ML20207L448

Forwards Info in Response to Issues Raised During 880929 Meeting W/Nrc in King of Prussia,Pa & 880920 Telcon Re Plan for Restart,Industrial Relation Protocols & Revised Grievance Procedure & Disciplinary Guidelines

ML20207L448
Person / Time
Site:	Peach Bottom
Issue date:	10/10/1988
From:	Basilio J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Martin R Office of Nuclear Reactor Regulation
References
NUDOCS 8810170304
Download: ML20207L448 (12)

Text

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1 PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 (215) 8414ooo October 10, 1988 Docket Nos. 50-277 i 50-278 l I

Mr. Robert Martin, l Licensing Project Manager, NRR  ;

U. S. Nuclear Regulatory Commission  !'

Mail Station P1-137 Washington, DC 20555 ATTENTION: Document Control Desk

Dear Mr. Mart!a:

The purpose of this letter is to provide information in response to issuas raised during the September 29, 1988 meeting with the NRC in King of Prussia and topics discussed during a teleconference held with D. ;iorisseau and yourself on September 20, 1988. Information regarding the issue raised during the meeting are provided in Attachment I. The topics of our teleconference are addressed below.

Our teleconference discussion was focused en Philadelphia Electric Company's previous responses to NRC Question II-38 on the "Plan for Restart of Peach Bottom Atomic Power Station" which concerned the revised grievance procedure and disciplinary ,

guidelines for the Nuclear Group.

The first topic discussed was the revised set of Industrial Relations protocols which are currently k ing developed by a consultant. You requested that we provide information regarding these protocols. A copy of those protocolr. will be transmitted to you when they are completed. We are currently scheduled to complete the protocols in Noverbor, 1988.

Tho second topic discussed was the distribution of the revised grievance procedure and disciplinary guidelinos. Copies of the proceduro and guidolines and the distribution memorandum are included as Attachment II. In addition, to help gauge the employees' understanding of the procedure and guidelines and dt.termine the need for document revision, wo will keep track of the employee questions directed to the Plant Personnel Administrator for a porlod of 90 days following the distribution.

Please do not hesitate to con'.act me if you have any further questions regarding the material presented in this letter and the attachments.

Sincerely,

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8610170304 881010 (

PDR ADOCK 05000277 cjm

. T.. Basilio

, Restart Manager-Licensing Attachments .

cc: Addrossee .

I T. P. Johnson, NRC Resident Inspector T. E. Magette, State of Maryland h

/ th i j O

, ATTACHMENT I

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Page 1 of 4 ISSUE 1: STAFFING OF THE INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)

Philadelphia Electric Company is committed to maintaining an Independent Safety Engineering Group (ISEG) for the Peach Bottom Atomic Power Station with sufficient staff to perform its function as described in Section I of the "Plan for Restart of Peach Bottom Atomic Power l Station", Revision 1, pages 41, 42 and 43.

Our proposed commitment is to have Peach Bottom ISEG composed of at least three dedicated, full-time engineers, including the ISEG l Supervisor, located onsite. The staf f of the Peach Bottom ISEG may be supplemented by dedicated, full-time engineers located at the corporate office. The total of the staffs of the Peach Bottom ISEG and the dedicated engineers located at the corporate office shall always be at least five engineers.

The PBAPS ISEG staff currently consists of five engineers (a Supervisor and four engineers). One of the four engineers is assigned to the Senior Reactor Operator license training class which will conclude in June, 1989. The staff of the PBAPS ISEG is currently supplemented by two engineers on the corporate office staff (the Manager and one additional engineer). At Peach Bottom restart, the ISEG staff is expected to consist of the personnel currently assigned to the corporate office staff and PBAPS ISEG, as described above.

b ATTACHMENT I  ;

Page 2 of 4 ISSUE 2: LICENSED OPERATOR STAFFING i

t The Technical Specifications require 5 licensed operators per on-duty shift which means 30 licensed positions are required to be filled when

