B16617, Provides Response to Recommendations Made by Little Harbor Consultants,Inc During 970603 Meeting

Provides Response to Recommendations Made by Little Harbor Consultants,Inc During 970603 Meeting

ML20149K721
Person / Time
Site:	Millstone
Issue date:	07/24/1997
From:	Goebel D NORTHEAST NUCLEAR ENERGY CO.
To:	External (Affiliation Not Assigned)
References
B16617, NUDOCS 9707300105
Download: ML20149K721 (9)

Text

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w \ Rope Ferry Rd. (Route 156). Tcterford. CT 06385 Northe)it V/h)k NuclearEnergy nu ion, Nucie., Power station

• Northcut Nuclear Energy Company P.O. Box 128 Waterford, CT 06385-0128 (860) 447 1791 Fax (860) 444-4277 The Northeast Utihtice System  ;

July 24,1997 Docket No. 50-245 50-336 50-423 B16617 Little Harbor Consultants, Inc. l Millstone -ITPOP Project Office  ;

P.O. Box 0630 Niantic, Connecticut 06357-0630 Millstone Nuclear Power Station, Unit Nos.1,2 and 3 Response to Recommendations References (a): J. W. Beck letter to D. M. Goebel, " June 3,1997 Little Harbor Meeting," dated June 5,1997.

This letter provides the Northeast Nuclear Energy Company (NNECO) response to the l recommendations made by Little Harbor Censultants, Inc. (LHC) during the June 3, 1997, meeting. These recommendations were also reflected in a letter from J. W. Beck ,

to D. M. Goebel dated June 5,1997 [ Reference (a)]. Accordingly, Attachment 1 to this i letter provides NNECO's response to LHC's recommendations.

The following are NNECO's commitments contained within this letter. All other statements within this letter are for information ca!y.

B16617-1 Establish common standards and criteria for processing concerns by all organizations handling employee concems by September 5,1997.

B16617-2 Expand the monthly report to include all active Millstone-related employee concerns being handled by all organizations handling employee concerns by September 5,1997.

B16617-3 Implement a formal process for management overview of the concem process by September 5,1997.

B16617-4 A requirement will be documented for conducting an annual extemal assessment of the ECP by August 1,1997.

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B16617-5 Confirm that the site exit process is supporting these options (i.e., either i

participating in an exit interview with the ECP or be given a letter requesting any concerns they may have) by September 12,1997.

l B16617 6 Application of the ECP to contractors at off-site locations will be defined

by September 12,1997.

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B16617-7 Qualifications and training of ECP personnel involved in handling employee concerns will be described in administrative controls by August +

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22,1997.

i B16617-8 issue Revision 2 of the ECP Manual by August 8,1997, to 1) reflect experiences gained with implementing the manual; 2) reflect changes in t responsibilities; and 3) describe interfaces with the Employee Concerns Oversight Panel.

B16617-9 Enhance the ECP corrective action process by August 29,1997.

B16617-10 Review the- pre-Decembw 1996 files and resolve documentation de'iciencies by October 31, 997.

B16617 Complete the ECP database improvements by August 29,1997.

Please contact Mr. W. J. Temple at (860) 437-5904 should you have any questions Ii regarding this matter.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

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b. NI. Goebel Vice President - Nuclear Oversight Attachment (1) cc: see next page

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U.S/ Nuclur R:gulatory Commission B16617\Page 3

, cc: W.D. Travers, PhD., Director, Special Projects Office

! W.D. Lanning, Deputy Director, inspections, Special Projects Office P. F. McKee, Deputy Director, Licensing and Oversight, Special Projects Office H. N. Pastis, Sr. Project Manager, Licensing, Special Projects Office ,

U. S. Nuclear Regulatory Commission Attention: Document Control Desk l Washington, DC 20555 l

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Docket No. 50-245 5 50-336 50-423 B16617 j

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I Attachment 1 i

Millstone Nuclear Power Station, Units 1,2 and 3 Response to Little Harbor Consultants, Inc. Recommendations j Made During the June 3,1997 Meeting 4

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B16617 \ Attachment 1 \ Page 1

Millstone Nuclear Power Station, Units 1,2 and 3 Response to Little Harbor Consultants, Inc. Recommendations Made During the June 3,1997 Meeting During the June 3,1997 meeting with the Nuclear Regulatory Commission and Northeast Nuclear Energy Company, Little Harbor Consultants, inc' made recommendations which were later reflected in a June 5,1997 letter from LHC to NNECO. Following are restatements of the recommendations and NNECO responses .

thereto. l l

Recommendation 1 )

i Survey Must be Properly Administered to Deliver Meaningful Results

Response

Human Resources (HR) conducted the second Nuclear Leadership Assessment during

the week of June 16, 1997. HR placed an emphasis on increasing employee 4

participation and incraasing the controls on the administration of the assessment. /4 a result, the assessment was administered differently from the initial assessment conducted in November 1996. Specifically, to the extent possible, assessment forms were distributed by HR representatives to small groups of employees at local sites.

