ML20058P119
| ML20058P119 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/14/1991 |
| From: | Bashhurst R ENTERGY OPERATIONS, INC. |
| To: | |
| References | |
| W1.501, NUDOCS 9312230081 | |
| Download: ML20058P119 (33) | |
Text
{{#Wiki_filter:GDC1-1W3 11:44CTRCri TJAT 3 UStRC 5047832232 Td DRP R4 P.02 a y,u p3 e'~'} L /Entergy SITE POLICY NO. W1.501
MANAM MANUAL
@@nt VOLitfE IV REV. NO. 0_ PAGE 1_ 0F 3 j
Title:
Quality Reporting
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Revision No. __ o ! Effective Date 6-14-91 Senior Nuclear Executive @ ' 1
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i 1.0 PURPOSE l 1.1 This policy outlines the methods of reporting and handling of employee concerns related to Quality / Safety at Waterford 3. j j 1.2 I This polk replaces and supersedes Executive Directive-013, !
" Quality Reporting."
2.0 RESPONSIBILITY i l 2.1 The Vice President, Operations is ultimately responsible for: 2.1.1 the overall formation and implementation of this policy. 2.2 The Director, Nuclear Safety is responsible for: 2.2.1 establishing the Quality Te u; and 2.2.2 development of directive (s) to implement this policy. 2.3 The Safety Review Manager, as the manager of the Quality Team, is responsible for: _ 2.3.1 ensuring employee concerns presented to the Quality Team 1 I are dealt with is a thorough and timely fashion; and I 2.3.2 ensuring that confidentiality, when requested, is maintained. 2.4 The Quality Assurance Manager is responsible for : 2.4.1 ensuring employee concerns brought to QA are handled in a thorour,h and timely faa:hion. 2.5 The Ouality Team is responsible for: 2.5.1 receiving employee concerns from Waterford 3 employees; 2.5.2 investigating these employee concerns; and r
- 2.5.3 maintaining confidentiality when requested.
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- T3 FOR INFORMATION DNI.Y f g 9312230081 910614 PDR ADOCK 050003B2
09-01-1993 11:44AM FROM WAT 3 UStRC 5047832232 TO DRP R4 P.03 I '; __ . i. /Erniergy MANAGEMENT MANUAL SITE POLICY NO. W1.501
'~' Operatforts VOLUME IV REV. No. O_ PAGE 2 0F 3; 2.6 Waterford 3 employees are responsible for: i 2.6.1 ensuring that their activities are performed in accordance with approved procedures and established requirements.
3.0 DETAILS
- 3.1 Introduction 3.1.1 ,
The employees of Waterford 3 are comunitted to assure that all requirements of the facility operating license, the Technical Specifications and applicable federal and state regulations which address nuclear safety are met. This is done to assure that no undue risk is presented to the health and safety of the general public. 3.1.2 Due to the complex and exacting nature of the work at Waterford 3, quality and safety are of primary importance. It is essential, therefore,.that any employee who discovers a condition or practice adverse to quality or safety bring ' that condition or practice to the attention of management. 3.2 Methods of Reporting 3.2.1 Notify your immediate supervisor. . 3.2.2 > If that fails to satisfy your concern, exercise the Open Door policy and bring your concern directly to management. 3.2.2.1 Management desires to be personally informed of any unresolved quality concerns. 3.2.3 If you are uncomfortable with either of the above steps, then you may notify QA of your concern. 3.2.3.1 You may contact QA anonymously if desired. i 3.3 Quali.ty Team 3.3.1 In addition to the methods of reporting in Section 3.2, Waterford 3 employees may want to contact the Quality Team ; regarding their concern (s). 3.3.2 The Quality Team is an independent group on-site, established to deal specifically with employee concerns. 3.3.2.1 Concerns may be presented in person at the Quality Team office, or by either mail or telephone. i
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09-01-1993 11:45AN FROM WAT 3 UStRC 5047832232 TO DRP R4 P.04
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( jgniergy SITE POLICY NO.'W1.501 l liWAGEMENT tiANUAL ~ Operatient VOLGiE IV REV. NO. O_ PAGE 3 0F 3 , 3.3.2.2 The Quality Team maintains a 24 hour telephone service to ackept concerns.
- a. The local Quality Team HOTLINE number is (504) 739-6600, the nationwide toll-froe number is 1-800-621-TE.AM. i 3.3.3 Confidentiality of all concerns is assured no matter which method is used to report the concern, e.g., phone, mail or walk-in.
3.3.4 If the amployee provides his/her name and address, a written response to the concern will be provided. 3.4 Nuclear Regulatory Commission 3.4.1 It is the preference of management that all employee concerns be addressed within the site organization using one of the methods of Sections 3.2 or 3.3. 3.4.2 However, employees are also free to bring matters affecting health and safety of the public to the attention of the NRC. 3.4.3 The NRC's Region IV Office of Inspection and Enforcement located in Arlington, Texas ~(Telephone 817-860-8100), will accept colleet telephone calls 24 hours a day. 3.4.4 You may also contact the Resident. NRC inspector on-site (Extension 3108 or by the local telephone number 783-6253/ 6254). 3.5 No person who voices a concern to managet.cnt, QA, the Quality Team, or the NRC should fear retribution or reprisal because of such action. 3.6 No discriminatory actions will be t.olerated due to participation in the Quality Reporting program. 4.0 ATTACHMENTS None I
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ov-ol-1v::o 11:4::wn FRUM uM1 3 USNRC 50478'2232 TO DRP R4 P.05
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( s)antergy SITE DIRECTIVE NO. W5.606 i MANAMNT MAN ~ l OP0fallOMS VOLUME IV ' REV. No. O_ PAGE 1 or 1_55
Title:
Randling of Waterford 3 Rev. No. O Concerns - Effective Date 8-12-91 Applicable Not Applicable Quality Organization Review [X] [] Safety Evaluation Applicability Review [] [X] , Environmental Evaluation [] [X] Prepared: Q.A. Reviewed: 1&4.3 j-
.- . y Reviewed: N - 65 V!f/ Approved: W/ .
