ML20058P164

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Package Consisting of Attachment to Employee Concerns Programs
ML20058P164
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 08/25/1993
From:
NRC
To:
References
NUDOCS 9312230118
Download: ML20058P164 (42)
v • d • e


Text

ey w /Oh &

t EMPLOYEE CONCERNS PROGRAMS i

PLANT NAME: WOLF CREEK GENERATING STATION LICENSEE: WOLF CREEK NUCLEAR OPERATING CORPORATION DOCKET 050-0482 A. PROGRAM:

1. Does the licensee, have an employee concems program?

(Yes prNo/ Comments) -

YES. ITIS CATIFD THE QUALITY FIRST PROGRAM  !

2. Has NRC inspected the program? Report # NOT IN RECENT YEARS BUT A REVIEW WAS PERFORMED PRIOR TO IJ. CENSING IN 1985 B. SCOPE: (Circle all that apply)
1. Is it for:
a. Technical? (Yes, No/ Comments) YES
b. Administrative? (Yes, No/ Comments) YES
c. Personnel issues? (Yes, No/ Comments) YES THE PROGRAM ACCEPTS ALL TYPES OF CONCERNS. PERSONNELISSUES ARE REFERRED TO MANAGEMENT OR HUMAN RESOURCES. CORRECTIVE ACTION DOCUMENTS (PERFORMANCE IMPROVEMENT REQUESTS) ARE WRTITEN FOR SAFETY ISSUES.
2. Does it cover safety-as well as non-safety issues?

(Yes pf_No/ Comments)

YES

3. Is it designed for:
a. Nuclear safety? (Yes, Ncl Comments)

YES, THIS IS THE PRIMARY PURPOSE.

b. Personal safety? (Yes, No/ Comments)

YES, TIESE ARE REFERRED TO THE SUPERVISOR OF INDU'STRIAL SAFETY.

c. Personnel issues - including union grievances?

(Yes p_r_No/ Comments) 200049~

O 9312230118 930825 /

PDR ADOCK 050004B2 (k .

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YES, BUT SUCH ISSUES ARE REFERRED TO HUMAN RESOURCES OR

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MANAGEMENT. TIERE IS NO UNION REPRESENTATION.

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4. Does the program apply to all licensee employees?

(Yes art.No/ Comments) YES

5. Contractors? i (Yes pLNo/ Comments) YES

-i

6. Does the licensee require its contmetors and their subs to have a similar. ]

program?

{

(Yes a No/ Comments) NO

7. Does the licensee conduct an exit interview upon terminating employees asking if they have any safety concerns?  ;

(Yes a No/ Comments) l EXITING EMPLOYEES AND CONTRACTORS ARE PROVIDED A  !

CONCERN DISCLOSURE STATEMENT FORM. ECP PERSONNEL DO l NOT CONDUCT EXITINTERVIEWS. f i

C. INDEPENDENCE:

1. What is the title of the person in charge?

SENIOR PERFORMANCE ENHANCEMENT SPECIALIST

2. Who do they report to?

DIRECTOR, PERFORMANCE ENHANCEMENT

3. Are they independent of line management?

YES, THE DIRECTOR OF PERFORMANCE ENHANCEMENT REPORTS TO THE PRESIDENT AND CHIEF EXECUTIVE OFFICER.

4. Does the ECP use third pany consultants?

NO

5. How is a concern about a manager or vice president followed up?

WOULD SEND IT TO CORPORATE LEGAL COUNSEL.

D. RESOURCES:

i

1. What is the size of the staff devoted to this program?

ONE, USING ABOUT 15% OF HIS TIhE.

2. What are ECP staff qualifications (technical training, interviewing training, investigator training, other)?

ENGINEERING BACKGROUND, TRAINING IN ROOT CAUSE ANALYSIS l AND INVESTIGATION TECHNIQUES.

s-E. REFERRALS:

1. Who has followup on concerns (ECP stah, line management, other)?

_ _ _ - - - - - _ - - - - - - - - - - - - - - - - - - - - - - - - - ----- i

CONCERNS ARE REFERRED TO THE EXISTING CORRECTIVE ACTION PROGRAM. THE ECP COORDINATOR MONITORS THE RESOLUTION OF THE CONCERN AND PROVIDES FEEDBACK TO THE CONCERNED INDIVIDUAL.

F. CONFIDENTIALITY:

1. Are the repons confidential?

(Yes p_I No/ Comments)

QUALITY FIRST FILES ARE CONFIDENTIAL. PERFORMANCE IMPROVEMENT REQUESTS ARE NOT CONFIDENTIAL, BUT THE CONCERNEE IS NOT IDENnMuu IN THE PIR.

2. Who is the identity of the alleger made known to (senior management, ECP staff, line management, other)?

(Circle, if other explain)

TECHNICAL CONCERN - ONLY ECP STAFF PERSONNEL CONCERN - MANAGEMENT OR HUMAN RESOURCES PERSONAL SAFETY CONCERN - ONLY ECP STAFF ADMINISTRATIVE CONCERN - ONLY ECP STAFF

3. Can employees be:
a. Anonymous? (Yes, No/ Comments) YES
b. Report by phone? (Yes, No/ Comments) YES - HOTLINE WITH ANSWERING MACIHNE G. FEEDBACK:
1. Is feedback given to the alleger upon completion of the followup?

(Yes atNo - If so, how?)

YES, BY THE METHOD REQUESTED ON THE CONCERN DISCLOSURE FORM.

2. Does program reward good ideas? NO
3. Who, or at what level, makes the final decision of resolution?

MANAGER

4. Are the resolutions of anonymous concerns disseminated?

NO

5. Are resolutions of valid concerns publicized (newsletter, bulletin board, all hands meeting, other)?

NO H. EFFECTIVENTSS:

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1. How does the licensee measure the effectiveness of the pmgram7 NOT DONE  ;
2. Are concerns:
a. Tmnded? (Yes or No/ Comments) YES, INFORMAL BY ECP STAFF
b. Used? (Yes or No/ Comments) YES, ECP COORDINATOR DISCUSSES TRENDS AND RECURRING CONCERNS WITH MANAGER.

j 3. In the last three years how many concerns were raised? _35 of the concerns raised, how may were closed? 32 What pementage were substantiated? 34 %

4. How are followup techniques used to measure effectiveness (random survey, interviews, other)?

NOTHING FORMAL IS DONE IN THIS AREA.

5. How frequently are internal audits of the ECP conducted and by whom?

NONE ARE PERFORMED.

I. ADAIINISTRATION/ TRAINING:

1. Is ECP prescribed by a procedure? (Yes or No/ Comments)

YES, BY A SITEWIDE PROCEDURE AND SEVERAL IMPLEhfENTATION PROCEDURES FOR THE ECP STAFF.

