B16232, Provides Response to RAI Re Proposed Third Party Oversight of Comprehensive Plan for Reviewing & Dispositioning Safety Concerns Raised by Employees

Provides Response to RAI Re Proposed Third Party Oversight of Comprehensive Plan for Reviewing & Dispositioning Safety Concerns Raised by Employees

ML20134M008
Person / Time
Site:	Millstone
Issue date:	02/14/1997
From:	Goebel D NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES SERVICE CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
B16232, NUDOCS 9702200056
Download: ML20134M008 (17)

Text

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1 i Ne=t Milet ne ffwes e H pe Ferry Rd.. Waterford, CT Utilities System e.o.nori28

Waterford, Cr 06385-0128 (203) 447-1791 I

l February 14,1997

! pocket Nos. 50-245 i' ' E-)El 50-423

B16232

U.S. Nuclear Regulatory Commission

! Document Control Desk Washington, D.C. 20555 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 Proposed Third Pady Oversight of Comprehensive Plan for Reviewing and Dispositioning Safety Concerns Raised by Employees

Response to Reauest for Additional Information i

j in our letter dated December 23,1996 Northeast Nuclear Energy Company (NNECO) proposed that the independent, third party function to oversee the implementation of NNECO's comprehensive plan, as required by the NRC's Order dated October 24,  !

j 1996, be fulfilled by a team under the direction of Mr. John W. Beck of Littis Harbor j l Consultants, Inc. (LHC). To further your review of LHC, your letter dated January 30, I l 1997,' requested a written response to twelve topic areas. These topic areas were

also discussed during our February 5,1997 meeting. Our written response is contained in Attachment 1. >

j During our meeting on February 5,1997, some issues were discussed which required

further clarification. Regarding restrictions placed on LHC for performing future work l for NNECO, it is now our position that individual team members and their companies, including John Beck and LHC, will be contractually restricted from performing or seeking new work at any NU facility for the duration of the IOTEC project and for 12

months following completion of the IOTEC project. Should a team member leave the  ;

i IOTEC project prior to the end of the project, they will still be subject to these conditions  ;

until 12 months after the IOTEC project ends. LHC has agreed to the terms of these -

restrictions. These terms will become part of the contract between NNECO and LHC.

4 in response to a question regarding whether or not there was sufficient experience in a few technical areas, we stated that it may be necessary to supplement team membership based on the technical nature of the issues that arise during the project.  ;

I I

' Nuclear Regulatory Commission letter, William D. Travers to Bruce D. Kenyon ,

dated January 30,1997.

}l M

9702200056 970214 PDR ADOCK 05000245 P PDR

U.S. Nuclear Regulatory Commission

. , B16232\Page 2 l The ' selection of new team members will be made using the same criteria and methodology used in assembling the current team, as discussed in Attachment 1. In addition, we intend to use the following process for informing the NRC and obtaining approval of new team members. After successfully verifying the independence of the

! new team member, information on the new member will be fonwarded to the NRC for i review and approval. We intend to allow the new team member to begin to participate l in IOTEC activities as soon as the independence verification process is completed by

NNECO and information on the individual has been sent to the NRC. This will ensure i timely execution of the review and assessment duties for which the new team member

is responsible. Should the NRC ultimately not approve the new team member,

compensatory actions will be taken, as appropriate, such as a secondary review of the

} work the individual had peiformed, based on the nature of the NRC's rejection of the

! individual. This process will be formalizaed in the IOTEC project controls that will be i

prepared by LHC and approved by the NRC

{ Subsequent to the February 5,1997 meeting, questions have been raised regarding j the independence of Ms.- Billie Garde and Dr. Paul Wood. The basis for these i questions is their prior work with NU. We have characterized the nature of their

{ previous involvement with NU in Attachment 1. As is the case for the entire team, we

, have considered the work conducted for NU by both of these individuals and have l

concluded that, subject to the administrative controls that will be enacted by the IOTEC

! team leadership, these individuals should not be disqualified on the basis of 1 l independence. The administrative controls, which will be stated in writing and agreed

! to by the individuals in question, will be binding for the duration of the member's involvement on the IOTEC. These controls enforce compliance with the Order of October 24,1996, by ensuring that they are not assessing activities with which they have had previous involvement. Both Ms. Garde and Dr. Wood bring unique and valuable skills and perspectives to the IOTEC. In the case of Ms. Garde, we bel!sve the attributes are critical to the needs of the IOTEC.

Commitments There are no commitments contained in this letter.

If you have any questions, please contact me.