1.0 PURPOSE 1.1 This directive describes the methods used for the confidential acceptance, investigation, and resolution of quality / nuclear safety concerns in the design, procurement, construction, maintenance, modification, or operation of Waterford 3 and; the methods used for the acceptance and formal transfer of management related concerns. 1.2 This directive also describes the methods to: 1.2.1 provide concern status and resolution to the individual; 1.2.2 track and trend concerns; and 1.2.3 provide Waterford 3 management with the status of Waterford 3 concerns through regular reporting. 1.3 This directive replaces NOAP-009, Rev. 4.
- 2.0 Rt.r t.m.NCES 2.1 10CTR50, Section 50.7, Employee Protection 2.2 10CTR21, Reporcing of Defects and Noncompli a ce '
2.3 Energy Reorganisation Act of 1974, Section 210 2.4 W1.501, Quality Reporting 2.5 UNT-006-010 Event Notification and Reporting I i l INFORMATION ONLY l
09 FROM 15tT 3 USNRC 5047832232 .TO 1DRP R4 P.06 ip , . 1993 11:46AM 8Entergy
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MANAGEMENT M SITE DIRECTIVE NO. W5.606 , Operations v0tuME IV , i-REv. No. O PAGE 2 or p5, , 2.6 UNT-005-002, Condition Identification (CI) 2.7 W2.501, Corrective Action 2.8 QAP-012, Quality Notice 2.9 HP-001-105, ALARA Improvement Report 2.10 UNT-007-016, Safety-Loss Control Activities , 2.11 ANSI N45.2.6, Qualification of Inspection, Rramination, and Testing Personnel for Nuclear Power Plants 2.12 ANSI N45.2.9, Requirements for the Collection, Storage and Maintenance of Quality Records for Nuclear Power Plants 3.0 DEFINITIONS 3.1 Quality Team personnel assigned to receive, investigate, evaluate, resolve, and document Waterford 3 quality / nuclear safety concerns relating to the design, procurement, construction, maintenance, modification, or operation of Waterford 3. 3.2 Quality / Nuclear' Safety Concern - an interest expressed by an individual regarding the quality of work or nuclear safety in the design, procurement, construction, maintenance, modification, or operation of Waterford 3. 3.3 Management Related Concern - an interest expressed by an individual not related to Paragraph 3.2, (i.e., industrial safety / OSHA, health Ph ysics, personnel / disciplinary actions, not pertaining to IG as defined in Paragraph 3.4, and other relevant management concerns.) 3.4 Intimidation and Harassment (I E) - an undue or unwarranted action against an employee, which includes bodily harm, loss of job or employment privileges, etc., or a threat of the aforesaid, as-identified by the Safety Review Manager to be stemming from the reporting of a concern as defined in 10CFR$0.7. 3.5 Protected Activity - the expression or reporting of a concern / l violation of requirements, or providing such related information to j Waterford 3 nupervision/ responsible management, the Quality Team, or the NRC. ; 3.6 Finding - a determination resulting from an investigation of a i concern (either substantiated or unsubstantiated). ! i 1 4 l
>i ~ 09-014 993 11:46AM. ;FROM WAT 3 UStRC 5047832232 TO DRP R4 P.07
.- 8g qy MANAGEMENT MANUAL SITE DIRECTIVE NO. W5.606
~ gyggg VOLllME IV REV. NO. O, PAGE 3_ 0F 15, 5
4.0 RESPONSIBILITY _ 4.1 The Vice President, Operations is ultimately responsible for: 4.1.1 the overall formation and implementation of the Quality Team l program. 4.2 The Director, Nuclear Safety reports directly to the Vice President,' Operations and is responsible for: 4.2.1 eatsblishing the Quality Team and development and maintenance of this directive. , 4.3 The Safety Review Manager reports directly to the Director, Nuclear Safety and is responsible fors 4.3.1 the implementation of this directive. (The Safety Review i Manager maintains access to the Vice President, Operations.) 4.4 Quality Team Specialists report directly to the' Safety Review i Manager and are responsible for:
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4.4.1 the planning, organizing, and control of the activities -' associated with a specific investigation. These responsibilities include but are not limited to, the following; 4.4.1.1 conducting interviews; ; 4.4.1.2 planning investigations; 4.4.1.3 assessing concern reportability In accordance with UNT-006-010, Event Notification and Reporting (Reference 2.5), and preparing a Potentially Reportable Event Report where applicable; 4.4.1.4 establishing and maintaining files; ' 4.4.1.5 preparing or assisting in the preparation of , correspondence and/or responses related to asaigned ' concerns which require signature at management or executive level; and ' 4.4.1.6 initiating a Condition Identification (C1) or a Quality Notice (QN) in accordance with References 2.6, 2.7 and/or 2.8. e
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0#h01-1993_ilt47AM FROM WAT 3.USmC 5047832232 TO DRP R4' P.08 _ SITE DIRECTIVE No. V5.606
~ Entergy M G M T M AL Operations v0LUME IV REV. NO. O PAGE 4_ 0F ,15 4
NOTE: These are ad'ainistrative instruments utilized by the Quality Team to document, report, and track a substantiated concern which identifies a quality / nuclear safety l nonconformance or a programmatic deficiency. 4.5 The cognizant manager is responsible for: 4.5.1 researching and correcting, when required, the identified deficiencies noted on a CI or QN. (See Paragraph 5.2.3) 1 5.0 DETAILS 5.1 Waterford 3 Concern Acquisition Methods ' 5.1.1 Quality Team Hot Line/ Toll Free Line (" HOT" Files) 5.1.1.1 The Quality Team Bot Line/ Toll Free Line is located in the office area of the Quality Team. 5.1.1.2 Incoming calls on these limes will be monitored ' during working hours by a Quality Team Specialist.
