NRC 2007-0015, Nuclear Management Company, LLC Plan to Address the Safety Culture Issues at Point Beach, Units 1 and 2

Nuclear Management Company, LLC Plan to Address the Safety Culture Issues at Point Beach, Units 1 and 2

ML070890434
Person / Time
Site:	Point Beach
Issue date:	03/29/2007
From:	Koehl D Nuclear Management Co
To:	Document Control Desk, NRC/NRR/ADRO
References
3-2005-010, EA-06-178, NRC 2007-0015
Download: ML070890434 (29)

Text

Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC March 29,2007 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 Renewed License Nos. DPR-24 and DPR-27 Nuclear Manaaement Comoanv, LLC Plan to Address the Safetv Culture Issues at Point Beach Nuclear Plant Reference (1) NRC Letter Dated January 3, 2007, Transmitting Confirmatory Order EA-06-178 (Effective Immediately) (Office of Investigations Report No. 3-2005-010)

This letter provides the Nuclear Management Company, LLC (NMC) response to Section IV.4 of Confirmatory Order EA-06-178 as delineated in Reference (1). NMC is committed to maintaining a strong safety culture at Point Beach Nuclear Plant (PBNP).

The enclosures of this letter provide a summary of the activities undertaken by the PBNP Nuclear Safety Culture Improvement (NSCI) team. These activities included a review of the 2004 and 2006 comprehensive cultural assessments; a review of the actions taken to address Action Request (AR)00510074; and NMCs action plans that have been developed to address significant issues. These action plans were developed as a result of an analysis of focus group interviews conducted with Priority 1 and 2 organizations by the PBNP NSCI Team, which was formed during the fourth quarter of 2006. The 2006 Culture Survey Executive Summary is being provided via separate cover letter (NRC 2007-0025 dated March 29,2007).

Summan, of Commitments In accordance with the guidance contained in Nuclear Energy Institute (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes," the corrective actions outlined in the enclosure of this letter do not meet the criteria as new regulatory commitments.

As such, there are no regulatory commitments contained in this letter. However, NMC intends to implement the corrective actions described in the enclosures via the PBNP corrective action program.

6610 Nuclear Road Two Rivers, Wisconsin 54241-9516 Tdephone: 920.755.2321

Document Control Desk Page 2 NMC would be pleased to meet with representatives of the Commission to periodically review the scope of NMC's efforts and progress in addressing this issue. If there are questions associated with this effort, please contact me at 920ff55-7624 or Ms. Monica Ray, Regulatory Affairs Manager at 920/755-7633.

Dennis L. Koehl /

Site Vice-President, Point Beach Nuclear Plant Nuclear Management Company, LLC Enclosures (6) cc: Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC

ENCLOSURE 1 NUCLEAR MANAGEMENT COMPANY, LLC PLAN TO ADDRESS THE SAFETY CULTURE ISSUES AT POINT BEACH NUCLEAR PLANT CONFIRMATORY ORDER EA-06-178 SECTION IV.4 NRC Confirmatorv Order Section IV.4 "By no later than March 30, 2007, NMC shall develop action plans to address significant issues identified as needing management attention in the NMC 2004 and 2006 Comprehensive Cultural Assessments at PBNP; to conduct focus group interviews with Priority I & 2 organizations to understand the cause of the survey results; and to review and, as appropriate, reflect nuclear industry best practices in its conduct of focus groups and action plans to address the issues at PBNP.

As part of the development of the action plans, NMC shall also assess and address any legacy issues identified in prior safety culture assessments (i.e., CAP report A ROO510074 and Synergy Safety Culture Assessment) that impact the safety culture at PBNP.

The executive summary, analysis, and contemplated action plans shall also be submitted to the NRC. "

Nuclear Manacaement Com~anv(NMCI Resmnse In May 2006 SYNERGY Consulting Services Corporation (SYNERGY) was commissioned by Nuclear Management Company (NMC) to perform a Nuclear Safety Culture Assessment (NSCA) of the Point Beach Nuclear Plant (PBNP). The 2006 NSCA Survey was administered between July 31 and August 9,2006, and the results were presented to PBNP managers, supervisors, and International Brotherhood of Electrical Workers (IBEW) Local 2150 union leadership on October 2,2006.

The PBNP 2006 NSCA Executive Summary Report, Revision 1, dated January 25,2007, is being transmitted under separate cover via letter NRC 2007-0025. It is being withheld from public disclosure in accordance with 10 CFR 2.390.

Develo~mentof the Nuclear Safetv Culture lm~rovement(NSCI) Team The Nuclear Safety Culture Improvement (NSCI) team was established as a site focus group by the PBNP Site Vice-President with an objective to represent the site in developing an action plan in response to the NSCA results. Following the issuance of Confirmatory Order EA-06-178 on January 3,2007, the scope of the NSCI team effort was expanded to include the 2004 NSCA survey results as well as a review of actions associated with Action Request (AR)00510074.

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The NSCl team was comprised of managers, supervisors, individual contributors, and union representatives. Team members were volunteers and were individuals with a desire to change the culture at PBNP. The NSCl team membership included a cross-representation of the following PBNP departments:

Chemistry NOS Emergency Preparedness Operations Facilities Procedures Finance Safety Instrumentation & Control Security Maintenance (2 representatives) Training Oversight for the NSCI team was provided by the Employee Concems Manager and the Management Sponsor.

Individuals from Salem/Hope-Creek, Southern California Edison, Palisades, and Progress Energy were queried regarding their experiences and site responses to nuclear safety culture surveys. The documents and information provided as a result of these queries were reviewed and provided to the NSCl team members. The information was used in development of problem statements and action plans outlined in Enclosure 4 based upon the NSCl team's analysis of interview results.

