ML16342D444
| ML16342D444 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/26/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16342D443 | List: |
| References | |
| 50-275-96-22, 50-323-96-22, NUDOCS 9610030205 | |
| Download: ML16342D444 (20) | |
See also: IR 05000275/1996022
Text
ENCLOSURE 1
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
50-275, 50-323
License Nos.:
DPR-SO, DPR-82
Report No.:
50-275/96-22, 50-323/96-22
v
Licensee:
Pacific Gas and Electric Company
Facility:
Diablo Canyon Nuclear Power Plant, Units
1 and 2
Location:
7 1/2 miles NW of Avila Beach
Avila Beach, California
Dates:
September
9 through 17, 1996
Inspector:
F. R. Huey, Chief, Branch
E
Division of Reactor Projects
Approved By:
F. R. Huey, Chief, Branch
E
Division of Reactor Projects
ATTACHMENT:
Partial List of Persons
Contacted
List of Inspection Procedures
Used
List of Items Opened,
Closed, and Discussed
96i0030205
960926
ADOCK 05000275
8
EXECUTIVE SUMMARY
Diablo Canyon Power Plant Units
1 and 2
NRC Inspection Report 50-275/323/96-22
This special inspection reviewed licensee programs for addressing
and resolving employee
safety concerns.
~Oerationa
~
The licensee's
employee concerns
program procedures
and files appeared
satisfactory, and incorporated previous NRC comments.
However, interviews with
involved employees
identified several potential areas for improvement, including:
providing clearly documented
consensus
on the scope and character of identified
concerns;
providing clearly documented
resolution of concerns to involved
employees;
providing for third party review of sensitive issues;
and ensuring
thorough correction of identified problems.
~
The licensee was encouraged
to expedite plans to provide additional discrimination
sensitivity training to supervisors
and managers.
~
The licensee was encouraged
to expedite plans to implement peer review of the
employee concerns program.
Although Diablo Canyon has recently experienced
increased activity in the employee
concerns
area, the program remains staffed by only one individual.
It appeared
prudent to anticipate the likely need for expanded
resources
in that area.
~
The inspector noted several examples of missed opportunities for the licensee to
have corrected additional problems associated
with identified employee concerns.
One example, involving failure to properly document
an identified quality problem,
was treated as a noncited Violation. Other examples included the need for
additional effort to identify potential supervisory problems, and to critique employee
concerns
program responses
that did not satisfy the involved employees.
A final
example involved unresolved differences of technical opinion that were found to
exist among General Office engineering
personnel.
0
Report Details
Summar
of Plant Status
During this inspection both Diablo Canyon Units
1 and 2 operated
at 100% reactor power.
08
Miscellaneous Operations Issues
08.1
Back round and Pur ose (40001)
The Ckablo Canyon employee concerns
program
(ECP) was last reviewed by the
NRC in October 1993.
The review concluded that the licensee had implemented
a
nominal program that was unique in its emphasis
on total anonymity of employees
using the program.
The NRC found that the program was very infrequently used,
and associated
files provided limited information on the specifics of the licensee's
evaluation or conclusions related to the identified concerns.
It was noted, however,
that these findings were not inconsistent with a general NRC conclusion that the
licensee had implemented
a well functioning problem identification and corrective
actions program that appeared
to be founded on wide-spread
employee confidence
and satisfaction with the established
supervisory chain and routine problem
correction methods.
In response
to significant NRC insights gained during recent reviews of employee
concern problems at other facilities, and recognition of the potential impact of
ongoing reorganization initiatives on employees
at the Diablo Canyon plant, the NRC
determined that a followup review of the licensee's
ECP was warranted.
08.2
Review Strate
The review was organized into three parts.
The first part included
a review of the
current licensee procedures
and organization for its employee concerns program.
The second part included
a review of recent employee concern files which were
initiated by employees
available for followup interview by the NRC inspector.
These
interviews were focussed
on assessment
of employee satisfaction with the
employee concerns process,
and probed for insights into the employee's motivation
for use of that process.
The third part involved interview of selected licensee
employees to probe their attitudes about raising nuclear safety problems, and to
establish their confidence with licensee processes
for documenting,
evaluating, and
resolving those problems.
Employee interviews were focussed
into three areas:
operations
personnel involved in significant recent plant operational events;
technical maintenance
personnel affected by recent reorganization of their work
groups and reporting structure; and engineering
personnel involved in significant,
and protracted evaluation of problems which potentially affected operability of
significant plant equipment.
0
-2-
08.3
Observations
and Findin s
Procedures
and Files:
The licensee's
employee concerns program is implemented by
Inter-Departmental Administrative Procedure OM3.ID3, "Employee Concerns
Program (Quality Hotline)." The procedure
had been significantly improved from
that last reviewed by the NRC in October 1993, and incorporated
all NRC comments
provided during that review.
