ML20072B865

Responds to Request for Info Re Statements Made by PVNGS Spokesman,M Fallon & Responds to Request for Info Re Allegation That Fallon Comments Might Discourage PVNGS Employees from Raising Concerns to NRC

ML20072B865
Person / Time
Site:	Palo Verde
Issue date:	05/05/1994
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE)
Shared Package
ML20072B531	List: ML20072B790 ML20072B849 ML20072B865
References
102-02943-WFC-A, 102-2943-WFC-A, NUDOCS 9408160282
Download: ML20072B865 (54)

Text

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Arizona Public Service Company P O BOX $3999

• PHOENIX ARIZONA 85072 3999 wwAM F CONWAY 102-02943-WFC/ACR

" " 0fl%"*"" May 5,1994 Mr. James Ueberman, Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

NRC Let'er dated March 8,1994 from J. Lieberman, NRC, to W. F. Conway, APS

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1,2, and 3 Docket Nos. STN 50-528/529/530 File: 94-056-026: 94-003-350 This letter responds to your request for information (Referenced letter) regarding statements made by a PVNGS spokesman, Mr. Mark Fallon, that were quoted in a West Vallev View article dated January 26,1994. This letter also responds to your request for information regarding an allegation that Mr. Fallon's comments might discourage PVNGS employees from raising concerns to the NRC.

As described more fully below, APS believes that the article accurately reflected the substance of Mr. Fallon's comments. APS further believes that, taken in context, Mr. Fallon's comments were appropriate and were neither intended to discourage employees from raising concerns to the NRC nor would they tend to have such an effect.

APS notes that it encourages its employees to first raise their concerns with their line management or through other internal means because this is the most effective way for concerns to be promptly addressed and resolved. However, APS emphasizes to its employees that they should always feel free to raise their concerns with the NRC.

Mr. Fallon's Statements The statements quoted in the January 26,1994 West Vallev View article resulted from a telephone conversation between Mr. Fallon and Mr. Dan Nowicki, a reporter. Mr. Fallon speaks with Mr. Nowicki periodically (typically three times per week), and on the occasion of this call, Mr. Nowicki inquired if Mr. Fallon had any comment regarding the National 94o8160282 940812 PDR ADOCK 05000528 P PDR y ju 3

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1 Mr. James Lieberman, Director Office of Investigations U.S. Nuclear Regulatory Commission Page 2  ;

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Whistleblower Center's announcement that it was opening a " regional office" in Buckeye, Arizona (near PVNGS). Mr. Fallon noted that APS was taking a number of steps to foster an atmosphere at PVNGS in which employees feel free to raise concerns. He further indicated that APS expected its efforts to be effective, and therefore, he hoped that employees would not feel the need to go to the Buckeye center.

Mr. Fallon's statements were not intended to discourage employees from communicating with the Buckeye center. As noted in the article, Mr. Fallon's message to the reporter was that he expected that APS' revised programs would be effective and "should leave the staff of the Buckeye center with little to do." Mr. Fallon merely indicated that APS' goal was that employees would be satisfied with the effectiveness of APS' internal mechanisms for resolving concerns, and therefore, they would not feel the need to go to an external organization such as the Buckeye center.

APS also recognizes that its employees should always feel free to raise concerns with the NRC. Mr. Fallon's comments did not make any reference to the NRC, and he did not make any statements intended to discourage employees from raising concerns to the NRC. Mr. Fallon's comments that the Buckeye Center will hopefully have little to do are simply irrelevant to APS' consistent message to its employees that they should feel free to raise concerns with the NRC without fear of retaliation.

APS Actions To Make Clear to Employees That They Should Feel Free To Raise Concerns With ths.NRC Without Fear of Retallation Consistent with the guidance of NRC Form 3, APS encourages all employees first to raise safety concerns with their supervision or management. APS believes that supervision and management personnel are in the best first line position to address and resolve concerns promptly and efficiently. Therefore, APS' goal is that all employees will feel free to raise concerns internally and that management will effectively resolve these concerns.

However, APS has consistently emphasized to its employees that they should feel completely free to bring their concerns to the NRC.

APS management has communicated its expectations through a variety of means. For example, on August 10,1993, APS' Chief Executive Officer, O. Mark DeMichele, issued an all hands memorandum, in which he emphasized his expectations that " employees should feel completely at ease to raise safety concerns" and " management has an

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I Mr. James Ueberman, Director )

Office of Invesf jations j U.S. Nuclear Regulatory Commission  ;

Page 3 i

absolute duty to listen attentively and respond appropriately." (See Enclosure 1). In ,

doing so, Mr. DeMichele also noted that "any employee has an absolute right to raise a l concern with the NRC without fear of retribution."

This message was also communicated in Safety Concerns All-Hands Meetings that were conducted by Mr. DeMichele, Corporate Counsel Nancy Loftin, and me on August 16 and 17,1993. In addition, I provided a written summary of some key questions and answers from these meetings in an October 1993 special edition of PVNGS' New Era employee news bulletin. (See Enclosure 2). This summary included the following Q&A:  !

O: Can we change the tendency to go straight to the NRC with safety concerns?

A: It's our desired state to have the company internally handle safety concerns so that people don't feel they need to go to the NRC with them. But, of course, an employee is always free to do so. j APS also has consistently reinforced the message that employees should feel free to go to the NRC in its employee training programs. In the quality assurance component of i APS' site access training, employees are instructed that their suggested flow path for l raising concerns is to first go to their supervisor, next APS' Employee Concerns Program, next APS management, and then the NRC. However, the lesson plan emphasizes: .

"*1mportant Note: THE EMPLOYEE CAN GO DIRECTLY TO THE NRC WITHOUT I FOLLOWING THE SUGGESTED FLOW PATH." (See Enclosure 3). The radiation protection (RP) component of APS' site access training emphasizes that employees not only have a responsibility to report violations of RP requirements to their supervisor or the NRC, but also have a responsibility to go to the NRC if they believe that APS has not

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corrected a violation. (See Enclosure 4). I i

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4 Mr. James erman, Director Office of Inv@estigations U.S. Nuclear Regulatory Commission Page 4

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~? APS has taken a number of aggressive actions over the last several mordhs in order to ddi .f assure..that there is an atmosphere at PVNGS in which employees are encouraged to I iggg [@EIo ncerns. A more detailed summary of these actions was provided in Mr. DeMichele's April 21,1994 letter to the NRC's Execuj

'Sp M nt '

hfa *' Operations, $. James M. Taylor. You have been previously provided a copy of this letter and its attachrnent. If you have any further questions regarding this response, please

. contact Mr. M Carter Rogers at (602) 340-4041.

' - 4 Sincerely,

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l ENCLOSURE 1 1

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Arizona Public Service Company P O. BOX 53999

• PHOENIX, ARIZONA 85072-3999 MARK De MICHELE cmis"E%ls cia August 10,1993 TO: All Palo Verde Employees FROM: Mark DeMichele Recently, there have been several press accounts of alleged inappropriate management responses to employees who have raised safety concerns. The gist of these accounts is that APS management tolerates,if not encourages, heavy-handed treatment of persons who raise safety concerns.

Just last week we learned that one of our supervisors, contrary to his earlier sworn statements, declined to hire a contractor employee because the candidate had previously raised safety concerns at Palo Verde and elsewhere.

This behavior will not be tolerated.

In light of this event, I think it is timely and vital to restate my expectations for how everyone at Palo Verde should address safety concerns.

Employees at Palo Verde who identify and report safety concerns perform an invaluable service to the company and to the public. The watchful eye of every employee is at the heart of the elaborate measures which assure safety of operations at Palo Verde each day. APS counts on all employees to do more than merely their assigned jobs with complete dedication and discipline. .We ask and expect that you all identify safety concerns to your supervisor; to alert us when tasks are not being performed in the manner required by the detailed procedures which govern almost every activity at Palo Verde; and to advise of any other problems which, because of your training and experience and your closeness to operations, you are uniquely positioned to recognize. Neither I nor anyone else on the APS management team look upon such activity negatively, rather it is viewed as a positive contribution.

We have recently initiated the " Hero" system to reward those who raise concerns and enable the company to more safely conduct its business.

Each Palo Verde employee should feel completely free to raise safety concerns directly with his or her supervisor. It is the responsibility of everj

All Palo Verde Employees i August 10,1993 Page 2 l

supervisor to listen carefully and then respond appropriately to the expressed concern; in fact,it is an essential element of each supervisor's job.

I would like to emphasize the special responsibility of the management chain of command-from first line supervision through senior management.  ;

This group has a special responsibility.to foster an atmosphere in which conscientious employees know that their concerns will be treated seriously and that they may be expressed without fear of retribution or other adverse consequences. Of course, we also have a formal employee concerns program if, for whatever reason, employees do not choose to raise their concerns with management and would rather do so in confidence or even anonymously. In addition, any APS employee has an absolute right to raise a concern with the NRC without fear of retribution. Regardless of the means chosen, all of us at every level have an overwhelming stake in assuring the free flow of information that may affect safe and reliable plant operation. I personally l i welcome open communication, not only because it contributes to safe plant operation but also because it makes good business sense.

I am communicating with each of you personally and directly so that this message is unmistakable and to assure that you understand the company's expectations as you perform your daily activities.

In closing, I want to reemphasize that unprofessional conduct on matters affecting nuclear safety has not and will nqt be tolerated. For their part, employees should feel completely at ease to raise safety concerns. For its part, management has an absolute duty to listen attentively and respond appropriately. Should there be any doubt as to my expectations in this regard, I expect each of you to discuss this matter directly with your supervision.

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ENCLOSURE 2 4

s j .is Nuclear, industrial & personal safety:

s 9 13 Top priority at Palo Verde n )1ny cy &cutwe Vce Resident William F Conway

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Safety is the number-one concern at Palo Verde. Ifyou to vour supervisor, mana of8cer of the company. ger or A /7 R have a safety concern, step As an organization, we must 4 s.1 A forward and bring it to your

.! } supervisor's attention or to respond to safety concerns and we can only do so ifwe are made

, j '( Employee Concerns. Reporting aware of them.

