ML17334B489
| ML17334B489 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 09/01/1993 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Martin J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1184D, NUDOCS 9309090125 | |
| Download: ML17334B489 (51) | |
Text
ACCiKLERAT~DOCVMENTDIST
" TION SYSTEM REGULAT~ INFORMATION DISTRIBUTION
-STEM (RIDS)
ACCESSION NBR:9309090125 DOC.DATE: 93/09/01 NOTARIZED: YES DOCKET FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
05000315 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
Indiana Michigan Power Co. (formerly Indiana !'ichigan Ele RECIP.NAME RECIPIENT AFFILIATION MARTIN.J.BE Document Control Branch (Document Control Desk)
SUBJECT:
Responds to notice of violation a proposed imposition of civil penalty
& demand for info w/respect to DOL Case 92-ERA-37.
DISTRIBUTION CODE:
IE14D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: Enforcement Action Non-2.790-Licensee
Response
NOTES:
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NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT 'fHE DOCUMENT CON'I'ROL DESK.
ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISfRIBUTION LISTS FOR DOCUMENTS YOU DON'T HEED!
TOTAL NUMEER OF COPIES REQUIRED:
LTTR 16 ENCL 16
Indiana Michigan Power Company P.O. Box 16631 Columbus, OH 43216 INCAN@
NlCHIGAM POMfKR AEP:NRC!1184D Donald C.
Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 NOTICE OF VIOLATION AND PROPOSED ZMPOSITZON OF CIVIL PENALTY AND DEMAND FOR INFORMATION U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Attn:
J.
B. Martin September 1,
1993
Dear Mr. Martin:
The purpose of this letter is to respond to your Notice of Violation and Proposed Imposition of Civil Penalty and Demand For Information (U.S.
Department of Labor Case No.
92-ERA-37).
Attached are our responses along with pertinent exhibits to substantiate the facts set forth therein.
We remain convinced that fear of retaliation or discrimination by anyone who may raise a safety concern, either zeal or perceived, at Cook Nuclear Plant is not a problem now and has not been a
problem in the past.
This letter is submitted pursuant to 10 CFR 50.54(f) and, as such, an oath statement is attached.
EF E. E. Fitzp trick Vice President Attachment cc:
A. A. Blind G. Charnoff T. E. Murley NFEM Section Chief NRC Resident Inspector J.
R. Padgett 9309090125 930901 PDR ADOCK 05000315 8
STATE OF OHIO)
COUNTY OF FRANKLIN)
E. E. Fitzpatrick, being duly sworn, deposes and says that he is the Vice President of licensee Indiana Michigan Power Company, that he has read the foregoing Response to NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY AND DEMAND FOR INFORMATION and knows the contents thereof; and that said contents are true to the best of his knowledge and belief.
dg-Subscribed and sworn to before me this ~g day of A~M
, l9 NOTARY PUBLIC RITA D. HILL NOTARY PUBLIC. STATE OF OHIO
ATTACHMENT TO AEP:NRC:1184D NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY AND DEMAND FOR INFORMATION RESPONSES
ATTACHMENT TO AEP:NRC:1184D Page 1
Statements From page 3 of the August 5, 1993 USNRC to Indiana Michigan Power Company Notice of Violation and Proposed Imposition of Civil Penalty and Demand for Information
".....[D]escribing those actions and any additional actions you have taken or plan to take to minimize any potential chilling effect arising from this incident.
Included in that written
- response, you should describe:
(1) the steps you have taken to ensure that your employees and site contractors, including but not limited to American Nuclear Resources, and the employees of your contractors, understand their responsibilities with respect to the right of individuals to raise safety concerns without fear of retaliation or discrimination, (2) the actions you have taken to assess the extent to which workers at the D. C. Cook Nuclear plant may fear retribution for raising safety
- concerns, and (3) the actions you have taken or plan to take to eliminate or minimize any such fears."
General Res onse Actions taken to minimize any potential chilling effect arising from this incident include informing employees of the incident, sensitizing them to the requirements of 10 CFR 50.7, and emphasizing existing management policy that encourages reporting of safety concerns.
These actions were accomplished through a series of letters from the Plant Manager.
A letter was issued to all site personnel to inform them of the existence of the
- concern, identify the Department of Labor process as the appropriate process for resolving the concern, emphasize existing management policy, and review the reporting and escalation process.
(Exhibit 1)
A letter was issued to all plant management personnel to inform them of the concern and to direct them to meet with their employees to specifically ensure that they understand they can raise safety related concerns without fear of reprisals or job related discrimination.
(Exhibit 2)
A letter was issued to all contractor management to inform them of the existence of the concern and request that they meet with their employees to specifically ensure that they understand that they can raise safety related concerns without fear of reprisals or )ob related discrimination.
(Exhibit 3)
In addition to the letters, postings were placed throughout the plant to make this information readily available to all site personnel.
(Exhibit 4)
The Special Provisions for Donald C. Cook Nuclear Plant, which are included in all contracts, have been revised to add Section 16.0 which emphasizes the requirements of 10 CFR 50.7, specifically, Employee Protection.
(Exhibit 5)
ATTACHMENT TO AEP:NRC:1184D Page 2
Statement 1 Res onse The policy of American Electric Power Company, Znc.,
has been and still is to ensure that all personnel engaged in activities affecting safety-related functions of structures,
- systems, and components in Cook Nuclear
- Plant, have the right to, and are encouraged to, raise safety concerns without fear of retaliation or discrimination.
The Statement of Policy for the Donald C.
Cook Nuclear Plant Quality Assurance
- Program, which is issued by the Chairman of the Board, President, and Chief Executive Officer of American Electric Power
- Company, Znc.,
states that any site personnel engaged in activities affecting safety-related functions who believes the Quality Assurance Program is not being complied with, or that a
deficiency in quality exists, should notify his/her supervisor, the American Electric Power Service Corporation Director~ality Assurance, and/or the Plant Manager. If the notification does not in the employee's opinion receive prompt or appropriate attention, the employee should contact successively higher levels of management.
An employee reporting such conditions shall not be discriminated against by companies of the American Electric Power System.
Discrimination includes discharge or other actions relative to compensation,
- terms, conditions, or privileges of employment.
(Exhibit 6)
Ample initial and recurring training concerning the processing of safety concerns are/were provided to all personnel.
The process of our Quality Assurance Condition Reporting
- program, which outlines the requirement to escalate known or suspected safety concerns up through management and/or directly to the NRC, is explained on pages 6 and 7 of 8 of GE-C-2005 (Exhibit 7 - General Employee Training Lesson Plans).
The NRC Form 3
is also thoroughly reviewed with all trainees as part of the orientation program.
