IR 05000346/1993017

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Insp Rept 50-346/93-17 on 930814-0924.No Violations Noted. Major Areas Inspected:Action on Previous Insp Findings, Operational Safety,Surveillances,Maint & Followup of Ti 2500/028
ML20059A444
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 10/14/1993
From: Lanksbury R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059A442 List:
References
50-346-93-17, NUDOCS 9310260333
Download: ML20059A444 (15)


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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-346/93017(DRP)

Docket No. 50-346 Operating License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, OH 43652 Facility Name: Davis-Besse Nuclear Power Station Inspection At:

Oak Harbor, Ohio Inspection Conducted:

August 14, 1993, through September 24, 1993 Inspectors:

S. Stasek J. M. Shine D. Kosloff R. K. Walton Approved B : N7 MLN

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1sR. D. Lanksb&fy, Chief Reactor Projects Section 3B

Inspection Summary Inspection on August 14. 1993. through September 24, 1993

{ Report No. 50-346/93017(DRP))

Areas Inspected: A routine safety inspection by resident inspectors of action on previous inspection findings, operational safety, surveillances, maintenance, and followup of Temporary Instruction (TI) 2500/028.

Results: An executive summary follows:

Plant Operations:

Overall, performance of the operating crews was adequate this inspection period. However, some instances were noted where administrative control processes were not adequately implemented (paragraph 3.b).

Inspector review was not complete at the end of the inspection period, but the root cause appeared to be inattention-to-detail in each case. An unresolved item was initiated to track completion of inspector review of this matter.

Logkeeping was, in general, sufficient to reconstruct shift activities.

The control room continued to be conducted in a professional manner during this period.

i Maintenance:

Surveillance and maintenance activities observed during this

inspection period were conducted in accordance with required procedures and regulatory requirements. Acceptance criteria associated with one test was not j

initially met due to the failure of a component cooling water valve failing to 9310260333 931014 PDR ADOCK 05000346 G

PDR

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fully close (paragraph 4). The root cause was determined to be a low pneumatic pressure setpoint for the associated pressure regulator.

Further followup is necessary to determine the cause of the established setpoint being low and will be tracked as an inspection followup item pending that determination.

i Enaineerina: During calibration of the #2 containment hydrogen analyzer, an

inadvertent short circuit deenergized the #2 analyzer concurrent with a

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failure of the #1 hydrogen analyzer (paragraph 5.b).

The inspectors raised some questions as to the level of electrical and physical separation' required for that system.

This matter will be tracked as an inspection followup item pending resolution of those questions.

Plant Support: Adherence to the radiation protection and onsite security programs was good this inspection period with no substantive problems noted.

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Also, a review was conducted per Temporary Instruction (TI) 2500/028.of the

licensee's employee concerns program with no concerns identified, t

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DETAILS 1.

Persons Contacted Toledo Edison Company

  • L. F. Storz, Vice President, Nuclear
  • G. A. Gibbs, Director, Engineering
  • S. C. Jain, Director, Nuclear Services
  • J. K. Wood, Plant Manager T. J. Myers, Director, Nuclear Assurance J. W. Rogers, Manager, Maintenance J. Dillich, Manager, Radiation Protection
  • S. Byrne, Manager, Plant Operations
  • L. D. Myers, Shift Supervisor
  • B. Donnellon, Manager, Plant Engineering
  • J. Holden, Manager, Design Engineering J. E. Moyers, Manager, Quality Assessment D. Crouch, Superintendent, Mechanical Maintenance
  • G. Honma, Supervisor, Licensing
  • D. P. Ricci, Supervisor, Operations
  • R. C. Zyduck, Manager, Nuclear Engineering
  • G. Skeel, Manager, Security
  • W. O' Conner, Manager, Regulatory Affairs
  • G. J. Helssen, Superintendent, Electrical Maintenance
  • G. R. McIntyre, Supervisor, E/C Systems
  • T. Haberland, Manager, Planning
  • N. Peterson, Engineer, Licensing
  • D. Hochhausler, Licensing
  • Denotes those licensee personnel attending the September 24, 1993, exit meeting.

2.

Followuo of Previous Inspection Findinas (927011 a.

(Closed) Unresolved Item (346/92005-02(DRP)): On April 27, 1992, the licensee documented a potential environmental qualifications concern related to an error in a previously assumed calculation.

