IR 05000440/1993016
| ML20057F956 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/08/1993 |
| From: | Lanksbury R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20057F954 | List: |
| References | |
| 50-440-93-16, NUDOCS 9310200012 | |
| Download: ML20057F956 (16) | |
Text
l U. S. NUCLEAR REGULATORY COMMISSION j
REGION III
Report No. 50-440/93016(DRP)
Docket No. 50-440 License No. NPF-58 Licensee:
Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name:
Perry Nuclear Power Plant Inspection At:
Perry Site, Perry, Ohio Inspection Conducted:
July 30 through September 13, 1993 Inspectors:
D. Kosloff A. Vegel S. Burgess s
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Approved By:
db v \\ ',1-u _
i r i b,s R.D.Lanksbury,Chttf Date Reactor Projects Section-38
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Inspection Summary
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i Inspection on July 30 throuah September 13. 1993 (Report No.
50-440/93016(DRP))
i Areas Inspected:
Routine unannounced safety inspection by resident inspectors of licensee action on previous inspection findings, licensee event report followup, design changes and modifications, surveillance observations, maintenance observations, operational safety verification, event followup, and
followup of concerns.
Results:
In the eight areas inspected, one violation was identified in the maintenance area (Paragraph 6.b) concerning improper installation of scaffolding.
In additior., one non-cited violation was identified concerning plant equipment tagging.
The following is a summary of the licensee's performance during this inspection period:
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Plant Operations The plant was operated at or near full power during the inspection period. Operator control of plant activities was good.
Observed i
auxiliary operator equipment rounds were conducted effectively.
9310200012 931000 ADOCK0500g0 PDR G
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Maintenance The quality of observed maintenance and surveillance activities was
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I generally good. However, weaknesses were noted in the adequacy of
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maintenance planning and attention to detail during performance of a planned maintenance outage on Division III system components.
Inadequate control of scaffold installation caused a violation.
Enaineerina
Engineering support of daily plant activities was good. A lack of i
detailed action plans concerning motor operated valve (M0V) and service water system programs was noted. Quality Assurance identified j
weaknesses in the MOV program and formally stopped work in that area.
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Plant Suonort The quality of observed activities involving radiation protection and security were generally good.
Earlier improvements in plant j
housekeeping were maintained. A weakness in control of contractors allowed a second incident of a vehicle striking a low voltage overhead line to occur within less than a two month period.
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l DETAILS 1.
Persons Contacted Cleveland Electric Illuminatino Company
- R. Stratman, Vice President - Nuclear
- D. Igyarto, General Manager, Perry Nuclear Power Plant (PNPP)
- K. Donovan, Manager, Regulatory Affairs
- M. Bezilla, Operations Manager, PNPP
- N. Bonner, Director, Perry Nuclear Engineering J
Department (PNED)
- R. Schrauder, Director, Perry Nuclear Support Department (PNSD)
H. Hegrat, Compliance Engineer, PNSD K. Pech, Director, Perry Nuclear Assurance Department (PNAD)
- V. Concel, Manager, Mechanical Design Section, PNED
- V. Sodd, Manager, Maintenance Section, PNPP
- P. Volza, Manager, Radiation Protection Section, PNPP D. Cobb, Superintendent, Plant Operations, PNPP L. Teichman, Plant Unit Supervisor, Plant Maintenance Section, PNPP P. Roberts, Manager, Instrument & Control Section
- F. Von Ahn, Manager, Technical Section, PNED
- D. Conran, Compliance Engineer, PNSD
- W. Coleman, Manager, Engineering Project Support, PNED
- J. Lausberg, Acting Manager, Quality Assurance Department, PNAD
- W. Kanda, Manager, Integrated Scheduling and Controls, PNPP
- Denotes those attending the exit meeting held on September 13, 1993.
2.
Licensee Action on Previous Inspection Findinas (40500. 71707. 92701.