. utilizing a six shift rotation. Peach Bottom plans to restart with six i

shift crews each manned with six operators (3 SR0s and 3 R0s) n -

requiring 36 positions to be filled.  ;

Peach Bottoa's goal is to maintain 42 active licensed operators on shift assignments. This number would provide an additional SRO and an i additional RO for each shift crew to help cover the planned and  ;

unplanned absences without excessive use of overtime. This goal of 42

operators does not include the licensed personnel planned to fill the l Blocking Coordinator or Blocking Permit Writer positions. It is t i anticipated that this goal will be achieved by early 1990. l 4

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ATTACHMENT I Page 3 of 4 ISSUE 3: QUALIFICATION OF FACILITY STAFF The Peach Bottom Atomic Power Station requirements for the qualification of facility staff are provided in paragraph 6.3.1 of PBAPS Units 2 and 3 Technical Specifications. The paragraph states:

"Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1 - 1971 for comparable positions, except for (1) Senior - Health Physicist (radiation protection manager) who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975 and (2) the Shif t Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant for transients and accidents."

The statement requires the qualifications of the facility staff, with the exception of the Senior - Heelth Physicist and the Shift Technical Advisor, to meet the requirements of ANSI N18.1 - 1971 for comparable positions in accordance with the definitions set forth in the standard.

Each of the positions is required to meet the "shall" statements for the comparable positions in the standard because the word "shall" is defined in the star.dard to denote a requirement. The Technical Specification requires the Senior - Health Physicist to meet the recommended requirements of the Radiation Protectiori Manager position as set forth in Regulatory Guide 1.8, September,1975. The Shift Technical Advisor position is required to meet the qualifications set forth in the Technical Specifications.

ATTACHMENT I Page 4 of 4 ISSUE 4: STAFFING OF THE BLOCKING COORDINATOR AND ELECTRICAL SUPERVISOR POSITIONS The Blocking Coordinator function is one of the functions currently being performed by a group of staff engineers assigned to the Work Control Center staff. Peach Bottom's goal is to have the Blocking Coordination group staffed with a licensed Senior Reactor Operator and four to eight licensed Reactor Operators. This group is planned to be fully staffed in early 1990.

The Electrical Supervisor position was previously filled by a formerly licensed Senior Reactor Operator; however, the individual was recently promoted to the Operations Support Superintendent position. As the Operations Support Superintendent, he currently performs the functions of the Electrical Supervisor position in addition to those of his new assignment. We are currently re-evaluating the need to have the Electrical Supervisor position remain a separate position.

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• ATTACHMENT II Page 1 of 7 PEACH BOTTOM ATOMIC POWER STATION Office of the Vice President l

l September 30, 1988 FROM: 0. M. Smith }

TO: Senior Staff

SUBJECT:

Grievance Procedure and Discipline Policy for Nuclear Plants The Nuclear Group Disciplinary Guidelines were recently revised and a copy is attached. Please ensure your personnel are pr0Vided copies of the revised Disciplinary Guidelines. Other Personnel Policks, including the Grievance Prcaedure, as distributed in John Kemper's letter of February 3, 1988 are stiil in effect. Please ensure that your employees are familiar with this.

An;' questions on these policies should be directed to the PBAPS Personnel Administrator, Steve Grosh.

Vice President CMS /RAK:j1w

ATTACHMENT II Page 2 of 7 S 26-1 2301 Markee Streec August 18, 1988 M4: C. A. McNeill'Jr.

E: J. W. Gallagher D. R. Helwig J. S. Ke.~per S. J. Ecwalski G. M. Leitch D. M. Smith

3. Silanich SUPJECT: Discipiirrf Glidelir.es i

Attached is an interim set of disciplirary guidellres for use in the htclear i Gr:Up.  ?.ese guidelires specify hcw the htclear Group Will L plerent the corporata discipliref precahres, ard are in effee i. nediately. n.ey l

supa-Me any previcesly issued iscipliref guideliras or staninds. R.ey '

are subjecc to revisien, ba,ad en the %trk of the Prctccol Grcup.