Additionally, the following documents and presentations were reviewed in preparation for the focus group interviews and in development of the action plans:

1. Basics of Conducting Focus Groups, "Carter McNamara, Authenticity Consulting, LLC, Copyright 1997-2006.

2. ECP Forum Presentation by Southern California Edison (SONGS), "Responding to Identified SCWE Survey Weaknesses," September 12-13,2006.

3. Culture survey recommended actions and information sharing provided for the Palisades Nuclear Plant.

4. SYNERGY'Smanagement presentations to PBNP in 2004 and 2006.

5. NRC Regulatory Issue Summary (RIS) 2005-18, "Guidance for Establishing and Maintaining a Safety Conscious Work Environment: August 25,2005.

6. 'Safety Culture Initiative: NRC/lndustry Interactions and Results: First Energy Nuclear Operating Company (FENOC).

7. Docketed correspondence associated with the following sites: Hope Creek and Salem Nuclear Generating Stations; Davis-Besse Nuclear Power Station; Indian Point Energy Center.

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A charter was developed for the NSCl team, which includes the vision, mission, team membership, implementation, and team responsibilities. Quorum meeting requirements were established and a regular meeting schedule was developed with meeting minutes being maintained. Communication on the survey results and NSCl team efforts have been provided to the site via e-mails, leadership forums, group briefings, and at an all-employee meeting.

A review of actions taken in response to AR00510074 was performed. Corrective action program documents had been previously initiated to refresh and review the meanings of the terms "safety conscious work environment" and "nuclear safety" with employees. Additional corrective action program (CAP) documents were initiated to:

Communicate the results of major technical and operational decisions to employees, acknowledging events as learning opportunities at all-employee meetings.

Evaluate whether additional training was needed to aid in rebuilding trust throughout the organization.

Track the improvement of interpersonal communications between managers/supervisors and their work group.

Document review of the meaning of "group think" and methods to avoid falling into this error trap.

Review the process for work order feedback with the appropriate employees involved in the process.

Evaluate training needs for employees not enrolled in accredited programs.

Based on a review of AR00510074, it was concluded there were no unaddressed legacy issues identified with this subject.

Anatvsis Utilized to Develo~Action Plans The NSCl team reviewed the NSCA reports and associated attachments prepared by SYNERGY. The team also gave consideration to noteworthy environmental conditions which could have had some effect on the 2006 NSCA results. NSCA attachments, including the percentage of negative responses and colorcoded windows, provided background for determining potential questions for each group.

The approach the team took was to first conduct interviews with the 2006 Priority 1 and 2 organizations to gather additional information from the employees to assist with problem identification. In parallel, the NSCl team interviewed several organizations that were consistently graded high or had made significant improvements in order to utilize best practices and lessons learned. The Page 3 of 5

organizations recognized for their improvement from 2004 to 2006 and high overall ratings included Engineering, Security and Training. Finally, the NSCl team interviewed the groups rated as Priority 1 and 2 in 2004. Enclosure 2 contains a list of the Priority 1 and 2 organizations identified by SYNERGY in the 2004 and 2006 NSCA.

Interviews were conducted by members of the NSCl team who were not associated with the organization being interviewed. The individuals interviewed included a representative sample of the group, including managers, supervisors, individual contributors, and where applicable, Local 2150 union represented personnel. In several cases, the manager and/or supervisors were interviewed separately to ensure that there was an open exchange of information.

The interview findings were discussed, challenged and validated as necessary in an effort to clarify both the NSCA results and the interview comments. The NSCl team was tasked with determining if the NSCA ratings and interview comments were associated with nuclear safety concerns or with general culture and work environment.

The initial approach taken by the team was to review the attributes and drivers present in the higher rated organizations (i.e., Engineering, Security and Training) in order to potentially incorporate the positive traits into Priority 1 or 2 groups. In addition, the negative attributes consistent among the Priority 1 or 2 groups were discussed to determine common or group-specific actions necessary to mitigate the issues. Once the attributes were agreed upon, the NSCI team began to focus on the potential drivers, potential medium to long-term action plan items and "Quick Hitter" actions. "Quick Hitters" are tangible, prompt action items that are implemented as a direct result of communication between the NSCl team and PBNP personnel related to the 2006 NSCA. At least one team member was assigned to each Quick Hitter action item to discuss the recommended action with the appropriate Organizational Manager. Enclosure 3 provides the list of the NSCl team's "Quick Hitters."

As a result of the reviews performed and interviews conducted, the NSCl team identified six common drivers:

Communication Problem Resolution Training Trust/Respect Resource Loading CAP Participation Utilizing the model developed at SalernJHope Creek, the NSCI team developed an action plan including problem statements and action items. The focus of this action plan was: (1) to incorporate positive traits from the organizations with higher ratings or significant improvements from 2004; and (2) to incorporate actions specific to Page 4 of 5

Priority 1 and 2 organizations, as required, as well as site-wide actions that would improve the nuclear safety and general culture and work environment at PBNP. The action plan was presented to the senior management team on March 23, 2007. provides this plan.

Enclosures 5 and 6 provide tables of significant issues identified as needing management attention in the 2004 and 2006 NSCA, respectively. These tables identify actions taken or planned to address each of the issues included in the Action Plan.

