ML20149E041
| ML20149E041 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/15/1997 |
| From: | Mckee P NRC (Affiliation Not Assigned) |
| To: | Beck J AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9707180077 | |
| Download: ML20149E041 (10) | |
Text
__e
___.4 a-Mr. John W. Beck, President July 15, 1997 Little Harbor Consultants, Inc.
^ Millstone - ITPOP Project Office P. O. Box 0630 Niantic, Connecticut 06357-0630
Dear Mr. Beck:
The NRC's Order to Northeast Nuclear Energy Company.(NNECO) dated October 24, 1996, required NRC approval of the oversight plan to be used by the a
independent, third-party organization to oversee implementation of NNECO's comprehensive plan and its employee safety concerns program (ESCP).
This letter approves the oversight plan (Plan), which Little Harbor Consultants, Inc. (LHC), as the independent, third-party oversight program (ITPOP) organization, will use to oversee the implementation of NNEC0's ESCP.
The staff's review of the proposed ITP0P oversight plan is enclosed. We note that the Plan describes some activities that extend beyond those required by the October 24, 1996, Order. While our review and approval of the Plan does not specifically address these areas, we have no objection to their being performed.
In its April 7, 1997, approval of LHC as the ITPOP organization, the NRC stated that after receiving the ITP0P oversight plan, the NRC will conduct additional resume reviews, and possibly interviews, to confirm that individuals are appropriately assigned tasks in their areas of expertise. On June 4, 12, 17, and June 30 members of the NRC staff interviewed the ITPOP team members.
On the basis of the information provided in your submittals of May 2 and June 13, 1997, and our interviews, the staff has concluded that the Plan has the scope and depth necessary to discuss and provide appropriate oversight for judging the effectiveness of NNECO's ESCP in resolving and disposing employee safety concerns presently and in the future. On May 21, 1997, the NRC held a meeting with members of the public to receive comments on the proposed Plan.
There were no comments recommending specific changes to the Plan.
Please call me at (301) 415-2240 if you need any additional information or clarification of the enclosure.
Sincerely, Origina1 signed by:
.Y(h-Phi 1Tip F. McKee Deputy Director for Licensing Special Projects Office Office of Nuclear Reactor Regulation
Enclosure:
Staff Review of the Proposed ITP0P Oversight Plan l
g DISTRIBUTION:
Ducket File PMcKee PUBLIC LBerry SP0-L Reading HPastis qk lfl[hl[ll[hljll))lllllllll kp3 SP0 Reading OGC WTravers ACRS Ju cr, RI DOCUMENT NAME: G:
- r...i
...,y. ihi.oocum.\\.PASTIS\\LHCPLAN. APP._ioaic.i. i. in. oou c - copy witnout.it.ch,9,p 0 ncio.u,.
. copy with.it.cho.ot/.ncio.u. u = No copy 0FFICE SP0-L:PM l6 uSP0-L:LAt0 C/
SP@j. : )D l
l l
ll NAME HPastis G((f LBerry k6' PMdKee DATE 07/f)/97 'l 07/10/97
\\
07/)\\ /97 07/ /97 07/ /97 9707180077 970715 PDR ADOCK 05000245 P
s'DR
pwouq
[
k p
UNITED STATES s
j NUCLEAR REGULATORY COMMISSION g
2 WASHINGTON, D.C. 20666-0001 8
%,..... p July 14, 1997 j
I Mr. John W. Beck, President 1
Little Harbor Consultants, Inc.
Millstone - ITPOP Project Office i
P. O. Box 0630 1
Niantic, Connecticut 05357-0630 l
Dear Mr. Beck:
The NRC's Order to Northeast Nuclear Energy Company (NNECO) dated October 24, 1996, required NRC approval of the oversight plan to be used by the independent, third-party organization to oversee implementation of NNECO's l
comprehensive plan and its employee safety concerns program (ESCP).
4 This letter approves the oversight plan (Plan), which Little Harbor i
Consultants, Inc. (LHC), as the independent, third-party oversight program (ITPOP) organization, will use to oversee the implementation of NNECO's ESCP.
The staff's review of the proposed ITPOP oversight plan is enclosed.