,Q J safety concerns is the right thing You may raise a nudear safety S to do. We depend on Palo Verde concern without fear ofdiscrimi-

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employees to maintain plant nation or retribution.There is no I safety. reason for discrimination since

'j Although employees may safety has always been, and

~ always contact the NRC directly, remains, the top priority at

$ the most positive approach to Palo Verde. v address a safety concern is to go A ae 4

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Employee Concerns:

' Dial 82-2702,

%- 944-5444, or toll-free ks 1-800-248-0068.

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SMETY CONCERNS

. 1 Your ro e in addressl To reinforce management's Q: Wharpotentialwhhtleblouer j A: Protected status is granted ,

expectations in identifying paiahiesfice APSat thh time? { whether the concern is raised I safety concerns, three Safety i internally or externally. I Concerns All-Hands meetings  : A:There is a potential for NRC were held in August. Attendance  : civil penalties. There is also a was mandatory for all day-shift  ; potential that individuals may be , Q: Mat'r the best way to handle a l employees. Video tapes were made l prosecuted for perjury or violation j situation where an allegation is of the whisdeblouvrlaw, and the '

available for people unable to rahed you ansuerit, andd>e attend. l company could be held criminally emplopedisagnes with d>eansacr?

President and CEO Mark j liable for activities on the part of ,

DeMichele, Executive Vice certain individuals. A: Get somebody to help you. l President Bill Conway and Cor- While you are never going to i porate Counsel Nancy Loftin satisfy 100 percent of the people, I discussed the importance and Q: Ofthe 72 whsdeblouer the person who raised the issue l necessity ofidentifying safety complaints, are they allawaiting can never turn around and say, l concerns and answered questions action by the company? "They never paid attention to me." i from co-workers. Here is a sum-mary ofquestions and answers: A: We never knew how many allegations were raised until we Q: What wouldyou recommend Q: Whyare whndeblouerslabeled read and heard the results of the as a course ofaction ifIam awarr 1 asprotectedemployees and what Inspector General's teport. So it is ofasupervisor outside ofmy airdxyproteadfivm? awfully difficult to define whether organization ignoring orsomehow all 72 an written by 72 individual slam dunkingan individualwho .

A: Employees who raise safety PeoPl e, whether 36 people initi- brought up a safety concern? I concerns immediately have a ated two each, or whether all or l

protected status whether or not any have been remedied. A: It's your responsibility is to l the concern is valid.They're make that known. My first im-protected from being treated Pulse is that you should arobably l differently by other employees and Q: Mu talkedabout discrimina- go to that individual anc say, "You from being discriminated against. tion in the workplace. Gm some- are not helping the organization.

We need to assure that people onefle a discrimination com- In fact, you are hurting us." If>uu who bring forward safety concerns Pl dint 'fth'30"'re ofthe discrimi- don't get the right tesxnse,yuu get answers to their questions and nation isjustignoringsomeone? should raiseit up hig3et My number aren't left dangling. (BillConway)is 81-3900.

A: Yes, if the working environ-ment is such that one person is Q:A recentsurvey doneforAPS Q: IfIraisea safety concern, willi being ignored or treated indiifer- indicatedfeeproblan areas where belabelleda valuable employee or endy, this can be considered a people might not becomfortable a whisdeblouvr? hostile wark environment and raisingsafery concerns. Is that by may be grounds for a discrimina- larlsofsupenision ordepartmans?

A: No one can label you a tion claim. Whatdos thatmean?

whistleblower unless you acknowl-edge yourself as one. Ifyou bring a i '

A: It means that anywhere from salery concern to management, Q Isprotectedstatus onlygranted three percent to 14 percent of the you would be providing a valuable 8"## d" individet 2/ mdh'J d" People in that part of the organiza-service to the company and the  : allegation or raises a conceni outdde tion who responded to the suney public. l ofdrorganianion? , have said they would not take i l safety concerns to theirsupenisors.

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! i g NEW ERA /Special Edition

ng safety concerns Q:Shouldn't the residts ofthe I Q: W77doesthis211chargeafect admitted the truth because the NRCsuret7, whichfound that 92 APSsince Saporito was a contract issue welghed heavily on his mind percent ofemployees do not haie a employee? and he wanted to clear the slate.

pmblem reportingsafety concerns to theirsupervisors, scare us? Thh A: Section 211 ptotects all employees means that onein ten wouldstill at Palo Verde, ind' nding contractors.

have aproblem. Q: Thelawfirm ofSnellcf Wilmeris deeply entrenchedwith APSandPin West. How can u e k In the survey conducted by the Q: Howlegitimate was Saporito's do anythingtogetoutofthh NRClast fall,it was found that 92 concern? rrlationship?

percent ofemployees didn't have a problem reporting a safety con- k Saporito had more than one & We're currently reviewing the cem. About six percent said they concem. He raised around 20. All total performance ofthe law firm.

would have a problem raising a of the concerns that were ofa The board members have a very safety concern and two percent safety nature were thoroughly strong opinion of this situation.

said that under no conditions investigated.He others were

. 1 would they raise a safety concern. either not safety issues or not an  !

In the more recent compre- issue at all. Q: Whatabout thelawymin-  !

hensive survey,90 percent said The administrative law judge volved? Whataretheimplicatwns they would raise a safety concern ruled in his favor that he was forAPS?

100 percent of the time. So the discriminated against and recent '

surveys are very close. events helped to reinforce that k Both lawyers at Snell and What about the one in ten? decision. In all, Saporito fded Wilmer will no longer represent That's the problem.The data we three charges against APS. In the APS in any future matters. We can have from the more recent APS first case, it was proved that the be and are held responsible for the susveylets us breakit down so company had discriminated conduct ofanyone we hire to that I now know where the against him and there will be a represent us.

problems are. With this survey, we hearing to determine damages can get down to the bottom of the from that case.The second and apple barrel to remove the bad third cases pending will be heard Q: W7thirgards to the numberof apples. at a later time by the DOL concerns bmught to the NRC, how do uv compare to other nuclear l

plann?

Q: Why h theNRCinivivedwith Q:In the &porito case, was the the Saporito charges? supervisorpressuredtolie? A:The Inspector General's Office report identified theTennessee A:The NRC monitors Section A: No, he wasn't pressured. He Valley Authority as number one in 211 charges filed with the Depart- said that it was his sole decision. allegations, with 150 concerns ment oflabor. An investigation brought up in a four and one-half sometimes is conducted by the year period. We were number nvo, NRC concurrently with the Q: Why didthesupervisor tellthe with 72 concerns over a four and investigation by the DOL This is truth afterheperjmrdhimsd# one-halfyear period. Unfortu-relatively new. Previously, the nately, we can't define whether 72 NRC let the DOLinvestigate and A: After reviewing the testimony, individuals have raised allegations go through a hearing to determine our lawyers discovered inconsis- or 36 people have raised nvo what happened with a whistle- tencies with the supervisor's allegations each - that informa-blower charge. statement. When they presented tion is not available to us.

these inconsistencies to him, he October 1993 3

SAFETY CONCERNS Q: How legitimate air the con- A: At present. there are approxi- A: Emplovces have a responsibility cmu that hate beenfiled? mately 125 open concerns. ta dearly co>mnunic.ne with d>eir Roughly,45 of these are potential superviron that they have a poten-A:There have been some that are nuclear safety issues. Over the past tial nuclear safety concern . Super-of a safety nature and those have year. less than 15 percent of the visors have a responsibility to been addressed. We need to prove potential nuclear saferv issues were employees to follow up on poten-that a safety concern will be substantiated. tial nuclear safety concerns in a addressed (3y the company. It may timely manner. As a general guide, not be armvered in the manner if reasonable feedback has not you want, but it will be addressed. Q:How can employeesget ir- occurred within a month. the sponses to safety concmu ifue employee and the supervisor can'tgct nzpoma to otherconcerns? should, together, escalate the issue Q Howlong does it take to to the next level of management.

imestigate a medcarsafetyconcme? A: Supervisors should work closely j with the frontline employees when .

A: Simple concems may take only i there is a concern. They need to Q: Can we change the tendency to a few days to deal with, but more  ! deal with these problems on a  ! go straight to the NRC with safety complex concems may take a year j timely basis and fully explore the  ! concerns?

or more.The average, over the  ! issue. We need to do both these  !

past 12 months for potential , things better. A: It's our desired state to have the nuclear safety concems, has been company intemally handle safety approximately 85 days. Efforts j i concerns so that people don't feel have been underway to improve Q:So, ifwe take a concern in  ! they need to go to the NRC with i this response time. For example, house, address it efectively, and  ;' them. But, or course, an employee the authorized number of Em- documentwhetherthisconcm is always is free to do so.  ;

playee Concems stalfhas tripled orisn' validandtheindividualh t 1 over the past year.  ! stillnotsatisRed sinulduego up to i the nealetelofmanagement? Q: Ifueget to ahepoint that i

nobody can satisfy us andwejust Q: Whats the number ofconcerns A:That is the proper thing to do. , go to the NRC, have uv stilldone on our books, how many are  ; ourjob?

nuclearsafery concerns, andwhat -

are uw doing to take care ofthem? Q: Whatifapman has a nuclear l A: Yes.

Y safety hsueanilbringsit up to

, management andit takes a uveh, i' i

month, oryearfor a response?

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I ENCLOSURE 3 l

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PALO Vt r$DE NUCLEAR GENERATING STATION

1. TITLE 9,[ .

Lesson Number: NGA01-05-RC-003-04 LP Revision Date: O #!

Course

Title:

Site Access Training Lesson

Title:

Quahty Assurance (QA)

Author: C.T. Seliga Technical Review: -

p , c/ar/ 05 Duration: 30 minutes Teaching Approva t

11. INITIATING DOCUMENT (S)

, 15AC-0TR09, Rev. 3. General Employee Training Program Description i

ANSI /ANS 3.1,1978, Section 5.4, Selection and Training of Nuclear Power Plant Personnel lit. TOPIC REQUIREMENTS 15AC-0TR09. Rev. 3, General Employee Training Program Description INPO ACAD 91-011 Guidelines for General Employee Training RCTS No. 038572.