Page 11 of 11 of GE-C-5100-HO-1 also explains the workers'ights and responsibilities with regard to the Plant Managers Instruction (PMI) 7030 Condition Report process.
(Exhibit 8)
Each
- employee, as part of initial training (and during annual requalification) also receives the radiation protection procedures as outlined in GE-C-1004, 1013 and 1016.
(Exhibits 9, 10, and 11)
To assure that each employee understands the requirements of the specific PMZs, the employee is required to review the information with his/her supervisor prior to initialing the form signifying receipt and understanding of the training.
(Exhibit 12)
In addition, ANR management posted portions of the Michigan Whistleblowers Protection Act to reassure their personnel that their safety concerns would be addressed without discrimination or retaliation.
(Exhibit 13)
ATTACHMENT TO AEP:NRC:1184D Page 3
Statement 2 Res onse Actions taken to assess the extent to which workers at the Donald C.
Cook Nuclear Plant may fear retribution for raising safety concerns were based on a review and evaluation of the normal reporting process to determine if a notable change in the normal cyclic and workload reporting had occurred since the event.
The review and evaluation were made of the number of condition reports generated before and after the two week employment period (in
- March, 1992) of the individual addressed in the Notice of Violation.
The number of condition reports initiated per month between July,
- 1991, and April, 1993, were noted.
The number of condition reports were listed in three categories:
ANR initiated reports, contractor initiated reports, and total reports initiated by all individuals.
The number of condition reports generated on a monthly basis for all three categories did not reveal any impact as a result of the cited event.
The only noted difference was the expected impact of outage versus non-outage activities.
(Exhibit 14)
Statement 3 Res onse Ongoing programs that continuously encourage employees and contractors to identify safety concerns and other problems include the following.
As previously indicated, General Employee Training (GET) discusses worker rights and responsibilities, and NRC Form 3.
GET requalification training will be emphasizing this area based on recent events.
Annual State of the Plant meetings promote feedback between Plant Manager and personnel, including contractors.
The human performance evaluation system (HPES) provides a
method for employee and contract personnel to communicate with site management.
Indiana Michigan employee exit interviews provide open insights necessary to correct or stabilize any variances which may exist in our management or operations style.
These
- programs, along with management's commitment to ensure the rights of all site personnel, will eliminate or minimize any fear of retribution for raising safety concerns.
Additional Items Also from page 3 of the August 5, 1993, USNRC to Indiana Michigan Power Company Notice of Violation and Proposed Imposition of Civil Penalty and Demand for Information:
" ~
~ ~ [P]rovide the following information within 30 days of the date of this letter, in writing and under oath or affirmation:
ATTACHMENT TO AEP:NRC 1184D Page 4
(1) a written description of the duties and activities currently performed by the tool accountability supervisor and the site supervisor for American Nuclear Resources; and (2) your basis for concluding that the tool accountability supervisor, the contractor's site supervisor, and the managers of American Nuclear Resources fully understand their responsibilities under your NRC license and their obligation to fulfill NRC regulations and license requirements."
Item 1 Res onse The duties and activities performed by an ANR tool accountability supervisor, a
temporary position activated only during open containment, are as follows.
"TOOL ACCOUNTABILITY SUPERVISOR Personnel in this category will have similar responsibilities as a
QC Tool Accountant.
In addition, will be responsible for supervising a crew of accountants.
This individual will be held accountable for the crews'ctivities, including compliance with plant and company rules and procedures, resolving conflicts and the training of personnel.
EDUCATION AND EXPERIENCE:
Must have previous supervisory background.
Previous tool accountant background is preferred."
The duties and activities currently performed by the ANR site superintendent are as follows.
"SITE SUPERINTENDENT Meet with client supervision to determine what skills are needed to applicably fillan open job requisition.
2 ~
Interview potential candidates for open job requisitions, then determine if the candidate is acceptable for that position.
3 ~
Process in new employees.
4 ~
Discipline and terminate Scope/ANR employees as required.
The superintendent has the final decision on the degree of the disciplinary action.
5.
Liaison between Scope/ANR employees and client supervisors.
ATTACHMENT TO AEP:NRC 1184D Page 5
6.
Liaison between Scope/ANR corporate office and client supervisors.
7 ~
Completes or ensures an employee evaluation on each employee is conducted once a year.
The superintendent will also review all completed evaluations.
8.
Decide when employees merit a pay increase, and fillout applicable paperwork.
9 ~
Work with employees and listen to their problems and
- concerns, and try to work out conflicts or problems accordingly.
10.
Prepare weekly and monthly reports to the client and Scope/ANR Company President.
11.
Investigate all charges of harassment and discrimination.
12.
Conduct weekly ANR supervisor meetings.
13.
Write company
- memos, procedures, etc.,
as required.
14.
Remain in constant contact with client supervisors to keep updated on employees'erformance, problems, etc.
15.
Attend various management training workshops and seminars to enhance management skills.
16.
Complete Michigan Employment Security Commission (MESC) requests for information reports and wage and severation forms.
Also represent Scope/MR at MESC Hearings.
17.
Represents Scope/ANR in various legal proceedings.
The site superintendent is held accountable to the client and Scope/ANR for the employees'ctions.
This includes but is not limited to safety, work quality, dependability, and procedural compliances."
Item 2 Res onse The tool accountability supervisor involved is no longer employed by ANR.
The tool accountability supervisor resigned from ANR on June 15,
Cook Nuclear Plant on June 16, 1993, in the Computer Security Standards Department as a measuring and test equipment specialist (non supervisory).
The ANR site superintendent remains in the employment of ANR at the Donald C.
Cook Nuclear Plant in the same
- position, site superintendent.
ATTACHMENT TO AEP:NRC:1184D Page 6
The basis for concluding that the former tool accountability supervisor, the contractor's site superintendent, and the managers of ANR fully understand their responsibilities under our NRC license and their obligation to fulfill NRC regulations and license requirements is as follows:
A The General Employee Training referred to in the above response applies to all employees, both upon initial employment and annual recurring/requalification training.
Training is also used to ensure that all personnel (including contract personnel),
who work at Cook Nuclear Plant, understand their responsibilities with respect to the right of individuals to raise safety concerns, and Cook Nuclear Plant management's expectation that individuals are to raise safety concerns without fear of retaliation or discrimination.
As part of the General Employee Training program given to all employees (including contractors) upon their assignment at Cook Nuclear
- Plant, employees are instructed that they are to report to their supervisor anything that they think may be a problem, to write a condition report, and/or to report to successively higher levels of management.
Employees (including contractors) are also instructed that if problems are not adecpately resolved within the
- company, they should contact the Nuclear Regulatory Commission.
Employees are instructed concerning the content and provisions of NRC Form 3, "Notice to Employees",
and that reporting will not jeopardize their job.
