ML20113F319
| ML20113F319 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/27/1991 |
| From: | Opeka J NORTHEAST NUCLEAR ENERGY CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 9607090106 | |
| Download: ML20113F319 (84) | |
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December 27, 1991 1
22ggat No. 50-336
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A09998
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Mr. Thomas T. Martin Regional Administrator, Region I U.S. Nuclear Regulatory Commission j
475 Allendale Road King of Prussia, PA 19406 I
Dear Mr. Martin:
3 Millstone Nuclear Power Station, Unit No. 2
,I Resoonse to NRC Intnliry Into Emolovee Terminations 4
i This provides the response of Northeast Nuclear Energy 13, 1991, letter to J. Opeka Company (NNECO) to your November concerning the terminations from employment of two individuals i
Your letter vho worked at the Millstone Unit No. 2 facility.
j (1) provide the basis for the terminations requested that NNECO:
from employment of the two for1ner employees, and (2) describe the l
i actions taken or planned to be taken to assure that the j'
terminations do not have a chilling effect which discourages a
other employees from raising perceived safety concercns-The original response date for this letter was i
December 13, 1991.
On December 11, 1991, R. M. Kacich from my l
staff contacted your E. M. Kelly to seek up to an additional l
two weeks to respond to this request, changing the due date to j
December 27, 1991.
The reason for this request was the initiation of other proceedings associated with this matter that were involving many of the same personnel involved in the review and preparation of this response.
Mr. Kelly indicated,that this l
artens on was acceptable to the Staff.
3 j
Rasis for the Terminations I
The basis for the terminations is summarized in the November 8,1991, termination letters, copies of which are provided as Enclosure A.
The basis is further expanded upon in 0
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. Thomas T. Martin POR PUB IC'S URE l
A09998/Page 2 December 27, 1991 Enclosur9 5 provides relevant this letter and its enclosures.
l information concerning the termination from amployment of Inclosure C provides similar information for l
Mr. Del Core.
In regard to your request for any investigative Mr. O'Sullivan.
reports regarding these actions, Enclosure D is a third-party i
Finally, extensive documentation providing additional report.
i detail is available at the site for review at the convenience of i
f the NRC.
At the outset, however, it must be emphasized that l
Messrs. Del Core and O'Sullivan were not terminated for raising Indeed, for the past four years it was safety concerns.
generally known within NNECO that Messrs. Del Core and O'Sullivan were raising safety concerns, and it is equally clear that throughout that time period no action was contemplated or taken f
i against either individual due to their having raised safety Rather, the termination decisions were reached on the concerns.
basis of an exhaustive and careful review of disruptive work i
After conduct separate and apart from their protected activity.
l reviewing all available information, NNECO concluded that the continued employment of Messrs. Del Core and O'Sullivan presented j
a serious and potential safety concern due to the irreconcilable breakdown in the working relationships between the two individuals and other employees at the site, including a majority l
j of their fellow workers, as well as first-line supervision and This breakdown was the direct result of the management.
antagonistic, contemptuous, and profane manner in which these two individuals interacted with their peers and supervision on a wide l
variety of issues on almost a daily basis.
NNECO, with over two decades of history as a i
l responsible licensee, has always re.spected and encouraged the The fact that rights of its employees to raise safety concerns.
l these individuals had repeatedly raised concerns made these Indeed, the very employment decisions all the more difficult.
j fact that these individuals had raised safety concerns caused NNECO to tolerate considerable misconduct by these employees over j
a lengthy period of time before being compelled to take the 1
These employment actions were motivated out termination actions.
of a concern for others on the site and in furtherance of the
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safe operation of the Millstone station, and Unit No. 2 in j
particular.
.This point warrants further discussion.
Although both Messrs. Del Core and O'Sullivan have been disruptive since at least 1988, NNEco senior management has since that time directed i
j its employees, and particularly site management, to be extremely solicitous when dealing with Messrs. Del Core and O'Sullivan in j
an effort to reconcile any differences with these individuals and l
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'b.ThomasT. Martin
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December 27, 1991 restore a constructive working relationship.
This approach can be characterized as management anbracing a tolerant attitude a
j toward criticism, ignoring attacks on individual integrity, and attempting to respond to concerns in a prompt manner, even as to Although there concerns without apparent safety significance.
may be examples where management was not as timely as it might have been in responding to an individual concern, a fair review 4
of management's overall conduct well illustrates this approach.
j This approach even extended to giving both Messrs. Del Core and j
o'Sullivan generally favorable performance appraisals over the j
years, although the overall ratings they received did not reflect 1
their overall adverse impact on the site.
Over this same four-i year period, virtually every level of NNECO management, fromfi with one or both of these individuals in an effort to understand and be responsive to their concerns as well as establish a more i
constructive working environment.
The solicitous approach ultimately extended NNECO's tolerance beyond the limits of reason.
Although NNECO tolerated l
the highly disruptive, nonprotected conduct of these two individuals, in part because they engaged in protected activity, J
unfortunately, this approach was not successful in reconciling i
differences or restoring positive relationships.
Rather, the i
approach eroded, over time, the morale of other employees and those that had to supervise Messrs. Del Core and O'Sullivan.
NNECO management came to be perceived as unreasonably favoring l
i and sanctioning disruptive and unprofessional conduct by Just as a primary concern for Messrs. Del Core and O'Sullivan.
safety led NNECO to tolerate disruptive behavior for an extended i
period, so too did it ultimately compel NNECO to remove these l
individuals from the site when their negative impact on others and the site became apparent.
i While the conduct of Messrs. Del Core and O'Sullivan had become increasingly disruptive ever a period of four years, a 1991, meeting provided particular impetus for this l
July 25, decision.
On this date NNECO management held a meeting at the j
site, wherein it was strongly stated by site management that the handling of allegations at the site needed a firm, objective review, and that site morale was low.
NNECO senior management thought it was particularly disturbing that site management felt its relationship with the vast majority of employees was being adversely impacted as a result of the cycle of contentious l
(
conduct on the part of Messrs. Del core and O'Sullivan and the corresponding lack of a productive employer-employee relationship l
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due to that disharmony.
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Mr. Thomas T. Martin Fo]POSL]I dis BURE A09998/Page 4
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i December 27, 1991 i
In August 1991, NNECO senior management initiated a j
third-party assessment to review employee willingness to raise concerns and management's receptivity to such concerns..The j
Millstone Unit No. 2 Electrical and Instrumentation and controls j
(IEC) groups were the primary focus of this review because most concerns and criticism were being generated in these groups.
NNECO senior management hoped that this initiative could disclose I
a way to break the cycle of contentiousness and restore a moreRather, the review It did not.
constructive work environment.
found that t;he continued presence of Messrs. Del Core and c'Sullivan presented a serious and pressing management issue and l
a potential safety concern due to the irreconcilable breakdown in i
the work environment.
j As NRC is no doubt aware, before taking these termination actions, NNECO tried repeatedly to establish constructive working relationships with both individuals; however, both individuals made it equally clear that such attempts were futile and any further attempts would be to noVi l
avail.
line supervision to the Chairman of the Board, interacted with j
one or both of these individuals in an effort to understand and l
be responsive to their concerns and establish a more constructive l
j work environment.
As described in the enclosures, there are some h
differences between the two individuals with respect to their i
However, their behavior had certain common behavior.
characteristics that adversely affected site activities in the l
l By the conduct of each, the trust and confidence same way.
j required in any working relationship, but particularly at aWhen people engaged nuclear power plant, had been destroyed.
safety-related work do not trust and have confidence in their co-l workers, the potential exists for an adverse impact on nuclear i
j j
safety.
To further assure that the disharmony between l
Messrs. Del Core and O'Sullivan and the company was not the result of improper conduct on the part of NNECO site management, prior to deciding on an appropriate action, management reviewed the cumulative record of NNECO's dealings with these two j
.e individuals.
That record showed:
NNEco ha6 taken extensive actions to work wita 1.
Messrs. Del Core sa6 O'Sullivan to no avails trNEco had taken extensive actions and dedicated major resources to l
respond to the particular employee concerns, yet Messrs. Del Core and o'sullivan seemed more galvanized i
against the company than ever and had shown no genuine l
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i Mr. Thomas T. Martin 00NFIDEIrf FOks703LICJIS S
A09998/Page 5 C
December 27, 1991 willingness to work with supervision to improve relations.
1 NNECO not only augmented and continues to improve its i
allegation response processes to be more responsive.to these individuals, but also over the past couple of years virtually every level of NNECO management met with these individuals in an effort to understand and be responsive to concerns as well as establish a more constructive working i
j environment.
2.
NNECO had taken extensive actions to enhamos its employee l
J ooncerns programs:
NNECO had taken extensive actions to j
enhance its employees concerns programst yet, despite harsh criticisms of such programs by Messrs. Del Core and O'Sullivan, insofar as NNECO is able to determine, neither Messrs. Del Core nor O'Sullivan ever availed themselves of l
these programs.
This was a further indication that ths employment relationship was irretrievably broken.
3.
Messrs. Del Core and O'sullivan continued criticism of NNECO Messrs. Del Core and O'Sullivan continued to j
disparage and frustrate the legitimate aims of NNECO in a highly critical way, and with a serious adverse effect on the organization.
Such criticisms included attacks on the integrity of NNECO management as well as the integrity of those fellow employees trying to work with Messrs. Del Core j
and O'Sullivan.
Again, this was a further indication that the employment relationship was not improving.
l 4.
Messrs. Del Core's and O'Su11ivan's conduct was having an adverse impact on co-workers, supervision, the work environment, and the NNECO organisation generally:
Both Messrs. Del Core and O'Sullivan had, by their conduct:
l Unnecessarily disrupted their work units.
i a.
I b.
Engendered mistrust among their co-workers.
4 Demonstrated insubordi m ion toward multiple layers of l
c.
management, extending from their immediate supervision to the most senior members of the NNECO management i
I team.
d.
Disparaged the company and been disloyal to e
legitimate aims of the company in a way calculated to thwart Company ains and objectives.
5.
There had been no harassment or intimidation In search to explain this highly disruptive conduct, NNECO had reviewed i
its past conduct for an explanation.
The record of the 17
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Mr. Thomas T. Martin 90 A09998/Page f
$1CJIBchBy December 27, 1991
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Section 210 claims brought by these two individuals made it 4
abundantly clear that there had been no harassment or
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intimidation of either individual by NNECO for the raising i
of safety concerns.
None of the 6 claims brought by i
Mr. O'Sullivan nor the 11 claims brought by Mr. Del Core j
have resulted in final Department of Labor decisions adverse j
to NNECO.
The NRC has never issued a violation under 20CFR50.7, based upon harassment or intimidation of l
Messrs. Del Core or o'sullivan or any other reason.
Aside f
i j
from the formal claims of harassment and intimidation, NNECO's review demonstrated that co-workers, immediate j
supervisors, and more senior management have taken no action that could reasonably be construed as harassing or intimidating toward Messrs. De'l Core and O'Sullivan.
i j
6.
Both individuals actively pursued claims against NNECO in i
numerous forums:
Continued prosecution of numerous claims in every available forum was an additional indicator that the relationship between these individuals and NNECO had irretrievably broken down and revaaled employees so completely dissatisfied with their management that all communication and trust had disappeared.
In addition to the j
17 Section 210 complaints, on January 15, 1991, both individuals filed a complaint against NNECO in Connecticut i
l State Court, elleging an " intentional infliction of emotional distress" based upon essentially the same improper 4
i conduct that had been claimed in the numerous Section 210 l
cases which were decided in favor of NNECO.
A' review of the interactions which form the basis for the alleged " emotional l-distress" reveals that they are routine interpersonal encounters and exchanges which occur in the course of j
conducting business and which would pass by reasonable people without note and that would hardly constitute the
" outrageous, shocking, malicious" behavior alleged.
This suit was filed despite the fact that NNECO had retained a i
mediator to try and resolve the strained relationship i
between Mr. O'Sullivan and uis co-workers.
j In addition, both individuals have pursued claims before the Connecticut Human Rights and Opportunities Commission i
alleging age discrimination.
Mr. Del Core had also pursued f
claims against NNECO before the Occupational Safety and Health Administration and the State Workers' Compensation I
Commission.
i l
The recent third-party review by a seasoned nuclear consultant corroborated this micconduct on the part of i.
Messrs. Del Core and O'Sullivan and its overall effect on their i
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00NFIDE3fT I*
Air. Thom o T. Martin J
FOR'?p3 ICx3y B_
l A09998/Page 7 1
December 27, 1991 1
i co-workers and the site in general.
The third-party review, attached as Enclosure D, found in relevant parts There was a general perception on the part of f
a vast majority of both co-workers and l
immediate suprvisors that the volume, frequeng and type of concerns being raised i
j by both individuals was not due to genuine safety concerns but was due to a desire to "take on management", cause confusion, and
- bury management in paperwork".
The view l
among most co-workers was that both 1
l Messrs. Del Core and O'Sullivan were raising concerns out of a personal vendetta against i
the company.
There appeared to have been an unreasonable and unintelligible unwillingness on the part of Messrs. Del Core and O'Sullivan to use approved lines of communication within NNECO, j
either through the chain of command, the Nuclear Safety Concerns Program or the
]
Nuclear Review Team.
There appeared to have i
been a near-total breakdown in the employer / employee relationship.
