ML20151K880
| ML20151K880 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/01/1997 |
| From: | Beck J AFFILIATION NOT ASSIGNED |
| To: | Goebel D NORTHEAST UTILITIES SERVICE CO. |
| References | |
| ITPOP-97-0023, ITPOP-97-23, NUDOCS 9708060179 | |
| Download: ML20151K880 (10) | |
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Little Harbor Consultants, Inc.
Millstone - ITPOP Project Omce P.O. Box 0630 Niantic, Connecticut 06357-0630 Telephone 860-447-1791, ext $966 Fax 860-444-5758,
August 1,1997 i
ITPOP 97-0023 l
David M. Goebel Vice President - Nuclear Oversight Northeast Utilities Service Company i
P.O. Box 128 Waterford, CT 06385-0128
SUBJECT:
Information on ECP Files During the July 22,1997 presentation to the NRC and NNECo, LHC identified deficiencies with ECP files that were reviewed during the evaluation of the implementation of the ECP.
l The following information is provided as examples of discrepancies that led to our conclusions presented on July 22,1997. In many files, the discrepancies precluded a comprehensive review of the files. As a result, additional problems may be identified once these discrepancies have been resolved.
1.
Evaluation criteria used by LHC for the review of ECP files.
i 2.
List of ECP files that LHC believes were inappropriately classified as either resolved or closed.
3.
L.ist of significant deficiencies noted during LHC review of the ECP files noted in item 2 above.
4.
List of generic deficiencies noted during LHC's review of the ECP files.
l Following your review of this information, we will be available to answer any questions or provide clarification as necessarj.
Very truly yours, I
k S W ~,8HC Jh c,D l ') ;
John W. Mck, President
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9708060179 970001 Team Leader
- ITPOP PDR ADOCK 05000245 p
PDR Attachments (4)
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David M Goebei Page 2, ITPOP 9'I 0023 Distribution:
P. Loftus, NNECo First Selectmen Bldg 475/5 Town of Waterford Hall of Records K. M. McBrien, NNECo 200 Boston Post Road Bldg 475/5 Waterford, CT 06385 7
W. J, Temple, NNECo Charles Brinkman, Manager
- Bldg 475/2 Washington Nuclear Operations ABB Combustion Engineering Nuclear Power U.S. Nuclear Regulatory Commission 12300 Twinbrook Pkwy, Suite 330 Attn: Document Control Desk Rockville, MD 20852 Washington, DC 20555 Mr. John Buckingham U.S. Nuclear Regulatory Commission Department of Public Utility Control Atta: W.D. Travers Electric Unit Mail Stop: 014D4 10 Liberty Square Washington, DC 20555-0001 New Britain, CT 06051 U.S. Nuclear Regulatory Commission Citizens Regulatory Commission Attn: P.F. McKee ATTN: Ms. Susan Perry Luxton Mail Stop: 014D4 180 Great Neck Road Washington. DC 20555-0001 Waterford, CT 06385 U.S. Nuclear Regulatory Commission Deborah Katz, President Attn: H.N. Pastis Citizens Awareness Network Mail Stop: 014D4 P.O. Box 83 Washington, DC 20555-0001 Shelburne Falls, MA 03170 Mr Wayne D. Lanning The Honorable Terry Concannon Deputy Director ofInspections Nuclear Energy Advisory Council Special Projects Office Legislative Office Building 475 Allendale Road Hartford, CT 06106 King of Prussia, PA 19406-1415 Mr. Evan W. Woollacott Kevin T. A. McCarthy, Director Co-Chair Monitoring and Radiation Division Nuclear Energy Advisory Council Department of Environmental Protection 128 Terry's Plain Road 79 Elm Street Simsbury, CT 06070 Hartford, CT 06106-5127 Ernest C. Hadley, Esquire Allan Johanson, Assistant Director 1040 B Main Street Office of Policy and Management P.O. Box 549 Policy Development and Planning Division West Wareham, MA 02576 450 Capitol Avenue-MS 52ERN P.0, Box 341441 Hartford. CT 061341441
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David M. Goebel ITPOP 97-0023 / Attachment I / Page 1 1.
EVALUATION CRITERIA FOR ECP FILE REVIEW A.
General Criteria For All Files Did the file contain documentation to support the resolution or closure of the ~
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' file?
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Was the issue raised by the concerned individual (Cl) clear and agreed to by the Cl?
Was the issue properly classified? (ie, safety related, etc.)
- Was there a complete chronological log?
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- Was there an investigation report and did it reach a sound conclusion?
- Was the C1's issue clearly addressed?
- If the issue was safety related, was a reportability review made and i
documented by a competent individual and process?
