ML17229A416
| ML17229A416 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/16/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17229A417 | List: |
| References | |
| 50-335-97-08, 50-335-97-8, 50-389-97-08, 50-389-97-8, NUDOCS 9707250101 | |
| Download: ML17229A416 (10) | |
See also: IR 05000335/1997008
Text
i
U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved By:
50-335,30-389
50-335/97-08, 50-389/97-08
Florida Power and Light Company
St. Lucie Nuclear Plant,
Units 1 8 2
6351 South Ocean Drive
Jenson Beach, FL 34957
June 9-20, 1997
June 26, 1997
Joseph
B. Brady, Team Leader
Lori C. Stratton, Safeguards
Inspector
David R. Lanyi, Resident Inspector
Paul E. Fredrickson, Chief
Special Inspection Branch
9707250101
970716
ADOCK 05000335
8
EXECUTIVESUMMARY
St. Lucie Nuclear Plant, Unit 1 8 2
NRC Inspection Report 50-335/97-08, 50-389/97-08
This special inspection reviewed the licensee's program for addressing
and resolving
employee safety concerns.
Procedures
were satisfactory in that they were clear, concise, and thoroughly
documented
the Speakout process.
The Speakout program was effective in investigating individuals'oncerns.
Safety-
related employee concerns were being adequately resolved.
A weakness was identified in that Speakout did not take responsibility to verify that
.
employee concern related corrective actions were completed.
Concern resolution had
not been included as a key element of the Speakout program, and it resided with line
management.
The lack of this element had led employees to the perception that
Speakout was ineffective.
The program had improved in transmitting the results of the investigations to the
concerned
individuals.
It was further concluded that improvement would be necessary
to establish full employee confidence.
Speakout closure letters to employees with
substantiated
concerns were often sent prior to completion of corrective action.
No
follow-up letters were sent to announce when a concern was resolved.
Speakout was readily accessible,
and employees were familiar with the various
avenues
available to express their concerns.
0
During interviews, employees questioned the effectiveness of the Speakout program.
Interviews with managers
indicated that management
was unaware of the reason for
this perception.
Report Details
08
Miscellaneous Operations Issues
08.1
Resolution of Em lo ee Concerns (40001)
The St. Lucie Nuclear Plant employee concerns
program (ECP), was last reviewed by
the NRC in April 1996.
This review was documented
in Inspection Report 50-335/96-
07, 50-389/96-07;
The review concluded that the program was effective in handling
and resolving employee safety concerns.
The NRC identified several weaknesses
associated
with the implementation of the Florida Power and Light Company (FPBL)
ECP.
Specifically; (1) investigative techniques and methods used to make corrective
action recommendations
had the potential to reveal albeit inadvertently the identity of
the concerned employee; (2) letters to the concerned employee did not provide
adequate feedback; and (3) corrective action recommendations
were not tracked
through implementation.
4
In response
to these weaknesses,
recognition of ongoing organizational changes
at
St. Lucie, and other NRC insights, the NRC determined that a followup review of the
licensee's
ECP was warranted.
The review was organized into three parts.
The first part included a review of the
licensee's current procedures
and organization of the ECP.
The second part included
a review of recent employee concern files. The third part involved interviews of
randomly selected licensee employees and supervisors to gain insight into their views
about raising nuclear safety problems and to determine their confidence level with
licensee processes
for documenting, evaluating, and resolving those problems.
Observations and Findin s
Procedures
and Organization
The licensee's
ECP is designated
as "Speakout" and is implemented by Nuclear
Division Policy NSS-1, "Nuclear Safety Speakout Program," Revision 6, dated
April 11, 1997.
Additionally, Site Administrative Procedure ADM-21.01, "Nuclear
Safety Speakout Program," Revision 0, dated January 22, 1997, implemented the
St. Lucie ECP.
Classification of employees'oncerns
were appropriately assigned within the
pr'ocedures.
Concern classification were as follows:
Class
1 - Nuclear Safety or Quality concerns
Class 2 - Management concerns
Class 3 - Industrial Safety concerns
Class 4 - Security and potential wrongdoing concerns
Class 5 - Miscellaneous concerns
The licensee's current procedures
documented
responsibilities of the Speakout
Review Committee (SRC).
The SRC was established
to ensure that concerns were
appropriately classified and that investigative reports were responsive to the concern.
In addition, cognizant line organization Department Heads were tasked with
investigating any concerns
assigned
by Speakout and determining, initiating, and
following through corrective actions with appropriate Plant Management.
Speakout procedures were generally adequate
in that they were clear, concise, and
thoroughly documented
the Speakout process.
The inspectors observed that for
substantiated
concerns, ownership by Speakout was relinquished before the corrective
actions were completed and the concern resolved.
The President, Nuclear Division, has overall responsibility of the Speakout programs
at St. Lucie and Turkey Point. The Director of Nuclear Assurance
reviewed the
classification and assignments
of concerns
at both facilities on a monthly basis and
reported potentially significant concerns to the President.
