Expressing Concerns and Differing Views

WHAT

TVA encourages the voluntary expression of concerns and differing views involving all aspects of its activities in all of its operating groups. It places special emphasis on differing views on substantive public health, environmental and safety matters.

Employees are strongly encouraged to seek resolution of concerns and differing views with their immediate supervisor and to proceed up their management chain if necessary to achieve resolution. However, differing views may be voiced to any management level at any time. Any person found guilty of acts of reprisal, such as acts of intimidation, harassment or discrimination, against an employee because the employee expressed a differing view is subject to disciplinary action, up to and including termination.

TVA encourages and protects the concerns and differing views of employees regarding all aspects of TVA's construction projects and operations. Every employee is entitled to have differing views heard by management when the employee considers the issue significant and the view differs from a management decision which has been made or is pending. It is TVA policy that every responsible view is valuable and should be heard and appropriately considered in decision-making processes.

WHO

All employees and contractors

WHY

TVA encourages the voluntary expression of concerns and differing views. This policy is communicated to employees to encourage their cooperation and participation at all working levels, thus furthering the employees' fulfillment of duties, productive efforts and observance of standards.

HOW

ALTERNATIVES
Employees who believe they have been subjected to reprisal (which includes any form of intimidation, harassment, or discrimination) for expressing concerns or differing views should report their concern to appropriate TVA managers or to the Inspector General.

Employees who disagree with the final disposition of an occupational health or safety issue may file a complaint in writing to the:

Office of Federal Agency Safety Programs
Occupational Safety and Health Administration
U.S. Department of Labor
200 Constitution Avenue, N.W.
Washington , D.C. 20210

Employees who believe violations of Nuclear Regulatory Commission (NRC) rules or terms of the license have occurred associated with the design, construction or operation of a TVA nuclear plant should report suspected violations immediately to their supervisor. Employees are free to contact the NRC directly with issues associated with the design, construction, or operation of a TVA nuclear plant. Employees may contact the NRC through an NRC inspector or contact the:

U. S. Nuclear Regulatory Commission, Region II
Sam Nunn Atlanta Federal Center , 23 T85
61 Forsyth Street, SW
Atlanta , Georgia 30303-8931
Telephone (404) 562-4400
Toll Free: 1-800-577-8510

You may also call NRC's Toll Free Safety Hotline:
Toll Free: 1-800-695-7403

ROLES

All Employees

Are encouraged to resolve issues directly with their line management so corrective action may be handled promptly and at the working level.
Are encouraged to express their views about significant issues through their chain of command if not resolved.
May at any time express their views related to occupational health or safety issues to Human Resources, Health & Safety, and views related to design, construction, testing, or operation of TVA nuclear plants to TVA's Concerns Resolution Program Staff.

Supervisors

Have principal responsibility for ensuring the implementation of the policy.
Communicate the policy to employees.
Ensure that differing views are heard and appropriately considered in decision-making processes.
Provide protective measures to encourage participation without fear of reprisal.
Refer unresolved issues through the chain of command as far as necessary.

The Chief Executive Officer, Chief Operating Officer, Inspector General, General Counsel, Executive Vice Presidents, and Senior Vice Presidents/Vice Presidents

Administer this policy for their organizations.
Inform the Board through the chain of command of differing views that have not been resolved to the satisfaction of the employee.

Line Management, Nuclear Power Group and Nuclear Generation Development and Construction

Receives, investigates, and provides for the resolution of concerns and differing views associated with the design, construction, testing, and operation of TVA's nuclear plants. Line Management is responsible for pursuing concerns and differing views whether they are received directly or brought to them by their Concerns Resolution Program.

Chief Nuclear Officer and Executive Vice President, Nuclear Power Group

Is responsible for matters relating to receiving, assessing and, as appropriate, reporting to the NRC defects and noncompliances related to nuclear safety for TVA's operating nuclear plant sites.

Senior Vice President, Nuclear Generation Development and Construction

Is responsible for matters relating to receiving, assessing and, as appropriate, reporting to the NRC defects and noncompliances related to nuclear safety for TVA's nuclear construction sites.