• Employee Communication with the NRC*

Quality Assurance Plan, Rev.1 TCS 92-0267

• Unit 2 Rx Trip due to Loss of CEDM MG Output

• IV. CONTENT REFERENCES 10CFR50, Appendix 8, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants 84DP ORM27. Rev. 6 Receipt and Control of NATM Procedures 83PR-0CC01, Rev. 0.04 Configuration Management Program 90AC-OlPO4, Rev.1.00, Condition Reporting 01PR-DOOO2, Rev. O. Employee Concerns Program 84AC-ORM01, Rev. 3, Nuclear Records Mgmt. Drawing, Document and Procedural Retrievals TCS 92-0843 *CRDR/ECP Processes

• TCS 92-0267

• Unit 2 Rx Trip due to Loss of CEDM MG Output

• V. MATERIALS REQUIRED Whiteboard, Non-permanent markers, eraser

. Handout Overhead Projector with Transparencies PAGE 1

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PAGE 9 LESSON NUMBER: NGA01-05-RC-003-04 COURSE TITLE: Site Access Training LESSON TITLE: Quality Assurance STUDENT OBJECTIVES SEQUENCE METHODS AND ACTIVITIES Responsibilities include:

A. Comply with requirements. Recent changes by the NRC in A. Show T004.

the Code of Federal Regulations a!!sws for action to be taken against Individual workers who willfully violate requirements.

B. Pay attention to detail. DO IT RIGHT THE FIRST TIME.

C. Be properly trained.

TCS 92-0267 ' Unit 2 Rx Trip due to D. Use Self Verification Techniques to ensure you do your task D. Example: turning on a light.

Loss of MG Output

• correctly. S-T-A-R

1. Stop - get organized and focused on the job at hand. 1. I have to turn on the light.

2. Think - have the proper procedure, tools and equipment. 2. Where is the light switch?

3. Act - perform the job safely and properly. 3. Turn on the light safely, make sure it is not wet, etc.

4. Review - verify the job was performed propeily. Did you 4. Did the light come on, stay get the desired resu!ts? What could have been done on and provide adequate better? lighting?

5. Use of these self verification techniques are for use by everyone. Anyone could make a mistake while performing their job which could have an effect on the plant.

E. Participate in a team effort.

EO3. List the steps and suggested F. Inform manag ement of discrepancies and/or nonconformances F. Show T005.

path for reporting affecting quality or safety.

discrepancies or nonconformances affecting quality or safety.

PAGE 10 LESSON NUMBER: NGA01-05-RC-003-04 COURSE TITLE: Site Access Training LESSON TITLE: Quahty Assurance l

STUDENT OBJECTIVES  ; SEQUENCE METHODS AND ACTIVITIES TCS 92-0843 *CRDR!ECP Processes

• 1. Start by reporting problem to your supervisor. You can 1. CRDR's will be discussed do this verba!!y or using a CRDR (Condition later in the LP.

Report / Disposition Request).

2. Employee Concems Program is next suggested step but 2. Show T006.

is not required (944-5444 or ext. 2704).

a. For QA/ Safety concerns that have not been addressed to your satisfaction.

b. Employee reporting concern may,if he chooses, request confidentiality when utilizing this method.

c. Research of concern will be done by Employee Concerns group.

d. Il requested, the employee will be provided feedback as to problem resolution.

3. An officer of APS, a Vice-President or above.

a. For concerns that have not addressed to your satisfaction.

b. Employee reporting concern may request confidentiality.

4. Nuclear Regulatory Comm.ission (NRC).

a. If you believe adequate corrective action is not being taken, you may report this to an NRC inspector (x3737) or the nearest NRC Regional Office.

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PAGE 11 LESSON NUMBER: NGA01-05-RC-003-04 COURSE TITLE: Site Access Training LESSON TITLE: Quality Assurance STUDENT OBJECTIVES SEQUENCE METHODS AND ACTIVITIES

b. Federal law prohibits an employer from firing or otherwise discriminating against a worker for bringing safety concerns to the attention of the NRC.

c. NRC Resident inspectors are located on the top floor of the original Admin Building, now called Bidg. D.

RCTS No. 038572

• Employee d. Although this is the recommended order for Communication with the NRC.* reporting concerns relating to quality or safety, you have the riaht to go to the NRC first, if you so desire.

• lmportant Note: THE EMPLOYEE CAN GO DIRECTLY TO THE NRC WITHOUT FOLLOWING THE SUGGESTED FLOW PATH.

EO4. State the document used to G. Use Condition Report / Disposition Request (CRDR). G. Show a CRDR. Show T007.

identify problems or potential problems.

1. It is the responsibility of every individual to identify problems at PVNGS.

2. CRDR's do not apply to normal equipment wear. A work request is the proper document for normal maintenance.

3. Needs to be completed and turned in to your supervisor, 3. If it is in regard to plant the Shift Technical Advisor in the control room or the safety it should be turned in CRDR group in Bldg. B,3rd floor.as soon as possible to the control room. Call the (no later than the end of shift). CRDR group x5674 or the unit control room for advice.

4. Procedure 90AC-OlP04

• Condition Reporting."

V. Procedures and Drawings A. Show T008.

. perform receipt inspections of material and .;uggested path for reponing quality or safety documents upon arrival to the site. concerns:

Ouality Systems. This group develops and -

Your supervisor (verbally or in writing, maintains the QA Plan. They also ensure use the CRDR)

OA requirements are in procedures.

PVNGS Employee Concern Program, 944-5444 or 393-2704 (Ext. 2704) located QUALITY IS YOUR in Building. D (the original Admin RESPONSIBILITY Bldg.), top floor Everyone at Palo Verde is responsible for An officer of APS performing the highest quality work that can be reasonably achieved. Providing proper Nuclear Regulatory Commssion (NRC),

documentation of this quality work is also Ext. 3737, located in Bldg. D, top floor required.

Note: Although the recommended order Individual responsibilities include: for reporting concerns are as stated above, YOUHAVE TtiERIGHTto Comply with requirements. go directly to the NRC first,if you so desire.

Never deviate from an approved proce-dure.

CONDITION REPORT / DISPOSITION Pay attention to detail. REQUEST (CRDR) THE "CRTITER" Be properly trained. Policies, plans, programs and procedures ,

are part of the administrative controls, but I Use " STAR" (Self Verification Tech. vou are the one that makes the programs niques). work. You are the one performing work activities.

1. Stop

2. Think PVNGS depends on you to identify problems

3. Act when (or before) they occur. The CRDR

4. Review is used to help you identify and report any conditions that may negatively impact the Participate in a team effort. safe operation or Palo Verde.

Ensure you fully understand your task CRDR forms are available in each unit before you start. Control Room and also from the STA group (Bldg. A,2nd floor) and the CRDR group Inform management of discrepancies (Bldg B,3rd floor). The CRDR needs to or nonconformances affecting quality be completed and turned in to your supervi-or safety. sor, the CRDR group, or the Control Room as soon as possible (no later than the end of shift). See procedure 90AC-0lP04 If you identify a quality or safety related " Condition Reporting" for more information.

problem. REPORT IT!-

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j ENCLOSURE 4 '

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j D Dh PALO VERDE NUCLEAR GENERATING STATION

1. TITLE Lesson Number: NGA01-05 RC-009-000 LP Revision Date: W O' N Course

Title:

Site Access Training Author: C.T. Seliga Lesson

Title:

Radiation Protection Technical Review: IN bb Duration: 1 flour Teaching Approval $m II. INITIATING POCUMENT(S)

Q /stlD 15AC-0TR09, General Employee Training Description Program, Rev. 2.01 Updated Final Safety Analysis Report, Section 13.2.9 111. TOPIC REQUIREMENTS 10CFR19, Notices, Instructions and Reports to Workers; inspections USNRC Reg. Guide 8.13, Instructions Concerning Prenatal Radiation Exposure, Rev. 2,12/87 USNRC Reg. Guide 8.29, ine.cction Concerning Risks from Occupational Exposure, Rev. O,7/81 INPO ACAD 91-011, Guidelines for General Employee Training IV. CONTENT REFERENCES NCRP 93, lonizing Radiation Exposure of the Population of the United States USNRC Reg. Guide 8.13, instructions Concerning Prenatal Radiation Expsoure, Rev. 2,12/87 USNRC Reg. Guide 8.29, instruction Cons'.ning Hisks from Occupational Exposure, Rev. O,7/81 75AC-9RP01

• Radiation Exposure and Access Control *, Rev.1 75AC-9RP02 " Radioactive Contamination Control *, Rev.1 V. MATERIALS REQUIRED Whiteboard, Non-permanent markers, eraser -

Attendance sheet (s)

Exams Training alds

PAGE 13 LESSON NUMBER: NGA0105-RC-009-000 COURSE TITLE: Site Access Training LESSON TITLE: Radiation Protection STUDENT OBJECTIVES SEQUENCE METHODS AND ACTIVITIES ,

i i D. Radioactive Material-is labeled with radioactive material '

stickers and is usually wrapped in yellow poly bags, yellow herculite or in clear bags with yellow and magenta . .;

markings. Radioactive material could be any material used  !

In the RCA such as wrenches, valves, protective clothing or ,

trash. These items belong in the RCA or at a radioactive material burial site. PVNGS does not want one single  ;

radioactive atom to accidentally find its way off site.  ;

Therefore, it is extremely important that you can recognize this material and take the appropriate actions if you were to ,

come in contact with it.

EO4. Select the appropriate VI. Abnormal Situations i response for various abnormal radiological conditions. '

A. In the course of your work at PVNGS If you: A. Unit 1 - x1403 Unit 2 - x2403  ;

-see radioactive material unattended or radiological warning Unit 3 - x3403 signs laying on the ground outside of the RCA, do not touch or move these materials. Call Radiation Protection and keep other personnel away.

-find a radiological boundary or posting in your path, do p_ot I cross this boundary. Call RP for assistance if you need something in this boundarled area. @ gth

,' Vll.- NRO Form 3

• Notice to Employees * ' NT P .

, orouod0.M Ce y BIr$ 3d , j EOS. Recognize the purpose of A. NRC Activities and Responsibilities 6, SM cMemuG the N RC. "

3 4

1. Licensing and inspecting nuclear power plants.

2. Ensuring nuclear power plants are constructed and operated safely.

_ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ e . _u__ _ _ _ ,_o < _ _ - m - . .- - - - , m

PAGE 14 LESSON NUMBER: NGA01-05-RC.009-000 COURSE TITLE: Site Access Training LESSON TITLE: Radiation Protection STUDENT OBJECTIVES SEQUENCE METHODS AND ACTIVITIES

3. Ensuring that workers and the public are protected 3. This is their primary f from unnecessary or excessive radiation exposure responsibi!!ty.

from nuclear power plants. ,

B. Employers Responsibilities

1. Comply with NRC requirements.

5

2. Post NRC Notices of Violations. 2. These are posted at plant entrances.

EO6. Recognize the rights and C. Workers Rights and Responsibilities

, respotibilities of nuclear plant workers as outlined in NRC Form *

1. Workers have the right to:  ;

. a. Pfeelve Radiological Work Practices training prior to entry into the Radiological Controlled  :

Area.  !

b. Receive a report of the radiation exposure they received, annually and after termination.

c. Talk to an NRC Inspector privately and confidentially.

d. Request NRC Inspections.

e. Protection from discrimination for filing a complaint.

