ML20149M252

Forwards Memo from Jn Hannon to WT Russell Re Independent Review of Millstone Station & NRC Handling of Employee Concerns & Allegations

ML20149M252
Person / Time
Site:	Millstone
Issue date:	10/29/1996
From:	Blanch P AFFILIATION NOT ASSIGNED
To:	Zwolinski J NRC
Shared Package
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References
NUDOCS 9612130191
Download: ML20149M252 (4)

Text

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From: PAUL M. BLANCH <PMBLANCH@ix.netcom.com>

To: JZ <JAZWOL9aol .com>

Date: 10/29/96 3:50am

Subject:

Letter to Russell John:

This confusing, undated letter, addressed to an NRC official no longer employed by the NRC was put on the Internet yesterday. Could you please explain what this is all about.

Recommendations of Millstone Independent Review Group MEMORANDUM T0: William T. Russell, Director Office of Nuclear Reactor Regulation THRU: Roy P. Zimmerman, Associate Director for Projects

Office of Nuclear Reactor Regulation FROM

John N. Hannon, Leader i Millstone Independent Review Group

SUBJECT:

INDEPENDENT REVIEW 0F MILLSTONE STATION AND NRC l HANDLING OF EMPLOYEE CONCERNS AND ALLEGATIONS The charter for the Millstone Independent Review Group required the team to l

develop recommendations for licensee actions related to the Millstone Station j

for improvements in handling of employee concerns and for NRC staff actions related to improvements in handling of allegations.

. The team's recommendations for NRC are provided in the attachment to this memorandum. Each of the recommendations is referenced back to the process 4

issue (s) identified in the team's report. As indicated in the report, these recommendations are provided for consideration by the staff in evaluating the i adequacy of continuing process improvements by NRC.

Attachment:

As stated RECOMMENDED CORRECTIVE ACTIONS FOR NRC PROBLEMS

1. Change the attitude that allegations are a necessary burden, and enhance sensitivity to the importance of the allegation process as a valuable tool for accomplishing the NRC's mission. (Process issue 8.1, 8.6)

. Incorporate Millstone lessons into agency-wide allegation program training, counterpart meetings and seminars. Place emphasis on appreciation of the public visibility of the allegation process, and reenforce training with specific examples.

9612130191 961210 PDR ORQ NRRA

• Ensure NRC management recognition of the potentially significant insights to be gained from allegations, and the adverse impacts on agency

, resources and credibility with public if we fail to react appropriately.

NOTE: Senior NRR management has adopted these insights in recent training that was conducted for NRR staff.

2. Avoid under-reaction to claims of disc- mination.

(Process issue 8.1) l

• Recognize that the perception of discrimination can i be just as significant and damaging as the reality of discrimination. A chilling effect can spread rapidly within a licensee facility, with innediate negative impact. Treat all discrimination claims as potentially safety .ignificant issues, not iust  ;

those paired with apparently significant technical problems. l

• Don't diffuse or rationalize indications of

. discrimination by averaging them away. If one i employee is identified as having experienced or )

perceived discrimination, a problem exists that i needs to be remedied. It should not be minimized by identifying numerous other employees who have ,

not experienced a problem.

l NOTE: One of the improvements implemented by MD 8.8 was the prioritization of agency resources to promptly investigate claims of discrimination.

3. Develop expert resources to help establish and monitor effective performance indicators for measuring licensee employee trust and confidence in management's ability to resolve employee concerns without fear of discrimination. (Process issue 8.4)

• Avoid the usual " employee concern" type survey vehicles. Experience has demonstrated that employees will not meaningfully respond to direct types of questioning. More sophisticated me'. hods appear to be needed to accurately measure the work place environment.

• Absent more effective survey vehicles, NRC inspections should not document findings of no apparent chilling effect at any licensee facility with pending discrimination claims, e.g., (1) we should not make broad conclusions absent probative evidence, and (2) we should not draw conclusions broader than evidence supports.

4. Recognize the potential chilling effect created by NRC

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enforcement that is publicly perceived as being soft on 1

discrimination. Enforcement action for discrimination violations should err on the side of increased severity j level if senior management involvement was apparent.

l (Process issue 8.3)

NOTE: Revision I to the NRC Enforcement Manual issued in i

November 1995 incorporated many of the recommendations from NUREG-1499.

j 5. Recognize the potential chilling effect of inadequate l licensee correction of discrimination problems, especially when a licensee has minimized or denied

discrimination findings. (Process issues 8.2, 8.3)

!

• Provide timely follow-up to verify and validate i licensee corrective actions for all discrimination i enforcement actions.

l

• Ensure enhanced, periodic follow-up for licensees that have minimized or denied discrimination j findings (e.g., inspections, management meetings, SALP).

• Ensure that NRC acknowledgement of enforcement

action response letters appropriately addresses i licensee rationalization or denial of

discrimination. findings. For example, it may be

appropriate to require the licensee to utilize l credible, independent resources to periodically s assess the work environment for raising safety l concerns.

g

• Consider revising Management Directive 8.8 to specifically identify the NRC office with programmatic oversight for discrimination follow-up activities.

6. Appreciate alleger unfamiliarity with NRC processes, and

. provide them more informative responses to help them put their concerns into better perspective. (Process issue

8.3)

!

• Do not respond to alleger challenges of NRC conclusions with terse generalizations. Provide

! specific additional information to fully explain

the bases for NRC determinations.

!

• Provide timely explanation to allegers about the j NRC process for evaluating potentially generic

. safety concerns. Help them to understand the

} relative safety significance of their concern, and the basis for the timing and scope of NRC planned actions to address the concern.

NOTE: NRC will soon issue an informative brochure to be made available to 'he public, that will explain the NRC allegation process.

7. Expedite completion of current Agency Allegation Advisor initiatives and NUREG-1499 recommendations to improve the allegation process. Reconsider any NUREG-1499 recommendations that were not adopted. . For example, recommendation II.B.3 regarding development of a survey instrument.

(Process issues 8.1,8.2,8.4,8.5,8.6)

8. Reevaluate participation of both licensee and alleger attorneys during NRC discrimination investigations.

(Process issue 8.5)

Paul M. Blanch Energy Consultant 135 Hyde Rd.

West Hartford CT 06117 Voice 860-236-0326 Fax 860-232-9350

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