ML090280115
| ML090280115 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 01/28/2009 |
| From: | Collins S Region 1 Administrator |
| To: | Spence W PPL Corp |
| KROHN P, RI/DRP/PB4/610-337-5120 | |
| References | |
| EA-09-003 | |
| Download: ML090280115 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406-1415 January 28, 2009 EA-09-003 Mr. William H. Spence Executive Vice President Chief Operating Officer/Chief Nuclear Officer PPL Corporation Two North Ninth St., GENTW 16 Allentown, PA 18101-1179
SUBJECT:
WORK ENVIRONMENT ISSUES AT THE SUSQUEHANNA STEAM ELECTRIC STATION - POTENTIAL CHILLING EFFECT
Dear Mr. Spence:
As noted below, the NRC has conducted several inspections and investigations in response to allegations and concerns related to the safety conscious work environment (SCWE) at PPLs Susquehanna Steam Electric Station (Susquehanna). A safety conscious work environment is, in part, one in which employees are encouraged and feel free to raise safety concerns without fear of retaliation or discrimination.
In December 2006, the NRC advised PPL of concerns raised and feedback provided to agents of the NRCs Office of Investigations by workers at Susquehanna regarding the negative perceptions of the SCWE that existed among those performing refuel floor activities (ML063460470).1 In late 2006, PPL performed a site-wide culture survey, which indicated that some work groups, including maintenance and health physics, warranted additional attention.
In response to the 2006 survey results, PPL developed action plans and implemented several corrective actions through 2007 to address the identified work environment issues. Further, the NRC performed independent inspections throughout 2007, which indicated that PPLs actions to address work environment issues appeared appropriate (ML070330186, ML072070055, and ML080770308), and NRC annual allegation program trend reports noted some improvement in the work environment through 2006 and 2007 (ML071060192 and ML081650435).
In contrast to the 2007 trend, the NRC received a significantly increased number of allegations from onsite sources in early 2008, several of which involved concerns with the SCWE at Susquehanna.2 Using the allegation process, the NRC engaged PPL in March 2008 regarding multiple allegations with similar work environment concerns. However, in May 2008, PPL did not provide the NRC sufficient detail to support its assessment of the stations safety conscious work environment. As a result, the NRC re-engaged PPL in June 2008 requesting 1
Designation in parentheses refers to an ADAMS ascension number. ADAMS is the NRCs document system, accessible from the NRC web site at www.nrc.gov/reading-rm/adams.html. Documents referenced in this letter are publicly available using the ascension number in ADAMS.
2 NRC allegation statistics are publicly available at http://www.nrc.gov/about-nrc/regulatory/allegations/statistics.html.
W. Spence 2 additional details and bases regarding conclusions that PPL employees and contractors were willing to raise nuclear safety issues without fear of retaliation. In a June 2008 response, PPL concluded that the work environment at Susquehanna had declined and PPL attributed the decline, in large part, to (1) ineffective change management of personnel and work policies that occurred prior to the Spring 2008 refueling outage, and (2) selected events involving management that were widely known across the site and were negatively perceived by certain PPL staff. As a result, PPL developed a work environment improvement plan in August 2008 to address these issues and communicated the plan to employees in September 2008. The plan included a SCWE survey focused on the Operations, Maintenance, and Health Physics departments to be conducted by an independent, third party contractor during October 2008.
The NRC continued to review and monitor PPLs activities regarding SCWE through 2008. For example, in June 2008, the NRC inspected PPLs progress in completing actions planned in response to the 2006 culture survey. NRC inspectors observed that while the survey was developed and conducted with an appropriate plan, management of the overall effort appeared to be lacking in that some corrective actions in response to the 2006 survey were not completed and some follow-up activities identified issues for which corrective actions had not been developed (ML082250702). Also, in September and October 2008, the NRC conducted independent interviews of a cross-section of Susquehanna employees regarding the work environment. Although none of the employees interviewed indicated that they would not raise an actual safety concern, several individuals described negative perceptions of the SCWE and the Employee Concerns Program, as well as other work environment issues involving personnel and work policies (ML090230434).
