ML17290A942
| ML17290A942 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/10/1994 |
| From: | Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17290A941 | List: |
| References | |
| 50-397-93-51, NUDOCS 9402020026 | |
| Download: ML17290A942 (11) | |
See also: IR 05000397/1993051
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No:
Docket No:
License
No:
Licensee:
Facility Name:
Inspection'at:
Inspection
Conducted:
Inspectors:
50-397/93-51
50-397
Washington Public Power Supply System
P. 0.
Box 968
Richland,
MA 99352
Washington Nuclear Project
No.
2 (WNP-2)
MNP-2 site near Richland,
Mashington
December
8-10,
1993
F.
R.
Huey
Enfor ement Officer
Approved .by:
~Summa':
-P.
H. Johnso
,
ief
Reactor Project
Section
1
il(
z
Date Signed
Ins ection
on December
8 throu
h
10
1993
Re ort No. 50-397 93-51
Areas
Ins ected:
Special,
announced,
inspection of the licensee's
employee
concerns
program.
Inspection
Procedure
92720 was used
as
gui,dance during this
inspection.
Safet
Issues
Mana ement
S stem
SIMS
Items:
None.
Results:
General
Conclusions
and
S ecific Findin s:
Meaknesses:
E
The inspection identified a number of weaknesses
in the licensee's
employee
concerns
program which indicate the need to establish
procedures
which more clearly define specific requirements
for hoP Concerns
are to
be evaluated,
tracked
and resolved.
The inspection also identified that the licensee
had performed
a poor
evaluation
and resolution of a recent
employee
concern involving
procedure
compliance, training, inadequate
technical
review of potential
fire seal deficiencies;
and potential discrimination for-,raising safety
concerns
to licensee
management.
9402020026 940ii2
ADOCK 05000397
6
4
Summar
of Violations and Deviations:
None
Unresolved
and
0 en Items
Three unresolved
items were identified involving: (I) the failure to properly
document,
evaluate
and correct potential fire seal deficiencies,
(2) the
failure to provide an adequate fire seal
inspection
procedure,
and (3)
possible discrimination against
an employee
who raised safety concerns to
licensee
management.
0
DETAILS
Persons
Contacted
J. Parrish, Assistant
Managing Director for Operations
D. Coleman, Acting Manager,
Regulatory
Programs
J. Gearhart,
Director, guality Assurance
M. Hatcher, Staff Attorney
R. Steiner,
Manager,
Project
Human Resources
W. Kiel, Licensing Engineer
Em lo ee Concerns
Pro ram
Or anization
and Structure
92720
,Appendix
B of 10 CFR 50 requires that licensees
implement measures
to
ensure that conditions
adverse to quality are promptly i'dentified,
documented,
and corrected.
Although such
programs
are not specifically
required
by NRC regulations,
many licensees
have elected
to. implement
employee
concerns
progr ams
(ECPs)
as
one means of identifying and
evaluating potential quality concerns
at licensed reactor plants.
The
ECP at WNP-2 is defined
by General
Information Handbook-Administrative
Procedures
Manua'l procedures
GIH 3.4.6,
"Nuclear Safety Issues
Policy,"
and
GIH 9.5. 1,
"Open Door Policy/Direct Line," which are approved
by the
Managing Director for Operations.
The Direct Line program is supervised
and maintained
by two individuals,
the Assistant
Managing Director for Operations
(AMDO) and his secretary.
A'
Direct Line concerns
are initially evaluated
by. the
AMDO, who
typically refers the concern to the cognizant line organization for
evaluation
and correction.
The
AMDO may also refer the concern to an
independent
party for evaluation, if he deems
such action appropriate.
The Direct Line program is publicized by inclusion in site training and
numerous
signs located at various locations
on site.
ECP Pro ram Statistics
1991
1992
1993
Number of employee
concerns
submitted:
Number of anonymous
concerns:
Average.=length of time to close file (weeks):
Longest period file was
open
(weeks):
Number of concerns
substantiated:
Number of files remaining open:
5
4
3
9
2
0
3
10
1,4
3
2
3
5
0
0
0
0
General
Findin s
The inspector
reviewed licensee files associated
with the
18 employee
concerns
submitted since the beginning of 1991, with the following
findings:
a.