2. How are employees, as well as contractors, made aware of this program (tmining, newsletter, bulletin board, other).7 GENERAL EhiPLOYEE TRAINING BULLETIN BOARDS - HOTLINE NUMBER ADDITIONAL COMNIENTS: (Including characteristics which make the program especially effective, if any.)

THE PROGRAM USES THE EXISTING CORRECTIVE ACTION PROGRAM FOR RESOLUTION OF CONCERNS. THE ECP STAFF DOES NO INVESTIGATIONS.

NAME: W. D. JOHNSON TITLE: CHIEF, PROJECT SECTION A, DIVISION OF REACTOR PROJECTS PHONE #: 817-860-8148 DATE COMPLETED: AUGUST 17,1993 REVIEWED: ATE: )

FORM KGF-2 REV.1/87 NUMBER:

W$LF CREEKNUCLEAR OPERATING CORPORATION REVISION:

oOMENP OUALITY FIRST PROGRAM PROCEDURES MANUAE'INDEX 6FC3ito "A -

k r*

aEnzAsE DATE: oc4 7e//7o Rev.

Number Title Revision Date i

QFP Forms Index 1 07/90 l QFP-2410 Receipt, Inve'stigation and Closure 1 07/90 l.

of Concerns QFI-2410.1 Conducting Exit / Walk-In Interviews 1 07/90 l QFI-2410.2 Preparation, Maintenance and 1 07/90 l  !

Security of Quality First Files 3 QFI-2410.3 Functional Concern Coordination and Deleted l Closure QFI-2410.4 Investigation of Potential Section 1 07/90 l 210 Violations  :

s h

PAGE 1 OF 1

PORM KGF-2 REY.1/87 NUMBER:

'i WOLF CREEK. NUCLEAR OPERAVNG CORPORADON REVISION:

1- l O UncWy 0 0 L 9

!QM OUALITY FIRST PROGRAM PROCEDURES MAEAL FORMS INDEE

f.  :'

RELEASE DATE: 7/3/&O NUMBER REV TITLE PROCEDURE KFF-01 Deleted Quality First Action Request N/A KFF-02 Deleted Quality First Observation N/A KFF-03 07/90 Quality First Record of Concern QFP-2410 KFF-04 Deleted Quality First Action Request Log N/A KFF-05 Deleted Quality First Observation Log N/A KFF-06 Deleted Concern Disclosure Options N/A I

i PAGE 1 OF 1

, FORM KGF-1 REV,4/89 - '

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W4) NUCLEAR OPERA PROCEDURE NO.: QFP-2410 REVISION: 1 l TITLE- ,

RECEIPT, INVESTIGATION AND CLOSURE OF CONCERNS REVISION

SUMMARY

COMI%7 Revision 0: (Released 12/23/87) C ,, O O

- supersedes QFM-01, QF1-001 and QF1-002 o i 5 A h Revision 1:

- changes to align with KGP-1211

- satisfies the relevancy review requirement

- deletes Forms KFF-01, KFF-02, KFF-04, KFF-05 and KFF-06

- revises Form KFF-03

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APPROVALS DATE APPROVALS Dr [

bhk V 7-(S-1C AUTHORIZATION- DATE:

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C' b NO RELEASED: 004 7[J/[fB PAGE 1 OF 12

FORM KGF-2 REY.1/87 .

NUMBER:

.QFP-2410 l NUCLE.AR OPERATING CORPORATION REVISION:

t TABLE OF CONTENTS 1.0 PURPOSE W

2.0 SCOPE

3.0 REFERENCES

4.0 DEFINITIONS 5.0 RESPONSIBILITY 6.0 PROCEDURE 6.1 Quality First Hotline 6.2 Termination / Walk-in Interviews 6.3 Concern Receipt '

6.4 Concern Investigation 6.5 Corrective Action 6.6 Feedback to the Concerned Individual 6.7 Concern Closure

[ 7.0 EXHIBITS l 8.0 APPENDICES l 9.0 FORMS l 10.0 RECORDS i

PAGE 2 OF 12

FORM KGF.2 REV,1/87 NUMBER:

W$LF CREEK NUCLEAR OPERATING CORPORADON REYlSION:

1.0 PURPOSE This procedure establishes the methodology utilized by Quality First to resolve safety-related concerns.

l 2.0 SCOPE This procedure is applicable to the receipt, investigation, evaluation, disposition, reportability evaluation and response to the concerned individual of safety-related concerns l l received on the Quality First Hotline or from employee /

contractor exit or walk-in interviews.

3.0 REFERENCES

3.1 KGP-1211, " Quality First Program" l l

3.2 KGP-1162, " Records" l

3.3 QFI-2410.1, " Conducting Exit / Walk-in Interviews" l 3.4 QFI-2410.2, " Preparation, Maintenance and Security of i Quality First Files" 3.5 QFI-2410.4, " Investigation of Potential Section 210 Vio-lations" 3.6 Form KGF-73, " Quality First Concern Disclosure Statement" l

4.0 DEFINITIONS None; See General Procedure KGP-1211 for definitions. l 5.0 RESPONSIBILITY 5.1 The Supervisor Corporate Policies and Procedures is responsible for this procedure and its implementation. l 6.0 PROCEDURE 6.1 QUALITY FIRST HOTLINE

.6.1.1 Hotline telephone calls shall be recorded utilizing a telephone answering device.

l 6.1.2 Hotline recorder operability and evidence of incoming calls shall be monitored frequently.

PAGE 3 OF 12

FORM KGF-2 REV.1/87 ~

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NUMBER;

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I W$LF CREEK NUC1. EAR OPERATING CORPORATION REVISION:

1 6.1.3 All incoming calls (whether answered directly or

  • recorded on the answering device) shall receive a response and any concerns shall be recorded on a Quality First Concern Disclosure Statement, Form KGF-73.

NOTE: Exception to recording concerns on Form KGF-73 shall be permitted for calls which may be referred to another WCNOC '

office (e.g. , Media Information, Service Information, Wichita office, Nuclear Information) or for calls which do not result in an expressed concern.

6.1.4 In certain cases, a concern may be concluded during the telephone conversation and a detailed investigation may ap.1 be required for reasons such as:

a. the caller agreed to use established channels of communication (e.g., nonconformance reporting system or chain of command)  ;
b. personal knowledge that the concern has been or is being investigated and documented NOTE: If it is determined that an investigation will not be necessary, the individual shall be contacted (if possible) and so informed.

f 6.1.5 Every precaution shall be taken to protect and maintain the anonymity of the caller.