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An error was made by a contractor in the mid-1980s for modeling the condensing heat transfer mechanism of a computer code which generated temperatures in rooms affected by postulated high energy line breaks (HELBs). The licensee detected the error after purchasing a similar computer code which calculated higher peak room temperatures. The licensee documented this via LER 92-004,

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"Part 21 Report of HELB Analysis Error."

The licensee took short term corrective actions to mitigate the effects of a HELB outside containment and developed a-plan of action to address permanent corrective actions as discussed in Inspection Report 50-346/92005. As a long term solution to mitigate the effects of a HELB outside containment, the licensee j

replaced its safety features actuation system containment pressure l

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transmitters with models which were environmentally qualified for the new temperature profile. Additionally, steam supply pipe

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supports were modified or removed to eliminate postulated breaks as allowed by Generic Letter 87-11. The inspectors toured the areas of concern and reviewed the licensee's modification package and work orders with no substantive concerns noted.- This item is closed.

b.

(Closed) Open Item (346/92017-02(DRP)):

Loose flange bolts on the containment purge system. The flange consisted of approximately 36 bolts mated through a gasketed type seal. With seven loose-

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balts identified, an air-tight seal was still maintained and no indication of leakage was noted.

Further reviews were done and walkdowns performed of similar type flanges.

No further problems were noted. Although the licensee was not able to conclusively determine why those particular bolts were loose, it appeared to be an initial construction problem. Since there was no leakage path

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in the one identified instance, the particular configuration was corrected, and no further examples of similar problems were identified. This item is closed.

3.

Operational Safety Verification (40500) (71707) (92701)

The inspectors observed control room operations, reviewed applicable logs, and conducted discussions with control room operators during the

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inspection period. The inspectors verified the operability of selected emergency systems, reviewed tagout records, and verified tracking of limiting conditions for operation (LC0's) associated with affected components.

Tours of the auxiliary and turbine buildings were conducted

to observe plant equipment conditions including potential fire hazards, fluid leaks, and excessive vibrations, and to verify that maintenance requests had been initiated for certain pieces of equipment in need of maintenance. Walkdowns of the accessible portions of the following systems were conducted to verify operability by comparing system lineups

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with plant drawings, as-built configuration, or present valve lineup lists; observing equipment conditions that could degrade performance; and verifying that instrumentation was properly valved, functioning, and calibrated.

Emergency Diesel Generator 1-1 and 1-2

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Station Blackout Diesel Generator (SB0DG)

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High Pressure Injection (Trains 1 and 2)

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The inspectors, by observation and direct interview, verified that the

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physical security plan was being implemented in accordance with the station security plan, including badging of personnel, access control, security walkdowns, security response (compensatory actions), visitor control, security staff attentiveness, and operation of security equipment.

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Additionally, the inspectors observed plant housekeeping, general plant l

cleanliness conditions, and verified implementation of radiation protection controls.

Specific observations and reviews included the following:

a.

On August 18, the licensee conducted an emergency preparedness drill. The drill was performed to evaluate the licensee's ability to implement its emergency plan and take actions to ensure the health and safety of the public. The drill consisted of a simulated steam generator tube break accident coincident with s.

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loss of offsite power.

The inspector witnessed the drill initially from the simulator control room and later from the technical support center. The inspector noted that the licensee properly classified the event and made the necessary offsite notifications within the required time limits. The associated supporting facilities were quickly activated, equipment required to support the drill was available and in a good state of repair, and personnel appeared knowledgeable of their p9sitions and assigned tasks.

b.

During a routine review of administrative controls and processes

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used by onshift personnel, the inspectors noted the following implementation deficiencies:

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1)

An entry in the Inoperable Equipment Tracking Log documented an inoperable reactor coolant system pressure instrument associated with the remote shutdown panel.

It'also specified two other instruments as being operable to meet Technical Specification 3.3.3.5 requirements.

However, in one case, the specified instrument was located in the control room which was inappropriate for meeting remote shutdown requirements, and in the other case, the specified

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instrument was not correctly identified by number.

2)

An impaired fire barrier (door 309) was noted during a routine walkdown in the auxiliary building.

The inspector

subsequently determined that an hourly fire watch was in

place and the required checks of the associated fire areas were accomplished.

