ML20058P032

Package Consisting of Attachment to Employee Concerns Program

ML20058P032
Person / Time
Site:	Millstone, Haddam Neck  File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	09/22/1993
From:	NRC
To:
References
NUDOCS 9312220367
Download: ML20058P032 (8)

Text

jEP22'93~0851 HRC MILLSTONE OFFICE P02

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EMPI4YFF CONCERNS PROGRAM Plant Name: Haddam Neck,1 11 stone

'ts 1, 2, and 3 Licensee:-

Connecticut Yarkee A ic Power Company, and Northeast Nuclear Energy' Company Docket:

50-213,50245,50-336, and 50423 A.

PROGRAM:

1. Does the licensee have an employee concerns program?

YES. ne th first developed the employee concerns prorum la August,

_j 1982. A separate nuclear safety concerns program office was located off-site i

on January 1,1990

2. Has NRC inspected the program? Report #:

YES '

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De NRC previously miewed the licensee's Nuclear Safety Concerns Program in report 50 213/96-82,50-245/96-81,50-336/90-81,50423/90 82,SpecialReview Group l

report on March 6,1992 and Special Team Review dated June 8,1993. De licensee _

j presented the contents of the nuclear safety concerns program (NSCP) to NRC-Region 1 on March 22,1990, l

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SCOPE:

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1. Is it for:

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a. Technical?

YES. De principal focus of the program as documented

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in procedure NEO 2.15, " Nuclear Safety Concerns" is to risolve nuclear and radiological safety concerns. - De licensee also has procedure NEO 2.30, _" Differing.

Prof"r r! Opinion Resolution". with an objective to evaluate differingjudgmawak om matters of technicaland safety significance that differ from the pmaling line management position.

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b. Administrative?

YES. Procedure NEO 2.15 states that the licensee's

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NSCP will racilitate contact between the alleger and the

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appropriate Northeast Utilities management for non-200032 nuclear concerns.

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c. Personnel issues?

YES. Procedure NEO 2.15 states that the licensee's NSCP will facilitate contact between the alleger and the appropriate Northeast Utilities management for non-nuclear concerns. However, it should be noted that admini trative procedures exists for employee grievances S

and union grievances.

2. Does it cover safety as well as non-safety issues?

The licensee's definition of a nuclear safety concern is that it focuses on observations believed to violate regulatory requhtments or Northeast Utilities (NU's) policy or procedure concerning nuclear safety, which have not been adequately /promptly addressed by formal quality program reporting mechanisms or fall outside the scope of the formal reporting mechantan, (i.e.,non-conformance reports, plant incident /Information reports, drawing change requests, ect.)

3. Is it designed for:

Nuclear Safety?

YES Personnel Safety? YES Personnel issues - including union grievances?

YES, however other admintrative processes better define actions concerning union Issues.

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4. Does the program apply to all licensee employees?

YES.

Th=+ procedure NEO 2.15 section 2.0, states that the Nuclear Engineering and Operations Group, including Northeast Nuclear Energy Company and the Connect!mt Yankee Atomic Power Company, supporting organintions within NU, and all other personnel (including contractor personnel) working at Northeast Utilities Service Company, Connecticut Yankee, or Millstone Station.

5. Contractors?

YES. See ':he response to question No. 4.

6. Does the licensee require its contractors and their subs to have a similar program?

MO, but licensee procedure NEO 2.15 step 5.7 state that Northeast Utilities Contractor Managers shall ensure that the requirements of contracts for nuclear work extend the requirements and protection of this procedure to all personnel directly employed by NU vendors / contractors and subvendors/ subcontractors to perform nuclear work.

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7. Does the licensee conduct an exit interview upon terminating employees as!

g have any safety concerns?

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' YES. CYAPCo precedun ADM 1.1-123, " Nuclear Safety Concess Pr Exit Interview" requires that the department head / manager at the termination or transfer of an employee to'an NU non-nuclear poskion, nottfles the.

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s Adadnistrative and Mannr4al Control Supervisor or Designee to schedule an exit interview with the Nuclear Safety Concerns Program. He licensee added an exit laterview with the Nuclear Safety Concerns Program by a inter-omte 1

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memoranden dated February 22,1990. At NNECo,'an exit interview with the NSCP is part of the employee terndnation/or transfer process.-' At NU -

J l-corporate omce, the exit laterview is curnstly under revision to "fonnalise"

't the process.