2. Workers are responsible to:

n. Know how the NRC requirements relate to their work.

PAGE 15 LESSON NUMBER: NGA01-05-RC-009-000 COURSE TITLE: Site Access Training LESSON TITLE: Radiation Protection STUDENT OBJECTIVES SEQUENCE METHODS AND ACTIVITIES

b. Report violations.

1) To your supervisor.

2) NRC Site Office: x3737 in the Annex Building Lobby.

3) Region 5 Office: 1450 Maria Lane,

1. 210, Walnut Creek, CA,94596, (510) 975-0200.

• SUM MARY * * * * * * ** **

SUMMARY

. Summary of Main Principles. -

A. Objectives Review A. Review the lesson objectives. Refer students to their handouts.

D. Topic Review

1. Introduction

2. Terms and Definitions

3. Sources of Rad!allon Exposure

4. Radiological Postings / Radioactive Material

5. Responses to Abnormal Situations

6. NRC Form 3

11. Questions and Answers ll. Ask questions which implement the objectives.

Discuss students' answers as needed to ensure the

Y:llow and Magenta Pzekages it is important that you understand that these incidents are more likely inside the RCA All materials which arc or may be radioactive and that this course does not provide the will be wrapped in yellow or clear plastic l necessay instruction to enter the RCA.

bags with yellow and magenta labels which Further,it is essential that untilyou complete include the radiation symbol,the trifoil, and the next course, RWP, you may not cross i the words Caution Radioactive Material. any radiological barriers. There may be If containers are used instead of bags, they disciplinary action taken against anyone will have similar markings. If you encounter violating Radiological Controlled Area material marked in such a way and they boundaries.

seem to be out of place:

THE WORKERS RIGHTS AND

1. Do Not touch the item.

RESPONSIBIIITIES

2. Keep others away.

The Nuclear Regulatory Commission has produced the " Notice To Employees". This

3. Contact Radiation Protection by phone document is commonly referred to as NRC or messenger.

Form 3. It addresses NRC, employer and worker rights and responsibilities. The NRC

4. Stay until R.P. says it is okay to leave.

Form 3 will be conspicuously posted in many m You Discover YtttOW AND MAGENTA BAGS OR places on bulletin boards and at plant CONTAINERS THAT SEEM To BE OUT OF PLAeE, CntranCCs. There is also a copy in this STAY AWAY, KEEP OTHERS AWAY AND handout on the following page Generally NOTwy nP. iuuEoaTELY it refers to the following:

The Nuclear Regulatog I f Commission

$ \ NRC responsibilities include:

6 as g'

-Licensing and inspecting of nuclear power l s ,e plants.

k -Assuring that workers and the public are protected.

jj i

' '" D -Assuring that the construction and operation

/fj k of facilities is safe. l

\ -Responding to any worker's request for an 7'# $ \ inspection and solving of worker identified

'N problems.

k_ -

The address and telephone number for the I regional office are also conspicuously listed i for employees.

1 I

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1 The Employer The Workers Responsibilities Palo Verde's responsibility is: Your responsibilities are to:

-To comply with the NRC requirements. -Know and obey NRC work requirements.

-To notify workers of radiation protection -Report observed violations of these require-requirements. ments to plant management.

-To post NRC Notices of Violation involving -Contact the NRC if it is believed that the radiological working conditions. employer has not corrected such violations.

-To record as well as report to the worker his or her radiation exposure.

The Workers Rights You as workers have the right to:

-Receive Radiological Work Practices (RWP) tmining prior to entry into the Radiological Controlled Area (RCA).

-Receive a report of the radiation exposure you receive, annually and after termination.

-Talk to an NRC inspector, privately and conGdentially. ,

-Request NRC inspections.

-To be protected from discrimination for filing a complaint.

17 i 1

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nce of each occurrence; Congress.

Progress subrmtted to the Congress on or before January 1,1978, and progress trence; rep rts. reports shall be included in the annual report of the Commission thereafter.u mination to the pubhc o!

iecetymg (2} of this " EMPLOYEE PROTECTION mgg c\

a o"n of 42 USC 5851

$5 wide d mination to "Sec. 210. (a) No employer, including a Commission licensee, an ition spe in clauses l applicant for a Commission license, or a contractor, or a subcontractor es available to it. of a Commission licensee or applicant, may discharge any employee or otherwise discriminate against any ernployee with respect to his compensation, the emplo terins, conditions, or privileges of employment because employce)yee (or any person acting pursuant to a request of the

) O{ anandExecutive be removableDirector by

"(1) commenced, caused to be commenced, or is about to com-n such functions as the 42 USC 2011 mence or cause to be commenced a proceeding under this Act or

"tive Director shall not note. the Atomic Energy Act of 1954, as amended, or a proceeding for

'"*P nent organization the administration or enforcement of any requirement imposed 3rt directly to the under this Act or the Atomic Energy Act of 1954, as amended;

~nt ganization deems it "(2) testified or is about to testify in any such proceeding or; Not withstanding the "(3) assisted or participated or is about to assist or participate in

' 11 keep the Executive any manner in such a proceeding or m any other manner m such a Proceedmg or m any other action to carry out the purposes of this ,

("3 the content of all suchComplaint. Act or the Atomic energy Act of 1954, as amended.

to the Commission at GI ng and "(b)(1) Any empk)yee who believes that he has been discharged or P' ress,and status of the noufication. otherwise discriminated against by anyperson in violation of subsection orts w (a) may, within thirty days after such violation occurs, file (or have any

!# and forward to the pers n file on his behalf) a complaint with the Secretary of Labor

1. 1. car 1978 and each (hereinafter in this subsection referred to as the ' Secretary') alleging Commission's programs such discharge or discrimination. Upon receipt of such a complaint, the

' din an assessment of the Secretary shall notify the person named in the complaint of the filing of the complaint and the Commission.

facilities and activities Investigation shall forward to the and "(2)(A) Upon receipt of a complaint filed under paragraph (1),

ebruary 1,1979, as a nouncauon. the Secretary shall conduct an investigation of the violation alleged in the , complaint. Within thirty days of the f each succeedingyearasa I re ort (required under complatnt, the Secretary shall complete suchvestigation m, receipt andof such et f 1974)foll wtng the Orde r. shall notify in writing the complainant (and any person acting in his behalf) and the person alleged to have committed such violation of more than five additional the results of the investigation conducted pursuant to this ositions of such officers subparagraph. Within ninety days of the receipt of such complaint l

u ject to subsection 161 d. the Secretary shall, unless the proceeding on the complaint is terminated by the Secretary on the basis of a settlement entered into by the Secretary and the person alleged to have committed UES PIAN such violation, issue an order either providing the relief prescribed l '1 plan providing for the Nouce and by subparagraph (B) or denying the complaint. An order of the l issues relating to nuclear heanng. Secretary shall be made on the record after notice and opport unity

necessary to implement seulement. for public hearing. The Secretary may not enterinto a settlement

~ies. Such plans shall be terminating a proceeding on a complaint without the participation and consent of the complainant.

Rehef.

2, U 1 ,. +,,=, ,w "(B) If,in response to a complaint filed under paragraph (1). the

,a - "

. ,,a .

Secretary determines that a violation of subsection (a) has 3

occurred, the Secretary shall order the person who committed U

Publu Law 95 209 (9i Sur 1482W 19"), ,et i added see 2 to 189

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REGION IV aRUNGToN l l.

J..,,,, , evano =ico ENERGY REORGAl SECTION 211. EMPLC

(

(a) (1) No employer may discharge any employee or otherwise (b) (1) Any employee who believes that he has been discharged or discriminate against any employee wtth respect to his otherwise discriminated against by any person in violation of compensation. terms, conditons, or privileges of subsection (a) may, within 180 days after such violation employment because the employee (or any person acting occurs, file (or have any person file on his benalf) a pursuant to a request of the employee)- complaint wrth the Secretary of Labor (in this section referred to as the ' Secretary') alleging such discharge or (A) notified his employer of an alleged violation of this Act disenmination. Upon receipt of such a complaint, the or the Atomic Energy Act of 1954 (42 U.S.C. 2011 et Secretary shall notify the person named in the compiaint of seq.); the filing of the complaint, the Commission, and the Department of Energy.

