A97068, Forwards Independent Investigation Rept Assessing Safety Conscious Work Environ at Zion Station.Rept Details Team Investigation,Conclusions & Basis for Conclusions,As Requested in

Forwards Independent Investigation Rept Assessing Safety Conscious Work Environ at Zion Station.Rept Details Team Investigation,Conclusions & Basis for Conclusions,As Requested in

ML20202F138
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	12/05/1997
From:	Brons J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20202F144	List: A97068, Forwards Independent Investigation Rept Assessing Safety Conscious Work Environ at Zion Station.Rept Details Team Investigation,Conclusions & Basis for Conclusions,As Requested in ML20202F145
References
ZRA97068, NUDOCS 9712090023
Download: ML20202F138 (8)

Text

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, Zion. ll U kN9 JY w ,r. ,620si ZRA97068 December 5,1997 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk

Subject:

Zion Station Safety Conscious Work Enuronment Investigation Report; Zion Generating "tation, Units 1 & 2:

NRC Docket Numbers 50-295 & 50-304

References:

1. Letter to T. J. Maiman (Comed) from A. B. Beach (USNRC), dated July 22,1997 l

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2. Letter to R. J. Manning (Comed) from A. B. Beach (USNRC), dated September 15,1997 l 3. Letter to R. J. Manning (Comed) from A. B. Beach (USNRC), dated October 20,1997

4. Telecon Between A. Bill Beach (NRC) and L. Waldinger (Comed) on November 17,1997 Extending Report Submission Date to December 5,1997.

Gentlemen:

In response to the NRC's request in reference 3, enclosed, as Attachment C to this letter is the independent investig,ation report assessing the safety conscious work enviromr.ent at Zion Station. The report, which details the team's investigation, conclusions, and the basis for these conclusions, was prepared by the independent investigation team commissioned by Comed's Nuclear Oversight Manager during the summer of 1997.

Submission of this report was originally planned for the early fall of 1997. However, as the team was neariag completion of its investigation, a Complaint was filed in Cook County Circuit Court, which identified a number of new technical allegations involving Zion Station. The decision to delay submittal of the report until December 5,1997, to allow the assessment of these new allegations was approved by the NRC during the Reference 4-telephone call. gDk 9712090023 971205 *

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ZRA97%8 Page 2 of 3 This independent team's investigation was the basis for Commonwealth Ndison's presentation to you during a public meeting held on October 2,1997 at the NRC's regional offices in Lisle, Illinois. The attached report documents the team's complete investigation and supplements the information provided to the NRC in the course of that October 2nd meeting. The report documents the degree to which Zion Station hat challenges impacting its safety culture. This report also provides the team's assessment of Zion Station's work environment, the methods-used to ensure that employees' concerns are appropriately addressed and employees r.re provided feedback, and the effectiveness of the Employee Concems Program.

l Consistent with the information we shared during the October 2nd meeting, the independent investigation team has concluded that the fundamental attributes of a safety conscious work environment exist at Zion Station. The team concluded that the current work environment at Zion Station is conducive to workers bringing up safety concerns

- without fear of retribution, and that there have been no actual cases of retaliation for raising safety concerns. The independent team found that there is a high priority on safety issues at Zion Station and that the Zion management team generally is fostering an atmosphere in which reporting of safety concerns is encouraged. However, as we have discussed, the independent team also concluded that there are weaknesses and some individual perception issues that are being addressed.

The attached report characterizes the work environment challenges at Zion Station, with associated causal factors. The independent team provided a list of recommended =

corrective actions to improve identified weaknesses. Zion Station management has reviewed the team's recommendations and is tracking the appropriate corrective actions in its Nuclear Tracking System (NTS) to completion. We have also taken additional actions in the interest of achieving my personal goal of having a robust safety conscious work environment at Zion Station. A summary of those actions already completed is provided as Attachment B to this letter. Those actions that are in progress are also being tracked in NTS and will remain open until I am satisfied that my objectives have been achieved. A summary of these currently open actions is provided as Attachment A to this letter.

