ML20149L681

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Concerns Resolution Program - Sequoyah Nuclear Plant
ML20149L681
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 09/30/1994
From: Hunter B
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20149H858 List:
References
FOIA-97-223 94-5331, NUDOCS 9610010219
Download: ML20149L681 (20)


Text

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.[U8M8C ON8 Office of the Inspector General l

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CONCERNS RESOLUTION l l

l PROGRAM-- l SEQUOYAH NUCLEAR l PLANT \

94 5331 l Principal Contributors September 1994 Brenda 8. Hunter Thomas B. Johnson l

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my atscem m m - ~ _ -

.. Office of the inspector General, insp:ctions

. ... . ......1 TABLE OF Int roduction ... . .. .. . ...... ..... . .

CONTENTS .. . .........1 Met.hodology .. . . .... .. . . .

. . . ...........2 Observations. .. .... .. .. .

. . . .. .. .2 Thc >rogram Files . . . . . .

. .. . . . . .3 Survey Results. .. .

... .. .6 Anonymous Survey Feedback. . . . .

. . .. ..... . .... ..7 Opportunities for improvement . .

Appendices 1

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,. Office of the inspector General, inspections During 1986, the Nuclear Regulatory Commission INTRODUCTION requested TVA's Office of the inspector General to  ;

periodically review TVA's Concerns Resolution Program '

(hereinafter referred to as "the program"). This review l covers the portion of the program applicable to We completed our Sequoyah Nuclear Plant (SON).

fieldwork at SON in May' 1994 In summary, SON i

employees overwhelmingly felt free to raise nuclear

' safety concerns to their supervisors and management.

However, the Concern Resolution Staff (CRS) could '

improve its contractors' Employee Concem Programs (ECP) by ensuring the programs exhibit the necessary independence from management.

4 Our objective was to determi.ne whether the program is '

METHODOLOGY accomplishing its intended mission effectively.

The program consists of employees, supervisors, and the ,

CRS. Program effectiveness, in general, may be measured by the extent (1)TVA employees and contractors feel secure in raising questions about nuclear safety at TVA installations and (2) the program has in place adequate means to resolve nuclear safety outside of line issues when they are raised management.

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We reviewed the program by (1) reviewing the CRS process for handling concerns, (2) reviewing all files  !

closed in 1993 and all pending files, (3) reviewing contractor ECP at the site, and (4) conducting face-to- l face interviews with randomly selected TVA nuclear and f contractor employees. The structured interviews were designeo to assess the extent people on-site feel free to raise nuclear safety and quality issues and to obtain l feedback on the effectiveness of CRS and c' the program. We interviewed 15 percent of the personnel 3 on-site, which allows us to project our results to the Ij entire workforce, generally, with a 95 percent

! confidence level and a margin of er.ror of +/- 3 percent. J ig (A' copy of our structured interview questionnaire is

3 attached as Appendix A.) We also requested each l interviewee to complete an anonymous feedback form, l- thus giving them another opportunity to provide further relevant information. l I , ,

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Office of the Inspector General, inspections We found the majority of files handled by CRS and ECP OBSERVATIONS were handled effectively. Additionally, our survey shows the overwhelming majority of employees and contractors know about and would use CRS or ECP.

We believe this collective evidence indicates CRS and i the program are operating effectively at SON. The following outlines the specific results of our review.

CRS--Based on the evidence in the files, CRS THE PROGRAM follows its own program directives. In our review of  !

FILES the CRS files, we looked for whether the concerns were clearly documented and appropriately classified.

We looked for evidence that the concem was evaluated by someone with sufficient knowledge and that an independent reviewer could reasonably reach the same conclusion as reached by CRS. We also looked for indications of how CRS responded to the concerned .l individual. We reviewed 12 files that were closed during 1993 and 5 pending files. In summary, our review led to l

the following conclusions.

Based on the evidence in the files, CRS follows its own-l program directives, sponsors avenues to receive and  ;

investigate nuclear safety and quality issues in '

confidence, coordinates with management to get technical issues resolved, and responds to the s concerned individuals about investigation outcomes and corrective actions. i CONTRACTORS--Based on the evidence in the files, l ECP follows its own program directives. In our l

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review of ECP files, we looked for the same, kinds of l l

1 evidence we looked for in the CRS files. We reviewed l J 12 files that were closed during 1993 and 1 pending file.

In summary, our review led to the following conclusions.

i Most of the evidence in the files indicates ECP follows sts own program dir6ctives, sponsors avenues to receive and investigate nuclear safety and quality issues in t

confidence, coordinates with management to get technical issues resolved, and responds to the g concerned individuals about investigation outcomes and corrective actions.

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Office of the Inspector General. Inspections Areas for improvement in the ECP include the following.

1. One of the ECP managers for Bechtel is also the safety manager, acting project manager, and craft

- sponsor. The other Bechtel ECP official has responsibility for hiring, firing, administering payroll, and granting security clearances. In addition, the

[ - ECP manager for Stone and Webster Engineering Corporation (SWEC) is also the SWEC project manager and has responsibility for hiring and firing.

f When the individual with ECP responsibilities also controls ernployee matters related to career

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continuation, the employee may be inhibited from raising safety concerns. Therefore, extra care

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should be taken to assure the necessary j

independence between roles is exhibited to the

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workforce.

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2. We saw one file where ECP for Bechtel had placed a copy of the employee concern in a file other than the

] ECP file. Upon interviewing the ECP manager, we U

i found this was common practice. This practice provides an opportunity for Bechtel managers to gain

' access to ECP information apart from ECP. We recommend that all information relating to ECP be confined to ECP files under the control of ECP management.

