ML20203H689
| ML20203H689 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/02/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20203G676 | List: |
| References | |
| FOIA-99-76 NUDOCS 9902230073 | |
| Download: ML20203H689 (35) | |
Text
a' A 4 L l 2 % s t / /
d UNITED. STATES ~ NUCLEAR REGULATORY COMMISSION
~
REGION 1 In re:
LIMERICK GENERATING STATION, Licensee Enforcement Conference taken by Cynthia First, Registered Professional Reporter and Notary Public, at the Offices of the United States Nuclear Regulatory Commission, 475 Allendale Road, King of Prussia, Pennsylvania, on Monday, June 2,
- 1997, commencing at 1:00 p.m.
NRC MEMBERS PRESENT:
PAUL SWETLAND RICHAPI KEIMIG NEIL PERRY CHARLES HEIL BRADLEY FEWELL WILLIAM AXELSON DANIEL HOLODY PRESENT ON BEHALF OF THE LICENSEE:
GERRY RAINEY GLENN STEWART WALTER McFARLAND 12ITH KEMPER ROBERT BOYCE DARYL LeQUIA ALSO PRESENT:
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LIMERICK GENERATING STATION 2
NRC:
We'll introduce 3
.ourselves.
~
4 5
(Introduction of 6
participants occurred at this time.)
7 8
NRC:
Let's go ahead and get 9
started.
This is a Predecisional Enforcement 10 Conference.
11 As indicated to you in my 12 letter of April 29th, which we invited you to 13 participate in this conference, the subject of
-14 the conference is to discuss the 15 licensee-identified issues associated with 16 falsification of record.
There are two 17 instances identified in the April 29th letter, 18' one associated with a reactor enclosure cooling
~
19.
water sample in which several individuals were 20 involve., in changing the recorded time of 21 sampling; and certainly indications that a 22 technician, supervisor and, unfortunately, also 23 a-facility manager was involved in this process.
24 Also, there was a situation involving a fire 25 protection assistant technician, I guess, level
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LIMERICK GENERATING STATION 2
involved in falsification of fire protection 3
round entries.
4 As we indicated, we 5
certainly need to discuss these specific issues, 6
but we are also very concerned with the 7-implications, from a generic standpoint, of 8
these issues.
Recognizing that based on the 9
length of time it takes tc conduct these type of 10 investigations, some of these issues are now 11 becoming a bit dated; however, we think it's 12 important that you address that aspect also.
13 As you certainly are 14 aware, this isn't the first time we've had an 15 opportunity to speak in this environment.
The 16 NRC needs to assure through this enforcement 17 conference that we have sufficient information 18 to make an enforcement decision.
We have, of 19 course, reviewed both your investigative records 20 and also conducted some interviews as part of 21 our investigative effort.
And I think the 22 results of those, both efforts, both the 23 investigation and the NRC's renewal and 24 follow-up of those investigations did e
25 substantiate that these falsifications of
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LIMERICK' GENERATING STATION
.2 records occurred.
3 Really what we need to
'undersbandtodayistheculpabilityofthe 4
5 licensee in these'what appear to be individual 6.
acts.
You can certainly glean from the 7-enforcement policy that the NRC has a lot of 8
options with regard to where we go on these
'9 issues, whether we hold not only the individuals 10 responsible for acts, accountable for their 11 activities, but we also have to make a decision 12 on whether the licensee was culpable in these 13 activities.
So'that's why we're here today.
14 And I guess with that, I 15 would ask if anyone else had~anything to add.
16 Then we'll just turn it over to you for your 17 discussion.
Go ahead.
18 LICENSEE:
Good afternoon, 19 we appreciate the opportunity to be here this 20 afternoon and to share with you the information 21 concerning these apparent falsification events at 22
-Limerick.
We intend to show that these are 23 independent events and are not. indicative of the 24 culture at Limerick.
25 If you take a look at the L
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LIMERICK GENERATING STATION 2
agenda on the second page, Bob and Daryl will 3
each discussion the events respectively, 4
including the immediate actions, investigation 5
results, follow-up actions and actions to 6
prevent recurrence.
