ML20134G976

Northeast Utilities Program for Addressing Employee Concerns

ML20134G976
Person / Time
Site:	Millstone
Issue date:	01/22/1997
From:	Kenyon B NORTHEAST UTILITIES SERVICE CO.
To:
Shared Package
ML20134G955	List: B16154, Forwards Plan & Program for Employee Concerns Re Dispositioning Safety Issues ML20134G975 ML20134G976
References
PROC-970122, NUDOCS 9702110106
Download: ML20134G976 (98)

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Northeast Utilities Program for Addressing Employee Concerns J

l PREPARED BY:

The Employee Concerns Program Task Force Millstone Station SUBMITTED TO:

Bruce D. Kenyon, President - CEO, Nuclear JANUARY 22,1997 l

I ECTy January 22, t997 D KOO 45 DR p P

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Executive Summary 1 On October 24,1996, the Nuclear Regulatory Commission (NRC) issued to Northeast Nuclear .

Energy Company (NNECo), an order to ". . . develop, submit for NRC review, and begin to [

implement a comprehensive plan for (a) reviewing and dispositioning safety issues raised by ,

its employees and (b) ensuring that employees who raise safety concems are not subject to  !

discrimination." Additionally, the Order required NNECo to address " root causes" identified by  ;

key NRC and NNECo review teams, ". . .with the objective of achieving a safety-conscious  :

environment". '

The Employee Concems Task Force (ECTF) has completed the activities required for Millstone Station to comply and respond to the Nuclear Regulatory Commission's Order. To that end, a '

comprehensive plan has been developed and presented with recommendations for adoption  !

by NNECo, hereafter Northeast Utilities (NU). This plan consists of six (6) major elements. l They are interdependent upon one another and are meant to enhance management / employee i relations while not usurping management prerogatives. Those elements are:

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. A commitment to rebuilding employee, regulatory and public trust, t

. Training and orientation to provide specific skills to reinforce a healthy l employee management relationship with respect to employee concems, l

. Specific organizational, policy and procedure changes,

. Development of Performance Action items that assign responsibility for implementation of the plan, A new Employee Concems Program and, ,

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l . Creation of a Concems Oversight Panel. ~

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The incorporation of the comprehensive plan into the day to day operation of Millstone represents a new commitment by NU management and employees to take those steps which ,

will result in employee concems being addressed in a comprehensive and fair manner. The {

success of the comprehensive plan will be apparent when the employees and supervisors l work together to resolve concems without fear of harassment, intimidation, discrimination or l

retaliation.

l The comprehensive plan, while developed by the ECTF volunteers from various sectors of the ,

Millstone community, represents input gathered via the aggressive solicitation of ideas from all r Millstone personnel, interviews, review of NU historical data and consideration of employee

! concems programs from other organizations. l l - .

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ECTF knn,y D. W g ,

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Table of Contents l

Executive Summary i

Table of Contents il 4.V Introduction 1

1.1 l Background of Employee Concern issues at Millstone 2 l 1.2 Nuclear Regulatory Commission Order of October 24,1996 2 I 1.3 Millstone Independent Review Group and 2 {

Fundamental Cause Assessment Team Root Causes l

i 2 .0 The Comprehensive Plan in Response to the NRC Order 6 Summary of Plan and Root Cause Corrective Action Recommendations 6 2.1 Rebuilding Employee, Regulatory and Public Trust 11 2.2 Training and Orientation 14 2.3 Organizational, Policy and Procedure Change Recommendations 19 for Human Resources and Employees Concems Program 2.4 Employee Concerns Program 22 2.5 Concems Oversight Panel 26 2.5.1 The Concems Oversight Panel Responsibilities 26 l 2.5.2 Development of'.ae Concems Oversight Panel 28 l 2.5.3 The Concems Oversight Panel Organization 28  :

2.6 Performance Action items 29 3.0 Program Outreach and Communications Plan I 43 4.0 Attachments 47 Attachment i Summary of Historical Themes Attachment il Matrix of the Comprehensive Plan to Identified Root Causes Attachment 111 Employee Concems Resolution Form Attachment IV Employee Concern Program Developmental Diagram Attachment V Employee Concem Program Procedure (in preparation)

Attachment VI Problem Resolution Standard Attachment Vil Employee Concems Task Force Letter Attachment Vill Transmittal Letter of Comprehensive Plan Attachment IX Acronyms Attachment X Transmittal Letter of Technical Concems Which Could impact Restart Attachment XI Northeast Utilities Plan for Addressing Employee Concems Q,,e ii  % 22. m I

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1.0 Introducti n i

l On October 24,1996 the Nuclear Regulatory Commission (NRC) issued an order to Northeast Utilities (NU) requiring NU to " .. develop, submit for NRC review, and begin to implement a comprehensive plan for (a) reviewing and dispositioning safety issues raised by its employees and (b) ensuring that employees who raise safety concems are not subject to discrimination."

tri response to this order Northeast Utilities established a task force of volunteer employees, including representatives of exempt staff, non-exempt staff, contractors 1

! and union, to design and develop a comprehensive plan to address work environment i

and employee concem program changes for submission to the NRC. Two facilitators '

t with extensive background in employee concems were employed to assist the task force in developing the new program. The task force convened on December 2,1996 and worked daily through January 22,1997 to develop this program. l While developing the plan, the Employee Concems Task Force (ECTF) actively solicited input from the Millstone employee population for consideration in the formulation and presentation of the comprehensive plan and the revised Employee )

Concems Program (ECP). This effort yielded many suggestions, which were included in the deliberations of the team.

While in the design phase, numerous individuals were interviewed by the Employee Concerns Task Force. Those interviewed included representatives from Human Resources, the current Employee Concem Program (ECP), members of the Peer Representative group, work force employees including the Barrier Breakers, a local politician, several NU vice presidents and directors, the president of the Nuclear organization, an ex-employee active in the area of nuclear safety issues and a senior counsel from the NU corporate legal group.

Additionally, employee concems p.ograms of other utilities were reviewed and evaluated for background information. The ECTF analyzed significant audits, reviews and reports which identified management and cultural problems, including independent assessments and the NRC Order.

The ECTF then undertook the development of a comprehensive plan which would fit the needs of the Millstone community. This development relied on the team's collective understanding of the Millstone culture, its history and the root causes attributable to the decline in overall nuclear performance. These factors led to the development of program element, which establishes a system of balance and accountability, unique to NU Nuclear's history. The ECTF strongly believes that the implementation of the comprehensive plan relies on the adoption of each element described herein.

The ECTF adopted the premise that whatever final product evolved, the ECP can succeed only if there is a commitment of individuals at all levels to support that success, in that:

f "It's not the paper, it's the people" \

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1.1 B:ckgr:und of Empi:yee C ncern is ue3 ct Millstone i On April 2,1982 Northeast Utilities (NU) established procedure NEO 2.15, " Employee Complaint Grievances" per 10CFR19. During the mid to late eighties an increasing number of concerns were being expressed by employees. It became evident by the growing number of contems being expressed that NU would need a department devoted to handling employee concems. A formal concems program wm established

,on December 4,1989. On January 1,1990 a Director-level position was established to head the new Nuclear Safety Concem Program (NSCP).

Over the past ten years Millstone has had a high number of employee concems and allegations related to the saftty of plant operations, harassment, intimidation, retaliation, and discrimination of employees raising such issues (see Attachment I for further details). NU's response to many of these allegations has been considered inadequate and adversarial by employees using the present Employee Concems i Program, the NRC, and the public. The NRC conducted many inspections and investigations which substantiated many of the employee concems and allegations,  ;

including the inability of NU to address concems in a competent and responsive i manner. As a result, NU has been cited for violations and escalated enforcement action has been taken. Both the NRC and NU's intemal audits have concluded that the company has not been effective in the area of handling employee concems, nor in implementing effective corrective action for problems that have been identified by concemed employees. As a result, employees have lost faith in the current Employee Concems Program and NU management's willingness or ability to address concems. l Consequently, the handling of employee concems at NU has been the topic of discussion from the public town meeting level to the United States Congressional level.

Finally, NU has lost litigation with former employees, or has failed to convince the NRC that its approach to complaints and concems is reliable.

1.2 The Nuclear Regulatory Commission Order of October 24,1996 The NRC, in its October 24,1996 Order, stated that the Northeast Nuclear Energ)

Company (NNECO) must " . develop, submit for NRC review, and begin to implemen' i a comprehensive plan for (a) reviewing and dispositioning safety issues raised by its employees and (b) ensuring that employees who raise safety concems are not subject to discrimination." Further, ". . .the comprehensive plan shall address the root causes of past performance failures as described in the Licensee's July 12,1996 report of the Fundamental Cause Assessment Team and the NRC's September 1996 report of the Millstone Independent Review Group with the objective of achieving a safety-conscious environment."

1.3 Millstone Independent Review Group (MIRG) and Fundamental Cause Assessment Team (FCAT)

A summary of the basis for the comprehensive plan follows. Please note that this discussion parallels the format of *NU Root Causes for Problems", Section 7, of the Millstone Independent Review Group (MIRG) Report. In so doing, reference is made to ongoing initiatives outside of the scope of the Employee Concems Task Force's endeavor for the purpose of ensuring that all identified root causes are being addressed. Specific root cause corrective action recommendations are listed in Section

2.0 and Attachment II,

• Matrix of comprehensive plan to identified Root Causes".

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Root Cause # 1: Inadequate Problem Resolution and Performance Measures' The MIRG concluded that NU did a good job of identifying problems, but has had an ineffective problem resolution process. In sum, this weakness spans the spectrum from problem identification to untimely resolution, including a cumbersome decision making <

process that all too often relies on rationalizing problems away.

Root cause analysis techniques are weak, sometimes identifying symptoms vice root causes. Performance indicators and self assessment are not effectively used, with slow follow-up oftentimes not using the logical resources for implementation of corrective measures. These weaknesses, when combined with senior management's unwillingness to support Gose fundamental actions necessary to effect change, cause many employees to feo, the necessity to go to the NRC with issues rather than attempt to disposition these through the normal line channels and/or the Employee Concems Program. The MIRG's assessment, while more detailed, is consistent with the findings of the FCAT.

Root Cause # 2: Lack of Sensitivity to Employee Needs2 The NRC Team concluded that Millstone management has been, in general, insensitive i to employee needs. This is evidenced by a lack of identifiable efforts to take actions which could reduce or counter events which tend to contribute to creation of a " chilling" environment. There has also been a discouragement of dissenting opinions to the point l of some employees believing that certain individuals have been " black listed", along with the consistently predictable corporate denial, via highly visible cr,edia, of all adverse findings in the area of harassment and intimidation. The FCAT concluded that management weaknesses in the area of interpersonal skills resulted in an inability to foster trust, teamwork and good morale. Additionally, there was a failure to communicate and capitalize on lessons leamed.

Root Cause # 3: Reluctance to Admit Mistakes' The MIRG concluded that management's reluctance to admit mistakes has significantly impeded the corporate attitude toward Millstone employees who raise concems. The l use of legalistic approaches by the Human Resources group, the protracted study of I some issues, the discrediting of assessment results, the feeling of futility relative to the filing of a concem with the ECP and a " shoot the messenger" attitude toward those who bring issues forward, have all contributed to a pervasive chilling effect. The FCAT  !

concluded that there has been an ineffective leadership team having weak interpersonal skills and a willingness to accept low standards at Millstone, findings consistent with those of the MIRG.

Root Cause # 4: Management Style and Support for Concemed Employees" The MIRG identified the existence of an arrogant management style condoned by top leadership, which has not been supportive of concerned employees. Retaliation against employees was not acknowledged, resulting in no disciplinary action taken against l

8 l See the MIRG Report, Section 7.1 for additional details 2

l See the MIRG Report, Section 7.2 for additional details 8

1 See the MIRG Report, Section 7.3 for additional details l ' See the MIRG Report, Section 7.4 for additional details l 3 .im 22. nn

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off;nding minig:m:nt. Tcchnical conceit was cvid:nced within engineering management resulting in a lack of conservative decision making. Promotions to management positions of technically competent individuals without sufficient regard for people skills contributed to some managers having poor listening skills and created an environment where a questioning attitude was not tolerated. This was further evidenced by management's lack of recognition for employees who raised safety concems and by high level NU managers who made statements that degraded employees who had

, raised concerns to the NRC.

The MIRG was also critical of Human Resources tendency to develop legalistic approaches to contest Department of Labor (DOL) findings of discrimination. The FCAT concluded that the nuclear organization leadership's management and interpersonal skills were weak and a questioning attitude was lacking, contributing to deficiencies in programs and processes and the lack of conservatism in decision making involving plant operations and maintenance. This led to reduced margins favoring continued operations and cost containment. The FCAT specifically noted management's ineffectiveness in responding to many employee concerns.

Root Cause # 5: Lack of Communications and Poor Teamwork 5 The MIRG concluded that communications at Millstone has been a continuing problem area, characterized by poor inter-departmentalinteraction, general failure to encourage a questioning attitude, and a tendency to manage by memorandum. The methods, functions and current philosophy of several departments is not well known to some employees. Some managers were noted as being unaware of the magnitude of problems outside their own organization. The Differing Professional Opinion (DPO) process was not effectively championed. Several instances of ineffective communications were noted in the areas of bases for performance evaluations, reasons for disciplinary actions and the communication of reasons for delays in resolving concerns brought to management attention.

There has been a misapplication of the concept of " teamwork"in part of the work force, with some employees perceiving that the need to be viewed as a

• team player" is discouraging dissenting opinions. It was noted that some former employees were excluded from decision making processes since they were not viewed as team players after they raised safety concems. Furthermore, " teamwork" was misperceived by a portion of the work force to mean that there is a need for total consensus to the detriment of proper and timely decision making. The FCAT identified the existence of ineffective communications among and within the various parts of the NU nuclear organization. Lessons leamed by one NU nuclear unit were not effectively communicated to or acted upon by other NU organizations. Additionally, communications to employees have often been untimely or unclear.

Root Cause # 6: The Lack of Management Accountability

• The MIRG concluded that a generallack of management accountability and sense of ownership has contributed to current problems at Millstone. An example is that management is perceived as being more focused on justifying the status quo rather than aggressively addressing or resolving employee-identified problems. There is a 5

See the MIRG Report, Section 7.5 for additional details

• See the MIRG Report, Section 7.6 for additional details scrr 4 . ram zz. ins

i widesprud beli:f cmong th2 work force th t supervision his not been sv luttId for  !

performance in this area on perfommnce reviews. The MIRG also concurred with a  ;

j widely held employee belief that supervisors responsible for discriminating against  :

l employees were not routinely disciplined in an appropriate manner. Another problem in ,

! this area was the absence of position descriptions for some employees and managers,  !

leaving both groups uncertain about their duties, responsibilities, and authority. I Responsibility for handling employee concems was noted to be abrogated by line I n)anagement through inappropriate referral to the Legal Organization or to the i Employee Concems Program. The FCAT also identified a series of significant events  !

and long-standing issues arising from decisions to justify the status quo rather than attack and resolve issues, essentially validating the MIRG findings.

Root Cause # 7: Nuclear safety Concerns Program (NSCP) Implementation 7 The MIRG concluded that based on the large number of allegations the NRC has received, the Employee Concems Program had not done an effective job of dealing with employee concems. The NRC report cited NU for lack of management support for the program as well as inadequate resources and insufficient independence and authority to fully resolve issues. The MIRG also noted a poor corrective action process and the failure to deal with concems in a timely _ manner. Employees expressed a concem that the ECP director reported directly to a vice-president and therefore may lack the proper independence or authority to address some concems. Millstone self assessments have noted that a lack of support by line management has contributed to the backlog of unresolved concems and this inability to effectively deal with the concems has led many employees to take their concems directly to the NRC. While the FCAT did not specifically address the NSCP, one of the fundamental causes they identified, that management was ineffective in responding to many employee concems, is related.

' See the MIRG Repon, Section 7.7 for additional details scir $ ""*> 21 m' C ,. w Men

2.0 The C mprehen:lva Plan in R:spinse 13 the NRC Order i

Summary of the Plan and Root Cause Corrective Action Recommendations

, The comprehensive plan consists of six key elements, summarized below. Each of these elements will require new or revised programs at Millstone. Implementing these changes will bring about a break with past practices, and restore a culture based on

, respect and recognition of employee contribution to a safe and productive environment.

. Each element is interdependent thereby making the success of this plan incumbent upon the adoption and incorporation of all the elements. Selected portions of the best industry practices were used as the comerstone for this comprehensive plan and 4

revisions to the Employee Concem Program. The comprehensive plan allows for  ;

revisions based upon experience in plan implementation.

j e Rebuilding Employee, Agency, and Public Trust (see Section 2.1)

The ultimate measure of the success of this comprehensive plan is the day-to-day l

interaction of employees and supervision to identify and resolve concems without I discouragement or retaliation. Rebuilding trust involves open communication, positive actions, and enforcement of the process to ensure complete and fair treatment of i employees. This comprehensive plan represents a new commitment by NU ,

management and Millstone employees to take those steps that will result in an i environment that welcomes concems and investigates those issues to a full and final l resolution and treats each employee in a fair manner.