However, during the review it was found i

i that the fire impairment sheet, that should have been initiated to identify and control compensatory measures (including initiation of the hourly fire watch), was not on file in the shift manager's office nor could it be located i

elsewhere.

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3)

During a review of currently outstanding temporary modifications, the inspector noted that temporary modification (TM)93-033 to " jumper out" a control room

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annunciator input had been physically installed in the plant several weeks previous. However, no individual had

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indicated on the TM that the required post installation testing had been performed, therefore, the acceptability of

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the TM as installed was not adequately demonstrated.

It was also noted that onshift personnel were unable to determine the current status of TM 93-028 for several hours i

due to not maintaining a copy of the TM 93-028 package in its required file location in the control room.

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4)

During review of the Equipment Removal / Restoration Log, the i

inspector noted that Attachment 4 of Administrative Procedure DB-0P-0000, Conduct of Operations, was not the current revision included in the log.

Attachment 4 was

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moved to Attachment 12 of the procedure as a result of the latest revision to the procedure, but had not been

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appropriately incorporated into the log.

Although inspector review of each of the. aforementioned discrepancies was ongoing at the end of the inspection period, it appeared that the root cause(s) of each related to inadequate i

attention-to-detail during implementation of the associated

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control processes. All four areas are considered, in the aggregate, as an unresolved item (346/93017-01(DRP)) pending completion of inspector review.

c.

During routine tours of the auxiliary and turbine buildings, the

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inspectors noted instances of housekeeping weaknesses in several

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areas.

Included were stepladders not properly stored and/or secured, miscellaneous trash and/or debris found within

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contaminated spaces, several oil and water leaks, and instances of boric acid buildup on leaking connections on a containment spray l

pump.

Once identified to plant management, actions were initiated

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to address each of the particular items.

i d.

In response to a regional request, the inspectors performed a brief review of the licensee's employee overtime program.

The inspectors determined that the plant technical specifications provide OT guidelines which the licensee had incorporated into

procedures and administrative controls.

The control of overtime procedure encompassed all persons, both licensee and contractor, who performed safety-related work.

Other personnel that did not perform safety-related activities were also administratively

controlled as well, but under separate program requirements.

No violations or deviations were identified in this area.

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4.

Surveillance L61726)

The inspectors observed safety-related surveillance testing and verified i

that the testing was performed in accordance with adequate procedures, test instrumentation was calibrated, LCO's were met, removal and

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restoration of the affected components were accomplished, test results conformed with Technical Specification and procedure requirements and were reviewed by personnel other than the individual directing the test, and any deficiencies identified during the testing were properly

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reviewed and resolved by appropriate management personnel.

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The following test activities were observed and/or reviewed:

DB-SP-03150 Auxiliary feedwater Pump #1 Monthly Jog Test

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DB-SP-03160 Auxiliary Feedwater Pump #2 Quarterly Test

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DB-FP-04012 Fire Hose Station Valve Operability

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DB-MI-03001 Reactor Protection System Channel #1 Functional Test

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DB-PF-3100 Component Cooling Water Non-essential Inlet Valve CC1495

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Stroke Test DB-PF-03072 Component Cooling Water Pump #1 Quarterly Test

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DB-MI-3030 Channel Function Test of RPS Channel #3

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Regarding DB-PF--3100, on September 13, 1993, the component cooling water-non-essential inlet valve (CC1495) failed to fully close during stroke testing. The valve required air to open and utilized a spring with air assistance to close.

The cause of the failure was low air pressure for the close assist portion of the air operator.

The valve had previously tested satisfactorily at the same air regulator pressure setpoint as the current test, however, previous testing was performed utilizing an open bypass valve around CC1495, reducing the amount of flow across the valve during the test. The current test was conducted under full flow conditions.

The licensee raised the setpoint of the regulator, which was still within vendor specifications. The inspector witnessed the subsequent successful stroke test. At the end of the inspection period, the licensee reviewed the adequacy of the testing associated with this valve. The inspectors will continue to review this matter as an inspection follow-up item (346/93017-02(DRP)).

No violations or deviations were identified in this area.

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5.

Maintenance (62703)

Station maintenance activities of safety-related systems and components were observed and/or reviewed during the inspection period to ensure that they were conducted in accordance with approved procedures, regulatory guides, and industry codes or standards, and in conformance with technical specifications.