Concerns Resolution Program Staff, Nuclear Power Group

Receives differing views from employees at TVA's operating nuclear plants either:
- On referral, after line management and the employee have been unable to resolve the issues, or
- Directly, if the employee believes that pursuit of the issues with line management would be ineffective.
May receive and act upon concerns or differing views that are made in confidence or anonymously.
Executes a confidentiality understanding at the request of the employee.
Provides its findings to the responsible organization.
Notifies employees of investigation findings and corrective actions.
Refers to the Inspector General:
- Alleged violations of law and employee conduct regulations, including allegations of reprisal.
- Allegations of waste, fraud, and abuse.
- Other matters within the Inspector General's investigative jurisdiction.
Provides information to and, as appropriate, consults with the Human Resources, Health & Safety, on all differing views which raise issues of occupational health and safety.
Provides governance and oversight of contractor Concerns Resolution Programs.

Concerns Resolution Program Staff, Nuclear Generation Development and Construction

Receives differing views from employees at TVA's nuclear plant construction sites either:
- On referral, after line management and the employee have been unable to resolve the issues, or
- Directly, if the employee believes that pursuit of the issues with line management would be ineffective.
May receive and act upon concerns or differing views that are made in confidence or anonymously.
Executes a confidentiality understanding at the request of the employee. Provides its findings to the responsible organization.
Notifies employees of investigation findings and corrective actions.
Refers to the Inspector General:
- Alleged violations of law and employee conduct regulations, including allegations of reprisal.
- Allegations of waste, fraud, and abuse.
- Other matters within the Inspector General's investigative jurisdiction.
Provides information to and, as appropriate, consults with the Human Resources, Health & Safety, on all differing views which raise issues of occupational health and safety.
Provides governance and oversight of contractor Concerns Resolution Programs.

Human Resources, Health & Safety

Represents the Designated Agency Safety and Health Official in matters involving differing views on occupational health and safety issues.
Receives, investigates, and provides for resolution of differing views on issues of occupational health and safety associated with TVA activities.
May receive differing views:
- On referral, after line management and the employee have been unable to resolve the issue, or
- Directly, if the employee believes that pursuit of the issue with line management would be ineffective.
May receive and act upon differing views made in confidence or anonymously.
Maintains confidentiality at the request of the employee.
Provides follow-up reports with findings and recommendations both to the employee and the responsible organization.
Monitors implementation of recommendations.
Makes recommendations to the appropriate corporate officer where further action by the responsible organization is deemed necessary.
Refers reports of reprisal to the Inspector General for investigation and, as requested, assists in the health and safety aspects of such investigations.
Refers reports of nuclear safety issues to TVA's Nuclear Power Group or to Nuclear Generation Development and Construction, as appropriate, for investigation and, as requested, assists with the occupational health and safety aspects of such investigations.

Office of the Inspector General

Receives and as the Office of the Inspector General determines appropriate investigates:
- Allegations of known or suspected violations of laws, regulations, or TVA policies and procedures.
- Concerns about the efficiency and economy of TVA programs and operations, including allegations of mismanagement, waste, fraud, and abuse.
- Allegations of reprisal by superiors or coworkers for expression of differing views.
May receive allegations in confidence or anonymously.
As appropriate, consults with and provides information to Human Resources, Health & Safety, on occupational health and safety issues.
As appropriate, consults with and provides information to TVA's Nuclear Power Group or to Nuclear Generation Development and Construction on nuclear safety issues.

President and Chief Executive Officer

Reviews and acts upon views expressed by employees to management that have not been resolved to the satisfaction of the employee.

RESOURCES

Human Resource Representatives
Managers/Supervisors
Concerns Resolution Program Staff, Nuclear Power Group
Concerns Resolution Program Staff, Nuclear Generation Development and Construction
Human Resources, Health & Safety
Office of the Inspector General

COMMUNICATIONS
PRACTICE 5

Expressing Concerns and Differing Views

Last Revised 06/08