IR 05000245/1998215
| ML20154L227 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/14/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20154L221 | List: |
| References | |
| 50-245-98-215, 50-336-98-215, 50-423-98-215, NUDOCS 9810190183 | |
| Download: ML20154L227 (24) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket Nos.
50-336,50-245 and 50-423 Report No.98-215 License Nos.
Licensee:
Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385 Facility:
Millstone Nuclear Power Station Dates:
August 24 - 28,1998 Team Leader:
Helen N. Pastis, Senior Project Manager l
Evaluators:
Robert DeFayette, NRC Consultant l
Steve Dembek, Project Manager for Millstone Unit 1 l
Richard Urban, Millstene Project Engineer, Region i Approved by:
William M. Dean, Project Director, Millstenc Project Directorate, NRR Helen N. Pastis, ECP and SCWE Oversight, Senior Project Manager i
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9810190183 981014 i
PDR ADOCK 05000245
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. TABLE OF CONTENTS Page Executive S um mary.......'.................................................
i 1.0 Purpose of the ECP Evaluation Team...................................... 1 2.0 Review Methodology.................................................. 1
- 3.0 Composition of the Team............................................. 1 4.0 Backgrou nd......................................................... 1 5.0 Employee Concerns Program........................................... 3
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5.1 EC P Organization.............................................. 3 5.2 EC P Training................................................. 5 5.3
- EC P a nd H R interface........................................ 6 i
j 6.0 Employee Concerns Oversight Panel.................................... 7
7.0 Safety-Conscious Work Environment
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7.1 SCWE Staffing and Organizational Support........................... 8 7.2 Recent Change in the Position of Vice-President of Human Services....... 9
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7.3 Pending Management Reorganization.............................. 9
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7.4 Management Surveys......................................... 10 7.5 Identification and Resolution of Focus (Problem) Areas................ 11 7.6 SCWE Long-Range Plan....................................... 13 7.7 Lessons Learned Review....................................... 14
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7.8 Self-Assessments and the Executive Review Board................... 14 7.9 Key Performance indicators..................................... 15 7.10 Site Response to LHC Recommendations.......................... 17 7.11 SCWE Training.............................
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EXECUTIVE SUMMARY On October 24,1996, the Dir'ector of the Office of Nuclear Reactor Regulation issued an Order to Northeast Nuclear Energy Company (NNECO), the licensee for Millstone, requiring establishment of (1) a comprehensive plan for resolving the Millstone station employees' safety concerns, (2) an independent third-party oversight organization, and (3) a plan developed by the independent third-party organization for overseeing NNECO's implementation of the employee concerns program plan.
A team was formed to evaluate whether NNECO has improved sufficiently and has demonstrated sustained performance in maintaining a safety-conscious work environment (SCWE) to allow NRC to lift the Order, and whether the conditions that led to the requirement of the third-party oversight have been corrected at Millstone. This was the second evaluation of the Millstone employee concerns /SCWE programs. On December 8 - 12,1997, and January 5 - 9,1998, the NRC conducted its first team evaluation of these programs.
On August 24 - 28,1998, the NRC conducted its second team evaluation. The team attended meetings, interviewed personnel, studied information, and observed various training sessions.
The team members were Helen N. Pastis, Team Leader; Robert DeFayette, NRC Consultant; Steve Dembek, Millstone Unit 1 Project Manager; and Rick Urban, Region 1 Project Engineer.
Everyone on the second team had also participated in the first evaluation. The team used as
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guidance inspection Procedure (IP) 40001, * Resolution of Employee Concerns."
The material that follows identifies certain program areas reviewed by the team and summarizes the team's findings in these areas.
Findinas Emolovee Concerns Proaram (ECP): The team evaluated the ECP organization. The ECP organization continues to possess the independence, resources, and management support necessary to perform thorough, unbiased investigations. The ECP continues to function well.
ECP Trainina: The program for training Millstone staff on the ECP program was informative and effective.
ECP and Human Resources (HR) Interface: The interface between the ECP and HR organizations continues to be effective. The two organizations work together closely and share information to the benefit of both organizations.
Emolovee Concerns Oversiaht Panel (ECOP): During the team's evaluation, ECOP's role was being redefined and ECOP was scheduled to be reorganized shortly. The ECOP focus group reports and the quarterly reports are useful products for management, but the most recent quarterly report was not well balanced and was not well-received by the ECP.
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Safetv-Conscious Work Environment (SCWE): The team evaluated the SCWE by reviewing of
. the following material:
SCWE staffing and orbanizational support,
Management surveys, e
' identification and resolution of focus (problem) areas, e
e Lessons teamed,'
e Self-assessments, Executive Review Board reports, e
Key performance indicators (KPis) with particular attention to concems of harassment, e
intimidation, retaliation, or discriminations (HIRD),
Site response to recommendations made by Little Harbor Consultants P.HC).
o NNECO continues to improve the SCWE at Millstone. The overwhelming majority of employees are willing to raise concems, and of those who have used the ECP, only a relatively few stated they would n1 use the program again. Management has shown it is willing and capable of immediately c.scoming involved to resolve problems and concerns as they arise, indicating that the programs in place are working. Further evidence of this is that LHC has stated that although it is involved in assisting NNECO in responding to and resolving concerns, it is not involved nearly as much as it was only a few months ago and believes it is approaching the time when it will not be needed for third-party oversight.
Followuo issues at the October 26.1998. Evaluation I
' During a public exit conducted September 22,1998, the team noted eight issues that will be the focus of another evaluation scheduled for the week of October 26,1998: Issues 1-3 are related to the Employee Concerns Program; lssues 4-8 are related to the Safety-Conscious l
Work Environment.
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1.
. Emolovee Concerns Proaram (ECP): The team will continue to monitor the recent issues that developed in the ECP organization during the week of its evaluation.
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ECE.pnd Human Resources (HR) Interface: The team will continue to monitor the plans for, and the ability of HR to assume some of the ECP work load, as outlined in NNECO's Transition Plan.
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Emolovee Concems Oversiaht Panel (ECOP): The team will evaluate ECOP's new role to assess its effectiveness and how some of the ECOP functions will be incorporated within the SCWE and HR functions.
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SCWE Lono-Ranoe Plan: The team will continue to monitor the transition of the SCWE from a recovery organization to an operating organization. As Millstone is going through this transformation and the resources for the various programs are being reduced, functions are being transferred, and managers are being changed, and programs are evolving, the team will coritinue to monitor Millstone's performance with respect to its l
Performance and Transition Plans.
