IR 05000390/2018013
| ML18333A033 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 11/28/2018 |
| From: | Masters A NRC/RGN-II/DRP/RPB5 |
| To: | James Shea Tennessee Valley Authority |
| References | |
| EA-16-061, EA-17-022 IR 2018013 | |
| Download: ML18333A033 (13) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 28, 2018
SUBJECT:
WATTS BAR NUCLEAR PLANT - FOLLOW-UP FOR NRC CONFIRMATORY ORDER EA-17-022 AND CHILLED WORK ENVIRONMENT LETTER EA-16-061; NRC INSPECTION REPORT 05000390/2018013, 05000391/2018013
Dear Mr. Shea:
On November 26, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed its review of Unresolved Item (URI) 05000390, 391/2018012-01, Potential Failure to Implement Reviews of Adverse Employment Actions in Accordance with Confirmatory Order, EA-09-009 and EA-09-203; which was identified in the August 17, 2018, inspection report 05000390/2018012, 05000391/2018012 (ML18229A153). The NRC inspector discussed the results of this inspection with Mr. Paul Simmons and other members of your staff on November 28, 2018. The results of this inspection are documented in the enclosed report.
As part of the inspection activities, the inspector reviewed past revisions of Tennessee Valley Authoritys (TVA)s procedure NPG-SPP-01.7.4, Adverse Employment Action and the Executive Review Board, along with a review of TVA databases and human resource (HR) records, dating back to March 2017, to ensure that activities identified as Executive Review Board (ERB)
Adverse Actions and Non-ERB Adverse Actions were reviewed per the requirements of the 2009 & 2017 Confirmatory Order (CO).
The inspector documented two Severity Level IV (SL IV) violations for failure to implement the requirements of the Confirmatory Orders under traditional enforcement process in this report.
The NRC is treating these violations as non-cited violations (NCVs), consistent with Sections 2.2.4 and 2.3.2 of the NRC Enforcement Policy.
The inspector also documented a licensee-identified SL IV violation under traditional enforcement process in this report. The NRC is treating this violation as an NCV consistent with Sections 2.2.4 and 2.3.2 of the NRC Enforcement Policy. If you contest the violations or significance of these NCVs, you should provide a response within30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC resident inspector at the Watts Bar Nuclear Plant.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Anthony D. Masters, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos.: 50-390, 50-391 License Nos.: NPF-90, NPF-96
Enclosure:
IR 05000390/2018013, 05000391/2018013
REGION II==
Docket Nos.: 50-390, 50-391 License Nos.: NPF-90, NPF-96 Report No.: 05000390/2018013, 05000391/2018013 Licensee: Tennessee Valley Authority (TVA)
Facility: Watts Bar, Units 1 and 2 Location: Spring City, TN 37381 Dates: September 17 through November 28, 2018 Inspector: S. Smith, Senior Construction Inspector Approved by: Anthony D. Masters, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
This inspection was initiated to review Unresolved Item (URI) 05000390, 391/2018012-01.
Activities performed include a review of past revisions of Tennessee Valley Authoritys (TVA)s procedure NPG-SPP-01.7.4, Adverse Employment Action and the Executive Review Board; along with a review of TVA databases and human resource (HR) records, dating back to March 2017, to ensure that activities identified as ERB Adverse Actions and Non-ERB Adverse Actions were reviewed per the requirements of the 2009 & 2017 Confirmatory Order (CO). Two NRC-identified Severity Level IV (SL IV) Non-cited Violations (NCV) and one additional tracking item are summarized in the table below. A Licensee-identified SL IV NCV is documented in report section 92702.
List of Findings and Violations Failure to Adequately Implement Requirements of Confirmatory Order EA-09-009, -203 Cornerstone Significance Cross-Cutting Aspect Report Section SLIV NCV 05000390,
N/A 391/ 2018013-01 N/A 92702 Closed The inspector identified a SL IV NCV for the licensees failure to adequately implement requirements of CO EA-09-009, -203. Specifically, procedure NPG-SPP-01.7.4, Adverse Employment Action and the Executive Review Board, failed to provide procedural guidance for the implementation of a process to review proposed adverse actions such as demotion, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access.
