ML20207D526
| ML20207D526 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/26/1999 |
| From: | Krich R COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9906030357 | |
| Download: ML20207D526 (21) | |
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- - .O Commonwealth Edhon Company N00 Opus I' lace Downers Grove. II. 60515-5701 May 6,1999 U. S. Nuclear Regulatory Commission ;
ATfN: Document Control Desk i Washington, DC 20555 l i
Byron Station, Units 1 and 2 l Facility Operating License Nos. NPF-37 and NPF-66 j NRC Docket Nos. STN 50-454 and STN 50-455 l I
Subject:
Response to Questions Concerning the Alleged Chilling Effect
References:
(1) Letter from J. A. Grobe (U.S. NRC) to O. D. Kingsley (Comed), " Byron Chilling Effect Concerns," dated March 18,1999.
(2) Letter from J. A. Grobe (U.S. NRC) to O. D. (Comed) dated August 5,1998. j (3) Letter from J. A. Grobe (U.S. NRC) to O. D. (Comed) dated August 26,1998.
(4) Letter from K. L. Graesser (Comed) to H. B. Clayton (U.S. NRC), " Byron Station ;
Request for Evaluation - NRC Tracking Nos. 98-A-0105 and 98-A-0134," dated November 20,1998.
l This letter is in response to Reference 1, which requested our responses to 12 specific questions concerning the alleged chilling effect at the Byron Station. The NRC requested that we evaluate j examples of a potential chilling effect in References 2 and 3. Reference 4 provided the results of our !
evaluation and the conclusion reached that the overall work environment at Byron Station is conducive to the raising of nuclear safety issues.
I Our responses to the 12 questions transmitted by Reference 1 are provided in the attachment to this '
letter. Reference 1 also raised three additional points based on well-recognized NRC positions. We jI '
conducted a reassessment of our original evaluation and confirmed that these positions were taken )
into account. The following summarizes the results of our reassessment. !
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. . We recognize that a chilling effect by its nature can exist because of personal perceptions of discrimination for raising safety concems. In the November 20,1998 letter, we did not intend to minimize the significance of personal perceptions. A review of the interview results for each of the seven examples in the Reference 2 letter confirms that the concept of perception-is-reality was well recognized by the Evaluation Team. Interviewees were questioned concerning their
- perceptions ofevents in addition to their knowledge of specific incidents. Responses based on perceptions were considered by the Team. Personal perceptions of discrimination were a factor in the Team's' determination that Example No. 7 was valid with respect to the Operations Department.
( We recognize that management action, intentional or not, can influence an individual's perception. Therefore, any distinction in our Reference 4 letter that was based on a person's intent was not meant to downplay or excuse management action reviewed during the evaluation.
Accordingly, the Team did not use intent as a criterion to screen out concerns.
- e. We recognize that even a small number ofinstances of chilling behavior could produce a chilled environment. While the Team found inappropriate behavior in some instances, it was unable to conclude that these instances created a chilled environment. Specifically, the Team found that despite a widespread knowledge about a limited number ofinstances ofinappropriate behavior, a substantial majority of the work force at Byron Station was not negatively impacted by the events in question.
- The reassessment we conducted confirms that the methodology employed by the Team resulted in a thorough and comprehensive review of the issues. Our reassessment further confirms the conclusion in Reference 4 that the work environment at Byron Station is conducive to the raising of safety concerns.
We conclude that a safety conscious work environment is well-established and that there has not 1
L been a pattem of discrimination that_ would cause or lead to a chilled environment. We recognize the room for impmvement in the workforce environment.' Training has been co'mpleted for first line supervisors and above that emphasized the need of employees to see that management is addressing y their concerns. Corrective action is also being taken to address the Problem Identification Form
'(PIF) process issues identified during the evaluation, such as the need for improved feedback to PIF originators and clarification for employees of the processes available for raising concerns.
. Additional corrective ac* ions are described in the attachment.