We note that the Plan describes some activities that extend beyond those required by the October 24, 1996, Order. While our review and approval of the Plan does i
not specifically address these areas, we have no objection to their being j
performed.
i
_In its April 7,1997, approval of LHC as the ITPOP organization, the NRC i'
stated that after receiving the ITPOP oversight plan, the NRC will conduct additional resume reviews, and possibly interviews, to confirm that individuals are appropriately assigned tasks in their areas of expertise. On June 4, 12, 17, and June 30 members of the NRC staff interviewed the ITPOP team members.
On the basis of the information provided in your submittals of May 2 and June 13, 1997, and our interviews, the staff has concluded that the Plan has the scope and depth necessary to provide appropr' ate oversight for judging the effectiveness of NNECO's ESCP in resolving and disposing employee safety concerns presently and in the future. On May 21, 1997, the NRC held a meeting with members of the public to discuss and receive comments on the proposed Plan. There were no comments recommending specific changes to the Plan.
Please call me at (301) 415-2240 if you need any additional information or clarification of the enclosure.
Sincerel Phillip F.
cKee Deputy Director for Licensing Special Projects Office Office of Nuclear Reactor Regulation
Enclosure:
Staff Review of the Proposed ITPOP Oversight Plan
NgrtheastNuclearEnergyCompany 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 Drojects 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 Nuclear Energy Company Protection P.O. Box 128 79 Elm Street Waterford, CT 06385 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 Nuclear Energy Company i
P. O. Box 128 Regional Administrator, Region I Waterford, CT 06385 U.S. Nuclear Regulatory Commission 475 Allendale Road Mr. M. L. Bowling, Jr.
King of Prussia, PA 19406 Recovery Officer - Millstone Unit 2 Northeast Nuclear Energy Company First Selectmen P. O. Box 128 Town of Waterford Waterford, CT 06385 Hall of Records 200 Boston Post Road Senior Resident Inspector
-Waterford, CT 06385 Millstone Nuclear Power Station c/o U.S. Nuclear Regulatory Commission Mr. J. P. McElwain P. O. Box 513 Recovery Officer - Millstone Unit 1 Niantic, CT 06357 Northeast Nuclear Energy Company P. O. Box 128 Mr. J. K. Thayer Waterford, CT 06385 Recovery Officer - Nuclear Engineering and Support Deborah Katz, President Northeast Nuclear Energy Company Citizens Awareness Network P. O. Box 128 P. O. Box 83 Waterford, CT 06385 Shelburne Falls, MA 03170
j
~
Northeast Nuclear Energy Company Millstone Nuclear Power Station Units 1, 2, and 3 l
cc:
L l
Mr. M. H. Brothers Little Harbor Consultats, Inc.
l Vice President - Millstone Unit 3 Millstone - ITP0P Project Office Northeast Nuclear Energy Company P. O. Box 0630 P. O. Box 128 Niantic, Connecticut 06375-0630 Waterford, CT 06385 Mr. Evan W. Woollacott i
Mr. M. R. Scully, Executive Director Co-Chair l
Connecticut Municipal Electric Nuclear Energy Advisory Council Energy Cooperative 128 Terry's Plain Road 30 Stott Avenue Simsbury, Connecticut 06070 l
Norwich, CT 06360 Mr. Daniel L. Curry Mr. William D. Meinert Project Director Nuclear Engineer Parsons Power Group Inc.
Massachusetts Municipal Wholesale 2675 Morgantown Road Electric Company Reading, Pennsylvania 19607 P. O. Box 426 Ludlow, MA 01056 Mr. Don Schopfer Verification Team Manager Ernest C. Hadley, Esq.
Sargent & Lundy 1040 B Main Street 55 E. Monroe Street P. O. Box 549 Chicago, Ilinois 60603 West Wareham, MA 02576 Mr. Neil S. Carns Joseph R.-Egan, Esq.
Senior Vice President Egan & Associates, P.C.
and Chief Nuclear Officer 2300 N Street, NW Northeast Nuclear Energy Company Washington, D.C. 20037 c/o Ms. Patricia A. Loftus Director - Nuclear Licensing Services Citizens Regulatory Commission P.O. Box 128-ATTN: Ms. Susan Perry Luxton Waterford, CT 06305 180 Great Neck Road Waterford, Connecticut 06385 The Honorable Terry Concannon Co-Chair Nuclear Energy Advisory Council Room 4035 Legislative Office Building Capitol Avenue Hartford, Connecticut 06106
i i
t j'-
STAFF REVIEW 0F PROPOSED ITPOP OVERSIGHT PLAN Introduction On October 24, 1996, the NRC issued an Order to Northeast Nuclear Energy Company (NNEC0), the licensee for Millstone, requiring
- 1. a comprehensive plan for resolving the Millstone Station employees' safety
- concerns, l
- 2. an Independent, Third-Party Oversight Program (ITP0P) organization to i
oversee NNEC0's. implementation of the Employee Safety Concerns Program
.(ESCP),and
- 3. an oversight plan (Plan) to be used by the ITP0P organization to oversee implementation of NNEC0's comprehensive plan and its ESCP.
