ML031920509
| ML031920509 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/11/2003 |
| From: | Gwynn T Division of Nuclear Materials Safety IV |
| To: | Sheppard J South Texas |
| References | |
| FOIA/PA-2004-0138 EA-97-341, IR-03-009 | |
| Download: ML031920509 (4) | |
See also: IR 05000498/2003009
Text
July 11, 2003
James J. Sheppard, President and
Chief Executive Officer
STP Nuclear Operating Company
P.O. Box 289
Wadsworth, Texas 77483
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRC
INSPECTION REPORT 50-498/03-09 AND 50-499/03-09
Dear Mr. Sheppard:
On June 12, 2003, the US Nuclear Regulatory Commission (NRC) completed an inspection at
your South Texas Project Electric Generating Station, Units 1 and 2 (STP). The enclosed
inspection report documents the inspection findings which were discussed on June 12, 2003,
with you and other members of your staff.
On June 9, 1998, the NRC issued a Confirmatory Order Modifying License - EA-97-341(Order)
to confirm your commitments to enhance STPs process for addressing employee protection
and safety concerns. The Order required you to perform several activities including
comprehensive cultural assessments, use of a leadership assessment tool for managers, and
continuing training for supervisors and managers.
On April 7, 2003, your letter to the NRC stated that you had met all of the requirements of the
Order. On June 3, 2003, you briefed the NRC on the results of your 2003 comprehensive
cultural assessment in a public meeting at NRCs Region IV office. In this meeting, you stated
STPs continuing commitment to maintain a strong safety conscious work environment.
As documented in this inspection report, NRC has confirmed that you have met all of the
requirements of the Order. The inspection concluded that a safety conscious work environment
was in place at STP. Therefore, the Order dated June 9, 1998, is closed.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response will be made available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
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NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Thomas P. Gwynn
Acting Regional Administrator
Dockets: 50-498; 50-499
Enclosure:
Inspection Report 50-498/03-09; 50-499/03-09
cc w/Enclosure:
Tom Jordan, Vice President
Engineering & Technical Services
STP Nuclear Operating Company
P.O. Box 289
Wadsworth, Texas 77483
S. M. Head, Manager, Licensing
Nuclear Quality & Licensing Department
STP Nuclear Operating Company
P.O. Box 289, Mail Code: N5014
Wadsworth, Texas 77483
A. Ramirez/C. M. Canady
City of Austin
Electric Utility Department
721 Barton Springs Road
L. D. Blaylock/W. C. Gunst
City Public Service Board
P.O. Box 1771
San Antonio, Texas 78296
D. G. Tees/R. L. Balcom
Houston Lighting & Power Company
P.O. Box 1700
Houston, Texas 77251
-3-
Jon C. Wood
Matthews & Branscomb
112 E. Pecan, Suite 1100
San Antonio, Texas 78205
A. H. Gutterman, Esq.
1111 Pennsylvania Avenue NW
Washington, DC 20004
C. A. Johnson/A. C. Bakken
AEP Texas Central Company
P.O. Box 289, Mail Code: N5022
Wadsworth, Texas 77483
Records Center
700 Galleria Parkway
Atlanta, Georgia 30339-5957
Director, Division of Compliance
& Inspection
Bureau of Radiation Control
Texas Department of Health
1100 West 49th Street
Brian Almon
Public Utility Commission
William B. Travis Building
P.O. Box 13326
1701 North Congress Avenue
Environmental and Natural
Resources Policy Director
P.O. Box 12428
Judge, Matagorda County
Matagorda County Courthouse
1700 Seventh Street
Bay City, Texas 77414
-4-
Terry Parks, Chief Inspector
Texas Department of Licensing
and Regulation
Boiler Program
P.O. Box 12157
Susan M. Jablonski
Office of Permitting, Remediation and Registration
Texas Commission on Environmental Quality
MC-122, P.O. Box 13087
Ted Enos
4200 South Hulen
Suite 630
Fort Worth, Texas 76109
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Electronic distribution by RIV:
Acting Regional Administrator (TPG)
DRP Director (ATH)
Acting DRS Director (TWP)
Senior Resident Inspector (GLG)
Branch Chief, DRP/A (WDJ)
Senior Project Engineer, DRP/A (TRF)
Staff Chief, DRP/TSS (PHH)
RITS Coordinator (NBH)
OEMail
GSanborn (GFS)
JDixon-Herrity, OE
NHilton, OE
FCongel, OE
Only inspection reports to the following:
Mel Fields (MBF1)
ADAMS: Yes
No Initials: ______
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
S:\\RAS\\ALLEG\\Rev 4 South Texas Project IR2003-009.wpd
RIV:SRI
RIV:SRA
RC
D:ACES
DRP:BC:A
Thoeg*
Rwise*
Ksmith*
GFSanborn*
WJohnson*
/RA/
/RA/
/RA/
/RA/
/RA/
6/26/2003
6/25/2003
6/25/2003
6/27/2003
6/26/2003
A:DRA
D:OE
A:RA
DChamberlain*
FCongel*
TGwynn
/RA/
/N. Hilton Actg for/
/RA/
7/1/2003
7/1/2003
7/ 11/2003
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
- Previously concurred
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Dockets:
50-498; 50-499
Licenses:
Report No.:
50-498/03-09; 50-499/03-09
EA No.