7 Bob Boyce will then 8
discuss the station-wide actions taken to 9
prevent recurrence.
10 I will then talk about the culture and discuss enforcement policy 11 12 considerations.
13 And then Gerry Rainey will 14 discuss the overall actions and close the 15 presentation.
g/g 16 With that I'd like to turn 17 the presentation over to Bob Boyce to discuss 18 the details of the chemistry event.
19' Thank you, Walt.
The 20 direct enclosure cooling water system is a 21 non-contaminated secondary enclosed cooling 22 water system.
With the RECW system radiatation 23 monitor operable, the tech spec LCO action 24 statement requires that the RECW system water be i
25 sampled and analyzed for contamination once
, _, _. - ~._._._ __._.._ _.-_ _ _. _ _.._._ _ _._~._______
l
=
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LIMERICK GENERATING STATION 2
I'll present the' fire 3~
protection _ event.
4 In August of
'96, I was 5
conducting personal interviews with the fire 6'
' protection group.
The purpose of these 7
interviews was to address some teamwork and 8'
efficiency issues within that group.
At that 9
time I was aware of the chemistry ST performance 10 issues, and Bob had been bringing that up at the 11 director's meeting and we had discussed that at 12 length; so that did give me some heightened 13 awareness on ST performance.
14 During the interviews one 15 of the individuals came up-and mentioned that he 16 was' concerned relative to a ST test that he 17 thought was performed with too short a duration 18 and maybe poor quality was identified.
So I 19 perked up my ears at that.
I obviously thought 20 there was some concern to go pursue after that.
21 Responding to the 22 concerns, I did recommend that a line management 23 review be conducted to determine the validity of 4
i 24 the potential obstruction.
That included review 25 of the ST, review of the due access records, and
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LIMERICK GENERATING STATION 1
2
. walk-downs of the selected plant areas.
l c
3 As a result of that, the 4
discrepancy ~was confirmed in that an individual 5
had failed-to go to all areas of the plant i
i 6
Tacessary to perform required fire hose 7
inspections, and.that the individual signed off the surveillance test indicating he had 8
9 performed the inspection in those areas.
10 Immediate actions, once I 11 determined that, once the ST was confirmed, the 12 problem was confirmed, I notified my management 13 and' raised the issue of NQA's concern.
As a
'14 result, a joint NQA and corporate security 15 investigation was initiated.
At that time I i
16 also dropped the status of the unescorted access 17 of the individual involved in the issue.
.18 Inves".igation results:
Of 19 the NQA and corporate security investigation 20 revealed that one individual had falsified a 21 total of six surveillance tests between April 22
'95'and July '96.
The investigations showed 23
.that an individual acted out of his own accord 24 and that there was no supervisory coercion
- 25 involved.
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LIMERICK GENERATING STATION 2
As a result of the 3
investigation, we did expand within the fire 4
protection group.
The investigation included or 5
identified that there were two other 6
discrepancies involving two other individuals 7
within the fire protection team.
And in one 8
case the work was performed, but the wrong date 9
was recorded.
In other case, the individual had 10 entered the area to perform the work, but had 11 not remained long enough to perform the work 12 properly.
In both cases the ST was signed off.
13 However, we did 14 investigate it, and both cases were considered 15 to be isolated errors by the individuals.
16 Therefore, the investigation concluded there was 17 no intent to willfully falsify records.
18 However, it did not meet my performance 19 expectations and the individuals were 20 appropriately disciplined as a result of the 21 investigation.
Also, their access was suspended 22 to light-duty investigation.
23 Immediate follow-up 24 actions:
After admission of intentional 25 falsification, the individual's appointment was i
51 p_.-
1 LIMERICK GENERATING STATION 2
suspended and the applicable surveillance tests i
I 3
were reperformed satisfactorily.
The ST's were i
k
~
4 all completed satisfactorily, indicating that 5
the affected fire protection equipment was t
i 6
Therefore, there was no plant safety 7
consequences as a result of the failure to i
8 perform the ST's.
