ML20235D723
| ML20235D723 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/13/1987 |
| From: | Evans P TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 72000, 72000-V07-R03, 72000-V7-R3, NUDOCS 8902210003 | |
| Download: ML20235D723 (34) | |
Text
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l EMPLOYEE CONCERNS SPECIAL PROGRAM l
VOLUME 7 MANAGEMENT AND PERSONNEL CATEGORY SUBCATEGORY REPORT 72000 PERSONNEL RECORDS UPDATED TVA NUCLEAR POWER
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s IVA CMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
72000 REPORT TYPE: Management and Personnel Subcategory REVISION NUMBER:
3 TITLE: Personnel Records PAGE 1 0F 16 REASON FOR REVISION: Incorporation of final evaluator comments.
PREPARATION PREPARED BY:
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SP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
72000 SPECIAL PROGRAM FRONT NATTER REY:
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.PAGE i 0F viii Preface This subcategory report is one.of a series of reports prepared for_the Employee' Concerns Special Program (ECSP) of the Tennessee Valley Authority; (TVA). The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of Nuclear Power.to evaluate and report on those.0ffice of Nuclear Power (ONP)-
employee concerns. filed before February 1, 1986".
Concerns filed after that date are handled lby the ongoing ONP Employee Concerns Program (ECP).
The ECSP addressed over 5800 employee concerns. Each of the concerns was a-formal, written description of a circumstance or circumstances that an employee thought was unsafe, unjust. inefficient, or inappropriate. The mission of the Employee Concerns Special Program was to. thoroughly.
investigate all issues presented in the concerns and to report.tho'results of those investigations in a form accessible to ONP employees,.the NRC, and the general public. The results of these investigations are communicated-by four levels of ECSP reports: element, subcategory, category, and final.
Element reports, the' lowest reporting level, will be published only.for.
c those concerns directly affecting the restart of Sequoyah Nuclear. Plant's reactor unit 2.
An element consists of one.or more closely related issues. An issue is a potential problem identified by ECTG during the evaluation process as having been raised in one or more: concerns.
For efficient handling, what appeared to be similar concerns were grouped into.
j elements early in the program, but issue definitions emerged from the.
evaluation process itself. Consequently, some elements did include'only one issue, but often the ECTG evaluation found more than-one issue per element.
Subcategory reports summarize the evaluation of a number of elements.
j However, the subcategory report does more than collect element level evaluations. The subcategory level overview of element findings leads to.
an integration of information that cannot take place at the element level.
This integration of information reveals the extent to which problems overlap more than one element and will therefore require corrective action for underlying causes not fully apparent at'the element 11evel.
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To make the subcategory reports easier to understand, three items have been l
placed at the front of each report:
a preface, a glossary of the-terminology unique to ECSP reports, and a: list of acronyms.
I Additionally, at the.end of each subcategory report will be a Subcategory Summary Table that includes the concern numbers; identifies other j
subcategories that share a concern; designates nuclear safety-related, safety significant, or non-safety related concerns; designates generic applicability; and briefly states each concern.
Either the Subcategory Summary Table or another attachment or a combination of the two will enable the reader to find the report.section or sections in which the issue raised by the concern is evaluated.
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n TTA EMPLOYEE CONCERNS REPORT NUMBER:
72000 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE 11 0F vili The subcategories are themselves summarized in a series of eight category reports. Each category report reviews the major findings and collective significance of the subcategory reports in one of the following areas:
management and personnel relations industrial safety construction material control operations quality assurance / quality control welding engineering A separate report on employee concerns dealing with specific contentions of intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.
Just as the subcategory reports integrate the information collected at the element level, the category reports integrate the information assembled in all the subcategory reports within the category, addressing particularly the underlying causes of those problems that run across more than one subcategory.
A final report will integrate and assess the information collected by all of the lower level reports prepared for the ECSP, including the Inspector General's report.
For more detail on the methods by which ECTG employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employee Concerns Task Group Program Manual.
The Manual spells out the program's objectives, scope, organization, and responsibilities.
It also specifies the procedures that were followed in the investigation, reporting, and closeout of the issues raised by employee concerns.
