ML20137N947

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Differing Professional Opinion
ML20137N947
Person / Time
Site: Millstone Dominion icon.png
Issue date: 04/03/1997
From:
External (Affiliation Not Assigned)
To:
Shared Package
ML20137N877 List:
References
PP-05, PP-5, NUDOCS 9704090096
Download: ML20137N947 (8)
v • d • e


Text

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O - PARSONS PP-05 MILLSTONE UNIT 2 ICAVP PROJECT PROCEDURES

Title:

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. Differing Professional Opinion f

REVISION 0 ,

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REVISION HISTORY REVISION DATE REVISION DESCRIPTION i 0 04/03/97 Procedure lnitiation O 9704090096 970403 r PDR ADOCK 05000336 P pon

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MILLSTONE 2 ICAVP PP-05 PROJECT PROCEDURES TITLE: DIFFERING PROFESSIONAL OPINION REVISION: 0 DATE: 04/03/9'l PAGE 2 OF 8 TABLE OF CONTENTS 1.0 PURPOSE ........................................................................................................3 2.0 DEFINITIONS............................................................................................................3 3.0 R ES PO N S I B I L I TI ES ......... .................... ... ................... ......... .......... ............. . . ...... ...... 3 1

4.0 I N S T R U CTI O N S ...... ....... ... .............. ..... ... .... . . . . .. ....................... .......... ...... ............... 4 4.1 GENERAL. . .. . . .. . . .4 4.2 INITIATION OF DPOS , . . .5 4.3 TRACKING, RESOLUTION, AND REVIEW OF DPOS . . .5

' 4.4 APPEAL OF DPO RESOLUTION.. . . . . . . . . . . .6 i

4.5 CLOSE-OUT AND FOLLO'W-UP OF DPOS.. . .6 l

i ATTACHMENT I - DIFFERING PROFESSIONAL OPINION RESOLUTION . . .7 ATTACHMENT 2 -TRACKING LOG.. .. . .8 l l

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i ED MILLSTONE 2 ICAVP PP-05 l E PROJECT PROCEDURES l n .

(/ ) TITLE: DIFFERING PROFESSIONAL OPINION REVISION: 0 DATE: 04/03/97 PAGE 3 OF 8 1.0 PURPOSE To encourage Parsons team members to make known their judgments on matters of technical and safety significance concerning the Millstone Unit 2 ICAVP even though theirjudgments may differ from those of management positions. While discussion regarding differing viewpoints is preferable between individuals within the chain of command, this procedure provides a formal process where these differing judgments can be recognized and considered so that safe and appropriate actions are taken.

Nuclear Regulatory Commission (NRC) regulations assure the employee that he/she is protected against retaliation in any form when engaged in nuclear activities as defined in 10 CFR 50.7

" Employee Protection" Additional information concerning this is posted (Refer to NRC Form 3) on ICAVP project area bulletin boards. This includes the initiation of a Differing Professional Opinion (DPO).

( Employees that have expressed a DPO may also input this concem into the NNECo Employee Concerns Program in accordance with the instructions provided in NNECo procedure " Nuclear Safety Concerns" NGP 2.15, available in the project records office.

2.0 DEFINITIONS 2.1 Difics.g Professional Opinion (DPO) - A conscientious expression of professionaljudgment expressed in a written staternent submitted to one's immediate supenisor concerning matters of nuclear safety which differ from the prevailing Millstone Unit 2 ICAVP team view 2.2 DPO Resolution - A written statement providing the technical basis in support of the fmal ICAVP team position on a nuclear safety issue. The DPO Resolution will either confirm the validity of the position described in the DPO, or provide a detailed response to each issue expressed in the DPO.

Concurrence of the DPO initiator is not required for DPO Resolution.

3.0 RESPONSIBILITIES 3.1 Project Director (Vice President Nuclear Senices) 3.1.1 Makes the final determination as to the resolution of the DPO betwecm team members and the A

i ) Technical Advisory Panel.

f E3 MILLSTONE 2 ICAVP PP-05 E PROJECT PROCEDURES (O

V TITLE: DIFFERING PROFESSIONAL OPINION REVISION: 0 DATE: 04/03/97 PAGE 4 OF 8 3.2 DEPUTi PROJECT DIRECTOR 3.2.1 Makes the final determination as to the resolution of the DPO between Core Team members.

3.2.2 Maintains controlled tracking system for monitoring the progress toward resolution in accordance with the Millstone Project Administrative Manual (Attachment 2).

d 3.2.3 Provides a written statement describing in detail the basis for the prevailing project position that includes specific responses to the concerns identified in the DPO.

3.2.4 Obtains technical input as necessary from other affected disciplines within the Parsons to fully address the issues identified in the DPO.

3.3 MANAGER COMPANY QUALITY 3.3.1 Advises the Project Director (Vice President-Nuclear Services) or the Deputy Project Director, as

() appropriate, as to the resolution of DPOs.

3.4 INITIATOR 3.4.1 Prepares written statement describing in detail the technical issue and the differing opinion, and forwards that statement and Form provided in Attachment I to the Deputy Project Director, in accordance with the requirements described in Section 4.

4.0 INSTRUCTIONS To ensure timely processing, the cover sheet (Attachment 1) should accompany all DPO documentation.

4.1 GENERAL 4.1.1 Free and open discussion of technical and nuclear safety issues on the Millstone Unit 2 ICAVP is encouraged and expected.