3. The documentation of concerns in ECP files was  ;

h arranged in chronological order as received and l were not sorted among issues or concerned I individuals. We believe some issues may require h follow up, and accordingly, such issues should be bound separately, complete with all documentation relevant to the specific issue.

SURVEY RESULTS We interviewed 235 TVA SON empi.oyees and 97 SON q'J. contractors.

Based on our survey interviews, the overwhelming l majority of employees and contractors felt free to report nuclear safety or quality problems at SON.

Specifically, 99 percent of the employees and 5 99 percent of the contractors interviewed at SON said they would report a problem, if they knew' of one, through some avenue. The employee's and the h

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Offica of the inspector General, inspections contractor's immediate supervisor was the most e

frequently mentioned avenue for reporting concerns. All of the contractors and 99 percent of the employees interviewed said they would go to their supervisor, if needed. Of the 235 employees interviewed,1 would not, citing fear of reprisal. None of the 97 contractors would not. (Please see Appendix B for further details of survey responses.)

Of the employees interviewed,103 (35 as a routine part

] of their job) said they had reported a problem to their supervisor. Of those, 88 percent said the supervisor 3

was responsive and thorough, and 97 percent said they

] would use that avenue again.

Of the contractors interviewed,26 (7 as a routine part of their job) said they had reported a probiem to their supervisor. Of those, 96 percent said the supervisor

] was responsive and thorough, and all said they would

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use that avenue again.

The majority of employees and contractors surveyed said they would go to their CRS or ECP, if needed.

For the employees, 99 percent said they knew about l

] CRS, and 91 percent of those said they would bring an l issue to them, if needed. Only 3 percent of the employees interviewed cited a negative reason for why they would not report to CRS. Of the negat,ive reasons cited, three were because of possible harm to career or 3 reprisal from supervisors, and four were because they J thought CRS was ineffective or not independent enough to accomplish the tasks. Eight respondents said they would report through other avenues.

h For the contractors, 97 percent knew about ECP, aad 1

j 97 p.ercent of those said they would report an issue tc them, if needed. One of the contractors said reporting

^ to ECP would not be kept confidential. Four respondents said they would report through other avenues.

- We also found t' hat for the contractors,95 percent knew about CRS, and 96 percent of them would use it, if 4

needed.

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  • Office of the Inspector Generaf. Inspections

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The majority of employees and contractors surveyed ,

{ said they felt free to raise intimidation and harassment (l&H) Issues with CRS or ECP. For the 235 employees,88 percent said they felt free to raise an f I&H issue with CRS, while 9 percent said they would not. Only 3 percent of the employees interviewed cited

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a negative reason for why they would not report to CRS. '

J Of the negative reasons cited, five, were related to management and career concerns, and two were g because of a belief that CRS was not effective. '

Fourteen respondents said they would report through other avenues. .

For the 97 contractors,94 percent said they felt free to raise an I&H issue with ECP, while 4 percent said they would not. Only 5 percent of the contractors interviewed

] cited a negative reason for why they would not report to ECP. Of the negative reasons cited, six were based on management and career concerns and one that ECP

] was not independent. One respondent said he would

" report it elsewhere "

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The majority of employees and contractors surveyed a

appeared to have a general understanding of the l In addition, most

~- purpose of CRS or ECP.

employees who had a basis for an opinion indicated

] their program's staff was effective. Of the J employees, 39 percent of the respon'se.s said the primary purpose of the CRS is "an alternate path to

] management," and 15 percent of the responses said the J

primary purpose of the CRS is to " investigate or record

' nuclear safety issues." Only 4 percent of the 1spondents said CPS was ineffective in these roles.

The remaining considered CRS to be effective or had no basis for opinion. Of the 230 employees we interviewed

} at SON who knew about CRS,37 employees had used it. Of those 37,30 w'ould use it again, and 6 would not.

Of the six, three were dissatisfied with the results from a

' previous encounter, two reported that their confidential concern was given to their management; and one p indicated he would report to the OlG instead. (Please

~ see Appendix C for further details of survey responses.)

Of the contractors,18 percent of the responses said the primary purpose of the ECP is "an altemate path to management," and 28 percent of the responses said the

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Otfice of the Inspector General, inspections primary purpose of the ECP i.s to " investigate or record Only 3 percent of the nuclear safety issues.'

respor. dents said ECP was ineffective in these roles.

The remaining considered ECP to be effective or had no basis for opinion. Of the 97 contractors we interviewed at SON who knew about ECP,2 contractors had used it and would use it again. (Please see Appendix C for I further details of survey responses.)  !

{ For the contractors, 5 of 97 (5 percent) did not know

) about CRS. This is in contrast to the 2 of 235 (1 percent) TVA employees who did not know about CRS.

With respect to how well the respondents thought nuclear safety or quality problems are being resolved at

]. SON,80 percent of the employees and 90 percent of the contractors at SON who had an opinion thought the For problems were being resolved well or very well.

] those who said problems are not being resolved well, about one-half of the comments were related to budget, about one-third to operations and maintenance issues,

] and about one-fifth to the concerns program. (Please see Appendix D for further details of survey responses.)

Lastly, respondents were asked if they had any other comments they would like. to add. The most frequent

. comments are highlighted in Appendix E.

i We provided interviewees with an anonymous feedback l ANONYMOUS SURVEY questionnaire (see Appendix F) which gathered data l

about the interviewee's perceptions of the interview and I FEEDBACK confidentiality issues and which gave interviewees E another opportunity to raise issues in a nonthreatening j environment.