Likewise, the licensee's
employee concern files were
found to be well organized,
and consistently appeared
to clearly document
a
thorough evaluation of the employee's
concerns.
However, several additional areas
for improvement were noted during this review. It was also found that recent
changes
in organizational stability at Diablo Canyon have created new challenges for
the employee concerns program, as well as affecting the environment for employees
raising concerns.
Based on interviews with involved employees,
the inspector noted several areas for
potential procedure
enhancement:
The current program emphasizes
direct verbal contact with employees
about
their concerns,
both during initial problem identification and final problem
resolution.
However, employees were not routinely provided with a clearly
documented
statement of their concerns,
nor were they routinely provided
with a clearly documented
resolution of their concerns.
The NRC has found
that it is important to clearly document the character and scope of identified
concerns,
and to promptly solicit employee concurrence that concerns
have
been properly captured prior to expending resources to evaluate the concerns.
The NRC has also found that a clearly documented 'record of the licensee's
evaluation and resolution of an employee's
concerns can make a significant
positive impact on the employee.
b.
The inspector observed that several of the employee concern files had been
closed prior to completion of final corrective action for the identified concerns.
The inspector noted that pre-mature file closure, and failure to appropriately
follow-through on necessary
corrective actions may result in negative
reenforcement
of the employee concern process with affected employees,
and
those with whom they interact.
The inspector found that one employee had been specifically denied
a copy of
the licensee's
report of its evaluation and resolution of his concerns.
The
inspector noted that this did not appear to establish
an appropriate
environment for dealing with employee concerns,
and cautioned the licensee
to keep legal advice in proper perspective when dealing with concerned
employees.
d.
The inspector noted that the licensee's
program did not specifically recognize
the potential need for independent
third party review of discrimination
concerns,
or other types of concerns about licensee processes
which may
0
-3-
warrant independent
evaluation.
The NRC has found that licensees
can
establish good faith and credibility by promptly initiating reviews of
discrimination concerns
by knowledgeable
parties that are totally independent
of the licensee's
organization.
Su ervisor Mana
er Sensitivit
Trainin: The inspector noted that the licensee had
initiated plans to provide additional training for managers
and supervisors.
The
inspector encouraged
the licensee to expedite these plans, and to promptly
emphasize
additional discrimination sensitivity training for supervisors
and
managers.
This was noted as being particularly important during the current period
of heightened
stress at Diablo Canyon associated
with reorganization initiatives.
The inspector also noted the need to improve lines of communication to better
ensure employee understanding
and support of planned changes,
management
priority for problem resolution, and to avoid potential misunderstandings
associated
with new supervisory reporting structures.
For example, interviews associated
with
review of employee concern 96-05 indicated that planned changes to the program
for auditing of controlled documents
had not been effectively communicated to
involved employees.
Peer Review:
The inspector also noted that the licensee had initiated plans to
provide peer review of the Diablo Canyon employee concerns program, and
encouraged
the licensee to expedite these plans.
The inspector pointed out that
some Region IV licensees
have gained valuable, hard-earned
experience
and insights
on potential pitfalls associated
with management
and implementation of effective
programs.
Ex anded
Resources:
The inspector found that Diablo Canyon has recently
.experienced
increased activity in the employee concerns
area, yet the program
remains staffed by only one individual. It appeared
prudent to anticipate the likely
need for expanded
resources
in that area.
0
ortunities for Additional Corrective Actions: The inspector noted that the
licensee did not appear to have taken full advantage
of opportunities afforded by the
employee concerns
process to more thoroughly address
associated
problems.
The inspector also noted at least one instance of the need for additional
management
attention to employee problems that have not yet been effectively
addressed
by the normal supervisory chain.
The inspector emphasized that it is
particularly important to take prompt advantage
of opportunities to recognize and
resolve these types of problems before the involved employees
feel the need to
resort to other means to resolve their concerns.
The NRC has found that good
employees
are often reluctant to make a big deal of perceived supervisory or
management
problems until the problem becomes
so frustrating as to demand
attention.
Accordingly, it is important for licensee supervisors
and managers to be
skilled at recognizing and promptly acting on symptoms when they occur.
0
The inspector noted the following specific examples:
a ~
During review of employee concern
File 96-05, the inspector found that the
licensee had identified that a controlled copy of the plant manual had not
received an annual audit, as required by Administrative Procedure AD1.DC2
(now AD3.ID5), "Procedure Distribution and Control." The inspector further
noted that the licensee did not appear to have appropriately initiated an Action
Request to document and correct the problem, as required by Administrative
Procedure
OM7.ID1, "Problem Identification and Resolution-Action Requests."
In response to the inspector's concern, the licensee subsequently
confirmed
that an Action Request
had not been properly initiated, and action was taken
to initiate the required documents.
This violation is considered to be of minor
safety significance, and is being treated as a noncited Violation, consistent
with Section IV of the NRC Enforcement
Polic
. (50-275/96022-01)
The inspector noted that the licensee's
process
did not appear to attempt to
understand
why employees
chose to utilize the employee concerns
process
rather than using more routine methods.
