IR 05000341/2024011

Nbsp;Safety Conscious Work Environment Issue of Concern Follow-up Inspection Report 05000341/2024011

ML24067A189
Person / Time
Site:	Fermi
Issue date:	03/08/2024
From:	Billy Dickson NRC/RGN-III/DORS/RPB2
To:	Peter Dietrich Detroit Edison, Co
References
IR 2024011
Download: ML24067A189 (1)

Text

SUBJECT:

FERMI POWER PLANT, UNIT 2 - SAFETY CONSCIOUS WORK ENVIRONMENT ISSUE OF CONCERN FOLLOW-UP INSPECTION REPORT 05000341/2024011

Dear Peter Dietrich:

On January 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Fermi Power Plant, Unit 2 and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Billy C. Dickson, Jr., Chief Reactor Projects Branch 2 Division of Operating Reactor Safety Docket No. 05000341 License No. NPF-43

Enclosure:

As stated

Inspection Report

Docket Number: 05000341

License Number: NPF-43

Report Number: 05000341/2024011

Licensee: DTE Electric Company

Facility: Fermi Power Plant, Unit 2

Location: Newport, MI

Inspection Dates: January 02, 2024 to March 31, 2024

Inspectors: M. Keefe-Forsyth, Safety Culture Program Mgr.

R. Sigmon, Senior Reactor Systems Engineer

Approved By: Billy C. Dickson, Jr., Chief Reactor Projects Branch 2 Division of Operating Reactor Safety

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Safety Conscious Work Environment Issue of Concern Follow-up Inspection at Fermi Power Plant, Unit 2, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===93100 - Safety Conscious Work Environment Issue of Concern Follow-up

Over the last two years the NRC Resident Inspectors at Fermi had been closely monitoring the safety conscious work environment (SCWE) due to observations and interactions with plant staff. Some of these observations involved Radiation Protection (RP) staff but other examples involved staff from others licensee departments including the Quality Assurance group. These observations did not reach the threshold for documentation in any inspection report.

During the performance of the Biennial Problem Identification and Resolution (PI&R) Inspection at Fermi in late 2023, the NRC inspectors determined that there was a perceived environment that discouraged RP staff from initiating condition reports. Specifically, during the PI&R focus group discussions, all RP technicians participating stated that they were willing to raise safety concerns to their first-line supervisors but would not write condition reports for fear of retaliation, embarrassment, and/or it would be closed out to the initiator just having a beef with management with no actual resolution taken. (See Fermi Power Plant, Unit 2 - Biennial Problem Identification and Resolution Inspection Report 05000341/2023010 (ML23340A032)).

Therefore, the NRC determined that an assessment of SCWE at the Fermi Power Plant, Unit 2, using Inspection Procedure (IP) 93100, Safety Conscious Work Environment Issue of Concern Follow-up was appropriate.

The purpose of this IP 93100 inspection was to determine if indications of a chilled work environment exist; if employees were reluctant to raise safety or regulatory issues; and if employees were being discouraged from raising safety or regulatory issues at Fermi. The inspection consisted primarily of reviewing licensee SCWE assessments, reviewing SCWE related issues documented in the licensees Corrective Action Program (CAP), observing plant activities, and conducting interviews with plant workers. During this inspection, the team conducted focus groups and interviews with individuals from Operations, RP, Maintenance, as well as supervisors and managers. In addition, the team interviewed the department managers for Operations, RP, and Maintenance, the Employee Concern Program (ECP) manager.

Safety Conscious Work Environment Issue of Concern Follow-up===

(1) Review of SCWE at Fermi

INSPECTION RESULTS

Assessment 93100 Safety Conscious Work Environment

Overall Assessment of SCWE The team did not note any current indications of a chilled work environment within the RP department. Licensee staff in this department and other staff who were interviewed were all willing to identify and raise nuclear safety issues and did not fear retaliation. The team interviewed all available employees

(22) from the RP department, some randomly selected employees from the Maintenance and Operations departments, as well as supervisors and managers, and the ECP manager.

Willingness to Raise Safety or Regulatory Issues Based on focus group discussions held with employees, focusing on the RP department but also including personnel from the Operations and Maintenance departments, the team determined that employees generally felt free to raise nuclear safety concerns without fear of retaliation. However, the team noted that with the recent transition of the sites Corrective Action Program (CAP) system to a new software package, some workers, particularly contractors, felt challenged with the new program due to a lack of familiarity and training that was not uniformly available to everyone. This lack of familiarity and training caused some individuals to express reluctance about using the new software, relying instead on supervisors to initiate condition reports. The team noted that steps already underway to provide one-on-one training for the new software within the RP department were well-received by those who had participated.