, The success of the comprehensive plan is contingent on full management support and participation. The plan includes self-assessment tools for the Employee Concems Program, measurement of the work environment atmosphere to judge progress, i identification of problem areas, and provides a mechanism to establish and maintain l

accountability. As the work environment improves and management begins to assume '

responsibility and accountability for handling concems, the most active intervention elements may be considered for obsolescence.

, The ECTF believes that successful implementation of this plan will help bring Millstone back to the forefront of the nuclear industry.

. Training & Orientation (see Section 2.2)

A critical element in reversing the present culture will be the training of the Millstone workforce in new expectations for employee - management relations, the comprehensive plan and the new Employee Concems Program. The plan incorporates orientation and training, and integrates awareness on handling of employee concems into the process. Training in the new ECP will commence with top level management, and proceed down through officers, directors, managers, first line supervisors, and then the general work force. The program elements for raising and handling employee concems and professional dissent will be set forth in such a manner that there will be no question regarding the role, responsibility and accountability for all employees. The training will be developed to provide knowledge and specific skills to succeed in the new work environment.

ICTF Janney 22. I991 Connpntwun.e1%n 6

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Additionally, retirees from NU, former NU employees, state and local govemment leaders and the general public will be made aware of the new Employee Concerns Program. This will be accomplished through an involved communications plan which includes public meetings, newsletters, etc.

Organizational, Policy and Procedure Change Recommendations (see Section 2.3)

.The ECTF has recommended several significant staff and policy changes, including the addition of a senior Human Resources individual being assigned to the nuclear organization, reporting directly to the CEO. The comprehensive plan provides for a review and revision of site procedures to ensure that all the programs and processes recognize and support the contributions of individual employees. Additionally, the Employee Concems Task Force has recommended the review and modification of personnel procedures, performance review processes, supervisor selection and promotion criteria, and other programs to ensure that these policies incorporate the elements of the comprehensive plan.

The ECTF recommends the development of a protocol to facilitate the interaction between Human Resources and the Employee Concems Program. A modification to ,

the LINKS Performance Review Program is recommended to ensure a positive l response to the raising of concerns and the expression of differing opinions. Also, a review of job descriptions to bring them current in the context of the ECP, including the expectations to incorporate recognition for encouraging and positive handling of employee concems. Finally, the ECTF has recommended consideration of a peer review process as an altemative to litigation. i

. Employee Concerns Program (see Section 2.4) i The Employee Concern Program (ECP) provides employees the resources and options necessary to help ensure concerns are handled in a fair and competent manner, i Although the ultimate measure of success will be employees' confidence in addressing and resolving concems with first line management, this plan recognizes that there will be instances when concemed employees will choose to use the ECP.

The new ECP process includes three fundamental steps. First, is the intake Phase, in I which a trained interviewer receives the r.smployee concem and assures it is accurately documented with concurrence of the concemed individual (Cl). During the intake process, attempts will be made for ;nformal resolution or referral, if appropriate, through normal channels. If the issue cannot be immediately resolved, the concem goes to the Triage phase. Here, a team approach is used by a group of individuals selected to provide resolution. Each facet of the concem is reviewed and evaluated.

Ideally, the Triage phase will develop an informal resolution acceptable to the Cl. If not, .

issues will be passed onto the third phase which is a formal investigation which will be performed by a competent and independent investigation team. When substantiated and causes determined, then a corrective action plan will be developed to address each element of the concem. The Cl should play an active role throughout the employee concem process.

Once the investigation is completed and all agreed-to actions have been taken, the Cl may, upon review, determine that all elements were not sufficiently evaluated and therefore disagree with the results. In cases of full agreement, the case is closed by the

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ECP. In cases of disagreement, the Cl may request a case review by the Concems i

! Oversight Panel.

l e . The Concerns Oversight Panel (see Section 2.5) f l

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l The Concerns Oversight Panel is designed to serve as a check and balance on the  !

l ECP and management to promote the practice of "doing the right thing", establish >

visible accountability, and ensure that the new programs are implemented and i l sustained. ,

i" The conception, development and implementation of the Concems Oversight Panel is integral to various stages and processes to the "new" ECP. The Concems Oversight  !

Panel will review all requests for third party reviews, and may request additional l investigation, assist in resolution, or close the case.  !

The nine-member Concems Oversight Panel will provide oversight of the Employee Concems Program, intervene on harassment, intimidation, retaliation and discrimination ,

, cases, review the work environment for " chilling effect", evaluate requests for third party i reviews, review employee terminations and layoffs with respect to protected activities, -

and perform "hotspot" intervention where appropriate.

The Concems Oversight Panel will be selected through a formal process to identify individuals from all segments of the organization whose integrity and competency are well respected throughout the site.

Performance Action items (see Section 2.6)

A series of Performance Action items (PAI) have been developed to ensure successful implementation of this comprehensive plan. Pals listed are the action steps that the ECTF has determined are necesnry to implement this comprehensive plan and promote its continued success. These steps are supported by specific objectives and matrixed to the various root causes identified by the NRC order.

Root Cause Corrective Action Recommendations (see Section 1.3)

Root Cause #1: Inadequate Problem Resolution and Performance Measures Adoption of the comprehensive plan's recommendations included in this report will result in a culture at Millstone that encourages "a questioning attitude" and

" conservative decision making". The new leadership team is currently demonstrating  !

their expectations by modeling behaviors and communicating their expectations.

Training for management and workers alike is recommended which focuses on problem solving, conservative decision making and the expectations that illustrate constructive methods for evaluating personnel performance.

Included in the ECTF's recommendations are steps to develop measures of performance that will help to identify

• hot spots" in the organization where there is a need for management and interpersonal skill development and/or discipline based on demonstrated insensitivity when dealing with subordinates. The implementation of a significantly improved Employee Concems Program (ECP), processing all types of concems, will reinforce employee belief that ali ievels of management recognize the scrr g .r ,n un

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I need for th:s3 kinds of ching). Th3 ECTF is clso r:comm:nding creation of an Concerns Oversight Panel to assure accountability. These actions, when combined with i the improved Corrective Action Process currently under development and the new I leadership team's commitment to "do what's right", will result in a healthier relationship between employees and management, which in tum will result in a significantly improved problem resolution process.

, Root Cause # 2: Lack of Sensitivity to Employee Needs While the comprehensive plan does not interfere with traditional management authority, it underscores new expectations for accountability. The new leadership is presently communicating expectations and modeling desired interpersonal skills and techniques

] for resolving issues. Training for management in areas which will improve communications, give guidance on professional dissent, develop interpersonal skills, i outline methods for making proper conservative decisions, and maintain awareness of l management's expectations are recommended by the ECTF. As noted previously,

, implementation of the recommended ECP and accompanying performance action items will facilitate prompt response and resolution of concems as well as a capability for management to measure and assess performance. Instances of unacceptable line management performance in the area of dealing with employee concerns will be identified through the recommended process thereby revealing the poor performers.

The periodic use of surveying techniques such as those recently employed is endorsed

, by the ECTF. Development of a questionnaire seeking the input of current and former

! employees as a means of leaming from past wrongdoing is strongly suggested. The information from this questionnaire will identify past issues or events that continue to have a chilling effect.

Where management fails to meet new expectations, the use of effective progressive discipline techniques needs to be employed with the intent of either improving performance or removing individual (s) from r anagement positions who cannot meet j NU's goals. Above all, management must hold organizational leads accountable for the establishment of a working environment conducive to open discussion, professional

dissenting opinions and a healthy level of trust among and between working level and management employees.

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Root Cause # 3

Reluctance to Admit Mistakes

Millstone management needs to embrace the philosophy that the mistakes that will inevitably happen must be recognized and leamed from. This is a key expectation espoused by one of the Unit Recovery Officers in a recent Expectations paper.

Special awards or incentive programs (such as Spot Recognition) are recommended to visibly send the message that Millstone management appreciates the efforts of those identifying issues so that these can be evaluated and promptly understood and, as necessary, corrected.

The ECTF has recommended a revised ECP and the use of qualified ECP intake counselors and mentors to help the individual through the process with the goal of a prompt quality outcome and to negate the feeling of isolation that a concemee might experience. The plan also incorporates a third party review process to assist in

resolving issues. The ECTF believes that a responsive, " user friendly" and consistent scir 9 .i -rn un c m.

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ECP th;t is ch mpion:d by tha high:st I vils of Millstons m; rug:m:nt will ultimit:ly restore trust. This trust must be established between employees and management.

Root Cause # 4: Management Style and Support for Concemed Employees The ECTF has provided the framework and detailed working procedure for a revised ECP that has the means to detect evidence of harassment and intimidation through the use of meaningful performance indicators. We fully expect that organizational " hot s ots" will be readily detected through the use of case files, surveys and Concems Oversight Panel reviews and recommendations. Managers who are unwilling to accept the new expectations will then need to be held accountable for their actions. Concems Oversight Panel review of management decisions in chilling effect situations will provide an additional check and balance too! for NU senior officers.

ECTF recommends a strong message be sent by leadership that there will be no toleration of retaliation against employees who raise concems and that this message be posted sitewide as an expectation. The ECTF recommends that training requirements to be presented to all levels of management to improve professional skills in the area of listening, prevention of a chilling environment and dealing with dissent.

ECTF also recommends that an awards program be established to recognize individuals who bring concems forward.

The plan also recommends that concems be brought to resolution with the concemees knowledge of disposition, within approximately 45 days or in a time frame agreed upon '

by the concernee. The Human Resources organization and ECP staff need to establish a partnering relationship, working as a team to resolve concems that have Human Resource and ECP implications. Establishing cooperation between employees, management, Human Resources and the ECP will help to promote the growth of a healthy work environment free of retaliation and restore trust.

Root Cause # 5: Lack of Communicatons and Poor Teamwork The new management team has established a clear expectation to the work force regarding inter-departmental communication and interaction. Several examples of new programs recently put in place include the PEER Representativ, Program (Nuclear Group), the Barrier Breakers (site) and the Employee Review Board (MP3). NU is actively promoting industry and unit-wide interaction to ensure NU gains a position of industry leadership once again. The ECTF has recommended the development of a protocol to be utilized between the ECP staff and Human Resources when involved with concerned employees.

The ECTF has also been assured that the Legal Department has revised their approach to pre-litigation and litigation strategies. The Differing Professional Opinion (DPO) process needs to be communicated and promoted as a " process of choice" for use in resolving differing technical opinions. Of utmoa,t importance is a proper roll-out of the new comprehensive plan with senior management support. The ECTF strongly recommends a high management profile in the field as a means to restore trust in the workplace and open line communication as opposed to " management by memo."

Finally, the ECTF promotes the careful and thoughtful use of the word Teamwork by management so as to promptly restore its true meaning.

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I l Root Cause # 6: The Lack of Management Accountability l The Chief Executive Officer, Nuclear, and the Recovery Officers have taken the initiative to establish accountability throughout the organization. This initiative has elevated the topic of employee concems stating that management at all levels is expected to provide dynamic and visible leadership necessary to bring about required fundamental change. This is aggressively being pursued and communicated throughout the Millstone organization in the form of clear expectations. The ECTF has witnessed considerable evidence that the new leadership team is actively working to restore accountability. Additionally, the ECTF recommends that the Human Resources Organization develop appropriate descriptions for all existing and proposed positions.

The new ECP will also have performance indicators to bring " hot spots" of employee concems to management's attention to ensure proper handling and to the Concems Oversight Panel for review. The program will also reinforce the requirement for line management to demonstrate accountability by establishing an approximate 45 day period for handling most concems. The Concems Oversight Panel will provide oversight of the Employee Concems . Program, and ensure that all cases of harassment, intimidation, retaliation and discrimination are being handled in a manner that is respectful of the parties involved, and wards off any " chilling effect" on other employees.

Root Cause # 7: NSCP Implementation The comprehensive plan calls for a strong orientation program for the new plan to be actively attended by senior management as a display of their support. A time limit of approximately 45 days has been specified for responding to employee concems, replacing the former "in a timely manner" terminology that has led to poor results and criticism in the past. A major focus of th) Employee Concems Task Force was to develop an employee concems program with features and safeguards essential to an effective program. An Concems Oversight Panel has been established to ensure that management makes progress toward restoring trust and accountability so essential to the re-establishment of employee trust.

The ECTF concurs with the MIRG observations from interviewed employees that the ECP Director must have the authority, independence, and objectivity to effectively champion ECP's role in resolving employee concems, and recommends that line management actively support these objectives. The ECTF further recommends that the staffing levels of the department be increased, and an additional full time administrator for the Concems Oversight Panel be appointed. We recommend that the ECP Director report functionally to the CEO, Nuclear and report administratively to the Board of Trustees.

2.1 Rebuilding Employee, Agency and Public Trust An initial step in regaining employee, agency, and public trust is that the VP of Nuclear Oversight elected to have this comprehensive plan, which is an integral part of the entire recovery process developed by a task force of volunteer employees. The ECTF concluded that strong recommendations were necessary to effect a plan that could succeed.

g_ ,,, 11 ' * ""

It is important to recognize that all of the root causes are symptomatic of ineffective and j weak leadership, a malady already acknowledged by the senior nuclear management  !

team to have existed at Millstone Station. It is equally important to recognize that the  !

comprehensive plan is, essentially, a recovery plan to restore ethical and accountable leadership to Millstone. This philosophy is espoused in the words of one of the '

Recovery Officers, as follows:

i l

Expectations ,

l l This message is specifically for the Unit's management and supervisory team, but it  ;

includes expectations that each of us can help satisfy.

It is my expectation that: '

l . We will make our expectations clear to our employees.

. We will hold ourselves accountable to uncompromising levels of performance.

l . We will encourage empicyees to identify issues.

]

. We will treat employees with respect and value their input - any input ]

. We will encourage an en>ironment where employees are not afraid to make decisions or try new approaches.

. We will recognize that mistakc:: occur. Leaming from the mistakes is l most important - nql the mistakes themselves.

. We will ngt tolerate those who create a hostile, unprofessional, or intimidating work environment.

I have many more expectations, but these are the most important ones on the list.

These are the basics that will provide the foundation upon which we build the future.

Two final expectations:

. I expect each manager and supervisor to fully embrace the above expectations and to discuss them with their employees.

. If any employee finds their manager or supervisor falling short on these expectations, please tell me personally.

I want these expectations to be p_ur expectations.

l I

In addition to other actions required by the comprehensive plan, an Concems Oversight ,

Panel is proposed to search out and recommend remedial actions for improving areas )

of weakness within the organization related to processing of employee concems. It takes into account many characteristics that interact with one another in a manner that will help reestablish trust between Millstone management and its employees. The comprehensive plan provides the steps required to address concems in a full, fair and  !

final manner. It will be evident that the comprehensive plan is performing near its highest efficiency when employees trust that their concems will be addressed by line management in a manner that is mutually agreeable.

I ECTy demmy ZE, I997 c%,m

l Employee Trust l l

A theme developed and used as a continuing reminder for the Employee Concems i Task Force (ECTF) to remain focused on their main goal was that, .

'It's not the paper, it's the people."

1 l .The ECTF reviewed assessments and reports identifying needed corrective actions, and identified matrixed elements to address necessary activities that will enable Millstone to proceed toward recovery.

Elements that were determined to require action included: poor root cause analysis, l ineffective long term corrective actions, reluctance to admit mistakes, arrogant management style and the tendency to develop HR " legalistic approaches." The ,

comprehensive plan establishes measurable deliverables that, when fully developed i and implemented, are designed to compel individuals to behave differently within all '

levels of the Millstone organization, reducing the opportunities that result in peer pressure deterring coworkers from identifying concems.

Agency Trust A critical phase to support validation of a positive change in the Millstone culture is that it must be visible to any outside agency. Since the agency may not be involved in the day to day activities at the site, verifiable signs must be inherent in the process to indicate positive change. Mandating that an Independent Oversight Team (IOT) be ,

contracted to oversee implementation and continuing assessment of the "new" process i stresses the importance that this undertaking must be verified to be effective before I any unit is allowed to start up.

This highly visible commitment from management should be considered as one that will not only help to rebuild trust with employees, but also indicates to extemal agencies that NU management is beginning to take steps towards positive change, therefore helping to rebuild trust at the agency level.

A series of Performance Action items has been developed and assigned to various individuals or groups at Millstone to help assure successful implementation of the comprehensive plan. The Concems Oversight Panel will oversee and steer those accountable toward active participation in reaching the goal of implementing a successful program. Success of the comprehensive plan is measurable and will promote a higher level of trust to develop between Millstone and outside agencies.

Similar to measuring the success between employees and management, the same philosophy can be used to measure trust between outside agencies and Millstone. As mentioned previously, it will be evident that the comprehensive plan is performing near its highest efficiency when employees trust that their concems will be addressed by management in a manner that is mutually agreeable. Visible success of these elements, when combined, will form yet another facet of trust between outside agencies and Millstone.

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Public Tru t The combination of the previous two sections should produce results which when added to the following discussion will help rebuild trust between the public and Millstone. The public receives most of its information from two sources: the newspaper and television. This may be a case where the anecdote, "no news is good news", would be appropriate. When there is no negative news to report, the public hopefully will

. regain trust in Millstone.