If additional issues (ex: chilling effect, other problems, etc.) were identified during the course of the investigation, were they properly addressed?
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- Did the information in the file clearly support resolution or closure of the file?
If the file referenced CR's, ACR's, investigation reports done by another organization (ie, Human Resources, Internal Audit, etc), etc; were copies of these documents in the file and was it evident that the ECP investigator had reviewed and agreed with them?
- Were corrective actions adequate, implemented, and effective?
- Was a root cause analysis needed, and was it performed and in the file?
B.
Criteria For Files Ooened After Aoril 15.1997 In addition to the above file criteria:
Was the process described in the ECP Manual followed and were all the forms required by the ECP Manual properly completed (including signatures) and in the file?:
- The following items were given special attention:
Intake Process and Documentation Triage Process Investigation Plans Investigation Reports Closure Checklists i
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. Dav:,d M. Goebel ITPOP.97-0023 / Attachment 2 / Page 1 2.
LIST OF ECP FILES THAT LIIC BELIEVES WERE INAPPROPRIATELY l
CLASSlFIED AS EITHER RESOLVED OR CLOSED Files that have a significant enough weakness that the basis for resolution / closure is not reliable without further information.
106 197/198 118 213 126 226 128/129 22 133 223 137 230 142 235 159 236 162 239 168 242 169 243 171 244 186 250 192 l
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9 David M. Goebel ITPOP 97-0023 / Attachment 3 / Page 1
' 3.
LIST OF SIGNIFICANT DEFICIENCIES NOTED DURING LHC REVIEW OF THE FILES NNECO SIIOULD CONSIDER FOR REOPENING File Number Deficiencies Not clear what the " grievance panel" did.
106 Can't determine if the concern was substantiated or not.
Nothing in file to support resolution.
I18 Resolution for part 2 is unclear on basis of the file.
126 Resolution of the second issue is unacceptable.
Concerned individual (Cl) does not agree with closure.
128/129 The files do not contain any evidence of contact with C1 either verbally or in writing to verify the correctness of the issues or any inquiry into why the issue was permitted to languish so long before any review.
Corrective action not adequately explained on face of file.
There is no root cause analysis or reportability documentation determination in the file, although one appears to have been done and is referenced.
H I & D issues not addressed.
No final report in the file.
No letter to the Cl.
Closure does not address: 1) training of SQR's; 2) checking PUP's 133 program; and 3) implementation for adherence to App B VI.
Relies on the NRC required 50.54 (f) review and doesn't address what will be done after the 50.54 (f) contractors leave.
137 File and ECP Database conflict te closure / resolution.
l Harassment issue has not been investigated.
File should not be resolved or clo,ed based on documentation in file.
142 Issues were not adequately investigated.
Doesn't address which came first--concern or poor performance.
Doesn't address serious retaliation issues with currently employed managers.
Ci still being harassed by peers.
159 No HR report in the file and the file does not cover the outcome or nature of the HR investigation.
No evidence of chilling effect evaluation.
David M. Goebel ITPOP 97-0023 / Attachment 3 / Page 2 File Number Deficiencies 162 Investigation performed by Executive staff assistant:
Does not appear to be adequate.
Points out several issues requiring corrective action outside the original issues brought up by the Cl; but there is no evidence that corrective actions were identified or implemented.
ECP database shows concerned resolved but chronologicallog shows the concern not resolved.
Cl not happy.
No final investigation report in the file.
No review of the investigation by ECP to determine adequacy.
168 No basis to support the ECP conclusions that: 1) No coercion took place; 2) No additional action is needed.
Draft report (l) reveals a detailed root cause analysis while the final version (9/5/95) of the study by the managers does not address the root cause. Instead it explains and defends management actions.
No action taken by ECP to deal with the investigation by management.
1 The investigation appears to have missed the point in deternumng 169 whether a misrepresentation was made to the NRC and instead details the apparent activities that were being taken to bring the programs into conformance with representations previously made.
No basis for closure.
No supporting interview notes.
No copy ofletter (1 year later) sent to the NRC was in the file. Letter states the intent of the originalletter was..
The misrepresentation issue was not addressed by ECP.
j 171 No corrective action (CA) was provided for the ineffective work control issue even thought the issue was substantiated.
ECP didn't determine why the ACR did not result in CA.
186 Report states that no root cause (RC) was performed but doesn't state why not.
Report has "yes" for reportability determination having been nude; but doesn't follow-up with the outcome and whether a repon was made.