The Order states that the NRC staff will approve the Plan.
l The purpose of the ITP0P, as stated in the Order, is to confirm that Mi11 stone's ESCP resolves and disposes of employee safety concerns.
The ITP0P evaluation required by the NRC is expected to provide independent verification, beyond the licensee's quality assurance and management oversight, that NNECO has identified and satisfactorily resolved employee safety concerns and has established programs, processes, and procedures for effective ESCP management in the future.
Backaround On December 23, 1996, NNEC0 submitted information on the proposed selection of Little Harbor Consultants, Inc. (LHC), as the contractor or organization for the Millstone ITPOP.
The submittal identified the principal individuals involved in each major aspect of the ITP0P and their resumes. The submittal also included the proposed ITPOP team structure.
On April 7,1997, the NRC approved LHC as the ITPOP organization and stated that after receiving the ITPOP oversight plan, it will conduct additional resume reviews, and possibly interviews,.to confirm that individuals are appropriately assigned tasks in their areas of expertise.
On May 2, 1997, the ITPOP team submitted its oversight plan. On May 15, 1997, the NRC staff published in the Federal Reaister (62 FR 26825) the availability of the Plan and that it will hold a public meeting to discuss and receive comments on the Plan.
In the evening of May 21, 1997, the NRC staff held a public meeting in the Waterford Town Hall to receive comments from the residents of Waterford, Connecticut, on the ITPOP oversight plan. There were no comments recommending specific changes to the Plan.
On June 3, 1997, LHC discussed at a meeting with the NRC changes to the ITPOP oversight plan to address comments from NRC staff.
i
a s
a
<+-
e h,
s a
J 4.
.--m.
-m
\\. l On June 4, 1997, members of the NRC staff interviewed most of the ITP0P team members. On June 12, 17, and 30, 1997, the NRC staff held telephone interviews with the ITP0P team members who were~ not available previously.
)
On June 13, 1997, the ITP0P team submitted a revised oversight plan addressing NRC and making editorial changes. The staff raised concerns as follows:
l Discussion 4
The Order states that.the NRC staff must approve the ITPOP oversight plan.
The staff conducted a review of the information submitted by LHC on the proposed Plan to ensure that the Plan covers the requirements of the Order and has the scope and depth necessary to provide appropriate oversight for judging the effectiveness of NNEC0's ESCP in resolving and disposing employee safety concerns presently and in the future.
LHC Oraanization LHC is a sub-chapter S corporation formed in 1992 to serve as the corporate vehicle for the consulting practice of its President, John W. Beck.
LHC has 1
assembled individuals to perform the ITP0P. Many of the ITP0P members have worked together at nuclear facilities before on activities associated with licensee programs for addressing employee concerns.
The ITP0P team currently has 12 members covering the following areas of expertise: management, operations, engineering, maintenance, ESCP, safety analysis, regulatory, legal, and training.
]
Puroose of the Plan The purpose of the Plan is to describe the process by which the ITP0P team will monitor and evaluate NNECO's efforts to improve the safety culture at Millstone.
The ITP0P team will evaluate the ESCP through structured interviews with certain employee and contractors, employee surveys, and observations of day-to-day activities.
The evaluations will focus on NNEC0's efforts to (1) correct and prevent repetition of past failures in its treatment of employee safety concerns, (2) create an environment in which employees and contractors are encouraged and feel free to raise concerns, (3) review and resolve safety concerns in a timely manner, and (4) conduct self-assessments and changes to the ESCP to maintain the effectiveness of the program and NNEC0's maintaining a safety-conscious work environment in the future.
Assessina Millstone's Safety Culture The ITPOP team will evaluate whether NNECO is establishing a safety-conscious work environment where employees are encouraged and feel free, without the fear of retaliation, to raise concerns to their management, confident that the safety concerns will be addressed and resolved in a timely manner.