The expectations were 9
reinforced within the fire protection group by-10 myself with members of the fire protection team.
11 Actions to Prevent i
12 Recurrence:
Based on the findings within the 13 fire protection group, management expectations 14 for personal integrity were reinforced with all 15 members of my division, the Site Support 16 Division.
In addition, because of both the
-17 chemistry and the fire protection issues, of 18 which we were aware now, Walt did issue a letter 19 regarding personal integrity at all site 20 personnel.
And based upon our knowledge of the 21 chemistry and fire protection issues, we did
.22 take site-wide action.
23 So we'll address questions 24 at this time or refer to Bob to discuss the 25 site-wide actions.
4 i
I
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LIMERICK GENERATING STATION 2
Any questions of Daryl?
3
-The site-wide actions really came as a part 4
of'--
5 Subsequent to having an 6
-issue in both chemistry and fire protection, 7
while as been described they may appear to have 8
.been different, independent NQA investigation-9 was expanded to include other site groups to 10 assure ourselves that they were, in fact, 11 isolated.
Some discrepancies were identified 12 and were investigated by security and were 13 turned over to management to address; i.e.,
with 14 the hundreds of tests and reviews that were 15 done, there were some discrepancies attributable 16 to poor work practices.
However, based on the i
17 results of the assessment, management concluded 18 there was no generic concern regarding i
19 falsification of records.
20 I'll give you an example.
l 21 We had found that during an outage, there was 22 some work performed where the work order, which 4
1 23 is a low-level activity, the actual sign-off was i
24 done after the work had.been completed at &
1 i
25 later time with best estimate times, but not the I
I-j
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LIMERICK GENERATING STATION 2
actual time.
We considered that poor work 3
practices, and it was identified by us because 4
really there was no reason to have a date or 1
5 time in there, because in this case it was I
6 installing some cameras.
And so we probably --
7 not probably.
We were demanding more of the 8
work force when the guy was doing his job than 9
was absolutely necessary.
That was the kind and 10 depth of detail that we went to to assure 11 ourselves that we didn't have issues of people 12 doing something wrong.
13 In addition, the group 14 meetings were conducted with all site personnel, 15 with the vice president personally, 16 Mr. MacFarland personally, and the other senior 17 managers and directors present discussed the 18 expectations of truthfulness and integrity.
It 19 was brought home to each member of Limerick 20 Generating Station, and the groups that work 21 with us, that we would not and could not 22 tolerate any activities or events that would 23 challenge the integrity of our systems which 24 rely on the personal integrity of the people 25 involved.
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LIMERICK GENERATING STATION 2
So at this time I'd like 3
to turn it back over to Walt, and he'll discuss Limerick's culture and some enforcement policy 4
5 considerations.
6 NRC:
Before we leave this, 7
could you expand a little bit on the independent 8
assessment that was conducted site-wide?
Is there 9
some sort of sampling process?
10 LICENSEE:
Sampling'of 11 entries; there were samplings of signatures.
The 12 NQA organization called an extensive review in all 13 the areas, from security to operations, ST's; and 14 so that we were not in any way deluding ourselves 15 that while these two isolated incidents were just 16 that, we were not going to allow ourselves to try 17 and do that without actually looking, physically 18 looking for this type of error in other 19 organizations.
20 And subsequently we've 21 also gone back and done sampling, extensive 22 sampling in both Daryl's organization and in 23 chemistry in particular, associated with --
l 24 since this event we have any other issues 25 associated with that.
So we've pulled those in
I 1
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LIMERICK GENERATING STATION 2
particular.
3 And we'll also heightened 4
our awareness, both by looking at the 5
assessments performed by NQA to make sure we 6
really understand what theyre looking at and i
7 what we're getting out of those to do what we 8
can to assure that the people acknowledge the 9
integrity aspect.
And that's all put into our 10 self-assessments as we go forward.
11 NRC:
One comment.
Maybe I 12 missed it.
I apologize if I did.
