ML20217H397
| ML20217H397 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/07/1997 |
| From: | Bajestani M TENNESSEE VALLEY AUTHORITY |
| To: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 9710150245 | |
| Download: ML20217H397 (6) | |
Text
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Tennessee Vaney Authority, Post Offee Box 2000, Soddy Dasy Tennessee 37379-2000 Masoud Bajestani Sde Vce Presdont "wh Nuclear Fiant October 7, 1997 Mr. Luis A. Reyes, Regional Administrator U. S. Nuclear R;gulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 l
Atlanta, Georgia 30303 Attention:
Mr. Luis Reyes:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUC. LEAR PLANT (SQN) - SAFETY CONSCIOUS WORK ENVIRONMENT (NRC OFFICE OF INVESTIGATIONS REPORT NO. 2-97-001)
This letter and its enclosure respond to your letter dated September 8, 1997, concerning an investigation recently concluded by NRC's Off,1ce of Investigations (OI) which consisted of a review of a TVA Office of Inspector General (OIG) Report of Administrative Inquiry (File No. 2D-160).
The investigation concluded that a TVA manager made statements which created a chilling effect on at_least two persons present in a meeting at the Sequoyah Nuclear Plant (SQN) in April 1995.
In accordance with standard practice, and at the request of TVA Nuclear,-TVA's OIG investigated the circumstances surrounding the meeting in question and other matters associated with a Department of Labor complaint.
The OIG did not substantiate the complainant's allegations of discrimination for raising safety concerns; however, the OIG did find that a manager made inappropriate statements in violation of TVA policy.
Upon receipt of the OIG's report, TVA Nuclear took corrective actions to address the manager's statements _and to assess their impact on the work environment within that manager's organization and the SON site.
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9710150245 971(37 PDR ADOCK 05000327 lll l l l
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Mr. Luis A. Reyes i
Page 2 October 7, 1997 TVA is critically aware of the importance of maintaining a viable safety-conscious work environment where all employees feel free to raise concerns.
We place a high priority on maintrining open lines of communication to ensure the prompt identification and resolution of problems, and we recognize that the continued success of our nucicar program depends upon our succeeding in this l
l area.
The enclosure to this letter describes in detail tho l
actions that were taken that address the NRC's concerns regarding the manager's statements and their potential chilling effect on the work environment.
Any questions may be directed to me at (423) 843-7001 or Pedro Salas at (423) 843-7170, o
Masou c-ani Vice rasident Sequ y h Nuclear Plant Sworn to and subscribed before me this,/'
day of A//JA,k) _,
1997 Yhedr) $ b/ hun Notary Public
- 4' My commission expires ff/f////
Enclosure cc (Enclosure):
Mr.
R. W. Hernan, Project Manager U.S. Nuclear Regulatory Commission one White Flint, North 11555 Rockville Pike Rockville, Maryland 20052-2739 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C. 20555
ENCLOSURE TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)
SAFETY CONSCIOUS WORK ENVIRONMENT RESPONSE TO NRC OI REPORT NO. 2-97-001
)
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l Corrective Actions Involving the Manager to Address the Manager's Statements Upon completion of the TVA Of fice of Inspector General's (OIG) investigation of the meeting.in question and receipt of OIG's Report of Administrative Inquiry, the Sequoyah Nuclear Plant (SON) Vice President took individual corrective action to address the inappropriateness of the manager's statements.
Specifically, the manager was counseled by the SON Vice President about TVAN policies and expectations regarding maintaining a work environment of open and free employee communications, the need to be aware and sensitive to personal remarks made about any particular employee, and about how such remarks may be interproted by employees in a manner which could create a negative-atmosphere in the organization.
The SON Vice President also issued a memorandum to the manager documenting and reaffirming the points raised during the counseling session.
f In addition to the cou'nseling session and follow-up memorandum, the SON Vice President placed a restriction on the manager's ability to take any personnel actions until further notice.
Durinn such time, no personnel action can be undertaken by the manager unless and until that action is reviewed by a higher level of management.
