IR 05000213/1990082
| ML20058D575 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 10/23/1990 |
| From: | Eugene Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058D564 | List: |
| References | |
| 50-213-90-82, 50-245-90-81, 50-336-90-81, 50-423-90-82, NUDOCS 9011060165 | |
| Download: ML20058D575 (22) | |
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U.S. NUCLEAR REGULATORY COVMISSION
REGION I
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Report Nos.
50-245/90-81, 50-336/90-81, 50-423/90-82, and 50-213/90-82
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f Docket Nos.
50-245, 50-336, 50-423, and 50-213 License Nos.
DPR-21, DPR-65, NPF-49, DPR-61
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Licensee Northeast Nuclear Energy Company and
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Connecticut Yankee Atomic Power Company
P.O. Box 270 Hartford, Connecticut 06141-0270
Facility:
Millstone Units 1,
2, and 3; Haddam Neck; and
Berlin Corporate Office i
Inspection conducted:
October 1 - 12, 1990
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Team Members:
A. Cerne, Resident Inspector, Pilgrim
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E. Benner, Region I Reactor Engineer
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M. Boyle, NRR Project Manager R. Freudenberger, Resident Inspector, Maine Yankee D. Morisseau, NRC Research, Human Factors Analyst R. Brady, NRR Allegations-Program Manager
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A. Fasano, Consultant i
Team Leader:
D N
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Eugede M. Kelly, CM ef Date
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Technical Support /taff Conclusions:
See Executive Summary.
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9011060165 901024 PDR ADOCK 05000213
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TABLE OF CONTENTS i
Executive Summary i
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1.0 Introduction
1.1 Objective
l 1.2 Background
1.3 Scope and Method
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1.4 Method
2.0 Alternative Methods
2.1 Chain of Command
2.2 Nuclear Review Team
2.3 NRC
2.4 Conclusions
3.0 Organizational Responsiveness to Issues and Nuclear Safety concerns
4.0 Nuclear Safety Concerns Program
4.1 Structure
4.2 Program Implementation
4.3 Interview Results
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4.4 Conclusions
5.0 Safety Ethic
'12 6.0 Organizational Climate
6.1 Work Relationships
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6.2 Communications
6.3 Management Style
6.4 Conclusion
7.0 Management Meetings
Attachment:
Interview Guide - Questions for NE&O Technicians and Engineers i
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EXECUTIVE SUMMARY i
The Team interviewed 127 NE&O employees, including managers and supervisors, at Millstone, Haddam Neck, and the Berlin corporate engineering office.
" Structured" interview questions - wherein the questions could be and were asked in different manners depending upon the interviewee were designed so that the
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responsiveness of the organization to nuclear safety concerns
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could be assessed on a variety of topics.
The questions addressed the following general topics:
problem resolution; the efficacy of the newly created Nuclear Safety Concerns Program (NSCP);
alternative methods to communicate issues and concerns; feedback from a March 1989 Millstone site survey conducted by the licensee, including specifically the issue of " productivity versus safety";
and organizational dynamics such as communications, working relationships, and management style.
Each interview was conducted by two NRC team members, and interviewees were selected randomly with the exception of three individuals.
No individual observations or names were retained; the Team strove to reach conclusions based on qualitative arguments (not statistics) and patterns of observations.
Hence, the terms " overwhelming majority" or "relatively few" were used in reaching a
Team consensus on the organizational climate, responsiveness and safety ethic of the NE&O Group.
Based upon the diversity of questioning, the flexibilLP.y from using three interview teams and the random selection across all work levels, the Team reached a high confidence that the results represent an accurate portrayal of the prevailing atmosphere with respect to solicitation and resolution of nuclear safety concerns.
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With respect to judging the newly formed Nuclear Safety concerns Program (NSCP), the Team received a presentation by the NSCP Director which closely resembled that given to NE&O employees.
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decision was made to not review any of the " red" files containing names of concernees, nor were any concernees. consciously contacted. Reviews were' based on information in " yellow" working files, enabling an assessment as to the handling and resolution of most cases by the Team.
But, because the NSCP-is relatively new, there were few case files available to form any full assessment of the actual " track record" of the Program to date.
Only a fraction of NSCP cases were closed as of this inspection, and not all cases were of substantive technical merit as to warrant meaningful assessment.
Although the structure (location, personnel, protocol) was found to be satisfactory, and a majority of employees interviewed were knowledgeable of and expressed a preference for the Program,. full effectiveness could not be judged by the Term due to-the indeterminate status of case histories resulting from the short history of the program.