Licensee:
STP Nuclear Operating Company
Facility:
South Texas Project Electric Generating Station, Units 1 and 2
Location:
FM 521 - 8 miles west of Wadsworth
Wadsworth, Texas
Dates:
June 9-12, 2003
Inspectors:
R. Wise, Senior Allegations Coordinator
T. Hoeg, Senior Resident Inspector, Project Branch A
Approved By:
W. Johnson, Chief
Branch A
Division of Reactor Projects
SUMMARY OF FINDINGS
IR 05000498/03-09, 05000499/03-09; on June 6-12, 2003; South Texas Project Electric
Generating Station, Units 1 & 2; inspection of the identification and resolution of problems
associated with a safety conscious work environment and licensee response to the Order.
The inspection was conducted by the Region IV Senior Allegations Coordinator and the Senior
Resident Inspector from Grand Gulf Nuclear Station. No findings of significance were
identified.
Identification and Resolution of Problems
The licensees actions to enhance employee protection and reporting of safety concerns were
determined to be in compliance with the terms and conditions of the Order. Licensee audits,
surveys, and assessments were found to be adequate. A safety conscious work environment
at STP was found to be in place, maintained, and accepted by licensee personnel. The
inspectors found workers at the site felt free to identify concerns to their supervision and to
input safety findings into their corrective action program or Employee Concerns Program
without fear of retaliation. The licensees compliance with the terms and conditions of the Order
were verified through direct inspection and documentation reviews.
Report Details
4
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
1.
Background
The NRC Office of Investigations had previously concluded that the licensee had
subjected four employees to a hostile work environment in retaliation for the employees
having engaged in protected activities (i.e., raising safety concerns). On June 9, 1998,
the NRC issued the Order and Exercise of Discretion to the South Texas Project
Nuclear Operating Company (STPNOC). The Order was issued to confirm STPs
commitments to enhance STPs process for addressing employee protection and safety
concerns. As a result, the licensee committed to conduct comprehensive and mini-
cultural assessments, perform employee ratings of supervisors via a Leadership
Assessment Tool, and implement a mandatory continuing training program for all
supervisors and managers.
By letter dated April 7, 2003, the STPNOC notified the Region IV Regional Administrator
of their completion of actions to meet the requirements of the Order. On June 3, 2003,
STPNOC management met with Region IV management to review actions taken by
STPNOC to demonstrate compliance with the Order.
2.
Assessment of Safety-Conscious Work Environment
a.
Inspection Scope
The inspection team verified and validated licensee actions taken to comply with the
Order. The specific commitments reviewed were Item No. 1, Comprehensive Cultural
Assessment Program, Item No. 2, Leadership Assessment Tool Implementation, Item
No. 3, Continuing Training Program for Supervisors and Managers, and Item No. 4,
Site Wide Publication of the Confirmatory Order and Rights to Raise Safety Concerns.
The team evaluated the licensees 1998, 1999, 2000, 2001, 2002, and 2003 Action
Plans against the requirements set forth in the Order. The Action Plans included but
were not limited to condition reports, NRC correspondence, comprehensive cultural
assessments, surveys, training lesson plans, training attendance records, and various
statistical scoring documentation related to cultural assessments.
The team met with 62 randomly chosen licensee and contractor employees from
departments representing union and management personnel. Included in the interviews
were personnel who had been in the division that was the focus of the Order. The
interviews discussed the safety conscious work environment using a fixed set of
questions focused on management actions, personal experience with reporting safety
concerns and worker protection, freedom to voice safety concerns to plant
management, training of supervisors and managers, and management communication
of survey results.
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b.
