Text

Responds to NRC Re NOV (EA-95-079) Related to Creation of Hostile Work Environ by Morrison-Knudsen Employees at PSC Fsv Facility.C/A:Distributed Rept Of...Nrc Program for Protecting Allegers Against Retaliation
	ML20092C937
Person / Time
Site:	Fort Saint Vrain
Issue date:	09/13/1995
From:	Pardi L; MORRISON-KNUDSEN CO., INC.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20092C935	List: ML20092C934; ML20092C937;
References
	EA-95-079, EA-95-79, NUDOCS 9509130197
	Download: ML20092C937 (133)
	v • d • e

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MORRISON KNUDSEN CORPORATION ENGINEERING. CONSTRUCTION

& ENVIRONMENTAL GROUP E[ROUSON fWA

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September 13, 1995

[ U. S. Nuclear Regulatory Commission Mail Stop P1-37 One White Flint North

[ 11555 Rockville Pike Rockville, MK 20852-2738 r- Attn: Document Control Desk L

Sebhet: " Reply to a Notice of Violation" EA-95-079 r

L Sirs:

Morrison Knudsen (MK) has prepared this response to the NRC's letter of August 14, 1995, which advised MK of a Notice of Violation (EA-95-079) related to the creation of a hostile work environment by MK employees at Public Service Company of Colorado's Fort St. Vrain Facility. This response has been put in the format as specified in the

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instructions of the Notice of Violation.

Reason for Violation

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l The decommissioning of Fort St. Vrain has been and continues to be a challenging

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project. Many of the activities performed at Fort St. Vrain, such as concrete cutting, underwater diving and demolition, and rigging / handling of activated materials have never been done on the scale encountered on this project. At Fort St. Vrain, unlike a E conventional construction project, all of these activities have to be done with the care, excellence, and discipline required in a nuclear facility. Additionally, the efforts at Fort St. Vrain required the coordination of all activities of the four principals involved; i.e.,

The Public Service Company of Colorado and the Westinghouse Team (WT) comprised of

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Westinghouse Electric Corporation (W), Scientific Ecology Group (SEG), and Morrison Knudsen (MK). In the initial phase of this project and through those activities culminating

[ approximately in March,1994, Morrison Knudsen did not recognize that within an intense work environment as described above special care must be exercised to avoid the l development of a work environment which could be perceived as hostile or " chilling". As b a result a significant number of personnel workir.g at the site did have the perception that production was emphasized over safety and raising such safety concerns cculd result in retaliation.

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I E MoRRISoN KNUDSEN CORPORATION U. S. Nuclear Regulatory Commission Page 2 September 13,1995 While, as the Stier, Anderson, Malone Report indicates, there was no one singular act or cause for this situation there were a number of contributing causes including:

A lack of sensitivity on the part of certain MK superintendents as to how readily the perception of a hostile work environment can be created.

Middle and upper level project management were not aware that the perception existed. The project's safety and ALARA performance, as shown in pages 30 and 31 of Exhibit I, were/are exemplary (loss time incident rate less than 10% of industry average and personnel contaminations and total dosage significantly below industry average and the project's goals) and may have in fact served to mask these

!I perceptions. Because a chilling effect inherently can keep concerns from being l expressed management must pro-actively look for evidence of a hostile work place beyond the data and indices normally used to monitor project performance.

Inadequate communications between various employees and entities engaged in the project.

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Lack of teamwork particularly between MK and SEG employees.

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Corrective Action and Results l

Immediately upon becoming aware that a hostile work environment apparently existed at l Fort St. Vrain, PSC, Westinghouse, SEG, and MK took immediate corrective action. MK ;

was aggressive in these actions and fully supported PSC's efforts including the Stier, !

Anderson, Malone investigation. Many of the corrective actions taken on the part of PSC and MK are detailed in the presentation made to the NRC on June 1,1995, at the predecisional enforcement conference, a copy of which is attached as Exhibit I. Specific corrective actions which MK took on unilaterally or as part of the PSC/ Westinghouse team and the results of these actions follow.

. Corrective Action for Improved Suoerintendent Awareness / Training l

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During the February,1994 time frame, the WT obtained a copy of the January 18, 1994, release of "The Report of the Review Team for Reassessment of the NRC's Program for Protecting Allegers Against Retaliation". The MK operations manager distributed copies to key personnel and numerous discussions took place to sensitize the MK staff to the expectations and interpretations contained within j this document which was shortly thereafter released as NUREG-1499.

MoRRISoN KNUDSEN CORPORATION U. S. Nuclear Regulatory Commission Page 3 l

September 13. 1995 l

I l On February 24,1994, L. E. Pardi, MK Executive Vice President, Power

'E Division, removed the MK superintendent responsible for intimidating remarks to E an SEG employee from the project. This superintendent was re-assigned to l another (non-nuclear) project. Mr. Pardi met with this superintendent again on August 17,1995, and discussed MK's Notice of Violation with him to underscore the seriousness of his actions.

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l On March 9 and 10,1994, all MK management, supervisory, and craft personnel attended a presentation on project values. Central to this presentation was the importance of industrial and radiation safety and the ability of employees to raise

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concerns. The project's ongoing "open door" policy which has always encouraged

- employees to discuss job related concerns with project management was also i emphasized. The outline of this presentation is shown as Exhibit II. ,

l m On March 31,1994, Mr. Pardi participated in a joint MK, PSC, Westinghouse, I u and SEG presentation related to corporate philosophies, values, and expectations.

This presentation was made to all supervisory employees at Fort St. Vrain 7 including union general foremen and is included as Exhibit III.

L During the Marcl: 25,1994 work stoppage training lesson plans were revised to

- include enhanced coverage of 10 CFR 50.7 requirements. It was mandatory that each employee take restart training prior to his/her badge being reactivated.

Copies of applicable parts of this lesson plan are included as Exhibit IV.

E On August 15, 1994, MK's operations manager at Fort St. Vrain issued

" Guidelines for Reductior in Force Actions" to all MK Superintendents and union E foremen and general foremen, specifically pointing out the requirements of 10 CFR E 50.7. These guidelines are attached as Exhibit V.

F - Corrective Action for Increased Management Aggrenss L

MK management became pro-active in looking for signs of a hostile environment I during the 1994 work stoppage when all union business agents were requested to contact their constituents for feedback on the work environment. MK continues to meet with business agents on a regular basis and with the Building Trades Council quarterly for feedback.

L Beginning March 14,1994, Public Service has opened a confidential " Hotline" E phone answering service which enables employees to voice concerns anonymously.

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I MoRRISoN KNUDSEN CORPORATION U. S. Nuclear Regulatory Commission Page 4 September 13, 1995 I MK is committed to investigating and resolving these concerns. Additionally, MK has been conducting exit interviews of all employees, including craft and I subcontractors, as they are terminated or work becomes completed. Copies of sample exit interviews are included as Exhibit VI.

MK's operations manager, the Westinghouse project director, and SEG's project radiation protection manager meet weekly to exchange information pertinent to the project work environment. These same managers and their direct reports, including the supervisore of radiation technicians and final survey radiation technicians, also meet weekly. Additionally, MK's operations manager, the I Westinghouse project director and Public Service's project director meet weekly with periodic briefings by PSC's oversight staff who conducts audits of the work environment.

I An important activity develeped to give senior site management direct "from the field" information is the Safety Surveillance Tour in which a key manager from the WT tours the project with representatives from the craft and radiation protection ,

I technicians and an MK safety supervisor. An example of one of these surveys, which are conducted monthly, is attached as Exhibit VII.

- Corrective Actions Related to Improved Communications and Teamwork In March,1994, executives of PSC and the Westinghouse Team realized that enhanced communications and teamwork were needed. Westinghouse provided the services of their Manager of Communication Services who acted as a facilitator for !

a number of communication workshops attended by SEC and MK personnel. The 1 objectives of these workshops included instilling the importance of two way communications, appreciation of accomplishments made through teamwork, and the importance of mutual trust. A memorandum initiating and describing these workshops is included as Exhibit VIII.

For many years MK has conducted " Tool Box" safety meetings on all of our projects. These meetings, which are an excellent form of communication, are usually led by a safety specialist and are a forum for the discussion of safety topics. During these meetings craft personnel are encouraged to raise any questions or concerns about any task. An example documenting one of these meetings which included an ALARA update is shown in Exhibit IX.

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MoRRISoN KNUDSEN CORPORATION U. S. Nuclear Regulatory Commission j Page 5 September 13,1995 At Fort St. Vrain MK also conducts ongoing briefings of the requirements of work packages and radiation work permits. These meetings which are attended by engineering, supervisors, craft, ALARA coordinators and radiation protection technicians provide yet another opportunity for workers to raise concerns.

Results g The corrective actions have achieved the desired results. In fact, the Stier, B Anderson, and Malone report concluded that the major elements of the atmosphere of harassment and intimidation were no longer factors when the stop work order was issued in late March,1994. From this, it is apparent that the substantial corrective actions undertaken by PSC, SEC, and MK began to be effective very l shortly after the hostile atmosphere was identified.

MK continues to refine mechanisms to promote comfortable, open communication of safety issues. The focus is to maintain the trust of the work force by g

considering and acting on identified safety concerns. Two notable examples are the support of the core support floor (CSF) for segmentation and the removal of Kaowool insulation from the beltline concrete segments. The first example relates to the support system for supporting one half of the CSF above the other half while the crane monorails and insulation were removed from the top half. This ,

system had been adequately engineered to support the load although minor l

,l l deformation did occur due to a point load. Some of the ironworkers who were :

required to work underneath the floor questioned the adequacy of the support system. The superintendent called for engineering to evaluate the situation and

.l meet with the workers. Even with the explanation of the adequacy of the system, it was agreed not to proceed until additional support members were placed beneath the floor. The second example involves the removal of Kaowool insulation from I the beltline concrete segments. The airborne radiation levels had been monitored and had been determined not to require respiratory protection. The Kaowool had been questioned in regard to being a possible carcinogen and due to the lack of I data to show otherwise and until such time that testing shows that fiber counts are below acceptable levels, respirators are being utilized during this activity.

Communication continues to receive focus in weekly tool box meetings and job ,

briefings to seek out concerns and show active interest in their resolution. l Recent exit interviews for craft labor and subcontractors have been very encouraging. These interviews have been performed by our Senior Safety I

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{ uoResoN KNUOSEN CoRPoRAnoN U. S. Nuclear Regulatory Commission

{' Page 6 September 13,1995 Supervisor, who reports directly to the operations manager. The remarks of the interviewee are recorded by the Safety Supervisor and then the interviewee signs the acknowledgement. These employees have expressed a sincere willingness to contemplate further employment with MK and have not expressed any sense of intimidation related to expression of safety concerns. Nor have there been any safety concerns or harassment and intimidation calls placed through the project

" Hotline" relative to MK's activities on the project.

' As endorsed by PSC during the predecisional enforcement conference, the project now demonstrates an appropriate atmosphere where employees are comfortable to bring up safety concerns and the program identifies problems or conflicts and with management involvement, if necessary, they are resolved.

L Many times difficult problems serve as a catalyst for pulling people together and in working their way towards a solution people find that they have a common cause,

b. This was indeed the case at Fort St. Vrain. Employees, supervisors, managers, and executives of all the companies involved appreciate each others position on the

. various issues involved and have developed a sense of teamwork and trust.

b Because of this intercompany relationships are now excellent. A commitment by SEO to promote efficiency and by MK to support RPT activities has been openly 7 embraced by both companies.

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- Corrective Actinne to Avoid Further Viohtians We believe that the corrective actions discussed above combined with a diligent continuing effort of implementation of these policies, procedures, and attitudes developed as part of these corrective actions will present the recurrence of a ;

{- hostile work environment at Fort St. Vrain.

Of equal importance to MK senior management is the prevention of the occurrence

{ of a hostile or chilling environment at any of our projects at NRC licensed I facilities. To assure that this des not happen MK has/will implement the

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following actions:

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1. On June 6,1995, Tom Zarges, President and CEO of MK's Engineering and Construction Group issued a Safety Alert Bulletin to all projects. This

['L bulletin (attached as Exhibit X) discussed the need for open communications particularly as relates to safety concerns and the employee protection requirement of federal statutes including 10 CFR 50.7.

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I MoRRISoN KNUDSEN CORPORATION U. S. Nuclear Regulatory Commission Page 7 September 13,1995 I

2. In early June,1995, L. E. Pardi drafted and circulated for comments an MK Project Management Bulletin entitled " Harassment and Intimidation in I the Workplace". This document was released for implementation on August 24, and is included as Exhibit XI. It clearly expresses MK's policy of ensuring that our employees are not subject to harassment or intimidation in the workplace pointing out that such activities at NRC licensed facility is a violation of federal law. The bulletin requires that each project working I under 10 CFR 50.7 requirements shall have a procedure which as a minimum requires (a) indoctrination and training of all MK supervisory employees (including union foremen and general foremen) to the requirements of 10 CFR 50.7; (b) indoctrination of all employees of their rights to express workplace safety concerns; and (c) a method of collecting and dispositioning employee concerns.