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Recent Chance in the Position of the Vice-President of Human Servicas: During the team's evaluation the position of the Vice-President of Human Services was in transition. The team will continue to monitor the effect of this transition on the organization's effectiveness.
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Pendina Management Reoraanization: The team noted that a lot of thought has been given to the pending reorganization and to acquiring professional assistance in the formulation of the reorganization. However, the team also noted that the pending reorganization had not yet been announced to the site employees. Subsequent to the team's evaluation, the team noted pertinent articles in the licensee's newsletter, "To The Point," and in roll-out meetings. The tearn felt that given the reaction of employees to previous substantial personnel reductions, the licensee's efforts in this area required additional monitoring.
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Oversiaht of the SCWE: The team noted that plans for oversight of the SCWE to replace the role of the third party oversight organization had not yet been developed.
The team will continue to monitor the licensee's development of plans for oversight of SCWE by organizations both internal and extemal to NNECO.
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SCWE Training Proaram: The SCWE training program has continued to operate satisfactorily since the last evaluation, and since restart of Millstone Unit 3. The team will continue to monitor long-term plans for the SCWE training program that have not yet been finalized, such as the SCWE refresher training for supervisors and managers, SCWE continuing training, and enhancements to current SCWE training courses based on lessons learned.
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Evaluation Details 1.0 Puroose of the ECP Evaluation To evaluate whether (1) Northeast Nuclear Energy Company (NNECO) has improved sufficiently and has demonstrated sustained performance in maintaining a safety-conscious work environment (SCWE) to allow the NRC to rescind the October 24,1996, Order and (2) the conditions that led to the requirement of the third-party oversight have been corrected at Millstone Nuclear Power Station.
2.0 Review Methodoloav The team used as guidance inspection Procedure (IP) 40001, " Resolution of Employee Concems." During the week of August 24 to 28,1998, the team attended meetings, interviewed people, reviewed pertinent information, and observed various training sessions.
The team incorporated the information that was available to it during this evaluation and considered the latest and most up-to-date information before issuing its report. Regarding evaluations of SCWE elements, information obtained from onsite monitoring of activities, both before and after the team's evaluation, were used to supplement the findings in this report.
On September 22,1998, the team leader held a public exit interview with NNECO.
3.0 Comoosition of the Team The team was led by Helen N. Pastis, who is a Senior Project Manager in the Office of Nuclear Reactor Regulation (NRR). Robert DeFayette is an NRC consultant and a former Director of Enforcement and Allegation Programs in Region Ill. Stephen Dembek is the Millstone Unit 1 Project Manager. Richard Urban is the Region i Millstone Project Engineer.
4.0 Backaround On October 24,1996, the Director of NRR issued an Order to NNECO, the licensee for Millstone, requiring the development of (1) a comprehensive plan for handling the Millstone
Station employees' safety concems, (2) an independent third-party oversight organization, and
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(3) a plan developed by the independent third-party organization for overseeing NNECO's implementation of the comprehensive plan.
The NRC staff has performed the following activities to ensure that NNECO's programs for l
handling safety concems and the independent third-party organization program (ITPOP) will be effectively implemented:
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Reviewed the Millstone employee safety concerns comprehensive plan for reviewing
and dispositioning safety issues raised by employees of NNECO.
Approved the selectidn of the independent third-party oversight program organization to
ensure that the organization is comprised of qualified individuals who will conduct the review adequately and independently of NNECO. The ITPOP organization will oversee the implementation of the NNECO Employes Concerns Program (ECP).
Approved the ITPOP plan which audits the implementation of the Millstone ECP. The
ITPOP review must be comprehensive, incorporating appropriate audit and technical disciplines so the NRC can be confident that NNECO has been thorough in identifying and resolving of employee safety concerns at Millstone.
During its January 1998 evaluation, the team found that NNECO had not sufficiently developed plans to address actions for maintaining and enhancing an SCWE beyond the restart of a
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Millstone unit. Specifically, processes for maintaining the ECP and SCWE infrastructure, monitoring performance (including' recognition of program degradations), and phasing out oversight organizations were not addressed in NNECO's planning documentation.
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In February 1998, subsequent to the onsite team evaluation, NNECO provided the NRC with its document, " Progress Toward Restart Readiness and Long-Term Improvement at Millstone Station." The plan identified key performance indicators and self-assessment activities that will be used to continue monitoring performance at Millstone. It organized the plan into five strategic areas: safety, operating excellence, work environment, organization effectiveness, and
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l extemal relations. SCWE is one of three subsections of work environment. However, the plan
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was preliminary and incomplete.
In a March 31,1998, letter, NNECO included plans, commitments, and actions for monitoring and maintaining an SCWE past the restart of Millstone Unit 3. Attached to that letter was the 1998 - 2000 Performance Plan for the Work Environment Area. The SCWE portion of the work l
environment area identified a set of actions to implement the future tri 1sition of various
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functions and work groups from the current recovery organization to a future operational organization. On April 24,1998, NNECO supplemented its March 31 letter with a more detailed discussion of the organizational changes, the decision-making process, and the performance
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measures that NNECO planned to use to guide that transition.
Regarding actions required by the October 24,1996, Order, the NRC staff has commented on NNECO's comprehensive plan, approved the third-party organization that oversees the implementation of the comprehensive plan, and approved the third-party's oversight plan. In accordance with the Order, the third-party organization, Little Harbor Consultants (LHC), will continue to oversee the effectiveness of Millstone's Employee Concerns Program (ECP) and SCWE until NNECO has demonstrated by its performance that the conditions that led to the Order have been corrected to the satisfaction of the NRC.
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On April 24,1998, the staff fonvarded to the Commission SECY-98-090, " Selected Issues Related to Recovery of Millstone Nuclear Power Station Unit 3." In that paper and in a May 1, 1998, meeting with the Comrrjission, the staff concluded that the ECP and SCWE were
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acceptable to support restart of Unit 3. The staff noted that it anticipated that continuation of the third-party oversight would be required for 6 months beyond restart to allow for evaluation of the licensee's continuing. performance in the ECP and SCWE areas. Attached to the Commission paper was the staff's evaluation containing a detailed assessment of these issues.