- a. After working hours, weekends and holidays, calls will'be monitored by an answering machine. ,
- b. On weekends or during holiday periods, no more-than 72 hours may elapse without monitoring of the machine by a Quality Team Specialist.
5.1.1.3 The Quality Team Specialist monitoring the answering machine or receiving the call will complete the Hot Line Daily Log (Attachment XV), identifying the date and file number and initialing the entry.
- a. If no calls were received, he will so indicate on the log, and initial in the space provided.
'l 5.1.1.4 The Quality Team Specialist monitoring the !
answering machine or receiving the call shall initiate a Record of Concern form (Attachment I) to establish the database of the expressed-concern (s) .
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09-01-1993I1248AM FROM 1JAT'3 tSRC 50cuh TO_ .DRP R4 P.09 SITE DIRECTIVE NO. WS.606 4 Enter 5Y ;
" " " "I "* " L '
g,,g. VOL M IV REV. NO. 0_ PAGE $_0F J5 t
- a. A unique " HOT" file number-(i.e., NOT-YR-XX) shall be assigned to each Hot Line/ Toll Free call received', and a file shall be established for further investigation and tracking.
5.1.1.5 The Quality Team Specialist will enter the file number in the Quality Team Concern Assignment and Tracking Log (Attachment VI). 5.1.1.6 once a transcript has been made of concern (s) received by an answering machine, the concern will be erased from the answering machine tape to preserve confidentiality. 5.1.2 Exit Processing (QI Files) 5.1.2.1 All personnel, excluding employees of or_ under contract to the NRC, terminating from Waterford 3' . who have a picture badge will exit through the Quality Team office and be requested to complete a Concern Disclosure Statement (Attachment II). 1
- a. Those individuals who decline'to complete _a- !
Concern Disclosure Statement shall be provided : with a secondary method of contacting the Quality Team with any concerns (see Attachment-III). i
- b. Exit processing is handled on a walk-in basis and appointments are not necessary. However, ,
the Quality Team office should be alerted, by ' telephone, to group releases which may be ; planned or scheduled outside of normal work;- hours.
- e. For convenience purposes, Quality Team' exit !
processing may be accomplished up to 72 hours i prior-to an employee's actual departure from Waterford 3. 5.1.2.2 Those individuals who complete Attachment II but do not state a concern will receive a Concern Form > (Attachment III)-and will continue their exit process. ; e b
T 09-01-1993 11:40AM- FROM WRT 3 USNRC 5047832232 TO , DRP R4 P.20- ~y . , SITE DIRECTIVE NO. W5.606 eEntergy MANAGEMENT MANUAL Operations VOLIME IV REV. NO. D. PAGE 6_ QF 15 5.1.2.3 Those individuals.who complete Attachment II indicating a concern (s) will be requested to participate in an interview with a Quality Team Specialist to establish the details of the concern (s).
- a. The foregoing is applicable to those personnel who are physically exit processed at the Quality Team office.
- b. Each individual directing concerns to the-Quality Team shall be afforded confidentiality if so requested via the Confidentiality Agreement (Attachment IV).
5.1.2.4 For each individual expressing a concern (s), a unique file number shall be assigned (i.e., QI-YR-XX); and a file shall be established for further investigation and tracking. 5.1.2.5 The Quality Team Specialist shall enter the concern (s) in the Quality Team Concern Assignment and Tracking Log (Attachment VI). 5.1.3 Alternative for Exit Interviews 5.1.3.1 For those individual who terminate their susployment - offsite or during off-shift hours, the Safety Review Manager will send a Concern Solicitation Letter package consisting of the following documents:.
- a. Concern Disclosure Statement (Attachment II);
- b. Concern Form (Attachment III);-
- c. Confidentiality Agreement (Attachment IV);
- d. Concern Solicitation Letter (Attachment V); and
- e. Self-addressed stamped envelope.
The individual is requested to complete Attachments II or III and IV and return them in the self-addressed stamped envelope.
us-01-1'J93 11:45&l FROM t#iT 3 USNRC 5047832232 TO DRP R4 P.11 f~~' s SITE DIRECTIVE No. W5.606 . I !Ente MANAGEMENT MA M I,
+' g ,rgy g, vowME IV REV. NO. O PAGE 1 0F 15 5.1.3.2 The Safety Review Manager shall ensure that an administrative record is maintained in regard to concern related letters and responses received by the Quality Team.
5.1.3.3 The Quality Team Specialist will identify those responses which result in concerns and establish files in accordance with Paragraph 5.1.2.4.- 5.1.3.4 The Safety Review Manager shall ensure that objective evidence of undelivered Concern Solicitation Eetter packages returned to the Quality Team is administratively retained. 5.1.4 Walk-In Interview (QI Files) 5.1.4.1 All' personnel employed or retained by Entergy Operations having access to the Waterford 3 facility can " walk-in" to the Quality Team office to discuss Waterford 3 concerns with the Quality Team. 5.1.4.2 The Quality Team Specialist receiving the concern (s) shall complete a Record of Concern form (Attachment
- 1) for each concern and shall establish a file in acccordance with Paragraph 5.1.2.4.
5.1.5 Waterford 3 Concerns Identified by External Sources 5.1.5.1 All concerns received by the Quality Team from sources external to the Waterford 3 site will be documented, investigated, and resolved in accordance with the applicable requirements of Section 5.1. 5.1.6 Confidentiality 5.1.6.1 Employees erpressing concerns will be assured of the strictest confidentiality in the handling and processing of concerns consistent with the provisions of Attachment IV. 5.1.6.2 Employees who encounter any acts of discrimination, either blatant or covert, resulting from direct or indirect involvement in previously expressed concerns may contact the Quality Team by any means available for the purpose of reporting such acts. s
09-01-1993 11:49AM FROM WAT 3 USNRC 5047832232 TO DRP R4 P.12
/~~ N SITE DIRECTIVE NO. WS.606
(")gyg(*r5Y MANAGEMENT MANUAL ggggg VOLUME IV REV. NO. O, PAGE 8,OF 1_S. S
- a. These reported concerns will be investigated by a Quality Team Specialist.