Further, although not-reflected by the interviews, the Team felt that the Program was formal and highly i
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chain of command, distinctions made between the definitions issue i
l and concern, and the various memoranda from the licensee that reinforce employee responsibility / obligation to communicate
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concerns to their supervision.
The NSCP does incorporate j
i sufficient elements such that it has the potential to be l
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it has appropriate visibility, accessibility,
and qualified staff).
The independence and credibility needed to
be established to convince an overwhelming majority of employees
to use the Program as an alternative (when the " chain of command" l
doesn't work)
for resolving concerns will, in the Team's
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estimation, be reached when more case histories become known.
j The organizational climate of the NE&O Group was assessed by the Team to consist of the following:
good communications between i
employees, supervisors, and work groups; productive working relationships; and, an open and responsive management style.
While some individual situations were found wherein not all of the above were working fully to the interviewee's satisfaction, there was nonetheless no pattern to suggest impediments to bringing forth safety questions and satisfactorily resolving them.
Despite the previously known and prominent situations within NE&O, there was little polarization outside of the immediate work groups
involved that would indicate any hesitancy in solving safety
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problems.
The Team drew this conclusion from the fact that an overwhelming majority of those interviewed stated a confidence in using their chain of command, inferring their trust in
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supervision.
Further, the responses to interview questions related to the topic of productivity versus safety confirmed a safety consciousness and a conservative approach to solving safety
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problems throughout the NE&O organization, therefore reflecting a
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generally sound safety ethic.
l The Team's overall conclusion was that there exists within NE&O
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I four equally accessible options (supervision, NSCP, NRC, NRT) from which to pursue safety concerns, with an overwhelming preference for and confidence in the supervisory " chain of command."
The new NSCP contains the appropriate elements and the potential for a
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successful program, pending further reinforcement of its independence and credibility by way of actions (i.e.,
track
record).
Feedback to employees is needed to balance the initial i
training, counteract any early perceived negative feedback, and i
fully convince a similarly overwhelming majority of NE&O employees
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that NSCP is a viable option to. resolving safety questions at
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Northeast Utilities nuclear plants.
Finally, the Team found no pattern which would suggest that nuclear safety concerns are not being brought forward - by any alternative method - and answered-with timely feedback and' appropriate resolution.
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1.
Introduction 1.1. Obiective This Team inspection addressed the responsiveness of the Northeast Utilities company organization to nuclear safety concerns by:
(1)
evaluation of the structure
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and effectiveness of the Nuclear Safety Concerns Program (NSCP);
(2)
conducting structured interviews of a
representative sample of Nuclear Engineering and operations (NE&O)
Group employees'
attitudes.
and opinions regarding the solicitation and resolution of safety concerns; and (3) evaluating alternative methods l
to the NSCP.
1.2.
Backaround Prominent allegations received ~over,the past two years, related U.S.
Department of Labor complaints, and the
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evaluation thereof by NRC -have led to questions regarding the proper solicitation and-resolution of employee concerns throughout the Northeast Utilities-organization.
Several safety concerns have been substantiated from these issues, and NRC investigations of certain findings under
CFR 50.7 have.been instituted over the past two years.
In response to the NRC's last SALP reports issued in final version in April 1990, the licensee instituted an
" enhanced" NSCP in January 1990 with creation cf a
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dedicated director reporting directly to the NE&O Senior Vice President and at an. office in East Lyme which is remote but centrally located-to the Millstone, Haddam,-
and Berlin sites.
The NSCP is relatively new (nine
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l-months) and has few case-files active-to date, l
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A six-person Team inspection was-conducted from; October 1 - 12, 1990.
The inspection consisted of a
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briefing by and review of the files and protocol for the
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NSCP, structured interviews - at each of the Millstone units on October 2 - 4, ' interviews at the Haddam Neck
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site on October 5, and interviews-at the Berlin corporate office on October; 9 - 10.
The Team interviewed 10 managers, 18 supervisors, ' and 99 ' staf f members for a total of-127 interviews.
This represents approximately eight percent of-the total ' technical population of NE&O personnel.
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Three disti'act elements were evaluatedt
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NJCP structure and effectiveness.
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Alternative methods to identify, solicit, and
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resolve issues or concerns.
Structured interviews to evaluate employee
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opinions and attitudes related to various topics related to concern resolving at the Haddam and Millstone sites as well as Berlin Corporate offices.
1.4 Method
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Evaluation of.the NSCP consisted of review of Corporate l
Procedure NEO 2.15 (the implementing procedure for NSCP)
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and briefing of the C2am by the Program Directors which was equivalent to the presentation of the program given to NE&O employees.
Team members were encouraged to stop
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the presentation at any time for clarification of
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issues.