5.0 Emolovee Concerns Proaram Evaluation 5.1 ECP Oraanization
Evaluation Scone Using IP 40001, the team evaluated the licensee's ECP organization by evaluating the staffing of the ECP organization, reviewing ECP procedures, and conducting interviews with ECP staff and managers. The team also reviewed several completed case files and the latest external assessment of ECP.
Observations and Findinas The team reviewed the current staffing of the ECP organization. During the team's previous assessment, the Director of ECP stated that his goal was to eventually have 10 investigators The team concluded that the number of investigators (currently 9) was appropriate to effectively h9ndle the number of submitted concerns. This conclusion is based on (1) the sustained low backlog of uncompleted investigations, (2) statements made by the majority of investigators (all 9 investigators were interviewed) and ECP managers, and (3) a review of the qualifications of the investigators. The team found that the investigators have the experience and qualifications that allow them to independently reach reliable conclusions.
The team interviewed the Director of ECP, his managers, and staff regarding their
' independence from the line organization and the level of senior management support. The ECP managers noted that each investigator has to address any impediments to the
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investigations (including any imposed by the line organization)in their reports. The reports indicate continued good support from the line management, and the majority of investigators interviewed by the team agreed with the observation. As an indicator of line management's confidence in ECP, the Director of ECP stated that he sometimes gets calls from line managers seeking advice on potential ECP issues. The ECP continues to maintain independence from the line organization by using its own investigators and ensuring their conclusions are based on the facts discovered during the investigation. When there was a potential conflict ofinterest,
ECP used outside investigators to perform the investigation. This practice is expected to continue in the future. As an indication of continued support from upper management, the Director of ECP has the capacity to report directly to the highest levels of management to ensure his views are appropriately conveyed.
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l ECP has no current plans to significantly reorganize. However, as part of the overall NNECO reorganization currently in planning, the ECP management positions will be subject to open bidding. Although the reorganization has the potential for significant turnover of ECP managers, the team consider's the current procedures and ECP staff are robust enough to support management turnover without degrading the effectiveness of the ECP.
i The team also reviewed several of the ECP's administrative controls. The team found the
l administrative controls to be comprehensive and well written. For example, the team reviewed l
the licensee's latest revision of the Employee Concerns Processing Manual, which became l
effective September 4,1998. The revision was based on ECP's experiences and lessons
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leamed. The team attended a training session introducing the revised manual to the ECP staff.
The training was well attended and resulted in a good exchange of information and suggestions for further improvements. The team found the new manual to be very thorough and well written. It demonstrated the licensee's commitment to continually improve the ECP program.
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l The team noted that the licensee's process for quickly resolving concerns that do not require
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formalinvestigations was a worthwhile tool. This process reduces the length of time it takes to l
close issues. An important aspect of this process is that investigators still have the ability to i
use the normal investigation process if they find the issue no longer complies with the rapid-j resolution criteria.
The team reviewed five ECP case files that were either closed or resolved between June 1 and August 19,1998. These were files that the ECP had classified as involving potential safety issues or potential harassment, intimidation, retaliation, or discrimination (HIRD). A closed
concern is defined as one in which the investigation and corrective actions have been
completed. A resolved concern is one in which the investigation was completed but the
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corrective actions have not been completed. Four of the key findings by the team are:
(1)
The team found that all ECP case files properly defined the issues of concem and had well-designed plans for investigating the issues. The team found that the licensee performed thorough investigations for all the case files reviewed and that the corrective actions were appropriate to close or resolve the issues.
l (2)
With one exception, the team found the investigation reports were well supported and l
consistent. The one exception involved a report that was confusing in its conclusions.
The team concluded that this was a minor documentation concern and did not indicate a l
significant weakness in the ECP.
l (3)
The team found that the ECP organization sent a closure letter to the employees who
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l raised the concerns, where applicable, describing the resolution of their issues in all the case files reviewed. The team also noted that employees were frequently contacted regarding the status of the investigation of their concem.
(4)
The team noted that all the case files, unless sent anonymously, contained a l
confidentiality statement. An employee could either request confidentiality or could waive confidentiality. Confidentiality assures the employee that the ECP would take all reasonable steps to ensure that his identity would be protected.
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l The team reviewed an external assessment of the ECP performed by two employees of GPU
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i Nuclear between June 17 and June 19,1998. The assessment report was issued on July 16, 1998. The objectives of the assessment were to (1) determine the overall effectiveness for establishing an alternate path'for employees to raise concerns; (2) assess the adequacy of the l
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program when compared to industry document NEl 97-05, " Employee Concems Program Process Tools in a Safety Conscious Work Environment," and NRC Inspection Module 40001; and (3) make recommendations for improvement as necessary. To meet their objective, the two GPU employees reviewed procedures and interviewed ECP personnel, senior Millstone management, people on the Employee Concerns Oversight Panel (ECOP) and selected line managers. The two GPU employees performing the assessment concluded, "The ECP at Millstone provides all personnel with an effective program for problem resolution that assures a safety conscious work environment at the Millstone Nuclear Power Station." The staff found that the report mainly contained favorable comments on the ECP. The staff did not find any l
recommendations listed by the GPU employees that would conflict with the staff's overall l
conclusions regarding ECP.
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l Additionally, the March 1998 ECOP survey results show that 90 percent of those employees l
who have used the ECP would use it again. This is an improvement from the January 1998 survey which showed that only 75 percent would use ECP again.
I Conclusions The team found that the ECP organization continues to possess the independence, resources, and management support necessary to perform thorough, ur, biased investigations. The conclusions of the ECP cases reviewed by the team were properly supported by the licensee's investigations, corrective actions were appropriate to resolve the issues, and communications l
with the concerned individuals were adequate. The ECP was adequately defining the
concerned individuals' issues. The ECP was properly protecting the identities of those individuals bringing concems to the ECP. An external assessment of the ECP organization conducted by GPU Nuclear personnel was very positive. The employee survey results continue to rate ECP highly. Therefore, the team concludes that the ECP continues to function well.
i Since the team's last evaluation, NNECO has made additional modifications in the ECP to improve the efficacy of the program. The team will continue to monitor the recent issues that developed in the ECP organization during the week of its evaluation and any other issues that
emerge in the near term.
5.2 ECP Trainina Evaluation Scoce l
The team evaluated the ECP training given to the Millstone staff and to some contractor l
employees by reviewing the lesson plan and attending a training session.