TVA EMPLOYEE CONCERN 3 REPORT NUMBER:
72000 SPECIAL PROGRAM FRONT MATTER REY:
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'PAGE.iii 0F vili ECSP GLOSSARY OF' REPORT TERMS
- classification of evaluated issues the. evaluation of an issue leads to one of the following determinations:
Class A:- Issue cannot be verified as factual Class B:
Issue is factually accurate but what is described is not a problem (i.e., not a condition requiring corrective action) l Class C:
Issue is factual and identifies'a problem, but corrective action for the problem was initiated before thc' evaluation of the issue was undertaken Class D: Issue is factual and presents a problem for which corrective' action has been, or is being, taken as a result of an evaluation Class E: A problem, requiring corrective action, which was not identified by an employee concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.
l collective significance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
1 concern (see " employee concern")
corrective action steps taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causas in i
order to prevent recurrence.
criterion (plural:
criteria) a basis for defining a performance, behavior, or quality which ONP imposes on itself (see also " requirement").
element or element report an optional level of ECSP report, below the subcategory level, that deals with one or more issues.
employee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or-inappropriate; usually documented on a K-form or a form equivalent to the X-form.
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73000 SPECIAL PROGRAM FRONT MATIER REY:
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l evaluator (s) the individual (s) assigned the responsibility to assess a specific grouping of employee concerns.
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findinas includes both statements of fact.and the. judgments made about.those l
facts during the evaluation process; negative findings require corrective action.
l issue-a potential problem, as interpreted by the ECTG during the evaluation process, raised in one or more concerns.
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l K-form (see " employee concern")
requirement a standard of performance, behavior, or quality on which an evaluation' judgment or decision may be based.
root cause the underlying reason for a problem.
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- Terms essential to the program but which require detailed definition have been l
defined in the ECTG Procedure Manual (e.g., generic, specific, nuclear safety-rolated, unreviewed safety-significant question),
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s TVA EMPLOYEE CONCERNS REPORT NUMBER:
72000 SPECIAL PROGRAM FRONT MATTER REY: 2 1
PAGE v 0F vill l
' AI Administrative Instruction
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AISC American Institute of Steel Construction i
ALARA As Low As Reasonably Achievable l
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ANS American Nuclear Society ANSI American National Standards Institute ASME American Society of Mechanical Engineers
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ASTM American Society for Testing and Materials AWS American Welding Society BFN Browns Ferry Nuclear. Plant BLN
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CATD Corrective Action Tracking Document CCTS Corporate Commitment Tracking System CEG-H Category Evaluation Group Head CFR Code of Federal Regulations CI Concerned Individual i
CMTR Certified Material Test Report l
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COC Certificate of Conformance/ Compliance DCR Design Change Request DNC Division of Nuclear Construction (see also NU CON) 1
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i TVA EMPLOYEE CONCERNS REPORT NUMBER:
72000 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE vi 0F viii l
DNE Division of Nuclear Engineering DNQA Division of Nuclear Quality Assurance DNT Division of Nuclear Training DOE Department of Energy DP0 Division Personnel Officer DR Discrepancy Report or Deviation Report ECN Engineering Change Notice ECP Employee Concerns Program ECP-SR Employee Concerns Program-Site Representative ECSP Employee Concerns Special Program ECTG Employee Concerns _ Task Group EEOC Equal Employment Opportunity Commission EQ Environmental Qualification EMRT Emergency Medical Response Team l
l EN DES Engineering Design 1
ERT Employee Response Team or Emergency Response Team
'FCR Field Change Request FSAR Final Safety Analysis Report FY Fiscal Year GET General Employee Training HCI Hazard Control Instruction HVAC Heating Ventilating. Air Conditioning i,
II Installation Instruction INPO Institute of Nuclear Power Operations l
IRN Inspection Rejection Notice
TVA EMPLOYEE CONCERNS REPORT NUMBER: 72000 SPECIAL PROGRAM-FRONT MATTER REY:
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'l L/R Labor Relations Staff M&AI Modifications and' Additions Instruction MI Maintenance Instruction MSPB Merit Systems Protection Board MT Magnetic Particle Testing
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NCR Nonconforming Condition Report NDE Nondestructive Examination NPP Nuclear Performance Plan NPS Non-plant Specific or Nuclear. Procedures System NQAM Nuclear Quality Assurance Manual NRC Nuclear Regulatory Commission NSB Nuclear Services Branch
.I NSRS Nuclear Safety Review Staff NU CON Division of Nuclear Construction (obsolete abbreviation, see DNC)
NUMARC Nuclear Utility Management and Resources Committee OSHA Occupational Safety and Health Administration (or Act)
ONP Office of Nuclear Power OWCP Office of Workers Compensation Program PHR Personal History Record PT Liquid Penetrant Testing QA Quality Assurance QAP Quality Assurance Procedures QC Quality Control QCI Quality Control Instruction
o TVA EMPLOYEE CONCERNS REPORT NUMBE'At ~ 7200L SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE viii 0F vill QCP Quality Control Procedure QTC Quality Technology Company RIF Reduction in Force RT Radiographic Testing SQN
,Sequoyah Nuclear' Plant-SI Surveillance Instruction S0P Standard Operating Procedure SRP Senior Review Panel SWEC Stone and Webster Engineering Corporation TAS Technical Assistance Staff T&L Trades and Labor TVA Tennessee Valley Authority TVTLC Tennessee Valley Trades and Labor Council UT Ultrasonic Testing VT Visual Testing WBECSP Watts Bar Employee Concern Special Program WBN Watts Bar Nuclear Plant WR Work Request or Work Rules WP Workplans I
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PERSONNEL RECORDS Subcategory Report 72000 Executive Summary The subcategory included 22 employee concerns which raised eight issues.