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ENCLOSURE 2 PBNP PRIORITY LEVEL 1 & 2 ORGANIZATIONS BASED ON INDUSTRY NORMS CRITERIA 2004 AND 2006 INTEGRATED PRIORITY LEVEL PRIMARY ORGANIZATION 1 &2 AREAS OF CONCERN 2004 2006 I&C Maintenance 1 NSC, GCWE 1 NSC Supply Chain 1 NSC, GCWE 2 NSC Radiation Protection 1 NSC, GCWE I NSC, SCWE Nuclear Oversight 1 SCWE Chemistry 2 GCWE Facilities Maintenance 2 GCWE Maintenance Support 2 GCWE Other Operations' 2 GCWE +

Performance 2 GCWE +

Accounting 1 NSC, SCWE Other Maintenance 2 NSC Shift Operations 2 NSC Regulatory Affairs 2 SCWE+

Other Business Support* 2 SCWE

• The individuals who comprised these groups could not be identified. Therefore, interviews could not be conducted with these groups.

NSC Nuclear Safety Culture GCWE General Culture Work Environment SCWE Safety Conscious Work Environment Page 1 of 1

ENCLOSURE 3 NUCLEAR SAFETY CULTURE IMPROVEMENT TEAM QUICK HllTER LIST Quick Date Action To Be Taken Status Source Hitter Initiated Maintenance Manager to meet with Instrument &

I c Control (I&C) group at morning meeting or D-15 Compfete 1 1/15/2007 interviews introduction session.

Schedule SVP, Site Director or Plant Manager to I&C meet with I&C group marthly du"ng morning 2 1/15/2007 Complete

'mews meetings or D-15 meetings.

Based on interview comments, I&C does not know ILC their CAP Liaison. Invite CAP Liaison to meet with Complete 3 1115/2007 Interviews grow.

I&C has requested that the equipment/component identificationcode be populatedfor CAPs. This progress 3a 1/15/2007 lac would benefit 1&C and Engineering for histotical purposes.

CAP Initiators in I&C do not receivefeedback on IBC Complete 4 1/15/2007 the CAPSthey write. Maintenance Manager to Interviews provide feedback to initiators.

Provide feedback to Radiation Protection (RP) on RP CAP process in RP (contractor as CAP Liaison, progress 5M007 Interviews CAP initiators are not receiving feedback or providing input into actions).

RP RP Technicians should provide oversight for

'fi5RW7 n o d e dam training. Complete Interviews RP $500 K of equipment in stand-by in RP area. In progress 5/2007 lnterviews Dedicated resources needed.

A recommendationwas made by NSCl team that Finance the Finance Group attend another department's 1m007 Complete lnterviews D-15 meeting. The intent is to gain a different peqxzthe of the site-l&C Review the completed actions from the 2004 1R2/2007 Complete lnterviews Nudear Safety Culture Focused Self-Asesment D i Fire Brigade requirementswith Fire 10 2m~07 Ops Protection Coordinator and Operations Complete marlagenlent Recommend a team building session for RP In progress 11 2/8/2007 RP (Phase II) with RP Manager.

Recommend a team buikiing session for Shii 12 2/8/2007 Ops Operations Management (with timeline goal for Complete comptetion prior to Unit 1 Refueling 30 outage).

13 2/8/2007 I&C Recommenda team building session for I&C. In progress Page 1 of 2

ENCLOSURE 3 NUCLEAR SAFETY CULTURE IMPROVEMENT TEAM QUICK HIITER LIST Quick Date Action To Be Taken Status go, Hitter Initiated SW@Y Work Ma- mining (impove site 14 2/8/2007 Complete familiarity with process).

-I Supply Concern Regarding ProcedureAdherence -

15 2IU2007 Chain Specific examples from inte~ewees to be cOmptete Interviews provided by NSCI team.

Supply Concern Regarding Procedure Adherence --

15a , 2/8/2007 Chain NSCl team to review the examples provided in Open Interviews QH#15 and take action as required.

Procedure NP 2.1 -4, Operator Budens, has been in draft form for >I year.

mte Ops opera~out-of~liinot~ralize d .

Complete Management opportunitiesto recognize positive behaviorswith face-@face e r-i Action:

Team NSCI team to engage Plant Manager and S i e VP comkk?

meetings for opportunitiesto recognize positive behaviors.

Make harrkopy action tracking f m available Closed to Team with CAP liaisons andlor admin staff for individuals D i i u n bwritefiard copy CAPS.

Develop communication regarding the availability of the hard copy action tracking forms for Team submitting CAPS, reinforcing expectations and Open Discussion describing the circumstancesfor when hard copy submittal is acceptable.

ACEMAN thumb level to be changed tu defaultof Team sideways. Discuss ACEMAN thumb level at Plant 1 Discuaion Operational F - and Plant Operations Daily Complete

~'eetings.

Team RP does not currently have a web page for their 2126m7 In pmgress Discussion group.

Supply Chain Stock Handlers are not in an I I I I accredited training program. Requests were I I made to evaluateif a qualification is appropriate for a Stock Handler and to provide training on In progress rigging,shipping of hazardous matedals and Interview Harmat. if this is within scope of non-accredited I 1 1 I training efforts, communication should be provided 1 1 to st& ~andlers.

Ensure Training Oversight Committee, Training Team Advisory Committee and Curriculum Review 23 3/232007 Complete Discussion Committee meetings are listed on the plant calendar.

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ENCLOSURE 4 NUCLEAR SAFETY CULTURE ACTlON PLAN The intent of this Action Plan is to improw the work environment at Point Beach by assessing the issues identified by the 2004 and 2006 Synergy Nuclear Safety Culture Assessment, developing actions in response to those identified issues, and providing a mechanism to track these actions to completion.

1. Problem Statement and Associated Actions There are opportunities for interpersonal and interdepartmentalcommunication at PBNP to be more effective.

Communications training currently exists in the Supervisor Leadership Development Program and initial training; however, both are offered as one-time training only.

