ML20217D431
| ML20217D431 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/26/1997 |
| From: | Nunn D SOUTHERN CALIFORNIA EDISON CO. |
| To: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| NUDOCS 9710030183 | |
| Download: ML20217D431 (29) | |
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Dwight E. Nunn Vice President h whoh m$RMITIONAL Company
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Mr. E. W. Marschoff, Regional Adminirtrator
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U. S. Nuclear Regulatory Commission, Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064
Dear Mr. Merschoff:
Subject:
. Docket Nos. 50-361, 50-362 Response to Questions from Meeting of August 1997, Commitment to a Safety Conscious Work Environment, and Transmittal of Meeting Handouts San Onofre Nuclear C9nerating Station, Units 2 and 3 Referance; Notice c.? Licensee Meeting, dated July 15,1997 Meeting Date: August 4,1997 Meeting Pur 3scuss the Employee Concerns Meeting In a September 1996, meeting with the Nuclear Regulatory Commission (NRC),
Southern California Edison (SCE) dircussed its analysis and understancing of AEOD Report 96-02, which identi5ed San Onofre as having a disproportionately large I
number of allegatica.s, and informed the NRC of its intention to perform a Nuclear
- Safety Culture Assessment. At the referenced meeting, SCE provided the results of the Assessment, which was cenducted in late 1996, and additional infonnation on the steps SCE has taken to rrn.intain and assess a Safety Conscious Work Environment at San Onofre.
The purpose of this letter is to provide answers to questions asked during the Inseting, to restate SCE's commitment to a Safety Conscious Work enviromnent, and to transmit the handouts used.
- Attachment 1 to this correspondence is the handout distnbuted at the referenced U'
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3eyta..mber 26,1997 i
At the meeting, several questions were asked concendng the cone.usion reached by the independent consultant conducting the assessment, which strates:
" SYNERGY concluded that SCE has embuhed a strong nuclear safety culture (NSC) at SONGS and that there is a continuing positive trend. The SONGS nuclear safety culture ranks at the medisn of the twenty plants recently surveyed by SYNERGY.
The survey results indicate that a positive nuclear safety culture exists and that workers are willing to bring ibtward safety concerns."
9 Specifically:
1.
Which plants were represented in the surveyed plants?
Surveyed plants included: Susquehanna, Harris, Byron, Grand Gulf, Maine Yankee, Grand Gulf, Palo Verde, Brunswick, STP, Robinson, Braidwood,-
Riverbend, Fitzpatrick, Indian Point 3, Zion, Waterford, Dresden, Quad Cities, La Salle, Crystal River 3, 2.
WMeh of those plants surveyed, using the methods of the consultant, would hs u ost similar to San Onofre Nuclear Safety Culture, i.e. plants near the med:an?
To answer questions like question 2, the consultant has developed a composite Nuclear Safety Culture measure. The composite measure is a weighted average of the response to certain questions' that are asked at every plant surveyed (see page 15 of Attachment 1 for some of the questions considered). The consultant has identified an empirical correlation
- between the composite measure for plants surveyed between 1994 aim 1996 and the SALP score applicable at the time of the -
survey (see Figure 1),-
In the opinion of the consultant, and based on our own analysis, San Onofre is most similar to other surveyed plants with SALP scores of 1.5 or 1.25 and with a composite measure of about 3.6 (see box on Figure 1).
The scale used for responses to questicas about the safety culture is:
1.0 = Strongly Disagree. 2.0 = Disagree. 3.0 = Generally Agree,4.0 = Strongly Agree. 5.0 = Fully Agree -
Thus. San Onofre's cornposite score of 3.50 would indicate an opinion between " Generally Agree and Strongly Agree" when responding to a question calling for a positive (> 2.0) opinion on the Nuclear Satety Culturei 2
A linear least squares fit with a coefficient of detettnination. R* of.79
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M.. E. W. Merschoff 3
September 20,1997 Figure 1, Relationship of SALP Score with Synergy Composite Nuclear Safety Culture Measure 1994-1996 4 00 t
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o 2 40 2.20 2.00 1 00 1 50 2 00 2.50 3 00 SALP Score, at time Of survey Composite, Other Plante Correishon a Compoone, San Onoke As stated at the meeting, SCE has established and is committed to maintaining, by its policies, programs, and actions, a Safety Conscious Work Environment at San Onofre. SCE will also continue to measure and assess its Nuclear Safety Culture, including the Safety Conscious Work Environment, and act on the results of such assessments.
