We appreciate the elevated tone of the latest NRC report about safety issues at SONGS, but personally it was

We appreciate the elevated tone of the latest NRC report about safety issues at SONGS, but personally it was disappointing to see that the same remedy that has not worked in the past is expected to produce better results this time. It’s like giving someone a “fix it” ticket for reckless driving repeatedly, but the behavior only worsens. Just because they have air bags and On-Star does not make them any safer as drivers. At what point does the number of “minor” safety violations amount to something that you can actually take action on and demand that improvements are made before they are allowed to continue to operate? The fact that back up systems are in place seems to minimize the severity of the violation. We can’t always count on the back up system to be operable as evidenced on many occasions. I’m afraid that giving them six more months to see how they have progressed completely ignores the critical nature of restarting Unit 2.

March 2, 2010

 

 

EA-10-024

 

Mr. Ross T. Ridenoure

Senior Vice President and

  Chief Nuclear Officer

Southern California Edison Company

San Onofre Nuclear Generating Station

P.O. Box 128

San Clemente, CA  92674-0128

 

SUBJECT:      WORK ENVIRONMENT ISSUES AT SAN ONOFRE NUCLEAR GENERATING
STATION ? CHILLING EFFECT

Dear Mr. Ridenoure:

 

The purpose of this letter is to verify Southern California
Edison (SCE) is taking appropriate actions to ensure San
Onofre
Nuclear Generating Station (SONGS), Units 2 and 3, is a workplace that
fosters an environment where employees feel free, and are encouraged,
to raise safety concerns.

 

The
Nuclear Regulatory Commission (NRC) has concluded that some employees
in multiple workgroups at SONGS have the perception that they are not
free to raise safety concerns using all available avenues, and that
management has not been effective in encouraging employees to use all
available avenues without fear of retaliation.
  This conclusion resulted from numerous observations,
including; (1) employees expressing difficulty or inability to use the
corrective action program; (2) a lack of knowledge or mistrust of the
Nuclear Safety Concerns Program (NSCP); (3) a substantiated case of a
supervisor creating a chilled work environment in his/her work group;
and (4) a perceived fear of retaliation for raising safety concerns.
 

 

The
NRC has identified that safety concerns are being raised by SONGS
personnel through some communication avenues, and has not identified
any safety issues that were not reported by some available avenue.
 
The NRC has determined that some employees do not consider certain
avenues available, such as discussing a concern with their immediate
supervisor, but would find an alternate avenue to communicate their
safety concern.

 

The
NRC has received a significant increase of allegations from onsite
sources at SONGS to nearly ten times the industry median in 2009.
  During this time, there was a significant increase in
chilling effect, discrimination, and anonymous concerns
raised to the NRC as compared to prior years.  These allegations were received from multiple onsite
organizations.

 

The
NRC observed that not all SCE managers have completed Safety Conscious
Work Environment training, and that SCE communications and policy
statements do not clearly reflect the availability of multiple avenues
for raising safety concerns.
 
Also, the NRC?s 2009 Mid-Cycle Assessment noted that this was the
fourth consecutive assessment period with substantive cross-cutting
issues in the areas of human performance and problem identification and
resolution.
 
SCE?s corrective actions have not demonstrated adequate improvement in
these areas, and the NRC continues to identify additional problems in
these areas.
 

These internal communication issues, long-term failure to correct
substantive cross-cutting issues, and a potential inconsistent
understanding of expectations and standards are contributors to some
employees? reluctance to raise safety concerns.
 

 

Supporting
details from NRC inspections, allegations, and NRC conducted focus
group interviews are provided in the attachment to this letter.

 

Action:

 

Within 30 days of the date of this letter, the NRC requests
that SCE provide:

 

(1) Results of your Safety Conscious Work Environment root cause evaluation and focus group interviews, conducted on or about
January and February 2010.
 
As part of the results, provide the basis for determining the number of
interviews and scope of work groups selected, as well as the questions
used for the interviews.
 
Also provide what immediate actions were taken to address these
results, and what longer-term actions are planned, including
descriptions, milestones, and due dates;

 

(2) Your action plans to address existing Safety Conscious
Work Environment issues to improve the environment at SONGS.
 