To provide an appropriate introduction of the comprehensive plan to the public, an orderly process is recommended. A Millstone Communications Specialist has been assigned to coordinate with the ECTF. Ongoing press releases will be issued to the news media, a transmittal presenting the Plan to the NRC will become a public document. Finally, it is recommended letters be sent to local politicians, former concemed employees and retired employees. The letters should include a question and answer brochure and a timeline for program implementation. This information will also be sent to community outreach groups, i.e., Citizen's Regulatory Committee, Citizen's Advisory Committee and others that may.be noted during the outreach process. It is expected that regaining public trust will take longer than regaining trust from the employees and outside agencies since the public does not have access to the day to day positive steps that will be taken at the site to implement the comprehensive plan. In order to provide information to the public, the ECTF recommends regular briefings of concemed members of the public through press and television media.

2.2 Training and Orientation The goal of creating a healthy work environment can be considered to be fulfilled by the comprehensive plan when the majority of concems are successfully handled between the employee and their first line supervisor. To help facilitate meeting this goal, enhanced skills are needed across all levels of personnel to create an environment where employee concems are addressed in a full, fair and final manner.

Senior Management (Vice-President and Director Level)

Senior Management must receive a full briefing on the comprehensive plan and the new Employee Concems Program. This training in the new accountabilities and expectations of the ECP will be conducted prior to manager and supervisor training in order that senior management be able to set the example for the level of management reporting to them, especially first line supervision. It is critical that senior level managers receive training in effective management of professional dissent and Managing for Nuclear Safety.

Managers and First Line Supervision Encouraging employees to pursue DPOs which conflict with accepted views is neither natural nor easy. The Employee Concems Task Force has identified that a training module needs to be developed and incorporated in all site training. The Nuclear Training Department is developing the courses required for first line supervision and building a performance contract matrix with agreed upon timelines to demonstrate proficiency in the expected competencies. All managers need to attend or demonstrate proficiency in the following training:

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Comprehesanw Man 14

_ _ _._ _ __ _ -_ _ _ _ _ _ .. _ . ___ _ ._ _ _ _ . . . m.__. _ _ . _ . .

I SevIn H: bits of Highly Effictive People j MBTI: Myers-Briggs Type Indicators '

Labor Relations l =

Principle Centered Leadership  ;

. Interpersonal Skills l Ethical Issues in Engineering Managing for Nuclear Safety

~k li addition to these existing programs, training modules in the following areas need to be developed and presented: 1 l

Differing Professional Opinion (DPO) l l Successfully working with employees who present a differing opinion is not easy. There are no current courses inside of Northeast Utilities that address this area. As training in this area is critical to the success of NU, a vendor, experienced and knowledgeable in the area of professional dissent, should be contracted to conduct this essential training for the ECP staff prior to the implementation of the comprehensive plan, and for all supervisors, managers, directors and officers as scheduled after implementation.

Interviewing and Listening Skills The psychology of information gathering, listening and the demeanor for interviewing concemed individuals is fundamental to the success of this comprehensive program.

Courses addressing these skills need to be identified as part of training.

. Chilling Effect A thorough understanding of what constitutes and causes a " chilling effect" combined with methods to recognize and treat the problem needs to be incorporated in training modules for management and employees.

To assist line management in their responsibilities to resolve concems of employees, Employee Concems Task Force recommends the adoption of the Employee Concems Resolution Form (Attachment 111). This form provides an avenue for an employee to express a concem in writing, directly to their first-line supervisor, who will try to achieve a mutually acceptable resolution. The investigation of the concem and the actions taken to resolve the concem in a competent and timely manner are agreed upon by both parties. This form will serve to document and track the issue. The form is then ,

dated and signed by the employee and the supervisor. This innovative process is the I first step toward addressing concems in a manner agreeable to all before going to the Employee Concems Program. Should the employee choose to employ this method of resolution and it does not satisfy the concemed individual, the employee can still go to ECP or other agency of their choice.

I Human Resources Staff l

Past audits and reports have determined that a majority of the concems expressed by employees are rooted in areas traditionally the responsibility of Human Resources (i.e., l performance appraisals, wage and hour issues, assignments). The revised ECP 1' program does not attempt to substitute for the traditional role of Human Resources; scrr 1$ .r -r 22. inr c, - m na, l

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howev:r, in ord:r to b) r sponsiva to til cmploye] concems the ECP may receive these concems. Collaboration between ECP and HR in addressing the issue is critical.

This comprehensive plan requires a dynamic working relationship between the l

Employee Concems Staff and the Human Resources Department. Therefore, the HR staff will need some of the same training as the ECP staff including:

.- . Interviewing Skills

. investigative Report Writing

. Investigative Planning

. Effective Writing l

. Listening Skills

. Team Building - As part of team building, it may be appropriate to include other groups who may play a major role in the investigation of concems I including but not limited to Intemal Audit, Security and Safety. By i developing a sense that all areas of NU are part of the process, we may be able to avoid some of the territorial disputes that in the past have created obstac'es to the investigation of concems.

All Employees All employees including contractors need to receive training about the new ECP program and the expectations set forth which detail the responsibilities of non-management employees. This training needs to be used in the roll out of the program for all emp!oyees and will be included as part of initial and annual Plant Access Training (PAT). The Employee Concems Task Force recommends that the following practicer l be applied to reinforce PAT in the ECP area:

Hold biannual department meetings to review the ECP video, to discuss the elements of the Employee Concems Program, and perhaps even interact with ECP staff members. This will provide an opponunity for first line management to reaffirm their support of the ECP.

Increase and change the number and nature of questions relating to the l Employee Concerns Program included in future PAT testing.

Partnership 2000 training has not been well received by the employees who have attended. Changes to these programs are necessary and should include sections l relevant to resolution of employee concerns and the ECP.

ECP Investigators and intake Staff The ECP staff needs a skill set that takes into account the varied nature and responsibilities of their work. They will not only be obtaining information that may ultimately lead to formal investigations, but need to be objective listeners as well as skilled report writers. The following list details training or previously acquired skill sets that will be required by certain members of the ECP staff along witn any recommended courses that may be available inside of Northeast Utilities. A customized performance contract should be developed for each staff member identifying which courses need to be completed.

scr' 16 ' ~ " " "

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• Inttrvi1 wing Skills Course to cover interview demeanor, the psychology of information gathering, overview on interviewing theory, verbal and non-verbal clues of deception, taking signed I statements and why interviews may fail.

- LegalIssues in Employment Idourse covering the use of attomey-client privilegs, protecting material under the work -

product doctrine, privacy rights of the suspects and witnesses, dealing with unions and regulatory agencies, individualliability, disposition of evidence of criminal wrongdoing.

- Investigative Report Writing Prerequisite is completion of in-house / college level technical course. Course work includes teaming and practicing a process for writing effective investigative documents.

. Investigative Planning Course teaching participants to apply project management steps and skills to current job projects and to identify the factors that influence success in the organization.

• Time Management Course teaches how to handle interruptions, clearing desks and in-baskets, coordinating multiple projects, follow-up on commitments, retrieving information and prioritizing plans and schedules (NU ME2)

. Effective Writing  ;

Course to include principles of clear writing, structure / format of formal reports and presentation of information. (NU MD9) l

=

Plant Systems l l

NU currently offers two systems classes, one of which is more detail oriented than the  !

other. For the purposes of the intake person and investigator, the less detailed course ,

is recommended in that this level of knowledge is needed to be able to communicate I effectively with the concemed individual, not to solve technical issues. This class will I need to be taken for all three units.

- Interpretive Skills (HPES / Root Cause Analysis)

- Training is offered through INPO (consulting firms offer a similar root cause failure course). The Human Performance Enhancement System (HPES) course concentrates on developing techniques for determining root cause failures. HPES describes interviewing methods for determining poor human performance problems. HPES also focuses on identifying physical or administrative barriers to success. HPES relates human behavior to human performance and describes methods to link how some things happen.

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l

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. C:mmunicating with RtgulItors atnd Auditors Course develops skills to prepare for audits and inspections; focuses on how to limit  ;

responses to the individuals area of knowledge, expertise and authority; stresses i making a clear distinction between opinion and facts and maintaining personal composure and rapport. l

,. Listening Skills Course to help participants identify listening barriers, recognize good listening characteristics, and practice active and interactive listening skills.

Problem Analysis / Decision Making l

Course provides a structured approach for analyzing and solving different kinds of business and personnel problems. Core concepts include situation clarification, cause .

analysis, gathering and evaluating information, determining the need for and degree of developing decision attematives, brainstorming guidelines, and other special i techniques for enhancing creativity l Legal aspects of confidentiality Course to deal with the rights of the concemed individual and when confidentiality can l and cannot be maintained. l 1

- Action Plan Development Course will deal with the elements in creating action plans, identification of key issues, resolution of open issues and time management. j l

- Root cause analysis j Course providing ways to conduct effective fact finding intarviews, organizing data for I analysis, determining causal factors and developing corrective action recommendations. (NU Root Cause Investigator Training) in addition to formal training, the following areas will need to be addressed in ECP staff development for increased awareness:

e Northeast Utilities Policies (NUP)- Where many of the company policies goveming human resource issues are outlined.

• Nuclear Group Procedures (NGP) - In panicular NGP 2.30 " Differing Professional Opinion Resolution",

e Fitness for Duty - Requirements of the Fitness for Duty program.

• Security t

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4

! l; e Grievance - Knowledge of the grievance procedures for the various on-site i 3

f collective bargaining units as well as knowledge of all existing grievance procedures  ;

for employees not covered by collective bargaining agreements. i

! e k

Medical- Knowledge of the Employee Assistance Program  !

. l

. Record keeping ,

l . Safety \

)

I Contreactor relations - Knowledge of the where to locate information on any programs l

)

that individual contract companies may have for their employees.

l t

The Employee Concems Task Force recommends that an individual from the Nuclear Training Department Professional Development Group be ' assigned to the Director of Employee Concems for the time required to establish a training program meeting the l j ECP needs. The service of a vendor skilled in the required training is recommended to i enhance the training product. Once established and validated, the training program will

{ be managed by the Nuclear Training Department for the ECP Director. The  ;

j comprehensive program needs to include provisions for remedial and continuing j training as well as establishing expectations and measurable competencies that will i j validate proficiency in the skills required form managers, supervisors, and the ECP ]

. staff. '

e j i 2.3 Organizational, Policy and Procedure Change Recommendations for l l Human Resources and Employees Concerns Program l 1

! The ECTF has reviewed the programmatic weaknesses and root causes that led to the ,

! present situation at Millstone. in developing a comprehensive plan to respond to the i l NRC's October 24,1996, order an:: to restore Millstone to a healthy and functional j 4

work force, the Employee Concems Task Force recommends a number of J j organizational changes, revisions to policies and procedures, and the development of  !

i new expectations. These recommendations are identified below. l 1 l 4

) Recommendation 1:The ECTF recommends assigning a senior Human Resources j individual to report directly to the President and CEO, Nuclear Operations, to direct i human resource matters at the nuclear facilities. This position, which may be j considered temporary for the duration of recovery, would provide information and j assistance in addressing and resolving human resource issues more effectively and

! efficiently. The ECTF further recommends that the Director of ECP needs the same

] reporting path, with an administrative reporting path to the Board of Trustees.

i i

i f

sctr s ,n. seer c, > n,. 19 l . . . .- . . . -

CEO Nuclear

.- VP Oversight Nuclear HR Officer Board of "~~~~'

ECP Director Human Resources Trustees Nuclear Site l

Employee Concerns Program l

These recommendations enable the CEO to have the authority to quickly address HR I issues as they pertain to the ECP, and in b e case of the ECP, provides necessary 1 independence. Human Resources would still receive procedural guidance in the legal and regulatory arenas from Corporate Human Resources.

Recommendation 2: The Employee Concems Task Force recommends a review and modification of the Human Resources procedures, performance review processes and supervisory selection process to address the attributes of addressing employee concems and handling dissenting / differing opinion as positive attributes which gain employees' positive recognition. The HR personnel will need to identify, review and revise procedures with ECP consultant assistance. (it would be an oversight group i function to ensure changes meet the intent of the ECP.)

Recommendation 3: The Employee Concems Task Force recommends that protocol, l expectations and goals for HR and ECP interfecing be developed. This protocol will l define and make clear the expectations of the on-site HR representatives in the I handling / resolving of issues brought to their attention by employees, supervisors, or other company organizations, especially ECP (Adversarial and territorial attitude roles will not be tolerated as they do not foster the raising of concems, facilitate the resolution of employees concems, nor restore tne culture needed to make NU successful.)

Recommendation 4: The Employee Concems Task Force recommends that training, performance reviews, promotion / selection criteria for supervisory positions within nuclear be amended to include competencies / goals related to handling employee concems. The raising of concems and expression of differing opinions shall be handled in a positive, encouraging fashion. Supervisors doing performance reviews shall consider the individual raising concems in a positive manner, and themselves be rated

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{ _ , , ,

20

l

on their ability to encourage employee contributions to a self-conscious environment.

l Failure to meet the competencies / goals will result in disciplinary actions up to and including termination.

Recommendation 5: The Employee Concems Task Force recommends that HR l continue its current effort of revising job descriptions to be made current for supervisory l

and non-supervisory personnel, including requirements for the encouragemt:nt of tiringing forth concerns and differing opinions, and the subsequent proper handling of such issues.

Recommendation 6: The Employee Concems Task Force recommends the renewed use of award programs such as " Spot Recognition" awards and/or other types of instant rewards to be given to individuals bringing forward nuclear safety issues and other enhancements , not limited to technical domains. This award program shall specifically recognize individual contributors who have made contributions to the process through l raising valid concerns leading to procedural or technical improvements or corrections. I Recommendation 7: The Employee Concems Task Force recommends making  !

modifications to the LINKS program. Changes should include the performance  !

management competencies listed in LINKS in regard to ECP expectations by the end of l the first quarter of 1997. New competencies to be included are the positive approach of j open expression of differing opinions, encouragement of differing opinions, and the handling of employee concems by both peers and supervisors.

Recommendation 8.The Employee Concems Task Force recommends that a Peer Review Process to the existing NU grievance procedure be developed by Human Resources and an ECP consultant and implemented. This process would be considered final and binding arbitration. This process would be conducted outside of, and in lieu of, litigation, and be offered at no cost to the employee.

Recommendation 9. The Employee Concems Task Force recognizes that the experience and qualifications of Employee Concerns Program staff can significantly affect the success of the program. The ECTF therefore recommends that the ECP strive to attract and retain a core of senior level personnel with a minimum of ten years l experience. A significant portion of this experience is to be in a highly regulated environment dealing with both technical and personnel issues. Personnel with prior supervisory / managerial experience are desirable. ECP personnel must be held in high esteem by both co-workers and management if selected from the Millstone organization.

Rotational assignments and development of additional entry level personnel should be considered at a later date. Once the ECP has implemented the new process and demonstrated to the regulatory agencies, general public, and employees sustained success in resolving issues, then attemative approaches for staff development should be considered.

Personnel with these desired skill sets would have an established track record in

! effectively and fairly dealing with concemed employees. One or two investigative mentors may initially come from outside the NU organization. ECP will have difficulty in attracting TOP QUALITY individuals from their respective disciplines unless a creditable

(

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l. _ _ _ - - _ _ _ _ _ _

! program is imp!emented and salary ranges are competitive to attract top-notch {

l personnel even from the supervisory / managerial ranks at NU. l l

Recommendation 10. The Employee Concerns Task Force recommends that an

{

independent vendor perform a supervisor assessment in conjunction with the l l introduction of the new plan. The content should ask questions that will allow the identification of *hotspots". The assessment needs to be handled in a manner such that {

the results will be indisputable and that actions can be taken on the results.

Participation needs to be mandatory and supervisors held accountable for ensuring that their personnel participate. The possible answers to the questions need to have equal opportunity to pinpoint the good and bad performers. Management must embrace this assessment and communicate to the employees that the results from this assessment will be acted upon. The employees at Millstone need to see that all levels of management are responsible and accountable for their actions.

Recommendation 11. The ECTF recognizes the need for a review of NGPs, NU Policies, and Millstone departmental procedures to ensure that appropriate elements of the new ECP are reflected in these documents.

2.4 Employee Concerns Program The restructured Employee Concems Program has three fundamental steps, these include: Intake, Triage and Investigation. A flow chart (Figure 1) process is included in this section. Attachment IV shows the process diagram used to develop the program.

The implementing procedure EC0001, " Processing Concems identified to the Employee Concems Program" is presented as Attachment V. Anonymous concems, e.g., phone-in, drop-box, etc., will be processed to the extent possible in accordance with the goveming procedures. The ECP plan is also contained in Attachment XI.

The intake phase entails a process in which a trained interviewer receives the employee concem and assures it is accurately documented with concurrence of the Cl.

Attempts are made at informal resolution or referral through the normal channels or mediation with supervision. The proposed plan also addresses confidentiality. The resolution at this juncture may include, but not be limited to, the following:

. Facilitated meeting with line management

. Differing Professional Opinion process

. Human Resources

. Employee Assistance Program

. Adverse Condition Report

. Third Party Review if the issue cannot be immediately resolved the concern goes to the Triage phase. The purpose of the Triage Team is to evaluate and classify concems and recommend a resolution plan to the ECP Director. A team approach to handling concems is undertaken in order to assure each facet of the concem is considered and evaluated.