Evaluation of program structure was accomplished at the NSCP East Lyme office by review of Protocol NSC PP-3 which is;the procedure by which the NSCP is internally operated.
In addition, review of-the i
NSCP file system was done, in particular, on the
" yellow" files which are the working files of the program from which names and references have been removed for confidentiality considerations.
The NSCP Director and the NE&O Senior Vice President were-also interviewed, although not subjected "to the same t
questions as in the standard Interview. Guide for other personnel.
Evaluation of alternative methods consisted of review'of--
Millstone Administrative Procedure ACP-QA-1.20,-Problem Reporting, as well as all-of the procedures. referenced in that document.
However,- although opinions.and attitudes of employees were evaluated relative to
alternatives (i.e.,
NRC, Nuclear Review Team, and.
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various routine reporting'
mechanisms such'
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nonconformance or plant incident reports), these methods were not specifically assessed in and of themselves by the Team.
l Structured interviews were conducted which consisted of
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l two Team members - one transcriber and one questioner for each interviewee.
A set of-16 standard interview
questions (attached to-this report); with several l
supplements to each question was asked in each j
interview.
Varied wording of the questions was allowed i
(hence the term " structured") as long as the intent l
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remained the same.
Sessions lasted from 30 - 60 minutes each but were not limited to that time frame.
Interviewees were-encouraged to elaborate on any topic they felt was relevant or important, and were also given time at the end of-the interview for-additional observations and questions.
Identity protection, while not strictly offered, was inferred by not recording the name of the interviewee; only his/her organization, position and site affiliation.
To minimize inspection impact,, interviews were conducted in private locations, close to the work area.
Also, consideration was-given to critical path activities.
The - Team decided not to request the names of.any actual users of the program.-
However,~each organization was notified'that.any= person seeking to talk to the Team would be welcome.
Conversely, any person specifically not wishing to speak to the Team would be accommodated (although none were encountered).
To ensure that a broad cross-section of NE&O was represented,!the sample was randomly selected.
Generally, a manager, a supervisor, and 2 - 3. staff members were randomly selected from.each organization.-
Three individuals were preselected because of their-previous involvement with safety concerns at'NNECO.
The intent of the interviews was' to accomplish 'a qualitative evaluation in order to assesa meaningful patterns.and support the Team's conclusions, 2.
Alternative Methods
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t The optiona available to all personnel involved =iniwork or activities related to NortheastLUtilities nuclear. facilities for communicating Nuclear-Safety Concerns:are described-in Nuclear Engineering 'and. - Operation : (NE&O)
Procedure 2.15.
These options _are further discussed uin-various other - NE&O administrative documents, letters,_
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' memoranda.
Specifically, there are four major paths open'to NU employees-in communicating a Nuclear Safety.Conceru.:
These paths _are represented by the four separate. points of contact'available to receive.and act upon any stated concern,Las follows:
(1)
NE&O management (i.e.,Jthe." chain of command").
(2)
Nuclear Safety. Concerns Program'(NSCP).
(3)
Nuclear Review Team'(NRT)
(4)
Nuclear Regulatory Commission. (NRC)-
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The licensee clearly documents and advertises the fact that
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This position was clearly corroborated in the overwhelming opinion of NE&O employees, as stated in the t
interviews conducted by the NRC Team during this inspection-i (see section 3 of this = report).
To the extent that the emphasis upon chain-of-command use is a basic = principle in-the NSCP and considering the NSCP's strong interaction with NE&O management in following-up concerns, options (1) and~(2)
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above are generally viewed as being' closely related.-
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However, from the perspective of providing separate paths;for the resolution of. concerns, options (1)
and.(2)
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considered distinct, alternative methods available -toi any concerned individual, and are as readily-accessible'for use i
as options (3) and=(4).above.
Option (2),-i.e.,
the NSCP itself as-a separately staffed
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organizational entity with.its own protocol, is discussed-in greater detail in Section 4.of this inspection report.
The other three options are further elaborated upon below ~ as alternative methods to the NSCP.
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2.1 Chain of Command The chain-of command,-
besides representing the licensee's preferred first point of contact for Nuclear
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Safety Concerns, also provides for a'.way of.: assigning accountability, reportability,
'and ' tracking control:
l responsibilities to the appropriate-line management personnel.
This method allows for the communication of
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any Nuclear Safety Concern.to successively higher; levels'
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of NE&O management.
At any time.the concern--may also be taken to any of the other three-alternative methods for
resolution.
Utilization of the chain of command for
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handling problems also provides- ' flexibility'
in interfacing with routine programmatic corrective. action
mechanisms (e.g., the Millstone ~ Administrative Control Procedure ACP QA-l'. 2 0 )
for identified ; Nuclear Safety Issues.