4.1.2 Employees should endeavor to resolve differences of professional opinion through discussions with

, their co-workers, immediate supervision on the project, and the project organization.

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1 F) MILLSTONE 2 ICAVP PP-05 E PROJECT PROCEDURES g >

b TITLE: DIFFERING PROFESSIONAL OPINION REVISION: 0 DATE: 04/03/97 PAGE 5 OF 8 l

4.1.3 While addressing technical and nuclear safety issues through line management is encouraged, nothing in this procedure should be interpreted as interfering with or discouraging employees from i exercising their rights as discussed in this procedure. In addition, team members have the opportunity to have their concerns addressed through the NNECo Nuclear Safety Concerns Program as detailed in NGP 2.15 or by the NRC.

4.2 INITIATION OF DPOS 4.2.1 The initiator shall document in writing, the unresolved difference which they believe to have actual or potential safety significance.

Documentation may be in the form a memorandum, and should include the following with as much supporting detail as practical:

4.2.2.1 Initiate DPO Cover Sheet (Attachment 1).

O 4.2.1.2 A summary of the perceived Team position along with supporting documentation.

4.2.1.3 A description of the employee's professionaljudgment on the issue and how it differs from the l l

Team position complete with supporting documentation.

4.2.1.4 An assessment of the potential resultant consequences if the employee's position is not adopted.

4.2.1.5 The initiator shall forward the original DPO to the Project Deputy Project Director for Core Team Members) or the Project Director (Vice President, Nuclear Senices) for Technical Adsisory Panel members, with copies sent to the initiator's immediate supenisor and project records.

4.3 TRACKING, RESOLUTION, AND REVIEW OF DPOS 4.3.1 The Deputy Project Director shall:

4.3.1.1 Within three working days, er the DPO into a tracking system and identify the tracking number on Attachment 1. A copy will be provided to the Project Director, Deputy Project Director, Group Lead and Initiator.

4.3.1.2 All correspondence related to the DPO shall reference the DPO tracking number.

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E) MILLSTONE 2 ICAVP PP-05 l E > PROJECT PROCEDURES

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TITLE: DIFFERING PROFESSIONAL OPINION REVISION: 0 DATE: 04/03/97 PAGE 6 OF 8 4.3.1.3 The proposed DPO Resolution must be completed within ten working days from the time the DPO is received, and may either affirm the validity of the basis for the DPO and adopt the position of the DPO initiator, or it may provide the technical basis for maintaining the prevailing project position.

4.3.1.4 Should resolution not be achievable within ten working days, an Action Plan shall be prepared within three additional working days and approved by the Project Director. The initiator will receive a copy of the Action Plan.

4.3.5 The DPO Resolution shall include the following:

4.3.5.1 A summary of the areas of technical disagreement being addressed by the DPO Resolution.

4.3.5.2 A detailed response to each issue identified in the DPO, including all facts relevant to the basis for the position being adopted. The DPO Resolution must address every issue raised in the DPO.

4.3.5.3 An assessment of the potential consequences of the position adopted.

4.3.7 The Deputy Project Director shall:

4.3.7.1 Confer with the DPO initiator and forward the DPO Closure within five working days for fmal status and distribution.

4.3.7.2 Update the DPO status in the tracking system to reflect that the DPO is considered closed.

4.3.7.3 Send DPO resolution to Project Records with a copy to the Project Director and Manager, Company Quality.

4.4 APPEAL OF DPO RESOLUTION Since the Deputy Project Director makes the final determination of the DPO Resolution after making a complete and impartial evaluation of all the issues (with nuclear safety being paramount),

and conferring with the DPO initiator, there will be no appeal process under this procedure.

4.5 CLOSE-OUT AND FOLLOW-UP OF DPOS f]

V The Deputy Project Director shall:

4.5.1 Advise the Project Director, as appropriate, as to the DPO Resolution.

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E) MILLSTONE 2 ICAVP PP-05 E PROJECT PROCEDURES TITLE: DIFFERING PROFESSIONAL OPINION REVISION: 0 DATE: 04/03/97 PAGE 7 OF 8 ATTACHMENT 1 DIFFERING PROFESSIONAL OPINION RESOLUTION Tracking Number #

I. INITIATION 1.1 Document in written form the unresolved difference.(Attach DPO memo and Additional documentation as necessary). Provide Summary Statement of DPO.

.l Initiator /Date 1.2 Forward the DPO related documentation to Deputy Project Director with copies to initiator's supervisor.

2. RESOI,UTION 2.1 Enter the DPO into the DPO tracking system.

Deputy Project Director /Date 2.2 Within 10 working days, prepare written documentation with detailed basis for final project position. (Attach resolutlodactionplan and documentation as necessary)

Prepared by/Date Deputy Project Director /Date 2.3 Forward DPO resolution to initiator or prepare action plans as required, with a copy to the Project Director and the Director Company Quality.

2.4 Review DPO Resolution with Initiator.

Initiator /Date Deputy Project Director /Date

3. CLOSURE 3.1 DPO Closed Deputy Project Director /Date 3.2 Send approved DPO resolution to Project Records.

f P) MILLSTONE 2 ICAVP PP-05 E .

PROJECT PROCEDURES TITLE: DIFFERING PROFESSIONAL OPINION REVISION: 0 DATE: 04/03/97 PAGE 8 OF 8 ATTACIIMENT 2 I DIFFERING PROFESSIONAL OPINION RESOLUTION TRACKING LOG DPO Number Initiator Date Initiated Date Logged Date Closed DPO-01 Q

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