92702)
(Closed) Violation (50-440/90012-03(DRS):
Lack of testing the fire pumps at shut-off pressure, lack of identifying and correcting significant reduction in the operating characteristics of the fire pumps, and not demonstrating that each fire pump could meet the demand of 3750 gallons per minute at 85 psi.
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The licensee revised periodic test instruction (PTI)-P54-P0036, " Diesel and Electric Fire Pumps Flow Data and Control Panel Functicnal Test."
The revised PTI changed the method of conducting flow tests from using
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installed flow meters to hydrant flows with Underwriters' Laboratories playpipes, changed acceptance criteria to conform to industry and fire
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protection standards (testing at shut off pressure), and added pump
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curve graphs to plot against plant demands. Surveillance tests i
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completed in October 15, 1991, and August 10, 1993, tested the fire pump at shut off pressure and demonstrated that each fire pump could meet the system demands. This item is closed.
No deviations or violations were identified.
3.
Licensee Event Report (LER) Followun (90712. 92700)
Through review of records, the following event report was reviewed to determine if reportability requirements were fulfilled, immediate corrective actions were accomplished in accordan:e with technical specifications (TSs), and corrective action to prevent recurrence had been established:
(Closed) LER 50-440/92001:
Loss of reactor protection system (RPS) due to electrical protection assembly (EPA) trip results in BOP and RWCU isolations.
Licensee Investiaation of Root Cause and Corrective Actions Root Cause The cause of the event was failure of one of two EPAs provided for the RPS Bus B motor generator (MG) set.
Troubleshooting cor.cluded that the trip was not related to the MG set and the component responsible for the loss of RPS Bus B was the EPA logic board.
Following replacement of the logic board, the EPAs successfully completed a four hour load test and were returned to service.
Corrective Action To evaluate root cause and potential generic implications of the failure, the EPA was sent to General Electric for failure cause determination. The EPA failed to maintain a new setpoint and the only detectable problem with the board was found to be that the 12,000 +/- 60 Hz adjustment was out of tolerance.
To correct the problem, a 20 kohm resistor was replaced with a 22.1 kohm resistor.
This resistor affects the internal reference voltage of the voltage-to-frequency converter. The problem was not observed in any other cards and was considered unique to this particular card since all other cards have successfully maintained their setpoints since the initial setting.
Instrumentation and Control (l&C) procedure ICI-C71B-2 has been revised to check and adjust the output of the voltage-to-frequency converter and record the results on data sheets.
Inspectors Review The inspectors reviewed the licensee's investigation of the event and corrective actions. The inspectors concluded that licensee actions appeared adequate te prevent recurrence. This item is closed.
No deviations or violations were identified.
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4.
Desian Chanaes and Modifications (37700_1 Enaineerina Assessment
!Luality Assurance (0A) Enaineerina Assessments Self-assessment of engineering activities appeared to be effective and performance based, and identified potential problem areas to management.
A follow-up audit regarding the MOV program performed in January 1993,
still identified the lack of a detailed action plan or schedule for completing all remaining Generic Letter (GL) 89-10 work.
Similarly, Audit 93-31 identified the lack of a detailed action plan regarding Perry's GL 89-13 (service water system) program.
These areas, including corrective actions in response to the audits, will be reviewed further in future inspections of MOV and service water programs.
System Enaineerina Proposed changes and strategies in the system engineering group appeared to target previously identified weak areas such as MOV program
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deficiencies.
The strategies also focused on overall plans for large programs such as check valves and erosion / corrosion. As identified in the QA audits reviewed, the lack of overall governing programs continued to be a weak area in engineering. To help correct this, internal and external audits will be requested by engineering once programs are in place to validate the confidence level in the program's effectiveness and completeness.
Plant and System Walkdowns Tours of the containment, tu M ne building, and auxiliary building were
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conducted to observa plant equipment conditions, fluid leaks, and to i
verify that maintenance requests had been initiated for equipment in need of maintenance. The inspector also observed plant housekeeping and cleanliness conditions. The inspector walked down the accessibie portions of the reactor core isolation cooling (RCIC) system to verify operability by comparing system lineup with plant drawings, as-built configuration, and to identify equipment conditions that could degrade performance.