5.2 Investigation Planning and Process 5.2.1 Potential Reportability Screening and Safety System Assessment 5.2.1.1 Those concerns expressed to the Quality Team which are pertinent to Technical Specifications and/or may have an impact upon plant operability or safety system availability will be directed immediately to the Shift Supervisor for further evaluation per UNT-006-010, Event Notification and Reporting. Reference 2.5.
- a. A copy of the Potentially Reportable Event Report form should be inserted into the assiguad file where applicable.
5.2.1.2 Information relative to concerns for which immediate action is deemed a requirement will be relayed to the Vice President, Operations; the Director (s) of the organization (s) involved; and the Director, Nuclear Safety.
- a. Responsibility for relaying this information shall rest with the Safety Review Manager and, in his absence, with the Quality Team Specialist receiving such concern (s).
5.2.2 Investigation Plan Development 5.2.2.1 The Safety Review Manager shall assign a Quality Team Specialist (INVESTIGATOR block of Attachment I) for investigation of each concern. 5.2.2.2 The Quality Team Specialist shall initiate an Investigation Pla2 (Attachment VIII) for each concern file generated in accordance with Section 5.1.
- a. Each concern file will be assigned a separate sequential number (ITEM NO. column) with the concern described in detail (CONCERN column).
W-01-1W3 11: 5OAn FROM - WAT 3 UStRC 5047832232 TO DRP R4 P.13-f SITE DIRECTIVE NO. WS.606 ( - JEntergy MANAGEMENT M M Operatier.s v LuME IV REV. No. O PAGE 9 0F ]5 5.2.2.3 A comprehensive series of investigative steps, ' which are intended to resolve each concern identified, shall be defined (ACTION column).
- a. The action items are to be structured, if possible, to identify "cause."
5.2.2.4 As each ACTION is completed, the Quality Team Specialist shall indicate the actual date of - completion (COMPLETION DATE column). 5.2.2.5 As new developments arise, the Quality Team Specialist will revise the Investigation Plan by ' repeating the steps defined in Paragraphs 5.2.2.3 and 5.2.2.4. 5.2.2.6 Upon con:pletion of all planned investigative actions and resolution of the concern, the Quality Team Specialist shall indicate whether the concern was substantiated or unsubstantiated (SUBSTANTIATED YES/ NO column). 5.2.3 Qaality Team Deficiency Reporting 5.2.3.1 Each substantiated quality / nuclear safety concern, as applicable, shall be reported via a Condition Identification (CI) in accordance with UNT-005-002, Reference 2.6.
- a. If a concern regarding a programmatic deficiency is substantiated, a Quality Notice (QN) shall be generated in accordance with QAP-012, Quality Notice, Reference 2.8.
5.3 Resolution of Waterford 3 Concerns 5.3.1 The Safety Review Manager shall review each completed file and sign the acknowledgement at the bottom of the Quality Team Completed File Checklist (Attachment X) as an assurance that the file is complete. , NOTE: Reports may incluce several concerns if investigation completion is in the same general time frame. 4
09-01-1993 11:50AM FROM _1JAT 3 UStRC 5047832232 TO DRP R4- P.14-l .. l R eEntergy MANAfFENT MANUAL SITE DIRECTIVE No. W5.606 ; j Operations VotuME IV . REV. NO. 0 PAGE JO, OF 1_5, 5 ' a' l i 5.3.2 The Quality Team Investigation Report (QTIR) (Attachment IX) shall include the folle, wing: 1 5.3.2.1 personnel contacted during the investigation; 5.3.2.2 concern investigated in accordance with the i Investigation Plan (Attachment VIII); and 5.3.2.3 findings (results of investigation - concern substantiated or not substantiated). 5.3.3 Where the corrective action is unsatisfactory and/or : attempts at resolution have been unacceptable, the Safety Review Manager shall notify, by letter, the Vice President, Operations (copy to the Director, Nuclear Safety and the responsible director) requesting resolution and action (s) to prevent recurrence of the concern (s). , 5.3.4 The Safety Review Manager shall prepare a Quality Team Concern Disposition form (Attachment XI) to document completed files. 5.3.5 Upon completion of review of a completed file, the Safety Review Manager shall contact the concerned individual by forwarding a Concern Processed Letter (Attachment XII) and the Quality Team Concern Disposition Form (Attachment XI) associated with the concern.
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5.4 Categories of Concerna for Investigation NOTE: The following categories list and describe the areas of investigation and requireamnts relative to resolution of those specific areas. 5.4.1 Quality / Nuclear Safety Concerns 5.4.1.1 Quality / nuclear _ safety concerns shall be reviewed by the Safety Review Manager for categorization with similar concerna for investigation and resolution. 5.4.1.2 The Quality Team Specialist shall plan and investigate thosa concerns to assure compliance to applicable: O
09-01-1993 11:51AM FROM . WAT 3 LSRC 5047832232 TO. DRP R4 P.15 77 SITE DIRECTIVE NO. W5.606 (")Entergy HA M EMENT M UAL Operations VOMME IV REV. NO.'O PAGE pl 0F M
- a. drawings;
- b. specifications;
- c. codes and standards; and
- d. site procedures.
5.4.1.3 The investigation may encompass physical hardware inspections with assistance by qualified inspectors from site / contract personnel (ANSI N45.2.6/ASNT-TC-1A, Reference 2.11) or documentation / records reviews, or a combination of both. 5.4.1.4 The investigative process may entail additional interviews and lead into other areas of concern < review. 5.4.2 Management Related Concerns 5.4.2.1 The Safety Review Manager shall document all management related concerns on the Investigation Plan (Attachment VIII).