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INDEPENDENCE:

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1. What is the title of the person in charge?

DIRECMR, NUCLEAR SAFETY CONCERNS PROGRAM

2. Who do they mport to?

a THE DIRECTOR, NSCP REPORTS ADMINISTRATIVELY.10 THE EXECUTIVE VICE PRESIDENT, NUCLEAR, AND FUNCTIONALLY TO THE NU CHAIRMAN OF THE BOARD.

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3. Are they indW_t ofline management?

Organization 1

YES. De NSCP orgnalzation is independent of line organization based on i the managan==t reporting chain. De peer evaluators for the NSCP do not nport to their napective line management when deallag with a nuclear safety concern from another individual..

Follow-un of Cmmas YES AND Nit. YES in that if the individual sespasts confkitatiality the L

resolution of. the issue may not rely on line emanagement support (i.e.~,-

consultants). NO, in that the beness's Nacker Safety Concerns Prograrn encourages connnunication1 between empicyee's: and their L diract Inne -

'j manage==*=t for the risolution of a nuclearWety concern.' If an ladividual L

does not request confidentiality the nsolution of the concern may'be from line management.

Final Resolution of Concern o

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1 YES. he NSCP Director makes the final deiston for resolution of a De decision may/or may not agree with line ruanagement's l

concern.

nsolution.

4. Does the Employee Concerns Program use third party consultants?'

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he licensee proceduit NEO 2.15 ~ step 6.2.2. allows _ for third. party i

consultants to be used for neolution of a nuclear safety concern when the j

program needs to protect the identity of the' alleger, or the licensee does not

. have the available tehniemi expertise.

5. How is a concern about a manager or vice_ president followed up?

Licensee procedure NEO 2.15 states that confidanti=nty can be obtained. Ir.

-j a prospective alleger has a concern of managerment dealings of the nuclear l

safety concern the Individual can 30 to prognesively higher levels of-managernent for resolution.

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RESOURCES:

1. What is the size of the staff devoted to this program?

De licaneas has one Director, one staff consultant, one secretary, and thirty-two peer evaluators at Millstone Station, the ^ Connecticut Yankee station, and the NU Corporate Office. -

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2. What are employee concerns program-staff quahfications (technical training, i!

interviewing training, investigator training, other)?

i Both the NSCP Director and staff consultant have each approximately twenty -

1 year of management experience. he staff consultant has r' ecieved tralaing j

by NU legal staff on 10_CFR 50.7 and bu=inaan ethics. De peer evaluators -

1 undergo approxhnstely sixteen hours of orientation training._ De orienta* Ion 1

training consists of the program expectations, legal aspects, and hypothetical j

scenarios.

Two of the thirty-two peer-evaluators. are NU supervisory 9

personnel. De peer evaluators are volunteers within the NU organization,1 1

that have assummed a collateraljob function as a NSCP peer evahrator.-

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REFERRAIE:.

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.1. Who has followup on concerns (Employee Concerns Program Staff, line management, i

other)7 i,

Procedure NEO 2.15 steps 6.1.4 through 6.1.7 state that the appropriate-Nuclear Plant Operating Companies (NUPOC) (i.e., CYAPCo) and NEO functional management will assess the impact of the concern, assign neources, -

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-.,S.EP L 22 ' 93 -.088 54 HRC MILLSTONE OFFICE.

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and set a plan in motion to eval==t* and resolve the nuclear safety conce i

constatat with the severity of the concern. Results of the evaluation and corrective actions @J shall be pmvided to the appropriate NUPOC i

Director, Leentive Vice-Ptw=Idant, Nuclear and Divisiost Vice Pnsidents.- :i he supervisor shau provide the asults 'af the prethninary evaluation in -

-writing to the ladividual within 14 calendar days.

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' When the individual chooses not to comun== lente the nuclear safety co with the managment chain-of-comunand: NEO 2.15 section 6.2 states that-' j upon receipt of the nuclear safety concern the NSCP; Director wiR l

knesediately notify the Executive Vice-Passident, Nuclear of the NSC in such1 a manner as not to disclose the individuaPs identity. : ne Nucleme Safety -

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Concerns Prograrn wiH work with the ' appropriate _NUPOC and' NEO managment to evaluate all nuclear safety concerns. When necessary t?

protect an ladividual's identity, the NSCP wul obtain an' Independent perspective, or secum technical expertise not available within NEO.

