ML20058P257

Package Consisting of Attachments to Employee Concerns Programs

ML20058P257
Person / Time
Site:	Perry
Issue date:	09/07/1993
From:	Kosloff D NRC
To:
References
NUDOCS 9312230175
Download: ML20058P257 (9)

Text

g .

4 Attachment 1 '

[MPl.0YEE CONCERNS PROGRAM: TI 2500/028 PLANT NAME: LICENSEE: DOCKET #:

Perry Cleveland Electric 50-440 >

Illuminating Company A. PROGRAM:

1. Does the licensee have an employee concerns program?

Yes, " Call-for-Quality" ,

2. Has NRC inspected the program? Report # 85087 Yes (See comments)

B. SCOPE:

1. Is it for:

a. Technical? Yes

b. Administrative? Yes

c. Personnel issues? No

2. Does it cover safety as well as non-safety issues? _Yes

3. Is it designed for:

a. Nuclear safety? Yes

b. Personal safety? Yes

c. Personnel issues - including union grievances? No 4 Does the program apply to all licensee cmployees? Yes

5. Contractors? Yes; however, exit interviews are required of all licensee employees but are-not required for contractors.

6. Does the licensee require its contractors and their subs'to have a similar program? Yes-

7. Does the licensee conduct an exit interview upon terminating employees asking if they have any safety concerns? Yes, except contractors ,

1 200085 9312230175 930907 g\

PDR ADOCK 05000440

\

G PDR' D\

!s .

a: ,

N i C. INDEPENDENCE: >

1. What is the title of the person in charge?

Corporate Ombudsman

2. Who do they report to?

Vice President, Nuclear Group

3. Are they indepencent of line management?

Yes

4. Does the ECP use third party consultants?

No '

5. How is a concern about a manager or vice president followed up? 2 The VP, Nuclear, follows up on any concern about a manager. The Ombudsman would go to the president-of CENTERIOR (parent company) for guidance on any VP concern. ,

1 D. RESOURCES:

1. What is the size of staff devoted to this program?-

None. The Ombudsman receives all concerns and coordinates followup using Quality Assurance staff. )

2. What are ECP staff qualifications (technical training,  ;

interviewing training, investigator training, other)?  !

Standard QA inspector.or Lead QA auditor qualifications.

E. REFERRALS:

1. Who has followup on concerns (ECP staff, line management,. i other)?

Quality Assurance staff.

F. CONFIDENTIALIlY:

1. Are the reports confidential? ,

.i Yes 2

-l

f.

2,

2. Who is the identity of the alleger made known to (Senior management, ECP staff,.line management, other)?

Ombudsman or his designated alternate.

3. Can employees be:

a. Anonymous? Yes

b. Report by phone? Yes G. FEEDBACK:

1. Is feedback given to the alleger upon completion of the followup? Yes, by letter sent through the U.S. Mail.

2. Does program reward. good ideas? No, the licensee has another program for that.

3. Who, or at what level, makes the final decision of resolution?

Ombudsman

4. Are the resolutions of anonymous concerns disseminated?

No

5. Are resolutions of valid concerns publicized (newsletter, bulletin board, all hands meeting, other)?

No H. EFFECTIVENESS:

1. How does the licensee measure the effectiveness of the program?

By the number of concerns that go to the NRC and by the ratio of concerns self-identified by the plant staff to concerns identified by oversight organizations.

2. Are. concerns:

a. -Trended? No

b. Used? Yes, to look for widespread or generic problems.

3

i

3. In the last three years how many concerns were raised?

22* Of the concerns raised, how many were closed? 4 What percentage were substantiated? unknown.

The licensee does not keep a record of the number or percentage of substantiated concerns. Each individual record of a concern states if the concern was substantiated.

• 1991: 2; 1992: 4; 1993: 16, as of September 8,1993

4. How are followup techniques used to measure effectiveness (random survey, interviews, other)? ,

Generally, a second review is conducted using quality assurance techniques (interviews, document reviews, observing work in progress) dependent on the subject' of the concern. .

5. How frequently are internal audits of the ECP conducted and

• by whom?

No regular audits. Audited once in September _1986.

1. ADMINISTRATION / TRAINING:

1. Is ECP prescribed by a procedure?

Yes

2. How are employees, as well as contractors, made aware of this program (training, newsletter, bulletin board, other)?

Initial general employee training (access training),

periodic. newsletter, and poste.rs in the plant. <

ADDITIONAL COMMENTS: [

Comment on Item A.2.: The program was reviewed by the NRC in July or ,

August of 1985. This was documented on August 21, 1985, in a memo from i the SRI to his section chief but was not documented in an inspection t report. A licensee memo dated May 27, 1986, indicates that there were-additional NRC reviews of concerns addressed by the program, including  !

allegations closed in Inspection Report 86007. Attachments to e Inspection Report 86007 include references to the licensee's program and- 1 letters written by the Ombudsman.

l' NAME: TITLE: PHONE #: DATE COMPLETED:

Don Kosloff/Sr. Resident Insnector/216/259-3610 09/07/93  ;

i 4

' fy22h y

tgi t 9 393 -

s L

Docket No. 50-440 Centerior Service Company ATTN: Mr. R. A. Stratman Vice President Nuclear - Perry c/o The Cleveiand Electric illuminating .

Company 10 Center Road  :

Perry, OH 44081 1

i

Dear Mr. Stratman:

1 This refers to the inspection conducted by Mrs. S. Burgess and Messrs. A. Vegel and D. Kosloff of this office, on July 30 through- ,

September 13, 1993. The inspection included a review of activities ~

authorized for your Perry Nuclear Power Plant, Unit 1, facility. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed _ report.

Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress, f

Based on the results of this inspection, certain of your activities appeared to be in violation of NRC requirements, as specified in the enclosed Notice of Violation (Notice). The violation indicated weaknesses in management 1 oversight of scaffold activities and the questioning attitude of maintenance and operations personnel. Weaknesses concerning the questioning attitude of plant personnel has been identified previously. i You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this 'i Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement' action is  ;

necessary to ensure compliance with NRC regulatory requirements.

-i

' You are also requested to address in your response to the Notice any specific actions you have taken or plan to take to address the weaknesses discussed d above. '

I L During this inspection, certain other of your activities appeared. to be in L violation of NRC requirements. However, as described in the enclosed l' inspection report, you identified the violation. Therefore, the violation will 'not be subject to enforcement action because your ef forts in identifying

t OCT 0 81993 Y

i Centerior Service Company 2 r

and correcting the violation meet the criteria specified in Section VII.B of  :

the " General Statement of Policy and Procedures for NRC Enforcement Actions,"'  !

(Enforcement _ Policy, 10 CFR Part 2, Appendix C). As noted in the enclosed inspection report, additional attention is needed in the areas of maintenance- 3 planning and compliance with equipment tagging procedures.

In accordance with 10 CFR 2.790 of tne Commission's regulations, a- copy of  :

this letter, the enclosures, and your responses to this letter will be placed '

in the NRC Public Document Room. .

The responses directed.by this letter and the accompanying Notice are not. l subject to the clearance procedures of the Office of Management and-Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

We will gladly discuss any questions you have concerning this inspection.

Sincerely, t "C1:cn1c'enedbyL.f.cra,_

L. R. Greger, Chief i Reactor Projects Branch 3

Enclosures:

1. Notice of Violation

2. Inspection Report No. 50-440/93016(DRP) j' See Attached Distribution i

f f

a

[

l t

RIII RI I Rill R111 k*Y A  ;[p CCC 4, Lanhsbury BBurgess Olteanu .g,e r -

IGMib lan 4' if hyf  ;

ac.1b=V 1 f is 9esd 6.Osio $ l I

i

a: ,

DCT 0 81993 - ,

.i f

Centerior Service Company 3 ,

t Distribution cc w/ enclosures: }

R. W. Schrauder, Director, Nuclear .i Support Department D. P. Igyarto, General Manager, .

Perry Nuclear Power Plant '

K. P. Donovan, Manager,  !

Licensing.and Compliance Section  ;

N. L. Bonner, Director, Perry ,

Nuclear Engineering Dept. .

H. Ray Caldwell, General >

Superintendent Nuclear Operations Resident Inspector, RIII Terry J. Lodge, Esq. t State of Ohio State Liason Officer '

Robert E. Owen, Ohio Department of Health A. Grandjean, State of Ohio  :

t Public Utilities Commission OC/LFDCB Licensing Project Manager, NRR Technical Support Section, RIII bcc: PUBLIC l

v - , - +-

-. . . l l

,- .i i

1 1:

{

NOTICE OF VIOLATION -

t Centerior Service Company Docket No. 50-440 L_ Perry Nuclear Power Plant License No. NPF-58 i

During an NRC inspection conducted on July 30 through September 13, 1993, a violation of NRC requirements was identified. In accordance with the " General t L

Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:  ;

Technical Specification 6.8.1.a requires that written pfocedures be-established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, November 1972. i Appendix A of Regulatory Guide 1.33 states.that maintenance which can af fect the performance of safety-related equipment should be performed in accordance with written procedures or documented instructions ,

appropriate to the circumstances. Erection of scaffolds near safety-  ;

i related equipment is maintenance which could affect the performance of '

safety-related equipment.

I >

l Procedure GCI-0016, Scaffolding Erection Guidelines, controls the erection of scaffolding. GCI-0016, Section 3.2.1, requires, in part,- -l that scaffolding shall not be connected to or be in contact with any  ;

equipment unless provided for in Subsection 5.2. Subsection 5.2.5 ,

requires a clearance of three inches from all safety-related equipment j j unless approved by the Perry Nuclear Engineering Department. In i addition, Section 7.0 requires, in part, that the work supervisor j initial and date the scaffolding Equipment Identification Tag, and  !

annotate the tag to indicate that the scaffold was inspected and was in .j compliance with GCI-0016.

]

Contrary to the above: r l

A. On August 31, 1993, scaf folding was found attached to the low pressure core spray instrument rack that had not been approved by the Perry Nuclear Engineering Department.

B. On September 9,1993, scaffolding was found installed near the low i i

pressure core spray instrumentation rack and in the Division I and  :

Division III Emergency Diesel Generator rooms that did not have i

Equipment Identification Tags annotated to indicate that a work  !

supervisor inspection had been conducted to verify that the scaf folding was in compliance with GCI-0016. 1, This is. a Severity Level IV violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Centerior Service Company is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,  ;

O.C. 20555 with a copy to the U.S. Nuclear Regulatory Commission. Region 11I, 1 799 Roosevelt Road, Glen Ellyn, Illinois 60137, and a copy to the NRC Resident i Inspector at the Perry Nuclear Power Plant within 30 days of the date Notice  !

i

n i

I l Notice of Violation 2 '

l of the letter transmitting this Notice of Violation (Notice). This reply i should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or if contested, the basis for disputing the violation, (2) the corrective steps i that have been taken and the results achieved, (3) the corrective steps that w111 be taken to avoic further violations, and (4) the date when full  ;

compliance will be achieved. If an adequate reply is not received within the ,

l ti.me specifiec in this Notice, an order or a demand may be issued as to why

• the license should not be modified, suspended, or revoked, or why such other '

actior as may be proper should not be taken. Where good cause is shown,  ;

consideration will be given to extending the response time, i

Dated at Glen Ellyn, Illinois this 79 day of October 1993 4

b t

7 4

i