nuclear employee concerns evaluation program ...utilized when conducting ecp evaluations...

Nuclear Quality Management Leadership

Nuclear Employee Concerns Evaluation Program Performance Objectives And Attributes

NECE-GUID-001 R01

Approved: ____________________________________________________ Chair, Nuclear Quality Management Leadership

Nuclear Employee Concerns Evaluation Program Performance Objectives & Attributes, R01 June 18 2012

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Foreword

The Nuclear Quality Management Leadership (NQML) forum consists of utility quality assurance management decision-makers to sponsor and promote activities that support effective quality management within the nuclear industry. The NQML optimizes the interface with other industry organizations to bring consistent and complimentary focus to the current issues challenging our business. The NQML has partnered with the Nuclear Energy Institute (as defined within sub-process LP002 of the NEI Standard Nuclear Performance model) to further promote the advancement of effective independent oversight of Nuclear Power operations. In 2007, the NQML agreed to establish a program for measuring the effectiveness of Employee Concerns Programs (ECP) across the industry to apply consistently high standards of performance for the ECP process. A subcommittee was responsible for the identification and development of good practices pertaining to successful ECP oversight and implementation of ECP Programs. The subcommittee was charged with the development of specific performance objectives and attributes associated with a leading ECP and the development of industry peer evaluation guideline. NECE-GUID-001 “Nuclear Employee Concerns Evaluation Program Performance Objectives and Attributes” describes specific criteria to assist nuclear utilities and facilities in developing, improving, and evaluating their ECP functions. The performance objectives are broad in scope and each objective lists several criteria to provide the breadth and depth of the objective. NECE-GUID-001, “Nuclear Employee Concerns Evaluation Program Evaluation Guidelines” establishes a uniform method for evaluating the effectiveness of each member’s ECP Program.

Acknowledgement This document consolidates the efforts of many nuclear industry professionals actively involved in Employee Concerns Program activities. The document reflects the industry’s experience in evaluating Employee Concerns Program activities as well as good practices that support excellence in nuclear operations. The document was prepared under the sponsorship of the NQML. Specifically, the NQML wishes to thank the Employee Concerns Program Subcommittee for the development of this document.


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NUCLEAR QUALITY MANAGEMENT LEADERSHIP (NQML) NQML STEERING COMMITTEE

Jeff DeFebo PSEG Nuclear NQML Chairperson

Tom Tankersley Entergy NQML Vice Chairperson

Ed Dutton Arizona Public Service NQML Nuclear Industry Evaluation Program Chairperso

Open Advisor to the Chair

Jim Burkhead Exelon Nuclear Oversight Conference Chairperson

Darlene Stimart Xcel Energy Nuclear Procurement Issues Committee Chairperson

Al Ashton Bruce Power NQML Secretary

Dennis Petersen Pacific Gas & Electric NQML Training and Education Chairperson

Nuclear Energy Institute Representative

Mark Harvey

NQML – EMPLOYEE CONCERNS PROGRAM (ECP) SUBCOMMITTEE

Mike Headrick PSEG Nuclear

Dutch Chancey First Energy

Bob Speek Exelon Corp

Kirk Pedersen Exelon Corp

Rick Burnside Pacific Gas & Electric


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NUCLEAR QUALITY MANAGEMENT LEADERSHIP

NUCLEAR EMPLOYEE CONCERNS EVALUATION PROGRAM PERFORMANCE OBJECTIVES AND ATTRIBUTES

NECE-GUID-001 R01

TABLE OF CONTENTS

Introduction ………………………………………………………………………………………..1 Employee Concerns Program Organization & Organizational Effectiveness (Objective A) .... 2 Employee Concerns Program is Administered by Competent Personnel (Objective B) ......... 3 Employee Concerns Program has Appropriate Levels of Confidentiality (Objective C) .......... 4 Employee Concerns Program has a Defined Scope (Objective D) ....................................... 5 Employee Concerns are Effectively Prioritized and Investigated (Objective E) .................... 6 Employee Concerns Program Ensures CI’s Receive Feedback (Objective F) ..................... 7 Employee Concerns Program Self Assessment/Independent Review (Objective G) ............. 8 Employee Concerns Program Trend Identification and Reporting (Objective H) .................... 9 Employee Concerns Program Documentation/Records (Objective I) ................................... 10 Employee Concerns Program is Visible to People (Objective J) .......................................... 11