The Triage phase will attempt to develop an informal resolution to an issue.

The Triage Team membership could comprise, but not be limited to, individuals from the following groups as appropriate to the case:

i

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.1 l

e Employee Concems . Human Resources e Nuclear Safety . Industrial Safety i e Security . Other Sources j l

Should an issue not be resolved during the Triage Phase, it would will be passed onto the third phase which is a formal " investigation." This may be accomplished by various )

! methods as described below.

l l Investigations may be performed by an investigator from an organization extemal to ,

ECP with ECP oversight, or by an investigative team comprised of an ECP investigator '

and an investigator from an external organization. Note: An extemal organization to l ECP can be an NU group or a group altogether extemal to NU.

I When substantiated, elements of the concern are assigned corrective actions. The Cl is l maintained as a continuing part of the employee concem process. Once agreed-to I actions have been verified, the Cl may choose to agree or disagree with the results. In i cases of full agreement, the case is closed. In cases of disagreement the Cl may l request a case review by the Concems Oversight Panel.  !

The ECP Director will, at his discretion, insure that senior line management (VPs/ Unit Directors) are aware of general employee concem issues within their organization. 1 Confidentiality of concems will be maintained during this information exchange except where maintaining confidentiality would prevent the correction of eminent safety issues 1 or notification of a reportable item. Every effort will be made to notify the Cl before the i information is released. '

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Figure 1  !

4 (page I of 2)

Y Engplayee Concern FlowPath i  ;

CONCERN INTAKE i

• Establish -;

Orcund Rules l E

i 4 l Not

. Anonym.ms Confidential j  % f j h Concerned Applicable ,

Individual (Cl) i 1 -

'  % Confidentiality j Simple Referral Agreed l

4 To By CI Fonns ,

1 5 Immediate Actions:Reportabiiny? Harassment?Inunudation?

Closure Ayeed To By Cl?

j Document in Contactlog / Case File  !

, 4

.............. Concerns a

ReferralOptions(Examples) e.....<.............*

As Needed }....., Oversight ,

Panel  !

4 4 4 ir 4 4 4 Meeting Differms Fonnal Emple Human Medical l

With Professional Employee w  %

a Concern Supervision Opinion Program Resources Department Investigation l

2 I I I I I l l

.l 1P

Document / Expand Elements of Concern Intake Rep. And CI Agree Closure Of Some Elements Agreed To By Cl?

Document in Contact lag / Case File h

Concerns nage For Evaluation

,,,, **[

• • }. Oversight p,,,3

.. . . . . .............1'............ . . . . . .. . .

? Examples ofAttnbutes  :

1 Type ofissues and subsequent classification Confidentiahty must be considered Chilhng offeet evaluation l Is the usue reportable?

. If the issue can be resolved through informal process, which method would be most effective?

) If formal investigation is warranted. who will perform the investigation?

i . Follow.ut, wah Cl with proposed action plan for concurrence a

! Closure Of Some Elements Agreed To By Cl?

1 Document in Contact leg / Case File ir i COA 77NUED ON AE27P,8GE i

4

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.- . . - - - . _ . . _ - _. .- .. . . ~ . . ~ .

.- - . . - - . - - . . - - - - _ . _ - - . - . - . - - - . ~ - . _ - . - . , _ .

1 i

Figure 1 (page 2 of 2)

If the initial review chhe concem indicates that there could be a chillmg effect or hostile work environment. Triage will notifythe ECP Dweetor / Concerns Oversight Panel ]

i

, Doci. ment in Contact Los / Case File i

ECP Directos & Investigator Concerns Final Classification of Concerns & Notify *- " ~ { As Needed ; . . m ., oversight Wate Individuals **************

Panel t

i Examples ofAttnbutes Type ofissue . technical, procedural. compensation, discipline, discrumnation, harassment Cassider Confidentiahty i

Regulatory. Security. Not6 cation Required?

l l

Assignment sf Concern to an ECP Reprementative or Investigator  :

• Prioritize Work Assignments  ;

l

! Identify Trends

!. Resolution Process Selection Investigator & Cl Estabhsh Schedule Document in Contact Log / Case File Investigation By Internal Or External Resources Concerns

p. j *

• M*Q*

• i . , Ovmight

............ 4 p,,,,  ;

1 Investigator Reports Status / Progress To CI

!. . . . .C.l. D. .IS. A. .G.R.E.E. S. . . . . .l i

l l 4 3. . . . . . C. .l.A.G. R. .E.E.S. . .  ;

Cl & Investigator Meet With ECP Director i

d REQUEST For nird Party Review Goes To Concerns Ovmight Panel i

..................... l Third Party Review  :  :. NO Third Party Review :

.e-

..........g........... .

nird Party Review is Agreed To l By Concerns Ovmight nird Party Review is NOT Agreed PanelA CI To By Concerns Oversight Panel A Cl f

Closure By Concerns Ovmight Panel CI Notified

• As items Are Closed

Closure Checklist is Tilled Out Wah  :

Cl f

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t 2.5 The Concerns Oversight Panel  !

While it should be noted that it is impossible to prescribe a code of ethics that can legislate behavior, the Employee Concems Task Force appreciates the necessity of  :

establishing a group that, by its very pressnce, promotes the practice of "doing the right

• thing." The Concems Oversight Panel is comprised of a representative cross section of  :

Millstone employees, exempt and non-exempt, whose function is to provide oversight of i the workplace environment issues and ensure that employees are free to raise a concem, and encouraged to question, without fear of retaliation. The Panel reports to the CEO, Nuclear. i l

2.5.1 The Concerns Oversight Panet Responsibilities The Concems Oversight Panel shall have the following responsibilities:

Oversee the Employees Concern Program The Concems Oversight Panel will oversee the performance and effectiveness of the ECP, This will be done in part by establishing and evaluating performance action indicators. The Concerns Oversight Panel will be responsible for reviewing self-assessments and audits that concem the ECP, as well as complaints of harassment, intimidation, discrimination and retaliation. The ECP Director will be responsible for supplying these reports to the administrator of the Concems Oversight Panel. The Concems Oversight Panel will review the self assessments to assure their accuracy, completeness, and that corrective actions are being addressed. The Concems Oversight Panel will generate periodic reports for the CEO Nuclear and the Board of Trustees, which will give a comprehensive view of the concems environment based on the key performance indicators and self-assessments.

i

. Harassment, Discrimination, Intimidation and Retaliation intervention The Concems Oversight Panel reviews all complaints and cases of harassment, l intimidation, discrimination and retaliation. This review will validate that these issues are handled promptly, and in a responsible manner and address any potential chilling effect on the work force of issues between employees and management. The panel will also .

ensure that, in substantiated cases of harassment, intimidation, retaliation, and I' discrimination, the appropriate disciplinary actions were taken. If the Panel disagrees that appropriate discip!! nary action was taken, the Panel can recommend consideration of other action to the CEO.

. Review for Chilling Effect The presence of a chilling effect in the work place can prevent the success of any Employees Concems Program. The Concems Oversight Panel is responsible for reviewing randomly selected case files to ensure that a chilling effect has been considered and if chilling was detected, that the appropriate remedial actions were taken. Further, in all cases of harassment, intimidation, retaliation, and discrimination, the Concems Oversight Panel will review that appropriate actions have been taken to offset any potential chilling effect. The panel will make recommendations, as serr 2s w s2. m' C- - ee Mme

t necess ry, to the ECP Director to neutralize the chilling effects to ensure that an atmos l:hore in maintained which fosters a healthy questioning attitude.

i l Request for Third Party Review

! All requests for Third Party Review will be submitted to the Concems Oversight Panel by the Director of ECP. The Concems Oversight Panel will consider only those l l 54 quests that have not been resolved by the ECP Director. The Concems Oversight l Panel will review and evaluate these requests. The concemed individual will be invited i l to submit their rational for further investigation of their case. The panel will review these requests for technical merit and will only recommend further such third party  ;

l Investigation if there is an indication that the ECP investigation was not completed in a l l

reliable and complete manner. All decisions made by the Panel would be final. The  !

l Request for Third Party Review will be part of the case file documenting the differing ,

l opinion or objection of the concemed individual. i ECP Director Request i The panel can intervene in a dispute resolution at the request of the ECP Director. This  !

assistance will be available to facilitate cooperation in implementing the l recommendations made by the ECP. The Panel will also be available to assist in the '

resolution of disagreements within the ECP staff.

l

• Employee Termination Review The Concems Oversight Panel will perform a review of all terminations and layoffs with respect to protected activities. This is solely a review of the process and not an evaluation of whether or not an individual should have been terminated. This will ensure that the appropriate ECP personnel were involved in the review of the termination process to ensure that exiting employees are aware of their rights and obligation to raise concems, and to evaluate for potential retaliation for protected activities, if it is determined that possible retaliatory actions in the form of termination has taken place, the panel willinform the CEO of Nuclear and the Board of Trustees.

HOTSPOT Intervention The Concems Oversight Panel will use the evaluation of individual case files, assessments, surveys and trends to identify possible "hotspots" in the workforce. l Hotspots are specific within an organization which experiences higher than expected l ECP activity, i.e., acts of intimidation, harassment or discrimination, high case file substantiation rates, increased HR activities, repeated failures to effectively implement corrective actions or the confirmation of chilling effects. When a "hotspot" is identified by the Panel a recommendation for remedial action will be made to the Director of the ECP. The Concerns Oversight Panel will ensure that prompt and decisive actions be carried out to remedy that effect, and the Concems Oversight Panel will monitor the ,

corrective actions taken by line management. If the Panel does not see responsible l l actions taken by management, they have the responsibility to report this to the CEO of j Nuclear and the Board of Trustees.

l *Hotspot" intervention, in instances where a chilling effect has been identified, has been

determined to be one of the most important roles of this panel. Based on the input from scrr s ->ss.nn l 27 l

i the workforco, as well as numerous assessments, the lack of accountability has been identified as the overwhelming impediment to tuming the present environment around.

It is expected that the Concems Oversight Panel will provide a method to address the lack of accountability that has plagued the Millstone site.

2.5.2 Development of the Concerns Oversight Panel

. Hiring of the Concerns Oversight Panel Administrator The Employee Concems Task Force has recommended that the CEO, Nuclear will i need to hire a full-time Concerns Oversight Panel Administrator, reporting to the CEO, to support the Penet. The Administrator will be the only full time employee of the Concems Oversight Panel and will be responsible for the day to day operations of the Panel. The individual selected must have experience in employee and industrial relations, and have experience in the field of employee concems. It is equally critical that this individual have a strong reputation for integrity and competence. The ECTF strongly recommends that the CEO solicits recommendations from experienced consultants or from established panels in other companies to identify potential candidates.

The Administrator will be responsible for keeping a " pulse" on the environment for raising concems at Millstone. This " pulse" will be obtained by continually overviewing the concerns process, performing thorough reviews of all surveys, audits and self-assessments involving all aspects of the concerns process, and reviewing all complaints of harassment, intimidation, discrimination, and retaliation. The Administrator will monitor those activities of other organizations and management required for the success of the concems resolution process. The Administrator is a resource for line management / supervision in the intervention and resolution of emerging issues.

The Administrator will be expected to keep an accurate and complete record of all observations, available for review by the Concerns Oversight Panel when they meet.

The Administrator will report all findings to the Panel and provide detailed facts of all issues the board reviews. The Administrator will facilitate the Concems Oversight Panel meetings and organize resources necessary for the Panel to make responsible decisions. The Administrator will not be a voting member of the Panel, however, it is essential that the Panel carefully consider the advice given by the Administrator.

2.5.3 The Concerns Oversight Panel Organization a Concerns Oversight Panel Make-Up The Concems Oversight Panel will be made up of one full time administrator, seven employees serving part time on an approximate fourteen month rotation, and one peer representative chosen by the Panel on a case by case basis.

I The ECTF recommends the following process be utilized for the selection of member for the initial panel:

A letter will be sent to the employees from the CEO asking for volunteers for this program. Employees will also have the option of nominating persons whom they

,n. sm E 2 28 .i

t fxl would be good candidatIs far consid: ration. Thos) individurls int:rcstad will attend an orientation seminar where the duties, responsibilities, and commitments -

of the Concems Oversight Panel will be explained. Those who choose to be .

considered will then be interviewed by a three member committee comprised of: l l

e the Concems Oversight Panel Administrator l

. one member of the original ECTF

.. ~ . and one other individual who is independent and experienced in the field of personnel selection, specifically familiar with labor relations and the desired skills set for selecting an independent, principled, representative pane!

The positions will be filled from the workforce as follows:

three (3) non-exempt employees (including union and non-union employees); }

one (1) exempt non-supervisor, i.e., engineer, trainer, etc. '

three (3) management employees, at least one of whom is a first line supervisor. >

The Panel will attend training on relevant aspects of their duties, the ECP program, and ,

the proper handling of employee concems. The members of the Panel will remain on i said Panel for a minimum of a year. After this assignment is completed, each member l will be replaced at a frequency of one member every two months, thereby assuring l continuity as well as refreshing the Panel. I Allissues that require a vote from the panel shall require a minimum of five members to  ;

be present. One of the five can be a peer of the concemed individual, but if a conflict of interest exists as a result of close friendship or personal relationship, that Panel member will remove himself from involvement of this resolution process. The purpose of the peer is to provide insight to the Panel from someone that has the same type of work history / technical experience as the Concemed Individual. The Panel may request specific expertise to assist in specific cases as it feels necessary.

2.6 Performance Action items Performance Action items are set forth in the following comprehensive action plan tables. These plans identify three phases of tasks to be accomplished: first, those items necessary to be completed prior to the effective date of the new Employee Concems Program revision; second, those items required during initial program implementation; and third, those items necessary to be completed on an on-going basis. Line management is ultimately responsible for creation and continuance of a healthy work environment that promotes open communication without fear of retaliation or harassment.

l scr, 29 M rs. im Camp,4,,,,g

Comprehensive Action Plan '.

ECP STAFF TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS ECPS-1 7.1 On-going Initiate ACRs and/or track ACRs submitted to implement corrective actions required intake or agreed to as a result of an ECP concern.

ECPS-2 7.In.3D.40.7 E try two- Prmide feedback to Cis (or a memo to file if the Cl is unknown) on regular basis.

Intake /imtstigators wrcks ECPS-3 7.2n.7 On-going ECP staIT reinforce the need for all supervisors and employtes to address concerns intake /imtstigators ECPS-4 7.7 On-going implement and support the requirements of the ECP.

Intake /imestigators ECPS-5 7.1 On-going Prmide accurate, real-time input to database system so that tracking and trending of Intake / Investigators activitics can be completed.

ECPS-6 7.1/8.2 On-going  ?,scalate to the ECP Director those concerns that have not been properly Intake /imestigators dispositioned.

ECPS-7 7.2n.40.5/8.2 Weckly increase visibility in the work place.

Intake /Imtstigators ECPS-8 7.7/8.2 On-going Complete the intake / triage process within 5 working days after the Cl concurs with the intakcffringe concern being accurately documented or upon receipt of anon 3Tnous concerns.

ECPS-9 7.In.2n.40.7 On-going Conduct or coordinate imtstigations to resolve concerns within 45 days.

Imtstigator R.2 ECPS-10 7.7 3/30/98 Complete all required ECP Intake /Imtstigator training.

Intake /imestigators

? .n 30

Comprehensive Action Plan '.**

First Line Supervisors, Managers, and Directors TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS SUP-1 7.2n.4 3/15/97 Review, sign and post a copy of the Problem Resolution Standard for supervisors in the work areas.(initiate by 3/1/97).

SUP-2 7.2n.4n.5 On-going Actively solicit input from employees and address all identified issues per established procedures.

SUP-3 7.2n.4 On-going Respond to requests for information and assist in ECP imestigations to support agreed schedules.

SUP-4 7.2n.6 On-going Completc required corrective actions per ECP imestigation.

SUP-5 7.2n.49.6 On-going Place subordinates that are evaluated to be weak in any of the expected competencies in a documented remedial plan with specific goals to achieve in a set time period.

SUP-6 7.2n.49.7 Semi-annually Ensure that all assigned personnel view the ECP video and discuss the ECP process ymi-annually.

SUP-7 7.2n.4n.6 3/15/97 Include ECP performance goals in annual performance plans SUP-8 7.2n.4n.6 10/1/97 Complete Managing For Nuclear Safety Training by third quarter of 1997. Personnel promoted into supcavisory positions should complete course within 90 days of effective ofpromotion.

SUP-9 7.10.40.5/7.7 12/31/97 Ensure all managers and first line supervisors complete a course on professional dissent.

cwn 3t * *'"'

st ~s

Comprehensive Action Plan '.-

Training Department TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS T-1 7. ID.5n.7 3/30/98 Develop, impicment and complete initial ECP training for all emplovecs.

T-2 7.7 3/30/97 Revise Plant Access Training to include an expended ECP section.

T-3 7.1/7.7 4/1/97 Revise Managing For Nuclear Safety course to include ECP procedural requirements, and expected competencies.

T-4 7.7 12/30/97 Assist ECP Director in the identification, development, and delivery of ECP staff training.

T-5 7.1/7.7 3/30/97 Ensure adequate resources are made available to provide support staff (i.e. IIR) NU Program for Addressing Emplovce Concerns specified training.