Corrective Action Program There appears to be a misconception about the purpose of the CAP amongst the staff the team interviewed. Condition Reports (CRs) are not meant to be punitive, but some communications imply that if action is not taken, a CR will be written, which could lead to a perception that initiating a CR is intended to have negative consequences for someone.

Employees also expressed skepticism that raising concerns would make a difference, as it was felt that if a CR was initiated, it would be closed to trending, closed to a work order that would never be scheduled, or assigned as work back to the originator of the issue. This appears to represent a fundamental lack of understanding about what the purpose of the CAP is - that owning a CR does not mean that person is required to do the work; that trending failures, even if the problem was immediately fixed has safety value; and that writing a CR is not in any way some kind of negative action. It is a way to initiate the process for ensuring deficient conditions are appropriately addressed.

ALARA and Work Process Controls There were concerns raised in discussions with RP department personnel, validated in interviews with members of other departments, that there is a perception amongst the licensee staff that radiological safety is not held to the same standard as industrial safety. The licensee staff provided examples regarding choices made across the organization up to management levels to sacrifice dose impacts in the name of efficiency, a production-over-(radiological) safety mentality. The RP department feels they shoulder the burden for radiological safety for the entire site, especially in contrast to industrial safety, which is recognized as the responsibility of every individual. There appears to be an opportunity to incorporate ALARA better (as low as reasonably achievable) and dose planning into the work planning process to raise awareness of radiological safety while better coordinating work in high radiation areas across the departments to minimize dose. This effort could also alleviate concerns in the RP department about whether current staffing levels will be adequate to meet the workload demands.

Other Observations The team heard from long-term contractors that they dont feel they are as respected as in-house DTE employees. When asked about hesitancy with raising concerns, some contractors stated that there is a potential that a contractor could be seen as rocking the boat if they were to raise a concern, and that could potentially impact their jobs. It should be noted that every contractor interviewed stated they would be willing to (and had) raised safety concerns. However, the inherent tension of the more tenuous nature of a contractors job is a management and communication challenge that requires maintaining awareness of the need to reinforce that raising safety concerns is a good thing constantly.

The licensee captured the teams observations in the CAP as follows:

CR-2024-36020, NRC SCWE Inspection Observation - Perception of Production Over Safety (Radiation Safety)

CR-2024-36022, NRC SCWE Inspection Observation - Site Over-Reliance on RP CR-2024-36023, NRC SCWE Inspection Observation - Long-Term Contractor Support

No violations or findings of significance were identified during this inspection.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On January 31, 2024, the inspectors presented the Safety Conscious Work Environment Issue of Concern Follow-up Inspection results to Peter Dietrich and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

93100 ALARA Plans 231029 Drywell/Reactor Building Steam Tunnel Emergent Work 08/18/2023

Corrective Action CR-2023-32672 Prioritization of Refuel Floor Work Activities Increased Both 08/29/2023

Documents Industrial Safety and Radiological Risk

CR-2023-32778 Unnecessary Dose Received When Two Techs Were 09/02/2023

Directed to Enter the Drywell Basement to Take Pictures of a

Condition Already Reported

CR-2023-33183 NRC Identified: Lack of Written Guidance for Initial ECP 09/20/2023

Screening of Anonymous CRs

CR-2023-33970 PO 23-01 Drywell 2nd Floor Entry Deviations from RWP 10/24/2023

Instructions

CR-2023-33980 Potential Safety Culture Concern 10/25/2023

Corrective Action CR-2024-36020 NRC SCWE Inspection Observation - Perception of 02/01/2024

Documents Production Over Safety (Radiation Safety)

Resulting from CR-2024-36022 NRC SCWE Inspection Observation - Site Over-Reliance on 02/01/2024

Inspection RP

CR-2024-36023 NRC SCWE Inspection Observation - Long-Term Contractor 02/01/2024

Support

Miscellaneous NAQA-22-0045 2022 Nuclear Safety Culture Assessment Report 09/19/2022

NG-22-0011 Second Trimester 2022 Nuclear Safety Culture Report 11/21/2022

NG-23-0003 Third Trimester 2022 Nuclear Safety Culture Report 02/10/2023

NG-23-0007 First Trimester 2023 Nuclear Safety Culture Report 06/30/2023

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