ML032030590

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Submittal of Supplemental Information & Slides from Pre-Decisional Enforcement Conference on 07/16/03
ML032030590
Person / Time
Site: Kewaunee 
Issue date: 07/18/2003
From: Coutu T
Nuclear Management Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
FOIA/PA-2006-0113, NRC-03-080
Download: ML032030590 (57)
v • d • e


Text

NMCA Committed to Nuclear Excellence Kewaunee Nuclear Power Plant Operated by Nuclear Management Company, LLC NRC 03-080 July 18, 2003 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 KEWAUNEE NUCLEAR POWER PLANT DOCKET 50-305 LICENSE No. DPR-43 SUBMITTAL OF SUPPLEMENTAL INFORMATION AND SLIDES FROM THE JULY 16, 2003 PRE-DECISIONAL ENFORCEMENT CONFERENCE On July 16, 2003, a pre-decisional enforcement conference was conducted between representatives of the Nuclear Management Company, LLC (NMC) and members of your Staff to discuss apparent violations related to the Fitness For Duty Program at the Kewaunee Nuclear Power Plant. During the presentation, supplemental information was discussed regarding additional investigation interviews conducted during June 2003. Attachment 2 to this letter contains documentation of these interviews as requested by your staff during the meeting. provides a statement requesting that the investigation information be withheld from public disclosure pursuant to 10 CFR 2.790. to this letter provides a copy of the slide presentation used during the July 16, 2003 meeting. As noted during the meeting, slide 19 contained an error. Attachment 4 contains a corrected copy of the presentation.

As a result of the information conveyed at the July 16, 2003 Pre-enforcement Conference, NMC will be conducting additional interviews.

If you have any questions, please contact Gordon P. Arent at 920/388-8537.

Thomas Coutu Site Vice-President, Kewaunee Plant GPA cc:

US NRC, Senior Resident Inspector, w/o attach.

US NRC, Region l1l, w/o attach.

US NRC, KNPP Project Manager, w/o attach.

Electric Division, PSCW, w/o attach.

KNPP QA Vault, w/o attach.

Attachment N490 Highway 42

  • Kewaunee, Wisconsin 54216-9510 Telephone: 920.388.2560

NRC 03-080 July 18, 2003 bcc:

J. P. Cowan L. L. Weyers T. J. Webb T. Coutu A. Capristo G. P. Arent S. L.Campion (2)

K. A.Hoops E. J. Weinkam III

NRC 03-080 July 18, 2003 ATTACHMENT 1 NUCLEAR MANAGEMENT COMPANY, LLC KEWAUNEE NUCLEAR POWER PLANT DOCKET 50-305 LICENSE NO. DPR-43 July 18, 2003

AFFIDAVIT OF THOMAS COUTU NUCLEAR MANAGEMENT COMPANY. LLC I am Thomas Coutu, Site Vice President, Kewaunee Nuclear Power Plant, Nuclear Management Company, LLC (NMC). I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant investigation activities, and am authorized to apply for its withholding on behalf of NMC.

I am making this Affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the NMC application for withholding accompanying this Affidavit.

I am authorized to execute this Affidavit on behalf of NMC and that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information and belief.

Pursuant to the provisions of Paragraph (b)(4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information "sought to be withheld from public disclosure" should be withheld:

(i)

The information is owned and has been held in confidence by NMC.

(ii)

The information is explicitly held in confidence by NMC and not to be disclosed to the public. NMC, through the use of an independent investigator, conducted interviews in support of a Fitness For Duty concern raised at the Kewaunee Nuclear Power Plant.

These interviews contain information of a personnel nature and were conducted in confidence. NMC requests that this information be withheld from public disclosure because it represents "Personnel and medical files and similar files, the disclosure of which would constitute a clearly unwarranted invasion of personal privacy," in accordance withl 0 CFR 2.790(a)6.

The proprietary information "sought to be withheld" in this submittal is provided in and contains the headings, Report of Interview, Affidavit, and Review of Personnel File.

(iii)

The information is being transmitted to the Commission in confidence, and under the provisions of 10 CFR 2.790, it is to be received in confidence by the Commission.