No comments were critical of the interviewer or expressed doubts about the confidentiality of their Additionally, no comments raised issues

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relating to the safety or quality of the nuclear plant.

il Of 71 comments made,55 expressed appreciation for a well done interview and/or the chance to talk about the issues to a willing listener,1 suggested a topic for future interviews,11 involved issues that were peripheral to this review,2 reaffirmed the interviewee's belief that the 1

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' Office of the inspector General, inspections CRS is working well, and 2 contained suggestions for the program.

In our opinion, the tenor of the feedback suggests that the interviewees felt free to discuss the issues that were the focus of the interviews. (We have provided the text of these comments to CRS management.)

j The most significant opportunity for improvement at OPPORTUNITIES SON is to ensure that the contractors' ECP exhibit the i FOR necessary independence from contractor management.

IMPROVEMENT One way to achieve this goal would be to select an ECP manager who would be perceived as independent from the contractor's line management. Alternatively, the availability of CRS to contractor personnel could be more highly publicized. A third option would be to determine whether the contractors' employment level on-site is large enough to justify having an ECP.

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Appendix A Page 1 of 3 TVA Nuc.ur Safety and Quality Concerns Questionnaire No. Sate:

Interviewer:

h} Job

Title:

Contractor Years at TVA Time in TVA Nuclear 1)+ If you had a nuclear safety or quality problem, would you report it? Y ,,,,,, N ,,,,, M _NR ,_,_ o If no, why not?

5 + If you would report a problem, to whom would you first report? (. . . and secon d, . . . and third?)

. Work Order

f. . Corrective Action Process

. Fellow Worker

. Immerfiate Supervisor or Foreman

' . Your Supetvisor's Management

. Contractor's Site Management TVA's Site Management h .

. Contractor's Employee Concerns Program

. TVA Concerns Resolution Staff

{

- . Human Resources

- . TVA Office of Inspector General

. Nuclear Regulatory Commission

. Department of Labor

. Other

}

4 2)+ Would you report a nuclear safety or quality problem to your Supervisor?

Y ,_ N _ M _NR _o f If no, why not1 (Note: Do not read options to inserviewer: Use as a convenient way to record data.)

Schedule pressures Hurt my career _

Fear of reprisal from Supv. _

Report it elsewhere No response _

Mgmt. ineffective to fix it _

Other

  • Have you ever raised a safety or quality problem with your supervisor?

Y ,,,,_ N _ M _NR _ o I' If yes' Approximately when?

Was your supervisor responsive and did he or she get the problem evaluated thoroughly?

Y _ N .,,,,, M _NR _ o 3 Would you report a problem through your supervisor again?

Y ,,,,_ N _ M _Mt _,,,,, O If no, Why Dot?

4 KEY: Y = yes, N = no, M = maybe or it depends, NR = no response or don't know, O = other  ;

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Appendix A Page 2 of 3

') TVA Nuclear Safety and Quality Concerns Questionnaire (Page4 l 3)+ Did you know that your employer has an Employee Concerns Program (ECP)?

Y ,,,__ N M __,.NR ,,,_ O (l/no. ask "since you don't know about ECP, perhaps there is a weakness in their training prognm that we need to identify and fix Have you had GET or other orientation training'* Tes_,,No and shp gussnon 4, below.)

+ Would you report nuclear safety or quality problems to your Employee Concerns Program Y .,,,,, N _ M _NR _ O

,m If no, why not? (Note: do not read option,s to inteniewee: use ar a convenient way to record data)

Fear of reprisal from Supv. _ Schedule pressures _ Hurt my career _,

ECP ineffective to fix it _ Report it elsewhere _ No response _

_ Other ECP not independent enough to accomplish its duties?

  • Have you ever used ECP?

. Y _ N ,,,_, M _NR ,,,,_, O ie If yes, what year did you use the program (date: ) and please describe the problem?

safetyrTechnical _, Mpnt & Personnel ,,,,_ Inurnidation & Harassmeru _ EEO _

g %e l Was ECP reeponsive and did they get the problem evaluated thoroughly?

i Y _ N _ M ,,,,NR ,,,,_ O Was the feedback you received adequate and timely ?

Y _ N ,,,,,, M ,,_,,NR ,, O a

Would you report a problem through ECP again?

Y _ N _,,,, M _NR _ O
4 If no, why not ?

4)+ What do you consider to be among the primary purposes of the ECP' (Note: do not read options to inteniewee: use as a convenient way to record data) 1 g /Jternate path for those who dont go to line mgmt. Effee. Ineffec. No Opin/Dir. Knowledge _

i5 Arbitrator or additional path after going to line mgmt. EEec. Ineffec. No Opin/Dir. Knowledge _

Raise Quality issues E Eec _ _ Ine Eec. No Opm/Dir.Kn
wle: ,,_

No Opm/Dir. Knowledge _

Raise " technical

  • issues Ecec. Inecec.

_ Record nuclear safety concerns Effee. IneEec. No Opin/Dir. Knowledge _

Raise concerns to site Management EEec. Ineffec. No Opin/Dir. Knowledge _

I Satisfy the Nuenear Regulatory Commission Efrec. IneEec. No Opin/Dir. Knowledge _

Investigate nuclear safety concerns Effec. Ineffec. No Opin/Dir. Knowledge _

Direct concems toward the best resolution EEec. Ineffec. No Opin/Dir. Knowledge _

Handle Management and Personnel issues Effec. IneEcc. No Opin/Dir. Knowledge .__,,

Provide a safe harbor to register concerns Effee. Inefree. No Opin/Dir. Knowledge ,_ _.