?.ese guideliras shculd be apperded to Nuclear Statien %crk rules and l distributed thrcugh nor al chstrels.

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• ATTACHMENT II

- - Page 3 of 7 DISC FLOG.RY CUICEL2iES I 2m'CCCCTICN Sese guidelines apply t.c all htclear Grcup e:colcyees. S ey describe the prece ares by which disciplira vill be a&tirtiste.n.ad in the htclear G:cep.

A successful disciplirary prpm depends en its fairness and censis*ancy of a&tinistratien. Disciplirary accien is intended w cenect behavier Its gcal is incersistent with htclear Grxp policies, prccerures and gcals.

to assist e:=lcyees in successfally charging such behavice thrcugh pm.v corrective actiens. Disciplira sy to used as a ccrreceive acticn in cases of peor wrk perfccance, or violatiens ad htclear Grcup work rales, policies and precetares.

In res cases, disciplirarf actien shculd he a&tinis~ared puw;ussively, and urdertaken cnly after ccurselirs has failed a bring alcut the desired behavier change. Se severity of the ac-J.cn shculd increase as previces steps fail to bring alcut the desired behavice change. Se pr:gressien detailed helev is the htclear Grcup's acceptei preceiare for a6tirtisterirq disciplira. In'scro cases, the early steps in this prcgressica ray nce be urdertaken, as the sericus rature of scre offerses ray necessitate rcre severe actica as a first step.

II CEFD CTICNS Sere are five steps in the htclear G cup's disciplirarf prccess:

Step 1 C F E 'rG P2 C iG Step 2 hEITIEt 'rGMD;G Step 3 FIFRnG2fD Step 4 SUSFEISICN Step 5 NGIICM of EGI.DYMEC Se geal of each step is to corm ths prcble.m, ard assist the erployee in heccctirg a su~m-eJ1, valued rcrher of the htclear Grcup *aa:n.

CFE 'rGRCiG An cral varning is the first focal centact with an e.pleyce to discuss pe .fc=ance issues or minor efferses, hRrITEI 'rGRCiG A written warnirq is the secend step in the pr cess. It is issued if perfc=ance has not i: prcved, er behavier ciarged af*ar an cral %nniing.

Scre offerses ray result in a vritten arning withcut an cral itmirg heirq a&tinistered first.

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ATTACIU2hT II Page 4 of 7 l FIFF M 'ID .

A reprirard is the third step in the process It is issued after %ritten C:ntir.ued unirpreved work warnLgs have net resulted in 1 preved behavior. j perfor-ance or centir.ued repetitien of effenus resultirg in oral and I written %arnirgs will result in a reprirand. J SUSFDISICN A suspensien withcut pay is the fcurth step in the pto:ess. It is a ver/

severe discipltrary act.icn, issued in cases of a::ntint.ed peer perfccance f.hich has not L preved as a result of previcus steps, or sten an erp loyee  ;

ccmits a breech of Nuclear Grcup %crk rules or proceddres sufficiently serices to warrant rercval frem the votk place. l

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t TEDOMICN of mFMmDC Termiratien is the fifth and firal step in tha process. It shculd he used as a cLisciplin:ry acticn enly after centbued peer perfc= axe teccmes an intolerable si'.uatien, and other less severe disciplirary acticns have 4

t failed to brirg abcut the re owf i p:everents; er % ten an erpleyce .

w....lts a sirgle, intc1erabin of! arse.