These individuals appeared to be both unmanaged and unmanageable.
Their course of conduct was l
unprofessional and at times insubordinate.
There existed a serious question with respect to the safety perspective of Messrs. Del Core i
and O'Sullivan.
This conduct, which occurred over a considerable period l
of time and which was tolerated by NNECO management out of an abundance of caution and a fira desire that no NNECO actions be construed as retaliatory, resulted in a deteriorating work l
. condition for other amployees to the extent that the third-party review found:
j Co-workers, immediate supervision, as well as l
unit directors and.the site director saw no i l
and in sight to the chronic discord created,
by these two individuals.
Many co-workers were distracted in that the co-workers were "looking over their shoulder" out of a concern that their job activities would be misinterpreted or mischaracterized i
I
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(y Mr. Thomas T. Martin NF 1&L==h f
o IC 100L0 j
A09998/Page 3 i
December 27, 1991 j
1 I
and become part of a contentious situation unnecessarily created by Messrs. Del core and i
o'Sullivan.
l
. Immediate supervisors and managers within these work units were spending anywhere from 20 to 70% of their time on issues with little to no impact on safety") that had been raised by either Messrs. Del Core or j
O'Sullivan.
This distraction further eroded the work environment.
There was a perception among co-workers that if they disagreed with either Messrs. Del Core or O'Sullivan there would be retaliation from these individuals in some i
form.
This fostered mistrust between the l
workers.
Equally important, the failure on the part of management to deal with this long-standing situation contributed to a growing mistrust i
l between workers and managers.
t l
The long term effect on both the Millstone Unit No. 2 electrical and I&C groups was an l
erosion of morale and performance, and a corresponding potential safety issue with i
respect to their ability to properly concentrate on their work.
f Upon review of all available information, NNECO decided to terminate the employment of Messrs. Del Core and O'Sullivan.
l Specifically, NNECO reviewed the long, documented history of each in creating discord and mistrust within the workplace.
Meetings were held with NNECO management at both the corporate and site
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i level, the third-party report was considered, and a final consultation with site management occurred.
Of course, throughout these deliberations the advice of counsel has been sought.
i l
1.
An extensive record of allegation letters, NNECO responses, and NRC review is available to substantiate this conclusion.
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l Mi'.Thom$0T. Martin 00NPIDENT
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A09998/Page 9 70E POBLIC DISC URE Nj i
I December 27, 1991 s
Actions to Avoid chillina Effect Before providing our specific reasons for our belief i
that the terminations are unlikely to give rise to a chilling effect, we believe it is instructive to put into some propective our lengthy and extensive commitment to nuclear technology, and the resulting appreciation we have for the importance of ensuring j
the free and unencumbered flow of information regarding actual or j
NNEco has been involved in the potential safety concerns.
l construction and operation of nuclear power plants for more than two decades.
The NU system companies have full or partial ownership in eight of the nine nuclear facilities in the New The depth of our commitment to nuclear technology, England area.
and our extensive experience with it, has reinforced in unambiguous terms the importance of ensuring that information bearing on nuclear safety flows freely.
We believe that our track record as a highly successful operator of nuclear facilities over the years bears this out.
We have employed many thousands of nuclear workers who have experienced literally i
I millions of contacts with each other and with company management in dealing with nuclear safety issues.
There have been very few section 210 claims or other signals of a potential chilling
- I effect on worker's willingness to come forward with safety concerns and, at that, no section 210 case has resulted in a It is final Department of Labor (DOL) decision adverse to NNECO.
with this backdrop that we proceed with a more specific response as to our actions to avoid a chilling effect.
5 NNECO does not believe that the terminations are at all l
likely to give rise to a chilling effect on the Nuclear NNECO Engineering and Operations (NE&O) organization as a whole.
l firmly believes that members of the Millstone work force and the j
NE&O organization as a whole recognize that the termination actions were not the result of retaliation for raising s.afety j
concerns and that management acted properly.
Perhaps the most compelling reason to believe that there has been no chilling effect is a recent action taken by Millstone employees in which j
j NNECO management played no initiating role.
An ad appeared in the November 17, 1991, edition of The Day, a newspaper published j
in New London, Connecticut, that had carried several stories j
following the terminations suggesting the remaining workers would be hesitant to raise concerns in the future.
In a wholly l
unanticipated response, approximately 600 Millstone site workers i
took out an ad at their own initiative and expense which read:
i We the undersigned who work at the f
Millstone Nuclear Power Static 3 would like it to be understood that we are pr644 employees j
j 5
- i
. ~ - -
J i
.b Mr. Thomas T. Martin
'\\OObENT PUBL]I D1
$URE FOR A09998/Page 10
'NJ d
i December 27, 1991 3
mad contract personnel who support and i
1 believe in commercial suolear power.
We are not afraid to stand up and weise j
our opinions.
We believe in Northeast
)
Utilities and Northeast Nuclear Ene m company as a safe provider of electrielty j
i generated by nuclear power.
This ad was paid for entirely by the j
employees and contract personnel at the Millstone Nuclear Power station without the express oonsent or opinions of management.
Enclosure E provides a copy of this advertisement which contains the signatures of these employees.
The clear message from this ad has obvious implications to your question on l
This spontaneous outpouring of support from the chilling effect.
front-line work force is even more impressive when it is ij' recognized, as NNECO is led to believe, that the initiators of j
this gesture had only 2 or 3 days to secure the signatures and funding between the time this idea was conceived and the paper's
!j In addition, although NNECO sanagement has neither deadline.
l encouraged nor discouraged sending letters to you in response to j
1991, inquiry, NNECO is generally aware that your November 13, j
letters to the NRC supporting NNECO management have been l
I circulating around the site.
I Rather than having a chilling effect, NNECO management j
has reason to believe that the terminations of Messrs. Del Core and O'Sullivan may have precisely the opposite effect.
Both a r
l recent self-assessment and a third-party review suggest that a significant number of site personnel felt that NNECO's past toleration of disruptive behavior on the part of Messrs. Del Core i
and O'Sullivan had a chilling effect on the co-worker's willingness to raise concerns out of a fear that the concern i
would be used by either individual as a means to "take on the To the extent these dynamics were at work, the removal company."
l of Messrs. Del Core and O'Sullivan from the workplace should allay this concern.
i NNECO has taken a number of actions both prior to and after the recent terminations to encourage amployees to come j
forward with concerns.
Prior to the recent terminations, NNECO l
1
(
. Thomas T. Martin 00 ICENTI)
A09998/Page 11 70 PUBLI@ DI S
l December 27, 1991
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l had taken extensive actions") to put programs in place to 1
assure supervisors appropriately respond to employee concerns and, conversely, that erployees have alternative avenues l
available if for any reason they wanted to raise concerns outside the chain of command.
Specifically, in June 1988, managers received training in how to deal effectively with employee 1
The training emphasized the right of all employees to concerns.
raise concerns within NNECO or to go directly to the NRC.
In
)
{
June 1989, NNECO issued a policy statement, again emphasizing the t
j rights of all employees to engage in protected activity and be free from any concern that they would be subject to adverse In amployment actions as a result of raising a safety concern.
January 1990, more expansive enhancements to our MSCP were put in l
j place, incorporating the insights from an exhaustive review of l
programs of other licensees.
This program has been generally j
favorably reviewed by the NRC.0)
I On November 1, 1991, NNECO made effective a new
)
groupvide procedure (NEO 2.30) providing an additional avenue for employees to raise differing professional opinions in a manner designed to assure an appropriate and timely technical review.
i This new procedure has been utilized on three occasions to date.
i i
In addition, as a result of a recent self-assessment, j
i durther programmatic enhancements of the NSCP have been recommended.
These recommendations have been substantially j
adopted, are in the process of being implemented, and were the j
subject of NRC management meetings on September 3,1991, and i
again on December 9, 1991.
The NSCP is in the process of being l
further upgraded to reflect these recommendations.
1 j
All of the above efforts are enhancements over and j
above NNECO's existing Nuclear Review Team program, which has historically provided an avenue for employees raising concerns 4
outside the chain of command.
All personnel requiring site j
access are informed of these programs as part of general employee j
training.
This training is repeated annually.
It is telling i
2.
Some of these previous actions were summarized in the April 9, 1990, letter from E. J. Mroczka to Mr. T.TT. Martin responding to the NRC roguest of March 8,1990.
We also met j
with you in your offices on March 22, 1990, to further amplify these enhancements.
1 i
3.
For example, see the Combined Inspection Nos. 50-245/90-81, i
50-336/90-81, 50-423/90-82, and 50-213/90-82, dated October 24, 1990.
i i
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.t FN Str. Thomas T. Martin CONF 2 DENT
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A09998/Page 12 FUBLZ DISC 733 l
December 27, 1991
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i that insofar,as NNECO can determine, neither Messrs. Del Core nor c'sullivan have over availed themselves of any of these programs.
l As an example of management support and endorsement of j
employee behavior at issue here, Enclosure F ded.
Enclosure F i~s a letter from Mr. B. Fox to a WNECO
)
employee, which was prompted by this employee s role n
i identifying an incorrect valve alignment on a safety system at i
Millstone Unit No. 2.
Notwithstanding the fact that the NRC took
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escalated enforcement action against NNECO regarding this incident and imposed a civil penalty, the company president j
personally thanked the individual instrumental in detecting this i
j problem and emphasized the importance of this type of behavior to i
the success of our nuclear program.'
Company management has and continues to routinely verbally reinforce this message to its i
entire work force.
1 j
l In addition, to assure that site personnel understood j
the basis for NNECO's action and that no chilling effect would j
occur, on the day of the terminations, in response to numerous inquiries, the station director issued a sitevide
- Millstone i
Messenger" which outlined the basis for the actions and which is attached as Enclosure G.W Also, on November 8, the daily NE&O
- Tie Line," available to all NE&O employees, briefly summarized j
the basis for the termination action and encouraged employees to i
bring forward any and all safety concerns.
(See Enclosure H.)
l The executive vice president--nuclear--also sent the enclosed i
memorandum to all NE&O employees on November 12, 1991, i
reinforcing Northeast Utilities' commitment to responsibly j.
address safety concerns.
(see Enclosure I.)
Further evidence j
that this termination action is not having a chilling effect can l
be found in a variety of letters to the editor published in Ihm Day.
Some examples are provided as Enclosure.7.
i To further assure that those workers most affected--the Millstone Unit No. 2 electricians and I&C technicians--understood the basis for NNECO's actions and had an opportunity to ask j
questions, managers met with these groups on the morning of the j
terminations.
Also on the morning of the terminations, the j
Millstone Unit No. 2 unit director met with his direct reports l
and exempt employees in the affected departments, I
1 1
i 4.
It should be noted that the ' Millstone Messenger" is 1
incorrectly dated November 8, 1990.
The issue was published on November 8, 1991.
i
i 00NFID ZAL--M Itr. Thon30 T. Startin i
A09998/Page 13 FOR'P "UBLIC DISCEO URE I
December 27, 1991 j
concluaion The recent terminations were taken for the reasons i
contained in this letter and the enclosurts in a manner and in i
conjunction with other actions to assure that the terminations Considorable would not have a chilling offact on others.
j objective evidence has been provided to substantiate this Finally, this response and all of its enclosures are conclusion.
being filed on a confidential basis because they contain material I
j An affidavit supporting this request usso in personnel actions.
j pursuant to 10CFR2.790(a)(6) is provided as Enclosure I.
i We trust this adequately responds to your November 13, Should you have any further questions on this 1991, letter.
satter, please contact R. M. Kacich at (203) 665-3298.
l Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY b
f*
e, I
J. Q./opeka G
Executive Vice President i
Enclosures:
November 8, 1991, Termination Letters A.
Relevant Information Concerning the Termination From l
B.
Employment of Mr. Donald W. Del Core, Sr.
1 Relevant Information Concerning the Termination From l
i C.
l Employment of Mr. Timothy O'Sullivan l
D.
Third-Party Review in the Area of Employee Concerns The Day Advertisement l
E.
B. M. Fox Letter to gM i
F.
G.
" Millstone Messenger 4
i M.
' Tie Line" 2.
J. F. Opeka Memo to All NE&O Employees J.
Letters to the Editor R.
Affidavit U.S. Nuclear Regulatory Commission Document Control Desk l
cc G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 W. J. Raymond, Senior Resident Inspector, Millstone Unit l
)
Nos. 1, 2, and 3 l
E. M. Kelly, U.S. Nuclear Regulatory Commission, 5tegion I i
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Docket No. 50-336 A09998 CONFEDE4TIAfr <30'. FOR PUBLIC BISCIASITRR 4
1 1
4 Enclosure A 4
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i December 1991 i
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Docket No. 50-336 A09998 1
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December 1991 l
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Mr. Thomas T. Martin 00NFJD 3
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Enclosure B/A09998/Page 1
$L2QD8 St December 27, 1991 i
l SELEVANT ZWFORMATION CONCERNING TEE TERMIMkTION yaou munavurwT or ant. now nn v. DEL core. sa.
.i 1
l Donald W. Del Core, Sr., joined Northeast Muclear Energy Company (NNECO) in March 1979 as a station Electrician B In December in the Millstone Unit No. 2 Maintenance Department.