The inspector did not identify any discrepancies.
Housekeeping and material condition of the plant was generally good and recently painted areas made leak identification easier. However, B0P systems and areas continued to contain excessive scaffolding.
The containment was adequately lit and suppression pool water was clean,
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i Root Cause Analyses Condition reports (CRs), post scram restart reports, and other investigative type reports were reviewed to assess the engineering department's ability to determine root causes for equipment malfunctions. Several of the draft documents reviewed appeared to have stopped short of identifying the root causes.
Incomplete root cause
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't analyses had been noted in the past to be a weakness.
Two examples where this was noted were in the preliminary investigation for CR No.
'93-114, " Slow Re-opening of Scram Discharge Volume Vent Valves" and CR Nos.93-115 and 93-118, which documented failure of a control room heating, ventilating, and air conditioning (HVAC) fan motor.
For instance, the inspector noted that CR 93-114 documented an excess amount of "never-seeze" residue in the inlet and associated line ports.
NUREG-1275 documented failures of solenoid operated valves due to
"loctight," a similar product. The residue appeared to have not been considered in the preliminary root cause analysis. Also, CR Nos.93-115 and 93-118 did not appear to fully address the potential causes of the
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failure mechanisms such as voltage surges or insulation breakdown.
The inspector recognized that the documents reviewed were drafts; l
however, the degree of questioning attitude being used to determine the
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root cause of problems was not always apparent. The licensee had sent the valves described in CR 93-114 to the manufacturer for additional
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f.ilure analysis and the inspectors observed that the licensee was monitoring the affected bus for the suspected voltage surge discussed in CRs93-115 and 93-118. The licensee's corrective actions for both items were being tracked by open LERs.
No deviations or violations were identified.
5.
Monthly Surveillance Observations (61726)
For the surveillance activities listed below, the inspectors verified.
one or more of the following: testing was performed in accordance with procedures; test instrumentation was calibrated; limiting conditions for operation were met; removal and restoration of the affected components were properly accomplished; test results conformed with technical specifications, procedure requirements, and were reviewed by personnel other than the individual directing the test; and any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnel.
Surveillance Activity Title
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PTI - P42-P001 Emergency Closed Cooling Heat Exchanger Performance Testing TXI - 148 Division III Diesel Generator Start with One Air Bank SVI - E22-T2001 High Pressure Core Spray (HPCS) Pump and Valve Operability Test SVI - R43-T1318 Division II Diesel Generator Monthly Test No violations or deviations were noted.
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6.
Monthly Maintenance Observation (6270_3_1 Station maintenance activities of safety-related systems and components listed below were observed and/or reviewed to ascertain that activities 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 limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components 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.
Work requests were reviewed to determine the status of outstanding jobs and to assure that priority was assigned to safety-related equipment maintenance which had the potential to affect system performance.
During the inspection period, the inspectors also assessed the effective ess of licensee planning of maintenance and troubleshooting activities.
Based on the inspectors observations, further licensee emphasis appeared to be needed to improve planning effectiveness.
For example, the Division III maintenance outage planned for 44 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br /> actually took 97 hours0.00112 days <br />0.0269 hours <br />1.603836e-4 weeks <br />3.69085e-5 months <br /> because of inadequate pre-job preparations, incorrect or unavailable parts, and weaknesses in the evaluation and correction of emergent issues. Another example of inadequate planning, which contributed to the occurrence of a half-scram signal, involved the replacement of a burned relay base on August 21, 1993. While installing a jumper in a cramped location, a technician shorted the power supply to ground resulting in a half-scram signal.
Licensee post-event review
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identified that inserting a trip signal into a calibration unit, instead of installing a jumper, may have been a better option with respect to system and personnel safety. This option should have been identified during job planning.
a.