Failure to Adequately Implement Requirements of Confirmatory Order EA-17-022 Cornerstone Significance Cross-Cutting Aspect Report Section SL IV NCV 05000390,
N/A 391/2018013-02 N/A 92702 Closed Additional Tracking Items Unresolved Item Potential Failure to Implement Reviews of Adverse (URI) 05000390,
Employment Actions in Accordance with Confirmatory 92702 391/2018012-01 Order, EA-09-009 and EA-09-203 (Closed)
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at:
https://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html The inspector reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 92702 - Follow-up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, Confirmatory Orders, and Alternative Dispute Resolution Confirmatory Orders The inspector reviewed Unresolved Item (URI) 05000390, 391/2018012-01, Potential Failure to Implement Reviews of Adverse Employment Actions in Accordance with CO, EA-09-009 and EA-09-203.
INSPECTION RESULTS
URI 05000390, Potential Failure to Implement Reviews of Adverse 391/2018012-01 Employment Actions in Accordance with Confirmatory 92702 (Closed) Order, EA-09-009 and EA-09-203
Description:
TVA CO EA-09-009, -203 issued to TVA on December 22, 2009, required, in part, that:
By no later than ninety
- (90) calendar days after the issuance of this Confirmatory Order, TVA shall implement a process to review proposed licensee adverse employment actions at TVAs nuclear plant sites before actions are taken to determine whether the proposed action comports with employee protection regulations, and whether the proposed actions could negatively impact the SCWE. Such a process should consider actions to mitigate a potential chilling effect if the employment action, despite its legitimacy, could be perceived as retaliatory by the workforce During the June 2018 inspection for Follow-up for NRC CO EA-17-022 and Chilled Work Environment Letter Safety Conscious Work Environment (SCWE) and CO EA-16-061, inspectors identified that TVA procedure NPG-SPP-01.7.4, Adverse Employment Action and the Executive Review Board (ERB), Revision 01, dated December 21, 2017, defined Adverse Action, or Adverse Employment Action (AEA) as an employer-initiated action that detrimentally affects an employees compensation terms, conditions, or privileges of employment. Such actions include but are not limited to termination, demotion, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access. The procedure then delineates between adverse actions as ERB Adverse Actions and Non-ERB Adverse Actions; stating that Non-ERB Adverse Actions do NOT require ERB review. However, management may elect to have other employee actions reviewed by ERB, as they deem necessary. Specific Adverse Actions, identified by the procedure as Non-ERB Adverse Actions, included:
- Demotions
- Transfer to a Less Desirable Job
- Denial of Access As part of the inspection activities, the inspector performed a review of TVA databases and human resource (HR) records, dating back to March 2017, to ensure that activities identified as ERB Adverse Actions and Non-ERB Adverse Actions were reviewed per the requirements of the 2009 & 2017 CO. Specifically, the inspector reviewed:
- Denial of Access database,
- List of Contractor Terminations,
- TVA Incident Report Database, and
- HR records for individuals that received Lower Grade Pay, Change in Pay, and Transfers.
Finally, the inspector reviewed various ERB packages along with the contractor oversight process to ensure that the Adverse Actions were being identified and reviewed in accordance with the applicable procedures and met the requirements of both COs.
Corrective Action Reference(s): Condition Report (CR) 1449611 Licensee Identified Violation 92702 This violation of very low safety significance was identified by the licensee and has been entered into the licensees corrective action program and is being treated as a non-cited violation, consistent with Sections 2.2.4 and 2.3.2 of the NRC Enforcement Policy.
Violation:
TVA CO EA-09-009, -203 issued to TVA on December 22, 2009, requires, in part, that:
By no later than ninety
- (90) calendar days after the issuance of this Confirmatory Order, TVA shall implement a process to review proposed licensee adverse employment actions at TVAs nuclear plant sites before actions are taken to determine whether the proposed action comports with employee protection regulations, and whether the proposed actions could negatively impact the SCWE.
