and whether the issues were resolve These were: ECP-90-SQ-E50-F1, ECP-91-SQ-081-F1, ECP-91-SQ-162-F1, and ECP-92-SQ-146-F1. The two 1991' issues had the investigations complete and the corrective actions identified (classified by >
licensee as resolved), and were being held open pending completion of corrective actio The 1990 issue (ECP-90-SQ-E50-F1) had been open for three years and the investigation was not yet completed. The licensee-estimated that 2-3 man-months of time had been spent on the investigation over the past three years and that it was close to completion. Corrective ac'. ion had.not yet been identifie However, the licensee indicated tnat some would be neede .;
The 1992 issue (ECP-92-SQ-14F-F1) had been open for 18 months and ,
the investigation was not yet completed (started 2/12/92). .The issue dealt with ASME Pressee Vessel Code compliance on the welds for the feedwater heater she'is. This issue was referred to the i Corporate Engineering Manager:for investigation. The Corporate Manager referred the issue to the Site Engineering Manager who ,
provided an informal response to CRS December 23, 1992. Th response indicated that an independent consultant had-reviewed the-issue and concurred with the adequacy of the initial disposition, but the written evaluation was only 40% complete. No furthe information had been received by CRS since December of 1992. The inspector questioned the independence of the Corporate Engineering referral to the Site Engineering organization (independence referenced in Section 4.5.2 of CRS Instruction 1) since the ,
independent consultant was contracted by the site engineering organization which had originally been -involved in this issu The licensee's Site Engineering Manager discussed the status of the investigation with the inspector. The Engineering Manager . 3 previously involved had been replaced and the new manager had.been in place for approximately 3 months, which indicated that ha' was: l independent from the previous decisions. The Engineering Manager !
indicated that he had talked with the consultant and was changing- .1 the licensee's approach on this issue as compared to the stated ;
position in the December 1992 memorandu ;
' :l The inspectors concluded that the backlog was generally being - i adequately managed. However, the two above issues had remained 1 open for an excessive amount of time without the investigations l being complete !
J Repetitive Issues 'l 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
!
!
I z
i
.- ,
i l
<
. 2_ ,
-_ 2
-
-9 I i
previous concerns could indicate some level of dissatisfactio l The inspector considered that repetitive-concerns from the sam s individual could indicate a weakness in getting employee concerns :
resolved. There were a total of-119 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 six individuals who had provided more- '
than one concern and had submitted at least one' concern since January 1990. Concerns reviewed included:
ECP-86-SQ-556-F1 ECP-87-50-049-99 ~
ECP-91-SQ-616-F1 ECP-91-SQ-620-F1 ECP-89-SQ-B45-F1 ECP-90-SQ-G92-F1 ECP-91-SQ-056-F1 ECP-89-SQ-C72-F1 ECP-91-SQ-H43-F1 ECP-89-SQ-H31-F1 ECP-90-SQ-G08-F1 ECP-89-SQ-754-F1 ECP-91-SQ-294-F1 ECP-86-SQ-025-F1 i
ECP-86-SQ-281-F1 ECP-89-SQ-755-F1
-
ECP-90-SQ-H20-F1 ECP-90-SQ-T29-F1 ECP-91-SQ-249-F1 ECP-91-SQ-318-F1 ECP-91-SQ-433-F1 ECP-92-SQ-130-F1 ,
The inspector noted no apparent repetitiveness of concerns for the six individuals reviewed. Further discussions with CRS indicated that several concerned individuals had expressed the same concer twice. One of those was associated with ECP-91-SQ-250-F1 and the other with ECP-92-SQ-224-F1, which was reviewed in paragraph 2b :
abov In these cases where an employee had~come back.and disagreed with the CRS resolution of the issue, the. contact was treated as an inquiry, and placed in the associated concern' fil ,
Inspector discussion with CRS concerning this practice is contained in paragraph 2b abov 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 t from January 1990 through June 1993 to determine if the Sequoyah ,
Concerns Resolution Staff (CRS) had properly identified employunt 1 concerns involving potential harassment and intimidation-(H&I),:
and had referred those identified to the TVA/IG for investigatio *
The inspector determined through discussion with the-licensee and I by sampling concern files that H&l_ had been properly identified and that all H&I files had been properly referred to the IG-for-investigation. There were no TVA/IG investigation substantiations ;
for H& . ;
i
,
P
.. _
- s "
( ,
No violations or deviations were identifia Employee concerns were generally being adequately resolved. However, the CRS threshold for investigation of technically oriented management issues was overly high resulting in some issues being missed. H&I concerns were being conservatively referred to the TVA-IG. CRS management of the investigation backlog was generally adequate. Although several pre-1993 examples were identified where the independence of employee concern investigations referred to the line were questionable, the inspectors noted that CRS management attention to independence during the past year was improving. CRS guidance was needed on how to handle concerned employee negative responses to CRS investigation results . Two items were identified (station blackout and feedwater heater shell weld)_ where the investigations needed to be completed so that restart deteminations can be mad . Contractor Employee Concern Programs SSP 1.02, Section 3.2, Contractor Responsibilities for Resolving Concerns, provides guidance and expectations for contractors'
responsibilities 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. These included providing a
'
mechanism for their employees and subcontractors to report safety and quality issues, 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&l received, and maintain documentation of the resolution of safety and quality issue The inspector reviewed with the CRS site representative the list of all contractor organizations on site (26) 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 subcontractor 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, the investigation was adequate, the investigation substantiated the concern, CAQ documents were generated when required, corrective actions were identified for substantiated concerns, the-corrective actions resolved the concerns, and the concerned individual i was informed of the results of the investigatio I Bechtel Bechtel Corporation provides contract support to the modifications organization. The Bechtel employee concerns program was described ,
'
in the Bechtel procedure titled Employee Concerns Resolution Program, Revision 1, dated june 10, 1993. Review of the procedurr ,
.