13 In your investigation, 14 before the individual's employment was 15 suspended, was he interviewed by --
16 LICENSEE:
This is the fire 17 protection one?
18 NRC:
Yes.
19 LICENSEE:
The individual 20 was --
21 NRC:
What was the reason?
22 Why did he do it?
23 LICENSEE:
He had basically 24 two reasons that he talked to me about.
One was 25 that he was using his own prioritization or his
4.
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LIMERICK GENERATING STATION 2
own judgment to prioritize a task.
He didn't 3
think that was as important.
An'd he also was 4
going to take credit for being in the plan't at 5
different times, but that wasn't substantiated 6
when you did the walk-down or looked at the ST's, 7
et cetera.
There were no access records.
8 It's really hard at that 9
point to understand.
Was someone rationalizing 10 what they did or was that rationalization done 11 prior to not performing the test properly?
I 12 mean, so the guy felt that the inspection was 13 not that important to the safety of the plant, 14 right, Daryl?
15 Right.
16 And he felt like I'm c 5,
17 there anyhow and checking this stuff all the 18 time while I'm there; so he kind of rationalized 19 it, that it was not that important.
20 NRC:
One other question on 21 the independent assessments and things.
Is this a 22 routine activity or is this a one-time --
23 LICENSEE:
No.
In the 24 environment that we ask the employees tc be in and 25 certainly the management to be in, with
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LIMERICK GENERATING STATION 2
relationship to you, we do not feel that we're 3
going to go out and do audits to look to see 4
whether people actually do the surveys or not.
We 5
believe that's an-expectation of employment, is to 6
do that.
We look for the environment to be open 7
and for people to be honest.
We have gone back 8
and done some checks here as a result of the 9
problems that we have to say, was it isolated or 10 is it still going on?
11 So we don't do it on a 12 yearly basis or a monthly basis.
But whenever 13 there's an event that we feel needs to be 14 investigated, we go and do those cross checks 15 and do the comparisons of the gate logs to 16 security, the surveillance test logs to operator 17 rounds.
It has been done before.
18 But we haven't written 19 down on a line we're committed to do this on a 20 certain frequency.
21 Right.
It's not a routine 22 thing that we do, but if there's any doubt in 23 our mind, we can always do those type of 24 investigations.
25 I want to go to the other
~
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1 LIMERICK GENERATING STATION l
2 side and say what we do do.
We are very adamant l
3 about the success of people being able to 4
perform tests.
As part of our routine 5
expectations you'll find observations of people 6
in the field doing surveillance tests by i
7 managers, by myself, presence in the main 8
control room.
You'll see, when we do specific 9
periods of review, whether it's from QA that 10 does the audits and the assessments, we'll go 11 out and focus on an area, making rounds, to 12 assure ourselves that the operators not only are i
13 going to where they're supposed to, which we 14 believe they will, but we are not in the -- I 15 guess I would look at it as the one-over-one 16 oversight of attempting to relate a particular 17 time to a particular surveillance, because it's 18 relatively unaccomplishable in that the person 19 could enter and do ST's and never go through 20 another guarded door.
And I think we would take 21 away the development of the self-accountability 22 that we've driven so far down in the 23 organization, which I think is the key element 24 to success.
25 I have got to be able to
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1 LIMEYP.'K GENERATING STATION 1
believe that the person, whether I'm watching 2
3 him or I check the door, I can trust him to do 4
what he has to do.
That's what I hired him to 5
do.
That's what everything in our wnole system 6
is based on, is the integrity and 7
trustworthiness of that individual.
And I don't 8
believe in our environment I have to go and 9
challenge that on a daily basis.
I do that --
10 We have a lot of cases l
l 11 where people do speak up and cases where it 12 would never reveal itself.
We have cases where 13 people open a panel door and they hear an odd l
14 noise, like a relay picked up or a breaker l
15 closed or they thought the unit load hum 16 changed.
They'll call control and say, I don't 17 know what I did or if I did anything, but when I 18 opened the door, I thought something changed.
19 We have a lot of cases where people 20 self-identify.
l 21 And we want that healthy 22 environment.