References …………………………………………………………………………………........... 12 Revision History …………………………………………………………………………………… 12

Nuclear Employee Concerns Evaluation Program Performance Objectives & Attributes, R01 June 18, 2012

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Introduction

The purpose of this document is to outline the Performance Objectives and Attributes that Employee Concerns Programs can utilize as standards of excellence. This document will be utilized when conducting ECP Evaluations (NECE-GUID-002). The scope of the ECP evaluation will only pertain to activities executed by the ECP organization. Evaluations should take into consideration ECP variables such as differences in staffing, site specific procedures, and program monitoring that meets the needs of the organization. These objectives and attributes were derived from regulatory standards and industry experience to bring about a consistent excellence standard for Employee Concerns Programs. The following are the main references used to develop this document:

NRC RIS 2005-18 Guidance for Establishing and Maintaining a Safety Conscious Work Environment

NRC RIS 2006-13 Information on the Changes Made to the Reactor Oversight Process to More Fully Address Safety Culture

NRC Inspection Manual – Resolution of Employee Concerns Inspection Procedure 40001 (06/03/97)

NRC Inspection Manual – Identification and Resolution of Problems Procedure 71152 (01/10/08)

INPO Principles for a Strong Nuclear Safety Culture (Nov. 2004) INPO SOER 02-04 (Rev. 1) Boric Acid Corrosion / Davis-Besse NEI 97-05 Nuclear Power Plant Personnel-Employee Concerns Program-Process

Tools In A Safety Conscious Work Environment (Revision 2, December 2003)


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Objective A – Employee Concerns Program Organization & Organizational Effectiveness The ECP organization responsibilities and accountabilities for ECP activities are clearly defined, understood, and effectively implemented. The ECP Organization is separate and independent from line management. ECP managers, by leadership, commitment, and example, establish high standards of performance of the ECP Program. Attributes: A.1 A high level company policy exists that documents clear expectations for the ECP.

A.2 The ECP is defined and implemented with approved procedures that describe the purpose of the ECP, responsibilities of ECP personnel implementing the program, and responsibilities of personnel in the line and support organizations.

A.3 The ECP provides an alternate reporting path for employees and contractors to report Nuclear Safety, technical and compliance concerns, and concerns dealing with harassment, intimidation, retaliation, or discrimination (HIRD) for having engaged in protected activities.

A.4 The ECP organization is separate and independent of the line-management chain.

A.5 The ECP organization is staffed appropriately to effectively implement the ECP Program.

A.6 The ECP organization is a learning organization as exhibited by self-assessments, evaluations, benchmarking and improving to industry best practices. (Reference: SOER 02-04)

A.7 Interfaces exist between the ECP and the line organization to ensure that ECP trends are considered for maintaining a Safety Conscious Work Environment. (Reference: NRC RIS 2005-18 Guidance for Establishing and Maintaining a Safety Conscious Work Environment)

A.8 Interfaces exist between the ECP and the line organization to ensure that ECP trends are considered for maintaining a strong Nuclear Safety Culture. (References: INPO Principles for a Strong Nuclear Safety Culture, and NRC RIS 2006-13 Information on the Changes Made to the Reactor Oversight Process to More Fully Address Safety Culture).

Note: The interfaces described in Attributes A.7 and A.8 can be formal or informal. The interfaces can be communications with Senior Management and/or communications with a structured working group/committee whose purpose is to review employee issue trends.


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Objective B – Employee Concerns Program is Administered by Competent Personnel Personnel responsible for implementation of the ECP have appropriate experience/background and training to effectively implement the program and perform investigations. Attributes: B.1 An effective qualification process is established for ECP personnel, to include

indoctrination, initial, and continuing training.

B.2 Expertise of personnel responsible for the ECP is established through a combination of education, training and/or experience. The following are examples of skill areas for ECP Managers and ECP staff that contribute to effectively implementing an ECP:

Initial Training Indoctrination, Confidentiality, Investigative Techniques Training, Interviewing, Technical Background in Nuclear Power, Auditing or Quality experience, Organizational experience, Listening, Report Writing, Root Cause Analysis, Investigator, Record keeping, Collection of Evidence, Conflict Resolution, Regulations and On The Job Training (OJT).

