ML20058Q406

Package Consisting of Employee Concerns Programs

ML20058Q406
Person / Time
Site:	Comanche Peak
Issue date:	08/30/1993
From:	NRC
To:
References
NUDOCS 9312290078
Download: ML20058Q406 (6)

Text

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.- - EMPIDYEE CONCERNS PROGRAMS PLANT NAME: Comanche Peak Steam Electric Station 1

LICENSEE: TU Electric DOCKET NOS.: 50-445; 50-446 I A. PROGRAM

1. Does the licensee, have an employee concerns program? l (Yes er No/ Comments)

YES

2. Has NRC inspected the program?

i YES, Reports # 50-445/92-60; 50-446/92-60 and # 50-445/88-23; 50-446/88-20 B. SCOPE

1. Is it for:

a. Technical? (Yes, No/ Comments) YES

b. Administrative? (Yes, No/ Comments) YES

c. Personnel issues? (Yes, No/ Comments) YES

2. Does it cover safety-as well as non-safety issues? ]

(Yes ptNo/ Comments) YES

3. Is it designed for:

a. Nuclear safety? (Yes, No/ Comments) YES

{

b. Personal safety? (Yes, No/ Comments) YES

c. Personnel issues - including union grievances? j (Yes oLNo/ Comments) l YES, BUT THE PROGRAM HAS NO AUTHORITY TO FILE GRIEVANCE ON 1 BEHALF OF THE PERSON

4. Does the progmm apply to all licensee employees?

(Yes ntNo/ Comments) YES K-0 1 9312290078 930830 PDR P

ADDCK 05000445 )

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6. Does the licensee require its contactors and their subs to have a similar.

program? (Yes nr No/ Comments) 4 NO; EVERYONE BADGED ONSITE IS PROVIDED~ . .  :

SAFEmAM ORIENTATION OR GIVEN INFORMATION ABOUT THE PROGRAM

7. Does the licensee conduct an exit interview upon terminating employees asking. ,

if they have any safety concerns? (Yes nr No/ Comments)

.j YES C. INDEPENDENCE ~

I. What is the title of the person in charge? MANAGER, SAFETEAM 2 Who do they repon to? MANAGER OF REGULATORY AFFAIRS

3. Are they independent of line management? YES

4. Does the ECP use third party consultants?  !

YES; INVESTIGATORS ARE THIRD PARTY CONSULTANTS, SUBCONTRACTED TO UTILITY TECHNICAL SERVICES (UTS), THE OWNER OF THE PROGRAM

5. How is a concern about a manager or vice president followed up?

THE ISSUE IS TAKEN TO AN INDIVIDUAL AT LEAST ONE .

STEP IN THE CHAIN OF COMMAND ABOVE THE PERSON IN QUESTION. THAT INDIVIDUAL HAS THE RESPONSIBILITY AND AUTHORITY TO ADDRESS AND RESPOND TO THE MATiER. AN INTERNAL REVIEW.

ORGANIZATION WHICH REPORTS TO THE CHAIRMAN, TU ELECTRIC, COULD ALSO BE CALLED IN TO FOLLOW '

UP ON SUCH A MATTER.

D. RESOURCES

1. What is the size of the staff devoted to thh program?

10 PEOPLE (3 INVESTIGATORS, 5 INTERVIEWERS (1 FULL TIME,4 PART TIME), PROGRAM MANAGER, AND SECRETARY) c' tv l, / -

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2. . What are ECP staff qualifications (technical training, interviewing training,-

investigator training, other)? ,

MANAGER RECEIVED TRAINING FROM UTS ON OVERALL..

OPERATION OF THE PROGRAM. ALL INTERVIEWERS HAVE RECEIVED INTERVIEWING TRAINING. INVESTIGATORS ARE TRAINED AND SUBCONTRACTED FROM UTS. TUE CORPORATE - ,

SECURITY INVESTIGATORS ARE CERTIFIED BY THE STATE OF.