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II.I TEE DISCIPLINE FW., CESS CFAL h'AFNDU After discussirq the sitatien with the seccnd level superviser ard the 1ccal Human Fascurces Specialist, the first level super /iser discusses hcw ,

the egleyee's perfecarce is not reecirq expectatiens, or the rature of a ,

specific infraction with the erployee. The supervisce clearly states the  ;

igreverents expec*ced en the part of the employee. The super /isce decurents l the %2Micn, and retairs the documentation in his files fcr fellcy up. t b'AIT1H NAF2C G t l

The first level super /iser prepares the written warning, clearly stating the  !

rature of the prcblem, past discussiers of the pr blem with the enleyee, . l expectatiers for irprevement en the part of the crployee, ard the '

ccrsequences of centinued lack of Lprevement. The seccrd level super /iser  :

ard lccal B.rcan Fesc%r:es Specialist review ard cercar with the warning.

The first level super /iser discusses the arnLg with the aployee. acth l 1

the super /iser ard erplcyee sign ard date the notice, which is placed in the '

1 employee's ser/ ice reccrd, ard provided to the enleyee.

FIFRD9ND The first level super /iser prepares the reprinani with the approval of the seccrd Ic. vel super /iser ard Erployirq officer, ard cercarrence of the 1ccal l

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Huran Fascurces Specialist. The reprirard ircludes a descriptien of the 1

' rature of the prcblem (centinued pcce perfecance or violatien of %rrk rules ard/or precatares), expectatiens fer irpreverent, ard ccrsequences of centinued lack of ig reverent. Any restrictiers are also rcted. The firs i

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ATTACHMENT II i l

Page 5 of 7 l i

level superviscr diccurses 2e repri-and sic de erplcyee. Ec2 de super /iser ard e=' ,yce sim te repri-and. A ccpy of ce mpri ard is placed in O.e erp.- , ee's s r/ ice reccrd, prcvided Oc O.c e=leyce, ard fervardcd to de Mclear Greue Rran Fescu~cs Parageren Scccien.

S*CSFDS CU 2e first level super /is:r decrents the reascrs fer ce s"spersien, ,

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e:cectar_icrs for 1.preverent, ard ccrsequerces of centinued lack of i=revercnt, for ac.creval bv. the seccnd level sc.erviser and Em. icyi.g Officer, and cercarrence of de 1ccal Bran Rescurces Specialist. The first leve' superviser and n=leying Cfficer discuss the suspersien eith te '

em. icv.ce, ex:ectatices fer irpreverent at de cenclusicn of the suspersien, I

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ard ccrse@ences of centinued lack of i.preverent. S e erpleyce, first ?.e level cuper/iser ard n:picyi.g officer sign ard data the dec=cntatien.

decrentatien is placed in ce e=leyee's ser/ ice recc d, previded to de erleyce, ard fcrsarded to the Nuclear Grcup Rean Fescurces Parageren:

Sectien.

TE.MDGTCN cf DEEM 2e first level supervisc" dec. ents de reascrs for ta=dratien, for l appre-/a1 hy the seccrd level super /iser, Dgicying Officer ard cepa=-ent Vice President, and cercarrerce by the 1ccal He-an Eescur es 5pecialist, Director, Bran Rescurces Paragerent, ard Vice President, Persennel ud '

'rcustrial Palatiers. Se lccal Rean Fescurces Scecied.is crecares '

ne ter-dratien ta=iratien papers. Se Copar ren: Vice Presiden: 'recc= ends' '

ard fersares the papers _c ce Nuclear Grcup x=an aescurces x. rc.en:

Sec-icn, and vice President, Fersernel and 'ndustrial Eelatiers j

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At any step, the e=lcyee has de r:.ght to representatien by de _a. IGA representatives sill receive cepies of any dec~a.ntation placed into an ecpicyce's service rcccrd upcn rescst.

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. ATTACRMENT II

., .- Page 6 of 7 S25 2301 Market Street Februsry 3. 1988 FROM: J. S. Kemper TO: 'NJ . W . G alla g hc.c S. J. Kowalski G. M. Leitch D. M. Smith D. R. Helwig

SUBJECT:

Nuclear Group Personnel Policies During the past year, changes to certain personnel policies were agreed upon between Nuclear Management and the Personnel Department and IGA. ,

Thess changes were documented in various letters dat3d between September and November,1987. The purposes of this letter are to compile them together and to make th"n applicable to t) e total Nuclear Group. '

Policy No. 1 - Hiring Process of 1 Sar Erroloyees During the annual review of P, sonnel Budgets, the Chief F.xecutive Officer will review and approve employee positions necessary for each Nuclear Plant and Department.