6.2 TERMINATION / WALK-IN INTERVIEWS '

6.2.1 Personnel associated with WCGS activities shall be given the opportunity to list and discuss, in confidence, any concern (z) they may have regarding:

a. the safe operation, the plant maintenance or modification of ,
b. conditions that may affect the quality of P

WCGS activities

c. any violation of procedure, code, standard, regula-tion, the Technical Specification or licensing requirements 6.2.2 Interviews shall be conducted in accordance 2410.1. with QFI-1 a

PAGE 4 OF 12

FORM KGF-2 REY.1/87 NUMBER:  ;

W$LF CREEK NUCLEAR OPERATING CORPORATION REVISION:

6.2.3 All. terminating / walk-in personnel shall be afforded an I opportunity to complete a Quality First Concern Disclosure Statement, Form KGF-73.

6.2.4 Should an exiting employee or contractor refuse to sign '

the Form KGF-73, Quality First shall t

a. note on the form their refusal to sign and I
b. inform the individual of the notification options listed on the back of Form KGF-73 6.3 CONCERN RECEIPT 6.3.1 A Quality First Record of Concern, Form KFF-03, shall be prepared in accordance with Appendix 1 for each individual
  • expressing safety-related concern (s). l 6.3.2 A Quality First concern case file shall be prepared in accordance with QFI-2410.2.

6.3.3 When applicable, Quality First shall inform concerned individuals that concerns other than those with safety-related implications will be forwarded to another organization for investigation and no Quality First file will be opened. i 6.4 CONCERN INVESTIGATION 6.4.1 Each identified concern shall be evaluated for its safety significance and the scope and methods to be used to l investigate the concern shall be determined and documented on an Investigation Work Plan.

6.4.2 Additionally, each safety-related concern shall be assigned a code for trending purposes based upon the Quality First Concern Code Matrix contained in Exhibit A.

6.4.3 A meaningful investigation shall be conducted and all available facts necessary to arrive at a logical conclusion shall be gathered.

6.4.4 Investigations shall be conducted by means of personnel interviews, document reviews, hardware / installation'inspec-tions or any combination of the above.

6.4.5 Non safety-related concerns shall be forwarded to the responsible organization for investigation in accordance with other applicable company policies or procedures.

PAGE 5 OF 12 M

FORM KGF-2 REY.1/87 '

NUMBER:

W$1.F CREEK NUCLEAR OPERATING CORPORATION REVISION:

1 6.4.6 Safety-related concerns (see Exhibit B for examples) shall be investigated and dispositioned in accordance with this procedure and accompanying instructions.

6.4.7 An Investigation Report shall be prepared in accordance with the format described in Exhibit C for each concern or group of related concerns being investigated.

6.5 CORRECTIVE ACTION 6.5.1 Deficiencies in documentation, procedures or programs which are within the safety-related concern interest area of investigation shall be documented and processed accordance with KGP-1210.

6.5.2 Hardware deficiencies shall be documented using the l appropriate nonconformance document as required by KGP-1211.

6.5.3 Observations of perceived quality deficiencies in hardware, documentation, procedures or programs which are outside of a safety-related concern interest area under investigation shall be discussed with the responsible division l manager and recommendations for correction may be included in l the investigation report.

! 6.5.4 Recommended corrective action for substantiated wrong-doing shall be handled in a confidential manner with the recommended corrective action included in the Investigation Report.

6.6 FEEDBACK TO THE CONCERNED INDIVIDUAL 6.6.1 In accordance with the method agreed upon between H Quality First and the concerned individual (as documented on

Form KFF-03), notification shall be prepared, to include the i following information, as a minimum:

l a. description of the concern l

b. investigation conclusion and disposition of the concern (substantiated or unsubstantiated)
c. corrective action taken, if required 6.6.2 Whether written or verbal notification is the agreed  ;

upon format, Quality First shall mention gratitude for the i j concerned individual's interest in the quality of the Wolf Creek Generating Station and shall provide Quality First

( PAGE 6 OF 12 i

FORM KGF-2 ' REV,1/87 -

NUMBER:

QFP-2410 NUCLEAR OPERATING CORPORATION REYlSION:

contact information (contact name, company mailing address and phone . number) should the concerned individual have .any questions regarding the disposition of the concern.

6.7 CONCERN CLOSURE 6.7.1 A concern is considered CLOSED when investigative activities are completed, corrective action verified and reportability evaluated when necessary, QA records transmitted to Records Management and the concerned individual notified of the investigation results.

  • 6.7.2 A final report to the President /CEO shall summarize the disposition when all concerns in a Quality First case file are closed.

6.7.3 For each concern, verification that the file contains the necessary documentation shall be completed prior to closing the file in accordance with QFI-2410.2.

7.0 EXHIBITS 7.1 Exhibit A, " Quality First Concern Code Matrix" 7.2 Exhibit B, " Examples of Wrongdoing" 7.3 Exhibit C, " Format for Quality First Investigation Reports" ,

8.0 APPENDICES 8.1 ' Appendix 1, " Instructions for Completing the Quality First Record of Concern" 9.0 FORMS 9.1 Form KFF-03, " Quality First Record of Concern" l 10.0 RECOR_D_S.

10.1 All case file documents generated in accordance with this procedure (with the exception of the investigation report and corrective action documents) shall be permanently

-maintained by Quality First in a confidential manner.  ;

10.2 Form KFF-03, is a non OA record maintained in accordance with paragraph 10.1.

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PAGE 7 OF- 12

FORM KGF-2 REY.1/87 -

NUMBER: i

_QFP-2410 ,

NUCLEAR OPERATING CORPORATION REYlSION:

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l l ,C_QQ ODE CONCERN CATEGORY Q01 PERSONNEL QUALIFICATIONS Q02 PROCEDURE VIOLATION OR INADEQUACY ,

003 MATERIAL TRACEABILITY I 004 INSTALLATION DEFECT i 005 RECORDS FALSIFICATION I Q06 TRAINING RECORDS OR INADEQUACY  ;

Q07 MATERIAL CONTROL I Q08 DOCUMENT CONTROL / RECORDS MANAGEMENT I Q09 INADEQUATE REPORTING Q10 INADEQUATE INSPECTION i Q11 ENGINEERING / DESIGN DEFICIENCY  !

l Q12 WRONGDOING Q13 HOJSEKEEPING/ CLEANLINESS CONTROL i EXHIBIT A Page 1 of 1 QUALITY FIRST CONCERN CODE MATRIX PAGE 8 OF 12 1

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.- FORM KGF-2 REV 1/87

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NUMBER:

W$LF CREEK NUCUMR OPERATING CORPORATION REYlSION:

The following list represents the types of issues the NRC Office of Investigations (OI) considers to be wrongdoing.

This list is for illustrative purposes only and may not include all examples of wrongdoing.

