B17850, Forwards First Lhc Quarterly Assessment Rept for Assessment Performed 990621 to 990701.NNECO Taking Appropriate Actions to Address Observations in Rept

Forwards First Lhc Quarterly Assessment Rept for Assessment Performed 990621 to 990701.NNECO Taking Appropriate Actions to Address Observations in Rept

ML20210P888
Person / Time
Site:	Millstone
Issue date:	08/11/1999
From:	Necci R, Danni Smith NORTHEAST NUCLEAR ENERGY CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
B17850, NUDOCS 9908130102
Download: ML20210P888 (11)

Text

4 Northeast Rope Feny Rd. (Rom 1W, Toerford, CM6385 Nuclear Energy Malstone Nuclear Power Station Northeast Nuclear Energy Company

' P.o. Box 128

. , ,, Taterford, CT 06385-0128 (860) 447-1791 Fax (860) 444 4277 The Northeast Utilities System AUG I I 1999 Docket Nos. 50-245 50-336 50-423 B17850 U.S. Nuclear Regulatory Commission Attention: Document Control Desk i Washington, DC 20555 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 Submittal of Little Harbor Consultants Second Quarter 1999 Assessment of the Millstone Safety Conscious Work Environment in a Northeast Nuclear Energy Company (NNECO) [[letter::B17566, Application for Amend to License NPF-49,proposing Amend to TS 3/4.7.4, SW Sys, by Adding AOT for One SW Pump Using Duration More in Line with Significance Associated with Function of Pump|letter dated March 2,1999]],* we l outlined our plans to continue to retain the services of Little Harbor Consultants (LHC)  !

inc. following closure of the NRC Order

• on independent oversight of the Millstone )

employee concems program and safety conscious work environment (SCWE).

Specifically, we indicated that LHC would be performing quarterly assessments of the Millstone SCWE during the one year period following closure of the Order.

Additionally, we stated that the LHC assessment reports would be made available to the NRC and the public. Attached to this letter is the first LHC quarterly assessment report for the assessment performed June 21 to July 1,1999. NNECO is taking appropriate actions to address the observations in the report.

There are no regulatory commitments contained within this letter.

l (1) NNECO Letter B17679, " Scope of Services of Little Harbor Consultants, Inc. Following Closure of the October 24,1996 NRC Order," dated March 2,1999.

g a\

(2) NRC Order dated October 24,1996, Requiring independent, Third-Party Oversight of N.NECO's Implementation of Resolution of the Mil; stone Station Employees' Safety Concems issues. The Order was lifted on March 11,1999.

9908130102 990811 PDR ADOCK 05000245 p PDR

7- ,

U. S. Nucl ar R:gul tory Commission B17850\Page 2 If there are any questions on the information provided in this letter, please contact Mr. John T. Carlin at (860)-437-5938.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR: R. P. Necci Vice President - Nuclear Oversight and R latory Affairs David A. Smith Manager - Regulatory Affairs Attachment (1) cc: H. J. Miller, Region 1 Administrator L. L. Wheeler, NRC Project Manager, Millstone Unit No.1 D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 R. B. Eaton, NRC Senior Project Manager, Millstone Unit No. 2 A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3 J. A. Nakoski, NRC Project Manager, Millstone Unit No. 3 H. N. Pastis, ECP and SCWE Oversight, Senior Project Manager

rj. .

Docket Nos. 50-245 50-336 50-423 B17850 l

Attaenment 1 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 Little Harbor Consultants, Inc. (LHC)

Assessment of Millstone Safety Conscious Work Environment (SCWE) -

Performed June 21 - July 1,1999 August 1999 I

l ,, Little IIarbor Consultants, Inc. (LHC)

Assessment of Millstone Safety Conscious Work Environment (SCWE)

Performed June 21 - July 1,1999 I Background In March of this year, the NRC lifted their Order requiring Northeast Nuclear Energy Company (NNECo) to contract with an outside, independent entity to oversee their recovery efforts for a safety conscious work enviromnent (SCWE) at their Millstone site.