Continuing Refresher Training on topics described above, Human Resources, Legal, and Co-Employment.

Temporary Assignments (to ECP) Indoctrination, Confidentiality, Investigative Techniques Training,

B.3 ECP training includes how to conduct ECP activities, such as investigations and interviews, in a way that ensures to the extent practical the confidentiality of the concerned individual.

B.4 Documentation of ECP education, training and experience should be available. A good practice is to use of a formal qualification card/form for documenting

qualifications.


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Objective C – Employee Concerns Program has Appropriate Levels of Confidentiality

The ECP includes measures to treat certain information as confidential, to the extent practical under the circumstances. Attributes: C.1 The identification of the Concerned Individual (CI) will be kept confidential to the fullest

extent possible. C.2 Concerned Individuals receive explanations on confidentiality options.

C.3 If the CI requests their identity be maintained confidential, the ECP Representative will make every effort not to disclose the identity of the CI. The following conditions may require release of the CI’s identity:

When required by the Nuclear Regulatory Commission (NRC). When required in response to subpoenas or in response to proceedings before the

Department of Labor, Equal Employment Opportunity Commission, a court of law, or other legal and governmental bodies.

Pursuant to the requirements of federal laws, regulations, orders or other directives.

If immediate nuclear safety or personnel safety would be compromised if confidential information were withheld.

Corporate Ethic investigations.

C.4 The identification of the CI can be released within the company to those employees with a specific need to know in order to address the concern, but the CI should be contacted in advance to discuss the reason for sharing the CI’s name.

C.5 If the CI waives confidentiality, the ECP Representative will respect the privacy of the CI and only reveal the CI’s identity as outlined above and as required in order to conduct a complete and thorough investigation.

C.6 ECP voicemail and e-mail have a secure access (i.e. access is protected through use of passwords/ security codes).


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Objective D – Employee Concerns Program has a Defined Scope The ECP is designed to include/address Nuclear Safety, technical and compliance issues and concerns related to harassment, intimidation, retaliation, and discrimination (HIRD) for engaging in protected activities. Attributes: D.1 ECP procedural guidelines exist that include methods for communicating and promptly

investigating Nuclear Safety, technical and compliance concerns, and HIRD concerns. Nuclear Safety and HIRD are clearly defined in procedural guidelines.

D.2 The ECP should have a method to refer issues that are beyond the scope of the ECP, such as issues in the areas of Ethics, Hostile Work Environment, and Human Resources.

D.3 The ECP will be designed to accommodate concerns submitted anonymously.

D.4 For concerns involving the ECP or Management responsible for the ECP, there is a defined process for having an independent investigation.

D.5 ECP should pulse the Safety Conscious Work Environment (SCWE) of the site, communicate any identified concerns to line management, and follow-up with line management to determine that appropriate actions are taken to address the concerns.


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Objective E – Employee Concerns are Effectively Prioritized and Investigated The ECP screens issues for safety or other significance, and takes appropriate actions based on significance. Investigations are initiated, conducted and completed on a timely basis, and are sufficiently thorough to permit management to make an informed decision regarding action to address the concern. Attributes: E.1 ECP investigations are performed in accordance with approved procedures that address

significance, performance, corrective actions, feedback to the CI, and reporting to appropriate management personnel.

E.2 ECP procedural guidelines exist to ensure that ECP personnel evaluate the significance of issues, ensuring those that impact Nuclear Safety/Quality or HIRD for engaging in Protected Activity are responded to in a timely manner.

E.3 ECP should have in place a “Duty to Act” – that is, a duty to respond appropriately to issues that could impact safe plant operations, or those that indicate wrongdoing.

E.4 If issues are identified to be conditions adverse to quality, such as a Nuclear Safety/Quality issue, then the issue needs to be documented in the Corrective Action Program. Effort should be taken to protect the confidentiality of the CI when documenting the issue.

E.5 Investigations are performed to the depth necessary to identify all potentially significant Nuclear Safety, technical and compliance issues, and HIRD issues.

E.6 Corrective actions to address issues that are validated during ECP investigations are documented and tracked by an appropriate tracking method by ECP staff personnel.