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Observations and Findinas The team observed the portion of the " Partnership Beyond 2000" training given to employees (the team observed a sessiori attended mainly by contractor personnel) regarding the ECP. A member of the ECP staff gave the training. The training adhered to the approved lesson plan, was very informative, and provided useful information regarding the different purposes of the ECP, ECOP, SCWE, and LHC. Overall, the ECP training session was well planned and executed. On the basis of the responses from the audience, the licensee's training program was effective.
Conclusions The team concluded that the licensee's program for training Millstone staff on the ECP was informative and effective.
5.3 ECP and Human Resources (HR) Interface Evaluation Scooe The team evaluated the ECP and HR interface be interviewing the Director of ECP and the
. Director of HR.
Observations and Findinas The team noted that the ECP and HR managers and staff continue to meet often to address HR-related concerns. For example, several HR staffers were working directly with ECP staff to provide information related to current ECP cases. Also, the Directors of HR and ECP meet daily to discuss significant issues, and one HR person has been temporarily assigned to the ECP as an investigator. Both ECP and HR have been working together to ensure the planned major reorganization will be conducted fairly and objectively. The evaluator found that the reorganization process, outlined by the Director of HR, was extremely thorough and well planned, in addition to the changes that may occur from the site-wide reorganization, the licensee expects to realign some of ECP's responsibilities once Unit 2 has restarted. ECP will only investigate those concerns involving nuclear safety issues and those alleging discrimination on the basis of engaging in a protected activity. HR will assume responsibility for investigating all concems involving pay, benefits, discrimination unrelated to protected activity, and similar issues. The Director of HR noted that her organization, is already receiving these types of concems directly from employees. This is an indication of the renewed confidence the
employees have in HR. On the basis the employee survey results and management interviews, I
the team is confident HR will be capable of successfully assuming this added responsibility in the future.
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Conclusions The team concluded that the interface between the ECP and HR organizations continues to be effective. The two organizations work together closely and share information to the benefit of both organizations. The team will continue to monitor the plans for, and the ability of HR, to assume some of the ECP work load.
6.0 Emolovee Concerns Oversicht Panel l
Evaluation Scone i.
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The team evaluated the effectiveness of the licensee's Employee Concems Oversight Panel l
(ECOP) since the last NRC evaluation, and reviewed how this panel will continue to function in the future. Evaluation criteria used were applicable portions of the licensee's Performance Plan L
and the NRC's IP 40001.
l Observations and Findinas j
During the previous NRC evaluation, the ECOP was determined to be functioning effectively,
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I but appeared overtaxed in its ability to perform all its activities.. Also, some documentation I-weaknesses were noted. Since that evaluation, the licensee determined that the ECOP would l
be restructured to better serve the needs of the future Millstone organization. Much of ECOP's
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efforts since the last NRC evaluation were devoted to developing a " Going Forward Plan,"
which presented different options for the new ECOP, to the President /CEO-Nuclear. Three l
options were developed, and the President /CEO-Nuclear selected the third option, which is an ECOP comprising of four full-time panelists, one full-time administrator, and clerical support.
Specific duties for the new ECOP have not yet been formalized, but the licensee intends for the new ECOP to be operational by November 1,1998. In the meantime, original ECOP members
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are slowly being moved into various organizations on site with some also maintaining their
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former duties. A process is being developed to select new ECOP panelists and an j
administrator so that there can be some overlap and turnover.
l ECOP personnel interviewed by the team recommended the following activities for the new panel; oversight of ECP/SCWE, HIRD cases, and Executive Review Board meetings and decisions. The President /CEO-Nuclear perceives that the future emphasis of ECOP will focus on assessing the organizational climate, i.e., being his unofficial eyes and ears. The team will continue to monitor the development of the new ECOP.
i The team reviewed four focus group reports issued between June and August 1998. The subjects of the four reports were the ECP organization, Unit 3 operations (twice), and Unit 1 operations. The reports were issued to the President and CEO-Nuclear and the manager of the particular organization. The reports contained information that would be of interest to management and also contained recommendations. The team found the reports beneficial because they are a real-time summary of the health within an organization, and could help
management deter problems before they escalate.
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The team also reviewed another ECOP product, its second-quarter report issued on August 13, 1998. The report assessed three of the licensee's four SCWE attributes and found them all to be satisfactory. Although the,re were good findings in the report, it was very critical of the ECP organization in its efforts related to four individual cases investigated by the ECP. The ECOP report noted that the individuals felt that they were attacked by the system and that their interviews were accusatory and threatening. All four individuals sought legal counsel.
Additionally, the report stated that ECP management is defensive when presented with negative feedback or questions regarding investigations. When the report was issued, it was not well-received by the ECP organization. The ECP organization was surprised by the content of tne report and felt that the criticisms were unfair. ECOP's position was that it had adequately shared its findings with ECP and that the ECOP findings were accurate.
The team found conflicting information concerning who in ECOP reviewed the report before it was issued, and what preliminary information was shared with the ECP organization.
Differences between the two organizations were not completely settled by the end of the evaluation, although ECOP admitted that there was a major omission in the report. ECOP failed to report that the ECP organization had performed admirably in its investigations of most of the approximately 60 cases in the second quarter. However, ECOP believes that its concerns were valid and feels it prevented an embarrassing situation from developing at Millstone.
Conclusions The ECOP is in a state of flux and will be reorganized soon. The President /CEO-Nuclear believes that in the future ECOP should focus on assessing the climate of the site organization.
It appears that the initial role of ECOP was too broadly-based to serve the site effectively.
Although not yet finalized, one of the more valuable aspects of ECOP will be moved to the SCWE organization (employee surveys) and other functions will remain with the new ECOP (SCWE/ECP oversight, review of harassment cases, and focus group reports).
The ECOP focus group reports and the quarterly reports are useful products for management, but the second-quarter report was not well balanced. The fact that the focus group reports are a real-time summary of the health within an organization and could allow management to handle problems before they escalate promotes an SCWE. Also, by virtue of providing site employees with an alternate method to resolve their concerns, the ECOP promotes an SCWE.
t 7.0 Safety Conscious Work Environment 7.1 SCWE Staffino and Oraanizational Sucoort in Evaluation Reports 50-245/97-212,50-336/97-212,50-423-212, issued on April 20,1998, the NRC concluded that there was increased organizational support for SCWE activities. A formal organization had been established, all open SCWE organizational vacancies had been filled, and daily meetings were conducted with the Vice-President of Operations to assure that the
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SCWE staff was meeting its goals and responsibilities. The current status has not changed and the organization has become more effective. Key members of the SCWE staff meet twice weekly as a group to coordinate their activities and to discuss ongoing issues. In addition, key
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managers of the Human Services organization meet daily to discuss and coordinate activities.