The HR representatives were generally present to address questions from employees filling out the assessment forms and they collected the forms upon completion. Forms a l

were hand-carried in sealed envelopes to the HR offices located in Berlin where they were immediately input into a database by a vendor for processing. In addition, unlike the 1996 administration, employees were not given access to the identification coding for supervisors other than their immediate supervisor. HR believes that these above-mentioned administrative changes helped to ensure that each employee completed only a single assessment and that the responses were maintained in the strictest confidence.

With respect to the FPI-NU Culture Survey conducted on June 23,1997, the survey was distributed by the Nuclear Officers. Instructions were given to each individual to not enter their name or their employee identification number to ensure the survey inputs would not reveal the identity of the responders. Collection points were located in the various departments and at other remote locations throughout the site.

Recommendation 2 Must be committed to Act on Results s..__ __

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. B16617 \ Attachment 1 \ Page 2 e

i l Resoonse l Regarding the Nuclear Leadership Assessment, each leader who has three (3) or more j responses receives a report with personal scores. The individual's supervisor also j receives a copy of the report. Structured group feedback workshops will be offered to j address skill gaps. The purpose of the workshop is to assist in interpreting the i assessment results, clarify expectations concerning leadership and provide

! developmental guidance. The personal reports also contain comparative data such as

' the previous individual scores from the November 1996 assessment and median scores for the function. In addition, the nuclear officers receive copies of the individual reports

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for their entire organization as well as a roll-up report for their furiction and the roll-up i t

median scores for all nuclear. The purpose of this comparative data is to allow for

identification of problem areas. The top 10% and bottom 10% scores by name are provided to the President & CEO, Nuclear.  ;

i l j During the workshop session, individuals are given a developmental guide that was j designed to complement the assessment questionnaire. The guide provides a process l

, for individuals to follow to determine reasons behind assessment scores and to develop

appropriate action (s) to address weaknesses and to leverage strengths. Further, it i provides specific developmental recommendations for consideration. In addition to j group feedback workshops, individual feedback sessions are conducted upon request

}_ from the individual and sessions are held for managers who seek help in developing their personnel. Finally, the results of the 1996 assessment were used as one data l point in determining the content of a leadership development program for Units 1 and 3. '

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! Beginning wititte 1997 assessment, the results of the assessment are tied to the

' performance management process. Individuals who are not trending positive in their scores will be expected to work with their immediate supervisor to document a 3 developmental goal as part of LINKS (computer based employee goal setting and j performance review system). Also in 1997, results are tied to the rewards system l throuch the Nuclear Performance incentive Program. Millstone directors and managers havef a leadership improvement factor incorporated into their rewards to recognize the performance improvements into their area.

It is our view that integrating assessments with the performance management and rewards processes demonstrates our commitment to act on results.

! With respect to the FPl-NU Culture Survey, it was communicated to the Millstone 3

Station workforce that once the survey was completed and the results tabulated, each i department would receive a printout of its scores. The results of the survey will be i processed and reports will be developed by site, unit, and departments. Each nuclear j leadership team officer will ensure appropriate actions are taken in a timely manner for j any areas identified as needing improvement.

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- B16617 \ Attachment 1 \ Page 3 l

Recommendation 3

- NNECO Should Review and Revise the ECP Manual to Address the Following:

a) Develop common standards and criteria for processing concems by all l organizations handling employee concems .

l b) Develop clear interfaces, expectations between these organizations

c) Implement a management overview of the concem process j d) Provide comprehensive monthly reports to management addressing concems handled by all organizations Resoonse The ECP Manual was originally envisioned to be the document that described all ECP activities. Subsequently, it was decided to confine the ECP Manual to describe the method by which the ECP would receive, investigate, report and respond to employee concems. Consequently, it will be necessary to develop complementary administrative controls to address other aspects of the NU handling of employee concerns, such as the handling of concerns by organizations other than the ECP. Those complementary administrative controls will address the issues identified by LHC as follows

a) The Vice President , Human Resources, is leading a team in establishing common standards and criteria for processing concerns by all organizations handling employee concerns. Organizations represented on the team are Human Resources, Employee Concerns Program, Internal Audit, Security, and Environmental Health 1 and Safety. These common standards and criteria will be issued and implemented by September 5,1997.

b) The standards and criteria described above will provide clear interfaces and expectations between all organizations that handle employee concems.

c) in July 1997, the first monthly report was initiated which included all active concem efforts with which the ECP was involved. The report is currently distributed to nuclear leadership team officers. By September 5,1997, the report will be expanded to include all active Millstone-related employee concems being handled by those organizations that handle employee concems.