E.7 ECP should keep management appropriately informed on issues. Timeliness of updates should take into account the significance of the issue(s).

E.8 Investigation results are reported to the appropriate level of management to address corrective actions, and to provide insights and recommendations.


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Objective F – Employee Concerns Program Ensures CIs Receive Feedback ECP personnel provide feedback to CIs during investigations. CIs are also provided feedback on the final results of investigations, including actions taken to address concerns that are validated. Attributes: F.1 CIs receive feedback on a periodic basis during investigations, and the feedback is

documented in case files.

F.2 When investigations are completed CIs receive feedback on the results of the investigation:

Feedback should include any actions being taken by Line Management to address those aspects of the concern that are validated.

Feedback to the CI should be generic in nature and should not identify specific corrective actions that may compromise confidentiality of others. (Example: It is appropriate to indicate that an issue was validated and appropriate corrective actions have been taken; however, it is not appropriate to say “John Doe received three days off without pay as discipline for his involvement with the issue.”

The CIs reaction to the feedback should be documented.

F.3 For concerns received anonymously, alternate methods maybe used as appropriate to communicate results of investigations, including actions to address issues (i.e. work group rollouts, global communications). In some cases it may be appropriate not to communicate the results of investigations.


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Objective G – Employee Concerns Program Self Assessment/Independent Review Evaluations are performed periodically to gauge overall effectiveness of the ECP and to identify possible areas for improvement. Attributes: G.1 The ECP will be assessed on a nominal biennial basis, and can be in the form of a self

assessment or an independent assessment.

G.2 Specific performance objectives and criteria will be used as a guide during the assessment process.

G.3 The assessment team will use existing industry standards of excellence as a basis for their assessments.

G.4 Assessment team members sign a confidentiality agreement that documents the team members understanding of their responsibility to not share information related to the assessment.

G.5 The final report detailing the findings and conclusions of the assessment team will be presented to appropriate members of Senior Management.

G.6 The Senior Management person responsible for the ECP will determine the adequacy of ECP self assessment/independent assessment.

G.7 Conditions adverse to quality will be entered into the site-specific corrective action program for tracking and closure.

G.8 Site-specific recommendations intended to improve program performance will be tracked to completion by the site ECP staff.

G.9 ECP or SCWE surveys allow for write in comments. Survey results are communicated to site personnel.

G.10 The Employee Concerns Manager or equivalent may use selected concerns, results of investigations or evaluations, and conclusions as program feedback (maintaining confidentiality where appropriate) when they are determined to have value in communicating policies, procedures, practices and performance expectations.

G.11 When performing assessments to determine how effectively management and the ECP staff oversee the ECP, review the following:

Monitoring and auditing of the effectiveness of the ECP by internal and independent review organizations.

ECP solicits input from program implementers. Encouragement and evaluation of employee feedback. Dissemination of the results to management and the staff. Assessment of employee satisfaction with reporting safety concerns to the ECP. Does ECP benchmark other ECPs and/or attend industry forums.


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Objective H – Employee Concerns Program Trend Identification and Reporting The ECP has a mechanism to identify and report concern trends to Management. Attributes: H.1 ECP Performance Indicators (PIs) exist to monitor ECP performance. The data from the PIs

are used to provide insights to Senior Management on ECP trends related to line organizations and ECP implementation.

H.2 When declining trends are identified during monitoring of the ECP performance they are acted upon in a timely manner.

H.3 ECP should utilize performance indicators when reporting trends to Senior Management. The following are areas where performance indicators/trending could be utilized to evaluate the ECP:

Intake Source (i.e. Interview, ECP Hotline, Drop Box, Mail, Survey) Concern Origin (i.e. Plant, Corporate Headquarters) Concern Category (i.e. Nuclear Safety/Quality, HIRD, SCWE, DPO) CI Category (i.e. Union, Management, Contractor, Professional) CI Work Group (i.e. Operations, Maintenance, Engineering) Affected Work Group (i.e. Operations, Maintenance, Engineering) Associated Issue (Equipment, Procedure, Management Style, Human Resources) Number of concerns received and number of concerns validated. Number of concerns received that were anonymous, CI requested confidentiality, and

those not requesting confidentiality. Number of concerns reported to outside agencies ( NRC, DOL, OSHA, EEOC,

media, etc) Timeliness of ECP investigations

H.4 ECP should provide periodic trend reports to Senior Management, considering the following: Establish frequency of reports to Senior Management (i.e., monthly, quarterly,

annually). Have a remarks section for important indicators for identifying insights on trends

and changes in indicators. Senior Management should be provided the following information on an annual

basis; indicators, trend analysis, program actions, survey results, self-assessment results and regulatory activity.