- a. Each concern of this nature shall be formally transferred to the appropriate responsible level of management for investigation and resolution. '
- b. The letter transferring the management concera(s) should contain a request for a response within 30 days from the date of transfer.
- c. The transfer of a management related concern !
completes the action required by the Quality ' Team to close the investigation.' Response by the cognizant manager should be inserted in the completed concern file to ensure documentation of the concern resolution.
- d. The level of detail of response by the !
cognizant manager is determined by the cognizant manager. Such response shonid contain adequate information to document the resolution of the concern.
09-01i1993 11:51R1 FROM UAT~3 USNRC 5047832232 TO DRP R4- P.16 - 8Entergy
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M A M MANUAL SITE DIRECTIVE NO. W5.606 Operations votts IV REV. NO. O_ PAGE J2 0F 15, 5 5.4.2.2 For those concerns' relevant to man rea reduction, utilize an ALARA Improvement Report in accordance with departmental procedure HP-001-015, Reference
- 2.9, as applicable.
5.4.2.3 For those concerns relevant to Industrial Safety / OSHA Guidelines utilize a Hazardous or Unaafe Condition Report in accordance with UNT-007-016, Reference 2.10, as applicable. 5.4.2.4 Those management concerns which are identical or closely resemble a previously submitted / closed concern may be reviewed, evaluated, and closed by the Quality Team without prior review by the responsible organization. a. Documentation associated with concerns closed under the aforementioned conditions shall contain written reference to the previously cited concern.
- b. For record purposes,-the Quality Team should l forward a periodic (annual) summary of repetitive concerns to the appropriate responsible director.
5.4.3 Intimidation and Harassment (I&H) I 5.4.3.1 concerns involving 1&H shall be processed in. accordance with this policy and the following additional criteria: . 1
- a. 1&H concerns require the identification of a protected activity and participation in a protected activity by the individual. '
Protected activity is defined in Paragraph 3.5. An individual shall be considered to'have engaged in a protected activity if his-involvement meets the criteria of Paragraph 3.5. I
09-01-1993 11:52Fri' F' ROM , LAT 3 IBRC 5047832232 TO DRP R4 . P.17 - [~ g SITE DIRECTIVE No. V5.606
! MANAG E NT HA M
/Entergy Operations VO N IV M . NO. g PAGE y W g
- b. As a minimum, the Investigation Plan (Attachment VIII) should include actions that, when completed, will have the capability to demonstrate whether any discriminatory acts may have occurred subsequent to the protected activity.
- c. Upon completion of the I&H action items, a letter may be transmitted to the Vice President,
- Operations.
e The letter should reiterate the concern, the investigative actions taken, the results of the investigation, and other actions, if any.
- A copy of the letter will be maintained in the applicable concern file.
5.5 Analysis of Inve',tigative Results and Resolutions 5.5.1 The Quality Team is ceamitted to plan and investigate quality / nuclear safety concerns in a manner that focuses on determining validity and the need for corrective action, as appropriate. 5.5.2 To support "cause" determination, the Safety Review Manager shall implement and maintain a trending program which will provide management with a basic " feedback" mechanism required to meet Waterford 3 requirements. 5.5.2.1 This mechanism is the Quality Team Trends report (Attachment XIII). 5.5.2.2 The basic elements of the trending program center on ! data retrievability and sorting to suit Waterford 3 requirements. 5.5.2.3 The key attributes are:
- a. concern categorization and coding; and
- b. statistical data and evaluation.
5.5.3 The Quality Team Trends report and the Investigation Plan provide for detailed tracking of status and actions scheduled for resolution. I
+ eEntergy
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MANA N MA WAL SITE DIRECTIVE NO. W5.606
,% VOLUME IV REV. NO. O PAGE 1_4 0F 15, P
5.6 Management Reports 5.6.1 The Safety Review Manager shall compile Quality Team data and issue the following to the appropriate Waterford 3 management: 5.6.1.1 Quality Team Monthly Status Report (Attachment XIV). 5.6.2 In addition to the safety significance and "cause" determination / reporting addressed in Paragraphs 5.2.1.2 and ~; 5.5.2, the analysis for generic implications performed on substantiated concerns shall be reported promptly to ! Waterford 3 management. 5.7 Quality Team Records 5.7.1 The Quality Team files are not considered quality records '1 and as such are not public documents. a. However, due to the nature and guarded importance of the-files, every attempt will be made to organize, control, and protect the records.
- b. ANSI N45.2.9, Reference 2.12, will be used as a gnide to assemble, control, and store these files.
1 5.7.2 The MASTER file is the designated working (in process) file utilized by Quality Team Specialists and shall be maintained in the fire rated file cabinet located within the Quality Team office during investigation of the concern. ; i
- a. Upon conclusion of the concern investigation the contents of the MASTER file shall be indexed (Attachment I) and.
placed in the Waterford 3 Records Center vault. 1 i 5.7.3 Audio tapes upon which interviews have been recorded in conjunction with a concern or. its investigation shall be .! erased when the concern file has been closed. I 5.7.4 Master files which have been completed'and closed for i greater will than 2 years will be microfilmed and the hard copies be destroyed. ! i 5.7.5 All Safety Review personnel having access to Quality Team l l information shall be required to sign a Quality Team Disclosure Statement (Attachment VII).
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BT 'd . PM d80 01 2CMPOS NE C 12 N W TT N-TW
SITE DIRECTIVE NO. W5.606
<." 8Entergy- MANAGEM MAL
~ Operations VOLUE IV REV. No. O PAGE 15 0F 15 ,
5.7.6. Access to the in-p ocess and closed files by other than - Quality Team personnel shall be authorized by the Vice President, Operations.
- s. In the event the Vice President, Operations is unavailable the Director, Nuclear Safety or Director, Site Support may provide this authorization.
