ML20216G414
| ML20216G414 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/11/1998 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Bassilakis R CITIZENS AWARENESS NETWORK |
| Shared Package | |
| ML20216G419 | List: |
| References | |
| NUDOCS 9803190401 | |
| Download: ML20216G414 (5) | |
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NUCLP.R REGULATORY COMMISSION WASHINGTON, D.C. 300000001 k
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Ms. Rosemary Bassilakis, Research Director Citizens Awareness Network Mr. Mark Holloway, Member Citizens Regulatory Commission 54 Old Tumpike Road Haddam, CT 06438
Dear Ms. Bassilakis and Mr. Holloway:
I am responding to your letter to Chairman Jackson of the U.S. Nuclear Regulatory Commission (NRC) of January 12,1998, which expressed concems about the safety-conscious work environment at the Millstone Station and requested that the Commission not schedule the Millstone Unit 3 restart vote until the Northeast Nuclear Energy Company (the licensee) has achieved and maintained a defined level of performance for a period of at least 4 months. Your letter was forwarded to me for a response.
Your request is similar to one from the Citizens Awareness Network that the Chairman responded to during her visit to the Millstone Station on February 2,1998. As the Chairman stated during her visit, when the NRC's October 24,1996, order was issued, the NRC recognized that it would take a long time for employees to develop trust in a developing and evolving safety-conscious work environment, and that it takes time for management to avoid I
the occasional errors and elimMate actions, which may lead to a chilling effect. As specified in the NRC's October 24,1996, order, the independent Third-Party Oversight Program will continue to be implemented until the licensee demonstrates, by its performance, that the conditions that led to the requirements of the oversight have been corrected. The licensee will have to demonstrate sustained performance in order to discontinue this third-party oversight program following restart. Demonstration of sustained performance will be assessed using the continued findings of the third party, licensee self-assessments, performance indicators, and NRC evaluations. The NRC staff anticipates that independent oversight will need to be in place at least 6 months following the restart of a Millstone unit to provide a sufficient period to assess sustained performance related to a safety-conscious work environment and a capability to handle safety concems raised by employees and contractors.
In your letter, you express concems about Little Harbor Consultants' (LHC's) approach to evaluating the licensee's safety-conscious work environment implementation effort. It should be noted that LHC's highest attribute rating category corresponds to an ideal safety-conscious work environment. The approach of benchmarking against an ideal performance standard is discussed in LHC's Oversight Plan Section 3.1, which states, in part: "Once the [ Millstone) site culture is sufficiently characterized by the LHC oversight team, the attributes of the current
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environment will be compared with those of an ' ideal' environment....Using this comparison as a template, methods will be developed to monitor progress toward achieving an environment l
closer to the ' ideal' state.' l.HO'; approach for determining that licensee performance is i
acceptable for restart h not impose, as a minimum requirement, that the licensee meets the f
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N, R. Bassilakis and M. Holloway Additionally, you commented that "LHC has gone beyond their oversight role and is acting as a consultant to [the licensee)." The NRC's October 24,1996, order requires LHC to develop
"[rjepods on oversight activities, t..idings, and recommendations to the NRC and the Licensee."
The order also requires the licensee to respond to each recommendation. Although LHC activities on site are extensive, and in some cases involve interaction with the licensee, staff observations are that LHC's activities are consistent with their oversight role as required by NRC's order and specified in LHC's approved oversight plan.
The NRC staff believes the current requirements imposed by the October 24,1996, order will provide a sufficient oversight process for resolving concems regarding the Millstone licensee's 4
ability to effectively resolve employees' safety concoms. The licensee's current extended outage I
provides for a substantial initial assessment period regarding implementation of the employee safety concems program and establishment of a safety-conscious work environment. The NRC staff does not believe an additional 4-month waiting period is necessary. The Commission has j
reviewed the status of a safety-conscious work environment at each Commission meeting, and j
will further aaluate the status upon a recommendation from the staff that the unit is ready for j
restad. The NRC staff intends to maintain a high level of oversight at Millstone until the licensee i
demonstrates a sustained level of improved performance.
Sincerely, i
S clor Office of Nuclear Reactor Regulation
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R. Bassilakis and M. Holloway March 11, 1998 Additionally, you commented that "LHC has'gone beyond their oversight role and is acting as a consultant to [the licensee)." The NRC's October 24,1996, order requires LHC to develop
"[rjeports on oversight activities, findings, and recommendations to the NRC and the Licensee."
The order also requires the licensee to respond to each recommendation. Although LHC activities on site are extensive, and in some cases involve interaction with the licensee, staff observations are that LHC's activities are consistent with their oversight role as required by NRC's order and specified in LHC's approved oversight plan.
The NRC staff t:elieves the current requirements imposed by the October 24,1996, order will provide a su#icient oversight process for resolving concems regarding the Millstone licensee's -
ability to effectively resolve employees' safety concems. The licensee's current extended outage provides for a substantial initial assessment period regarding implementation of the employee safety concoms program and establishment of a safety-conscious work environment. The NRC staff does not believe an additional 4-month waiting period is necessary. The Commission has reviewed the status of a safety-conscious work environment at each Commission meeting, and will further evaluate the status upon a recommendation from the staff that the unit is ready for restart. The NRC staffintends to maintain a high level of oversight at Millstone until the licensee demonstrates a sustained level of improved performance.
Sincerely, MMk W J. C olftf18 Samuel J. Collins, Directnr Office of Nuclear Reactor Regulation DISTRIBUTION: (Reference GT #980037 / CRC-98-0058) spedint Me(50 423)1 WTravers PUBLIC PMcKee SPO-L Reading MThadani SPO Reading OGC LCallan OCA HThompson OPA AThadani SDembek PNorry LBerry
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EDO Principal Correspondence Control i.
IFROM DUE: 02/05/98 EDO CONTROL: G980037
- DOC DT: 01/22/98 FINAL REPLY:
es n ter Joseph I. Lieberman
$2nnter Christopher J. Dodd
}R:prccentative Sam Gejdenson
' !TO:
l Chairman Jackson f0RSIGNATUREOF:
chairman DESC:
ROUTING:
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RESTART OF MILLSTONT UNIT 3 Callan l
Thadani Thompson l-Norry Blaha Burns IDATE: 01/26/98 Miller, RI ihSSIGNED TO:
CONTACT:
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NRR Collins CPECIAL INSTRUCTIONS OR REMARKS:
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l, OFFICE OF THE SECRETARY CORRESPOITDENCE CONTROL TICKET PAPER NUMBER:
CRC-98-0058 LOGGING DATE: Jan 23 98 ACTION OFFICE:
EDO AUTHOR:
J LIEBERMAN, C. DODD, AFFILIATION:
U.S. HOUSE OF REPRESENTATIVES ADDRESSEE:
CHAIRMAN JACKSON LETTER DATE:
Jan 22 98 FILE CODE: ID&R 5 MILLSTONE
SUBJECT:
RESTART OF MILLSTONE UNIT 3 ACTION:
Signature of Chai: man DISTRIBUTION:
CHAIRMAN, COMRS, OGC, OIG, SECY SPECIAL HANDLING: OCA TO ACK CONSTITUENT:
NOTES:
SEE CRC LTRS. 98-0009, CRC 98-0013 AND CRC 98-0039 DATE DUE:
Feb 98 SIGNATURE:
DATE SIGNED:
AFFILIATION:
l 1
EDO -- G980037