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NEO 2.15 section 5.0, " Responsibilities," state that the Director of NSCP, and

'the NSCP Peer Representatives are not involved in the resolution of thel j

nuclear safety concern, j

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CONFIDENTIAIIIT:

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i 1, Are the reports confidential?

YES. NEO 2.15 section 6.6 states that-daemnant=*lan pertaining to. the y

identity of ladividuals raising NSC shad be maintainad in locked confidential fues with lindted access. De final resolution report of the concern is sent to :

the alleger's horne address or other non-wort related address.

2. Who is the' identity of the alleger made known to (senior management,-Employee Concerns Program Staff, line management, other)?

NSCP staff. If the issue is of a non-nuclear matter, the NSCP may raise the issue With other NU departments (i.e., Human Resoureas Group).-

3. Can employces be:

a. Anonymous? YES.

b. Report by Phone? YES. NEO procedure 2.15 provides a toH free "800"-

number.

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FEEDBACK:

1. Is feedback given to the alleger upon completion of the followup??

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YES. If the nuclear safety concern is provided to line management by the aueger, the supervisor of the ladividual is requimd to in _ writing provide preihninary evaluation within 14 days. If the prellada=ry evaluation does not -

completely resolve the concern, the supervisor shall inform the individual of-l an action plan for neolution.

If the alleger seeks confidentiality of a nur%r safety concern, the Nuclear Safety Concerns 7.

will provide notification of the final resolution to the individual, if possible.

2. Does program reward good ideas?

NO i

Inspector nelew of NEO 2.15 concluded that no mention was provided for

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j a reward system for good ideas. According to the NSCP staff, for non-

- t confidential concerns, NSCP may encourage UAe unanagement to initiate n'.

perfonnance nward.

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3. Who, or at what level, makes the final decision of resolution?

NSCP Director i

4. Are the resolutions of anonymous concerns disseminated?

j NO 5 Are resol ons of valid concerns publicized (newletter, bulletin board, all hands NO H..

EFFECTIVENESS

1. How does the licensee measure the effectiveness of the program?;

- 1j According to the NSCP staff, the effectiveness of the program is =wamutd y

on a case-by. case resolution ofissues. Spwhny, the NSCP requests nuegerj

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feedback on the neolution by either agreement or disagressment. In addition the licensee measures the amount of concerns processed by the NRC to measure the effectiveness of the program.

2. Are concerns:

a. Trended? YES W

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b. Used?

According to the NSCP staN, if the concerns is beneGelal to the

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- organization, employee recognition by line management maybe -

lattisted, when neonunended by the NSCP staN..

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3. In the last three years, how many concerns were raised?

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- According to the NSCP staN, the number of concerns are available for NRC

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audit purposes.

1 Of the concerns raised, how many were closed?

As of August,1993 aprivuir.etely 84% of the cases wen closed.

1 What percentage were substantiated?

The NSCP staN does not consider if concerns were aihatanti=*=I, but rather if the aHeger's wem satisfied with the final neolution of the concern.'Of l

' the identitled cancerns appromhnstely 91% of the alleger's were satisRed with the raahitten.

4. How are followup techniques used to measme effectiveness _ (random. survey, j

interviews, other)7 j

The NSCP program seeks feedback on the resolution from the alleger to unmane program eNectiveness. De NSCP staN has not initiated employee surveys : related :

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to the program and its objectives.

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5. How frequently are internal audits of the Employee Concems Program conducted and -~

by whom?

NONE accottling to the NSCP staff.

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ADMINISTRATION / TRAINING

1. Is Employee Concerns Program prescribed by a procedure?

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j YES. Tice=== procedure NEO 2.15, Nuclear Safety Concerns Program 4

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2. How are employees, as ~well as contractors, made' aware of this program (training,-

j newsletter, bulletin board, other)?.

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Employees are made aware of the pmgrun through general employee training (GET), posters, various " drop" boxes located within the NU ~ system, annual

. letter to all employees by senior NU management, depadmental meetings, y

adminletrative control procedure training,'and by the existence and awareness of " peer" evaluators.

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ADDITIONAL COMMENTS:.

1. Accordig to the NSCP staff, au concerns am ww si,g.,

~ 2. AcchQ to theNSCPWaff, dug hg the NU Chainnan of the Board, W w d the " peer" evaluators, attended the sessions detaHW % Mg g ident, Nuclear i

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