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l May 26,1999 U.S.. Nuclear Regulatory Commission l Page 3 1
It should be noted that there have been significant management personnel changes in 1998 and 1999
~ at the Byron Station, including most recently the appointments of Mr. Levis as Site Vice President
. and Mr. Lopriore as Station Manager. Additional changes have occurred in the Operations,
' Maintenance and Radiation Protection Departments. The new management team has been fully advised of the need for, and is demonstrating a commitment'to, sensitivity to maintaining an
' environment where employees do not hesitate to raise concerns.
! Should you have any questions or desire further information, please contact me at (630) 663-7330.
Respectfully,
,. R. M. Krich l Vice President - Regulatory Services
' Attachment -
cc: . Regional Administrator-NRC Region III NRC Senior Resident Inspector - Byron Station i
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J ATTACHMENT Responses to Ouestions Concernine Alleged Chilline Effect at Byron Station Transmitted by NRC Letter Dated March 18.1999 '
Ouestion 1: ,
Explain the basisfor the sample size and conclusion that the scope of the problem has been l identified. Please include a description ofyour investigation. For example, the discussionfor most examples indicates that the data was gatheredthrough interviews; however, the discussion ofsome '
examples could imply the use ofsome type ofsurvey. Also, identify the number ofindividuals questioned or surveyed by department.
Response to Ouestion 1:
As described below, the evaluation was appropriately designed for a thorough review of the concerns provided in the NRC's letters dated August 5 and August 26,1998, and was sufficient to identify of the scope of the issues underlying the concerns. The Team's entire methodology was conservative and designed to identify issues and employee perceptions. Therefore, based on the evaluation, we remain convinced that the overall working emironment at Byron Station is conducive to the raising of nuclear safety issues. l l
The evaluation consisted of five basic steps: (1) preliminary review; (2) evaluation preparations; (3) {
systematic interviews of station employees; (4) analysis of data collected; and (5) preparation of a j report. i Step 1 began promptly after receipt of the NRC's August 5,1998 letter, when the Nuclear Oversight !
Vice President -initiated a review of the concerns in that letter. This initial review concluded that the concems were substantive and called for significant management attention. Following consultation j with other senior executives, the Nuclear Oversight Vice President established an Independent i Evaluation Team to examine the concerns in more depth. The Team's composition and independence were described in our November 20,1998 letter to the NRC. The Team was made up ofindividuals from a law firm experienced in nuclear matters and possessing significant skills in interviewing and pursuing leads, and members of the Comed Employee Concerns Program Staff.
Step 2 began with the Team reviewing information related to the concerns raised in the NRC letters.
This included a review of relevant procedures and policies concerning the Problem Identification 1
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Form (PIF) process and root cause evaluations, as well as prior mlated correspondence with the NRC and.dther applicable background information. In addition, the Team contacted two individuals who were extremely knowledgeable about the concerns and who agreed to be interviewed. These two individuals were interviewed at substantial length. As part of their interviews, the two individuals provided written materials related to their concems.
- As to the basis for the sample size and conclusion that the secpe of the problem was identified, the following describes the process used to identify interviewees and determine that the extent of the problem had been satisfactorily covered. Based on the two interviews and the associated written materials, the Team determined that the specific issues underlying the seven examples raised by the
' NRC had been identified, thereby defining the scope of the problem. With respect to the sample I size, it was the intent of the Team to capture a sufficient number of. people who might have information concerning the seven NRC examples; 103 individuals were interviewed.
In response to the question conceming whether interviews or surveys were used to gather >
information, the following describes the methodology employed. Face-to-face interviews were deemed to be the more effective way to probe the issues and gather data because they assured that responses would be obtained and that leads could be followed. Also, the people interviewed consisted of those known to possess relevant information about the seven examples.