Specific Maintenance Activities Observed or Reviewed Division III Diesel Generator Air Start Motor Replacement Off-Gas Brine Unit Repairs Division III Diesel Generator Temperature Switch Replacement HPCS Waterleg Pump Repairs
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b.
Division 111 Outaae Observations l
During the week of August 16, 1993, the licensee performed a i
l scheduled maintenance outage on the Division 111 diesel generator j
and HPCS components.
During the outage, several examples of poor l
l procedural compliance by maintenance personnel were identified.
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On August 17, 1993, during maintenance on the HPCS waterleg pump, i
the licensee identified that vent and drain valves lE22F0515 and
IE22F0516 had been removed from the system with out-of-service j
tags still installed on them.
Out-of-service tags are utilized at
the plant to temporarily provide control over the operation of a j
component, and then only for the period that operation or control
is necessary. The vent and drain valves were out-of-service
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tagged to support the venting and draining of the system prior to removal of the waterleg pump.
Following the venting and draining evolution, the tags should have been cleared but were not. As a result, the valves were removed with the pump, with the tags still attached.
Perry administrative procedure PAP-1401, " Safety Tagging," Section 6.3.6 requires-that valves with danger or out-
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of-service tags attached 'shall not be disassembled or removed from the system.
The licensee's failure to comply with procedure PAP-
140 was a violation of Technical Specification.6.8.1.a which
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requires written procedures be implemented for equipment control (e.g., locking and tagging).
This violation was not cited because
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the licensee's efforts in identifying and correcting the violation met the criteria specified in section VII.B of the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
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(Enforcement Policy,10 CFR Part 2, Appendix C).
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On August 17, 1993, the inspectors observed maintenance on the Division Ill diesel generator, specifically WO-92-02212, Air Start
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Motor Replacement. The work order involved the replacement of the
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four air start motors which we n installed in pairs on each side of the diesel.
The inspectors noted that on one side, the
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maintenance crews had covered the disconnected air hoses to
maintain system cleanliness while on the other side they had not.
The inspectors informed a quality control (QC) inspector observing l
the maintenance of the discrepancy.
Prompt actions by the QC
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inspector and the maintenance crew insured that the uncovered i
hoses had minimal safety significance.
However, further licensee
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attention appears needed to ensure that system cleanliness l
standards are being met during maintenance activities.
j On August 31, 1993, the inspectors observed a scaffold that was attached to the safety-related low pressure core spray pump instrument rack.
This was contrary to Section 3.2.1. of procedure
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GCl-0016, Rev. O, effective 6/10/93, which stated that " Scaffolds shall not.... be connected to or in contact with any equipment
... unless provided for in Subsection 5.2 of this instruction."
Subsection 5.2 required a 3-inch minimum clearance between scaffolding and all safety-related equipment unless infringement
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of the clearance had been approved by the Perry Nuclear Engineering Department. This approval was not obtained.
The licensee modified the scaffold so that it complied with Section 3.2.1 of GCI-0016 and issued condition report CR-93-197 to track additional corrective actions. On September 9, 1993, the inspectors verified that the scaffold complied with Section 3.2.1
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of GCI-0016, but observed that it was not in compliance with Section 7.0 of GCI-0016, which required the work supervisor to initial and date the Equipment Identification Tag and annotate the tag to indicate that the scaffold was inspected and was in compliance with GCI-0016. The inspectors also observed that scaffolding in the Division I and Division III emergency diesel generator (EDG) rooms did not comply with Section 7.0 of GCI-0016.
The licensee inspected the scaffold and determined that it also did not comply with Section 3.2.1 of GCI-0016. The licensee's failure to comply with procedure GCI-0016 was a violation (50-440/93016-01(DRP)) of Technical Specification 6.8.1.a which required written procedures to be implemented for maintenance activities which can affect the performance of safety-related equipment. The licensee brought the EDG room scaffold into compliance and documented the condition with CR-93-207.