1. Prior knowledge of NRC requirements by responsible ,

personnel and a deliberate or conscious decision not to act accordingly I

2. Failure to take. corrective action when on notice of noncompliance from an authorized source
3. A record of some past similar experience indicating '

knowledge that an act was wrongdoing, yet proceeded regardless

4. Testimonial or documentary evidence which eliminates the possibility that a violation of NRC requirements resulted from an accident, carelessness, ignorance, confusion, etc.
5. Deliberate attempts at deception, such ass
a. watering down facts given to the NRC
b. failure to document reports of noncompliance
c. efforts aimed at containing, diverting or stopping l information from reaching the NRC
d. manipulation of documentation to confuse or hinder NRC investigation / inspection efforts
6. Testimony or documentation which directly demonstrates  :

that management knew an act was wrong and contrary to NRC requirements, yet proceeded regardless ,

e

7. Evidence of any act committed in the name of expediency, with a later claim to the NRC that commission of the act was the result of confusion
8. Any effort to segregate, isolate, transfer, fire, intimidate or otherwise retaliate or discriminate against an individual surfacing or attempting to surface information of interest to the NRC, providing information of interest to the NRC or providing safety-related information to employers EXHIBIT B Page 1 of 2 EXAMPLES OF WRONGDOING l ,

PAGE 9 OF 12

evnes kur-inev ire ~~ ~

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I W4l>LF CREEK NUCLEAR OPERATING CORPORATION REYlSION:

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9. Falsification of documents
10. Violation of federal, state or local criminal statutes NOTES: a. These examples are contained in the OI Investiga-tion Manual
b. All of these examples are within Quality First concern code category Q12. i g c. Example number eight (8) represents OI's interpre- i tation of regulation 10CFR50.7 which implements '

section 210 (Employee Protection) of the Energy Reorganization Act of 1974. Discrimination or i retaliation within this context has been defined ,

broadly enough to include adverse actions such as -

demotion, relocation, transfer, coercion, black-  !

listing or loss of phone privileges. QFI-2410.4 provides additional instructions for the investi-gation of allegations in this category.

f EXHIBIT B .

Page 2 of 2  !

EXAMPLES OF WRONGDOING PAGE 10 OF 12 i

runas mar-e new, or, NUMBER:

W$LF CREEK NUCLEAR OPERATING CORPORATION WSION:

)

FILE AND CONCERN NUMBER: (e.g., QCI 87-260T, Concern #3)

DISCIPLINE / WORK GROUP: (e.g., Elect. Maint., Doc. Ctl., etc.)

RESPONSIBLE ORGANIZATION: (e.g., Operations, Mgat. Systems, ,

Quality Control, etc.)

INVESTIGATION PERFORMED BY: (Individual or organization name)

WORK ACTIVITY / PROCESS: (e.g., procedure review, material control, quality. inspection, etc.) i a

CONCERN STATEMENT: (Verbatim from originator's written state- {

ment)

PERSONNEL CONTACTED / INTERVIEWED: (List all information sources and interviewees) i

SUMMARY

OF INVESTIGATION: (Brief synopeias of investigation methodology employed) '

INVESTIGATION DETAILS: (Document facts gathered, evaluations ,

performed, etc.)

CONCLUSION / JUSTIFICATION: (Whether or not the concern is substantiated; with factual basis)

CORRECTIVE ACTION RECOMMENDATION: (Steps to correct condition  ;

and preclude recurrence or reference to corrective action document (s) when quality deficiencies exist or are perceived to exist but not directly related to the concern investigation interest area).

Distribution: Determined by the Investigator according to the nature of the concern and its disposition; +

minimum distribution shall be to the President / j CEO and the division manager responsible for the interest area under investigation.

EXHIBIT C I Page 1 of 1  ;

FORMAT FOR QUALITY FIRST INVESTIGATION REPORTS I l

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FORM KGF-2 MkV.1/87 NUMBER: *

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W4) NUCLEAR OPERATING CO REYlSION.

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SECTION I This section shall contain the concerned individual's name, . ,

address and telephone number in case additional contact should I be necessary for concern clarification or other information  !

and to facilitate investigation results feedback.

SECTION II This section shall be completed for the purpose of determining. I whether the concerned individual attempted to resolve the concern through the supervisory chain of command and, if so,  !

whether supervision took appropriate action to resolve the concern in accordance with policy.

SECTION III This section shall document the agreed upon method of contacting the concerned individual with the results of concern (s) investigation. ,

SECTION IV This section shall classify the safety significance of the Concern.

SECTION V .

r This section shall document which organization has responsi-bility for investigation of the concern (s).

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r APPENDIX 1 Page 1 of 1 i INSTRUCTIONS FOR COMPLETING THE QUALITY FIRST RECOhD OF CONCERN FORM KFF-03 PAGE 12 OF 12

. FORM KGF-1 REY. Wee -

t W4l>LF CREEK NUCLEAR OPERATING CORPORATION PROCEDURE NO.: QFI-2410.1 REVISION: 1 1 TITLE:

CONDUCTING EXIT / WALK-IN INTERVIEWS REVISION

SUMMARY

lAE47 Revision 0 (Released 12/23/87) b$ l -

- supersedes QF1-003 0 o D r-Revision 1:

- revised position title from Administrator Quality First to Supervisor Corporate Policies and Procedures l

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i APPROVALS DATE APPROVALS DATE  !

___ A/OAwdea L/

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AUTHORIZA ON: . DATE:

RELEASED: OC4 7/J/[f8 PAGE 1 OF 3 h

POP 9J KGF-2 REV.1/87 -

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NUMBER:

QFI-2410.1 ,

l NUCLEAR OPERATING CORPORATION REVISION:

1 1.0 PURPOSE '

This instruction governs the conduct of interviews with l individuals expressing the desire to document a safety-related

oncern to ensure that sufficient information is gathered for ,

the conduct of a meaningful investigation.  !

2.0 SCOPE This instruction shall be followed when interviewing concerned -

employees and contractors during exit' interviews (upon termi-nation of employment or contract) or during interviews on a walk-in basis (voluntary disclosure).

3.0 REFERENCES

3.1 QFP-2410, " Receipt, Investigation and Closure of Concerns" ,

3.2 QFI-2410.2, " Preparation, Maintenance and Security of Quality First Files" 3.3 Form KGF-73, " Quality First Concern Disclosure Statement" 4.0 DEFINITIONS None.

5.0 RESPONSIBILITY l The Supervisor Corporate Policies and Procedures is responsible for this instruction and its implementation. ,

6.0 INSTRUCTION 6.1 Interviews shall be conducted with no disturbances or '

interruptions and with no time limitations imposed by the interviewer.

i 6.2 Interviews shall be conducted in such a manner that- an

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individual presenting a concern may feel at tase and afforded every opportunity to provide sufficient, detailed information.

6.3 During initial contact the interviewer shall maintain eye-contact with the concarned individual. An honest, confident "'

and positive attitude shall be presented in order to gain the individual's trust.

