ML20138E034

Comment Supporting Revs to General Statement of Policy & Procedure for Enforcement Actions.Util Does Not Understand How Investigation Rept Is to Be Edited in Order to Protect Privacy of Individual

ML20138E034
Person / Time
Site:	Beaver Valley
Issue date:	04/23/1997
From:	Jain S DUQUESNE LIGHT CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR13906, RULE-PR-MISC 62FR13906-00004, 62FR13906-4, NUDOCS 9705020019
Download: ML20138E034 (2)

Text

. _ ._ _ _ __ . _ _ _ - . _ _ _ _ . _ - _ __

ll Duquesm @Wy a ggggyggaea o SNppigM5077 0004 W APR 29 P3 55 eel"Md" eem r.,$llUlEE Nuclear Servic . i Nuclear Power Division OFFICE OF SECRETA,.R' April 23, 1997 l DRANCH l

! Secretary of the Commission DOCKET N(M8ER U. S. Nuclear Regulatory Commission Washington, DC 20555 PROPOSED f IMlLE S 2Pff 56 l

i ATTN: Docketing and Service Branch (. 64F# /3706)

Subject:

Beaver Valley Power Station, Unit No. I and No. 2 l BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73

Policy and Procedure for Enforcement Actions; Policy Statement Amendment and Request for Comn;ents l

l

' Duquesne Light Company (DLC) is responsible for the operation of Beaver Valley Power Station Units I and 2. DLC has reviewed the amendments to the General Statement of Policy and Procedure for Enforcement Actions regarding predecisional enforcement conferences that are based on findings of discrimination. The request for comments was published in the Federal Register on March 24,1997 (62 FR 13906). The policy statement will allow some degree of participation by the complainant in the

predecisional enforcement conference. DLC hereby submits the following comments.

One of the hallmarks of an Employee Concerns Program is maintaining the confidentiality of the claimant. This confidentiality would be compromised in cases where the enforcement conference is made public. Also, if the enforcement conference is open to the public, then DLC does not understand how the investigation report is to be edited in order to protect the privacy of the individual.

The amended policy statement assumes that the discrimination cases in which there is a full adjudicatory record is held in favor of the complainant. DLC would like to know what, if anything, in the process would change if the Department of Labor holds in favor of the licensee. )D 9705020019 970423 g PDR PR MISC 62FR13906 PDR DEllVEllllG

• UAL

n y n ,y 'f WMW Nuclear Power Division ENERGV P.O. Box 4, Route 166 Shippingport. PA 15077-0004 D5 to

e

. Beaver Valley Power Stati:n, Unit No. I and No. 2 Policy and Procedure for Enforcement Actions; Policy Statement Amendment and Request for Comments Page 2 Thank you for the opportunity to comment on this issue. If you have any questions on this submittal, please contact Mr. J. Arias, Director, Safety and Licensing Department, (412) 393-5203.

Sincerely,

& B-

. Sushil C. Jain l

l l

l l