The following items were considered during this review:

the LCO's were

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met while components or systems were removed from service; approvals-were obtained prior to initiating the work; activities were accomplished

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using approved procedures and were inspected as applicable; functional

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testing and/or calibrations were performed prior to returning components l

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or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological-controls were implemented; and fire prevention controls were implemented.

Maintenance work orders (MW0s) were reviewed to determine the status of outstanding jobs and to assure that priority was assigned to safety-

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related equipment maintenance which could affect system performance.

The following maintenance activities were observed and/or reviewed:

Replace Sight Glass for #2 auxiliary feedwater pump inboard

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bearing (MWO 3-93-1703-01)

Troubleshoot Detent Device Failure (CC1495) (MWO 7-93-0429-01)

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Containment Hydrogen Analyzer Channel #2 Calibration (DB-MI-03729)

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Troubleshoot Hydrogen Analyzer Channel #1 Fuse Failure Coincident

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With Channel #2 Analyzer Calibration (MWO 7-93-0415-01,02,03)

Calibration of Level Transmitter LT-1525A BWST Level SFAS Channel

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  1. 1 (DB-MI-03141)

a.

The inspectors spoke with the mechanical maintenance superintendent about an event which occurred at another nuclear power station in which maintenance workers assembled an oil lubricator in a manner such that the bearing did not receive proper lubrication. On August 27, 1993, the inspector attended a training session conducted by the mechanical maintenance department on the proper operation of oil lubricators.

The training included a demonstration of their operation and problems which could occur if improperly assembled. Oil lubricators were currently included as part of operators' routine plant rounds with lubricator levels routinely replenished as needed.

Subsequently, during a walkdown of maintenance work orders prior to removing the #2 auxiliary feedwater pump from service, a mechanic noted that an oil gauge glass of an incorrect size was staged to support a job. The detection of an erroneous piece of staged equipment indicated good attention-to-detail by the individual performing the maintenance walkdown.

At the end of the inspection period, the licensee was in the process of determining how the incorrect piece was staged in the warehouse.

b.

On September 11, 1993, the maintenance personnel, who were performing a calibration of the containment hydrogen analyzer channel #2, inadvertently induced a short circuit which caused the cabinet power supply fuse to fail. The cabinet work space was limited, and apparently contributed to the error.

Procedures were revised, as a corrective measure, to require deenergization of components in the cabinet to facilitate electrical lead manipulations to prevent recurrence.

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When the technician realized the fuse had failed for channel #2,-

channel #1 (shared cabinet) operability was questioned.

The technician determined channel #1 also experienced fuse failure.

The fuse was replaced and channel #1 was declared operable shortly thereafter. However, the hydrogen analyzer is required for post accident combustible gas monitoring, and therefore, requires redundancy and divisional separation. The licensee reviewed the

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event but as of the end of the inspection period, had not determined how the short circuit in analyzer #2 caused fuse failure of channel #1. While troubleshooting, the licensee determined that the channel #1 millivolt transformer, a seismic I component, was not adequately installed in the cabinet.

Additionally, it was found that the analyzer electrical drawings were generic vendor drawings, and not specific to the facility.

The licensee intends to further evaluate the cabinet design, and correct the drawing deficiency. The inspectors will continue to review this matter as an inspection follow-up item, (346/93017-03(DRP)).

No violations or deviations were identified in this area.

6.

Review of Temocrary Instructions (Closed) Temporary Instruction 2500/028:

Employee Concerns Program.

The inspector reviewed the licensee's process to review employee

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concerns, also designated as the Ombudsman Program.

The inspectors interviewed the ombudsman and reviewed Administrative Procedure i

NG-VP-000124, Nuclear Group Ombudsman Program. The program provided a method for individuals to report perceived safety or quality concerns and ensure that these concerns were documented, investigated and resolved.

The program received inputs from both employees and contractors for both technical and administrative safety issues.

Reports made by individuals were kept confidential and could be received in writing, by phone or during exit interviews. The concerns were resolved with feedback to the individual who made the concern, either in writing or verbally.