Training records confirm that the complainant addressed in the Notice of Violation, the tool accountability supervisor, and the contractor's site superintendent received the above training.
(Exhibit 15)
The
- policy, procedure, and training have been a
routine part of the activities at Cook Nuclear Plant for years prior to the event alleged in the Notice of Violation.
We believe the policy, procedure, and training for encouraging reporting of potential safety concerns are sound, with no need of change.
B.
Plant management sent a letter and posted information (see Exhibits 1
and
- 4) relative to the event and stated in the information that individuals can raise safety related concerns without fear of reprisals or job related discrimination.
ATTACHMENT TO AEP:NRC:1184D Page 7
C Plant management issued a letter to all contractor management (see Exhibit 3) identifying the existence of the concern and requesting that contractor management meet with their employees to specifically ensure they understand they can raise safety related concerns without fear of reprisals or job related discrimination.
D.
ANR management has responded to the issue.
ANR sent a
memo to all ANR supervisors identifying the existence of the concern, posted relevant information, and verbally reinforced that everyone is and will be continuously encouraged to report any safety concern to management at any time, and that reporting to a
government agency rather than management may be done without fear of retaliation or of job related discrimination.
(Exhibit 16)
E.
Plant and corporate management verbally reviewed with ANR management our contractual agreement to ensure compliance with appropriate laws.
In conclusion, based on actions taken by plant management to sensitize employees and contractors'mployees to this issue, and ANR's response to a plant issued letter and the incident, it has been concluded that the former tool accountability supervisor, the contractor's site superintendent, and the managers of ANR fully understand their responsibilities under the Donald C. Cook Nuclear Plant's NRC license and their obligation to fulfill NRC regulations and license requirements.
u -- 5 /c-'Pp R 1NDIANA Oato Nay 3, 1993 Sub)oct Problem Reporting by Empl'oyees From To A.A. Blind All Site Personnel Employees of nuclear power plant licensees and employees of contractors of nuclear power plant licensees are protected from discrimination for engaging in activities that are protected by law.
Information concerning these activities (NRC Form 3) is posted on the plant official bulletin boards locate" at the west side of the Security Control Center, at the turbine entrance to the Auxiliary Building, and at the RPAC entrance to the Auxiliary Building.
Whenever questions come up concerning alleged discrimination against an
- employee, whether substantiated or not, there is a concern about whether or not these questions might inhibit other employees from raising safety related concerns.
The purpose of this letter is to inform you that an employee has raised a concern about discrimination for engaging in protected activities.
This concern is presently being handled through administrative proceedings in the Department of Labor, which is the appropriate process for addressing and evaluating such concerns.
Details of this concern are not included in this letter because the proceeding has not yet been concluded.
However, I would like to take this opportunity to emphasize that the existence of this case should not be a concern to any employee who wishes to bring safety related concerns to the attention of management or to the attention of the NRC.
Zt is corporate policy, and therefore a requirement, for all personnel to encourage the reporting of safety related concerns and other problems.
At the Cook Nuclear Plant this is done through the PMI-7030 Condition Report process, through direct reporting to
Problem Rep ing by Employees May 3, 1993 Page 2
management, or to the NRC.
Normally, the reporting of safety related concerns or problems should be accomplished through the PMI-7030 Condition Report process.
Xf the concern or problem is not appropriately addressed, then reporting directly to successive levels of management and ultimately directly to the NRC might be appropriate.
I would also like to point out that any employee may go directly to management or the NRC at any time.
In summary, I would like to emphasize the importance of continuing our excellent working relationships here at Cook Nuclear Plant, which includes the reporting of safety related concerns and other problems without fear of discrimination.
A.A. Blind
AEP:NRC 1184D EXHIBIT 2
fl-fNDIAMA M)CH'AN PNVER oa~o May 3, 1993 subj~
Problem Reporting by Employees From To A.A. Blind All Managers Title 10 of the Code of Federal Regulations Part 50, Section 50.7 prohibits discrimination by licensees of nuclear power plants against employees (including Contractor employees)
.for engaging in certain protected activities.
Section 50.7 goes on to list activities that are included under this protection, but states that protected activities are not limited to this list.
The purpose of this letter-is two fold.
First, I want to advise and make you aware of an ongoing administrative proceeding which concerns a potential violation of 10 CFR 50.7 and, secondly, I want to ensure that we, as Plant Management, are continuing to take appropriate actions necessary to promote a positive work environment in which all employees at Cook Nuclear Plant feel comfortable with raising safety related concerns.
As you might know, a Contractor employee has filed an administrative claim with the Department of Labor (DOL) against his employer.
The claim alleges that the employee was discriminated against and not recalled for work as a
result of engaging in an activity protected under 10 CFR 50-7
~
A DOL Administrative Law Judge has issued a decision in favor of the employee.
The Contractor is presently appealing this decision.
Details of this proceeding will not be addressed in this memo because the administrative proceeding has not yet been concluded.
- However, notwithstanding the ongoing proceeding, we need to take this opportunity to ensure that our employees and contractors understand that they are encouraged to come forward whenever they have a safety related concern.
Problem Report ng by Employees May 3, 1993 Page 2
I am directing all managers to meet with their employees and communicate Cook Nuclear Plant's commitment to safety and our adherence to the requirements of 10 CFR 59.7.
More specifically you need to ensure that our employees understand that they can raise safety related concerns and/or contact the NRC without fear of reprisals or job related discrimination.
I will instruct all site Contractors to take similar actions with respect to their employees who are engaged in activities at Cook Nuclear Plant.
In support ef the above activity I will be sending a Plant Manager memo to each employee acknowledging the ongoing DOL proceeding, but emphasizing our commitment to safety and our adherence to the requirements of 10 CFR 50.7. If you have any questions concerning this memo or its directions you are to contact me directly.
A.A. Blind
AEP:NRCs1184D EXHIBIT 3
~~fall Cook Nudear Plant One Cook Race Bridgrnan. N 49106 616 465 5901 May 3, 1993 Ms. Lydia Demski President American Nuclear Resources/Scope Services 2095 Niles Rd.
St. Joseph, MX 49085
Dear Sir:
Title 10 of the Code of Federal Regulations Pa'rt 50, Section 50.7 prohibits discrimination by licensees of nuclear power plants against employees (including contractor employees) for engaging in certain protected activities.
Section 50.7 goes on to:l'ist activities that are included under this protoction; hut states that protected activities are not limited to this list.
The purpose of this Letter is two fold..
- First, X want to advise and make you aware of an ongoing acbninistrat9ve.'proceeding.
which concerns a potential violation of 10 cpR 50-7 andy...secondly., l want to ensure that you, as managers of employees working at Cook Nuclear Plant, are continuing to take appropriatek actions.necessary to promote a positive work environment in which.Cherie'emyXoyees feel comfortable with raising safety related concerns."