The independent team's report reflects Comed's continued effort to measure the health -

of the work environment at Zion Station. The team facilitated two sets of interviews by independent consultants at two points some three months apart during their investigatir.n.

In the short term, I intend to periodically conduct site-wide surveys of my workforce to monitor our continuing performance.

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t ZRA97068 Page 3 of 3 Finally, current site management and bargaining unit leadership are lecding the effort to rebuild a sense of trust across the Station. They are being assisted by a team of organization development consultants (the Critical Action Team - CAT) who have demonstrated success at resolving management / bargaining unit differences at the Comed fossil stations. Specifically in the Operations Department, a series of interventions was conducted in September to bridge the gap between bargaining unit and management.

Those actions constitute a first step in an ongoing process to improve performance within the Operations Department. Similar processes are being implemented within and between other Zion Station departments.

I will continue to brief you on the progress we have achieved during our periodic recovery panel meetings.

If you have any questions about the attached information or questions related to this matter, please contact me at (847) 746-2084, extension 3600, or Mr. Robert Godley, Zion Station Regulatory Assurance Manager, at extension 2900.

Sincerely,

< hkw ohn C. Brons Site Vice President Attachments cc: Regional Administrator, USNRC - Region III Senior Project Manager, USNRC - NRR Project Directorate III-2 NRC Senior Resident Inspector, Zion Generating Station Office of Nuclear Facility Safety - IDNS l

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t ZRA97068 ATTACilMENT A COMMITMENTS IDENTIFIED IN Tills LETTER The following table identifies those actions committed to by Comed in this letter. These actions are on going and the expected milestone or date for completion is identified to the right of each action. Any other actions discussed in this letter represent intended or planned actions by Comed. Other actions are described to the NRC for the NRC%

information and are not regulatory commitments. Please notify Mr. Robert Godley, Zion Station Regulatory Assurance Manager, of any questions regarding this letter, its g attachments, or any associated regulatory commitments.

Commitment: Committed Date The " Zion Nuclear Station Recovery Plan," Revision 2, Action Prior Plan to Startup of 8 ~ (or Outag

" Corrective Actions" has numerous elements designed to increase and Unit 2 reinforce management involvement and accountability in the wrrective -

action program. The tasks described in Action Plan 8 will be completed prior to startup of Unit 2.

The process for ensurmg feedback to the originators of Problem Prior to Startup of Identification Forms (PIF) will be revised to ensure that the originator is Unit 2 awne of the classification of the PIF, how to access the status, and is informed of a mechanism appeal process if the originator is not satisfied with the resolution.

The SVP will establish his presence on site through large group Prior to Startup of meetings, and through small meetings with groups or individual Unit 2 employees in the field. During these meetings he will communicate his expectations on employee participation in the issue identification and resolution processes, and share the message that the corrective action process is not punitive and that the use of these processes are critical to the improvement effort of the Station.

The Zion Communications Director will use the site newspaper to Beginning communicate, on a monthly basis: (1) management's expectations for December 19,1997 employees to feel free to raise concerns; (2) management's recognition for employees who raise concerns; and (3) positive reinforcement for identification of concerns by employees.

Zion Station will conduct periodic follow up cultural surveys on station Beginning personnel to assess the effectiveness of management's actions to J .uary 5,1998 promote teamwork and establish trust.

The Zion Employee Concerns Program (ECP) Administrator will March 31,1997 participate in department meetings and smaller group meetings on a rotating basis to discuss the fundamental philosophy of the ECP K:komplyicg.nrc\saftyctdoc

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Commitment: Com,nitted Date (or Outage):

program and increase station awareness of the program. In addition, the Zion ECP Administrator will conduct an informal open house in the cafeteria to increase visibility.

To ensure that the actions committed above to increase the awareness of April 1,1998 the ECP program were effective; an effectiveness review will be performed.

