ST-HL-AE-4780, Provides Status of Upgrades to Employee Concerns Program, as Part of Clarification to Author 931231 & s. All Major Actions to Change & Implement Revised Employee Concerns Program Completed
| ML20069E984 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/13/1994 |
| From: | Cottle W HOUSTON LIGHTING & POWER CO. |
| To: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20069E972 | List: |
| References | |
| ST-HL-AE-4780, NUDOCS 9406080105 | |
| Download: ML20069E984 (7) | |
Text
05/13 '94 16:50 ID:MJCLEAR LICENSIlO FAX:512-972-8298 PAGE 2
The Light company llouston Lighting & Powes, South Tczas Project Electric Generating Station P. O. Ilum 289 Wadswoith, Tesse 77481 May 13, 1994 ST-HL-AE-4780 File No.: G03.12 10CFRSO Mr. L. J. Callan Regional Administrator, Region IV U. S. Nuclear Regulatory Commioojon 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 South Texas Project Unita 1 and 2 Docket Nos. STN 50-498; STN 50-499 Status of Unor3 des to_Emplovec Concerns Procram
Reference:
Letters from W.
T.
Cottle (HL&P) to J.
L. Milhoan (NRC) dated December 31, 1993 (ST-HL-AE-4665) and to L.
J. Callan (NRC) dated February 11, 1994 (ST-HL-AE-4685)
Dear Mr. CalJan:
In the two referenced letters, I expressed the fact that one of my highest prioritico since coming to the South Texas Project has been to assure that there is an environment which encourages employees to bring forth their concerno and that employees who bring forth concerns are recognized as contributors to our overall vision and mission for the station. I also submitted a description of actions taken to upgrade the Employee Concerns Program at the South Texas Project.
As previously mentioned, these changes are designed to enuure that sub-programs with appropriate expertise investigate various types of concerns, while at the same time providing employees with a simple, easy-to-use, aingle point-of-contact to assist them in raising concerns and preserving confidentiality, m oc 94\\e4 nuu A Subddiaiy of flouston Industries Incorporated 9406080105 940601 PDR ADOCK 05000498 G
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Houston Lighting & Power Company ST-HL-AE-4780 South Teams Project Dectric Generating Station File No. : G03.12 Page 2 The current status of specific items discussed in the December 31, 1993 and February 11, 1994 letters is as follows:
Item No. 1, in the February 11, 1994 letter, Houston Lighting & Power Company stated that;
" Revisions to procedures used by the employee concerna program to more completely describe the specific methods uned to protect the identity of those who wish their concerns to be handled on a confidential basia have been completed.
The specific methods describe who has renponsibility for maintaining confidential
- files, proccan for assigning numbers to concern to protect identit y and caution statement for ensuring an individual's identity doeu not get inadvertently linked with an investigation."
During an interna) review of the Employec Concerns Program procedures on April 28, 1994, it was discovered that while the overall Employee Concerns Program procedurea covered confidentiality, the specific methods described above (i.e.,
maintaining confidential f11eo, assigning numbers, and a caution statement) were covered in detail only in the Nuclear Safety and Quality Concerno Program sub-program procadure.
However, after review of the actual confidentiality practices being used by the three aficeted sub-programn, we believe that those practices were adequate to maintain confidentiality.
The NRC was notified via phone of the above on May 2, 1994.
The procedures for the three sub-programa were revised by May 5, 1994 to specify the actual confidentiality practices being used by the three sub-programs.
Item No. 3:
Three Ettployee Concerns Oversight Group meetingn have been held to review completed concern reports from each oub-program.
This activity will continue for Class 1 (Nuclear Safety or Quality)
Concerno.
Mlk. 94 \\ *4 -ll 4. 091
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Hounon Lighting & Power Company ST-HL-AB-4780 South Texas Project Electric Generating Station File No. 2 G03.12 Page 3 Item No. 4:
In addition to the training mentioned in my previous letters:
One Nuclear Safety and Quality Concerns Program evaluator completed five days of formal training regarding interviewing techniques in February 1994.