As you might know, a Contractor employee has fiI,ed:an administrative claim with the Department of Laboi"(DOL). against his employer.
The claim alleges that the employee was discr5ainated against and not recalled for work as a result of-engaging'.in an activity protected under 10
@FR 50.7.
A DOL Adihinistrative Law Judge has issued a decision in favor of the employoe. 'he.'.
Contractor is presently appealing this decision 'etails'. ot this proceeding vill not be addressed in this.
memo.biciuse-the'dministrative proceeding has not yet been.conctuded Boiaver.,
notwithstanding the ongoing proceeding, you: need -.to. take this opportunity to ensure that your employees underihinck thit they are encouraged to come forward whonever they have'a:safety..related concern.
II E am recoxesting all managers of companies that manage:employees who work at the Cook Nuclear Plant to meet. with their employees. and communicate Cook Nuclear Plant's commitment to: safety:and'our adherence to the requirements of 10 CFR 50.7.
Note specifically you need to ensure that your employees understand 'Chat-they can raise safety related concerns and/or contact the'NRC.'without fear of reprisals or job related discrimination.
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NOTE:
This letter was also sent to the following contractors'n Donald C. Cook Nuclear Plant site.
Bartlett Nuclear Inc.
Brand Utility Services, Inc.
Clean America DSI Industries Holtec International MQS Inspection,.Inc.
Master-Lee Energy Services Corp.
NRT Technical, Inc.
National Installation Services Company Nuclear Energy Consultants PRC Engineering Syst'ems, Inc.
Stanley Smith Security Wondermakers, Inc.
AEP:NRC:1184D EXHIBIT 4
August 11, 1993 The NRC has proposed a
$25,000 fine for Indiana Michigan Power based on discrimination by a contractor against a former employee of the contractor at the Cook Plant.
The pexson charged that he was discharged in 1992 fox'aising questions about hia zadiation ex osure and for requesting a copy of his exposure records.
expos The fine, based on a decision by a United States Department of Labor Administrative Law Judge, does not have to be paid until 30 days after the decision becomes final.
Xt.is stol being reviewed by the Secretary of Labor.
The individual was being released at the end of a work assignment and was proceeding with his termination whole body count when he became engaged in a heated discussion c'oncerning informat:ion being
.provided him regarding his radiation exposure.
Based partially. on this behavior, the contractor decided Not toirecall this person the
'ext, time this skill was needed at the Cook Plant.
There was no retaliation oz discrimination because he.questioned his exposure or contacted the NRC.
The Department of Labor Law Judge ruled that this individual's emotional reactions to the perceived delay, in receivi'ag information regarding his radiation exposure was understandable and should not have been used in the decision not to.rehire, as.. the'ight to question and receive information regarding radiation exposure is a protected activity.
Indiana Michigan Power disagrees with this finding,.Our policy and procedures remain that we encourage. the reporting of.potential safety concerns.
Everyone is encouraged to -report. safety:.concerns to management at any time.
Xf they feel.that'. it"is necessary to report it to a govexnment
- agency, they may'do so',without fear of retaliation or of placing their job in jeopardy.
POSTED:
08-11-93 REMOVE:
08-18-93
AEP t NRC: 1184D EXHIBIT 5
n ~
August 20, 1993 s~q~ Special Provisions for'onald C. Cook Nuclear Plant r~
E. E. Fitzpatrick O. L Aguilar P. A. Barrett B. H. Bennett A. A. Blind S. J. Brewer J. R. Corbett J. A. Howard R. F. Kroeger
~ L. G. Lewis B. A. Renz
'W. G. Smith The Special Provisions (contractual) for Donald C. Cook Nuclear Plant have been revised.
The revised special provisions, dated August 15, 1993, should be included in all nuclear contracts for which the request for proposal is dated August 20, 1993, or after.
'lease notify all personnel in your area of responsibility that this document has been revised.
Copies may be obtained from the corporate supply room.
rdh cc: B. R. Signet
16.0 EMPL YEE PR TE TI N 1
FR
.7 16.1 10 CFR 50.7 pzohibits discrimination against nuclear power plant employees, including Contractoz and subcontractor employees-for engaging in certain protected activities.
Discrimination includes discharge and other actions that relate to compensation,
- terms, conditions, and privileges of employment.
The protected activites are those established in Section 210 of. the Energy Reorganization Act as amended.
Contractor shall be familiar with the requirements of 10 CFR 50.7 and ensure that its employees understand, their rights under this provision.
More specifically,. Contractor shall ensure that its employees understand that, they can raise safety related concerns and/or directly contact the NRC without fear of employer reprisyls or job related discrimination.
16.2 Contractor shall notify the Plant.
- Manager, or his designee, if any safety related concerns are reported by or raised by Contractor's employees.
Contractor is prohibited from discriminating against any employee, or making any employment related
- decision, based on an employee raising a
safety related concern and/or contacting the NRC.
16.3 Violation of this provision or of 10 CFR 50.7 shall be considered a material breach of contract.
7 Rev. 081293
[legalya]aycook 2]
Page 12 of 12
American Electric Po~
Service Corporation 1 Riverside Plaza Columbus. OH 43215 614 223 1000 Z
AMERICAN KLECTRJC POWER STATEMENT OF POLICY FOR THE DONALD C.
COOK NUCLEAR PLANT EQUALITY ASSURANCE PROGRAM POLICY American Electric Power Company Inc.,
recognizes the fundamental importance of controlling the design, modification, and operation of Indiana Michigan Power Company's Donald C.
Cook Nuclear Plant (Cook Nuclear Plant) by implementing a planned and documented guality Assurance
- Program, including equality
- Control, that complies with applicable regulations,
- codes, and standards.
II The guality Assurance Program has been established to control activities affecting safety-related functions of structures,
- systems, and components in the Cook Nuclear Plant.
The guality Assurance Program supports the goal of maintaining the safety and reliability of Cook Nuclear Plant at the highest level through a systematic program designed to assure that activities affecting safety-related functions are conducted in compliance with applicable regulations,
- codes, standards, and established corporate policies and practices.
As Chairman of the
- Board, President, and Chief Executive Officer of American Electric Power
- Company, Inc.,
I maintain the ultimate responsibility for the guali ty Assurance Program associated with Cook Nuclear Plant.
I have delegated responsibilities for implementation of, and compliance with, the guality Assurance
- Program, as outlined in this statement.
IMPLEMENTATION The AEPSC Director-guali ty Assurance, under the direction of the AEPSC Senior Vice President-Nuclear Generation, has been assigned the overall responsibility for specifying the guality Assurance Program requirements for Cook Nuclear Plant and verifying their implementation.