Licensee
procedures
do not define the expected
format or content of
employee
concern files, nor are requirements
specified for how files
are to be closed.
In this regard,
the inspector
noted that many of
the Direct Line files do not include
a formal signoff or clear
description of actions taken to closeout the concerns.
b.
Licensee
procedures
do not define specific measures
which should
be
taken to protect employee confidentiality.(e.g.
ensure that the
employee
agrees that his concern
can
be referred directly to his
management
for review).
C.
d.
One Direct Line concern received
on April 2,
1991, did not include
an indication that the results of the licensee's
evaluation
were
provided to the concerned
employee.
Many of the Direct Line concern files did not include information on
the results of the licensee evaluation of the concerns
or how the
files were closed.
Examples
included concerns
received
on
September
23,
1992,
May 21,
1992,
and March 6,
1991.
e.
The licensee
ECP procedures
did not provide for periodic independent
assessment
of Nuclear Safety Issues/Direct
Line program performance.
f.
The licensee's
Direct Line program is currently staffed
by only the
AMDO and his secretary.
The inspector
was concerned that these
programmatic
deficiencies limited
the effectiveness
of the
ECP.
During the exit meeting,
the inspector
indicated that the licensee
should evaluate
whether periodic assessment
is warranted to ensure that the program effectively performs its intended
functions.
In addition, the licensee
may want to consider whether
additional
resources
are appropriate to properly maintain -and oversee
the
program,
or whether the program should
be delegated
to an existing .audit
organization to implement.
The licensee
acknowledged
the inspector's
comments.
5.
S ecific Findin s:
a.
A Direct Line concern received
on September
30,
1993,
addressed
a
technical
concern
and also indicated that
a licensee
supervisor
had
made potentially threatening
remarks
about the use of the Direct
Line Program.
The file addressing
the technical
concern
was closed;
however,
the issue of discriminatory remarks
by a licensee
supervisor
did not appear to have
been evaluated.
b.
A Direct Line concern received
December
4,
1992, identified
a
specific source for information about
a technical
concern,
and also
identified a potential discrimination problem.
Thy .file was closed
without any indication that the identified sou'rce
heal been
contacted,
nor did it appear that the discrimination concern
had
been evaluated.
c.
A Direct Line concern received
September
1,
1993, identified several
concerns
involving:
(1) procedure
compliance,
(2) training,
(3)
inadequate
technical
review of potential fire seal material
deficiencies,
and (4) potential discrimination against
an employee
for raising safety concerns to his management.
The Direct Line
concern
was received
by the
ANDO and referred to the Plant Technical
Hanager for evaluation.
The inspector
was concerned that the concern
should
have
been
referred to an independent
party for a more objective evaluation,
because
the employee's
concerns largely reflected frustration with
the response
that he had already received
from his immediate
supervision.
Furthermore,
the licensee
did not appear to have
properly evaluated
the employee's
concerns.
In particular:
(1)
Em lo ee Concern:
Some fire seals
are inadequate
because
the
seals
have shrunk
and
do not make complete contact with the
walls or conduits they are intended to seal.
The licensee
has
not consistently
documented
these deficiencies
or documented
an
engineering
evaluation establishing their acceptability.
A
Request for Technical
Services
(RFTS) submitted
by the
employee,
concerning the adequacy of shrinking seals,
was
rejected
and not provided to engineering for evaluation.
Licensee
Evaluation:
The licensee
concluded that fire seal
shrinkage
was being properly documented
and evaluated,
noting
that seal .shrinkage of less that 1/2 inch depth or width was
acceptable
and need not be documented.
The licensee
also
determined that shrinkage in excess
of 1/2 inch may be
acceptable if evaluated
by Plant Technical
not to reduce the
minimum seal
depth required
by applicable
seal
drawings.
The licensee's
evaluation referenced
several
discussions
with
other utility and fire seal
vendor representatives.
The
- --inspector noted that one utility had determined that seal
material
would expand significantly when exposed to fire,
noting that
a test
showed that
a 'seal with a one-half inch gap
expanded
to close the
gap "before vast. amounts of smoke or
flame passed
through the opening."
