ML20062L268

Rev 3 to Speakout Program Instruction SPI-10, Potential Wrongdoing Investigations

ML20062L268
Person / Time
Site:	South Texas
Issue date:	04/29/1992
From:	HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20062K985	List: ML20062K983 ML20062L146 ML20062L158 ML20062L169 ML20062L176 ML20062L186 ML20062L210 ML20062L230 ML20062L254 ML20062L268 ML20062L276 ML20062L284
References
SPI-10, NUDOCS 9312290265
Download: ML20062L268 (4)

Text

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, STP 724 (02/90)

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION ""85 7 SPI-10 3 SPEAK 0UT PROGRAM INSTRUCTION SPI-10 l

PAGE 1 OF 4 POTENTIAL WRONGD01NG INVESTIGATIONS EFF C M  %

1.O PURPOSE This instruction delineates how SPEAKOUT will handle investigations of potential wrongdoing and improper conduct, and reporting potential wrongdoing matters to the United States Nuclear Regulatory Commission (NRC) .

2.0 SCOPE This instruction applies to any issues, over which SPEAKOUT has cognizance, deemed a potential wrongdoing or improper conduct.

This instruction does not apply to issues related to the-Continued Behavior Observation Program or the Fitness For Duty  !

Program.

3.O DEFINITIONS 3.1 Wrongdoing - The violation of an NRC requirement or a company procedure or policy designed to implement ^

NRC requirements or assure nuclear safety, under circumstances involving:

a. Knowledge that the requirement, policy or procedure applied; and

b. either deliberate intent to violate t',

requirement, policy or procedure or care 3 aos disregard for whether the requirement, N11cy or procedure was violated.

3.1.1 Careless disregard - When a person conducts an act, or intentionally fails to conduct an act which is required, knowing or having reason to know that the conduct ' is in violation of requirements, and that the conduct is more severe than mere negligence.

NOTE: Wrongdoing does not include simple cases of inadvertent error, nistake, or forgetfulness.

)

3.2 Improper Conduct - The violation of a procedure or  ;

policy which is not designed to implement NRC  !

requirements or assure nuclear safety. _

I 9312290265 900921 PDR ADOCK 0500049B P PDR

.- e STP 724 (02/90)

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION "*8" E

SPI-10 3 SPEAKOUT PROGRAM INSTRUCTION SPI-10 PAGE2 OF 4 POTENTIAL WRONCDOING INVESTIGATIONS EFFECTIVE DATE 4/29/92 4.O REFERENCES 4.1 SPEAKOUT Program Instruction manual, SPI 08, SPEAKOUT Review Committee 4.2 SPEAKOUT Program Instruction manual, SPI 09, Recommendations / Suggestions 5.0 RESPONSIBILITIES 5.1 The Manager, SPEAKOUT Program, is responsible for the implementation and maintenance of this instruction. ,

5.2 The Manager, SPEAKOUT Program, is responsible for making the final decision concerning what matters contain a potential wrongdoing, who will perform the investigation, reviewing the investigation report and making recommendations to the SRC. 1 5.3. The Manager, SPEAKOUT Program, or designee, has the responsibility for reporting all potentially significant wrongdoing matters under investigation to the NRC Senior Resident Inspector, documenting same and coordinating such information with Licensing.

5.4 SPEAKOUT is responsible for maintaining the completed file of related correspondence and documentation of wrongdoing matters investigated by SPEAKOUT or other entities.

5.5 The SPEAKOUT Interviewer / Investigator is responsible for identifying any potential wrongdoing during the receipt or investigation of any concern and notifying the Manager, SPEAKOUT Program.

5.6 The SPEAKOUT Review Committee (SRC) is responsible for reviewing wrongdoing investigation reports and recommendations made by SPEAKOUT.

5.7 The SRC is responsible for determining whether l wrongdoing has occurred.

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• L STP 724 (02/90)

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION wuam p SPEAK 0UT PROGRAM INSTRUCTION' SPI-10 SPI-10 3 0

POTENITAL WRONGDOING INVESTIGATIONS ERECVW DAE 4/29/92 6.0 REQUIREMENTS 6.1 WRONGDOING 6.1.1 When the SPEAKOUT Interviewer / Investigator receives a concern containing potential wrongdoing, the Manager, SPEAKOUT Program is notified.

6.1.2 The Manager, SPEAKOUT Program will review each SPEAKOUT Concern Record and Investigation Report for possible wrongdoing.

6.1.3 When the Manager, SPEAKOUT Program, determines that potential wrongdoing is evident, a decision will be made to 1) notify the NRC 2) immediately cause an investigation to be performed; 3) perform 2) above and allow SPEAKOUT to investigate the nuclear safety or nuclear quality issues; 4) gather additional information to support the potential wrongdoing prior to performing (1) or 2) above.

6.1.4 When a wrongdoing is revealed, SPEAKOUT will continue to retain responsibility for the investigation of the concern but may delegate responsibility to investigate the potential wrongdoing portion of the concern. This does not however, prohibit the SPEAKOUT Investigator from gathering information or facts that will aid the responsible entity in

.its investigation of the wrongdoing.

6.2 IMPROPER CONDUCT 6.2.1 Improper conduct will be investigated by SPEAKOUT at the discretion of Management.

6.2.2 Documentation of improper conduct investigations will be as dictated by the situation.

STP 724 (02/90)

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION

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7 SPEAK 0UT PROGRAM INSTRUCTION SPI-10 PAGE 4 OF 4

POTENTIAL WRONGDOING INVESTIGATIONS DATE 4/29/92 6.2.3 SPEAKOUT will retain, as a minimum, a copy of documentation generated as a result of an improper conduct investigation conducted by SPEAKOUT.

7.O DOCUMENTATION 7.1 All documentation concerning any SPEAKOUT Investigation Report, including wrongdoing investigations, will be maintained in the respective SPEAKOUT Concern File Folder.

7.1.1 All Class 1 and wrongdoing concern documentation will be controlled, to include controlled storage of computer, microfilm, and hard file copy information.

7.1.2 The retention period for documentation concerning potential wrongdoing, if determined to be wrongdoing, is life of plant.

8.0 Attachments None i