The licensee also performed inspections of other plant scaffolding on September 11, 1993, which identified a6fitional scaffolding that was not in compliance with GCI-0016. The licensee informed the inspectors that all identified scaffold non-compliances had been corrected.
One violation was identified. No deviations were identified.
7.
Operational Safety Verification (71707)
The inspectors observed control room operations, reviewed applicable logs, and conducted discussions with control room operators during this inspection period. The inspectors verified the operability of selected emergency systems, reviewed tagout records, and verified tracking of limiting conditions for operation associated with affected components.
Tours of the pump houses, control complex, the intermediate, auxiliary,
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reactor, radwaste, and turbine buildings were conducted to observe plant l
equipment conditions, including potential fire hazards, fluid leaks, and l
excessive vibrations, and to verify that maintenance requests had been i
initiated for certain pieces of equipment in need of maintenance.
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inspectors by observation and direct interview verified that the
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physical security plan was being implemented in accordance with the j
station security plan. The inspectors observed plant housekeeping, general plant cleanliness conditions, and verified implementation of radiation protection controls.
a.
Auxiliary Operator Observations and Component Lubrication On August 10, 1993, the inspectors observed a non-licensed plant auxiliary operator (AO) conducting shift equipment rounds.
The inspectors accompanied the A0 on the rounds to assess plant
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i knowledge, proper safety precautions, and to assess the adequacy of the rounds in evaluating equipment performance.
The inspectors observed that the A0 appeared knowledgeable of the plant, properly recorded equipment data, and was observant in monitoring equipment status, including noting any deficiencies.
In addition to evaluating the performance of the A0 conducting his rounds, the inspectors assessed the licensee's lubrication program, specifically the control of oil lubricants. The inspectors observed the A0 check oil levels on various pumps and discussed what actions would be taken if the oil level was low.
The A0 was knowledgeable of oil sightglass and lubricator operation as well as component lubrication requirements, including
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use of the daily equipment lubrication record and the lubrication manual. The inspector discussed the maintenance of the lubrication manual, which lists components and the associated recommended lubricants, with the site lubrication engineer. The inspector reviewed the process in place to update the-lubrication manual when design changes occur..
Based on the above observations and discussions, the inspector concluded that the lubrication of components were being adequately controlled.
No violations or deviations were identified.
8.
Onsite Followuo of Events at Operatina Power Reactors (93702)
a.
General
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The inspectors performed onsite followup activities for events which occurred during the inspection period.
Followup inspection included one or more of the following:
reviews of operating logs, procedures, and condition reports; direct observation of licensee actions; and interviews of licensee personnel.
For each event, the inspectcrs reviewed one or more of the following:
the sequence of actions, the functioning of safety systems required by plant conditions, licensee actions to verify consistency with plant procedures and license conditions, and verification of the nature of the event. Additionally, in some cases, the inspectors verified that the licensee's investigation identified root causes of equipment malfunctions and/or personnel errors and the licensee was taking or had taken appropriate corrective actions.
Details
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of the events and licensee corrective actions noted during the inspector's followup are provided below.
b.
Details (1)
Start of Annulus Exhaust Gas Treatment System. Train B On August 18, 1993, at about 3.:04 p.m. (EST), while in Operational Condition 1, 100 percent reactor power, an apparent automatic start of the B train of the Annulus Exhaust Gas Treatment System (AEGTS) occurred. At 3:04 p.m.
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,,-,r-a.,we--rw-r,wwt+-,6 met wm+y-wf--e-rwweM
i a licensed operator transferred AEGTS system operation from train B to train A.
The transfer involved starting the A train and securing the B train in accordance with system operating instruction (S0I) M15, Section 5.1.
At approximately 3:05 p.m., during independent verification of the transfer, a second licensed operator discovered that both trains were running. At about 3:08 p.m., the B train was secured.
Initial investigation determined that AEGTS i
train B autostarted and, since AEGTS was considered a Engineered Safety Feature, an Emergency Notification System (ENS) notification in accordance with 10 CFR 50.72 was made at about 4:47 p.m.
