ML20062L088
| ML20062L088 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/19/1992 |
| From: | Humphrey L, Yelverton J ENTERGY OPERATIONS, INC. |
| To: | |
| Shared Package | |
| ML20062K930 | List: |
| References | |
| A2.205, NUDOCS 9312290164 | |
| Download: ML20062L088 (4) | |
Text
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Hznegnacnt Hnnual Station Directivo A2.205 Rsv. 3
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Title:
Nuclear Safety / Quality Concerns Effective Date:
October 19, 1992 Quality or anization Review hES NO Quality organization Representative:
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Vice President, Operations, AND O@ ?
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f 3.0 PURPOSE The purpose of the directive is to set forth the commitment of Arkansas Nuclear One's management to nuclear safety / quality and to prescribe the requirements for the establishment and administration of the program for avaluating potential Nuclear Safety / Quality concerns that are reported by esployees and contractors, including the formulation of recommended courses of action as appropriate to the findings.
2.0 REFERENCES
Entergy Operations Hanegement Manual, Volume 1, Directive No. C7.520 2.1
" Nuclear Safety".
2.2 AND Procedure 1000.104, " Condition Reporting and Corrective Action" 3.0 DEFINITIONS Nuclear Safety / Quality Concern - A concern regarding the quality level schieved or maintained in a design, modifications, maintenance or operational process / activity which if unacceptable could result in ANO being operated either in violation of regulatory requirements or in a manner which may be detrimental to the health and safety of the public.
4.0 RESPONSIBILITY Vice President. Operations ANO has overall responsibility for the 4.1 establishment of effective methods of communication between employees and management in those staffs directly involved in the construction, operation, saintenance and administration of ANO and for programs which ensure that matters brought to the attention of management are promptly and adequately addressed.
4.2 Director Quality is responsible for assigning an individual to serve as Concerns Coordinator and ensuring that each concern reviewed by the Concerns Coordinator is appropriately investigated.
4.3 Each Department Head is responsible for:
4.3.1 Ensuring that the intent of this directive is made known to personnel within his/her department.
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-:::::::: Entergy volume 11 Page 2 of 4 4.3.2 Emphasizing to department personnel and contractors that they have the right and are responsible for notifying proper levels of management of nuclear safety / quality concerns.
(See l
paragraph 5.2.3) 4.3.3 Ensuring that letters received from vendors / contractors notifying ANO of concerns or potential problems with equipment or services are forwarded to the Manager, Industry Events Analysis for processing.
4.3.4 Ensuring that copies of the applicable procedures and forms for reporting nuclear safety / quality concerns are available to department personnel and contractors and that they are aware of the procedures.
4.3.5 Prior to taking any disciplinary action (except for letters of reprimand), notification is to be made to site Human Resources.
. Human Resources will then contact the appropriate site organization to ensure that the subject individual is not also involved in an active concern investigation. Human Resources will then make the appropriate decision as to whether the proposed disciplinary action should be executed or constrained, based on the existence and status of any pending concern investigation. This applies to both employees and contractors.
4.4 Each Manager / Supervisor is responsible to have knowledge of the Nuclear Safety / Quality Concerns process, to encourage concern identification, and to provide timely evaluation of concerns identified to them.
4.5 Each ANO employee or contractor is responsible to identify concerns.
It is preferred that the process described in paragraph 5.2 be utilized to address the concern. However, neither this directive nor any company policy in any way alters an individual's right to address their concern directly to the NRC per 10CFR19.
5.0 DETAILS 5.1 The management of ANO is dedicated to the safe conduct of its operations.
Tremendous resources are allocated to ensure that design, operation, testing, surveillance and maintenance at ANO are completed in a manner commensurate with that dedication.
To ensure that nuclear safety / quality takes precedence over all other considerations, the following must be achieved as a minimum:
5.1.1 Nuclear safety and quality requirements must be well understood and met by each employee or contractor performing work at or in support of ANO.
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5.1.2 Prevention and mitigation of events shall be accomplished through the application of conservative principles in design.
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construction, operation and maintenance.
5.1.3
. Nuclear refety concerns and nuclear safety reviews shall be directed to the Safety Review Committee, as appropriate.
l 5.1.4 ANO shall take advantage of experience gained from other nuclear utilities or from within Entergy Operations Inc. to enhance safety by evaluating good practices and avoiding mistakes made by others.
5.5 Normally when an esployee or contractor has a problem regarding matters l
including nuclear safety / quality, he should:
j 5.2.1 Address the matter, either orally or in writing, to his immediate supervisor. The immediate supervisor must carefully l
consider the matter and develop and provide to the employee an i
appropriately researched and accurate response in an.
expeditious manner.
If the employee is unable to obtain a response from their immediate supervisor or considers the response to be unsatisfactory, the employee should remind the.
supervisor that the concern still exists. Applicability of ANO Procedure 1000.104, " Condition Reporting and Corrective Action" is to be determined.
5.2.2 Proceed directly up the routing chain, exercising AND's open door practice, if a satisfactory resolution is not reached i
after info'rming the immediate supervisor of the unresolved status of the concern.
5.2.3 Contact the Concerns Coordinator who is the Supervisor, Quality Assurance (QA). While not mandatory, it is preferred that steps 5.2.1 and 5.2.2 be followed prior to calling the Concerns Coordinator at 964-5346.
1 A.
The Supervisor, QA ensures that a timely investigation is conducted.
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The Supervisor, QA will document the investigative results j
and actions taken.
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If the caller so requests, the investigative status /results will be reviewed with the caller.
l Notwithstanding any other provision in this directive, the identity of the coller shall be held in confidence by the
.l Supervisor, QA, if so requested by the employao unless required to be disclosed by law (e.g., pursuant to court order, state or federal agency investigation, or j
government action.)
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l 5.3 Employee reports and inved igative results shall be treated as
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confidential, with disclosure being sado only as required to effectuate I
the purposes of this directive or as required by law (e.g.,' pursuant to court order, state or federal agency. investigation, or government action.)
l 5.4 This concerns process in no way alters a person's right par 10CFR19 to I
contact a NRC inspector or the NRC regional office. NRC postings throughout the plant site contain the contact information.
i 6.0 ATTACHMENTS
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