The action plans, at a minimum, should specifically address how each
avenue for raising concerns will be improved, including ease of use of
the corrective action program, knowledge and use of the NSCP,
availability of the NRC, and SCE?s open door policy.
  Also include the measures that will be used to determine
your action plan effectiveness;

 

(3)
Your plan to communicate expectations and policies concerning Safety
Conscious Work Environment at SONGS, and methods used to verify that
all SCE and contract personnel have received the message and clearly
understand it;

 

(4)
Your plan to ensure that individuals who are not satisfied with the
resolution of a problem can pursue the concern further through
additional avenues (such as SCE management, the corrective action
program, the NSCP, or the NRC) without fear of retaliation;

 

(5)
Through focus group interviews, the NRC has identified Safety Conscious
Work Environment issues in multiple work groups, as indicated in the
enclosure to this letter.
  For those groups, provide your actions taken and planned to
address the chilled environment.
 
This discussion should include the specific actions taken to repair the
willingness of individuals in those groups to raise safety concerns,
and what longer term actions you are taking or plan on taking to ensure
the effectiveness of these actions;

 

(6)
Your plan to identify any other specific workgroup that may have Safety
Conscious Work Environment issues that have not been previously
identified;

(7)
What actions you have taken or plan to take to ensure that actions
taken against individuals are not perceived as retaliatory to avoid a
further chilling of the environment at SONGS; and

 

(8) Your plans to inform the SONGS workforce, including
contractors, of:
  (i)
the issuance and content of this chilling effect letter; (ii) the
current status of Safety Conscious Work Environment at SONGS; and (iii)
your action plans to address the Safety Conscious Work Environment
issues.

 

Furthermore, the NRC requests that SCE provide at a public
meeting, within six months of the date of this letter:

 

(9) The results of your evaluations of progress in addressing
the Safety Conscious Work Environment concerns at SONGS, and;

 

(10)
Any additional actions or changes in actions planned and taken to
address Safety Conscious Work Environment issues at SONGS.

 

The NRC also requests that SCE provide in writing, within six
months
of the date of this letter:

 

(11)
The effectiveness of actions taken to address the Safety Conscious Work
Environment concerns in the specific groups identified in Action (5)
above;

 

(12)
The effectiveness of actions taken to address Safety Conscious Work
Environment issues in any additional SCE identified groups with Safety
Conscious Work Environment concerns; and

 

(13)
Any additional actions or changes in actions planned and taken to
address Safety Conscious Work Environment issues at SONGS.

 

Following
receipt and review of SCE?s response, we will determine if a meeting is
needed to discuss SCE?s approach
and schedule, and the NRC?s planned
oversight.
 

 

In
accordance with 10 CFR 2.390 of the NRC’s “Rules of Practice,” a copy
of this letter will be made available electronically for public
inspection in the NRC Public Document Room or from the Publicly
Available Records (PARS) component of NRC?s document system (ADAMS).
  ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). 
In addition, on May 14, 1996, the Commission issued a policy statement
regarding the freedom of employees in the nuclear industry to raise
concerns without fear of retaliation.
  This policy statement is accessible from the NRC Web site at

http://www.nrc.gov/about-nrc/regulatory/allegations/scwe-frn-5-14-96.pdf.  

 

Because
your response will be placed and made available electronically for
public inspection in the NRC Public Document Room or from the PARS
component of ADAMS, to the extent possible it should not include any
personal privacy, proprietary, or safeguards information so that it can
be made available to the public without redaction.
 
If personal privacy or proprietary information is necessary to provide
an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a
redacted copy of your response that deletes such information.
 
If you request withholding of such material, you must specifically
identify the portions of your response that you seek to have withheld
and provide in detail the bases for your withholding claim (e.g.,
explain why the disclosure of information will create an unwarranted
invasion of personal privacy or provide the information required by 10
CFR 2.390(b) to support a request for withholding confidential
commercial or financial information).
 
If safeguards information is necessary to provide an acceptable
response, please provide the level of protection described in 10
 CFR 73.21.

 

If
you have any additional questions regarding these matters, please
contact Mr. Ryan Lantz, Chief, Project Branch D, at (817) 860-8173.

                                                                                   

                                                                                    Sincerely, 

 

                                                                                    /RA/

                                                                                   

                                                                                    Elmo Collins

                                                                                    Regional Administrator

 

 

Dockets:   50-361, 50-362

Licenses:  NPF-10, NPF-15

w/ Enclosure:  Background Information