ML20206U300
| ML20206U300 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/20/1998 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | Clayton H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20206U278 | List: |
| References | |
| NUDOCS 9905250149 | |
| Download: ML20206U300 (10) | |
Text
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- omsunt llyron Generating A.
.8 4450 North Gcrman Church fload Ilyron. 11.610149794 Tel Hl5 234 5441 November 20,1998 i
i H. Brent Clayton Region ill Enforcement Officer U.S. Nuclear Regulatory Commission Region ill 801 Warrenville Road Lisle, IL 60532-4251
Subject:
Byron Station Request for Evaluation - NRC Tracking Nos. 98-A-0105 and 98-A-0134
References:
(1) Letter from J. A. Grobe (U.S. NRC) to O. D. Kingsley (Commonwealth Edison Company) dated August 5,1998 (2) Letter from J. A. Grobe (U.S. NRC) to O. D. Kingstey (Commonwealth Edison Company) dated August 26,1998
Dear Mr. Clayton:
As requested, we are providing you a copy of our evaluation of the matters described in the referenced letters. As requested, this response is not being submitted on the station docket. The evaluation was conducted by a team, which was comprised of personnelindependent of Byron Station line management. We consider that the evaluation was of sufficient depth and scope to address the concems identified with Tracking Nos. 98-A-0105 and 98-A-0134. As discussed in a teleconference, held between representatives of Commonwealth Edison (Comed)
Company and the NRC on September 21,1998, the submittat dates for response to the concems identified in References (1) and (2) were extended from September 21,1998, and September 25,1998, respectively, to November 20,1998. In summary, and as detailed in the attachment, it is concluded that the overall working environment at Byron Station is conducive to the raising of nuclear safety issues.
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_'O.1'24/99 16:54 FAX 630 5151078 U.S..\\RC REGION III g0g4
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Page 2 November 20,1998 if you have any questions about the attached information or questions related to this matter, please contact Mr. R. M. Krich, Vice President-Regulatory Services, or Mr. J. A. Benjamin, Nuclear Oversight Vice President.
- Sincerely, K. L. Graesser Site Vice President Byron Station KLG/JUrp
Attachment:
Evaluation Report 9
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05]ei@9 36:56 0AA 6.30 $_L5.1078 l.S..\\kC khGiu\\ 111 g o l.3 Attachment Evaluation Report 98-A 0105 and 98-A-0134 1.
INTRODUCTION:
On August 5,1998, NRC Region ill requested an evaluation be performed of an allegation concerning Byron Station. The allegation (98-A-0105) is that " licensee management's responses to individuals writing problem identification forms (PlFs) may have created a chilled environment at the site. The majority of the examples concemed the Operations Department."
Seven examples accompanied the allegation. For the purposes of evaluation, each example is addressed separately. We have also provided information to address the following subjects:
1.
independence of the organization orindividual conoucting the evaluation; 2.
depth and scope of the evaluation; 3.
where the allegations were substantiated, consideration of appropriate root causes and generic implications; and 4.
adequacy of corrective actions, both planned and completed, to address the allegations, as well as appropriately address any generic implications.
On August 26,1998 NRC Region til requested an evaluation be performed of another,
allegation conceming Byron Station. The allegation (98-A-0134) is that "An individual declined to provide their name to the NRC when raising safety concems because the individual believed that in doing so, the individual would have to file a contact report with the licensee." The NRC noted that on approximately June 11,1997, it had referred a similar concem to Comed. The NRC is concerned that this issue has been identified again and specified that the review of this issue should include as a minimum:
1.
clarification of whether all employee contact with the NRC must be documented on a contact sheet and 2.
recent actions taken to assure worker understanding of management's expectations pertaining to contact by employees and contractors with the NRC.
11.
EVALUATION DETAILS:
Indeoendence of Evaluation Team f98-A-0105 and 98-A-0134)
A team independent of Byron line management was established to conduct the evaluation. This evaluation team was comprised of members of the Comed Employee Concems Program staff who report to management that is independent of Byron Station management. A law firm, which has conducted a number of similar evaluations, also supported the evaluation team. The evaluation team reported the results to senior management and their findings are reflected in this response. We believe this evaluation team provided a rigorous, objective evaluation and analysis of the allegations.
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- c., s.m au us ui eoie Death and Scoce of Evaluation (98-A-0105 and 98-A-0134)
Over 100 personnel at Byron Station were interviewed. The personnel intewiewed comprise about 10 percent of the entire workforce at Byron Station and were not selected at random.