In addition, twenty-cix hours of formal training on investigative principles was recently completed for the following evaluators /$nvestigators:
Groun Number of Evaluators / Investigators Nuclear Safety and Quality 1
Concerna Program STP Investigationti 1
Human Resource Services-Nuclear 4
Industrial Safety & Health I
ltema No. 5 and 6:
A dedicated exit room has been catablished.
An interviewer from the Nuclear Safety and Quality Concerno Program nub-program has been assigned to participate in the exit process for each person concluding a term of employment at the South Texas Project site since November 29, 1993 Documented interviews started in mid-December 1993.
From that time, throu the interviewer has participated in 578 interviews, gh April 1994 during which seventeen concerns have been received.
This compares with two concerns received during the exit interview process in the six months preceding November 29, 1993.
Item No. 7:
The Nuclear Training Department has completed modifications to the General Employee Training Program to cover the revised Employee Concerns Program.
General Employee Training covering the new program was initiated in February 1994.
Changes to the Basic Supervisory Skilla Program were completed and include material on how supervisors should addreou employee concerns as well as the workings of the Employee Concerno Program.
Thio updated material will be used in base supervisor training courses as well ao supervisory Skilln continuing Training beginnJng this summer.
Pit.C 94\\ts4-1)L uc}
+-
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Homton Lighting & PowerCompany ST-HL-AE-4780 South Texas Project Electric Generating Station File No. : G03.12 Page 4 ltem No. 8:
An internal ansessment of the Employeo Concerns Program by the Quality Assurance Department is in progress and will be completed by May 31, 1994.
Three Employee Concerns Oversight Group meetings have been held.
An Employee Recognition Award Program is currently being eatablished and one of the purposes of the program is "To recognize those employees who identify and bring forward significant or hard to detect nuclear or safety innues".
This program has been approved and is scheduled for implementation by June 1, 1994.
Random interviewD of site personnel to solicit feedback on the new Employee Concerns Program were started in February 1994.
The random interview includea questions that determine the person's knowledge of the program, whether they would use the program if they had a concern, and whether they thought an identified concern would be resolved.
The resulto of these interviews have been positive except that a minority of personnel indicated reluctance to use the Hun.an Resource Services - Nuclear sub-program. Actions have been taken to address this feedback. Houston Lighting & Power believes that the reluctance of personnel to identify concerns to this one particular cub-program has not adversely af fected the Employee Concerns Program because of the ability to report concerns by other methods such as other sub-programs, the employee advocate, and drop boxen.
The random interviews have been a useful tool for confirming our progress in improving employee confidence in the Employee Concerns Program and for identifying opportunities for improvement.
In addition, an Organizational Interface Assessment was conducted in April,
- 1994, that included questions regarding employee confidence in the Employee Concerns Program, and how employees would raine cafety concerno.
The results of this assessment have just recently been received and are being evaluated.
A preliminary review of the data suggents that significantly more employees are willing to raise concerno to their supervisor than a year ago.
The data also show a small increase in the number of people who would UDo the Employee Concerns Program.
This may be the first indication of the impact of the recent improvements in the program.
These nurvey renults also confirm Houston Lighting & Power Company's expectation that suntained effort to continue the improvement in the employee confidence in the program is warranted.
In the December 31, 1993 1ctter, Houston Lighting & Power Company i
otated that nteps had been taken to improve employee confidence in l
the Employee Concerns Program. One of the steps was to discontinue tape recordings and affirmation statements, except in certain
{
investigations performed by the STP Investigations oub-program.
Quality Assurance has recently identified that the Human Resource Services, Nuclear sub-program is a] so using an affirmation M16.D 91 \\ 44 - 11 f.. f eo
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Houston Lighting & Power Company ST-IIL-AE-47P0 South Texas Project Electric Generating Station File No. : G03.12 Page 5 i
statement.
However, iluman Resource Services-Nuclear only uses affirmation statements when performing formal investigations in accordance with Corporate Policy and only for personnel interviewed as part of the formal investigation, which does not normally include the concernee.