Very truly yours NORTHEAST NUCLEAR ENERGY COMPANY

) i David M. Goebel Vice President, Nuclear Oversight

U.S. Nuclear Regulttory Commission

. ,B1'6232Page 3 J -

3 Attachment 1: Proposed Third Party Oversight of Comprehensive Plan l Response to Request for Additional information I cc: W. D. Travers, Director, Special Projects Office

, H. J. Miller, Region i Administrator i P. F. McKee, Deputy Director of Licensing, Special Projects Office  !

W. D. Lanning, Deputy Director of Inspections, Special Projects Office i S. Dembok, NRC Project Manager, Millstone Unit No.1 ,

1 D. G. Mcdonald, Jr., NRC Senior Project Manager, Millstone Unit No. 2 l

J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 l l T. A. Eastick, Senior Resident inspector, Millstone Unit No.1 )

I D. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 l A. C. Corne, Senior Resident inspector, Millstone Unit No. 3 I i

, Mr. H. L. Thompson, Executive Director of Operations j Nuclear Regulatory Commission One White Flint North l

i 11555 Rockville Pike

)

Rockville, MD 20852-2738 Samuel J. Collins, Director Office of Nuclear Reactor Regulation l One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 i

I Assistant General Counsel for i

Hearings and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 4

! 4 l

i l

3

Docket Nos. 50-245 S1M

.g.4_2a

B16232 i

Attachment 1 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 Proposed Third Party Oversight of Comprehensive Pian Response to Request for Additional information February 1997

U. S. Nucbar R:guktory Commission B62,32%ttichm::nt 1\ Pcg31 NNECO's Response to the NRC's Questions Regarding Little Harbor Consultants, Inc.

1. Describe the organizational structure ofLittle Harbor Considtants, Inc. (LHC). Include a description ofpast LHC experience in work associated with handling employee concerns.

Little liarbor Consultants, Inc. (LHC) is a sub-chapter S corporation formed in 1992 to serve as the corporate vehicle for the consulting practice ofits President, John W. Beck. 1 The organizational structure of the team LHC has assembled to provide the independent oversight activities required by the October 24, 1996, NRC Order is shown on Attachment A. The other members of the LHC team are independent contractors affiliated I with LHC for the Independent Oversight Team for Employee Concerns (IOTEC) project.

l The primary basis of NNECO's selection of LHC to fulfill the IOTEC role is the  !

experience, and character, of the team. We believe they individually and collectively I possess the experience and demonstrated performance not just in the area of handling employee concerns, but in the overall area of leading, managing and structuring successful nuclear organizations that possess a strong nuclear safety culture. NNECO considers this the primary lesson of the critical assessments that led the NRC to issue its order of October 24,1996. Specifically, it is not NNECO's understanding that a weak Employee Concerns Program led the NRC to issue its order, but rather that weaknesses in management, leadership, and the resulting weak nuclear safety culture were primarily responsible. As NNECO moves forward to correct these past deficiencies and to create a strong nuclear safety culture, we believe LHC represents the appropriate organization to ,

critically assess our performance in these areas and provide fact-based feedback to the NRC and NNECO on our progress, and identify any areas where additional effort is required.

The following is a discussion of each member's experience relevant to the IOTEC project.

John W. Beck - Team Leader. Mr. Beck has participated in assessments of employee concerns programs at three different utilities during the past three and one-half years.

These assessments involved eight different sites and twelve reactors. One of these engagements extended to the broader issues associated with the nuclear safety culture at three of these sites. While a Vice President with Texas Utilities he was Chairman of a third party, independent Senior Review Team which provided policy direction for the Comanche Peak recovery effort. In that capacity he was also responsible for executive management of the Comanche Peak Response Team, a third party, independent organization of engineers and technical experts who implemented policies and programs issued by the Senior Review Team. He was Program Manager for a comprehensive Review of Nuclear Operations Performance at Unicom (previously Commonwealth Edison).

I

U. S. Nucisar R:gulatory Commission l

- B6232\ Attachment 1\ Page 2

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. lolm o M. Griffin - Deputy Team Leader. Mr. Griffin currently serves on the Nuclear ,

Safety Board for Comanche Peak advising senior management on a broad range ofissues I involving nuclear safety, employee concems and nuclear operations. He has extensive i

. experience in reviewing declining utility perfomtance in the areas that led to the issuance I of the October 24,1996 Order. Mr. Griffin has led or facilitated several independent .

assessments, diagnostic evaluations and performance improvement programs for utilities, l including those on the NRC " watch list". He has served as a mentor and advisor to senior l management in preparing the utility for initial operation of a nuclear plant. He has held l positions as Vice President, Nuclear Operations and Senior Vice President of Arkansas Power & Light Co.

