B13952, Forwards Final Rept of Northeast Utils Programs Involving Employee Concerns,For Review & Info.Partially Deleted Info Also Encl

Forwards Final Rept of Northeast Utils Programs Involving Employee Concerns,For Review & Info.Partially Deleted Info Also Encl

ML20147H836
Person / Time
Site:	Millstone
Issue date:	10/25/1991
From:	Opeka J NORTHEAST NUCLEAR ENERGY CO.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20147H828	List: B13952, Forwards Final Rept of Northeast Utils Programs Involving Employee Concerns,For Review & Info.Partially Deleted Info Also Encl ML20147H823 ML20147H831 ML20147H903
References
FOIA-97-22 B13952, NUDOCS 9704090118
Download: ML20147H836 (20)

Text

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(L E M -fi fn iO :0 ENCIOSURE i

~ ~ NW r . OeM*1 w%

• seleen Street, sema, Wnececut we eneen su sesee eeen r.o. sox tre

.( ' C . .mm M ,,',*; ".* i NAA"FoA CONNEchCUT 96141 ofM (Set) stS-g g esw nam wee ==

October 25, 1991 Docket No. 50-336 513951 i 1

d J

Mr. Thones T. Martin i

i Replocal U.5.

AdministratorNuclear Regulatory Commission 415 Allendale Road 19406 Elag of, Prussia, Pennsylvania i

Dear Mr. Martin:

4 Millstone Nuclear Power Station, Unit No. 2 teolovea concerne i

several weeks ago, you were conduct verbally an advised thatreview independent we hadofcontracted NU's with a third-party to The final report provided programs involving employee concerns, 4

- to us is ir.cluded as Encicsure I f or your information and and review.is su;:pe T*.s repc:: c or.t a i n s p r.c Accordingly, p : 1.e La r y i n f o r r a t i on it a s re spe ct.f ully r eque s te d the enclosed af fidavit.

l that the information contained in Enclosure public disclosure in accordance with 10CrR2.790.

a be withheld Very truly y,ours, 6

i NORTREAST NUCLEAR ENERGY COMPANY 1 1

I .

. e v

J. F.(ogpka Executive vice President cci w/o Enclosures NRC Froject Manager 0.

E. 8.

M.Vissing,hief, Kelly, C Reactor Projects Section 4A

' W. J. 3synond, Senior Resident inspector, Millstone Unit Hos. 1, 2, and 3 U. 8. Nuclear Regulatory Commission Attention: Document 20555 Control Desk Washington, DC

~

9704090118 970403 /

3 PDR FOIA LIFSHITZ97-22 PDR 3 7 0L j o30lil ,

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i. _l 2 NORTH 2A47 HUCLEAR ENERGY COMPANY

' AFFIDAVIT SUPPORTING REQUEST.TO WITHMOLD DOCUMENTS-FROM FUBLIC DIsCLOSURS

?

I, J. F. Opeka, being duly sworn, depose and state as follows:

h j

1. I an Executive Vice President, Engineering and Operations, and ,

j ps such I as responsible for the be review of - the from withheld informatica public ,

herein sought to referenced disclosure. I am submitting this affidavit in connection with the provisions of 10CFR 8ection 2.790(b) of the Commission's

regulations.

g 3.' The information soughtand/or to beutilised withheld by NHFC0 constitute in Muclear Energy Company (NNECO) making personnel determinations and/or which makes reference i to the conduct of performance of named individuals.

/

3. NHBCO considers documents relating to personnel matters to be confidentisi when they contain evaluations of or comments on NNECO employees or other employee-specific information, public employee's of which would infringe upon the disclosure privacy.

f;l.

Further , the information sought to be withheld constitutes an 4.

cptional analysis undertaken for the purpose of irr[rovin; disclosure o such performance, and public public policy I

corporate the important information interest in the could undermineof candid and uninpeded self-promotion ovaluation.

l.,

This information is of a type customarily ' held in confidence

. by NNECO and, other than its disclosure to th public.

f to remain policy, such information is

- 6. Under confidential,NNECO and public disclosure of this information would violate employee expectations that personnel information will l

remain confidential.

1.

The information sought to be withheld is being the transmitted provisione of to the Commission in confidence pursuant to l

10CFR section 2.190 with the understanding .

i

.the commission.

L I l

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45

8. The information oo' u ght to be withheld, tosources, the best and

- of any my knowledge, is not available in public ll disclosure to third parties has been and will be ande pursuant-that .provides for the regulator:r requirements

- only to maintenance of the unformation.An confidence.

The above paragraphs are true and accurate to the best of my knowledge, information and belief.