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The licensee initiated condition report CR-93-181 to investigate the cause of the event.
Subsequent review of the event, including analysis of strip charts for annulus differential pressure recorders and attempts to recreate the event, determined that AEGTS train B did not restart. The licensee determined that the B train was not shut off and was still running when observed during independent verification. The investigation determined that it was likely that the initial licensed operator may have confused the controls and stop indication for the B train fan with the controls and indication for the B train heater. As a result, the B train was not secured nor confirmed to be secured by the initial licensed operator.
Based on the findings of the licensee's investigation effort the AEGTS B train autostart did not occur, the ENS notification was retracted on September 17, 1993.
This event will be evaluated as part of the assessment of l
licensee efforts to reduce perso nel errors.
No violations or deviations were identified.
(2)
Low Voltaae Overhead Lines Struck by Truck On September 2, 1993, a truck operated by a contractor struck and severed a low hanging 125 VDC cable used to operate a signal bell for a gate to the high voltage transmission yard. The inspectors discussed the event with licensee personnel, including the plant manager.
A fence, which had been directly under the cable, had recently been removed and the truck driver attempted to take a short cut under the cable after seeing the cable and concluding that the truck could clear the cable. On Jdly 22, 1993, personnel working for the same contractor severed low voltage AC cables with a crane. The contractor took i
appropriate disciplinary action for personnel in the truck involved in the September 2 event. The licensee requested
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E formal assurance from the contractor that it would take
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appropriate action to ensure similar events would not occur again.
9.
Manaaement Meetinas On August 30-31, 1993, Mr. H. Miller, Deputy Regional Administrator, Region III visited the Perry Plant. On August 31, 1993,
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Mr. L. R. Greger, Chief, Reactor Projects Branch 3, and eight senior
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resident inspectors and Region ill managers-visited the Perry facility.
During the visits, the NRC managers toured the facility, observing plant conditions and on-going plant operations and interviewed members of the licensee staff in order to assist NRC management in evaluating the
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licensee's efforts to improve performance.
In addition, several of the f
managers met with members of the licensee staff to discuss recent plant i
performance.
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10.
Followup of Employee Concerns Programs (TI 2500/028)
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An inspection of the licensee's employee concerns program, in accordance l
with Temporary Instruction TI 2500/028, Employee Concerns Program was
conducted.
The objective of the temporary instruction was to determine the characteristics of employee concerns programs that licensees had
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implemented to provide employees, who wish to raise safety issues, an alternate path from their supervisor or normal line management to express these concerns and to encourage people to come forward with t
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their concerns without fear of retribution.
The results of the inspectors review are documented on the survey form, Attachment 1, to this report.
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11.
Items For Which A " Notice of Violation" Will Not Be Issued
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During this inspection, certain activities, as described above in paragraph 6.b, appeared to be in violation of NRC requirements.
i However, the licensee identified this violation and it will not be cited because the criteria specified in Section VII.B. of the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
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(Enforcement Policy,10 CFR Part 2, Appendix C), were satisfied.
12.
Exit Interview The inspectors met with the licensee representatives denoted in paragraph 1 throughout the inspection period and on September 13, 1993.
The inspectors summarized the scope and results of the inspection and discussed the likely content of the inspection report.
The licensee did
not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.
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Attachment 1
EMPLOYEE CONCERNS PROGRAM: TI 2500/028 PLANT NAME:
LICENSEE:
DOCKET #:
Perry Cleveland Electric 50-440 Illuminating Company A.
PROGRAM:
1.
Does the licensee have an employee concerns program?
Yes, " Call-for-Quality" 2.
Has NRC inspected the program? Report # 85087 Yes (See comments)
B.
SCOPE:
1.
Is it for:
a.
Technical? Yes b.
Administrative? Yes c.
Personnel issues? No 2.
Does it cover safety as well as non-safety issues? Yes 3.
Is it designed for:
a.
Nuclear safety? Yes
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b.
Personal safety? Yes c.