Contrary to the above, on October 12, 2017, TVA failed to review a proposed licensee adverse employment action at WBN before the action was taken. Specifically, a TVA contractor terminated an employee prior to giving TVA notification. This action resulted in a failure to perform an Executive Review Board prior to the termination which was required per procedure NPG-SPP-11.10, Rev. 7, Adverse Employment Action.
Significance/Severity Level: This violation was characterized using traditional enforcement because it is associated with Confirmatory Order EA-09-009, -203. The violation was assessed using Sections 2.2.2 and 2.2.4 of the NRCs Enforcement Policy. The inspector concluded that the violation represented a procedural error that did not result in an actual safety impact, the potential consequences were very limited, and that the licensee took appropriate corrective actions.
Corrective Action Reference(s): Condition Report (CR) 1352296 Failure to Adequately Implement Requirements of Confirmatory Order EA-09-009, -203 Cornerstone Significance Cross-Cutting Aspect Report Section N/A SL IV NCV 2018013-01 N/A 92702 The inspector identified a Severity Level IV Non-Cited Violation (NCV) for the licensees failure to adequately implement requirements of Confirmatory Order EA-09-009, -203. Specifically, procedure NPG-SPP-01.7.4, Adverse Employment Action and the Executive Review Board (ERB), failed to provide procedural guidance for the implementation of a process to review proposed adverse actions such as demotion, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access.
Description:
Confirmatory Order EA-09-009, -203 states that:
By no later than ninety
- (90) calendar days after the issuance of this Confirmatory Order, TVA shall implement a process to review proposed licensee adverse employment actions at TVAs nuclear plant sites before actions are taken to determine whether the proposed action comports with employee protection regulations, and whether the proposed actions could negatively impact the SCWE.
On October 20, 2017, TVA issued procedure NPG-SPP-01.7.4, Adverse Employment Action and the Executive Review Board, Rev. 0. Section 5.0, Definitions, defines Adverse Action (Adverse Employment Action, or AEA) as an employer-initiated action that detrimentally affects an employees compensation terms, conditions, or privileges of employment. Such actions include but are not limited to termination, demotion, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access.
TVAs definition for adverse action is consistent with the NRCs RIS 2005-18.
The only AEAs for which the procedure requires a review include: suspensions (one or more days off without pay), terminations for cause, involuntary reduction in force, and no-fault terminations of employment. Those four AEAs are subjected to an ERB review. However, AEAs, such as, demotions, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access are not required to be reviewed because the procedure does not require any reviews for the AEAs that are not required to have an ERB review. Procedure NPG-SPP-01.7.4 has been revised two times since it initially became effective on October 20, 2017, with Rev. 1 dated December 21, 2017, and Rev. 2 dated August 13, 2018. Both of these revisions also do not require any reviews for the licensee defined adverse actions which include demotions, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access.
Therefore, procedure NPG-SPP-01.7.4 fails to provide procedural guidance for implementation of a review process for proposed licensee adverse employment actions which do not require an ERB review before actions are taken to determine whether the proposed action comports with employee protection regulations and whether the proposed actions could negatively impact the Safety Conscious Work Environment (SCWE) as required by Confirmatory Order EA-09-009, -203.
Corrective Actions: In response to this issue, TVA has entered this into the corrective action program and is assessing potential impacts.
Corrective Action Reference: This issue has been captured in Condition Report 1449611.
Performance Assessment:
This violation was associated with previously documented AV 05000390, 391/2016013-03; documented in inspection report 05000390/2016013, 05000391/2016013 (ML17069A133).