Although it is important to ensure
that employees
are not discouraged
from using the employee concerns
program, it is also important to understand
whether the reasons for choosing
that process involve other problems which need to be recognized
and
resolved.
During interviews with selected employees,
the inspector identified
some potential problems which may warrant additional licensee followup.
For
example, review. of employee concern 96-05 indicated potential supervisory
concerns
(e.g., supervisor perceived
as being too busy, or lacking
understanding,
or lacking ownership for the employee's
concern).
C.
The inspector found that the licensee's
process
did not appear to ensure
a
formal means to understand
the reasons for unsuccessful
resolution of an
employee's
concern.
It this regard, employee concern Files 95-15, 96-10,
and 96-11 appear to represent situations in which concerns
have not been
resolved to the employee's satisfaction.
The inspector emphasized
the
importance of prompt identification of lessons to be learned from such
situations.
Significant experience at other facilities has demonstrated
that
failure to promptly assess
and correct these situations, before they are
repeated,
can result in significant degradation of employee morale,
confidence,
and trust.
Furthermore, these situations are frequently the result
of simple, inter-personal deficiencies that are readily corrected, if promptly
identified and communicated to involved parties.
The inspector also
emphasized
that, although it may not always be possible to achieve full
employee satisfaction, it is important to understand
the extent of employee
disenfranchisement,
and to minimize the potential impact on the overall work
environment.
The inspector interviewed several engineers
at the General Office about the
licensee's
process for evaluating plant engineering
issues which potentially
0
-5-
impact plant equipment operability.
These interviews focussed
on the
difficulties of communicating complex technical issues among several levels
within the licensee's
organization.
The inspector noted that the licensee
appeared
to have instilled a work environment which contributed to the
candor with which these employees
responded
to the NRC's questions.
The interviews involved two working-level engineers,
an engineering
supervisor,
and an engineering director associated
with evaluation of a
component cooling water flashing issue.
The interviews were noteworthy,
in
that they consistently identified similar concerns
and frustrations of inability to
effectively communicate differing opinions about the appropriateness
of
management
decisions to resolve this issue.
Although the inspector did not
attempt to independently
evaluate the bases for or appropriateness
of the
involved decisions, it was apparent that licensee management
had not
effectively communicated
the bases for those decisions to the involved
engineers.
Failure by management
to communicate to the involved engineers
the basis
for a decision on an issue where there were diverse opinions can result in
frustration, mistrust, and a reluctance to raise diverse opinions in the future.
Left un-evaluated
and uncorrected,
these problems can quickly undermine
an
organization's
rigor and effectiveness.
Licensee management
appears to
recognize the value of differing opinions similar to those involved in this issue.
It is equally important to properly follow-through with employees who offer
those opinions, both to ensure appropriate technical decisions,
and to ensure
the continued understanding
and support of those employees.
08.4
Conclusions
Past performance
has indicated
a generally healthy work environment for
identification and resolution of employee concerns at Diablo Canyon, and the
employee concerns
program appeared
adequate to the environment that existed.
However, recent reorganization initiatives have introduced potential challenges to
continuation of that healthy environment.
There have been several recent
indications that routine problem resolution and communication processes
are not
working as effectively as in the past, requiring additional attention to effective
employee concerns
program implementation,
and improvement of supervisory skills
in dealing with employee concerns.
It is important for licensee top management
to promptly, and effectively
communicate expectations for maintaining excellent performance
in this area, and to
provide the additional skills and insights to all levels of plant management
and
supervision necessary to ensure that, as future challenges
arise, a healthy
environment exists for employees to raise their concerns
and have them resolved.
0
-6-
V. Mana ement Meetin
s
X1
Exit Meeting Summary
The inspector presented
the inspection results to members of licensee management
at the
conclusion of the inspection on September
13 and 17, 1996.
The licensee acknowledged
the findings presented.
The inspector asked the licensee whether any materials examined during the inspection
should be considered
proprietary.
No proprietary information was identified.
0
-7-
PARTIAL LIST OF PERSONS CONTACTED
Licensee
J. Becker, Director, Operations
W. Crockett, Manager, Nuclear Quality Systems
T. Grebel, Manager', Regulatory Services
M. Jacobson,
Supervisor,
Nuclear Quality Systems
D. Oatley, Manager, Maintenance
R. Powers, Vice President
and Plant Manager
G. Rueger, Senior Vice President and General Manager "
D. Stetson,
Employee Concerns Program Engineer, Nuclear Quality Systems
D. Taggart, Director, Nuclear Quality Systems
By telephone
on September
18, 1996
0
-8-
INSPECTION PROCEDURES
USED
IP 40001: Resolution of Employee Concerns
ITEMS OPENED AND CLOSED
0 ened and Closed
50-275/96022-01
Failure to document identified quality problem