3. MK recognizes the need for, and is in the process of developing, a formal "open door" policy which will be distributed to and used at all MK projects. Prior to this MK's "open door" policy existed but it was not a part of our written project requirements.

l 4. All of the information contained in this response will be forwarded to all NRC licensed projects where MK is working. Each project manager will be required to read and document his understanding of this response.

5. MK's executive management has been sensitized to H&I issues as a result of our Fort St. Vrain experience. In working with PSC, Westinghouse, and l SEG, we have learned much about the importance of workplace attitude and more importantly ways in which employees can be encouraged to have open discussions about workplace concerns. We are committed to achieving this

I open atmosphere on all of our projects.

Date Full Compliance is Anticipated As noted above, the Stier, Anderson, and Malone report concluded that the major elements of the atmosphere of harassment and intimidation were no longer factors when the stop work orders were issued in late March,1994. From this, it is apparent that the substantial corrective actions undertaken by PSC, SEG, and MK were effective early on in their implementation. However, it is clear to MK that continued unrelenting efforts to maintain open communication are the only means to guarantee that the perception of harassment and intimidation will not recur.

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MoRRISoN KNUDGEN CORPORATION U. S. Nuclear Regulatory Commission E Page 8 September 13,1995 u

f~ MK believes that compliance has been achieved, that communication mechanisms are in place and functioning in a manner that will prevent similar violations at other NRC licensed facilities where MK is performing NRC licensed activities.

Sincerely, L. E. Pardi use

{ attachments cc: L. J. Callan Regional Administrator

[ United States Nuclear Regulatory Commission Region IV E

611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011

[ A. Clegg Crawford Public Service Company of Colorado 122517th Street Plaza, Suite 900

[ Denver, CO 80202 u

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I-u U.S. Nuclear Rrgulitory Commission c: MoRRSON KNUDSEN CORPORATION Reply to a Notice of Violation (EA-95-079)

TABLE OF CONTENTS E Exhibit I:

Presentation Summary - NRC Enforcement Conference, June 1,1995

[ Exhibit II: " Values" Presentation - Fort St. Vrain Decommissioning Project, March 9 & 10, 1994

[ Exhibit III: " Project Philosophies, Policies and Programs" presentation of March 31, 1994 Exhibit IV: Excerpt from Restan Training Plan Exhibit V: " Guidelines for Reduction in Force Actions" Exhibit VI: Exit Interview samples

[ Exhibit VII: Safety Surveillance Tour example Exhibit VIII: Communications Workshops memorandum 7

Exhibit IX: " Tool Box" Safety Meeting example l

L Exhibit X: " Safety Alen Bulletin" Exhibit XI: " Harassment and Intimidation in the Workplace" bulletin

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FORT ST. VRAIN NUCLEAR REGULATORY COMMISSION ENFORCEMENT CONFERENCE JUNE 1,1995 l

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HISTORICAL OVERVIEW l

CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

MK ACTIONS L. E. PARDI CONSIDERATIONS / MITIGATION / CLOSING A. C. CRAWFORD QUESTIONS / DISCUSSION 1

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i _-1 m 1_J u uum M FN L_J U-INTRODUCTION AND OPENING REMARKS PUBLIC SERVICE COMPANY OF COLORADO IS HERE TO ADDRESS YOUR NOTICE OFAPPARENT VIOLATION 1

IN MA Y 19,1995, LETTER, NRC STA TED THA T THE OFFICE OFINVESTIGA TION REACHED THE '

FOLLOWING CONCLUSION:

FOUR FORMER MK EMPLOYEES WERE HARASSED, INTIMIDATED AND ULTIMATELY TERMINATED BY THEIR SUPERVISORS FOR RAISING SAFETY CONCERNS, AND THESE SAME SUPERVISORS CREA TED A HOSTILE WORK ENVIRONMENT PSC/MK CONCLUSION:

AN A TMOSPHERE EXISTED IN WHICH THEPERCEPTION OFSOMEEMPLOYEES WAS THA T PRODUCTION WAS EMPHASIZED OVER SAFETY AND PROCEDURAL COMPLIANCE, AND RAISING SAFETY CONCERNS COULD RESULTIN RETAllATION AS WILL BE EXPLAINED, THERE WAS AN INDEPENDENT BASIS FOR THE CRAFT LA YOFF; HOWEVER, THE WEIGHT OF EVIDENCE FROM THE STIER, ANDERSON AND MALONE REPORTSUPPORTS THEPERCEPTION THA T THEEXPRESSION OFSAFETY CONCERNS HAD SOMEINFLUENCE ON LA YOFF DECISION Page 3

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INTRODUCTION AND OPENING REMARKS (CONTINUED)

UPON LEARNING OF POTENTIAL HARASSMENT AND INTIMIDATION CONCERN IN JANUARY 1994, PSC/WT INITIATED AN EXTEMSIVE INVESTIGATION AND CORRECTIVE ACTION PLAN IN THE FOLLOWING APPROPRIATE AND AGGRESSIVE !

MANNER:

RESPONDED TO QUESTIONS FROM OSHA, NRC, LABORER'S INTERNATIONAL UNION OF NORTH AMERICA, NLRB, IN TIMELY MANNER HAD DIRECT EXECUTIVE MANAGEMENT INVOLVEMENT INITIATED INDEPENDENT INVESTIGATION BY LAW FIRM OF STIER, ANDERSON AND MALONE (SAM), AT A COST OF APPROXIMATELY $1 MILLION OVER 9 MONTHS, INTERVIEWING APPROXIMATELY 50% OF THE WORKFORCE TOOK APPROPRIATE PERSONNEL ACTIONS, CONDUCTED EMPLOYEE TRAINING, TEAM BUILDING PROVIDED SUPPORT, OPEN COMMUNICATIONS AND FULL COOPERATION WITH NRC INVESTIGATION ENHANCED COMMUNICATIONS BETWEEN PROJECT TEAM MEMBERS REGARDING PERSONNEL ISSUES PRESENTED PRELIMINARY FINDINGS TO NRC ON AUGUST 4,1994 Page 4 1

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PSC/WT ACTIONS (CONTINUED)

PROVIDED CONSTANT REMINDERS EMPHASIZING THE IMPORTANCE OF SAFETY OVER PRODUCTION CONDUCTED 10 CFR 50.7 TRAINING FOR ALL WT BADGED PERSONNEL HELD DETAILED MANAGEMENT ROUND TABLE DISCUSSIONS TO ENSURE CONSISTENT UNDERSTANDING OF 10 CFR 50.7 EMPHASIZED CORPORATE PHILOSOPHIES, IMPORTANCE OF SAFETY, AND ELEMENTS OF 10 CFR 50.7 DURING ALL-EMPLOYEE MEETINGS l

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INTRODUCTION AND OPENING REMARKS (CONTINUED)

WE HAVE IMPLEMENTED A PROGRAM THAT WORKS , i WORKERS FEEL THAT FORT ST. VRAIN DECOMMISSIONING PROJECT IS SAFE, AND THEY ARE COMFORTABLE BRINGING UP SAFETY CONCERNS WORKER PERCEPTIONS ARE DETERMINED BY PERIODIC MONITORINGS, SURVEYS, QUESTIONNAIRES, AND INTERVIEWS WHEN CONFLICTS AND PROBLEMS ARISE, THEY ARE IDENTIFIED, BROUGHT TO MANAGEMENT'S ATTENTION, AND RESOLVED OMBUDSMAN (HOT LINE) ESTABLISHED IN MARCH 1994 TO ALLOW CONFIDENTIAL IDENTIFICATION OF CONCERNS VARIOUS COMMUNICATION AVENUES ARE AVAILABLE TO ENSURE A COMFORTABLE ROUTE FOR ALL EMPLOYEES TO RAISE SAFETY CONCERNS SAM CONCLUSION: BY MARCH 1994 WORK STOPPAGE, MAJOR ELEMENTS OF ATMOSPHERE OF HARASSMENT AND INTIMIDATION WERE NO LONGER FACTORS Page 7

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HISTORICAL OVERVIEW OF EVENTS AND

SUMMARY

OF PARALLEL ACTIONS Page 8 l

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FIRST QUARTER OF 1993, 4 MK WORKERS RAISED INDUSTRIAL SAFETY AND RADIOLOGICAL CONCERNS REGARDING HIGH DENSITY BLOCK REMOVAL AND CORE DRILLING OPERATIONS i

MARCH 9,1993,4 MK LABORERS LAID OFF

MARCH 1993, UNION REPRESENTATIVE INFORMED MK THAT LABORERS RAISED COMPLIANT DUE TO THE LAYOFF - UNION CONCLUDED THAT THE COMPLAINT HAD NO MERIT t

MARCH 16,1993, OSHA NOTIFIED MK OF A COMPLAINT REGARDING ASBESTOS REMOVAL AND HIGH DUST LEVELS AT FORT ST. VRAIN - MK RESPONDED APRIL 6,1993 l

JULY 1993, NRC INSPECTED SPECIFIC RADIOLOGICAL CONCERNS RAISED BY 4 FORMER MK LABORERS AND CONCLUDED THAT APPROPRIATE RADIOLOGICAL CONTROLS AND PRACTICES WERE IN PLACE Page 9

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HISTORICAL OVERVIEW (Continued)

DECEMBER 14,1993, NRC LETTER QUESTIONED WHETHER SAFETY CONCERNS RAISED DURING MARCH 1993 HIGH DENSITY BLOCK REMOVAL ACTIVITIES HAD BEEN ADEQUATELY ADDRESSED l

JANUARY 17,1994, PSC RESPONDED TO NRC LETTER - RESPONSE BASED ON A MARCH 1993 PSC PROBLEM REPORT AND APRIL 1993 OSHA RESPONSE WHICH CONCLUDED THAT THE SAFETY CONCERNS RAISED WERE WITHOUT FOUNDATION

JANUARY 19, 1994, NRC OFFICE OF INVESTIGATION NOTIFIED PSC OF POTENTIAL HARASSMENT AND INTIMIDATION ALLEGATIONS INVOLVING 4 FORMER MK LABORERS

FEBRUARY 3,1994, CONFRONTATION OCCURRED BETWEEN AN MK SUPERINTENDENT AND A RADIATION PROTECTION TECHNICIAN (RPT)

FEBRUARY 8,1994, UPON LEARNING OF THE FEBRUARY 3 INCIDENT, PSC REQUESTED THAT WT CONDUCT AN INVESTIGATION OF ISSUES SURROUNDING THE CONFRONTATION AND DEVELOP AN ACTION PLAN TO ADDRESS POSSIBLE CHILLING EFFECTS Page 10

7 HISTORICAL OVERVIEW i (Continued) l

WEEK OF FEBRUARY 14,1994, WT IMPLEMENTED ACTION PLAN TO MEET WITH ALL WT ON-SITE PERSONNEL, AND HELD ROUND TABLE DISCUSSIONS WITH WT MANAGEMENT PERSONNEL TO DISCUSS H & I AND CHILLING EFFECTS - INCLUDED 10 CFR 50.7 i SENSITIVITY DISCUSSION l

l FEEDBACK FROM MEETINGS REVEALED A LOT OF MISCONCEPTIONS ABOUT THE RADIOLOGICAL OCCURRENCE REPORT (ROR) PROGRAM AND MANAGEMENT'S j PHILOSOPHY PSC MET WITH WT UPPER MANAGEMENT TO DISCUSS THIRD PARTY INVESTIGATION AND WT AGREED TO BE INVOLVED

FEBRUARY 22,1994, PSC CONTRACTED WITH SAM TO CONDUCT A THIRD PARTY INVESTIGATION OF POTENTIAL H & I ISSUES AND OVERALL SITE RELATIONSHIPS

FEBRUARY 24, 1994, POTENTIAL H&l CONCERNS WERE DISCUSSED DURING SEMIANNUAL EXECUTIVE MEETING - MK SUPERINTENDENT REMOVED FROM SITE Page 11 E- __ - . - _ _

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,u c uw ww- w w cu c HISTORICAL OVERVIEW (Continued)

ON MARCH 10,1994, PSC/WT SITE MANAGEMENT CONDUCTED MEETINGS .WITH ALL SITE EMPLOYEES TO EMPHASIZE MANAGEMENT VALUES, PHILOSOPHY, PROJECT EXPECTATIONS, AND TO INTRODUCE THE THIRD PARTY INVESTIGATION

MARCH 31,1994, PSC, WESTINGHOUSE, MK, AND SEG SENIOR EXECUTIVES MET WITH ALL SITE MANAGEMENT TO DISCUSS CORPORATE CORE VALUES AND EXPECTATIONS, NRC REGULATIONS INCLUDING 10 CFR 50.7, AND RE-EMPHASIZE ON-SITE MANAGEMENT RESPONSIBILITIES

JUNE 30,1994, PSC/WT MET WITH REGION IV AND PRESENTED INITIAL OVERVIEW OF H & l lSSUES

AUGUST 4,1994, MEETING HELD WITH NRC REGION IV TO PRESENT INITIAL FINDINGS AND CORRECTIVE ACTIONS l

AUGUST 10,1994, ALL SITE EMPLOYEE MEETING REINFORCED CORE VALUES, PROVIDED STATUS OF INVESTIGATION, AND PRESENTED ELEMENTS OF 10 CFR 50.7 I