Additionally, the Nuclear
Safety Supervisor generally implemented and maintained the Speakout program at
.. both St. Lucie and Turkey Point, in addition to serving as Chairman, of the SRC at
each location.
Two investigators were assigned to each site, with line organization
Department Heads providing support on a as-needed
basis.
On September
5, 1996, the President,
Nuclear Division, issued a Statement of Policy
to all nuclear personnel reiterating FP8L's continuing expectation of maintaining a
safety conscious environment and providing encouragement
to discuss safety
concerns with their supervisor, management,
Speakout, and the NRC.
Employee Concerns Files
The inspectors reviewed approximately 70 closed Speakout files dating from 1995
through 1997.
The inspectors noted that approximately two thirds of the total number
of concerns were associated
with Personnel/Human
Relations issues, as opposed to
nuclear safety.
Sixteen Class
1 safety related files were reviewed in detail.
Generally, the inspectors noted that the investigations were good.
Closeout timeliness
has shown marked. improvement in the last two years, although closeouts were
occurring before corrective actions were complete.
The inspectors looked for various attributes to ensure that the Speakout program was
effective.
First, the inspectors checked to determine if the concerned individual's
assertions
had been thoroughly investigated; the findings documented,
and if
appropriate corrected, and the results reported to the individual. The inspectors
observed that the investigation and the documentation were usually well done.
However, the Speakout program had no formal method of instituting corrective actions
for substantiated
concerns.
The Speakout investigators would draft corrective action
recommendations
for the appropriate manager to accept, modify, or decline.
Speakout remained actively involved in the recommendations
until these were
accepted
by the appropriate management,
but Speakout relinquished ownership for
resolving the concern once the recommendations
were accepted.
Although Speakout
maintained a tracking data base, the inspectors found that there was no verification
function in the program to ensure that corrective actions were completed.
This was
considered
a weakness of the program and as discussed
below, has led to apparent
employee dissatisfaction.
The inspectors observed that individual concern closure occurred early in the process.
Speakout sent a closure letter shortly after the investigative process was completed.
For substantiated concern, the concerned
individual was not informed of corrective
action completion in the letter.
Furthermore, the inspectors noted those letters for
unsubstantiated
concerns were still quite terse.
The inspectors noted that many
workers apparently believed that Speakout was ineffective. A large portion of this
belief was attributable to the lack of information given to the concerned
individuals
about their concerns.
Speakout stated they encouraged
face-to-face exits with the
concerned
individual. Although face-to-face exits appeared
to be effective, the
inspectors did note that the vast majority of people did not return.
The inspectors reviewed the closeout letters to concerned individuals and found them
lacking some information. The inspectors believed that closeout letters should give
sufficient detail to the individual so there would be a clear understanding
of how the
concern was investigated and what the results were (substantiated
or
unsubstantiated).
The inspectors observed that the description of the investigation
had improved since the previous inspection.
Additionally, corrective actions for
substantiated
concerns were identified in the letters as recommendations.
This
.
indicated to the inspectors that ownership to correct substantiated
concerns
had
transferred from Speakout to the line organization.
In addition, the inspectors did not
find letters with a schedule for corrective action completion or followup letters to
inform the concerned individual of the corrective action completion.
Although the
inspectors noted that the Speakout program's closure letters had improved in
providing details of the investigation since the last Speakout inspection (Inspection
Report 50-335/389-96-07),
the letters appeared
to need further improvement if
Speakout was to improve employee confidence in the process.
Of the sixteen Class
1 concerns reviewed by the inspectors, the Table below
summarizes
ten Class
1 safety related concerns that were substantiated
or that had
associated
corrective action recommendations
provided by Speakout
. Only one
concern had all of the corrective actions completed before the closure letter was sent
to the concerned
individual. Additionally, the vehicle, if any, used to track the
corrective actions was noted in the Table.
Closed Class
1 Non-HR Concerns (1995-1997)
Concern
Number
95-27
95P1
95-42
96-15
96-26
96-37
96-65
96-79
97-10
97-12
Status
S
S
PS
S
S
PS
S
NS
NS
S
Corrective Action (CA) Status
No corrective actions recommended.
No corrective actions recommended.
No corrective actions recommended.
Closed 10/16/96 with CAs in place.
Closed 5/30/96.
CR 96-1183 closed out with CA
rolled to PMAI 96-07-112,113,114.
Closed 5/30/96.
CA closed 7/19/96
Closed 8/30/96.
PMAI 96-08-211 closed 9/30/96.
Closed 1/30/97. Recommendations
to HR still
outstanding.
Closed 5/2/97.
QA closed CAs on 5/10/97.
Closed 5/12/97 to CR 97-0769.
CR closed on
5/10/97 with CA rolled to PMAI 97-05-082.
Due
date 8/31/97
CA
Complete
N
N
S-Substantiated,
P-Partialty Substantiated,
NS-Not Substantiated
Generally, the Speakout program was effective in investigating individuals'oncerns.