T-6 7.1/7.7 4/30/97 Support the ECP Director by developing and implementing a new course for supervision addressing professional dissent.

T-7 7.7 On-going 1.,pdate Plant Access Training to include questions pertaining to the ECP.

T-8 7.1/7.7 On-going Ensure that all courses required for ECP Intake and Imtstigator staff are readily available for personnel to complete per the ECP performance goals.

T-9 7.4n.7 On-going identify a training liaison to work with the ECP Director in the overall implementation of training requirements to support the NU Program for Addressing Employre Concerns.

7& r,,, 32 M"'

Comprehensive Action Plan *'

Executive Management

~

TRACKING NO MATRIX NO. DUE DATE ' PERFORMANCE ACTION ITEMS CNO-1 7.1/7.4n.6n.7 1/30/97 Announce the NU Program for Addressing Employee Concerns and the proposed new ECP.

CNO-2 7.3/7.4n.7 3/30/97 Participate in a video presentation to introduce the Comprehensive Plan and the new CNO/VP-Ops /VP- ECP program.

Oversight CNO-3 7.In.3n.40.6 On-going IIold assigned individuals responsible for implementing corrective actions for 7.7 substantiated concerns.

CNO-4 7.2n.3n.7 1/30/97 Support the Spot Recognition Awards Plan to reward employees who identify and / or help resolve significant employee concerns.

CNO-5 7.19.3n.49.6 1/30/97 Issue a statement of support for the Concerns Oversight Panel to all Millstone CNO/VP-Oversight 7.7 prsonnel.

CNO-6 7.1/7.3n.5n.7 3/15/97 Issue open letter to all Millstone personnel requesting identification of any new 82 concerns.

CNO-7 7.1/7.2n.3n.4 2/15/97 Establish and post expectations to the work force regarding employee concerns.

7.5n.6n.7/8.2 CNO-8 7.4n.5n.7 3/31/97 Review recommendations contained in ECFF Report CNO-9 7.2n.7 3/31/97 Assign the Concerns Oversight Panel administrator.

EXEC-1 7. In.4n.5 On-going Increase executive visibility in the work place " walking the talk", promote the new Executive culture, ECP, and welcome the identification of concerns.

Management EXEC-2 7. In.4n.5 3/1/97 Direct and support the issuance of the Problem Resolution Standard For Executive Supervisors.(initiate by 2/15/97)

Management EXEC-3 7.49.6 3/15/97 Direct line supervision and support organizations to include ECP accountability goals Executive and competencies in cach supervisor's and employees' performance review plan.(initiate Management by 3/1/97)

EXEC-4 7.4n.7 On-going Introduce the Managing for Nuclea- Safety course.

Executive Management c1 re. 33 '""'"72

Comprehensive Action Plan ,.

Executive Management cont'd TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS EXEC-5 7.10.6 On-going Intenene as needed to ensure unresohtd concerns are prmided the necessary attention.

Executive Management EXEC-6 7.4n.6/8.2 On-going Support the goals of the ECP by effectively dealing with negative trends and poor Executive supenisory performance as identified by the ECP Director and/or Concerns Oversight Management Panel.

EXEC-7 7.In.3n.6/8.2 3/15/97 Direct the responsible organization to revise the supenisor assessment survey to include Executive questions which will result in corrective actions for poor supervisory performance.

Management ,

EXEC-8 7.19.4n.6 5/1/97 Complete the Managing For Nuclear Safety Course or be briefed on the revisions if the Executive course has already been completed.

Management EXEC-9 7.10.6 Monthly - Review action items not completed as reported by the ECP Director and determine what Executive minimum additional actions are necessary to support completion.

Management EXEC-10 7.10.5n.7 12/30/97 All managers and first line supenisors complete or demonstrate proficiency in the Executive following courses: Seven liabits, Mycrs-Briggs, Labor Relations, Principle Centered Management Ixadership, Interpersonal Skills, Interviewing Skills, Handling Professional Dissent and Chilling Effect.

EXEC-11 7. In.6 5/15/97 Ensure all employees are prmided the opportunity to participate and complete an Executive assessment of their supervision's performance. A goal of 90% participation is set.

Management EXEC-12 7.2n.4 4/15/97 Support the " Spot Recognition Awards Plan" and/or other types ofinstant rewards to be Executive given to individuals for nuclear safety and other appropriate non-technical Management enhancements.

VP-1 7.1n.4 On-going Ensure adequate resources are prmided to exate the ECP plan.

VP -Oversight VP-2 7.6 Annually Commission an assessment of the ECP by an external evaluator.

VP - Oversight

"'" 34 '"'"

c .. n

Comprehensive Action Plan ','.

Concerns Ostrsight Panel TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS COP-1 7. In.7 5/15/97 Dcfmc Concerns Oversight Panel goals and objectists.

COP-2 7.60.7 5/30/97 Develop and implement an operating procedure for the Concerns Ostrsight Panci's activitics.

COP -3 7.7 6/1/97 Develop a protocol for the Concerns Oversight PancI to be notified of terminations immiving individuals imchul in protected activitics.

COP -4 7.10.7 On-going Review Requests For Third Party Reviews submitted by ECP Director from Cis.

COP -5 7.40.5n.7 On-going Prmide assistance in dispute resolution for those case files as requested by the ECP director.

COP -6 7.69.7 On-going Oversee the performance and effectiveness of the ECP.

COP -7 7.5n.6n.7 Quarterly _ Report assessment findings with recommendations to the CEO and Board of Trustecs.

COP -8 7.6/3.2 6/1/97 Review instances of past and present activitics where evidence of " chilling effect" is apparent as identified by supenisor assessment surveys. Conclusions and recommendations shall be documented.(initiate by 4/1/97)

COP -9 7.4n.5/8.2 Annual Prmide constructive recommendation where " protected conduct" is being viewed as poor performance in order to avoid issues of harassment, intimidation, discrimination or retaliation.

COP -10 7.3/8.2 On-going Review terminations and planned reductions in the permanent work force to determine if there is esidence that employces invohrd in a protected activity are being singled out . Provide recommendations as appropriate.

COP 11 7.5n.60.7 On-going Review ECP trend data.

COP -12 7.3n.4/8.2 On-going Review for potential " chilling effect" and determine if work place intenention is required by management.

COP -13 7.6n.7 Six months Ensure audits and assessments of ECP's performance are completed on a periodic minimum. basis.

f .,,,,, 35 Wu m'

Comprehensive Action Plan ',-

ECP Director TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS ECPD-1 7.7 I/30/97 Retain ternporary experienced imestigator assistance to reduce the backlog and provide mentoring to staff.

ECPD-2 7.40.5 2/30/97 Develop and implement a comprehensive communication plan to promote the changes occurring at NU. Address training, employee recognition, community outreach, executive management imelvement, and long-term plans. Target audiences include all employees. NRC and general public.

ECPD-3 7.In.4n.5 1/30/97 Drall a letter, signed by CEO, Nuclear, imiting Millstone personnel who hase interest in the Concerns Oversight Panel to attend an orientation session.

ECPD-4 7. In.4 2/15/97 Conduct orientation for potential Concerns Oversight PancI members.

ECPD-5 7.7 3/30/97 Format, implement, and maintain new ECP procedures and guidelines specified by the flan. (i.e. Employee Concerns Resolution Form)

ECPD-6 7.7 3/15/97 Assist in placing the permanent Concerns Oversight PancI administratist position.

ECPD-7 7.7 4/15/97 Complete interviews for Concerns Ostrsight Panel.

ECPD-8 7.7 5/1/97 Attend first Concerns Oversight Panel meeting to facilitate start-up.

ECPD-9 7.7 4/15/97 Establish and publish internal performance goals and objectives for inclusion in ECP stafi's performance reviews.(initiate by 3/1/97) J ECPD-10 7.2 3/15/97 Maintain safeguards to protect the confidentiality of Concernal Individuals who request confidentiality.

ECPD-11 7.7 3/30/97 Impicment new ECP procedure to address concerns.

ECPD-12 7.2n.40.7 3/30/97 Ensure PEER procedure is updated to reflect ECP program resisions. Integrate PEER program into overall ECP communication plans.

ECPD-13 7.In.4n.5 5/30/97 Complete training for Vice-President and Director Icvel personnel in Employee Concerns and Professional Dissent.

ECPD-14 7.7 4/30/97 ECP brochure is updated and distributed.

ECPD-15 7. In.2n.6 As-needed Notify Concerns Oversight Panel of action items not completed satisfactorily.

ECPD-16 7.30.6/8.2 As-needed Notify Concerns Oversight Panel of alleged li,1,D&R instances.

ECPD-17 7. In.3n.5 On-going Attend NRC meetings and briefings at Millstone on ECP related issues.

^"*'"'

f n 36

Comprehensive Action Plan '.*

ECP Director cont'd TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS ECPD-18 7.4 ".5/8.2 On-going Develop a specific Community Outreach Plan as part of the mrrall comrmmication plan to update Concerned Individuals and Groups on the ECP Program prom.ss.

ECPD-19 7.5 6/1/97 Develop an Intranet NU ECP Web page.

ECPD-20 7.7 3/30/97 Developjob descriptions for Intake and Imtrtigative personnel.

ECPD-21 7.7 5/1/97 Identify and select appropriate permanent staff to support the new ECP program.

ECPD-22 7.7 5/30/97 Develop and publish an ECP Organization chart.

ECPD-23 7.2n.5 3/1/97; Develop a newly formatted ECP monthly report which will prmide more insightful monthly information to those reading it.

thereafter.

ECPD-24 7. In.5n.6 4/1/97; P.mide to senior management, IOT and Concerns Oversight Panel current trend minimum analyses of ECP actisitics.

monthly thereafter or as-nceded.

ECPD-25 7.6/8.2 6/1/97 Implement a database to identify and trend work place emironment issues i.e.,

" chilling effect".

ECPD-26 7.50.6n.7 3/31/97 Develop protocol with the licensing departraent to imrstigate concerns referred by the NRC.

ECPD-27 7.5 On-going Inform senior line management of concerns ECPD-28 7.1/7.5n.7 3/15/97 Assist the Training Department in review and revision ofinitial ECP orientation class.

Include new expectations policies, and procedures.

ECPD-29 7.6n.7 2'z8/97 Solicit personnel to become members of the Concerns Ostrsight Panel.

ECPD-30 7.10.5 On-going Ensure contractors cooperate with NU in the completion of required investigations.

rcw 33 m azunr m

Comprehensive Action Plan *'

ECP Director cont'd TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS ECPD-31 7. In.69.7 10/1/97 Ensure all contractor supervisors have completed Managing For Nucicar Safety Course and any new applicable course (i.e. professional).

ECPD-32 7.2U.4D.5 6/1/97 Establish and implement in collaboration with ECP personnel appropriate monitoring 7.7/8.2 measures to evaluate the werkplace environment being conducive for workers to raise concerns without fear of retaliation.

ECPD-33 7.2n.4/7.59.7 6/1/97 Ensure an adequate ECP knowledge base is present in the contractor uurk force 4t'nonstrated by completion of ECP training, and spot surveys.

ECPD-34 7.4n.5D.7 On-going Evaluate PEER Representatives augmentation of ECP staff for functions such as information gathering, looking for/at " hot spots", and promoting the new program.

ECPD-35 7.2 4/30/97 Draft a letter, signed by CEO, Nuclear, to forrner Millstone personncI sccking their input of potential technical concerns.

?+.,n 38 * * ' " '

. - ._ .. - .- .-. _ . _ ~ - .. .

Comprehensive Action Plan ',*

Iluman Resources TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS HR-1 7.6n.7 3/1/97 Matrix the site IIR organization to the President and CEO of Nuclear Operations for a minimum of two years.

IIR-2 7.3n.6/7.7/8.2 3/15/97 Establish protocol, expectations and goals for HR-ECP interfaces. Define and clarify the expectations of the on-site HR representatives in the handling of issues brought to their attention.(initiate by 3/l/97)

HR-3 7.In.3n.6/8.2 3/30/97 Review and respond to all elements contained in the NRC order's specified assessment as to what additional actions HR will impicment to support changing the culture at Millstone.

HR-4 7.2n.3n.4n.6 3/30/97 Change the performance management competencies listed in LINKS to reflect those i 7.7/8.2 expectations from the new ECP.

HR-5 7.In.2n.3D.4 3/30/97 Communicate philosophy, mission, and responsibilitics of HR to all employees.

7.5/8.2 HR-6 7.In.2n.3 3/31/97 Review performance reviews and promotion / selection criteria for supervisory /non.

7.4n.6/8.2 supervisory positions in the nuclear division to include competencies / goals related to handling employee concerns, reducing the opportunitics that result in peer pres.;ure deterring co-workers from identifying concerns.

HR-7 7.3n.40.5n.7 On-going Support the ECP through timely responses to investigation requests in accordance with set schedules.

HR-8 7.3n.4n.6/8.2 7/01/97 Develop and implement, with the assistance of the ECP, a plan for a Non-Union Peer Review Process as an addendum to the existing NU grievance process (develop by 3/30/97).

HR-9 7.In.30.4 3/31/97 Review and modify HR pwudui4 performance review processes and supervisory 7.7/8.2 selection criteria to address the attributes of addressing employee concerns and handling dissenting professional opinion as positive attributes which gain employres positive recognition. HR to identify, review and revisc procedures with ECP assistance.(initiate i by 2/15/97)

HR-10 7.2n.4 4/15/97 Support the " Spot Recognition Awards" and/or other types ofinstant rewards to be given to individuals for nuclear safety and other appropriate non-technical t

enhancements.

f , 39

i Comprehensive Action Plan '.

Iluman Resourtes (cont'd)

TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS IIR-11 7.In.3n.6 5/15/97 Implement a sunty to prmide all employces the opportunity to participate in an aswssment of their supenision's performance. Establish a goal of 90% participation.

HR-12 7.2n.4/8.2 6/1/97 Reimigorate a management led program to celebrate and reward employees for the identification and resolution of significani concerns.

IIR-13 7.5n.7 12/30/97 Assign IIR Reps participate in ECP Intake / Investigator training.

IIR-14 7.In.3n.6/8.2 7/1/97 Develop and implement a policy in which quantified sunty results identifying poor vrforming supenisors are addressed with redemption and/or any other discipline up to and including termination. All such actions shall be documented. (initiate by 5/15/97)

IIR-15 7.60.7 12/30/97 Revise supenisor and employee position descriptions to address problem identification and resolution.

IIR-16 7.6 2/1/98 Establish a leadership assessment which permits 360 degree reviews of site-wide supenision.

IIR-17 7.2n.4n.7 6/30/97 Modify the supervisor assessment process to ask questions that will allow the identification of"hotspots."

40 " ""'

cmm

Comprehensive Action Plan '.'

Misc. Organizations TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS COM-1 7.59.7 3/3/31 Assist in the advertisement of the new ECP and other clements of the communication Communication and On-going plan developed by the ECP Director.

Dept-COM-2 7.6n.7 1/30/97 Assist ECP Director in holding initial orientation meeting with employees.

Communication Dept COM-3 7.2n.4n.5n.7 2/2887 Produce a management video to introduce the new ECP with emphasis on new culture Communication and personnel.

Dept.

COM-4 7.5 6/187 Determine if a " Rumor Control llotline' to address rumors and general questions is Communication warranted and implement per a set schedule.

Dept.

COM-5 7.40.5n.7 3/3087 Reintroduce the PEER program and the PEER reps to the work force.

Communication ECFF-1 7.6U.7 2/1566 Support the Concerns Owrsight Panel scIcction.

Employee Concerns Task Force ECTF-2 7.5/7.6n.7 3/167 ECTF attend a public meeting to explain and promote the Comprehensive Plan.

Employee Concerns Task Force ECTF-3 7.7 1/2367 ECTF post program recommendations, concept diagram, timelines and flow charts.

Employee Concerns Task Force sw 4g ,22. ini m

Comprehensive Action Plan ' , .*

Misc. Organizations TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS ECIF-4 7.2n.4n.7 1/24 S 7 Issue a thank-you letter to all Millstone personnel.

Employee Concerns Task Force EMP-1 7.5n.7 On-going Report unresohrd issues and concerns Employres EMP-2 7.In.5n.69.7 On-going Cup.ute in imestigations as appropriate.

Employees EMP-3 7.5n.6 On-going Participate in supervisory assessments and company suntys.

Emploires EMP-4 7.3n.5 On-going Employees Maintain questioning attitude and make suggestions for imprmement, question the status quo, and raise concerns as ar.i,iopriate.

L-1 7.In.3/8.2 3/3067 Legal Communicate to all employces the responsibilitics, mission and philosophy of the Legal Department.

L-2 7.1/7.5n.6 On-going When safety concerns are raised in the course of depositions which hast not been Legal previously known by the company, forward them to the ECP Director.

PEER-1 7.5n.7 On-going implement iwoirements of PEER program procedure.

PEER Representatives PEER-2 7.7 3/3068 Completc all ECP specified training. (initiate by 2/1567)

PEER Representatists IrrF-1 7.60.7 7/1567 Review NGPs, other select procedures, and departmental policies as required, to ProcedureTask Force include appropriate elements of the new EC"in the documents and sulnaix..; training requirements. (initiate by 2/15M7) c., =--.m 42 * * " '

W 5

3.0 Program Roll Out and Communications Plan

'.. Employee Con'cerns Task Forcei

. Com~munications Plan . _

The Employee Concerns Task Force: Recommends the following plan to roll out the new comprehensive plan and Employee Concerns Program.