The major issues were tho alleged inaccuracy of Personal History Records, the possibility of " secret" records being improperly maintained by field construction managers, and alleged misuse of records by managers.
The findings reveal that by and large Personal History Records (PHR) are maintained according to TVA procedures which are satisfactory. Construction managers do generally maintain files apart from the central personnel files.
Some individual managers also keep private personal'uotes referring to employees under their jurisdiction. This is propar as long as the not6s are
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not circulated or used to justify actions concerning the employees.
It was i
found that warning letters sometimes remain in omp1.oyees' records after they
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have expired.
j There has been a lack of clear understanding by both managers and employpen l
concerning employees' rights, as provided for in the Privacy Act, to see ;.neir records. To correct this, information about the requirements of the Act has i
b6en included in the new Supervisor's Handbook, and a comprehensive article about this subjuct will soon be published in Inside TVA. WBN management also has initiated a project to remove outdated warning letters from personnel files.
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1.0 CHARACTERIZATION OF ISSUES j
l 1.1 Introduction This report covers the subcategory of Personnel Records; It1 l
addresses 8 issues raised about the maintenance, the accuracy, the disappearance, the misleading coding, the unauthorized access, and the falsification of TVA personnel history records (PHRs) and the L
access.to non-PHR files by theLemployees.. All the concerns in.
this subcategory are generically applicable to any TVA site.
In addition to the Employee Concerns Task Group (ECTG)' evaluation, this subcategory report includes a review of.the results of the Employee Response Team (ERT) Investigation Report "Perudnnel Records Concerns" and line managements response to that report.
The comments from the ERT' investigation have been incorporated into the Findings section-(4.0).
To locate the issue in which a particular concern is evaluated, consult the following attachments:
Attachment A Subcategory Summary Tables Attachment B, List of Concarns by Issue All Management and Personne1' Category concerns having a' technical' component (including all concerns designated Nuclear Safety-related) are shared with the appropriate technical category for investigation and resolution of that technical component.'
Report (s) sharing a concern with this report are_ identified in-the entry for that concern on Attachment A.
1.2 Description of Issues There are 22 concerns in t'e Personne1' Records subcategory report h
(72000). These 22 concerns ar,e: grouped into four elements addressing a total of 8 iswues. Two of the issues were about management's maintenance of separate records which' employees could not access. Three of^the issues were about the inaccuracy of the records and the requirements of the Privacy Act.. One of the issues was about the misuse of information.by supervisors. One miscellaneous issue was about unauthorized access of a personnel i
record by another employee and one miscellaneous issue was about management falsifying personnel record documents.
l 1.2.1 Secret Records l
About one half'of the concerns in this element specifically mentioned the Construction Office or the' Division of Nuclear Construction (DNC) Superintendent; three mention I
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h TVA' EMPLOYEE CONCERNS REPOR'S NUMBER: 72000 SPECIAL PROGRAM REVISION NUNBER:- 3 PAGE 3'0F 16 Office of Nuclear Power (ONP) plant operations organizations:
two at Watts Bar Nuclear Site (WBN) and one at Sequoyah Nuclear Site (SQN). Two were not specific about the organizational group.
A.
Issue 72001 - T&L Files and " Secret" Records a
This isaue.contains eight concerns addressing the-possible maintenance of personnel files other than the official TVA PHRs.
Most of the concerns in this element stated that employees cannot review these non-PHR personnel files; thus employees have no knowledge of the file contents and no opportunity to contest inforestion in the files.
B.
Issue 72002_, Personnel Notes Kept by Supervisor One concern raises an issue about misuse of personnel notes made by supervisors.
l 1.2.2 Flawed Records The issues in this element address Privacy Act requirements that records on individuals be maintained with such i
accurecy, completeness, relevance, and timeliness as to ensure fairness to the individual in any determinations made on the basin of those records. Ten of these eleven concerns were from DNC at WBN. The source of the other concern was unspecified.
A.
Issue 72003 - Inaccurate or Out-of-Date Personnel Record Documents Most of the concerns in this issue contend'that personnel record documents are inaccurate or out of date; therefore, determinations made on the basis of such records would not be fair to the individual.