TEXAS. JOB DESCRIITONS AND CRITERIA ARE IN PLACE FOR '

ONGOING EVALUATION OF STAFF PERFORMANCE.

h E. REFERRALS

1. Who has followup on concerns (ECP staff, line management, other)?- ,.

LINE MANAGEMENT, EXCEIrr FOR THOSE ITEMS RELATED TO NUCLEAR SAFETY, WHICH ARE HANDLED BY SAFETEAM INVESTIGATOPS. CORRECTIVE ACTIONS ,

ARE TRACKED THROUGH THE EXISTING PROJECT TRACKING SYSTEM. SAFETEAM PROGRAM OFFICE PROVIDES A WRITTEN RESPONSE TO EVERY CONCERN. -

F. CONFIDENTIALITT I

1. Are the reports confidential? 4 (Yes or No/ Comments) ,

b YES

2. Who is the identity of the alleger made known to (senior management, ,

ECP staff, line management, other)?

(Circle, if other explain) s ONLY THE ECP INTERVIEWER STAFF KNOWS THE NAME UNLESS THERE IS A NEED TO KNOW AND THE CONCERNED EMPLOYEE HAS SIGNED A RELEASE. '

3. Can employees be:

a. Anonymous? (Yes, No/ Comments)

YES

b. Repon by phone? (Yes, No/ Comments)

YES '

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.G. FEEDBACK' I.

Is feedback given to the alleger upon completion of the followup?

(Yes er No - If so, how?)

YES, RESPONSE 1S BY Lb111A

2. Does program reward good ideas?

NO, ALTHOUGH APPRECIATION IS EXPRESSED TO PEOPLE FOR THE ISSUES RAISED, THESE FINDINGS ARE NOT PUBLICLY SHARED REWARDING GOOD IDEAS IS NOT ONE OF THE ESTABLISHED OBJECTIVES OF THIS SPECIFIC PROGRAM.

3. Who, or at what level, makes the final decision of resolution?

THE SAFE 1EAM REVIEW COMMITTEE, CHAIRED BY THE ,

MANAGER, SAFETEAM, WHO SIGNS ALL OF THE RESPONSE LEITERS

4. Are the resolutions of anonymous concerns disseminated?

NO, BUT THE RESOLUTION MAY BE REVIEWED BY-CONCERN NUMBER IF REQUESTED.

5. Are resolutions of valid concems publicized (newsletter, bulletin board, all hands meeting, other)?

YES, THROUGH GROUP MEETINGS AS PART OF  ;

CORRECTIVE ACTIONS. THEY ARE NOT PUBLICIZED VIA NEWSLEITux OR BULLETIN BOARDS.

H. EFFECTIVENFSS

1. How does the licensee measure the effectiveness of the program? .

UTS PERFORMS AN ANNUAL AUDIT OF THE PROGRAM.

THE QUALITY ASSURANCE ORGANIZATION PERFORMS AUDITS OF THE PROGRAM. UNSOLICITED COMMENTS REGARDING THE PROGRAM ARE REVIEWED. A LOW PERCENTAGE (< 1/2 OF 1 %) OF CONCERNEES HAVE RECONTACTED THE OFFICE EXTRESSING DISSATISFACTION WITH THE RESOLUTION OF THEIR CONCERN. A REVIEW COMMI1 TEE OF DIVERSE MANAGERS, AS WELL AS SENIOR UTILITY MANAGEMENT, ALSO PROVIDES OVERSIGHT OF THE PROGRAM.

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2. Are concerns: 3

a. Trended? (Yes or No/ Comments)-

YES, AND CATEGORIZED.

b~. Used? (Yes or No/ Comments)

YES

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3. In the last three years how many concerns were raised? ,

1207 1

Of the concerns raised, how my were closed?  ;

1195 s

What percentage were substantiated?