Personnel issues - including union grievances? No 4.
Does the program apply to all licensee employees? Yes 5.
Contractors? Yes; however, exit interviews are required of all licensee employees but are not required for co1 tractors.
6.
Does the licensee require its contractors and their subs to have a similar program? Yes
7.
Does the licensee conduct an exit interview upon terminating employees asking if they have any safety concerns? Yes, except contractors.
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C.
INDEPENDENCE:
1.
What is the title of the person in charge?
Corporate Ombudsman 2.
Who do they report to?
i Vice President, Nuclear Group 3.
Are they independent of line management?
Yes 4.
Does the ECP use third party consultants?
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No i
5.
How is a concern about a manager or vice president followed
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up?
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l The. VP, Nuclear, follows up on any concern about a l
manager. The Ombudsman would go to the president of l
CENTERIOR (parent company) for guidance on any VP concern.
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D.
RESOURCES:
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What is the size of staff devoted to this program?
None. The Ombudsman receives all concerns and coordinates followup using Quality Assurance staff.
2.
What are ECP staff qualifications (technical training, interviewing training, investigator training, other)?
Standard QA inspector or Lead QA auditor qualifications.
E.
REFERPALS:
1.
Who has followup on concerns (ECP staff, line management, other)?
Quality Assurance staff.
F.
CONFIDENTIALITY:
1.
Are the reports confidential?
Yes
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2.
Who is the identity of the alleger made known to (Senior management, ECP staff, line management, other)?
Ombudsman or his designated a'Iternate.
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Can employees be:
a.
Anonymous? Yes l
b.
Report by phone? Yes j
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FEEDBACK:
1.
Is feedback given to the alleger upon completion of the l
followup? Yes, by letter sent through the U.S. Mail.
2.
Does program reward good ideas? No, the licensee has another program for that.
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3.
Who, or at what level, makes the final decision of l
resolution?
Ombudsman 4.
Are the resolutions of anonymous concerns disseminated?
No l
5.
Are resolutions of valid concerns publicized (newsletter,
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bulletin board, all hands meeting, other)?
No H.
EFFECTIVENESS:
1.
How does the licensee measure the effectiveness of the program?
By the number of concerns that go to the NRC and by the ratio of concerns self-identified by the plant staff to concerns identified by oversight organizations.
2.
Are concerns:
a.
Trended? No b.
Used? Yes, to look for widespread or generic problems.
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3.
In the last three years how many concerns were raised?
22*
Of the concerns raised, how many were closed?
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What percentage were substantiated? unknown.
The licensee does not keep a record of the number or percentage of substantiated concerns.
Each individual record of a concern states if the concern was substantiated.
- 1991:
2; 1992: 4; 1993:
16, as of September 8, 1993 4.
How are followup techniques used to measure effectiveness (random survey, interviews, other)?
l Generally, a second review is conducted using quality l
assurance techniques (interviews, document reviews, l
observing work in progress) dependent on the subject
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of the concern.
5.
How frequently are internal audits of the ECP conducted and by whom?
No regular audits. Audited once in September 1986.
I.
ADMINISTRATION / TRAINING:
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1.
Is ECP prescribed by a procedure?
Yes 2.
How are employees, as well as contractors, made aware of this program (training, newsletter, bulletin board, other)?
l Initia' general employee training (access training),
periotic newsletter, and posters in the plant.
ADDITIONAL COMMENTS:
Comment on Item A.2.:
The program was reviewed by the NRC in July or August of 1985. This was documented on August 21, 1985, in a memo from the SRI to his section chief but was not documented in an inspection report.
A licensee memo dated May 27, 1986, indicates that there were additional NRC reviews of concerns addressed by the program, including l
allegations closed in Inspection Report 86007. Attachments to Inspection Report 86007 include references to the licensee's program and letters written by the Ombudsman.
NAME:
TITLE:
PHONE #:
DATE COMPLETED:
Don Kosloff/Sr. Resident Inspector /216/259-3610 09/07/93
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