As a final part of the preparations for the employee interviews, the Team pmpared a set of standard questions to use during the interviews. These questions generally covered the seven examples and were used to gain an overall " sense" of the workplace (and to assist in identifying whether a pattem of discrimination existed that would cause or lead to a chilled environment). Interpretation of j findings and in-depth analysis of the problems was very important, especially for gaining an J understanding of behavior pattems in the context of the specific concems. Accordingly, the Team utilized the standard questions as a tool to ensure a systematic approach to the evaluation, to ensure consistency in questioning and as a means to maintain a focus on determining the validity of the
' seven concems. Therefore, the evaluation involved interviews and was not a survey.
Step 3 of the evaluation consisted of the 103 employee interviews. The sample size and composition were principally based on input from the two knowledgeable individuals interviewed at the beginning of the evaluation. Specifically, the two interviewees identified individuals who they regarded as knowledgeable about the concerns and the specific issues they raised during their interviews. This approach resulted in a near majority of the interviewees coming from the l Operations Department. In order to obtain a broader perspective, individuals were selected for interviews from various other Byron Station organizations. The breakdown ofinterviewees by l_ .
department is as follows. Unless otherwise noted, the interviewees were not bargaining unit employees.
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x e Operations -- 45 (17 Bargaining unit / 28 Non-Bargaining)
. . . Engineering -- 14
.. Radiation Protection -- 9 (5 Bargaining unit / 4 Non-Bargaining) e Regulatory Assurance--4 e Corrective Action Group- 5 e Training -- 4
- e. Chemistry -- 3
.. Nuclear Oversight -' 3 e Work Control - 5 e- Stores - 2
. Instrument Maintenance - 1 (Bargaining unit)
. . Electrical Maintenance - 2 (Bargaining unit) e' Miscellaneous (including current and former station management) -- 6 Each of the 103 interviews consisted of a two step process. First, the employees were asked to answer the standard questions on seven general issues. Second, the employees were asked to provide any information they had conceming the specific issues that were raised by the two previously referenced employees. The interviewers were not confined to the standard questions, but rather were -
able to pursue leads and new issues as they arose during the interviews.
Step 4 of the evaluation involved analyzing the data collected'via the interviews and through related documentation (e.g., PIFs, root cause reports and 'other station-specific documents). TheLdata
' analysis pmcess employed a phased approach, first determining whether individual issues were valid or not and then, based on these results, determining the cumulative effect on the workplace environment. This phased approach included both objective and subjective analysis techniques.
Severr.1 objective factors were used to help assess the individual issues (e.g., whether the matter was isolated, the level of management involved, whether an alleged incident was particularly noteworthy, and whether an ir;cident was a result of poor communication). This more objective analysis was supplemented with the Team's subjective analysis based on their experience and conclusions about the context of the situation surrounding the issues under consideration. This methodology.was applied conservatively, i.e., biased in favor of validating the concems. For example, as noted in the November 20,1998 letter, the interviewee selection process was biased in favor of those personnel most knowledgeable about the allegations being investigated. Finally, the Team used a mix of
! objective and subjective analysis ofinformation gathered.
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Ouestion 2 The " Depth ofScope ofEvaluation" section stated that the evaluation inquired into individuals '
knowledge of the experience of others but the resulting information was not discussed in the response because it tended to be "somewhat speculative, not consistently reliable, andpartially redundant. " Did this information include any common themes or insights related to the issues of safety conscious work environment?
Response to Ouestion 2:
A common-theme / insight that the Team derived from this "second-hand" information was that a large number of specific issues were based on the personal experiences of a small group of Operations Department personnel, including the two individuals interviewed originally. These issues were pursued with individuals possessing first-hand information. The interviews indicated that the experiences of these individuals were widely known to Byron Station personnel, which suggests that the individuals shared their experiences with others or that stories spread through rumor. These experiences formed the basis for perceptions of others regarding the nature of the workplace environment.
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Ouestion 3:
The evaluation ofExample No.1 states that about 20 percent ofthe 90 personnel questioned stated that they wokdd hesitate to raise non-safety issues, including those critical ofmanagement decisions.