Prior to the NRC action, NNECo had advised the NRC that they intended to contract with LHC to perform quarterly assessments of the SCWE at Millstone until they were satisfied that there was no longer any value added by doing the assessments. This repon provides the methodology, observations made and initial company responses to the first assessment. The assessment was conducted betweer. June 21 and July 1,1999. l II Methodology The principal mode of our essessment was to interview indenduals from all levels of management and across the workforce. We spoke direct!y whh over 60 people,18 of whom had requested the opportunity to speak with us, the remainder at our request.

We attended many meetings over the two week period, observing hov, management and workers interacted, and, where appropriate, how the conduct of the meetings compared with those held prior to lifting of the order. Examples include ECP staff meeting, SCWE group meeting, Executive Review Board (ERB) meeting, Harassment, Intimidation, Retaliation and Discrimination (HIRD) refresher training, Human Resources (HR) business partners meeting, and a weekly meeting of all station upper management, the Station Alignment Team (SAT).

We reviewed ECP files completed since we left the site in March ( 16 files ) which dealt with potential 10CFR50.7 (HIRD) related events.

We reviewed ECP Program reports for the months of March, April and May, ECP Self-i Assessments, ECP Assessment forms (filled out by users of the program since November), Workplace Survey Reports for the 1" Quader of 1999, the Culture Survey of December 1998, personnel recognition documentation, Leadership Surveys, the new Employee Concerns Oversight Panel (ECOP) Charter and the initial ECOP 1" Quarter Repod.

We used the four Millstone strategic objectives that apply to the safety conscious work environment as the principal focus of all our activities. Those objectives are contained in the Focus 99 document which management has made available to all on site who want it.

They are:

Page1

n ..

Establish and maintain high confidence that employees are willing to raise !

l ,,

concems.

Establish and maintain high confidence that management is effective in evaluating, prioritizing, and resolving employee issues.

Establish and maintain high confidence that the Millstone Employee Concerns Program (ECP) is continuously improving and effective in addressing issues raised by employees that are not resolved satisfactorily by other means within the organization.

Establish and maintain high confidence that line management is effective in identifying, investigating and resolving areas of concem and 10 CFR 50.7 related events, where the attributes of a SCWE are challenged or lacking.

III Observatioc and Responses The observations made during the assessment have been grouped for convenience under the strategic objectives which are most relevant to the observations. In some cases they could fall under more than one objective, but have not been repeated. The specific observations have been italicized and followed immediately by management's responses.

Strategic Objective: Establish and maintain high confidence that employees are willing to raise concerns.

Most of those with whom we spoke indicated that they that they felt free and were obligated to raise an issue or concern. Every individual with whom we spoke would raise a nuclear safety concern through one of the channels available t them. However, there were two specific issues raised by more than one individual which needed management's attention. First, numerous employees expressed an unwillingness to question management commitments / decisions out offear ofbeing labeled a " barrier" This wasparticularlyin the context ofdeadlines, which the individualsfelt were unrealisticfor various reasons.

The individuals wereprepared to takeflakfor missing the deadline rather than air the reasons why the deadline was not realistic and run the risk ofbeing labeled a " barrier".

This is a variation of" shoot the messenger". The second issue wasfrom some involved in the upcoming supervisory cascade (theprocess used to reduce and realign site supervision). They expressed an unwillingness to raise issuesforfear that it would impact their chancefor selection.

Management has indicated that these observations are of particular conce n to them because they could be precursors that challenge a safety conscious work environment.

Management has planned a series of actions to reiterate Lee Olivier's ext ectations of employees raising issues and his expectations for management responding thoughtfully and timely. "To the Point" will be used for general communication, the Station Page 2

y .

Alignment Team (SAT) forum for communicating with senior station management, and

' ail Directors will communicate directly'with their department personnel regarding management's expectations. ECOP and the SCWE group will continue their monitoring i of decision-type meetings and report their recommendations, as appropriate, to the Chief l Nuclear Officer (CNO) and VP, Human Services. Nuclear Oversight will also be monitoring these areas. The CNO is planning an off-site meeting with all Millstone management following the supervisory cascade where the safety conscious work environment will be one of the discussion topics.