Further, during November and December 2008, the NRC reviewed the results of PPLs October 2008 survey, conducted by the independent, third party contractor (ML090230434). The survey results indicated declining SCWE trends with broader organizational impacts when compared to the 2006 results. These results included negative comments regarding the willingness of a small number of workers to raise issues associated with nuclear safety. Finally, while interacting with onsite staff, the NRC observed that not all first-line supervisors and mid-level managers were fully supportive of efforts to improve the work environment. This observation was consistent with the assessment of an additional, independent, third party contractor conducted during September 2008.
The NRC acknowledges that more recently, PPL revised the work environment improvement plan during December 2008. As part of that plan, PPL created an Executive Review Committee to oversee work environment/SCWE issues and to ensure consistent application of personnel actions. In addition, PPL created a Susquehanna Work Environment Review Team to perform routine work environment and SCWE analyses. The NRC also acknowledges that, to date, the NRC has not substantiated occurrences of discrimination, identified specific instances where nuclear safety issues were not brought forward due to fear of retaliation, or identified during interviews individuals who said they would not bring forward nuclear safety concerns. However, the NRC is concerned with the progress and effectiveness of your actions in 2008 to address indications of a declining safety conscious work environment and negative employee perceptions, as it may impact employee willingness to raise safety concerns at Susquehanna and lead to a chilling effect at the site. Moreover, the NRC is also concerned that full alignment has not yet been achieved within the first-line supervisor and mid-level management ranks regarding support of efforts to improve the SCWE at Susquehanna.
Accordingly, the NRC requests that you provide: (1) a description of PPLs current action plans to address existing SCWE concerns to preclude a chilled work environment at Susquehanna;
W. Spence 3 (2) PPL plans for further evaluating the health of the SCWE at Susquehanna; and (3) the metrics you intend to monitor to determine the effectiveness of your actions and ensure a safety conscious work environment at the site. Based on our discussion with you on January 28, 2009, it is our understanding that PPL will provide this office with written information within 30 days of the date of this letter. Following receipt and review of the PPL response, we will determine if a meeting is needed to discuss your approach and schedule, and the NRCs planned oversight. Further, this issue will be a formal input to our assessment of plant performance for the period ending June 30, 2009, as described in Inspection Manual Chapter 0305, Operating Reactor Assessment Program, (ML082770835).
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC=s document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room). In addition, on May 14, 1996, the Commission issued a policy statement regarding the freedom of employees in the nuclear industry to raise concerns without fear of retaliation. This policy statement is accessible from the NRC Web site at http://www.nrc.gov/about-nrc/regulatory/allegations/scwe-frn-5-14-96.pdf.
Because your response will be placed and made available electronically for public inspection in the NRC Public Document Room or from the PARS component of ADAMS, to the extent possible it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your withholding claim (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
If you have any additional questions regarding these matters, please contact Paul Krohn at (610) 337-5120.
Sincerely,
/RA/
Samuel J. Collins Regional Administrator Docket Nos. 50-387; 50-388 License Nos. NPF-14, NPF-22
W. Spence 4 cc w/encl:
C. Gannon, Vice President, Nuclear Operations R. Paley, General Manager, Plant Support R. Pagodin, General Manager, Nuclear Engineering M. Crowthers, Manager, Nuclear Regulatory Affairs R. Smith, General Manager, Site Preparedness and Services D. Brophy, Supervisor, Nuclear Regulatory Affairs J. Helsel, Manager, Training D. McGann, Manager, Quality Assurance J. Scopelliti, Community Relations Manager B. Snapp, Esq., Associate General Counsel, PPL Services Corp Supervisor, Document Control Services, PPL Susquehanna, LLC R. Osborne, Allegheny Electric Cooperative, Inc.