5.7.7 The Quality Team program shall be subject to periodic audits conducted by personnel designated by the Vice President, Operations. 6.0 ATTACHMENTS 6.1 Attachment I QUALITY RECORD OF CONCERN (1 Page) 6.2 Attachment II QUALITY CONCERN DISCLOSURE STATEENT (1 Page) . 6.3 Attachment III CONCERN FORM (1 Page) , 6.4 Attachment IV CONFIDENTIALITY AGREEMENT (1 Page) a 6.5 Attachment V CONCERN SOLICITATION LETTER (1 Page) 6.6 Attachment VI QUALITY TEAM CONCERN ASSIGNENT AND TRACKING LOG (1 Page) 6.7 Attachment VII QUALITY TEAM DISCLOSURE STATEMENT (1 Page) 6.8 Attachment VIII INVESTIGATION PLAN (1 Page) 6.9 Attachment IX QUALITY TEAM INVESTIGATION _ REPORT (1 Page) 6.10 Attachment X QUALITY TEAM COMPLETED FILE CHECELIST (1 Page) 6.11 Attachment XI QUALITY TEAM CONCERN DISPOSITION FORM'(1 Page) 6.12 Attachment XII CONCERN PROCESSED LETTER (1 Page) i 6.13 Attachment XIII QUALITY TEAM TRENDS (1 Page) 6.14 Attachment XIV QUALITY TEAM MONTHLY STATUS REPORT (1 Page) - 6.15 Attachment XV HDT LINE DAILY LOG (1 Page) 9 NOTE: Sample documents are depicted in Attachments I through IV.. Minor changes which do not alter or affect the content of those documents may be made without the necessity.for publication of. a formal revision to this directive. p 6T*d PB d8G 01 Fr77eMr05 ~)Bts) E ltrl WOBd WOCS:TT E66T-10-60
8Entergy mAnw mm SITE DIRECTIVE NO. W5.606 ATTACH W T I
~ Operations V IMME IV REV. NO._g PAGE I OF 1 QUALITY RECORD OF CONCERN INSTRUCTIONS File No. !
PER$001AL/ CONFIDENTIAL - DATE/ TIME OF CALL RECEIVED OR INTERVIEW CONDUCTED: l _All/FM RECEIVED BT: Ans. Device? Yes/No CONCERNED INDIVIDUAL: ' SOCIAL SECURITY NO.: ADDRESS / STATION NO.: TEIEPHONE NO.: ALTERNAIE PHONE: EMPLOYER: DATES OF EMPIDTHENT: POSITION: STATEMENT OF PROBLEM: System I.D.: Bldg / Location: t Procedure: Hardware / Equipment I.D.: Contractor /Entergy: Date/ Time: Records: Activities in Progress: ADDITIONAL INFORMATION: SUPERVISOR / FOREMAN NOTIFIED: YES _ NO _ (Date/ Time) SUPERVISOR / FOREMAN NAME: , IF TES, RESULTS:
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IF No, WHY N0r7 StAMF.S OT OTHER INDIVIDUALS WHO MAY BE ABLE TO PROVIDE ADDITIONAL OR SUP INFORMATION RELATING TO SUBJECT CONCERN METBDD/ TIME FRANE ESTABLISHED FOR CONTACTING THE INDIVIDUAL: - QUALITY l#ve.STIGATOR ASSIGNED TO INVESTIGATION:
.t DE*d Pd celG 01 EEEEEB4POS DdNSn E lt:rl WOdd l#PS:TT E661-10-60
SITE DIRECTIVE No. V5.606 8Entergy
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N^m MAL A m c e ur II Operations VOLIME IV REV. NO. O PAGE 1 OF 1-QUAUTY CONCERN DISCLOSURE STATEMENT i A. Name: Bader. No. : _ __ SS N : DepartmenuWork Group : __ Company: There are castmg adverse condstions which could,(1) affect the safe operstmas of _ Waterford 3 SES and/or, (2) affect the health and safety of Waterford 3 site persoonal Yes No. and/or the geocral pubhc. If answered "NO'. proceed to Semion "C; if ansacred 'YES*, omnplete Secnons "B' nd 'C". t
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B. ladostrial Safety-Relaamd concern : rw-p. a " Safety Pa= - = r Form," '-
- if apphcabic, and attach it to this statesacat.
-J =1-Related concern : Complete an
- ALARA Improvement Report,"
if applicabic, and attach k to this matement. l l > f' " Qaanty.Relased concern : Identify the concx:ro in detailin the space provided telow: t l Confidentiality requested : Yes No (Pleans faitial) C. I certify that the abcne informarv= la true and accurare to the best of my knowledge. . Employec/ Contractor Signaccre/Date Quality Team Signature / Date Actual Departme Date : L TE*d Pd cl&! 01 ECEEEBLPOS 'kt si E lurt WOdd WUPS:TT E66T-TO-60
4
- SITE' DIRECTIVE'No. W516o6 ggggg g NANAGEMIUfT MANUAL ~ AITACIINENT III VOLUME IV
. Operations -arv.-No. o Paar 1 or 1 ,1 4
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__h CONCERN FORM ( y T
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^ Operations 285 . ;
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Entergy Operations v.t...< o..... s y Waterford 3 S.E.S. Quatty Team 1 As you are well aware. Waterford 3 was buik to operate safely. Esmergy Operanons appacasses youper L in helpmg us maatam a safe operstag plars. If you have any cancums about Waterford 3's alulley so . ' operate safely, please sail us so that we may looit imo them. When you amit us about nacieer aufery or i
- qualiry concems, please be as specific as you can. For example, if your concem mvolves aguymans, seu us which piece of eququnent, where it is located. and explain the probiana.