One method of evaluating ECP effectiveness with regard to numbers of concerns received over a given time period is to determine the ratio of ECP cases to NRC Allegations (should be > 3:1).


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Objective I – Employee Concerns Program Documentation/Records The ECP employs a method to record concerns and their disposition, and maintains records of concern investigations. Attributes: I.1 ECP documents should be completed and retained in the ECP case file.

I.2 ECP case files should contain all relevant documents for the case. ECP procedural guidance should specify the required documents to be created

and retained. Publicly available documents can be included through reference. Completed files should receive an independent review..

I.3 ECP files should contain appropriate documents such that a third party individual with an understanding of the process should be able to understand how the investigator reached their conclusion.

I.4 ECP case files will be maintained in a secure manner at all times. Files will be stored in a locked file or locked room when not in use. When the files are in use, they will be secured by returning them to the locked file or locked room.

I.5 Electronic files related to ECP cases will be secured to protect unauthorized personnel access.

I.6 ECP case files are retained in accordance with Records Management guidelines. Approved procedures should establish how long ECP case files are to be

retained. Approved procedures should specify what should be done with the files after

retention limits are exceeded. Confidentiality should be maintained by destroying ECP records after retention

limits are exceeded.


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Objective J – Employee Concerns Program is Visible to People The ECP is visible to employees and contractors. The licensee notifies the workforce of the ECP and describes ways to contact the ECP. Senior Management supports ECP visibility and credibility. Attributes: J.1 Employee Concerns Program personnel maintain a visible presence at the site.

J.2 ECP personnel should communicate to the site regularly through publications, video monitors, outage fairs, etc.

J.3 ECP informational posters, signs, etc. are displayed in key site locations (Security building, cafeteria, break areas, etc).

J.4 ECP promotes a SCWE at the site and “pulses” the organization to discern areas where attention may be required.

J.5 Site Management demonstrates sponsorship of the ECP.

J.6 Site and corporate communications demonstrate support of the ECP.

J.7 Multiple examples of site communications supporting the ECP exist.

J.8 ECP is addressed in appropriate administrative documents, such that ECP is part of new employee indoctrination (NGET), part of orientation to the site, part of transfer between sites, and part of release from site.

J.9 ECP is addressed in contractor entrance and exit processes.

J.10 ECP maintains an office for business, records storage, and a location to conduct private interviews.

J.11 The ECP office location is located in an area that is accessible, but is discreet and separate from management and Human Resources offices, such that employees and contractors are not inhibited from visiting the ECP office.


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REFERENCES This document takes its authority from: NECE-GUID-002, Nuclear Employee Concerns Evaluation Program Evaluation Guidelines REVISION HISTORY R01 – 06/18/12 – New document numbering system.

- References and Revision History Sections added.

R00 – 07/31/08 – Initial issue

Nuclear Quality Management Leadership

Nuclear Employee Concerns Evaluation Program Evaluation Guidelines

NECE-GUID-002 R01

Approved: __________________________________________________ Chair, Nuclear Quality Management Leadership

Nuclear Employee Concerns Evaluation Program Evaluation Guidelines, R01 June 18 2012