The meeting is normally chaired by the Vice-President of Human Services and includes managers from SCWE, ECP, ECOP, HR, and the Legal Department. The NRC attended several of these meetings and found them a valuable tool for the licensee to address and pnoritize developing issues. As appropriate, personnel are assigned responsibility to investigate an issue and report back to the group in a timely manner. Previously, there had been some weaknesses in accountability for such assignments. That has changed and assigned personnel are now asked to estimate completion dates and encouraged to adhere to those dates.
7.2 Recent Chanae in the Position of the Vice-President of Human Services With regard to personnel changes, the team was notified that the present Vice-President of Human Services is being reassigned to the position of Vice-President of Engineering Services, the position he was originally hired for in 1997. The team felt that he has been effective and instrumental in assuring that the SCWE staff remained focused on improving the safety culture at Millstone. The team interviewed his replacement and noted that this individual has extensive experience in the nuclear industry and appeared to have an excellent attitude regarding an SCWE. He noted that he intends to devote much time walking around the site to meet the staff and to learn their concerns firsthand. He believes one of his highest priorities is to unify the site in those areas than can be unified and to minimize the " silo" effect (that is a term used at the site, which signified that each of the three units operated as independent entities rather than as a unified site). He believes that this willimprove the SCWE. He also noted that the site must strive for organizational stability as soon as possible because the current instability and uncertainties are not healthy or conducive to good employee morale, which raises the potential for SCWE problems. On the basis of this briefinterview, the NRC believes the new Vice-President is a positive addition to the SCWE organization at Millstone; nevertheless, the NRC will continue to monitor the SCWE program for any signs of degradation.
7.3 Pendina Manaaement Reoraanization With certain exceptions, the majority of the reorganization is not planned to be implemented until after Unit 2 restarts. The team noted that a lot of thought has been given to the pending reorganization and to acquiring professional assistance in formulating it. However, the team also noted that the pending reorganization had not yet been announced to the site employees.
Subsequent to the team's evaluation, the team noted that the licensee announced its reorganization plans in its site-wide newsletter "To the Point," on August 28,1998, and in roll-out meetings. The licensee will solicit comments from its employees on the proposed reorganization before its implementation. Much effort has been devoted to this reorganization to minimize the potential problems. The licensee is applying lessons learned from previous reorganization efforts to improve the proposed reorganization process.
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The long-range plan for reorganizing of the entire site into an operating organization has not yet been finalized. The impact on an SCWE, if any, could come from the fact that all site i
leadership positions will be put up for bids and this will require incumbents to bid for their own position. However, it is unlikely that any such changes would negatively affect the SCWE because the selected person must meet the minimum qualifications noted on the position description, must be evaluated as technically qualified for the position, must have demonstrated high levels of the other skills and competencies, such as communications and leadership skills,
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and must be able to undertake the position with a reasonable expectation of success.
Furthermore, the selectior) process will be " cascaded"- which means that the vice-presidents Will select the directors; then the vice presidents and directors will select the managers; and the vice-presidents, directors, and managers will select the supervisors. The actual realignments may be phased in but will not be completed until after Unit 2 restart. As noted earlier, the SCWE organization is not expected to change until after that time.
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7.4 Manaaement Survevs l
Human Relations administers leadership surveys periodically to solicit information from
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employees on how management is performing with respect to five key competencies
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determined by nuclear executive management to be critical for operational excellence:
i communications, development, performance, leadership, and handling of concerns. Over time, the results show trends that indicate where managers are performing well and where improvements can be made. The information from the surveys is given to individuals in leadership positions and, when collected by function and level, is used to produce an overall profile ofleadership at Millstone.
The surveys rate leaders on a scale from 1 to 8 where 1 is ineffective,4 is effective, and 8 is extraordinarily effective. If a supervisor or manager is rated less than 4, or is in the bottom tenth of those surveyed for the second time, or if the score dropped more than 1 point from the previous assessment, the individual and his or her management must conduct a third-party-facilitated intervention and develop an improvement plan. If individuals cannot achieve and sustain effective performance, they are unlikely to remain in leadership positions.
The surveys have been administered four times - November 1996, June 1997, November
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1997, and most recently in June 1998. The results have shown improvement in leadership -
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the overall scores improved from 4.71 in November 1996, to 5.70 in June 1997, to 5.80 in November 1997, and fell very slightly to 5.76 in June 1998. These latest results exceeded the site goal of 5.5 for 1998. The Vice-President of Human Services has directed that improvement plans for individuals requiring them from the June 1998 survey be developed and approved.
Another survey will be conducted in November 1998 and annually thereafter.
In addition to the leadership surveys, the site conducts culture surveys, which are structured to obtain feedback in six areas: mission and goals, knowledge and skills, simple work processes, teamwork, self-improvement, and safety-conscious work environment. On the basis of the responses to questions in each of the areas, an average score is calculated for each area. The
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is scores for the first five areas are used to create a composite score which is known as the
" culture index"; the sixth area (SCWE) is a standalone indicator. The results help the organization to understand strengths and weaknesses, measure effectiveness o' corrective actions, and permit corrective actions to be focused properly.
The surveys have been conducted three times: June 1997, November 1997, and June 1998, Questions are asked related to each of the six areas and employees are asked to rate them as either strongly disagree, generally disagree, generally agree, or strongly agree. These answers are given corresponding numerical values of 1 (strongly disagree) to 4 (strongly agree). The overall scores for the surveys were as follows:
Area June 1997 November 1997 June 1997 Mission and goals 2.80 2.85 2.95 Knowledge and skills 3.11 3.13 3.22 l
Simple work processes 2.64 2.70 2.80 Teamwork 2.92 2.95 3.04 L
Self-improvement 2.48 2.56 2.70 j
SCWE 3.06 3.08 3.19
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l Culture index (summation of 13.95 14.19 14.71
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the first 5 areas)
On the basis of the numerical ratings, the Millstone staff generally agrees that an SCWE exists and that the work environment is improving. According to the researchers who developed the surveys for Millstone, the culture index is a subjective measurement of how the employees feel l
about the organization. The data show a good and improving trend.
l In preparation for the last survey, the vice presidents approved a plan to help the Millstone
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leadership team make good use of the results by training them on survey interpretation,
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effective communication and discussion with the workgroup, determination of areas for improvement, and development and implementation of action plans to improve work group
L performance. More than 85 managers attended the training, a schedule of activities relating to l
. the roll-out meeting and use of the survey data was reported to the managers.