The Ombudsman Program was one of the methods used onsite to resolve safety issues. The licensee utilized supervisor / employee communications, quality assurance and the Vice President-Nuclear as other avenues for resolving safety issues. Workers at the site received general orientation training which discussed these methods.

The ombudsman was a part-time position which reported directly to the Vice President-Nuclear in that capacity. The program did not resolve supervisor / subordinate or personnel-related concerns which were addressed through other programs. During the inspection, no individual file cases were reviewed. The results of the inspectors review are documented on the survey form, Attachment 1, to this report.

No violations or deviations were identified in this area.

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SALP Meetina On September 16, the NRC met with the licensee onsite to present the SALP 10 results. A characterization of overall licensee performance was presented.

Strengths, as well as areas in need of further improvement were discussed.

8.

Inspection Followun Items Inspection followup items are matters that have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of NRC or licensee or both.

Inspection followup items disclosed during the inspection are discussed in paragraphs 4 and 5.b.

9.

Unresolved Items An unresolved item is a matter requiring more information in order to ascertain whether it is an acceptable item, a violation, or a deviation.

An unresolved item was identified in paragraph 3.b.

10.

Exit Interview The inspectors met with licensee representatives (denoted in paragraph 1) throughout the inspection period and at the conclusion of the inspection on September 24, 1993, and summarized the scope and findings of the inspection activities. The licensee acknowledged the findings. After discussions with the licensee, the inspectors

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determined there was no proprietary information contained in this inspection report.

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Attachment 1 NRC INSPECTION MANUAL DORS TEMPORARY INSTRUCTION 2500/028 EMPLOYEE CONCERNS PROGRAM Attachment

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EMPLOYEE CONCERNS PROGRAMS PLANT NAME: Davis-Besse LICENSEE: Centerior Energy Corp._ DOCKET #:__50/346_

NOTE:

Please circle yes or no if applicable and add comments in the space

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A.

PROGRAM:

1.

Does the licensee have an employee concerns program?

(Yes or No/ Comments) Yes, it's called the Ombudsman Program.

2.

Has NRC inspected the program? Report #

No, the program has not been inspected by the NRC B.

SCOPE: (Circle all that apply)

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1.

Is it for:

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Technical? (Yes, No/ Comments)

Yes b.

Administrative? (Yes, No/ Comments) Yes c.

Personnel issues? (Yes, No/ Comments) No.

As of 1989, the program terminated personnel issues and supervisor / subordinate issues since it bogged down the program. Such issues, including sexual harassment, are handled by the Personnel Department on site.

2.

Does it cover safety as well as non-safety issues?

(Yes or No/ Comments)

Yes, the program does cover non-safety issues, however, these suggestions are not fed back to the individual as are safety issues.

3.

Is it designed for:

a.

Nuclear safety? (Yes, No/ Comments) Yes Issue Date: XX/XX/XX-1-2500/XXX

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b.

Personal safety?- (Yes, No/ Comments) Yes Personnel issues - including union grievances?

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(Yes or No/ Comments)

No, union grievances are handled by different programs. See response to 1.c. above.

4.

Does the program apply to all licensee employees?

(Yes or No/ Comments)

Yes 5.

Contractors?

(Yes on No/ Comments)

Yes 6.

Does the licensee require its contractors and their subs to have a similar program?

(Yes or No/ Comments)

No.

No such requirement exists.

7.

Does the licensee conduct an exit interview upon terminating employees asking if they have any safety concerns?

(Yes or No/ Comments)

Yes.

It is required by the licensees procedure for leaving the facility.

C.

INDEPENDENCE:

1.

What is the title of the person in charge?

The ombudsman.

2.

Who do they report to?

He reports directly to the Vice President-Nuclear.

3.

Are they independent of line management?

Yes. However, the ombudsman performs these duties concurrent to his duties required as an engineer attached to the Independent Safety Engineering Group 4.

Does the ECP use third party consultants?

If in the opinion of the Vice President-Nuclear, any concern requires independent investigation, a special investigator shall.

be appointed from outside of the Davis-Besse Nuclear Group.

5.

How is a' concern about a manager or vice president followed up?

If this situation occurs, the ombudsman has the authority to elevate the concern above the VP Nuclear to any position within

- 2500/XXX-2-Issue Date: XX/XX/XX

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the company.

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D.

RESOURCES:

1.

What is the size of staff devoted to this program?

