ML20056C918
| ML20056C918 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 06/09/1993 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cross J PORTLAND GENERAL ELECTRIC CO. |
| References | |
| EA-92-223, NUDOCS 9307260152 | |
| Download: ML20056C918 (2) | |
Text
UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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Docket No. 50-344 License No. NPF-1 EA 92-223 Portland General Electric Company ATTN: Mr. James E. Cross Chief Nuclear Officer /Vice President Nuclear Division 121 S. W. Salmon Street, TB-17 Portland, Oregon 97204 Thank you for your letter of May 17, 1993, in response to our Notice of Violation dated April 16, 1993, informing us of the steps you have taken to correct the items we brought to your attention. Your corrective actions will be verified during a future inspection.
Your cooperations with us is appreciated.
Sincerely, fh 9,:1a Ross A. Scarano, Director Division of Radiation Safety and Safety cc:
Mr. M. Gatlin, Security Manager, PGE Mr. L. Houghtby, General Manager, Plant Support, PGE Mr. Michael J. Sykes, Chairman, Board of County Commissioners, Columbia County Mr. David Stewart-Smith, Oregon Department of Energy Mr. Tom Walt, General Manager, Technical Functions Mr. Lloyd K. Marbet Mr. Jerry Wilson, Do It Yourself Committee
-Mr. Eugene Rosolie, Northwest Environmental Advocates 9307260152 930609 PDR-ADOCK 05000344 G
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I bec w/PGE Letter dated May 17, 1993:
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Project Inspector Resident Inspector G. Cook B. Faulkenberry J. Martin bec w/o PGE Letter dated May 17, 1993:
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Portland General Bectric Company m
Jarnos E. Cross Vice President and Chief Nuclear Offcer Xay 17, 1993 Trojan Noelear Plant Docket 50-344 License NFF-1 U.S. Nuclear Regulatory Commission Atta ' Document Control Desk Usehington DC 20555
Dear Sirs:
Reviv to Notice of Violation Your letter of April 16, 1993 transmitted a Notice of Violation which resulted from an investigatios conducted by the Nuclear Regulatory Comnission (NRC)
Office of Investigation (OI) from June 20, 1991 through September 23, 1992.
The investigation was previously discussed with NRC Region V during an enforcement conferenes (50-344/93 01) held on yobruary 2, 1993. The attachmant to this letter contains fortland General Electric Company's (PCE's) response to the violation.
'Ihe violation cover letter also stated that the Nic did not take comfort in the bowledge that up to 35 percent of the security force may refuse to come forward with concerns. PCE does not t he comfort in knowing that any employes vould hesitate to report cencarna. There remains indications that sono personnel in security may still be relucts.nt to report eeneerns. To address thir, condition, PCE is evaluating additional actions that may be necessary to facilitate reporting of concerns to management or the NRC. This evaluation vill be completed by June 30, 1993.
Since rely, gs Attachment l
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Mr. John B. b rtin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy Mr. Xenneth Johnston NRC 9anior Resident Inspector Trojan Nuclear Plant 121 SW Salmon Street. Portland, OR 97204 cmraeaann, ysy_
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Trojan Nucloor Ficnt Doctanent Centrol Dask
"* Document 50-344 May 17, 1993 License NFF-1 Attachment Page 1 of 5 l
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Fly 1Y To A NOTICE OF Vf 01ATION Violation During an Fuelear Regulatory Consission (NRC) investigation conducted from June 20, 1991 through September 23, 1992, a violation of the NRC requirements was identified. In accordance with the "Ceneral Statement of Policy and Procedura for NRC Enforcement Actions", Title 10 to the Code of Tederal Regulations (10 CFR) Part 2, Appendix C, the violation is listed below.
10 CFR 50.7(a) provides in part that discrimination by a C edission licenses against an employea for engaging in certain protected activities is prohibite d. Discrimination includes discharge and other actions reisted to compensation, torus, conditions and privileges of employment. The activities protected are established in section 210 (nov section 211) of the Energy Reorganisation 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 licenses, 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 amployee from parcicipating 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, licenses nanagement actions and directions discouraged the Trojan security force from providing information to licenses management or to the NRC concerning potential violations and other matters within NRC's regulatory responsibilities. Specifically, between November 1989 and August 1991, licensee canagers 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 vacches. 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 security force members, the identity of the author (s) of an anonymous June 11, 1991, letter to the NRC that had complained about Trojan security canagement, 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.
Trojen Nucloer Flant Document Control Dask Document 50-344 Eay 17, 1993 License RPT-1 Attachment Pass 2 of 5 Response to violation Portland General Electric Company (PCE) acknowledges that conditions existed 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 RIC's purview.
1.
Reason Tor 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 reveras the trend, PCE and Security Managenent implemented numerous system, procedur.1, 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, significent management issues which caused concern and mistrust within the Security Department were present. These concerns were centered around increased mandstory evertime, psy classification changes, and pest assignments.
2.