WHETHER A CONCERN 15 SUBSTANTIATED IS ONLY ,j TRACKED FOR WHAT ARE TERMED " CLASS 1" - !i CONCERNS. A CLASS 1 CONCERN IS ANY CONCERN INVOLVING NUCLEAR SAFETY, PLANT OPERATION, .

ENVIRONMENTAL MATTERS, OR l HARASSMENT / INTIMIDATION ISSUES. OF THESE ' i ISSUES, 8.7% (26/299) WERE SUBSTAN'IIATED OVER THE d LAST THREE YEARS. I l

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4. How are followup techniques used to measure effectiveness (random survey, l interviews, other)?

THE CLOSING PARAGRAPH OF THE CLOSURE LbHER -

ASKS THE CONCERNEE TO CONTACT THE S AFETEAM ,

ORGANIZATION IF ANY QUESTIONS REMAIN.  !

5. How frequently are internal audits of the ECP conducted and by whom?

INTERNAL AUDITS ARE PERFORMED ON REQUEST.

UTS, THE OWNER OF THE PROGRAM, PERFORMS AN ANNUAL AUDIT. I i

. I. ADMINISTRATION / TRAINING: I

.)

1. Is ECP prescribed by a procedure? (Yes or No/ Comments)

YES j

2. How are employees, as well as contractors, made aware of this pmgrar*

• . (training, newsletter, bulletin board, other).?

POSTED SIGNS, FLYER HANDOUTS, GENERAL l EhiPLOYEE TRAINING, PERSONEL PROCESSING ORIENTATION, COhiPANY ORIENTATION. .;

ADDITIONAL CONIMENTS: (Including characteristics which make the program l

especially effective, if any.)

1. SENIOR MANAGEhiENT'S APPARENT COMMITMENT TO i THE PROGRAM.

2. CONFIDENTIALITY

3. STRONG REVIEW COMMITTEE

4. PROFESSIONAL HAhTLING OF CONCERNS i

5. SEVERAL COMPANIES HAVE VISITED THE UTILITY TO  !

LEARN ABOUT THE PROGRAM AND TU ELECTRIC'S i IMPLEMENTATION. '

)

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NAME: L. A. YAhTELL 1

TITLE: CHIEF, REACTOR PROJECT SECTION B PHONE: (817) 860-8182 I

DATE COMPLETED 8/19/93 I

..r REVIEWED /

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ATE: N 3 I DIRECTOR, DRP l

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.. ;j COMANCHE PEAK ST2AM El.ECTRIC STATION' STATION ADMINISTRATION MANUAL  ;

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• EMPI.DYEE CONCERNS AND EMPI4YEE PROTECTION a

l PROCEDURE NO. STA-ll4 REVISION NO. I SCRC MEETING NO. b - O (( DATE: . / ' .30 - 93 EFFECTIVE DATE: Z '3 ~ 3 l

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PREPARED BY: (Print) (L $ d v1 f CL b VY16 I EXT.07 / 4 l

TECHNICAL REVIE'J BY: (Print)[d. Larrt! $f o elebac a Exr.(,/,o2 I

APPROVED BY:

M DATE: // E D.

.VICE PRESIDENT, NUCLEAR OPERATIONS .

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CPSES PROCEDURE NO. ,

STATION ADMINISTRATION MANUAL. STA-114 EMPLOYEE CONCERNS AND EMPILYEE PROTECTION REVISION NO. 1 PAGE 2 0F 8-

~1.0 PURPOSE i

This procedure establishes a method for employees to register nuclear complaints or concerns. It describes the protection afforded to employees who pursue these co= plaints / concerns or provide information to the Nuclear Regulatory Commission (NRC). ,

2.0 APPLICABILITY This procedure applies to Nuclear Engineering and Operations (NED)

=i

. personnel and all CPSES personnel, including contract personnel assigned to CPSES.