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Mr. E. W..Morschoff 4
September 26,1997 Should you have any further questions on the results of the survey, or our measures to establish, maintain and assess a Safety Conscious Work Environment, please do not hesitate to call.
Sincerely,
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I Dwigh1/E. Nunn Vice President Engineering a.?d Technical Services Attachment ec:
D. F. Kirsch, Chief, Reactor Projects Branch F, NRC Region IV E. T. Baker, NRR Agency Allegations Advisor R. Wise, Allegations Coordinator, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 v'NRC Document Control Desk
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The Safety Conscious Work Environment r
Self-Assessments and Independent Assessments of the Work Envircament l
f Industry Comparison
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Safety Conscious Work Environment o Workers are provided training, re-training, videos, periodic reminders, etc.,
concerning SONGS expectations on raising issues and the safety conscious work environment j
o Workers are encouraged to raise issues at a low threshold o Four Paths
- Action Requests (~2,000 per month)
- Supervision
- Employee Concerns Program i
-The NRC 1
o Workers use all paths - with a low threshold 0 Prompt and responsive feedback provided
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1 o Promulgate policy against retaliation
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o Few workers express concerns about retaliation o Allegations of retaliation are forcefully, promptly, and effectively investigated 4
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Nuclear Safety Concerns Program In place since early 1980's
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Available to all workers
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Responds to all types of technical issues and H&l issues relating
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to protected activity Provides general training / coaching for supentision/ worker Provides specific training as required i
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-In 1996-7 provided special 1/2 day training to supervisors (300) and workers (350) in specific work groups Concerns received via drop boxes,800 number, email, US Mail,
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walk in Reports to Oversight Manager Staff-6 specialists and 1 manager
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90-120 concerns per year 5
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Self Assessments - NSC Program
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t Monitoring of program performance Analysis of NSCs by type, origin, anonymous /not anonymous, work
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Program Effectiveness Assessments
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i Customer Survey Inter-utility audits Internal audits Employee surveys DOL cases l
Concerns and Allegations History 50 --
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. + Nuclear Safety Concerns EEB NRC Allegations (Annual Count /4) E NRC Allegations (Quarterly Count) 8
Analysis of Concerns by Origin and Nature of the Concern 0
O u arte rty A pp or.
2nd T otals b y Av e rage fo r 1 st Q un rter Quarter O ra a n tr ation o r S u b jec t 1994 1995 1996 1996 1997 1997 T rend W ork G ro up A 5
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_L T a b le ta ole s (1 l S o m e c o n c e en s in wo tve b oth tec h n ic al a n d it S I iss u e s 9
Self Assessments - NRC Allegations
= Analysis by
- Anonymous /not anonymous t
- Fraction of H&l issues
- Substantiated /not substantiated
- Other criteria NRC Allegations at SONGS 1996/First Quarter 1997/Second Quarter 1997 Technical H&l Total Substantiated Employee 10/5/5 3/2/0 13/7/5 4/1/0 Cintractor 1/0/2 0/0/0 1/0/2 1/0/0 Private Citizen 5/2/2 0/0/0 5/2/2 0/0/0 Lice nsee 1/0/0 0/0/0 1/0/0 0/0/0 Anonymous NA/1/1 NA/0/0 NA/1/1 NA/0/0 Other 7/1/0 0/0/0 7/1/0 2/0/0 To tal*
24/9/10 3/2/0 27/11/10 6/1/0 Note: In correspondence dated May 6,1997 responding to allegation RIV-97-A-0005 Edison requested that four allegations (RIV-97-A-C305, RIV-96-A-0215 and two 1995 allegations) not be considered in the allegation count..The NRC responded on June 4,1997.