Twelve ofthe individuals said they were apprehensive ofmanagement 's reaction and halfofthem
' felt their careers would be negatively impacted. One instance was identified when an individual did not write a Problem Identification Form (P1F)forfear ofretaliation. Yet she conclusion is that Example No.1 touldnot be validated. Explain the basisfor this conclusion.
Resoonse to Ouestion 3:
The first part of this question focuses on the percentage of negative responses. A similar focus appears in Questions 4,5, and 8, answered below. With respect to the issue of percentages, in general, we note that in surveys of safety consciousness frequently performed by licensees, some percentage of employees typically expresses a degree of reluctance to raise concerns. A review of several NRC decisions in this area indicates that such findings, however, do not necessarily indicate that a chilling effect on the environment exists, and that the pervasiveness of chilling effect is a
. factor. The Team took this into account in the evaluation.
The Team noted that none of the interviewees stated that they, or others, would be reluctant to raise safety concerns. The Team concluded that this finding reflects a general safety ethic at Byron Station that the workforce understands the responsibility to raise concerns, particularly safety concems. This conclusion served as a basis for not validating Example No.1, especially in view of the fact that none of the 89 individuals' asked the question indicated that they were reluctant to raise safety concerns. j in addition, most of the individuals who expressed hesitancy to write PIFs indicated that they were
- apt to use altemative means to raise their concerns. This fact was important to the Team in reaching its conclusion not to validate Example No.1. .Also, the confirmed concerns were limited to the :
Operations Department and were not pervasive across the station organization. The Team concluded l that in consideration of all the responses, Example No. I did not accurately characterize the workplace, and certainly not so with respect to the raising of safety concerns.
With regard to an individual who had stated that he was hesitant to write a PIF about the timeliness
. of corrective actions generally because he thought it could be " career limiting," the following specific infonnation was considered. The individual indicated in response to a question by the Team that a specific leakage problem that had been corrected could have been corrected sooner. The I i
individual's supervisor, after an on-shift meeting, encouraged him to write a PlF to emphasize 5-
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concern for attentiveness and timely resolution of problems that he had expressed to the supervisor. 1 The individual noted that the supervisor had emphasized that he and others needed to identify !
problems. The individual explained to the Team that his reluctance to initiate a PIF on his concern was because his management might not pay attention to his concern or might view such a PIF as a means of complaining publicly that his management is doing a bad job.
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l Ouestion 4:
The discussion ofExample tvo. 2 states that nearly 85% responded that draft P1Fs are not required to be submitted to supervisors. This would appear to indicate that more than 15% ofthose surveyed believe that PlFs must be submittedfor supervisory review. Yet the conclusion is that Example No.
2 could not be validated. Please explain the basisfor this conclusion.
Response to Ouestion 4:
Example No. 2, as set forth in the NRC letter dated August 5,1998, cites the following.
I Some supervisors requiring that draft PIFs be submitted and ' edited' by the supervisor prior to entry into the PIF data base.
Importantly, no interviewee claimed that management had substantively edited any of his or her j PIFs. Of the interviewees who said their PIFs were edited, most indicated that the edits were grammatical. For example, one interviewee stated that some supervisors asked to be shown draft PIFs to ensure their completeness and the proper characterization and identification of the problem.
Two other interviewees claimed that draft PIFs were reviewed prior to their submittal; but, both individuals again implied the review was for non-substantive reasons. Others indicated that the PIFs were edited to remove extraneous information. Furthermore, Nuclear Station Procedure (NSP)-AP-4004," Corrective Action Program Procedure," Section 1.2, only provides for supervisory review following PIF initiation to assure completeness and accuracy. Also, the PIF process was computerized in 1994 such that PIF originators now enter a PIF directly into the system and, once ,
entered, the PIF cannot be changed or edited. l 1
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r Qpntion 5:
Given the substantial number ofindividuals (20 percent ofthe 90 personnel questioned regarding Example No.1) who stated they would hesitate to raise non-safety issues, is Comed concerned that individuals may not raise what they believe to be non-safety issues, which really do have a nexus to l safety?