Executed this -__

2f_ day of JcMx -, 1991.

r j J. F.(Dyeka U 4

' State of Connecticut )

) es. Berlin County of Martford )

i Sworn and subscribed to before me thia Mb day of l

_, 1991. '

_. &/o h a,

d$v0 4. SlacW _

Hotary Public i

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My c:r.:i s sien e xpi r e s :

. &c4 Jf #f6 1 1

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4 Decket No. 50-334 t

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!. Enclosure 1 l .

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' Millstone Nuclear Power Station, Unit No. 2 Employee Concerns 1

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October 1991 a

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M HUKILL & HUKILL,Inc.

7 Meadowbrook Lane Elizabethtown,PA 17022 (717)367-8642 1

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October 17, 1991 4

0

• d Mr. Edward J.. Hroczka Semier Vice President N ulsar Engin'eering and operations -

l Northeast Utilities '

P.O. sox 270 '

Eartford, Connecticut 06141-0270 Dear Mr. Mrocska I Enclosed is the Report of my review of the company's programs for einployees to raise concerns and the company's nuc6er of reacti and 16C groups at Unit 2 because ci tr.c significant these concerne.

, Should you have l

concerns raieed by individuals in these grcupe .any questio forth in the Report, please contact me.

Sincerely, t

. D. ukill l

Encleeure e

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1 I

i. l I l Third Party Review in the Ares l of Eroloves concerns 1

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i inODUCTION This " review began with a two part purpose, to determine:

' (1) the willingness of NU personnel to raise concerns throu ebain of' command or other approved lines of reporting within N ands (2) 'the receptivity of WU supervision and manageme eencerns.

Since there has been en Anordinate number of employes i

concerns w ithin specific departments et the Millstone, Unit 2, -

feeliity, NU requested that personnel within the affected -

l work-units be interviewed in a way that fosters employeei l i ceafidence and ascertains the root cause, for these cont nu ng I concerns.

i t Ac xc ho';ND, MIT.C XLCGYa AND SAMP1.E i'

21. As that Enclosure i contains my professional background.

hschground indicates, I have had no previous involvement w n

l Apart from the information I either NU or the Millstone sites.

provided- in the course of the interviews, no NU manager or i

reptosentative attempted to direct my efforts in any subst aatter nor review or alter my findings in advance of this repor j

Since criticisms over the receptivity of management to employee concerns appeared to be centered within the E ,

and Instrumentation and Controls (I6C) groups at Unit 2, those

• groepe were the focus of interviews.

A, set of questions was developed designed to de d the the willingness of NU personnel to raise safety concerns an receptivity of supervision and management to those concerns.

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<. 2-1

i these questions are set forth in Enclosure 2, however, the ettsched questions were varied and supplemented in the course of

' individual interviews so sa to stimulate spontaneous, individual 4, .

j roepenses. '

4 About one to two hour interviews were held with Included among those interviewed approxi etely 38 6 personnal.

were substantially all Millstone, Unit Two, Electriolans; substantially all N111 stone Unit Two, IEC Technicians; current and l

previous immediate supervisors within those two work groups; managers s'nd directors within the chain of command of those two l work groups up through the Station Director; operations personnel; f l

' the Directors of Units 1 and 3; and other personnel involved in f

i the disposition of concerns currently being raised relative to NU.

Questions were intended to define organizational dynamics, processes, and existing concernee motivations and desires.

In addition, a selected document review was conducted to determine the quslity of procedures used in addressing the raising l

of s.afety concerns, including; Nucle 4.r Engineering ard Operations Frecedure NE0 3.15, Nuclear safety Concerns Program, Revision Six, l

dated April 20, 1990.

j 1

III. J55 ULT 5 0F INTERVIEWS WITH SELECTED PERSONNEL

1. Introduction Although all interviews initially followed the set of 4

questions in enclosure 2, and at no time were the names of 4

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. 3 spesific individuals initially raised by the interviewer, In

{ nearly every interview the interviewee focused their comments on i

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Substantially all personnel interviewed hold strong l

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opinions concerning the manner in which these eenduct'themselvesonsite,andasdescribedbelow,amajorityofh the personnel interviewed alter their conduct as. a result of a l

I concern over, and at times fear of, retribution 6 G

])

As a result of the information developed in the interviews, this report addressess (1) the willingness of employees to raise concerns and the corresponding receptivity of '

ii managernent toward those concerns; (2) employee's views of inercasar.;levelsofr.anage=ent;h $h f ' ands (4) the impact of that conduct on Finally, recomeendations the organization and site activities..

are provided, l _

2. Willinoness of *=nlovees To paise concerns and the 4

Correspondino Receptivity of ~Manseement, ,

i In the course of interviews, the vast majority of

personnel were candid and open, and demonstrated a clear understanding of the need to raise safety concerns to assure the safe operation of the Unit. Personnel generally displayed a -

mature attitude toward their jobs and had a level of experience at or exceeding the level seen elsewhere.

