ML20214E348
Text
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%, UNITED STATES
[ q NUCLEAR REGULATORY COMMISSION s -
! wasmucton, n. c.nosss
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March 19, 1986 -
DRAFT OR PRELIMINARY INFORMATION* [-
MEMORANDUM FOR: NRC TVA Senior Management Team M /
FROM: John W. Craig, Section Chief '
Special Projects Inspection Section Division of Quality Assurance, Vendor, and Technical Training Center Programs
. S'UBJECT:
TEAM REVIEW 0F FILES RELATED TO INTIMIDATION, HARASSMENT, AND-WRONGDOING - TVA ,
Purpose:
t From March 10-21, 1986, a 7 person team composed of five representatives of IE, with one representative each from NRR and OELD, conducted a review of existing files dealing with harassment, intimidation (H&I), and wrongdoing. The team also had the support of an 01 investigator from Region V, available for consultation in 01 matters, or techniques, as the need arose.
The teams's purpose was to identify potential safety concerns and to identify any patterns of harassment and intimidation, or wrongdoing, involving TVA management and supervisory personnel. The files contained employee concerns potentially involving H&I or wrongdoing. The team did not attempt to determine'
' whether or not the concerns were valid. Rather, an assumption was made that the information in each file was correct. With this assumption, and applying a conservative (low) threshold for potential safety concern (PSC), the team ;
reviewed each file and made a judgment as to whether or not the file * -
constituted a PSC.
The review schedule was as follows: ,
4 March 10 RII-0I files in Atlanta.
March 11 TVA-0GC files in Knoxville. .
l March 12-14 QTC fila: et Watts Bar.
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ECP files at Watts Bar.
ECP files at Sequoyah via the NRC resident.
ECP files at Bellefonte via the NRC resident.
ECP files at Browns Ferry via the NRC resident. '
ECP files at Knoxville via the TVA-ECP representative.
ECP flies at Chattanooga via the TVA-ECP representative.
March 14 TVA-IG files in Knoxville. .
. b03 W ao &G, ,
,-. _ . . - ..-. n NRC TVA Senior Management Team -
March 17-18 DOL files in Nashville; copied and reviewed in Bethesda.
QTC files concerning wrongdoing received in Bethesda from 01:RII. -
.Results:
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- 1. Approximately 250 flies classified as involving potential H&I issues were reviewed.
- 2. The team categorized 154 as involving H&I. Team judgments were made for each file and in some cases the file had been investigated and H&I was not
_ substantiated by QTC.
- 3. The team identified 136 of the 154 H&I file, and 24 of the non-H&I files
- _ as potential safety concerns.
- 4. Nearly 60 of the 106 QTC H&I cases related to the fear of TVA personnel to report quality deficiencies due to a TVA policy of suspension or
- dismissal. This policy was stated in a November 1982 memorandum which was presumably meant to. emphasize "do it right the first time," but was regarded as a threat by a number of TVA personnel. The general construction superintendent responsible for the memo was
- reassigned to other duties at Watts Bar in November 1985 during an ongoing investigation.
- 5. The team reviewed 136 flies involvin'g potential wrongdoing. Of these 100 were classified as potential safety concerns. -
6.
- ' The' team teviewed 11 DOL cases. Nine have had decisions rendered. Seven',
cases brought forth by professionals were decided "against TVA" and two -
brought forth by craft personnel were decided "for TVA." The deoistons in the other two cases have not been made. Note that 4 of the 5 recent DOL l
~ cases NSRS, filed have been by individuals (several supervisors) working in professionals. The team also reviewed 2 MSPS cases, both brought forth by 4 One was decided "for TVA* and one "against TVA."
- 7. The team has not as yet identified any individual (s), or work unit (s), as a potential source of multiple charges of H&I or wrongdoing; nor was the team able to identify trends involving TVA management personnel. No
- indications were found which demonstrated that either TVA or QTC is systematically attempting to reconstruct all of the alleged instances of H&I, or wrongdoing, in order to identify specific managers / supervisors or organizational units which may repeatedly appear in problem situations.