We don't want an environment where i'
23 people feel like we're looking over their 24 shoulder.
25 NRC:
Why don't you go on.
1 l
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LIMERICK GENERATING STATION 2
LICENSEE:
I want to take a 3
couple minutes and talk about the culture of 4
Limerick.
And we talked about the culture from 5
basically '93 on, and we believe the culture has 6
-been open all along.
We've had non-revealing 7
events brought forth by employees in various 8
organizations back in the
'92,
'93,
'94 time frame 9
as we do today.
We've had surveillance 10 documentation discrepancies generated on our 1
11 PEPS (ph), which is our internal system for root l
12 cause.
We've had self-identified LER's.
We 13 talked about several of those today.
14 So I think the climate 15 itself in the past was open and continues to be 16 open.
The fact that the technician felt that 17 she could come forward and.self-identify the 18 fact that the test was not done in a timely 19 manner to her manager, I think also demonstrates 20 that.
21 We continue to tell people 22 to take the time to do it right and make the 23 right decisions at the right time.
Those are 24 extremely important values to us.
We have 25 various methods of self-identification.
We have
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LIMERICK GENERATING STATION 2
management and supervisory oversight, which Bob 3
has talked about, wherein management supervision 4
is in the field on -- almost all the tims 5
there's some manager in the field.
We have team 6
meetings, where the team gets together with the 7
supervisors.
We have on-hands meetings, which I 8
hold on a certain frequency.
We do 9
self-assessment, which involves the employees, 10 where the employees have an opportunity to 11 identify issues.
12 We do corporate 13 assessments, where we bring in an outside 14 organization or people from Peachbottom and 15 Chesterbrook and peers from outside to take a 26 look at our processes and our people and look j
17 for areas to improve.
We have industry 18 assessments.
I talk to the VP system.
It's an 19 open way of communication.
We have PEPS and 20 PEPS hot line, which is way of being able to 21 identify issues and get them resolved and get 22 root cause for them.
We have the quality 1
23 concerns hot line.
24 And Gerry Rainey and Dick 25 Smith come out and conduct step 1.evel meetings
L' 1
LIMERICK GENERATING STATION 2.
with employees on certain frequencies, as does t
3 Joe Pettet (ph) and McNeil.
So I think we nave
-4 from top'to bottom the. management.of the' 5-organization gets a sense of being able to come 6
out and understand where the culture is of the 7
. organization.
i 8
I didn't talk about our i
9 Board of Directors,.but the nuclear committee i
10 has two consultants come out.
In fact, one of 11 the consultants is there today, walking around, 12 talking to employees, getting a sense for their I-l 13 organizations.
So all those are various means 14 of self-identification.
15 We, in the -- I don't 16 remember.the time frame.
I guess it's around 17
'94,
'95 -- came up with the PECO Energy i
18 Advantage, which are our core values for the 19 company; and they include time work, openness, 20 trust and respect, integrity, customer focus, 21 accountability, continuous learning, embraces 22 change and safety.
These are the key values 23 that we consistently _and constantly are letting i
24 the employee know that we believe are important 25 for us to interface with them.
And we also want l
l
l i
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1 LIMERICK GENERATING STATION 2
them to adopt these same behaviors and values.
3 And we've gone a long way.
4 This card has gone a long way in its use'.
I've 5
always got it in my pocket.
I pull it out many 6
times.
The employees are saying, "It's time to 7
pull the card out."
So we use it in a very open t
8 manner, reminding _each other about what's j
9 important about how we behave with one another.
'10 The open culture 11 continues.
People continue to self-identify 12 issues.
We recently had a union vote, and the i
13 results of the election itself would indicate 14 that the employees have faith in the management 15 system.
We beat that better than two to one --
16 actually, three to one.
17 We do an employee value 18 survey on an annual basis in the fall time 19 frame.
That would indicate, if you take a look 20 at the results of that over time, that 21 relationship with the employees are improving.
22 We've done that for the last three years.
So l
23 that's shown steady improvement.
t 24 We have maintained an open i
25 culture at Limerick which we have continued to
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LIMERICK GENERATING STATION 2
nurture.
