ML20127C436
| ML20127C436 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 12/24/1992 |
| From: | Ellis W NORTHEAST UTILITIES |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| NUDOCS 9301140209 | |
| Download: ML20127C436 (16) | |
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CAAIMMM AND Cwt! talCVM t O!hCin December 24, 1992 Nr. James M. Taylor Executive Director of Operations U.S. Nuclear Regulatory Comission One White flint North 11555 Rockville Pike Rockville, MD 20852
Dear Mr. Taylor:
RysJ n r Safety Concerns 1
The attention of Northeast Utilities (NU) management and the NRC Staff has been focused in the.last several months on performance issues at NU's nuclear-facilities.
Various NU internal Task Group efforts identified performance 1
issues last year very_ similar to those described by the NRC-Staff -Special Review Group (SRG) in the Executive Sumary of its report."'
Eight months have now passed since we responded to your letter transmitting the Executive Sumary,, and I wanted to take-this opportunity to 1rovide -you with an update on some of the issues raised by the SRG regarcing the handling of nuclear safety concerns at NU, At the-time of the writing of the Executive Sumary of its report, the_ SRG had observed that while there has not-been a " chilling effect" at NU on the-willingness of employees-to report safety concerns, the "presen.t _ atmosphere.-
could not be conclusively determined" because of the recent restructuring of H
our nuclear management team and pending effortt ' to enhance our nuclear performance.
A related theme-underscored by the SRG concerned the need _-to improve the ease of access to and visibility of NU's Nuclear Safety Concerns.
Program -(NSCP) (improvements targeted also in.our internal Task Group: review oftheprogram).
As a result of the restructuring of our nuclear organization-and' of uther j
management initiatives,:we believe that teamwork, comunications, and morale-
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have improved, and' a work environment that we always thought conducive to' the-
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expression of concerns has been enhanced.
While our efforts -to address manacement and performance issues such as those raised by the SRG predated the L
- development - of HU's Performance Enhancement: Program (PEP), our goals for r
(1)
- J. M. Taylor letter to W. B. Ellis, dated April 6,1992.
(2)
W. B. Ellis letter to J. M. Taylor, dated April 15, 1992.
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'Mr. James H. Taylor Page 2 December 24, 1992 improvement in these areas have been incorporated into the PEP in the form of comprehensive action items.
The PEP is moving forward, and we have been keeping the NRC Staff fully apprised of the progress of these efforts. As you know, a Comission briefing concerning the status of the PEP is scheduled for February 9, 1993.
We have also fulfilled the comitment we made in our response to your letter transmitting the 3RG's Executive Sumary to explore ways in which we could improve our NSCP.
As a result of our evaluation of the N3CP, we have implemented a number of enhancements, as well as a recent procedural revision to NEO 2.15, our internal procedure addressing " Nuclear Safety Concerns."
We intend that these changes will make the NSCP more accessible and visible to employees.
We fully recognize that it is very much in NU's interest that an environment be fostered in which employees will use this program to expruss themselves on nuclear safety issues should the nonnal use of itne management be perceived as ineffective or inappropriate in a particular case.
Pfer Representative Procram As part of our continuing scrutiny of the NSCP, we comissioned. an
" Allegations Root Cause Task Force" in 1991 to review NSCP performance. Among other things, the Task Force recomended that we:
(1) make the NSCP more
" user-friendly" by increasing its visibility, and (2) staff the program with working level pe sonnel who could relate to employees in their various locations within the organization.
As noted, subsequent to our internal Task Force review of the program, the NRC Staff Special Review Group similarly indicated that the NSCP's effectiveness could be enhanced by improving the ease of employee access to the program.
To implement these recomendations, we created a Peer Representative Program-to our knowledge, the first of its kind in the nuclear industry-in which volunteers throughout the nuclear organization (currently 32 individuals) act as liaisons to the NSCP.
I sent a memorandum to all nuclear employees announcing the implementation of this program on April 30, 1992 (Attachment 1).*
Rather than contact the NSCP oirectly, any employee may contact any NSCP peer representative, in confidence.
This individual will assist in and facilitate the handling of a nuclear safety concern.
When an employee approaches a peer representative with a concern, the representative will then relay the concern to the NSCP.
These volunteers work in a broad cross-section of departments and locations (including the Haddam Neck Plant, our Millstone units, and our Berlin office), and therefore provide our employees with ready access to the NSCP. These representatives were enrolled based on their knowledge of systems and procedures and based on their reputation for integrity and ability to inspire trust among their peers; all those who volunteered were selected. The l
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This and other recent enhancements to the NSCP were described in a l
September 25, 1992, letter from J. F. Opska to T. T. Martin.