The Plan
_3-acknowledges that while it is difficult to define organizational cultures with precision, it is possible to identify general attributes that, when evaluated collectively, will describe the environment that exists within an organization. The ITPOP team has developed a set of attributes that reasonably describe an " ideal" safety culture and will use those attributes to measure NNEC0's openness and receptivity to the timely identification and resolution of potential safety issues and safety concerns identified by employees.
The ITP0P team members will document their observations and distribute their reports to other team members for subsequent review and analysis to determine the extent to which the observed activities or behavior exhibited by employees or contractors provide insight into the prevailing safety culture at Millstone.
Results of the observations, including the conclusions reached as a result of analysis by the ITPOP team, will be provided to interested parties in each of its quarterly reports. Also, the ITPOP team will use its findings and conclusions to direct its future oversight activities.
ITP0P Proarammatic Evaluations The ITPOP team will verify that NNEC0 has properly designed and implemented those programs for correcting existing problems at Millstone and preventing recurrence of these problems. The ITP0P team plans to review the following NNEC0 programs:
- 1. The Comprehensive Plan for ESCP,
- 2. The ESCP,
- 3. The various corrective action programs that are intended to provide for the day-to-day identification of problems and to ensure the adequate resolution of these problems,
- 4. The root cause evaluation program, and
- 5. Various programs used at Millstone to conduct technical evaluations that are required to resolve problems.
Communications and Reoortina 4
The NRC Order primarily requires the ITPOP team to communicate with the NRC and NNECO. However, on its own initiative and outside the scope of the Order, the ITP0P team plans to communicate with various community groups because of the high degree of interest concerning events at Millstone.
The ITPOP team plans to develop and maintain procedures for the following areas:
- 1. Administration and scheduling,
- 2. Requests for information,
- 3. Formal meetings and written reports,
- 4. Characterization of Observations, Conclusions, and Recommendations,
- 5. Press or media communications, and
- 6. Communications related to NRC oversight of LHC.
Membershio The Plan describes the responsibilities of the various ITPOP team members.
The ITPOP team members will maintain their independence from NNECO and carry out their responsibilities in a professional and ethical manner. The ITPOP team leader will notify the NRC and NNECO of any additional or replacement team members. The ITPOP team leader will replace or select additional team members based on the same considerations and criteria used for the selection l
of the original team members.
Security The Plan states techniques for maintaining effective security over information in the ITPOP team's possession. One aspect of maintaining team independence l
and effectiveness is assuring that information obtained by the ITP0P team is l
adequately secured, protected, and communicated only to those individuals with i
l a need to know.
Sel f-Assessment The Plan states that the ITPOP team will implement a system of checks and balances; primarily in the form of a self-assessment. The self-assessment process will follow well-established principles and performed at two levels.
The first level of self-assessment will be focused on the ITPOP team's performance regarding their ability to meet the specific objectives contained in the Plan and the NRC Order. The second level of self-assessment will be conducted to verify that the ITPOP team members are maintaining the appropriate level of independence and objectivity.
Alleaations Brouaht to the ITPOP Team The Plan specifies actions for the ITPOP to take in the event an individual brings forth a nuclear safety, harassment, intimidation, or discrimination issue directly to the ITPOP team.
Staff Evaluation To complete this evaluation, the NRC staff performed the following activities:
1.
Determined whether the Plan addressed all the requirements of the Order and contained essential areas for overseeing NNECO's ESCP.
2.
Determined whether the Plan has provisions for the ITPOP team members to maintain their independence from NNECO and to carry out their responsibilities in a professional and ethical manner.
3.
Determined whether the Plan has provisions to communicate its findings and recommendations in an open environment.
I V
n m
T "d
W y
i*
i i'*
l p !
i
- 4. Interviewed each individual team member of LHC. The staff conducted additional resume reviews and interviews concurrent with its review of the i
Plan and organizational. structure to assure that individuals are i
appropriately assigned to tasks within their expertise. The.NRC staff wanted to evaluate the adequacy of the team's expertise and experience, with an understanding of the specific tasks they will perform in the j
oversight review.
i The Order requires the Plan to include methods for. examination of actions taken by NNECO to create an environment in which employees of both NNECO and onsite contractors are encouraged to raise concerns and the timeliness and thoroughness with which such concerns are reviewed and resolved, including how
!~
employees are informed of results. The Order further requires that the ITP0P i
team monitor and oversee NNECO's efforts to correct and prevent repetition of i-its past failures in its treatment of employee concerns and of those employees i
who raised such concerns. The staff has reviewed the Plan and finds that it includes ' approaches acceptable for observation and monitoring of NNECO's l
activities, performance of technical and audit reviews, investigation of concerns, and assessment of changes in NNECO's treatment of employee concerns as compared to past practices.