Employees'have demonstrated and i
3 continue to demonstrate their willingness to I
4 bringfissues, both significant auxi 5
non-significant, forward.
We' talked about l
6 several other discrepancies by some of the other i
7 employees we found along the way.
Th.ey are not 8
consistent with.my expectations; although',
9 however, the discrepancies were addressed 10 through reinforcement of expectations both 111 within the.affected group and site-wide.
So we L
12 didn't take those, even though they were of less 13 significance, lightly.
We do understand the 14 need for people to comply with the rules and 15 regulations.
So-I think, from a generic 16 standpoint, our culture has been good all along 17 and we've done nothing but to make it better and 18 much more open.
19 Just to add one thing to 20 what Walt said.
I'm sure a lot of places have 21 cards that they use to tell their employees how 22 they want management to behave and employees to 23 behave within the culture of that workforce.
l 24 But if you go and spend. time at Limerick or 25 Peachbottom or Chesterbrook, people will walk up t
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LIMERICK GENERATING STATION 2
to you and say, "Where are you on the card 3
today?"
They refer to it on a daily basis.
4 The ladder of_ accountability, which we teach in 5
all our supervisory courses, they'll ask you 6
sometimes, "Where are you on the ladder of 7.
accountability?"
Because we all know the 8
accountability model.
As you get lower on the 9
ladder, it's " disconnected, don't care, can't 10 find a solution."
Higher on the ladder is "want 11 to be a part of the team, want to help you find 12 a solution."
13 When they catch you on a 14 bad day and you're saying the wrong thing, 15 they'll say, "Where are you on the ladder?"
So 16 people really understand the values, the 17 accountability and the core behaviors, and 18 they'll talk to you about them.
So we really 19 try and work hard so all the employees 20 understand that; not just the card, they really 21 understand what it means in the work force.
22 Next we'd like to discuss 23 the events with respect to enforcement policy.
24 The following criteria were reviewed -- will be 25 reviewed, " plant safety significance,
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1 LIMERICK GENERATING STATION
.2 identification credit, and corrective action 3
credit.
4 Plant safety significance:
5 the affected RECW sample was determined not to 6
be contaminated; all affected. fire protection 7
equipment was determined to be operable; and 8
there was no plant safety consequences as a 9
result of this.
10' Identification credit:
11 Both events were a licensee-identified.
The 12 chemistry event was identified to the Limerick 13 experience assessment coordinator.
The fire 14 protection event was identified by a member of 15 the fire protection group to the director of 16 site support division.
17 Management relies on the 18 integrity and trustworthiness of station 19 personnel to perform their assigned duties.
20 Therefore, security access data is not used to 21 monitor surveillance performance unless a 22 specific problem has been identified as we 23 talked about before.
l 24 Additionally, there were i
25 no NRC or industry notifications within the two I
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LIMERICK GENERATING STATION 2
years previous to this event -- these events.
3 Prior NRC notifications information noticed 9230 i
4 l
and generic letter 9303 have been appropriately l
5 addressed.
The latest NQA follow-up 6
surveillance performed in'early 1995 identified i
7 no discrepancies.
8 Most recent industry notification imposed significant event report, 9
10 12/96, concerning non-licensed operators at 11 Susquehanna was issued on November '96 i
12 subsequent to the cccurrence of the event.
This 13 issue was appropriately addressed.
14 Corrective Action Credit:
15 The events -- our interaction and steps that we 16 took were prompt and immediate.
'2 he primary 17 chemistry manager was promptly relieved of 18 managerial responsibilities.
The unescorted 19 access of the individuals involved was i
20 appropriately -- the unescorted access of the 21 individuals involved was withdrawn or suspended.
22 The RECW sample was taken l
23 and analyzed and the applicable fire protection 24 surveillances were reperformed.