Robert F. Encimeier - .Mr. Engimeier is a Registered professional engineer and a certified Lead Auditor (ANSI N45.2.23). He has served as a Quality Assurance Managing Consultant to the Group Vice President of Nuclear at the South Texas Nuclear Project.

During that engagement Mr. Englmeier managed the Nuclear & Quality Concerns Program and coordinated the STP Employee Concems Program (ECP). He was Chairman of the Employee Concems Program Oversight Committee and provided senior management with a monthly report regarding the effectiveness of the ECP. This assignment was during a period when the ECP and the project were successfully recovering from a serious decline in performance.

Billie P. Garde - Ms. Garde has worked in and around the nuclear industry for nearly fifteen years, the last ten of them as a lawyer. She has represented individuals and third-party stakeholders in a number of situations involving allegations of harassment, intimidation aad discrimination in the nuclear and other industries. She has also worked  !

on' employee concerns investigations and employee concerns program development issues, including training. We believe Ms. Garde brings key experience and critical perspectives to the LHC team. She is clearly not a nuclear industry " insider" and in fact is not held in high esteem by some in the nuclear industry. We do not agree with this  !

characterization and have welcomed her contributions to our understanding of employee l concerns. Her personal experience as a whistleblower will enable her to effectively interface with various internal and external stakeholders. Of particular importance from our perspective, her involvement on the IOTEC will help establish a suitably high standard for NNECO's performance to ensure we are doing things right in our efforts to establish a strong nuclear safety culture that encourages and respects individuals with concerns.

- As is discussed under Question 5, Ms. Garde's involvement with NNECO during the preparation cf the employee concerns comprehensive plan earlier this year may, upon first look, appear not to meet the independence requirements of the Order. We would like to point out that she was at Millstone Station mentoring the Employee Concerns Task Force during their development of the comprehensive plan. for considerably less than half i the days the task force worked on the plan. Further, based on our discussions with Mr.

Beck, we believe appropriate controls will be placed on Ms. Garde's involvement with the IOTEC to assure any actual or potential conflicts are avoided.

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U. S. Nuclitr Rtgul: tory Commission l B62,32%ttichmsnt 1\ Pggs 3 l Based on her unique qualifications in the employee concerns area, we fully believe she is  ;

a key member of the IOTEC team and strongly support her selection by LHC. Her i unique combination of whistleblower experience and detailed knowledge of the law in l these areas are critical attributes to be sustained. Additionally, we believe her role in .i mentoring the team that developed the comprehensive plan enhances her role on the  :

IOTEC by providing her detailed knowledge of the basis and intent of the plan. This makes her uniquely qualified to evaluate the effectiveness of our implementation of the  ;

plan James K. Perry Jr. - Mr. Perry has worked as an executive for major corporations and as an independent consultant in the human resources area for over twenty years. He has experience with a wide variety of industries. For the past four years he has been l President of his own human resources consulting firm. His firm has. developed - l techniques for conducting and analyzing employee surveys so as to yield specific quantitative information. This quantitative information can then be used for assessing the effectiveness of cultural changes.

Donald M. Ehat - Dr. Ehat has had many engagements designing and executing culture .

awareness surveys in both commercial and government settings. This experience, coupled with hands-on involvement in team building, assessing employee morale and human behavior observation will be of critical importance in the task of. developing survey and interview instruments to provide insight into the Millstone culture and the effectiveness of the Employee Concerns Program.

Donald P. Irwin - Mr. Irwin is a Partner with Hunton & Williams and has over 25 years of experience in his law practice associated with all aspects of the nuclear industry, including representation of utilities in reactor licensing cases, in NRC rule making, and in  ;

related litigation. Recent years have seen a focus on enforcement issues involving NRC's l NRR and 01 offices, with representations of individual employees, as well as licensees.  ;

Alan B. Cutter - Mr. Cutter has more than 30 years of nuclear experience in technical,  !

executive and consultative roles. He is currently a member on the Safety & Audit l Committee for the Monticello and Prairie Island units, and is a consultant to Zion Station in support of safety evaluation reviews. His diverse background in nuclear power and recent experience in consultation and nuclear oversight roles provide a solid basis for his contribution to this project.