The evidence requires continuing training in the area of communications.

Tools for departments to use to communicate (e.g., D-15 sheets, NMC Today, clock reset communication sheets, etc.) are acceptable. However, there is evidence of a breakdown in the dissemination of information and further engaging of horizontal and vertical communication. This is evidenced by:

- Perception of a continual reactionary mode;

- Feedback not consistently being provided on CAPS;

- Lack of communication on how priorities are set;

- Changes to policies and procedures not explained to affected personnel and reasons for decisions not explained.

l tem Action Owner Due Date Benchmark to determine if Crucial Communications 04/27/2007 Conversations andlor Crucial A

Confrontations used elsewhere are effective. Consider other options.

SVP Staff 05/07/2007 6 Select training to be conducted.

Meeting Determine logistics for training using the Training 06/01/2007 Systematic Approach to Training (SAT) process to maximize effectiveness.

This includes selecting the target C audience (recommend all site personnel for initial training), the trainer (vendor or certify plant staff), the means (by work group or cross-discipline), and the feedback and effectiveness measures.

D Establish the schedule to conduct Training 06/29/2007 communications training.

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2. Problem Statement and Associated Actions PBNP has decreased effectiveness in succession and retention planning for some work groups based on attrition due to the aging work force.

In addition to emphasis on the right person for the right job, the objective should be to ensure and emphasize consistent expectations and the right picture.

Item Action Owner Due Date Provide attrition records from 2001 Human 04/27/2007 through 2007 to each department Resources manager for his or her department.

A Include separate report for retiring employees and employees seeking other employment.

Provide a report of the proiected Human 04/27/2007 attrition through 2017 to each Resources department manager for his or her B department based on available information. The report should include anticipated loss of head count by work group.

Based on the reports developed by Various 07/27/2007 Human Resources for 2.A and 2.5, Managers as Managers of the affected workgroups determined by shall determine an effective outcome of 2.A C succession and retention plan. This and 2.B plan shall include resources, required qualifications, training, and time required to achieve full qualification status.

Conduct First tine Supervisor Training Human 10/05/2007 on use of tools available in Resources performance management plan and represented employee evaluation D processes to encourage succession planning. Training should emphasize communication between individual and supervisor to discuss desire to progress and potential opportunities.

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3. Problem Statement and Associated Actions Continuous improvement is needed in the area of timeliness of training before using new equipment onsite.

Consideration of training needs is imbedded in the modification process. To improve on timeliness of training and to prevent installationof equipment without training, training should be consistently included as part of the process to purchase new equipment.

Item Action Owner Due Date Develop a consistent process for Plant Manager 0610112007 A evaluating training needs for small capital equipment purchases.

4. Problem Statement and Associated Actions Continuous improvement is needed in the training process to develop a support system to assist personnel in completing required training qualifications, and to enhance individual engagement of Curriculum Review Committees (CRC).

CRCs have been recognized as effective in general. An area for improvement is to increase the visibility of CRCs to site personnel, ensuring that issues and training needs are being identified and prioritized using this process. Operations was recognized as effectively reviewing training requirements and utilizing its CRC.

Jtem Action Owner Due Date To ensure the CRCs are being used to Chair of each 06/27/2007 their maximum potential, each CRC committee chair should evaluate the current membership, assessing: (1) if A the people within the committee are the right people for the job and fully understand the mission; and (2) how the committee can be used more effectively.

Develop a support system for assisting Training 0913012007 B individuals in completing training Manager qualifications.

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5. Problem Statement and Associated Actions Radiation Protection resource issues were identified as the primary reason for their low overall nuclear safety culture rating.

A benchmarking effort is recommended initially for the Radiation Protection group.

Prior to contacting other stations, an analysis of PBNP radiation protection tasks should be performed. This task review should consider who does what tasks, what drives the tasks (i.e., tradition, requirements, etc.), and what qualifications are needed.

A benchmark of compatible sites is intended to evaluate not only the staffing levels of both management and craft personnel but also the RP practices. It is recommended that the benchmark team include at least two management and at least two craft personnel from Radiation Protection.

At the conclusion of this effort in Radiation Protection, consideration should be given as to whether benchmarking may benefit other work groups (Action 5.E).

Item Action Owner Due Date Analyze radiation protection tasks. RPfChemistry 06115f2007 Identify who does what tasks, what Manager A

drives the tasks, and what qualifications are needed.

Conduct benchmarking of industry RP RPJChemistry 09/28/2007 in accordance with FP-PA-SA-04, Manager B "Benchmarking Process" evaluating staffing levels of both management and craft and the RP practices.

Benchmarking team to present the RPfChemistry 10/26/2007 results of the benchmarking report to Manager the Performance Assessment Review Board (PARB) and Plant Manager.

Communicate results of report and RP/Chemistry 11/02/2007 D resulting actions to entire RP Manager deparhnent.

Determine whether this effort was PARB 11/02/2007 E effective for RP and whether it would Chairman benefit other onsite groups.

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6. Problem Statement and Associated Actions Enhancements are needed in the area of issue resolution as evidenced by the lack of consistent documentation and lack of consistent feedback to initiators.

The NSCl team recognized that several workgroups identified as Priority 1 and 2 in the nuclear safety culture assessment (NSCA) needed improvement in the areas of issue resolution and communication. However, if those work groups were identified as having a lack of trust in their direct supervision or management, improvement in these areas is difficult to implement internally.

An observer not associated with the work group is recommended to periodically observe interactions within the group and to provide unbiased feedback to the group.

Security was recognized for a best practice by implementing a formal process to ensure issues are documented, resolved, and appropriately communicated.