The appropriate l
25 reviews and independent investigations were
o-i 68 1
-LIMERICK GENERATING STATION i
i 2
initiated.
i 3
Corrective actions
'l l
4 appropriately comprehensive to prevent 5
t t
5 recurrence: ' Corrective actions were I
i 6
appropriately comprehensiveLbased on the nature, 7
complexity and significance of the issues.
t 8
Investigations were' appropriately expanded ~ based 9
on the findings.
The site-wide assessment 10 showed that these were isolated cases of falsification.and not generic issues concerning 11 l
l 12 the integrity of station personnel or the 13 willingness to misrepresent events or 14 activities.
The result of the corporate
.15 assessment performed towards the end of 1996 l
16 indicated that the vice president, myself --
l 17:
discussions on integrity were well received by i
18 site personnel who considered them effective in i
19 communicating management expectations in these 20 areas.
t 21 We take these events very 22 seriously and will continue to rely on 23 individual accountability, self-assessment, and 24 independent assessment to ensure that issues are 25 being identified and addressed.
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Before I go to the 3
conclusion, any questions at all?
4 NRC:
I have one.
How long 5
was the chemistry manager, the one that we're 6
talking about here, how long was she employed?
7
. LICENSEE:
It had been, 8
like -- I think it was
'89.
9 NRC:
19897 10 LICENSEE:
Right.
And prior 11 to '89, she was employed as a contractor full-time 12 at Limerick for probably seven years, Keith?
13 Yeah.
It was something 14 along those lines.
She had been associated with 15 the company for a considerable amount of time.
16 NRC:
Was she i
17 ANSI-qualified, five years experience at the 18 chemistry manager position?
19 LICENSEE:
Yes.
20 NRC:
What type of degree 21
,did she have?
-22 LICENSEE:
She had a degree 23 in chemistry.
24 NRC:
Undergraduate?
25
. Graduate?
~
l 70 L.
1 LIMERICK GENERATING STATION i
2 LICENSEE:
She had an i
3
. undergraduate 1 degree in chemistry.
Her first job 4
vas as a chemistry teacher in a school, and she 5-had gotten involved in the chemistry industry.
6 She~also had a master's in business 7
administration.
8 NRC:
Okay.
9 LICENSEE:
She had also been 10 trained at the BWR course.
11 Yes.
She's been to the 12 13-week BWR course.
l 13 NRC:
Did she work anywhere 14 besides the chemistry department?
15 LICENSEE:
She had been on l
16 some other short-term special assignments with 17 other groups for durations up to like eight 18
. months.
But besides that, she had spent all her 19:
time in chemistry.
20 She was in our corporate 21 headquarters for about eight or nine months, 22_
looking at some of our central support l
23 activities in how to make them more efficient.
24 It was an opportunity for her to go downtown.
25 She asked for that through my predecessor, and L
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LIMERICK GENERATING STATION i
2 my predecessor said surely, he thought it would 3
be a good idea for her to be able to develop 4
herself.
She had just gotten her MBA and had 5
wanted to broaden herself a little bit.
~
6 And prior to '89 she had 7
worked in other Limerick groups as a contractor.
8 NRC:
Okay.
9 I had one.
The chemist, I
10 was he a supervisor or not?
i 11 LICENSEE:
No, he was not.
12 NRC:
That was some l
13 discrepancy.
14 LICENSEE:
He had 15 periodically acted for Sue when Sue was not 16 present, but he was not -- that was not in a 17 management position.
18 Individual contributor 19 salaried employee.
20 NRC:
So he did not provide 21 oversight for the technicians?
22 LICENSEE:
He did 23 periodically perform that function.
So sometimes l
24 he would be involved in doing reviews of their l
25 work and things.
So there's either a technician
i l
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LIMERICK GENERATING STATION 2
work force, and then there's a staff work force.
3 And the staff work force are usually the people 4
that are called upon to fill in.
They also i
5 sometimes provide some reviews of data and things 6
like that.
I would say it's considered somewhat 7
of a higher level, the salary versus an hourly 8
employment position.
9 Much like an individual 10 contributor engineer would be.
11 Very similar, yes.
12 NRC:
Not within the 13 hierarchy of management.