B.
Issue 72004 - Disappearance of Trades and Labor (T&L)
Flies This issue addresses the disappearance of personnel files kept in the Construction Superintendent's office.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 72000 SPECIAL PROGRAN REVISION NUNBER:~~3 l
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Issue 72005 - Elialbility Codes for Re-emolorment This issue' contends that personnel files contain a code on eligibility for rehire which is often in conflict with the evaluation of the employee.
1.2.3 Misuse of Records The two concerns inlthis element were from DNC at WBN.
A.
Issue 72006 - Supervisors Misused Information in l
Personnel Records
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'l One. concerned individual.(CI)' suggests that information in field files was used to keep supervisors informed on
" whistle blowers."
l The other CI contends that social security numbers were i
used without the-employees' authorization to monitor and track employee activities such as training.
i 1.2.4 Miscellaneous i
Three concerns in this element were from DNC at WBN. The other concern was from ONP at SQN.
A.
Issue 72007 - Unauthorized Access to Personnel Records This issue contends that there was unauthorized access to.the personnel records of another employee.
B.
Issue 72008 - Falsification of Personnel Records This' issue contains two contentions that management has; falsified documents in personnel records, l
2.0 SUKMAPl 2.1 Summary of Issues This subcategory report examined the issues stemming from employee
'l concerns about the personnel records kept on them.
2.2 Summary of Evaluation Process The evaluator has reviewed all the information available on the concerns in this subcategory. The information pertinent to the evaluation of the issues has been considered and incorporated in this report.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
72000 i
SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 5 0F 16' The evaluation of these issues involved research into ONP, and particularly WBN, personnel recordkeeping system; inspection of personnel files; and the conducting of. interviews.
j 2.3 Summary of Findinas The issues concentrated on trades and labor (T&L) field files
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rather than the employee's permanent file,.the Personal History Record, which is usually referred to as the PHR.
1 One specific finding'was that the procedure used elsewhere'for I
removing outdated-warning letters from the personnel files was.not used for T&L files in'the Office of.the Construction Superintendent.
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2.4 Summary of Collective Significance.
l The major problem in this subcategory was that during the time period when these issues were raised.'neither employees nor construction management recordkeepers seemed to be aware of employees' rights to review the personnel records kept on them.
2.5 Summary of Causes I
The cause was seen as the lack of instruction for both supervisors i
and employees on employee rights under the Privacy Act of 1974.
1 2.6 Summary of Corrective Action 1
Corrective action includes a presentation in the new Supervisors' Handbook of information on the requirements of the. Privacy Act and an article in Inside TVA informing' employees of their right of access to their personnel records.
3.0 EVALUATION PROCESS 3.1 General Methodology The evaluation of this subcategory was conducted according to the Evaluation Plan for the ECTG and the Evaluation Plan for the Management and Personnel Group. The concern case files were reviewed. Source documents were researched and interviews conducted in order to identify the requirements and criteria which applied to the issues addressed in the concerns. The concerns were
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'TVA EMPLOYEE CONCERNS
' REPORT NUMBER:
72000 SPECIAL PROGRAM-REVISION NUMBER:
-3 PAGE 6 0F 16 grouped into four elements; the elements were subdivided into issues. The issues were evaluated against the identified requirements.and criteria.to determine findings. A collective significance analysis was conducted;.causes were indicated.for.
l negative findings; and corrective actions for the negative findings were initiated or determined to have already been initiated.
3.2 Specific Methodology The documents reviewed included the Privacy Act of 1974, the Office of Management and Budget Guidelinos which' implement the Act, tne TVA Code and Instructions. TVA's last two annual Privacy.
Act reports to the Office of Management and-Budget TVA Instructions on employee records. TVA manuals on two automated systems relevant to employee records, and two. earlier responses to employee concerns.
A review was made of investigations and responses developed by the:
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Project Manager's Office (PMO), and the Office of Employee Relations. Information from these investigations was used in the I
development of this report.
In addition, the " Sensitive Files" from Quality Technology Company (QTC) were also reviewed.
Nine interviews were held. They included lead personnel officers for DNC, for WEN Project-Personnel Office; and WBN Plant Personnel Office; a WBN Construction Management Assistant (CMA); and managers in TVA's Labor Relations Staff.
.l Two telephone interviews were held:. one with the CMA at
'I Bellefonte Nuclear Project (BLN) and.one with a personnel officer l
at SQN Personnel Office.
Records inspected included the grievance log in the CMA's office; logs of warning letters issued to Salary Policy and to T&L employees; T&L personnel files and notebooks of forms;TVA 77.in-the Construction Superintendent's office; paper copy personnel files in WBN Project Personnel Office; and' microfiche PHRs in WBN Project Personnel Office and the Division of Construction
~l Personnel Office.