The selection process was biased in favor of those personnel most knowledgeable about the allegations being investigated. This was accomplished using two Byron Station personnel, who possessed a great deal of information about the allegations, to identify other personnet with or likely to have first hand knowledge of the allegations. Thus, we consider this sub-group of Byron Station personnel to be most knowledgeable about the matters under investigation.
The personnel interviewed were asked a number of questions related to allegations 98-A-0105 and 98-A-0134. The team evaluated over 140 specific issues related to the seven examples identified in allegation 98-A-0105. Each issue was individually assessed, including document review and specific questions of personnel thought to possess particular knowledge of the issue. Therefore, given the large number of personnelinterviewed and specific issues considered, we believe that the evaluation was of sufficient depth and scope to ensure an accurate assessment of the allegation and of the working environment at Byron Station.
It also should be noted that the team's evaluation reflected in this response presents the facts as known to those interviewed. The team's eisluation also inquired as to personnel's knowledge of the experiences of others as they relate to the seven examples. This latter information is viewed as not the best evidence in that it tends to be somewhat speculative, not consistently reliable, and partially redundant, and thus is not discussed in this response.
Example No.1 (98-A-0105)
" Operations department personnel, including licensed senior reactor operators, hesitate to write PlFs that are critical of management decisions, for fear that writing the PlF would be career limiting."
Approximately 90 personnel were questioned about this example. No one indicated a reluctance to raise safety issues. About 20 percent of these personnel stated they would hesitate to raise non-safety issues, including those critical of management decisions. Twelve of the personnel interviewed expressed that the reason for their hesitation was apprehension of management reaction. Approximately half of these personnet felt that their career would be somehow negatively impacted. Twenty of the specific issues were related to this example.
Only two of these issues were substantiated or partially substantiated. In one instance, it was found that an individual did not write a PlF for fear of retaliation. In the other Instance, it was confirmed that sensitive electronic mail was openly distributed, thereby identifying the originator, but a retaliatory intent, underlying the mistaken distribution, could not be found.
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tt.s.mm m iv3-iii g6i-Operations Department personnel generally are encouraged and willing to write PIFs. Many of the personnel interviewed were the Operations Department personnel most likely to be concerned about Example No.1. The responses of the personnelinterviewed concerning this example do not indicate a pervasive problem, particulady when most of the personnel did not describe a specific incident where they had been negatively impacted for raising a concern.
While some personnel expressed concem about the effect of writing management-related PIFs on career paths, it is concluded that Example No.1 is not an accurate description of the workplace and, thus, could not be validated. Nevertheless, it is important that all personnel understand and fulfill their obligation to write PlFs, whenever appropriate, and we are taking steps to rainforce management expectations.
1 Examole No. 2 (98-A-0105)
"Some supervisors requiring that draft PlFs be suomitted and " edited" by the supervisor prior to entry into the PlF database."
Approximately 70 personnel were questioned regarding this example. Neariy 85 percent responded that draft PlFs are not required to be submitted to their supervisors and are not edited by their supervisors before entry into the PIF database. Of those personnel indicating i
that draft PIFs are reviewed by management and possibly edited, no one interviewed stated that their PlFs had ever been substantively modified (e.g., modifying the intent of the PlF).
Instead, most personnelinterviewed indicated that the edits consisted of grammatical corrections, removal of opinions, and toning down inflammatory language. One specific issue was relevant to this example and it was not substantiated.
It is concluded from the evaluation of thi.s example that, in general, management does not require personnel to submit draft PlFs for review prior to entry into the database. Where j
management did review and edit PlFs, these reviews and edits were non-substantive and editorial in nature, often for the purposes of ensuring better quality PlFs.
Example No. 3 (98-A-0105)
" Dissenting views from management's approach to resolving problemp are not tolerated."
Approximately 80 personnel were questioned regarding this example. The vast majority of personnel believe that management is tolerant of dissenting views, with about ten percent
. disagreeing on this point. Of those personnel who responded (i.e.,43 personnel),100 percent stated that they would not hesitate to raise a dissenting view to management in the future. Ten of the specific issues were related to this example. Five of these issues were substantiated.
The substantiated issues range from a manager's long-standing " resentments' against certain personnel, to a. manager's inappropriate comments to an individual after he identified a valid Fitness-for-Duty concem which resulted in the termination of another individual's employment at Byron Station, to management's failure to effectively address possible unprofessional behavior identified in a 1996 Site Quality Verification (SQV) audit, to a manager's reference to a PlF as raising " nits."