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7 5 HISTORICAL OVERVIEW (Continued)

MARCH 27,1995, INDEPENDENT ASSESSMENT BY STIER, ANDERSON, AND MALONE COMPLETE, REPORT PROVIDED TO NRC

> IN DEPTH ASSESSMENT INVOLVED 9 MONTHS, APPROXIMATELY $1 MILLION

INTERVIEWED OVER 100 PEOPLE -- APPROXIMATELY 50% OF WORKFORCE AT THE TIME l

> REVIEWED 15,000 PAGES OF DOCUMENTATION

> INVESTIGATORS HAD FREE REIN AND WERE NOT RESTRICTED IN ANY WAY

> PSC COMMITTED 1 FULL TIME RADIATION PROTECTION PROFESSIONAL TO ASSIST INVESTIGATION TEAM PSC AND WT DEVELOPED AND IMPLEMENTED CORRECTIVE ACTIONS TO ADDRESS H &

I ISSUES AT FORT ST. VRAIN IN PARALLEL WITH THE SAM INVESTIGATION Page 13

y 7 q 7-HISTORICAL OVERVIEW j (Continued)

ORIGIN AND SCOPE OF SAM INVESTIGATION ,

REQUESTED BY PUBLIC SERVICE COMPANY OF COLORADO AND WESTINGHOUSE TEAM INITIAL SCOPE: POTENTIAL ATMOSPHERE OFINTIMIDATION AND HARASSMENT; EFFECTIVENESS OF RADIOLOGICAL OCCURRENCE REPORT ("ROR") PROGRAM ADDITIONAL SCOPE: POSSIBLE FALSIFICA TION OF RADIA TION SURVEY RECORDS i

ISSUES INVESTIGATED WHETHER AN ATMOSPHERE EXISTED WHERE WORKERS WERE RELUCTANT TO RAISE SAFETY CONCERNS WHETHER MK PERSONNEL INTIMIDATED AND HARASSED SEG RPTS WHETHER SEG EMPLO YEES USED THE ROR PROCESS TO INTIMIDA TE AND HARASS MORRISON KNUDSEN ("MK") WORKERS - SAM CONCLUDED THAT THIS ALLEGATION WAS UNFOUNDED Page 14

1 cm n n ca ca ca ci a ca cm ra ca ca ca ca ca ca ca cm CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

CONCERN NO.1:

A PERCEPTION EXISTED IN A CROSS SECTION OF THE WORK FORCE THAT PRODUCTION WAS EMPHASIZED OVER SAFETY COWORKERS FELT THAT THE LAYOFF DECISION WAS NOT BASED ON WORK SKILLS EXPRESSION OF CONCERNS WOULD RESULT IN RETALIATION Page 15

t m cDa n a ca va m .m . ra ra rm FT ca n ra rm n m CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

(Continued)

CORRECTIVE ACTIONS: ,

l MK AND SEG RE-EMPHASIZED POLICIES OF SAFETY OVER PRODUCTION DECOMMISSIONING ACTIVITIES WERE SHUT DOWN FOR 16 CALENDAR DAYS -

- PRIMARILY DUE TO RP RECORDS ISSUES ALL EMPLOYEES WERE TRAINED IN THE IMPORTANCE OF SAFETY, STOP WORK AUTHORITY, PROCEDURE COMPLIANCE CONDUCTED ADDITIONAL 10 CFR 50.7 TRAINING FOR ALL WT BADGED PERSONNEL TEAM BUILDING SESSIONS CONDUCTED BY THE WT TO CREATE ATMOSPHERE WHERE EMPLOYEES FEEL SAFE RAISBNG SAFETY CONCERNS MANAGEMENT ENCOURAGED WORKERS TO BRING UP SAFETY CONCERNS WITHOUT FEAR OF RETALIATION, IN EFFORT TO DEVELOP TRUST WITH THE WORKFORCE PSC AND WT MANAGEMENT MEET WEEKLY TO DISCUSS ISSUES AND I

POTENTIAL CONCERNS, ESPECIALLY REGARDING PERSONNEL ISSUES Page 16

r- ro, r r r r, c, muu, r, r r r r 1q CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

(Continued)

CORRECTIVE ACTIONS (Continued): ,

JOINT WT SAFETY WALKDOWNS INCLUDING MANAGEMENT, RADIATION PROTECTION, MK SAFETY REPRESENTATIVE, AND CRAFT LABOR TO PROMOTE TEAM CONCEPT AND PROVIDE OPPORTUNITY TO RAISE SAFETY CONCERNS WEEKLY WT MANAGEMENT MEETINGS WITH RPT AND CRAFT SUPERVISION TO DISCUSS OPERATIONAL ISSUES AND POTENTIAL CONCERNS I

MK ESTABLISHED ENHANCED / WRITTEN LAYOFF POLICIES MK ROUND TABLE DISCUSSIONS ON MANAGEMENT EXPECTATIONS REGARDING LAYOFFS Page 17

l CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

(Continued)

CONCERN NO. 2: i

THE FEBRUARY 3,1994, INCIDENT BETWEEN THE MK SUPERINTENDENT AND AN RPT

FOUR VIOLATIONS OF RADIATION PROTECTION PRACTICES BY MK SUPERINTENDENT '

SEG RPTS COMPLAINED OF INTIMIDATING CONDUCT OF MK SUPERINTENDENTS / SUPERVISORS !

SEG MANAGEMENT FAILED TO FORCEFULLY ADDRESS INTIMIDATING BEHAVIOR AND THE RPTS LOST CONFIDENCE IN BOTH THE ROR PROGRAM AND IN THEIR i MANAGEMENT ,

THE ROR PROGRAM WAS PERCEIVED TO BE A DISCIPLINARY TOOL l

f Page 18 l

CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

(Continued)

CORRECTIVE ACTIONS:

PROGRESSIVE DISCIPLINARY ACTIONS TAKEN AGAINST MK SUPERINTENDENT LEADING TO THE FINAL REMOVAL FROM THE SITE MANAGEltENT TEAM BUILDING SESSIONS HELD BETWEEN WT ORGANIZATIONS TO ADDRESS PROBLEM RESOLUTION WITHOUT INTIMIDATION POSITIVE CHANGE IN BEHAVIOR OF OTHER MK SUPERVISORS SEG INCREASED PERSONNEL TO PROVIDE ADEQUATE SUPPORT TO AVOID UNNECESSARY PRODUCTION DELAYS AND CONFRONTATIONS REGARDING ROR PROCESS:

SEG REORGANIZED TO PROVIDE SUPPLEMENTAL STAFF AND BETTErt MANAGEMENT INVOLVEMENT - PRIMARILY RELATED TO RP RECORDS ISSUE REMOVAL FROM SITE OF SPECIFIC SEG SUPERVISORS - PRIMARILY RELATED TO RP RECORDS ISSUE Page 19 i

L--...-----..- - - . . - . .

CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

I (Continued)

CORRECTIVE ACTIONS (Continued): .

COMMUNICATED MANAGEMENT'S INTENT ON THE ROR PROCESS -- TO CORRECT RADIOLOGICAL OCCURRENCES AND BEHAVIOR, NOT AS A DISCIPLINARY TOOL IMPROVED THE ROR PROCEDURE AND PROCESS ;

NEW SEG SUPERVISORS WERE SENSITIZED TO DETECT POTENTIAL ;

INTIMIDATION ATMOSPHERE INCREASED PSC AND SEG MANAGEMENT INVOLVEMENT IN THE ROR PROCESS WITH REORGANIZATION OF SEG i

IMPROVED VISIBILITY OF THE ROR PROCESS IN QA SURVEILLANCE AND PSC OVERSIGHT ACTIVITIES -

PSC PERIODICALLY INVOLVED IN INVESTIGATION OF RORs l

i 1

Page 20

W TT MU~ l fl F UN R CONCERNS AND CORRECTIVE ACTIONS

SUMMARY

(Continued)

IN CONCLUSION, SAM REPORT DETERMINED THAT THE MAJOR ELEMENTS CONTRIBUTING TO AN ATMOSPHERE OF H & I WERE NO LONGER FACTORS WITHIN A FEW WEEKS OF DISCOVERY ALSO, SAM REPORT CONCLUDED WORKERS FOUND EFFECTIVE MEANS OF ADDRESSING SAFETY CONCERNS SUCH THAT THE IDENTIFICATION AND RESOLUTION OF SAFETY CONCERNS WERE NOT COMPROMISED Page 21 l

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MK BACKGROUND

=

MK HAS LONG HISTORY OF EXCELLENCE IN NUCLEAR POWER INDUSTRY, AND MK'S GOVERNMENT AND ENVIRONMENTAL GROUP HAS SIMILAR HISTORY IN DECOMMISSIONING AND CLEANUP OF DOE AND DOD FACILITIES

CURRENT OTHER NUCLEAR PROJECTS INCLUDE TWO STEAM GENERATOR REPLACEMENTS AND WORK WITH WESTINGHOUSE ON AP600 MK HAS 80 YEAR HISTORY OF SUCCESSFUL PROJECTS EMPLOYING CRAFT AND PROFESSIONAL PEOPLE -- TAKE PRIDE IN BEING FAIR AND EQUITABLE EMPLOYER MK HAS NOT AND WILL NOT CONDONE HARASSMENT AND/OR INTIMIDATION OF OUR EMPLOYEES OR THE EMPLOYEES OF OTHERS INVOLVED IN ANY PROJECT Page 23 L - - - _ - _ _ _ _ _ _ - _ _ - - _ _ _

Jr_ID WL cT M rm v D rw I

MK POSITION l

l

MK HAS REVIEWED THE SAM INVESTIGATION REPORT AND THE SYNOPSIS OF THE NRC l OFFICE OF INVESTIGATION'S REPORT ,

I THERE WAS AN INDEPENDENT BASIS FOR LAYING OFF THE 4 LABORERS - THAT BASIS WAS THE FACT THAT THEIR WORK TASKS WERE COMPLETE WE AGREE THAT A PERCEPTION WAS 10JADVERTENTLY CREATED THAT RAISING SAFETY CONCERNS COULD RESULT IN RETALIATION WE ALSO AGREE THAT WE HAD AN MK SUPERINTENDENT THAT DID NOT INTERFACE APPROPRIATELY WITH SEG RPTs

UPON DISCOVERY, MK PROJECT AND EXECUTIVE MANAGEMENT ALONG WITH PSC AND WT INVESTIGATED AND INITIATED IMMEDIATE CORRECTIVE ACTIONS; AN EXAMPLE WAS THE PROMPT REMOVAL OF THE SUPERINTENDENT FROM THE PROJECT Page 24

7 LAYOFF OF 4 LABORERS- 1 4 LABORERS WERE ASSIGNED TO CONCRETE CORE DRILLING TASK IN NOVEMBER !

1992, WHICH WAS COMPLETED IN EARLY MARCH 1993 ,

RE-ASSIGNED TO HIGH DENSITY BLOCK REMOVAL TASK, WHICH LASTED APPROXIMATELY ONE WEEK

NO ADDITIONAL ASSIGNMENTS WERE IDENTIFIED 4 LABORERS WERE OBVIOUS CANDIDATES FOR LAYOFF WITHOUT DISRUPTING l EXISTING WORK CREWS l

LAYOFF OF 4 LABORERS WAS ONE OF SEVERAL LAYOFFS IN 1993:

JANUARY 7 7 LABORERS MARCH 9 4 LABORERS MARCH 25 2 LABORERS LABORERS' UNION DETERMINED THEIR CLAIMS HAD NO MERIT

( Page 25

J m M TM M DD M M LAYOFF OF 4 LABORERS (Continued) l *

"OPEN DOOR POLICY" INCIDENT INVOLVED UNION GENERAL FOREMAN' WHO DID NOT UNDERSTAND POLICY -- UNION GENERAL FOREMAN WAS COUNSELED AND RETRAINED TO AVOID FUTURE PROBLEMS Page 26

W m a m m M ime M M M M M m CM M m m m RESPONSE TO WORKERS CONCERNS IDENTIFIED TO NRC NRC INDICATED 4 MK LABORERS WERE LAID OFF FOR RAISING RADIOLOGICAL AND INDUSTRIAL SAFETY CONCERNS, INCLUDING:

1) AIR QUALITY WORKERS WERE PROVIDED RESPIRATORS APPROPRIATE FOR THE ENVIRONMENT DURING HIGH DENSITY BLOCK REMOVAL, LABORERS IN HALF-FACE RESPIRATORS WERE WORKING IN THE SAME AREA AS WORKERS IN FULL-FACE RESPIRATORS AND QUESTIONED THE DISPARITY HEASON FOR DISPARITY WAS THAT FULL-FACE RESPIRATORS WERE ISSUED TO OPERATORS OF JACKHAMMERS FOR PROTECTION AGAINST FLYING DEBRIS AND CHlPS AIR MONITORING INDICATED AREA WAS NOT RADIOLOGICAL HAZARD, ONLY DUST NRC INSPECTION IN JULY 1993 CONCLUDED NO RADIOLOGICAL CONCERNS Page 27

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RESPONSE TO WORKERS CONCERNS IDENTIFIED TO NRC (Continued)

2) WORK IN A RAD 10 LOGICALLY CONTROLLED AREA WITHOUT AN APPROPRIATE RACIA TION WORK PERMIT PSC AND THE WT ARE NOT AWARE OF THIS CONCERN; DURING OUR INVESTIGATIONS, THIS ISSUE DID NOT ARISE -- PROPER RWP COVERAGE HAS ALWAYS BEEN EMPHASIZED DURING THE FSV DECOMMISSIONING PROJECT DURING THE NRC'S JULY 1993 INSPECTION, RWP PRACTICES WERE REVIEWED AND FOUND ACCEPTABLE

3) PERSONNEL CONTAMINATION WHILE COREDRILLING SOME PERSONNEL WERE WETTED WITH CONCRETE SLURRY WHICH CONTAINED LOW LEVELS OF TRITIUM - NO PERSONNEL CONTAMINATIONS RESULTED NRC'S JULY 1993 INSPECTION CONCLUDED APPROPRIATE CORRECTIVE ACTIONS WERE TAKEN Page 28

R FW1 F7 FU L_J L_JR fl Fl Fl E l

FORT ST. VRAIN PROJECT SAFETY MK HAS MADE SUBSTANTIAL COMMITMENT TO SAFETY: .