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reonnel were in substantial, agreement that raising i  %

safety concerns through the chain of command is both the preferred l

approach' and tho one desired by NU. Personnel also indicated a general, willingness to raise safety concerns through the chain j eenmand'.

Personnel et the working level indicated that if-ocafronted with a concern which they either couldnt raise, or had l

raised to no avail, with their inusediate supervisor, they would l

eithers (1) raise it with a higher level of MU management; (2) go 1l 1 directly to the NRC) or (3) submit it to the Nuclear Safety f

1 Concerns Program (MSCP). .

Employses at the working level generally understood the l

t

' 59CP. Although the NSCP,was usually characterized as a i' well-designed program, few employees indicated a willingness to l

use the progra:..

When confronted with a concern not being l

adequately addressed by supervision, most employees indicated that l they would raise the concern with either second level management l

i er 30 directly to the NRC. The perception of the NSCF as an offactive avenue for concern resolution appears to be hampered by '

its off-site location, coupled with a preoccupation with 1

esafidentiality. Confidentiality is automatically bestowed on a e

l eencernee, even if it is not requested and even under eircumstances when it cannot be assured in light of the concern espressed. Thic unnecessarily erodes the program's credibility sad impacts f,ts offectiveness.

j Personnel at both the working level and ranagement evidence little knowledge of the Nuclear Review Team (NRT) l 888'

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• program. Few understand its relationship to the M8CF and when ons program should be utilised rather than the other. The NRT progras

)

appears redundant and unnecessary.

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3. EiEIloyee's views of Manaaement l

Interviews revealed a mutua1 respect among employees, as ir well as goed corrunications among the co-workers an 9 r-immediate . supervisors

{- i Empioyees generally considered their second% vel Employeer j

me.magers as accessible as their first-line supervisors.

j and managers evidenced a mutual respect for one another and good l

working relationships.

Most employees know the Unit and Station directors well, i

and indicated a level of famili,agty a

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greater than what is tv,1ca11r .se, at other sit.s.

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i d j.o the director level because it was v ewe l

I t k% in the past directors have not lived up to commitments. ' .

There is a sense among working-level personnel that the ocasitments by onsite directors are overruled by corporate 1' l management and accordingly, co-workers lack confidence in raising '

. There was a generally expressed view iseees with the directors.

that 1f an issue could not be resolved by the first line f ,

supervisor or second level manager, an employee would probably g j

to the NRd. A smaller nuraber would go to the NSCP under such l f

' When asked to explain this perceptiotr 'the two l

eistumstances.

examples consistently provided were corporate managemedt's f

! reversal of a site management decision to investigate how l, co-workers and

j refusal to cooperate in a company investigation into b

l *t h 4L Both employees and site directors perceive an excessive L ,

amount of direction from corporate management on issues that are )

As an example, supervisors and l -

t viewed to be properly site issues.

l i sanagers indicate they do not have the authority to adsinister i

discipline, even for minorgfractions f without specific . direction and/or f (j .orJ Additionally, corporate shanagements' approval from headquarters.

l decision to overrule site directors' agreement to investigate the apparent unauthorized release of personnel records including, i

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eagleyes evaluations, sent a clear message to site personnel rw Ming the limited authority of those senior managers and rs do not ors on site. Both employees and site dir i

ont j P*cesive a strong message from senior man 6h.b nd perceive signals se frequently mixed'and/or reversed. Their understanding of i

i boedguarters guidance is ta the high road", don't_.J:apk the best, and don't in any cas ad $.(

hopefully the issues will somehow resolve themselves.-

1 In short, the message about bringing concerns through the chain of command is bepg received by working levol personnel, but As not being followed' h  ;

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Management's inaction f

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_to resolve this situation has compounded this perception.

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" 11 issues discussed, the co-workers and immediate superviso appeare'd to be candid and genuine and gavs no season to

f their sincerity. As a result, rend based on their statements, ctive I

there' is a serious question with respect to the safety perspe l e,sammen.mmmys l There appears to be an unreasonable and unintelligible l

to use unwillingness on the part of, i

l approved lines of comtnunication within FJ, either through l

- Although chain of command, the NSCP or the NAT, thip j ih were critical of and indicated an. unwillingness to use e t erbb MRT cr NSCP, no basis fer that position is evident. is l

characterizations of both immediate supervision and managem N others in stark contrast That is to say, to althoug the characterisations ofco interviewed.  ;

v1111ngness in the first instance to raise concerns with supervision and a receptivity by supervision to hear such

]ategoricallywerenegativewith h.h,eencerns )

respect to all levels of management.