Another observation that could impact this strategic objective area was the identification  ;

ofthree examples ofconfirmed " chilling effect " by ECP in three different site organizations. No apparent action was taken to identifypossible unreported safety concerns, nor was there any apparent action taken to address the " chilling efect" {

through the same methodology which was used while under the NRC Order. l Management has acknowledged that there was a lack of clear communication between the ECP, SCWE and affected Officers and Directors concerning the three examples.

Management has committed to a number of actions designed to reinstate the previously used processes involving the ECP, SCWE and Rapid Response methods to assure that there is a complete communication of such matters in the future, that there is timely consideration (reinstated daily meetings of the " people team") of such issues, that there is ;

clear assignment of responsibility for any required actions, and that such actions will be l tracked by the site Action Item Tracking & Trending System to ensure completion. j Further, ECP will document such discussions in the Chronology section of the ECP case files. This will provide further validation that all the proper steps have been taken. Care should be taken to assure that the tracking ofissues and actions is at a level of significance which will avoid clogging the system with items of such low importance that there is no value added by tracking them. I l

Another observation was made concerning the use ofan intermediaryfor bringing concerns to the ECP rather than the individual raising the issue. Five ofsixteenfiles examined used the intermediary route. Whilepermitted under ECPprocedures, does this raise the question that the original concernee was afraid to raise the concern?

l i

Management responds that of the five concems cited, three were brought by an ECP j representative or ECP management based on conversations with employees or directed by  ;

management to do so based on infonnation coming to management. The other two were raised by individuals other than the concemed individual, one by a peer rep and the other j by a fellow employee. Management notes that concerns raised by an intermediary or peer rep are typically coded confidential or anonymous. Of the five concems noted four were coded confidential or anonymous and confidentiality was waived for the fifth. Trending of workers requesting confidentiality or anonymity shows a slight improvement when compared with the average in 1998. ECP management has committed to determine if the current level of confidemiality/ anonymity is an indication of a decreased trust level, and  ;

to examine the appropriateness ofintermediary usage for bringing concerns to ECP.

Page 3 .

. \

\

l l

Strategic Objective: Establish and maintain high confidence that management is  !

' effective in evaluating, prioritizing and resolving employee issues.

We observed that there were a number ofexamples where there was a lack oftimely feedback and communication to employees.

On reflection, management has acknowledged that they have recently been inconsistent and untimely in responding to employee issues. Problems such as grievance resolution, payroll and performance management issues have not always been addressed expeditiously by the line and HR. Management has endorsed the general principal that people bring issues forward because they think they are important and deserve at least an acknowledgment within two business days of requesting information or asking a question. Management also holds the expectation that each leader and member of a support organization must hold themselves personally accountable for responding to people.

Management has committed to use all the avenues available to them to reinforce these expectations and to do so repeatedly until it becomes part of the fabric at Millstone. 1 Another observation was that the lack oftimely resolution ofissues and concerns by employees has resulted in concerns going outside the company, wasted time and energy and embittered employees.

Management recognizes the importance of timeliness ofissue/ concern resolution. They have taken the following steps to provide greater assurance of achieving timely resolutions.

Re-establishment of the daily People Team meetings. Documenting follow up and status discussions at subsequent meetings.

HR has been realigned to establish clearer responsibility and accountability. The staffing function has been separated physically and organizationally from the Business Partners. A separce projects group has been established. Expectations have been defmed and communicated regarding timely responses and sharing ofinformation between Business Partners.

)

The grievance resolution process is being streamlined to reduce the time l

required to respond fully to grievances. l The weekly SAT meetings will have employec/ people issues added as a standard discussion topic. ,

HR will be using the Joint Investigation System (JIS) to help manage and track internal HR issues, {

i i

Strategic Objective: Establish and maintain high confidence that the Millstone ,

Employee Concerns Program (ECP) is continuously improving and effective in  !

addressing issues raised by employees that are not resolved satisfactorily by other c

Page 4

~

y ,

means within the organization.