The Plan also includes acceptable methods for providing feedback to NNECO regarding ITPOP findings and recommendations i
concerning NNECO's handling of specific concerns as well as NNECO's programs and processes for handling concerns.
The Order requires that the ITPOP organization M osen to oversee the conduct of NNECO's comprehensive plan be independent of NNECO, such that none of its j
members has had any direct, previous involvement with the activities at the Millstone Sta+. ion that the organization will be overseeing. The staff's review and approval of LHC as the independent, third-party oversight organization :ncluded an assessment.of the independence of individual LHC team members. One bases for establishing independence of each individual was the execution by team members of a certification that addresses organizational, experience, and financial independence from Northeast Utilities and NNECO.
If a team member needs to be replaced or aspects of the tasks that the team must perform require that additional or different expertise be available, replacement or additional members will be selected band on the considerations and criteria that were used in the selection of the original team members.
The ITP0P team leader will notify the NRC and NNECO of any additional or replacement team members.
Further, there are provisions in the Plan, including self-assessment, that provide a measure of continued independence of team members. The staff finds acceptable the Plan's provisions for establishing the independence of new team members as well as provisions for assuring that current team members carry out their responsibilities in a professional and ethical manner.
The NRC assessed the Plan's provisions for communicating its findings and recommendations to the NRC and NNECO in an open environment. The Order states that the ITPOP team is to report concurrently to the NRC and NNECO, on at least a quarterly basis, the results of its oversight activities, including all findings and recommendations. Section 5 of the Plan discusses the methods
l*.
i,-
1 of communications and reporting of the ITPOP team.
In Revision 0 of the Plan, the staff commented that the Plan was not sufficiently detailed in describing 4
the frequent administrative communications needed with NNECO and that the i
characterization of ITPOP findings needed to be better defined.
Revision 1 of
}
the Plan satisfactorily addressed these comments. The Plan provides that the ITPOP. team will communicate directly with NNEC0 regarding scheduling and i
requesting information.
Reports of activities, findings, and recommendations will be presented to the NRC and NNECO at periodic pre-announced meetings open j
to the public.
Further, the ITPOP team will provide a detailed written report i
to NNECO and the NRC at least quarterly. The NRC staff finds that these provisions for communication and reporting acceptably address the requirements of the Order.
i The Plan describes activities with respect to communication with parties, including members of the public, that extend beyond requirements of the Order.
The staff's review and approval of the Plan does not address these areas.
1 4
The Order states that the qualifications of the ITPOP team must include the expertise necessary to audit technical reviews of employee concerns, monitor j
corrective actions, recognize technical weaknesses in approaches to concerns taken by NNEC0, audit and determine the adequacy of NNECO's investigations into harassment, intimidation, and discrimination complaints, and conduct 1
employee surveys to determine the views of NNECO's employees on the success and completeness of these activities.
l To evaluate the adequacy of the team's expertise and experience, with an understanding of the specific tasks they will perform in the oversight review, i
the NRC staff interviewed each individual team member of LHC.
Interviews were conducted on two occasions.
In approving LHC as the independent third-party organization, the NRC staff interviewed the LHC team members to verify the qualifications of individuals and overall technical expertise of the proposed i
team. After approval of LHC as the third-party oversight organization and t
following receipt of the Plan, the NRC staff conducted a second-round of interviews to confirm that-individuals are appropriately assigned tasks in i
their~ areas of expertise and that review areas required by the Order were i
appropriately covered.
Section 6.0 of the Plan discusses the responsibilities 1
that will be assigned to the various ITPOP team members.
Based on the reviews and interviews, the NRC staff determined that the Plan acceptably addresses the responsibilities of each team member in relation to the member's
)
expertise.
I Conclusion i
Based on the various submittals from NNEC0, the interviews, the telephone interviews, and the public meeting with the residents of Waterford, t
i Connecticut, the NRC staff concludes that the Plan is acceptable for the ITP0P team to use in overseeing the implementation of the ESCP at Millstone.
4
. _ _ _ _.