192 Report doesn't adequately address the issues, there has been no follow-l up, and no training has been conducted.
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i David M. Goebel ITPOP 97-0023 / Attachment 3 / Page 3 l
1 File Number Deficiencies CI is very unhappy with the handling of his concern. HR makes it feel 197 as if the CI is the problem. The investigation appears to be adequate but not a good resolution.
198 This file demonstrates an example of the ECP oflice inability to get a handle on a bigger situation than an isolated concern. Essentially this j
concern covers a period of six months and the entire chain of command in the organization where the concern resides. The handling of this issue has resulted in the following:
- 1. Unhappy Cl who does not believe ECP addressed issues;
- 2. The appearance that the ECP is unable to address and control issues that involve management failures; j
- 3. Fails to respond effectively and appropriately to allegations of
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wrongdoing in regards to the NRC;
- 4. There is reverse discrimination / improper motive alleged by the j
department against the contractor C1 and nothing is done to respond to that situation.
- Very interesting issue raised by the fact that there was an internal investigation done, after referral from ECP, which does address broader issues and many of the correct questions about chilling effect and other issues. But the investigation does not appear to be incorporated at allinto the status of the file or the report to the Cl.
- No finalletter to Cl in the file.
- Cl not happy with ECP investigation.
- No HP report in ile but referenced.
213
- The concern was not adequately addressed.
- Concern resolved on 5/15/97 yet CI does not agree.
220
- No attempt for ECP to follow-up with the Cl to see if her going to the line had in fact resolved the issue.
221
- The favoritism issue was not addressed.
ECP did not follow-up to assure the referred concern was adequately addressed.
223
- No repart in file to substantiate basis for closure.
There is no report in the file.
- File was " resolved" on 5/30/97; but a letter in the file dated 6/30/97 shows the file still open.
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n David M. Goebel ITPOP 97-0023 / Attachment 3 / Page i File Number Deficiencies 230
- File does not contain investigation report, initial letter, and was
" resolved" before receiving the results of the June NUPIC meeting.
- Does not address how NU purchase orders will be written on this subject. CA addressed only " primed steel."
ECP letter to Nuclear Oversight (NO) did not contain the specific 235 recommendations contained in the ECP file and the letter sent to the C1 and does not request any feedback from NO.
- ECP has not followed up with NO regarding resolution.
236
- No repon in file.
- No Triage conducted.
- Chilling effect not investigated.
File in general does not meet requirements of the ECP Manual.
239
- No report in file.
- No investigation plan in file.
- No initialletter to Cl in file.
242
- No report in file.
Investigat on not performed yet.
i Database shows resolved.
243
- File shows resolved without any supporting documentation.
- ECP should not have turned over the issue to NO to investigate.
244
- Issue that came up during the investigation of the original concern was not addressed.
- No investigation plan in file.
250
- The investigation does not appear to address the issue.
No HR report in the file.
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David M. Goebel ITPOP 97-0023 / Attachment 4 / Page 1 i
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4.
GENERIC ECP FILE DEFICIENCIES NOTED BY LHC j
When an investigation surfaces other important issues beyond those brought up by the concerned individual (Cl), these issues usually aren't addressed.
In some cases ECP failed to identify the proper issue and this resulted in an inadequate investigation and oversight of significant issues.
In many cases in which retaliation has been alleged, the files do not contain any documentation of whether a " chilling effect" was investigated.
l HR investigations sometimes avoids the issue raised by the concerned individual and redefines the issue in a manner that defends management, j
The investigative conclusions are not obvious on the face of many files. Files do not clearly state whether a concern is substantiated, and if so, what the corrective action is, or if an issue is panially substantiated but requires more analysis or investigation. Some files were closed without anyjustification.
l Files do not contain copies ofimportant and referenced documentation (i.e., HR reports, j
l CR's, ACR's, etc.)
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l When a " chilling effect" is surfaced it isn't always investigated.
1 ECP tends to rely too much on feedback from other organizations without reviewing the information and assuring that all the issues were correctly and Wequately addressed.
Reportability evaluations for safety related issues aren't docume.ited.
l Files reference root cause (RC) analysis without any documentation in the file.
In several cases where the concern addresses more than one issue, all of the issues aren't l
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Required corrective action (CA) isn't always identified and implemented.
Investigation plans not in the file.
1' Investigation reports not in the file.
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l David M. Goebel i
j ITPOP 97-0023 / Attachment 4 / Page 2 j'NN t
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' xChronological logs are not always complete and in many instances it cannot be determined i
l who (which ECP person) made the entry.
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Follow-up with C1's isn't always done or done in a timely manner.
Files do not have required signatures, therefore determination cannot be made as to i
whether the file had adegrate review.
Status as noted in the files differs from the ECP database.
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