Jannan. TBD 1997 e n.1 et Q G " n The Employee Concerns Task Force members are available

{iMi}g ^:S _ __

to answer questions and receive comments on the pregram f

• Q y development process in Bldg. 475 Cafeteria, NTB Lunch d

sj**

• Room NAP & SAP. (Another thought on this instead of Tuesday we send out an e mail and Nuclear News about the submission of the plan to management and that we would gladly take the time to meet with individuals or groups to discuss the process we went through.

(Contact any member of the ECTF to arrange a time.)

January 20,1997 Bruce Kenyon appears as a guest on susan Perry Luxton's CRC program.

1 January TBD 1997 9 Company press selease on Program.

8 Letter to NRC (with Program).

9 Lettutopoliticians.

9 Letter to former concerned employees and their advocates.

9 Letter to retired employees.  !

l l

8 Letters to include Q&As brochure, copy of press releare, The comprehensive plan, timeline, process concept and flowchart, with an offer to make a presentation or advising of scheduled "

presentations.

1 scrr c+., n 43 un 22. nn

l i Januan 22.1997 Communitv Influencers Breakfast at the Groton Motor Inn from 700 to 9:00 am. Scheduled speaker is Bruce Kenyon, with Dave Goebel, Ed Morgan, and the Employee Task Force in F attendance and prepared with poster sized copies of program f q concept (diagram), timeline, and process flowchan. Copies of g "The Plan" available for review.

l Employee Concern Task Force distributes a thank you acknowledgment, signed by all members of the Employee Concerns Task Force.

G5 Send letter electronically to employees with FINAL program attached.

O Two Employee Concerns Task Force members will be located at each access point handing-out copies of thank you acknowledgment w/ FINAL program to all employees at the end of business January 22,1997.

Januan 22,1997 Make available large copies of program concept (diagram), timeline, and flowchart posted at:

@ Commumty Influencers Breakfast 7

@ ECP office ,

@ liuman Resources offices .s "/ ,

@ Berlin -

@ Kiosks

@ Information. Centers

@ Public Document Rooms kI

@ All entrances

@ Employee Concern Task Force member i locations. d

'M . 44 M n. ""

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l s

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February 1.1997 '

Bruce Kenyon & NU Officers are Establishing a Monthly Outreach to Community with

alternating Site presentations from Waterford (i.e., Feb. . Waterford, Mar.- New lendon; Apr.-

Waterford; May-Groton; .. ... ). '

W e Employee Concerns Program could be part of _

s j e Employee's notified prior to OUTREACH ofintended content information i l t

1 March 1.1997 Establish ECP presence on NU Corporate Web Page E Set up by Employee Concerns Task Force E Describing who we are & what we attempted to do E Copy of Plan on-line l.

j E Possibly a way for people to submit concerns j E ECP department maintains and further develops l March 1.1997 i

j ECP to establish Community Outreach to update Concerned Individuals and

~

Groups on ECP progress. j

e Earnest Hadley,' Esq. . Paul Blanch i

.

• Tim O'Sullivan e Susan Perry-Luxton

• Donald Delcore e Local Politicians e CRC (Citizen's Regulatory Committee) e Nuclear Energy Advisory Council e Citizens Advisory Committees I

h~

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C, wnon

1 .

l March 15.1997

., Letter signed by CEOs of Nuclear & NU to Any and All Individuals Who Have Performed Work at the Millstone Nuclear Station at any time from January 1,1992 to the Present.

I Letter to request individuals to identify any technical concerns which could impact restart.

Recipients toinclude :

C3 Present employees and contractors to Millstone.

C3 Employees and contractors to Millstone since January 1,1992 no longer working or sisiting Millstone.

El Retired employees C3 Publish letter in advatorial format in local newspapers (New London Day, Hartford Courant, Norwich Bulletin, . ..).

C3 Possible TV ad - as above.

Materials:

Printed list of Q&A's the Employee Concerns Task Force members need to be prepared with necessary resources to comfortably answer. (Questions from the media, employees, and the public....) j s Descriptive Brochure prepared and released. I s Company Newsletters.

s Timelines i s Flowcharts s Diagrams s ECPUpdates i I

I 1 IM 46 ""'

Cmheasm Plas

l l

1 l 4.0 Attachments '

' Attachment i Summary of Historical Themes Attachment ll Matrix of the Comprehensive Plan to identified Root Causes Attachment 111 Employee Concems Resolution Form Attachment IV Employee Concem Program Developmental Diagram i

~

, Attachment V Employee Concem Program Procedure (in preparation)

Attachment VI Problem Resolution Standard Attachment Vil Employen Concems Task Force Letter

• Attachment Vill Transmittal Letter of Comprehensive Plan l Attachment IX Acronyms

Attachrnent X Transmittal Letter of Technical Concems Which Could impact Restart Attachment XI Northeast Utilities Plan for Addressing Employee Concems I

t I

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e L

L l

Maynim BCTF Al

& wM  !

Attachment I - Summary of Historical Themes ~

' s Asegeeens NE80 INPO MP2 RT ---_-_ IMPO Nucteer NRC MSCP RT , , . . ' , _ . 0%;. . , _. R. F.

Root Covee Portermance Carperuse Yetve Nortrental Corpersee Licensing InspecWon NRC ECP fuesne took Group Assessment en Wesesley of the Foevsed Cause ReftG Cesaprehen Test Group Fweemenen 2C4-v442 seit Evehspelen E. Report Report Orts ACst 7007 Focesed Independent Audit Assesweent ofve gett 3r93 Report Assessment 4f95 Report 12ref95 ft29f96 (Nennen) 2f98 AudstCLSP Oversight CL&P Team 9f93 12r34 er95 itW98 Plan (9f95) Nuclear Ops OrgeMretten Nucteer Ope 7f12f96 1822r97 Lock er eust, w 9rsorse tarstags L** *r Lack et Lack clear Lack et Wust tat of twee. Lee e two.

commureceton -* NU Nucteur Week eeur and " " * '

toernwart stendeeds N --

~

het lost the IsoderWup.

^-teesyg M thsng ts " "

beerpe. ones trust end - _ , . ,.; ""d " ,

do- a'nd skies eenheence, sad 12. _ _ _

the werkforce #889e' sone 8 Smit Does not plan sWit 1 / c.;, to Teo rauch on Ema Lock er eteer T .. af No _ , lack ef No J,.v. ;, No _.m.

L._^^ msves

. adequagey piese Does met Reluctance and e#ectue weelvmg ownershe of Ownershe er tong term did net of regrams leem process to employee toadme Osunerspage BC5CP FSAft thWegy support entstakes

• 1. C-'#"W, mse and concems e(mayryses er Oversight hem sos = sues Seefugy ergemraham

- Lack el Does net Lock et lack W Lock et lack of

- =, sw,, No a _ _ C,,,,4 tack Lew Leur t ack

, ecc eccountow.t, ecc own, ecc ew., owns, , e pene. - ,

toeused NSCP accourtet>1dy and e.,eaet.ons o,ec e,r,e ered ,,~--_f and teamwert ered

-. ^

Teo masch tegel Adects Rehes en Teo mur:h lack of heret

.J. .J ensrumum Did not tegel te delay legal questierung nunamum mtunements meet cr eddress *=es ement siteude and eequnemerws appeahy many

.nd petdems nomyw locus ef regulehens , _ _ . . . _

~

henc- -- . Ah Lack es Lead by Lock of Lack cf CuRure needs and tecks . . ._ _, . and Loch et _,.m.; NU

_ _ , euerryle

. . priarties and to be set by Did not _ , _ .

strategic tecks tuo envo8vement

. . _ . , did nd enhetdt Nucteer ewercree cemerutnet heiss acton not inwohement _ _ , . . Esodershgp tenderstup vessen and Need sale septements and recesserf needershop nesmanaged eW styles and Deecteert commmment modekng tendershtp support 90F commament and vessen E concerned No J _ , ,, er LDut.eper asse ,L..-. '

H, J, - Issues *"8__ NSCP Cb--- . NSCP C. _..NSCP R C- --

kt ,.M , ., -

. - _ _ _ - f _;.  :,, L; ,

sperngt and N 88 Leur tw8kese NSce Emsdayee sole in the NSCP effectwe " ergemrahen cerindpacein ECP/MSCP Cancems handhng correctme Program ccncems actions to seat cause Shoot the 1,3,;,., T.J_ J Shoct M .. ' ^

se . . ._ . , ks

_ .- - n-ssev - poc=*s er en co,ee er onmer essesser Nai needs io r,e Cm e.,, i 6,,0 er, d eeds >

- ,_. phen

-.~_i, i Inch;-, CA; hwfPectswo conetfNe ewessegl4 conectme schons

_ _ , ,, Oggregfe sed achon oversight correcebe processes ";,

Leue Orgenereman's EL^. . . .s glandenfs leur Did vid - . _ _ _ ,to "..,__ No 9wethold 9er cf corectwo standards isnplement DMt not #w#ectne er identify and knourn meaninge n d estethsh entf shundamm was oceans of problem . . . . _ - ,

pevoormence too hig%

admwusereewe conect eversight Pevformance mento.n rosesuhan and schsem pertrmance programs pretdems ssensures and weeknesses Irdcasars e m.gh m .: . . . - , . . A.:- -

tree ^

..i._~. _ , ,

6 EC7F c# ,,,, 48 * 'l '"

- _ ~ - - -

i AttachmeIt II Mrtrix of The Comprebelsive Plan t) Identified Root Causes j Fundamental Cause NRC MIRG Comprehensive Plan

, Assessment (Hannon Report) 1/22/97 .

Team 10/96 Issue Additssed By:

7/12/96 {

7.0 Root Causes '

i L DW not eserrise eNective 7.1 Ineffective problem resolution e Adaptadon of snewide managemera expectations leaderddy and perfonnance measures based on already promulgated expectanons or e Maion and direction were not e Cumbersome decision. FCATimplemernanon plan cornistentlyin confeasa making process e ECPS .1,2,5,6,9 m1th the fundamental needa of a e lack ofresolution of e T 1,3,5,6.8 3

well-perfornung program concerns raised in FCAT. . CNO .1,3,5,6,7 i e Emphasis onjuctifying status failure to use originators of e EXEC 1,2,5,7,g,9,10,11 J gao rather than resohing report efectively in . yp,3 problems resolution process, e

e COP 1,4 l incEcctive response to generation of"chillm.g e ECPD 3,4,13,15,17,24,28,30,31 i

! mountmg indications of serious efect problems

• Top management unwillm.g e EMP.2 to support f "ad -'

! e SUP-9 actions necessary to efect change e IIR-3,5,6,9,11,14 e Lack of correct root cause analysis and inesec6ve corrective action follow through e bek of performance measures, especially for measuring employee trust and confidence, training eEcetiveness

11. Did not establish and 7.2 Insensitivity to employee needs e Adopuon of sitewide expectations based on already i maintain high standards e bck ofexpeditious promulgated expectations or FCAT e Management and personnel workplace "chilhng efect" implementadon plan

!' standards did not ensure intervendon e ECPS 3,7,9 conservative decisions e Creation of some work e SUP .1,2,3,4,5,6,7,8, e Deficient conditions were

• environments were dissent is e CNO 4,7 overlooked, not corrected, or discouraged through e ECPD 10,12,15,23,31,32,33,35 corrected slowly with a narrow insensitivity by management e IIR 4.5,6,10,12,17 l focus e Predictable pattern of denial 4

e e ECTF.4 ,

Prevailing attitude towards ofrJverse FAmgs e EXEC 12 4 regulatory standards were not regarhng har asment and

, . COM 3 consistently appropriate for intint daison nuclear excellence e Claim :f"blacklistmg" by

{ some employees for the

raising ofissues j e Determmation of general 1

' insensnivity to employee needs 1

4 J

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4 BCTF .lenmon 22, nn l C, ' w% 49 4

e

Attachment II Mrtrix of Tbc CompreheIsive Plan t2 Identified Root Causes cont'd Fundamental Cause NRC MIRG Comprehensive Plan J Assessment (Hannon Report) 1/22/97 Team 10/96 Issue Addressed By:

7/12/96 7.0 Root Causes 11L Weak leadership, snanagement, 7J Reluctance to admit snistakes e CNO - 2,3,4,5,6,7 l 4

and interpersonal aldlls a Une oflawyers, and too e EXEC 7 i e Cofnmunications and legahstic an approach, e COP 10,12

irnerpersonal skills of particularly with respect to e ECPD - 16,17 l ananagement did not foster trust, Human Resources Dept e HR.2.3,4,5,6,7,8,9,11,14 l teamwork, or good morale e Severalcurrent and former . L,3 l e Management was ineEcetive in employees have cW e ECPS-2 I respondmg to many employee the opinion that e EMP4 I concerns management has used HR l' e Resource allocation, plan Dept to discredit or j implementation, and intimidate concerned J pnoritization did not support employees, believe filing '

improvement, self assessments concems with ECP futile not donc e A" shoot the messenger" e Organizational role not clearly attitude. Some employees or appropriately defmed feel a questioning attitude is neither encouraged or appreciated l e The above 3 items l are all" chilling efects"

. Use of a succession of consultants to refute NRC or DOL findmgs e luuance of memoranda to employees and public den >bg or muumizing culpabihty for adverse DOL, NRC fmdmgs within hours of receipt e Some employees felt NU dismisses fmdmgs of consultants who substantiate negative fmdmgs and use .Ily does not rehire them for wo-k i

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3C71 50 %n un Co -a.e- m i

I Attachmelt II Matrix of The Comprebersive Plan 12 Ide tified Root Causes cont'd Fundamental Cause NRC MIRG Comprehensive Plan ,

Assessment (Hannon Report) 1/22/97 Team 10/96 Issue Addressed By: i 7/12/96 7.0 Root Causes j 7.4 Unsupportise managesnent e ECPS . 2,7,9 '

styles and support for e SUP .1,2,3,5,6,7,8,9 ,

concerned employees e CNO 1,2,3,5,7,8 i e Condoned an arrogard e EXEC .1,2,3,4,6,8,12 management style in both , yp,g adnunistrative and technical e COP . 5,9,12 i

1. 15 "'

e ECPD 2,3,4,12,13.18,32,33,34 l

• Perception that management a HR . 4.5,6,7,8,9,10,12,17 I has not taken disciplinary '

action against supervisors e ECTF.4 e COM - 3,5 for retaliatory actions against subordinates who e CNO.7 raise issues because the

• T9 presence ofretaliation is not l acknowledged e A technical conceit influences decision makmg, l results in a lack of I conservatism, prornoting an atmosphere not conducuve of the raising of safety concerns e lack ofsupport for concerned employees . 1 including poor follow up, I no positive incentives for raising safety concems, no encouragement or recognition of a questioning stutude e Current promotion process that favors technical va.

people skilla e Human Resmrca Dept.

tendency to develop

" legalistic approachesto contest DOL findmgs of discrimination l

l 1

m 51 e  %.

. _ - - __ _-. - . _ - - - _ _ _ = - . . . . - -

l Attachmelt II Metrix of The Comprehensive Plan 13 Ideltified Root Causes cont d I i Fundamental Cause NRC MIRG Comprehensive Plan  !

Assessment (Hannon Report) 1/22/97 l Team 10/96 Issue Addressed By:

I 7/12/96 7.0 Root Causes  !

7.5 Foor communication and a New and eEcctive leaderslup brought m by Bruce teamwork Kenyon

. e IneEccdve communications e Newly enacted programs (i.e. Barrier Breakers) between and among . ECPS 7 corporate managers, site e spp. 2,9 management, and

• TI employees e CNO 6,7,3 l e Inefective communications 1

e EXEC - 1,2,10 of the basis ofperformance +

e COP - 5,7,9,11 evaluanons, reasons for disciptmary ac6m e ECPD-

. 2,3,13,17,18,19,23,24,26,27,28,30.32,33,34 e IneEective commumcana e HR 5,7,13 ofdelays m resolving concerns toinvolved parties

. COM 1,3,4,5 e DPO not cEcctively e 24 championed

, gp ,

a

• I'2 Process,meaningof .

confidentialityin ECP not

• PEER.1 cEcctively communicatedto work force e Managers not aware ofthe i magnitude ofproblems outside their organiza6on e Management by memo e Misapphcation of the a

• " teamwork concept",

resuhing in it's improper i use to lower concernee i performance reviews,to discourage a questioning >

attitude, inappropriate competinon between units, foremg ofc.aisensus that impedes prepar decision making

)

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l AttachmeIt U Mrtrix of The Comprehensive Plan to Ideitified Root Causes (cont'd)

Fundamental Cause NRC MIRG Comprehensive Plan Assessment (Hannon Repon) 1/22/97  !