INDUSTMAL SAFETY MK PROVIDED 3 FULL TIME SAFETY PROFESSIONALS AND 1 FULL TIME NURSE TO ADDRESS SAFETY ISSUES - SPEND MOST OF THEIR TIME WITH WORKERS, ADDRESS SAFETY CONCERNS AS THEY ARISE

SAFETY INCENTIVE PROGRAM RADIOLOGICAL SAFETY

ALARA SUGGESTION PROGRAM

INCREASED COMMUNICATION WITH RPTS l WORK PLANNING AND ALARA ENGINEERING

MK MEMBERS ON ALARA COMMITTEE Page 29

1 fMN FU l_J L_J U I__JU i F- U CWMUM l

FSV SAFETY STATISTICS LOST DAY INCIDENCE RATE s.s R

INDUSTRY AVERAGE l

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Page 31

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MK ACTIONS

MK OPEN DOOR POLICY MK MAINTAINS AN OPEN DOOR POLICY WHEREIN PERSONNEL ARE ENCOURAGED TO BRING FORTH ISSUES TO MANAGEMENT AND/OR THEIR RESPECTIVE UNION REPRESENTATIVES THIS OPEN DOOR POLICY WAS DISCUSSED WITH ALL LEVELS OFMKMANAGEMENT ON MARCH 14,1994 TO ENSURE A COMPLETE UNDERSTANDING OF THE POLICY AMONG ALL MANAGEMENT PERSONNEL OPEN DOOR POLICY WAS DISCUSSED WITH ALL EMPLOYEES ON MARCH 10,1994, AUGUST 10, 1994, AND PERIODICALLY DURING WEEKLY TOOLBOX SAFETY MEETINGS SPECIFICALL Y, THE UNION GENERAL FOREMAN DID NO T UNDERSTAND OPEN DOOR POLICY - WAS COUNSELED AND RETRAINED TO A V0lO FUTURE PROBLEMS Page 32 l

i rn o o o o FT o o o o F- T o o o o o o o F-MK ACTIONS (Continued)

MK LAYOFF PROCEDURES .

SENSITIVITY TRAINING WAS CONDUCTED WITHALL MKAND UNIONMANAGEMENT ON HARASSMENT AND INTIMIDA TION ISSUES AND THE ASSOCIA TED ELEMENTS OF 10 CFR 50.7 AS RELATED TO LAYOFFiMPACTS MANAGEMENT MEETINGS WERE HELD TO ENSURE UNIFIED EXPECTATIONS AND INVOLVEMENT OF ALL MANAGEMENT LEVELS REGARDING FUTURE LAYOFF DECISIONS EMPHASIS PLACED ON WORK PLANNING TO MINIMlZE LAY-OFF AND REHIRE CYCLES PUBLISHED ENHANCED GUIDELINES ON MAKING LAYOFF DECISIONS TO SITE MK MANAGEMENT PERSONNEL ON AUGUST 15,1994 Page 33

--__:.x . = - ~ . - . - -

MK ACTIONS (Continued)

MK FEEDBACK MECHANISMS: .

4

TOOL BOX SESSIONS WITH CRAFT AND RPT PERSONNEL l

JOB BRIEFINGS

MEETINGS WITH THE UNION REPRESENTATIVES MANAGEMENT FEEDBACK FROM SUPERVISORY AND FOREMAN LEVELS i

STOP WORK AUTHORITY

MANAGEMENT MEETINGS WITH PSC AND WT

PSC/WT QA MONITORINGS AND AUDITS

RORs EMPLOYEE MEETINGS TO ADDRESS INAPPROPRIATE PERCEPTIONS AND THE POTENTIAL CHILLING EFFECTS

PSC ENHANCED OVERSIGHT AND PSC HOTLINE TO IDENTIFY POTENTIAL PROBLEMS AREAS Page 34 1

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1 r ,- r r r r r r t__f r, r r - r,__r m, r-i MK PERFORMANCE CONSIDERATIONS PERFORMANCE SHOULD BE CONSIDERED IN EVALUATING THIS APPARENT VIOLATION:

PROJECT SAFETY RECORD

PROJECT ALARA RECORD

PROMPT, DECISIVE ACTIONS TAKEN BY PSC AND THE WT, INCLUDING REMOVAL OF A SUPERINTENDENT

OSHA, DEPARTMENT OF LABOR, AND THE UNION TOOK NO ACTION RELATIVE TO THE 4 LABORERS' CLAIMS t

4 LABORERS' GRIEVANCE WAS ONLY GRIEVANCE FILED, WAS RESOLVED AT FIRST STEP, IN FAVOR OF MK MK'S LONG HISTORY OF EXCELLENCE IN NUCLEAR ACTIVITIES Page 35 L. _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ . _ _

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m w 17 Fu 1__J7 IR El__ra FL_J7 rm rm FU DISCRETIONARY CONSIDERATIONS AS STATED PREVIOUSLY, THERE WAS AN INDEPENDENT BASIS FOR CRAFT LAYOFF, HOWEVER, THE WEIGHT OF EVIDENCE FROM THE SAM REPORT SUPPORTS THE PERCEPTION THAT THE EXPRESSION OF SAFETY CONCERNS HAD SOME INFLUENCE ON LAYOFF DECISION AN ATMOSPHERE EXISTED IN WHICH THE PERCEPTION OF SOME EMPLOYEES WAS THAT PRODUCTION WAS EMPHASIZED OVER SAFETY AND PROCEDURE COMPLIANCE, AND RAISING SAFETY CONCERNS COULD RESULT IN RETALIATION YOUR MAY 19,1995, LETTER ASKED PSC TO ADDRESS THE ISSUES OF SEVERITY AND I CIVIL PENALTY I PSC BELIEVES THIS APPARENT VIOLATION SHOULD BE NO MORE THAN SEVERITY LEVEL IV, BECAUSE:

PROMPT MANAGEMENT INVOLVEMENT AND CORRECTIVE ACTION

MAJOR H & I ISSUES WERE SELF-IDENTIFIED

> H&l ACTS INVOLVED ONLY FIRST LINE SUPERVISION

NO SIGNIFICANT IMPACT ON ENVIRONMENT OR PUBLIC HEALTH AND SAFETY Page 37

m r m x-_rt ra r uw cw w ra ra rD' DISCRETIONARY CONSIDERATIONS (Continued)

REASONS WHY APPARENT VIOLATION SHOULD BE NO MORE THAN SEVERITY LEVEL IV (Continued): ,

> NO SAFETY SIGNIFICANCE o SAM REPORT CONCLUDED WORKERS FOUND EFFECTIVE MEANS OF ADDRESSING SAFETY CONCERNS SUCH THAT THE IDENTIFICATION AND RESOLUTION OF SAFETY CONCERNS WERE NOT COMPROMISED ,

l o SAFETY SIGNIFICANCE OF FORT ST. VRAIN DECOMMISSIONING IS NOT COMPARABLE TO POWER REACTOR o NO WORKER WAS OVEREXPOSED

NO CIVIL PENALTY SHOULD BE ASSESSED

(

l Page 38 1

w mw ruum a cJun tv cm ru DISCRETIONARY CONSIDERATIONS (Continued)

ENFORCEMENT DISCRETION IS APPROPRIATE, PER NRC ENFORCEMENT POLICY SECTION Vll.B.7:

1. PSC/WT SELF-IDENTIFIED WORKER PERCEPTIONS AND RELUCTANCE TO RAISE SAFETY CONCERNS

2. PSC/WT TOOK PROMPT, COMPREHENSIVE, AND EFFECTIVE CORRECTIVE ACTIONS TO ADDRESS BOTH PARTICULAR SITUATION AND OVERALL WORK ENVIRONMENT

3. ADDITIONAL MITIGATING CONSIDERATIONS l

l Page 39

DISCRETIONARY CONSIDERATIONS (Continued)

1. IDENTIFICATION t

THE 4 LABORERS CONTACTED NRC DIRECTLY AS OPPOSED TO CONTACTING PSC/WT MANAGEMENT -THIS CIRCUMVENTED THE SELF-IDENTIFICATION PROCESS IDENTIFICATION WAS MORE COMPLEX BECAUSE WORKERS DID NOT REPORT DIRECTLY TO PSC l

WE DID SELF-IDENTIFY.

THE FEBRUARY 3,1994, INCIDENT BETWEEN THE MK SUPERINTENDENT AND AN RPT A PERCEPTION IN A CROSS SECTION OF THE WORK FORCE THAT PRODUCTION WAS EMPHASIZED OVER SAFETY 1

THREATS BY MK SUPERINTENDENTS / SUPERVISORS AGAINST 96?TS VIOLATIONS OF RADIATION PROTECTION PRACTICES BY MK SUPERINTENDENTS / SUPERVISORS Page 40

_ y - - -- _

l DISCRETIONARY CONSIDERATIONS (Continued)

WE DID SELF-IDENTIFY: .

COWORKERS' PERCEPTION THAT THE LAYOFF DECISION WAS NOT BASED ON WORKERS SKILLS PERCEPTION OF SOME EMPLOYEES THAT EXPRESSION OF CONCERNS WOULD RESULT IN RETALIATION FAILURE OF SEG MANAGEMENT TO FORCEFULLY ADDRESS INTIMIDATING BEHAVIOR l

MISPERCEPTION THAT THE ROR PROGRAM WAS A DISCIPLINARY TOOL LOSS OF CONFIDENCE ON PART OF RPTS IN BOTH THE ROR PROGRAM AND IN THEIR MANAGEMENT 1

Page 41 L-_- . - - - - - - - _ - . _ _ _ _ - _ _ _ . _ -

DISCRETIONARY CONSIDERATIONS (Continued)

2. CORRECTIVE ACTIONS PSC AND THE WT TOOK PROMPT AND AGGRESSIVE ACTION AS SOON AS WE WERE AWARE OF THE POTENTIAL HARASSMENT AND INTIMIDATION CONCERNS

WE WERE INFORMED OF THE POTENTIAL H & I CONCERN ON J ANUARY 19, 1994

> AFTER FEBRUARY 3,1994, INCIDENT WITH MK SUPERINTENDENT, PSC REQUESTED WT TO DEVELOP A CORRECTIVE ACTION PLAN TO PREVENT RECURRENCE

> WE RETAINED SERVICES OF STIER, ANDERSON, AND MALONE ON FEBRUARY 22,1994

> SAM CONCLUDED MAJOR ELEMENTS OF H & 1 ATMOSPHERE WERE NO LONGER FACTORS AT THE TIME OF THE WORK STOPPAGE - WITHIN A FEW WEEKS OF IDENTIFICATION i > ADEQUACY OF CORRECTIVE ACTIONS CONTINUES TO BE PERIODICALLY MONITORED TO ENSURE EFFECTIVENESS

EFFECTIVE CORRECTIVE ACTIONS FULLY IMPLEMENTED BY AUGUST 1994, WELL BEFORE SAM REPORT WAS COMPLETED IN MARCH 1995 Page 42

- - . . l

y_

DISCRETIONARY CONSIDERATIONS (Continued)

3. ADDITIONAL MITIGATING CONSIDERATIONS PSC/WTBEllEVE THEREAREADDITIONAL MITIGA TING CONSIDERA TIONS THA T THENRC SHOULD CONSIDER IN ASSESSING THIS APPARENT VIOLA TION:

LICENSEE PERFORMANCE JULY 1993 NRC SPECIAL INSPECTION TEAM CONCLUDED RADIOLOGICAL CONTROLS WERE ACCEPTABLE OSHA FOUND NO MERIT IN MARCH 1993 COMPLAINTS PSC HAS HAD A GOOD PRIOR PERFORMANCE IN THIS AREA - WE HAVE LAID OFF APPROXIMATELY 750 EMPLOYEES WITH ONLY ONE PRIOR INCIDENT IN 1991 WHICH PSC DENIED WAS VALID.

s.