While the NRC interviews. revealed-an.
incomplete.
understanding at the worker level.~ of the i licensee 's differentiation between a nuclear-safety concern.and an issue, such differentiation'
takes.
on. -increased significance of how' a problem would Lbe handled ife raised through the chain-of-command path.
Worker confidence;in the chain of command as a -viable- -option for raising concerns was probed -by the NRC interviews and is further discussed in Section 3 of this report.
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2.2 Nuclear Review Team
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Another alternative method 'of communicating a Nuclear Safety Concern is contact with the Nuclear Review Team.
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The NRT consists of a group of-outside consultants who (
have been retained by the. licensee over the years for :
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the conduct of special stadjes and 'the pursuit' of
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specific' problems brought ' to their attention via this.
route.
In addition to - the description of the. NRT
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provided in NEO Procedure 2.15,: a June 1990 letter from'
the Chairman and Chief Executive Officer of Northeast
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Utilities to NE&O. employees discussed the NRT and; its
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members.
.This letter also providen contact points for-the employees end indicates upper management's assurance
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that the communication of' concerns' to the-NRT will be handled in a confidential manner.
Worker views of:the
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NRT as an alternative path for raising concerns :were-questioned during the NRC interview process,= with the results evaluated in Section;3 of this report.
2.3 Nuclear Reaulatory Commission A third alternative method of communicating a Nuclear Safety Concern' is direct = contact, with the Nuclear-Regulatory Commission.
NEO 2.15 provides NRC Form 3'as
an attachment and refers to its language in reenforcing
M3 licensee's position that the. preferred-path for resolving concerns is the chain of command, starting with the concerned
. individualls supervisor.
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Additionally, employees who choose the NRC as>the; point of cotsact-for their concerns are requested - by' the licensee to' concurrently notify'their supervisor.
Use-of the NRC ar. an option for getting Nuclear ' Safety concerns ~ addressed is generally recognized by employees at all worker levels.and'is acknowledged as a protected
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right of nuclear employees under federal regulations.
Nuclear Safety Concerns-directed to the-NRC-are
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evaluated and processed ' in accordance with the NRC
' l program for the management of allegations.
Depending H
upon the specific issue raised asLa concern, certain
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allegations may be turned over to the' licensee' for resolution. :In the. case of Northeast Utilities, recent allegations handled in such a way have not been referred
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to NSCP for-processing, but~rather at;NU management's discretion have been' turned.over toiline management ~.for.
review and closure.
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I 2.4 Conclusions In summary, the four options available-to NE&O employees
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for resolving their Nuclear Safety Concerns appear to be equally accessible to the employees depending upon their:
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individual desires.
Notwithstanding NEO's emphasis upon use of the chain of command as'the preferred ^ path for raising concerns, sufficient alternative paths have been advertised as available.for use.. The NSCP.as a' separate.
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programmatic path'is further. evaluated in~Section 4 of
this inspection report.
The effectiveness of the'three'-
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alternative methods'to the NSCP have not been' assessed r
by this NRC inspection effort'.
However,_ access to all four patt9 was generally. confirmed by the results'of the
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Team's interview. process,.'with personal preference
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governing each individual's choice.
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3.
Oroanizational Responsiveness to1 Issues and Nuclear Safety Concerns During the interview process,..when employees were asked,-"If you had a Nuclear Safety Concern, ; what; would-you do?", ^ the overwhelming majority of-the' employees responded that.they would raise the question to their immediatel supervisor.
Most people stated that they-felt that their : supervisor would satisfactorily resolve the question.
LHowever, when asked i
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if their supervisor couldn'tc or wouldn't. Lesolve the I
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question who would they.go-to next?"? the. overwhelming majority stated that they would. take the Lquestion up the chain of command, through successive layers or their.line-management (up to and including theavice-presidential level'
in many cases),
until the' -question: was resolved.
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satisfactorily
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I a satisfactory resolution to-their' question from-their line management, where would they go next, a significant minority of resolution other than the NSCP:(i.e.,(the'NRC or the NRT).
A smaller number stated that they,would go outside these four alternative resolution methods.
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.Most employees stated that there were no impediments to raising a safety question.to: their supervisors'. -
That is, most employees stated that'. they didn't ' need to provide a
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recommended. solution'to their question,-they didn't.need to provide a written statement' of their. safety. question, ~ and
that supervisors-were open :and, responsive to safety l
questions.
Many employees stated that it 'would be
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preferable, if - possible, to provide'. a solution and. many stated that if their supervisor couldn't. supply an immediate answer to their question,.the supervisor would document.the-question to ensure that it as tracked'and; answered..