Flies for inspection were identified primarily from.the.various logs. All entries that involved the concerns in this subcategory were selected from the T&L grievance logifor January 1984 through December 1985, the salary policy log for January 1982 through June 1983, and the T&L warning letter log from January through.
May.1984. T&L files were also randomly selected by retrieving oco
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TVA EMPLOYEE CONCERNS REPORT NUMBER:. 72000~
SPECIAL PROGRAM REVISION NUMBER: l3 PAGE 7 0F.16 I
file from a position twelve inches from the front of each of the first 19 file drawers. For T&L flies that were inspected and
-i found to contain documents related.to the issues in this subcategory, the corresponding personnel records were inspected in
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WBN Project Personnel Office, j
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4.0 FINDINGS Overview of TVA's Personnel Record System q
TVA's official record on employees is the PHR.that is maintained in Knoxville in the TVA Division of Personnel.
PHR " field files" are maintained in the office of the employee's division personnel officer or, in the case of construction T&L employees, in the office of the employee's project personnel officer or area employment officer. Other files on employees are maintained by supervisors.or by administrative officers acting for a group of supervisors. These files are referred to as " supervisor's files" or "S/A flies." Supervisors tiso have the option of maintaining personal notes to serve as memory joggers.
The basic structure of TVA's personnel record system predates WBN construction project.. However, other aspects of the system have been' changed since the beginning of that project.through implementation of the Privacy Act of 1974 and conversion of PHRs and field files to microform in 1980. The Privacy Act imposes requirements for the protection of information on individuals. It also gives individuals the right to review certain information maintainoa about them and the right to request corrections and amendments in that information.
Conversion of PHRs to microform included the replacement of most " paper copy" field flies with microfiche copies of the PHR, thus eliminating discrepancies in contents of these two flies. -Supervisors, particularly those who did not have ready accessibility to the-microfiche PHR, continued to maintain paper-form S/A flies.
4.1 Secret Records 4.1.1 Issues 72001 - T&L Files and " Secret" Records This issue addresses the contention that management keeps-
" secret" personnel records (non PHR flies wnich employees-cannot review). This would be a violation of the Privacy
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Act.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: '72000 SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 8 0F 16 1
Discussions Personnel records called "T&L files" are maintained in the R
Office'of the Construction. Superintendent at WBN and other.
I nuclear construction sites. Their use is governed by the' Privacy Act of 1974. The Privacy Act prohibition of
" secret" records on individuals is reflected in the.IVA Code under II PRIVACY:
TVA permits.an individual. except as authorized by. law, to ascertain what records pertaining to that individual I
are maintained in TVA systems of records. to gain
. access to and to request correction or amendment of such records.
A " system of records" is a set of records from which H
personal information about an individual'can be retrieved.
by use of the individual's name or.other. personal identifier such as social security number, badge number, etc. Thus, T&L files, as well as other S/A files, ln/A PHR, and PHR field files, are a system of records under the Privacy Act and are subject.to the Act's requirements.
One WBN management employee who. shares the responsibility for maintaining the T&L files said_that_if.an employee so requests, he may see his T&L file without the file being prescreened. A follow-up interview with the same I
individual reaffirmed that. employees can review their T&L flies on request and have been able.to do so since at least.
1977. However, another.WBN management representative (who also assists in maintaining these-files) stated the following in an earlier response to one of the concerns in I
this group:
l Employees would not see these documents unless an adverse personnel action resulted. If an. adverse personnel action does result, the employee has an
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opportunity to review any documents upon which.the action was based.
1 A management representative responsible for, maintaining T&L files at BLN reported that employees may review specific documents from their T&L file if the superintendent approved the employee's request.. Employees are not permitted to review the entire flie.
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3 PAGE 9 0F 16 A management employee responsible'for maintaining personnel files on. Operations personnel at SQN reported that those i
employees may. access their PHRs but may not access the paper field file.. When employee inquires about' information in the paper field file, a clerk checks the file 'and relays information to the employee.
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Conclusion No evidence was found of " secret" personnel records in the DNC Personnel Office (Salary Policy employees) WBN Project Personnel Office (T&L employees), or bHHi Site Personnel Office. However, while this issue is not technically accurate, it has revealed a problem: T&L records in the Construction Superintendent's office.
and some other paper field files were not consistently made available to employees to the extent required by the Privacy Act.
4.1.2 Issue 72002 - Personal Notes Kept by Supervisors This issue which contains one concern addresses the misuse of personnel. notes kept by supervisors.