The AEPSC Director-guali ty Assurance has authority to stop work on any activity affecting safety-related items that does not meet applicable administrative, technical, and/or regulatory requirements.
The AEPSC Director-guali ty Assurance does not have the authority to stop unit operations, but shall notify appropriate plant and/or corporate Revised:
8/11/93
Statement of Policy for the Donald C.
Cook Nuclear Plant Quality Assurance Program Page 2
management of conditions not meeting the aforementioned criteria and recommend that unit operations be terminated.
The AEPSC Senior Vice President-Nuclear Generation, under my direction, has been delegated responsibility for effectively implementing the Quality Assurance Program.
All other AEPSC divisions and departments having a
supporting role for Cook Nuclear Plant are functionally responsible to the Senior Vice President-Nuclear Generation.
The Cook Nuclear Plant Manager, under the direction of the AEPSC Senior Vice President-Nuclear Generation, is delegated the responsibility for establishing the plant Quality Control Program and implementing the Quality Assurance Program at Cook. Nuclear Plant.
The AEPSC Director-Quality Assurance is responsible for providing technical direction to the Plant Manager for matters relating to the Quality Assurance Program at Cook Nuclear Plant.
The AEPSC Director-Quality Assurance is also responsible for maintaining a Quality Assurance Section at Cook Nuclear Plant to perform required reviews, audits, and survei llances, and to provide technical liaison services to the Plant Manager.
The implementation of the Quality Assurance Program is described in the AEPSC General Procedures (GPs) and subtier department/division procedures, Plant Manager's Instructions (PMIs), and subtier department head instructions and procedures, which in total document the requirements for implementation of the Program.
Each AEPSC and Cook Nuclear Plant organization involved in activities affecting safety-related functions of structures,
- systems, and components in Cook Nuclear Plant has the responsibility to implement the applicable policies and requirements of the Quality Assurance Program.
This responsibility includes being familiar with, and complying with, the applicable Quality Assurance Program requirements.
COMPLIANCE The AEPSC Director-Quality Assurance shall monitor compliance with the establ i shed Qual ity Assurance Program.
Audit programs shal 1 be established to ensure that AEPSC and Cook Nuclear Plant activities comply with established program requirements, identify deficiencies or noncompliances, and obtain effective and timely corrective actions.
Any employee engaged in activities affecting safety-related functions of structures,
- systems, and components in Cook Nuclear Plant who believes the Quality Assurance Program is not being complied with, or that a
Revised:
8/11/93
Statement-of Policy for the Donald C.
Cook Nuclear Plant equality Assurance Program Page 3
deficiency in quality exists, should notify his/her supervisor, the AEPSC Director-equality Assurance, and/or the Plant Manager.
If the notification does not in the employee's opinion receive prompt or appropriate attention, the employee should contact successively higher levels of management.
An employee reporting such conditions shall not be discriminated against by companies of the American Electric Power System.
Discrimination includes discharge or other actions relative to compensation, terms, conditions, or privileges of employment.
E. Linn Draper, Chairman of the Board, President, and Chief Executive Officer American Electric Power Company, Inc.
Revised:
8/1 1/93
AEP: NRC: 1184D EXHIBIT 7
~
seem
~
D TITIE'uality Assurance, Quality Control REQI$ION 8
2.
You can make the greatest contribution to quality at the Cook Plant by doing the job right the first time.
III.
REP RT P TENTIALITEM F NON MPLIAN E 8.03.A A.
lt's recognized that things break and go wrong.
B.
C.
The Cook Plant has a system for reporting problems, defects, and procedural violations.
lt is called a Condition Report.
This system is required by federal regulations.
Specific items that must be reported are:
1.
Usted in the Plant Managers Instruction (PMI) on Condition Reports.
8.03.D F.
Basically, you should report anything you think may be a problem to your supervisor.
G.
You may need to write a Condition Report.
1.
Your supervisor should help you with this.
2.
Instructions contained in Plant Manager Instruction on Condition Reports, PMI-7030.
If you feel your report is not receiving the proper attention:
First, go to your immediate supervisor.
2.
Then, go through the other higher levels of your management.
Page 6 of 8
E
-2 0
Quality Assurance, Quality Control REVISION:
8 3.
Ifyou are unable to get problems resovlved, then contact the NRC.
NRC Form 3, "Notice to Employees.'.
Informs employees of:
a.
Thier rights.
2.
b.
The employer's responsibilities.
Divides the United States up into NRC regions.
3.
Provides addresses and phone numbers for each NRC region.
4.
Copies of the NRC Form 3 are posted at:
a.
Security Control Center.
b.
South Security Control Center.
c.
Auxiliary Building Access Control J.
These reports will not Jeopardize your job.
K.
You can be held criminally liable ifyou know of a nuclear safety related problem and you do not report IV.
MMARY A.
The Cook Plant has:
QA Program to-a.
Ensure safe operation of the Plant.
Page 7 of 8
E P
N lBILIE 28.
How do you go about reporting problems at the plant?
Normally, the reporting of safety related concerns or problems should be accomplished through the PMl-7030 Condion Report process.
Ask'your supervisor for guidance.
If the concern or problem is not appropriately addressed, then reporting directly to successive levels of management and ultimately directly to the NRC might be appropriate.
29.
Can an employee go directly to management or the NRC with a problem or safety related concern?
~ at any time.
Please see a Management representative or the NRC resident inspector.
30.
Can an employee lose his/her Job or be dlscrlmlnated against for reporting problems/safety related concerns directly to the NRC?
~.
Employees of nuclear plant licensees and employees of contractors of nuclear af power plant licensees are protected from discrimination for engaging in activities th t e protected by law, such as reporting problems/concerns.
information concern'ng these activities is contained in NRC Form 3.
3'f.
Where can you find postlngs of NRC Form 3?
ELF NRC Form 3s are posted in the Security Control Centers, the turbine entrance to the Auxiliary Building and at the RPAC entrance to the Auxiliary Building.
KIN 32 ~
Remember to use the S.TA..R. method when performing work at the Cook Plant.
~ Stop
~ Think
~ 4ct
~
Review lfyou are not familiar with the self-checking process, or have questions regarding how you should be using it to perform your work, ask your supervisor.
TRAININGINFORMATIONONLY GE-C-5100-HO-1 Revision 13 Page 11 of 11
AEP: NRC: 1184D EXHZBXT 9
Dosimetry REVISlON:
cx"-'s ~sy@~w~q~xw+NA~%v +~
~~%~+-~+V/>4&~4~~>%'.~ '~M+'~~5~~:.-
~.- -
~ "
54'%8:: ~""" iV"'4C""
3.
Chirper.
Low Battery.
5, Audible Alarm also causes digital display to change or blink.
6.
Any time you encounter an alarm - contact RP.