In addition, the affirmation statement is routinely used by the STP Investigations oub-program due to the nature of the concerns they investigate, but as in the case of the Human Resource Services-Nuclear sub-program, the STP Investigations sub-program would not normally require the concernee to sign an affirmation statement,.
Houston Lighting & Power Company believes that the use of affirmation statements by the STP Investigations and Human Resource Services-Nuclear sub-programs for the situations described above, does not adversely af fect employee confidence in the Employee Concerns Program.
Item No. 111 Three Employee concerns oversight Group meetings have been held.
Both concern re by thic group. ports and responses to concerneos are being reviewed Item NL.13:
A dedicated exit interview room has been established.
Item No. 14:
A videotape, which details the workings of the new Employee concerns Program and describes the methods for raising concerns, was mailed to Houston Lighting & Power Company South Texas Project employees in March 1994.
This videotape was also distributed to baselino contractors.
The Nuclear Safety and Ouality Concerns Program Manager has addressed approximat.ely 1700 South Texas Project employees (Houston Lighting & Power Company and contractors) in group settings to explain the Employee Concerns Program and answer qucations.
Additional presentations are planned.
A pamphlet titled " Employee Concern Program - Qucations and Answers" was distributed to South Texas Project employees (Houston Lighting & Power Company and contractors) in April 1994.
This pamphlet is also being given to new South Texas Project employees (Houston Lighting & Power and contractors) at General Employee Training.
I l
l MtY 94\\94 41's.001
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Houston Lighting & Power Company ST-HL-AE-4780 South Texas Project Electric Generating Station File No. : G03.12 Page 6 In addition to the actions described above, the following actions have been taken or are planned:
New Employee Concerns Program performance indicators have a,
been established and are being presented to the South Texas Project Group Vice-President, Nuclear, his direct reports, the Employee Concerns Program Employee Concerns oversight Group members, and selected other personnel.
b.
An external assessment of the Employee Concerns Program will be scheduled for July - Auguot 1994 All major actions to change and implement the revised Employee Concerns Program have been completed.
Future actions will concentrate on implementation of the program and assessing program effectiveness.
If you need further information please do not hesitate to call me or Mr. Robert Englmeier, Manager of the Nuclear Safety and Quality Concerns Program.
Sincerely, w f' ($:svrrr W.
T.
Cottle Group Vice President, Nuclear RFE\\csh me 94\\,4 ut o:o
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s*
Houston Lightimp & Power Company ST-HL-AE-4780 South Texas Project Electric Generating Station Pilc No.:
G03.12 Page 7 C
U.
S. Nuclear Regulatory Comm.
Rufus S.
Scott I
Attn.
Document Control Dcok Associate General Counsel Washington, D.
C.
20555 Houston Lighting & Power Company P.
O. Box 61867 Houston, TX 77208 l
Lawrence E. Kokajko Institute of Nuclear Power Project Manager Operations - Records Center U. S. Nuclear Rcgulatory Commlusion 700 Galleria Parkway Washington, DC 20555 13H15 Atlanta, GA 30339-5957 David P. Loveless Dr. Joseph M. Hendrie Sr. Resident Inspector 50 Bellport Lane 1
c/o U.S. Nuclear Regulatory Comm.
Bellport, NY 11713 P.
O. Box 910 Bay City, TX 77404-910 J.
R. Newman, Esquire D.
K. Lacker Newman, Bouknight & Edgar, P.C.,
Bureau of Radiation Control STE 1000, 1615 L Street, N.W.
Texac Department of Health 1615 L Street, N.W.
1100 West 49th Street Wauhington, DC 20036 Austin, TX 78756-3189 K. J. Fiedler/M.
T. Hardt F.
R. Huey City Public Service U.S. Nuclear Regulatory Comm.
P. O.
Box 3771 1450 Maria Lane San Antonio, TX 78296 Walnut Creek, CA 94596-5368 J. C. Lanier/M.
B.
Lee City of Austin Blectric Utility Department 721 Barton Springs Road Austin, TX 78704 G.
E. Vaughn/C. A. Johnson Central Power and Light. Company P. O. Box 2121 Corpuo Christi, TX 78403 M)hC.94\\S4 j j 'a fo)