I
.
._
'
,
%
-
noted several administrative problems with the procedure in describing where the concern is~ documented, documentation of l
'
investigation results, and response to the concerned individua Bechtel ECP representatives estimated that approximately 2300 exit interviews had been conducte Bechtel employee concern representatives indicated that the program is discussed with :
employees on a regular basis. Bechtel provided Revision 2 to the procedure dated August 19,.1993, which adequately addressed the inspector's comments. Bechtel had received 15 employee concerns, one which was safety-related. The inspectors reviewed the one'
safety-related concern file (93-007) and determined that it was adequately resolved in accordance with the. program instruction Stone and Webster Engineering Corporation (SWEC)
SWEC provides contract engineering service The SWEC employee -
concern program was described in the SWEC Project. Procedure SQNPP '
2-7, Revision 0, Interface with the Employee Concerns Program, dated October 16, 1991. SWEC had not received any employee concerns. The procedure provides for employees raising concerns through their.line management or the TVA employee concerns program. After discussion with SWEC management, the inspector = ^ 'j concluded that SWEC did not have their own employee concerns program independent from TVA's program. That appeared to be- :
contrary to the intent of SSP 1.2 Section 3.2 stated above. Th ,
inspector discussed this fact with the. site CRS organization,.
members of which had conducted an audit of the contractor. The i inspector concluded that they had knowledge SWEC did not hav o separate employee concerns program. The audit report did not .
'
identify that fact as the auditor did not feel it was significan enougtn to be an audit finding. As a result, the corporate CRS Manager was unaware the situation existeri until it was identified '
by_the inspection team. SWEC issued Revision 1 to SQNPP 2-7'on August 25, 1993, which included an employee concerns program ,
separate from CRS. The inspector considered the procedure adequat ~
_. g% i Rust, Pullman, Cleveland (RPC)
RPC was performing the site security system upgrade. The RP [
program was described in the RPC Site Procedure titled Employee '
Concerns Program, dated November 4,.1992. Review of the precedure '
noted several administrative problems with the procedure'in ._
describing where.the concern is documented, documentation ofi L investigation results, and response to the concerned individua :
RPC issued Revision 1 to the procedure on August 25, 1993, which addressed the inspector's comments. RPC had received 12. employee-concerns, of which one related to safety. The inspectors revleued !
the one safety-related concern file (MAR 93) and determined that -
it was adequately resolved in accordance with the' program instruction pg
.
.
t
~~
r -_ ym ,__ ___ L
.
. . . .. n,r
' No violations or deviations were identified. The inspectors concluded that the contractor employee concerns programs were still at an early stage from the stand point of safety-related concerns receive Procedural changes made during t9a inspection improved program guidanc . Employee Perception Intervicws were conducted with 221 persons at the Sequoyah site for TVA and the various contractors. The objectives of the interviews were to evaluate the awareness and use of the licensee and contractor employee concerns programs, and to evaluate the willingness of persons to identify quality or safety concerns to their supervision or management without fear of retributio The sample size was selected to include a large cross section of laborers, craftsmen, engineers, operations personnel, supervision, and-management from all three shifts currently working at SQN. The inspectors selected the persons to be interviewed from an alphabetical computer listing of the employees for each major contractor'and for TV The method used was to select a starting point, which was varied.for.
each organization, and then selecting every tenth person thereafte The table below summarizes the number of interviews conducted for each contractor and TVA, the questions asked, and the results. In interpreting the interview results, if a person stated that he wa unsure about the existence of his employers program this was counted as his not being aware that the program existed. Many of the Bechtel. and -
SWEC interviewees were former TVA employees and their experience and'
attitudes toward employee concerns programs reflected their experience as a TVA employee, s
?