Findings and Observations
Comprehensive Cultural Assessment Program
The inspectors determined that STPNOC established a comprehensive cultural
assessment program with the use of written surveys and confidential interviews of
selected individuals. Licensee employees, contractors, supervisors, and managers
participated in the process. The first comprehensive cultural assessment survey was
performed in June 1998 followed by 3 additional comprehensive surveys performed in
June 2000, December 2001, and January 2003.
The June 1998 survey identified 6 organizations which scored lower than most and were
given a mini-survey in December 1999 which showed improvement in 5 out of 6
organizations. Overall, the nuclear safety culture was determined to be strong. The
general culture and work environment ranged from acceptable to good. The inspectors
determined that during the period from 1998 through 2003, the survey results showed
improvement and indicated an acceptable safety conscious work environment.
The final comprehensive cultural assessment performed in January 2003 was reviewed
by the inspectors and found to be timely, comprehensive, well documented, and well
communicated. The survey indicated that the workforce at the South Texas Project
Electric Generating Station was willing to take the appropriate actions to raise safety
concerns without the fear of retaliation and felt that the Employee Concerns Program
was an acceptable alternative path to report concerns.
Leadership Assessment Tool Implementation
The inspectors determined that STPNOC developed a Leadership Assessment Tool to
measure performance of individual supervisors and managers during the period of 1998
through 2003. The tool utilized an annual survey taken by employees to rate their
supervisors and managers relating to their communication styles, leadership styles,
recognition abilities, and coaching abilities. The inspectors determined the survey
information to be well documented and utilized. Those individual supervisors and
managers who scored low were given action plans, developmental training, and
feedback sessions to improve their leadership capabilities.
Continuing Training Program for Supervisors and Managers
The inspectors determined that STPNOC developed and implemented mandatory
training for supervisors and managers designed to build positive working relationships, a
safety conscious work environment, and reinforce the requirements set forth in
10 CFR 50.7, Employee Protection. The inspectors reviewed training attendance
sheets and training course lesson plans to verify employee participation and the quality
of the training materials. The inspectors determined that all STPNOC employees were
trained annually. However, contractor personnel were considered exempt from this
continuing training and did not receive it on an annual basis.
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Site-Wide Publication of the Confirmatory Order and Rights to Raise Safety Concerns
The inspectors determined that STPNOC issued a site-wide publication on bulletin
boards and via the internal electronic mail from the President and CEO to all employees
and contractors. The publication informed the site staff of the Order and employee
rights to raise safety concerns without the fear of retaliation.
Random Interviews and Discussions
The inspectors interviewed 62 South Texas Project Generating Station employees to
discuss their experience and knowledge of the Order and their willingness to raise
safety concerns without fear of retaliation. The inspectors questioned the employees to
gain a general understanding of their individual perceptions of the safety conscious work
environment at the South Texas Project Generating Station. The inspectors chose the
employees at random as they walked around the site covering easily accessible areas of
the plant. The employees selected included company employees, contractors, union
members, supervisors, and managers. The employees represented a large cross
section of departments including operations, maintenance, engineering, plant support,
and security.
During interviews with the NRC, employees stated they understood they were free to
contact the NRC and most indicated they had received training that encouraged contact
with the NRC should they want to report safety issues and chose not to use the internal
processes. Some stated that they had been provided the 800 number for contacting the
NRC when they believed the licensee had not addressed their concerns or if they had
additional questions they wanted to be answered. Overall, the inspectors received
positive responses from the employees related to the safety conscious work
environment at the station. In general, the employees were aware of the 1998 Order;
participated in and received feedback on cultural surveys and supervisor assessments;
felt free to express safety concerns without fear of retaliation; and possessed
confidence in the Employee Concerns Program. The inspectors concluded that a safety
conscious work environment at the South Texas Project Generating Station was in place
and employees felt free to express their safety concerns openly and deliberately without
fear of retaliation or a lack of response from their management.
4OA6 Meetings, including Exit
On June 12, 2003, the inspectors presented the inspection results to Mr. J. Sheppard,
President and CEO, and other members of his staff. The inspectors confirmed that one
proprietary document, Management Insight Technologies STP Focused Culture
Assessment - October 2002, was reviewed by the inspectors and was not documented
in this report.
ATTACHMENT
KEY POINTS OF CONTACT
Licensee personnel
J. Sheppard, President and CEO
G. Parkey, Vice President, Generation
R. Piggot, Licensing Engineer
D. Cobb, Employee Concerns Program Coordinator
NRC personnel
C. OKeefe, Senior Resident Inspector
G. Guerra, Resident Inspector
ITEMS OPENED, CLOSED, AND DISCUSSED
Closed
50-498; 50-499/0309-01
ORDER EA-97-341
Confirmatory Order
Modifying License
(EA 97-341) and Exercise of
Discretion, dated June 9,
1998.
