ML17306A514

Forwards DOL000483, Employee Concerns Program, Detailing Steps Taken by Util to Assure That Employees & Contractors Know That Mgt Supports Identification & Resolution of Safety Concerns.Rev 0 to 01PR-0QQ02 Also Encl

ML17306A514
Person / Time
Site:	Palo Verde
Issue date:	02/25/1992
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML17306A515	List: ML17306A514 ML17306A516 ML17306A518
References
102-02116-WFC-T, 102-2116-WFC-T, NUDOCS 9203090262
Download: ML17306A514 (25)

Text

ACCELERATED DISTRIBUTION DEMONSTPATION SYSTEM DOCKET 05000528 05000529 05000530 REGULAIRY INFORMATION DISTRIBUTISYSTEM (RIDE)

ACCESSION NBR:9203090262 DOC.DATE: 92/02/25 NOTARIZED:

NO FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi AUTH.NAME AUTHOR AFFILIATION CONWAYFW.F.

Arizona Public Service Co.

(formerly Arizona Nuclear Power RECZP.NAME RECIPIENT AFFILIATION MARTIN,J.B.

Region 5 (Post 820201)

SUBJECT:

Forwards DOL000483, "Employee Concerns Program," detailing steps taken by util to assure that employees

& contractors know that mgt supports identification

& resolution of safety concerns.Rev 0 to 01PR-OQQ02 also encl.

DISTRIBUTION CODE:

ZEOZD COPIES RECEIVED:LTR I

ENCL /

SIZE:

/P WpR/

TITLE: General (50 Dkt)-Insp Rept/Notice. of Violation Response NOTES:STANDARDIZED PLANT Standardized plant.

Standardized plant.

05000528 05000529 05000530 RECIPIENT ZD CODE/NAME PD5 PD THOMPSONFM INTERNAL: ACRS AEOD/DEIZB DEDRO NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 0

G FZL 02 EXTERNAL: EG&G/BRYCEFJ.H.

NSIC COPIES LTTR ENCL 1

1 1

1 2

2 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 RECIPIENT ID CODE/NAME TRAMMELL,C AEOD AEOD/DSP/TPAB NRR HARBUCK,C.

NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/DST/DZR 8E2 NUDOCS-ABSTRACT OGC/HDS1 RGN5 FILE 01 NRC PDR COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 1

1 NOTES:

1 1

NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDI TOTAL NUMBER OF COPIES REQUIRED:

LTTR 26 ENCL 26

I f

l I

Arizona Public Service Company P.O. BOX 53999

~

PHOENIX. ARIZONA8507Z-3999 WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR 102-02116-MFC/TRB/KR February 25, 1992 Wl

~ C7~Pl Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368

~ ~

Reference:

Letter dated January 31, 1992, from Roy P. Zimmerman, Director, Division of Reactor Safety and Projects, NRC Region V, to Mr. William F. Conway, Executive Vice President, Nuclear, Arizona Public Service Company

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 RESPONSE TO NRC CONCERN File: 92-019-026 The purpose of this letter is to describe steps taken by Arizona Public Service Company to assure that employees and contractors know that management supports the identification and resolution of safety concerns.

Employees at Palo Verde have the responsibility to report problems or abnormal conditions that come to their attention to their supervisor or foreman.

Equally, they have the freedom to bring their concerns to the NRC without fear of negative repercussion.

These two means of problem identification are essential aspects of the operation of Palo Verde.

From initialorientation training to annual site access retraining, Palo Verde employees and contractors are apprised of their responsibility to identify problems to their supervisors and are reminded of their freedom to discuss their concerns with the NRC without fear of retribution, retaliation, or termination.

Our STANDARDS 8 EXPECTATIONS, selected orientation and training material, and past memoranda which convey this message are provided in Attachment 1.

~ D':~

PDR 2~" 9>0-a5 PPDR ADOCK 05000528 PDR

~z 0/

Letter to J. B. Martin Page 2 102-021 16-WFC/TRB/KR I have taken additional steps to ensure that employees and contractors at Palo Verde do not have the misperception that we discourage problem identification or that they are not free to speak openly or privately with the NRC.

I have issued two memoran'da, one to Palo Verde employees and contract personnel, and the other to supervisors and managers, reminding them ofmy expectations concerning problem identification, problem resolution, regulatory interface, and the sensitivity that management and supervision should have to potential employee perceptions.