1979 he transferred as an instrument technician to the Millstone i,
He was l
Unit No. 2 Instrumentation and Controls (IEC) Department.
promoted to an I&C specialist in August 1981 and remained in that From the position until his termination on November 8, 1991.
l period 1979 until approximately early 1988, Mr. Del Core proved i
to be a capable worker, although arrogant, boisterous, and His co-workers within the IEC group found him to be j
profane.
generally competent and acceptable to work with while acknowledging at the same time that he was, on occasion, j
aggressive, overbearing, and argumentative.
1 Until 1988, the Millstone Unit No. 2 I&C group was a t
very close-knit group and morale. was high.
Virtually every technician and supervisor in the group described it as a
" family."
As a result, employment within the group has been 1
extremely stable, with most of the technicians and supervisors
~
having considerable experience in the I&C group.
I Since approximately early 1988, both Mr. Del core's i
conduct within the IEC group and the performance, attitude, and morale of the entire group have changed markedly.
Most of the l
i
7-03 ENT
-M R
Mr. Thomas T. Martin DSLI65)S j
Encicsure B/A09998/Page 2 December 27, 1991 1
t IEC technicians and supervisors attributed the change in f
Mr. Del Core and the resulting changes in the I&C group to a j
disputes between Mr. Del Core and Northeast Utilities l
series of (NU) management concerning the scheduling and payment for l
In particular, Mr. Del Core was upset because he f
overtime work.
f was not permitted to work three consecutive days over the 1987-The company had instituted a policy J
1988 New Year's Day weekend.
4 that each employee could work only two of the three
- weekend" Mr. Del Core took exception to this policy and filed an l
days.
internal company grievance because he believed that he should l
This have been allowed to work all three days if he so chose.
3 dispute was resolved adversely to Mr. Del Core and seemed to have l
dramatically and negatively affected his attitude towards NU One of the technicians recalls that after failing in management.
his internal company grievance proceeding involving his overtime i
dispute, Mr. Del Core stated that he would "make the company pay" i
i for opposing him.
During the period 1988-1991, Mr. Del Core's attitude l
towards his job and his conduct on the job declined in a number l
Specifically, his attitude towards selected co-of respects.
- i workers and management seriously and adversely affacted nearly all of the employees in the I&C group--both technicians and i
Mr. Del Core's activity during the period supervisory personnel.
which ultimately led to his termination, can be i
1988-1991, That conduct, segregated into a few dominant types of conduct.
J
' $r. Thoaac T. Martin 00N CENTII NOTNR j /A09998/Page 3 TU3LIC'D_ZSCIA tmEb December 27, 1991 I
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as explained in the following discussion, formed the basis for I
ananagement's termination decision.
1 j
pases for Teralmation I
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Ynsubordination and fe k of Yntaarity.
Beginning
)
in early 1988, Mr. Del Core's attitude towards management and his j
treatment of his immediate supervisors changed significantly, i
i Many directives issued by the I&C management team were met with i
4 l
abusive, insulting, and often vulgar argument from Mr. Del Core.
The decisions of management, as well as the members of management, were labeled as stupid or incompetent by 1
Mr. Del core.
He frequently used profanity to describe 4
management personnel and management decisions.
For example, during a recent monthly meeting c,f the I&C technicians and supervisors, f the I&C group who was l
not present at the meeting, was openly and harshly criticized by Mr. Del core and called a "f...ing a.. hole."
In that regard, 6 had approximately three or four meetings a year with l
Mr. Del core which would result in Mr. Del Core shouting at and about management.
Recently, for example, Mr. Del core had a very loud and contentious interaction with As overheard
]
and described by a number of employees in the group, Mr. Del Core was shouting and using profanity in speaking to in the IEC conference room.
Apparently, Mr. Del Core was upset because he wanted to force a contract engineer to apologize to l
Mr. Del Core over an argument that had occurred earlier between
R t
Mr. Thomas T. Martin CQNFKDyNT POR i
Enclosure S/A09998/ Pag'A 4 FUSLIC qI$, cid>S V
1 December 27, *L991 i
l Mr. Del Core sind the engineer.
One employee became so upset by Mr. Del Core's conduct towards @ that she felt it 4
j necessary to leave the area in order to compose herself.
other examples of Mr. Del Core's insubordinate attitude 4
towards management were described by
@ I&C j
supervisors.
He recalls a number of instances in which he heard 1
or had reported to him that Mr. Del Core described i
(an I&C M and I
respectively) as "a.. kissers" and "a.. holes." @ also recalls instances in which Mr. Del Core was openly contemptuous 1.
]
of management.
On one occasion for instance, a dispute over I
overtime arose between (a fellow I&C 6 who I
had temporarily been upgraded to supervisor) and Mr. Del Core in which Mr. Del Core accused of acting in " collusion" with his friends in assigning overtime in a " preferential" sought to talk to Mr. Del Core about the manner.
l natter but Mr. Del Core refused and simply turned his back on and walked away. The next day M called Mr. Del Core to his office to attempt, once aga!n, to discuss i
i i
Mr. Del Core's conduct tewards 6 As he had on the earlier occasion, Mr. Del Core refused to talk to M and I
again turned his back on M and walked out.
Perhaps the most graphic example of Mr. Del Core's l
openly insubordinate and contemptuous attitude towards management involves a conversation which Mr. Del Core had with 6 1
l l
l
9b. Thom:0 T. Martin CONFIDENTIAI,--IAT )POR n
N P UB Ltc ' p (stE E(
! /A0999s/Page 5 N
December 27, 1991 l
an 2&c6 and overheard by @ in July 1991.
As
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Mr. Smith was walking through the Inc work area and appoaching f
Massrs. Del Core and overheard Mr. Del Core advise how to raise safety or other allegations in the following terms:
In making allegations you don't have to give them all of the information--and boy does that f..k them up.
After making this statement, Mr. Del Core laughed loudly.
I At the time this statement was made, Mr. Del Core clearly knew that M would hear his comments. g was only a few feet away, and Mr. Del core was looking at l
6 as he made the statement in his typically loud voice.
Although @ brought this statement to the attention of management, nothing was done because of management's concern over Mr. Del core's "whistleblower" ststus and the desire to take no
' action which could be construed as chilling the raising of safety concerns.
l Apart from Mr. Del core's insubordination, management i
l began to have legitimate questions regarding Mr. Del core's l
integrity.
In 1988, during the course of a deposition, 4
Mr. Del core admitted that he had falsified material parts of his i
)
employment application.
Specifically, in his employment l
application, Mr. Del Core stated that the reason he left his i
j immediate past employer was due to
" contractual constraints."
l During a 1988 deposition, however, Mr. Del Core acknowledged 4
i i,
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Mr. Thomas T. Martin
-1107 poa C
S Enclosure B/A09998/Page 6 i
December 27, 1991
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l NU could have l
that he had been fired by his prior employer.
fired Mr. Del Core immediately for providing false information i
but chose, at that time, not to pursue the issue in an effort to reconelle its relationship with Mr. Del Core.
j I
since that time, management observed other conduct on 1
the part of Mr. Del Core which caused management to further f
question his integrity. 'For example, in January 1991, Mr. Del core alarmed an exit portal monitor and, although he was 1
apparently aware of his responsibility to notify the Health I
Physics Department prior to leaving the site, he did not.
l f
Nonetheless, upon his exit of the plant, Mr. Del Core apparently phoned the NRC resident inspector's office and reported a This violation, contributed to by l
violation of plant procedures.
l Mr. Del core and the guard who permitted Mr. Del Core to exit, J
i gave management reason to seriously question Mr. Del Core's i
1 judgment and his integrity.
Lack of Interaction Between I&c Technicians and i
~
2.
Between Technicians and Mannaement.
Over the course of the last three or four years, there has been a marked and serious decline 1
in job-related interaction between the Millstone Unit No. 2 I&C l
technicians and between the technicians and supervisory i
IEC technicians often rafrained'from openly' personnel.
discussing technical issues or' problems among themselves, and the i
supervisory personnel were reluctant to engage in open
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4 OQNFIOE3rf!1
-1pf 703 Mr. Thomas T. Martin
- /A09998/Page 7 PUBLI : h(80%TRE December 27, 1991 J
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i discussions with the IEC technicians.
There rre at least three reasons for this decline, all related to Mr. Del Core's conduct.
First, a number of the IEC technicians feared that if I
they were to raise any issue with Mr. Del Core or discuss any i
problem with him, however trivial, it would be aisrepresented to the NRC, the Department of Labor (DOL), or the Occupational i
safety and Health Administration (OSHA) as a " major safety concern" which the I&C technician either caused or failed to 1
i report.
l l
Second, while working with Mr. Del Core as part of.a team--a common practice in the IEC group--individual technicians typically deferred to Mr. Del Core's judgment on technical issues I
in order to avoid abusive, insulting, and profane outbursts from l
Mr. Del Core and extended and unremitting. argument.
Thus, in the case of a technical disagreement over the proper way to perform a procedure, for example, most of the I&C technicians would simply defer to Mr. Del Core in order to avoid a protracted fight.
e similarly, if Mr. Del Core were to decide that a particular procedure was incomplete or defective requiring a complete cessation of work, the other IEC technicians would not dispute his position even when they disagreed.
i I
Third, Mr. Del Core was openly critical of his fellow workers and seemed to delight in finding mistakes in their work.
While performing inspections as part of a team, the participating t
IEC technicians often perceived Mr. Del Core as looking over
Mr. Thomas T. Martin Q NFIC IAL-4, FOR TURIIC ISCLglB Enclosure B/A09998/Page 8 i
December 27, 1991 their shoulders hoping to find errors or mistakes in their work rather than performing his own work.
In the last year,-the situation had deteriorated to the point where a number of i
In technicians preferred not to work with Mr. Del Core.
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addition, one technician volunteered for work outside I&C in order to avoid Mr. Del Core entirely, and one technician would These not go into the IEC work area if Mr. Del Core was present.
behavior patterns were also running afoul of NNECO's prime i
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objective of assuring nuclear safety.
i Many of these same factors have also affected the
)
supervisors and their relationship with the technicians. h i
i had previously made it a the practice of walking through the IEC shop and engaging in l
technical discussions with the technicians over the various These procedures or inspections they were performing.
l discussions often involved a number of the technicians and proved to be helpful in both resolving problems as well as keeping management informed.
Over the last year or so this practice had 4
I all but ceased.
Technicians seemed reluctant to talk to supervisors when Mr. Del Core was in the shop, and any discussions in which Mr. Del core took part often became i
argumentative, loud, and unproductive.
As a result, 6 typically talked to his technicians about technical issues only behind closed doors in his office.
Informal, spontaneous discussion of technical issues had all but d
4
Ib5NTI b - k FOR Mr. Thomas T. Martin PUB IC'BIsj!hSU68 /A09998/Page 9 MM J
December 27, 1991 Additionally, monthly meetir.gs involving all the ceased.
technicians and the I&C management were curtailed for a period of time because of Mr. Del Core's frequent outbursts at these i
i meetings.
The safety. impact of Mr. Del Core's conduct and its effect on the other technicians is obvious.
The technicisns no longer attempted to subject the problems which they encountered to open and frank discussion with their peers and management.
Instead, a number of the technicians often performed their work When Mr. Del Core in secrecy in an effort to avoid Mr. Del Core.
could not be avoided, they simply agreed with his technical opinions without debate.
Thus, over time, the IEC group largely lost the benefits of peer review and discussion and stifled their own technical judgments in an effort to avoid or placate Mr. Del Core.
Refusal To Follow Established Procedures.
The 3.
nuclear management at Millstone, like management at other nuclear power stations, requests that its employees immediately report any condition which could adversely affect the safety of the station.
This policy furthers NRC's preference, as stated in NRC Form 3, and is reflected in Nuclear Engineering E.nd Operations Procedure NEO 2.15, " Nuclear Safety Concerns Program," dated I
April 20, 1990.
It provides that:
l As a matter of NU policy in the safe operation of its nuclear facilities and in keeping with the NRC's preference as stated on [NRC) Form 3 (Attachment 8.8),
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O DENTIAL-WOT R
'Mr. Thomac T. Martin
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LI DIWC MSURE Enclosure S/A09998/Page 10 V
' December 27, 1991 l
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'If you believe that violations of NRC rules or of the terms of the license have occurred, you should report l
them immediately to your supervisor."
supervision will assess the sensitivity and the need for confidentiality r
regarding the individual's identity.
l NEO 2.15 also allows employees to report concerns confidentially or, if an employee desires, they can report a concern directly to j
However, if an employee does report a concern to the
(
i the NRC.
i NRC, they are also requested to " inform NU of this action on a concurrent basis by reporting it to NU via their direct supervisor."
The importance of nuclear workere promptly bringing f
safety issues to the attention of site managear.nt can hardly be doubted.
l contrary to the above guidance, Mr. Del Core told his i
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former manager that he did not intend to inform his supervisor of Although potential safety problems that came to his attention.
l he was requested to change his position and at times did bring
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concerns to supervision, NU management was confronted with an employee who was in a position to detect safety problems but with no assurance that he would disclose those problems to management, i
thus preventing management from taking prompt action to assu're that they would be dealt with appropriately.
I Manner of criticism of Unner Manamanent's 4.
i Intaarity and cossatence and Alienation of ihnolovaas h i
Since 1988, Mr. Del core has continually and openly Mananament.
criticized all levels of NU management and has challenged not
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This only NU management's comp'etence but its integrity as well.