Handle concerns in confidence Effec. Ineffec. No Opin>Dir. Knowledge ___

Report Intimidation and Harassment issues Effec. In d ec. No Opin/Dir. Knowledge _,

Catch concerns before they become problems Effee. Inecec. No Opin/Dir. Knowledge _

,g Other Effee. Ine!Tec. No Opin1Du. Knowledge _

l 2 KEY: Y = yes, N = no, M = rnaybe or it depends, NR = no response or dont know, O = other

Appendix A r TVA Nuclear Safety and Quality Concerns Questionnaire (page 3) 5)+ Do you feel free to raise Intimidation and Huassment concerns with Y _ECP?

N ,.,,_ M .,_NR ,,,_ O >

1f no, why not? (Note: do not read options to internewee: use as a conunient way to record data)

Schedule pressures Hun my cueer _

Few of reprisal from Supv. __

Repott it elsewhere _

No response _

ECP ineffective to fix it _

Other ECP not independent enough to accomplish its duties? _ , _ ,

j 6+ Do you know that TVA has a Concerns Resolution Staff (CRS) for reporting employee concerns?

Y ,_,,_ N,,,,,,, M _NR _ O l Ufno, ask *sinceyou don't know about CRT, parhaps 6are is a mahness in deir raining pergram dat w need to idena fix Haveyou had CLT or oder oriansanion asining1' Yas_,_,,,, No_.)

+ Would you report nuclear safety or quality problems to the TVAY ,,,,_ Concerns Resolution Staf!?

N _ M ,,,,,,NR _,,,, O lino, why not* (Note: do not read options to interviewee: use as a convenient wery to record data)

Schedule pressures Hurt my career _,_,,

Fear of reprisal from Supv. _,,

Report it elsewhere _._ No response _

CRS ineffective to fix it ___

CRS not independent enough to accomplish its duties? _

Other 1

+ Have you ever used the CRS program? Y _ N _ M __.NR _._ o I if yes, what year did you use the program (date:

) and please describe the prot.mm?

Stfety/ Technical _,,,_ Mgmt & Penannel ,,,,_ tncunidsdon & Harassment _ EEO _,_.

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I Was CRS responsive and did they get the problem evaluated thoroughly?

Y .,_, N ,_ M _NR _,_0 Was the feedback you received adequate and timely ?

Y ,_ N __, M .__NR ,,,, O Would you report a problem through CRS again?

Y _,_ N _,_ M _,,,NR _ 0

' If no, why not?

7)+

In your judgment, considering all the possible ways to get nuclear safety and quality problems 6xed, how well a problems being resolved at Browns Ferry?

Fairjob Poorjob Very poor No OpinJDir. Knowledge _,_

! Very good Goodjob Please explain and include specific examples:

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I 8)+ Do you have any additional comments ?

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s. - _ KEY: Y = yes. N = no, M = maybe or it depends. NR = no response or don't know, O = other

Appendix B Page 1 of 3 i

j l DO SON EMPLOYEES / CONTRACTORS FEEL FREE TO I NUCLEAR SAFETY ISSUES TO MANAGEMENT?

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' SON EMPLOYEES a'

J No i

1%

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' Yes

99 %

'. N = 235 Interviewees i

SON CONTRACTORS

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d W

Yes 100 %

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N = 97 Interviewees s.

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' Appendix B Page 2 of 3 j

TO WHOM WOULD YOU REPORT A CONCERN?

SON EMPLOYEES First Choice All Others

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All of these respondents cited

other internal avenues as their first choice. This may be an I indication of program effectiveness.

I immediate f g j E

Supervisor 89 %

P L N = 235 Interviewees

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Avenues for Reporting a Concern g

250 " 225

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200-- 192 t

i 150 -

119 Second or third choice of all20 respondents

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100 --

46 43 ll 50 --

fl 0- '

Imm Spvr Site CRS Corr Other NRC Spvr Mgmt Mgmt Act

.l N = 235 Intervie'aees

Appendix B Page 3 of 3 TO WHOM WOULD YOU REPORT A CONCERN?

1 SON CONTRACTORS First Choice 4

All Others l

All of these respondents cited f i

other internal avenues as their first choice. This may be sn j Indication of program l effectiveness.

Immediate j l Supervisor I l 93%

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N = 97 Interviewees i

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Avenues for Reporting a Concern Top Three Choices 100 - gj

! 90 -

80 - Second or third choice of at: 11 respondents l 70 -

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l 60 -

50 -

53 40 - 31 31

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l 30

13. 14 '

Ij 20 -

c 11 10 8 )

10 -

o i i i

,M

,4 EE ,

f Site TVA Other NRC OlG CRS Imm Spvr ECP l

Spvr Mgmt Mgmt Mgmt l

l s N = 97 Inten/iewees 5 . -.

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7 Appendix C

[ Page 1 of 2 THE MAJORITY OF EMPLOYEES UNDERSTAND CRS'S ROLE s

SON EMPLOYEES PURPOSE OF PROGRAM Add / Alt Path to Mgmt 134 invest / Record Nucl 50 Safety Cncrs Provide Safe Harbor 24 l Reg Cncrs Handle Cncts in 20 Confidence L Direct Cncrs Twd 20 Best Res Catch Cncrs Early 18 Elevate Cr.crs to Site 7

Mgmt E 1O 20 30 40 50 60 70 80 90 100 110 120 130 140 N = 342 Responses

[

F s .