Discussion 1
Maintenance of personal notes is not prohibited by.the Privacy Act but under some circumstances the notes are.
subject to its provisions. More specifically,.0ffice of-Management and Budget guidelines provide that uncirculated personal notes, paper, and records-which are retained or discarded at the author's discretion and over which the
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agency exercises no control or dominion (e.g., personal telephone lists) are not considered to be agency records within the meaning of the Privacy Act. However, the courts i
have' ruled that when personal notes have been circulated or.
used to bear negatively on worker's employment status or situation. they must be handled in a manner' consistent with tho' letter and spirit of the Privacy Act..
Information from interviews indicated that some supervisors keep personal notes.
Supervisors are taught ~in training courses, and are encouraged by management, to keep personal notes on employees to serve as memory joggers. Supervisors are told also that their personal. notes are not subject'to review by employees.
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3 PAGE 10 0F 16 Conclusion The advice to supervisors that the notes are not subject to review by the employee is accurate only as far as the notes are not circulated or used to support a personnel action.
However, mere maintenance of personal notes by TVA supervisors is not a violation of the Privacy Act and is within TVA recommended practice. Therefore, this issue is factually accurate, but does not constitute a problem requiring corrective action.
4.2 Flawed Records 4.2.1 Issue 72003 - Inaccurate or Out-of-Date Personnel Record Documents This issue addresses inaccurate or out-of-date personnel record documents. Determinations using such documents I
would be unfair to an individual.
Discussion Based upon requirements of the Privacy Act, the implementing TVA instruction states:
TVA maintains all records used in making determinations about an individual with such accuracy, relevance, timeliness, and completeness to ensure fairness to the
-individual in any determination which may be made on the basis of that record.
The instruction on employee records provides that the PHR contain information officially recognized and pertinent to personnel actions and record requirements. All information proposed for filing in the PHR is submitted to the division personnel officer who screens it according to guidelines for authenticity and appropriateness.
Removal of Out-of-Date Warning Letters The TVA instruction on employee records provides:
Letters of reprimand, admonishment, caution, or warning are retained until recalled by a written request from the personnel officer of the issuing division. When a reprimand, admonishment, caution, or warning is included in or used in support of a notice of adverse,
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TVA EMPLOYEE CONCERNS REPORT. NUMBER:
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3 PAGE 11 0F 16 disciplinary, or other personnel' action, the letter cannot be recalled unless the action in the notice is cancelled. Otherwise. the recall is made at the end of three years or earlier at the option of employee's division.
This evaluation found that temporary warning letters that include a six-month limit (a) are not removed'from the T&L files in the office of the Construction Superintendent. (b) are, except when inadvertently overlooked, removed from the paper field file in the' project personnel office and from the nuclear plant site personnel office.-and (c) are not submitted to the PHR and thus are not in either the microfilm PHR or the microfiche PHR fleid file..
Other " disciplinary" letters which are removed from the PHR because the passage of time are not removed from the T&L files in the Construction Superintendent's office.
The accuracy and completeness of a document is situation specific and cannot be determined on a general basis.
However, information from interviews showed that records maintained in personal files are checked for accuracy and completeness by those who prepared the record and the superiors and personnel officers who also sign them.
Job relatedness of information is situation specific and cannot be determined on a general basis. However, documents flied in the PHR are those that the division personnel offi'cor has determined are officially recognized.
and pertinent to personnel actions-and record requirements. Although " job relatedness" is not a controlling factor, it is one of the factors the personnel officer looks at and makes a judgment determination on appropriateness for filing.in the PHR.
Chanaes in T&L files-No documented guidance on notifying employees of changes in the record was found. However, the employee is given a copy of most personnel forms that are prepared. The.raason for a record change is not always explained to the employee. The issuing personnel officer decides, based on the nature of the change, whether a specific explanation is indicated and, if so, notifies the employee of the reason for the change.
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Conclusion i
l A number of safeguards protect against the transfer of outdated or faulty data from the T&L flies to the permanent PHRs. However, employees are not always informed of i
changes to their personnel files and temporary letters of reprimand are not removed from T&L flies in the Office of the Construction Superintendent. Therefore, the failure to remove temporary letters of reference does constitute a problem, but corrective action was initiated before the evaluation of this issue was completed.
4.2.2 Issue 72004 - Disappearance of T&L Files This issue contains one concern which addresses the disappearance of personnel flies from the Construction l
Superintendent's office, Discussion l
i l
The TVA instruction on employee records provides; Individual documents in the S/A file are destroyed when superseded or earlier if no longer needed for reference. The entire S/A file is destroyed when the employee leaves the organization component where the l
file is maintained.
Conclusion l
No evidence was found to indicate that T&L files disappear. The routine DNC practice is to maintain T&L files for at least as long as the construction project continues. Therefore, this issue is not factually accurate.