(iv)

The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

Thomas Coutu Site Vice President Kewaunee Nuclear Power Plant Sworn to and Subscribed before me this 18th day of July 2003 4S ff-)

.zLF Kim uescher Notary Public, State of Wisconsin My Commission Expires March 12, 2007

/ _ _- _

NRC 03-080 July 18, 2003 ATTACHMENT 3 NUCLEAR MANAGEMENT COMPANY, LLC KEWAUNEE NUCLEAR POWER PLANT DOCKET 50-305 LICENSE NO. DPR-43 July 18, 2003

X lN;MC

'il

,l Committed to Nuclear Excellence Kewaunee Nuclear Power Plant Pre-Decisional Enforcement Conference July 16, 2003

Kewaunee Nuclear Power Plant Ire-Decisional Enforcement Conference Agenda Purpose - Coutu

Objective - Coutu Results of Investigation - Coutu Investigation Details - Cleveland Effect on Safety Conscious Work Environment - Capristo

.Actions Taken by NMC - Cleveland/Capristo Summary - Coutu Cnmtdto MOSTxcfe~

Purpose To provide the NRC with the facts that NMC's investigations revealed regarding Allegation 1, welders deliberately failed to 1,,report Fitness-For-Duty (FED) concerns and a contract V.Mechanical and Civil Superintendent deliberately failed to report a FFID concern involving a Foreman.

.To provide the NRC with the facts that NMC's investigations Urevealed regarding Allegation 3, a contract Mechanical and Civil MeacaCvSuperintendent provided false information to the NMC's inestigator relative to being informed about the FED concern involving a Foreman.

To provide the NRC insights from the NMC's evaluation of the

-pterntial for "chilling effects.

To provide the NMeC's conclusions concerning a pote ial Tpviolation.

Gomilie I I Nuerxfen~

3

Objective To show that the NMVC investigation was thorough Hand conclusions were based on the facts as identified by the NMC.

To demonstrate how NMVC carried out its FED obligations based on the information that was obtained during two related investigations.

To explain how NMVC maintained a Safety Conscious WorkEnvironment (SCWE) during this investigation and the following period.

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xet 4

Results of Investigation

Background

liegation: Day & Zimmerman NPS (D&Z) supervisors turn mer heads when certain individuals come in "half-blitzed."

Ue to the potential seriousness of the issue, an independent ivestigator (Walker Investigative Consultants) was retained to omplete a comprehensive investigation.

IMC's investigative efforts and conclusions were summarized n'dreported to the NRC in a letter dated February 8, 2002.

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Results of Investigation Initial Investigation Iniialinvestigation identified four individuals who stated that on occasion they perceived the odor of alcohol on the breath of a D&Z Foreman while inside the Kewaunee protected area.

None of the individuals notified their immediate supervisor or oher member of management at that time.

All four individuals who detected the odor of alcohol on the breath of the D&Z Foreman were aware of their responsibility to report or act.

Access was denied to three individuals who detected an odor of alcohol on the breath of the D&Z Foreman and did not(pr this to their supervisor.

7 N~i

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a:,,.:5 : X~~~~~~~~~~~~~~~~~~~~~~~

Results of Investigation Supplementary Investigation Supplementary investigation was undertaken flblowing communication by a Concerned Individual to~, NMVC Employee Concerns Program (ECP) wishing to: poie additional observations relative to the initial investigation.

This Concerned Individual provided two new elements of concern.

Both elements were investigated and were n substantiated.

(

NucerEcl 7

Results of Investigation Conclusion

-ern partially substantiated.

  • It could not be concluded that the D&Z Foreman was unfit for duty.
  • It was concluded that the odor of alcohol was detected.
The D&Z Superintendent failed to comply with the NMC's FFD Program.
  • It was not substantiated that any welder reported the odor of alcohol to the immediate supervisor or any member of management. 

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Cor~dvNrIeM cef~

8

Results of Investigation Summary The NMC did not substantiate the allegation that the odor of alcohol had been reported to the

'Contract Mechanical and Civil Superintendent NMC did not conclude that the contract Mechanical and Civil Superintendent provided incomplete or inaccurate information A, "chilling effect" has not been created at NMC facilities as a result of this FFD issue These findings do not support escalated enforcement

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C(mmitted to Nv Meer I

9

Kewaunee Nuclear Power Plant we-Decisional Enforcement Conference Investigation Details N-.

~

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10

Investigation Details NMC's Conclusion The Mechanical and Civil Superintendent was not informed of an odor of alcohol.

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11

Investigation Details Four welders deliberately failed to report the odor of alcohol Welders adequately trained

  • Prior to denial of access, welders admitted failure to report
  • Welders provided their reasons for not reporting
  • Don't create waves, keep eyes open, and mouth shut
  • Not my job to sniff others
  • Supervisors were aware of the D&Z Foreman's drinking habits; therefore, there was no reason to report and he was a fellow worker
  • Feared union reprisal

(

.CoimMed to Nulear 12

Investigation Details JContract Superintendent Did Not Fail to Act on Welder Reports

  • A fifth welder claimed to have reported the odor of alcohol to the contract Superintendent
  • NMC investigation found welder not credible
  • Contradictory statements
  • Uncorroborated claims and statements
  • Threat made to Superintendent

..~~~~~~~~~~

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co= m.t 13

Investigation Details Fifth Welder Credibility Contradictory statements made to NMC Investigators Example I

  • "...[foreman] loaded every morning..."

versus

  • "didn't know anything about foreman being drunk..."