6 Page 43

e r w uuu-uwuy u w u m ua 1

DISCRETIONARY CONSIDERATIONS (Continued)

MITIGATING FACTORS (Continued) l

PRIOR OPPORTUNITY TO IDENTIFY PREVIOUS INSPECTIONS DID NOT REVEAL ANY CONCERNS -- BY PSC QA, NRC, OUTSIDE RP INSPECTION l INDIVIDUAL RORs AND PROBLEM REPORTS WERE GENERATED, INVESTIGATED AND CORRECTIVE ACTIONS TAKEN WITHOUT IDENTIFYING WORKER PERCEPTIONS ABOUT RAISING SAFETY CONCERNS MULTIPLE OCCURRENCES AND DURATION PREVIOUSLY DENIED DISCRIMINATION CASE WAS UNRELATED AND OCCURRED MORE THAN 4 YEARS AGO THE SAM REPORT CONCLUDED THAT THE MAJOR ELEMENTS CONTRIBUTING TO I AN ATMOSPHERE OF H & I WERE NO LONGER FACTORS WITHIN A FEW WEEKS OF DISCOVERY l

1 Page 44 1

i CLOSING

1. AN ATMOSPHERE EXISTED IN WHICH THE PERCEPTION OF SOME EMPLOYEES WAS l THAT PRODUCTION WAS EMPHASIZED OVER SAFETY AND PROCEDURAL COMPLIANCE, AND RAISING SAFETY CONCERNS COULD RESULT IN RETALIATION

2. .THERE WAS AN INDEPENDENT BASIS FOR CRAFT LAYOFFS: HOWEVER, THE WElGHT OF EVIDENCE FROM SAM REPORT SUPPORTS PERCEPTION THAT THE EXPRESSION OF SAFETY CONCERNS HAD SOME INFLUENCE ON LAYOFF DECISIONS

3. OUR CORRECTIVE ACTIONS HAVE BEEN EXTENSIVE AND ONGOING, ENCOURAGING WORKERS TO IDENTIFY SAFETY CONCERNS WITHOUT FEAR OF REPRISAL

4. OUR SYSTEM HAS BEEN SHOWN TO WORK - WE HAVE THE ABILITY TO DEAL OPENLY AND FAIRLY WITH WORKFORCE PROBLEMS AND REACH EFFECTIVE SOLUTIONS I

Page 45 i

1 Exhibit ll

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FORT ST. VRAIN DECOMMISSIONING PROJECT VALUES L

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DON WAREMBOURG AND MARY FISHER I E i E

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L MARCH 9 & 10,1994

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'MEMEEED#

l WHY ARE WE HERE?

I l o PSC AND THE WESTINGHOUSE TEAM MANAGEMENT BELIEVE WE NEED TO l

l MEET WITH EVERY EMPLOYEE TO DISCUSS THE FOLLOWING AREAS:

I l

CORE VALUES AND WORK PLACE CONDUCT I

RECENT EVENTS I

l

PLANNED ACTIONS PSC BRIEFINGS -

OPEN DOOR POLICY - - -,

EMPLOYEE CONCERN PROGRAM. .

INDEPENDENT ASSESSMENT

CONCLUSIONS I

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L _ -- _ --------- _ -- - _ - - - - - - - - - - - - - - - - - - - - - - - - _ - - - - -- - - -

L 1 CORE VALUES AND WORK PLACE CONDUCT o THE HEALTH, SAFETY AND WELL BEING OF EVERY INDIVIDUAL WORKING ON SITE AND HEALTH AND SAFETY OF THE PUBLIC

> SAFETY IS ALWAYS FIRST; NO JOB OR SCHEDULE IS SO IMPORTANT THAT APPROPRIATE SAFETY PRECAUTIONS ARE NOT OBSERVED H

EMPLOYEES HAVE THE RIGHT TO STOP WORK IF THEY BELIEVE THAT

[ AN UNSAFE CONDITION EXISTS

]

" THIS INCLUDES RADIOLOGICAL OR INDUSTRIAL CONDITIONS, PRACTICES AND IMPLEMENTATION MEASURES THAT ARE DESIGNATED FOR AN RCA

.i-1 o PROMOTE A SAFE WORK PLACE AND AN ENVIRONMENT IN WHICH

] EMPLOYEES ARE FREE TO RAISE SAFETY CONCERNS WITHOUT FEAR OF RETALIATION PSC AND THE WT REQUIRE PERSONNEL TO REPORT TO THEIR IMMEDIATE SUPERVISOR OR OTHER APPROPRIATE MANAGEMENT UNSAFE ACTS SO THAT CORRECTIVE ACTIONS CAN BE TAKEN L_

E o INTEGRITY AND HIGH STANDARDS OF BUSINESS ETHICS

PROFESSIONAL, OPEN AND HONEST COMMUNICATIONS PROCEDURE COMPLIANCE IS MANDATORY .

> TEAMWORK

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I L o EQUAL OPPORTUNITY / DIVERSE WORK ATMOSPHERE

RESPECT INDIVIDUALISM l

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RECENT EVENTS o AN NRC INSPECTOR ARRIVES ON SITE TO INVESTIGATE ALLEGED CLAIMS OF WRONGFUL DISCHARGE o DURING THE INVESTIGATION, A SUPERINTENDENT THREATENED A RP ~

TECHNICIAN FOR WRITING A ROR i

o IT APPEARS THAT THE NRC INVESTIGATION HAS EXPANDED TO INCLUDE I THE OVERALL SITE ATMOSPHERE FOR RAISING SAFETY CONCERNS L

i ,o PSC MANAGEMENT MET WITH WT MANAGEMENT TO REQUEST AN ACTION PLAN TO ASSESS THE SITUATION

] -

o DISCIPLINARY ACTION WAS TAKEN AGAINST THE SUPERINTENDENT FOR THREATENING THE RP TECHNICIAN.

I w

o FURTHER INFORMATION IS RECEIVED BY WT MANAGEMENT AND PSC

/

PERSONNEL AT WT MEETINGS TO DISCUSS TTtfE ISSUES THAT HAVE ARISEN L

o PSC AND WT MANAGEMENT DECIDE 'IV UNDERTAKE AN INDEPENDENT E THIRD PARTY ASSEESMENT TO PROACTIVELY ADDRESS THE SITUATION o THE NRC INVESTIGATION CONTINUES

PSC AND THE WT ENCOURAGE YOU TO COOPERATE FULLY WTIE THE NRC BY PROVIDING TRUTHFUL, FACTUAL AND OBJECTIVE INFORMATION S_______________________________________________________ ________ _ ____ _.

r L

RECENT EVENTS 5 .?,

o THE ACTIONS DISCUSSED HERE TODAY ARE BASED ON CONTINUING

[ CONCERN FOR THE WORK FORCE, SAFETY ON THE PROJECT AND THE COMMITMENT OF PSC AND THE WT TO ENSURE THAT EMPLOYEES ARE FREE TO RAISE CONCERNS RFEARDING SAFETY.

~

THESE ACTIONS ARE NOT CONNECTED TO THE NRC INVESTIGATION L

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I PLANNED ACTIONS I

e PSC BRIEFINGS

PSC IS BRIEFING ON SITE PERSONNEL TO MAKE KNOWN THE VALUES FOR THE FORT ST. VRAIN DECOMMISSIONING PROJECT I

o PSC AND WT MANAGEMENT HAVE ALWAYS HAD AN OPEN DOOR POLICY

> THIS OPEN DOOR POLICY WILL CONTINUE TO BE IN EFFECT THROUGHOUT THE PROJECT ,

r ., ,. .

> AS A REMINDER, IF YOU HAVE QUESTIONS OR CONCERNS WE STRONGLY ENCOURAGE YOU TO UTILIZE THE OPEN DOOR POLICY:

YOUR MANAGEMENT .

PSC MANAGEMENT PSC PERSONNEL j

j THE HOT LINE - 294-8985 AFTER NOON ON MARCH 14, 1994 I

I I

I .

I I

L r

L r PLANNED ACTIONS L

E o EMPLOYEES' CONCERN PROGRAM

= PSC IS ESTABLISHING AN OFF SITE HOT LINE TO SUPPLEMENT THE E

EMPLOYEES' CONCERN PROGRAM SO THAT EMPLOYEES MAY ,

ANONYMOUSLY REPORT ANY CONCERNS IMMEDIATE SAFETY CONCERNS SHALL BE HANDLED BY THE STOP WORK AUTHORITY EMPOWERED TO ALL EMPLOYEES ON

[

SITE - SAFETY SUGGESTIONS CAN BE CALLED IN ON THE HOT LINE THE HOT LINE WILL BE AVAILABLE 24 HOURS A DAY TO A >

ANSWERING MACHINE MONITORED BY PSC PERSONNEL L A MESSAGE WILL BE INCLUDED TO INFORM PERSONNEL AS TO WHEN THE PHONE WILL BE ANSWERED BY AN INDIVIDUAL

[ ALL COMMENTS AND REQUESTS WILL BE PASSED ANONYMOUSLY ON TO APPROPRIATE MANAGEMENT PERSONNEL FOR r RESOLUTION ;

L MANAGEMENT WILL ENSURE A TIMELY INVESTIGATION AND r PROVIDE ANY NECESSARY RESPONSE INCLUDING l L COMMUNICATIONS AS APPROPRIATE i I

"

THE PROCESS TO ACCESS AND HOW TO USE THE HOT LINE WILL BE POSTED ON OFFICIAL BULLETIN BOARDS E

L L

r 1

w

I I -

PLANNED ACTIONS I

e INDEPENDENT ASSESSMENT I

PSC AND THE WESTINGHOUSE TEAM HAVE AGREED THAT IT IS IN THE I BEST INTEREST OF THE PROJECT TO CONDUCT AN INDEPENDENT THIRD' PARTY ASSESSMENT

THE OBJECTIVE OF THIS ASSESSMENT IS TO EVALUATE THE SITE WORK ENVIRONMENT AND SAFETY CULTURE WHICH WILL ALLOW PSC AND THE WT TO TAKE CORRECTIVE ACTIONS AS APPROPRIATE ,

PSC AND THE WT EXPECT YOUR PARTICIPATION AND I COOPERATION j > THE ASSESSMENT IS EXPECTED TO BEGIN ON MARCH 14,1994 AND LAST E ABOUT ONE MONTH:

AN INITIAL-INFORMAL INTERVIEW WITH VARIOUS SITE PERSONNEL WILL BE CONDUCTED IF APPROPRIATE AND YOU AGREE, A FORMAL DOCUMENTED

.l INTERVIEW WILL THEN BE CONDUCTED l l YOU WILL HAVE A CHANCE TO REVIEW, CORRECT OR CHANGE YOUR DOCUMENTED INTERVIEW PRIOR TO IT BEING FINALIZED l

I ,

CURRENTLY, WE ARE STRUCTURING THE DETAILS OF THIS ASSESSMENT AND WE ARE LOOKING FOR YOUR INPUT TO FINALIZE THE PROGRAM I

I .

l I

I

r L

7 CONCLUSIONS L

o PSC, AND EACH COMPANY OF THE WT, IS DEDICATED TO PROMOTE A QUALITY CONSCIOUS, SAFE, AND PRODUCTIVE WORK ENVIRONMENT, IN p WHICH ALL EMPLOYEES FEEL FREE TO RAISE CONCERNS WITHOUT FEAR OF RETALIATION l

o TO FURTHER PROMOTE, THIS TYPE OF WORK ENVIRONMENT THE INDEPENDENT ASSESSMENT WILL BE CONDUCTED TO IDENTIFY AREAS REQUIRING ATTENTION OR IN NEED OF IMPROVEMENT L

I o PSC AND WT MANAGEMENT CONTINUE TO HAVE AN OPEN DOOR POLICY l o A SUPPLEMENT TO THE EMPLOYEES' CONCERN PROGRAM IN THE FORM OF A HOT LINE HAS BEEN ESTABLISHED FOR YOUR USE I

]

! o CONDUCT OF THE PLANNED INDEPENDENT ASSESSMENT TO IDENTIFY AREAS FOR IMPROVEMENT CAN ONLY BE DONE WITH YOUR HELP L

[

~

[

- - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ . - . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ - _ - _ - _ - _ . - _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ . . _ _ _ _ _ _ _ - _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ . - _ _ _ - J

Exhibit lli

]

. s J

] PROJECT

PHILOSOPHIES, .

r POLICIES AXD

] PROGRAMS b -

L

~

1 Steve Tritch, General Manager

[ Westipghouse Nuclear Technology Division

[

f l

I Pubilg roni sT. VRAIN NUCt. EAR GENERATING STATION Scrvlco* pusuc eenvms comeamy or cos.onano t

[

AGENDA

( FORT SAINT VRAIN r EXECUTIVE PRESENTATION MEETING L

r AGENDA & OPENING REMARKS CRAWFORD BRIEF REMARES, PROGRAM DIRECTOR WAREMBOURG INTRODUCI10N 1RTIUt -

PROJECT PHIIASOPHIES, POLICIES, PROGRAMS TRFICI p

L INDUSTRIAL SAFEIY PROGRAM PARDI r

RADIATION PRO 1ECTION & RADWASTE PROGRAMS ARROWSMrm .