3.0 REFERENCES

3.1 Title 10, Code of Federal Regulations, Part 50, Section 7-(10CFR50.7), i E=ployee Protection .

3.2 Title 10, Code of Federal Regulations, Part 19 (10CFR19), Notices, instructions, and Reports :o Workers; Inspections. l

'.3 TNL 1.06, Regulatory Posting Requirements  ;

3.4 The Energy Reorganization Act of 1974, Section 211 -

3.5 NEO Policy No. 201, Employee Concerns and E=ployee Protection 3.6 NEO Policy No. 206, Cooperation in Internal Investigations 4.O DEFINITIONS / ACRONYMS 4.1 SAFETEAM l SAFETEAM is an ad=inistrative pro 5:a= established to help identify and )

investigate concerns of workers at CPSES. The program is available to CPSES votkers and for=er workers at any ti=e and provides an opportunity '

for site workers to report concerns they =ight have as they leave the project. The pro 5 ram is ad=inistered through an on-site office by the .

SAFETEAM Manager.

4.2 Hotline l (

The Forline is a program intended to encour the reporting of quality l concerns via a dedicated telephone line to the offices of the Texas l Utilities Director, Corporate Security, located in Dallas.  !

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CPSES PROCEDURE NO.

STATXON' ADMINISTRATION MANUAL STA-114-EMPIDYEE CONCERNS- AND EMP14YEE PROTECTION REVISION NO. 1 PACE 3 0F 8

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5.0 RESPONSIBIETTIES 5.1 Manarement' Personnel. NEO Group 5.1.1 Managers have an obligation and responsibility *o address nuclear concerns of employees under their supervision and to resolve those  ;

concerns in a manner that vill. protect the health and safety of I CPSES personnel and the public, without discrimination towards employees who raise such concerns. .

5.1.2 Responsible for posting Form NRC-3 and Section 211 of the Energy Reorganitation Act of 1974 (.eference Section 6.11 of this procedure).

5.2 SAFETEAM Manarer The SAFETEAM Manager is responsible for the establishment and 3 i=plementation of an effective, independent SAtt1 TAM program. The SAFETEAM Manager is responsible for maintaining this procedure current.

5.3 Vice President and Corporate Secretarv of TU Serd ces The Vice President and Corporate Secretary of TU Services, throu5h the Director, Corporate Security, ir assigned responsibility for the Hotline Program in order to achieve a desired level of independence from the nuclear organitation.

6.0 INSTRUCTIONS 6.1 E=ployees =ay pursue their co= plaints or concerns regarding nuclear

=atters until they feel the issues are satisfactorily resolved, without fear of discrimination or reprisal by TU Electric. This protection from discri=ination or reprisal also applies to situations where an. employee:

(1) notifies his/her employer of an alleged violation; (2) refuses to engage in any practice made unlawful by the Energy Reorganitation Act of ,

1974 or the Atomic Energy Act of 1954, if the e=ployee has identified the alleged violation to his/her employer; (3) testifies before Congress or

• at any Federal or State proceeding regarding any provision of the Energy Reorganitation Act of 1974 or the Atomic Energy Act of 1954; (4) provides the NRC with information about possible violations; (5) requests NRC' action, (6) testifies in any NRC or DOL proceeding, or (7) co=mences or participates in a proceeding under Section 211 of the Energy Reorganitation Act of 1974 6.2 Employees are encouraged to provide any safety complaints or concerns to their supervisors and managers for resolution, and to use the CPSES pro 5 rams for reporting conditions adverse to quality. If they feel that their concerns are not being adequately addressed, employees may present their concerns in writing to their immediate supervisors with copies to the next icvel of manageuent.

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w CFSES PROCEDURE NO.

STATION ADMINISTRATIO24 MANUAL- STA-ll4

' EMPLOYEE 'ONCERNS C AND EMPLOYEE PROTECTION REVISION NO. l' PAGE 4 OF 8 6.2.1 The supervisor shall thoroughly consider the significance of the concern and should inform the employee of the results of the evaluation of the concern. If the concern is written, the supervisor should all present his-evaluation to his managen!ent, in writing, so that further resources can be employed as necessary.