Response to Ouestion 5:
i We are concerned when any individual feels constrained in raising any type ofissue. Therefore, the i following details of the interview information for Example No. I were carefully considered. Most of the individuals who expressed hesitancy to write PIFs indicated that they were apt to use alternative means to raise their concern, such as bringing it directly to a supervisor. It is this latter
' finding that led the Team to conclude that in the great majority ofinstances, employees will raise issues, safety or otherwise, with management. The Team concluded that the interviewees appreciated the distinction between actual or potential safety concerns and non-safety concerns. A substantial majority of individuals interviewed stated that they would not hesitate to raise any concerns, whether they were safety-related or not. The Team found that, when asked, most individuals stated that management is supportive of raising concerns.
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l Ouestion 6:
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The response to Example No. 3 stated approximately 80 personnel were questioned and 43
/ responded that they would not hesitate to raise a dissenting view. What did the lack ofa response l from the other individuals indicate?
Response to Ouestion 6:
Although about 80 individuals in total were asked standard questions regarding this example, it is
- i. -important to note that interviewees were not all asked the same questions. For example,43 individuals were asked whether they would dissent in the future; all 43 said they would do so. The Team' addressed other questions to personnel concerning Example No. 3. The Team inquired whether interviewees had experienced intolerance by management for expressing dissenting views, and whether interviewees are aware of others who may have experienced such intolerance. Based on the responses to these questions, the Team found that the vast majority of the personnel interviewed clearly stated their conclusion that management is tolerant of dissenting views, and they would not hesitate to voice such views.
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Ouestion 7:
. Please explain the basisfor the conclusion that Example No. 3 was not validated when 10 percent ofthe individuals questioneddisagreed that management was tolerant ofdissenting views andfive issues in this area were substantiated.
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Response to Ouestion 7:
The Team noted that of the 8 interviewees who responded that management is not tolerant ofdissent, ;
half were personnel assigned to the Operations Department. The Team's findings regarding the !
individuals who indicated that management was not tolerant of dissenting views and the five substantiated issues in this area led to the conclusion that, for a small segment of employees, certain -
supervisors had seemed to display unacceptable behavior from time-to-time. Therefore, the Team concluded that there are discrete pockets in which relations between a few managers and workers are not healthy. Importantly, however, there is no indication that this situation has compromised safety or inhibited the identification of safety-related issues by station personnel.
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j l l Ouestion.H: !
The discussion ofExample No. 5 concluded that it could not be validated. Please explain the basis
. for this conclusion in light of the statement that seven issues were substantiated or partially substantiated Inparticular, there was one instance where a management individualdiddissuade l an individualfrom writing a FIF.
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~ Response to Ouestion 8:
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l The Team inquired whether managers or supervisors attempt to dissuade personnel from raising j~ concerns or initiating PIFs. In response to this question, seven issues were identified. The Team l l evaluated these seven issues separately and concluded that, by themselves, the issues were not l
pervasive and should not be construed as establishing a " chilled environment," but were examples of questionable management effectiveness in administering the PIF process. While the interview responses confirmed that informal and appropriate communications between supervisors and employees initiating PIFs frequently occurred, an overwhelming majority of the interviewees i
responded that supervisors and managers have not attempted to dissuade them or others from raising
. concerns or writing PIFs. These responses confirmed that management is very supportive of writing PIFs. Many of those who expressed concems explained that management's actions were to seek an
- attemate resolution or professionally disagreed that the matter rose to the level of a PIF.
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The seven substantiated or partially substantiated issues involved at least two examples of miscommunication between management and a PIF originator that appears to have been unintentional. Other examples involved comments by managers said to have been made in jest or l to indicate that an altemative to writing a PIF might exist or that a PIF was not necessary.