- THE MAJORITY OF CONTRACTORS UNDERSTAND ECP'S L ROLE SON CONTRACTORS PURPOSE OF PROGRAM

invest / Record Nuct 33 i Safety Cncts r

Add / Alt Path to Mgmt 21 u

Provide Safe Harbor 9 Reg Cncts Alleviate Personal 6

Cncts m

j Catch Cocrs Early 6 L

0 5 10 15 20 25 30 35 D N = 116 Responses

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Appendix C j Page 2 of 2

j PERCEPTION OF CRS/ECP EFFECTIVENESS AS AN j ADDITIONAL OR ALTERNATIVE PATH TO MANAGEMENT l SON EMPLOYEES AND CONTRACTORS hese respondents indicated they did not have enough q experience with the program to
3 formulate an opinion.

h No Opinion / Basis 56 %

il Effective 43 %

f

!E Not Effective 1%

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N = 155 Responses ll 1

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Appencix D Page 1 of 1 l)

HOW WELL PROBLEMS ARE BEING RESOLVED I_

SON EMPLOYEES

[ 100 90

" $ 80 k $ 70 S 60 g 50 4] w 40 z 30 20

{ @

10 - " i -- - - i 0 i Very Well Fair Poor Very b Poor Well E N = 230 Interviewees 1

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{ 38 of the respondents indicated they did not have enough experience with the program to formulate an opinion.

5 i SON CONTRACTORS 1

!I l 40 g 35 l

!l S 30

[] $25 l j20 -

l o 15

'g

$10 W 5

! o ,

,M: ,~,.........

Very Well Fair Poor Very

'l Well Poor i

N = 85 Interviewees I 18 of the respondents indicated they did not hav e enough experience with the pregram to formulate an opinion.

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Appendix E Page 1 of 1

SUMMARY

OF COMMENTS I

1. 12 comments were complimentary cf CRS or the program.
2. 8 comments were critical of the program due to dissatisfaction with management or personnel issues.
3. 3 comments were critical of CRS or ECP.
4. 11 comments asked for more information on the program. ,
5. 12 comments suggested improvements. These suggestions were provided to the j: CRS.

j 6. 6 comments were complimentary of plant management relative to the program.

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Appendix F Page 1 of 1 OIG Interviewer Feedback Questionnaire 1 He interviewer told me my comment: would be con 5dential.

Neutral Disagree Strongly Disagree Strongly Agre Agree I ne interviewer treated me with counesy and respect.

Neutral Disagree Strongly Disagree Strongly Agree Agree The interviewer seemed interested in what I had to say.

Neutral Disagree Strongly Disagree Strongly Agree Agree The interviewer encouraged me to say whatever I wanted while answering the questions. l Agree Neutral Disagree Strongly Disagree Strongly Agree 1 Amshing else yoe wouid 11xe te teii the inte,v1 ewer 2 l 1

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E Office of the lnspector Genera, Specicil Report To the President and Chief Nuclear Officer CONCERNS RESOLETION l PROGRAM--

SEQUOYAH NUCLEAR PLANT i

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L l 96 91bS Principal Contributors g

h mas B J hnson a Deborah A.Kearnaghan l

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TABLE OF CONTENTS l Executive Summary . . .. . . . . . 1 Objective and Methodology... . . 1 Review Results.. .. .. . . . ... . .1 Review of Closed CRS and ECP Files. .1 l . .

Survey Interviews With 343 Respondents. .... . .. .2 Additional information Gathered. .. .. . .4 Response to Previous Review . . . . . . .5 Opportunities for improvement. . . .. . .5 e

h e

in 1986, the Nuclear Regulatory Commission (NRC)

EXECUTIVE asked this office to periodically review TVA's Concerns

SUMMARY

Resolution Program. This report covers the portion of the program applicable to Sequoyah Nuclear Plant (SON).

We completed our fieldwork at SQN during November 1995.

I in surnmary, we found that SON employees and contractors felt free to raise nuclear safety concerns to and the their supervisors and management, overwhelming majority know about and would use the Concerns Resolution Staff (CRS) or the contractor Employee Concern Programs (ECP). Additionally, we found the majority of cases handled by CRS and ECP were handled effectively. We believe this collective evidence indicates the Concerns Resolution Program is

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operating effectively at SON.

our objective was to determine whether the program is OBJECTIVE AND effectively accomplishing its intended mission. Program

- METHODOLOGY effectiveness, in general, may be measured by the

' extent (1) TVA employees and contractors feel secure in raising questions about nuclear safety at TV'A s

installations and (2) the program has in place adequate

[ means to resolve nuclear safety issues when they are raised outside of line management.

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We reviewed the program by (1) examining all CRS and ECP files closed in 1994 and 1995, (2) conducting 343 face-to-face interviews with randomly selected site employees and contractors, and (3) reviewing CRS and

' ECP actions taken in response to our previous review.  :

REVIEW RESULTS Review of Closed CRS and ECP Files I We reviewed 15 CRS files for evidence of handling consistent with program requirements. All of the files contained sufficient, evidence to suggest the underlying issues were reasonably pursued.

i We also reviewed 21 ECP files for evidence of handling p consistent with program. requirements. The ECP files I contained a variety of issues; that is, filed along with nuclear concerns were management, industrial safety, I

and other types of issues. Of the 21 files, only 5 were directly related to nuclear safety or quality concerns.