Enforcement:
Violation: TVA Confirmatory Order (CO) EA-09-009, -203, issued to TVA on December 22, 2009, requires, in part, that:
By no later than ninety
- (90) calendar days after the issuance of this Confirmatory Order, TVA shall implement a process to review proposed licensee adverse employment actions at TVAs nuclear plant sites before actions are taken to determine whether the proposed action comports with employee protection regulations, and whether the proposed actions could negatively impact the SCWE.
Contrary to the above, on October 20, 2017, TVA issued procedure NPG-SPP-01.7.4, Adverse Employment Action and the Executive Review Board, Rev. 0, which failed to provide procedural guidance for implementation of a process to review proposed licensee adverse actions before actions were taken.
TVA procedure NPG-SPP-01.7.4, Section 5.0, Definitions, defines Adverse Action (Adverse Employment Action, or AEAs) as an employer-initiated action that detrimentally affects an employees compensation terms, conditions, or privileges of employment. Such actions include but are not limited to termination, demotion, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access. TVAs definition for adverse action is consistent with the NRCs RIS 2005-18.
The only AEA for which the procedure requires a review include: suspensions (one or more days off without pay), terminations for cause, involuntary reduction in force, and no-fault terminations of employment. Those four AEAs are subjected to an Executive Review Board (ERB) review. However, demotions, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access are not required to be reviewed by the ERB or any other required reviews. This is not consistent with Confirmatory Order EA-09-009, -203. The failure to provide procedural guidance for implementation of a review process for non-ERB adverse actions was also identified in Revisions 01 and 02 of procedure NPG-SPP-01.7.4.
Severity: The NRC determined this violation constituted a more than minor traditional enforcement violation associated with failure to implement the requirements of Confirmatory Order EA-09-009, -203. While the inspectors did not identify any actual examples where the licensee failed to perform a review for non-ERB adverse actions, the potential to miss such a review exists; notwithstanding the licensees cognitive SCWE review. The inspector determined that the failure to perform such a review could potentially impact safety, in that, failure to perform SCWE reviews for non-ERB adverse actions could miss opportunities to identify and/or prevent an environment where individuals would be hesitant to raise nuclear safety concerns for fear of retaliation. The inspector determined that the licensees failure to implement the requirements of the Confirmatory Order is considered a SL IV violation, consistent with Section 2.2.2.d of the NRC Enforcement Policy, dated May 15, 2018.
Enforcement Actions: The violation is being treated as an NCV consistent with Sections 2.2.4 and 2.3.2 of the NRC Enforcement Policy, dated May 15, 2018.
Corrective Action Reference(s): Condition Report (CR) 1449611 Failure to Adequately Implement Requirements of Confirmatory Order EA-17-022 Cornerstone Significance Cross-Cutting Aspect Report Section N/A SL IV NCV 2018013-02 N/A 92702 The inspector identified a Severity Level IV Non-Cited Violation (NCV) for the licensees failure to adequately implement requirements of Confirmatory Order (CO) EA-17-022. Specifically, corporate and site procedure revisions failed to ensure that current and future CO requirements continue to be met when procedure NPG-SPP-01.7.4, Adverse Employment Action and the Executive Review Board, was revised such that it no longer required review of adverse actions as required by Confirmatory Order EA-09-009, -203.
Description:
TVA CO EA-17-022 states in part that:
Within six months of issuance of the CO, TVA shall revise corporate and site procedures, as appropriate, to ensure that current and future CO requirements continue to be met.
TVA CO EA-09-009, -203 states in part that:
By no later than ninety
- (90) calendar days after the issuance of this Confirmatory Order, TVA shall implement a process to review proposed licensee adverse employment actions at TVAs nuclear plant sites before actions are taken to determine whether the proposed action comports with employee protection regulations, and whether the proposed actions could negatively impact the SCWE.
The CO EA-17-022 requirement took effect on January 27, 2018. On August 13, 2018, TVA issued procedure NPG-SPP-01.7.4, Adverse Employment Action and the Executive Review Board, Rev. 2. Section 5.0, Definitions, defines Adverse Action (Adverse Employment Action)as an employer-initiated action that detrimentally affects an employees compensation terms, conditions, or privileges of employment. Such actions include but are not limited to termination, demotion, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access. The only Adverse Actions for which the procedure requires a review include: suspensions (one or more days off without pay),
terminations for cause, involuntary reduction in force, and no-fault terminations of employment.