There appears to be a near-total breakdown in the l , appear to be These

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employer / employee relationship.

Their course of conduct appears both unmanaged and unmanageable.

For example, several unprofessional and at times insubordinate. Ek' categorically supervisors and managers stated that M 1

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management an allegedly improper

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refused to discuss with Similarly,

,whic was involved in performing.

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intentionally exited several interviewees indicated that h theplantwithan(

)ithout Anforming the appropriate company personnel of this fact as .

l The required by company procedure. f h

repeatedly indicated their total unwillingness to raise concerns I

through th'e company's chain of responsibility or other company I programs designed for such purpose.

! Thare is a general perception among most co-workers that l

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! "{/ 6 j are on a campaign to harm the company and various and that,the individuals clearly do not 1evels of NU management,

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acct;t hT's cbjectives and strategies, and their Based on interviews with Each co-workers, no viable path to resolution was identified.

pers,on interviewed was asked how the situation with

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h could be resolved and the majority were unable to l 6 eaggest a solution short of transfer or termination.

l appear intractabit and this perception is shared among l i the co-workers.

IV. :tFFECT ON ORGANIEATION V>

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-is a perception among almost all co-worker 6 are given favored treatment when compared t6 others.

According to site personnel, Senior IfU management has j

eensistently preached a "high rped" approach to inanediate r j

s supervision and co-workers wher e h,h '

Although the appareift intent of this "high road" spproach is to assure all employees are treated equally and not l

4 the approach has sebject to discrimination for raising concerns

^

- been interpreted at the site _as permitting thet_.

4 b.b Co-workera, immed a e supervision, as well as unit 1.

directors and the site director see no- end in . sight to the chronic g and the company. This h d Mstering situation is a' continued disfraction to many employees in that they are "looking over their shoulder" out of a concern

' tLat their job activities will be misinterpreted or mischaracterised and become part of a contentious situation.

• 3sene'diate supervisors and managers within these work, units are spending anywhere from 20 to 70% of their time on This, distraction s eroded the l

h work environment.

There is eTae evidence of attrition among l

immediate supervisors and the interviews revealed that a number of supervisors as well as co-workers are considering leaving their

. There jobs or transferring because of the poor work environment.

l is a perception among co-workers that if they disagree wit O'Sullivart or Del Core there will be retallation from these 6 n some torn. This has fostered mistrust between the a man a a mTrN gl II f till IUIH I PMim

_ _ _ _ _ _ _ _ _ _ _ _ _ ~

4 r C s

l workers, and Equally important, this

, h appears to 6N contributed to a groNng mistrust between workers l

and managers due to the failure on the part of management to deal with' this long-standing situation.

There la difficulty within these work units n in planning J:

l P' work since immediate supervision and management 4d" spending am .

I

, Supervisors have j

insrdinate amount of time resolving concerns.

lost their ability to manage their people in ways traditionally hy

' For example, a supervisor indicated that t e seen in work units.

i would not. even let individuals leave ten minutes early to make a dentist's or doctor's sppointment because of an awareness that such treatment would be viewed as favoritism and the subject of a

• l Generally, j

concern to the NRC or the basis for a DOL complaint.

l r

L the peace.

l The long term ef fect on both the Unit 2 electrical and l

16C groups is an erosion of morale and performance, and c corresponding potential'eafety issue with respect to their ability 1

to concentrate on work.

v. RtcoMMENDATIONS In light of the information provided in the interviews, are i

~

as sumaggised above, the following three basic recommendatio (2) h as>de s J; significantly upgrade the authority and level of on-site

.) ,,

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. 12

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management (in this regard consideration should be given to an en-site corporate officer to provide the continuity between site Getivities and the corporate of f ace) and, f 3) comununicate NU's

" or site heels for any action taken relative tc - -

- i management to the working level.

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. ENCLOSURE 1 i

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' pm D. NUKILL j

F. - Consultant .

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Nemry D. Nuk11'1 retired in December 1990 from GPU Nuclear l.