I !

CORE VALUES AND WORK ATMOSPHERE CRAWPORD i l

OPEN DISCUSSION L

f INDEPENDENT ASSESSMENT STIER FOLLOWING THE MEETING A DISCUSSION Wrm EXECS & KEY SrIE PROJECT MANAGEMENT PERSONNEL ON THE INDEPENDENT ASSESSMENT ACTIVITIES, PURPOSE & EXPECTATIONS.

l 1

i so .m.m.ma

(

L - to e Methods for Addressing Issues and/or Concerns 2

o Stop Work Authority L

o Open Door Policy

) o PSC Hotline 1

- o Self Assessments / Internal Reviews L

e a Quality Performance Feedback (QPF) m Non-Conformance Report (NCR)

L a Problem Report (PR) -

a Radiological Occurrence Report (ROR) a SEG Self-Assessment' Program L

r 0 Employee Responsibilities l

o Methods for Addressing Issues and/or Concerns J-/d (cont'd) s SEG Self-Assessment Program Management tool to identify areas for improvements.

[

o Employee Responsibilities a Utilize site programs for identifying issues. ,

a Utilize programs for identifying non-

[ conformances or potential problems.

m Identify issues that may be safety or other

( concerns to the project.

a As managers / supervisors you have to r

l facilitate this to ensure we know of and

) address issues.

s If are not sure, elevate.

I l

L l

r

)

o Methods for Addressing issues and/or Concerns 4-/CP (cont'd) a

- o Self Assessments / Internal Reviews L

. Responsibility of all to identify and report 7 non-compliances.

. Basis premise is self police.

. Help us identify root cause and trends for corrective action.

L '

s Quality Performance Feedback (QPF)

Document programmatic non-conformances (i.e. incorrect work L package or violation of work processes). ~

s Non-Conformance Report-(NCR)

Deficiency in characteristic, l documentation or procedure which causes unacceptable or undetermined

}

l item quality.

) a L Problem Report (PR)

PSC mechanism to transmit concerns

[ to WT.

Also used to document audit fm' dings. i

~

t a Radiological Occurrence Report (ROR)

RP program to identify non-compliance or deficiencies.

Can be system, process or personnel related.

o Methods for Addressing Issues and/or Concerns F/O o Important that as supervisors / managers you support programs and encourage people to 7 utilize.

o Stop Work Authority a All employees have.

a Problem exists to comply for safety as planned or observe unsafe condition, employee responsibility to stop activity. .

m Covered in PSC procedure and WT Site

[ Specific Safety Manual.

I o Open Door Policy a Chance to address potential problems before become major problems.

E o PSC Hotline a Just established - another mechanism.

m Timely investigation and resolution key

}

l along with communication back to person

) if possible.

[

[ . l r

~.

e Project Guidelines

] ,.

)

o NRC Rules and Regulations 7 -

o

] Decomminaioning Plan and Tech Specs

)

o Project Control Manual '

] . . ,

o Project Quality Plan

)

a

] Decommissioning Manual Quality Assurance I a SEG QA Manual 2 o Site Specific Safety Manual l

E r -

O PSC Procedures

Project Guidelinas (cont'd) / to SEG QA Manual

. Covers site characterization and final

} site survey, Radiation Protection, and waste management including packaging and transportation.

o Site Specific Safety Manual .

m Industrial safety program for all WT site employees.

m Collection of applicable safety procedures h including accident prevention and treatment J guidelines, hazardous waste management, fire j protection, substance abuse, confined space, '

asbestos awareness, etc.

/

r o PSC Procedures e

L i

I E

Project Guidelines ( -ta L o NRC Rules and Regulations r 's Code of Federal Regulations a Also DOT, State OSHA and other regulations as well.

m Our programs on this Project have to ensure compliance.

o Decommissioning Plan and Technical Specs .

m Approved by th' NRC; our licensing Bible for this project.

m Essential we follow and work within bounds defined and rules established.

o Project Control Manual a Administrative Procedure Manual for Project

~

]

s Governs areas such as Work Control, QA, Financial, Planning and Scheduling.

O Project Quality Plan a Defines QA plan, program manuals and

]

L implementing procedures to be applied on Project; includes description of interface L

between DQAM and SEG QA Manual.

Decommissioning Quality Assurance Manual (DQAM) I

] . Covers all WT activities except most r SEG RP and Radwaste.

. Contains QA project specific r

procedures to control work.

7-/0 L e Core Values and Work Place Conduct r

H o Safety First L

r O Environment to Freely Raise Safety Concerns or Issues

[

O Integrity and High Standards of Business

)'

i Ethics '

m I

o Verbatim Procedural Compliance !

a E o Teamwork --

r 1

o Professional, Open, Honest Communications u

r 0 Equal Opportunity / Diverse Work Atmosphere

/G -t o L e Core Values and Work Place Conduct L o Safety First

- a Do have an obligation to PSC and'our companies to perform and meet our

~

commitments; however we will never tolerate doing so at the expense of safety.

o Environment to Freely Raise Safety Concerns u or Issues a Core is ability to communicate with direct E supervision and others; Project has several mechanisms for this. -

o Integrity and High Standards of Business -

Ethics o Verbatim Procedural Compliance 7

m Procedures are there for a reason; if m f' d that a procedure will not work as written

[ or do not understand, stop and bring it to appropriate person's attention to fix.

L '

o Teamwork o Professional, Open, Honest Communications r o Equal Opportunity / Diverse Work Atmosphere a Respect individuality and the talents and perspective each person bridgs.

[

L--------------------_

/V\ R

~

AeV rMMdt I - 't E

DDUSTRIAL SAFETY PROGRAM z

e Regulations

}

I o OSHA -

h u o NRC E o EPA r

L o CDH '

1 F

o DOT

]

o PSC r

?

2 E

r - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

g ey i INDUSTRIAL SAFETY PROGRAM

$ e Purpose and Role of the Project l Safety Program t

l l o Site Specific Safety Manual

I ~

1 lI o Management and Supervision l

I l i ~

g I

I I .

I f

' .e 7 E

INDUSTRIAL SAFETY PROGRAM

[ e ' Project Specific Safety Challenges r

o Lead

]

o Asbestos .

E o Chemical Control Program /

Hazard Communication .

r

] o Heavy Lifts -

~

o Diamond Wire Cutting

]

] o Oxylance Cutting I

] o Plasma Arc Cutting o Long Handle Tools

)

]

L o Training n

o Records

}

1

{_ _- - - - - - - - - - - - - - - - - - - - - - -- - -

v-y j I3DUSTRIAL SAFETY PROGRAM

] e Employee Responsibilities F . .

)

1 .

L

?

J

) ,

2

~

[

E - -

1

1 o rgy g ,c u, o o o o o o og- .

C2!91Mbi EMPLOYEE RESPONSIBILITIES '

o SAFETY 1

o COMPLIANCE l

0 ALARA l

0 STOP WORK AUTHORITY O COMMUNICATIONS l

'o TEAM WORK o CONDUCT OF OPERATIONS

m. _ _ _ _ _ . _ _ _ _ - . _ _ _ _ _ _ _ _ _ . _ _ . -

_r o o o o_o o o o o o o o my;9 l

2!@Mhi l RECORDS o DOSIMETRY l

o SURVEYS I

5,500 Generated during 1993 0

l CALIBRATIONS AND ANALYTICAL RESULTS

! o SUPPORT OF UNCONDITIONAL RELEASE OF 4

MATERIALS o ESTIMATED 60,000 OPERATIONAL o ESTIMATED 100,000 FINAL SURVEY

m m ,_ m, m, , , o , -

CMSS TRAINING '

o GET I

o RADWORKER o RADIATION PROTECTION TECHNICIAN o SPECIALTY TASK o MOCKUP OPERATIONS o VISITOR ACCESS

]

- - - - _ _ _ _ - _ _ - _ = - _ _

L.]._M..._E=

1 SITE RELEASE SURVEY '

l i o SYSTEMATIC, DETAILED SURVEYS a o EXTENSIVE DOCUMENTATION REQUIRED o DEVELOPMENT OF NEW SURVEY METHODS FOR INACCESSIBLE AREAS O SAMPLING AND ANALYSIS TO ACCOUNT FOR HARD TO DETECT NUCLIDES o PATHWAY ANALYSIS FOR RELEASE OF RESIDUAL ACTIVITY I i

I

~

a!!EMhi RADWASTE HANDLING AND SHIPPING o APPROXIMATELY 100,000 CUBIC FEET OF WASTE TO BE SHIPPED o SHIPPING REQUIRES EXTENSIVE PLANNING

-Characterization and Classification

-Proper Packaging

-Scheduling of Vehicles

-Documentation o STORAGE / CONTROL OF RADIOACTIVE MATERIAL o UNCONDITIONAL RELEASE OF UNCONTAMINATED MATERIALS

s

~ i

, 7-UM5hi PERSONNEL CONTAMINATION EVENTS PERIOD CLOTHING SKIN' FEBRUARY 2 0 1994 2 0 TOTAL PROJECT 36 12 POSITIVE BIOASSAY RESULTS PERIOD WHOLE BODY TRITIUM COUNTS ANALYSIS FEBRUARY O O 1994 0 0 TOTAL PROJECT O O 6-

- - , , m mm, 1 rw mumy y CEMi PERSONNEL PERFORMANCE -

INDICATORS -

PERSON-REM ESTIMATE GOAL ' '

ACTUAL !

.' (to date)

FEBRUARY 6.5 5.2 5.086 1994 -

12.0 :

"9.6 9.249

' " ~

TOTAL 433 347 98.666 PROJECT ,

1

.. .j

CEDE.!h!

ALARA '

O DOSE

-Project Goal

-Monthly Goals )

o PERSONNEL CONTAMINATIONS o NO INTERNAL CONTAMINATIONS o MINIMlZATION OF RADIOACTIVE EFFLUENTS 4

- The Public is Not impacted

- Pathways are Releasable i

__ < - ,- m _ _ ,.y U@?hi PROJECT SPECIFIC CHALLENGES '

o ALARA GOALS

-Dose

-Contamination

-Internal Exposure

-Effluents l

l 0 RADWASTE HANDLING AND SHIPMENTS 1

o FINAL SITE RELEASE ' SURVEY o TRAINING o RECORDS

~

- ~_ ~ ~ ~ - _ - - - ,n 7 LJGMi ORGANIZATIONS INVOLVED IN ~-

COMPLIANCE -

O NRC o STATE AND FEDERAL DOT

~

WASHINGTON .

TENNESSEE

. O LICENSEE o EMPLOYERS

7 ---

7-CUJ.ilhi REGULATIONS WHICH GOVERN ,

o DOT 49CFR - TRANSPORTATION ..

O STATE 0 EPA MIXED / HAZARDOUS WASTE ENVIRONMENTAL EFFLUENTS 4

o DECOMMISSIONING TECHNICAL SPECIFICATIONS o DECOMMISSIONING PLAN .

u -

l2nilEll't..i REGULATIONS WHICH GOVERN .

o NRC cont'd l

10CFR 61 - LICENSING REQUIREMENTS FOR LAND DISPOSAL OF RADIOACTIVE WASTE 10CFR71 - P ACK AGING AND TRANSPORTATION OF l -

RADIOACTIVE MATERIAL a

m

-__.____-_______m_ _ _ _ _ _ _ . _ _ _ _ _ _

_ ~ n-u_ _gy C@)]lhi ,

i REGULATIONS WHICH GOVERN ,

o NRC 10CFR19 - NOTICES, INSTRUCTIONS AND REPORTS TO WORKERS:

I INSPECTION AND INVESTIGATIONS 10CFR2O - STANDARDS FOR PROTECTION AGAINST RADIATION 10CFR21 - REPORTING DEFECTS AND

, NONCOMPLIANCE 4

10CFR50 - DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES u.._._... . - - . _ _ . _ _ . _ _ _ _ . _ . . _ _

_ _u , _ _ _ , _ , _ _ , _ , , _ , _ _

2Ef@!.si PURPOSE AND ROLE OF THE '

PROJECT RP/RADWASTE PROGRAM o PROTECT WORKERS AND THE GENERAL PUBLIC FROM THE RADIOLOGICAL HAZARD 3 OF THE DECOMMISSIONING o ENSURE STRICT COMPLIANCE WITH ALL REGULATORY AND PROCEDURAL REQUIREMENTS O MINIMlZE RADIATION EXPOSURES AND RELEASES

, OF RADIOACTIVE MATERIALS - ALARA o MINIMlZE GENERATION OF RADIOACTIVE WASTE o DOCUMENTATION TO ALLOW RELEASE OF SITE

u

/

[

r FORT ST. VRAIN DECOMMISSIONING PROJECT CORE VALUES AND WORK ATMOSPHERE -

[ CLEGG CRAWFORD w-L e MARCH 31,1994 2

L' 2. - /

F L

' CORE VALUES e FITJD A BETTER WAY

> 11AMWORK AND COMMUNICA110N k - ,

USTEN TO THE IDEAS OF GTHERS -

EVEN UTHER COMPANIES l

~

> DONT BE AFRAID OF CHANGE - HAVE L A " BIAS FOR ACITON* ;

I

SECOND HAMILTONIAN:

c' - DONT BELIEVEtYOUR OWN B.S.

u

(~

L r

l L

W

J >

l CORE VALUES I e EXCFff M CE

= STRIVE FOR EXCELLENCE IN ALL ASPECTS OF THIS PROJECT I -

> BELIEVE IN QUALITY o QUALITY WORK, RECORDS AND MANAGEMENT IS EXPECTED I > IF MANAGEMENT WALKS THE TALK, THE REST OF UIE EMPLOYEES WILL FOLLOW SUIT l

INTEGRITY AND HONESTY ARE REQUIRED.