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Hr. James H. Taylor Page 3 December 24, 1992 NSCP Staff har quarterly meetings with the peer representatives to exchange experiences, ideas, and industry information.
The NRC Senior Resident inspector from Hillstone Station was invited to, and attended, the most recent of these meetitegs.
Management is comitted to the success of this program. A 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> orientation sest, ion for the peer representatives was conducted, during which time I met with the peer representatives for a sessinn which evolved into a two hour discussion.
in short, our Peer Representative Program is designed to make it easier for employees to comunicate with the NSCP and more likely that they will do so.
Indeed, a number of peer representatives have already been contacted by NU Most encouraging is the fact that a majority of the issues employees.
identified to the peer representatives were able to be resolved through the chain-of-comand.
The peer representatives acted as facilitators, guided by NSCP staff, in bringing the issues forward and achieving timely resolutions with a minimum of formality.
We believe that this innovative enhancement to the NSCP will substantially increase the program's visibility and effectiveness throughout our nuclear organization.
figLNSCP Charter In recent years, the NU Board has been keenly aware of empicyee concerns issues.
This interest and oversight has been even further laightened as witnessed by their recent approval of an NSCP Charte which defines the a'Jthority, objectives, and ressonsibilities of the NSCP.
The charter formalizes existing reporting rei ationships whereby the Director of the NSCP re> orts functionally to me as Cheirman of the Board, and administrative 1y to Joan Opeka as Executive Vice President Nuclear.
The NSCP Charter is n ovided as Attachment 2 to this letter.
As the Charter states, the principal responsibility of the program is to ensure 'that all nuclear safety and radiological concerns brought to its attention are addresse:f in a timely and thoroug'1 manner, and that those who raise such concerns receive an r opriate response."
The Charter further provides that the NSCP Director
'l have direct access to the Chairman of the Board of Trustees, as well a:, to the Chairman and members of the Corporate Responsibility Comittee of the Board, l
l if and when that access is necessary. The Charter also mandates the quarterly review of all open concerns in order to determine what actions are required to l
bring them to resolution, and that the Director of the )rogram review with the Corporate Responsibility Comittee any matters for whic1 the Director believes management action is required and has not been taken.
As a result of your letter of June 3,1992, to each member of the NU Board of l
Trustees, the Board has raised its awareness of the performance of the NSCP.
The Corporate Responsibility Comittee of the Board has been briefed twice since early June by the Director of the NSCP and has examined several typical NSCP cases.
The NSCP Director also provided a briefing to Dr. Norman l
Mr. James H. Taylor Page 4 December 24, 1992 Rasmussen, in his capacity as a member of the Corporate Responsibility Comittee, during which several investigative case files and results were discussed along with the protocols used to manage the handling of nuclear safety concerns.
One of the major points of focus of the 1990 enhancements to our NSCP was a measure designed to underscore the commitment that employees utilizing the program would be accorded confidentiality and anonymity if they wished.
In its Executive Summary, the SRG described a concern among certain employees that confidentiality and anonymity might not be assured.
Sensitive to this concern, and recognizing that both the maintenance and perception of anonymity are important elements in a successful nuclear concerns program, the new NSCP Charter reaffirms this important element of the NSCP in the section on
" Responsibilities." The Charter provides as follows:
In carrying out its responsibilities, the program shall:
(a) exercise a
high degree of sensitivity to the confidentiality of individuals raising concerns up to the point where the risk of disclosure is outweighed by the company's ethical and legal obligations to discover and correct as necessary, those concerns with a significant impact on the safe operation of our nuclear facilities; and (b) refer concerns to the organization most responsible / capable of achieving an effective resolution with due regard-for the confidentiality of the concernee.
Confidentiality and the means for raising concerns anonymously are also prominently treated in NE0 2.15.
In addition, the handling of employees who wish to remain anonymous and maintaining the confidentiality of the matters addressed by the NSCP are subjects dealt with at length in NSCP protocols.
Education about the NSCP Because we believe that the effectiveness of the NSCP can be enhanced by integrating information about the program into our employee training sessions, since early this year an NSCP representative has participated in the segment on NSCP procedures included as part of NU's Administrative Procedure Training course.
The NSCP representative assists the course instructor in answering employee questions and providing specific information on the functioning of the NSCP.
The feedback from training instructors with regard to the NSCP participation in the training.:ourses has been positive.
In addition, trainees have been eager to discuss program-related issues openly with NSCP representatives.
We believe that this enhancement to our program has already produced substantial benefits, and it is our plan to continue this new arrangement in future training sessions.
