ML20203B653

Provides Preliminary Results of Independent,Third Party Oversight Program or Little Harbor Consultants,Inc Which Oversees Implementation of Employee Concerns Program & safety-conscious Work Environ at Plant

ML20203B653
Person / Time
Site:	Millstone
Issue date:	02/18/1998
From:	Mckee P NRC (Affiliation Not Assigned)
To:	Beck J AFFILIATION NOT ASSIGNED
References
NUDOCS 9802240375
Download: ML20203B653 (3)

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5 NUCLEAR REGUUsTORY COMMISSION WASHINGTON, D.C. Es006-0001 February 18, 1998 Mr. John Beck, President Little Harbor Consu'tants, Inc.

Millstone -ITPOP Project Office P.O. Box 0630 Niantic, CT 06357-0630 Dea: Mr. Beck:

This letter provides the preliminary results of the independent, third-party oversight program (ITPOP) or Little Hart >or Consultants, Inc. (LHC), which oversees the implementation of the E.mployee Concems Program (ECP) and safety-conscious work environment (SCWE) at the Millstone Nuclear Power Station. The evaluation was conducted in conjunction with NRC's evaluation of Northeast Nuclear Energy Company's (NNECO's) ECP and programs addressing -

SCWE. As part of the staff's evaluations, findings related to the licensee's programs were compared to findings made by LHC, The evaluation team leader, Ms. Helen Pastis, provided you with the results of the evaluation at a pub'icly observed exit meeting on January 22,1998, The team is continuing to prepare the evaluation report, IR No. 50-245, 50-336, and 50-423/97-212.

The team conducted its evaluation in two parts. During the week of December 8 - 12,1997, the team talked to some 7f LHC's team memberc and requested information. At the end of that week, the team retumed to the NRC headquarters to evaluate the information gathered at the site. During the week of January 5 - 9,1998, the team retumed to the site to follow-up on certain issues, which arose during its evaluation. During this week, the team again gathered additional information.

Overall, the team found LHC effective in implementing its Oversight Plan for mointoring and overseeing NNECO's efforts to correct and prevent the repetition of past failures in management processes and procedures for handling safety issues raised by employees, and in ensuring that the employees who raise safety concems are not discriminated against. The team found LHC

. particularly effective in its efforts in overseeing the licensee's activities to improve its ECP.

Based on comparison with NRC evaluation of NNECO's ECP program, LHC observations and findings concoming the ECP program and program implementation appear accurate and thorough in identification of deficiencies and weaknesses. Further, LHC's recommendations in this area appear to have had a very constructive impact on licensee program improvements.

The team found that some SCWE areas, such as Employee Concerns Oversight Panel and SCWE's identification and resolution of problem areas, had not been extensively covered by LHC. The team was concemed that LHC work priorities may impact eventual coverage by LHC of these areas, l

in addition to the above, preliminary findings of the team include:

1. LHC structured interviews of the licensee's employees perforfned in the summer of 1997 were well planned and documented. The survey results provided detailed and relevant

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J. Beck 2. LHC cofisultant's review of harassment, intimidation, retaliation, and discrimination cases and processes was thorough and effective in its assessment and identifying case-specific and program weaknesses.

3. LHC conducted a comprehensivo review of NNECO's corrective action program with emphasis on how the licensee's processes for addressing employee concems in the line organization was functioning. LHC's assessments of other line organization functions have seen less rigorous. - For example, LHC recently completed assessments of Nuclear oversight and self assessment programs. As thcussed previously, assessments have not been accomplished for other areas importcni to a safety-conscious work environment.

4. The team found that LHC did not have an effective system for evaluating and tracking NNECO's responses to LHC recommendations. Subsequent to the team evaluation at a January 27,1998, public meeting with the NRC, LHC, and the licensee, LHC provided docurnentation that presented the status of NNECO's responses to LHC's recommendations.

5. The team found LHC slow in addressing revisions to its Over%hi Plan to make it current and more accurately reflect LHC's oversight activities.

6. The Oversight Plan specifies that the third-party organization activities, findings, and recommendations be provided quarterly as a written report. LHC has primarily relied on information provided as handouts distributed during the periodic. three way meetings with NU and the NRC as the means for reporting its activities. While information provided at the periodic meetings is substantial, this approach to reporting has resulted in a documentation that does not reflect a complete picture of LHC activities and documented basis for LHC findings.

I We will continue to monitcr LHC's oversight activities and 9 hold periodic meetings to discuss its findings and recommendations in overseeing the Millstone ECP and SCWE. No response to the issues discussed in this letter is required. The NRC's evaluation report will provide the final evaluation observations and findings; and we will ask you to respond to the evaluation results at that time.

Should you have any questions or comments regarding the issues discussed in this letter, please contact me at (301) 415-2240.

s Sincerely, FML.

Phillip F. McKee Deputy Director for Licensing Special Projects Office Office of Nuclear Reactor Regulation cc: See next page 1

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J. Beck February 18, 1998

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2. LHC consultant's review of h:raasm:nt, intimid:ti:n, r:tilintion, cnd discrimin': tion cas ;s and processes was thorough and effective in its assessment and identifying case-specific and program weaknesses.

3. LHC conducted a comprehensive review of NNECO's correcuve action program with emphasis on how the licensee's processes for addressing employee concems in the line organization was functioning. LHC's assessments of other line organization functions have seen less rigorous. For example, LHC recently completed assessments of Nuclear Oversight and self-assessment programs. As discussed previously, assessments have r ot been accomplished for other areas important to a safety-conscious work environment.

4. The team found that LHC did not have an effective system for evaluating and tracking NNECO's responses to LHC recommendations. Subsequent to the team evaluation at a January 27,1998, public meeting with the NRC, LHC, and the licensee, LHC provided documentation that presented the status of NNECO's responses to LHC's recommendations.

5. The team found LHC slow in addressing revisions to its Oversight Plan to make it current and more accurately reflect LhC's oversight activities.

6. The Oversight Plan specifies that the third-party organization activities, findings, and recommendations be provided quarterly as a written report. LHC has primarily relied on information provided as handouts distributed during the periodic, three-way meetings with NU and the NRC as the means for reporting its activities. While information provided at the periodic meetings is substantial, this approach to reporting has resulted in a documentation that does not reflect a complete picture of LHC activities and documented basis for LHC findings.

We will continue to monitor LHC's oversight activities and to hold periodic meetings to discuss its findings and recommendations in overseeing the Millstone ECP and SCWE. No response to the issues discussed in this letter is required. The NRC's evaluation report will provide the final evaluation observations and findings; and we will ask you to respond to the evaluation results at that time.

Should you have any questions or comments regarding the issues discussed in this letter, please contact Mr. Phillip F. McKee at (301) 415-2240 Sincerely Original signed by:

Phillip F. McKee Deputy Director for Licensing Special Projects Office Office of Nuclear Reactor Regulation ec: See next page DISTRIBUTION:

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