6.2.2 If management determines that the concern is quality-related and that an investigation may be warranted, they should notiry the SAFETEAM Manager.

6.2.3 If a concern, complaint, or allegation is quality-related and a formal review (investigation) is appropriate,.the SAFETEAM Manager should be contacted to determine whether or not an investigation of the particular matter has already been conducted, is in progress, or is scheduled. If the quality-related investigation is conducted outside of the SAFETEAM process, a copy of the results should be forwarded to the SAFETEAM Manager.

6. 3 The employee may, at any time contact any of the following members of TU l Electric Management directiv:

6.3.1 Director / Manager 6.3.2 Vice President 6.3.3 Group Vice President, Nuclear 6.3.4 Executive Vice President, TU Electric - Production Division 6.4 An employee may contact the Nuclear Regulatory Co= mission with a concern or complaint at any time whether or not the e=ployee has first raised the concern or complaint with his/her supervision or with TU Electric Management.

Any empicyee may co==unicate directly with the Nuclear Regulatory Commission (NRC), per Reference 3.2, by calling or requesting a meeting with any of the following:

6.4.1 NRC inspectors, including resident inspectors at Comanche Peak l-Steam Electric Station.

6.4.2 NRC Region IV Office, 611 Ryan Plata Drive, Suite 400, Arlington.

Texas 76011 (817) 860-8100 or (S17) 860-8245 (NRC Allegation Coordinator) 6.4.3 NRC Headquarters.

Phone collect: (301) 951-0550 l

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CPSES PROCEDURE NO.

STATION ADMINISTRATION MANUAL , STA-ll4 EMP14YEE CONCERNS AND EMPLOYEE PROTECTION REVISION NO. 1 PAGE 5 0F B 6.5 Additionally, to provide employees with a further opportunity to report safety concerns in a manner that provides protection for the worker and assures that the concerns are properly addressed, TU Electric has instituted two specific programs to identify'and address nuclear-related employee concerns. Employees are encouraged to use thesa resources to report concerns and to obtain a response to the concerns identified. * '

These programs may be used whether or not the employee has first' raised the concern or complaint with his/her supervision, with TU Electric 4

Management or the NRC.

6.5.1 SAFETEAM 6.5.1.1 The SAFETEAM Program is intended to help identify and investigate concerns of workers associated with CPSES.

The SAFETEAM process shall include opportunity for ,

personal interviews, opportunity to submit written concerns, and convenient telephone access.

6.5.1.2 The SAFETEAM Manager shall:

a. Establish an " Appreciation Center" where workers can call, write, or schedule an interview for the i opportunity to express their concerns. j

b. Ensure that expressed concerns are given prompt, confidential attention.

c. Ensure that a response is provided to the concerned individual.

l 6.5.1.3 Employees may contact SAFETEAM at any time with their l concerns, but a specific opportunity shall be provided for each exiting employee to have a confidential interview to express any conecrn regarding CPSES. ,

Each concern shall be investigated, a report shall be {

prepared, and the concerned individual shall receive a written reply.

6.5.1.4 Identity of persons expressing concerns to SAFETEAM shall be kept confidential, except when the person specifically signs a vaiver of confidentiality. .

6.5.1.5 The SAFETEAM representative may be contacted at any time by calling: <

Extension 8149 or 8214 (Onsite) 1-300-633-6502 (ln Texas) 1-800-645-0021 (Dut-of-State)

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CPSES PROCEDURE NO.

STATION ADMINISTRATION MANUAL STA-114 EMPLOYEE CONCERNS AND EMPLOYEE PROTECTION REVISION NO. 1 PAGE 6 OF 8 6.5.2 Hotline 6.5.2.1 The Hotline program is intended to provide a means for. g an individual to contact TU Electric Corporate Security and report a concern.