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CONFIDENTIAL-40T*FOR Mr. Thomas T. Martin FUBLIC DIscusDRE s
Enclosure B/A09998/Page 11 December 27, 1991 i
criticism is not merely routine and sporadic.
Rather, it has 1
become a frequent occurrence which is part of an overall. pattern 3
of conduct aimed at alienating management from the employees.
Thus, Mr. Del Core routinely referred to management in his l
discussion with other technicians as the " enemy" and severely n
criticized any technician who Mr. Del Core believed was " pro-management" or a " company man."
Mr. Del Core has been heard to 8
refer to co-workers who agree with management as "having had a lobotomy and ready for a move up" to become a part of management.
j I
In addition, two IEC technicians were subjected to particularly l
abusive conduct because Mr. Del Core associated them with I
management.
Mr. Del Core's disloyalty to and alienation from the company and his attacks on management are manifested in a number l
of ways.
References to all levels of management were made using i
crude, vulgar language as were references to fellow workers who l
i l
Mr. Del Core viewed as aligned with management.
There is also a general view among the technicians that Mr. Del Core's activities i
in performing his various job-related functions were calculated l
to cost the company money.
For example, Mr. Del Core would stop work on jobs in the plant for the most frivolous of reasons, i
often resulting in substantial delay, sometimes weeks,'in completing routine procedures.
In a similar vain, Mr. Del Core had expressed dissatisfaction with the NRC's handling of his i
l allegations because the company had not been fined haavily.
on e-
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l December 27, 1991 l
I one occasion f.then the NRC found that NU had committed a Inval V violation in response to Mr. Del Core's allegation, Mr.-Sel Core i
l complained to other technicians that the NRC action was insuffi-I j
cient and, in his view, a substantial fine should have been On another occasion, Mr. Del Core i
imposed on the company.
f expressed delight when he found out that the company had to pay through the NRC users fee of Part 170 for the cost of an NRC on-1 site inspection apparently resulting because of concerns he had 9
raised.
Apart from his disloyalty to the company (evidencing i
an irreconcilable relationship with management), Mr. Del Core's attempts to divide management and the technicians would be intol-j arable in any work environment.
It is particularly serious, how-l l
ever, in the work environment at a nuclear power plant where the l
lines of communication between management and the work force j
The work for obvious safety reasons, always remain open.
l I
- must, atmosphere must be one where nuclear workers feel free to discuss j
among themselves safety or other issues and to bring them to the attention of management.
Mr. Del Core attempted, through con-l stant criticism of management and bullying his fellow workers, to create an atmosphere of mistrust and to stifle communication.
I i
Imss of Productivity and Declinina Morale in the 5.
There is a near consensus among the supervisors and IEC Group.
the IEC technicians that Mr. Del Core's conduct significantly affected productivity in the IEC group and adversely affected i
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Mr. Thomas T. Martin hWFIDllMT y
3R /A09998/Page 13 FUBLIC D C
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December 27, 1991 s
i morale.
A number of the I&C technicians noted that they had I,
little' enthusiasm for their work as a direct result of j
Mr. Del Core's conduct, including his constant complaining about i
management, his continued efforts to find mistakes in his co-4 technician's work, his use of profanity, and his argumentative and abrasive demeanor with almost everyone in the IEC group.
As l
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noted earlier, Mr. Del core's conduct caused a number of tech-1 nicians to prefer not to work with Mr. Del Core under any circum-5 i
stances.
i Mr. Del Core's adverse effect on morale resulted, among other things, from his constant criticism of the work and ability i
of other technicians.
Mr. Del Core made it a habit of question-ing other technicians about their work and subjected them to j
I criticism if it was not done in a manner which Mr. Del Core found acceptable.
Mr. Del Core coupled his criticism of his fellow workers with at least an implied threat that if a technician did l
f something with which Mr. Del core disagreed, it would become the i
i subject of an allegation to the NRC, DOL or OSHA.
In short,
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j Mr. Del Core used the allegation process not to bring safety
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j issues to the attention of management, but rather to intimidate the other technicians--and in some instances his superv,isors.
i This implied threat, coupled vf' h his constant abusive conduct, i
served to quash any professional dialogue among workers and i
l between workers and management and adversely impacted the j
effectiveness and morale of the IEC group as a whole.
i l
CONFID IAL FOR
. Thomac T. Martin LIC ICIAS
. Enclosure 5/A09998/Page 14 i
December 27, 1991 4
Although Mr. Del Core was never among the most produc-1 tive employees, over the past two years his productivity has i
Prior to his termination, he spent hours each week on declined.
the telephone claiming to be talking to federal agency personnel.
At times he left his work area or a particular job without
,j notifying his supervisor that he would be leaving the job site.
l Apart from these activities, his personal work habits changed.
1 He became far more interested in attempting to creati
- problems, real or iu J ned, while performing routine procedures rather than i
completing the task at hand.
His supervisors became reluctant to allow him to work on major assignments because they would inevit-j ably expand, unnecessarily, in scope and time.
Mr. Del Core's attitude is exemplified by his. statements to his fellow IEC i
i technicians that it was "his job to find problems--not to solve 1
l them" and that he viewed his " company business" as
" screwing the l
company."
i Conclusion In summary, Mr. Del Core's termination was solidly based on conduct which has no place in any work environment.
Management's decision to terminate Mr. Del Core had nothing to do j
l with Mr. Del Core's reporting of alleged safety concerns but instead was driven by the unquestioned need to restore 'appropri-i i
ate working conditions in the Millstone Unit No. 2 ZEC work group and ensure that the important tasks assigned to the Millstone Unit No. 2 I&C group were properly and safely performed.
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D M.t No. 50-336 A09998 i
OG)fFIDENTJAL-=
.POR PUS $1C DISCIolq 1
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December 1991 i
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lMr. Thomac T. M2rtin
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Enclosure C/A09998/Page 1 N
December 27, 1991 i
i RELEVANT INFORNATION CONCERNING TIE TERMiiGLTION F20M EMPI4YMENT OF tru. TIMOTRY O'SULLTTAN j
Mr. O'Sullivan was terminated from employment due to an i
l
. irreconcilable breakdown in the amployment relationship, as demonstrated by insubordination, the disruptions he caused among his co-workers and supervision, the profane and unprofessional 4
manner in which he conducted himself, the effect his conduct had l
on the morale of the work unit, and the potential for adverse 4
impacts on the safe operation of the Millstone Station.
The following provides the background in this case and illustrative i
examples of Mr. 0'sullivan's conduct.
i
Background
Timothy O'Sullivan was first employed at Millstone l
Unit No. 2 in November 1981 in 'the Operations Department where he trained to be an NRC licensed reactor operator.
In February 1984, the NRC sent a letter indicating that Mr. O'Sullivan did not pass the written examination to become a licensed operator.
Mr. O'Sullivan blamed the MJilstone Training Department for his failure to obtain an NRC license and thereafter sought and obtained a position in the Millstone Unit No. 2 Quality Services Department.
Mr. o'sullivan had disagreements with management in that department and in August 1986, Mr. O'Sullivan sought and i
obtained a position within the Millstone Unit No. 2 Maintenance Department as an electrician.
g e ee e e e emm WMe t
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00NFIE h h IPor
' Mr. Thomac T. Martin i
FUBLI IecIAS Enclosure c/A09998/Page 2 V
December 27, 1991 j
5 Mr. O'Sullivan came to the Maintenance Department with a mixed reputation.
Those that interviewed him thought he would make a good addition given his operations and Oc background as I
well as his training as an electrician.
The Maintenance 1
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Department @ however, had reservations about Mr. O'sullivan based upon working with and observing Mr. O'Sullivan on several occasions.
Me opposed Mr. O'Su11ivan's u'
selection; however, since his background and experience qualified him for an electrician's position, Mr. O'Sullivan was offered the job.
For their part, the other electricians were vaguely l
aware that there had been earlier problems with Mr. O'Sullivan, l
but had no adverse dealings with him while he was in the l
Operations or Quslity services departments.
I j
Although management found that Mr. O'Sullivan did I
conduct himself appropriately when initially assigned to the electrical group, his co-workers remember that almost immediately he took an us against them" attitude toware! sanagement.
This a
was in stark contrast to the close-knit organization that existed i
prior to his arrival, pases for Termination 1.
D'su111 van's sincerity susnact in a 1987 overtime criavance.
The first significant issue following 1
i Mr. o'sullivan's assignment to the Maintenance Department that i
rose to the attention of station sanagement was an overtime l
grievance filed in July 1987.
Although the details of the 1987 i
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i 3DENTf1L-- h 703
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'Nr. Thom00 T. Martin LIDfdMC148 Enclosure C/A09998/Page 3 j
December 27, 1991 grievance have been provided previously to the NRC, the significance this event had for station management was that it 1
l furthered an impression that Mr. C'sullivan was inflexible and l
In addition, unwilling to make reasonable compromises.
Mr. O'Su111 van's conduct in the prosecution of his overtime claim For example, he l
caused management to question his sincerity.
l first ace:ected the overtime payment, then returned it and later i
claimed (unser oath) he was not offared payment.
Equally i
i important, while pursuing the overtime grievance, Mr. O'sullivan seemed principally concerned with NNECO overtime policy and However, when it appeared that financial entitlement.
Mr. O'Sullivan would be unsuccessful at getting the overtime t
l policy changed, he raised essentially the same operative facts with the NRC as a safety concern in working excessive hours and i
again the very same facts before the connecticut Human Rights and It opportunities commission as an age discrimination concern.
appeared his overtime concern was being recast to fit the forum.
Inability to Work with Fellow Electricians.
2.
Electricians at nuclear power plants generally work under a 4
l Under this rule, a safety practice known as the "two-man rule."
The team of two electricians goes out and performs a task.
second electrician provides a safety function for the other by 1
l reading through procedures as well as watching for and warning of 4
any potential safety problem.
Mutual trust and confidence in the abilities and sincerities of each is vital for the efficient ar.d ese
s j
Mr. Thomas T. Martin CONRIDEN'f2M-
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LIC DI' CLqstStad B
Enclosure C/A09998/Page 4 December 27, 1991 N
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effective conduct of work.
Each electrician must be able to consicier the other a " safety net."
In this regard, for example, all electricians have.been provided CPR training because of the i
life-threatening potential of an electric shock.
1 This was the work environment within which Mr. O'Sullivan and his five Millstone Unit No. 2 fellow 4
electricians had to perform their duties.
It was premised on 4
autual trust and respect.
As illustrated by the several examples which follow, Mr. O'Sullivan conducted himself in a manner which 1
i breached this fundamental and necessary trust with substantially all his fellow electricians as well as his supervision.
l In 1987 Mr. O'Sullivan had a confrontation with a O fellow electrician.
Toward the conclusion of the work which formed Mr. O'Su111 van's overtime grievance, Mr. O'Sullivan shouted at this fellow worker and accused him of setting him up, j
" bagging him," and siding with management.
At the time, Mr. O'Su111 van's co-worker did not understand the basis for his l
verbal attack and after work he approached Mr. O'Sullivan in the i
j locker room in an attempt to reconcile.
Mr. O'Sullivan would not i
i discuss the matter which triggered his outburst and, thereafter, Mr. O'Sullivan " shunned" any conversation with this fellow electrician, except discussions that were absolutely required in order to perform work.
To this date, this co-worker cannot l
explain what triggered the outburst and subsequent shunning.
In June 1990, this co-worker authored a memorandum to management i
1
A boo IDgMT.
-WOT(FOR
.'Thom&c T. Martin Q
Lle/CISC
- IncicCuro C/A09998/Paga 5 I
December 27, 1991 indicating that Mr. O'Sullivan had told every electrician *in the J
He has further stated that he l
shop that he ir.tends to sua me.
This conduct is totally Antends to set me up and get me fired."
i l
If workers unacceptable in the conduct of safety-related work.
do not have absolute confidence and trust in their co-workers, l
and particularly in situations where electricians must rely upon each other in the performance of potentially dangerous work, often on energized safety-related equipment, the potential for a l
This outburst and subsequent safety problem becomes quite real.
shunning, in part, led this fellow electrician to request that he l
not be assigned to work with Mr. O'Sullivan because he did not i
feel he could either trust or rely upon him.
Mr. O'Sullivan had earlier conducted himself in a l
similav ursiner with respect to a second of his five fellow i
2 In July 1987, this second electrician had been i
electr4rlans.
recently hired as a NNECO electrician after working as a contract electrician since March 1986.
This second electrician J
l characterizes his working relationship with Mr. O'Sullivan in the i
f year he was a contract electrician as cordial and cooperative.
In fact, Mr. O'Sullivan encouraged him to submit an application for the posted vacancy to become an in-house NNECO electrician.
i l
Upon becoming a NNECO electrician, Mr. O'Sullivan approached this i
second electrician and asked if he would be willing tc tell j
Mr. O'Sullivan the pay grade at which he was hired.
j (Mr. O'Sullivan initially had been hired as an Electrician "B"
1 l
005F1 PINT KR I
Mr. Thomas T. Martin l
Enclosure C/A09998/Page 6 PDsLICsD]IClas December 27, 1991 4
when he joined the department based upon his experience and l
The sacond electrician indicated he was hired 1
l qualifications.)
- as an Electrician "A" based upon his experience and l
l This caused Mr. O'Sullivan to become angry and l
qualifications.
shun this second electrician, except for minimum conversation which was absolutely necessary in order to perform their job.
i.