In addition,
a vendor
representative
had advised the licensee that fire test
information was available to show that defects
up to 1-3/4 inch
depth were acceptable.
The licensee
concluded that additional
engineering
review of seal
shrinkage
was not warranted
and that
the
RFTS submitted
by the employee
was appropriately rejected
in accordance
with licensee
procedures.
Fi di
ih
i
p t
1
d d
h
h'l
did
have
an appropriately
documented
basis for acceptance
of
observed fire seal
shrinkage conditions.
The licensee
was
unable to provide
a quantitative engineering
evaluation
supporting its conclusion that shrinkage of up to 1/2 inch was
acceptable
and
bounded
by the qualification tests for the fire
seals installed at WNP-2.
It appeared
to the inspector that
without such
a quantitative evaluation,
the employee's
Direct
Line concern
should not have
been closed,
and that the
employee's
RFTS submittal
was appropriate
and should
have
been
validated
and reviewed.
(2)
The inspector also noted that
a Problem Evaluation Request
(PER)
was initiated on October -21,
1993,
documenting
apparent
deficiencies
on Emergency Diesel
Generator
room fire seals.
The
PER was not validated
by the originator's supervisor
and
was returned to him without documenting the reason for
invalidation in the "Condition Description" block of the
PER
and without signing and dating the form, as required
by
procedure
PPM 1.3. 12,
"Problem Evaluation Request."
The
licensee
committed to document
an appropriate
engineering
evaluation establishing
the acceptability of existing fire seal
configurations
and seal
inspection criteria.
The failure to
properly document,
evaluate,
and correct potential fire seal
deficiencies is
a potential violation of the requirements
of
Appendix B.
This item will remain unresolved
pending
completion of the. licensee
evaluation
(Unresolved
Item 93-51-
01).
Em lo ee Concern:
Licensee
procedure
PPN 15.4.6, "Fire Rated
Assembly/Inspection
and Operational Verification," required
that fire seals
be flush with the wall'n one side.
Host fire
seals
are not flush with the wall on either side.
The employee
raised
a procedure
compliance
concern
when his supervisor
refused to have the procedure revised, after determining that
seal
design criteria did not require the seal to be flush with
the wall.
Licensee
Evaluation:
The licensee
dete'rmined that the fire
seal
sketch referenced
by the procedure,
although showing the
seal
flush with one side of the wall, was not intended to
require that the seal actually
be flush with the wall.
The
licensee
maintained that the sketch configuration was only
intended to show the wall as
a reference line for establishing
the minimum-required,
seal
thickness.
The licensee
concluded
that the employee
should have accepted
the judgement of his
supervisor that non-flush seal
configurations
were acceptable
and that
a procedure
change
was not necessary.
N~R
Fi di
Th i
p t
i
d d th
L
h fi
inspection
procedure
was not violated; however, the procedure
was not clearly written. 'lthough, the sketch could reasonably
be interpreted
as requiring
a flush configuration, the
inspector
agreed with the licensee's
conclusion that the sketch
did not intend that the seal
be flush with the wall.
Nevertheless,
in view of the licensee's
recent senior
management
emphasis
on strict procedure
compliance,
the
inspector
concluded that the licensee
should
have
acknowledged
the employee's
concern
and clarified the procedure.
The
inspector also noted that the procedure
may be inadequate
in
that it did not clearly specify how unacceptable
or cosmetic
seal deficiencies
were to be determined
or dispositioned.
The
issue of procedure
adequacy will remain unresolved,
pending
receipt of .the licensee's
evaluation
(Unresolved
Item 93-51-
02).
Em lo ee Concern:
The, training of personnel
who inspected fire
seals
was not adequate.
The training did not adequately
cover
acceptance
criteria or the types of sealant
used at WNP-2.
Also, the training did not,include .field walkdowns of the seals
to provide examples of the types of fire seals
and sealants.
Licensee Ev'aluation:
The licensee
concluded that tra'ining was
adequate
and that training walkdowns were not necessary,
since
new inspectors
were paired with experienced
inspectors.
heidi:
Th
t
p
t dd htth
pt
training was minimally acceptable.
