ML20044D770
| ML20044D770 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/17/1993 |
| From: | Cross J PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9305200259 | |
| Download: ML20044D770 (6) | |
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l asuk smut Em Portland General Electric Company f
James E. Cross Vice President and Chief Nuclear Officer
.j May 17, 1993 Trojan Nuclear Plant l
Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555 l
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Dear Sirs:
l Reply to Notice of Violation l
Your letter of April 16, 1993 transmitted a Notice of Violation which resulted l
from an investigation conducted by the Nuclear Regulatory Commission (NRC)
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Office of Investigation (OI) from June 20, 1991 through September 23, 1992.
The investigation was previously discussed with NRC Region V during an j
enforcement conference (50-344/93-01) held on February 2, 1993. The attachment to this letter contains Portland General Electric Company's (PGE's) response to the violation.
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The violation cover letter also stated that the NRC did not take comfort in the knowledge that up to 35 percent of the security force may refuse to come j
forward with concerns.
PGE does not take comfort in knowing that any employee l
would hesitate to report concerns. There remains indications that some i
personnel in Security may still be reluctant to report concerns. To address this condition, PGE is evaluating additional actions that may be necessary to j
facilitate reporting of concerns to management or the NRC.
This evaluation will be completed by June 30, 1993.
Sincerely, i
l Attachment c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr.. David Stewart-Smith State of Oregon kpartment of Energy Mr. Kenneth Johnston NRC Senior Resident Inspector
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Trojan Nuclear Plant 9305200259 930517 PDR ADDCK 05000344 fl l
G PDR
.21 SW Salmon Street, Portland, OR 97204 503/464-8897
l Trojan Nuclear Plant Document Control Desk Document 50-344 May 17, 1993 License NPF-1 Attachment Page 1 of 5 I
REPLY TO A NOTICE OF VIOLATION Violation During an Nuclear Regulatory Commission (NRC) investigation conducted from June 20, 1991 through September 23, 1992, a violation of the NRC requirements was identified.
In accardance with the " General Statement of Policy and Procedure for NRC Enforcement Actions", Title 10 to the Code of Federal Regulations (10 CFR) Part 2, Appendix C, the violation is listed below.
10 CFR 50.7(a) provides in part that discrimination by a Commission licensee against an employee for engaging in certain protected activities is prohibited. Discrimination includes discharge and other actions related to compensation, terms, conditions and privileges of employment.
The activities protected are established in section 210 (now section 211) of the Energy Reorganization Act of 1974, as amended, and include, but are not limited to, preparing to provide to the NRC, the licensee, or a contractor of the licensee, information about possible violations of NRC requirements.
10 CFR 50.7(f) provides that "No agreement... may contain any provision which would prohibit, restrict, or otherwise discourage, an employee from participating in protected activity.
.. including, but not limited to, providing information to the NRC on potential violations or other matters within NRC's regulatory responsibilities."
Contrary to the above, and as described below, licensee management actions and directions discouraged the Trojan security force from providing information to licensee management or to the NRC concerning potential violations and other matters within NRC's regulatory responsibilities.
Specifically, between November 1989 and August 1991, licensee managers took certain actions which many officers interpreted to mean that they were not to report sleeping / inattentive individuals or other security concerns to management or to the NRC.
These actions included:
1.
Security managers giving instructions and taking actions indicating that security officers should let their presence be known when checking on security posts and fire watches. As a result, several security officers stated that they felt intimidated with regard to reporting sleeping officers.
2.
Security managers attempting to determine, through questioning of
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security force members, the identity of the author (s) of an anonymous June ll, 1991, letter to the NRC that had complained about Trojan security management, creating the impression that management would retaliate against the author (s). As a result, several security officers stated that they were intimidated with regards to raising safety concerns to the NRC.
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Trojan Nuclear Plant Document Control Desk Document 50-344 May 17, 1993 License NPF-1 Attachment Page 2 of 5 Response to Violation i
Portland General Electric Company (PGE) acknowledges that conditions existed
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which could have discouraged the Trojan security force from providing information to management or to the NRC concerning potential violations and other matters within the NRC's purview.
1.
Reason For The Conditions.
These conditions were the result of ineffective communications which resulted in a perceived atmosphere of mistrust among members of the security force.
During the period from 1986 to 1989, the Trojan Security Department performance declined from a SALP 1 to a SALP 3.
To reverse the trend, PGE and Security Management implemented numerous system, procedural, and personnel changes. During this transitional period of initial change, some of the security officers misunderstood management's intentions regarding various security activities. Also, during this time period, significant management issues which caused concern and mistrust within the Security Department were present.
These concerns were centered around increased mandatory overtime, pay classification changes, and post assignments.
2.
The Corrective Steps That Have Been Taken And The Results Achieved.
L In order to provide more direct control and support for the nuclear security organization and improve management to guard force communications, the following actions were implemented:
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1989 - 1990 The department manager was separated from Corporate Security and relocated to the Trojan site.
