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CARD 18-27984
May 9, 2019
SUBJECT: FERMI POWER PLANT, UNIT 2—NRC INTEGRATED INSPECTION REPORT 05000341/2019001
On October 8, 2018, a plant employee generated condition assessment resolution document (CARD) 18-27984, which detailed a potential safety conscious work environment (SCWE) issue where an AECOM contractor working at the plant stated he was told that he would be laid off if he wrote a CARD. In response to the issue, the licensee initiated various actions that included, but were not limited to:
• On October 10, 2018, the licensee convened an emergent Nuclear Safety Culture Monitoring Panel (NSCMP) meeting to discuss the concerns outlined in CARD 18-27984 and to ensure that the proper investigation, actions, and communications were being conducted. • The Plant Manager held numerous meetings with AECOM and licensee craft employees at the plant to reinforce the importance of raising nuclear safety concerns and to emphasize the importance of a healthy SCWE. • The Employee Concerns Program (ECP) Coordinator conducted an investigation into the incident and performed an assessment of the nuclear safety culture at the plant, specifically focused on the AECOM contractor workforce. • The licensee performed a study of the number and types of CARDs initiated by the AECOM organization to confirm CARDs were being generated and that issues were being documented. • The Chief Nuclear Officer (CNO) discussed the licensee’s expectation in the area of problem identification with AECOM senior management.
On January 18, 2019, the inspectors completed a review of the actions taken by the licensee associated with CARD 18-27984.
The inspectors interviewed the ECP Coordinator and reviewed documents pertaining to the investigation of the events surrounding the CARD, which included written statements from individuals at the scene when the comment in question was made. The inspectors also reviewed ECP records and performed a corrective action program (CAP) document search for issues relevant to SCWE for the previous 3 months leading up to the inspection. In addition, the inspectors reviewed CARD initiation data from previous refueling outages at the plant and compared them to RFO 19 when CARD 18-27984 was written.
The inspectors reviewed training material provided to new employees arriving at the plant to ensure that all personnel, particularly supplemental personnel brought in for refueling outages, were made aware of their responsibilities for raising nuclear safety concerns and the licensee’s expectation for maintaining a healthy SCWE.
The inspectors conducted one focus group, consisting of seven AECOM craft personnel, and five individual interviews, comprised of three AECOM craft personnel and two AECOM supervisors, to assess the SCWE fostered by AECOM. Additionally, the inspectors interviewed the Plant Manager and CNO regarding the actions taken in response to CARD 18-27984 and discussed any feedback that they received concerning those actions.
Overall, the inspectors did not identify an environment where AECOM craft personnel at the plant were reluctant to raise nuclear safety concerns for fear of retaliation. During the inspection, all of the individuals that participated in the focus group and interviews stated that they did not fear raising nuclear safety concerns and, in general, felt supported by their supervisors to do so. None of the individuals who were interviewed identified with the comment
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made by the individual in CARD 18-27984 stating that they would be fired for writing a CARD. None of the individuals interviewed had witnessed or heard of anyone in their organization being told not to write a CARD or being retaliated against for writing a CARD. Pertaining to the ECP Coordinator’s investigation into CARD 18-27984, given the information that was available, the inspectors concluded that the investigation was reasonable in depth and scope and was sufficiently thorough to conclude that there was not a SCWE issue within the craft in the AECOM organization.
The inspectors did not identify any additional issues pertaining to SCWE in their record review of the ECP and CAP. The inspectors noted that the rate of CARD generation for contractors during the outage was consistent with previous outages indicating that conditions adverse to quality were being identified and documented in the CAP by AECOM personnel at an expected level. Additionally, the inspectors did not identify any issues with the content of the training provided to new plant employees concerning their responsibilities for raising nuclear safety concerns or the licensee’s expectation for maintaining a healthy SCWE.
The inspectors provided observations from the inspection to licensee management regarding opportunities for improving the knowledge retention of SCWE training received by new employees being processed into the plant as well as opportunities for licensee management to raise the level of understanding among the craft on how the CAP system functions to address issues. These observations were documented by the licensee in CARD 19-20652.
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