D. Allard, Director, PA Dept of Environmental Protection Board of Supervisors, Salem Township J. Johnsrud, National Energy Committee, Sierra Club E. Epstein, TMI-Alert (TMIA)
J. Powers, Dir, PA Office of Homeland Security R. French, Dir, PA Emergency Management Agency A. Dimperio, Area Director, OSHA
W. Spence 3 (2) PPL plans for further evaluating the health of the SCWE at Susquehanna; and (3) the metrics you intend to monitor to determine the effectiveness of your actions and assure a safety conscious work environment at the site. Based on our discussion with you on January 28, 2009, it is our understanding that PPL will provide this office with written information within 30 days of the date of this letter. Following receipt and review of the PPL response, we will determine if a meeting is needed to discuss your approach and schedule, and the NRCs planned oversight. Further, this issue will be a formal input to our assessment of plant performance for the period ending June 30, 2009, as described in Inspection Manual Chapter 0305, Operating Reactor Assessment Program, (ML082770835).
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC=s document system (ADAMS).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room). In addition, on May 14, 1996, the Commission issued a policy statement regarding the freedom of employees in the nuclear industry to raise concerns without fear of retaliation. This policy statement is accessible from the NRC Web site at http://www.nrc.gov/about-nrc/regulatory/allegations/scwe-frn-5-14-96.pdf.
Because your response will be placed and made available electronically for public inspection in the NRC Public Document Room or from the PARS component of ADAMS, to the extent possible it should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your withholding claim (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
If you have any additional questions regarding these matters, please contact Paul Krohn at (610) 337-5120.
Sincerely,
/RA/
Samuel J. Collins Regional Administrator Distribution w/encl: (via e-mail)
See attached page SUNSI REVIEW COMPLETE: ____PGK________(Reviewers Initials)
DOCUMENT NAME: G:\DRP\BRANCH4\SUSQUEHANNA\CHILLING EFFECT LETTERS\SQ CEL JAN 2009\SQ CEL JAN 2009 REV12.DOC After declaring this document An Official Agency Record it WILL be released to the Public. Adams Accession No. ML090280115 To receive a copy of this document, indicate in the box: C" Copy without attachment/enclosure "E" Copy w /attachment/enclosure "N" No copy OFFICE RI/DRP RI/OI RI/ORA RI/ORS RI/DRP NAME PKrohn/PGK EWilson/
- KFarrar/KF DHolody/DH DLew/DCL DATE 1/22/09 1/ 23/09
- per email 1/ 26 /09 1/ 26/09 1/26 /09 OFFICE HQ/NRR/DIRS HQ/OE HQ/OE RI/RA NAME FBrown/RFranovich *** LJarriel/ ** CCarpenter/ ** SCollins/
DATE 1/26/09 *** per email 1/23 /09 ** per email 1/23/09 ** per email 1/27/09
W. Spence 4 OFFICIAL RECORD COPY
W. Spence 5 Distribution w/encl: (via e-mail)
S. Collins, RA M. Dapas, RA D. Lew, DRP J. Clifford,DRP P. Krohn, DRP R.Fuhrmeister, DRP T. Setzer, DRP E. Torres, DRP F. Jaxheimer, DRP P. Finney, DRP, RI S. Farrell, DRP, OA D. Roberts, DRS R. Conte, DRS G. Meyers, DRS E. Wilson, OI K. Farrar, ORA D. Holody, ORA B. Boger, NRR F. Brown, NRR M. Cheok, NRR L. Jarriel, OE D. Vito, OE C. Carpenter, OE S. Campbell, RI OEDO T. Kobetz, NRR R. Nelson, NRR M. Kowal, NRR J. Andersen, NRR B. Vaidya, NRR, PM J. Hughey, Backup, NRR G. Dacus, OCA S. Imboden, NRO W. Burton, NRO S. Freeman, NRO B. Adkins, NRO B. Holian, NRR D. Pelton, NRR S. Lee, NRR C. Marco, OGC ROPreportsResource@nrc.gov Region I Docket Rm w/concurrences)