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Mr. James H. Taylor Page 5 December 24, 1992 The NSCP Staff has also provided input into the General Employee Training Program for employees. Additional information on new features of the NSCP has been provided through memoranda to all employees in our nuclear organization and through newly revised program posters located in vtrious locations throughout Nuclear Engineering and Operations.
NE0 2.15. Revision 9 Revision 9 of the NE0 2.15 procedure describing the available means for handling nuclear safety concerns became effective on October 1,1992.
This revision reflects the changes described in this letter and clarified certain administrative details.
In its Executive Sumary, the SRG reported a perception of too high a threshold before a concern meets the definition of a nuclear safety concern.
In response to that observation, Revision 9 advises employees of the historical and continuing acceptance of all concerns by the program, thereby lowering any threshold employees might have perceived as an obstacle to utilizing the program.
Elimination of the NRT The Nuclear Review Team (NRT), an outside consultant organization (LRS Associates), for many years provided one of the parallel, alternative routes by which employees could seek resolution of nuclear safety cencerns.
With the implementation of the enhancements to the NSCP, tie NRT's role in addressing safety concerns became somewhat redundant and was not widely used in this function or, in our view, as accessible as the peer representatives.
Accordingly, the Company has now eliminated the NRT's safety concern function (although we continue to use the services of Robert Staker, who was a member of the NRT, for other purposes).
This change was announced in a memorandum that I sent to all nuclear employees dated July 31, 1992 (Attachment 3).
Conclusion As indicated in my letter to you of April 15, 1992, the Company is proceeding with diligence to implement our PEP, which has been designed to address wide-ranging performance issues.
In addition, NU has expended substantial effort in recent months in exploring methods of enhancing our employee concerns program.
We anticipate that the enhancements implemented to date will make the NSCP more accessible and visible to employees and in that way foster an environment in which employees will not hesitate to express themselves on nuclear safety issues.
Indeed, I can report that the items in the PEP Action Plan for the NSCP were completed earlier this year.
The Action Plan will pow be subject to the validation process of the PEP.
Beyond that, we will continue to monitor the effectiveness of the NSCP and implement any necessary refinements which may come as a result of employee or peer representative feedback, our participation in the Edison Electric Institute subcommittee drafting program guidelines, or observations offered by the NRC.
Mr. James H. Taylor Page 6 December 24, 1992 If you have any questions about these matters, I would be pleased to discuss them with you further.
Very truly yours,
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T. T. Hartin, Region ~ I Administrator J. F. Stolz, Project Directorate 1-4 W. J. Raymond, Senior Resident inspector, Haddam Neck Plant P. D. Swetland, Senior Resident Inspector, Hillstone Unit Nos.1, 2, and 3
7 Nuclear Safety Concerns Program Enhancements Memo April 30, 1992 E'
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M 66 N April 30, 1992 wwau a tous cumnum auo cer estcurwr oonenn To:
All NEO Employees
Subject:
Nuclear Safety Concerns Program Enhancements I am pleased to let you know about an organizational enhancement 1
Under the' direction of our Nuclear Safety Concerns Program (HSCP).
of David Diedrick, we have been working to address the One of recommendations of the Allegations Root Cause Task Force.
the recommendations was to enhance the program by the addition of Peer Representatives.
These representatives are volunteers throughout the Nuclear Group who act as liaisons to the NSCP office.
They are representatives whom you can contact in f
confidence, and who will assist you on any safety concern.
They can serve as a liaison with Dave and Bob Zysk who will work to provide a response to the concern.
We continue to emphasize that the chain-of-command is the best way to resolve nuclear safety concerns, but we recognize that some people are not comfortable with this approach.
By providing the peer representatives we hope to make it even easier for you to communicate with the NSCP.
You will note that the representatives are scattered-throughout the Nuclear Group both geographically and organizationally; however, they do not represent exclusively either their organization or their location.
It is our intent that we have. people in these positions who.you will recognize and feel comfortable with in discussing your concern.
This new program is effective immediately and a list of the Peer Representatives is attached.
I am enthusiastic that this enhancement will further improve our program and will enable us to elevate the NSCP's. visibility _
throughout the organization.
Nuclear safety is paramount at-Northeast Utilities'and of course, is paramount with sach of;us personally.
Our Nuclear Safety Concerns Program is a very l
important element of=our commitment to safety, and_its-success--and our success as a nuclear plant operator--depends on each of us as well, to participate, to be vigilant-in_ finding and reporting safety concorns, and to ensure that these concerns are resolved.