Team 10/96 Issue Addressed By: I 7/12/96 7.0 Root Causes ,

7.6 Lack of Accountabihty e 360 Assessmerns allowing employees to grade l

• Generallack of supervision  !

accountability and e New leadership from Recovery officers ownership . spp . 4,5,7,8 e Some managers lacked a e CNO .1,3,5,7 Proactive atutude towards e EXEC 3,5,6,7,8,9,11 aggressively resolving e COP 2,6,7,8,11,13

• • P I Y" * "C*'"'

e ECPD - 15,16,24,25,26,29,31 {

e Abrogation of e HR - 1,2J,4,6,8,11,14.15,16 accountabihty by

• COM 2 snanasenunt m . ECTF 1,2 mappropriate referral of employee concerns to legal,

, gp HR, and ECP Depts. e 1. 2

. Perception by some e W2 employees that sum

• PTF1 considered responsible for discriminating against employees were not disciplined in an appropriate manner e Management reluctant to i use independent evaluauon, discounts independent evaluation fin 6ngs wtan adverse l

. Lack of effe< tive position descriptions :'or some j

employees le A both parties i uncertain of duties, 1 responr:oility, and authonty e More tne spentjustJying status que t'an in addressing e-besolving issues i

i ECTF Jeman 22. I991 C, .e n 33

_. _. _ _ _ _ _ _ _ . . _ _ ._ _ _ _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _- . ~ -

s Attachment II Matris of The Comprehensive Plan to Identified Root Causes (cont'd)

Fundamental Cause NRC MIRG Comprehensive Plan Assessment (Hannon Report) 1/22/97 Team 10/96 Issue Addressed By:

7/12/96 7.0 Root Causes 7,7 Ineffecth e NSCP e ECPS . 2,3,4,8,9,10

., implementation e SUP . 6,9 e Insufficient resources, e T .1,2,3,4,5,6,7,8,9 independence, and authonty e CNO .1,2,3,4,$,6,7,8,9 to fully resolve issues led to e EXEC. 4,10 l f stranonandraism' gof e COP 1,2,3,4,$,6,7,11,13 alleganetoMRC e ECPD.1,$,6,1,8,9,ll 12,14,20,21,22,26,28,29 e Poor correcove action -

33,33,33,34 process, failure to deal with e HR 1,2,4,7,9,13,1$,17 L cans m a tunely -

j e e COM .1,2,3,5 lack ofmanagement e EG.W e EMP .1,2 e PTF.1

• PEER .1,2 8.2 Clullmg Effect e All management tramed in chilling effect e ECP staff to address chilhng effect during intake e Concem Oversight Panel to assess reported chi!!ing impact e ECPS - 6,7,8,9 e COP 8,9,10,12

. CNO.6,7 i e ECPD 16,18,25,32 l

e EXEC 6,7 e HR 2.3,4,5,6,8,9,12,14 e L1 l

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1 Q%t :.

Northeast T,

W g,/,/j}\ Utilities System Attachment III

-:- Employee Concerns Resolution Form Date:

1 Description of Concern:

i 1

1 Investigation of Concern:

Action Taken:

Resolution of Concern:

)

Timetable agreed upon: Start Date: Completion Date:

Sign Sign Employee Supervisor A copy of this form should be retained by the supenisor and indisidual

'[ . __, ,, 55 M 22. ""

Attachusesd IV Entplayee Concem kgrant Lu'._, .. ;;;1%ngram

.', 1 e .

CtGTOMEM INEDTIGATION TL4M ,

+

NUCLEAR CONCERNS: ,

NU Employees Nuclew Safety NU Managemere ECP ( 3 ,

,...,., ._, " Call  : IhTAKEPROCE55 dk

TRIAGE  :

di Pattected Activity e legal Ideswify Isames e

l ,,,,,,,,,a l ( ) g %,,,

y ' " "M " ' " " '

' h Imharial Sarety

• i Back To Line Supervision Roural taw ' '

Early Resolution Resolution Using Various Sources SECURITY Referral Resolutinn INTERNAL AUDITINO: ,

Pai ums: Crane No lnvestigation

,- -.s 11ack To tine L . .L. Fraud l ,

g ,. ,

8 *Cimiting" s Ilumen Reserces , gy . , Abuse *

• • • • s ACR ,

• Nuclew Safety w 8

• Chilling

• e DPO *. ,

->, Effect

..........'m ' e f g ,

g Third Party Review  % , IIAI #

, Inebntrial Safety g IIAI , IRTMAN RESOURCES: , ' hat Meda ,

Oiher Sou,ces - .- - D rn.natu , . .. . e .

ru ,

- Ha,asse,,er. , , i 1

1

...... r." ." ......" '

l CIDSUPE l e l CIDSURE l OTHER e e

, e E

Concerns OverstgM Pane! +---h--....=-..--...--......--. .......... 7 Duties Include: ECP Rep. Sends Concern To Concerns Oversight Panel  !

Review cf FrP trendmg data Review HAI concerns for " chilling" effect ,r Review issues for. Resolution Renohstson l I. Concurrence Possible Optionr [

2 M ===* Acg .

l CIDSURE k en. Resurn sources ternalIether to ECP for investigation by no I Ceudidendeel ACR Assess tenmaation efemployees uwolved i in preeected activities Aid in disputes resolution irregsemed by ECP ,r 4 r I

Review for breakdown in chain ofcommand u Request For l CIDSURE l Otherliasiness as W t

u.iro P.rty

.......................................... Review l

Concerns OverstgM Penri MAKEUP (?)

3 **-emit emP mes.includmgunion k

gg7 I exempt .~.. _, ..m,y employee i 3 management employees t of which will be a ............. ECP Staff I ECTF fuW Ime supervisor  % A"8PJM. M?  !

• I peer rep. (mm4eting includmgunion Concern / Concerned Indmdual 1 Adminiserseer(nevotmg)

_._..__x_ __ . .

__.____v-__ __ he- --m-_

J Attachment V Employee Concem Program Procedure i (In Preparation) 1 l

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Attachment VI (DRAFT) i MILLSTONE NUCLEAR POWER STATION PROBLEM RESOLUTION STANDARD i I agree that a principle responsibility in my role of supervisor at Millstone Station is that of  ;

addressing workplace-identified problems. To be effective at myjob, I have to anticipate potential problems and take steps to resolve these before they have a negative impact on the work environment.

When an issue is presented to me, my first consideration will be whether or not I will need help in ,

resolving the issue. If the problem is in the form of a complaint such as race discrimination, sexual harassment or harassment for raising a safety or quality concern, I may need or choose to call on experts from such departments as Safety, Employee Concerns, Human Resources or NU employees in my own management chain. I will attempt to resolve each issue informally in the normal course of my job. I may need your help to do this.

My management chain encourages and fully expects me to handle issues raised in the workplace  ;

as part of my normaljob responsibility.

I will strive to resolve issues within a reasonable time frame and will keep you informed of l progress in those instances when you are not directly involved in the issue resolution process.

1 When you and I concur on the appropriate set of corrective actions we will then reach agreement  !

on the schedule for implementation of corrective measures. I will not close any issue that you have raised prior to informing you of the closure actions decided on. I will respect your right to disagree with my decision and will provide any assistance you feel is necessary to allow you to appeal that decision through the Employee Concerns Program or other avenues.

Signed: Dated:

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i Attachment Vil Employee Concerns Task Force Letter January 22,1997 f

TO: All Millstone Employees FROM: The Employee Concems Task Force i l

l

SUBJECT:

Thank You!

l l Now that the task of writing the Employee Concems Program and presenting it to the NRC is complete, we'd like to take this opportunity to thank each of you for the input you've given the  !

Employee Concems Task Force.

l t l We've received and incorporated thoughts, feelings, concems, and ideas from a number of  :

people from a variety of areas in response to our request for suggestions. We've talked to  !

current and past employees of alllevels, members of management, concemed citizens, local legislators, Human Resources, Legal, Employee Concems, Nuclear Oversight, and Bruce '

Kenyon. We have attempted to hear all sides of this extremely important issue.

Our work product is now complete, and was presented to the NRC this moming. This program is something that each of us sincerely believes in, and believe can and will work. But before this, or any, program can work, each of you need to believe in it as well.

We've tried very hard to keep everyone informed of our progress. The first step is done, but we will continue to keep you informed periodically as the program progresses, in an effort to .

keep the lines of communication open, we've attached the final copy of the Employee  !

Concems Program that has been submitted to the NRC for their review and approval.

Implementation is underway to revive the pride in Millstone. In order to get the pride back it will take renewed effort by every employee, supervisor, manager and officer alike.

We believe that every Millstone employee wants a safe and productive plant, and a healthy work environment. We are determined to restore it.

This is just the first step on a very long joumey, a joumey that each of us are an integral part of. We could neither have done what we have, nor get to where we need to be without everyone's help. We know this program can work, but we also fundamentally believe that no program will work without the effort of all employees.

THANK YOUiII "It's not the paper-It's the PEOPLE!"

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t Attachment Vill Transmittal Letter of Comprehensive Plan January 22,1997 Mr., Bruce D. Kenyon President and CEO, NU Nuc! car l Millstone Nuclear Power Station l

Rope Ferry Road, Waterford, Connecticut i

06385 l l

l Dear Mr. Kenyon.

The Millstone Employee Concerns Task Force is pleased to provide under cover of this letter, a Comprehensive Plan to address Millstone's workplace emironment for raising concerns, including a vastly modified Employee Concerns Program. The plan and program are responsive to the Nuclear Regulatory Commission's (NRC) October 24,1996, Order relating to employee concerns at Millstone.

1 The Plan was developed by a group of twenty (20) Millstone employees who responded to a published request for  !

volunteers to work on this endeavor. The group became known as the Employee Concerns Task Force (ECTF). l' The Task Force is comprised of a broad cross-section of the Millstone workforce and includes contract, union, non-exempt and exempt employees, a few of whom have served in management positions at Millstone. The Task Force was authorized to begin with a " blank sheet of paper" using the expertise of two independent Employee Concerns Program development consultants as facilitators. The guiding phrase, "It's not the paper - it's the people", was used as a reminder that the success or failure of any program will depend upon the commitment of the people charged with its implementation. The Task Force recognized that any new process had to be designed to foster employee and management participation and accountability. The objectives of the new programs are to rebuild mutual trust, encourage communications and demand zero tolerance for harassment, intimidation and discrimination, using a process that will bring emr>loyee concerns to full, fair and final closure. A summary l

description of the Comprehensive Plan is provided in Section 2.0 of our program document.

The plan describes a living program containing some elements that will need to be developed prior to or during the early stages ofimplementation. Nevertheless, the plan represents what we believe are the best recommendations for recovering the work environment at NU.

Members of the ECTF, while soon returning to their regular assignments, will remain available on an Ad Hoc basis to provide any assistance you may desire. The experience of our involvement has revealed how sitally important the inclusion of all sectors of the workforce in the formulation of this plan has been. It was our pleasure to have been involved in this very important actisity.

Respectfully submitted, i

l serr Sg Jomon 22. IM c, ,. m

' - b4 dekkw f 4W,(

Sheila Hall, Richard DeVeau, dy Mari l

,. Performance Evaluation Nuclear Materials Health Facility

.. b Jim Bennett, w

Za Chuck Mihalko, Nuclear Trainmg ond Employee Concerns Program

, d,h e Frances DiCarlo, Steve Steele, George " Skip" Dacier Assessment Services Myroc Contract r, PQS N -d .

L ..

Jim McHugh, Jim Rothgeb, ancy o

[ Emergency PlanmngU-1 IAC Contrac r, U-l Tech Support l- '

W

, 'John Godinez, Micha Billie Pirner Garde, V U-2 Maintenance Projects Consultant, Garde Law Office Or /& w -

Karen Shannon kgtiP Thomas Clyde Stewart U-2 Design Engineering Manages, Engineering ECP Consulting Services,Inc.

h  % y , , 1 Michael Kennedy Barry Kreiling Je ateN l U-3 Operations Health Physics Chemistry Consultant I ArrL  %=

Condition Based MhTC ,

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. . .. - . .- ... .~. - -- - . _- - - _-_ . - . _.- - -. - - -

A Attachment IX Acronyms  !

i.

CFR- Code of Federal Regulations Cl- Concemed Individual CRC- Citizen's Regulatory Committee DOL- Department of Labor ,

DPO- Differing Professional Opinion ECP- Employee Concems Program  !

l ECTF- Employee Concems Task Force  !

FCAT- Fundamental Cause Assessment Team ,

HPES- Human Performance Enhancement System i

HR- Human Resources INPO- Institute of Nuclear Power Operations ,

IOT - Independent Oversight Team LINKS - Northeast Utilities Appraisal Program MIRG - Millstone Independent Review Group NEO- Nuclear Engineering Organization NGP- Nuclear Group Procedures NNECO- Northeast Nuclear Energy Company NRC- Nuclear Regulatory Commission NSCP- Nuclear Safety Concern Program NU- Northeast Utilities NUP- Northeast Utilities Policies pal - Performance Action items PAT- Plant Access Training g . 62 - 22 "'

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Attachment X Transmittal Letter of Technical Concerns Which Could Impact Restart l

(DRAFT)

From: Bruce Kenyon Chief Nuclear Officer To: Individuals Who Worked at the Millstone Nuclear Station 1/1/92 - Present

Subject:

Technical Concerns Which Could Impact Restart Northeast Utilities is moving forward resoMng technical issues that are in part restraints to restauing our three Millstone nuclear power plants. I personally want to be confident that any potential technical concern you may have is identified to my organization for review. It is all our responsibilities to work together to address any potential issue that could effect the safe operation of any one of our Millstone nuclear units. I have requested our new Director of Employee Concerns, Ed Morgan to coordinate this effort.

Enclosed is a form you can utilize or give Ed's ECP staf* a call at one of the following numbers:

Toll free 1-800-282-7233 Local 1-860-444-5444 If you contact Ed's organization, please identify that you are responding to my request.

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Attachment XI Northeast Utilities Plan for Addressing Employee Concerns 1

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EC71 Jmn 22,19M

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j Northeast

{\ Utilities System 4

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Northeast Utilities  ;

Plan for Addressing l

Employee Concerns a

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JANUARY 22,1997 i

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Executive Summary l

On October 24, 1996, the Nuclear Regulatory Commission (NRC) issued to i Northeast Nuclear Energy Company (NNECo), an order to ". . . develop, submit for'NRC review, and begin to implement a comprehensive plan for (a) reviewing i and dispositioning safety issues raised by its employees and (b) ensuring that l' employees who raise safety concerns are not subject to discrimination."

Additionally, the Order required NNECc to address " root causes" identified by ,

key NRC and NNECo review teams, ". . .with the objective of achieving a safety- l conscious environment".

This Plan, consisting of six (6) major elements, responds to and complies with  ;

! this order. The major elements are interdependent and are meant to enhance management / employee relations while not usurping management prerogatives.

j These elements are:

1 l' A commitment to rebuilding employee, regulatory and public trust, .

A new Employee Concerns Program, Specific organizational, policy and procedure changes, 1

Training and orientation to provide specific skills to reinforce a healthy )

management / employee relationship, l i

Development of Performance Action items that assign responsibility for implementation of the plan, and Creation of a Concerns Oversight Panel.

The incorporation of the plan into the day to day operation of Millstone represents a new commitment by management and employees to take those steps which will result in employee concerns being addressed in a comprehensive and fair manner. The success of the plan will be apparent when the supervisors and employees work together to resolve concerns without fear of harassment, intimidation, discrimination or retaliation.

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l Table of Contents Executive Summary 1

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Table of Contents 2 1.0 Introduction 3 1.1 Background of Employee Concern issues at Millstone 4 P

2 .0 Northeast Utilities Plan for Addressing Employee Concerns 4 2.1 Rebuilding Employee, Regulatory and Public Trust 4 i

2.2 The Employee Concerns Program 5 2.3 Organizational, Policy and Procedure Change 6  !

Recommendations 2.4 Training and Orientation Program 7 2.5 Performance Action items 9 2.6 The Concerns Oversight Panel 9 I Enclosures 10 Figure XI-I Employee Concern Plan Development Diagram Attachment XI-I Matrix of The Comprehensive Plan to Root Causes l Attachment XI-il Comprehensive Action items l

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1.0 Introduction j i i On October 24,1996 the Nuclear Regulatory Commission (NRC) issued an order to

• t i No'theast Utilities (NU) requiring NU to "... develop, submit for NRC review, and begin to ,

i implement a comprehensive plan for (a) reviewing and dispositioning safety issues i raised by its employees and (b) ensuring that employees who raise safety concems are

, 6bt subject to discrimination." ,

i  !

I in response to this order Northeast Utilities established a task force of volunteer i

employees, including representatives of exempt staff, non-exempt staff, contractors  ;

and union, to design and develop a plan to address work environment and Employee i Concems Program changes for submission to the NRC. Two facilitators with extensive i

background in employee concems were employed to assist the task force in developing the new program. The task force convened on December 2,1996, and worked daily

through January 22,1997, to develop this program.

l t While developing the plan, the Employee Concems Task Force (ECTF) actively solicited input from the Millstone emp!9yee population for consideration in the

' formulation and preparation of the plan and the revised Employee Concems Program '

(ECP).

j j  !

Numerous individuals were interviewed. The interviewees included representatives from: Human Resources, the present Employee Concems Program, and work force '

members. Several NU vice presidents and directors, the president of the Nuclear organization, an ex-empioyee active in the area of nuclear safety issues, a senior 1

counsel from the NU corporate legal group, and a local politician were also interviewed.