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NRC Inspection, R. Huey 5/97 Observations
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- Comprehensive and well-functioning employee concerns program
- Positive feedback from submitters
- Program self-assessment well focused and contributes to program performance
- Effective peer assessment
. Good process for periodic reporting of performance, trends, and corrective actions Findings / Actions l
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- Provide written feedback on issues at start
- Modify feedback timeliness criteria l
- Address all aspects of allissues
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-ldentify/ trend reason for not writing AR/ going to supervisor 12 L
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Independent Consultant
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Method - Nuclear Safety Culture model with five dimensions
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- 1. Values & priorities
- 2. Behaviors
- 3. Practices & performance
- 4. Environment for pursuing nuclear safety concerns
- 5. Employee concerns process i
Process - Develop questions to measure culture against the model
- Interviews
- 95 questions of three types, numeric response (1-5)
-4 open ended questions f
13
Results Response 12/96 43 %,801 1100 written comments i
Findings Strong and improving safety culture Workers willing to come forward with safety issues Environment supportive of raising issues Safety priorities have been effectively communicated i
Workers show self-critical, questioning attitudes Overall positive opinions on key safety processes Strong confidence in NSC Program T
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Industry Comparison 4.5 0 --
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SYNERGY concluded that SCE has established a strong nuclear safety culture (NSC) at SONGS and that there is a continuing positive trend. The SONGS nuclear safety culture ranks at the median of the twenty plants recently surveyed by SYNERGY. The survey results indicate that a positive nuclear safety culiure exists and that workers are willing to bring forward safety concems."
15 i
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Survey Actions i
Communicate the high value the organization assigns to those who identify o
issues i
Continue to re-state priorities o
Address bargaining unit issues o
Analyze and address pockets and work group issues l
o Monitor AR program effectiveness, continue improvements 0
Publicize NSC Program value and results
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Communicate expectations and results from self-assessment and industry
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Follow-up Survey 1998 16
General Work Environment Assessment-High fraction of workers:
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Are quality conscious Accept accountability for their performance General culture less positive than nuclear safety culture, but
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improvina No direct relationship to Nuclear Safety Culture
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Management Actions
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Communicate information on the outlook for SONGS and employment at SONGS l
More communication, by more paths Develop the supervisory path for communication
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= Emphasize value of workers to the organization
= ingrease training and development 18
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I Industry Comparison - Raw All@gation Numbers Raw Numbers:
= AEOD Report 96-02, " Annual Report of the Status of NRC's l
Allegation Program," SECY 97-006 1
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= SONGS relatively large or " disproportionate" number of allegations Observations
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-Training encourages workers to raise issues by any path with a j
low threshold
- Data not adjusted for site population
- H&l allegations not " disproportionate" l
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- Substantiated allegations not a large fraction
- Specific developments at SONGS
. Competition in California
. Labor negotiations l
. Voluntary Retirement / Severance 20 i
e Industry Comparison - Raw Allegation I
Numbers (continued) i Analysis
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- Raw allegation numbers receive attention from senior management i
- Information on raw allegation numbers reviewed thoroughly l
- SONGS considers raw numbers as only one factor in assessing a safety l
conscious work environment i
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Industry Comparison Benchmarking to Other Programs
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- South Texas Project, Palo Verde, WNP-2 i
1 Review of Industry Events and Lessons Learned - Millstone l
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i Review of inspection reports, draft policies, draft regulations,
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NOVs, DOL cases, SECY reports, other NRC reports, etc.
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Participation in Industry Groups l
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t DOL History
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i Enforcement History 22 l
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Basis for Overall Assessm'ent of Safety.
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Conscious Work Environment NSC Program Analysis o
NRC Allegation Analysis and Raw Numbers o
NRC inspections Results o
Independent Survey Results o
Industry Comparison o
Trends from Other Site Programs o
' Employee Survey Results o
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CONCLUSIONS SONGS has a safety conscious work environment
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SONGS pro-actively assesses the work environment and takes action where required Independent measures of the safety culture confirm the safety conscious
=
work environment i
Management pays continuing attention to allegations, allegation numbers,
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employee concems, resolution of concems, the willingness of workers to come forward, and other aspects of a safety conscious work environment 4
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