-6.4 The interviewer shall- listen attentively to- the individual's presentation of the concern in order to obtain~an PAGE 2 OF 3

FOHas Kue-2 Maiv. us7 '

NUMBER:

QFI-2410.1 NUCLEAR OPERATING CORPORATION REVISION:

understanding of the concern. The-interviewer shall not take notes or ask questions during this phase of the interview process.-

6.5 After the concerned individual has completed his presan-tation of the concern the interviewer shall ask the individuel to readdress the concern and may now take notes in full view.

6.6 A dialogue of discussion and questioning may now take place under- the control of the interviewer to obtain information pertinent to the concern (i.e., location, activity, governing procedure (s), names of individuals who may corroborate the concern or provide additional specifics to-support the fact gathering mission of the investigation, etc.).

6.7 The interviewer shall be constantly aware of the necessity to conduct the interview with objectivity, refrain from exhibiting an intimidating or coercive manner. and avoid making subjective- remarks which could mislead the individual into believing that the concern has merit before an attempt has been made to gather other credible and contrary facts..

6.8 The interview shall be conducted with the obvious purpoce-of obtaining m ifice and not general statements. Specifics are essential to the performance of a meaningful investiga-tion. ,

6.9 The remainder of the interview shall concentrate on documenting the concern on the Quality First Disclosure ,

Statement, Form KGF-73 and administering completion of the other paperwork required to initiate a case file, as '

delineated in QFP-2410 and QFI-2410.2.

6.10 At the close of the interview the interviewer shall.

thank the individual for disclosing the concern.

7.0 FORMS None.

8.0 RECORDS 8.1 There are no QA records generated as a result of this instruction.  ;

8.2~ Any interview notes taken shall become part of the concern case file and be permanently maintained by Quality l

First in a confidential manner.

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L-W$LF CREEK NUCLEAR OPERATING CORPORATION PROCEDURE NO.: QFI-2410.2 REVISION: 1 l ,

( TITLE:

l PREPARATION, MAINTENANCE AND SECURITY OF QUALITY FIRST FILES REVISIOff

SUMMARY

GUMENy Revision 0:

0 o l (Released 12/23/87) Q gO

- supersedes QF1-004 2

{ Revision 1:

- minor changes to align with KGP-1211 l

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f APPROVALS DATE APPROVALS DATE h MOAkM v 716 go '

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AUTHORIZA ON: . DATE:

RELEASED: OC4 7[J/[90 PAGE 1 OF 5

___ _______---_--__.-__--_-______-__.___--__--_-_--._-___.__-._.-.--------___-------------------------_--------_--------__.---U

NUMBER:

QFI-2410.2 ,

NUCLEAR OPERATING CORPORATION REYlSION:

l 1 s

1.0 PURPOSE This instruction' ensures completeness of documentation

} associated with each safety-related concern receipt, evalu-ation, investigation, disposition, corrective action and feedback to the concern initiator. It also establishes administrative controls vital to maintaining the confiden--

tiality of the source of the concern and all investigatory details.

, 2.0 SCOPE i The -instruction is applicable to all concern case files initiated as a result of safety-related concerns received by l Quality First and processed in accordance with QFP-2410.. i

3.0 REFERENCES

1 3.1 QFP-2410, " Receipt, Investigation and Closure of Con-  !

cerns"  !

4.0 DEFINITIONS None.  !

5.0 RESPONSIBILITY l The Supervisor Corporate Policies and Procedures is respon-sible for this instruction and the results of its implementation.

6.0 INSTRUCTION 6.1 CASE FILE PREPARATION AND MAINTENANCE 6.1.1 A concern case file shall be prepared for each individual voicing concern (s).

6.1.2 Each case file shall be assigned a tracking number, follows: as QCI-YY-###

a. where QCI is the acronym prefix for Quality Concern Investigation'
b. where YY is the year the file was initiated c, where ### is the sequential number of the case file being' opened,
d. for example: QCI 87-261, where 261 is the two hundred sixty-first case file to be opened and this number is sequentially assigned irrespective of the year, 1987, in which the file was opened.

PAGE 2 OF 5

.u_-

FORM KGF-2 REV.1/87 NUMBER:

QFI-2410.2 NUCt. EAR OPERATING CORPORATION REVISION:

i

\

6.1.3 Each case file will normally represent the concern or '

multiple concerns of one individual. Separate case files shall not be opened for each concern fram the same individual ,

unless time elapses after the interview process is closed and the individual presents another concern under different circumstances.

6.1.4 Each case file folder shall be numbered in accordance with paragraph 6.1.2 and stamped " CONFIDENTIAL".

6.1.5 Quality First case files shall be maintained current for each concern identified within. Each file folder should ,

contain a Quality First File Checklist,. Exhibit 1, which I identifies key documentation contained within the file. The check list should be initialed and dated as the documents are completed and filed.

6.1.6 Prior to closure of a concern case file, the file -

should be inventoried and verified against the checklist. '

Closed files shall be marked " CLOSED" in red ink on the front of the folder.

6.2 CASE FILE SECURITY 6.2.1 Continuous and systemacic controls over both open and closed Quality First case fil s shall be ensured.

6.2.2 Case file folders shall be stored in locked, fire. proof file cabinets secured within a locxed file room in the Quality First office area.

6.2.3 Case file folders shall never be left unattended and shall be returned to the file cabinet when not needed or at the er.d of the work day.

6.2.4 Only those individuals determined as having a bona fide '

"need,to know" may be permitted to review certain file documentation as fits the circumstance of their request. ,

6.2.5 Copies of file material shall not be permitted, except-as considered necessary to comply with orders or subpoenas 1ssued by a court of law, hearing board or other law l

enforcement or regulatory agency.

7.0 ' FORMS .

None.

PAGE 3 OF 5 t i

FORM KGF-2 ' REY.1/87 .

NUMBER:

QFI-2410.2 REVISION: '

WUCII.AR OPERATING CORPORATION i- 1 8.0 EINIBITS 8 . .\ Exhibit 1, " Quality First File Checklist" <

S.O RECORDS There are no QA records generated as a result of this instruc-tion. '

I

~i t

1 PAGE 4 OF 5 t

runaw ,sur-e nc,. s, s

/ NUMBER:

QFI-2410.2 NUCLEAR OPERATING CORPORATION REVISION:

FILE NO.