Subsequent to making the inappropriate statements, the manager attended a four-hour executive training session l
which addressed TVAN personnel policies and procedures, L
including TVA's policy regarding expression of concerns and differing views.
This course uses an experiential learning
- approach through the use of case studies and discussion, and stresses the importance of maintaining an environment which encourages employees to raise safety concerns.
The course also provides written material covering TVAN's policy against intimidation and harassment.
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.E2 The NRC's letter of September 8, 1997, made specific reference to a separate investigation regarding unrelated statements made by the same manager, described in footnote 1 of the OIG's Report of Administrative Inquiry (File M.20-160).
TVA's OIG has completed this investigation and issued a report on March 11, 1997 (File No. BG-84).
That report concluded that the manager's comments did not support a finding of misconduct.
However, in part because of the concerns raised in this investigation relative to the expression of staff views and because of similar concerns raised in an OIG Special Project Report of February 1997, the substance of which is discussed below, a
the OIG conducted a special follow-up assessment.
This special assessment was described _in an April 4, 1997 -
j Special Project Report and is also discussed in further detail below.
Corrective Actions to Address Any Potential Chilling Effect Associated with-the Manager's statements Beyond taking-the individual corrective actions as discussed above, TVA is keenly aware of the importance of-assessing the potential chilling effect that the manager's inappropriate statements may have had on those hearing or those hearing about such statements.
Other than the manager, there were three direct participants in the April 1995 meeting.
The meeting was being held to address the interests of represented employees within the manager's organization, and two of the participants were union
- representatives who regarded certain of the manager's statements as inapprop'riate.
To address any potential chilling effect that these statements may have had on these two individuals, the SON Vice President has met separately with both to reinforce the fact that SQN management -
regarded the manager's remarks as inappropriate, and that the manager was counseled for making such remarks.
The SQN Vice President also-reinforced TVA's policy regarding each employee's right to express differing views without fear of intimidation or harassment, and gave them the clear message that neither they nor any employee should feel any reluctance whatsoever about raising problems or concerns with TVA management at any level,=with TVA's OIG, or the NRC.
TVA did cot limit its actions to the individual meeting
-participants.
As TVA has previously explained to the NRC, TVA uses several measures to monitor the TVA Nuclear work environmer.t as a means of ensuring.that all-employees feel free to dircuss problems and concerns with management.
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.E3 principal measure is the employee survey conducted by TVA's OIG as part of its periodic audit and review of TVA Nuclear's Concerns Resolution Program.
These independent reviews cover TVA Nuclear corporate offices and each of the nuclear sites, examining a randomly selected, statistically valid, population of TVA and contractor employees.
Subsequent to the April 1995 meeting at SON in which the inappropriate statements were made, several OIG employee l
surveys have been conducted at SQN which continue to show that employees feel comfortable about expressing nuclear safety concerns to SQN management.
4 In November 1995, the OIG completed a sample survey at SON designed to provide 95 percent confidence that the survey results would be within 5 percent of the total population results.
The survey included both TVA employees and contractors.
In its Special Report dated January 1996, the OIG stated that "the overwhelming majority of employees and contractors felt free to report nuclear safety or quality problems at SON."
Specifically, 99 percent of employees and contractors interviewed said they would report a problem, if they knew of one, through their supervisor.
Of those interviewed who had actually reported a problem to their supervisor, all said they would do so again.
In December 1996, the OIG completed a sample survey at SQN designed to provide 98 percent confidence that the survey results would be within 5 percent of the total population results.
Once again, the survey included both TVA employees and ccatractors.
In its Special Project Report dated February 1997, the OIG found that its survey results were consistent with previous surveys, and stated the same conclusion that "the overwhelming majority of employees and contractors felt free to report nuclear safety or quality concerns."
Specifically, 98.4 percent of employees and contractors interviewed said they would report a problem, if they knew of one, through some avenue.
The employee's and the contractor's immediate supervisor was the overwhelming first choice for reporting concerns.