!
t
-
.
.
-
-
M
i
- , & -.
!
-- --- . . . .
, :
.& - _=_ l
-
-
L 13
SUMMARY OF INTERVIEWS CONCERNING USE OF ECP AND CRS TVA BECHTEL SWEC RPC MSC SUM Aware of Contractor ECP NA 35 17 10- NA- 62 j d
,
! Aware of TVA CRS 129 53 22 14 1 219 Would Use Either ECP or CRS- 122 50 23 14 1 210
]
Have Used ECP or CRS 18 8 2 0 0 28 j L Would Use ECP or CRS Again 16 8 2 NA 26-Would Not Use ECP or CRS 2 0 0 0 2 L l Would Raise Concerns to 127 52 '23 14 1- 217 1 Suoervisor
!
EC Program Independent of Line 123 49 23 15 1 211 Management Needed
'
Number of Persons Interviewed 129 53 ?3 15 1 221 Total Persons On Site 1535 579 243 155- 75 2587
A review and evaluation of the -interview results by the inspectors resulted in the following conclusions:
- Everyone interviewed 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 NR Very few people had used either the ECP or CRS - 14% for TVA and ,
11.0% for the three major contractor (Most of the experience '{
was not as recent as the last three years.)- ;
- A significant percentage of those who had used the program would i do so again - approximately 93% for TVA and the contractor ;
Several indicated that they were not satisfied with.the resolutio .!
of their concerns, but would use the programs'again. The inspectors noted that some of the dissatisfaction centered around the resolution of personnel issues rather than safety or quality ,
issue Approximately 98% of all persons interviewed would raise quality or safety concerns ~to their supervisio Approximately 95% of the persons interviewed felt that an independent path to report concerns, such as ECP or CRS,.needed to exis ,
.i i '
.
l * 5 .
i /
- P
'
,
- A significant number, approximately 32%, of the contractor employees were not aware of the-contractor ECP However, - all ~ but ..
two interviewed indicated that they were aware that they could use the TVA CRS program. The inspectors concluded that essentially all contractor employees were aware of and had access to an '
employee concerns program (either the contractor's or TVA's).-
No violations or deviations were identifie . Employee Concern Program Audits and Management Involvement :
The Quality Assurance organization performed an. audit (SSA92204) of 7 Corrective Action / Correction of Deficiencies which was _ issued July 14, . ,
1992. The audit included a review of the Conc 9rns Resolution program to ,
ensure the emoloyee concerns were documented and resolved in a .
,
satisfactory manner. The audit reviewed five emp nyee concern. files at Watts Bar. The audit concluded that the investigations and actions were
-
appropriate and adeouate 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 closecut
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- 4 concerns were adequately investigated and that appropriate corrective actions were taken. The audit team did not find any corrective actions-that had not been taken. In discussing the audit recommendations with ,
the CRS site representative and CRS manager, the inspector learned that-the recommendation had not been completely implemente 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 QA 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 noted that file !
organization at Sequoyah was not as good as it was at the Watts Bar -l sit l 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 May 14, 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. None of the contractors j had received any concerns at the time of the audi j The audit revealed that all contractors had programs in compliance with ;
l '
'
the requirements, all contractor personnel displayed a desire to l
establish and maintain an atmosphere free of intimidation and harassment-l
.
A
_
l
. -, 1
_
k
-
in which quality and safety issues can be identified, and STD 1.2 was i
being adequately implemente The audit identified the following i deficiencies: Information describing the EC programs (contractors and TVA) was- l not contained in the orientation packages of two contractor i Orientation training for the EC program was not being documented !
by one contracto i Each contractor received a copy of their portion of the audi Responses from the two affected contractors were requested within 30 i days. The RPC response was received on May 26, 1933,. and adequately resolved the deficiency. The SWEC response was received on August _12, :)