FILE INVENTORY CHECKED AND CLOSED:

Signature Date INITIAL DATE

1. FINAL REPORT TRANSMITTAL LETTER /
2. CONCERN RESULTS FEEDBACK TO INDIVIDUAL- /
3. 'lNVP.STIGATION REPORT (1 EACH CONCERN) / l
4.
  • ACES, DOCUMENTS, CORRESPONDENCE, ETC. /
5. PEN'.AMMATIC DEFICIENCY REPORT /
6. NONCONFORMANCE DOCUMENT /
7. INVESTIGATION WORK PLAN /

l8. QUALITY FIRST RECORD OF CONCERN '

/

9. QUALITY FIRST CONCDtN DISCLOSURE STATEMENT /

IF A PARTICULAR DOCUMENT / ITEM IS NOT APPLICABLE, ENTER "N/A" IN FRONT OF THE INITIALS AND DATE P

EXHIBIT I (Page 1 of 1)

" QUALITY FIRST FILE CHECKLIST" j

PAGE 5 OF 5 i

i

FORM KGF-1 REV. 489 W$LF CREEK NUCGAR OPERATING CORPORATION PROCEDURE NO.: QFI-2410.4 REVISION: 1 '

l TTTLE:

INVESTIGATION OF POTENTIAL SECTION 210 VIOLATIONS hEVISION

SUMMARY

g%ENy Revision 12 0

'8 minor position title changes 8

$6 .-

i APPROVALS DATE APPROVALS DATE 1 hk '

7 18.*10 l

l i

AUTHOR 2A N: . DATE:

0 RELEASED: 004 7/N!NO PAGE 1 OF 5

FORM KGF-2 REV.1/87 -

NUMBER:

QFI-2410.4 ,

NUCLEAR OPERATING CORPORADON REVISION:

1.0 PURPOSE This instruction is> 1 signed to provide Quality First investi- '

gative individuals >ith an understanding of " Employee Protection" as ad in Section 210 of the Energy Reorganization Act c,2 1974 and the Code of Federal Regulation,  ;

Title 10, Section 50.7.

2.0 2.@f.R \

2.1 The information contained in this instruction is appli-cable to the investigation of concerns of potential wrongdoing which may have occurred against employees engaged in a

" protected activity."

2.2 This instruction is not applicable to discrimination' or  :

harassment actions which may be out of line with the WCNOC '

Equal Employment Opportunity Policy.

3.0 REFERENCES

3.1 42 U.S.C. 5851, " Energy Reorganization Act of 1974, Section 210" 3.2 10CFR50.7, " Employee Protection" 3.3 QFP-2410, " Receipt, Investigation and Closure of Con- i cerns" .

4.0 DEFINITIONS None.

5.0 RESPONSIBILITY l 5.1 Supervisor Corporate Policies and Procedures 5.1.1 Immediately notifies the President /CEO and the I responsible department head upon receipt of concerns which allege of occurrence of potential wrongdoing encompassing any act retaliation against an employee engaged in a protected activity.

5.1.2 Immediately notifies the President /CEO and the  ;

} responsible department head whenever a suspicion of such.

retaliatory forms of wrongdoing is surfaced during investi- .

(!

gation of concerns which were categorized as another subject matter.

l 3

PAGE 2 OF 5

'i

.. . NUGABER:

QFI-2410.4 NUCt. EAR OPERATING CORPORATION REVISION:

5.1.3 Forwards discrimination and harassment allegations not implying occurrence due to a protected activity to the Manager i Human Resources for investigation and disposition. I 5.1.4 Receives the assistance of Legal Counsel as determined by the President /CEO.

5.1.5 Provides the President /CEO and the responsible depart-l ment head with the details and outcome of investigation with which he may make the decision as to what NRC notification may be required.

6.0 GENERAL 6.1 The Energy Reorganization Act of 1974 was amended in 1978 to include Section 210, Employee Protection, to specifically protect the employment rights of individuals engaged in protected activities. 10CFR50.7 was implemented in 1982 to delineate enforcement actions which may be taken by the NRC against a Commission licensee, permittee, applicant for . a license or permit, or a contractor or subcontractor of a Commission licensee, permittee or applicant found to have discriminated against an employee for engaging in certain protected activities established in Section 210 of the Energy Reorganization Act.

6.2 10CFR50.7 emphasizes that the protected activities of Section 210 include but are not limited to: providing the NRC information about possible violations of requirements imposed under either the Atomic Energy Act of 1952, as amended or the Energy Reorganization Act of 1974, as amended; requesting the NRC to institute action against an employer in order to administer or enforce these requirements; or testifying in any NRC proceeding.

6.3 Persons engaged in protected activities are not automati-cally guaranteed job protection or immunity from disciplinary action or discharge for legitimate reasons. Investigation of

-this form of wrongdoing must. include testing for any recogni-zable attempts by the employee to use Section 210 as a

" shield" to guarantee job security or enhancement of position or as a personal vendetta to settle a grudge.

6.4 The definition of discrimination has become broad enough within this context to include all forms of retaliatory and adverse actions against an employee with respect to his compensation, terms, conditions or privileges of employraent.

i Such discriminatory action includes but is not limited to the .i following:

PAGE 3 OF 5 l

l

_ _ _ _ _ _ _ _ _ _ - - - _ - - - - - - - - - - - - - - - - - - - - ]

P U H M M R -2 M etf. 1/W/~

'--=-- -

QFI-2410.4 1

- Isolation - Harassment

- Segregation - Coercion

- Transfer / Relocation - Demotion '

- Improper discharge - Blacklisting

- Intimidation - Denial of privileges (e.g., loss of tele-phone use) 6.5 It is absolutely imperative that investigations of concerns of this sensitivity be conducted with the utmost priority, objectivity and confidentiality and in close cooperation / consultation with Legal Counsel.

6.6 It is also essential that the individual alleging the act of discrimination not be misled into assuming that Quality First is acting as an advocate in his/her behalf or that an  ;

investigation by Quality First is, in any way, construed to take the place of or circumvent the individual's right to file-a complaint with the U.S. Department of Labor as explained in Form NRC-3, Notice to Employees, posted on the premises in various bulletin board locations.

7.0 INSTRUCTION 7.1 Concerns of this nature shall be received and investigated in accordance with QFP-2410, except that the following additional precautions and evaluations shall apply to this type of concern:

7.1.1 The concern shall be evaluated to determine if it contains sufficient substance to support the probability .that wrongdoing has occurred.

7.1.2 The concern shall be investigated with a focus on determining whether the concerned individual was engaged in a protected act.

7.1.3 The investigation shall also focus on whether the claim of discrimination may be warranted by evaluating for the following possibilities:

a. Is the employee a malcontent?
b. Is the employee competent or insincere?
c. Is the claim (s) frivolous?
d. Is the complaint made in the interest of public' ,

safety rather than in the interest of saving a job?

c. Is the complaint made for protection from impending -

employer action for legitimate reasons?

i t

PAGE 4 OF 5

NUMBER:

QFI-2410.4 NUCt. EAR OPERATING CORPORATION REYlSION:

7.2 Important to the determination of the validity of this l type of concern is the review of objective evidence of l performance, as found in personnel records:

{

a. length of service
b. absenteeism, reprimands, atta-boys, personal problems, punctuality
c. performance evaluations, with focus on consistency or abrupt changes
d. qualifications for position (s) held
e. reason (s) for termination and any documented exit interview
f. employee acknowledgement of the validity of any documented disciplinary action (s) 7.3 The investigator should also be alert for personality conflicts between the employee and the supervisor or coworkers,
a. personal vendettas
b. grudges )

)

c. flurry of disciplinary action documentation generated just prior to termination date with no previous performance problems documented 8.0 FORMS None.

