ML20138K979

Ack Receipt of 970114 & 0204 Ltrs That Provided Addl Info on Independent third-party Organization,Little Harbor Consultants,Inc,Selected to Oversee Implementation of Util Comprehensive Plan Addressing Employee Safety Concerns

ML20138K979
Person / Time
Site:	Millstone
Issue date:	02/14/1997
From:	Travers W NRC (Affiliation Not Assigned)
To:	Kenyon B NORTHEAST NUCLEAR ENERGY CO.
References
NUDOCS 9702190275
Download: ML20138K979 (5)

Text

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[ t UNITED STATES i'

g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2000H001 i o\ .....f 8 February 14, 1997 i Mr. Bruce D. Kenyon J President - Nuclear Group i

Northeast Utilities Service Group c/o Richard T. Laudenat

Director - Nuclear Licensing Service P.O. Box 128 Waterford, CT 06385-0128 i

Dear Mr. Kenyon:

l This letter is to acknowledge receipt of Northeast Nuclear Energy Company's (NNECO) January 14 and February 4,1997, letters that provide additional information on the independent, third-party organization, Little Harbor Consultants, Inc. (LHC), that you selected to oversee the implementation of NNECO's comprehensive plan addressing employee safety concerns (ESC).

On January 30, 1997, we sent you several topic areas to discuss at the February 5, 1997, meeting. Just before the meeting, you provided us with a February 4, 1997, letter that proposed the addition of two people to the independent, third-party oversight team. You proposed to add Mr. James K.

Perry, Jr., and Ms. Billie P. Garde. In the evening of February 5, 1997, the NRC staff held a public meeting in the Waterford Town Hall to receive comments  ;

from the residents of Waterford on NNECO's selection of LHC as the independent l third-party organization to oversee your employee safety concerns program.

In reviewing your letters, we note that two people, Ms. Garde ar.d Dr. Wood, have had direct, previous involvement with NNECO.

In your January 14, 1997, letter, we note that the resume for Dr. Paul J. Wood states that he "Provided senior management oversight to and participating in the planning and implementation of the Palisades PRA [probabilistic risk assessment] for Consumers Power Company, as well as the Millstone Point Unit 3 PRA for Northeast Utilities Service Company."

In the February 4, 1997, letter, proposing to add Mr. Perry and Ms. Garde to the independent, third-party oversight program (ITPOP), you stated the following:

Ms. Garde was involved as a consultant to NNECO assisting our employee team in the development of NNECO's Comprehensive Plan... As an added precaution, to ensure Ms. Garde's independence, administrative controls will be implemented by LHC to preclude her involvement in LHC's programmatic assessment of the adequacy of the Comprehensive Plan.

NNEC0 believes this is acceptable and fully supports the addition of Ms.

Garde to the LHC team.

I 1RC IRE CHUS COPY ON D j

i 190025 9702190275 970214 i PDR ADOCK 05000245 I P PDR ]

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' Mr. Bruce D. Kenyon i While we agree that adding someone like Ms. Garde to the oversight team brings

a valuable perspective of the employee and of the whistleblower and addresses

one of the topic areas raised in our January 30, 1997, letter, we find that she does not meet a specific provision of the Order; Dr. Wood also does not meet the same provision. The Order states specifically that

The third-party organization chosen to oversee the conduct of the i Licensee's comprehensive plan must be independent of the Licensee, such

that none of its members has had any direct, previous involvement with i the activities at the Millstone Station that the organization will be

overseeing.

5 Dr. Wood's involvement in the Millstone Unit 3 PRA, and Ms. Garde's work on

the ESC comprehensive plan appear to represent direct, previous involvement with activities at the Millstone Station that the organization will be

overseeing. Therefore, the inclusion of Dr. Wood and Ms. Garde would be contrary to the Order. If NNECO wants to pursue having Dr. Wood or Ms. Garde or any other individual having direct prior involvement at NNECO, participate as a member of the oversight team, NNECO needs to demonstrate good cause for l the NRC to relax the above-identified provisions of the Order.

1 l During the February 5,1997, public meeting, members of the public commented l that although Ms. Garde would make an excellent addition to the oversight team j in providing the perspective of an employee and the experience of a i whistleblower, she would have conflicting interests in overseeing the ESC plan j she helped to develop. '

i

If Ms. Garde cannot participate as a team member, NNECO should consider i rounding out the oversight team with someone who can represent the perspective j of an employee and the experience of a whistleblower.

Sincerely, l

! William D. Travers, Director Special Projects Office

! Office of Nuclear Reactor Regulation i

Docket Nos. 50-245, 50-336, and 50-423 cc: See next page l

. i .. ,  ;

Mr. Bruce D. K;nytn - [ February 14, 1997 w

l. While we agree that adding someone like Ms. Garde to the oversight team brings  ;

a valuable perspective of the employee and of the whistleblower and addresses

one of the topic areas raised in our January.30, 1997, letter, we find that  !

i she'does not meet a specific provision of the Order; Dr. Wood also does not  ;

meet the same provision. The Order states specifically that:

~

, .The third-party organization chosen to oversee the conduct of the '

, Licensee's comprehensive plan must be independent of the Licensee, such i

that none of its members has had any direct, previous involvement with .

l the activities at the Millstone Station that the organization will be ,

overseeing.-

• Dr. Wood's invo'1vement in the Millstone Unit 3 PRA, and Ms. Garde's work on ,

the ESC comprehensive plan appear to represent direct, previous involvement with activities at the Millstone Station that the organization will be t overseeing. Therefore, the inclusion of Dr. Wood and Ms. Garde would be i

, contrary to the Order. If NNECO wants to pursue having Dr. Wood or Ms. Garde

or any other individual having direct prior involvement at NNECO, participate

as a member of the oversight team, NNECO needs to demonstrate good cause for- 1

the NRC to relax the above-identified provisions of the Order.