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The overwhelming response that management is tolerant of dissenting views supports a conclusion that the working environment at Byron Station is basically healthy. Despite the substantiation of a few instances where dissenting opinions were not tolerated, we conclude that the vast majority of individuals refuted this attegation, safety was not compromised, and the raising of safety issues was not impeded. As a result, this example could not be validated.
Example No. 4 (98-A-0105)
" Root cause investigation reports being revised by management over the objections of the investigators (e.g., the authors of the reports)."
Of the 72 personnel questioned about this example, approximately 75 percent were aware that management reviews and revises root cause reports. Several personnel recognized that the reviews were inherent to the root cause determination process. Moreover, several personnel stated that management had revised root cause reports to provide clarity and specificity and also to ensure accuracy. Five personnelimplied that root cause reports had been revised over their objections. However, no one believed that these interactions had been conducted unprofessionally. While two individuals characterized the revisions as inappropriate, neither could be specific as to the root cause report involved. Five of the specific issues were relevant to this example. Only one of these issues was sub antiated and then only partially. For this partially substantiated issue, it was determined that did not consider the revision to the root cause report t was concemed with the process leading to the revision.
The evaluation results indicate that root cause reports are reviewed and revised by management. Upon consideration of the interviews, the reviews or changes were found to be cppropriate and part of the normal root cause resolution process. The various specific issue findings do not support this example. The management review of root cause reports at Byron Station has generally worked as intended, with management and personnelinteracting to assure a rigorous and systematic review. Accordingly, this example could not be validated.
Example No. 5 (98-A-0105)
" Supervisors and managers try to talk individuals out of writing PlFs."
Approximately 75 personnel were interviewed concoming this example. An overwhelming majority of the personnel responded that supervisors and managers have not attempted to dissuade them or others from raising concems or writing PIFs, but rather that management is v:ry supportive of writing PlFs. A small number responded to the contrary, four personnel ctated attempts had been made to dissuade them from raising an issue or writing a PlF. Some cf these personnel explained that management's actions suggested that an attemative resolution path should be considered, or that management professionally disagreed that the matter rose to the level of a FIF. Twenty of the specific issues were relevant to this example.
Only seven of these issues were substantiated or partially substantiated. These seven issues include two issues that involve statements made in jest but not taken that way; four issues where management s sted attemative ans of raising issues outside the PIF process; and one incident in which did attempt to dissuade an individual from writing a PIF.
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E 03 2 & 92 17:03 F.R 630 515 1070
'l.S.NRC REGiuN 111 4019 caa The overall evaluation results for this example support a finding that management encourages the reporting of issues through PIFs or other means. Overall, this example could not be validated.
Example No. 6 (98-A-0105)
" Managers confronting individuals and asking and/or accusing the individuals of providing a concem to the NRC."
Approximately 75 personnel were questioned regarding this example. Thirteen personnel claimed that they were aware of instances where management personnel had confronted individuals for raising concems to the NRC. Six of these 13 personnel declined to or could not give details regarding a specific incident. Seven of these 13 personnel provided details of incidents that were pursued. These incidents involved two specific workers and one specific manager, between whom there had been a history of tension. Nine of the specific issues were relevant to this example. Only three of these issues were substantiated or partially substantiated. Of these three issues, one issue deals with the confusion regarding the NRC contact report, which is discussed later; another issue reflects poor management demeanor in response to an employee's indication that he may take an issue to the NRC; and the third issue I
involves management speaking with personnel shortly after they were interviewed by Comed Corporate Security in conjunction with investigation of an issued raised by the NRC.
We have concluded there is no pattern of management attempting to discourage personnel from communicating directly with the NRC. We have taken, and will continue to take, steps to assure the right of all personnel to communicate directly with the NRC.
Example No. 7 (98-A-0105)
" Originators of PIFs are either rebuked or ignored."
Of the 84 personnel who were questioned about this example,17 personnelindicated only a personal perception that they had been rebuked, or provided details of incidents. Several of these incidents were examined as specific incidents and were not substantiated. Of the 45 personnel who were asked whether they had been ignored, six personnel stated that they had been ignored. Most of these personnel equated being ignored to inadequate management response and not retaliation for raising an issue. Among specific issues, over 80 issues were related to this example. Twenty-seven of these issues were substantiated or partially substantiated. The substantiated or partially substantiated issues involved areas such as management demeanor, performance evaluations, personnel issues, negative responses to I
concerns, and management inaction. Most of these specific issues involved the Operations Department.