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If you prefer, you can set up an imerview or register a concent wid the OUAIJTY TEAM while on she ' or from wnhin the Gremer New Orleans asua by calling 739 6600. Also, you can cantass us using our G toll. free munber.1808 6218326, ham any locanon watun the W United States. Agam, pisses be as spec Sc as possdde about the dotads of your concem. You do not have to give your narne to share your concems wids us. However, we wooid like so have your . address and phone suunber for two reasons: (1) we may need addidonal infunnanen so thM we can do a good job oflooking imo your caar- ras. (2) we would Hice to let you lasaw what we found out and what - l we did about your concem. 'Ihe QUAUTY TEAM cannot issue a response if you do not give your mase , and address. Name Phans No. 3 _ :j Addgggg
-4 City same -
i Zipcode _ l u Es. W i % orisite '
- i I PItase deserthe your Costcan Ort the back of this local and isnant in to us. If yog ast Mill %'M Waterford 3. this c- Form can be roused disoody to the QUAUTY TEAM unng the onske mail '
system. If you have left the she, our carapl=a= maihng addrums is: Entergy Operemons , waservore s j
. P.O. Box 0106 KHlona, LA.700054105 !
gg *d - Pd dNG 01 NNPOS DBNSn E ltri WOdd , WSS:TT EG6T-TO-60
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v < LSITE DIRECTIVE No. W5.606' Entergy . HANAG N NT MANUAL ATTACBEENT.IV . . . .
~ Operations Vol.uns Iv- .REv. No.3 PAGE 1 0F Q q
CONFIDENTIAI.ITY AGItIDENT
=
s I have information that I wish to provide in confidence to Entergy Operations. L
-Ise. I. request an espress pledge of confidentiality as a condition of '!
providing this Lafousstion to Eatergy operations. .inc. I will.not provide this inforestion voluntarily to Eatergy Operations Inc.' without such i confidentiality being extended to me. I It is my understanding, consistent with its legal obligations, Entergy - Operations, Inc. by agreeing to this confidentiality, will adhere to the. . following conditions: l t (1) Entergy Operations, Inc. will not identify as by mans or personal . identifier is any Entergy Operations, Inc. Laitiated document, . conversation, or c-4 cation released to the public which relates to . l the information provided by ae. I understand.the term "public release" , to encompass any distribution outside of Eatergy Operations, Inc. with a the exception of other public seemeies which may require this . information la furtherence of their responsibilities under law or public . trust.- -.!
's (2) Est.ergy Operations, Inc. will disclose my identity within Entergy Operations, Inc. only to the estent required for the conduct of Entergy - ;i Operations, Inc. related. activities. -;
(3) During the tourse of the iavestigation, Entergy Operations Inc. will also make weary effort consistent'with investigative needs of Entergy i Opsretier.s lac.' to avoid actions which weald clearly be espected to
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result in the disclosure of myl identity to perseas subsequently ; contacted by Entergy operations, Inc. At a later atage I understand :; that even though Estargy Operations, Inc. will rake' every reaseeable : effort to protect my identity, my ideatification could be compelled by , orders or subpoemas issued by courts of law, hearing. beards,- or similst legal entitses. In such cases, the basis for graattag this premise of-. l confidentiality and any other relevant facts will be comausicated to the authority ordering the disclosure in an effort to maintain my_- ; confidentiality.: If this effort proves unsuccessful .a representative' of Eatergy Operations,' Inc. will attesyt to' inform me of any sach actica l before disclosing my identify. I also understand that Entergy Operations, Inc. will consider me to have waived my right'of confidentiality if I'should take any action that any be ;i reasonably espected to disclose my identity. I further understand that .1 Entergy operations, Inc. will consider me to have waived my rights to : i! confidentiality if I provide (or have previously provided) information e' r. if circumstances indicate t. hat I an intentieaaily providias-false'inforestion to - (l ; Entergy operations, Inc., this confidentiality will be deemed waived.- -! 5 I have read and fully understand the contents of this agreensat. .I agree with its provisions.
. :I Date Rams J -
Address: . , Agreed to on behalf of Entergy Operations ~ 'j l l Signature Signature u -
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.c SITE DIRECTIVE NO. W5'.606 8Entergy: ' MAGMNT MEL ATIAC M NT V Operations voL a Iv nav. x0. o PAGE 1 0F 1 CONCERN SOLICITATION LETTER Date Name Address City, State '
Dear :
Entergy Operations, Inc. has implemented the Quality Team Program.to provide all employees at.Waterford 3 a confidential avenue to disclose any quality concerns they may have. A part of the program requires that upon termination / release.from Waterford 3, all personnel be requested to complete'a Quality Concern Disclosure Statement. Our records indicate that you were not available to participate in the Quality Exit Interview. A Quality Concern Disclosure Statement has been enclosed. . Please complete it in accordance with the instructions on the back of the form and return it in the envelope provided. This action will permit the Quality Team to finalize the exit process in your case. Also enclosed with this letter _ is a QUALITY TEAM CONCERN FORM for your ; retention and future use, if desired. Although we would appreciate having your name and badge number on the Quality Team Concern Form for follow-up activities, it is not required. Should you have any questions or wish to talk with a member of the Quality Team, please call us anytime at 739-6600 or nationwide, toll free at 1-800-621-TEAM. Thank you for your cooperation. Sincerely, Safety Review Manager Waterford 3 SES Enclosures 9 PE*d' #8 dda 01 M77N#0S DUNSri E lte WOM:1 WO99:TT E661-10-60
t SITE DIRECTIVE NO. W5.606 - j")N'- ( Entergy RNAGDENT N A m m VI , vottas IV arv. no..o Fact 1 or 2
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A_Entergy SITE DIRECTIVE NO. W5.606 HANAGMENT MANUAI, ATTA N NT VII
~~ Operations VoIuME IV REV. No. O PAGE 1 0F 1 QUALITY TEAM DISCIoSURE STATEMENT Personnel performing or directed to perform any service, investigations, audits, or rendering any and all administrative assistance to the Quality Team which may result in access to or contact with Quality Team files or other matter pertaining to or generated from the Quality Team program shall be aware of the confidentiality guaranteed by Entergy Operations, Inc.
to concerned individuals who choose to use the Quality Team program. To maintain this confidentiality, it is mandatory that all notes, conversations, - documents, records, and any other information which pertains to active or closed concerns be handled on a need-to-know basis and with the strictest ecnfidence. If any doubt should exist in relation to the written or spoken transmission, reporting and/or discussion of such information to or with anyone other than designated Quality Team members or the Vice President, Operations, the person having such doubts is obligated to consult with the Safety Review Manager prior to transmitting, releasing, reporting or otherwise divulging that information. In cases of this type, the decision of the Manager shall prevail and can be overridden only by the Vice President, Operations or higher authority. Violation of this confidence shall be dealt with from executive level and in the case of proven or admitted violation by a Company employee, disciplinary action shall result. Acknowledgement: I have read and understand the content and intent of the above statement.