Vill. D E RE RD (S.G.P7)
A.
You can obtain your dose record from RP-Dosimetry.
IX.
MMARY A.
B.
Proper care and use of dosimetry is a part of your job as a radiation worker.
Review Objectives C.
Allowtrainees to handle the dosimetry devices to become familiar with them.
D.
Answer Student Questions.
Page 8 of 8
G E-C-1013 D
TITLE:
Workers'ights and Responsibilities REVISION:
ggos~~e@P."~<~>~~-',,"-:.~~<-'.<;=,-.."'~<~ihxW~<g~PRESENTATIGN~~~~,,~@~~'+g~~jg~~~~~~~"-.'SGAE3) 4 c.
Contact RP prior to starting any work in the restricted area.
d.
Notify RP personnel when changes or potential changes in working conditions occur that were not previously evaluated.
e.
Limitthe amount of material that has to be decontaminated or disposed of as radioactive waste by limiting material taken into the restricted area.
f.
Personal tools or equipment shall not be used in restricted areas.
Utilize hot tool crib tools and consumable issue items.
g.
Promptly obey "stop work" and evacuate instructions of (RP) personnel.
h.
Do not smoke, eat, drink, chew or apply cosmetics in Restricted Areas.
i.
Do not move or reposition radiological posting s.
Reporting Problems - Responsibilities of each individual.
a.
b.
C.
d.
Inform Radiation Protection immediately of any unusual incident in the restricted area including alarms or lights from radiological monitoring equipment.
Ifyou tear your Anti-Cs, immediately leave the contaminated area and contact RP.
Report the presence of treated or open wounds to RP personnel prior to entry into a restricted area.
Immediately inform RP personnel if a wound occurs while in a restricted area.
For a known or possible radioactive spill, minimize its spread and notify RP personnel promptly.
Page 6 of 7
AEP: NRC: 1184D EXHIBIT 11
Internal Exposure Control R~ISIQN 4
.Ng-,a~g~:.-~Wg';,.".~'Q~',.~~ PRESBfNBON~~~.) "><...~;>.~~!
SL-AS B.
Air samples are taken in areas where airborne radioactive material is suspected or where it might occur due to work activities.
1.
They are only a sample of the air you have breathed; therefore, they are an estimate of the contaminants you have deposited internally.
SL-WBC C.
A whole body counter is normally used to check for internal radioactive material.
The whole body counter is a very sensitive machine that can detect radioactive material inside the body.
2.
It gives an accurate value of radioactivity in your body.
3.
Everyone has a small amount of radioactive material inside their body from natural sources
'in their food (e.g., K~).
4.
WBCs are required initially, periodically, and upon completion of work at Cook. Also, if needed, for evaluation of a suspected uptake of airborne radioactivity above the plant limits.
D.
Normally, we (Cook) don't use other bioassay, but in the event of an accident or large ingestion, urine or feces samples may be obtained.
1.
This is an example of how the body works to eliminate the contamination that gets inside.
2.
Like the WBC, this is to determine internal exposure.
Page 6 of 13
AEPsNRC 1184D EXHIBIT 12
PMI-5080 CO T CTOR TRA G
(SECTION 1)
P. A'A/8l'7 CONTRACTOR COMPANY:
TYPE:
Offsite Support: Services WORK INDEPENDENTLY: Q Yes No Onsite SCOPE OF WORK:
Safety Related APPROXIMATE START DATE:
Non-Safety Related Both
,APPROXIMATE END DATE:
OR, ONGOING WORK (FOR SUPPORT SERVICES ONLY)
CONTRACT EMPLOYEE' ROC PMI-2160 PMI-2220 PM1-2270 PMZ-4010 PMI-4080 PMZ-4100 PMI-5080 PMZ-6010 PMZ-7030 SASO ~ 007 0
Control of Chemicals System Internal Cleanliness Fire Protection Plant Operations Policy Control of Non-Core Ob)ects in the Spent Fuel Pool and Transfer Canal Plant Shutdown Safety and Risk Management Administration of Contractors Radiation Protection Plan Condition Reports Logging of Tools - Refueling 3
=48 Standing on Lines/Pipe Instruction:
Emergency Alarms:
Date:
Verification I have received the above specified training:
signature:
Z
" /l.
a nee gnat e ~
Det:reination BygddaAzÃrIHrIINzyvy@ssaIirroaS~u4vtu~
'Date:
g Departuent Bupervrsor Approved By: ~<<~ +uo +>~>~~i+~>~ee~dtvt<e Date:
Depa ent Superintendent FORWARD TO DE Page ~ of ~
P
-50 0
CO 0
(SECTION l)
TOPIC DATE INITIAL Work hour limitations - policies and department specific practices.
Plant PA system use and restrictions.
Parking lot rules.
Plant walkthrough for familiarization with Plant layout.
Cook Plant hearing protection device policy.
Heat stress program.
Vital area door alarms.
Security door alarms.
Paper recycling program.
Safety Manual - ANR.
~/'/
c c q'4
~Yw wa &82 C
C Plant Speci.fic Personnel Guideline Reference No. PM P ocedu e
A e
e o
S e
Plant Specific Personnel Guideline Reference No. PM E ectat o s o
Rad o
o s
Plant Specific Personnel Guideline Reference No. SAF-8 Ha Co o o
a t
w w
Proper handling and wearing of security badge.
Vital area door enclosure requirements.
TOPIC DEP POL CIES SASO. 007 - Lo i o
Too s - Refuelin Safety equipment.
Housekeeping standards.
Plant PA system use and restrictions.
Parking lot rules.
Di partment smoking policy.
c" n~
Page 4 of ~
4
%PLOCE ORIENTATION SIZZ c;rLC~~ mZ
~r "S~
~ '~
,p
/
iiZRE DATE 1e DO YQl UIIPSTAND THE RIGhT TO E'OH LAN 7 IF NO EXPLAIN ULLY TO EOYEE.
2, SHCM EMPLOYEE LIBRARY AND JliKRE TO FIND iSDS SHE"TS
~ ~ ~.
3e SHOH EGXEE THE EVACUATION RCUTE 8: EXPLAIN CRA'GE CARD ~~IElQe 4 ~
HAVE EMPLOYEE FILL QlT THE PMX SHEETe 5e HAVE EMPLOYEE FILL QlT THE COltER SHEET.
S. REPmT ALL IRJURZES PRES'TLY.
8k
- 7. GIVE JOB DESCRYPTIOH l r s.
'~h ttf'.
J
~
~
1.
10e Si ACKET P 'KICYe 11e SECtKKTY RULES,
,A 12e PAiulIKr LOZ RULES ~
f3e EBESS
- CODE, 1-;"t.P, aW. S~Y WuZ..
F?