4.2.3 Issue 72005 - Eligibility Codes for Re-employment This issue contains one concern which addresses the centention that personnel files contain an eligibility code which could conflict with the evaluation of the employee for rehire.
Discussion All TVA employees must meet basic security and suitability criteria.
Employees who leave TVA under conditions listed below are subject to re-evaluation for compliance with the l
w-
v s
TVA EMPLOYEE CONCERNS REPORT NUMBER:- 72000 SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 13 0F 16 security and suitability criteria before they are re-employed. Such employees include those who are discharged for, or resigned following notice of discharge for-the following reasons:
security reasons
' misuse of Government property or official authority or position unapproved absences i
failure to satisfy training program requirements other than work performance unsatisfactory work refusalfto perform work assigned unsatisfactory conduct in work area falsifying records relating to employment violation of article II of the General Agreement; discharge recommended by Joint Committee conduct off job (includes violation of political activity policy and participating in strike against TVA)
The re-employment of applicants who are subject to re-evalus' tion for compliance with the security and suitability criteria is delayed with a temporary restriction (which is indicated by a code) until the re-evaluation is completed.
The process of detecting re-employment appilcants who are subject to re-evaluation is now automated in the Security and Suitability System. Before implementation of the Security and Suitability System, the appropriate restriction code was placed in the automated Employee Information System. Employment restriction codes are used in the automated personnel data. systems to ensure that applicants meet the security and suitability requirements j
for TVA employment. Employment restrictions may stem from statutory, negotiated, or-other requirements, as well as from ratings on employee evaluations and,_therefore, are at times inconsistent with conclusions drawn from the performance ratings.
1 d
_.__..m_... -
-.-m_- - -. - - - - - - -
s--
1 TVA EMPLOYEE CONCERNS' REPORT NUNBER:
72000
.SPECIAL PROGRAM REVISION' NUMBER:
3 PAGE 14 0F 16 Conclusion This issue is' factually accurate, but what is described is not a problem. The codes do not serve the same. purpose:as.
performance ratings. Therefore, differences between them-do not constitute inconsistencies in the system.
4.3 Misuse of Records 4.3.1 Issue 72006 - Supervisors Misused Information in Personnel Records This. issue contains two concerns which contend that.
supervisors misuse'information in personnel records.
Discussion Based on requirements in tho' Privacy Act TVA policy is that "TVA... uses... records of identifiable personnel information in a manner that ensures that such action is for a necessary and lawful purpose; 1
Conclusion No evidence was revealed in interviews with management, representatives to support allegations of use of personnel-record information to keep supervisors informed on " whistle blowers" or to track employee activities. Therefore,.this
)
issue could not be verified as factually accurate.
4.4 Miscellaneous 4.4.1 Issue 72007 - Unauthorized Access to Personnel Records This issue contained one concern which contends-unauthorized access to the personnel records of another' employee was permitted.
3 Discussion Based on requirements in the Privacy Act. TVA. Instruction II PRIVACY, Procedures, Provides:. " Records maintained in a TVA system of records-are not disclosed except pursuant to a written request by or prior written consent of the' individual unless disclosure is permitted by TVA policy in.
TVA Code under II PRIVACY."
m 1
TVA EMPLOYEE CONCERNS REPORT NUMBER:.72000 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 15 0F 16 Conclusion
.This issue contends a single instance of unauthorized access.to personnel records of another employee.
Information on the K-form is insufficient to permit investigation of this contention. No additional information is available. Therefore, this issue could not be verified as factually accurate.
4.4.2 Issue 72008 - Falsification of Personnel Record Documents This issue addresses two concerns which contend that management falsified documents in personnel records.
Discussion Information on the K-forms is insufficient to permit investigation of this contention. No additional information is available.
Conclusion This 1.ssue could not be verified as factually accurate.
I S.0 COLLECTIVE SIGNIFICANCE The issues in this subcategory do not, by themselves, require sweeping corrective action. During the period when these issues were raised.
)
both management and employees at WBN seemed confused about employees' rights to review their personnel field files. Additionally, DNC was not ensuring a systematic purging of the outdated warning letters in its files at WBN. Action has been taken to correct both situations.
However, suspicion of management's motives is evident in almost all of 1
the concerns in this category. That suspicion does form a small part of a much larger problem. The employees who raised these concerns did not perceive their managers as trustworthy: whenever the concerned individuals (CIs) had doubts about what was being done with or to their records, they assumed the worst.
The corrective action spelled out in section'7.0 of this report is intended to not just correct specific shortcomings, but to restore employee confidence that their records are correct and accurate.