This second shunning, as in the case of the first, continued until Mr. O'Sullivan's termination.
Also, as in the first case, b
the second electrician viewed this conduct as sufficiently upsetting so as to not have trust and confidence in how l
Mr. O'Sullivan might conduct himself on the job and thereafter j
/
asked not to be paired with Mr. O'Sullivan, if possible.
Initial Concern Over His Fitness for Duty.
In the 3.
l weeks preceding February 1988, Mr. O'Sullivan exhibited increasingly aggressive behavior towards his direct supervisor i
j over a number of seemingly insignificant or readily correctable l
administrative matters.
For example, he inadvertently had not l
Rather than been provided upgrade payment for work performed.
l approaching his supervisor for clarification, Mr. O'Sullivan i
wrote a formal document charging improper conduct.
He also j
i authored a meno with respect to different allotments of personal i
time between himself and another worker when both arrived late i
due to an ice storm.
There was no reason either issue could not have been informally resolved with supervision without resorting a
i 1
i J
~...
n IDENT
$fot Mr.'Thom&D T. Martin IC "ZC N>S N 2nclosuro c/A09998/Pago 7 December 27, 1991 to formal memoranda containing personal attacks, sarcasm, and 1
implied threats.
on February 1, 1988, Mr. O'sullivan received his 1987 personal evaluation and had a meeting with his supervisor and his Although that evaluation was generally positive, manager.
Mr. O'Sullivan was encouraged to communicate with management more In effectively prior to reducing complaints to formal memoranda.
response to that suggestion, Mr. O'Sullivan began to shake in This 14&s anger and exhibit an unusually emotional response.
j reported to the Millstone Unit No. 2 unit director,m who also l
was aware that Mr. O'Sullivan had recently made a statement to f
the effect that NNECO "had gotten him five times" and he was j
l
" going get them back as many times."
The Millstone Unit No. 2 unit director, in consultation with his management, determined that this behavior was cause for concern relative to Mr. O'Su111 van's continued fitness for duty at the Millstone i
l Station.
The director exercised his responsibility to have a
j independent and informed verification that Mr. O'Sullivan was indeed fit for duty, fully consistent with NNECO policies and r
guidance concerning the prominence of nuclear safety in t
exercising such judgments.
l i
It was conduct such as this that led the Millstone Unit No. 2 unit director to consult with his management and to decide l
1.
On January 30, 1990, the station and unit superintendent titles were changed to station and unit directors.
l L
l l
r N
i 4tr. Thon o T. Martin 00lfFIDEpIW pon'
\\
. Enclosure C/A09998/Page 8 M BLICTESCIC V
December 27, 1991 to call the company doctor.
He advised the doctor that j
Mr. O'Sullivan was displaying an unusually hostile attitude j
I towards management concerning a grievance he had filed on a rest t
time pay issue and in general was displaying growing hostility and aggressiveness and had threatened supervisors with law suits.
4 i
The doctor suggested that he should meet with Mr. O'Sullivan and l
look into the situation.
i Mr. O'Sullivan did meet with the doctor and it was the 4
i doctor's recommendation that Mr. O'Sullivan develop more amicable h
working relationships with his supervisors and workers.
In fact, a
l Mr. O'Sullivan apparently indicated to the doctor a desire to j
improve these relationships.
However, Mr. O'Su111 van's relationship with his fellow workers and supervision did not improve on its own, so in the late spring and early summer of 1988, management approached Mr. O'Sullivan through an ombudsman f
in an attempt to open up lines of communication and resolve j
issues.
This effort never resulted in any meaningful improvements.
4.
Mr. O'Sullivan Continues to Strain Work Relations.
Mr. O'Sullivan has consistently strained an already stressful working relationship with his co-workers and supervisors.
For example, in the course of his first Section 210 bearing',
3 Mr. O'Sullivan produced confidential NNECO performance evaluations of his co-workers and attempted to admit them into evidence.
It has never been determined how he came into l
l
f WFIDEhE11NNOT(FOR
?
'Mr.-Thoaa'3 T. Martin LI Q 1SC3489RE Enclosure C/A09998/Page 9
~
December 27, 1991 possession of these evaluations and no proper and authorized l
means exists.
Although his co-workers desired that the company conduct a full investigation into this matter, NNECO senior j
management decided not to pursue an investigation in an effort to avoid precipitating another conflict, to create good will with l
Mr. O'Sullivan, and with a view toward a more constructive Although the relationship working relationship with the company.
with Mr. O'Sullivan failed to improve, this decision served to I
impair the relationship between site management and l
J Mr. O'Su11ivan's co-workers.
Mr. O'Sullivan became bolder in his disruptive conduct.
over more than a two-year period beginning in the summer of 1989, 4
l Mr. O'Sullivan kept detailed notes on the arrival and departure 1
times of his fellow electricians as well as the most minute f
details of their daily work activities.
He submitted these notes to his supervisor, as well as senior management, complaining that NNECO his fellow electricians received preferential treatment.
i management always looked into the merits of Mr. O'Su111 van's l
NNECO l
complaints and generally found them to be without merit.
f management also emphasized to Mr. O'Sullivan that the performance of other maintenance personnel was appropriately being monitored, the results of those evaluations could not be shared with him, i
and his reporting on such matters strained his relationship with i
i his co-workers.
l
)
l I
n FOR NF} DENT Mr. Thomas T. M2rtin FDBLIC 'S Enclosure C/A09998/Page 10 December 27,.1991 l
Mr. O'Su11ivan's disruptive, accusatorial conduct extended beyond his co-workers to his supervision.
For example, f
in February 1991, Mr. O'Sullivan provided his immediate supervisor a memorandum responding to his annual evaluation.
Mr. O'Su111 van's response included a copy of the immediate supervisor's shift turnover log sheet.
The supervisor responded to Mr. O'Su11ivan's memorandum and addressed the inclusion of the shift turnover log by stating *I have no problem with department j
l personnel using the material in my book case or file cabinets, although I do believe that it would have been courteous to have
.i I
been asked for this information first."
Mr. O'Sullivan then accused his supervisor of making defamatory and libelous i
statements and attacking his integrity and demanded in writing I
the withdrawal of the " accusation."
In addition, Mr. O'Sullivan on several occasions had told his co-workers that he was going to "get" not only his supervisor, but also his second-level manager, i
the last statement to this effect occurring just a weak before he I
was terminated.
He was also heard to say that *he would take the problem as far as possible and do the most damage to the careers" l
of his first-and second-level supervisors because of the Raychem incident.
As this administrative issue continued to boil, the Millstone Unit No. 2 Maintenance manager wrote the Millstone Unit l
i No. 2 unit director it,31cating "Mr. O'Su11ivan's threat of legal action against his supervisor is another example of the 4
G
=9-e G
1 4
3 n
n
,l POR Mr. Thon20 T. Martin (ONFID I
i ICCLC LIC Enclosure c/A09998/Page 11 December 27, 1991 environment in which we are operating.
My view is that this is another calculated attempt by Mr. O'sullivan to intimidate i
l department management by any means that is available to him.
l Actions such as this continue to adversely impact our ability to 1
i a
j effectively manage this department."
Mr. O'Sullivan had also recently authored menos attacking the integrity and competence of a co-worker he recently began to work with.
i In March of 1989 Mr. O'Sullivan stated in front of a f
number of his co-workers that "he was going to get g 1
, and O i
@ and g jobs."
Messrs.
were Mr. O'Su11ivan's M aupervisor, f
supervisor and the Millstone Unit No. 2 As a result of Mr. O'Su11ivan's comment, on respectively.
i 1989, he met with the station director and his March 15, f
assistant to discuss how to best resolve his contentious interactions with his supervisors.
In this meeting it was suggested that a mediator be used to facilitate conversation bettisen Mr. O'Sullivan and his supervision.
Further discussions regarding mediation were held with Mr. O'Sullivan on March 21 and i
Mowever, Mr. O'Sullivan declined to participate in 31, 1989.
mediation.
Mr. O'Sullivan's May 1989 concern with the removal of I
d an electrical breaker arc chute may illustrate best how he conducted himself on-site and the level of mistrust that was engendered by his misconduct among both his co-workers and l
y
(
t' yon n
.s j
sNFID
'i Mr. Thomas T. Martin LIC ISCLOjB Enclosure C/A09998/Page 12 December 27, 1991
)
1 On May 1,1989, Mr. O'Su111 van's immediate management.
supervisor had scheduled a counseling session with Mr. C'sullivan concerning his workmanship and his quality of work on an 1
During equipment qualification issue unrelated to the arc chute.
I the counseling session, Mr. C'sullivan initially denied he was 1
i even involved in the work in question and, when pressed, became 1
l At some point during the counseling session, silent.
f Mr. O'Sullivan stormed out of his supervisor's office with no j
f explanation.
That same day Mr. O'Sullivan contacted the chairman of i,
the Safety Committee expressing an asbestos concern with respect to the removal of the arc chute.
Apparently, Mr. O'Sullivan had j
this concern for several weekst yet, in disclosing this concern to the Safety Committee chairman, he made a general reference to i
the counseling session and stated that if his supervisor could l
f give him a hard time about procedure compliance and workmanship requirements, then the same rules should apply to his supervisor.
Thus, Mr. O'Sullivan raised his asbestos concern in an effort to l
f cast his supervisor in a bad light rather than resolving the oguipment qualification issue which was the subject of the 1
counseling session.
According to the safety Committee chairman, Mr. O'Sullivan started out the conversation "in a cala'and controlled manner, but as he continued his explanation of this i
situation, he had become loud, irate and was using profanityr his demeanor was getting up to the point where it was intimidating."
i i
l i
j i
courzb vom N.thomabT. Martin JFUBLZd51(C1/0 l
Enclosure c/A09998/Page 13 i
December 27, 1991 The safety committee chairman, along with Mr. o'sullivan's first-and second-level managers, accompanied him to inspect the arc i
l chute which, unknown to anyone, had been removt* earlier by a fellow Millstone Unit No. 2 electrician as part of the disposal l
plan for this component.
several days earlier, this fellow electrician recalls Mr. O'Sullivan warning him " sternly, in a way a supervisor would warn an employee, not as two co-workers would talk to each other" to not remove the arc chute.
Mr. O'Sullivan immediately assumed the arc chute had 1
i' been removed in an attempt to ridicule him and make his look l
On May 7, 1989, Mr. O'Sullivan authored a memorandum to l
foolish.
l f
the Millstone Station director indicating that the removal of the arc chute represents a " type of juvenile behavior and leadership 1
4 i.
instability on the part of the maintenance department head and I
two of his assistants that has caused department employees to i
i become jaded by the double standard, demoralized by a permanent leadership vacuum and the hemorrhaging caused by selective and l
i q
1 unfair treatment of certain employees."
3 i
After the arc chute incident, Mr. O'Sullivan subjected i
l the electrician who had removed it to the same shunning behavior i
that the two other electricians had been receiving since mid-i t
The result of Mr. O'Su111 van's conduct was that !as of mid-1987.
h 1989, he'was not speaking to three of his five fellow electricians and those same three had stated a preference not to work with him.
Of critical importance is the fact that the
s Mr. Thomas T. Martin CONF D.
-1 Fom' FtFB C D2 s'
Enclosure C/A09998/Page 14 December 27, 1991
(
reason that they did not want to work with him was a lack of trust in performing their potentially dangerous and safety-related work.
Thus, through his own unreasonable conduct, he had i
breached the trust and confidence with his co-workers needed to
)
perform.his job.
At that point, in May 19,89, Mr. O'Sullivan's immediate i
supervisor documented a concern that various actions filed by j
1 Mr. O'Sullivan against NNECO and his fellow electricians were having a detrimental effect on the work effort.
He indicated that based on observations he personally had made and statements t
made to him by a number of Millstone Unit No. 2 electricians, co-workers were fearful of working with Mr. O'Sullivan and that some h
workers were hesitant to perform in an upgraded position when l
l Mr. O'Sullivan was one of the people being supervised.
He also l
said that the workers did not discuss jobs as openly es they once l
l did, and there was "a fear of being ' set up'" or "being involved l
in some sort of litigation."
He said that others were reported i.
as having said they would leave the department if a chance arose.
Mr. o'sullivan's immediate supervisor stated, "I believe that d
when people have concerns as serious as these on their minds the level of concentration needed to perform their work safely and j
correctly may not be there."
4 This concern had been felt by Mr. O'Sullivan's immediate supervisor for some time prior to the are chute
- incident, several months earlier, this supervisor had been i
4 1
N N
-t 03NFIDM
==WPt a
'SURE Mr. ThosOc T. Martin M
IT3LIO DESC f
Enclosure C/A09998/Page 15 December 27, 1991 I
sufficiently frustrated and concerned that he sought and obtained Although senior f
a meeting with MNECO senior management.
management acknowledged the autremely difficult job of a first-l line supervisor, it also took the opportunity to underscore that NNECO simply could not and would not allow any action which i
suggested that legitimate concerns were being suppressed or going In short, NNECO management counseled the solicitous i
unanswered.
l Such a response further l
approach described in the cover letter.
l demoralized this supervisor, who was a highly regarded supervisor I
of the electrical group and who had headed that group for almost 2
i However, after two years of trying to manage ten years.
l Mr. O'Sullivan, this supervisor felt compelled to seek a position 1
l elsewhere because of the discord and distraction caused by i
Mr. O'Sullivan coupled with more senior management's lack of
{
l success in holding Mr. O'Sullivan accountable for improper i
conduct in the workplace.