Those four adverse actions are subjected to an Executive Review Board (ERB) review.
However, demotions, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access are not required to be reviewed. The procedure does not require any reviews for the adverse actions that are not required to have an ERB review. Although, both previous revisions to this procedure (Procedure NPG-SPP-01.7.4, Rev. 0, dated October 20, 2017, and Rev. 1 dated December 21, 2017) also do not require any reviews for the licensee defined adverse actions demotion, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access, Rev. 2 was the first revision issued after the Confirmatory Order EA-17-022 requirement to ensure that current and future CO requirements continue to be met went into effect.
While TVAs definition for adverse action is consistent with the NRCs RIS 2005-18; procedure NPG-SPP-01.7.4 fails to provide procedural guidance for implementation of a review process for proposed licensee adverse employment actions which do not require an ERB review before actions are taken to determine whether the proposed action comports with employee protection regulations and whether the proposed actions could negatively impact the SCWE.
Therefore, since this procedure revision does not require reviews of personnel actions defined as adverse actions, it is not in compliance with the 2009 Confirmatory Order and thus is a failure to ensure that current CO requirements continue to be met.
Performance Assessment:
This violation was associated with previously documented AV 05000390, 391/2016013-03; documented in inspection report 05000390/2016013, 05000391/2016013 (ML17069A133).
Enforcement:
Violation:
TVA CO EA-17-022, issued to TVA on July 27, 2017, requires, in part, that:
Within six months of issuance of the CO, TVA shall revise corporate and site procedures, as appropriate, to ensure that current and future CO requirements continue to be met.
TVA CO EA-09-009, -203, issued to TVA on December 22, 2009, requires, in part, that:
By no later than ninety
- (90) calendar days after the issuance of this Confirmatory Order, TVA shall implement a process to review proposed licensee adverse employment actions at TVAs nuclear plant sites before actions are taken to determine whether the proposed action comports with employee protection regulations, and whether the proposed actions could negatively impact the SCWE.
Contrary to the above, TVAs corporate and site procedures did not ensure that current CO requirements continue to be met. Specifically, on August 13, 2018, TVA procedure NPG-SPP-01.7.4, Adverse Employment Action and the Executive Review Board, Rev. 2, was issued and failed to provide procedural guidance for implementation of a process to review proposed licensee adverse actions before actions were taken. Procedure NPG-SPP-01.7.4 Rev. 2 did not provide procedural guidance for implementation for a process to review proposed Adverse Actions, which do not require ERBs, such as demotion, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access. This is not consistent with Confirmatory Order EA-09-009, -203, which states in part that TVA shall implement a process to review proposed licensee adverse employment actions at TVAs nuclear plant sites before actions are taken to determine whether the proposed action comports with employee protection regulations, and whether the proposed actions could negatively impact the SCWE. Although, both previous revisions to this procedure (Procedure NPG-SPP-01.7.4, Rev. 0, dated October 20, 2017, and Rev. 1 dated December 21, 2017) also do not require any reviews for the licensee defined adverse actions demotion, denial of a promotion, an unfavorable performance appraisal, transfer to a less desirable job, and denial of access, Rev. 2 was the first revision issued after the Confirmatory Order EA-17-022 requirement to ensure that current and future CO requirements continue to be met went into effect.
Severity: The NRC determined this violation constituted a more than minor traditional enforcement violation associated with failure to implement the requirements of CO EA-17-022. While the inspectors did not identify any actual examples where the licensee failed to perform a review for non-ERB adverse actions, the potential to miss such a review exists; notwithstanding the licensees cognitive SCWE review. The inspectors determined that the failure to ensure that current and future CO requirements continue to be met could potentially impact safety. Specifically in this example, failure to perform SCWE reviews for non-ERB adverse actions could miss opportunities to identify and/or prevent an environment where individuals would be hesitant to raise nuclear safety concerns for fear of retaliation. The inspectors determined that the licensees failure to implement the requirements of the Confirmatory is considered SL IV violation, consistent with Section 2.2.2.d of the NRC Enforcement Policy, dated May 15, 2018.