However, an overall employee perception of management untrustworthiness is not a problem which can be dealt conclusively at the subestegory level. It will require comprehensive corrective action at the category and final report levels.
l l
u
TUA EMPLOYEE CONCERNS REPORT NUMBER:
72000 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 16 0F 16 6.0 CAUSE 6.1 The effort taken to purge all PHRs and most T&L files of outdated warning letters was not taken by the Office of the Construction Superintendent.
6.2 Neither supervisors nor employees were adequately informed of employee rights under the Privacy Act of 1974.
7.0 CORRECTIVE ACTION 7.1 Corrective Action Already Taken WBN management has initiated a project to remove from the T&L files the six-month warning letters issued from the beginning of WBN Project to July 1983.
The Division of Personnel has included in the new Supervisors' Handbook information about the requirements of the Privacy Act and information on maintaining employee records and personal notes in compliance with the Act. The handbook is now in reproduction.
It is intended for distribution to all TVA supervisors.
7.2 Corrective Action Initiated as a Result of This Evaluation An article was publi d:d I-th: Entry 1, MS7 i n _. ;f !... L TVA (Volume 8 Non
))Movidl.np, p ds(@Mhef, k h(CATD pg
' of No.720-NPS-01).{
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employees' right CGTE:
n-zLe7 8.0 ATTACHMENTS 2
Attachment A - Subcategory Summary Table Attachment B - List of Concerns by Issue
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.ii II'
ATTACHMENT B PERSONNEL RECORDS List of Concerns by Element / Issue The Personnel Records Subcategory (72000) is comprised of 22 concerns which are grouped into four elements addressing eight issues.
" Secret Records" 72001 - T&L files and " Secret Records" I-86-239-SQN IN-85-612-003 IN-85-172-003 PH-85-002-020e IN-85-241-006*
PH-85-008-004*
IN-85-453-002 WI-85-075-002 72002 - Personnel notes kept by supervisors WI-85-046-012 Flewed Records 72003 - Incecurate or out-of-date personnel record documents EX-85-080-001 PH-85-008-004*
s IN-85-045-003 WBP-86-003-001 IN-85-612-004 WI-85-043-001 IN-85-631-001 WI-85-046-011 PH-85-003-030 72004 - Disappearance of T&L files IN-85-241-006*
72005 - Eligibility codes for ro-employment IN-85-480-008 Misuse of Records 72006 - Supervisors misusbd information in personnel records IN-85-913-005 PH-85-002-020*
t 4
i e
Fege 1 of 2 4
6 ATTACHMENT B (continusd)
Miscellaneous 72007 - Unauthorized access to personnel records SQM-86-004-008 72008 - Falsification of personnel records
]
IN-85 631-X02 PH-85-045-003
- Concern addressed in more than one issue.
,j 1
I J
i Page 2 of 2
(
ECTG C.3
(
Attachment A Page 1 of 1 Revision 2 l
I ECSP Corrective
{
Action Tracking Document (CATO)
IKITIATION Applicable ECSP Report No.:
72000 1.
Immediate Corrective Action Required: 0 Yes 08 No 2.
Stop Work Recommended: O Yes pl No 3.
CATD No.
720-NPS-01 4
INITIATION DATE 01-21-87 5.
RESPONSIBLE ORGANIZATION: TVA Division of Personnel 6.
PROBLEM DESCRIPTION: O QR JE NQR TVA management and' emDloyees are i
not adequately informed of employee rights under the Privacy Act of 1974.
O ATTACHMENT I DATE: 01-21-1987 7.
PREPARED BY: NAME John Lont A
8.
CONCURRENCE: CEG-H -f>M/% W %
DATE:
's.1 L x d 9.
APPROVAL: ECTG PROGRAM'MGR. (Y#d*tF//d 6 DATE: t/ Twf/') '
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN: Ao article will be distributed in_
TVA's publication for employees. Inside TVA. providing a detailed explanation of employees' rights to access their personnel records.
NOTE: The above article appeared in the January 6, 1987 issue of Inside TVA (Volume 8. No. 1).
This CATD was subsequently issued in accordance with ECTG l
Policy Statement No. 9 to document corrective action.
i O ATTACHMENTS DATE:
11.
PROPOSED BY: DIRECT 0R)/ GR:
////1.
n 12.
CONCURRENCE: CEG-H: C r,-- d I5 W C # w DATE:
it % f(7 l
SRP:
(
~'%DATE:
1 DATE:
DATE:
i DATE:
ECTG PROGRAM MGR:
DATE:
I VERIFICATION AND CLOSEOUT 1
l 13.
Approved corrective actions have been verified as satisfactorily implemented.
~
SIGNATURE TITLE DATE 3334T q
l l
J l
.