Item Action Owner Due Date For work groups identified as Human Resources 04/27/2007 Priority 1 and 2 in the 2004 and/or 2006 NSCA whose focus interviews identified a lack of trust in direct supervisionfmanagement, A

an observer shall be named to periodically observe interactions within the group and provide unbiased feedback to the group for at least six months.

7. Problem Statement and Associated Actions There are opportunities for enhancement in communication of the planned prioritization and resolution of equipment issues.

Item 1 Action Owner Due Date Incorporate communication of Communications 04(20/2W7 recentfy resolved and near-term A equipment issues in PBNP plant-wide communications on a periodic basis.

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8. Problem Statement and Associated Actions Continuous improvement of corrective action program is needed in the area of familianty with the new electronic corrective action program process.

The CAP initiation rate is less for some work groups following implementation of the new process. This is due, at least in part, to unfamiliarity with the process.

No long-term actions were recommended by the NSCl team in the area of familiarity with the new electronic CAP process. This concern was recently identified in AR01079965, Station Perception - Action Tracking Difficutt, initiated on March I, 2007, and AR01080781, "CAP Initiation Thresholds," initiated on March 6,2007. Action items have been assigned to seven work groups out of ARO1080781 based upon a CAP initiation rate that was lower than expected.

Security was recognized for a best practice of providing a group training setting as an opportunity for officers to gain familiarity with the electronic CAP process and initiating CAPS. Operations was recognized for a best practice by developing step-by-step instructions for initiation of action requests, work orders and procedure change requests.

9. Problem Statement and Associated Actions Enhancements are needed in the area of Work Management as identified by interview statements regarding qualify of life and resource loading.

No new actions were recommended by the NSCl team in the area of Work Management. Work Management is a priority area for PBNP and action plans have been developed as a resutt of the work management root cause evaluation performed in accordance with AR01040188. Corrective actions are being tracked by the Plant Excellence Review Group (PERG).

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ENCLOSURE 5 SIGNIFICANT ISSUES IDENTIFIED AS NEEDING MANAGEMENT AlTENTtON IN THE 2004 NSCA

Problem Statements and Associated

1. issue Descriptlon Actions as Listed in Enclosure 4 1 PBNP Site Oraanization - Summary Addressed in 3, 4, 9, and 10.

The December 2004 CCA rating of the Overall Safety Conscious Work Environment provided by the PBNP Site Composite Organization is adequate as compared to industry standards. One SCWE-related metric showed a significantly declined rating since the January 2003 CCA.

The December 2004 CCA rating of the Overall General Culture &Work Environment provided by the PBNP Site Composite Organization is nominally adequate as compared to industry standards. Most GCWE-related metrics showed declined ratings since the January 2003 CCA.

The December 2004 CCA results indicate that management attention is needed to address the underlying causes for the metrics with low andlor significantly declined ratings.

2 PBNP Site Oraanization - Nuclear Safetv Values, Behaviors & Practices Action 1 - Communication Action 6 Observer of Priority 1 & 2 Groups The ratings of the following NS VB&P metrics and attributes are at levels that indicate Action 7 - Communication of Equip ~ S S U ~ S the need for particular management attention: -

Action 8 Familiarity with new CAP process Action 9 Work Management "Overall Effectiveness of the Corrective Action Program", as it relates to Nuclear Safety. -

QH-3 Maintenance CAP Familiarization "Effective Resolution of identified Nuclear Safety Issues" QH Feedback to CAP initiators "Potential Adverse Impacts of Workload on Nuclear Safety" QH Feedback to CAP initiators "Timely Resolution of identified Nuclear Safety issues" QH Availability of Hardcopy AR form "Nuclear Safety as Top Priority" Forum meeting on safety culture to be The December 2004 CCA results indicate that management attention is needed to provided by SVP in May 2007 address the underlying causes for the low ratings, particularly the ratings of Nuclear Safety Values, Behaviors & Practices. SCWE training scheduled for June 2007

3 PBNP Site Oraanization - Safetv Conscious Work Environment Action 1 - Communication Ratings of the following SCWE sub-metrics have declined significantly since the Safety Conscious Work Environment January 2003 CCA: guidebooks and briefing provided at Leadership Forum on March 20,2007 "SCWE Indicators & Precursors for the General Site Environment" Forum meeting on safety culture to be The December 2004 CCA results indicate that management attention is needed to provided by SVP in May 2007 address the underlying causes for this low and declined SCWE rating.

SCWE training scheduled for June 2007 4 o t Action 1 - Communication Action 2 - SuccessionIRetention Planning The ratings of the following GCWE sub-metrics or attributes are at levels that indicate Action 3 - Timeliness of Training the need for particular management attention. Action 4 - Engagement of CRCs "Performance Appraisal" Action 5 - RP Benchmark "General Communications" Action 6 - Observer of Priority 1 & 2 Groups "Overall Personal Satisfaction & Morale" Action 9 -Work Management "Performance Recognition" "Potential Adverse Impacts of Workload on Quality of Work and Plant QH Sr. Mgmt meetings with I&C Material ConditionIReliability" QH RP Equipment and Training "Personnel Development & Training" QH Team Building Session "Change Management" QH Team Building Session QH Team Building Session The following additional GCWE sub-metric or showed a significantly declined rating that indicates the need for management attention:

"Dignity, Trust & Respect" The December 2004 CCA results indicate that management attention is needed to address the underlying causes for the low and declined GCWE ratings.