Richard W. Dubiel - Mr. Dubiel has more than twenty-four years experience in applied health physics, decontamination and decommissioning, chemistry, radiochemistry environmental monitoring and radioactive waste management program development and impi: mentation. He is familiar with rules and regulations of the Nuclear Regulatory Commission and the Department of Energy. Past assignments have included project manager for decontamination and decommissioning activities at several Department of Energy and Department of Defense facilities. He has performed program reviews to 3

U. S. Nucirr R:gulatory Commission

,  ; B62,32\Att chm:nt 1\ Paga 4

. assess the management and technical adequacy of operational radiation protection programs. Ile has provided over four years of professional consulting services in the areas of radiological safety and emergency preparedness, including expert testimony in licensing hearings and government investigative hearings. He recently performed an assessment involving a significant element of disaffected employees at a nuclear facility.

His sensitivity and understanding of all stakeholder's interests contributed to the successful conclusion of this assignment.

Donald R. Fercuson - Dr. Ferguson has over 24 years of experience in the nuclear industry. Since late 1994, he has been a member of the Kaiser-Ilill team that holds the Integrating Management Contractor contract to operate the Rocky Flats Environmental Technology Site (RFETS). During the period of 1990-94, he served in a senior technical advisory role to the management of EG&G Rocky Flats. For the six years prior to that, he served as a consultant to electric utilities, where he designed and managed complex programs to address problems associated with the design, construction, licensing, and operation of nuclear power plants. During this period, Dr. Ferguson has served as Project Manager for the resolution of regulatory problems preventing the issuance of the operating license for Comanche Peak, and he managed the review process for producing investigative reports to be used in the licensing hearings. He has experience in interacting with the NRC staff and management while serving as Program Director of the third party activities at Comanche Peak. Before entering the consulting profession, he managed the development of the Departnent of Energy's (DOE) program plan for advanced reactor safety technology development and subsequently directed the ofiice that managed this program for DOE for several years. Dr. Ferguson's extensive technical background and experience in the regulatory arena provide a solid background for successful participation on the IOTEC.

Timothy J. Snyder - Mr. Snyder has over 25 years of experience in providing management and technical engineering consulting services to the nuclear power industry.

For the past six years, he has specialized in management consulting focused on producing significant organizational and work process performance improvements. His areas of expertise include work process analysis and design, information system management, procedural effectiveness, and organizational design. In this capacity, Mr. Snyder has participated in several performance evaluations at nuclear plants. He has conducted assessments of engineering organization effectiveness and has performed technical audits and independent technical reviews. His technical engineering experience has included the performance and management of a broad range of design and analysis activities related to power plant structure, systems, and components. Over the past ten years, most of his technical consulting has been in the form of facility design reviews and third-party overviews of utility contracted work scopes.

Paul J. Wood - During twenty years as a management consultant Dr. Wood has made significant contributions to the clarification and resolution ofissues affecting the safety and regulatory performance of electric utilities and various other public companies. He is an acknowledged industry leader in the application of qualitative and quantitative risk 4

U. S. Nuclsar R:gulttory Commission

. B6232%ttachment 1\ Prgs 5

. assessment techniques to the effective management of safety, health and regulatory risks.

This leadership has included design and implementation of risk management systems for nuclear power plant operators and for numerous facilities conducting energy and defense-related research, development and production. His efforts have contributed significantly to the current general acceptance by regulatory agencies of risk management as a fundamental tool in effective management of operations.

Dr. Wood began his career in 1969 working at Westinghouse Electric Corporation in the development of advanced nuclear power reactors. There he managed the second full-scope probabilistic risk assessment (PRA) of a nuclear plant in the United States.

Beginning in 1978, as president and a principal in a series of successful technical and management consulting firms, Dr. Wood developed and demonstrated management systems that utilized the results of PRAs to support management decision making and resource planning. After establishing CYCLA Corporation in 1990, Dr. Wood and his partners have introduced risk management systems and tools to enhance communication of risks, decision making, and budget allocation processes across the broad spectrum of facilities operated by commercial contractors for the Department of Energy.- Dr. Wood worked recently with the US Enrichment Corporation to design and manage the resubmittal of their application to the NRC for a certificate of operation. This task involved very complicated and unprecedented regulatory issues.

Dr. Wood's background and acknowledged industry leadership position in safety analysis and related analytical techniques will provide a unique perspective to the IOTEC. His superior problem characterization and analysis capabilities will not only greatly contribute to success in his areas of focus but will positively contribute to the performance and success of the entire IOTEC team.