One person working half-time.

2.

What are ECP staff qualifications (technical training, interviewing training, investigator training, other)?

The licensee does not have any training requirements for the position. The present ombudsman was SR0 qualified and has had INP0 plant evaluator and observation and interviewing training.

E.

REFERRALS:

1.

Who has followup on concerns (ECP staff, line management, other)?

The investigations conducted to resolve concerns are handled individually. However, mo::t concerns are followed up by line management F.

CONFIDENTIALITY:

1.

Are the reports confidential?

(Yes or No/ Comments)

Yes

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2.

Who is the identity of the alleger made known to (senior management, ECP staff, line management, other)?

(Circle, if other explain)

The program is designed such that only the ombudsman knows the identity of the alleger (assuming the alleger is not anonymous).

3.

Can employees be:

a.

Anonymous? (Yes, No/ Comments) Yes b.

Report by phone? (Yes, No/ Comments)

Yes G.

FEEDBACK:

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Is feedback given to the alleger upon completion of the followup?

j (Yes or No - If so, how?)

Yes. The ombudsman provides a written response to the alleger at the conclusion of the investigation. The ombudsman stated that he

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has periodically phoned the alleger with the resolution.

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Does program reward good ideas'?

Issue Date:

XX/XX/XX-3-2500/XXX q

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The ombudsman program does not reward good ideas. The licensee has other programs to reward individuals including, the Bright i

Idea program, which evaluates suggestions to improve performance and reduce cost.

3.

Who, or at what level, makes the final decision of resolution?

The Vice President-Nuclear, concurs on all resolutions.

The ombudsman maintains veto power.

4.

Are the resolutions of anonymous concerns disseminated?

Depending on the level of interest. The licensee has disseminated some concerns using a letter format through the mail system or by j

use of a column in the biweekly site paper.

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Are resolutions of valid concerns publicized (newsletter,

bulletin board, all hands meeting, other)?

l Yes, as appropriate.

See response to 4. abcve.

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EFFECTIVENESS:

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How does the licensee measure the effectiveness of the program?

Trending of quantity of concerns receivsd after an outage and the number of allegations received by licensee from the NRC.

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2.

Are concerns:

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Trended? (Yes or No/ Comments) Yes b.

Used? (Yes or No/ Comments)

Yes Some root causes of these concerns have resulted in modifications of the licensee General Orientation Training program provided to all site personnel and contractors.

3.

In the last three years how.many concerns were raised? ~55 Closed? All but one What percentage were substantiated?

N/A

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The licensee addresses all concerns as valid and does not spend -

time to determine if the allegation is substantiated.

The nature of the response to the allegation infers if the concern was valid.

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How are followup techniques used to measure effectiveness (random survey, interviews, other)?

The effectiveness of the program is rather difficult to measure, j

However, the licensee looks for repeat concerns and trends.

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5.

How frequently are internal audits of the ECP conducted and by whom?

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l 2500/XXX-4-Issue Date:

XX/XX/XX

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Has not been audited.

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ADMINISTRATION / TRAINING:

1.

Is ECP prescribed by a procedure? (Yes or No/ Comments)

Yes, NG-VP-000124, Nuclear Group Ombudsman Program.

2.

How are employees, as well as contractors, made aware of this program (training, newsletter, bulletin board, other)?

The licensee includes the program in its General Orientation Training program and posts information about the program with concerns sheets on various bulletin boards on site.

ADDITIONAL COMMENTS:

(Including characteristics which make the program especially effective or ineffective.)

The licensee feels that their program is effective -in investigating and resolveing concerns. The licensee interfaces with other ombudsman programs at other nuclear facilities and have been told that their program is good by other facilities standards.

They do not have any evidence that their program is ineffective.

Additionally, the licensee is very sensitive about maintaining credible confidentiality in their ombudsman program. They prefer not to have the NRC to review their records and would prefer to have their program remain independent of NRC review.

The person completing this form please provide the following information to the Regional Office Allegations Coordinator and fax it to Richard Rosano at 301-504-3431.

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NANE:

TITLE:

PHONE #:

R. K. Walton_/_Res. Inspector _/_(419) 898-2775_ DATE COMPLETED:_8-20-93_

lssue Date:

XX/XX/XX-5-2500/XXX

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