These memoranda are provided in.

Should you have any questions regarding this matter, please contact me.

Sincerely, WFC/TRB/KR Attachments:

1.

STANDARDS 8 EXPECTATIONS, selected orientation and training material, and past memoranda 2.

Two memoranda issued to Palo Verde employees and contract personnel and to supervisors and managers cc:

D. H. Coe

ATTACHMENT1 STANDARDS & EXPECTATIONS, SELECTED ORIENTATION AND TRAINING MATERIAL,AND PAST MEMORANDA

l

ATTACHMENT1 CONTENTS MEMORANDUMTO PALO.VERDE EMPLOYEES JUNE 8, 1989 - NOTICE ON EMPLOYEE NUCLEAR SAFETY CONCERNS QUALITYTALKS - QA HOT LINE - JULY 14, 1989 MEMORANDUMTO ALLPALO VERDE EMPLOYEES SEPTEMBER 21, 1989 - NOTICE ON PALO VERDE EMPLOYEE CONCERNS EMPLOYEE CONCERNS PROGRAM VIDEO SCRIPT SEPTEMBER 27, 1989 MEMORANDUMTO ALLPALO VERDE EMPLOYEES OCTOBER 13, 1989 - POLICY STATEMENT MEMORANDUMTO CONTRACT COMPANIES PROVIDING SERVICES/CONTRACT LABOR TO PVNGS OCTOBER 25, 1989 - PVNGS POLICY ON EMPLOYEE COMMUNICATIONS& CONCERNS 01PR-OQQ02 - EMPLOYEE CONCERNS PROGRAM POLICY REVISION 0 - DECEMBER 1, 1989 MEMORANDUMTO PALO VERDE EMPLOYEES FEBRUARY 22, 1990 - PROBLEM IDENTIFICATION PALO VERDE'S NEW ERA - SEPTEMBER 1990 STANDARDS AND EXPECTATIONS - APRIL 9, 1991 YOU AND YOUR COMPANY HANDBOOK-AUGUST 1991 EMPLOYEE CONCERNS PROGRAM PAMPHLET EMPLOYEE CONCERNS PROGRAM POSTER POSTED THROUGHOUT PVNGS SITE ACCESS TRAINING HANDOUT SECTION C: QUALITYASSURANCE I

SITE ACCESS TRAINING LESSON PLANS NGA01-04-RC-003 QUALITYASSURANCE NGA01-04-RC-008 RADIATIONPROTECTION NGA02-09-RC-001 SITE ACCESS RETRAINING

Arizona PubHc Service Company COMPANY CORRESPONDENCE ID<<

102-01295-WFC/TDS/PJC DATE:

June 8,

1 989 TO.

Sta Ext <<

Palo Verde Employees

FROM, sta Ext <<

FILE'UBJECT W.

F.

Conway 9012 81-3900 89-003-726 Notice on Employee Nuclear Safety Concerns Nuclear safety is our foremost concern at Palo Verde.

Each employee is responsible to maintain nuclear safety and to immediately report safety concerns.

To assist us in raising, addressing, and resolving nuclear safety concerns, I have established the policy delineated in the attached notice.

This policy applies to management, supervisory, and working-level personnel, including contract employees.

Harassment, intimidation, discrimination, or any other form of retaliation against persons who raise safety concerns will not be tolerated.

WFC/TDS/PJC/kj Attachment

I

(

i

NOTICE ON EMPLOYEE NUCLEAR SAFETY CONCERNS Arizona Public Service Company (APS) is committed to nu-clear safety at Palo Verde Nuclear Generating Station and throughout the corporate nuclear energy program.

APS as a

whole and each employee are responsible for maintaining nuclear safety.

This policy applies to management, super-

visory, and working-level personnel, including contractors and their employees.

It is the policy of APS to encourage employees with nuclear safety concerns to bring them for-ward so that they can be investigated and addres-sed.

It is the duty of any employee who has a

safety concern to report it immediately.

You should ordinarily report nuclear safety concerns to your supervisor, who will assist you in selec-ting and preparing the most effec'.ive method for getting your concern resolved, such as prepara-tion of a Nonconformance Report (NCR), Procedure Change Request (PCR), or other appropriate docu-ments.

2.

If you are.uncertain where to report a concern, or do not feel that your concern will be ade-quately resolved through ordinary channels, APS has established nuclear safety concern programs to assure that your concerns will be addressed.