- d) A formal process for management overview of the' concem. process will be implemented by September 5,1997. This process will include the overview of active concem efforts from those organizations that handle employee concerns.

I Recommendation 4 Ensure the Elements Referenced in Conclusion 4 kre Addressed a) Manual does not contain requirement for conducting an annual extemal assessment of the ECP as committed to in the CP (Action item 10-13) l

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! b) Requires all NU employees to participate in an exit interview; However, site l exit process does not assure they will be directed to the ECP

c) Manual does not address coverage for contractors at off-site locations i i

d) Handling of NRC referred allegations is not covered I e) Does not address personnel qualifications and training ,

I i Response

! Administrative controls have been or will be developed to address the elements in i Conclusion 4 as follows: i

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. a) A requirement will be documented for conducting an annual external assessment of j the ECP. This will be accomplished by August 1,1997. l i b) The ECP Manual, Revision 1, gives NU employees the option of either participating  ;

in an exit interview with the ECP or be given a letter requesting any concerns they i e may have. We will ensure by September 12, 1997, that the site exit process is j supporting these options, including making any necessary changes to the process. l j c) Application of the ECP to contractors at off-site locations will be defined by j September 12,1997. )

i d) Handling of NRC referred allegations is now covered in procedure DC 18 (Section i 1.2.9), Change 1, which was effective on June 30,1997.

i e) Qualifications and training of ECP personnel involved in handling employee i concerns will be described in administrative controls by August 22,1997. l

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l Recommendation 5 i

l Implement Corrective Action for Self-Assessment identified items i

l Resoonse l Actions have either been taken or are underway to address each of the ECP self-l assessment items identified as requiring improvement, including the specific items j highlighted by LHC. The status of our actions is as follows:

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• jigm: The concerns resolution process is flawed in several respects including lack of formalization, inefficiency, and lack of direction regarcing corrective actions i resulting from investigative findings.

i Actions: Revision 1 of the ECP Manual was issued on June 6,1997, to enhance the i formalization and ef5ciency of the ECP process by providing additional specific 4 guidance' on the conduct of activities and the assignment of responsibilities.

Revision 1 also provides guidance on the identification and tracking of corrective actions. Revision 2 of the ECP Manual will be issued by August 8,1997, to 1) i reflect experiences gained with implementing the manual; 2) reflect changes in i

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, B16617 \ Attachment 1 \ Page 5 responsibilities; and 3) describe interfaces with the Employee Concerns Oversight Panel. An experienced consultant has been hired for the specific purpose of enhancing the ECP corrective action process including tracking and assessing corrective action effectiveness. The enhancement of the ECP corrective action process will be completed by August 29,1997.

e j!gn The ECP files are deficient in several areas.

Actions: ECP personnel have begun to review those files in which they were directly involved ~ and resolve documentation deficiencies. One additional experienced consultant has been added to the ECP staff and another will be added by August 1, 1997, for the purposes of reviewing files, resolving documentation deficiencies, and reducing the current backlog of open files. The file reviews will be completed by October 31,1997. )

• l!gm: The working environment for ECP personnel is inadequate in that the space is not sufficient in size and does not provide enough area for private discussions.

Actions: Physical changes to the ECP offices have been completed to provide acceptable working spaces and private discussion areas to address the initial self-assessment item. However, the adequacy of that space is being adversely impacted by the addition of temporary ECP personnel and the need for space for LHC reviewers. That impact is temporary and therefore no additional physical changes are anticipated at this time.

• llgm;, The ECP has an inadequate database management system and lacks '

sufficient report preparation software and hardware. . l Actions: The ECP database is being improved for report generation, data input, data retrieval, and trending. The database improvements will be completed in i coordination with the ECP corrective action process improvements discussed above by August 29,1997. l l

ligm: The ECP staff needs training in several areas to upgrade their skills.

Actions: A new position reporting directly to the Director has been created to oversee training and organizational development. The ECP Staff Training Program has been established and implementation has begun. The primary thrust of this program is to provide permanent NU ECP personnel with training to support an orderly and effective transition from a substantially contractor supported ECP organization to one that is fully supported by NU personnel. The goal is to make this transition by early 1998.

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