The program was less effective in transmitting the results of the investigations to the
concerned
individuals and ensuring that the corrective actions resolved the concerns.
The ownership for resolution of the employee concerns was left to line management.
The inspectors found that for the eight concerns above with completed corrective
actions, the concerns were adequately resolved.
Interview of Employees
The inspectors interviewed 28 bargaining unit employees who directly conducted
safety related work. Several common themes were noted by the inspectors.
All had
received training on the Speakout program.
All individuals iqterviewed exhibited a
positive attitude toward nuclear safety.
The workers and management
have the same
goals: to return St. Lucie to the top rated plant it used to be.
The following Table depicts the questions asked of the employees and their
responses
with respect to Speakout:
QUESTION
YES
NO
UNSURE
TOTAL
Are you encouraged
to identify and report safety
related concerns?
Ifyou had a safety concern, who would you
report it to?
Are you familiar with the Speakout Program and
how to submit a concern?
Are you satisfied with the Program's process?
Are you satisfied with the Program's
accessibility?
Are you satisfied with the Program's
independence?
27
28
'mgt.
first
28
28
28
19
28
28
28
28
28
Have you or anyone you know, voiced a concern
through the Speakout Program?
Was the concern resolved adequately?
Was the concern resolved timely?
Was the completion notification in a timely
fashion?
Would you use the Speakout Program again?
In the course of your everyday work, have you
been intimidated, harassed
(given a hard time)
for raising a safety concern?
Would it make you reluctant to report safety
concerns to management
or Speakout in the
future?
15
10
13
21
20
28
15
15
15
15
28
28
Generally, employees believed that Speakout was a part of management.
The
inspectors'iscussions
with Speakout revealed that FPBL communication fliers (FYI)
presented
the program in this light. The inspectors noted that of the 28 employees
intewiewed, all 28 would go to their management
first with a perceived safety
concern.
Since management
already knew their concern, identity protection was not a
significant factor in determining whether to use Speakout.
However, since Speakout
reports directly to upper management,
employees questioned the independence
of the
program and whether Speakout could resolve their concern, since management
already had not. The inspectors noted that all employees interviewed agreed that
Speakout was readily accessible
and were familiar with the various avenues available
to express their concerns.
Another common theme among employees interviewed was that Speakout was
ineffective in resolving concerns.
As discussed
previously,
the inspectors determined
that although Speakout did provide employees with a closure letter and a
recommended
corrective action for substantiated
concerns, the Speakout file was then
normally closed.
The concerned
individual was not provided any further
communication on whether his or her concern was corrected, which was why he or
she had gone to Speakout originally. Therefore, employees were no better off after
closure of the concern than before they went to Speakout, which would explain why
they had the perception that Speakout was ineffective.
A majority of the employees interviewed stated that plant procedures
continued to be
an ongoing problem.
Some employees stated that they were put in the position of
either stopping work to correct the procedure, which would delay the schedule, or
continuing the job without adequate
procedural guidance, relying solely on skill of the
craft.
Employees stressed
that this dilemma places them in a "no-win" situation.
A common theme from employees was that management,
through communications
and actions, was providing a message
that safety was number one but that the
'schedule should not be allowed to slip.
In addition, 13 middle level managers were interviewed about their perceptions of
Speakout and practices related to Speakout.
Their answers were consistent with the
information provided by employees.
However, management
personnel expressed
the
belief that Speakout was effective and were unaware that employees felt the opposite.
Conclusions
In general, the FP&L Speakout program has clear implementing procedures.
Concerns were appropriately investigated and documented.
Safety-related employee
concerns were being adequately resolved.
Concern resolution had not been included
as a key element of the Speakout program and resided with line management.
As
such, concern resolution was not documented
in a closure letter to the employee.
The lack of this element had led employees to the perception that Speakout was
ineffective.
Management was unaware of the reason for this perception.
Mana ement Meetin s
Exit Meeting, Summary
The inspectors presented
the inspection results to licensee management
at the
conclusion of the inspection on June 26, 1997.
The licensee acknowledged the
finding presented.
Although reviewed during this inspection, proprietary information is
not contained in this report.
Dissenting comments were not received from the
licensee.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
R. Acosta, Director, Nuclear Assurance,
Florida Power and Light Company (FP8L)
D. Fadden, Services Manager, Plant St. Lucie (PSL)
J. Gallagher, Speakout Investigator, PSL
R. Leckey, Supervisor, Nuclear Safety Speakout, FP8L
J. Luchka, Speakout Investigator, PSL
J. Scarola, Plant General Manager, PSL
J. Stall, Site Vice President,
PSL
E. Weinkam, Licensing Manager, PSL
NRC
K. Clark, Public Affairs
P. Fredrickson, Chief, Special Inspection Branch
J. Jaudon, Director, Division of Reactor Safety
M. Miller, Senior Resident Inspector
INSPECTION PROCEDURES USED
IP 40001:
Resolution of Employee Concerns