DO THINGS RIGHT THE FIRST TIME I

DIVERSITY 1

o EVERYONE HAS THE OPPORTUNITY TO ACHIEVE POTENTIAL i

o WE VALUE DIFFERENCE I o EVERYONE TREATED FAIRLY AND WITH RESPECT l

1

' l o HARASSMENT OF ANY KIND WILL NOT BE TOLERATED l

i o NAVE EXTREMELY HIGH STANDARDS

1-1 L

- CORE VALUES E .

l l

e SAFETY

' . THE HEALTH, SAFETY AND WELL BENG OF EVERY INDIVIDUAL L. WORKING ON Sf!E AND HEALTH AND SAFETY OF THE PUBUC DEPEND ,

ON 'I15 DECOMMISSIONING TEAM COMPLIANCE WrfH PROCEDURES I

)

l t

> PROCEDURE COMPLIANCE IS MANDATORY R o STRICT RESPONSIBILITY AND ACCOUNTABILITY l

> SAFETY MUST NEVER BE COMPROMISED; NO JOB OR SCHEDULE IS SO IMPORTANT THAT APPROPRIATE SAFETY PRECAUTIONS ARE NOT l OBSERVED

IT IS MANAGEMENTS' RESPONSIBILrrY 'IV PROMOTE A SAFE WORK y PLACE AND AN ENVIRONMENT IN WHICH EMPLOYEES ARE FREE TO

( RAISE SAFETY CONCERNB WrrHOUT FEAR OF RETALIATION m

L m

+

t' l

. y --

=

[

C_ -- _ - - _

g- ,,

WORK PLACE ENVIRONMENT e HARASSMENT AND INTD4IDATION 1

f l

HARASSMENT AND INTIMIDATION WILL NOT BE TOLERATED AT FSV

RECOGNrrION OF HARASSMENT IS DIFFICULT BECAbSE TT IS THE PERCEP110N OF BEING HARASSED THAT MAKES IT HARASSMENT.

i

> SOME ACTS THAT CREATE A HOSTILE WORK ENVIRONMENT ,

.I

. v. . . , :

o DISCRDENATION BEIWEEN WORKERS - INCONSISTENT TREATMENT OF WORKERS e ,,

I i

I o ANNOYING ACTS THAT ONCE TOLD ARE ANNOYING ARE DONE JUSTTO AGGRAVATE l

o INTERFERING WITH A PERSONS ABILITY TO GET THEIR WORK l

! DONE BY CREATING A HOSTILE WORK ENVIRONMENT l E l o TALKING DOWN TO AN INDIVIDUAL OR TREATING AN i l

INDIVIDUAL Wini A LACK OF RESPECT

.E l

.THESE ARE BUT A FEW EXAMPLES BUT THERE IS NO SUBSTITUTE FOR TALKING TO j PEOPLE ABOUT THEIR WORK ENVIRONMENT l '

,E l

lI

- _ _ _ . - - . . . . - _ - . - . _ _ . _ - - - - _ _ . - - - - - - _ _ - - _ _ _ . - - - - - - - - - . r- -. , - -, e , , , - , ~ --~-

en ~ /

b

_ PSC AND WT MANAGEMENT RESPONSIBILITIES b .

e 10 CFR SSJ - DELIBERATE MISCONDUCT - AN INTENTIONAL ACT OR OMISSION - SUMMARIZED

[ > IF YOU KNOWINGLY PROVIDE EQUIPMIDR, GOODS OR SERVICES THAT ,

CAUSES, BUT FOR DETECTION, A LICENSEE TO BE IN VIOLATION OR DELIBERATELY SUBMIT INCOMPLETE OR INACCURATE INFORMATION b THAT:

o WOULD CAUSE A LICENSEE TO BE IN VIOLATION OF A RULE, REGULATION OR ORDER, OR ANY TERM, CONDITION c OR LIMITATION, OF ANY LICENSE ISSUED BY THE L COMMISSION E'

L o OR CONSTTTUTES A VIOLATION OF A REQUDtEMENT, PROCEDURE, INSTRUCTION, COIRRACT, PURCHASE ORDER E OR POIJCY OF A IJCENSEE, CONTRACTOR OR SUB-L CONTRACTOR r

L

= IF YOU KNOWDfGLY AND INTENITONALLY VIOLA 11 THE ABOVE YOU

[ MAY BE SURIECT TO NRC ENFORCEMENT

[

p e IS CPR lie- ENFORCEMENT L

E L = ANY PERSON WHO WILLFULLY VIOLATES ANY PROVISION OF 'I1E ACT OR ANY REGULATION OR ORDER ISSUED THEREUNDER MAY BE GUILTY

' OF A CRIME AND. UPON CONVICTION, MAY BE PUNISHED BY FINE OR IMPRISONMENT OR BOTH, AS PROVIDED BY LAW.

~

S

[

_ _ _ _ . _ _ ._ . _ _ _ _ _ _ _ _ _ . ---__ _ ___ _____- _-_---___-___ ______-_--_-__ _ _ ____ _ ___ D

/~/

[

PSC AND WT MANAGEMENT RESPONSIBILITIES

[

b le CFR 50.7 - Simagarrm e ,

b

= PROTECTED ACTIVITIES b ,

[ o PROVIDING INFORMATION TO THE NRC CONCERNING POSSIBLE VIOLATIONS o REQUESTING NRC ACTION POR T1IE ADMINISTRATION OR -

ENFORCEMENT OF THESE REQUIREhGNTS (PART 50 -

[ REQUIREMENTS) b o TEST 1FYING IN ANY COh0GSSION PROCEEDING E

L p

WRONGFUL DISCHARGE - YOU CAN NOT DISCHARGE AN EMPLOYEE FOR L PARTICIPATING IN PROTECTED ACITVITIES ,

L ,

r , YOU CAN NOT TAKE OTHER ACTIONS THAT RELATE TO .

COMPENSATION,1ERMS, CONDITIONS, AND PRIVILEGES OF EMPI4YMENT FOR PARTICIPATING IN PROTECTED ACTIVTITES b

r u

~

[

b L _----------- - --- - - - - - - - _ - - - - - - - - - ----- _----- - - _-

Exhibit IV p

TRAINING MATERIAL APPROVAL FORM Training Material Type: RFRTART b Iesson Number: , RFm2-00 JQS/ Card Number: NA Seminar:

JPM/Egan

[

n.N

~

Developed by: Date:

Reviewed by: k2 ' -dTAD Date: 's 31-48/

v y E Reviewed by:

<[/ Date:

Approved by: dbb Date: Y3'b4 Approved by: ##4/#!# Date: M f/ / D

[ Approved by: 7///I/ Date:

r P l

[

c L

[

E

(- 1

[

l

- - _ - _ _ _ _ _ - l

E

' STUDENT HANDOUT

[

c L

[ PROCFnURE COMPilANN STOP WORK & DOCUMKhTTATION E

c L

I L

RM02N00 L

F -

u r-1 r

L I l t

E 1

COURSE TITLE: RESTART LESSON TITLE: PROrpnURE COMPLIANCE. STOP WORK & DOCUMFRTATION LESSON NUMBER: RFID2 00 00-00 LESSON PLAN Course of Instruenon Hogs B. Requirements

1. Regulatory

a. 10 CFR Part 19 Part 19 Notices, Instructions and Reports to Workers: Review NRC Form 3 Inspection and Investigations .

(19.11 Posting of notices to workers Each licensee and applicant shall post Form NRC-3, (Revision 6.82 or later) " Notice to Empicyw," as required by Parts 30, 40, 50, 60, 70, 72, and 150 of this ch.yw. ,

$19.15 Consultation with workers during inspections.

Commission inspectors may consult privately with workers concerning matters of occupational radiation i I

protection and other matters rtlated to applicable provisions of Commission regulanons and licenses to the extent the inspectors deem necessary for the conduct of an effective and thorough inspecnon.

During the course of an inspection any worker may bring privately to the attention of the inspectors, either orally or in writing, any past or present condition which he has reason to believe may have contributed to or caused any violation of the act, the regulanons in this 4, er license condition, or any unnecessary exposure of an individual to radianon from licensed radioactive matenal under the licensee's control. Any such notice in writing shall comply with the requirements of (19.16(a).

1 I

l

r COURSE TITLE: RESTART LESSON TITLE: PROCEDURE COMPLIANCE. STOP WORK & DOCUMENTATION LESSON NUMBER: RP'It)2-00-00-00 LESSON PLAN l _

E a

I Course of Instructinn h The provisions of paragraph (b) of this section shall not be interpreted as authorization to disregard instructions pursuant to (19.12.

(19.16 Requests by workers for inspections.

Any worker or representative of workers who believes that a violation of the Act, the regulations in this ,

~ chapter, or license conditions exists or has occurmd in L iicense activities with regard io radioiogical working conditions in which the worker is engaged, may request p an inspection by giving notice of the alleged violation to L the Administrator of the appropriate Commis:sion Regional Office, or to Commission in%;ers.

r '

L Any such notice shall be in writing, shall set forth the specific grounds for the notice, and shall be signed by

' the worker or representative of workers. A copy shall be provided the licensee by the Regional Office Administrator, or the inspector no later than at the time

[

of inspection except that, upon the request of the worker giving such nonce, his name and the name of individuals referred to therein shall not appear in such I copy or on any record published, released or made l l

available by the commission, except for good cause shown.

r L.

COURSE TITLE: RESTART

[ LESSON TITLE:

LESSON NUMBER: RFIV2N PROrpnURE COMPLIANCE STOP WORK & DOCUMENTATION I .

LESSON PLAN E.

L course or instruction uni.

650.7 Employee protection Discrimination by a Commission licensee, permittee, an applicant for a Commission license or permit, or a contractor or subcontractor of a Commission licensee, p permittee, or applicant against an employee for L engaging in certain protected activities is prohibited.

r c. 10CFR2 .

Subpast B-Procedure for Imposing Requiressents by Order, or for Modification, S=g: c's, or Revocation

' of a License, or for Imposing Civil Penalties.

[ 12.200 Scope of Subpart (a) This subpart prescribes the procedure in cases

[ initiated by the staff, or upon a request by any person, to impose requirements by order, or to modify, y suspend, or revoke a license, or to take other acnon as L may be proper. agamst any person subject to the jurisdiction of the Commission.

i E Notice of violation u (2.201 62.203 Settlement and compromise r 62.204 Demand for information :

l L 62.20s Civit penaities Requests for acuan under the subpart j 62.206

[

E

[

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c .$- 18 b k k ? ? b??${

as N r : 4

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Examination Number: RPTO2-00-01-00 I \

NAME: ko% Lntsac4oop o te: 4-4-44 I The work I performed to take this exam was my own. I did not use any material or references not provided specifically by the instructor.

hxM AW11A ~"

Signat\ ire

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I SCORE:

/ Fall 4fG,letL INIT DATE I

I This exam contains:

l RPT02-00-01-00 Pass / Fall Criteria

1) Examinations must be completed to satisfy course completion requirements.

2) Criteria for completion is 100%. All required knowledge items must ,

be completed in full. l twesmemvem2 n 1 n,y i ,

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E E 1. What document was used to inform the Westinghouse Team of the Fort Saint Vrain (FSV) Stop Work action.

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Describe the purpose of Code of Federal Regulations, Chapter (i.e.,10CFR19). 4e 10, Par; f;ljI f

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3. In accordance with NRC Form 3, how would you report a violation of r radiation protection requirements specified in regulation.

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E 4. State the protection afforded to an employee under 10CFR19.20.

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5. State the direction or scope of 10CFR50.5. (State what that section I addresses.) {Q E MI#LtJ'/Elf MMD '\

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6. Give an example of deliberate misconduct that may fall under the purview of b 10CFR50.5.

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13. Who can initiate a STOP WORK 7

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14. If you find that a procedure governing a specific work activity was not

[ followed because the procedure was in error, what actions should you take.

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15. Who may resend, or withdraw, a radiation protection STOP WORK ORDER 7 RP bm amiew>s 50 msise ./

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- 16. What action would you take if you recognize a violation of RP work practices or failure to follow ALARA principles.

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[~ 17. Concerning records and logs produced as part the decommissioning. Define

' a " RECORD."