Jeffrey J. D. Jeffries - Dr. Jeffries has more than thirty-two years of leadership and experience covering a wide range of responsibilities within the nuclear industry. He has proven technical capabilities, and is a nationally recognized expert in the areas of nuclear safety and oversight, regulatory affairs and applied risk assessment. His efforts have been focused on making the nuclear industry effective and cost competitive while improving safety performance. Dr. Jeffries has performed assessments of nuclear safety cultures and has assisted utilities in developing self assessment programs. He has participated in l several performance evaluations of nuclear organizations and has served on Nuclear ]

Review Boards for several utilities. As Manager of Nuclear Oversight for Carolina j Power & Light Co., he was responsible for the overview of all nuclear activities at three  !

nuclear stations. In addition, Dr. Jeffries has experience in the use of PRA techniques.

In addition, LHC will supplement the team on an as-needed basis to provide needed skill sets for specific issues, inch ding specific engineering disciplines. The method of supplementing team membership is discussed in the response to Question 11.

The LHC team experience in work associated with the handline of employee concems <

from an employee's perspective is as follows:  :

5 l 1

U. S. Nucl=r Rigul: tory Commission 862,32\Att chm:nt 1\ P:g3 6 John Beck has participated in assessments of employee concerns programs at three different utilities during the past three and one-half years. These assessments involved l twelve reactors at eight different sites. His role in the assessments included over 250 separate, structured interviews with employees and contractors, collation of the interview results into coherent themes and issues, conducting interviewee feed-back seminars to validate thematic results, and developing, writing and presenting reports to utility executive management. The focus at three of the sites was on the broader subject of l nuclear safety culture, including the employee concerns program. During his tenure at Texas Utilities he served on an executive review board which met monthly and reviewed the status of all employee concerns. The status review was focused on prioritization of issues and the timeliness and adequacy of corrective actions whenever corrective actions were needed to resolve concerns.

Robert Enulmeier served as the Quality Assurance Managing Consultant to the Group Vice President of Nuclear at the South Texas Nuclear Project. During that engagement he managed the Nuclear & Quality Concerns Program and coordinated the STP Employee Concerns Program (ECP). He was Chairman of the Employee Concerns l Program Oversight Committee and provided senior management with monthly reports  !

regarding the effectiveness of the ECP. This assignment was during a period in which the project was successfully recovering from a serious decline in performance.

Billie P. Garde has worked on employee concerns program development issues and training associated with employee concerns programs. She has represented individuals and third-party stakeholders in a number of employment related litigations involving allegations of harassment, intimidation and discrimination in the nuclear and other industries.

2. How was thefinancial and organi:ational independence of LHCfrom NNECO verified?

What criteria were used to establish independence and what information was reviewed?

The NRC Order of October 24,1996 established that the third-party chosen to oversee the conduct of NNECO's comprehensive plan for improving the employee concerns climate at Millstone must be independent of NNECO such that none of the members would have had any direct, previous involvement in the activides at Millstone that they will be overseeing.

Each LHC team member has executed an Independence Certification that addresses this criteria. We have provided copies of these certifications to the NRC as part of our submittals of the LHC initial and revised technical proposals for performing the IOTEC project. The individual certifications go on to identify past involvement with NU and/or NNECO. These are discussed under Question 5. In cases where some manner of past involvement with NU or NNECO has occurred, individual-specific administrative controls will be imposed on the individual's involvement on the IOTEC to assure they are l never involved in assessment of activities relating to their prior involvement. This is to l 6

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. B6232\Att: chm:nt 1\ P:gs 7

- assure compliance with the Order. NNECO has reviewed each Certification of Independence and team member resume and found no disqualifying issues, subject, where appropriate, to the administrative controls relating to specific past involvement of individual team members.

Beyond the requirements of the Order, NNECO has established additional criteria to judge prospective IOTEC contractor and team members; namely that they should have no ownership of, or direct control over, NU stock. To verify this element independence, NNECO has taken the following actions for all proposed team members:

. NNECO has verified that no team member is the owner of record of NU stock.

. NNECO has verified that no team member has ever had, up until the time of being named to the IOTEC team, unescorted access to any NU nuclear facility.

. NNECO has verified that no team member has been an NU employee.

3. Has LHCperformed anyprevious workfor NNECO?

NNECO has reviewed the NU purchase erder data base and determined that LHC, as a corporate entity, has never been under contract to NU. This has also been verified by LHC's principal, John Beck. l l

As mentioned previously, some team members have had prior involvement with NNECO  ;

or NU outside the context of LHC. This prior invalvement is discussed under Question 5. '

4. Willfuture work that LHC may seek to performfor NNECO be restricted?

Individual team members and their companies, including John Beck and LHC, will be contractually restricted from performing or seeking new work at any NU facility for the duration of the IOTEC project and for 12 months following completion of the IOTEC project. Should a team member leave the IOTEC project prior to the end of the project, they will still be subject to these conditions until 12 months after the IOTEC project ends.

