ML20203K743

Provides Prelimenary Results of Employee Concerns Program Evaluation as Described in SECY-97-003, Millstone Restart Review Process

ML20203K743
Person / Time
Site:	Millstone
Issue date:	02/18/1998
From:	Mckee P NRC (Affiliation Not Assigned)
To:	Bowling M, Loftus P NORTHEAST NUCLEAR ENERGY CO.
References
SECY-97-003-C, SECY-97-3-C, NUDOCS 9803050220
Download: ML20203K743 (7)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 300eHo01

• t February 18, 1998 Mr. Martin L Bowling Recovery officer-Millstone Unit 2 c/o Ms. Patrida Loftus Director Regulatory Affairs Northeast Nuclear Energy Company 0.0. Box 128 Waterford, CT 06385-0128 4

Dear Mr. Bowling:

This letter provides the preliminary results of the Employee Concems Program evaluation as described in SECY.97-003, " Millstone Restart Review Process." The evaluation team leader, Helen Pastis, provided you with the results of the evaluation at a publicly observed exit meeting on January 22,1998. The team is continulnMo n wpare the evaluation report, IR No. 50 245,50-336, and 50-423/97 212.

The team's main objective in this evaluation was to assess the implementation of the employee concems program (ECP) and the employee concems oversight program (ECOP) at Northeast Nuclear Energy Company's Milletone Nuclear Power Station.

During its evaluation, the team also had the opportunity to conduct some of its evaluation of the safety conscious work environment (SCWE).

The team conducted its evaluation in two parts. During the week of December 8 12, 1997, the team attended meetings, interviewed people, requested information, and observed various training sessions. 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 returned to follo+up on certain issues and questions, which arose during its evaluation. During this week, the team again gathered additional information.

The following identifies certain program areas reviewed by the team and a summary of t

the team's preliminary findings in these areas, Employee Concerns Program:

The team found that the ECP was well established, has made significant improvements since the beginning of 1997, and is functioning effectively. The team's evaluation included the following:

ECP Oroantration: The team found the ECP organization had independence, resources, and management support to perform thorough, unblased investigations. The minor discrepancies found by the team did not significantly detract from the program or its accomplishments.

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m M.L Bowling 2-ECP Case Files: The team reviewed 18 ECP case files that were either closed or resolved after July 1997. For two of the case files, the team verified that the i

i corrective actions had been completed as stated. The team found that conclusions of the ECP evaluations were property supported by Northeast Nuclear Energy Company's (PNECO's) investigations, corrective actions were proper to l

1 resolve the issues, and communications with emp!7ees about their concems were improving. The team also found ECP was adequately defining concemed individuals' Issues with one exceptiots. The exception was considered an isolated ooourrence and did not reduce the overall effectiveness of the ECP. The team found that ECP was properly protecting the identities of those hdividuals bringing conooms to the ECP. The team noted some minor discrepancies including the licensee's communicating on a timely basis to persons who raised concems, classification of some cases, and, in one case, premante closure.

d ECP Belf Assessments: The team concluded that ECP self assessments were adequmly self critical. The latest self assessment reports were improved as compared to the first several reports. The licensee was adequately tracking most i

ofits self assessment corrective actions. The licensee's tracking of actions being taken to address Little Harbor consultant's recommendations was initially slow, but had shown improvement at the time of the evaluation. Self assessment and extemal assessment findings and recommendations were appropriately l

disseminated to plant management and staff, f

Employee Concerns oversight Panel (ECOP):

J Review of documentation indicated that the ECOP was very slow to develop and I

begin meaningful activities. However, at the time of the evaluation, the team found ECOP to be functioning effectively. ECOP was found to be especially effective in administering leadership surveys in specific par *.s of NNECO's organization to help identify probl6m areas. The ECOP was found to be made up of a diverse group of site employees independent of the line organization reporting directly to the President and Chief Executive O'ficer.

Problem Areas:

The team reviewed the Problem Area Plan that describes the standards, expectations, and course of action to address problem areas. The licensee defines problem areas as areas of personnelinteraction where an SCWE is challenge ( ir does not exist. This plan calls for specific action plans to be develope 6.cr each problem area Gent, ally, the team found that the licensee has made considerable progress to improve its identification and resolution of problem eress. The team found some weaknesses in the action plans used for resolution of problem areas, Specifically, the team found weaknesses in the program with respect to (1) prioritizing problem areas by significance, (2) high-level management review and attention, both in the development and

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M.L Bowling 3-implementation of the action plans, (3) assurance tat the scope of its action plan is adequate and addresses all possible organizational areas, (4) consistency and quality amongst the action plans, (5) setting and scheduling milestones, (6) i developing the basis for closing the action plans as complete, (7) evaluating the effectiveness of meeting goals and objectives of each action plan, and (8) identifying action plans as confidential and to follow procedures for confidentiality, as is done with other documents dealing with personnel actions.

SCWE Long Rarm Pik:.:

The team found t et the licensee had not sufficiently developed p!ans to address long rango actions for enhancing and maintaining an SCWE. Specifically, process for maintaining the ECP and SCWE infrastructure, monitoring of performance, including recognition of program degradations, and phasing out of oversight organizations were not addressed in licensee planning documentation.