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j NRC Form 3,
" Notice to Employees," which-is required to.be displayed at nuclear facilities,: states,-among other. things, that an employee may contact'the NRC about! safety-questions-and that an employee is protected from discrimination.if he does raise a safety question.
When the Team asked employees-
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if they could recall the Form and. describe its; intent,-most employees could not recall the detailed message in the form, but they did know that the NRC was an available' avenue-for j
question resolution.
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The initial method chosen by employees interviewed to resolve.
safety questions -(through line management) demonstrates ; a high degree of confidence of employees:in their management.
The interview results also demonstrate that'there-is a lesser-i degree of confidence of employees in'the NSCP to date.. An evaluation of the reasons for not usingJ the' NSCP and the-
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effectiveness of the NSCP is presented in Section 4..
4.
Nuclear Safety Concerns Procram 4.1.
Structure The Team reviewed NEO Procedure NEO 2.~15, Nuclear Safety Concerns Program (NSCP)., Revision 6;.~ Protocol NSCPP-1, Revision 2; and held discussions with NSCP personnel to determine the structure of the program.
-Procedure NEO 2.15 describes the: alternatives available to NE&O personnel for communicating ' their=
Nuclear -Safety Concerns (NSC) '.
The-procedure' contains'. adequate:
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guidance for an employee to contact the Director, NSC i
Program,.
and present
.his/her.. concern.. with
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confidentiality (when requested).
'Better distinction between the. terms issue and nuclear safety _-concern was-amplified in a March 21, 1990,. memorandum-(NEO-90-G-90)'
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from the Senior Vice President of.NE&O to all: employees.
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4.1.1 Protocol Protocol NSCPP-1, Revision 2, -describes the)
l methodology l used-by-the NSCP ? personnel in
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receiving. and processing ' reported ' concerns.
The concernee is allowed x to present - his/her concern and -is informed of. confidentiality options.
He/she is informed of the-estimated time. that the investigation might ' require.a The concernee, when presenting the. concern in person, presents ' the information and,is ;not -
required:to document.the concern lin.their own-words.
The concern is taken~and written down.
by the NSCP person.
If the concern < is considered
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be reportable, the ' NSCPf
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Director will.
contact and inform-the-concernee for further discussion-on confidentiality and the NSCP Director will retain a: memorandum on file noting that the individual was contacted.
.The protocol addresses the various ways that a concern can be received and how the received concern will be. processed..
Also, there-is. guidance provided on conducting. exit interviews (i.e.,
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personnel leaving the NE&O. group to. either
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another non-nuclear organization or-outside
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the company) and' where ' particular types; of -
concerns; are routed, (e.g.,. individual and l
' harassment concerns are' directed to HumanL Resources).-.
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t Further, the NSCP-Protocol allows, for. a-choice of internal-organizational groups to
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perform the needed-investigation;
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resolution. Lrequired.to follow up.
on a
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concern.
The NSCP Director reports to the
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NE&O Senior Vice 'Presidenti The NSCP Director requires that.
the Einternal organization, which he determines should investigate / review a ~ concern, respond inLten
days.
When the work is-completed on a'
concern, _the NSCP_
Director reviewal - the; l
actions for' acceptance.^If not. acceptable,-he has the option to return i the concern for
additional work using,~for example',othe~line L
of command above; the responding group, or other. independent internal or external source for investigation.
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The relatively few: files'available for, review l
by the Team. did not reveal that ' the NSCP had -.to date - -. utilizedi external ' resources
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for ' review or investigation.
However, NSCP personnel emphasized. :to -'.the Team that the j
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Directori has ' the_ yoption L to have a1 concern -
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1-address'd outside ~ the Company, in, parallel e
L investigation
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and/or third party groups.- 'Oncel satisfactory resultsThave been
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received, the.-NSCP. Director 4 prepares. and'
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i; sends'a? feedback: report.to the~concernee and l --
allows-for-the-concernee to; respond -on his/her acceptance.
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4.1.2 Locatiom The - structure includes the establishment 1 of
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the NSCP office' at"a location a, fews miles
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The interviews performed Lby the Team-indicated that the location was not a problem ' for _the majority of personnel. contacted.
. Tolli free phone
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numbers are -established 'for' program-use.
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Further, the NSCP _ Director stated that.
concern (NSC) drop boxes will be-located in various work areas for ease of communicating-i concerns. -Also, the_NSCP. personnel.can go to the various work areas.
4.1.3 Confidentiality The discussions with the NSCP : Director - and
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his assistant indicated that confidentiality, is provided by the Program in the structure ~
r of their filing = system to assure privacy and, controlled access.-
.Further, an : - individual
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not requesting confidentiality. is ~ informed--
that his/her concern will be handled - in the -
same manner as if. he/she had requested-confidentiality.