In a memorandum to the staff, the Vice-President of Human Services stated that the completion i
dates noted were absolute end-dates for each of the activities, and that each director was to
- take acMon to maintain accountability for successful completion of the process.
7.5 Identification and Resolution of Focus (Problem) Areas In the previous evaluation report, the NRC noted some weaknesses in action plans used for
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resolving focus areas with respect to (1) prioritizing focus areas by significance; (2) high-level j
management review and attention, both in the development and implementation of the action j
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plans; (3) assurance that the scope of the action plan is adequate and addresses all possible organizational areas; (4) consistency and quality among the action plans; (5) setting and scheduling milestones; (6) developing the basis for closing the action plans as complete; (7)
evaluating the effectiveness of meeting goals and objectives of each action plans; and (8)
identifying action plans as confidential and following procedures for confidentiality.
Most of these weakness have been corrected. As an example, Revision 2 of the SCWE I
Handbook was issued on June 5,1998. The major changes to the revision were the following:
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l Section 5 - A description of the Employee Relations Training module was e
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added. The objective.of this training is to provide supervisors with the interpersonal skills and knowledge of NNECO/ Millstone Human Relations
policies and procedures necessary to establish and maintain effective employee relations. Among other things, the training covered employee coaching and counseling, personnel performance documentation, discipline i
guidelines, grievance and dispute resolution processes, recognition and
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response to claims of retaliation, and recognition and response to potential chilling-effect incidents, i
i Section 6 -The Focus Area plan was replaced with the SCWE Group Case e
process, which is a process used to identify, monitor, track, and assess actions associated with areas requiring or requesting significant SCWE group i
assistance. (Note: NNECO has changed the terminology several times for these types ofissues. Initially they were called " hot spots," then " problem areas," then " focus areas," and now " cases." The rationale is that not all issues should or can be called problems and some require very little or no intervention
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i or focus of SCWE efforts. Therefore, " cases" better describes the SCWE activities, yet still captures and documents all of its efforts.) The objective of the process is to satisfy the requirements and needs of the managers responsible for SCWE cases and the SCWE group, and to provide a simple trail for cases from open to close. The goal is to ensure that significant challenges to SCWE-related areas are adequately identified, documented, and resolved. A related goalis to prevent unnecessary processing or documenting of straightforward or easily addressed issues.
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Fundamentally, the Case Process section is a step-by-step handbook by which SCWE issues are identified, confidentiality is maintained, and cases are prioritized. It also discusses development of action plans, tracking of actions, and case closure, including assessment of the actions taken. These are significant improvements.
Section 7 - Guidelines were added for administration of the culture survey
described above in Section 7.4, " Management Surveys."
The improvements in the handling of SCWE cases is noted in statements made by LHC in a public meeting on August 27,1998. During that meeting, LHC stated that 17 new cases were opened in 1998, and all of them were extremely well done, had good action plans for correction,
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and had goed assessments done at the completion of the action plans. LHC also noted, however, that there were still several open cases from 1997. The evaluation team reviewed the case files for those and found they were not being ignored, that there were active action plans for resolving them, and that remained open for a variety of reasons. Three of the six are related to the Nuclear Oversight organization, which had significant personnel and morale difficulties in late 1997 that continued into 1998. In general, the delays were justified.
7.6 SCWE Lono Ranae Plan in Evaluation Reports 50-245/97-212,50-336/97-212, and 50-423/97-212, the NRC noted that the licensee did not have sufficiently developed plans for long-range actions to enhance and maintain an SCWE. Since then, however, the licensee has made progress. For example, on July 24,1998, the 1998-2000 Performance Plan was finalized. The plan is organized into five i
strategic focus areas that form the basis for longer term initiatives to support the Millstone o
recovery and return to operations. The five areas are safety, operating excellence, work environment, organizational effectiveness, and external relations. SCWE is included as part of
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work environment. The long-term vision of work environment emphasizes, among other things:
Leadership that is strong and continually improving, e
Establishment of clear standards for performance and accountabilities, o
A healthy SCWE in which all employees feel comfortable that any issues they e
raise will be addressed with commitment, respect, and timeliness, An ECP that is effective, continually improving, and held in high regard by e
employees, A work force that is motivated, resp 1ctful, and takes pride in personal, team, o
and organizational accomplishments.
The plan states that Millstone will maintain the current structure of the SCWE organization through restart of the units. Subsequently, all changes to the SCWE-related organizations and processes will be based on demonstrated performance and results achieved, and will not be schedule-driven. Self-assessment will be used to verify that performance expectations are being met. The objectives, measures, and targets to assess performance are stated in the SCWE segment of the plan, along with specinc action items to support each objective. These action plans are assigned to specific individuals and are given specific target dates for completion. Each action item is also tracked in the Action item Tracking and Trending System (AITTS). Of the 29 items originally scheduled to be completed,20 have been completed, and 9 were under way.
One long-term issue directly related to an SCWE that has not been resolved is oversight of the SCWE organization after LHC departs. During the team's onsite evaluation, NNECO had not decided how that wou'd be done. The Recovery Director for Nuclear Oversight told the evaluation team that this issue had priority, and that he intended to resolve it as soon as possible.
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7.7 Lessons-Learned Review
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Millstone established a small group to study past events for any lessons learned (Millstone refers to this as " common threads" instead of " lessons learned"). Although the process was not complete at the time of the team evaluation, a matrix had been developed that listed SCWE-related causes, causal factors associated with three Millstone SCWE-related events, and actions that Millstone had taken to address the causes and additional actions that should have been taken. At the time of the team evaluation, Millstone was in the process of writing a cover paper explaining the matrix and the lessons learned. The staff plans to review this document at a later date.
7.8 Results of SCWE Self-Assessments The SCWE organization conducted two self assessments in 1998. The first (98-SCWE-1) was completed on March 13,1998. It evaluated the effectiveness of selected aspects of the Employee Concerns Comprehensive Plan. Generally, it found satisfactory results, relative to the effectiveness of evaluated areas and noted improvements in leadership and organizational effectiveness. No conditions adverse to quality were discovered.