5. Has any of the proposed team members been previously employed by NNECO cr been employed by a contractor and assigned work involving any of the Millstone units? For any involvement by a team member, identify the work performed, the time fame, and controls to ensure the team member does not become involved in that same technical area as part ofthe thirdparty team.

Some LHC proposed team members hase been involved in work for Northeast Utilities as delineated below. LHC team leadership will be responsible for assuring that the particular individuals do not participate in any activities which are specified in the following paragraphs as prohibited. Each team member will be provided a letter by the team leader specifying the area (s) in which he or she will not be allowed to participate. Receipt of this letter will be acknowledged by the team member's signature and returned to the team leader for retention. Taken individually and collectively, these measures will assure 7

U. S. Nucl=r R:gul: tory Commission B62,32%ttachm:nt 1\ Pegs 8

. ' compliance with the Order by ensuring no team member becomes involved in assessing activities relating to their prior involvement with NU or NNECO.

Billie Garde provided, along with another individual, consulting services in December of 1996 and January of 1997 to the team of employees NNECO charged with the development of the Employee Concerns Comprehensive Plan for Millstone. Her consulting services on that project have ended with the publication of the Plan on January 31,1997. LliC team leadership will ensure that she will be excluded from participation in the programmatic review of the Comprehensive Plan. The programmatic review will be performed by other LIIC team members. She will, however, be assigned responsibilities for participating in the ongoing oversight of the Plan's implementation by NNECO. Other critical duties for Ms. Garde include interfacing with extemal individuals and stakeholders, participation in the design and performance of employee culture assessments, and providing awareness training to team members in the area of concerned employees.

l Paul Wood provided consulting services to Northeast Utilities Service Company on a part-time basis over a period from 1983 to 1985. His consulting assignment consisted of 6

two tasks. The first task was to perform a concurrent and independent review of the PRA that was being developed by Westinghouse for Millstone Unit 3. The second task was advising NU on how to apply risk tools to the Integrated Resource Management System that NU was developing as part of the effort to develop an Integrated Living Schedule.

Rese assignments did not involve the development of any specific models or analysis, and are best characterized as mentoring NUSCO personnel and assisting in technology I transfer. j If any issue under evaluation by IOTEC is determined to be related in any way to the Millstone Unit 3 PRA or its development, Dr. Wood will be precluded from involvement.

If this were to occur, Dr. Jeffries, who has considerable experience in PRA, will be assigned the responsibility to provide the technical review and assessment of the issue.  ;

Dona'd Fercuson performed a short duration (approximately one week) assignment at Millstone 3 in 1984. The assignment involved a completeness review of technical documentation transmittal from Westinghouse to NNECO. lie will not be allowed to participate in any oversight activities which involve that particular document transmittal activity.

Donald Irwin represented several nuclear utilities, including Northeast Utilities, in support of their participation in NRC rule-makings on ECCS, GESMO and the uranium fuel cycle. This took place in the 1970's and early 1980's. Should any of these areas arise in the course of LHC's oversight activities, Mr. Irwin will be excluded from any involvement.

John Griffin's company (The Kestrel Group, Inc.) had an employee at Millstone Unit 1 in the summer of 1996 performing an evaluation of the Millstone Unit I work control 8

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U. S. Nuclear Rrgulitory Commission B62,32\Attachm:nt 1\ Pcg3 9

, . program. Mr. Griffin was not directly involved in that evaluation. His employee, who actually did the assessment, will not be involved in any IOTEC activities, nor will Mr.

Griffin be allowed to participate in any IOTEC oversight activities related to the area of work control.

6. How were team members screened to determine that they had no financial interests in NNECO? Does any proposed team member have financial interests (e.g., securities) in Northeast Utilities (NU)/NNECO?

Although not required by the NRC's October 24,1996 order, as stated under Question 2, the criteria established by NNECO was in pan that no team member should own or have direct control over NU stock. Each team member was required to certify such on his or

-her Independence Certification. NNECO verified that no team member is the owner of record of NU stock.

7. Describe any experience /quahfications of LHC or the proposed team-in assessing employee concerns programsfrom the perspective ofthe employees.

The methodology used in assessing the effectiveness of employee concerns programs and characterizing nuclear safety cultures, in which John Beck was involved, was developed to elicit the response of employees using structured interviews. The structured interview output was then synthesized into underlying themes and recommendations for improvement. The themes and recommendations were then verified in a series of ,

employee led workshops, facilitated by the consultant. Thus the entire assessment, while  !

performed by consultants, was done from the perspective of the employee.