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Signature / Date se.a va asa 01 eccerswes m en t wn wasa ww.sm test-le-se
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8Entergy WAEMT NUAL SITE DIRECTIVE NO.-WS.606 ATTAC M NT IX
~ Operations VOL M IV REV. NO. O PAGE'1 0F 1 QUALITY TEAM INVESTIGATION REPORT l
t QT INVESTIGATION REPORT FILE f _ Page of .
SUBJECT:
ACTION ITEM # PERFORMED BY: f OBJECTIVE OF INVESTIGATION: i DETAILS: r i O s eMe b Signature Date P t E *d PB d80 01 N77WPOS 38NSn E ltR't WOdd WUBS:TT E66T-10-60
A=~ ggy MANAGEMENT MANUAL SITE DIPACTIVE NO. WS.606 ATTACHMENT X Operat orts 1 M IV REV. NO. PAE 1 F 1 QUALITY TEAM COMPIITED FILE CHECKLIST FILE NO. NO DOCUMENT TITLE ATIG NO OF INIT NO PAGES
- 1. QUALIIT RECORD OF CONCERN I
- 2. QUALITY CONCERN DISCLOSUPI II STATEHENT
- 3. CONFIDENTIALITY AGRW WhT IV
- 4. QUALITY TEAM. INVESTIGATION VIII PLAN (LATEST COMPLETED REVISION)
- 5. QUALITY TEAM INVESTIGATION II REPORT (S)
- 6. QUALITY CONCERN DISPOSITION FORM XI
- 7. CONCERN PROCESSED LETTER (AS _KII APPLICABLE)
- 8. MISCELLANEOUS DOCUMENTS TOTAL NUMBER OF FILE PAGES FILE REVIEWED /
Safety Review Manager Date 6E*d Pd cB3 01 EENNPOS M61 E lurl 108d WBS:TT E66T-TB-60
sin DInsCTIVE NO. vs.60s < Qymatorer- "*EEE WUAL ATIACB E R H -
. Operations VOLDE IV M . E. A PAE 1 QF 1. .
P 1 QUALITY TEAN CONCERN DISPOSITION FORM -t FILE f: DATE OF PREPARATION: , CONCERN (S): , 1 I FINDINGS (S): CORRECTIVE ACTIONS (S) i TAEN: A i CLOSURE STATEENT: t t t
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n: ,- .; SITE DIRECTIVE NO. W5.606'-
+- Sgaggygy
- MANAGEMENT MANUAL AframMrWT XII. ;
~ % ems VOLUME IV.
EEV. NO. O PAGE 1 0F 1 : CONCERN PROCESSED LETTER ! i (Date)
Dear:
The Quality Team has processed your concern (s) f as indicated in the e disposition section of this. letter. 'If you have questions.regardina the.- disposition or additional items of concern, please contact us on site at -i Building 65 Extension 739-6600, or toll free in the United States at i 1_-800-621-TEAM. , We appreciate your interest in the Quality effort at the Waterford'3 SES. Sincerely, [ i i Safety Review Manager. - Enclosure i i
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PI o gi . a QUALITY TEMi TRENDS y
- D g "A" Code Category Not la Open Closed Substantiated Substantiated Hot Walkin-in ROF/ Termination l
; 1. Unqualified Personnel
- 2. Procedural Violations
- 3. Harassment / Intimidation
- 4. Pipe Clesaliness Violation f
- 5. Material Traceability O
- 6. Defective Installation y
'7. Inadegnate Procedures ) ! 8. Falsification of Records ] -
- 9. Inadequate Training
% 10. Material control h 11. Inadequate Reporting S 12. Document Control / Records $ 13. Inadequate Inspection M 14. Safety (Industrial) h 15. Inadequate Eng. Definition
- 16. P gement/ Nissen Relations
- 17. Drugs
- 18. Program Breakdown g er h 19. Security-h N 20 Health Physics 0
= $ -
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9 8Esotorgy . SITE DIRECTIVE NO. W5.606
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MANAGEMENT MANUAL ATTACRISET XIV Operahs _ VOLIM IV REV. NO. O PAmt1_0F 1 QUALITY TEAM MONTRLY STATUS REPORT
.i V3QTM87-IIII
.A4.07 IQA '
DATE: TO: FROM:
SUBJECT:
Quality Team Monthly Report During the month of , 19%X,. opened: new Quality Team files were ' Attached is a listing of all outstanding /open Quality Team concerns which require resolution. l Safety Review Manager i Attachment , cc: R.F. Burski Waterford 3 Records Centar - w/o atta;:hments ' A h
;- EE*d - PM ddQ 01 F N '4'OS m Elt#1 WOdd WdOO:EI E66I-10-60 -
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VE'd "10101 SITE DIRECTIVE NO. W5.606 .g
~ Entergy MAGE!ENT MANiiAI. ATTACESurf XV '
Operations vor. m Iv arv. no. o_ PAa J 'r 1 i i P HOT I71rK MILY LOG DATE ENTRY INITIALS t j i 1 h i i l i i l l l I i t'E 'd PB d80- 01 EEEEE8!.,POS DtNSn E 10M: WDdd WdOO:ET E661-10-60}}