The second self-assessment (98-SCWE-2) was completed on August 14,1998. It evaluated the effectiveness of the Executive Review Board (ERB)in the following specific areas:
Assure due process has been afforded NNECO and contractor employees in
areas covered by the ERB Charter (proposed adverse employment action),
including assuring that the proposed adverse action is not counter to the provisions of 10 CFR 50.7.
Assess the timeliness of the ERB review of proposed NNECO and contractor e
disciplinary actions.
Determine the satisfaction level and perceptions of ERB effectiveness as
assessed by individuals who have been involved in (but not subject to) various aspects of the ERB process.
l The assessment concluded that the ERB was effective in assuring that individuals received due process. This was also the conclusion of ECOP in its second-quarter report which states: "The ERB process continues to improve and mature. Presentation packages are largely thorough and well researched. The level of questioning and scrutiny given to cases by ERB members is thorough and appropriate " For " timeliness of the ERB review process," the assessment noted that the site had set a goal to have the cases completed in 5 days, and that it had met that goal in April, May, and June 1998, but that the numbers started to increase in July and August (5.2 days and 7.0 days respectively). For " satisfaction level of ERB effectiveness by individuals who have been involved," the assessment noted that the ERB was considered effective by those who had been involved in the process. In this regard, it is significant to note that the Vice President for Operations informed the NRC that the ERB will continue to be functional for the foreseeable future because it was considered to be a valuable tool for the Millstone site.
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7.9 Kev Performance Indicators (KPls)
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in addition to the KPls that arb tracked routinely by the ECP, Millstone has started to use what it i
calls Nuclear Safety Indicators (NSis). These are based on a model developed in 1995 and 1996 by consultants to the International Atomic Energy Agency (IAEA), which has three fundamental attributes (1) safe plants operate smoothly, (2) safe plants are operated with low risk, and (3) safe plants maintain a healthy safety culture. For the present time, however, only the third attribute is being used at Millstone because it is applicable to any unit, whether operating or shut down. The other two attributes are primarily associated with operating plants and would not be a meaningful indicator with Unit 2 shut down and Unit 1 entering l
decommissioning. Each of the attributes is broken down into indicators that are then color coded from green (significant strength) to red (unsatisfactory performance) and given a numerical rating of 2 (significant strength),1 (satisfactory performance), -1 (improvement needed); and -2 (unsatisfactory). These numerical ratings are then averaged to get an overall score. Scores that range from 1.50 to 2.00 are excellent,0.01 to 1.49 are satisfactory,0.00 to-1.49 indicate a need for improvement, and -1.50 to -2.00 are unsatisfactory.
JUNE 1998 SAFETY CULTURE /SCWE NS! RATINGS Millstone Unit Indicator Codes (Safety Culture rating and SCWE rating)
Excellent Satisfactory Needs improvement Unsatisfactory (1.50 to 2.00)
(0.01 to 1.49)
(0.00 to -1.49)
(-1.50 to -2.00)
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The SCWE portion of the indicator attempts to measure organizational responsiveness to employee concerns and the urgency placed on resolving concems. The following four specific indicators are monitored:
e Employee concerns about resolution timeliness Overdue employee concerns about corrective actions e
Ratio of HlRD concerns to total concerns
Number and age of problem areas The evaluation team was told that these indicators were presented to the Nuclear Safety Assessment Board (NSAB) on August 27,1998, and that NSAB believes that these are a good addition to the SCWE assessment of the site and has requested that they be presented to the board at its monthly meeting.
l in addition to these NSIs, the team reviewed the routine updates of the ECP KPls. Some of the more significant ones and their status are the following:
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Concems Received - For July (the last full month data were available)
Millstone received 19 employee concerns and the NRC received 1. The rate af employee concems appears to be a leveling out because 19 is also the i
sverage for the last 6 months. The one received by the NRC was the lowest total in at least 18 months (the average for the last 6 months was 4). Through August 18, ECP had received 9 concems.
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Concerns Received Alleaina HIRD and Nuclear Safety System (NSS)
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i Deficiencies -In July, 7 of the 19 concerns received alleged some form of HIRD, one of which was alleging a 10 CFR 50.7 issue, and one was alleging an NSS deficiency. These total HlRD numbers are the same as for June and 3'
more than for May. However, the number is lower than the average of about
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13 for the 5 months previous to that. Of the 9 concems received by ECP as of L
August 18th,4 were classified as HIRD and none as NSS. Of the 10 CFR 50.7 i
concems,- the one in July is the lowest since November 1997 and is much lower j
than the average of about 4.3 over the last 12 months. None of the HIRD concerns received in August were related to 10 CFR 50.7 issues.
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HIRD Concerns Substantiated-Of 8 HIRD concerns investigated in July,2 were substantiated. The number substantiated has been averaging about 2.7 for the last 6 months, and the number investigated has been averaging about 12.
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NSS Concema -In the last 6 months,13 NSS concems have been investigated and none of them were substantiated.
Another KPI is the percentage of employees who rate their work environment as conducive to raising and resolving concerns. This is considered a valuable measure in evaluating employees' comfort with the current ECP and their confidence in programs, peers, supentisors, and upper management in supporting an SCWE. It can be used in conjunction with other similar indicators as evidence of the presence and strength of the Millstone SCWE. The data are obtained from the culture surveys that are conducted about every 6 months. The November 1997 survey indicated that about 82 percent of the employees surveyed agree that an SCWE exists and that they would be willing to raise concerns to their supervisors, and the June 1998 survey showed an increase to 86.6 percent. These data are based on responses of nearly 2000 employees and contractors.
A related indicator is the percentage of employees who have used the ECP for resolving their concerns and who report a willingness to use the program again. Most of these data are obtained from questionnaires sent to employees when the concems are closed, asking them to answer questions relating to their level of satisfaction with the ECP personnel and process.
The answers are rated as positive, neutral, or negative. Since inception of the orogram,229 questionnaires have been sent out, of which 72 were retumed (about 31%). Only 12 (5%) of the retumed questionnaires have been negative. Furthermore, the rate of negative responses has fallen over the last 6 months - 128 questionnaires have been sent out in the last 6 months
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of which 35 (27%) were returned and only 3 (2%) were negative.