We reexamined the Team's interview results conceming the incident noted in our November 20, 1998 response to Example No.- 5 (i.e., the concem involving a manager alleged to have dissuaded an individual from writing a PIF). The facts indicate that after discovering the issue and bringing it to management's attention, the individual became frustrated and tumed the issue over to a fellow worker. The reason for the frustration was that his supervisor questioned the individual's technical ability to evaluate the condition. Nevertheless, the concem was promptly addressed as a result of I responsive action by management. The individual stated when questioned during his interview that ll ordinarily in such a situation, he would have written a PIF, but that he elected not to in this instance.
l While this situation was judged to be noteworthy, it did not provide enough of a basis to validate l l- : Example No. 5.
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- Ouestion 9:
~ The response to Example No. 6 indicated that six individuals " declined to or could not" provide details regarding instances when managers had confronted individualsfor raising concerns to the INRC Did the individuals performing the evaluation explore the reasons why some individuals declined to provide more information (i.e., was this an indication offear ofretribution)?
Response to Ouestion 9:
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1 We reviewed the interviews of the six individuals and determined that the Team did explore the reason why_ one individual declined to provide more information. This individual indicated reluctance to provide specifics, although the individual was willing to be interviewed, responded to l questions and did not indicate that his reluctance was based upon a fear of retribution. In this regard, the review of the six interviews indicated that none indicated a fear of retribution and that the l remaining five of the six responded candidly to the Team's questions during the interviews but were unable to provide all pertinent details.
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i Ouestion 10:
The corrective actions discussed in the attachment are described in a general manner (e.g.,
" tailoring corrective actionsfor each, which may include, " and "taking appropriate corrective
. actions, such as"). In addition, the response to Example No. I said steps are being taken to reinforce management expectations regarding individuals' responsibility to write PIFs. Please discuss in detail the corrective actions being taken and the schedulefor those actions.
Resoonse to Ouestion 10:
The following information provides a detailed description and current implementation status of the .
corrective actions summarized in our letter dated November 20,1998. As noted in that letter, while the focus of many of the findings of the Team was on the Operations Department, these corrective actions apply. to the entire Byron Station workforce. The Byron Station Nuclear Oversight'
.. organization will evaluate the overall effectiveness of these corrective actions by September 30, 1999. The corrective actions generally cover communications, training and the PIF process.
- 1. Trainingfor all supervisors and managers, to include behaviors necessary to create a safety conscious work environment.
Status: Safety Conscious Work Environment training was completed at Byron Station on March 8,9, and 17,1999 for first-line supervisory personnel and
. above. This training.will be added to the continuing training for Byron Station supervisors and managers. The training focused on the importance of maintaining a safety conscious work environment and the responsibility of management to encourage the raising of concems in a professional manner. The training included review of discrimination issues, worker protection regulations and discussions on the most appropriate way to handle situations in the work environment.
- 2. Assessment ofissues vertfied and tailored corrective actions.
Status: Corrective actions pertaining to the personnel issues verified during the evaluation were established in January 1999. Corrective actions include:
Safety Conscious Work Environment Training was provided for first-line supervisors and above, as noted earlier; I
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Department tailgate communication meetings were conducted for all
.- departments; and, Individual coaching sessions were completed by supervisors.
- 3. Station-wide dissemination ofa summary ofthe evaluation together with appropriate corrective actions.
Status: A clear message needed to be sent to all personnel by station management and this has been done. This action was completed by the issuance of the January 29,1999 Memorandum to Byron Station Personnel from Mr. K. L.
Graesser, Site Vice President.' This memorandum highlighted the principal conclusions from the evaluation, noted the specific corrective actions taken to assure that all employees fully understand and meet management's expectations, addressed the resolution of the " contact form" issue and emphasized that management "will nel tolerate behavior that is intended to stifle communications or undermine safety, such as discouraging the raising of safety issues or the writing of PlFs."
- 4. . Conduct meetings with stakeholders (i.e., personnel interviewed) to review the Evaluation Team's findings in order to underscore the importance of communications and build confidence that we are committed to a safety conscious work environment.