To ensure consistent application of employee concerns programs Zion February 6,1998 site contractors will be requested to adopt the Comed Employee Concerns Program or submit their program to Comed for approval.

To ensure that initial and continuing General Employee Training March 31,1998 (NGET) at Zion most accurately communicates the role of the Comed Employee Concerns Program a review will be made of the initial and continuing NGET program and recommended changes will be forwarded to the Production Training Center for incorporation into the Station Training module.

To ensure that initial and continuing General Employee Training March 31,1998 (NGET) effectively communicates the importance, purpose, and use the corrective actions processes, a review will be made of the initial and continuing NGET program and recommended changes will be forwarded to the Production Training Center for incorporation into the Station Training module.

Documentation supporting Employee Concerns investigations and February 6,1998 conclusios at Zion will be as essed to ensure record integrity. This will include sampling concerned individuals files for evidence that I

communication was made to the concerned individual on the outcome of their concerns.

An assessment will be performed specifically focusing on the Zion February 28,1998 -

contracted security force to determine any actions needed to promote teamwork within the group.

The Plant Manager will hold quarterly meetings with the Site Quality Beginning Verification Supervisor, Site Security Manager, Human Resources January 5,1998 Manager and the Employee Concerns Administrator to share significant issues to provide an opportunity for early Magnosis and assure that

" silos" of problems that are indicative of generic issues needing site-wide remedies t.re not overlooked.

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. s ZRA97%8 ATTACliMENT B ACTIONS TAKEN TO IMPROVE THE HEALTH OF THE SAFETY CONSClOUS WORK ENVIRONMENT AT ZION STATION To address the overtime concems in the Operating Department, the Operations Manager has personally met with each Shift Manager and other key supervisors to point out their accountability in administering overtime. In addition, to ensure all Operations clearly understand those expectations directly from the Operations Manager a Standing Order was isrued. The Standing Order clarifies past misunderstandings and directs the Supervisor to identify in advance if a shift tumover process will result in exceeding the procedural time constraint of thirteen hours. The offgoing shift personnel are required to obtain Operations Manager's (or his specific designee) pre-approval. The Department Head and Supervisor do not have authority to approve deviations without first obtaining the Operations Manager pre-approval. The Operations Manager will then ensure compliance is in accordance with ZAP 200-04.

A short term training initiative was completed for selected managers, first line supervisors and above, to increase sensitivity toward employee concerns and develop better listening skills. The training also included instruction on the proper handling of employee safety concerns; the need to encourage employees to raise and docmnent concems, and providing feedback to employees on the resolution ofissues they raise.

An Independent Investigation Team was established at Zion Station to understand the current state of the safety culture at Zion Station and to recommend corrective actions.

That team focused on those issues that would have impacted the perceptions of workers at Zion, including the effectiveness of our corrective action processes.

The Zion Site Vice President (SVP) distributed an "All Hands" memorandum and ccnducted all-hands meetings re-emphasizing management's expectation that employees should feel free to raise concerns and that discrimination against such employees will not be tolerated.

Efforts to re-emphasize the role and presence of the Zion ECP Administrator were initiated by introduction (from the SVP) to Zion Station personnel in the all hands on deck meeting in November.

. Zion Station established a Quality Hotline; a dedicated phone line for the Site Quality organization where site personnel can report concems about quality issues, and we have publicized the existence of this new Quality Hotline.

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4 Zion Station has established a policy guideline that provides the Zion SVP expectation that employees should feel free to raise concerns and that discrimination against such employees will not be tolerated. It emphasizes that the normal method to raise concerns should be to line management. The policy also makes it clear that alternative paths are equally available, the Site Vice President or other senior managers can always' be I approached, the Employee Concerns Program is available, the Quality organization can be used and that people may raise issues to the NRC - all without fear of retaliation.

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1 ZRA97068 ATTACHMENT C l

Independent Investigation Team's Report On the Safety Conscious Work Environment At Zion Station l

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