(B) refused to engage in any practice made unlawful by this Act or the Atomic Energy Act of 1954, if the employee (2) (A) Upon receipt of a complaint filed under paragraph (1),  ;

has identfred the alleged illegality to the employer; the Secretary shall conduct an investigation of the violation alleged in the complaint. Within thirty days of (C) testifu ! before Congress or at any Federal or State the receipt of such complaint, the Secretary shall proce* ding regarding any provision (or proposed complete such investgation and shall notty in wnting prov:. son) of this Act or the Atomic Energy Act or 1954; the complainant eri any person actng in his behalf) and the person as.eged to have commrtted such (D) commenced, caused to be commenced, or is about to violation of the resutts of the investigation conducted commence of cause to be commenced a proceeding pursuant to this subparagraph. Wrthin ninety days of under this Act or the Atomic Energy Act of 1954, as the receipt of such complaint the Secretary snall, unless amended, or a proceeding for the administration or the proceeding on the complaint is terminated by the enforcement of any requirement imposed under this Act Secretary on the basis of a settlement entered into by or the Atomic Energy Act of 1954, as amended; the Secretary and the person alleged to have committed such violation, issue an order either providing the rehef (E) testfied or is about to testify in any such proceeding or; prescribed by subparagraph (B) or denying the complaint. An order of the Secretary shall be made on (F) assisted of participated or is about to assist or the record after notice and opportunrty for public participate in any manner in such a proceeding or in any hearing. Upon the conclus4on of such hearing and the other manner in such a proceeding or in any other issuance of a recommended decision that the complaint action to carry out the purposes of this Act or the Atomic has merrt, the Secretary shall issue a preliminary order Energy Act of 1954. as amended. providing the relief prescribed in subparagraph (B), but may not order compensatory damages pending the final (2) For purposes of this section, the term' employer' includes . order. The Secretary may not enter into a settlement terminatng a proceeding on a complaint without the (A) a licensee of the Commission or of an agreement State participaton and consent of the complainant, unoer section 274 of tne Atomic Energy Act of 1954 (42 U.S C. 2021); (B) If, in response to a complaint filed under paragraph (1),

the Secretary determines that a violation of subsection (B) an apolicant for a license from the Commission or such (a) has occurred, the Secretary shall order the person an agreement State; who committed such violaton to (i) take affirmative action to abate the violaton, and (ii) reinstate the (C) a contractor or subcontractor of auch a licensee or complainant to his former position together witn the applicant; and compensaton (including back pay), terms, conditions, and pnvileges of his employment, and the Secretary ;

(D) a contractor or subcontractor of the Department of may order such person to provide compensatory ,

Energy that is indemntfied by the Department under damages to the complainant, if an order is issued 6 secton 170d of the Atomic Energy Act of 1954 (42 under this paragraph, the Secretary, at the reavest of U.S.C. 2210(d)), but such term snalt notinetude any the complainant shall assess against the person agairs contractor or subcontractor covered by Executive Order whom the order is issued a sum equal to the aggregate No.12344, amount of all costs and expenses (including attorneys, I

101 Marietta St., N.W., Suno M (404!) 331-4503 tsispnons:

As:nts GA 30323-0199 e

. u.S NucW,r hguttery Commiss.on, %gion m OFFICE OF THE l 799 Roosevett Road (708) 790-5500 INSPECTOR GENERAL Gien Eltyn,IL 60137-5927 U.S. Nuotear Regulatory Commiss.on, Region IV 611 Ryan Plaza Drive, Surte 400 (817) 860-8100 HOTLINE Arlington, TX 76011 8064 u.s. mm, Regutatory Commission, Region v 1-800-233-3497 1450 Maria Lane (510) 975-0200 Walnut Creek, CA 94596-5368 TION ACT -

PROTECTION e y

• *:.= .& > j p., .

A*Mpi[sitiw6tness fees) reasonably incurred, as was found to occur to enforce euch order, in actions brought  !

under this subsection, the distnet courts shall have Junsdiction to

%ggd  %.g%WM detenulhe(hy with, thethe Secretary, bnnging of theby the complainant complaint upon for, or grant all appropriate relief includmg, but not limited to, injunctive Qh. which the ceder was issued, relief, compensatory, and exemplary damages. ]

..- 2 ,

' @m a c .[(A)1The Geissenry shall dismist a complaint filed (e) under(1) Any person on whose behalf an order was issued under jeg. peregraph (1), and shall not conduct the investigation paragraph (2) of subsection (b) may comrnence a civil action against the person to whom such order was issued to require J1 M[L.,, required hea made a under prima facie paragraph showing that(2), unless the complainant any behavior compliance wrth such order. The appropriate United States lA, (A) through (F) of distnct court shall have jurisdiction, wrthout regard to the

-r 7*] essested mamarmams .-in subparagraphs

-(a)(1) was a contributing factor in the amount in controversy or the crtirenship of the parties, to unfeworeinio personnel action alleged in the complaint. enforce such order,

-7.p?* ,

tWe p a finding by the Secretary that the (2) The court, in issuing any final order undsr this subsection, V f[ w)

L .has made the showing required by may award costs of litigation (including reasonable attomey and expert witness fees) to any party award as appropriate.

9 -

]b@,' [subpareDreph peregsspkj2) shall (A),

be no investigation conducted required under if the employer o g 62 demoneentes, by clear and convincing evidence, that it (f) Any nondiscretionary duty imposed by this section shall be JfQ'Mieutd' howe 7taken the same unfavorable personnel enforceable in a mandamus proceeding brought under section 1361 of trtle 28 of the United States Code.

g 7. 4 K? 4 ,,; etson in vv" tie absence of such behavior.

• 9 j(Op.The"SpoN4ar a violation of (g) Subsection (a) shall not apply with respect to any employee who, M ' Wsubesetich (a)y may determine has occurred that only rf the complainant has acting without diroceon from h4s or her employer (or the

.~ idemenetreled that any behavior described in employer's agent), deliberately causes a violation of any V % - ebbperegraphs (A) through (F) of subsection (a)(1) was requirement of this Act or of the Atomic Energy Act of 1954, as y a canetbuting factor in the unfavorable personnel action amended.

,, alleged,,lh pe complaint. (h) This section may not be construed to expand, diminish, or

, ,.._ju dM otherwise affect any right otherwise available to an employee

' *%:K Melief1Haytot be ordered under paragraph (2) if the under Federal or State law to redress the employee's discharge M % employeriWomonstrates by clear and convincing or other discnminatory action taken by the employer against the s:r evidence 9tet it would have tamen the same unfavorable employee.

'33uch behawlor.

M (i) The provisions of this section shall be prominently posted in any place of employmerit to which this section applies.

(c) (1) My personfedworsely affected or aggrieved by an order 2 e issued undet subsection (b) may obtain review of the order irl the Urdted States court of appeals for the circuit in which Q) (1) The Commission or the Department of Energy shall not delay

= the v4olatWetth respect to which the order was issued, taking appropriate action with respect to an allegation of a allegedly ecoghed. The pettion for review must be filed substantial safety hazard on the basis of -

withm sixty days from the issuance of the Secretary's order.

Review thelf tonform to chapter 7 of title 5 of the United (A) the filing of a complaint under subsection (b)(1) arising States Code'.'The commenument of proceedings under this from such al6egation; or gegbperegraph shall not, unless ordered by the court, operate jegaeleyet Secretary's order. (B) anyinvestigation by the Secretary, or other action, under t' Jh y , this section in response to such complaint.

' $ M$M btary with respect to which review could

.;.M nder this section.that a m; W- Mp4 bdast ehdiladilAder paragraptgay notbo subag,, @ ' "(2) A determination t ag,y ,

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- f ductory text or under theQO require- (d) Actions taken by an err-ployer ments if the employee has identifled others, which advenely affect an k the alleged illegality to the employer; ployee may be predicated upon nd (111) Requesting the Commission to discriminatory grounds. The prohlg institute action against his or her em.

tion applies when the adverse action player for the administration or en- occurs because the employee has es forcemenrof these requirements; gaged in protected activities. An eg (iv) Testifying in any Commission ployee's engagement in protected ac, j proceeding, or before Congress, or at tivities does not automatically render

, any Federal or State proceeding re- him or her immune from discharge og i garding any provision (or proposed pro- discipline for legitimate reasons og vision) of either of the statutes named from adverse action dictated by in paragraph (a) introductory text. nonprohibited considerations.

(v) Assisting or participating in, or is (e) Each !!censee and each applicant about to assist or participate in, these for a license shall prominently post the 1 activities. revision of NRC Form 3. " Notice to 4

(2) These activities are protected Employees," referenced in 10 CPR even if no formal proceeding is actu. 19.11(c). This form must be posted at lo.

e ally initiated as a result of the em. cations sufncient to permit employee, l

l ployee assistance or participation. protected by this section to observe a 4

(3) This section has no application to copy on the way to or from their place I any employee alleging discrimination of work. Premises must be posted not

{ prohibited by this section who, acting later than 30 days after an application J without direction from his or her em. is docketed and remain posted while ployer (or the employer's agent), delib. the application is pending before the erstely causes a violation of any r,. Commission, during the term of the 11 quirement of the Energy Reorganiza- cense, and for 30 days following license tion Act of 1974, as amended, or the termination.

Atomic Energy Act of 1954, as amend-Nors: Copies of NRC Form 3 may to og l ed. tained by writing to the Regional Admig (b) Any employee who believes that trator of the appropriate U.S. Nuclear Rep.

l he or she has been discharged or other. 1 story Commisalon Regional Ofuce listed in I wise discriminated against by any per. appendix D to part 2) of this chapter or by son for engaging in protected activities atacung the NRC Informadon and Recons k' specified in paragraph (a)(1) of this sec- 8

' ( * * '

r tion may seek a remedy for the dis-charge or discrimination through an (f) No agreement affecting the com.

i administrative proceeding in the De- pensation, terms, conditions, or priri-partment of Labor. The administrative leges of employment, including an proceeding must be initiated within 180 agreement to settle a complaint filed days after an alleged violation occurs. by an employee with the Department The employee may do this by filing a of Labor pursuant to section 211 of the complaint alleging the violation with Energy Reorganization Act of 1974, as the Department of Labor, Employment amended, may contain any provision i

Stedards Administration Wage and which would prohibit, restrict, or oth- '

j Hour Division. The Department of erwise discourage an employee from

{ Labor may order reinstatement, back participating in protected a,ctivity as pay, and compensatory damages. defined in paragraph (a)(1) of this sec-J' (c) A violation of paragraph (a), (e), tion including, but not limited to, pro-or (f) of this sect.fon by a Commission viding information to the NRC or to 5

4 licensee, an applicant for a Commis- his or her employer on potential viola.

it sion license, or a contractor or sub- tions or other matters within NRC's i contractor of a Commission licensee or ngulatory responsibilities.

applicant may be grounds for- 158 FR $2410. Oct. 8.19101 (1) Denial, revocation, or suspension of the license. 6 50J Information collection require-(2) Imposition of a civil penalty on saents: OMB approval.

the licensee or applicant. (a) The Nuclear Regulatory Commis-(3) Other enforcement action. sion has submitted the information 632

Arizona Public Service Company' P O OCu53999

• PHO(NIX AAt2ONA 85072 3999 WILLIAM F CONWAY 102-02943-WFC/ACR n,cung ys" May 5,1994 Mr. James Ueberman, Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

NRC Letter dated March 8,1994 from J. Lieberman, NRD, to W. F. Conway, APS

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1,2, and 3 Docket Nos. STN 50-528/529/530 File: 94-056-026: 94-003-350 This letter responds to your request for information (Referenced letter) regarding statements made by a PVNGS spokesman, Mr. Mark Fallon, that were quoted in a West Vallev View article dated January 26,1994. This letter also responds to your request for information regarding an allegation that Mr. Fallon's comments might discourage PVNGS employees from raising concerns to the NRC.