9.0 RECORDS There are no QA records generated as a result of this instruction.

PAGE 5 OF 5 l

. ~. . . . . . .

M EFF-03, EEF. 7/90

+I. W Individuals N FWIST RECORD OFCONCERN 4

8' FIIe:

o GUMENy O

o 4

4

'O j

1 I

t Address '

i

\

Tale,1homas a,

II. A. T===rHate sigervisor notifiad? ] Yes Bo i h notified: -_

t

.l If not, dy? -l Sugervisor e s amass  :

B. East level of supervinirm notified (if you received no roeptzise -

or an i W ate response)? Yes En  ;

i If not, dy? .I i

C. h Deld y]ou Yes reonive Nofah on your even-rn from superviair=?  !

Mant level T===diate supervisor East level supervisor {

Othme l D. If the response to your av=n=rn was i= a--@te or none, which of the falle=-iner do you feel represents the reason for 'the lack of -  !

response?

Forgetf=1n===

Mininter]Estetigm of yotar twen=ra ,

ui - 1,satirm i Supervisione s sock load heavy, has not been able to address l t)3 rinnnern ~?

Dontt care attitude touard av=rwrn

  • Other, Esplain d I

~r III. M M N MIVIEXEls IV. N N: i WF3[ MMRrtrMet: 'I i

Phtmo '

Imtter V. IEVESTIGRTIM BY Bone required  !

Quality First  :,

cuality First and others j other =i y

e N

, n --- a,m.. .- ,..:=,..

~

FORM KGF 1 REY.11/90 W$LF CREEK NUCLEAR OPERATING CORPORATION n GSNP PROCEDURE NO.: KGP-1211 REVISION: 2 ,e ggQ -

TITLE: i O QUALITY FIRST PROGRAM ,,f RELEASED: DC4 $4' /92.e, REVISION

SUMMARY

- incorporates minor but relevant changes as marked

- Form KGF-73 was not revised i

l i

)

/ ,. APPROVALS DATE APPROVALS DATE

,,tb5NW 9.nn& led b & 9/khz Mkw wan t- l

/LM _ "hs/vt f OY4 '--'

AUTHORIZATION: DATE:

QUAUTY: _ YES _ANO 8-d7 - 7 b CVM: _ YES _.gNO PAGE 1 OF 6 1

l ~. _ _ _ _ _ _ _ _ - _ _ - - - _ - _ _ _ _ _ - _ _ _ _ _ _ _ - - _ _ _ _ _. _ .'

FORM KGF-2 REV.11/90  ;

NUMBER: i KGP-1211 F CREEK NUCLEAR OPERATING CORPORATION REVISION:

2 1.0 PURPOSE This procedure establishes responsibilities and requirements for effective implementation of the Quality First Program in support of Administrative Policy III.4.

2.0 SCOPE 2.1 This procedure provides an avenue for employees and contractors to disclose any safety-related concerns they may have. The Quality First Program provides independent and objective evaluation, investigation, disposition and resolution of safety-related concerns.

2.2 This procedure is .not applicable to the disclosure and resolution of employee complaints, grievances, industrial safety or well-being issues, personnel matters and other nonsafety-related problems that are to be resolved by supervision, management, Human Resources, Health Services or Safety Services.

2.3 The Quality First Program is not an NRC-regulated _ activity and changes to this procedure are exempt from licensing basis screening requirements. _

3.0 REFERENCES

3.1 10 CFR 50.7, " Employee Protection" 3.2 Administrative Policy III.4, " Employee Concerns" 3.3 KGP-1210, " Performance Improvement Request" l 3.4 ADM 01-057, " Work Request" 3.5 HR-151, " Termination / Separation of WCNOC Employees and Contractor / Consultant Personnel" 3.6 KP-2145, " Control of Nonconforming Material, Parts and Components" 4.0 DEFINITIONS 4.1 SAFETY-RELATED CONCERN - a concern which, if substantiated, indicates a defect or deficiency that could adversely affect the functions of safety-related structures, systems or components.

This ter= is also referred to as a Quality First concern.-

PAGE 2 OF 6 m_______ _ _ _ _ _ _ _ _ _ _ _ _ _ _

FORM KGF-2 REV.11/90 NUMBERt KGP-1211 F CREEK NUCLEAR OPERATING CORPORATION 2 5.0 RESPONSIBILITIES 5.1 EMPLOYEES and CONTRACTORS:

a. openly discuss questions or safety-related concerns with and immediately report quality program and hardware deficiencies to their supervisor
b. present concern (s) in a specific and factual manner and provide documentary evidence to the fullest extent possible
c. alternatively, present safety-related concern (s) to .

Quality First or the Nuclear Regulatory Commission (NRC) 5.2 MANAGERS AND SUPERVISORS:

a. maintain the open door policy, encourage employees to address their concerns through the supervisory /

management chain of ccamand and sincerely attempt to t resolve issues with employees in an objective, timely "

and professional manner ensure individuals have the freedom to disclose and b.

discuss their safety-related concern (s) with Quality First or the NRC

c. prevent, in accordance with 10 CFR 50.7, discriminatory or retaliatory action against any employee or con- l tractor known to have expressed a concern to Quality First or provided information of interest to the NRC
d. ensure terminating contractors or temporary personnel who were issued a WCNOC ID or WCGS ACAD badge are provided a Quality First Disclosure Statement, Form KGF-73, prior to their exit  ;

5.3 The MANAGER HUMAN RESOURCES:

a. ensures terminating employees have an opportunity to disclose any safety-related concerns-
b. sends Forms KGF-73 completed by terminating employees to the Supervisor Corporate Policies
c. ensures the Quality First Program Hotline telephone number is posted in work areas  :

PAGE 3 OF 6

FORM KGF.2 REY.11/90 **

NUMBER:

KGP-1211 F CREEK NUCLEAR OPERATING CORPORATION 2 5.4 The MANAGER TRAINING provides an explanation of the Quality First Program to employees and contractors as part of General Employee Training (GET) initial and requalification courses 5.5 The SUPERVISOR CORPORATE POLICIES: l.

a. administers the Quality First Program
b. coordinates safety-related concern investigation, corrective action and closure activities with the responsible manager
c. obtains technical, legal or additional investigative assistance when appropriate
d. is available to any employee or contractor wishing to state a safety-related concern 5.6 The PRESIDENT AND CHIEF EXECUTIVE OFFICER:
a. ensures that the Quality First Program functions to resolve employee safety-related concerns
b. monitors Quality First Program effectiveness through the review of investigation reports 6.0 GENERAL REOUIREMENTS 6.1 The following practices are sustained to ensure the continued integrity of the Quality First Programs
a. the availability of a Quality First representative to candidly discuss individuals' safety-related concerns
b. preservation by Quality First, Human Resources, managers and supervisors of the anonymity of individuals expressing concerns, consistent with company, regulatory or legal obligations
c. when requested, Quality First discussion with or notification to the concerned individual of the results ,

of investigations and any corrective action taken for identified deficiencies 6.2 Quality First- concerns may be disclosed via. telephone (Quality First Hotline), walk-in interview or exit interview at termination of. employment or contract.