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Foreword The Nuclear Quality Management Leadership (NQML) forum consists of utility quality assurance management decision-makers to sponsor and promote activities that support effective quality management within the nuclear industry. The NQML optimizes the interface with other industry organizations to bring consistent and complimentary focus to the current issues challenging our business. The NQML has partnered with the Nuclear Energy Institute (as defined within sub-process LP002 of the NEI Standard Nuclear Performance model) to further promote the advancement of effective independent oversight of Nuclear Power operations. In 2007, the NQML agreed to establish a program for measuring the effectiveness of Employee Concerns Programs (ECP) across the industry to apply consistently high standards of performance for the ECP process. A subcommittee was responsible for the identification and development of good practices pertaining to successful ECP oversight and implementation of ECP Programs. The subcommittee was charged with the development of specific performance objectives and attributes associated with a leading ECP and the development of industry peer evaluation guideline. NECE-GUID-001 “Nuclear Employee Concerns Evaluation Program Performance Objectives and Attributes” describes specific criteria to assist nuclear utilities and facilities in developing, improving, and evaluating their ECP functions. The performance objectives are broad in scope and each objective lists several criteria to provide the breadth and depth of the objective. NECE-GUID-002, “Nuclear Employee Concerns Evaluation Program Evaluation Guidelines” establishes a uniform method for evaluating the effectiveness of each member’s ECP Program.

Acknowledgement This document consolidates the efforts of many nuclear industry professionals actively involved in Employee Concerns Program activities. The document reflects the industry’s experience in evaluating Employee Concerns Program activities as well as good practices that support excellence in nuclear operations. The document was prepared under the sponsorship of the NQML. Specifically, the NQML wishes to thank the Employee Concerns Program Subcommittee for the development of this document.


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NUCLEAR QUALITY MANAGEMENT LEADERSHIP (NQML) NQML STEERING COMMITTEE

Jeff DeFebo PSEG Nuclear NQML Chairperson

Tom Tankersley Entergy NQML Vice Chairperson

Ed Dutton Arizona Public Service NQML Nuclear Industry Evaluation Program Chairperson

Open Advisor to the Chair

Jim Burkhead Exelon Nuclear Oversight Conference Chairperson

Darlene Stimart Xcel Energy Nuclear Procurement Issues Committee Chairperson

Al Ashton Bruce Power NQML Secretary

Dennis Petersen Pacific Gas & Electric NQML Training and Education Chairperson

Nuclear Energy Institute Representative

Mark Harvey

NQML – EMPLOYEE CONCERNS PROGRAM (ECP) SUBCOMMITTEE

Mike Headrick PSEG Nuclear

Dutch Chancey First Energy

Bob Speek Exelon Corp

Kirk Pedersen Exelon Corp

Rick Burnside Pacific Gas & Electric


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NUCLEAR EMPLOYEE CONCERNS EVALUATION PROGRAM EVALUATION GUIDELINES

NECE-GUID-002 R01 TABLE OF CONTENTS

1.0 Introduction ............................................................................................................................. 1 2.0 Purpose..................................................................................................................................... 1 3.0 Program ................................................................................................................................... 1

3.1 General Conditions .................................................................................................... 1 3.2 Team Qualifications and Duties ............................................................................... 2 3.3 Evaluated Member Management Responsibilities ................................................. 4 3.4 Evaluation Schedule .................................................................................................. 4 3.5 Reporting Evaluation Results ................................................................................... 5 4.0 References ............................................................................................................................... 6 5.0 Revision History ..................................................................................................................... 6 Appendix A Definitions ...........................................................................................................… 7


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NUCLEAR EMPLOYEE CONCERNS EVALUATION PROGRAM

EVALUATION GUIDELINES NECE-GUID-002 R01

1.0 INTRODUCTION

This guideline establishes a uniform practice regarding evaluating the effectiveness of implementation of each member’s ECP, either via self-assessments or independent assessments.

This guideline assesses member’s ECP using the criteria established in NECE-GUID-001, “Nuclear Employee Concerns Evaluation Program Performance Objectives and Attributes.” The NECEP can be used to provide an independent method for members to evaluate their organization’s ECP performance to the industry guidance established in the reference documents listed in NECE-GUID-001. During the NECEP, evaluators perform interviews of site personnel and review site documents.

2.0 PURPOSE

2.1 The purpose of NECEP is to provide a consistent, structured method to evaluate member’s ECP. These guidelines provide management with a process for the performance of a self-assessment/independent assessment of the adequacy/effectiveness of implementation of their ECP. Utilities may customize the requirements where appropriate to conform to their specific ECP requirements.

3.0 PROGRAM

3.1 General Conditions

3.1.1 The scope of NECEP is to evaluate the effectiveness of the implementation of the evaluated member’s ECP.

3.1.2 NECEP assessment Teams typically consist of a Team Leader, team members,

and a site peer. The number of team members should be commensurate with the evaluation scope (typically five).