As described more fully below, APS believes that the article accurately reflected the substance of Mr. Fallon's comments. APS further believes that, taken in context, Mr. Fallon's comments were appropriate and were neither intended to discourage employees from raising concerns to the NRC nor would they tend to have such an effect.

APS notes that it encourages its employees to first raise their concerns with their line management or through other internal means because this is the most effective way for concerns to be promptly addressed and resolved. However, APS emphasizes to its employees that they should always feel free to raise their concerns with the NRC.

Mr. Fallon's Statements The statements quoted in the January 26,1994 West Vallev View article resulted from a telephone conversation between Mr. Fallon and Mr. Dan Nowicki, a reporter. Mr. Fallon speaks with Mr. Nowicki periodically (typically three times per week), and on the occasion of this call, Mr. Nowicki inquired if Mr. Fallon had any comment regarding the National

.. -w+-

Mr. James Ueberman, Director Office of Investigations U.S. Nuclear Regulatory Commission

'Page 2 Whistleblower Center's announcement that it was opening a " regional office" in Buckeye, Arizona (near PVNGS). Mr. Fallon noted that APS was taking a number of steps to foster an atmosphere at PVNGS in which employees feel free to' raise concerns. He further indicated that APS expected its efforts to be effective, and therefore, he hoped that employees would not feel the need to go to the Buckeye center.

Mr. Fallon's statements were not intended to discourage employees from communicating with the Buckeye center. As noted in the article, Mr. Fallon's message to the reporter was that he expected that APS' revised programs would be effective and "should leave the staff of the Buckeye center with little to do." Mr. Fallon merely indicated that APS' goal was that employees would be satisfied with the effectiveness of APS' internal mechanisms for resolving concerns, and therefore, they would not feel the need to go to an external organization such as the Buckeye center.

APS also recognizes that its employees should always feel free to raise concerns with the NRC. Mr. Fallon's comments did not make any reference to the NRC, and he did not make any statements intended to discourage employees from raising concerns to the NRC. Mr. Fallon's comments that the Buckeye Center will hopefully have little to do are simply irrelevant to APS' consistent message to its employees that they should feel free to raise concerns with the NRC without fear of retaliation.

APS Actions To Make Clear to Employees That They Should Feel Free To Raise Concerns With the NRC Without Fear of Retallation Consistent with the guidance of NRC Form 3, APS encourages all employees first to raise safety concerns with their supervision or management. APS believes that supervision and management personnel are in the best first line position to address and resolve concerns promptly and efficiently. Therefore, APS' goal is that all employees will feel free to raise concerns internally and that management will effectively resolve these concerns.

. However, APS has consistently emphasized tc its employees that they should feel completely free to bring their concerns to the NRC.

APS management has communicated its expectations through a variety of means. For example, on August 10,1993, APS' Chief Executive Officer, O. Mark DeMichele, issued an all hands memorandum, in which he emphasized his expectations that " employees should feel completely at ease to raise safety concerns" and " management has an

4 Mr. James Ueberman, Director Office of Investigations U.S. Nuclear Regulatory Commission Page 3 absolute duty to listen attentively and respond appropriately." (See Enclosure 1). In doing so, Mr. De Michele also noted that "any employee has an absolute right to raise a concern with th9 NRC without fear of retribution."

This message was also communicated in Safety Concerns All-Hands Meetings that were conducted by Mr. DeMichele, Corporate Counsel Nancy Loftin, and me on August 16 and 17,1993. In addition, I provided a written summary of some key questions and answers from these meetings in an October 1993 special edition of PVNGS' New Era employee news bulletin. (See Enclosure 2). This summary included the following Q&A:

Q: Can we change the tendency to go straight to the NRC with safety concerns?

A: It's our desired state to have the company internally handle safety concerns so that people don't feel they need to go to the NRC with them. But, of course, an employee is always free to do so.

APS also has consistently reinforced the message that employees should feel free to go to the NRC in its employee training programs. In the quality assurance component of APS' site access training, employees are instructed that their suggested flow path for ,

raising concerns is to first go to their supervisor, next APS' Employee Concerns Program, '

next APS management, and then the NRC. However, the lesson plan emphasizes:

"*lmportant Note: THE EMPLOYEE CAN GO DIRECTLY TO THE NRC WITHOUT FOLLOWING THE SUGGESTED FLOW PATH." (See Enclosure 3). The radiation protection (RP) component of APS' site access training emphasizes that employees not only have a responsibility to report violations of RP requirements to their supervisor or the NRC, but also have a responsibility to go to the NRC if they believe that APS has not corrected a violation. (See Enclosure 4).

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l Mr. James Ueberman, Director Office of Investigations U.S. Nuclear Regulatory Commission Page 4 1

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l APS has taken a number of aggressive actions over the last several months in order to l

.g assure that there is an atmosphere at PVNGS in which employees are encouraged to 9.:q freely raisewoncerns. A more detailed summary of these actions was provided in  !

py.* . ' Attachment'2t Mr. DeMichele's April 21,1994 letter to the NRC's Executive Director of J~

l Operations l Mr'. James M. Taylor. You have been previously provided a copy of this letter 1 and its attachment. If you have any further questions regarding this response, please contact Mr. A.: Carter Rogers at (602) 340-4041.

y Sincerely, w jp LM/ u '

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Enclosures:

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1i. Mr.DeMichele's 8-10-93 memo

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2. Nos Era article 3.'-Training Lesson Plan - SAT 143 Training Lesson Plan ,. Rad Protection a.- , .

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cc: K. E. Perkins lf .

T. J. Saporito .

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ENCLOSURE 1 I

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i Arizona Public Service Company P O. BOX 53999 . PHOENIX. ARIZONA 85072 3999 MaAK De MICHELE '

August 10,1993 TO: All Palo Verde Employees i FROM: Mark DeMichele Recently, there have been several press accounts of alleged inappropriate management responses to employees who have raised safety concerns. The gist of these accounts is that APS management tolerates,if not encourages, heavy-handed treatment of persons who raise safety concerns.

Just last week we learned that one of our supervisors, contrary to his earlier sworn statements, declined to hire a contractor employee because the candidate had previously raised safety concerns at Palo Verde and elsewhere.

This behavior will not be tolerated.

In light of this event, I think it is timely and vital to restate my expectations for how everyone at Palo Verde should address safety concerns.

Employees at Palo Verde who identify and report safety concerns perform an invaluable service to the company and to the public. The watchful eye of every employee is at the heart of the elaborate measures which assure safety of operations at Palo Verde each day. APS counts on all employees to do more than merely their assigned jobs with complete dedication and discipline. We ask and expect that you all identify safety concerns to your supervisor; to alert us when tasks are not being performed in the manner required by the detailed procedures which govern almost every activity at Palo Verde; and to advise of any other problems which, because of your training and experience and your closeness to operations, you are uniquely positioned

, to recognize. Neither I nor anyone else on the APS management team look upon such activity negatively, rather it is viewed as a positive contribution.

We have recently initiated the " Hero" system to reward those who raise concerns and enable the company to more safely conduct its business.

Each Palo Verde employee should feel completely free to raise safety concerns directly with his or her supervisor. It is the responsibility of every

All Palo Verde Employees August 10,1993 Page 2 l

1 supervisor to listen carefully and then respond appropriately to the expressed concern; in fact, it is an essential element of each supervisor's job.  !

I would like to emphasize the special responsibility of the management chain of command-from first line supervision through senior management.

This group has a special responsibility.to foster an atmosphere in which conscientious employees know that their concerns will be treated seriously and that they may be expressed without fear of retribution or other adverse consequences. Of course, we also have a formal employee concerns program if, for whatever reason, employees do not choose to raise their concerns with management and would rather do so in confidence or even anonymously. In addition, any APS employee has an absolute right to raise a concern with the NRC without fear of retribution. Regardless of the means chosen, all of us at every level have an ovenvhelming stake in assuring the free flow of information that may affect safe and reliable plant operation. I personally welcome open communication, not only because it contributes to safe plant operation but also because it makes good business sense.

I am communicating with each of you personally and directly so that this message is unmistakable and to assure that you understand the company's expectations as you perform your daily activities.

In closing, I want to reemphasize that unprofessional conduct on matters affecting nuclear safety has no't and will nqt be tolerated. For their part, employees should feel completely at ease to raise safety concerns. For its part, management has an absolute duty to listen attentively and respond appropriately. Should there be any doubt as to my expectations in this regard, I expect each of you to discuss this matter directly with your supervision.

A OMD:cjs

0 ENCLOSURE 2

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.j Nuclear, industrial & personal safety:

s y c1J Top priority at Palo Verde

[y by Eecutiw Vice Presient WiHin F Conny

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c Safety is the number-one g to your supervisor, mana D, g concern at Palo Verde. Ifyou ofhcer of the company. ger or 4 r, 2 have a safety concem, step As an organization, we must

>4 *

'] fonvard and bring it to your respond to safety concerns and we

, supervisor's attennon or to can only do so ifwe are made O Employee Concerns. Reporting aware of them.

d safety concerns is the right thing You may raise a nudear safety

., .S to do. We depend on Palo Verde concem without fear ofdiscrimi-employees to matntain plant nation or retribunon.There is no k' safety. reason for discrimination since j Although employees may safety has always been, and always contact the NRC directly, remains, the top priority at

$- the most positive approach to Palo Verde y address a safety concem is to go

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'i Employee Concerns:

Dial 82-2702, 4 944-5444, l

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1-800-248-0068.

1;y You may remain

!1 B anonymous.

mo-cI Y CONCERN 1 Your ro To reinforce management's e in address j Q

htpotentialwhhtkblouer expectations in identifying  ; penalticsflice APSat thh time? l A

Protected status is granted safety concerns, three Safety  :  ! whether the concern is raised Concerns All41 ands meetings internally or externally.

A:There is a potential for NRC were held in August. Attendance 3

, civil penalties. There is also a was mandatory for all day-shift l j potential that individuals may be l employees. Video tapes were made t Q: Whats the best way to handha prosecuted for perjury or violation available for people unable to situation wherean aHegation is of the whhtleb/ourrlaw, and the attend.

rasedyou answerit, anddu company could be held criminally employeedisagim with dransarr?