PAGE 4 OF 6 i

FORM KGF.2 REV.11/90 NUMBER:

KGP-1211 F CREEK NUCLEAR OPERATING CORPORATION REVISION:

2 6.2.1 Ouality First Hotline This Hotline (site extension 4949) is a telephone answering device that is available to employees and contractors 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a -

day. The caller should leave a message that, as a minimum, identifies the concern, including specific information that will ,

aid in investigation of the concern. Although not mandatory, the caller may wish to leave a name and how the individual may be contacted later for. additional information. ,

6.2.2 Walk-In Interview The Quality First Program representative is normally available t between the hours of 0730 to 1600 to discuss employee or contractor safety-related concerns on a walk-in basis or as pre-arranged.  !

I 6.2.3 Emolovee Exit Interview i 6.2.3.1 Human Resources ensures that all terminating employees have an opportunity to disclose safety-related concerns prior to .

their exit by completing Form KGF-73, " Quality First Concern .

Disclosure Statement" or by requesting to speak with the Quality First Program representative.

6.2.3.2 Should an exiting employee refuse to sign Form KGF-73, the Human Resources interviewers

a. notes on Form KGF-73 the individual's refusal to sign and r r
b. asks the individual if an interview with the Quality First Program representative should be arranged ,
c. notifies the individual of concern disclosure options listed on the back of Form KGF-73 6.2.3.3 The Human Resources interviewer forwards all completed Forms KGF-73 to the Quality First representative.

6.2.4 Contractor Exit 6.2.4.1 Supervisors ensure that terminating contractor, consultant and temporary personnel are provided Form KGF-73 as 4 part of the check-out process required by HR-151.

6.2.4.2 The contractor or temporary employee may complete Form KGF-73 and drop the folded and sealed disclosure form in any company mail drop or the U.S. Mail. i l

PAGE 5 OF 6 l

-I J

FORM KGF-2 REY.11/90 NUMBER:

KGP-1211 F CREEK

~

RE _  :

NUCLEAR OPERATING CORPORATION 2  !

6.3 Quality. First conducts investigations of expressed safety-related concerns with consideration given to all available facts, including the existence of credible, contrary facts.

Quality First discusses concerns with the- responsible manager '

for concurrence with the investigation action plan. Identified deficiencies- and the investigative report are drafted and '

discussed with the responsible manager prior to issue.

6.4 Quality First forwards to the responsible manager those concerns which, upon sufficient investigation and evaluation, are determined to not contain safety-related implications. Such concerns are resolved in accordance with other company _ policies and procedures and not within the Quality First program.

Feedback is provided to Quality First for concern closure and, when requested, feedback to the concerned individual.

6.5 Program deficiencies identified as a result of a safety-related concern are documented and corrected via the Performance ,

Improvement Request (PIR) per KGP-1210 to ensure that the elements of root cause and potential for reportability are ,

addressed.  ;

6.6 Hardware deficiencies identified as a result of a safety-related concern are documented and corrected via a Corrective Work Request (CWR) per ADM 01-057 or Nonconformance Report (NRC) per KP-2145, as appropriate. ,

6.7 Quality First investigation reports are distributed to the responsible manager, associated department head, General Counsel and President /CEO.

7.0 PROCEDURE None. Quality First implementing procedures fulfill the requirements of this general procedure.

8.0 FORMS 8.1 KGF-73, " Quality First Concern Disclosure Statement" 9.0 RECORDS  !

9.1 There are no QA records generated by this procedure.

9.2 Administered Forms KGF-73 and all related attachments are l retained as permanent records in the Quality First files.

9.3 Corrective action documents (NCRa, CWRs, PIRs) initiated as a result of Quality First activities are treated as records according to their respective controlling procedure. l 1

PAGE 6 OF 6

e REBE EGF-73, REF. 09/90 '

0 CM%P o l

QUAUTYFIRST ,4 o g ,

CONCERN DISCLOSURESTATEMENT g GOM , l g O  !

/

4 ERME MEtt GROUP (Please Print)  ;

errrar. SECtRITY W.

ACRD narrat E. (if ==14r=hlm) .j EtlPIDYED BY ,

i I. I do not have any safety-r= lated manerna. ,

t%-+4 5 this statamart. f rwif tmtes you do not have any nnaner== 7'rii=

the falle==iM:  ;

1. The safe operation, unrlifirmtica cu ==i=*===ar= af the pLust.

B. &wertitions that may affect the gamlity of M3m activities.

C. The violation of Prnr-inre, Oode, Standmed, ,-- lei , hir=1

%-4 r< r= tion az r.< ,---45 . _ _.s. _.

i r

II. I would like to supress the fnii,.,r5 safety-ralatad marmrn(s):  :

f FM M N N R M N 1 N M M 1 ,

RE N .  !

Pitannummy arrunststs _

i M M:

The infar== tim la tras and arvne=tm to the best of my bar=rla'if "-

BEPIDYEE !tTt3EaTEEtEs Db2E l i

M Y.UWT M Ma f i

b -

i 1

^

j 4

I i

1

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i J

l

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i 8*marvert Ftd i Place .I here 4 t IIDlf Creek cenmratinIJ Staticut Quality First (IIC-W) j P.O.. Box 411 > h 14=atout, IE 66839  ; e d i l First Fold -; MR.IE mm FM M FM i i Feld and seal ly stay 11mg er tuplag er plan to a campesy leemrefflee mutilag amuelaps. Erup is the m ar tuternal r nati as part of the emplges/emmeracter/emummituut estt preemms , er . . 

                                                                                                                                        .' i Feld and sent er place la a esmolapa put le the 5.1. mall eith proper pmmenge if electleg to ensplete tMs tIsra                    _!

after artting IEEE. -f 

                                                     ._.. s.  .

a.. , 

                                                                                                          ~

ladivlshmis electtag met to emplete tMs Maclemure w hmeld s to amre of the gttens for disclosure of , safety-related cumenrus . i

a. muy emstact the Ouality First natitus. (315) 54-M est. SW _ . _ . . '
b. muy contact the E K Restdsat 1supacter's afflee et the IEEE site ut. 4EFE er (315) 304 5E5 er call- ',

the E Et hugle IV Office to #11mpton, Tams, ellect, anytten, at 1-317 45 888 .. , i

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