Example 2

  • Escorted by foreman to collection site versus
  • Not escorted by foreman to collection site Example 3
  • Collector acknowledged the foreman as "a little ripe" versus
  • Foreman was not at collection site and collector "appeared puzzled" when challenged regarding foreman's fitness CmmtdtNulea xefee 14 r'~.

Investigation Details Fifth Welder Credibility Uncorroborated claims and statements made to NMVC Investigators

  • Claimed foreman and co-worker went through access control together.

One hour later he claimed the co-worker was for-cause tested

  • Claimed collector acknowledged foreman as not fit for duty
  • Provided a document (twice-removed hearsay) alleging that the Superintendent admitted to receiving reports of odor of alcohol and lying to investigators IVNcla Ecf 15

Investigation Details Fifth Welder Credibility Statements to Superintendent - June 2001

Claims he (fifth welder) should have been set up as foreman.
  • States foreman is an "idiot."
  • States he is not going to "burn rod for the rest of his life."
  • Threatens to "get even, and when I do you people won't know what hit you."
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,)C 16

Investigation Details Conclusion The NMC investigation concluded that the Mechanical and Civil Superintendent was not informed of an odor of alcohol.

Commtted to Nudner 17

Kewaunee Nuclear Power Plant Pre-Decisional Enforcement Conference Effect on Safety Conscious Work Environment doNuereen 18

Zffect on Safety Conscious Work Environment Introduction

'NMC self-identified the potential for a "chilling effct"and took actions to address the Safety ConsciousWork Environment (SCWE) throughout this period The basis for the NMC's conclusion that the

,-,.~Kewaunee FFD issue did create a "chilling effect" atKewaunee orother NMC facilities NIV F-ornmftfsdo Nucntroductfion 19

fect on Safety Conscious Work Environment Evaluations NMC Fleet Safety Culture Assessment Concerns Environment Assessment Investigation in Response to NRC RAI 02-A-01 14 Commfttej

,oNcerFree z I,:

20

ffect on Safety Conscious Work Environment NMVC Fleet Safety Culture Assessment Independent assessment completed by Synergy in September Respnsefor contract labor "Good" to "Very Good" in the areas

~of Nclear Safety and SOWE Litechange identified in follow-up assessment completed Jnuary 2003

/

NIMC 21

fect on Safety Conscious Work Environment Concerns Environment Assessment Report on the SCWE at Point Beach completed by Dr. Michael Quinn, Sc.D. of Management Systems on January 31, 2002 DZworkforce common to Kewaunee and Point Beach "Cauesof challenges to SCWE reviewed and actions taken

^ None related to the Kewaunee FED issues

  • Causes related to craft labor culture GfnIttod Nudiw~cfeic 22 I I a-S, :

9

fect on Safety Conscious Work Environment Investigation in Response to This Kewaunee FFD Issue (NRC RAI 02-A-01 14)

,Investigation initiated by NMC to evaluate the potential impact on' the SCWE Interviewees indicated no reluctance to raise safety-related

'issues onclusion: No evidence of a chilling effect at NMC facilities ha s been created because of the actions taken as a result of this FFD issue cam l

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.. ~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~~~~~~M t

to 23

Actions Taken by NMC NMC Access Authorization form updated FED Program communication issued to NMC employees and contractors D&Z superintendent coached and counselled General Employee Training test question revised Releantprocedure clarified

'NMC and D&Z management met with union officials:t

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24

Kewaunee Nuclear Power Plant

're-Decisional Enforcement Conference Summary NMC did not substantiate the allegation that the odor of alcohol had been reported to the contract Mechanical and Civil Superintendent

NMC did not conclude that the contract Mechanical and Civil Superintendent provided incomplete or inaccurate information A.-"chilling effect" has not been created at NMC facilities as a result of this FED issue These findings do not support escalated enforcement Niiii U10o NucEX a xeffenc 25

NRC 03-080 July 18, 2003 ATTACHMENT 4 NUCLEAR MANAGEMENT COMPANY, LLC KEWAUNEE NUCLEAR POWER PLANT DOCKET 50-305 LICENSE NO. DPR-43 July 18, 2003