3.1.3 When this evaluation is being performed as a self-assessment, the procedures

governing the site/utility self-assessment processes direct the actual performance of the self-assessment and the Performance Objectives and Attributes can form the basis for the scope of the self-assessment. The remainder of this guideline pertains only to independent assessments.

3.2 Team Qualifications and Duties


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3.2.1 Team Leader

3.2.1.1 The Team Leader will be a management-level individual (e.g., Director,

Manager, or Supervisor level personnel). The Team Leader will have the requisite skill and/or experience to interface successfully with the management of the evaluated utility. The Team Leader should have appropriate experience, an appreciation for sensitive management issues and an awareness of ECP requirements. In addition it is recommended that the Team Leader have participated in, or led similar or large scope evaluations.

3.2.1.2 Basic Duties/Accountabilities:

a) Review qualifications and approve the composition of the evaluation team, including industry peers, observers, or consultants.

b) Review previous utility performed self-assessments and/or

independent assessments to identify particular areas of focus for the team.

c) Assign scope items to team members to prepare portions of the

evaluation checklist based on expertise. Monitor the team’s preparation progress.

d) Develop the detailed evaluation schedule.

e) Provide the required information to the host utility for in processing

team members.

f) Provide orientation for the evaluation team.

g) Make evaluation team assignments, including evaluation areas and responsibilities for completing sections of the final report.

h) Coordinate activities during the evaluation. Ensure effective

communications within the team.

i) Meet daily with the evaluation team to review their observations, perceptions, and conclusions. Team meetings are intended to promote coordination, cooperation, and sharing of information regarding issues and experience gained during the evaluation process. The Team Leader shall coordinate the identification and evaluation of potential findings.

j) Work with the Evaluation Team. Coordinate planning and preparation

to ensure an effective evaluation. This includes arranging logistics for


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the evaluation team.

k) Arranging for and conducting Entrance and Exit meetings. Organizing the evaluation results for the facilitation of the Exit meeting.

l) Developing and approving the final report, in conjunction with the

team members.

3.2.2 Team Members

3.2.2.1 Team Members will be industry peers who are experienced in the assigned scope area.


a) Perform pre-evaluation reviews of documents provided in order to:

Familiarize themselves with the evaluated members site organization and processes

Determine potential vulnerabilities to focus on in assigned areas b) Assist the Team Leader in developing evaluation focus areas. c) Perform evaluation in assigned area(s) through interviews and/or

document reviews. d) During the evaluation, each evaluator meets as needed with the Team

Leader to discuss the details of the evaluation, including fact and data gathered, as well as conclusions and insights made based on this information. The purpose is to ensure accuracy and understanding of the information gathered.

e) Work with the other evaluation team members to reach final

conclusions. f) Provide input to the final report and related documentation, as required

by the Team Leader.

3.2.3 Site Peer Team Member

3.2.3.1 A Site Peer Team Member is an individual from the evaluated member’s ECP organization who brings expertise and experience to the evaluation team based on an in-depth knowledge of the evaluated members processes and site organization.



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a) Establishing logistics, including site access for all team members, a meeting area, basic office supplies, and communications equipment, and providing necessary documents for team review prior to and during the on-site evaluation. Consideration should be given for the confidential nature of the material and interviews.

b) Facilitating the development and issuance of evaluation scope and

plan. c) Facilitating communication between evaluation team members and

plant staff, including Entrance and Exit meetings, and scheduling interviews.

d) Participating in team meetings, contributing needed information and

challenging issues to ensure they are accurately characterized.

3.3 Evaluated Member Management Responsibilities a) Ensuring appropriate line organization support for the NECEP. b) Approving the NECEP plan prior to the teams arrival on site. c) Ensuring NECEP issues are appropriately entered into evaluated member’s corrective

action program and conducting appropriate follow-up as required by their ECP. d) Approving evaluation team composition, including Industry Peers, observers and

consultants.

3.4 Evaluation Schedule 3.4.1 At least ninety (90) days prior to the evaluation the Team Leader shall contact the

evaluated member to establish a point of contact to arrange for planning, coordinating and scheduling of the evaluation. The dates shall be mutually agreed upon between the two parties.