1 I
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d.U 24/99, 1Y:04. FAX 630"515 1078 L.S..NRC REGIO.N 111 l6020 033 The large volume of specific issues related to this example and the fact that 27 of these issues l
were substantiated or partially substantiated supports a conclusion that some interactions i
between personnel and management have been unnecessarily tense or adversarial. However, I
it was not concluded that management, by design, took action to intentionally discourage employees from raising issues. In fact, the evaluation results suggest that clashes of style and unmet expectations are the likely explanations. Nevertheless, there were some substantiated
' instances of behavior that were unprofessional and did not meet our expectations, thereby validating this example with respect to the Operations Department. In light of the evaluation results, we deem it necessaty to reinforce the principles of professionalism in the workplace within the Operations Department at Byron Station, and to review certain relationships among Byron Station personnel to assure that those principles have not been compromised.
Work Environment (98-A-0105)
Personnel were also questioned as to whether a proper work environment existed at the Byron Station. About 16 percent (i.e.,13 of 79) of the personnelinterviewed felt that the environment was not always conducive to the open raising of issues. This number generally corresponds to the range of responses given for the seven NRC examples discussed above. No incidents other than those covered by the seven examples were provided. Further, the majority view was that this negative environment was not widespread but instead existed in limited number of discrete area's.
Root Cause and Generic Imotications (98-A-0105)
We have concluded that the overall work environment at Byron Station is conducive to the identification of issues. This conclusion is suppoded by the low-threshold, high-volume, PlF process used to track issues at Byron Station. As a result, a determination of root cause and 9eneric implications on this broad issue is not required. There are, however, a number of incidents disclosed during the evaluation which suggest a failure to understand, or a failure to meet, management's expectations in terms of professionalism and the free flow ofinformation.
Failure to preclude incidents resulting from strained relationships has created the impression among a small, but important, minority of workers that less than full openness in identifying issues is acceptable and condoned at Byron Station. It was confirmed that this impression is not widespread at Byron Station, so we conclude that there are no station-wide generic implications. Nevertheless, we have outlined a series of corrective actions designed to deal with any misperceptions that may exist at Byron Station.
It was also found that concems raised regarding implementation of the PIF process (e.g.,
timeliness and adequacy of feedback) accentuated the perception among some workers of a less than open environment. These PlF process deficiencies are attributable to the 4
effectiveness of management's oversight of the PlF process rather than the PlF process itself.
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0L 20/10$ it:04 FAX 630 H 5 n@ M L.S..NRC REGlu.N 111 gogg,033-i Corrective Actions (98-A-0105)
With regard to whether proposed corrective actions are sufficient to address the allegations.
outlined below are the planned corrective actions. While the focus of many of the findings of the investigation is on the Operations Department, these conective actions would apply to the entire Byron Station workforce and address concems substantiated during the evaluation.
These corrective actions include the following.
1.
Continuing training for all supervisors and managers, to include behaviors necessary to create a safety conscious work environment.
2.
Assessing issues substantiated during the evaluation and tailoring corrective actions for each, which may include:
communicating with involved parties; e
counseling; e
removal of derogatory information from personnel files; e
discipline; and e-reassignments.
e 3.
Station-wide dissemination of a summary of the evaluation together with appropriate corrective actions.
4.
Meetings with stakeholders (i.e., personnel interviewed) to review the team's findings in order to underscore the importance of communications and build confidence that we are committed to a safety conscious work environment.
l 5.
Assessing the PlF implementation issues identified during the investigation and taking appropriate corrective actions, such as:
providing a more personal feedback mechanism; e
performing an assessment of the proper threshold for raising concems and e
communication of this threshold; discussion / training regarding how PlF resolution work is assigned, stressing e
that it is not retaliation for raising issues; j
establishment of a mechanism which addresses,'on a timely basis, a PlF j
e originator's dissatisfaction with PlF resolutions; and stressing management expectations for follow-up on identified issues.
e i
NRC Contact Report (98-A-0134)
Personnel were asked whether they were aware of the station contact form which was required i
to be completed when a contact with the NRC was made and whether this form would inhibit them from raising an issue with the NRC. Fifty-three of 57 personnel (93%) indicated that they were aware of the form. In addition, of 51 personnel asked whether this form would inhibit them, eight personnel (16%) answered that it would cause them to hesitate to raise issues with the NRC. Four personnel were not aware that the form existed. Thcretore, the matter was substantiated.