Most of Billie Garde's work in the nuclear utility field has been on the behalf of employees and by the very nature of those engagements has been from the perspective of the employee. Her training and teaching consultations in assisting nuclear utility management develop a better appreciation of what motivates and is important to the

" whistle-blower" is fundamentally driven by her understanding and familiarity with the perspective of the employee. This is particularly true in the case of employees who have become disaffected for reasons having to do with intimidation, harassment or i discrimination.

Bob Encimeier's work at the South Texas Project, while it was done from a management position, was successful in large part because of his intimate understanding of the employee's perspective.

While not specifically in the area of employee concerns, Don Irwin has experience over the past several years in the area of representing individual utility employees who are the subject of or involved in OI investigations. Some of these individuals have been concerned employees or are employees who have been dubbed as " whistle blowers" as a result of their actions.

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8. . Based on our preliminary review of the resumes in your proposal, it appears that, in

. general, the disciplines neededfor the review are being provided. However, we request l that you discuss the general quahfications of the review team and the overall distribution

' of the technical, investigative and employee relations disciplines during the February 5, 1997 meeting.

. As requested, NNECO supplemented the information it had earlier provided during the February 5,1997 meeting. That information has been summarized in response to earlier .

questions, and in the experience matrix provided as Attachment B.

In general, team members were selected to ensure a diverse experience base in order to provide different perspectives when evaluating issues:

John Beck and John Griffin have extensive management and technical experience in all aspects of nuclear power operations as well as in managing large projects. -

Bob Englmeier has hands on experience in the day to day management of a successful Employee Concerns Program.

Billie Garde has considerable experience with employee concerns programs throughout the United States and is intimately familiar with employee relations from the concerned employee's perspective.

Don Irwin and Billie Garde have considerable experience in conducting investigations.

They will have primary responsibility for any investigations that may be conducted as part of IOTEC activities. In the event additional investigative experience is' required, either due to IOTEC workload or the need for specific expertise, LHC will obtain the services of additional professional investigators. Additional firms are being contacted in order to provide an adequate resource pool to draw upon. All additional personnel will be processed in accordance with the process outlined under Question 11.

Jim Perry has'many years of successful experience in the various fields of human i resources and has participated in and assessed efforts to change corporate cultures. The  !

individuals assembled to address potential technical concerns are also very experienced and represent capabilities in areas of potential concerns at Millstone.

LHC recognizes that specific concerns may arise that require expertise that is not resident in the existing team. If this should occur, LHC will ensure that individuals with the appropriate experience are added to the team, in accordance with the provisions discussed  !

under Question 11. I

9. Describe the team's experience in conducting root cause evaluations, developing corrective actions, and implementing corrective actions l While the entire LHC team has not worked together as a team on past projects, various 10

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B62,32%tt:chmtnt 1\ Paga 11  :

l l , team members have worked together and individually on projects that required them to 1 perform root cause evaluations and to develop and implement corrective actions. Team l

! members were selected based in part on their prior experience and proven ability to l

perform these functions. The resumes of the team members provide clear indication of ,

j these capabilities. A few examples.of projects where team members have demonstrated  !

the ability to identify root causes and to develop and implement corrective actions are: ,

4 Independent Comanche Peak Review Team (CPRT) Beck. Fercuson. Snyder The  ;

CPRT reviewed all facets of the design of the Comanche Peak primary and secondary  ;

l plant, evaluated the QA records data base for adequacy and completeness, recommended changes, updates and additions to the historied. record where it was found deficient,  !

evaluated the adeguacy of ongoing corrective actions being implemented by project j ' personnel, and recommended changes where necessary.

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Comanche Peak Operational Readiness Evaluation - Griffin. Fercuson. Jeffries - This was- .

j an independent review conducted prior to Comanche Peak receiving an operating license. I

The evaluatica reviewed all functional areas and identified problems within each area that required correction prior to unit operation. The evaluation team identified the corrective

, action necs wry to resolve each problem and team members worked with the utilities' i managers to implement the corrective actions. ,

l Commonwealth Edison Evaluation of Nuclear Division Performance - Griffin. Beck.

! Jeffries. ' Fercuson -- This. was a diagnostic evaluation conducted for senior utility l j management at Commonwealth Edison to identify the root causes contributing to the  !

I cyclic and poor performance of their nuclear units. The evaluation identified the root i causes of the performance issues and provided Commonwealth Edison with a detailed i

description and plan for implementing the necessary corrective actions.

i Zion Station Diesel Generator Task Force - Griffin - This was an independent task force

. to investigate and determine the root causes for the unreliable performance of the safety  !