Under these

programs, you may report nuclear safety conce'ms directly to the Quality Assurance Hot Line Program (944-5444).

It is important that you provide sufficient information so that your concern can be clearly identified and inv'estigated.

If you have a nu-clear safety concern but desire to have your identity kept confidential, your identity will be protected.

Although employees have a duty to report their safMy concerns to APS, concerns may also be brought directly to the Nuclear Regula-tion Commission.

3.

Concerns reported under nuclear safety concerns programs will be investigated, resolved and docu-mented.

In cases where action is required to correct a reported condition, the completion of that action will be verified.

A description of the actions taken to address the concern will be available to the individual who raised the con-cern.

H

Employee reporting of nuclear safety concerns is important to the safe and reliable operation of Palo Verde Nuclear Generating Station.

Only if these concerns are known can they be investigated and corrected.

Accordingly, APS seeks to main-tain an environment in which those having nuclear safety concerns will report them without fear of any retaliation.

Arizona Public Service Company will not tolerate harassment, intimidation, dis-crimination, or any other retaliation against persons raising safety concerns.

If you believe that you have been discriminated or retaliated against because of safety concerns, you should immediately report this fact directly to the appropriate site personnel (listed above).

William F.

Conway Executive Vice Pre i ent '- Nuclear

II

~g o

~ev ~ y t sot 1st

~ 'o

~ 1to 0

ee1

~ t ~

~

~ e s

Dot ooos5>

~dna PubBc Savice Company PALO VERDE NUCLEAR GENERATING STATION Mhaox essod

~ ~hlx. AssccwA L50Q40$ 4 QQLLITf CLZXS QA Hot Line Hotlfnes 044->~

July lId, i%69 lIaek 0 27 4 26 The Quality Inveetfgatfone Sectfon has the reeponefbilfty d'or implementing and documenting the QA Hot Line Programs This Program includes

<<dmfnfstcrfng the QA Hot Line telephone, conducting quality fntervfesse, and fnvestfgatfosl concerna antercd into the QA Rot Line by AS employeee, plant management, or agencies such aa the SEC.

Concerns fdcntfffed vfa the above Isentfoned alethode are documented and entered into QA Hot Line Program for tracking.

In some caeees the concern clay bc resolved by rafcrrfng a

concerned individual to other established channels (e.g.,

chain of command), if agreed upon.

Through the lot I.fne Progra~,

fndfvfduale can talk dfrcctly vith an ASS Corporate Qualfty Assurance Xnginner to explain concerns and ask for as sf s tance.

The Hot 1tne 4 ~ sptttdtesllp destdnsd to help so)ve ~salsa and ~eualft ptobleat at tns pele Verde Nuclear Ceneratfng Station.

A concerned fndfvfdual should uee eetablf abed Procedures to brfnj potential problems to light.

The individual should notify their supervisor or foraaan of safetylqualfty problemea If the norsssal channels have been trfed and they don't work, you should ssee the Hot Line Program.

To uee the Hot Xtns, eall 944 S444 ~an talma.

When a

concerned indfvfdual contact the Quality Investigations Section through any o

tbe aforementioned Rot Linc Program Iscthode s

@he concerned fndfvfdual needl o

gfvc a

complete description of the problem.

The Quality Invaatfgatfonc Section aeede to knous ae sssuch as Poerfbles the follossfngs left Number Specfffc Location System or Procedure Activity in Process Ccnetructfon Startup or Operations Hov QA Investigations Can Learn More about the Problem Rsather You Have Iotfffad Your Supervisor or forasaan Qualfty and/or safety concerns are ravfeved and enaiysed ao that potential problems are identified, dfepoaftfoned, and zesolvedo Investigations era baaed on ob)ectfve evidence gathered through aethode such ae personnel fntervfava, revfevs or plant designs COnetruCtions Startup or operations 1ocssmentatfonj ongfneerfnj ana}yeeed and determfnatfon of pertfnent regulatory requfrementao The QA Znveetfgatfone Section takes every action Possible to acfntafn confidentiality of individuals who present concerns.

0

tlVV Pl hei VA III~ I L. L~ I IVhv

~ 54%-ev

~

~ ~vv ~

~

+I@i

>S I ~ Q tp f+

lp

/

t ia iportent that the concerned indfvidual late tha Quality Znveatfgations Section to report results back to than.