15,
".IT1KSS FCR IZTY, RARDCH DRUG & ALCOHOL TESTI%.
16e AS A CONTRACTOR ME RECEIVE JOB DIRECTION rRQi AN AH'UPERVISCR lstHO IN TtlRN RECEIVES JOB DIRECTION FRGH A ZBH SUPERVISOR.
DATE ORIENTATION CQAPLETEe
/inc Pkcauwh~44 ~ZuPEX~crR u+im~TRAINER SIGNATURE
..v->
EPPLOYEE SIGNATURE
AEP: NRC: 1184D EXHIBIT 13
.-zy-Fa.
, ATTEN: ON EMPLOYEES The Michigan Whistteblowers'rotection Act (469 P.A. 1980, as amended by 146 P.A. 1982) creates protections and obligations for employees and employers under Michigan law.
PROTECTIONS:
Michigan employers are prohibited from discriminating against an employee because he/she or a person acting on his/her behalf reports or is clearly about to report a violation or suspected violation of federal, state or local )aw to a public agency.
Discrimination because of an employee s. participation in a public investiga-tion, hearing, inquiry or court action is also prohibited.
OBLIGATIONS:
An employee is. not protected from disciplinary action when making a report or allegation which he/she knows to be false.
The Act does not diminish or impair the rights of individuals or the employer under any collective bargaining agreement, nor to permit disclosures which would diminish or impair the rights of any person to the continued protection of confidentiality of communications where statute or common law provides such.
protection.
The Act does not require employers to compensate employees for participation in public investigations, hearings.
inquiries or court actions.
Employees should be aware that Michigan's General Rules of Pleading. (Rule 111.6) permit courts to order complainants to pay the reasonable
- expenses, including reasonable attorney fees,, incurred jn defending against unreasonable allegations which ought not to hav'e been mage.
ENFORCEMENT'n employee or employer alleging a violation of the Whistleblowers'rotection Act may bring a civil action in circuit court within 90 days of an alleged violation of the Act.
P EN ALTIES Persons found in violation of the Act can be assessed a civil fine up to ssoo.oo.
1 Persons found to have been illegally discriminated against under the Act may be awarded injunctive relief, attorney fees, reinstatement, back compensation and/or actual damages COMPANY POLICY:
Company policy prohibits employees or management. from engaging in discrimina-tion or retaliation against another employee because of his/her cooperation with public officials involved in the enforcement or adjudication of federal, state or local law.
A violation of this policy could result in discipline, up to and including discharge.
PLEASE 3EPORT ANY VIOLATIONS OF THIS POLICY TO THE PERSONNEL L,,7 +lrg 'l>w
-,/V+l&i LWDL'ii)'1 AV '
!1U I ULr I UtII AL t AN ACT to provtne proto=non mptovees who report a violation or sns ed vsotation ei state.
Icc=l. or federal !aw; tc provide protection to employe s wno participate in hearings, investigations,'
le~@lative inouiries, or court ac'Lions; and to prcsc~oe remecies and penalties.
Tne People of the Stcte of Michigan enac.'t Sec. l. As used in this ac'.:
(a) "Employeeee means a person who performs a service for wages or other remuneration under a contrac'. of nire, hhxtten or oral, e.-.press or implied. Employe includes a person employed by the state or a political subdivision of the state exc pt state classified civi'cree.
(b) "Emploveree means a person who has 1 or more employees.
Employer includes an agent of an cmplover and the state or a political subdivision of the state.
(c) "Person" means an individ'ual, sole proprietorship, parenewhip, corporation, association, or any 0 her lesaval entity.
(d) "Public bodvee means all of the following:
(i) A state oificer, employe,
- agency, depa..ment, division bureau
- board, commission,
- council, authority, or othe: body in the e"ecutivc branc!r oi state government (ii) An ag ncy, board, commission, council, member, or employee of the lemo'ative branch of state governmente (iii) A county, city, township village, intercounty intercity, or re@'onal governing body, a co'unc.l, school diswc'pecial disrnct. or municipal corporation, or a board, department, commission, coun agency, or any member or employee thereof.
(io) Any other bociy which is created by state or local authority or which is primarily funded by or througn state or local authority, or any member or employee of that body.
(v) A law eniorc ment agency or any member or employee of a law enforcement agency.
(ui) The judiciary and any memocr or employee of the judic ary.
Sec.
-" An employe.
shall not discharge,
- threaten, or othevvise discriminate against an employee reevarding the employe
's compensation, toms, conditions location, or privileges of employment because the employee, or a peaon acing on behalf oi the employe
. reports or is about to report, veroally or in writing, a vioiation or a suspected violation of a law or regulation or rule promulgated pursuant to law of this state.
a political subdivision of this state, or the United Statai to a public body, unless the employee ltnows that the report is.'alse. or bec" use an empioyee is reoucsted by a puolic body to participate in an investigation hearing, or inauiry he!d by that puoiic bociy, or a court ac:ion.
ec 3 ~
('
A pecan
~o a'eyes a violas'oa of t"~ s ac say bri~ a c'vil action.c.
a"J 5 e Ln'mcsive res
~ ef, a." actus
~ ~yes, or bosh v'Ln oo days art>>.- she cc ence of she aU c-ed v a~tion a~
na'Lss
~ -
c~e v a~
oa
(
n a
icn cadenced
<<=.m~=s, to subsection (1) eay be b~gh La e c%'out fcr he county vhe.
tvse a'
e
~ oa.
on octa.. sd ~ the county vhe e he coapla'ant resides ot the county vhe-.
he pe.=on a@Last vhoa
'ie civ' caetplains Ls "ed;os ides oc'as his oc'e.- prisnci <<aa
<<Lac of business.
(
)
s used Ln subse
~ on (1) ~ "4atnastes" aeans bcsees for Lsh)ug or less causes by ea=h violation of this act, Lnclud'e. essonable astor ey ees
(
)
i oye w s.~op by c ear and convincientt evidence th, hc or she oc a pecan acting on his or bcr bcha '
seas ahcut z ~<<a~
~ verba'y or Ln vs Lath ~ a vialas'an at' sus~<<-"= ed violat'on of
- a. Lav of this s=ate,
~ pol'Leal subC'vision of ~s staten oz he United S~ es to a pub" c body.
sL cou., in r ada=inst a J ud pens Ln an ac Loa brau tSht pursuant to th' ac
~ shall crde.", as the taut= consider aPProPriase, rcinssascaent of the c Ployee ~ the Pa~at of bae" ttsattes
~ full reinssateatent and senior y r bahts, acsua'aaatSes,-o-.
any ccabLnat'on of these r~die=.