ECH and SCWE Training:

The team found that the licensee has made significant improvements in the training provided to HS staff regarding the SCWE and ECP, Generally, the team i

found that the licensee's program provides accurate and naaningful training on SCWE and ECP. The licensee is also ensuring that training records are maintalnoa to ensure the training is given to those that require it and soliciting and using feedback to determine the training's effectiveness. However, the team found severalInstances of deviations from procedures and the training manual.

For example, the team found instances where the training for managers was not property recorded, training for ECP did not follow the training manuals, and the ECP Administrative Control procedures were not followed to independently confirm the background qualifications of investigative contractors.

Metrics and Trending:

The team reviewed and compared the Millstone Unit 3 Performance ladicators related to ECP.nd SCWE over a number of weeks. From its interviews, the team found that NNECO's manspement considers that the reports are useful tools for tracking and trending information on the ECP and SCWE. The team noted that in most cases the data shows an improving trend. The team noted that while the data changed every week, the Analysis / Action section of the reports, that is, the text, did not always change, and at times had little bearing on the data presented.

Also, sometimes the data for the same parameter were presented in different formats from week to week (bar vs. line, good trending up or down).

M.L Bowing The NRC staff wik include these findings, along with the findings of other activities and issues identified by the team, in its evaluation report on the effectiveness of your efforts to establish an SCWE at Millitene. 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 you will be asked to respond to the avaiustion results at that time.

Should you have any questiens or comments regarding the issues discussed in this letter, please contact me 6t (301) 415 2240.

Sincer !,

Phillip F.

Kee i

Deputy Director for Licensing Special Projects Office Office of Nuclear Reactor Regulation Docket No. 50-336 cc: See next page 4

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. M.L Bowling 4*

February 18, 1998-l The NRC staff will include these findings,' along with the findings of other activities and

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Issues identified by the team, in its evaluation report on the effectiveness of your efforts to establish an SCWE at Mil l stone. 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 you will be asked 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.

Sincerely, j

original signed by:

l Phillip F. McKee Deputy Director for Licensing Special Projects Office Office of Nuclear Reactor Regulation Docket No. 50-336 cc:

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Northea';t Nuclear Energy Company Millstone Nuclear Power Station Unit 2 cc:

Lillian M. Cuoco, Esquire Mr. F. C. Rothen Senior Nuclear Counsel Vice President - Work Services Northeast Utilities Service Company Northeast Utilities Service Company P. O. Box 270 P. O. Box 128 Hartford, CT 06141-0270 Waterford, CT 06305 Mr. John Buckingham Emest C. Hadley, Esquire Department of Public Utility Control 1040 B Main Street Electric Unit P.O. Box 549 10 Liberty Square West Wareham, MA 02576 New Britain, CT 06051 Mr. D. M. Goebel Mr. Kevin T. A. McCarthy, Director Vice President - Nuclear Oversight Monitoring anci Radiation Division Northeast Utilities Service Company Department of Environmental Protection P.O.Rox128 79 Elm Street Waterford, CT 06385 Hartford, CT 06106 5127 Mr. David Amerine Regional Administrator, Region l Vice President - Nuclear Engineering U.S. Nuclear Regulatory Commission and Support 475 Allendale Road Northeast Utilities Service Company King of Prussia, PA 19406 P. O. Box 128 Waterford, CT 06385 First Selectmen Town of Waterford Mr. Allan Johanson, Assistant Director Hall of Records Office of Policy and Management 200 Boston Post Road Policy Development and Planning Waterford, CT 06385 Division 450 Capitol Avenue - MS# 52ERN Mr. Wayne D. Lanning P. O. Box 341441 Deputy Director of Inspections Hartford, CT 06134-1441 Special Projects Office 475 Allendale Road Mr. M. H. Brothers Kng of Prussia, PA 19406-1415 Vice President - Operations Northeast Nuclear Energy Company Charles Brinkman,.Aanager P.O. Box 128 Washington Nuclear Operationt Waterford, CT 06385 ABB Combustion Engineering 12300 Twinbrook Pkwy, Suite 33L Mr. J. A. Price Rockville, MD 20852 Unit Director-Millstone Unit 2 Northeast Nuclear Energy Company Senior Resident inspector P.O. Box 128 Millstone Nuclear Power Station Waterford, CT 06385 c/o U.S. Nuclear Regulatory Commission P.O. Box 513 Niantic, CT 06357

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2'1 Northeast Nuclear Energy Company Millstone Nuclear Power Station

- Unit 2

cc:

t Mr. 8. D. Kenyon Chief Mucler Officer Millstone-Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385 Citizens Regulatory Commission ATTN:= Ms. Susan Perry Luxton 180 Great Neck Road j

- WaterfoM, CT 06385 l

Deborah Katz, President Citizens Awareness Network

P. O. Box 83 i

- Shelbume Falls, MA 03170 The Honorable Terry Concannon Co Chair Nuclear Energy Advisory Council Room 4035 Legislative Office Building.

Capitol Avenue -

Hartford, CT 06106 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terry's Plain Road -

Simsbury, CT 06070 t

Little Harbor Consultants, Inc.

Millstone -ITPOP Project Office P. O. Box 0630-Niantic, CT 06357-0630

~ Mr. Daniel L. Cuny

. Project Director.

Parsons Power Group inc.

2675 Morgantown Road

-Reading, PA 19607.

1

- Mr. Don Schopfer'

' Verification Team Manager Sargent & Lundy:

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- 55 E. Monroe Street Chicago, IL-60603 -

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