ML17306A640

Forwards Two Memos Issued to Util Employees & Contract Personnel Re Problem Identification,Problem Resolution & Regulatory Interface,In Response to NRC Concerns.Memo Missing from Util

ML17306A640
Person / Time
Site:	Palo Verde
Issue date:	04/04/1992
From:	James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-02133-JML-T, 102-2133-JML-T, NUDOCS 9204150009
Download: ML17306A640 (14)

Text

ACCELERATED ISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9204150009 DOC.DATE: 92/04/04 NOTARIZED:

NO DOCKET 4YT FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION LEVINE,J.M.

Arizona Public Service Co.

(formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

I

SUBJECT:

Forwards two memos issued to util employees

& contract personnel re problem identification, problem resolution regulatory interface, in response to NRC concerns. Memo missing from util 920225 ltr.

DISTRIBUTION CODE:

A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal:

General Distribution NOTES:STANDARDIZED PLANT Standardized plant.

Standardized plant.

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05000528 05000529 05000530 D

RECIPIENT ID CODE/NAME PD5 LA TRAMMELL,C INTERNAL: ACRS NRR/DET/ESGB NRR/DST 8E2 NRR/DST/SICB8H7 NUDOCS-ABSTRACT OGC/HDS 1 RES/DSIR/EIB EXTERNAL: NRC PDR

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1 RECIPIENT ID CODE/NAME PD5 PD THOMPSON,M NRR/DET/ECMB 7D NRR/DOEA/OTSB11 NRR/DST/SELB 7E NRR/DST/SRXB 8E OC/LFMB~~

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NOTE TO ALL"RIDS" RECIPIENTS:

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PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEED! pq TOTAL NUMBER OF COPIES REQUIRED:

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ENCL

JAMES M. LEVINE VICE PRESIDENT NUCLEAR PRODUCTION Arizona Public Service Company PALO VERDE NUCLEAR GENERATING STATION P.O. BOX 52034

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PMOENIX.ARIZONA85072-2034 102-02133-JNL/TRB/KR April 4, 1992 U.

S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station Pl-37 Washington, D.C.

20555

Reference:

Letter dated February 25,

1992, from William F.

Conway, Executive Vice President, Nuclear, Arizona Public Service Company, to Mr. John B. Martin, Regional Administrator, NRC Region V.

Dear Sirs:

Subj ect:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1,2, and 3

Docket No.

STN 50-528/529/530 ATTACHMENT 2 TO RESPONSE TO NRC CONCERN File 92-019-026 Attached please find Attachment 2, consisting of two memoranda issued to Palo Verde employees and contract personnel and to supervisors and managers'his attachment was missing from your copy of the referenced letter.

If you have any questions, please contact T. R. Bradish, Compliance Manager, at (602) 393-5421.

Very truly yours, JML/TRB/KR Attachment cc:

W. F.

Conway J.

B. Martin D. H.

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ATTACHMENT2 MEMORANDAISSUED TO PALO VERDE EMPLOYEES AND CONTRACT PERSONNEL AND TO SUPERVISORS AND MANAGERS

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21t.OOCA Aev. 2 SO 4190 txOI21 (BX/500) r 0

Arhnna PubHc Service Company COMPANY CORRESPONDENCE lD<<,'02-02117-WFC/TRB/KR DATE:

February 26, 1992 TO:

sta. >>:

Ext.:

Palo Verde Employees and Contract Personnel FROM:

sta. <<

Ext.

W. F.

Conway 9082 81-3900 92-056-026

'ROBLEM IDENTIFICATION, PROBLEM RESOLUTION, AND REGULATORY INTERFACE Employees at Palo Verde have a personal responsibility to report problems or abnormal conditions that may come to their attention.

This is in line with our STANDARDS & EXPECTATIONS. If you are concerned about a problem which could adversely affect nuclear safety, quality, or plant operability; or, if you are concerned about ANY problem which could adversely affect any aspect of our performance, I expect you to -let'y'our supervisor or foreman know of your concern AND your recommendation to correct it. I expect your supervisor or foreman to. listen;" to take the action(s) necessaxy to resolve.your

concein, to,.escalate xt..to. management",ffequ'ixed"'for, resolution, and to report back to"'you on the"resolution.'f this normal process of communication and action does not resolve your concern; if action was taken but did not resolve the problem to your satisfaction; or, if for some particular reason you feel you cannot go to your supervisor or foreman, I expect and invite you to contact the next level in your management chain or our Employee Concerns staff at 944-5444 or extension 6701.

As

always, you may choose to discuss your concerns with the Nuclear Regulatory Commission (NRC).

You may always speak freely and privately with the NRC without fear of retribution, retaliation, or termination.

I would invite you to give your foreman, supervisor,

manager, or Employee Concerns an opportunity to resolve your concern prior to discussing it with the NRC.

However, APS will not take any action against any individual for bringing concerns to the NRC or for any communication with the NRC.