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I One person interviewed understood that the form is not required if one wants to maintain confidentiatity, but did imply that others may be confused. Another person felt that Comed had made a reasonable effort to convey this message but implied that some people may have not
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heard it or may have misinterpreted it. But another person stated his understanding that
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employees were required to complete the contact report "when and if (they] have any discussions with the NRC."
As a result, we have concluded that it is still unclear to some Byron Station personnel that the contact form is not mandated if confidentiality of an NRC contact is desired. The Memorandum to Department Heads," Contact Report Submittal," dated February 28,1997, which was part of the 1997 corrective action to clarify this issue, does not explicitly specify that the contact form need not be completed if individuals wish to confidentially raise issues with the NRC.
Therefore, we will take additional corrective actions to clarify the February 28,1997, Memorandum. These actions include the following.
1.
Issuance of a memorandum to all Byron Station personnel which states unequivocally that if an individual wishes to bring a concem to the NRC, the individual does not have to fill out an NRC contact form.
2.
Revision of Site Policy 100.05, " Policy for Employees Raising Nuclear Safety Concerns," to include the above clarification.
3.
Tailgate meetings with all Byron Station personnel, led by trained managers and supervisors, to discuss this matter.
111.
CONCLUSION:
A thorough and comprehensive evaluation, of the allegations questioning whether the working environment at Byron Station is conducive to the raising of nuclear safety issues, has been conducted. As a result of this evaluation, we have confirmed that overall the personnel at Byron Station have a strong nuclear safety ethic and a serious approach to the performance of their safety-related activities. Management recognizes the value of plant personnelidentifying issues, and those personnel take seriously their obligation to do so. The overwhelming majority of those personnelinterviewed stated that they were not reluctant to raise safety issues, and in fact were assertive in their commitment to raise issues through the variety of options available.
Most preferred the chain of command, but were familiar with the Employee Concems Program, j
and ultimatel the NRC, as being available for this purpose. Therefore, it is concluded that the overall working environment at Byron Station is conducive to the raising of nuclear safety issues.
f We are not satisfied with the instances identified which indicate that a limited number of j
discrete areas of conflict exist among the workforce or that some workers uill do not appreciate management's commitment to nuclear safety, which must include the free flow of safety information throughout the organization. Therefore, we are taking corrective action to assure universal understanding of this principle, and to remediate situations which are incompatib!e with this principle.
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9.i!26/99 16:52 FAX 630 515 1078' U.S.NRc REGION 111 1g 009 s
March 18, 1999
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Mr. Oliver D. Kingsley.
President, Nudear Generation Group Commonwealth Edison Company ATTN: Regulatory Services Executive Towers West lli 1400 Opus Place, Suite 500 Downers Grove,IL 60515
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SUBJECT:
BYRON CHILLING EFFECT CONCERNS
Dear Mr. Kingsley:
In letters dated August 5, and 26,1998, the NRC informed you of multiple examples of actions alleged to have caused a chilling effect (i.e., an environment which is not conducive to raising nuclear safety concems) on Byron Station personnel. These allegations were of particular concem to us because the majority of the examples concemed the Operations Department and because one of the concems related to your station contact forms on which station personnel recorded any contactwith the NRC. This contact form could hinder the wi!!ingness i
of personnel to raise concems to the NRC. The letters requested that you review the concems and provide us with the results of your evaluation.
l The results of your evaluation were provided in a letter'from Byron Site Vice President K. L Graesser to H. Brent Clayton of our staff, dated November 20,1998. Your evaluation report responded to the specific examples described in our letters. Your report indicated that certain examples of chilling effect were substantiated, but that the issues were of only personal perception and that there was no pattem that management intentionally attempted to discourage employees from raising safety concems. Although your staff's overall conclusion stated that the working environment at Byron was conducive to raising nuclear safety issues, the evaluation also indicated that areas of conflict axists among the workforce and management, induding the free flow of safety information.
Subsequently, our teview of your evaluation identified a number of questions regarding your findings and corrective actions. A chilling effect is by its nature a perception that raising safety concems may result in retribution. Therefore, it is unclear why your response concluded that the originators of PlFs being either rebuked or ignored was "only a personal perception." Also, it is unclear why your response distinguished between intentional and unintentional management actions, as that may be irrelevant in individuals' perceptions of those events.