When the concernee receives:
the final close-out or resolution of~his/her-concern, he/she may inform -the NSCP
'o f i
his/her satisfaction.with the response.
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-Significant emphasis.
is _
placed ons the-
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confidentiality of - concernees, both in: the.
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hand-out material and in.the presentation and training on the program..
This.- significance i
is also borne-out by personnel. interviewed when questioned:on'how he/sherwould design a=
n NSCP.
However,;in two NSCP filesF memoranda-l which were prepared to document resolution.of-
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the concern ;could be viewed as; an ' indication:
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part of those' involvedl in 'the resolution i
process of tne need to protect ; the ' identity.
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of those who raise concerns.. One: memorandum,
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which received distribution ~throughout1 the-affected work f force, '(1) identified that the concern arose.via. the _ NSCP and..(2) identified
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the specific work force fromL which the the-licensee to provide positive'l feedback to ~
concern arose.
Notwithstanding the'need for.
L its employees - on the' effectiveness of - the,
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NSCP~
and the possibility. t h a t;. : s p e c i f i c
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concerned-employees-. may,
- have
- waived'
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c'onfidentiality, the Team L felt' that.those involved with'. resolution.~of concerns; brought-to-the NSCP..should be.' careful to avoid even the-appearance
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breech.
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confidentiality.
Some-additional training or l
guidance to NE&O staff (outside the NSCP) may l
be required in this area.
4.2. Procram Imolementation (Actual Case Historv)
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In addition to the review of the structure and implementing procedures of the NSCP, the Team reviewed all of the " yellow" files in the NSCP office.
While the-
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Team noted evidence.in some: files of ' a satisf actory -
resolution or approach to-the concern, the - number of--
cases that have been completed by the NSCP (i.e.,' file-
'l closed) is not sufficient to allow a: determination on!
the effectiveness of the program in dealing with nuclear safety concerns and responding to L concernees..
Until there is a sufficient number of cases of some' technical y
substance that' have been : processed ~ completely by e the j
program,- at which time the-NRC can perform a full. review'
of the actions'taken by the NSCP, the question ofJfull j
effectiveness of the NSCP-remains indeterminate.
j 4.3.
Interview Results-4.3.1. Knowledae of the NSCP j
Nearly all of theEemployees interviewed. by :the Team were aware' of the. program 'and had some
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general knowledge of how 'it operates.
This knowledge had been received through formal
'l training presentations and: management memoranda.
Many had varying specific.or detailed' knowledge
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of the - program; - however,- : this 'is. balanced by-responses from-the- '
large-majority of interviewees that,they know how. and where to obtain the -information which would ' enable. them tj to use the program.
4.3.2.
Effectiveness of the NSCP Most interviewees - had no direct knowledge on which to base an opinioniof the? effectiveness of'
the NSCP.
Most employees. interviewed felt that
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the program had.the= potential.to be successful, and-that' it : contained the.- appropriate elements-which'should ensure effectiveness over time.
4.3.3.
Feedback Based ~ on' the. Team's-interviews,.there exists isolated,
' informal (second and-third-hand)
feedback about' the. program that is negative.
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Positive (counteracting)
-feedback. about 'the
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evident from the interviews.
The Team evaluated the _ opinions of the significant minority :ofz i
employees interviewed, who: _istill have. not.-
identified NSCP as a preferable alternative to the NRC, as reflecting questions related to the
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Program's perceived independence from the "line (
organization."-
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4.3.4. Need for NSCP
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The' overwhelming majority of.the interviewees believe there is a need for a program like NSCP, (e.g.,
some people.may ' notl be able to _- bring.
s concerns'to;their supervisors:and "need"another-l
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path or avenue").. However, most of these people
stated that'they didn't believe1they1wouldLever.
use the program because they had,a good working; i
relationship with their supervisor,.and,would'be able to resolve any. questions / issues / concerns-that may arise through their chain of command.
4.4.
Conclusions The Team reached the following conclusions regarding the NSCP:
Although the NSCP as structuredLhas theLpotential-
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for success, a fully effective: program:ist: notnyet in evidence because:.
It is a young program-(nine months'old)_.
t o
confidence.in~the chain of command-appears to
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o minimize use-of the program.;
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Credibility of the program has; not yet been o
established..
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o The NSCP case files thatchavecrun the courseJ
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to closure.do not provide sufficient data:to:
confirm-absolute. success.-
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area of confidentiality..
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Employees are, aware of.'the programL.and have.
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information available L:to them Mif "they_ choose tot j
use the program.