Zf you chooaa to remain totally anonymous One

~u can can ca11 back to check en tha atatua ot the concern (a.g.,

vfa Sot Line

'fa]aphona)

~

Jnvaatiga fone ere documented in Quality Invaatfgati on Report.

Tha concerned indfvfdual vill ba aotfffado shan

yoaafbla, Ln writing aa to results of tha lnvaatfiatfon.

tie cfoul Sactf on ggfntafna 0~~0~

All. Quality Xnvaatfgatf era eubcitted to the Dfrector Corporate qg]qg A quarter]y rcport vfD nasally ba provided to eucasarfae the otatus of OA Rot Lfna

concerns, Qualfty Xntarviau activities, end fnvastf gatfon results.

Thfs rcport fa fasuad to tha Dfractor, Corporate QA/QC vfth zinieum dfatrfbutfon oi the report to tha executive Vice President, Q. y, Corlay, AN.

All concerns brought to the attention of the Hot Ifna Program vfll ba pursued.

>a Qua]fty Xnvastfgationa Section villaaka avery effort to resolve iaouaa zs Qufck)y end thoroughly aa poaafbla.

1f you have a quality or aafaty concern ffrat tall your auparvf aor or foreman Tf tha problem ia sot resolved f con tact tha Hot jjyfna at 944 $444.

2I2.gaga 4~i 2 C0

~>&9K:2'B<RK'rizona Public Service Company COMPANY CORRESPONDENCE ID 4:

DATE:

TO:

SIa. 4:

Ext.:

022-01266/WFC/BEB/TCS/CWJ September 21, 1989 All Palo Verde Employees Various Various W. F. Conway sI>'012 81-3900 FIL~:

89.003.726 jI9 OO'P RO/

sUaJ~DT-'OTICE ON PALO VERDE EMPLOYEE CONCERNS (Replaces Memo ¹102-01295-WFC/TDS/P JC)

'89 OCT 27 A9:24 Quality and safety are our primary concerns at Palo Verde.

Each employee is responsible to maintain quality and safety and to immediately report concerns which could have an effect on the. safe and reliable operation of the Station.

Moreover, we solicit the identification of any concern which may adversely affect the performance of our operations so that they may be resolved promptly.

To assist us in identifying, addressing, and resolving these

concerns, I have established the policy delineated in the attached notice.

WFC/BEB/TCS/CWJ:kid Attachment

i 1

PVNGS POLICY ON EMPLOYEE COMKNICATIONS E

CONCERNS APS PERSONNEL AT ALL LEVELS ARE ENCOURAGED AND EXPECTED TO COMMUNICATE IN AN ACTIVE AND OPEN MANNER SUCH THAT KNOWN PROBLEMS hHICH MAY AFFECT ANY ASPECT OF OUR PERFORMANCE ARE QUICKLY IDENTIFIED AND SATISFACTORILY RESOLVED.

THIS POLICY APPLIES TO ALL EMPLOYEES INCLUDING MANAGEMENT AND SUPERVISION, CONTRACTORS, AhD THEIR EMPLOYEES.

ARIZONA PUBLIC SERVICE COMPANY (APS)

IS COMMITTED TO QUALITY AND SAFETY IN THE OPERATION OF THE PALO VERDE NUCLEAR GENERATING STATION AND THROUGHOUT THE APS NUCLEAR GENERATING PROGRAMS APS AS A WHOLE, AhD EACH EMPLOYEE, IS RESPONSIBLE FOR ASSURING THAT THIS COMMITMENT IS MET.

CONCERNS WHICH COULD HAVE AN ADVERSE IMPACT ON THE SAFE AND RELIABLE OPERATION OF THE STATION OR h'HICH MAY ADVERSELY AFFECT OUR NUCLEAR OPERATIONS MUST BE REPORTED'ROMPTLY AND BE ADEQUATELY RESOLVED.

EACH SUPERVISOR AND MANAGER SHOULD ACTIVELY SOLICIT FROM THEIR EMPLOYEES ANY KNOWN SAFETY CONCERN AND PROBLEM.

SUPERVISORS AhD MANAGERS ARE RESPONSIBLE TO THOROUGHLY REVIEh'DENTIFIED SAFETY CONCERNS AND EMPLOYEE

PROBLEMS, OBTAIN EFFECTIVE CORRECTIVE ACTION WHERE APPROPRIATE, AND FEEDBACK TO THE EMPLOYEE THE RESULTS OF THEIR ACTIONS.