From almost every perspective the ECP gets continuing high marks. Overall morale within the ECP is markedly improved since we left, good interaction during intemal staff meetings, excellent training, good briefing of officers by the ECP Director, the ECP monthly reports continue to improve in their content and value, and self assessments are excellent.

While there are some users of the program who were complaining about not being kept informed about the progress of their specific case, there was also a comment in March by a user which bears repeating here, "I was very impressed with the way my case was handled and, although my case was not safety-related, it makes me very comfortable knowing first hand that this program does work.....I wish there was some way that the concemed citizens (in newspapers) could witness first hand a case handled by this program. I think they would be impressed that all issues, safety-related or not, are addressed......everyone from first phone call to the secretary to the final letter were very professional."

We mentioned earlier the cases where confirmed chilling effect had not been effectively handled once the information was passed on by ECP. Thepreviously mentioned actions by management shouldprovide adequate compensationfor this observation.

. Another observation was thatfor some substantiated concerns there was no identification oftimely corrective actions. ECP has committed to thefollowing actions:

Determine ifimmediate corrective actions are necessary for employee issues and communicate them to the People Team.

Stop extensions of due dates unless necessary to support other organizational priorities.

Eliminate backlog of corrective actions.

Evaluate if management is effective in implementing corrective actions to resolve employee issues.

Communicate (if appropriate) ECP corrective actions through an ECP Newsletter to be developed.

We observed that some issues identified in ECP investigations do not result in self-initiated reviews.

ECP management reviewed case files from the last six months of 1998 and compared the number of self-initiated concems and issues with the first six months of 1999. There have been slightly higher rate of self-initiated issues during 1999 than the last six months of 1998.' Based on this fact ECP management is confident that issues are being opened by ECP management and investigators based on infonnation uncovered during the course of investigations. However, ECP management will use the LHC observation as a leston teamed with the ECP staff to provide additional assurance that the proper sensitivity is Page 5 j

o.

maintained regarding opening of additional issues based on information identified during

• ihvestigations.

l We observed a customer satisfaction ratio of 79% (19 positive responses out ofa total of 24 respondents).

Management responded that the comparable figure cited by LHC in October of 1998 was 80%. They felt that the 79% figure indicated that ECP is still viewed as an effective attemative for the identification and resolution of employee concerns and that there has been no backsliding in this effectiveness.

Strategic Objective: Establish and maintain high confidence that line management is effective in identifying, investigating and resolving areas of concerns and i 10CFR50.7 related events, where the attributes of a SCWE are challenged or lacking.

We observed that HIRD events continue to occur.

i Management responded that although HIRD events continue to be identified by ECP, the  !

average number of HIRD issues is dropping. In 1998, the average was 16 HIRD related I issues out of 21. In 1999, the average is 8 out of 21 per month. This is a significant reduction. )

i Management has stated that they are not satisfied with these numbers and has identified some corrective measures as a result of the 1" Quarter SCWE Workplace Survey. First, i the assimilation process for all supervisors after the supervisory cascade is completed will be specifically directed toward establishing, maintaining and building trust between the supervisor and direct reports. Supervisors will not simply be given this message, they will be given the tools and support to ensure it is achieved. This will be accomplished by formal planning of the assimilation and utilization of existing support groups (HR Business Partners and SCWE facilitators) for addressing performance issues in the line groups.

We observed a lack oftimely and effective action (several instances where chilling effect indications were not resolved in a timely manner). Further, that the People Team was not meeting its originalpurpose, and a lack ofcooperation between groups responsiblefor SCWE.

1 Management has committed to ensuring that the People Team responds to issues in a timely and effective manner. Daily People Team meetings have been resumed and will  !

follow a structured format. Each issue will be evaluated to determine if the Rapid j Response Process should be applied (eg., for confirmed existence of a chilling effect).

Each meeting will answer the following questions for each issue:

Who is responsible for the resolution of the problem?

