ML20094S243
| ML20094S243 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/10/1992 |
| From: | Diprofio W PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | |
| Shared Package | |
| ML20094S238 | List: |
| References | |
| NUDOCS 9204140280 | |
| Download: ML20094S243 (8) | |
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STATION MANAGER'S EVALUATION OF A0 PERFOR_M_ANCE CONCERNS hAud)YE W. A. Di 'ofio Station anager April 10, 1992 t' e 0 4 i ;>
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j STAi10N MANAGER'S EVALUATION OF A0 PERFORMANCE CONCERNS On Sunday, March 1,1992, a Shif t' Superintendent (SS) was conducting a quarterly performance monitoring surveillance to determine if an Auxiliary l Operator (AO) was appropriately carrying out all of his assigned duties. The !
SS discovered that the A0 had not completed all of the tasks associated with the l A0 Rover rounds. Specifically, the A0 had not entered certain areas to perform the required routine periodic inspections. After confronting the A0 with the discrepancy, the SS counseled the A0 on his duties and responsibilities. The l A0 was then relieved by the oncoming shift. The SS informed the Assistant 1 Operations Manager, who in turn notified the Station Menager of - the A0 performance concern.
The following morning, Monday, March 2, 1992, the Station Manager briefed the Executive Director - Nuclear Production on the A0 performance concerns. As a result of the briefing, the Executive Director - Nuclear Production requested that an Independent Review Team (IRT) assessment be performed to determine, among other things,.if this was an isolated case or if there were generic implications.
Later that day the A0 who had not properly completed his rounds was interviewed by the Assistant Operations Manager, his Shift Superintendent, and the Employee i'. elations Manager. As a result of the intsrview, Ine A0 was suspended withcut pay pending further investigation, and his protected area access was revoked.
On Monday, March 2, 1992, the IRT was directed to initiate an assessment of the A0 performance concerns. On Wednesday, March 4, 1992, the IRT informed Station Management that based on the preliminary review of the data, additional A0s had not completed all of the required actions during their Rover rounds.
It became apparent that additional actions would be necessary outside of the scope of the IRT, This evaluation is intended to summarize those actions, both investigative and disciplin ry, taken by Station Management, which were independent of the IRT's assessment. Although the IRT has performed an extensive assessment of the programmatic aspects of the A0 performance concerns, care had been taken to ensure separation from Station Management's investigation and subsequent disciplinary actions.
After it was determined that there were concerns with the first A0's performance and the IRT had informed management that there were similar concerns with additional A0s, an interview team consisting of three people was convened 1
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in order to interview the A0s and determine the nature of the performance concerns. The interview team consisted of the Assistant Operations Manager, a Shift Superintendent (soon to become the Assistant Operations Manager), and the Employee Relations Manager. The interview team met with each A0, along with the A0's Shif t Superintendent, and asked the A0 a series of predetermined questions.
The questions were designed to fetermine if, in fact, there were concerns with an A0's performance and the reasons for such performance concerns. After this meet ing, and if warranted, the A0 was suspended "pending further investigation."
The suspension was designated as "pending further investigation" in order to provide the interview team with sufficient time to verify any information provided by the A0, to review all other data relevant to the investigation and to make a determination as to whether u formal disciplinary action meeting was warranted. If it was determined that a disciplinary action meeting was not warranted, then the suspension would.have been lifted and the individual would have been reinstated without prejudice. If, however, disciplinary action was warranted, then the disciplinary action would be detcrmined on a case-by-case basis.
This same method was used to ensure consistency and fairness when interviewing each A0. The interview team used a standard list of questions to ensure that each individual was given a f air and complete airing of his performance issues and to ensure that all relevant questions were asked relating to the issues. Both the questions and the answers were documented durina each a
interview. The interviews were designed to give each individual the opportunity to provide as much data and information in his defense as was possible, it also ensured that the interviews were conducted in a controlled and equitable manner.
Subsequent-to this data-gathering interview, a disciplinary action meeting was scheduled if it was determined to be necessary. The disciplinary action meeting was typically held 48 to 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> af ter the interview. This disciplinary action meeting included the interview team members, the Station Manager, Assistant Station Manager, Executive Director - Nuclear Production, the individual and his Shift Supervisor.
Early in the investigation process, a concern arose with regard to the adequacy or completeness of the data being provided by the IRT that identified discrepancies in A0 performance. The concern was to avoid any potential for Station Management taking disciplinary action based on preliminary data that 2
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l might later be found to be incorrect. -.The IRT was providing a comparison of A0 roundkeeping. logs and the computerized Security Department keycard transaction 11ogs. While every effort was being made to verify the accuracy and completeness of the-data,_it became. apparent that in some instances additional sources of information needed to be considered.
Subsequently, the IRT used these additional sources to verify accuracy prior to supplying data to Station Management. This data was verified as complete -and accurate by the IRT. This process of verification of the information slowed the pace of Station Management activities, however, it was essential to maintain the accuracy of the data to ensure proper decision making with regard to disciplinary action meetings.
The IRT provided four-months worth of data that compared the A0's log entries with Security Department keycard transaction logs. The four months included January and February of 1992 and November and December of 1991.
As a result of the data analysis, the IRT concentrated their efforts on determining compliance with Technical Specification surveillances for the period of time going back to the issuance of the Full-Power Operating License.
The IRT determined that there were six (6) instances where activities required by-Technical Specifications had not been conducted. Five(5)ofthose instances involved surveillances of the Condensate Storage Tank (CST) and Enclosure. This . Technical Specification surve-illance is - unusual in that completion of the Technical Specification surveillance is logged in the Control Room, however, it is the A0 that performs the required activity. At the bottom of the Roving A0's Log Sheet is a " Note B" which states the following with regard to CST Enclosure integrity:
" SAT - Condition - No evidence of work activity that may compromise CST Enclosure Seal integrity, C0-V142 (Condensate Low Point Suction) Locked Closed, C0-V154 (EFW-F-37A Suction Isolation) Locked Open, Housekeeping SAT."