! During the February 5,1997, public meeting, members of the public commented ,

that although Ms. Garde would make an excellent addition to the oversight team in providing the perspective of an employee and the experience of a l

whistleblower, she would have conflicting interests in overseeing the ESC plan she helped to develop.

• If Ms. Garde cannot participate as a team member, NNECO should consider rounding out the oversight team with someone who can represent the perspective of an employee and the experience of a whistleblower.

Sincerely, Original signed by E. Imbro for:

3

~ William D. Travers, Director i

- Special Projects Office y Office of Nuclear Reactor Regulation

- , , i Docket Nos. 50-245,:50-336, .

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and 50-423 * ,a l p ,. t*, s

~

l cc: See next-page .^

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DATE 02/h/97 02/Iy/97 02//v/97 02/12/97 02//f /97 0FFICIAL RECORD COPY

Northeast Utilities Service Company Millstone Nuclear Power Station Units 1, 2, and 3 cc:

Lillian M. Cuoco, Esquire Mr. Wayne D. Lanning Senior Nuclear Counsel Deputy Director of Inspections Northeast Utilities Service Company Special Projects Office P.O. Box 270 475 Allendale Road Hartford, CT 06141-0270 King of Prussia, PA 19406-1415 Mr. Kevin T. A. McCarthy, Director Mr. F. C. Rothen Monitoring and Radiation Division Vice President - Work Services Department of Environmental Northeast Utilities Service Company Protection P.O. Box 128 i 79 Elm Street Waterford, CT 06385 i Hartford, CT 06106-5127 Charles Brinkman, Manager Mr. Allan Johanson, Assistant Washington Nuclear Operations Director ABB Combustion Engineering Office of Policy and Management 12300 Twinbrook Pkwy, Suite 330 Policy Development and Planning Rockville, MD 20852 Division 450 Capitol Avenue - MS 52ERN Mr. D. M. Goebel P.O. Box 341441 Vice President - Nuclear Oversight Hartford, CT 06134-1441 Northeast Utilities Service Company i P. O. Box 128 l Regional Administrator, Region I Waterford, CT 06385  !

U.S. Nuclear Regulatory Commission 475 Allendale Road Mr. J. P. Cowan i King of Prussia, PA 19406 Millstone Unit No. 3 Nuclear l Recovery Officer First Selectmen Northeast Utilities Service Company Town of Waterford P. O. Box 128 Hall of Records Waterford, CT 06385 200 Boston Post Road Waterford, CT 06385 Mr. M. L. Bowling, Jr.

Millstone Unit No. 2 Nuclear Mr. P. M. Richardson Recovery Officer Nuclear Unit Director Northeast Utilities Service Company Millstone Nuclear Power Stetion, P. O. Box 128 Unit No. 2 Waterford, CT 06385 Northeast Utilities Service Company P. O. Box 128 Waterford, CT 06385

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Northeast Utilities Service Company Millstone Nuclear Power Station Units 1, 2, and 3 cc:

Mr. M. H. Brothers Mr. P. D. Hinnenkamp Nuclear Unit Director Director, Unit Operations Millstone Nuclear Power Station, Northeast Utilities Service Company Unit No. 3 P. O. Box 128 Northeast Nuclear Energy Company Waterford, CT 06385 P. O. Box 128 Waterford, CT 06385 Mr. J. P. McElwain Millstone Unit No. 1 Nuclear Burlington Electric Department Recovery Officer c/o Robert E. Fletcher, Esq. Northeast Utilities Service Company 271 South Union Street P. O. Box 128 Burlington, VT 05402 Waterford, CT 06385 Mr. M. R. Scully, Executive Director Mr. T. C. Feigenbaum Connecticut Municipal Electric Executive Vice President and Energy Cooperative Chief Nuclear Officer 30 Stott Avenue Northeast Utilities Service Company Norwich, CT 06360 P. O. Box 128 Waterford, CT 06385 Mr. William D. Meinert Nuclear Engineer Deborah Katz, President Massachusetts Municipal Wholesale Citizens Awareness Network Electric Company P.O. Box 83 P.O. Box 426 Shelburne Falls, MA 03170 Ludlow, MA 01056 Senior Resident inspector Ernest C. Hadley, Esquire Millstone Nuclear Power Station 1040 B Main Street c/o U.S. Nuclear Regulatory Commission P.O. Box 549 P.O. Box 513 West Wareham, MA 02576 Niantic, CT 06357 Joseph R. Egan, Esq.

Egan & Associates, P.C.

2300 N Street, NW Washington, D.C. 20037 Mr. J. K. Thayer Recovery Officer, Nuclear Engineering and Support Northeast Utilities Service Company P. O. Box 128 Waterfod, CT 06385