A first-line supervisor?
14 LICENSEE:
No, not in the 15 direct line.
16 Ms. Blacklock was a 17 first-line supervisor.
18 That's correct.
19 NRC:
Any other questions?
20 LICENSEE:
In conclusion, 21 there was no plant safety consequences due to 22 either event, the chemistry eventevent or fire i
l 23 protection event.
Both chemistry and fire 24 protection concerns were identified by members of 25 the station staff.
This is significant because it
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LIMERICK GENERATING STATION i
2 supports the fact that we do have the right i
3 culture at Limerick.
i 4
Immediate or promph 5
comprehensive actions were taken in both cases.
6 Thorough investigations were performed in both 7
cases.
And additional corrective actions were 8
implemented as appropriate.
9 On the surface these 10 events appear'to be related, but after more 11 detailed investigation and review, we find them 12 to be independent.
We found no generi~c 13 implications of a willingness to misrepresent
)
14 data or activities.
i 15 These are very serious 16 events for PECO Nuclear.
I personally find it 17 absolutely unacceptable for individuals who 18 would knowingly misrepresent information and 19 then try to cover it up like occurred in the 20 chemistry event.
The foundations of our 21 programs are integrity, openness,
.22 trustworthiness of line employees.
That is why 23 we took immediate actions as we did.
Suspending 24 individuals from unesco.rted access were 25 appropriate and suspending their. employment with l
y s.,
..r
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LIMERICK GENERATING STATION 2
intent to terminate were appropriate.
3 Myself and the entire 4
Limerick management team are committed t6 5
ensuring that an open culture does exist at 6
Limerick, and we will continue to work on that 7
and continue to improve it.
That's all I have 8
to say.
9 NRC:
I guess on the first 10 case, the fire protection, I think you've said it, 11 first-line supervisory oversight of field 12 activities is very critical in this business.
And 13 in you don't -- the workers want the supervisor 14 out in the field to watch their activities.
They 15 value that.
Without it, sloppy people become 16 sloppier, and one event leads to another.
17 On the second issue, 18 that's the issue that we have to meet on 19-obrselves, we have to evaluate the person's 20 position.
This person is a very important 21 person, and the extreme measures that were taken 22 to cover up the issue we'll have to assess.
23 That's the disturbing issue.
I don't have 24 anything else.
25 I guess nothing much to
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LIMERICK GENERATING STATION 2
add other than I think -- I guess I would just 3
take issue with perhaps -- not issue with the l
4 plant safety consequences, but certainly'the 5
significance of a supervisory level integrity 6
issues are certainly devastating to you as a 7
licensee and certainly to us, being in a 8
position of having to do much less sampling 9
program than you had the opportunity to do, to 10 ensure that there's appropriate performance.
11 I guess where we go from 12 here, I would certainly'need to make a decision 13 in this situation.
As indicated when we 14 started, and I guess just for the record, we, I 15 guess, conclude that ir both these cases there 16 was essentially a violation of 50.9, being that 17 inaccurate information on required records was 18 made as a result of these two events.
And 19 certainly the thing that we have to determine is 20 whether or not the licensee contributed to those 21 violations by establishing an environment that 22 perhaps condoned those type of activities.
23 I don't know if you're l
24 aware or not, but we do have enforcement l
25 conferences scheduled with individuals involved,
o.
I 76 l
LIMERICK GENERATING STATION and we'll'certainly take all of this information 1
into consideration.
And if we have further questions, we will be back in touch with'you if we need some clarification.
But with that, I guess we're done.
Thank you very much.
(At 2:30 p.m., proceedings were concluded.)
e 77 1
2 CERTIFICATE 3
4 I,
CYNTHIA FIRST, RPR, 5
hereby certify that the proceedings and evidence 6
are contained fully and accurately in the notes
'7 taken by me in the above cause and that it is a I
8 correct-transcript of the same.
9 kd Q hdsf 10 CYNTHIA#PIRST,~RPR'-~
11 Professional Court Reporter 12 13 i
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18 19 20 21 l
22 23 24 25