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jy We found no ECP files where we disagreed with the  :

2 actions taken.

l The background documentation of some files from - l Bechtel's ECP were not filed alongside of the issues l'  !

addressed, making the course of the investigation J difficult to review. Files from Stone and Webster

] Engineering Corp. (S&W), in contrast, were clearly i documented. 'In our previous review, we noted that i j S&W's ECP was not organizationally disconnected from ,

S&W project management. This condition remains, but

,, may increasingly become of less consequence as

l S&W's headcount on site declines.

ly. Survey Interviews With 343 Respondents 1

During November 1995, we interviewed more than 18 percent of the personnel on site. This sample size jg allows us to project our results to the entire SON ls workforce, generally, with a 95 percent confidence level and a margin of error of +/- 5 percent. We also asked each interviewee to complete an anonymous feedback

' form, thus giving them another opportunity to provide j further relevant information. During May 1994 we i

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conducted a similar survey at SON, and the NRC conducted a similar survey during August 1993.

Our survey results, along with comparisons to previous SON surveys, are presented in the charts beginning on 4

page 6. The results of our 1995 survey were consistent with our 1994 survey, with one exception; the only i statistically determinable difference was a 13 percentage point improvement in TVA employee l opinions about whether site problems were being )

resolved well. This improvement may be attributable to .

changes in site circumstances. When we interviewed in

!. November 1995, the site had just completed a a

successful outage. ..But when we interviewed in May 1994, the site had recently recovered from a lengthy unplanned shutdown due to a steam pipe rupture.

Based on our survey interviews, the overwhelming majority of employees and. contractors felt free to report nuclear safety or quality problems at SON.

4 Specifically, only 3 individuals out of 343 employees _

and contractors interviewed at SON said they v2ould not report a problem, if they knew of one, through their l

! 2

supemisor. The employee's and the contractor's d

immediate supervisor was the first choice for reporting j concerns for 94 percent and 88 percent, respectively.

Of the employees interviewed, 88 (37 as a routine part of their job) said they had reported a problem to their j supervisor, and all of them said they would do so again under similar circumstances. However, 6 of these 88 said the supervisor was not responsive and thorough in addressing the concern.

h Of the contractors intewiewed, ten (two as a routine part g of their job) said they had repoded a problem to their g

supervisor. All ten said the supervisor was responsive and thorough, and that they would use that avenue I again.

The majority of employees and contractors surveyed I said they would go to CRS or ECP, if needed. For the employees, 99 percent said they knew about CRS, and 92 percent of those said they would bring an issue to l them, if needed. Twenty respondents said they would not use CRS: one-half because of possible reprisal, lack of confidentiality, or ineffectiveness, and the other one-j half because they would report their concerns through other avenues.

For the contractors, 98 percent knew about ECP, and 94 percent of those said they would report an issue to j them, if needed. Of the three reasons cited by those a

who would not use ECP, one was based on potential conflicts of interest, and the other two respondents said they would report their concerns through other avenues.

We also found that for the contractors,95 percent knew J' about CRS, and 97 percent of them would use it, if needed. "

l The majority of employees and contractors surveyed said they felt free to raise intimidati'on and

.E J harassment (l&H) issues with CRS or ECP. For the employees,86 percent said they felt free to raise an I&H issue with CRS, while 7 percent indicated they would not 3 report to CRS. Of the reasons cited, 13 involved

I concerns about career or reprisal from matlagement, and 7 involved concerns about CRS effectiveness.

s.

3

Another 7 percent of the respondents said they would ,

" report l&H elsewhere."

For the contractors, 95 percent said they felt free to raise ap I&H issue with ECP, while only 3 percent said Of the they would not and cited a negative reason.

reasons cited, one was based on potential conflicts of interest'and one for concerns about career or reprisal from management. Another 3 percent of the -

" report I&H respondents indicated they would l elsewhere."

The majority of employees and contractors surveyed f appeared to have a general understanding of the In addition, most ,

purpose of CRS or ECP.

] employees who had a basis for an opinion indicated 1

their program's staff was effective. Of the employees, 49 percent of the responses indicated the

] primary purpose of the CRS is "an additional or alternate another 25 percent path to management," while indicated the primary purpose of the CRS is to

~

" investigate or record nuclear safety concerns." Only 3 percent of the employees characterized the CRS as ineffective.

)

Of the contractors, 29 percent of the responses indicated the primary purpose of the ECP is "an

] additional or alternate path to management," while another 38 percent indicated the primary purpose of the ECP is to " investigate or record nuclear safety ,

a "

Only 2 percent of the contractors concerns.

characterized the ECP as ineffective in its roles, With respect to how well the respondents thought nuclear safety or quality problems are being resolved at l SON,93 percent of the employees and 96 percent of the contractors who had an opinion thought the problems were being resolved'well or very well l

Additional information Gathered During the course of our interviews, we reccidad l approximately 199 additional observations the respondents made about plant quality, management, or the concerns program. Around 54 percent of the overall I remarks were positive, and remarks about plant quality were around 77 percent positive.

g 4

l - . - - _ _ _ _ _ _ _

i t

We received 336 anonymous' survey feedback sheets.  !

They indicated that all interviewees felt treated with courtesy and respect by the Office of the Inspector None expressed doubts General (OlG) interviewer.

about the confidentiality of the interview or disagreed >

that the respondent was with the proposition l

f encouraged to say whatever they wanted during the Of the 90 anonymous written comments, interview.

most were positive, 3 offered opinions on issues f unrelated . to our survey, 65 commented on the interviewer, and 22 commented on the status of the plant or the program. We forwarded all comments with negative implications about the safety or quality of the plant to SON management.

We provided information pertaining to an allegation of  ;

preferential treatment to OlG Investigations who were '

already investigating the issues raised.

A statistically significant gain was achieved during 1995 RESPONSE TO with regard to employee perceptions of how well the .