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7.10 Site Resoonse to LHC Recommendations in its previous evaluation report, the NRC noted that the SCWE group had initiated tracking of LHC recommendations in the' site-wide Action item Track and Trending System (AITTS), but that the NRC was not able to evaluate its effectiveness at that time L=cause the system was so new. Since then, however, the team has been able to verify that the system is a viable and useful tool and has been of considerable hel.n in maintaining schedules and holding personnel accountable to complete assignments. As evidence of this, LHC noted that it has made a total of 104 recommendations to NNECO since its inception and that NNECO has responded to all of them. Of the 104 responses, LHC has closed 81 as acceptable and another 6 as acceptable but with continued o.onitoring of the corrective actions. LHC considers the remaining 17 responses as adequate, but is keeping the recommendations open until it completes its E.Gations nf the corrective actions.
Conclusions On the basis of the team's observations, NNECO continues to improve the SCWE at Millstone.
The ovenvhelming majority of employees are willing to raise concerns, and of those who have used the ECP program, only a relatively few stated they would not use the program again. This
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was verified not only by Millstone through the various surveys and questionnaires at its disposal, but by LHC.
j Nevertheless, the team noted that there is still some fragility in the various programs that make up an SCWE. At this point, management has shown it is willing and capable of immediately becoming involved to resolve problems and concerns as they arise, indicating that the programs in place are working. Further evidence of this is that LHC has stated that although it is still involved in assisting the licensee in responding to and resolving concems, it is not involved nearly as much as it was only a few months ago and believes it is approaching the time when it will not be needed for third-party oversight. But given the potential problems that
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could arise from any number of areas, such as the impending reorganization and recent managerial changes, the team believes some continued monitoring is required.
7.11 SCWE Trainino Proa_ ram Evaluation Scone The team evaluated whether the licensee's SCWE training program has continued to function satisfactorily since the last NRC evaluation, and whether there is reasonable assurance that this program wi,l continue to function satisfactorily in the future. The team used applicable portions of the licensee's Performance Pian and the NRC's IP 40001 as evaluation criteria.
Qbservations and Findinas SCWE Trainina for Suoervisors and Manaaers During the previous NRC evaluation, the team found the licensee's SCWE training program to be effective for introducing and enforcing an SCWE at Millstone. Since that evaluation, the
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licensee introduced a " quick start" process, which ensures that new supervisors and new managers receive initie! SCWE training within a short period of time. !t includes a video tape, an SCWE Handbook, and a Quick Start Training Requirements Memo. When a new supervisor or managerjoins the Millstone team, HR informs the Training Department, so that a copy of the video tape, the handbook, and the memo can be sent to the individual. The memo informs the supervisor or manager that he is responsible for viewing the video tape, reading the handbook, and attending the following four training courses: (1) 'Jianaging for Nuclear Safety," (2)" Fitness for Duty and Civil Treatment for Managers," (3) " Employee Relations," and (4) "SCWE." The courses require 4% days to complete, and the licensee's expectation, as detailed in the memo, is to complete the stated requirements within 45 days, not to exceed 90 days. Continuing t'aining is also provided to supervisors and managers, and consists of "SCWE I & 11," and
" Setting the Winning Standard Workshop." The Training Department tracks completion of SCWE training with the Northeast Utilities Training Information Management System (NUTIMS).
The team viewed the video tape and found that it gave a good overview of the SCVE program and provided the licensee's expectation of management's role with respect to the SCWE program.
The quick-start process is an enhancement to the SCWE training program. NUTIMS is an effective tool to track completion of required training, and showed that 97 percent to 98 percent of all supervisors and manageis had completed initial SCWE training.
The team also reviewed plans or programs to support t..e long-term effectiveness of the licensee's SCWE training program. Although there were no finalized programs, the team reviewed an outline of a self assessment that was currently in progress concerning SCWE leadership tmining effectiveness. This self-assessment's objective was to determine how to improve the efiectiveness of the initial SCWE training program and to identify additional needs for continuing and refresher training. The licensee's performance plan rece nmended that this self-assessment should be complete by the end of September 1998. Through team interviews of training and SCWE personnel, it appears that refresher training for supervisors and managers will be in place early next year; the licensee will also be moving forward to improve the current SCWE training program by enhancing initial training and providing continuing training based on lessons learned frem its assessment of SCWE focus areas. The team will monitor this aspect of the licensee's SCWE training prograrn, which will be reviewed in a future evaluation.
SCWE Trainina for Non-Suoervisors/Manaaers All employees and contractors who work onsite are given SCWF initial training as part of Plant Access Training. Refresher training is done thereafter once a year by requiring that Plant Access Training be taken again. During the previous NRC evaluation, the team found that the Plant Access Training covering the ECP was potentially misleading in two areas: when can an individual use the ECP, and what role does the NRC play in ascriminy. ion complaints. The team reviewed the latest version (Revision 5, dated Augue,t 20,1998) of the Plant Access Training material covering the ECP and found that the new revision effectively had corrected these concerns.
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Once on site, employees and contractors are encouraged to attend Nuclear Acclimatization i
Training, which consists of two courses, " Civil Treatment for Employees" and " Partnership
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Beyond 2000." By interviewir)g training and SCWE personnel, the team noted that it did not
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appear that the licensee could easily determine what percentage of on site employees and
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contractors had taken this training.. Additionally, there did not appear to be a time requirement
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for completing this training. However, the licensee estimated that about 2500 people had taken
- the " Partnership Beyond 2000" course and about 2000 people had taken the " Civil Treatment for Employees" course since their inception in 1995. The licensee also estimated that about
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recently been made available to site workers and consists of the course entitled, " Setting the i
Winning Standard Workshop."
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Effectiveness of the SCWE Trainino Procram i
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The licensee measures the effectiveness of the SCWE training program by reviewing feedback from training sessions, surveys, and questionnaires, and from weaknesses identified in
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response to quizzes given during certain training classes. Results from these efforts are provided in self-assessments. The team revbwed a self-assessment conducted between l
March 16 and April 3,199S. The self-assessment noted strengths, areas for improvement, observations, and recommendations. The self-assessment found the SCWE training program to be effective based on positive feedback from training attendees and high marks received
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during an opinion survey. The team found the self-assessment to be critical but well balanced.
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Conclusions i
The licensee's SCWE training program has continued to operate satisfactorily since the
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previous evaluation and since restart of Millstone Unit 3. The introduction of the quick-start
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process is an enhancement to the SCWE training program. NUTIMS is an effective tool for tracking training requirements. Long-term plans for the SCWE training program have not yet been finalized, such as SCWE refresher training for supervisors and managers, SCWE continuing training, and enhancements to current SCWE training courses based on lessons learned. The team will monitor this area la a future evaluation.
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