ML20247A892
| ML20247A892 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/19/1989 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8909120237 | |
| Download: ML20247A892 (3) | |
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c Commonwealth' Edison
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i :J Kddress Reply to: Post Othce Box 767
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72 West Adams Street Chicago, Ilknois -
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3 July 19, 1989 s
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,Mr.:A. Bert Davis Regional Administrator U.S.. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
LaSalle County Station Units 1 and 2 Allegations Concerning Ben L. Ridings NRC Docket Nos. 50-373 and 50-374
Dear Mr.' Davis:
This letter provides further information on what action has been taken or could now be taken by Commonwealth Edison' Company to ensure that the termination of.a former Contractor at the Company's LaSalle County Station, Ben L. Ridings,'did not have a " chilling effect" in discouraging other Licensee or Contractor employees from raising perceived safety.' concerns. We understand that your concern about any possible " chilling effect" is. focused on those co-workers of'Mr. Ridings who could reasonably'be expecttd to be
. familiar with the details of the event, i.e., Mr. Ridings immediate " work g ro up.
The Company had vigorously denied Mr. Riding's allegation that it violated the Energy Reorganization Act.
The U.S. Department of, Labor-1 Administrative Law Judge has recommended dismissal of Mr. Riding's Complaint.
In addition, our review has found no reason to expect any employee in Mr.
Riding's work group would have been " chilled" under the factual circumstances of Mr. Ridings' termination and, in fact, there has been no indication that any individual has been prevented or discouraged from raising perceived safety, concerns.
In our previous correspondence, we detailed the scope of steps taken by the. Company, both before and after Mr. Ridings filed his Complaint, that would have encouraged individuals to raise any safety-related concerns.
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W A'. B. Davis Ju]y 19, 1989 The Company actions included:
Prominent posting at LaSalle County Station of NRC Form 3 pursuant to 10 CFR Section 19.11.
Inclusion in Nuclear General Employee Training (NGET) required initially and annually thereafter for each employee, including those in Mr. Ridings' work group, of a detailed discussion of the right of all individuals to report safety concerns to the NRC, without fear of retaliation.
Distribution of NGET Handbooks incorporating NRC Form 3 to all workers completing NGET.
Prominent posting at LaSalle County Station of pictures, names and phone numbers of the NRC's Senior Resident Inspector, Resident Inspector, and Secretary.
A corporate directive requiring a detailed explanation concerning the requirements of the Energy Reorganization Act to be conveyed to contractor construction site managers as well as a Company review of proposed contractor employment actions that possibly could result in a claim of discrimination to ensure, among other things, that there would be no " chilling effect" upon the contractor construction workforce.
Shortly after Mr. Ridings' termination, the implementation of " Quality First" at LaSalle County Station, a widely publicized program designed to encourage the reporting of safety concerns to independent Company management, including among other things, exit interviews where employees are not only encouraged to report safety concerns, but are expressly informed of their right to directly contact the NRC to express such concerns.
We believe the cumulative effects of these actions remove any potential for a " chilling effect" on licensee or contractor employees.
If there could have been an initial " chilling effect" upon these employees, following Mr. Ridings' terraination, the implementation of Quality First undoubtedly would havo removed any such reluctance to report safety concerns.
Because of your concerns, however, Quality first will interview the individuals in the technical writing work group that continue to work at LaSalle. The Company will reiterate its commitment to employee protection to encourage the voicing of any safety concerns and remind the individuals of their rights to bring safety concerns to the attention of the Nuclear Regulatory Commission.
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- A.B. Davis July 19, 1989 l
The Company also continues to be sensitive to the possibility of a
" chilling effect" in certain instances even where there has been no actual violation of the Energy Reorganization Act.
We, therefore, will undertake a further review of our policies and procedures to determine whether any enhancements may be appropriate to further encourage employee reporting of safety concerns.
Specifically, we will review and enhance as appropriate, Nuclear Operations Directive " Contractor's Employees Rights and Protection" and the Quality First Program to better identify the conditions and Company initiatives for employees subject to potential " chilling effect".
Very truly yours, p/I T. J. Kovach Nuclear Licensing Manager 1m 0194T:1-3 i
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