A new Nuclear Security Department manager was assigned.
l The support staff was reorganized to more closely support Trojan Security operations.
A new security contractor project manager was designated.
PGE initiated pay increases for the security officers to make salaries more competitive with area pay scales and improve officer retention.
January - July 1991 PGE management tours of back-shift operations were increased.
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Trojan Nuclear Plant Document Control Desk Document 50-344 May 17, 1993 License NPF-1 Attachment Page 3 of 5 i
A formal investigation of security officer concerns was initiated as part of the PGE Excellence Response Program.
The investigation was conducted by personnel independent of the security organization.
- At se request of Security Management, a study was conducted by a representative of the PGE Human Resources Department to review the type of tasks being performed by Security Watch Supervisors and the attitudes of the supervisors towards their work.
Contractor supervisory personnel recruitment was conducted with the goal of obtaining individuals with previous supervisory experience.
Rotating staff assignments were established that allowed supervisory personnel to gain additional experience in other areas, such as training. Assignment of Security Operations personnel to Training also assured that training material was updated to meet the department's operational requirements.
A new Nuclear Security Department manager was recirl;ed and selected who had experience in developing a quality sect
- . organization.
Aunust 1991 An extensive self assessment of the department which included a review of the Security Plan, Training and Qualification Plan, and operating procedures was begun. Management obtained suggestions and input on the effectiveness and morale of the organization by conducting one-on-one sessions with Security Department employees and making numerous back-shift visits.
The results of the assessment indicated that:
- There were no outstanding unresolved regulatory issues.
- Pay issues were still a concern for the security officers.
- The supervisor to subordinate ratio was high (1:25) and many of the supervisors had received little or no supervisory training.
- The amount of formal training provided each officer was limited to approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per year.
- There was insufficient communications from management down through the ranks and back up to management. Miscommunications were often the cause of morale problems.
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Trojan Nuclear Plant Document Control Desk l
Document 50-344 May 17, 1993
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License NPF-1 Attachment l
Page 4 of 5 September - December 1991 To correct the deficiencies identified during the self-assessment period, the following actions were taken:
Frequent department employee meetings with management were instituted l
to impro e communications and provide feedback.
l Fifteen additional supervisors were selected and trained to reduce the supervisor / subordinate ratio.
A core of Primary Responders was formed to assure personnel were properly qualified and trained to perform response duties and as a means of developing pride and esprit de corps.
The Security training function was transferred from the Training Department to the Security Department to better assure training reflects Security needs.
The officer pay issues were addressed rhen the officers began collecting pay relative to their qualific..tions instead of the post being stood.
A five team shift rotation schedule was established as a means of developing strong teams, assuring shift management rotated consistently with shift officers and to provide additional training time for each officer and supervisor.
The Nuclear Security Department was restructured and a new Security Operations Manager was selected.
Recruitment for a new Security Contractor Project Manager was initiated. The new contractor project manager reported in May 1992.
January 1992 - Present The following measures were put in place in 1992 and remain in effect to enhance communications throughout the Security Department.
The Manager, Nuclear Security meets with new Security training classes to assure personnel are aware of PCE's policies and procedures and the manager's expectations for their performance.
The Manager, Nuclear Security and the Security Operations Manager make back-shift visits to communicate with personnel at their work location.
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Trojan Nuclear Plant Document Control Desk Document 50-344 May 17, 1993 License NPF-1 Attachment Page 5 of 5 The Manager, Nuclear Security and the Security Operations Manager have an "open door" policy for department personnel and encourage feedback and suggestions.
Both PGE and the security contractor have active suggestion programs.
Security officers are solicited to provide input into post order changes, shift changes, and other decision-making activities.
Results Achieved l
As a result of the above actions, the Nuclear Security Department has increased communications, performance and improved morale, as reflected l
by the SALP 1 rating in 1992.
These improvements were recognized during l
i the Operational Safeguards Response Evaluation in 1992, when the NRC l
l evaluating team had no findings and identified six program strengths.
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The effectiveness of these actions in correcting the concerns has also been verified by the OI investigation and subsequent NRC inspectiors as noted in the NRC's letters dated December 23, 1992 and April 16, 1993 cn this subject.
3.
The Corrective Steps That Will Be Taken To Avoid Future Violations.
Based on the corrective steps taken, no additional corrective steps are required.
PCE is evaluating additional actions that may be necessary to facilitate reporting of concerns to management or the NRC.
This evaluation will be completed by June 30, 1993.
4.
Date When Full Compliance Will be Achieved.
PGE considers the Security Department to be in full compliance with the l
provisions of 10 CFR 50.7(f) in that PCE management does not discourage l
the Trojan security force from providing information to management or the NRC concerning potential violations and other matters within the NRC's regulatory responsibilities. However, as noted in our cover letter to this response, there remains indications that some personnel in Security may still be reluctant to report concerns. As noted above, PCE is evaluating additional actions that may be necessary to further facilitate reporting concerns to management or the NRC.
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