IF THE EMPLOYEE IS NOT SATISFIED WITH THE RESULTS PRESENTED, SUPERVISION SHOULD ENCOURAGE AhD, IF REQUESTED, ASSIST THE EMPLOYEE IN ESCALATING HIS CONCERN OR PROBLEM TO THE NEXT HIGHER LEVEL OF APS SUPERVISION.

EACH EMPLOYEE IS EXPECTED TO BRING THEIR SAFETY CONCERNS AND PROBLEMS TO THE ATTENTION OF THEIR IMMEDIATE SUPERVISOR.

SHOULD EMPLOYEES HAVE A REASON TO FEEL THAT THEIR SAFETY CONCERNS OR PROBLEMS HAVE NOT BEEN OR WILL NOT BE ADEQUATELY ADDRESSED THROUGH THE USE OF THESE N01ufAL

CHANNELS, THEY SHOULD REPORT THEIR CONCERN OR PROBLEM TO THE EMPLOYEE CONCERNS PROGRAM.

THERE ARE SEVERAL WAYS TO DO THIS:

1.

CALL THE EMPLOYEE CONCERNS OFFICE EXTENSION 6701; 2.

VISIT THE EMPLOYEE CONCERNS OFFICE NORTH ANNEX (ROOM 227);

3 ~

CALL THE EMPLOYEE CONCERNS DIRECT LINE - 944-5444; 4.

COMPLETE AN EMPLOYEE CONCERN DISCLOSURE FORM WHEN EXITING; 5.

HAVE A PERSONAL INTERVIEW WHEN EXITING.

WHEN REPORTING A

CONCERN TO THE EMPLOYEE CONCERNS PROGRAM EMPLOYEES MAY REQUEST CONFIDENTIALITY, EVERY EFFORT WILL BE MADE NOT TO DISCLOSE THEIR IDENTITY OUTSIDE THE EMPLOYEE CONCERNS PROGRAM.

CONCERNS REPORTED UNDER THE EMPLOYEE CONCERNS PROGRAM WILL BE INVESTIGATED, RESOLVED'hD DOCUMENTED.

IN CASES WHERE ACTION IS REQUIRED TO CORRECT A

REPORTED CONDITION, THE COMPLETION OF THE ACTION WILL BE VERIFIED.

A DESCRIPTION OF THE ACTIONS TAKEN TO ADDRESS THE CONCERN WILL BE AVAILABLE TO THE EMPLOYEE WHO RAISED THE CONCERN.

ALTHOUGH EMPLOYEES HAVE A DUTY TO REPORT THEIR CONCERNS TO APS, CONCERNS MAY ALSO'E IDENTIFIED DIRECTLY TO THE NUCLEAR REGULATORY COMMISSION, REGION V

(415) 943-3700, OR SITE RESIDENT (602) 393-3737.

EMPLOYEES ARE PROTECTED BY LAW AGAINST HARASSMENT, INTIMIDATION OR RETALIATION FOR IDENTIFYING NUCLEAR SAFETY CONCERNS.

THEIR RIGHTS IN THIS REGARD AS WELL AS OTHER RELEVANT INFORYiATION ARE SUMMARIZED IN NRC FORM 3

WHICH IS POSTED WIDELY THROUGHOUT PVKGS AND OTHER FACILITIES SUPPORTING OUR NUCLEAR OPERATIONS.

MOREOVER~

ARIZONA PUBLIC SERVICE COMPANY WILL NOT TOLERATE HARASSMENT, INTIMIDATION'ISCRIMINATIONOR OTHER ACTS OF RETALIATION AGAINST ANY EMPLOYEE FOR IDENTIFYING ANY CONCERN TO EITHER SUPERVISION, MANAGEMENT, THE EMPLOYEE CONCERNS

PROGRAM, OR THE NRC.

IF AN EMPLOYEE BELIEVES THEY HAVE BEEN OR ARE

BEING, DISCRIMINATED AGAINST BECAUSE OF IDENTIFYING A

CONCERN, THEY SHOULD IMMEDIATELYREPORT THIS DIRECTLY TO THE EMPLOYEE CONCERNS PROGRAM ON SITE.

W. F.

C WAY EXECUTIVE VIC RESIDENT NUCLEAR