PREVIOUS plant addresses problems. (A positive increase of

~

REVIEW 13 percentage points, from 80 percent to 93 percent positive.)

We found no statistically determinable difference in any other area. .

i We believe the Bechtel ECP program could improve the OPPORTUNITIES  ;

way documents relating to employee concerns are  :

fL FOR rganized in its files. In our view, the course of an ECP IMPROVEMENT inquiry would be easier to follow if background information was placed alongside of the documentation

} relating to the concern.

i i i il ,

ll .

. - 5 l .. _ _ . . _ _. . _ _ . _ _

i .

)'

i 1995 TVA Concerns Resolution Survey

) SON Employees who would report to management.

NO ll 1%

\ . .. i

.!;;tl.N. Y:{.[:::$ Sh{pn.

LE 4 + . ;j.;' ; i ..

[..,. T

. y'.i ' :_&, gl;'[t .

.].~j a

g .. & . r.. .
: c tr

. ;. 6,g  ;- 1 ; .-i . nf

. x7A

!L, 3-

..R Q 7 ..

y -

.c .

' .; y; .y - ../*

~.

y. . :. -, AQ: y,

...  ?

f .. .

. . .v5

..s

,

  • 4 O

', J- . "_ ,y g

^ '

{ *- [.-'. . .-

_ ~ ' ' ;,

.-.,f

...g

..[

i '

~

" 4 YES

}

i 99 %

N = 278 Interviewees i

i Previous SON Surveys 3

i 1994 TVA Survey 1993 NRC Survey i NO i NO 1%

2%

4}

M YES YES l 98 %

i" 99%

1 i

6 N = 235 Interviewees N = 129 Interviewees i

! 1 s.

%e

1 .

1995 TVA Concerns Resolution Survey SON Employees who would report to CRS.

NO 8%

_y

..;;;.;W ' .::.;e

. ;. r. l '

,' stD' ,

h.< '. :, i . .' -

Q L.,jp: .' : ; . _ _

y ?_'.J_.,

.. a..,.

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h.

.Qi'i 'I ' . ' -. .

I..?' Y . I. . , .

,.; ~ ..: . _ _ yg 1 -

. . }

_^

^

l -t _

-t

_' 9

".'_ ' l I . . .

l I YES

' 92 % i I N = 277 Interviewees 1

2 Previous SON Surveys i 1994 TVA Survey 1993 NRC Survey i i i NO NO 9% 5% ,

l

\

i l i l

l YES l

l YES 99%

91 %

}

4 I

N = 129 Interviewe'es 7 j N = 232 Interviewees il . -. -

1995 TVA Concerns Resolution Survey To whom would SON Employees report a concern?

All Others All but one of these respon-dents cited ther internal First Choice avenues as their first cho, ice.

I

)

immediate (

Supervisor l

' 94%

r N = 277 Interviewees h

E L

Avenues For Reporting a Concern '

! Top Three Choices I~

b 300 --265 250 -- First choice of one f "-

200 -- 162 136 l

$. 150 --

100 --

.l A '

50 - -

26 22 19 9

O- imm Spvr Site CAS Corr Other NRC
g SPYF Mgmt Mgmt Act lg ,

- 8 N = 277 Interviewees l

1995 TVA Concerns Resolution Survey -

t SON Contractors who would report to management.

NO z

0%

3-

.., l~ <

s f $l5l 3, , . ;. '

fg Q "'?t%g ~ ,,,

. , , t;, ' bl' ,

. W[;j$?li?$l,;$jff:f.

'I 6

g. .-Q'gi Qyfjd'::$,

Y

~:~<

h, gp['.g. , ~'f '.;' f. ,l."7 ,g;[':i,

+c '

,e , , J. . j ' . ,,]j.

e

' ' .', ':; '/ L ', -(

~ ' '.:.l[S . . )- ' {,(( p4 y;% 44Mi# glMncy YES 100%

N = 65 Interviewees Previous SON Surveys 1994 TVA Survey 1993 NRC Survey NO NO 2%

c' 0% ... x, E

az v c f

ve gan _ ,f ..

,n, '

)

W piri it 4,

.-  ;.4

+ :- g.  :

P l IEHEl 55 ,

YES YES 100% 98%

l N = 92 Interviewees 9 N = 97 Interviewees

~

y. 1995 TVA Concerns Resolution Survey SON Contractors who would report to ECP.

NO 6%

1 YES 94 %

1 N = 53 Interviewees I Previous SON Surveys 1 1994 TV A Survey 1993 NRC Survey.

1 NO NO 4%

3%

~

YES YES

) 97% 96 %

i N = 92 Interviewees 10 N = 95 Interviewees

~

4e

y

" 1995 TVA Concerns Resolution Survey .

To whom would SON Contractors reoort a concern?

All Others ,

12 %

^

) '

N#Ad * . . .

All but one of these respon-d*"'S *it'd t h * ' ' "' " * '

First Choice -

avenues as their first choice.

l immediate Supervisor 88%

N = 65 Interviewees Avenues For Reporting a Concern Top Three Choices 57 60 -

t 50 - -

Second or Third choice of each

.M e 9

respondent l

29 29 b.-

30 - -

20 -- l 13'

{

g o

l^: _

535.Rif._!_.

. 11 N = 65 Interviewees l

~.

4 9

!- 1995 TVA Concerns Resolution Survey l The majority of SON Employees understand the role of CRS.

PURPOSE OF PROGRAM g ............,.......... ,ss l l.. . . lJA . . .r. N . . l. . , S . f e,y g A . g i.i. , C ... . ,. . m. v 8.t. . Y n.y  :

C .ish C .a.e,.