It should.be noted.that the only way to verify the integrity of the Enclosure seals and the status of these' valves is to enter the Security Doors into the CST Enclosure areas. The Control Room contacts the Doving A0 once per shif t, 3
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l typically _during the first round,-and verifies that the A0 has completed that portion of his round involving the CST Enclosure integrity surveillance. The
- AO must signify verbally to the Control Room- that he has completed that surveillance, and also document completion of the surveillance on his round sheet.
There were cases where individuals represented to the Control Room that they had completed that surveillance, when in fact the Security Department keycard transaction logs indicated that the individuals had not entered those areas. The actions of_ individuals who knowingly gave false information to the-Control Room, and signified the same in their logs, which resulted in a missed Technical Specific >cion survcillance constituted falsification of documents.
It was the determination of Station Management that those individuals could not be remadiated. Therefore, the appropriate disciplinary action determined by Station Management was separation of ertployment from the Company.
Another Technical Specification surveillance requires the determination of the Fuel Storage Building Spent Fuel Pool Cooling Pump area temperature. This Technical Specification surveillance was missed on one occasion. The indiv ~ "ual involved represented on his log and to the Control Room that he had enterec usat area and had taken a local area temperature log reading when in fact the Security Department keycard transaction logs inoicated that he had not entered the area.
Extensive time was spent trying to resolve this discrepancy, including looking at the previous day's logs. to determine if the individual had inadvertently miscopied-the previous day's reading from his notes. No reasonable explanation was found. It was therefore concluded that the reading must have been fabricated. The individual was separated from the Company.
Disciplinary actions were evaluated on a case-by-case basis. Each case was reviewed separately to ensure that the individual was given every possible consideration. A standard format was used for each disciplinary action meeting.
Each case was reviewed in advance and discussed in detail. The individual was presented with the information available related to his case. He was encouraged to ask questions or to make comments as he desired through the ::ourse of the meeting.
The following items summarize the imprtant points of the data gathering, interviews and/or disciplinary action meetings:
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In all cases, when the-A0s were asked if the_ir Supervisor or any other individual nad told them that it was acceptable to' sign-off on their logs as if they had performed an inspection when in fact they had not, the answer was "NO." The signature without action was an assumption of authority that was made by each individual. The A0s did not'do what was expected of them by their supervision.
Similarly, in all cases when the A0s were asked if they had signed-off on t any procedures, surveillances, or any other documents as if they had performed an activity when in fact they had not, the answer was "NO." It is clear that the A0s separated the importance of the A0 round and log keeping from the. normal importance placed on procedure compliance. Since no specific procedure exists for conducting rounds, the-A0s assumed the rounds were not as important,
. 'It was believed by most A0s that if they had told their Supervisor that they had skipped portions of rounds, their supervisor would have found such actions unacceptable, and would hhve required the individual to complete his rounds correctly. In light of the actions Station Management had taken upon discovering this concern, the A0s now believed their actions were improper although at the time they did not feel that the actions were improper.
. When questioned, the A0s-could not explain how they could write " SAT" on the log without entering the area when the criteria for " SAT' was in a note on the bottom of the log. The note requires a visual.insptction of the area'for specific items. The A0s rationalized that they had the ability to judge what was important and could determine what activities they should conduct and what activities _they could delete.
. Some A0s were unclear about'why the Technical Specifications are important because they did not understand the function of these specifications in the larger context of Station operation and plant safety. Therefore, they did not appreciate the necessity, the seriousness or the need to check certain locations where equipment was in'a standby condition.
. Some A0s had bonafide confusion as to the need to perform rounds on a regular basis at the Service Water Cooling Tower. They remembered using 5
l the notation " Shutdown" for this inspection in the past and equated " SAT" with " Shutdown." Some A0s believed that if the equipment were " Shutdown" (as it normally is) an inspection was not required on each and every round.
New Hampshire Yankee has programmatically not allowed " Shutdown" as a log eritry for a number of years. However, it was clear from the discussions that some A0s still equated the two entries.
. In all cases the A0s felt they were doing an excellent job. They felt technically qualified and very competent to perform the duties of the position. Each thought he was a " good" A0.
As a result of the above information, I have been meeting with all Station departments. I have not completed all meetings at this date. At these meetings I spend an extensive amount of time discussing the A0 performance concerns and the generic implications for the rest of the organization.
The second subject of these meetings is the revision of 10 CFR, Part 2,Section VIII, entitled " Enforcement Actions Involving Individuals," published in the Federal Register on February 18, 1992. I have stressed that this revision makes this enforcement policy directly applicable to all who work at the Station, licensed or unlicensed. I have stressed that the NRC intends to hold each of us personally accountable for our actions or deliberate omissions. Each person receives a copy of the policy and is instructed to read it.
The third subject of tnese meetings is an extensive discussion of my expectations of Station employees in the areas of job performance, professionalism, procedure compliance, effective training and their general responsibility for the safety of the public and personnel working at the Station.
Each person receives a document describing these expectations and is instructed to read it. If there is not a complete understanding of these subjects after reading the material, employees are asked to see their supervisors to ensure all of us understand this material.
In summary, I believe that Station Management's investigative and disciplinary. actions in response to the A0 performance concerns were cco,,rehensive, effective and equ' table.
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New Hampshire Yankee April 10,1992 ENCLOSURE 3 TO NYN 92045 4
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