5 PBNP Site Oraanization - Leadershi~,Manaaement and Su~ervisorvBehaviors & Action 1 - Communication Practices Action 2 - SuccessionlRetention Planning Action 3 - Timeliness of Training The December 2004 CCA results indicate that management attention is needed to Action 4 - Engagement of CRCs address the underlying causes for the low and declined [Leadership, Management Action 5 - RP Benchmark and Supervisory Behaviors, Skills & Practices (LMS)] Topics ratings. Action 6 - Observer of Priority 1 & 2 Groups Action 9 -Work Management Ratings of the following Topical Areas are at levels that indicate the need for QH Sr. Mgmt meetings with I&C particular management attention: QH RP Equipment and Training QH Team Building Session

'Trust & Confidence in Corporate Management" QH Team Building Session "Corporate Communications with the Workforce" QH Team Building Session Trust & Confidence in Site Managemenl" "Site Management Communications with the Workforce"

'Trust and Mutual Respect between Management and the Workforce" "Functional Organization Management Communications with the Workforce" The following additional LMS Topical Area showed a significantly declined rating that indicates the need for management attention:

"Trust and Mutual Respect between Supervision and the Workforce" The December 2004 CCA results indicate that management attention is needed to address the underlying causes for the low and declined ratings.

6 PBNP Site Oraanization - To~icalAreas of S~ecialInterest to NMC AR00510074 review conducted.

At NMC's request, the January 2003 CCA included survey questions to fully address the issues included in AR00510074. These survey questions were also included in the December 2004 CCA, thereby providing the bases for trending.

The 2004 CCA overall rating by PBNP Site Composite Organization for the issues included in AR00510074 is in the 'Adequate to Good" range. This rating has declined nominally since the January 2003 CCA, and is at a level that warrants management attention.

7 Oraanizations - Combined Metrics Action Plan and Quick Hitters derived from NSCl team interviews with focus groups.

Several individual PBNP Functional Organizations provided significantly lower ratings andlor showed very significantly declined rating trends. These organizations have Safety Conscious Work Environment been identified as warranting particular management attention. guidebooks and briefing provided at

- Leadership Forum on March 20,2007

For the Priority Level 1 and 2 Organizations, it is recommended that PBNP Forum meeting on safety culture to be management further evaluate each situation and take remedial action, as appropriate, provided by SVP in May 2007 in the near-term.

SCWE training scheduled for June 2007 8 Nuclear Safetv Values. Behaviors and Practices Action 1 - Communication Action 6 - Observer of Priority 1 & 2 Groups The NS VB&P Topical Areas with the lowest ratings are: Action 7 - Communication of Equip Issues Action 8 - Familiarity with new CAP process "Effective resolution of identified Nuclear Safety issues"

'Timely Resolution of identified Nuclear Safety issues" "Nuclear Safety as Top Priority" Topical Area ratings indicate that management attention is warranted.

9 Safetv Conscious Work Environment Action 1 - Communication Action 6 - Observer of Priority 1 & 2 Groups Ratings of the following SCWE sub-metrics is low and has declined significantly since the January 2003 CCA: Safety Conscious Work Environment guidebooks and briefing provided at "SCWE Indicators & Precursors for the General Site Environment" Leadership Forum on March 20,2007 Ratings indicate that management attention is warranted. Forum meeting on safety culture to be provided by SVP in May 2007 SCWE training scheduled for June 2007 11 V. v y Action 1 -Communication Behaviors & Practices Action 2 - Succession/Retention Planning Action 4 - Engagement of CRCs Ratings of the following Topical Areas are at levels that indicate the need for Action 5 - RP Benchmark particular management attention: Action 6 - Observer of Priority 1 & 2 Groups Action 9 -Work Management

'Trust & Confidence in Corporate Management" "Corporate Communications with the Workforce" QH Sr. Mgmt meetings with I&C

'Trust & Confidence in Site Management" -

QH-7 RP Equipment and Training "Site Management Communications with the Workforce" QH Team Building Session "Trust and Mutual Respect between Management and the Workforce" -

QH-12 Team Building Session "Functional Organization Management Communications with the Workforce" QH-l - Team Building Session

12 V 1 I . a Action Plan and Quick Hitters derived from NSCl Team interviews with focus groups.

A number of individual PBNP Functional Organizations have been "targeted" for additional management attention. They are identified herein and have been assigned Safety Conscious Work Environment priority levels. guidebooks and briefing provided at Leadership Forum on March 20,2007 Forum meeting on safety culture to be provided by SVP in May 2007 SCWE training scheduled for June 2007 13 VIII. NMC S~ecialTOD~CS of Interest AR00510074 review performed.

AR00510074 The 2004 CCA overall rating by the PBNP Site Organization for the issues included in AR00510074 is in the "Adequate to Good range. This rating has declined nominally since the January 2003 CCA and indicates that management attention is warranted.

14 X. O~~ortunities for lm~rovement Action Plan and Quick Hitters derived from NSCl Team interviews with focus groups.

The primary opportunities for PBNP improvement have been identified in Section I of this Executive Summary Report either as "areas warranting particular management Safety Conscious Work Environment attention" or as "Priority Level 1 or 2 Functional Organizations." guidebooks and briefing provided at Leadership Forum on March 20,2007 Forum meeting on safety culture to be provided by SVP in May 2007 SCWE training scheduled for June 2007

ENCLOSURE 6 SIGNIFICANT ISSUES IDENTlflED AS NEEDING MANAGEMENT AmENTlON IN THE 2006 NSCA 6 pages fdlw

SIGNIFICANT ISSUES IDENTIFIED AS NEEDING MANAGEMENT ATTENTION IN THE 2006 NSCA Problem Statements and Assoclated

1. Issue Descrlptlon Actions as Llsted In Enclosure 4 1 Nuclear Safetv Values. Behaviors and Practices Action 1 - Communication Action 2 - Succession/Retention Planning The NS VB&P rating is the predominant driver of the Overall NSC rating. The key Action 5 - RP Benchmark opportunities for improvement of the NS VB&P are in the following area: Action 9 -Work Management Individual Functional Organizations providing particularly low ratings of the QH RP Equipment and Training Adverse Impacts of Workload on Nuclear Safety have been identified.