.......,..... 14 l s .i.. iv en. nae 5 l

.g ...... ............,,..... a n . . e ... . ,. . f . s , . u ,- i. 2

'" 02a*'* 34 , , , ,

20 40 60 80 100 120 140 160 0

N = 312 Responses I

.I The majority of SON Contractor employees understand the role of ECP.

PURPOSE OF PROGRAM  !

.......,,....1......

,, , WWWW6mW 22 g . . . .i S .;.;,,

, ,,.. ,. . , . ...' MM@MMWWSMd 29

. ... . . s .. ,. ,g . ,1. . . . .. '

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............ Om 3

..... .. ,.......,...... 2 . .

..,......, ,] 2 l ao~*

0

%!5skggpg112 ,

20 40 i f2 N = 75 Responses .

g

}' 1995 TVA Concerns Resolution Survey

) SON Employees' perception of CRS effectiveness.

r NO OPINION -

OR BASIS 53%

r L

r EFFECTIVE 44 %

NOT

[ EFFECTIVE 2H L

3%

~

SON Contractors' oerception of ECP effectiveness.

F NO OPINION 6R BASIS 53 %

r i

L F NOT L EFFECTIVE EFFECTIVE I 2% 52 %

+

N = 61 -

13 P

I- 1995 TVA Concerns Resolution Survey h SON. Employees / Contractors who feel free to report

" intimidation & Harassment issues to CRS/ECP.

s Employees to CRS B Contractors to ECP

)!

95%

- 100% -- ~ ' ' 'e 86% Employees = 276 Contractors = 59 80% -- l

  • 2

)

60% -- ,

0 40% --

L l

20% -- l 3%

"~~ "~ '~~ ~~^~~"

- N '-  !

i 0% - -

Those Who Would Not Those Who Feel ll i

Free to Report Report For a Negative Reason l&H i.

i 1994 TVA Concerns Resolution Survey i E Employees to CRS 8 Contractors to ECP 100% -- 94 %

88%

h ,

4^ . ' q. Employees = 231 l i

4' ' Contractors = 96 .

g 80% -- -

l E , g;; ' lJ i

60% - -

W9 - {

!l  ?

W .. i 4 0% --- 3  ;["F i -

g$'4 q? , .

fy g

' 2@jj 20% -

'l

% 5 e,io k{j 3%

~~?"SW *****#"'d l 0%

,j Those Who Feel Those Who Would Not Free to Report Report For a Negative ~ 14 i

l&H Reason I

.y .

1995 TVA Concerns Resolution Survey According to Employees, how well are problems being resolved?

y 150 --

5 120 --

W 90 -

g l=[

  • 60 -- l
{ 30 --

e g_ l j  ; tera m i _ .._ l .

.j

.B Very Well Fair Poor Very W ell Poorly g

I' N = 243 Interviewees l 35 of the respencents indicated they did nct have enough expenence wrth the program to formulate an opinion.

1

l According to Contractors, how well are problems being resolved?

j 50 -- -

g 40 --  !

1 ll $ 30 -

E 20 --T ~e u  ;

J l

-l 10 -- If [ , j 8 c ,  : .: , , ,

i o i i i i l O

.1 Very Well Fair Poor Very f Well Poorly l g

l i

1 N = 54 Interviewees 11 of the respondents indicated they did not have enough expenence with the . 15 program to formulate an opinion.

1

=, l

  • TVA Concerns Rssoluben Progrcm survey .1995 '

J l

1995 Tst. t99. Tow f i

1996S m__ 199. S*N l 1995 WSN i 199.WBNl199. 19CS SCN 233 SCN569 9c. .

1995 Cere.ms A.souen $Jv.y 210 278 3C6 110 lE gi l f.mployee.: 141 112 2C M E 1110 17s0  !

Contr.ctors: J.22 222 33 332 624 393 594 T ot.1: 37

'CC"4 99"*

1 90** I'JC** 99*. f l 100 % 99T. I CC**

99*. f 1 CC*. ' 99 6*.*

'WoWd ts 906 e. Scra. .v.%., .r'IDiry s: 99 7*. 10C%

907*. 10C*k 100*4 Wood t.pon vi. som. .v.%. corerssees- M. 99*.

99*h 99*.  !

10C% 99 7*b ICC*h 94 *. l ' 2. l H d** ' m

'Empoy..e trat woud r. cort to ssp.evgor 'CC*, 99*h 99 6 % 98 % f 100 % 2 W.

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{ l' 9C?.

$wpermact .s ,irst croc , .mpoy..s: l SS** 93 % 93*h 01 %

93*. 9f *. 89*k e 97*. l 94 % ; ai% f Suoe' veer as first ene.e. contr.cors-soo.nn.or r. wor v.. .m..y.n: u*. See, an am 9a l u% ij I 99% 9M 97 %

3 10C*. 99% 97*. 94** ICC%

Wr.Jd e. port to supv, .9.in emoeoy..s. 93*. 45*.

100 % 96 %

83 %

33*. 6.t. 92 %

Sup.rvsor f.sponssv.. contr.ctors: H**

97*h 97*. 92*. 100*. W._ 9E?.

oeuseors- 95 %

Woud r. con to suov .g.c.

M 96 96*.

94*h

  • 99*h 99"b  :

90 % 100*.

Get. 1 Emog.es snoweg .cou C93. 96*.

9?*. 99 %

99.8** 97 % 96*.

97*. 95*.

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9t % 90 %

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93*. # 92*.

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