- 8. Final reports by QTC frequently do not identify the period of. tin in ,
which the incident or item occurred. Rather, dates concerns were reported are identified. -
- 9. Mr. Steven A. White issued a memorandum on March 7,1986 noting his recent actions on cases involving H&I and reminded managers of his policy to issue severe penalties against those found guilty of H&I.
__.----r - . . . _ _ _ . - . _ . _ _ _ , . _ _ _ . _ - _ - - .- - - . _ . , . _ - . . _ _ _ _ _ . - - . . _ _ - ~ . - - _ _ _ , _ . - _
f NRC TVA Senior Management Team ..
- 10. The investigations.TVA IG's office is in the initial phases of acquiring staf to begin
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- 11. Resolution of potential safety issues may conflict with continued confidentiality. When QTC conducted interviews, employees requested and were given confidentiality. Specific technical issues contained in these instances may not have been provided to TVA if QTC concluded that doing so would identify the employee. During discussions with QTC personnel, this issue was discussed as was the need for follow-up discussions with individuals to clearly identify potential technical issues. QTC noted that if all documentation was provided to TVA, the confidentiality agreement made with employees will be breached. QTC estimates that there are approximately 580-1000 such instances. These do not necessarily '
represent different technical issues, and while specific technical details may not have been reported to TVA, the technical concerns may have been -
identified to some extent.
Preliminary
Conclusions:
i 1.
The team has not been able to correlate potential safety concerns in a manner which raises the issue of the competence, integrity, or conduct of individual TVA employees. Such a correlation is not possible without a significant effort to reconstruct and identify specific instances of ,
potential H&I or wrongdoing. Employee concerns have been divided into 4
numerous subconcerns. This splitting of concerns for resolution increases the " number of concerns" and will be misleading when attempting to identify trends. - '-
- 2. The team did not find any indication which demonstrated that either TVA or QTC was systematically attempting to reconstruct instances of H&I or wrongdoing.in order to identify specific employees, or organizational .
units, which may be the source of H&I or wrongdoing.
- 3. The concerns expressed by TVA employees repeatedly referred to retaliation by TVA managers when an employee identifies a QA concern or an honest mistake. This climate of impending retaliation is also evident in statements made by employees that those who don't have the " appropriate attitude" will not be promoted and employees with the. appropriate attitude do not identify issues which need to be resolved.
- 4. The current perception of TVA employees concerning retaliation for reporting quality issues is undefined. Recent DOL decisions and recent instances involving intimidation and harassment, or discrimination, indicate that this continues to be an unresolved issue which will require .
considerable senior TVA management effort and time to resolve.
I s
J
r NRC TVA Senior Management Team . ,.
- 5. Conflict between TVA and QTC concerning QTC's role in resolving concerns may impede efforts to get resolut on of potential safety items, f -
1 John W. Craig, Section C ef Special Projects Inspection Section Division of Quality Assurance, Vendor, and Technical Training Center Programs
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cc: H. L. Thompson, NRR -
B. J. Youngblood, NRR D. R. Muller, NRR R. L. Spessard. IE 4t;.
J. A. Axelrad. IE "
D. M. Yerre111. RI!
._ , J. Lieberman ELD t
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- DRAFT INFORMATION SUBJECT TO RtVIEW BY NRC SENIOR MANAGEMENT - NOT TO BE PUBLICLY RELEASED WITHOUT COORDINATION WITH NRC SENIOR MANAGEMENT TEAM, s
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.Uwrrrn srATEs.cov:nvrrr * .
Mestbraridum - '
T4GmbSEE VALLEY ATJMORITY
. s ro ' :
JAll Assistant General C&.struction Suprinta . dents, Craf t Superintendents, FRoM :
and All Trades and Iaber Ecurly D:plcyces, Vatta Bar R: clear Plaht C:"Er .
C.C2;STE. Jettan, General Censtrtecien Superinten3 enc, ,t'atts 3ar M: clear Plant Darn : .Nov e r.29, 1982 , ,
sunJrcr: .
WAITS BAR NDCIIAR PW2 - QCAUTY ISSUPRE PRCCPM -
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This me:orandan supersedes cy cemorandre dated F@ruary 4, BS2.'