Of those interviewed who had actually reported a problem to their supervisor, only 2.7 percent said they would not report again under-similar circumstances.
The-OIG's Special Project Report of February 1997 noted one deviation f rom the prior year's survey in the additional information that the respondents volunteered to expand or explain their interview answers.
The difference was in comments related to " downsizing" and their link to problems associated with employee morale-and opportunities for
.E4-management to remove employees who express differing staff views.
As a result, the OIG conducted a special follow-up assessment targeting three work groups at SON where more than one employee expressed a reluctance to engage in open communications with their supervision or higher management.
At the same time, the OIG performed an assessment of an additional SQN work group to determine whether a recent adverse Department of Labor ruling involving a former member of that group had a chilling effect on its employees.
(The ruling did not involve the subject manager or the April 1995 meeting.)
Two of the four work _ groups which were included in this OIG sped al assessment are overseen by the subject manager.
The OIG reported its results in a Special Project Report d6ted April 4, 1997 In this April 4, 1997 Special Project Report, the OIG found that each of the four target group's responses were generally as positive as the overall plant with regard to reporting nuclear uafety and quality issues to management.
Within all four groups, 100 percent of those interviewed said that they would report a nuclear safety or quality problem to their supervisor.
However, one of the two work l
groups overseen by the subject manager indicated some mixed responses to other work environment-related questions, most notably among lower grade employees who did not enunciate 1
group goals and standards in the same positive terms as upper grade employees.
The OIG opined that a lack of confidence and-trust in management expressed by some within this group could be linked to lack of clear communication through the layers of management within the group regarding
-performance standards and group objectives.
In addition to this OIG special assessment, in December 1996 the SON Plant Manager requested that RHR International Company perform another independent review of the work groups overseen by the subject manager.
RHR was asked to assess the overall health of these groups by virtue of their willingness to raise problems or concerns, and to assess the effectiveness of the' groups' leadership.
RHR interviewed 39 percent of the employees within these groups and arrived at similar conclusions about the same group which indicated some mixed responses in the OIG's special assessment..
Specifically, RHR found a problem in communication upward and downward within the group,.a climate f uncertainty about future job security, and concern
~ut how errors they make may influence decisions about thee future.
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Though_the TVA OIG and RHR findings with respect to this particular group did not find a problem in the employees' willingness to raise safety or quality issues to management, the OIG special assessment and RHR reviews did indicate a need for increased communication within the group and greater trust in the group's leadership.
Accordingly, the SON Site Vice President has directed the l
subject manager to develop a near-term group communication and change management plan to include regularly scheduled forums for communication among the mar. agers and staf f.
The plan must also identify means by which managers will reinforce and reward the early and proactive identification of issues and concerns within the group.
This communication and change management plan has been be submitted to and approved by the SQN Vice President, and its progress will be monitored by the SON Vice President on a regular basis.
Finally, though.not in particular response to the TVA OIG's investigation of the subject meeting and its potential chilling ef fect, TVA's recently appointed SON Vice President issued a memorandum to SON employees and l
contractors on August 20, 1997, which reinforced TVA's policy that intimidation, harassment, discrimination, or retaliation for identifying problems or expressing concerns would not be tolerated.
The message was clear and unambiguous, stressing the link between continued improved performance at SON and the ability to identify, evaluate, and correct problems.
The memorandum reads, in part, as follows:
It_is extremely important that we all continue to communicate openly, freely, and accurately.
I-place a high level of emphasis on resolving all
. problems, especially those related to the safe and reliable operation of-Sequoyah.
I encourage employees to resolve their concerns with line-supervision, up to and including me, if necessary.
Supervisors are responsible for listening, objectively evaluating,_and taking
-prompt action-to resolve problems and concerns.
In addition,- TVA Nuclear's' Concerns Resolution Staff:and contractor Employee Concern Programs provide an alternate avenue _for_ reporting concerns outside the' normal supervisory process.
As.always, employees may report concerns to the TVA Office of Inspector General and=the Nuclear Regulatory Commission.
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