3.4.2 At least ninety (90) days prior to the evaluation the evaluated utility will provide

a report of the most recent utility performed self-assessment of their ECP performance (i.e., past 2-4 years) to the evaluation Team Leader.

3.4.3 At least sixty (60) days prior to the evaluation the scope (including the specific

attributes to be evaluated) shall be finalized and approved. 3.4.4 At least forty-five (45) days prior to the evaluation the Team Leader will have

contacted and finalized the team composition. 3.4.5 At least thirty (30) days prior to the evaluation the scope and the plan shall be

finalized and approved.


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3.4.6 At least thirty (30) days prior to the evaluation the evaluated member will provide

the necessary documentation to the team. Recommend this include appropriate site procedures, site layout, current organization charts, etc. Distribution of the information via a CD is recommended. Confidential information will not be distributed, and should be reviewed at the site where the assessment is performed.

3.4.7 The evaluation team will coordinate prior to the scheduled evaluation to discuss

the evaluation and to finalize their preparation prior to the scheduled entrance meeting. The evaluated member should participate to provide the team with logistics of initial arrival at the station.

3.4.8 The evaluation team should meet with the evaluated station in an entrance

meeting to introduce evaluation team members, meet counterparts, discuss the evaluation sequence and plans for the exit meeting, and to confirm channels of communications.

3.4.9 Evaluations will normally require five (5) days onsite for each assigned

evaluation team member. 3.4.10 Daily de-briefs should be held with the evaluation team to review their

observations, perceptions, and conclusions. In addition, a pre-exit debrief may be conducted at the discretion of the Team Leader and the evaluated member management.

3.4.11 An exit meeting should be held with the management of the evaluated utility,

including both the line and the ECP organizations, to present the evaluation results.

3.4.12 Within fifteen (15) days of the exit, the Team Leader should provide a draft report

to the Evaluation Team Members and to the evaluated member for review and feedback.

3.4.13 Within thirty (30) days of the exit, the Team Leader will prepare a cover letter

and approve the final NECEP Report documenting the evaluation results, and provide a copy to appropriate line management of the evaluated member.

3.5 Reporting Evaluation Results

3.5.1 Typically the evaluation results are documented in the evaluated members report

format. As a minimum, the following will be included:

3.5.1.1 Description of the evaluation scope.

3.5.1.2 Identification of the evaluators.


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3.5.1.3 A summary of the evaluation results, including a statement regarding the effectiveness of the objectives and attributes that were evaluated.

3.5.1.4 Description of each identified issue (see Appendix A, Definitions) to assure that the evaluated member can effectively carry out corrective action. It is the responsibility of the evaluated member to prioritize each issue and include them in their corrective action process when appropriate.

3.5.1.5 Recommendations for correcting identified issues or improving the program as appropriate.

4.0 REFERENCES

This document takes its authority from: NQML-CHAR-001, NQML Charter This document is implemented by: NECE-GUID-001, Nuclear Employee Concerns Evaluation Program Performance Objectives and Attributes

5.0 REVISION HISTORY

R01 – 06/18/12 – New document numbering system. - References and Revision History Sections added.

R00 – 07/31/08 – Initial Issue


7

APPENDIX A

DEFINITIONS

The following definitions should be utilized to assist with the classification of evaluation results into appropriate categories. DEFICIENCIES (D) A condition or concern that does not meet specific requirements of procedures, policies, management expectations, or accepted industry standards. These should be tracked via the station’s Corrective Action Program or other appropriate tracking method. RECOMMENDATIONS (R) A suggestion identified during the assessment to enhance the assessed area and improve performance. Recommendations are not corrective actions to address standards deficiencies. These may be tracked via the station’s Corrective Action Program or other appropriate tracking method. STRENGTH (S) Strengths are those items identified as having sufficient interest and value to be shared with the industry. When reporting strengths, list only those items that others would want to benchmark against. These may be tracked via the station’s Corrective Action Program or other appropriate tracking method.

Headrick_NECE001R01_ECPObjectives_SanFranHeadrick_NECE002R01_ECPEvauationGuideSanFran

nuclear employee concerns evaluation program ...utilized when conducting ecp evaluations...

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