ML20148C720

Forwards Slides Used During Presentation,Adjusted to Reflect Discussion Points & Example Used

ML20148C720
Person / Time
Site:	Millstone
Issue date:	05/21/1997
From:	Beck J AFFILIATION NOT ASSIGNED
To:	Goebel D CONNECTICUT, STATE OF
References
ITPOP-97-0006, ITPOP-97-6, NUDOCS 9705280443
Download: ML20148C720 (8)

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3 3 ^h3 Little Harbor Consultants, Inc.

Millstone-ITPOP Project Office P.O. Box 0630 Niantic, Connecticut 06357-0630 Telephone 860-447-1791, ett 5966 Fax 860-444-5758 May 21,1997 ITPOP 97-0006 David M. Goebel Vice President- Nuclear Oversight Northeast Utilities Service Company P.O. Box 128 Waterford, CT 06385-0128

SUBJECT:

May 13,1997 Little Harbor Meeting Little Harbor Consultants, Inc. (LHC) presented its initial findings and recommendations to Northeast Nuclear Energy Company (NNECo) and the Nuclear Regulatory Commission (NRC) at a meeting on May 13,1997. The meeting was held in the Millstone simulator building and was open for observation by the public. This letter forwards the slides used during the presentation, adjusted to reflect the discussion points and examples used.

Discussions during the above mentioned meeting, plue, comments made during the May 13,1997 NNECo meeting with the public, indicated that some of our recommendations may have not been i fully understood by NNECo. The following is provided as amplification to clarify those discussions:

1) LHC has concluded that the NRC's Order of October 24,1996 required NNECo to prepare a comprehensive plan to address and correct the safety culture at Millstone. LHC evaluated the Comprehensive Plan developed by NNECo and determined that it is too narrowly focused on the Employee Concerns Program. It does not address adequately the breadth of programs and processes necessary to correct the safety culture at Millstone. LHC therefore concluded that the Comprehensive Plan does not fully comply with the requirements of the NRC order.

LHC believes that the plan, as required by the NRC order, is necessary in order to:

a) Provide a mechanism by which management can assure that all necessary actions are i identified, responsibility for completion has been assigned, and appropriate completion g j  ;

l dates are established.

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b) Provide a tool for management to monitor, track and evaluate implementation. I'D l

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L David M. Goebel ITPOP 97-0006, Page 2

-. c) Provide a communication tool to inform stakeholders (NRC, employees, and the interested public) of plans and progress.

2) LHC recommended that NNECo expand the requirement for formal and periodic self-assessments of each organizational unit. LHC recognizes that there are many efforts underway to correct problems at Millstone. While it is necessary to measure the effectiveness ofimplementing these programs, it is equally important to have a mechanism to ensure that once fixed, the problems stay fixed. A critical self-assessment program is necessary to fulfill this need.

3) LHC made three recommendations based on our evaluation of the Employee Surveys conducted in June and October 1996. These recommendations addressed a) survey content, b) administration of the survey and c) analysis and utilization of survey results, Discussion during the May 13,1997 meetings focused primarily on the issue of survey content. The issues of administration and utilization are as important and should not be overlooked by NNECo.

Following the May 13,1997 meeting, LHC had the opportunity to obtain additionalinformation from the survey developer. This discussion validated our conclusions that the survey was not constructed to measure the Millstone nuclear safety culture.

Very truly yours, i

John W. Beck President, LHC Team Leader,ITPOP Attachments: Revised May 13,1997 Presentation Slides cc: Distribution l

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, i Distribution:

P. Loftus, NNECo Charles Brinkman, Manager Bldg 475/5 - Washington Nuclear Operations

'ABB Combustion Engmeering Nuclear Power .

K. M. McBrien, NNECo 12300 Twinbrook Pkwy, Suite 330  ;

Bldg 475/5 Rockville,MD 20852 W. J. Temple, NNECo Mr. John Buckingham Bldg 475/2 Department of Public Utility Control Electric Unit U.S. Nuclear Regulatory Commission 10 Liberty Square Atta: Document Control Desk New Britain, CT 06051 Washington, DC 20555 Citizens Regulatory Commission i U.S. Nuclear Regulatory Commission A'lTN: Ms. Susan Perry Luxton  !