Page 6

- 1 Ilow can the People Team help?

'a' {

What course of action should be taken, including key action steps,

{

responsibilities, and due dates? '

What is the deadline to resolve the issue? ,

Schedule a management accountability session for resolution ofissues within I their specific area of responsibility. Line management will be responsible for the development and implementation of SCWE action plans. Line management will present their action plans to the People Team for concurrence.

Additionally, action items will be documented from each meeting and will be reviewed at each subsequent meeting to ensure completion.

We observed that there had been an 01 investigation ofretaliatory discharge and a DOL  ;

complaint with no Company knowledge about the contractor's underlying issues or apparent investigation ofthe retaliation claim.

The Legal Department points out that the particular termination at issue had been the subject of an Executive Review Board (ERB) evaluation. It has since been reviewed by ,

outside counsel, and outside counsel concluded that there was no credible evidence that I the termination was in retaliation for raising safety concerns. Legal acknowledges that the claim could have been pursued more vigorously at the time it arose.

The DOL complaint raised the same issues previously looked into by outside counsel.

Legal has taken the following steps:

Legal will provide the DOL complaint and documents provided to OI to ECP for a determination regarding fmther review.

Legal will provide in the future all new DOL complaints to ECP and discuss with the Director whether and investigation should be conducted.

Legal will meet periodically with the ECP Director to advise him of newly initiated OI investigations and whether an ECP investigation should be initiated.  ;

In-house counsel will emphasize the need to keep everyone properly informed l regarding any new DOL or OI matters that have been initiated.

We made a general observation that there was a perceived lack ofstrategyfor major issues affectingpeople.

Managemer.t has acknowledged that there is an apparent lack of overall strategy on major issues affecting people and that they need to effect improvement in this area. They have committed to the following initiatives:

11R is developing an overall communication strategy that will serve as the central repository framework.

IIR reps will attend other department meetings to address questions and provide Page 7

, information on major issues.

HR will conduct "in-touch" sessions with employees. This will allow for direct feedback which can be used to modify the process in a timely manner.

Millstone officers will also conduct "in-touch" sessions with small groups of employees to obtain direct feedback.

All major issues affecting people have been placed on the SAT's level I schedule.

This will help increase the level of awareness of HR issues affecting people.

We made the general observation that there is a declining conpdence in HR.

In addition to the previously mentioned changes and enhancements in HR, management has committed to conducting quarterly workplace surveys to monitor employees confidence in HR. A section of the survey has been designed to measure satisfaction with specific services and overall customer satisfaction.

We observed that the new ECOP charter is a major improvement, that the 1" Quarter ECOP report is an excellentpiece ofwork, and that based on interviews with all ECOP members their dedication and understanding ofthe role ECOP shouldplay was exemplary. It is a very sound and well balancedprogram which shouldserve a continuing, value-added role at Millstonefor some time to come.

IV Conclusions First, we believe that Millstone management is sincerely dedicated to maintaining a safety conscious work environment. We also believe that they are dedicated to achieving the kin'ds of change at Millstone which will allow Units 2 and 3 to continue operating in I the competitive environment. The combination of these two objectives will challenge

{

management and the workforce as they have never been challenged before. Some of the

]

" slippage" noted in our observations we think was due to a desire to return to normalcy a bit sooner than circumstances at the site warranted. Management's responses to our observations, ifimplemented, should greatly enhance their probability of achieving success in reaching their goal of continuing to safely generate electricity from Millstone for years to come.

It is our consideredjudgement that the overall state of the safety conscious work l environment is essentially where it was when we left our assignment ofindependent oversight earlier this year. Some areas have improved while others have slipped. The result is best described today as it was six months ago, a fragile safety conscious work environment. Whether this state of fragility is improved is entirely in the hands of management. Effective communication of management's expectations of themselves and of the workforce, holding everyone accountable and responding timely to all concerns are the keys to success.

We will be performing another assessment in the fall and will be very attentive toward the implementation of management's responses to our observations.

Page 8

>