LIST OF DOCUMENTS REVIEWED
Condition Reports
98-17986
00-00195
98-17989
98-17935
98-17956
98-17959
98-17962
98-17960
98-17958
99-00924
98-17963
98-17961
99-02594
99-12634
00-06238
00-04018
01-02389
00-16844
02-04234
98-09180
02-09069
02-08467
02-00203
Correspondence
Memo, D. R . Keating to M. A. McBurnett, Completion of Safely Speaking Commitment,
July 1, 1998
Memo, D. R . Keating to M. A. McBurnett, Confirmatory Order Training, March 22, 1999
Memo, S. J. Tanner to File, 10 CFR 50.7 Annual Training, December 28, 2000
Memo, S. J. Tanner to File, 10 CFR 50.7 Annual Training, January 15, 2002
Memo, S. J. Tanner to File, 10 CFR 50.7 Annual Training, December 16, 2002
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Letter, A. A. Thadani to W.T. Cottle, Confirmatory Order Modifying License and Exercise of
Discretion, (EA 97-341), June 9, 1998
Letter, E. W. Merschoff to W.T. Cottle, Request for Partial Relaxation of Confirmatory Order,
November 24, 1999 (Mini-Surveys not performed in the same year as CCAs)
Letter, E. W. Merschoff to W.T. Cottle, Relaxation of Confirmatory Order Modifying License,
November 24, 1999 (Focus Groups in lieu of surveys)
Letter, W. T. Cottle to E. W. Merschoff, South Texas Project Comprehensive Cultural
Assessment, September 15, 1998, ST-NOC-AE-000300 (Results of 1998 CCA)
Letter, W. T. Cottle to E. W. Merschoff, South Texas Project Comprehensive Cultural
Assessment, November 2, 1998, ST-NOC-AE-000347 (Action Plan for issues from the 1998
CCA)
Letter, W. T. Cottle to E. W. Merschoff, South Texas Project Comprehensive Cultural
Assessment, November 1, 1998, ST-NOC-AE-000691 (Requested change of schedule/notified
of survey groups)
Letter, W. T. Cottle to E. W. Merschoff, South Texas Project Comprehensive Cultural
Assessment, March 14, 2000, ST-NOC-AE-000769 (Results of 1999 mini-survey)
Letter, W. T. Cottle to E. W. Merschoff, South Texas Project Comprehensive Cultural
Assessment, October 26, 2000, ST-NOC-AE-000949 (2000 survey results)
Letter, W. T. Cottle to E. W. Merschoff, South Texas Project Comprehensive Cultural
Assessment, April 17, 2002, ST-NOC-AE-02001277 (2001 survey results, focus groups in lieu
of surveys, notified of survey groups)
Letter, J. J. Sheppard to E. W. Merschoff, South Texas Project Comprehensive Cultural
Assessment, October 30, 2002, ST-NOC-AE-02001411 (2002 Focus groups results)
Letter, J. J. Sheppard to E. W. Merschoff, South Texas Project Comprehensive Cultural
Assessment, August 5, 2002, ST-NOC-AE-02001370 (Use Management Insights/Schedule for
2003)
Other Documents Reviewed
Maintenance Improvement Team Progress Report, October 1, 2002
1998 Safely Speaking Course Attendance Sheets
1999 Annual 10 CFR 50.7 Training Attendance Sheets
2000 Annual 10 CFR 50.7 Training Attendance Sheets
2001 Annual 10 CFR 50.7 Training Attendance Sheets
2002 Annual 10 CFR 50.7 Training Attendance Sheets
1998 President and CEO Bulletin - Issuance of Confirmatory Order, dated June 9, 1998
1998 President and CEO Bulletin - Electronic Bulletin Board Notice, dated June 11, 1998
1998 STP On-Line Bulletin - Cultural Survey Results, dated October 5, 1998
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Lesson Plan, SCT600.00.LP, Annual 10 CFR 50.7 Training, Rev 0
Lesson Plan, SCT600.00.LP, Annual 10 CFR 50.7 Training, Rev 1
LIST OF ACRONYMS
South Texas Project Nuclear Operating Company
South Texas Project
Publicly Available Records
Enforcement Action
Chief Executive Officer
NRC
Nuclear Regulatory Commission
CFR
Code of Federal Regulations