Several incidents have cccurred recently in which we are nat fulfilling our total ccr:nitznent and respensibility to cur q:ality assurzice pregaz. We centinue to fall short in areas such as Lypassing welding hold points, re:crial or tampering falsdfication of cbcumentation,with finalized etc.itens witbout the proper dcce:entation, On Ja:n:ary 18, 1982, I issued instructions that ,t!ie craft superintendent er histhe of assistant would ceet with his forecen onca -rpeek and train them in one QA promtwes.
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- Ch April 2,1982, I issued instructions to utilize the fi.rst hour of the shife on Tuesday to train the crews in sality assurance matters.
All e ployees at Watts Bar have participated in the Annual'CA Se inar in which George H. II::raons, Panager, Office of Engineering Design and ccastruction, e:#.asized that line managers are accountable.for i=pl e tation of procedures which govern their respective *Ih*8 Of responsibilities. r '
Responsibility for CA'is charged to both canager and e=ployee alike. We must follow procedcres in order for the QA program to work. Penalties I=1st
.be i= posed toct. #.nsize our cc:n.itcent to quality ar.d correct cur
' deficiencies. Effective i::nediately, QA,violaticns will result in the .
follcwing disciplinar'f actions: . .
.e
/
First Offense .- suspension or discharge, depending en the circu=s.ancas ~,
t Secend offense - discharge
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C. H. 'Jetten EOS:SA ' .
cc: R. W. Olson, CEO-WEN CCNS*:'
Guenter Wadewitr, ItC-KEN C2EI s
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Enclosure <-
ffblyd se qs us a.co.wds.e s
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f CMTED'ETATES COVERNMENT AO? 860307 001
\ Memorandum p TENNESSEE VALLEY AUTHORITY
- O lU*?ua TO : Those listed - *dit OntCtcv Orrr*r FROM :: S. A. White. Manager of Nuclear Power, LP 6N 38A-C 14W 'Ui b0 O
DATE : March 7, 1986 _
,, g J:;UBJECT: HARASSMENT AND INIIMIDATION
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Recently I have had the unpleasant task of administering IY7taanns I u'. g g
action in sevaral cases arising from charges of harassment#-Ud '
!/
intimidation. .I know that you are all aware of my strong-f?5] iga! +
u-,e t.his matter,- and I know that you agree that there is no PIace. Jar m s g, activity anywhere in TVA's nuclear program.
1 mL These cases have caused me to believe that my policy pechibiting the harassment or intimidation of any employee in the Office of Nuclear Power may not have reached to all levels of management and to every employee.
Please redouble your efforts to ensure that each employee under your p, , . direction is fully informed .of my policy and of the severe penalties that will ensue if any employee is found guilty of harassment or intimidation of any other employee.
i
& .0.
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H. L. Abercromble. ONP, Sequoyah R. B. Kelly, LP 4N 45A-C W.- C. Bibb, Browns Ferry C. C. Mason, LP 6N 37A-C
- W. T. Cottle, LP 6N 35A-C L. E. Martin, LP SN 25A-C J. P. Darling, ONP, Bellefonte B. R. McCullough 12-108 SB-K R. P. Denise, LP 6N 40A-C R. A. Pedde, 9-169 SB-K W. C. Drotleff, W12 A12 C-K (
R. L. Gridley, LP SN 1578-C _ Site Director. ONP. Vatt's Bar i L. O. Holliman, LP 3N 41A-C E. K. Sliger LP 6N 48A-C J. W. Mutton, LP 6N 57A-C F. A. Szczepanski, BR IN 768-C j
L. L. Jackson, LP 6N 37A-C N. E. Taylor, LP 6N 45A-C
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DIVISION OF CONSTRUCTION -
i Working Rules s -
for Trades and Labor Employees .
4 I '
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. i 1 Effective July 15,1983 TVA h assee -
- Vasey ..
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Amthority l
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. T ' -, --
TABLE OF CONTfftFS ..
Page i
Int roduction' . . . . . . . . . . . . . . . . . .l . . . . . . . . . . . . .