This supervisor, f
left this position for a nonsupervisory position elsewhere at i
4 j
Millstone.
After his immediate supervisor transferred out of the i
department, Mr. O'Sullivan openly bragged about being responsible for his removal and indicated he would also "get" the jobs of his mext level manager and the Millstone Unit No. 2 unit director.
j Following the departure of his immediate supervisor, a long-time l
co-worker and personal friend of Mr. O'Sullivan became the 5
Although this new supervisor supervisor of the electrical group.
i 4
4
FOR' Mr. Thomas T. Martin
.NFIS FORLIC DISC E
Enclosure C/A09998/Page 16 V
December 27, 1991 d
found himself in a difficult situation-attempting to manage six electricians, three of whom did not want to work with s
4 l
Mr. O'Sullivan--he felt the situation was manageable and possibly even improving until November 1990.
5.
naveham solica Tasue.
In November 1990, a decision was made to reinspect a Raychem splice
- performed by l1 Mr. O'Sullivan several months earlier.
An electrician performing l
in an upgraded position had expressed a concern about the quality of the splice since the work seemed to have been performed in an j
unusually short period of time.
Mr. O'Sullivan was questioned at the time on how quickly the work had been performed; however, he indicated it had been done correctly and that QC had signed off I
on it.
This response was not accepted by the upgraded h
electrician who, et the start of the next outage, went to management and sought permission to inspect the suspected splice.
i l
I Management agreed, indicating that if there was a concern over h
i the quality of the job, then it would be redone.
The work was 4
found to be unsatisfactory and subsequently reworked.
i When Mr. O'Sullivan became aware o'f what had occurred, i
he became enraged.
He believed that the reinspection suggestad a vengeful and "get the guy program" of harassment approved by maintenance management.
Mr. O'Sullivan told his immediate k
j 2.
Certain details of this matter were discussed in a March 27, l
1991, enforcement conference with the NRC in Region 2 offices.
i
WFIDE IRL-=
TOR Mr. Thondo T. Martin L19DSCL]O Enclosuro C/A09998/ Pag 3 17 December 27, 1991 supervisor that he had been wronged and that he intended to sue Before the entire because this was defamation of his character.
shop, Mr. O'Sullivan then charged his immediate supervisor in a loud and profano manner of trying to bag him, indicating he had no credibility and shouting at him to the point where the supervisor had to leave work with chest pains.
l Mr. O'Su11ivan's supervisor subsequently attempted to talk with him to resolve differences and answer any questions.
1 l
Mr. O'Sullivan, however, refused to talk not only to his Just immediate supervisor but others involved in the incident.
as Mr. O'Sullivan had previously shunned three of his five fellow electricians, from the time of the Raychem splice inspection
{
until the time of his termination, Mr. O'Sullivan shunned his For almost a year he had no conversation i
immediate supervisor.
i with his immediate supervisor, except what was absolutely i
necessary to do his job.
This relationship was sufficiently 5
, carried 3a x 5" l
strained that his supervisor, cards in his breast pocket and recorded attempts to have polite l
exchanges with Mr. O'Sullivan.
i Several examples of insubordination occurred in the course of the Raychem splice issue.
First, Mr. O'Sullivan refused to talk about this safety-related incident with' his I
t immediate supervisor.
Thus, in response to a memo from Mr. O'Sullivan to NNECO management, it was decided that an j
J That task was delegated to the independent review would occur.
}
l s
. R eONFI>
f Mr. Thomas T. Martin FtPBL D
C Enclosure C/A09998/Page 18 December 27, 1991 1
When the assistant to the assistant to the station director.
l station director contacted Mr. O'Sullivan, he similarly refused to discuss the matter with him.
The QC inspector who had initially signed off on the adequacy of the Raychem splice based i
on Mr. O'Su11ivan's representations was counseled by his Similarly, supervisor with respect to future work expectations.
Mr. O'Su111 van's supervisor counseled his regarding the need to l
l follow procedure requirements at all times.
During this session, Mr. O'Sullivan became irate and walked out of his supervisor's i
i office.
NNECO management maintained the solicitous approach in response to this insubordination in an effort once again to " hope l'
fences could be mended."
The opposite result occurred.
f Mr. O'Sullivan was more galvanized than ever against his long time co-workers and immediate management.
As of the start of 1991, numerous co-workers preferred not to be sent on an i
j assignment with Mr. O'Sullivan out of a concern that he may not l
This come to their aid in the event of a worker safety issue.
fear was held by each individu lly and each based on a different, a
t Other events which 4
l personal experience with Mr. O'Sullivan.
eccurred in 1991 which ultimately led to the termination of Mr. O'Sullivan have been discussed elsewhere.
j I
conclusion f
In summary, Mr. O'Su111 van's termination was solidly l
based on conduct over a period of years which has no place in any s
I 1
00 ID FOR Mr..Thomac T. Martin
,fnciccuro C/A09998/Pago 19 LI@ISCLoURh December 27, 1991 I'
work environment.
Management's decision to terminate Mr. O'Sullivan had nothing to do with Mr. O'Sullivan's, reporting of alleged safety concerns, but instead was driven by the i
[
unquestioned need to restore appropriate working conditions in the Millstone Unit No. 2 Electrical group and ensure that the 4
l important tasks assigned to the Millstone Unit No. 2 Electrical 1
l group were properly and safely performed.
1 1
I 1
I f
1 1
i i
4
L Docket No. 50-336 A09998
/
ICQN3 50r1CR vgx s qstn u
2 i
4
+
4 Enclosure D l
4 i
j d
t t
l i
.f 3
I December 1991 J
t.
Third Party Rovicw in th2 Aroc t
of==eloven concerns 2.
TNTRODUCTION This ' review began with a two part purposs, to determines (1) the willingness of WU personnel to raise concerns through the chain of command or other approved lines of reporting within NU, ands (2) the receptivity of NU supervision and management to such j
j Since there has been an inordinate number of employee 1
concerns.
l concerns within specific departments at the Millstone, Unit 2,
!~
facility, NU requested that personnel within the affected
- i
{
work-units be interviewed in a way that fosters employee 1
l confidence and ascertains the root cause.for these continuing i
l concerns.
4 SACKGROUND, METHODOIOGY, AND SAMPLE f
22.
As that contains my professional background.
I l
background indicates, I have had no previous involvement with Apart from the information j
either NU or the Mi'1 stone sites.
j provided in the coarse of the interviews, no NU manager or representative attempted to direct my offorts in any substantive j
matter nor r(view or alter my findings in advance of this report.
since criticia:as over the receptivity of management to I
i employee conceins appeared to be centered within the Electrical j
khose f
and Instrumentation and Controls (IEC) groups at Unit 2, groups were the focus of interviews.
l A, set of questions was developed designed to determine the willingness of NU personnel to raise safety concerns and the
,[
those conce s.
receptivity of supervision and management 1
?
fl
}
,.ya l
L
N l.
These questions are set forth in Enclosure 2, however, W ottached questions were varied and supplemented in the course of Andividual interviews so as to stimulate spontaneous, individual
~
responses.
About one to two hour interviews 1 pero held with f
Included among those interviewed cyproximately 30 NU' personnel.
substantially all Millstone, Unit Two, Electricians; ersre:
substantially all Millstone Unit Two, ISC Technicians; carrent and previous immediate supervisors within those two work groups;
~
managers and directors within the chain of command of those two work groups up through the Station Directors oparktions personnel; the Directors of Units 1 and 3; and other personnel involved in the disposition of concerns currently being raised relative to NU.
Questions were intended to define organisational dynamics, processes, and existing concernes motivations and desires.
In addition, a selected document review was conducted to determine the quality of procedures used in addressing the raising of safety concerns, including; Nuclear Engineering and Operations Procedure NEO 2.15, Nuclear safety Concerns Program, Revision Six, dated April 20, 1990.
212. RESULTS OF INTERVIEWS WITH SELECTED PERSONNEL 1.
Introduction Although all interviews initially followed the Not of questions in enclosure 2, and at no time were the saaes of f
f SI{ d){.J't' b
t.
u
l*
cpecific individuale initio11y raiced by tho interviewer, in i
t on cearly every interview the interviewee focused their commen cither one, or both, of two Millstone Unit 2 employees:
f i
en Donald Del Core, Sr., an I&C Tech., or Timothy O'.ull van, l
Substantially all personnel;, interviewed hold strong Electrician.
dividuale l
opinions concerning the manner in which these two in 1
jority of l
conduct themselves on site, and se described below, a ma result of a j
the personnel interviewed aiter their conduct as a Del Core or i
concern over, and at times fear of, retribution from
~
l f
O'Sullivan.
cf the information developed in the f
As a resula l
(1) the willingness of interviews, this report addresses:
i ity of f
employees to raise concerns and the corresponding recept v 1
f l
management toward those concerns; (2) employee's views o f
increasing levels of management; (3) the specific conduct o l
i duct on l
Del Core and O'Sullivan, and; (4) the impact of that con l
Finally, recommendations the organization and site activities.
i I
are provided.
willinoness of Emplevees To Raise concerns and the Correspondino Receptivity of Mansaament 2.
I l
2n the course of interviews, the vast majority of personnel.dre candid and open, and demonstrated a clear l
i the understanding of the need to raise safety concerns to assure j
l Personnel generally displayed a este operation of the Unit.
l f
perience at l
inature attitude toward their jobs and had a level o ex Except for the perceptions or exceeding the level seen elsewhere.
f
.f De1 Co,. and...um.an,.s.e11 as the genera, per.e, tion o l
l dd.9/}N[
t
.4
)
others when de'aling with matters involvino Del Core and O'sullivan, personnel were in substantial agrmnt that raising i
j l
cafety concerns through the chain of command is both the preferred approach ard the one desired by stu.
Personnel also indicated a l
general willingness to raise safety conceitps through the chain of 1
Personnel at the working level indicated that if seamand.
confronted with a concern which they either couldn't raise, or had
]
raised to no avail, with their immediate supervisor, t. hey would a
(1) raise it with a higher level of afU management; (2) go
~
eithers directly to the NRC; or (3) submit it to the Nuclear Safety I
concerns Program (NSCP).
4 Employees at the working level generally understood the l
Although the NSCP was usually characterized as a i
l NSCP.
well-designed program, few employees indicated a willingness to l
When confronted with a concern mot being i
use the program.
l adequately addressed by supervision, most employees indicated tha l
l they would raise the concern with either second level management i
l or go directly to the NRC.
The perception of the NSCP as an l
of factive avenue for concern resolution appears to be hampered by Ats of f-site location, coupled with a preoccupation with l
f confidentiahty.
Confidentiality is automatically bestowed on a concernee, even if it is not requested and even under l
eircumstances when it cannot be assured in light of the concern i
l This unnecessarily erodes the program's credibility
-expressed.
and impacts its offectiveness.
i Personnel at both the working level and management t
t1e knowledge of the Nuc ar Review Team (NRT) f evidence b
l
- ~ ~ ~..
-- --- - - ~- - - - - -
r ----- --
-w mn,
a.
1 Few understand its relotionship to tho ESCP and when ena l..
propas.
The NRT program program should be stilised rather than the other.
l cppears redundant and unnecessary.
j A motable exception to this overall willingness to raise I
eencarns through the chain of seamand is 'the perceptions of f
Del core and O'Sullivan, as well as the general perception o f
ethers when either of these two individuals is favolved 1
The coworkers of Del Core and O'Sullivan for the i
i concern.
part expressed a general apprehension toward these indivi i
which at times was expressed as a fear, which results in a i
reluctance to confront these employees or to disagree with the r s
l positions.
3.
Emplevee's views of Management i
Interviews revealed a mutual respect among employees, as l
hi well as good communications among the co-workers and t e r i
j inanediate. supervisors, except for three individuals.8 l
Employees generally considered their second level Employees managers as eccessible as their first-line supervisors.
d good and managers evidenced a mutual respect for one another an working relationships.
Mos,t employees knew the Unit and Station directors well, l
and indicated a level of familiarity greater than what is l
For the sost part, the employees, typically seen at other sites.
I l
Del Core and O'Sullivan were a notable exception to this A third individual considered management meither 8
acceptable nor receptive, but his views were not expressed view i
with the same degree and level of intensity as t l
J l
KbL(7 f I' y'>crt.
in a re the condit on his name wougd not be u g
(q..
- a. <
,c v
however, did not fool confidgnt in bringing iconos ecsocioted with,
l Del Core or O'Sullivan to the director level because it was l
that in the past directors have not lived up to commitments.
There is a sonse among working-level personnel that the l
commitments by onsite directors are overrated by corporate ij, management and accordingly, co-workers lack confidence in raising l
There was a generally expressed view I
l 1ssues with the directors.
that if an issue could not be resolved by the first line supervisor or second level manager, an employee would probably go
~
A smaller number would go to the SISCP under such j
j to the NRC.