Very truly yours,
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4 NUCLEAR SAFETY CONCERNS PROGRAM (NSCP PEER REPRESENTATIVES EXT 1 LOCATION PEER REPRESENTATIVE 4222 Health Physics - Millstone 1 Frederick W. Altvator 5115 Nuclear _Eng. - Berlin WOO 7 Clifford J. Ashton 3517 Nuclear Services - CY Roy E. Brown 3531 Quality Services - CY Joseph M. Burke 5317 Maintenance - Millstone 1 Donald S. Cleary 4314 Engineering - Millstone 2 John L. Criscione 4575 Chemistry - Millstone 2 Gregory L. D'Auria Millstone 4494 Site Eng. & Maint.
P&ul F. Dillon 5784 HP Support - Millstone John W. Doroski 5795 Nuclear Eng. - Berlin N236 Arthur F. Flath
- 3834 Cost & Schedule - Berlin E228 Joseph S. Fowler 4396 Gen. Construction - MP ROB Robert A. Grebasch 3154 Project Services - Berlin N017 Richard J. Halleck 3567 Quality Services - CY Walt E. Heinig 4224 Maintenance -' Millstone 3 Randy J. Jacobson 5389 Procurement Eng. - Millstone Stephen E. Kane 3846 Project Services - Berlin N020 Frank J. Lukaszek 2660 Nuclear Training - MP Simulator Michael G. Manolakis 3005 Rad Assess.
Berlin W12'2 David W. Marzilli 4667 Rad Materials - Millstone Frank M. Matovic 4911 Quality Services - MP' NAP Robert E. Michaud 4971 Chemistry - Millstone Mark F Peterson 3994 Nuclear Eng. - Berlin WOO 6 Michael T. Smaga 4222 Health Physics - Millstone 1 George S. Smith 3575 Michael J. Steinbuchel operations --CY-2817
' Tech Trn. HP - MP Trng. Center Jeffrey Taylor 4227.
Rad Materials - Millstone Paul Tulba 5752 Engineering - Millstone 2 James A. Tyrol 3858 Nuclear Eng. - Berlin WO35-Steve W. Wainio 3287 Project Services - Berlin N30 Stephen J. Weyland rm.-
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Charter of the Northeast Utilities Nuclear Safety Concerns Program P
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Charter of the Northeast Utilities Nuc1 car Safety Concerns Program I.
Introduction The Purpose of this Charter is to define the authority and responsibilities of the Nuclear Safety concerns Program (the Program) of Northeast Utilities.
II.
Statement of Program Objective The objective of the Program shall be to assist the manage-ment of the Northeast Utilities system companies (collectively, the Company) in the effective discharge of their responsibilities to provide the Company with an effective means to ensure the safe operation of our nucicar facilities by addressing and resolving nuclear and radiological safety concerns.
III.
Responsibilities The Program shall be responsible for ensuring that all nuclear safety and radiological concerns brought to its attention are addressed in a timely and thorough manner, and that those who raise such concerns receive an appropriate response.
Within the context of nuclear safety the Program shall carry out these responsibilities by investigating or referring for investigation those matters which:
(a) may pose a
threat to the safety of employees, contractors or visitors at our nuclear facilities, or the general public; (b) may violate the laws, regulations, codes and guidelines governing the operation of our nuclear facilitics; (c) may deviate from Company
- policies, procedures and practices designed to ensure the safe operation of our nuclear facilities; (d) may create an environment inconsistent with the proper conduct of, or inhospitable to reporting of deficiencies with respect to, the operation of our nuclear facili-ties; or (e) may involve potential wrongdoing through act, omission or representation regarding the operation of our nuclear facilities.
In addition, the Program may, from time to ties, consult on existing or proposed
- systems, projects,
- plans, policies and t
procedures of the Company.
Participation in such activities will not preclude the Program from later investigating them.
The Program, however, shall strive to use personnel for the investiga-tion other than those who participated in the consultation.
Furthermore, the Program shall render such assistance to the Board of Trustees and any of its committees as required.
The Program shall have no direct responsibility or authority over activities or operations investigated.
Although the Program may recommend courses of action, the responsibility for taking action in response to such recommendations shall rest with operating management.
In carrying out its responsibilities, the Program shall:
(a) exercise a high degree of sensitivity to the confi-dentiality of individuals raising concerns up to the point where the risk of disclosure is outweighed by the company's ethical and legal obligations to discover and correct as necessary, those concerns with a significant impact on the safe operation of our nuclear facilities; (b) refer concerns to the organization most responsible /-
capable of achieving an effective resolution with due regard for the confidentiality of the Concerneo.