Category A Rule Violations . . . . . . . . . . . . . . .2. . . . ,
Supplementary Schedule H.XIX (Daily Work i Schedule on Construction Projects) . . . . . .2. . . .
' i Category B Rule Violations . . . . . . . . . . . . . .4. . . . . l
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Category C Rule Violations . . . . . . . . . . . . .6 . . . . . . l i :
i Unapproved . *.bsences . . . . . . . . . . . . . . .7. . . . . . . . 1 t L i i
Leaving Work in Groups in Violation of 1 Article 11 of the General Agreement . . . . . .. 1. . . . ;
Division of Construction Policy - }
Racial and/or Scaual Harassment. .8 . . . . . . .. . . . ,
Division of Construction Policy - .
Radiation Boundary Crossings . . . . . . . . . 9. . . . . .
l Division of Construction Policy - ,
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.. Investigation of Aftercations . . . . . . . . . . . .10. . . . i Employee Conduct Standards and - ;
Responsibilities . . . . . . . . . . . . . . . . . . . . . . .12.... .
j Specific Clarifications - ,'
TVA Conduct Regulations . . . . . . . . . . . . . .30 ... .
TVA Policy -
Search of Persons, Vehicles,- ,
or Packages 32 ..... '~
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Joint Security Plan - .
Construction Project Rules and Regulations 33 m- _ __ ____
sammagnue * . .
. TVA DIVISION OF CONSTWuCTION 1 woontmo muus For any organization to function smoothly, it is necessary that members of the organization understand i the guidelines for conduct in the workplace. While con.
duct guidelines are common sense items it is helpful for -
employees, supervisors, and managers,to have before them in writing some of the guidelines which most fre-quently raise questions and the probable consequences facing each person should those guidelines not be i
followed. That is the reason we are publishing the following conduct guidelines.
These guidelines are not intended to be allinclusive, but they do identify the types of offenses which fall into cer-tain individual categories. They provide the normal penalties that may be imposed for any specific infrac- l tion; however I reccgnize that on infrequent occasions the prescribed penalty may not be appropriate. Accord.
ingly, on such occasions I am charging each supervisor with the responsibility of modifying the penalty im-posed based on that particular set of circumstances.
You are encouraged, however, to conform to the prescribed penalties in all but exceptionally different documented. cases; and deviations must be justified and carefully ,
We ask the wholehearted support of all trades and labor .
employees within'the Division of Construction in the observance of these guidelines, and I assure each of you that these guidelines will be fairly and equitably ad.
ministered visory by employees with managerial and super.
oversight.
, ~ f ',
l Charles Boni r.
Manager of Construction 4
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CATEGORY D RUIE V808 ATNM88 i Category B Craft Supervisor, General Foreman, or Craft Superintendent l
Penelty before leaving. The General Foreman or Craft Superintendent will determine whether the absence is approved.) . :
First offense - 2 calendar week suspension Second offense - Discharge 9. Insubordination toward supervisor (discharge . -
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' yg, ' ' depending upon the severity of the act).
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1 I. Gambling (discharge depending on severity 10. Submission of false, incorrect, or inaccurate in-of offense). formation on TVA documents (up to and in- *
ciuding discharge for an obvious or willful viola- _
tion).
' 2. Concealing defective work or viotstion of Quality ;
Assurance / Quality Contr7 procedures (up to ,
and including discharge for obvious or willful g
!, I Li violation).
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- 3. Possession or use of TVA tools, equipment, or i
materials for other than authorized TVA work,
- 4. Crossing security barriers.
- 5. Solicitation or selling food or material items on .
TVA property by TVA employees. ,
.i j 6. Sleeping (discharge if clearly to avoid work or creating obvious safety hazard).
- 7. Possessing intoxicants on TVA property outside the controlled area. (Employees are responsible t l -
,' for articles covered under this rule found in any -
1 vehicle they are driving.)
- 8. Leaving job during work hours <ithout permis-sion of supervisor. (Employees who must leave the project for any reason must personally re-quec permission from their foreman, Assistant
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