A cauz asy e
e s
aso ain't'he cottpsinan a'
or a parian of the costs of litittasione Lnchdine reasonable attorney fees aad v'ess ees, if she cau>> dated.nes w thc avard sa appropriate e=
5 (1)
A Penna vho violates ndis act shall be liable for a cia. fLnc ot'at rare han 4500eooa
(
. ne h c is or-'ared pursuant ta thts ac-shal1 be subai ed to the s ate tressuz cr ar (2)
A cey41 te q
~
s.
de-as'n he pnenl fund Se-e 6n
~~~~s ac-ss~L not bc ccnstrued so danish or iapair the."Ltthss of a pecan unde." any eoVecsive ba"-a-
barsaa ni;g astret
- ent, nor sa pe. 'isclosu"es vhich vould dita'ish or tw~'r thc rirhss of any pe.
on to she. ccn Lnucd protection o
con Ldentiay of ccccunicasions Mhe.-e statute or cancan Laht <<avides such n
es suc.
pr -ec= on
~a Sec.
T.
hLs ac shall
- not, be canst. aed to reinquire an t pl-ye.-
m c=- mate pa. '=Lpsicn Ln an invest'tasioaa hearintt or Lnttui~ he' by a publ'c body La accaWnce s~s ac o
Se=-
8-An t a've".
sha 's ao 'es and use othe".
ao raoriase mans ta been h'
Lnfc
. c" of she'.
protections and obn-s ps'ons tc:der th's acs.
p ~
s a
shc' be 8:cva and eiv be c
ed a.
5
'<<.< net +tv>~
an employee for v'sh se ion 2 of 0
or ber eaalovees
AEP: NRC: 1184D EXHIBIT 14
CONDITION at PROBLEM REPORTS INITI JUNE 1991 THROUGH MARCH 1993 300 W ANR Initiated CR/PR O Contractor Initiated CR/PR H Total CR/PR 250 200 150 100 50 22 Ol Ol CP ol Cll Cb h.
g>>
D Cl CD o
cn 0
z o
C Cl CCC CD CV Ccl CCC ccc N
ccc a
cccE ccc cg 0
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CCC cD CO a
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COHTRACTOR sacr:
HAHE:
SPRAGUE SSH:
375-48-0149 DATE FROH RANGE: 91/Of/95' I
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COURSE rrTLE GEN EMPLOYEE RESP rl'OT ZYiUUI'E-T-OOOO fO/fe/92 GOMF'LETE GEtd EhPLOYKE lt<PO Gl-lALLENGE GEN EMPLOYEE 1HPO CHALLEHGE o~Eg~4P~P I>>PO CHA LE>>I*E GEM EtfPLOYEE INPO CHALLENGE GE-T-4000 E-T-AO.
I GE-T-4000 GE-T-neee 12/85/88 04/27/90 Qh/22/91 COHPLFTE COFIPI ETE COMPLETE COMPLErE
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GENERAL EMPLOYEE SECURITY GE-i-5e6O 12/05/88
~CONPLETE GFNERhL EMPLOYEE SECURITY GEt)ERAI FNPLOYEE SECURITY
'I GEHI=RAL EMPLOYEE SECURITY
+ GE-1'-5000 11/27/89 COl'll LETE ii GE-T-5000.
84/22/94 COMPLETE OE Et GENERhL EMPLOYEE SECURITY P
GE-T-SOOO fe/OV/91 COMPLETE GCNEI'AL EHrLr~~fz MKJRTVV I
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. ',I.P=< -OO 02/27/92 COMPLETE I=OQI<l.XFT OPERATIONS t1N-C-F51 0 08/15/9'0 CONPI ETE
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REFUEI XNG XNTE6'r<lTV e
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coURsE TIrLc rA33IATION AWARENESS SES>INAR FITNESS FOR DuTY PROI;RAH GEH EMPLOYEE SITE SPEC EN EHP OYEE SITE SPEC GEN EMPLOYEE SITE SPEC I.P
- HUi18ER, r~O-C-Reo~
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COMPLLTE GE-7-2060'F;7-2660 38/g3/85 D2/2>/8b coMPLErE COMPLETE GE-C-Ze < 0 09/$5/85'OtIPLFTE CE~EP&5
>727 I6785 CCHPLETE GFN Il<l-LOYEE SITE SPEC GLN,EHPLOYEE SITE SPEC GEN EMPLOYEE SITE SPEC GE-7~2066
'E-T-2060 02/24/88 62/27/89 COMI LEl'E
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COMPIETE; COMPLETE
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GEN E
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.- "...-GI;-N,EMPLOYLE,.4HPy 'Ct<ALL G8, -
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COMPLETE COMPLETE GENERAL.EMPLOYEE SECuRITY-GEHLRAL EIIPLQ'fEE SECURITY AGE-T-5000
~2*
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~OBPCKTE COMPLETE GENERAL EMr-LOYEE SEcuRxrY GE-T-5600 69/$ 1/92 COHPI ETE rYZivZ~z
American Nuc1ear Resources, 1nc.
2095 Noes Road SI.Joseph.MI 9085 Telephone: (616) 983~5 SEHVfCES lNC.
SERVlHG 1N8 IJIIIJIYWOVSIRY 2095 Niles Road St. Joseph, Ml49085 Telepheoe: (616) 983-1554 p y/C~
Au~t I1, 1993 To All American Nuclear Resources Supervisors From:
Lydia Demski, President You wilIhave observed buQetin board postings relative to a proposed $25,000 Gne by NRC against Indiana Michian Power Company for aHeged discrimination by American Nuclear Resources against aa employee who questioned safety regulations by D. C.
Cook. Discrirnir.)dion did not take place; American Nuclear Resources does not discriminate against any employee, nor do we seek retaliation or intimidate an employee who raises an issue relative to safety concerns.
On the contrary, we have a safety program that encourages questioning safety practices without risk of loss ofjob, etc.
Ia this particular incident the person charged that he was discharged in March of 1992 for raising questions about his radiation exposure and forrequestiag a copy of his exposure records.
The fact of the matter is that the employee was laid offaad whQe goiag through the exiting procedure there was an incident causing delay of the body count, the laid offemployee became extremely agitated and. demanding, a scene occurred.
It was management's decisioa not to recall this individual, aot because ofhis raised safety questions, but, because ofhis poor work performance (documented 03/20/92) oa lay offnotice.
The Qne, based on the decision by'a U.s. Dept. ofLabor Adrr)linistration Law Judge, does not have to be paid until 30 days after the decision, is finaL It is still being reviewed by the Secretary of Labor.
Indiana and Michigan Power disagrees with the cuaent Boding that 'American Nuclear Resources discriminated agamst the employee's does American Nuclear Resources.
Everyone is and wilIbe continuously eacouraged to report any safety concern to management at any time. Ifour employees wish to report to a govemmeat ageacy rather than management, they may do so without fear of retaliation or ofjob loss.