(c) refer to the Human Resources
- Group, concerns of intimidation, harassment and other employment related matters.
(d) refer to the Corporate SeSurity Department, concerns involving criminal wrongdoing or matters of a similar nature.
(e) refer to the Internal Audit Department, concerns involving internal business controls, use of resources, fraud, conflict of interest or other irregularities.
(f) refer to NU Executive Management, concerns involving the conduct of the Program.
(g) refer to outside agencies, organizations or third party contracted consultants, concerns where such referral is.
necessary to' maintain independence or objectivity or where it is determined that the overall effectiveness of the Program will best be served by doing so.
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Reporting Relationships The Director of the the Program shall report functionally to the Chairman of the Board of Northeast Utilities and administratively to the Northeast Utilities.
Executive Vice President -
Nuclear of The Director shall have direct access to the Chairman of the Doard of Trustees of Northeast Utilities and Chairman from time to time to review shall meet with the the
- nature, timeliness and adequacy of concern investigations and resolutions; the trending of concerns as a reficction on policico, procedures and management practicos; the effectiveness of the Program and enhancements /-
corrective actions necessary to achieve a high level of effectiveness.
The Director shall also have access to the Chairman and members of the Corporate Responsibility Committee of the Board and when that access is necessary.
if The Board of Trustees or the Corporate Committue may direct the Program to perform examinations or inveResponsibility tigations in any area as the Committee deems necessary s-V.
Relationship With Other Departments The Program is granted access to all activities, records, physical properties and personnel of the Company.
The Program shall conduct examinations and investigations in a minimizes adverse impact on the day-to-day operations manner that department
- involved, commensurate with maintaining nuclear and of the personnel safety and regulatory compliance.
all The departments and personnel involved are expected to render appropriate assist-
- ance, including furnishing documentation, making personnel available for interviews and responding to requests for data within tion of concerns.a reasonable time period, so as to facilitate the resolu-VI.
Reporting and Follow-up The Program shall, after each investigation, prepare such written recordo as are deemed necessary to resolved and an a ensure concerns are the Concerneo.ppropriate, timely, written response is provided to Where a predicated on a future actionresolution and response to are a concern by functional line management, the are in fact implemented. Program shall make reasonable efforts to ensure those actions E
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i The Program shall quarterly review all open concerns and determine what actions are required to bring them to resolution.
The Director of the Program shall review with the Corporate Responsibility Committee any matters as to which the Director believes management action is required and has not been taken.
Approved by the Corporate Responsibility Committee of the Board of Trustees of Northeast Utilities on flovember 24
, 1992.
0' Chairman of the Board of Trustees LEGAL-1033
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Nuclear Safety Concerns Program Memo July 31, 1992 December 1992 1
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Co* AMAN ANO Cstst9 t st wtut o,9Xin To:
Northeast Utilities Employees Involved in Engineering, Design and Operation of our Nuclear racilities 1
Even though we may all share some disappointment in the results of our recent nuclear operating record, I am writing to express my complete confidence in your ability to improve the operation and maintenance of our nuclear plants, and to encourage your freedom of expression on nuclear matters.
In large measure our reputation in the nuclear industry results from your daily efforts to openly communicate those nuclear matters which are important to maintain Nuclear Safety as our. number one objective.
i our reliance on each other's knowledge and understanding in'the highly complex area of nuclear generation means we 1; ave an obligation to work as a team in addressing matters important to nuclear safety.
I encourage you, therefore, to advise your supervisor of any concerns that you ray have about nuclear safety at NU's nuclear units.
However, if you would feel more.
comfortable doing so, I urge you to communicate with our Nuclear Safety Concerns Program (NSCP) through Berlin extension 3754, cY extension 3276, Millstone extension 4349 or by calling toll free l-800-282-SArc (7233).
The NSCP has also been expanded--to provide even easier access through_your Peer _ Representatives.
These volunteers, whose names and phone numbers are-posted throughout your work locations, may be approached to assist you in properly addressing nuclear safety _ concerns.
Any contacts with the NSCP will be kept confidential upon request.
You should also be advised that the Nuclear Review Team (NRT),
headed by Mr. P.obert G. Staker, will no longerHbe one'-of the available options for reporting nuclear safety concerns under our The NRT will continue to serve our nuclear program in program.
its other roles, but if contacted about a-nuclear safety concern-will refer employees to the NSCP.
I assure you that contacts with your_NSCP will be handled in-a confidential _ manner.
Your thoughts and suggestions regarding nuclear safety issues and concerns serve as the key to our continuing success, and I encourage you to expand and imptr,ve upon open communications at all levels.
Very truly yours, s:
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