When asked to explain this perception the two circumstances.
examples consistently provided were corporate management's 1
l f
reversal of a site management decision to investigate how O'Sullivan obtained the personal evaluations of his co-workers and l
c'sullivan's refusal to cooperate in a company investigation into i
i a nonconforming Ray-Chem splice.
l Both employees and site directors perceive an excessive t
l amount of direction from corporate management on issues that are As an example, supervisors and viewed to be properly site issues.
l managers indicate they do not have the authority to administer l
discipline,wven for minor infractions, (especially in the cases l
of Del Core and O'sullivan) without specific direction and/or li Additionally, corporate managements' approval from headquarters.
decision to overrule site directors' agreement to investigate the apparent unauthorized release of personnel records including, l
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sonnel employee cyclecticas, c nt o clear sesocg3 to cite per ior managers and i
.regarding the limited authority of those sen i
Soth employees and site directors do not l
directors on site.
to deal porosive a str'ong message from senior management on how li i
signals
)
erith the conduct of Del Core and O'Sullivan and perce ve i
Their anderstanding of l
cs frequently mixed and/or reversed.
i k the
]
headquarters guidance is *take the high road", don't soc I
boat, and don't in any case confront these individuals and j
l hopefully the issues will somehow resolve themselves.
Nmgh the l~
In short, the message about bringing concerns th:
onnel, but l
chain of command as being received by working level pers l
is not being followed when concerns involve either Del Core This appears to be the result of the abrasive and I
i i
ly O'Sullivan.
l intimidating manner of Del Core and 0*sullivan, and a genu ne d by l
felt concern on the part of coworkers that they might be sue in court or become these individuals or otherwise have to testify h or in any part of some other formal process if they disagree wit Management's inaction l
way interfere with Del Core or O'Sullivan.
tion.
l to resolve this situation has compounded this percep l
Conduct of Del Core and O'Sullivan 4.
Although there appears to be some ditforences with l
l s
respect to how Messrs. Del Core and O'Sullivan conduct th l
l is en the job site, their behavior has certain common charact There is a general l
that affect site activity in the same way.
d perception on the part of a vast majority of both co-worke l
immediate.eupervisors that the volume, frequency and type o i
concerns being raised by both individuals are not due to genu j
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safety concerns but are Cuo to o desire to "tako Cn managepsers
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The view cause confusion, and ' bury management in paperwork".
f emong most co-workers is that both Del Core and O'Sullivan are j
raising concerns out of a personal vendetta against the company.
On all assues discussed, the co-workers and tamediate superv j.
l*
appeared to be candid and genuine and gavs no reason to s As a result, and based on their statements, their sincerity.
spective there is a serious question with respect to the safety per of Del core and O'Sullivan.
~
There appears to be an unreasonable and unintelligible f
e unwillingness on the part of both Del Core and O'Sullivan to us l
approved lines of communication within NU, either through th l
Although both individuals j
chain of command, the NSCP or the NRT.
the were critical of and indicated an, unwillingness to ese either t
l Their NRT or NSCP, no basis for that position is evident.
is characterizations of both immediate supervision and management
.s..<
N in stark contrast to the characterizations o s
f interviewed.
That is to say, althoug willingness in the first instance to raise concerns with supervision and a receptivity by supervision to hear such l
concerns, Dg1 Core and o'sullivan categorically were negative 2
i respect to all aevels of management.
l There appears to be a near-total breakdown in the
)
L l
These individuals appear to be employer /amployee relationship.
i Their course of conduct appears both unmanaged and unmanageable.
i For example, several unprofessional and at times insubordinate.
j supervisora and managers stated that O'Sullivan categorically f
f O
o I
~
m er refused to discuss with his management en ollegedly asprop Stailarly, Ray-Chem splice which he was involved in performing.
lly exited several interviewees indicated that Del Core intentio ithout the plant erith an internal medical radiation source w informing the appropriate eenpany personn51 ef this fact as The exit radiation detectors f
required by company procedure.
informed the alarmed, as expected, and Del Core then tamediately I
Both O'Sullivan and Del Core t
NRC of the matter by telephone.
i oncerns repeatedly indicated their total unwillingness to ra se c f
company through the company's chain of responsibility or other programs designed for such purpose.
that There is a general perception among most co-workers d various both individuals are on a campaign to harm the company an l
do not 1evels of NU management, and that,the individuals clear y l
accept NU's objectives and strategies.
f h ir Based on interviews with both the individuals l
d Each l
co-workers, no viable path to resolution was identifie.
f Person interviewed was asked how the situation l Core or l
able to C'sullivan could be resolved and the majority were un Del Core and suggest a solution short of transfer or termination.
i d among D'sullivan appear intractable and this perception is share l
\\
i 5
i the co-workers.
EFFECT ON ORGANIEATION l
IV.
The conduct of Del core and O'Sullivan has had l
devastating effket on their respective work units. The mora e There l
nd Unit 2 2&C techs is low.
among the Unit 2 electricians 4
l Le e
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is a perception among almost all co-workers that Del Core cnd I-i O'sullivan are given favored treatment when compared to others.
l According to site personnel, Senior NU management has f
l consistently preached a "high road" approach to tausediate l
supervision and co-workers when dealing with Del Core and l
Although the apparent intent of this "high road" c'sullivan.
approach is to assure all employees are treated equally and not t
l subject to discrimination for raisir.p concerns, the approach has 1
l been interpreted at the site as permitting the two individuals to i
J be given favored treatment.
i l
Co-workers, immediate supervision, as well as unit i
l directors and the site director see no end in sight to the chronic This discord between O'Sullivan and Del Core and the company.
f festering situation is a continued distraction to many employees f
in that they are 'looking over their shoulder" out of a concern 1
l that their job activities will be misinterpreted or mischaracterized and become part of a contentious situation.
l Immediate supervisors and managers within these work units are f
spending anywhere from 20 to 70% of their time on issues raise
]
f This distraction has eroded the l
either Del Core or O'Sullivan.
There is some evidence of attrition among I
\\
work environment.
l immediate supervisors and the interviews revealed that a number o i
supervisors as well as co-workers are considering leaving their j
l There jobs or transferring because of the poor work environment.
j is a perception among co-workers that if they disagree with either f
O'Sullivan,or Del Core there will be retallation from these fostered mistrust between the This individualsina}eform.
i f
i e
i W
Egun11y important, thio workcrs, cnd Del Coro and O'Cullivan.
l oppears to have contributed to a growing mistrust between workers l
cnd managers due to the failure on the part of management to deal j
l with this long-standing situation.
l There is difficulty within these work units in planning Yependingam work since immediate supervision and management Supervisors have Anordinate amount of time resolving concerns.
l l
Jost their ability to manage their people in ways traditionally 1
l For example, a supervisor indicated that they l
seen in work units.
would not even let individuals leave ten minutes early to make a dentist's or doctor's appointment because of an awareness that l
such treatment would be viewed as favoritism and the subject of a l
Generally, concern to the NRC or the basis for a DOL complaint.
l co-workers do not want to work with these individuals, especially Supervisors tend to plan work around them to maintain l
j O'Sullivan.
i the peace.
The long term ef fect on both the Unit 2 electrical and l
I&C groups is an erosion of morale and performance, and a l
corresponding potential safety issue with respect to their ability 4
to concentrate on work.
l
.\\
V.
RECOMMENDATIONS l
In light of the information provided in the interviews, l
f as summarized above, the following three basic recommendations are (1) remove both Del Core and O'Sullivan from the site; (2) made:
significantly upgrade the authority and level of on-site 1
y e
i
12 -
i l
~
J management (in this regard consideration should be given to an on-site corporate officer to provide the continuity between site activities and the corporate office) and; (3) comeunicate SIU's j
basis for any action taken relative to these individuals or site I
management to the working level.
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7 f
MENRY D. MUKILL Nuclear Consultant i
Benry D. Mukal1 retired in December 1990 from G During his more than Island Nuclear Generating Station Unit One.10 years in this ij, modifications and testing following the 1979 accident at Unit Two which led to the successful restart of Unit One in late 19 l
Following restart he directed and supervised the operation and l
l asintenance of Unit One through more than th l
j For the year 1989 Three Mile Island Unit One had the highest capacity factor of all the operating nuclear plants in the outages.
l world.
Mr. Nukill has over 30 years' experience in the nuclear field.
j Sofore joining GPU he served as a senior civilian special l
No was assistant to the Commander, Naval Sea Systems Command.
responsible for all matters related to the selection, education, Navy's qualification, training and professional performance of the l
more than 1,200 engineering duty officers.
l A native of South Bend, Indiana, he received a bachelor of science Following graduation degree from the U.S. Naval Academy in 1953.he served l
During his career he was year of naval nuclear power training.primarily involved with I
l cperation of nuclear submarines.
]
l Nis Navy assignments included five years as Commanding Office a Nuclear Submarine and four years on the staff of Admiral l
Nyman G. Rickover, who for many years headed the Navy's nuc L
Ne was responsible for the selection and engineering training of all nuclear submarine commanding officer Power program.
l l
Ne retired with the rank of Captain.
l Since retirhent from GPU Nuclear Corporation, Mr. Nukill hasHe is curr remained active in the nuclear industry.
Ne is of the Nuclear Safety Review Boards for five utilities.
l also a member of the National Nuclear Accrediting J
l Justitute of Nuclear Power Operations (INPO).
Trom 1976 to 1977 he was associated with the Clin project for turns and Roe, Inc4 l
Nukill and his wife, Virginia, reared seven children and currently l
reside in Elizabethtown, Pennsylvania.
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- TNTERVTfw SiffBELTWER harB TTarE BF 8tFESTf 8WTMS 2.
Introduction
,1.
Introduce yourself.
.e.ie. with the inter.ie.ee th.,oints.e. forth i. th.
l-2.
Letter establishing this interview.
Emphasise that it is not the puroose of this' interview i
to receive or discuss specific cifety concerns, but 3.
rather it the purpose of this meeting to better understand how such concerns are raised by employees and responded to by management.
i Should any interviewee have specific ochcarns a.
refer them to their supervisor.
l If interviewees are insistent on providing specific concerns, the expert should indicate that b.
l he will receive those concerns and provide them to Rich Laudenet for appropriate disposition through j
the chain of command or Nuclear Safety Concerns Program, as appropriate.
Following this general introduction,' ask if they have 5
4.
any questions.
i 22.
specific Questions Current position and how long have you held this I
1.
position?
l Positions at Northeast Utilities prior to current l
2.
position?
Po(itions at other commercial nuclear power plants?
l 3.
l What is your current understanding of what is expected of you as an NU amployee when you identify a safety
/
4.
concern?
Where did you gain this understanding? (03T, formal i
5.
training, or soes combination thereof) e What is the typical response of your imeediate 6.
eupervisor if you raise a concern with him?
i j
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10-m 6
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4
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2-If you had a cone rt., would you raico it with your j
Zi mot, why not?
..7.
immediate supervisor?
Do you get adequate feedback from your immedi*ete l
supervisor when you raise a concern?
i N
i 8.
ld What is your current understanding of what you shou l
do if in the course of performing a task un
.S.
]
with the procedure?
j Do you believe that it is generally possible to do your job in compliance with the procedures you must work
.10.
mader as they are currently written? -
Have you ever identified a nuclear safety concern to l
your immediate supervisor that was inappropriately f
11.
~
If so, explain.
responded to?
j Under what circumstances would you not raise safety Would you -
concerns you may have with your supervisor?
d2.
vehicles then avail yourself of other employee concern j
If not, why not?
4 Nuclear Review Team?
NRC Inspections indicate that there is a responsive l
atmosphere to communicating safety issu l
13.
Do you agree or disagree eafety concern resolution.What is the basis for your opinion?
l l
with this?
NRC Inspections also indicate that the empl j
ith all i
14.
or the elements of a good program, do you agreeWhat is the basis fo l
l disagree with this conclusion?
i your opinion?
i What is your assessment of how effect i
?
15.
l ld j
Are there any recossendations or other points you wou f
16.
like to make?
i i
111. Conclusion Conclude by thanking interviewee for their cooperatio f the f
and ask that they not discuss with others the substanca o h benefit of each 3atters discussed so that you will have t eFinally, once again, ask if they person's individual answers.have any questions or anything else l
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4 Enclosure E i
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December 1991 1
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SERNAMD M. fox serueswres eranussom anuyn February 26, 1991 stone 2 Engineering 1
Dear g I have recently come to understand your role in identifying and correcting a problem with an important system at Millstone i
I would like to take this time to commend your J
initiative and insight in' your observation of the incorrect
)
Unit 2.
position of a valve in the service water' system on November 15, Thanks to your actions, a vital safety system at 1990.
Millstone 2 was restored to its design alignment.
I understand that setup and verification of proper system Your actions alignments is not part of your normal job duties. demonstra y
problems in all areas of plant operations.and important quality nuclear facilities.
Thanks again for your efforts and keep up the good work.-
i very truly yours, i
l cc: E. J. Mroczka W. D. Romberg S. E. Scace J. S. Keenan l
B.
. Duffy l
Pe sonnel File i
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FORYOURINFORMATION l
ments that have been established over the years to l
We have received inquiries regarding an action taken by' station management earlier today, address employee concems.
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j Two employees have been amoved from their i
jobs at the Millstone Nuclear Power Station and their employment with Northeast Utilities has been terminated. Their employment was termi-d j
nated because there has been an irreconcilable an, J
detrimental breakdown in their working reladon-i ships with others at the site as a result of their I
behavior. Although we have tried repeatedly to l
Teestablish harmonious working reladonships, we have not been successful in these attempts and it is clear that further attempts would be futile.