199 The following three shortfalls were identified with the CRS contractor !
audit which resulted in it not being fully effective. First, because the contractors had not yet received any concerns, the audit was not <
able to adequately review program implementation. Second, paragraph 3b
-
I above identified that SWEC did not have an. independent ECP that was.in- ;
compliance with STD 1.2, which contradicted the published audit resuit ;
'
Third, 68% of the contract employees were aware that their employer had an employee concern program as compared to the 97%. number that was-obtained by the CRS audit (see paragraph 4). Discussion with CRS ,
concerning the third discrepancy revealed that NRC questions were more specific than those asked by the CRS audit. Contractors may have been responding about awareness of the CRS. program in the audit.as compared :
to their employer's EC The inspector reviewed an audit conducted by TVA's 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 commitmeat to the NRC to report periodically on_ the effectiveness of_ the CRS program. The stated objecties were to determir.e if CRS complied ;
,
with its policies and operating procedures, closed investigative-casesc ~
in a timely manner, and added value by operating in an effective manne The audit was conducted of all TVA sites. The audit found that: CRS generally complied with its policies and procedure . On the average, CRS and TVA management appeared to resolve j l- concerns in a timely manne ;
1 . . CRS's effectiveness at resolving employee concerns could not 1 L be determined because (1) NRC would not provide details:
related to concerns expressed directly to NRC, (2) view varied widely concerning the program's effectiveness, and' 1 (3) the results of TVA/IG surveys were inconclusiv '); NP's subsequent decision not to close its SQN site offic appeared reasonabl P
-
l
~ ._
$
, _
____ __ .. .. . , _- _ . ..
E .. a; W .,- d_
. n ,
16 .
The inspector concluded that individually. the audits.did not cover the :{
entire employee concerns program. The QA audit. reviewed closed-files ;
for technical effectiveness of corrective action. The CRS' contractor- !
review audited only the contractors. The TVA/IG audit evaluated the j overall CRS program except for technical effectiveness. However, .!
collectively they adequately addressed'the scope of the employee j concerns programs. Although the inspectors found some' items-missed by i the audits, the audits were considered _ successful in providing :
management a tool to assess the employee concerns program ;)
i The inspector interviewed licensee senior management to determine their level of involvement and support for the employee concerns programs. . j The inspector found the senior line management to be supportive of the Li program and resolution of issues, and also. supportive, of the program's! ..
independence from line management in taking concerns.: The inspector a determined that management involvement:and awareness of thefemploye y concerns program at- the corporate and- site level was adequat :;
-
No violations or deviations were identifie .; Employee Concerns Program Survey (TI 2500/028) ** j The inspectors also conducted a Employee Concerns Program survey. - The! d purpose of the survey was to determine whether licenstes' have .
implemented an employee concerns program, and if-so, determine the characteristics of that program. The above inspection effort y constituted the basis for completion of the survey. The. documentation 'j form shown in the Appendix to this Inspection Report contains the
~
compilation of information'obtaine . Exit Interview (30703)
~
The inspection scope and findings were summarized on August 27,'1993 j
.
.
with those persons identified in paragraph 1. The-inspectors _ described the areas inspected and discussed in detail the inspection finding j The licensee did not identify as proprietary any of the material i reviewed by the inspectors during the inspection. Dissenting comments were not received from the licensee. Proprietary information is not g contained in this repor . !
Inspection' Findings:
No violations or deviations.were identifie In general, employees concerns.were'being adequately resolved. However, the CRS threshold fo investigation of technically oriented management issues was overly high resulting in some issues being missed.- CRS management of.the- 1 investigation backlog was generally adequate. - Although several pre-1993l R examples were identified where the independence of nployee. concern ~ j investigations referred to the line were questionable,:the-inspectors 1 noted that CRS management _ attention to independence during the past' year-was improving. Two items were identified (station blackout and- *
~
\
-
.q
~~ n:. - -: -
.: '
.
-4
?- --
.- i
'
i feedwater heater shell weld) where the employee concern investigations ;
needed to be completed so that restart determinations could be mad The conservatism exhibited by the Concerns Resolution Staff in classifying concerns as harassment and intimidation was a strengt Contractor- employee concerns programs were still at an early stage from the stand point of safety-related concerns received.-
I 8. List of Acronyms and Initialisms )
ASME American Society of Mechanical Engineers 1 CAP Corrective Action Plan i'
CAQR Condition Adverse to Quality Report CAQ Condition Adverse to Quality I
'
CATD Corrective Action Tracking Document CI Concerned Individual CRS Concerns Resolution Staff CRS-SR Concerns Resolution Staff Site Representative DCN Design Change Notice <
'
D0L Department of Labor ECN Engineering Change Notice ECP Employee Concern Program ECSP Employee Concern Special Program DCN Design Change Notice i
H&I Harassment and Intimidation l Incident Investigation
'
l II MSC Miscellaneous NP Nuclear Power
,
QA Quality Assurance
!
QC Quality Control QE Quality Engineering RII NRC Region II RPC Rust, Pullman, Cleveland i
"
SSP Site Standard Practice STD Nuclear Power Standard SWEC Stone and Webster Engineering Corporation TI Temporary Instruction j TVA Tennessee Valley Authority l TVA/IG TVA Office of Inspector General
-
.
'
!
I l
t l
l
.