Committed to Nuclear Excellence Kewaunee Nuclear Power Plant Pre-Decisional Enforcement Conference July 16, 2003 I

Kewaunee Nuclear Power Plant are-Decisional Enforcement Conference Agenda Purpose - Coutu Objective - Coutu Results of Investigation - Coutu

.investigation Details - Cleveland

,Effect on Safety Conscious Work Environment - Capristo Actions Taken by NMC - Cleveland/Capristo Summary-Coutu I-mmftdt hJs.c#ne" 2

Purpose To provide the NRC with the facts that NMC's investigations revealed regarding Allegation 1, welders deliberately failed to report Fitness-For-Duty (FED) concerns and a contract Mechanical and Civil Superintendent deliberately failed to report a --'FED concern involving a Foreman.

To provide the NRC with the facts that NMC's investigations

-revealed regarding Allegation 3, a contract Mechanical and Civil Superintendent provided false information to the NMC's investigator relative to being informed about the FED concern Involving a Foreman.

T o provide the NRC insights from the NMC's evaluation of the potential for "chilling effects."

To provide the NMC's conclusions concerning a pote tial violation.

CWrNW tonero NuivlngaceFrmn 3

Objective T

sow that the NMC investigation was thorough and conclusions were based on the facts as identified by the NMC.

To demonstrate how NMC carried out its FFD obligations based on the information that was

.obtained during two related investigations.

6To explain how NMC maintained a Safety Conscious Work Environment (SCWE) during this investigation and the following period.

NIMI6 do Mi Ma

Nefe, 4

Results of Investigation

Background

0legation: Day & Zimmerman NPS (D&Z) supervisors turn heir heads when certain individuals come in "half-blitzed."

)ue to the potential seriousness of the issue, an independent ivestigator (Walker Investigative Consultants) was retained to

omplete a comprehensive investigation.

iIMC's investigative efforts and conclusions were summarized

!nd reported to the NRC in a letter dated February 8, 2002.

tinrnlto Nuc/W.

62ek':',. ' :~~~~~~~~~~~~~~~~~~~~~~~~~~~

j 1E 0Results of Investigation Initial Investigation r t i.Initial investigation identified four individuals who stated that on occasion they perceived the odor of alcohol on the breath of a D&Z Foreman while inside the Kewaunee protected area.

o of the individuals notified their immediate supervisor or other member of management at that time.

~ ~llfor individuals who detected the odor of alcohol on the 1 Sbreath of the D&Z Foreman were aware of their responsibility to r~a9 t k rport or act.

Access was denied to three individuals who detected antodor of alcohol on the breath of the D&Z Foreman and did not Peort this to their supervisor.

i;:

4iiii:

I x ommitt#W to NW a eExmft m 5~

/~~~~~~~~~~~

. I.

~~~6

Results of Investigation Supplementary Investigation Supplementary investigation was undertaken following communication by a Concerned Individual to' NMC Employee Concerns Program (ECP) wishing to:: provide additional observations relative to the initial investigation.

This Concerned Individual provided two new elements of concern.

Both elements were investigated and were no substantiated.

(

NI iI

?d to Nu~aEkoeffer 7

Results of Investigation Conclusion icern partially substantiated.

] It could not be concluded that the D&Z Foreman was unfit for duty.

  • It was concluded that the odor of alcohol was detected.
  • The D&Z Superintendent failed to comply with the NMC's FFD Program.

I*

t was not substantiated that any welder reported the odor of alcohol to the immediate supervisor or any member of management.

0 : 0,, ~~~~~~~~~~~~~~~~~~~~~~~~~GO~

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Results of Investigation Summary The NMC did not substantiate the allegation that

.the odor of alcohol had been reported to the contract Mechanical and Civil Superintendent

'NMC did not conclude that the contract Mechanical and Civil Superintendent provided incomplete or inaccurate information A "chilling effect" has not been created at NMC facilities as a result of this FFD issue These findings do not support escalated

,,enforcement

_M(

9

Kewaunee Nuclear Power Plant e-Decisional Enforcement Conference Investigation Details

.dto Nudel

Exceffne, 5

10

Investigation Details NMC's Conclusion rhe Mechanical and Civil Superintendent was not nformed of an odor of alcohol.

,, ", , r, " :

comite fo Nude. Excefterm 11

Investigation Details Four welders deliberately failed to report the odor of alcohol Welders adequately trained

  • Prior to denial of access, welders admitted failure to report
  • Welders provided their reasons for not reporting
  • Don't create waves, keep eyes open, and mouth shut
  • Not my job to sniff others
  • Supervisors were aware of the D&Z Foreman's drinking habits; therefore, there was no reason to report and he was a fellow worker Feared union reprisal dto WuCfteftmcefl 12

Investigation Details Contract Superintendent Did Not Fail to Act on Welder Reports A fifth welder claimed to have reported the odor of alcohol to the contract Superintendent NMC investigation found welder not credible

  • Contradictory statements
  • Uncorroborated claims and statements Threat made to Superintendent
  • OMInfnWdI to der&xffenmo 13

Investigation Details Fifth Welder Credibility Contradictory statements made to NMC Investigators Example I

"...[foreman] loaded every morning..."

versus

.* didn't know anything about foreman being drunk..."

Example 2

  • Escorted by foreman to collection site versus 0* Not escorted by foreman to collection site Example 3
  • Collector acknowledged the foreman as "a little ripe" versus
  • Foreman was not at collection site and collector "appeared puzzled" when challenged regarding foreman's fitness