6.5.2.2 The Director, Corporate Security shall:

a. Maintain a dedicated telephone line over which e=ployees may report quality concerns at any time.

b. Post the Hotline number at the CPSES site,

c. Investigate, as appropriate, concerns reported on the Hotline.

d. Maintain appropriate records of reported concerns and disposition.

e. Report investigation results to the Group Vice ,

President, Nuclear.

l 6.5.2.3 Employees may report concerns on the Hotline at any time.

This Hotline representative may be contacted by calling:

1-800-442-3022. .

6.5.2.4 Should an individual request a response to their concern, a written response will be provided upon completion of the investigation and report. If the concern is anonymous, or if an individual requests a response after the concern has been reported, a written response will be provided only if the individual provides satisfactory identification as the original author of the concern.

6,6 TU Electric supervision and management shall not discriminate against an employee for the reason that he/she was involved in the activities identified in Reference 3.1, 3.2 or 3.4 or Section 6 of this procedure.

Discrimination includes discharge and other actions that relate to pay, terms, conditions, and privileges of employment.

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CPSES PROCEDURE NO.

. STATION ADMINISTRATION MANUAL STA 414 EMPLOYEE CONCERNS AND EMPILYEE PRUF/'IION REVISION NO. 1 PAGE 7 0F 8 6.7 'If'an employee believes that discrimination has occurred due to engaging in the protected activities described in Section 6.6 above, the employee )

should inform TU Electric management so that management can evaluate the -  ;

potential discrimination and take any remedial action that may be warranted. Additionally, the employee may, within 180 days of the discriminating act, file a written complaint with the Department of Labor, {

E=ployment Standards Administration, and Wage and Hour Division, 819 i Taylor St., Fort Worth, Texas 76102.

6.8 While an employee may not be discriminated against for communicating to the NRC or other investigating agency, an employee also has the following specific rights when involved in investigations by the NRC or other ,

investigating agency:

4 6.8.1 Unless served with a subpoena, the employee's participation in an investigation by the NRC or other governmental agency is ,

Thus, the employee may decline to participate in sach voluntary.

investigation, or to participate further, at any time during the interview. The employee may request, as a condition for participation in an interview, that legal counsel, or anyone else, be present during the interview. If an employee does not feel comfortable with his/her knowledge of the substance or the conduct of the interview, the employee has the right at any. time to decline further participation in the interview / informal investibation. However TU Electric encourages employees to l ,

participate in NRC investigations.  !

6.8.2 An employee who agrees to be interviewed in such an investigation has an obligation to tell the truth and may be liable, criminally or civilly, for any false statements. As in any investigation, answers should be limited to those areas that the employee knows.

Speculation should be avoided with respect to any questions that are not understood or for which the answer is not known.

6.8.3 TU Electric will not discharge or otherwise discriminate against any e=ployee for participating or declining to participate in an investigation by the NRC or other governmental agency, or for reporting to the NRC any concerns that they might have concerning the safety of construction or operation of Comanche Peak Steam Electric Station. ,

6.9 Internal investigations may be performed at CPSES to ascertain relevant r facts surrounding an event or allegation to assure that appropriate '

acticas are taken. As a result, employees of TU Electric and its contractors shall cooperate in such investi5ations.

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CPSES PROCEDURE NO.

STATION ADMINISTRATION MANUAL STA-ll4 EMPMYEE CONCERNS AND EMPMYEE PROTECTION REVISION NO. 1 PAGE 8 0F 8 6.10 If an employee has sny questions regarding his or her rights or responsibilities,' either now or if they arise in the course of an investigation, the employee should refer them i.cmediately to his or her supervisor who vill seek corporate legal assistance for resolution as may .;

be appropriate. The employee is not refrained from seeking his or her own legal counsel.  :,

f 6.11 NEO vice presidents shall ensure that Form NRC-3 and Section 211 of the  ;

Energy Reorganization Act of 1974 are posted per TNL-1.06.

7.0 FIGURES l None 8.0 ATTACR"E57S/ FORMS i None i

9.0 FICOP35 t

None l

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