Finally, while your response indicated that relatively few specifics were substantiate'd, it should be recognized that a small number of examples can have a widespread effect.
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"u.g 24/99 161_5LfAX 630 515 1078 U.S.NRC REGION III tg 010 i
E O. Kingsley Per our telephone conference with Mr. William Levis on March 17,1999, we request a further evaluation of the chilling effect at Byron be conducted. During this forthcoming evaluation, we request that you respond to the attached more specific questions conceming the alleged chilling effect at Byron. Upon completion, we would request that your staff present the results of the evaluations and the responses to the attached questions in a public meeting with us.
Please contact Mr. David Hills of my staff at (630) 829-9733 to schedule this meeting.
Sincerely, original /s/ John A. Grobe John A. Grotie, Director Division of Reactor Safety Docket Nos.: 504 54;50-455 License Nos.: NPF-37; NPF-66 l
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05/24/99 16:52 FAX 630 515 1078 l'.S.hRC REGION 111 (g oi l Enclosure Questions Recardina Alleoed Chillina Effect 1.
Explain the basis for the sample size and conclusion that the scope of the problem has
' been identified. Please indude a descripUon of your investigation. For example, the discussion for most examples indicates that the data was gathered through interviews; however, the discussion of some examples could imply the use of some type of survey.
Also, identify the number of individuals questioned or surveyed by department.
2.
The
- Depth of Scope of Evaluation" section stated that the evaluation inquired into individuals' knowledge of the experience of others but the resulting information was not discussed in the response because it tended to be "somewhat speculative, not consistently reliable, and partially ' redundant." Did this information include any common themes or insights related to the issue of safety conscious work environment?
3.
The evaluation of Example No.1 states that about 20 percent of the 90 personnel questioned stated they would hesitate to raise non-safety issues, induding those critical of mariagement dedslons. Twelve of the individuals said they were apprehensive of management's reaction and half of them felt their career would be negatively impacted.
One instance was identified when an individual did not write a Problem identification Form (PlF) for fear of retaliation. Yet the conclusion is that Example No.1 could not be validated. Explain the basis for this condusion.
4.
The discussion of example No. 2 states that nearly 85% responded that draft PIFs are not required to be submitted to supervisors. This would appear to indicate that more than 15% of those surveyed believe that PlFs must be submitted for supervisory i
review. Yet the condusion is that Example No.2 could not be validated. Please explain the basis for this conclusion.
5:
Given the substantial number of individuals (20 percent of the 90 personnel questioned regarding Example No.1) who stated they would hesitate to raise non-safety issues, is Comed concemed that individuals may not raise what they believe to be non-safety issues which really do have a nexus to safety?
6.
The response to Example No. 3 stated approximately 80 personnel were questioned and 43 responded that they would not hesitate to raise a dissenting view. What did the lack of a response from the otherindividuals indicate?
7.
Please explain the basis for the conclusion that Example No. 3 was not validated when 10 percent of the individuals questioned disagreed that management was tolerant of dissenting views and five issues in this area were substantiated.
8.
The discussion of Example No. 5 concluded that it could not be validated. Please explain the basis for this conclusion in light of the statement that seven issues were substantiated or partially substantiated. In particular, there was one instance where a management individual did dissuade an individual from writ]ng a PlF.
n.gm m :6LT3PTE T N~bHE 8078
& 4..WC REG 10.N 111 16 012 9.
The response to Example No. 6 indicated that six individuals 'dedined to or could not" i
provide details regarding instances when managers had confronted individuals for raising concems to the NRC. Did the individuals performing the investigation explore the reasons why some individuals declined to provide more information (i.e., was this
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an indication of fear of retribution?).
10.
The correctiite actions discussed in the attachment are described in a general manner (e.g., "talloring corrective actions for each, which may include," and Making appropriate corrective actions, such as"). In addition, the response to Example No.1 said steps are being taken to reinforce management expectations regarding individuals' responsibility to write PlFs. Please discuss in detail the corrective actions being takeri and the schedule for those actions.
11.
The corrective action section of the response states that actions may include removal I
of derogatory information from personnel files. Was disciplinary action taken against any individual (s) for raising safety concems?
)
12.
We note that the response paragraph titled " Work Environment" says the majority view was that the negative environment was not widespread but existed in a limited number of discrete areas. Please identify those areas and the describe the corrective actions being taken to address the environment in them.
e 9
2