Enforcement Actions: The violation is being treated as an NCV consistent with Sections 2.2.4 and 2.3.2 of the NRC Enforcement Policy, dated May 15, 2018.
Meeting Summary On September 21, 2018, the inspector presented the inspection results to Mr. Paul Simmons, Site Vice President and other members of the licensee staff. The inspector confirmed that all proprietary information reviewed during the inspection was returned and that none of the potential report input discussed was considered proprietary.
The inspector conducted additional briefings with your staff to the potential findings on November 2, 2018, and November 9, 2018. On November 28, 2018, the inspector presented the final inspection results to Mr. Paul Simmons, Site Vice President and other members of the licensee staff.
DOCUMENTS REVIEWED
Other Activities:
Follow-up of Confirmatory Order Commitments (IP 92702)
WBN Failure to Implement Adverse Employment Action Process, Event Date: 3/10/2017, Level
Evaluation (RCA) Report, dated 5/26/2017
NPG-SPP-01.7.4, Adverse Employment Action and Executive Review Board, Rev. 02, dated
8/13/2018
NPG-SPP-01.7.4, Adverse Employment Action and Executive Review Board, Rev. 01, dated
2/21/2017
NPG-SPP-01.7.4, Adverse Employment Action and Executive Review Board, Rev. 00, dated
10/20/2017
NPG-SPP-11.10, Adverse Employment Action, Rev. 07, dated 1/24/2017
NPG-SPP-11.10, Adverse Employment Action, Rev. 06, dated 7/28/2016
NPG-SPP-11.10, Adverse Employment Action, Rev. 05, dated 4/27/2016
NPG-SPP-11.10, Adverse Employment Action, Rev. 04, dated 3/2/2015
NPG-SPP-11.10, Adverse Employment Action, Rev. 03, dated 12/19/2013
NPG-SPP-11.10, Adverse Employment Action, Rev. 02, dated 4/24/2012
NPG-SPP-11.10, Adverse Employment Action, Rev. 01, dated 7/14/2011
NPG-SPP-11.10, Adverse Employment Action, Rev. 00, dated 8/31/2010
TVA-SPP-11.2.0, Filling Vacant Positions, Rev. 04, dated 5/1/2017
TVA-SPP-11.316, Employee Discipline, Rev. 06, dated 9/11/2018
TVA-SPP-11.316, Employee Discipline, Rev. 05, dated 7/3/2017
TVA-SPP-11.316, Employee Discipline, Rev. 04, dated 9/12/2016
NPG-SPP-07.7, TVA Nuclear CTS Role and Oversight of Supplemental Personnel, Rev. 07,
dated 3/16/2018
Watts Bar Nuclear Plant Nuclear Safety Culture Site Leadership Team Report, dated 7/12/2018
Watts Bar Nuclear Plant Nuclear Safety Culture Site Leadership Team Report, dated 1/11/2018
CR 1449501, The NRC Confirmatory Order Follow-Up Inspection at WBN identified the need to
review applicable vendor records to verify compliance to the NPG Adverse Employment Action
process.
CR 1449609, During the Confirmatory Order follow-up inspection held 9/17/18-9/21/18, the NRC
identified that an ERB package was missing some signatures and was incomplete. The ERB
was held on 5/8/17 with the action taken on 5/10/17, therefore the ERB was held prior to the
action being taken. The NRC interviewed the D&Z PM that was involved with the ERB and it
was confirmed that there was a calendar invitation sent on for the ERB to be held on 5/8/17.
CR 1448827 July 2018 SLT NSC Meeting Minutes are incorrect.
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