The corrective Steps That Have Been Taken And The Results ' Achieved.
In order to provide more direct control and support for the nuclear security organisation and improve ranagsment to guard force communications, the following actions were leptemented:
1989 - 1990 The depart =ent manager was separated from Corporate Security and relocated to the Trojan site.
A new Nuclear 5icurity Department manager was assigned.
The support staff was reorganised to more closely support Trojan Security operations.
A new security contractor project manager was designated.
PCE initiated pay increases for the security officers to make salaries more competitive with area pay scales and improve officer retention.
January July 1991 PCE usnagement tours of back. shift operations were increased.
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Trojen Nuctoar Plant Docunent Control Ds:k
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Document 50-344 May 17, 1993-l
- License NFP Attachment i
Page 3 of 5 3
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A formal investigation of security officer concerns was initiated as part of the PCE Ircellence Responso Program. The investigation was r
conducted by personnel independent.of the security organization.'
At the request of Security Management. a study vas conducted by a representative of the PCE Buman P.esources Department to review the type of tasks being performed by security vacch Supervisors and tha.
attitudes-of the supervisors towards their work.
Contractor supervisory personnel recruitment ves. conducted with the goal of obtaining individuals with previous supervisory experience.
Rotating staff assignments were establisbod that allowed supervisory personnel to gain additional experience in.other areas, such as.
training. Assignment of Security Operations personnel to Training also Assuted that training material was updated to meet the
- i department's operational requirements..
A new Nuclear. Security Department manager was recruited and selected
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5 who had experience in developing a. quality security organization.
Aurust 1991 i
An extensive self assessment of the department which included a e
review of the Security Plan, Training and. Qualification Plan, and i
operating procedures vas. begun. Management-obtained suggestions and input on the effectiveness and morala of the organisation by conducting ona-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.
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- 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~
f approximately 40. hours per year.
- There was insufficient communications from canagement down through the ranks and back up to management. Miscommunications vers of ten the cause of morale problems.
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.. Trojan Nuclear Plant Document 50-344 May 17, 1993 License NTF-1 Attachment Page 4 of 5 i
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_Seetember - December 19 91 To correct the deficiencies identified during the s elf-a s s es sment period, the following actions were takent Frequent department employee meetings with nanagement were instituted r
to bprove communications and provide feedback.
Fifteen additional agervisors were selected and trained to reduce the supervisor / subordinate ratio.
A core of Primary Responders was formed to assure personnel vera properly qualified and trained to perform response duties and as a 1
neans 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 of ficer pay issues were addressed when the officers began collecting pay relative to their qualifications instead of the post being stood.
A fiva team shift rotation schedulo was established as a neans of developing strong teams, assuring shift canagement rotated censistently with shift officers and to provide additional training 1
time for each officer and supervisor.
The Nuclear Security Department was restructured and a new Security Operations Manager was selected.
I Recruitment for a new Security Contractor Project Manager was
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initiated. The new contractor project manager reported in May 1992.
Janua rv.1992 - Pre s tag The following nessures 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 assura p=rsonnel are avara of PGE's policies and procedures and tha manager's arpectations for their performance.
The Manager. Nuclear Security and the Security Operations Manager' make back-shift visits to communicate with personnel at their vork location.
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,, Trojan Nucicer Flent Document Centrol Dede Document 50-344 X2y 17.-1993 License NFF-1 Attachment Page 5 of 5
- The Manager, Nuclear Security and the Security Dperations Manager have an open door" policy for department personnel and encourage feedhack and suggestions.
Both PGE and the security contractor have active suggestion programs.
Security officers are solicited to provide input into post order
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changes, shift changes, and other decision nAking activities.
Results Achieved As a result of the above actions, the Nuclear Security Department has increased coc=unications, performance and inproved morale, as reflected by the SALP 1 rating in 1992. These improvements vere recognised during the operations 1 Sefeguards Response Evalu tion in 1992, when the NRC evaluating team hsd no findings and identified six program strengths.
The effectiveness of these actions in correcting the concerns has also been verified by the OI investigation and subsequent NRC inspections as noted in the NRC's letters dated December 23, 1991 and April 16, 1993 on this subject.
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The corrective steps That vill Be Taken To Avoid Tuture violations.
l Eased on the corrective staps takan, no additional corrective steps are re quir ed.
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PGE is avaluating additional actions that may be necessary to facilitate reporting of concorrs to management or the NRC. This evaluation vill be conpleted by June 30, 1993.
4.
Date Vhen Full Compliance Will he Achieved.
PCE considers the Security Department to be in full compliance with the provisions of 10 CFR 50.7(f) in that FCE management does not discourage the Trojan sacurity force from previding information to managenent or the NRC concerning potential violations and other matters within the NRC's regulatory responsibilities. Eovever, as noted in our cover letter to this response, there remains indicatior.s that some personnel in Security nay still be reluctant to report concerns. As noted above, PGE is evaluating additionst actions that may be necessary to further facilitate reporting concerns to managenent er the !;RC.
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