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Employees believe there is a need for1the. program.=
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A small number of employees have received negative
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(second or third-hand) - feedback.,Little positive-feedback either formal or informal was'in evidence regarding NSCP.
5.
Safety Ethic In early 1989, two surveys were conducted ' at. the Millstone site which were of interest to the Team.
Both surveys were conducted to aid in measuring the strength of the safety ethic at the site.
One survey was conducted by. the NRC resident inspector office (NRC Inspection Report 50-245/88-21.
issued on December 21, 1988) and the other-was conducted'by'
the Millstone-site director in March 1989.
'As part of the
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personnel interviews conducted by the Team ' (see attached Interview Guide),
a ' series of. questions was - asked which-
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addressed participation in the surveys, knowledge.of survey, results, and recognized actions taken to ' address areas. fore improvement-identified by the survey results.
The survey completed by the NRC Millstone resident inspection staff in December 1988 received a ~ limited distribution to-the technician level of the Millstone site staff.
The Team'found that few of the interviewees participated in or recalled-the NRC resident survey.
-No knowledge of actions taken. as a l
result of this survey was' evident.
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The survey conducted 'by the licensee l received.' wide distribution at. Millstone Land addressed various topics.
related to the safety ethic at'the site.
The topics included the program for resolution of. employee concerns, procedure compliance, the conflict between productivity fande nuclear -
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safety,- and industrial-safety ' issues..
The'. Millstone-interviews revealed that the : majority of-the interviewees
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responded to the survey.
Specific topics'from'thatLaurvey,
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While not recalled'
in detail'
by
' interviewees, were nonetheless generally remembered..Most interviewees did not correlate any changes or corrective actions with the survey.
i Some considered the published survey:results.to serve as-a f
reminder, reemphasizing issues of importance to maintaining a
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positive safety ethic..
Based. on discussions during the
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Millstone interviews, the Team' concluded.that'the " conflict"'
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between productivity and nuclear safety was the,most, widely)
recognized topic. -. Most interviewees ' expressed: the copinion that nuclear safety-receives priority over productivity.
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Overall, the Team considered that comments from 'the interviewees indicated that 'a generally 1 sound safety ethic exists'within the Northeast Utilities NE&O organization.
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6.
Orcanizational Climate i
6.1 Work Relationshios The majority of those interviewed, both at the Millstone and Haddam Neck plant sites and at the corporate office, indicated that working relationships'within groups were good.
The relationships were also. characterized E as useful and productive.
One manager stated that, even when there was tension in relationships, it~ was
" positive tension" which led to creativity.
-At one
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plant, however,'some of those interviewed indicated that
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teamwork could be improved across working groups.
6.2 Communications
Communications at the plant sites were-generally viewed i
favorably _- in all-directions (i.e.,
vertically up and down, and laterally).
The majority of those interviewed at the corporate office (engineers, technical staff, supervisoro, and managers)- stated that L communications..
were good - across groups; however, they; felt routine:
vertical communications, both up and-down, were in some'.
instances poor although. not.specifically regarding concerns.
Those who elaborated said-that there was too much communication done through formal memoranda and not enough through verbal communication.
This did.not alter.
the perception that people felt they could communicate with their management chain.
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6.3 Manaaement Style l
People interviewed ~at the nuclear plant sites generally-indicated that the. management style-was-dif ferent-_- for each of the units.
- While some-subjective comments indicated a preference for one. unit over another, noi meaningful patterns could be drawn.
The. majority at
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both the' plant sites and the corporate _ office indicated-that-management was'open and: responsive and, encouraged people to bring queetions, problems, or; issues.to them.
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Management was characterizedL by al majority as. safety conscious.
First!
line. supervisors
~ and managers-indicated that their management was. supportive, ~ open, and safety conscious..
No.real: -trends'Lcould-be identified in the way: people characterized management.
The only conclusion that can be drawn by.the team from.
the interview responses with respect.to management style
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L is that-there is no prescriptive utility ' poli _cy concerning management style-or techniques.
Management'
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'those..
interviewed as ranging from totally-.
participatative to prescriptive.
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6.4. Conclu+ LQD
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The Team found no patterns or evidence from the i
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l interviews which would be-indicative of any barriers to the free flow of information with respect 2 to bringing issues and safety concerns to the supervision 1 and
.I management within Northeast Utilities NEGO. Group.
An.
l overall trust and confidence in' NE&O : supervision and-direct management was reflected by the responses;of.a
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majority of those interviewed.
7.
Manaaement Meetinas-l Meetings with NE&O - management representatives and the NRC Team Leader occurred throughout the inspection, 'on a. daily.
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basis, to discuss the progress, logistics, and findings:of:
the Team.