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18. If you make an error while completing a record, describe how you are

- required to make a correction to the entry that you made.

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19. Where are completed records for this project required to be stored?

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20. Logs records and turnovers shall be completed, kil.4 bto of 4 '

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I qQ, MORRISON KNUDSEN COP.PORATION MK FERGUSON GROUP Exhibit V INTER-OFFICE CORRESPONDENCE DATE: August 15, 1994 '

TO: Distribution FROM: Bill Hug

SUBJECT:

Guidelines for Reduction in Force Actions Attached is a copy of Section 5 of the MK-Ferguson Corporate Labor Relations Manual. This document addresses termination of field craft employees, including Reduction in Force (RIF).

The guidelines provided in this document are basic and relies heavily on the judgement of the Superintendent and the input provided to him by others. Our selection process is based on qualifications, performance, ability, attendance, attitude and the requirements of the project. We have no intent to change our process of selecting those to be laid off, however, we must be on guard to prevent the increasingly prevalent claims of discrimination. Not only do we need to be cognizant of discrimination from an EEO perspective, we must be aware of l a potential claim of discrimination related to the voicing of safety concerns. Both the NRC and OSHA have regulations which prohibit the discrimination against those who have raised safety concems.

I Also attached, are copies of 10 CFR 50.7, NRC Form 3 and 29 CFR 1903.11.

j l The NRC regulations, specifically 50.7, prohibit discrimination against an employee for taking part in protected activities. These protected activities are defined in the regulation to include providing the NRC or his employer

'E information about alleged violations. These alleged violations are defined by B NRC Form 3 and other documents and can be as general as bringing up a safety

! concern. It should also be noted that an employee's engagement in protected I activities does not automatically render him immune from discharge or discipline for legitimate reasons.

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OSHA, in its regulations 29 CFR 1903.11, is more specific in that it prohibits

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l discrimination against an employee who has filed a complaint or is involved in pursuing a complaint. l I

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'g Our best defense against claims of this nature is to adequately address any safety l 3 -

concern when it is initially brought up. If the concern is either fixed or explained '

to the satisfaction of the employee, it would be difficult for that concern to be I later used as the basis of a discrimination claim. Likewise, a healthy exchange with employees promotes the overall awareness to safety.

7 l

W. J. ud Project Manager l

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xx.Ferguson Fort St Vrain Decommissioning Project Exhibit VI g ,

Exit Interview We are pleased that you have participated in the Decommissioning of Fort St. Vrain and g appreciate your efforts in helping us make this a very successful project.

I In general, how would you rate this project?

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g Do you feel this project was safe?

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Do you feel that we placed a proper emphasis on safety?

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Do you feel that the project was adequately planned?

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Do you feel that your concerns about safety, industrial and radiological, were adequately l addressed?

l Did you ever raise a concern for which you were not given a satisfactory answer or an appropriate action was not taken?

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[ Did you feel comfortable raising concerns with your supervisor or one of the safety supervisors?

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Are you aware of any radiological or safety concerns that continue to exist at Fort St. Vrain?

b Would you consider work for MK-Ferguson again in the future?

Name SS# Date I

Interviewed By Employee Signature

I MK Ferguson Fort St Vrain Decommissioning Project Exit Interview We are leased that you have participated in the Decommissioning of Fort St. Vrain and appreciate your efforts in helping us make this a very successful project.

In general, how would you rate this project?

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Do you feel this project was safe?

Do you feel that we placed a proper emphasis on safety?

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Do you feel that the project was adequately planned?

ll E Do you feel addressed? that your concerns about safety, industrial ami radiological, were ade E

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I Did you ever raise a concern for which you were not given a satisfactory answer or an appropriate action was not taken?

l<f l Did you feel comfortable raising concerns with your supervisor or one of the safety II /*

Are you await of any radiological or safety concerns that continue to exist at Fort St. Vrain l ko Would you consider work for MK-Ferguson again in the future?

gd a ny sw-+

MK-Ferguson Fort St Vrain Decommissioning Project u Exit Interview We are pleased that you have participated in the Decommissioning of Fort St. Vrain and appreciate your efforts in helping us make this a very successful project.

In general, how would you rate this project?

hha t SW

Do you feel this project was safe?

j Do you feel that we placed a proper emphasis on safety?

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Do you feel that the project was adequately planned? g gj [ ,f fgh/c.,

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[ Did you ever raise a concern for which you were not given a satisfactory answer or an appropriate action was not taken?

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L Are you aware of any radiological or safety concerns that continue to exist at Fort St. Vrain? fa l

L l Would you consider work for MK-Ferguson again in the future? t/

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MK-Ferguson l Fort St Vrain Decommissioning Project

^

' Exit Interview ,

I 4

We are pleased that you have participated in the Decommissioning of Fort St. Vrain and

, appreciate your efforts in helping us make :his a very successful project.

In seneral, how would you rate this project?

l 1

Do you feel this project was safe?

sf 3

j Do you feel that we placed a proper emphasis on safety? (/ !t /

! you feel that the project was adequately planned? 6 ja, g[/ js* /[*

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I MK-Ferguson Fort St Vrain Decommissioning Project Exit Interview We are pleased that you have participated in the Decommissioning of Fort St. Vrain and appreciate your eNorts in helping us make this a very successful project.

In gene al, how would you rate this project?

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Do you feel this project was safe?

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L Did you ever raise a concern for which you were not given a satisfactory answer or an appropriate action was not taken?

I Did you feel comfortable raising concerns with your supervisor or one of the safety supervisors? /

Are you aware of any radiological or safety concerns that continue to exist at Fort St. Vrain?

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Would you consider work for MK-Ferguson again in the future? g[ ,

m_.. . _ _ _ _ _ . __.. _ . _ . - .. . . .

l MK-Ferguson p Fort St Vrain Decommissioning Project L Exit Interview a

We are pleased that you have participated in the Decommissioning of Fort St. Vrain and appreciate your eBorts in helping us make this a very successful project.

In general, how would you rate this project?

h9' -

Do you feel this project was safe?

lt/ NM*- NY] ,

Do you feel that we placed a proper emphasis on safety?

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Do you feel that the project was adequately planned?

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Do you feel that your concerns about safety, industrial and radiological, were adequately addressed? o fi/

Did you ever raise a concern for which you were not given a satisfactory answer or an appropnate action was not taken?

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l Did you feel comfortable raising concerns with your supervisor or one of the safety supervisors?

L Are you aware of any radiological or safety concerns that continue to exist at Fort St. Vrain?

I Would you consider work for MK-Ferguson again in the future?

ft/

l

MK-Ferguson F:rt St Vrain Decommissioning Project Exit Interview

/

We are pleased that you have participated in the Decommissioning of Fort St. Vrain and appreciate your efforts in helping us make this a very successful project.

In general, how would you rate this project?

VM pl- 9$se* MfMf < -

Do you feel this project was safe?

(1)Y Y'f! N ,

Do you feel that we placed a proper emphasis on safety?

lcJ Do you feel that the project was adequately planned?

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I Did you feel comfortable raising concerns with your supervisor or one of the safety supervisors?

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[ 65 !

l Are you aware of any radiological or safety concerns that continue to exist at Fort St. Vrain?

h would you consider work for MK-Ferguson again in the future? ,

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ll Exhibit Vil g ,

FORT ST. VRAIN DECOMMISSIONING PROJECT ENVIRONMENT, SAFETY & HEAI TH SURVEILLANCE RECORD Date: // Page2,,,,,,ofk rw' . es: wr Mines.n.n MK Safety Bw_oh

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9
, i;.:1995-1996 is " Setting the Tone for.Saf.ety ~w 5 ~'
M; ):.schieving'. excellence in safety and continue. "2 to " Set the T .u. '! 'poshfve resu .l ts; .. .
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" of safety informat, ion must' occur at'all levels.of.our or..w. ;ganization&.. Man,a E door policy and encourages empidyeeitol.reely.eiixhr,e's~sI$}i.y%a fe.^.y co
~
I a - t. ncerns'and it is the l
cw . . ~ . . ..c expressing a saf ety t
policy of the company not to d.iscriminate:against an amployee for. n.y v.
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program but is also c
,; protected under various federal statutes and,regu!St.io.ns.<<4.lt.i.s.!.MKEC&E.'s. policy to comply e
1 fr with employee prote..ct.i.on. p.. .rov,isioris.of:10..v.JT 'CF 5. 0.,s7f29 CF_R:24';. c Sect,io.n 9610 of CERCLA c
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, . . . . m. x (Superfund) and other. environmental.. . .l statutesswhere applicable, an.d to ensure that our ,
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Exhibit XI 1
MORRISON KNUDSON PROJECT MANAGEMENT BULLETINS l
SECTION 11. Project Startup BULLETIN NO.2.9
SUBJECT:
Harassment and intimidation in the Workplace Effective: 8/24/95 Page 1 of 3 I A. POLICY It is the policy of Morrison Knudsen to ensure that our employees are not subjected to harassment or intimidation of any kind in the work place. Employees must feel secure in expressing their concern, particularly those which relate to safety and working I conditions without the fear of retaliation of any kind on the part of MK management.
Harne= ment and intimidation of emr.loya at facilitien operatine under Nuclear ReenIntnry lg Comminion lit enne is a vinistian of Faderal I2w.
3 1
i B. REFERENCES The federal regulation which protects the rights of employees when they perceive they are being required to work in an unsafe workplace is in 10CFR50.7 " Employee Protection, g
g C. REQUIREMENTS i
'Ihe following are the minimum requirements to satisfy this policy:
1. Each project working to the regulation in (B) above shall have a procedure which
! addresses Harassment and Intimidation in the workplace. As a minimum the procedure should address:
l
a. Indoctrination and training of all MK supervisory employees (m' cluding union foremen and general foremen) of the rights of employees to report safety concerns.
1
b. Indoctrination and training of all non-supervisory employees of their rights to express workplace safety concerns.
c. A method of collecting and dispositioning employee concerns.
d. A method of ensuring that required posting of notices alerting employees to their rights as related to identifying safety concerns is accomplished.
n
MORRISON KNUDSON PROJECT MANAGEMENT BULLETINS SECTION 11. Project Startup BULLETIN NO.2.9 l
SUBJECT:
Harassment and intimidation in the Workplace Effective: 8/24/95 Page 2 of 3 I D. PROCESS / ACTIVITY FLOW Owner / client has applicable Obtain Owner / client Utilize Owner / client policy / procedure approval to adopt their procedure to I procedure Indoctrinate / train employees and collect and resolve employee concerns Owner / client does not have Develop joint Implement procedure applicable policy / procedure procedure or obtain to indoctrinate / train approval to implement employees and collect and resolve employee I MK procedure concerns E. CONSIDERATION Some important points to consider when developing / implementing project procedures are:
1. Work within the Owner / Client's system whenever possible.
I 2. Obtain the Owner / Client's approval before implementing a separate MK policy /
system / procedure.
I 3. Document all training and indoctrination.
4. Document all concerns and the resolution of each concern.
5. Accusation of harassment and intimidation in the workplace can be extremely I
sensitive particularly if these accusations imply violation of NRC or OSHA regulations. All such accusation should be reported to Cleveland H.O.
Management immediately.
6. Despite demonstrated good faith efforts, MK can be held liable for a manager's or supervisor's conduct of harassment or failure to respond immediately and correct I a complaint of misconduct, whether or not MK was aware of such misconduct.
I
L MORRISON KNUDSON PROJECT MANAGEMENT BULLETINS SECTION ll. Project Startup BULLETIN NO.2.9
SUBJECT:
Harassment and intirnidation in the Workplace Effective: 8/24/95 Page 3 of 3 b ~
F. TYPICAL PROCEDURES None
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as-43-1964 13:36 4126423Ut5 wat s aause re- , y,c, HRWorkSource" .-m - .-.-m c
Pittshargh,- Pa -
M Westinghouse Building 710 m# 273-setas 412 sea-asts aus: 1994 MmY camum.n2,ientions Westshops y
a yg Fort St. Traia, CO neuena Ares 11 InX 8303 530-1837 r
L The objoetives of the commuunientiens workshops ase: !
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To instill in the participants the importasse of open two-osy osummenientions.
To identify e mtas somesame se s.of. the harriers . .e me.. to effective h o ri asumummiestions and .
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To apprestate how maah een he sessuplished through useking as a l team. I r
L - The tapertanes of sustent tress.
The need fez and aseeptanee of obenge.
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Improve participants 8 skills is understandios others asking themselves undesstead and getting their - 4estion,s seeepted.
F Methodslogy:
L Th the use of lesterettes,jestives.
, schieve the aheve st learning instrummets and emperiential F
L The e ians =111 sua stese te a emit eight hears eastuding a least broes.
The gse g e should not smuter ever 25 unlese aheelstely necessary and should be p a mim og a&& eWeyes elessitientions.
L A rester should be paavided for me by name and egleyes elessifiesties - this helps when I divide them up tate groups for the esercises.
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J. D. th, Manager L Canunnicatiana Services Spesisi services operations Attaamment
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ML20092C937

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ML20092C937

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