These organizations warrant management attention.

2 Safetv Conscious Work Environment Action 1 - Communication Action 6 - Observer of Priority 1 & 2 Groups The key opportunities for improvement of the SCWE are in the following areas: Action 7 - Communication of Equip Issues PBNP Site Composite ratings of several SCWE questions and associated Action 8 - Familiarity with new CAP process attributes indicate the need for management attention to the general SCWE environment as it relates to: Training provided on the Operational Decision Making Issue (ODMI) process to supervisors Encouraging open, candid discussion and debate when Nuclear Safety and managers during 3Q06 matters are being evaluated; and Safety Conscious Work Environment Valuing individuals who demonstrate a questioning attitude on matters guidebooks and briefing provided at related to Nuclear Safety and safe plant operations, including treating them Leadership Forum on March 20, 2007 professionally with dignity and respect.

Forum meeting on safety culture to be provided by SVP in May 2007 SCWE training scheduled for June 2007

3 Other O~~ortunities for lm~rovement Action 1 - Communication Action 6 - Observer of Priority 1 & 2 Groups Individual Functional Organizations providing particularly low or significantly Action 7 - Communication of Equip Issues declined ratings of the General Adverse Impacts of Workload have been identified. Action 8 - Familiarity with new CAP process These organizations warrant management attention.

4 Other O~~ortunities for lm~rovement Action 1 - Communication Action 5 - RP Benchmark The PBNP Site Composite ratings of two areas indirectly related to the SCWE (i.e., Action 6 - Observer of Priority 1 & 2 Groups Quality of Communications with the Workforce, and Maintaining an Environment of Action 7 - Communication of Equip lssues Trust & Mutual Respect) indicate the need for continued improvement in these areas. Individual Functional Organizations that provided particularly low or Safety Conscious Work Environment significantly declined ratings of these two areas have been identified. These guidebooks and briefing provided at organizations warrant management attention. Leadership Forum on March 20,2007 Forum meeting on safety culture to be provided by SVP in May 2007 SCWE training scheduled for June 2007 5 JVuclear Safetv Values. Behaviors & Practices Action 1 - Communication Action 7 - Problem Resolution For the PBNP Site Composite Organization, the NS VB&P Metric with a Action 8 - Familiarity with new CAP process particularly low rating is:

Effective Resolution of Identified Nuclear Safety lssues This is an area in need of continued management attention.

6 Nuclear Safetv Values. Behaviors & Practices Action 1 - Communication Action 6 - Observer of Priority 1 & 2 Groups Individual survey questions related to NS VB&P with lower ratings indicate the Action 7 - Communication of Equip Issues need for continued management attention to the underlying NS VB&P attributes. Action 8 - Familiarity with new CAP process The vast majority of these attributes have shown improvement since the 2004 Action 9 - Work Management NSCA.

Safety Conscious Work Environment Within my Functional Organization, we perform line organization self- guidebooks and briefing provided at assessments that are effective in improving our Nuclear Safety Leadership Forum on March 20,2007 performance.

I am confident that the CAP will ensure that potential Nuclear Safety Forum meeting on safety culture to be problems are prioritized appropriately. provided by SVP in May 2007 Overall, the influence of Site senior management in promoting our Nuclear Safety priorities (i.e. by walking the talk and leading by example) is -

today.

Workload is not having an adverse impact on our ability to identify potential Nuclear Safety issues or concerns.

At our Site, we effectively utilize good practices and operating experience to improve our performance, including good practices or operating experience obtained from the nuclear industry.

At our Site, we effectively utilize good practices and operating experience to improve our performance, including good practices or operating experience obtained from other NMC Sites.

Within my Functional Organization, we value and use the insights and perspectives provided by Nuclear Oversight, Performance Assessment and other independent reviewers because these help us to strengthen Nuclear Safety and to enhance future performance.

Management at our Site ensures that actions taken to address issues related to Nuclear Safety and safe plant operations are defined and implemented in a timely manner.

Overall, the influence of management in my Functional Organization in promoting our Nuclear Safety priorities (is. by walking the talk and leading by example) is -today.

We properly balance Nuclear Safety, production, schedule and cost priorities as demonstrated by decisions related to continued plant operations.

The prospect of increasing workload for myself or others is currently not having an adverse impact on my willingness to identify and pursue resolution of potential Nuclear Safety issues or concerns.

7 Effectiveness of the Corrective Action Proaram Action 1 - Communication Action 6 - Observer of Priority 1 & 2 Groups The PBNP Site Composite rating of the Overall Effectiveness of the CAP is in the Action 7 - Communication of Equip Issues "Adequate to Good range. This rating has improved nominally since the 2004 NSCA and places the PBNP Site in the 15th percentile of the industry. QH Maintenance CAP Familiarization QH Feedback to CAP initiators This is an area in need of ~0ntinuedmanagement attention. QH Feedback to CAP initiators QH Availability of Hardcopy AR form

8 Adverse Impacts of Workload on Nuclear Safetv Action 2 - Succession/Retention Planning The PBNP Site Composite rating of Adverse Impacts of Workload on Nuclear Action 5 - RP Benchmark Safety is in the "Adequate to Good range. This rating has improved since the Action 9 -Work Management 2004 NSCA and places the PBNP Site in the 39th percentile of the industry.

All three of the Adverse Impacts of Workload on Nuclear Safety metrics showed nominal improvement.