An exit meeting was-held on 0ctoberc12, 1990, to-t discuss the. preliminary conclusions of ; the. Team, : with. the-
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following principals present:
Northeast Utilities E.J. Mroczka, Senior Vice President, NE&O.
E.A. DeBarba, Vice President,. Generation Engineering P.F. Santoro, NSCP Director R. Laudenat, Millstone Site,: Assistant to' Director l
R.
Zysk,.NSCP Staff S.
Scace, Millstone Site Director:
G.L.= Johnson,' Director, Generator--Engineering P.A.
Blasioli, Nuclear Licensing' Supervisor!
l E.M. Richters, NUSCo Counsel:
.
L.T. Keezing, Nuclear Information Specialist'
t-Nuclear-Reaulatory Commission l
E.M. Kelly, Team Leader E. Wenzinger, Region I, DRP Branch Chie'f s
l W. Raymond,. Senior Resident Inspector,tMillstone-
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l Team Members
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.ATTACIMENT
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- INTERVIEW GUIDE **
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INTERVIEW QUESTIONS FOR NORTHEAST UTILITIES INSPECTION
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TECHNICIANS AND ENGINEERS
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A.
CONCERNS (In General)
1.
If you had a Nuclear Safety Concern, what would you do? -
o Who would you go to?
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o What if they didn't take action?
o Where would you go next?:
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B.
NSCP 2.
Describe how the Nuclear Safety Concerns Program works?
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~ How did you learn about the program?
4.
When did the program begin?
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Why do you believe the program was. started?:
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Do you'believe there is a need for this program 7;Why?L o
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Do you believe the program is effective? If not,-why not?
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Can you give me an example?
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Have you ever used the Nuclear. Safety Concerns Program?.
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If sa,.were you satisfied with.the results? If not, why not?.
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o If not,.would you 'use it? : Under wha't circumstances?.
o Why wouldn't you use the program?
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Do you know anyone who has used the program? If so, what was his j
or her experience?
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6.
What other methods exist to communicate safety concerns? (NOTE TO
'I INTERVIEWER: Alternatives are immediate supervisor, management, and
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NRC.)
o Have you ever used any of these methods?
o.
If so, which method (s) did you use?
o Were you satisfied with the results? If not,;why not?'
If you hava not used'any of these methods, why not? (NCrfE TO'
o INTERVILWER: It is acceptable for them to say they have no concerns.)
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7.
What is the differen e between an issue and a safety concern?
-l 8.
If you were going to design such a program, how would'you do it?
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L C.
SURVEYS
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9.
Do you recall a survey the utility conducted last year?
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o Why.was the survey conducted?
What issues were addressed in the survey?,
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- Did you respond? 'If not, why not?.
o Did the survey omit issues you thought should'be included? If so, o
l what are they? (NOTE TO INTERVIEWER ' Don't be led into a
p detailed technical discussion of specific issues.)
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Were any actions taken as a result of the survey? ' If so;can you give -
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me an example?
o Have you seen'or read the report on the survey results? Who received-l-
the report? -
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What reaction did you have to the results'of the' survey as stated in.the -
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report?
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Interview Guide
1 10.
The survey results indicated that there were concerns in several areas. -Since -
those results were published, can you tell me about what changes there have.
been in:
o progress toward improvements and changes in procedures?
o attitudes concerning procedural compilance?
o resolution of industrial safety issues?
J o
attitudes about conflicts between productivity and safety?_-
11.
Did the responses to the survey change:;
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' your behavior? Give an example.
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o your attitudes?- Give an example.
o your supervisor's behavior? Give an' example.
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o your supervisor's attitudes? Give an example, o
management's behavior? Give an example.
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o management's attitudes? Give an example.
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12.
Do you recall a survey conducted by the NRC Resident Inspector?
o Did you respond to that survey?L o
What issues were addressed in that survey?
Was there any feedback from'that survey on' the part of the NRC o
Resident?
Were there any actions sken as a result o'f the survey? If so, can.you.
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- ive 'me an example?
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Interview Guide
.D.
SAFETY ETHIC / ORGANIZATION CULTURE 13.
Does your supervisor encourage you to come to him/her with issues:
and concerns?
o If so,'_how does he/she respond?
o What type of support does your supervisor get from line mangagement,-
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U if needed, in responding to issues or concerns?
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14.
How would you describe the working relationship in your shift crew or working group?
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15.
How would you describe communications here?
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- upward and downward
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across working groups 16.
How would you describe the management style at this unit? On the site? 7At f
this utility? -
o Are there differences in management style between units?
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OTHER a
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17.
o Are there any other observations you would like to make?
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