Attn. W.D. Travers 180 Great Neck Road Mail Stop: 014D4 Waterford, CT 06385 Washington, DC 20555-0001 Deborah Katz, President i U.S. Nuclear Regulatory Commission Citizens Awareness Network Attn: P.F. McKee P.O. Box 83 Mail Stop: 014D4 Shelburne Falls, MA 03170 -,

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Washington, DC 20555-iM01 The Honorable Terry Concannon U.S. Nuclear Regulatory Commission Nuclear Energy Advisory Council l Ixgislative Office Building Attn: H.N. Pastis l H:rtford, CT 06106 Mail Stop: 014D4 Washington, DC 20555-0001 Mr. Evan W. Woollacott U.S. Nuclear Regulatory Commission Co-Chair Attn: W.D. Lanning Nuclear Er.ergy Advisory Council l

Mail Stop: 014D4 172 Terrv's Plain Road l

Washington, DC 20555-0001 Simsbury, CT 06070

! KevinT. A. McCarthy, Director Ernest C. Hadley, Esquire Monitoring and Radiation Division 1040 B Main Street i Department of Environmental Protection P.O. Box 549 )

l West Wareham, MA 02576 l l 79 Elm Street 1

! Hartford, CT 06106-5127 i

Allan Johanson, Assistant Director Office of Policy and Management Policy Development and Planning Division J

450 Capitol Avenue-MS 52ERN P.O. Box 341441 Hartford, CT 06134-1441 First Selectmen

Town of Waterford i Hall of Records 200 Boston Post Road Waterford, CT 06385

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r l l Expectations for the Comprehensive ITPOP REVIEW OF.

• Address Each Requirement Esteb41shed la the NNECo m24N NRC order a'*** Sa' 'r '

COMPREHENSIVE PLAN - " a '' ==d Raised by Employees .

- Ensure That Employees Who Raise safety Issues Are Not Millstone subject se meien

- Address the Reet Causes of Past Performance Failures May 13,1997

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• Establish Clear Path to Meeting Goal of Achieving 1:30 PM

= a Safety-Ccascicus Work Environment

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' Expectations for CP, Cont'd Process for Reviewing CP' l

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• Identify Action Items That,IfImplemented,Will

• Reviewed 10/24N NRC Order to Identify Achieve the Stated Objective for the CP: a Safety- Requirements for the CP ,

• Studied Millstone Employee Concerns Assessment l Conscious Work Environment '

Team Report (IM), FCAT Report (7N) and

• Establish Completion Criteria for Each Action Item MIRC Report (9N) to Understand Problems and l

. Identify Methodology for Measuring Progress . Causes ,

1 Toward Achievlag a Safety-Conscious Work

• Interviewed Eleven ECTF Members Environment

• Reviewed CP and Action Plans 1

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Conclusion 2: Creation of an Conclusion 1: CP Provides an Adequate Independent Concerns Oversight Panel Approach for Upgrading Millstone ECP Has the Potential to Accelerate Progress l Towards Achieving the CP Goal l

• Requires New ECP Policy Statement and Developesent of Program Manual

• Prosides for Oversight of ECP and Millstone j

• Calls for Management to Demonstrate Support for Station Environment with Feedback to Senior Program

• Requires lusproved Qualifications and Training -

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• Calls for Review of Workplace Environment for for ECP Staff and Line Supervision Personnel

" Chilling" Effect and Problem "Hotspots"

• Requires a Policy Which Addresses Timely

• Calls for Identifying If and Where Workplace 1 Response to Concerns and Feedback to Concerned Intervention is Required

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l Conclusion 3: CP Does Not Address Conclusion 3: CP Does Not Address

1. - Full Scope of the 10/24/96 NRC Order

, Full Scope of the 10/24/96 NRC Order l

Example:

l e Places Primary Emphasis on Expanding and MIRG Report Roof Cause 7.1

! Strengthening the ECP i "De team concluded that ineffective problem reseletion i

e Does Not Place Proper Ensphasis on Restoring Line processes have contributed to continued employee concerns at l Managessent's Accountability For Establishing a Minstone, forcing reliance en the Nuclear Safety Concerns l Safety Conscious Work Eastromment Program (NsCP) process te resolve concerns that should have I been corrected by rentine process."

e Actions Identified to Address Root Causes From Past Investigations Appear to Be leadequate or Too As MP bas stated se CP does not address &is Root Cause.

Narrow in Scope The CP focus is the Dnployee Concerns Program and does not l address the routme process adequately.