Trust and confidence are required in any working
^
relationship, particularly where people must work together to safely operate a nuclear power plant.
This matter had degenerated to the point that it
' was negatively affecting the trust and confidence l
of coworkers and supervisors, including adverse impacts on nuclear safety.
l l
It must be emphasized that their employment has been terminated because they have made it clear l
that they do not trust or have confidence in station j
management, and are either unwilling or unable to work with management toward mending fences.
l l
This action is not the result of these employees' having filed allegations with state and federal regulatory agencies.
NU continues to strongly encourage employees to bring nuclear safety
, j concerns to their supervision or to other organiza-tions,6oth within or outside the company, estab.
lished to rec'eive such concerns, including state 4
and federal regulatory agencies.' NU is committed to resolving all employee concerns quickly and l
thoroughly, and remains committed to maintain-
'ne the various otstions and procram enhanee-Pare 1 l l
The MiUsteme Messenger November s.1990 v
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- ryr.pesusgummedudear Engineering pnd Operations *..
1 Two employees have been removed from tiheir jobs at Millstone and their employment with NU terminated because of an irreconcilable o
end detrimental breakdown in their working relationship with It must be others at the site as a result of their behavior.
emphasized that this action IS NOT the result of these employees having filed allegations with state and federal regulatoryNU conti agencies.their nuclear safety concerns to their supervisor or to the other organizations, both within or outside the company, established to NU is committed to resolving all employee receive such concerns.
concerns quickly and thoroughly, and remains committed to the various programs and program enhancements established over the years to address employee concerns.
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L-7 Docket No.*506336 109998 j-CONFIDENTIAL--NOT FOR 1
FUBLIC DISCIASURE 4
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All NE60 Employees 8.d.Opexa j
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j (Ext. 5323) i j
SUBJECT:
Nuclear concerns i
I am sure that by now you are aware that on Friday, November 8,1991, two I
employees were rcooved from their jobs at the Millstone Nuclear Fover Station, This memo briefly explains the bases for and their employment at NU terminated.
these actions on the part of NU management, and, more importantly, emphasizes l
the importance I place on the free expression of nuclear safety issues.
The employment of these two individuals was terminated because there had been an irreconcilable and detrimental breakdown in their working relationships with Although we tried repeatedly j
others at the site as a result of their behavior.
to reestablish harmonious working relationships, we were not successful in these further attempts would be futile.
Trust and attempts and it was clear thatconfidence are required in any working relations This matter had must work together to safely operate a nuclear power plant.
degenerated to the point where it was negatively affecting the trust and confidence of coworkers and supervisors, introducing adverse impacts on nuclear safety.
It must be emphasized that the employment of these individuals was terminated because they mede it clear that they did not trust, or have confidence in, l
station management, and were either unwilling or unable to work with management This action is not the result of these employees having i
toward sending fences.
NU continues to filed allegations with state and federal regulatory' agencies.
strongly encourage employees to bring nuclear safety concerns to their l
supervision or to organizations within and outside the company, including state l
NU is and federal regulatory agencies, established to receive such concerns.
cosaitted to resolving all employee concerns quickly and thoroughly, and remains i
and improving the various options and program consitted to maintaining have been established over the years to address employee enhancements that The continued success of our nuclear program is dependent upon your insights in identifying nuclear safety issues, and expressing them promptly to i
concerns.
your management or through the other vehicles we have established and described i
in NE&O 2.15, Fuclear Safety concerns Program.
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i December 1991 i
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THE DAY. WEDNESD AY. DECEMBER 4,1991 l
OPINIONS OF DADERS
~
i Millstone employee signedad withpride va o,e wi.r.f rue Day:
Robert Hamilton has once again proven he is unable to write an objective article about Millstone Station. In his Nov. 20 article. Mr.
Hamilton included a quote from Donald Deleore. Mr. Delcore stated that he believed that some employees signed an ad, in Sun-day's paper, because they feared for their jobs if they dida*t.
Since Mr. Delcore was not on -
site when employees signed the ad, he has no ability to speak fac-tually about it. Therefore, when Mr. Hamilton included it in his 4
article, he was doing nothing more than repeating gossip.
Unlike Mr. Delcore,I do not feel quellflod to speak for others. But.
as someone who signed the ad,I 4
een tell you that I proudly signed, with no fear for vny job if f didn't. I algned because I truly believed in what the ad stated, and believed it was about time that the allent ma-jority told itlike itis.
I repeat the challenge I made in a previous letter to your paper.
When Mr. Hamilton is ready to write a factual article about Mill-stone he should come and talk to some of the rest of us. Not just those who say what he wants to hear.
David W.Teece Oakdale
./
3 s
1 f
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4
THE W. THURSDAY, NOVEMBER 21,199 l
OPINIONS OF READERS l
Millstone is run safely; whistleblowers manipulating The Day
}
doing lately seems to go beyond the pursuit of sum.
edies ibr asfety issues and to have descended into j
To the Editar of The Day: l.you warn that %e pub-In your Nov.10 editoria
.the harassment of an enuty which is not just a face-i j
lie needs criucal employees such as Tim O'Sullivan less eorporation, but a team comprised of many J
l and Don Deleore at nuclear plants as if without dedicated. hard working men and women.
l these two men safety at Millstone is now in jeop-Mr. O'Sullivan and Mr. Delcore,with the advice of J
ardy.
4 heir very able legal help, have used The Day to set j
The underiying presumption, murtured by the the scene as ifit's a very simple esade-Spr.4alevision media, is that those who run Muistone would risk movie. Northeast UUllues will star as the Big, Bad
)
the general public's safety for proSt ifleft to abelt Conspany whichwillstos atnothing!
own devices.
Sadly, unless you have worked at a nuclear power Think about it! Those who work at Millstone,in plant, or have taken the une to Snd out, you have addition to their families, are part of the general i
so ldes to what extent asfety concerns control each public. We all live within a ahort radius flrom these plant's operation. Providing the power we all need for our daily living is very important, but it is sec.
generating stations.
4 If these plants were not run safely,the employees would be the most endangered. These experienced, ondary to the safe opersuon of every nuclear powe i
plant in this system.
intelligent people would not put up with serious I can proudly any that any husband is currently a j
5 threats to their well being, or to their families,or to endisuon protocuon technician at Millstone,whose l
the general population.
primary responsibility is to sninimite worker expo.
j If you could poll a random sampling of Millstone aure. And, before we started a family,I was an en.
i j
employees, you ould find that they are proud of gineer at Millstone assigned to construcuen projects 1
the job that they do. They know that the Millstone which were part of a continual etTort to further im-
)
plants are some of the best run facilitJes in this prove Plant safety.-
Tammy Stearns country. They know that there is a system in place to address any safety concerns that they may have.
Oldlyme j
What Mr O'Sullivan and Mr. Deleere have been s
I I-l 4
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4 i
Veryproudto work atMiHstone
'To the Eeterof the Der:
These are the people you I was diaboartened to see an-abound be seeklag Ser their spin-ether biased articleis the Nov.33 Goos. Centrary to what was al-ediuon soneerning Millstone. Auded to in a quote by Donald -
NowI feel one of the many areal" Deleore found in another biased people with a name Area Mill-article you vesency peblished, stone should beve a say.
these 800 warg est osereed erin-I I
This article was Slied brith thnidated.
The espport was so weer-I quotes and oplafons from " anon. whelming that the spaces se the -
l yunous" employees. It's hard to ad were Alled so inst that usany selieve that you would print this.
It's eary to And a poup of dis. hundred more aanployees didn't grusued ensployees and portray even have the abange to partici..
them as a representative aross pale. I am tired of reading your section, especially when they udiced, asti.auclear rhetoric, with soenganous aplaien.
heve no names.
Who are thesc people? Are they You owe it to your readers to supervisors, eompany spokesmen, activelypureve the whole ersth.I engloeers or workers involved work at Millstone and am eery with day.104tey station actjylues? proud of this I, along with many,.
many others support the Mill.
The real solees of Millslane stone administrados and am act were the 880 amployees who atald toletyou know whoI am.
l I
signed and paid for the Adl.page PaulJ.pgiv3Js ad that was reeency published.
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pocket No. 50-336 A09998 N
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A 90NFIDEWFI TOR
. Bir,Thomac T. Martin
$53LIC C18 I
i A09998/ Enclosure E/ Pag 3 1
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December 27, 1991
)
NORTIIAST WUCLEAR ENERST CONFANY AFFIDATIT SUPPORTING REQUEST j
TO WITEBOLD FROM PUBLIC DISCIASURE i
2, John F. Opeka, being duly sworn, depose and state as follows:
i i
I am Executive Vice President, Nuclear and as such I am j
1.
responsible for the preparation and review of the l
information referenced herein sought to be withheld from I am submitting this affidavit in public disclosure. connection with the provisions of 10 CFR Section 2.790 of j
the Commission's regulations.
l' The information sought to be withheld includes information 2.
contained in the personnel files of Northeast Nuclear Energy Company ("NNECO") and utilized by NNECO in making personnel determinations.
i This information is of a type customarily held in strict 3.
confidence by NNECO and, other than its disclosure to the Commission, ie intended to be held in confidence and not disclosed to the public.
NNECO considers the records and data contained in personnel l
4.
files to be confidential when the records and/or data l
contain evaluations of individual NNECO employees or other j
employee-specific information, public N sclosure of which would infringe upon the employee's pf vacy.
I The information sought to be withheld makes specific i
5.
reference to named individuals.
Under NNECO policy, this information remains confidential, and public disclosure of j
l this information would violate named employees' expectations
(
that personnel information will remain confidential.
In j
NNECO's view, disclosure of this information would constitute a clearly unwarranted invasion of privacy.
s Additionally, the information sought to be withheld l
6.
constitutes information that, due to the nature of the dispute and ongoing litigation, should remain confidential i
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in order to protect the interests of NNECO and to ensuro l
fair and impartial resolution of all claims.
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f 00NF1 DENT FOR Str. Thomas T. Startin A09998/ Enclosure R/Page 2 M M C D E,8 V
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December 27, 1991 The information sought to be withheld is being transmitted J
f to the commission in confidence pursuant to the provisions of 10 CFR Section 2.790 with the understanding that.it is to j
be received in confidence and withheld from public l
disclosure by the ccanission.
The information sought to be withheld, to the best of my 8.
knowledge, is not available in public sources, and any disclosure to third parties has been and will be made pursuant only to regulatory requirements that provide for i
the maintenance of the information in confidence.
i The above eight paragraphs are true and accurate to the best of my knowledge, information, and belief.
j Executed this 2 7 day of
, 1991.
I bb JohnJ. Opeka U
i state of Connecticut)
)
ss:
l County of Martford
)
sworn and subscribed to before se this g day of /[/g u M
{
1991.
9 Y_
Notary Pulpic i
My commission expires:
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SERNAMD M. FOX February 26, 1991 i
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i I
stone 2 Engineering l
f Dest g J
I have recently come to understand your role in identifying and correcting a problem with an taportant system at Millstone I would like to take this time to commend your l
initiative and insight in*your observation of the incorrect Unit 2.
l position of a valve in the service water system on November 15, Thanks to your actions, a vital safety system at l
1990.
l Millstone 2 was restered to its design alignment.
j I understand that setup and verification of proper system Your actions alignments is not part of your normal job duties. demonstr i
j l
problems in all areas of plant operations.and important quality fo i
nuclear facilities.
l Thanks again for your efforts and keep up the good work.*
I Very truly yours, l
A l
l cc: E. J. Mroczka W. D. Romberg i
E. Scace r
l onn ile
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I SERNARD M. FOX i
sueseparamermsussessucest February 26, 1991 4
i i
stone 2 Engineering j
j Desr g 2 have recently come to understand your role in identifying l
and correcting a problem with an important system at Millstone I would like to take this time to commend your l'
initiative and insight in*your observation of the incorrect Unit 2.
j position of a valve in the service water' system on November 15, Thanks to your actions, a vital safety system at l
i 1990.
j Millstone 2 was restored to its design alignment.
I understand that setup and verif t:stion of proper system f
Your actions alignments is not part of your normal job duties.
i j
demonstrated a keen desire and ability to identify potentialThis a much desire i
problems in all areas of plant operations.and important quality f nuclear facilities.
Thanks again for your efforts and keep up the good work. -
i very truly yours, I
/
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cc E. J. Mzoczka W. D. Romberg E. Scace d
onn ile t
l 21ms 13716
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SERNARD M. fox sursop6 A ENr OfWtWWS SWWM February 26, 1991 1
4 4
h stone 2 Engineering f
f Dear g 2 have recently come to understand your role in identifying and correcting a problem with an important system at Millstone l
I would like to take this time to commend your initiative and insight in'your observation of the incorrect Unit 2.
1 position of a valve in the service water ' system on November 15,
)
Thanks to your actions, a vital safety system at i
1990.
l Millstone 2 was restored to its design alignment.
i I understand that setup and verification of proper system Your actions f
y alignments is not part of your normal job duties. demonst j
problems in all areas of plant operations.and important quality f j
l nuclear facilities.
l Thanks again for your efforts and keep up the food work.
l very truly yours, i
M l
l l
I cc: E. J. Mroczka W. D. Romberg E. Scace a
onn ile l
- Ims l
13716
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