Status: We made personnel aware of the results of the evaluation and the corrective actions. The debriefing meeting with the two interviewees who provided the ;
issues was conducted on January 15,1999, at Byron Station by Employee Concerns Program and Evaluation Team representatives. The Site Vice President, Mr. Levis, subsequently met with both individuals to underscore the seriousness with. which company management approaches issues concerning a chilled environment and to stress management's commitment to a safety conscious work environment. Mr. Levis aise thanked the individuals for their participation and cooperation in the evalue. tion process. l He reiterated his commitment to a safety conscious work environment and i offered an open door to them and others with respect to issues that might adse.
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- 5. Assess the PIF implementation issues identified during the evaluation and take appropriate actions.
Status: A number of actions have been completed or are in progress, as described below.
Senior management is more closely involved in the PIF process issues. A cW.er was developed by December 22,1998, for the Byron Station Event Screening Committee (ESC) that is responsible for screening PIFs. This charter ensures that management personnel participate in event screening and that Senior Station Management participates in the daily ESC and these personnel are properly trained on the PIF program process.
Enhancements to station procedures and practices have been implemented to provide a more personalized feedback mechanism to the originators of PIFs.
Revisions provide for more direct feedback to PIF originators, including direct verbal feedback when appropriate. In addition, copies of Apparent Cause or Root Cause Reports are provided to the associated PIF originators upon completion.
A fonnal Corrective Action Review Board exists at Byron Station to evaluate the overall effectiveness of the corrective action process. We have reinfomed with the Board the need to scrutinize PIF resolutions to ensure their adequacy and to ensure that identified concerns are addressed in a timely manner.
Steps are being taken to reinforce expectations regarding individuals' responsibility to write PIFs. A handbook for station personnel is being developed for issuance by September 30,1999, which will address the proper threshold for initiating PIFs.
- 6. Issuance ofa memorandum to all Byron Stationpersonnel which states unequivocally that ifan individual wishes to bring a concern to the NRC, the individual does not have tofillout an NRC contactform.
Status: A Memorandum to Byron Station Personnel from Mr. K. L. Graesser, discussed above, was distributed on January 29,1999, to complete this action.
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- 7. Revise Site Policy 100.5, "Policyfor Employees Raising Nuclear Safety Concerns, "
to include the clarification discussed in item no. 6 above.
Status: The revision was made on January 11,1999. The procedure clearly states that employees may confidentially contact the NRC at any time without having to provide notification to any station personnel or fill out an NRC contact form.
- 8. Conduct tailgate meetings with all Byron Stationpersonnel to discuss this matter.
Status: The tailgate meetings were completed in March 1999.
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The corrective action section of the response states that the actions may include removal of derogatory information from personnel files. Was disciplinary action taken against any individual (s)for raising safety concerns?
~ Response to Ouestion 11:
This corrective action was identified as afprecautionary measure, to review personnel files to determine if any of the interviewees who raised safety concerns was disciplined. Disciplinary action has ~ not been taken against any individuals for raising safety concerns.
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Ouestion 12:
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. We note ti.at the response paragraph titled " Work Environment " says the majority view was that the negative environment was not widespread but existed in a limited number ofdiscrete area.
Please identify those areas and describe the corrective actions being taken to address the environment in them.
Resoonse to Ouestion 12:
The November 20,1998, response noted that there were limited areas of conflict, referring to the Operations Department. As discussed in response to the previous questions, the Team confirmed that a few Operations Department managers engaged in instances ofinappropriate behavior.
The corrective actions addressed in the response to Question 10 above, as well as Station management changes, are intended to address inappropriate behavior by managers and supervisors at Byron Station which could adversely impact the work environment, such as occurred in the Operations Department. Corrective actions to address PIF implementation issues, also addressed in the lesponse to Question 10 above, are aimed at ensuring that the work environment remains conducive to raising safety concerns.
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