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~ Conclusion 3: CP Does Not Address l Full Scope of the 10/24/96 NRC Order Conclusion 4: CP Does Not Sufficiently Address the Normal Programs for Example:

MIRG Renort Root Cause 7.5 Problem Identification and Resolution:

" Communications appeared to be a continuing problem area,

• No Requirement for Critical Review of Norinal characterized by peer inter. departmental interaction, general Corrective Action Programs and Their failure to accourage geestioning attitudes, and a tendency to Impleasentation manage by unemorandunL ineffective implementation of the

• Places lasufficient Emphasis on Effective Da of

? neept of teamwerk aise appeared to have contributed to g p

.t yleyee concerns at Millstone.

• Does Not Use Site Oversiglit Organization to ,

The action items identified in the CP to address the issues of per Provide Feedback on Plan Effectiveness Regarding communications and lack of teamwork are not sufficient to correct Problem Identification and Resolution these problems at Mdistone.

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Conclusion 5: The CP Does Not Conclusion 5: The CP Does Not Clearly Identify Criteria for Success or Clearly identify Criteria for Success or eamement chniques.

Measurement Techniques.

Example:

• Action item Elements Are Presented coed:

Essentially As" Punch list" items Action 1-2 Feedback to Concerned Individuals

• Success Criteria Are Not Established for Many Action Item Elements Thus Providing No Basis gym for Judging Implen.entation Success Action 7-2

• Cooperate in investigations as appropriate"

• Measurement Techniques for Evaluating Action 2-s llR communications Intplementation Agalmst Success Criteria Are There are n.3 criteria fu success Not Adequately Specified There is 3g mention t f menhoring errectiveness um a- n c  % nw s .w n.,

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Recommendations ~' Recommendations, Cont'd l Revise the CP to Address the Fellomlag: Revise the CP to Address the Following:

- Ensure All Reet Causes Are Effectively Addressed Se . Require a Crldcal Review of Current Cerrective That Resultant Action Plans. Combined With Action Programs haanadement's Directlen, WW Correct Each Root Cause - Espand the Requirement for Formal. Per6edic Self-  ;

- Place the Focus en une Management's Role and Assessments by Each Organizational Element '

Accountabihtiesin Achwylag the Desired $sfety.

Conscious Environment

- Develop success Criteria and Measurement Techniques mm s <- n nw  % ,, ,

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! OBJECTIVES l MILLSTONE EMPLOYEE CULTURE SURVEY . What has NNECo donc m. the past?

l HISTORY . What is the quality of that effort? ,

• Should we rely on the data?  !

l Millstone . Have past surveys yielded usefulinformation? I Msy 13,1997 l 1:30 PM RECOMMENDATION CONCLUSIONS Before Conducting the Next Survey Consider the I

• The surveys were not constructed to address

• Objectives are clearly defined.

I nuclear safety culture.

surwy owvn a communicaud. j The survey process may have adversely " '" "*i'**d '"d impacted results. * )M *"# *""*"' ' *"""' ""'I '

• Survey results were not factored into plant

• 611anas of culture are included.

• t.ine managers are appropriately prepared and involved.

improvement processes.

• Management is committed to translate and implement the resuks into actions.

I SURVEYS WERE NOT CONSTRUCTED SURVEY PROCESS MAY HAVE i TO ADDRESS NUCLEAR SAFETY IMPACTED RESULTS CULTURE y,,,,,,,.

home tsumples:

• There has been httle or no pre-survey communication.

• Did not mvolve hoe managers in the survey process. Ex:

D'd n I train them how to analyze, communicate results.

• Limited NNECo involvement in the design and

• The administration process itself bad minimal built-in selection of the questions.

controls over who filled out the survey, when, and how a he survey questions, themselves do not address ,,ny i,,,,.

attributes of nuclear safety directly.

• Never conducted follow 4n interviews, l

• Did not include employee concerns portion in a craphical. raw data detail from October survey siven to analysis. line management to distribute without any traming in how j i

to analyze and communicate it. l l

• Re questions address processes and programs rather

• 8"Y' **'e c nducted t o ci se t gether than relationships and morale.

• There has been no follow-on communication.

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SURVEY RESULTS WERE NOT FACTORED INTO PLANT IMPROVEMENT PROCESS Esemples

• No management commitment to etYectively communicate, act on the results.

• No effective analysis completed on either survey.

• Management did not implement any action plan related to survey findings after the June and October Surveys.

• Some employees appear to be skeptical since there was no activity.

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• Management chose not to communicate or analyze the resuhi l of the October 1996 Surwy.

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