However, considering the
relatively complex nature of fire seal
inspection,
which
involved both quantitative measurement
and qualitative
judgement,
additional. training or use of more qualified
inspection
personnel
would have
been helpful.
The inspector
noted that the use of seal
mockups during classroom training,
as
had
been
used during previous
seal
inspector training
classes,
would also have.been
helpful in training this
employee.
Em lo ee Concern:
Workers performing fire seal
inspection
were
inadequately trained
on Radiation
Work Permit
(RWP)
requirements
and did not follow health physics requirements
specified in RWP's.
Licensee Evaluation:
The licensee
determined that
some doors
included "Contact
HP Prior to Entry"
signs which were potentially confusing in that radiation
workers entering the area
had previously contacted
HP,
and
recontacting
HP for each'ntry
was not necessary.
The
unnecessary
signs were removed to alleviate confusion.
Th
t
p
dt
d tt
t
h
h
employee
and involved
HP personnel,
and concluded that the
licensee failed to properly evaluate this concern.
In
particular, the inspector noted that the employee
had advised
his supervisor that
HP personnel
were "very concerned"
and
"cancelled the job" when advised
by the employee that,they were
going to enter the
RHR heat exchanger
room.
',The licensee
evaluation did not appear to properly followup on this
information.
When questioned
by an
NRC inspector,
the involved
HP technician confirmed the employee's
concern, stating that he
had instructed the two,involved fire seal
inspectors that
compliance with the "Contact
HP Prior to Entry" sign on the
heat exchanger
room door was required.
The
HP 6.chnician
advised the workers that required surveys of the room had not
been performed.
If the high radiation boundaries
inside the
room had changed,
the workers
may not have
been signed in on
the required
RWP,
and they may not have
been wearing the
required dosimetry..
The inspector
noted that, priot to inquiry by the
NRC, the
involved
HP technician
had not been contacted
by licensee
personnel
about this event.
In this regard,
the licensee
may
want to reconsider
whether
a "Contact -HP Prior to Entry" sign
is not appropriate for the
RHR heat exchanger
room door.
(5)
Em lo ee Concern:
Workers performing fire seal
inspection did
not have
a copy of the applicable inspection procedure
in hand
when performing inspections,
as required
by licensee quality
assur ance procedures.
Licensee Evaluation:
The licensee
confirmed the employee's
concern
and retrained the involved worker.
hali dl:
Th
I
p
g
d
lth
h
evaluation.
(6)
Em lo ee Concern:
Because
he had raised fire seal safety
concerns,
the licensee
discriminated against the employee
by
including negative
comments in his performance
appraisal
and
giving him a lesser
pay bonus than his co-workers.
Licensee
Evaluation:
The licensee
concluded that the
employee's
performance
appraisal
was appropriate
and that
he
had not been criticized because
he had raised safety concerns.
The licensee
maintained that critical comments
in the
employee's
appraisal
wei e the result of his reluctance to
accept technical direction from his supervisor
and problems
interfacing with his inspection partner.
II ldl:
Th
I
p
dl
d htth
ply
submitted
a discrimination claim to the Department of Labor.
The licensee
committed to perform an independent
assessment
of
the handling of this Direct Line concern.
The issue of
possible discrimination will remain unresolved,
pending receipt
of the licensee's
evaluation
and findings by the Department of
Labor (Unresolved
Item 93-51-03).
In summary,
the inspector
concluded that the licensee's
employee
concern
prog'ram was not effectively structured,
nor did program procedures
provide sufficiently specific requirements
to ensure that concerns
were
confidentially, independently
and thoroughly evaluated
and resolved.
In
particular, the inspector
noted that the licensee
had not properly
evaluated
or resolved
a recent
employee
concern
about potential fire seal
deficiencies.
6.
Exit Heetin
30703
/
On December
10,
1993, the inspector
met with licensee
representatives
(as
noted in Paragraph
1) to discuss
the inspection findings.
The licensee
did not identify as proprietai y any of the materials
discussed
with or
reviewed
by the inspectors
during this inspection.
I
'