When questioned by an NRC inspector, I expect employees to be totally honest and candid.

Do not attempt to hide problems or act as though they are not important.

If you are asked questions that are not in your area of responsibility, you should tell the NRC that it is not your area.

If, ott the other hand, you do not know the answer to a question, even if in your area, do not speculate.

Tell the NRC inspector that you do not know the answer.

In other

words, be completely honest,.

Whenever

possible, tell the NRC inspector where to get the information or get back to the NRC inspector later with the answer.

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Memo to Palo Verde Employees and Contract Personnel Page 2

APS management has the responsibility to ensure that the NRC receives accurate and complete information regarding plant operations. 't is important that APS management be informed whenever any employee or supervisor, during the course of normal work activities, communicates information on significant technical i.ssues to the NRC on behalf of APS.

The complex nature of the operation of Palo Verde requires careful coordination of communications, commitments, and allocation of resources, to ensure that all of the technical issues that arise receive the appropriate level of detailed and comprehensive review.

Xf an NRC representative requests information, from you, you should inform your supervisor, who in turn will inform the Licensing or Compliance Department.

Our Licensing and Compliance Departments are established to assist us in coordinating our commitments and responses to the NRC.

These departments will work with all the plant personnel to ensure that the information provided by APS is accurate and complete, reflects the input of the best expertise available, and does not unknowingly have a significant impact on other areas of plant operati.on.

Documentation of communications with the NRC will accomplish the following:

1)

APS'osition on a regulatory issue will be clearly understood by all the parties involved.

2)

APS management wi11 be

~ aware of issues raised by the NRC representative and of APS'ommitments.

3)

Clear documentation will aid APS management in defining the scope of actions required to meet our goals, objectives, and commitments.

Of course, you are neither expected nor requested to document or report that you have carried a concern privately to the NRC.

The daily interface with the NRC by persons on behalf of APS is to be distinguished from occasions when individuals discuss concerns privately with the NRC.

l expect each employee to vigorously pursue resolution of problems.

T expect management to be receptive and responsive to employees'oncerns, and to report the actions taken in response to these concerns.

1 also expect that open and thorough communication with the NRC shall be maintained.

Accordingly, APS seeks to maintain an environment in which those having any concerns will report them without fear of any retaliation.

APS will not tolerate any acts of harassment, intimidation, discrimination, or any other retaliation against any employee for identifying any concern to supervision, management, Employee

Concerns, or the NRC; such acts are against the law.

WFC/TRB/KR

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212~A Rev. 2 99 d1 90.900121 tttX1$001 Arizona Public Service Company COMPANY CORRESPONDENCE 102-02118-MFC/TRB/KR February 26, -'1992 Palo Verde Supervisors and Managers sta. ¹:

Ext.:

W. F.

Conway st¹, ¹ 9Q82 81-39QQ 92-056-026

'ROBLEM IDENTIFICATION, PROBLEM RESOLUTION, AND REGULATORY INTERFACE A recent event prompts me to remind you that employees at Palo Verde have a

personal responsibility to report problems" or abnormal, conditions that may come to their attention.

This is in line with our STANDARDS & EXPECTATIONS.

We work in a very demanding technology and each employee must serve as an extra pair of "eyes and ears" to assure that things are done properly at Palo Verde.

I understand that a recent Nuclear Regulatory Commission (NRC) investigation centered around allegations that employees were. intimidated by supervisors.

It appears th'at a Palo Verde supervisor did question his employees as to whether they had spoken to NRC personnel,

'and if so, what they had said to the NRC.

Even though the intent was not to intimidate, some of the employees felt intimidated;'anagement

'must be sensitive to the potential perception of employees that such questioning may be intended to discourage openness with the NRC.

We

~de end on our employees to report such problems so that we can take prompt corrective action."

When an employee comes to you with a concern and a

recommendation to correct it, I" expect you to "listen, to take the action(s) necessary to-resolve 'the concern, to escalate it to management if required for resolution, and to report back to the employee on the resolution.

Every supervisor and manager should ensure that employees understand the difference between APS'eed to assure accurate and complete communication with the NRC by persons representing APS concerning technical issues and every employee's right to discuss concerns privately with the NRC.

For the

former, APS management needs to coordinate communications with the NRC.

For the l'atter, the piivate communication between'the employee and the NRC must be respected.

I expect each employee to vigorously pursue resolution of problems.

I expect management to be receptive and responsive to employees'oncerns, and to report the actions taken in response to these concerns.

I also expect that open and thorough communication with the NRC shall be maintained.

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Memo to Palo Uerde Supervisors and Managers Page 2

Accordingly, APS will seek to maintain an environment in which those having any concerns will report them without fear of any retaliation.

APS will not tolerate any 'acts of harassment, intimidation, discrimination, or any other retaliation against any employee for identifying any concern to supervision, management, Employee Concerns, or the NRC; such acts are against the law.

WFC/TRB/KR

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