One Metric had a particularly low rating: Adverse Impact of Workload on Ability to Effectively Resolve Identified Nuclear Safety Issues This is an area in need of continued management attention.

9 9 Action 1 - Communication Action 6 - Observer of Priority 1 & 2 Groups The percentage of survey respondents who indicated that they had personally received a negative reaction from their management during the past year for Safety Conscious Work Environment having raised an issue or concern related to Nuclear Safety was 10.5%, which guidebooks and briefing provided at places the PBNP Site in the 17th percentile of the industry. This percentage Leadership Forum on March 20,2007 increased since the 2004 NSCA, reflecting a declining SCWE performance trend.

Forum meeting on safety culture to be This warrants management attention, particularly for those individual Functional provided by SVP in May 2007 Organizations providing particularly high negative responses percentages.

SCWE training scheduled for June 2007 10 S s Action 1 - Communication Action 6 - Observer of Priority 1 & 2 Groups Individual survey questions related to SCWE Indicators and Precursors (I&P) with Action 7 - Communication of Equip lssues the lowest ratings are: Action 8 - Feedback for Equip Issues The low ratings or high negative response percentages for these questions QH Recognizing positive behaviors indicate potentially significant problems related to the underlying SCWE I&P attributes. These attributes represent significant opportunities for continued Training provided on the Operational Decision improvement of SCWE I&P. Some of these attributes have shown improvement Making (ODMI) process to supervisors and since the 2004 NSCA. managers during 3Q06 At our Site, the programs and processes that implement rewards, Safety Conscious Work Environment promotions, personnel recognition and personnel sanctions foster and guidebooks and briefing provided at reinforces attitudes and behaviors that are consistent with a strong Leadership Forum on March 20,2007 Nuclear Safety culture.

At our Site, we value individuals who demonstrate a questioning attitude Forum meeting on safety culture to be on matters related to Nuclear Safety and safe plant operations, and treat provided by SVP in May 2007 them professionally with dignity and respect.

At our Site, we encourage open, candid discussion and debate when SCWE training scheduled for June 2007 Nuclear Safety matters are being evaluated.

Concerns about receiving a negative reaction from my management are not having an adverse impact on my willingness to identify and pursue resolution of potential Nuclear Safety issues or concerns.

Concerns about being viewed as uncooperative, a complainer or as someone who is resistant to change are not having an adverse impact on my willingness to identify and pursue resolution of potential Nuclear Safety issues or concerns, I know someone who, during the past year, has experienced a negative reaction from supervision or management for having raised an issue or concern related to Nuclear Safety.

The lower ratings of these questions indicate the need for continued management attention to the underlying SCWE I&P attributes.

11 General Adverse lm~actsof Workload Action 1 - Communication Action 9 - Work Management Ratings of the individual survey questions related to General Adverse Impacts of Workload are as follows:

Workload is not having an adverse impact on our ability to assure the quality of our work products.

Workload is not having an adverse impact on our ability to maintain plant material condition or reliability.

12 Action 1 - Communication Action 6 - Observer of Priority 1 & 2 Groups Individual survey questions related to Overall Quality of Communications with low Action 7 - Communication of Equip Issues ratings indicate the need for management attention to:

QH SVP, Site Director and Plant Manager Management within my Functional Organization effectively communicates meetings with I&C the bases for changes in programs, policies and procedures.

Our Site senior managers are straightforward, open and honest in their Training provided on the ODMl Process to communications and interactions with the workforce. supervisors and managers during 3Q06 Our Site senior managers communicate sufficiently with the workforce.

13 Environment of Trust & Mutual R ~ s D ~ c ~ Action 1 - Communication Action 2 - Succession/Retention Planning Individual survey questions related to Overall Environment of Trust & Mutual -

Action 3 Timeliness of Training Respect with low ratings are: Action 6 - Observer of Priority 1 & 2 Groups Action 5 - RP Benchmark Supervisors and managers in my Functional Organization obtain workforce Action 7 - Communication of Equip Issues input and buy-in before implementing significant changes.

Our Site senior managers have earned my trust. QH Sr. Mgmt meetings with I&C Supervisors and managers in my Functional Organization regard people QH RP Equipment and Training and their professional capabilities, values and experiences as the QH Team Building Session organization's most valuable asset. QH Team Building Session Management in my Functional Organization has earned my trust. QH Team Building Session Supervisors and managers in my Functional Organization practice visible leadership in the field by observing the conduct of work, coaching, mentoring, reinforcing good behaviors and correcting deficient behaviors.

14 SYNERGY has established and implemented a methodology to identify any Action Plan and Quick Hitters derived from specific PBNP Site Functional Organizations that: NSCl Team interviews with focus groups.

Provided ratings that failed to meet "Industry Norms of Acceptability" - as Safety Conscious Work Environment interpreted by SYNERGY, or guidebooks and briefing provided at Represent, on a relative basis, outliers with respect to "Relative Norms of Leadership Forum on March 20, 2007 Performance" based upon comparison with PBNP Site general performance norms. Forum meeting on safety culture to be In applying this methodology, key cultural metrics were evaluated to provided by SVP in May 2007 identify both absolute and relative organizational strengths and weaknesses using complementary analytical techniques and specified SCWE Training scheduled for June 2007 selection criteria related to:

o Low absolute or relative NSC or SCWE ratings.

o High absolute or relative negative response rates (i.e., negative pockets).

o Declining NSC or SCWE ratings since the 2004 NSCA.

Based upon the application of this methodology, a number of individual PBNP Site Functional Organizations have been "targeted" for additional management attention. They are identified herein and have been assigned priority levels.