President and CEO Mark DeMichele, Executive Vice liable for activities on the part of certain individuals.

President Bill Conway and Cor- A: Get somebody to help you.

porate Counsel Nancyloftin Whileyou are nevergoing to discussed theimportance and satisfy 100 percent of the people, Q: Ofthe 72 whhtleblouer the person who raised the issue necessity ofidentifying safety complaints, are they a# awaiting concems and answered questions can never tum around and say, action by the company?

from co-workers. Here is a sum- "They never paid attention to me."

mary ofquestions and answen:

A: We never knew how many allegations were raised until we Q: Whyare whhthblournlabekd Q: What wouldyou recommend read and heard the results of the asprotectedemployees andwhat Ins ector General's teport. So it is as a coune ofactionifIam aware airdxypwtatedfrom? as ully diilicult to define whether ofa supervisorouaideofmy organization ignoringorsomehow all 72 are written by 72 individual slam dunkingan individualwho k Employees who raise safety People, whether 36 people initi-concerns immediately have a hmught upasafetyconcern?

ated two each, or whether all or protected status whether or not any have been remedied.

the concern is valid.They're & It's your responsibility is to protected from being treated make that known. My first im-differently by other employees and Pulseis that you should probably Q: Du talkedabout discrimina-from being discriminated against. tion in the wor / place. Can some- go to that individual and say, "You We need to assure that people are not helping the organization.

onefilea discrimination com-who bring forward safety concerns l In fact, you are hurting us." Ifyou P dinti['hefou're ofthediscrimi- don't get the right resaonse,you get answen to their questions and "d'io" l'l""I ' wring K someone?

aren't left dangling. should raiseit up higier. My number (BillConway)is 81-3900.

k Yes, if the working environ-ment is such that one person is Q:IfIrahea cafetycomrrn, wiuI being ignored or tteated indifTer- Q:A ircentsurreydoneforAPS indicatedfivepmblem areas where belabelleda whubleemployeee,  ! ently, this can be considered a a whhthblouvr? people might not be comfortable hostile work environment and w.ay be grounds for a discrimina- rahingsafety concerns. Is that by

& No one can label you a tion claim. leirls ofsuperchian ordepartmend whistleblower unless you acknowl- Etdos thatmean?

ed safety concern to management,yourselfas Qll3Pmtutedstatus onlygranted one. Ifyou

& It means bring that a anywhere from you would be providing a valuable three percent to 14 percent of the oncean individualmakesan service to the company and the alkgation or raiseamucem ouside people in that pan of the organiza-public, ofdrorgani:ation? tion who responded to the survey have said they would not take safety concems to theirsupenisors.

g NEW ERA /Special Edition

ng safety concerns Q:Shouldn't the residts ofthe Q: Whydoes this 211 chargeaffect NRCsurien whichfoundthat92 APSsince Saporito was a contract  ! admitted the truth because the percent ofemployees do not haira issue welghed heavily on his mind employee?

pmblem reportingsafety concenu and he wanted to clear the slate.

to theirsupervison, scare us? This A: Secxion 211 protects all emplayees means that onein ten wouldstill at Palo Veide, induding contractois.

haveaproblem. Q: Thelawfirm ofSnellcb Wilmeris deeply entrenchedwith A:In the sutvey conducted 6y the APS.indPin West. How can ur NRC last fall,it was found that 92 Q: How legitimate was Saporitos' concern? do anythingtoget outofthis percent ofemployees didn't have a rehtionship?

problem reporting a safety con- k Saporito had more than one cem. About six percent said they k We're currently reviewing the concern. He raised around 20. All total performance ofthelaw firm.

would have a problem raising a of the concerns that were of a safety concem and two percent The board members have a very safety nature were thotoughly strong opinion ofthis situation.

said that under no conditions investigated.The others were would they raise a safety concern.

either not safety issues or not an ,

In the more recent compre- issue at all.

hensive survey,90 percent said Q: What about the laur,rn in-The administrativelawjudge theywould raise a safety concern rohrd? Whataretheimplications ruled in his favor that he was 100 percent of the time. So the forAPS?

discriminated against and recent surveys are very close.

events helped to reinforce that What about the onein ten? & Both lawyers at Snelland decision. In all, Saporito fded That's the problem. The data we Wilmer will no longer represent three charges against APS. In the have from the more recent APS APS in any future matters. We can first case,it was proved that the surveylets us break it down so be and are held responsible for the company had discriminated that I now know where the conduct ofanyone we hire to against him and there will be a problems are. With this survey, we represent us.

hearing to determine damages can get down to the bottom of the apple barrel to remove the bad from t3at case.The second and third cases pending will be heard apples, Q: With regards to the numberof at a later time by the DOL concerns bmughtto theNRC how do ur compare to othernuclear Q: Whyis theNRCintwhrdwith plants?

Q:In the Saporito cme, as the the Saporito charges?

supervisorpressurrdto h.?

k The 1nspector General's OE1 ice A:The NRC monitors Section report identified theTennessee A: No, he wasn't pressured. He 211 charges filed with the Depart- Valley Authorityas number one in said that it was his sole decision. allegations, with 150 concems ment oflabor. An investigation sometimes is conducted by the brought up in a four and one-half NRC concurrendy with the year period. We were number two, investigation b Q: Why didthesupervisor tellthe with 72 concems over a four and relatively new. y the Previously, the DOL This is truthafter/xperfardhimsejo one-halfyear period. Unfortu-NRClet the DOL investigate and nately, we can't define whether 72

& After reviewing the testimony, go through a hearing to determine our lawyers discovered inconsis- individuals have raised allegations what happened with a whisde- or 36 people have raised two tencies with the supervisor's blower charge. allegations each - that informa-

> statement. When they presented tion is not available to us.

these inconsistencies to him, he October 1993 3

SAFETY CONCERNS l s

Q: Howlegitimate aw the con- A: At present. there are approxi- A: Employees have a responsibility cerns that hazibeenfiled? mately i25 open concerns. to clearly conununicate with their

Roughly,45 of these are potential supervisors that they have a poten-A:There have been some that are nuclear safety issues. Over the past ,

tial nuclear safety concern . Super-of a safety nature and those have , year, less than 15 percent of the , visors have a responsibility to been addressed. We need to prove potential nuclear safety issues were '

employees to follow up on poten-that a safety concern will be substamiated. tial nuclear safety concerns in a addressed by the company. It may .

l timely manner. As a general guide, not be answered in the manner if reasonable feedback has not you want, but it will be addressed. , Q: How can employeesget w- t- occurred within a month, the i

sponses to safety concerns ifue l employee and the supenisor

! can'tgct nsponsa to odxrmncerm?  ! should, together, escalate the issue Q: Howlongdoes it take to .

to the next level of management.

Investigate a nudcarsafetymncem? l A: Supervisors should work closely l with the frondine employees when l -

A: Simple concems may take only I there is a concern.They need to Qt Can ue change the tendency to a few days to deal with, but more deal with these problems on a go straight to theNRCwith safety complex concerns may take a year timely basis and fully explore the concents?

or more. The average, over the issue. We need to do both these past 12 months for potential things better. A: It's our desired state to have the nuclear safety concems, has been i companyintemally handle safety approximately 85 days. Efforts concerns so that people don't feel l

have been underway to improve j Qt So, ifue takea concern in they need to go to the NRC with this renonse time. For example, houre, address it effectiwly, and them. But, or course, an employee the autaorized number of Em- document whether thh concern s ahvays is free to do so.

ployce Concems staifhas ttipled orisn't validandtheinditidual4 over the past year. stillnotsatisped shoidduego up to ,

thenaslewlofmanagement? Q:Ifueget to thepoint that l nobody can satisfy us andwejust i Q: What's the number ofconcerns A:That is the proper thing to do.

go to the NRC, have nestilldone on our books, how many an ourjob?

nuclearsafety concerns, and what are nedoing to take can ofthem? Q: Whatifaperson has a nuclear A: Yes. Y l

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safety hsue andbringsit up to managementandit takes a uveh, month, oryearfora wsponse?

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h O h PAGE 9 LESSON NUMBER: NGA01-05-RC-003-04 COURSE TITLE: Site Access Training LESSON TITLE: Quality Assurance STUDENT OBJECTIVES SEQUENCE METHODS AND ACTIVITIES Responsibilities include:

A. Comply with requirements. Recent changes by the NRC in A. Show T004.

the Code of Federal Regulatiens allows for action to be taken against Individual workers who willfully violate requ!rements.

B. Pay attention to detail. DO IT RIGHT THE FIRST TIME.

C. Be property trained.

TCS 92-0267 Uni! 2 m 'irip due to D. Use Self Verification Techniques to ensure you do your task D. Example: turning on a light.

Loss of MG Output' correctly. S-T-A-R

1. Stop - get organized and focused on the job at hand. 1. I have to turn on the light.

2. _Think - have the proper procedure, tools and equipment. 2. Where is the light switch?

3. Act - perform the job safely and properly. 3. Turn on the light safely, make sure it is not wet, etc.

4. Review - verify the job was performed properly. Did you 4. Did the light come on, stay get the desired results? What could have been done on and provide adequate better? lighting?

5. Use of these self verification techniques are for use by everyone. Anyone could make a mistake while performing their job which could have an effect on the plant.

E. Participate in a team effort.

EO3. List the steps and suggested F. Inform managementof discrepancies and/ornonconformances F. Show T005.

path for reporting affecting quality or safety.

discrepancies or

' nonconformances' affecting

, quality or safety.

PAGE iOL LESSON NUMBER: NGA01-05-RC-003-04 COURSE TITLE: Site Access Training LESSON TITLE: Quality Assurance STUDENT OBJECTIVES SEQUENCE METHODS AND ACTMTIES TCS 92-0843 *CRDR/ECP Processes

• 1. Start by reporting problem to your supervisor. You can 1. CRDR's will be discussed

~ do this - verbally or using a CRDR (Condition later in the LP.

Report / Disposition Request).

2. Employee Concems Program is next suggested step but 2. Show T006.

is not required (944-5444 or ext. 2704).

a. For OA/ Safety concerns that have not been addressed to your satisfaction.

b. Employee reporting concern may, if he chooses, request confidentiality when utilizing this method.

c. Research of concem will be done by Employee Concems group.

, d. If requested, the employee will be provided feedback as to problem resolution.