! related diesel generators at Commonwealth Edison's Zion Nuclear Station. The task force

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l was successful in the identification of the root causes which included design deficiencies, operational and procedural problems and maintenance deficiencies. The task force also o identified the corrective actions necessary to resolve these issues and monitored the

effectiveness of their implementation. Reliability of the diesel generators improved significantly as a result of the task force efforts.

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j In addition, John Beck. John Griffin. Al Cutter, and Jeff Jeffries have held senior positions with responsibilities for nuclear plant operations. In these capacities they have

had direct responsibility for ensuring that root causes of problems affecting their organizations were identified, and that corrective actions were implemented effectively.

Bob Encimeier. as part of his assignment at South Texas in redesigning and revitalizing j the site's employee concerns program, was involved in determining the root causes of the

program's decline and designing / implementing effective corrective actions.

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a i i 10. Principal team members are identified in the December 23,1996 proposal. How much

, time are the principal team members anticipated to devote to the third-party oversight i i e.[ fort? i

- Little Harbor Consultants has obtained a commitment from each team member to support j the third party oversight project for its duration. Team members have other contractual obligations which must be fulfilled, however, the size and composition of the team will i . provide flexibility to meet contractual obligations without impacting the third-party oversight effort.

I It is anticipated that John Beck and John Griffin will be involved on essentially a full time basis, and either Mr. Beck or Mr. Griffin will maintain a full time site presence at

Millstone for the duration of this effort. It is anticipated that Robert Englmeier will spend

approximately 75% of his time supporting the IOTEC project. It is also anticipated that j the front-end activities will require 50-75 % of Ms. Garde, Dr. Ehat and Mr. Perry's

attention. This is anticipated to last for a few months. ,

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l L Other team members will be involved on an as-needed basis, as required by structured interview activities and specific technical issue demands. This level of effort will then

probably average one to two weeks per month, depending on the nature of IOTEC j activities.

j Team leadership will work with the individuals to schedule member participation and to

{ resolve schedule conflict to assure that team members are available when needed to

perform project critical tasks. If required to assure timely execution ofIOTEC activities,

! team leadership will supplement the team with additional members. When required, additional team members will be brought on in accordance with the provisions discussed j under Question 11.

i l 1. Your submittal states that LHC indicated that it will supplement or change team members

as developments warrant. Please describe how this process will work. Include a j description of how financial independence for these new individuals, if used, will be i established. \

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' i A written procedure covering the augmentation of team membership will be included in j the independent oversight plan to be submitted for NRC approval.  ;

I Should it be necessary to replace a team member or augment the team for any reason, the

! choice of a new team member (s) will be made by exercising the same criteria that were

used in the first instance. Those criteria were that the proposed team member had to i

] ' possess the technical qualifications appropriate to the anticipated assignments, had to i j have a reputation of the highest standards of ethical and professional conduct, and has l l demonstrated mature and sound judgment. The member should have experience in l 2 assessing organizational performance and be willing to make the necessary commitment 12 i

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. 862,32\Attachm:nt 1\ Peg 313 l

,. . to the project. While LHC feels that all the likely technical areas can be assessed by current team membership, should an issue arise for which the current team is not qualified to assess, then additional resources will be recruited. They will be held to the same criteria used to select the original project team.

The independence of additional LHC team members will be established and verified using the same standards and methodology as was used for the original membership, as discussed under Questions 2 through 6. All new team members will be required to execute a Certification ofIndependence.

Following successful verification ofindependence by NNECO of a new team member, information on the new member will be forwarded for NRC review and approval. It is our intention that a new team member may begin to participate in IOTEC activities as soon as the independence verification process is completed by NNECO and information on the individual has been sent to the NRC. This is to assure timely execution of the l review and assessment duties the new team member is responsible for. Should the NRC ultimately not approve the new team member, specific compensatory actions will be j taken, such as a secondary review of the work the individual had performed, that are )

appropriate based on the nature of the NRC rejection of the individual.  !

12. What process is used at LHC to handle differing professional opinions among their staff?

The LHC team will attempt to reach a consensus for all findings and recommendations resulting from the oversight activities. This objective creates an atmosphere in which team members must vigorously defend their particular views to other involved team j members, when differing opinions exist. Should there be instances where team consensus  ;

can not be reached, the applicable oversight report will identify that a differing professional opinion exists and include a written description of the differing opinion prepared by the dissenting team member (s). This written description will include a summary of the majority team view, a description of the dissenting views and how they differ from the team position, and an assessment of the consequences or impact if the dissenting position is not adopted. A protocol or project policy statement describing how 1 differing professional opinions will be handled will be included in the independent oversight plan.

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