~~~~~t Afnck 14

Investigation Details Fifth Welder Credibility Uoncorroborated claims and statements made to NMVC Investigators

  • Claimed foreman and co-worker went through access control together.

One hour later he claimed the co-worker was for-cause tested

  • Claimed collector acknowledged foreman as not fit for duty
  • Provided a document (twice-removed hearsay) alleging that the Superintendent admitted to receiving reports of odor of alcohol and lying to investigators 15

~,-

Investigation Details Fifth Welder Credibility Sta~tements to Superintendent - June 2001 Claims he (fifth welder) should have been set up as foreman.

States foreman is an "idiot."

States he is not going to "burn rod for the rest of his life."

Threatens to "get even, and when I do you people won't know what hit you.T...~ ~ ~ ~ ~ ~ ~

~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~~~~~~~~~~~~~~~~~Cmnts toNrde.,ete II

.~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~CMe to

' f,

16

Investigation Details Conclusion The NMC investigation concluded that the Mechanical and Civil Superintendent was not informed of an odor of alcohol.

NI1II

Commftted to Nuclear Frceffence I

17

I Kewaunee Nuclear Power Plant

-!Pre-Decisional Enforcement Conference Effect on Safety Conscious VWork Environment lCom~,

mftde to N cEarxcffencs j.-,51 18

Ffect on Safety Conscious Work Environment Introduction NMC self-identified the potential for a "chilling effect" and took actions to address the Safety Co:nscious Work Environment (SCWE) throughout this period he basis for the NMC's conclusion that the Kewaunee FED issue did not create a "chilling effct"at Kewaunee or other NMC facilities NM

_*MMftd o tNUcer 19

Rfect on Safety Conscious Work Environment Evaluations

  • NMC Fleet Safety Culture Assessment
  • Concerns Environment Assessment
  • investigation in Response to NRC RAI 02-A-01 14 dto Nu~aExceffe5 o

20

ffect on Safety Conscious Work Environment NMC Fleet Safety Culture Assessment

.Independent assessment completed by Synergy in September 2001 Response for contract labor "Good" to "Very Good" in the areas bfNuclear Safety and SCWE Little change identified in follow-up assessment completed January 2003

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fect on Safety Conscious Work Environment ocen Eniomn Assmn Reor onteSW tPin ec opeedb r

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.Quin Sc.D. ofMngmn Sseso anay3,20 D&.okoc omnt Kwue n

on ec Case of chlene toSW rveeadatonae Non reaeoteKwaneFDise

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'ect on Safety Conscious Work Environment investigation in Response to This Kewaunee FFD Issue (NRC RAI 02-A-01 14) nvestigation initiated by NMC to evaluate the potential impact an the SCWE nterviewees indicated no reluctance to raise safety-related ssues

&onclusion: No evidence of a "chilling effect" at NMC facilities has been created because of the actions taken as a result of this FFD issue dtoNucbearExceffenc9 23

Actions Taken by NMC

-NMVC Access Authorization form updated

.FFD Program communication issued to NMVC employees and contractors

,D&Z superintendent coached and counselled "General Employee Training test question revised Relevant procedure clarified

,NMC and D&Z management met with union

~~Officials

.doNueaExenc 24

Kewaunee Nuclear Power Plant

'.re-Decisional Enforcement Conference Summary

.NMC did not substantiate the allegation that the odor of alcohol had been reported to the contract Mechanical and Civil Superintendent NMCdid not conclude that the contract Mecanialand Civil Superintendent provided incomplete or inaccurate information A chilling effect" has not been created at NMVC facilities as a result of this FED issue Tese findings do not support escalated enforcement ed to Nocd &eErceer' 25

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