3. An officer of APS, a Vice-President or above.

a. For concems that have not addressed to your satisfaction.

b. Employee reporting concem may request confidentiality.

4. Nuclear Regulatory Commission (NRC).

a. If you believe adequate corrective action is not j being taken, you may report this to an NRC inspector (x3737) or the nearest NRC Regional Office.

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l perform receipt inspections of material and .;uggested path for reporting quality or safety documents upon arrival to the site. concerns:

Quality Systems. This group develops and -

Your supervisor (verbally or in writing, maintains the OA Plan. They also ensure use the CRDR)

OA requirements are in procedures. 1 PVNGS Employee Concern Program, 944-5444 or 393-2704 (Ext. 2704) located ,

QUALITY IS YOUR in Building. D (the original Admin l RESPONSIBILITY Bldg.), top floor  !

Everyone at Palo Verde is responsible for -

An officer of APS performing the highest quality work that can be reasonably achieved. Providing proper Nuclear Regulatory Commission (NRC),

documentation of this quality work is also Ext 3737, located in Bldg. D, top floor i required.  ;

Note: Although the recommended order '

Individual responsibilities include: for reporting concerns are as stated above, YOUHAVE THE RIGHTto Comply with requirements. go directly to the NRC first,if you ,

so desire.

Never deviate from an approved proce-dure.

CONDITION REPORT / DISPOSITION  :

Pay attention to detail. REQUEST (CRDR) THE " CRITTER" Be properly trained. Policies, plans, programs and procedures are part of the administrative controls, but Use " STAR" (Self Verification Tech. vou are the one that makes the programs niques). work. You are the one performing work activities.

1. Stop

2. Think PVNGS depends on you to identify problems j

3. Act when (or before) they occur. The CRDR l

4. Review is used to help you identify and report any .

conditions that may negatively impact the Participate in a team effort. safe operation or Palo Verde. 1 Ensure you fully understand your task CRDR forms are available in each unit before you start. Control Room and also from the STA group  !'

(Bldg. A,2nd floor) and the CRDR group Inform management of discrepancies (Bldg B,3rd floor). The CRDR needs to or nonconformances affecting quality be completed and turned in to your supervi- l or safety, sor, the CRDR group, or the Control Room ,

as soon as possible (no later than the end j of shift). See procedure 90AC-OlP04  !

If you identify a quality or safety related " Condition Reporting" for more information. l pmblem. REPORT IT! 1 C3 I

ENCLOSURE 4 I

i

O D D l PALO VERDE NUCLEAR GENERATING STATION

1. TITLE Lesson Number: N G A01 RC-009-000 LP Revision Date: OYO' N Course

Title:

Site Access Training Author: C.T. Seliga Lesson

Title:

Radiation Protection Technical Review: Id bb Duration: 1 Nour Teaching Approval @m ~

ll. INITIATING DOCUMENT (S) g g ( ej 3 15AC-0TR09, General Employee Training Description Program, Rev. 2.01 Updated Final Safety Analysis Report, Section 13.2.9 111. TOPIC REQUIREMENTS 10CFR19, Notices, instructions and Reports to Workers; Inspections USNRC Reg. Guide 8.13, instructions Concerning Prenatal Radiation Exposure, Rev. 2,12/87 USNRC Reg. Guide 8.29, instruction Concerning Risks from Occupational Exposure, Rev. O,7/81 INPO ACAD 91-011, Guidelines for General Employee Training IV. CONTENT REFERENCES NCRP 93,lonizing Radiation Exposure of the Population of the United States USNRC Reg. Guide 8.13, Instructions Concerning Prenatal Radiation Expsoure, Rev. 2,12/87 USNRC Reg. Guide 8.29, instruction Conserning Risks from Occupational Exposure, Rev. O,7/81 75AC-9RP01

• Radiation Exposure and Access Control *, Rev.1 75AC-9RP02 ' Radioactive Contamination Control *, Rev.1 V. MATERIALS REQUIRED Whiteboard, Non-permanent markers, eraser .

Attendance sheet (s)

Exams Tralning alds

,O

b h LESSON NUMBER: NGA0105-RC.009-000 PAGE 13 COURSE TITLE: Site Access Training LESSON TITLE: Radiation Protection STUDENT OBJECTIVES SEQUENCE METHODS AND ACTIVITIES D.

Radioactive Material-Is labeled with radioactive material sti::kers and is usually wrapped in yellow poly bags, yellow hercullte or in clear bags with yellow and magenta markings. Radioactive material could be any material used in the RCA such as wrenches, valves, protective clothing or trash. These items belong in the RCA or at a radioactive material burial site. PVNGS does not want one single radioactive atom to accidentally find its way off site.

Therefore, it is extremely impriant that you can recognize this material and take the appropriate actions if you were to come in contact with it.

EO4. Select the appropriate VI. Abnormal Situations response for various abnormal rcdlological conditions.

A. In the course of your work at PVNGS If you: A. Unit 1 - x1403 Unit 2 - x2403

-see radioactive material unattended or radiological warning Unit 3 - x3403 signs laying on the ground outside of the RCA, do not touch or move these materials. Call Radiation Protection and keep other personne! away.

-find a radiological boundary or posting in your path, do not o cross this boundary. Call RP for assistance if you need somethlag in this bounderled area. @ gdN Vll. NRC Form 3 " Notice to Employees

• N- ' #^ '

EOS. Recognize the purpose of A.

NRC Activities and Responsibilities oround S M (e. ., i%f, 4 th2 NRC. 6, $b'- CMGAN *

1. Licensing and inspecting nuclear power plants.

2. Ensuring nuclear power plants are constructed and operated safely.

l l J

. f P A 9 PAGE 14 LESSON NUMBER: NGA01-05-RC-OO9-OGO COURSE TITLE: Site Access Training LESSON TITLE: Radiation Protection STUDENT OBJECTIVES SEQUENCE METHODS AND ACTIVITIES

3. Ensuring that workers and the pubilc are protected 3. This is their primary from unnecessary or excessive radiation exposure responsibility.

from nuclear power plants.

B. Employers Responsibilities

1. Comply with NRC requirements.

2. Post NRC Notices of Violations. 2. These are posted at plant entrances.

EO6. Recognize the rights and C. Workers Rights and Responsibilities rTposibilities of nuclear plant workors as outilned in NRC Form ,

3.

1. Workers have the right to:

a. Receive Radiological Work Practices training prior to entry into the Radiological Controlled Area.

b. Receive a report of the radiation exposure they received, annually and after termination,

c. Talk to an NRC Inspector privately and confidentially.

d. Request NRC Inspections.

e. Protection from discrimination for filing a complaint.

2. Workers are responsible to:

a. Know how the NRC requirements relate to their work.

PAGE 15 LESSON NUMBER: NGA01.os-RC-OO9-000 COURSE TITLE: Site Access Training LESSON TITLE: Radiation Protection STUDENT OBJECTIVES SEQUENCE METHODS AND ACTIVITIES

~

b. Report violations.

1) To your supervisor.

2) NRC Site Office: x3737 in the Annex Building Lobby.

3) Region 5 Office: 1450 Maria Lane,

1. 210, Walntd Creek, CA,94596, (510) 975 0200.

o****

SUMMARY

• • • • • * * *** SU M M ARY * * * * *

. Summary of Main Principles. .

A. Objectives Review A. Review the lesson objectives. Refer students to their handouts.

B. Topic Review

1. Introduction

2. Terms and Definitions

3. Sources of Radiation Exposure

4. Radiological PostingsfRadioactive Material

5. Responses to Abnormal Situations

6. NRC Form 3

~

11. Questions and Answers 11. Ask questions which implement the objectives.

Discuss students' answers as needed to ensure the

, m _ g- , -- _ _ -__ - _ - - _ _ .*_-

Yellow cad MsgTuta Prckages It is important that you understand that these incidents are more likely inside the RCA All materials which are or may be radioactive and that this course does not provide the will be wrapped in yellow or clear plastic necessary instruction to enter the RCA.

bags with yellow and magenta labels which Further, it is essential that until you complete include the radiation symbol,the trifoil, and the next course, RWP, you may not cross the words Caution Radioactive Material. any radiological barriers. There may be If containers are used instead of bags, they disciplinary action taken against anyone will have similar markings. If you encounter violating Radiological Controlled Area material marked in such a way and they boundaries.

seem to be out of place:

THE WORKERS RIGHTS AND

1. Do Not touch the item.

RESPONSIBT.ITIES

2. Keep others away.

The Nuclear Regulatory Commission has produced the " Notice To Employees". This

3. Contact Radiation Protection by phone document is commonly referred to as NRC or messenger.

Form 3. It addresses NRC, employer and worker rights and responsibilities. The NRC

4. Stay until R.P. says it is okay to leave.

Form 3 will be conspicuously posted in many IF YOU DISCOVER YELLOW AND MAGEMTA BAGS OR places on bulletin boards and at plant CONTAINERS THAT SEEM TO SE OUT OF PLACE, entrances. There is also a copy in this STAY AWAY, KEEP OTHERS AWAY AND handout on the following page. Generally NOTWY RP. lMMEDLATELY it refers to the following:

The Nuclear Regulatory f Commission 9's \ $ NRC responsibilities include:

-4, -Licensing and inspecting of nuclear power

, plants.

- c k -Assuring that workers and the public are protected.

j J

4 ' > D -Assuring that the construction and operation fj[} g of facilities is safe.

\. -Responding to any worker's request for an

\

I

(( '

i

\

inspection and solving of worker identified problems.

k_ # The address and telephone number for the regional office are also conspicuously listed  !

for employees.

l I

)

i 16 l

I 1

The Employer The Workers Responsibilities Palo Verde's responsibility is: Your responsibilities are to:

-To comply with the NRC requirements. -Know and obey NRC work requirements.

-To notify workers of radiation protection -Report observed violations of these require-requirements. ments to plant management.

-To post NRC Notices of Violation involving -Contact the NRC if it is believed that the radiological working conditions. employer has not corrected such violations.

-To record as well as report to the worker his or her radiation exposure.

The Workers Rights You as workers have the right to:

-Receive Radiological Work Practices (RWP) training prior to entry into the Radiological Controlled Area (RCA).

-Receive a report of the radiation exposure you receive, annually and after termination.

-Talk to an NRC inspector, privately and confidentially.

-Request NRC inspections.

To be protected from discrimination for filing a complaint.

17

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