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Corporation where he was Vice president Duringand Director his more than of T

Is&and Nuclear Generating station Unit one.80 years i l modifications and testing following the which Igd to the successful restart of Unit one inration late and 1985 .

y successful ,

malatenance of Unit one through more1 than three hl refueling '

l eparational cycles For the yearas well 1989 asThree three equally Nile Islandsuccess Unit one had the l l ettages.

highest capacity factri of all the operating nuclear plants 1

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-world.

Str. Nukill has over 30 years' experience in the nuclear field.

Before joining GPU he served as a senior civilian special He was d ation,'

assistant to the Commander, Naval sea system i quellfication, training and professional performance of the l, more than 1,200 engineering duty officers.

c Indiana, he received aFollowing bachelorgraduation of science A native of South Bend, degree from the U.S. Naval Academy in 1953.he During his career he was serv i

Year of naval nuclear power training.primarily, involve operation of nuclear submarines.

Mis Navy assignments included five years as Commandi f Admiral 4 puclear submarine and four years on the staff o

~

l Nyman G. Rickover, No was responsiblewho for many years headed for the selection and the Na c power program.

engineering training of all nuclear submarine commandi  ;

} Ne retired with the rank of Captain.

l since retirement from cyU Nuclear Corporation, Mr. Nukill ha He is l

i remained active in the nuclear industry. ,

ei the Nuclear safety Review Boards for five utilities. l 4 anse a member of the Na$1onal Nuclear Acc Institute of Nuclear Power Operations (1NPO). '

l Fres 1976 to 1977 Inc.

project for Burns and Roe, he was associated with the C l l

] Mukill and his wife, Virginia, reared seven children and curre reelde in E11:abethtown, Pennsylvania.

_____._____.._______i___________-_____ _

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• Enclosure 2 Ivernvraw aurnettuns aun t.Yun OF OuunTraurug

, K. Introductica

1. Introduce yourself.

3. Review with the interviewee the pointe set forth in the

' } 1etter establishing this interview.

3. ' Emphasize that it is not the purpose of this interview to receive or discuss specific safety concerns, but rather it the purpose of this meeting to better understand how such concerns are raised by employees and responded to by management.

s'. Should any interviewee have specific concerns refer them to their supervisor. ,

i

b. If interviewees are insistent on providing specific concerns, the expert should indicate that he will rece.f,vp those concerns and provide them' to Rich Laudenet for appropriate disposition through the chain of command or Nuclear Safety Concerns l Program, as appropriate.

1 l l

4. Following this general introduction, ask if they have l any questions.

33. Specifio Questions l

1. Current position and how long have you held this l ~

position?

3. Positions at Northeast Utilities prior te current  ;

position?

l

)ther commercial nuclear power plc.nts? f

3. Positions at 4.

What is your current understanding of what is expseted of you as an NU employee when you identify a safety concern?

I

5. Where did you gain this understanding? (0JT, formal l

training, or some combination thereof) i l

6. What is the typical response of your launediate supervisor if you raise a concern with him?

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7. If you had a concern, would If not,you whyraise notfit with your immediate superviscr? ,

Do you get adequate feedback from your immedi' ate 1

' 8.

supervisor when you raise a concern? s

9. What is your current understanding of what you should do if in the course of performing a task under a j procedure you determine you cannot assure compliance 4

with the procedure?

i 104 Do you believe that it is generally possible to do your

job in compliance with the procedures you must work under es they are currently written?*-

l

11. Have you ever identified a nuclear safety concern to

'ss your immediate supervisor that was inappropriately j

responded to? If so, explain.

l

'h 2 . Under what circumstances would you not raise Would safetyyou -

concerns you may have with your supervisor?

l then avail yourself of other empicyee concern vehicles i such as the Nuclear Safety Concerns Program or the If not, why not? .

Nuclear Review Team?

. 13. NRC Inspections indica *~ that.there is a responsivs atmosphere to conmunicatla; safety issues at Millstone i- reflecting a conffdence in tupervision to you agree with respect to or disagree l safety concert. resciution.What is the basis for your opinion?

i

. with this?

14. NRC Inspections also indicate that the employeeco l

' the elements of a good program, do you agree orWhat is the basis for

- disagree with this conclusion?

your opinion?

15. What is your assesseent of how effective the current 4

system at Millstone is in resolving employee concerns?

l

16. Are there any recommendations or other points you would

" - like to make?

i III. Conclusion I -

Conclude by thanking interviewee for their cooperation 1

and ask that they not discuss with others the substance of the j

matters discussed so that you Finally, will haveonce the benefit again, ask of each if they p rson's individ;al answers.Mve any questiens or anything else to add.

mne ma ,n N U ATr ; i e oil.t U IMiy41r3n- --

. .- . - _ . . -_ -_ _. .