The Nuclear Group will submit, to Personnel and Industrial Relations, job titles and job descriptions (where applicable) and the number of people required in the coming year to expand forces and/or replace losses. Employment Division will maintain an 'open posting" for these critical jobs and maintain a current list of qualified employees interested in transfer. ..

Upon receipt of a requisition for employment in these critical jobs, Employ-

, ment Division will begin immediate and sirnultanecus processing of candidates for transfer and candidates for new hires fr e "

• side the Company. Qualified and available transferees will be given pret- : r. :

Policy No. 2 - Promotion to Supervision While there will be no change in historic procedures, the requirements for higher levels of excellence in perfo mance, responsibility, and ;; countability for nuclesr plant workers will extend into the process and procedures for promotion to first level and higher levels of supervision.

Qualification

• promotion to any level of supervision will require profisioni or better perforrnsa:e in the present job, as documented by periodic performance evaluation, 2nd understanding of the requirements and skills of supervision, and, where appropriate, qualification by test to demonstrate required techr.ical know-ledge. Assessment of an employee's potential abtl.ity to supervise people will be made on the basis of human relations performance in his present job.

ATTACHMENT II

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$ For promotion to first level supervision, the senior employee who has met the qualifications for the new position will be given an opportunity to demonstrate his qualification for promotion by temporary or upgrade assign-me n t s . Such temporary assignments will be increasingly important for main-taining skills and preparation for promotion. Present plant rules and practicus gc,verning overtimo, call-out, and upgrade seniority should be reviewed with IC A representatives and modified where necessary to permit these developmenu,1 assignments. .

For promotion to supervision above first level, plant management will select the best qualified candidate for temporary or upgraded assignments.

Permanent pro notion to any level of supervision will be made only af ter a candidate has demonstrated his qualification for the new position and has performeu satisfactorily in periods of temporary or upgrade assignments.

Policy No. 3 - Application of Disciolinary Guidelines The Dtsciplinary Guidelines contained in You and Your Company are applicable to all employees in all kinds of jobs. Because of the sensitive nater2 ef jobs in the Nuclear Group, however, and the potential effect on the public and on the Company of substandard performance, very high standards of performance, responsibility, at.d accountability are expected of nuclear employees. As a rese;t, infra cions involving job performance and behavior are more likely to be conside.ed to be serious or major infractions and be :reated accordingly in the disciplinary process.

Policy No. 4 - Application of Grievance procedure For all Nuclear Group employees, problems or complaints should first be brought to the attention of the employee's immediate supervisor for resolution.

If the problem is not resolved, she employee should submit it to successively higher levels of supervision up to the Employing Office r. When it has reached the Employing Officer level, it should be in writing. Where possible, this pro-cens should be completed within 20 days.

If the response froca the Employing Of!!cer is unsatisfactory, or if the -

process is not completed within 20 days, the employee may file a written state-ment of the grievance with his Department Vice President. A written response should be provided within 20 days.

If the Vice Pres. dent's answer is not responsive to the grievance, it may be submitted in acc.ordance with established procedure to the Vice President -

Personnel and Industrial Relations.

,c ' e No. 5 - Application of Suspension Appeals Procedure Nucler . 7.':yees will continue to have the righ; to appeal a suspension W P ot A nnels. In order to provide for the timely mposition of a for infractions involving job performance and behavtor, e 4 si such susper.=wns imposed on nuclear employees will be

.w and/or afte.' the suspension. If the sppeal is upheld, the

- e reimbursed for his regularly schedGed hours on suspension.

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Senior Vice President Nuclear ec: C. L. Fritz

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