This effort yielded many suggestions, which were included in the deliberations of the i team.

Employee Concems Programs of other utilities were reviewed and evaluated for background information. The ECTF analyzed all of the significant audits, reviews and l reports that identified management and cultural problems, including independent i

assessments and the NRC Order.

]

j The ECTF then undertook the development of a program that fit the needs of the i Millstone community. This development relied on the team's collective understanding of 1

the Millstone culture, its history and the root causes which ultimately led to the decline in overall nuclear performance. These factors led to the development of each program l

l component, which establishes a system of balance and accountability. Northeast 4 Utilities strongly believes that the implementation of the plan relies on the adoption of each program element described herein.

Northeast Utilities adopted the premise that whatever final product evolved, the ECP can succeed only if there is a commitment of individuals at all levels to support that success, in that:

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i "It's not the paper, it's the people" a

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_. _.._ _ _ ._ _ ___ _ _ ___ _..~.-.___._ _.__ _ ._- _ .__. _ __ _ _ _

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1.1 Background of Employee Concern issues at Millstone l On April 2,1982, Northeast Utilities (NU) established procedure NEO 2.15, " Employee

Complaint Grievances

• per 10CFR19. During the mid to late eighties an increasing number of ecncems were expressed by employees. It became evident by the growing

, n, umber of concems being expressed that NU would need a department devoted to I handling employee concems. A formal concems program was established on December 4,1989. On January 1,1990, a Director-level position was established to

head the new Nuclear Safety Concem Program (NSCP). In 1996, the program name j was changed to The Employee Concems Program, and the program director was j tasked to serve as the focal point for the concems at NU Nuclear, safety as well as

non safety related.

i l Over the past ten years Millstone has had a high number of employee concems and i allegations related to the safety of plant operations, and related to the harassment, i intimidation, retaliation, and discrimination against employees raising such issues. NU's

! response to many of these allegations has been considered inadequate and i adversarial by employees, the NRC, and the public. The NRC conducted inspections l and investigations that substantiated many of the employee concems and allegations, ,

including the inability of NU to address concems in a competent and responsive '

manner. As a result, NU has been cited for violations and escalated enforcement action j has been taken. Both the NRC and NU's intamal audits have concluded that the

. company has not been effective in the area of handling employee concems, nor in l implementing effective corrective action for problems that have been identified by j concemed employees. As a result, employees have lost faith in the current Employee

Concems Program and NU management's willingness or ability to address concems.

l Consequently, the handling of employee concems at NU has been the topic of i discussion from the public town meeting level to the United States Congressional level.

2.0 Northeast Utilities Plan for Addressing Employee Concerns l The Northeast Utilities Plan for Addressing Employee Concems, hereafter called the

Comprehensive Plan, consists of six key elements, summarized below. Each of these

elements require new or revised programs at Millstone. Implementing these programs will bring about a break with past practices, and restore a culture based on respect and

! recognition of employee contribution to a safe and productive environment. The

) comprehensive plan allows for revisions based upon experience and plan

implementation.

4 j 2.1 Rebuilding Employee, Regulatory and Public Trust

! 1 i The ultimate measure of the success of this comprehensive plan is the day-to-day interaction of employees and supervision to identify and resolve concems without j discouragement or retaliation. Rebuilding trust involves open communication, positive actions, and enforcement of the process to ensure complete and fair treatment of employees. This Comprehensive Plan represents a new commitment by Northeast Utilities management and Millstone employees to take those steps that will result in an j environment that welcomes the identification of employee concems, investigates those issues to a full and final resolution and treats each employee in fair manner.

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The success of the Comprehensive Plan is contingent on full management support and participation. The plan requires measurement of the work environment atmosphere to l Judge progress, identification of problem areas, and provides a mechanism to establish I and maintain accountability. The Comprehensive Plan provides for a review and i revision of site procedures to ensure that all the programs and processes recognize j aryd support the contributions of individual employees. The plan incorporates  !

brientation and training, and integrates awareness on handling of employee concems  !

into the process. As the work environment improves and management begins to  !

assume responsibility and accountability for handling concems, the most active intervention elements may be considered for obsolescence.

l Northeast Utilities believes that ultimate inclusive implementation of this plan will bring l Millstone back to the forefront of the nuclear industry.

2.2 Employee Concerns Program  !

The restructured Employee Concems Program has three phases: the intake, Triage j and Investigation. Figure XI-l shows the process diagram used to develop the program.

l An implementing procedure for the program has been developed.  ;

The Employee Concem Program (ECP) provides employees the resources and options ]

necessary to help ensure concems are handled in a fair and competent manner.

Although the ultimate measure of success will be employees' confidence in addressing i and resolving concems with first line management, this plan recognizes that there will '!

be instances when concemed employees choose to use the ECP. l l

The new ECP has three fundamental steps, which are shown pictorially in Figure XI-l.  ;

First, is the intake Phase, in which a trained interviewer receives the employee concem '

and assures it is accurately documcc,ted with concurrence of the concemed individual (Cl). The program will attempt informal resolution or referral if appropriate. If the issue l

cannot be immediately resolved, the concern goes to the Triage phase. Here, a team l approach to reviewing concems is undertaken by a group of selected individuals necessary to produce resolution. Each facet of the concem is reviewed and evaluated.

ideally, the Triage phase will develop an informal resolution acceptable to the Cl. If riot, issues will be passed onto the third phase which is a formal investigation that will be performed by a competent investigator or an independent investigation team. When substantiated, elements of the concem will be assigned corrective actions. The Cl will remain an active part of the employee concem process.

Once the investigation is completed and all agreed-to actions have been taken, the Concemed Individual may choose to agree or disagree with the results. in cases of full agreement, the case is closed by the ECP. In cases of disagreement, the Cl may request a case review by the Concems Oversight Panel. The conception, development and implementation of the Concems Oversight Panel is integral to various stages and processes of the "new" ECP. The Concems Oversight Panel will review all requests for third party reviews, and may request additional investigation, assist in resolution, or j close the case. Concems received anonymously will be accepted by ECP and processed in a similar manner.

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l The Peer Program objective remains the same, in that it will continue to provide a neutral point of contact where employees can express concems, have them addressed and receive feedback on the resolution. i The ECP Director will, at his discretion, insure that senior line management (VPs/ Unit Directors) are aware of general employee concem issues within their organization.

l tsonfidentiality of concems will be maintained during this information exchange except t where maintaining confidentiality would prevent the correction of eminent safety issues i or notification of a reportable item. Every effort will be made to notify the Cl before the .

Information is released.

u, 2.3 Organizational, Policy and Procedure Changes i Northeast Utilities has reviewed the programmatic weaknesses and root causes that led l to the present situation at Millstone. in developing the Comprehensive Plan to respond  ;

to the NRC's October 24, 1996, order and to restore Millstone to a healthy and functional work force, Northeast Utilities will undertake a number of organizational changes, revisions to policies and procedures, and the development of new expectations. These elements are identified below.

NU is assigning a Senior Human Resources individual to report directly to the President and CEO, Nuclear who will be responsible for human resource matters at the nuclear  ;

facilities. The Director of ECP will have the same reporting path, with an administrative  ;

reporting path to the Board of Trustees.

i NU is performing a review and modification of Human Resources procedures, performance review processes, and the supervisory selection process to ensure that  ;

successful addressing of employee concems and handling dissenting / differing '

opinions are viewed as positive supervisory attributes that gain employees' positive recognition. Protocol, expectations and goals for HR and ECP interfacing are also under development.

NU is revising training, performance review process and the promotion and selection criteria for supervisory positions within nuclear to include competencies and goals related to hendling employee concems.

NU will review all jcb descriptions for supervisory and non-supervisory personnel to include a requirement to be able to fairly deal with employee concems issues.

NU will continue use of an award program such as " Spot Recognition" awards and/or other types of instant rewards given to individuals bringing forward nuclear safety issues and other enhancements , not limited to technical domains.

NU is researching the development of a new Peer Review Process to supersede the existing NU grievance procedure. NU Nuclear's periodic assessment survey process will be modified as necessary to permit the identification of "hotspots" at Millstone.

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2.4 Training and Orientation Program The goal of creating a healthy work environment can be considered to be fulfilled by the Comprehensive Plan when the majority of concems are successfully handled between the employee and their first line supervisor. To help facilitate meeting this goal, enhanced skills are needed across all levels of personnel to create an environment where employee concems are addressed in a full, fair and final manner.

A critical element in reversing the present culture will be the training of the Millstone work force in new expectations for management - employee relations, the Comprehensive Plan and the new Employee Concems Program. Training in the new l l

' ECP will commence with top level management, and proceed down through officers, '

directors, managers, first line supervisors, and then the general work .'orce. The l 1 program elements for raising and handling employee concems and professional dissent i

1 will be set forth in such a manner that there will be no question retstrding the role, responsibility and accountability for all employees. The training will be developed to provide specific skills to succeed in the new work environment. '

i Additionally, retirees from NU, former NU employeis, state and local govemment i leaders and the general public will be made aware of the new Employee Concems I Program. This will be accomplished through an involved communication plan which includes public meetings, newsletters, and video docurrientaries.

Senior Management (Vice-President and Director Level)

Senior Management will receive a full briefing on the Comprehensive Plan and the new Employee Concems Program. This training in the new accountabilities and expectations of the ECP will be conducted prior to manager and supervisor training in order that senior management be abla to set the example for the level of management reporting to them, especially first line supervision. Understanding and enforcing the elements of effective management of professional dissent is a key aspect of the new culture.

Managers and First Line Supervision Resolving differing professional opinions which conflict with accepted views is neither natural nor easy. Northeast Utilities has identified that a training module needs to be developed and incorporated into site training. The Nuclear Training Department is developing the courses required.

All Employees All employees will receive training about the new ECP program and the expectations set forth which detail the responsibilities of non-management employees. This training will be used in the roll out of the program for all employees and will be included as part  !

of initial and annual Plant Access Training (PAT).

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ECP Investigators and intake Staff I  !

The ECP staff requires skill sets that take into account the varied nature and l

} responsibilities of their work. They will not only need to properly obtain information that l

{'

may ultimately lead to formal investigations, but will also need to be objective listeners '

as well as skilled report writers. The following areas will need to be included in ECP itaff development for increased awareness:

i i  !

e Interviewing Skills j e Legal issues in Employment l

e Investigative Report Writing j

e investigative Planning

• Time Management 4

. Effective Writing i

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• Plant Systems l . Interpretive Skills (HPES / Root Cause Analysis)

e Communicating with Regulators and Auditors i 1 e Team Building i Human Resources Staff i

1 Past audits and reports have determined that a majority of the concems expressed by

employees are rooted in areas traditionally under the purview of Human Resources  ;

j (i.e., performance appraisals, wage and hour issues, assignments). The revised ECP program does not attempt to substitute for the traditional role of Human Resources; however, in order to be responsive to all employee concems the ECP may receive l these concerns.

This program requires a dynamic working relationship between the ECP Staff and the  ;

4 Human Resources Department. Therefore, the HR staff will require some of the same training as the ECP staff including:

I e Interviewing Skills e Investigative Report Writing e investigative Planning

. Effective Writing

e Listening Skills j e Team Building 9

2.5 . Performance Action items 4

A series of Performance Action items (PAI) has been developed to ensure successful implementation of this Comprehensive Plan. Performance Action items are the action i steps necessary to be taken by various work groups (i.e., ECP Director, Human i Resources, Concems Oversight Panel, Legal, Executive Management, supervision, and employees). These steps are supported by specific objectives and matrixed to the

various root causes identified by the NRC order, and are enclosed as Attachment XI-1, 1

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" Matrix of the Comprehensive Plan to Root Causes" and Attachment XI-II,

" Comprehensive Action Plan."

2.6 The Concerns Oversight Panel l l

The Concems Oversight Panel is a nine member panel composed of Millstone I e'mployees, exempt and non-exempt, whose function is to provide oversight of j workplace environment issues and ensure that employees are free to raise a concem, and encouraged to question, without fear of retaliation. The Panel will also provide )

assistance to the ECP. l l

The Concems Oversight Panel shall have the following responsibilities:

l e Review conduct of the Employees Concem Program

. Harassment, Discrimination, intimidation and Retaliation Identification e Review workplace environment for Chilling Effect

. Evaluate request for Third Party Review e Respond to special requests of the ECP Director e Review cases where an individual who has been involved in protected activity has been terminated for any reason.

. HOTSPOT Identification A charter will be developed to detail the process for involvement in these areas, and to clearly delineate the panel's role and responsibilities.

The Concems Oversight Panel members will be selected through a formal process to identify individuals from all segments of the organization whose integrity and competency is well respected throughout the site. The panel has been created to promote the practice of "doing the, right thing", establish visible accountability, and ensure that the new programs are implemented and sustained. A quarterly report will be submitted to the President and CEO documenting the panel assessment of progress in these areas, with copies to the ECP Director and VP, Nuclear Oversight.

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Figure XI-I ,

Employee Concern Program Development Diagram ConcemedIndividuel MVES11GA T10N TEAnt  !

..................... . 1 NUCLEAR CONCERNS: .

NU Employees ( ] Nuclear W .

Nu Management ECP

• Contactors MTAKEPROCESS  ;  ; '

,, yppscE ,,

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Legal idenhfy Issues .

l unresolved l k l unresolved l SAFETY: ,

, , I "

. . . . in.d.u.s.tn.ai.

.r. ave.e . . .. .

S.

p . . i Back To h W Resoluhon Using Various SECURITY Earty Resolutm Sources l

INTERNAL AUDITING: . l Referrat Resoluhon N *

,--s Possible Ophons ,...s Fraud .

No investigshon 8 *CW"

• Human Resources *We Abuse .,#.

ME Possible Ophons l N SaW Effect

. . . . . . . . Waste, , , , , , , , .

, + Effect ACR '.....#

. industrial Safety * , . H8

,) .# HUMAN RESOURCES:

• g Hal ,

opo . Oct. Sources ,

D,scrmnenon . - --

. Harassmeni - -

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.....9"$"".....

2. l l CLOSURE l .

l CLOSURE l l OTHER

• Coneems Overs,ght Paner

. Duties include

...k....................}........ ...........f ECP Rep. Sends Concem To Com Oversight

. Review of ECP trending data

. Review H&l concems for "cNihng" effect ,r

. Reviewissues for: Document

1. Concurrence Re Correctrve Action

2. Retum to ECP for investigehon by Yes ,

extemaliotte sources in SM l CLOSURE l+- no tractang system

- Assessterminationof-4,:ainvofved in protected activities

. AJd in disputes resolution if requested by ECP

,, {

. Review for breakdown in chain of command RW Fw l @g l Third Party

- Other business as needed  : Review Concems Oversnght Panel htAKEf)P(9) 3 none - A,_ . includog union yy 1 exempt non-supervisory employee 3 management -6,;u 1 of which we be a ............. ECP S'aff first line supervisor 1 peer rep. (norurohng), including union ConcemiConcemed bulwidual

.. 1 Administrator (non-voting) _ , , , , , ,

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Attechment XI-I Matrix of The Comprehensive Plan to Root Causes 1

Fundamental Cause NRC MIRG Comprehensive Plan Assessment (Hannon Report) 1/22/97

, Team 10/96 issue Addressed By:

7/12/96 7.0 Root Causes i

i. old not emercise efrective 7.1 :nenective probiem . Adaptaten of sneede management i leadership resolution expectatens based on already promulgated e Vision and direction were not and performance measures expectatens or FCAT implementation plan consistently in conformance e Cumbemome decision-

• ECPS 1,2,5,6,9 with the fundamental needs rnaking process e T - 1,3,5,6,8 t of a well-performing program e Lack of resolution of e CNO 1,3,5,6,7

. Emphasis on justifying status concerns raised in FCAT, e EXEC 1,2,5,7,8,9,10,11 quo rather than resolving failure to use originators e VP 1 l problems of report effectively in e COP 1,4 e ineffective response to resoluten process, e ECPD 3,4,13,15,17,24,28,30,31 mounting indicatons of generation of

• chilling e gMp 2 senous problems effect" e L.1,2 e Top management . SUP-9 unwilling to support e HR-3,5,6,9,11,14 fundamental actions necessary to effect 4

change e Lack of correct root cause ana?ysis and ineffective corrective acton follow through 4 e Lack of performance measures, especially for measuring employee trust ,

, and confidence, training i effectiveness IL Did not establish and 7.2 insensitivity to employee e Adopton of sitemde expectatens based on maintain high standards needs already promulgated expectatens or FCAT e Management and personnel e Lack of expeditious implementaten plan standards did not ensure workp' ace *chilhng effect' e ECPS 3,7,9 conservative decisions intervention e SUP - 1,2,3,4,5,6,7,8,

• Deficient conditions were e Createn of some work e CNO 4,7 overlooked, not corrected, or environments were e ECPD -10,12,15.23,31,32,33,35 corrected slowty with a d:ssent is diccouraged e HR - 4,5,6,10,12,17 narrow focus through 6nsensitivity by e ECTF 4 e Prevaihng attitude towards management e EXEC-12 regulatory standards were e Predictable pattern of e COM-3 not consistently appropnate denial of adverse findings for nuclear excellence regarding harassment and intimidaten e Claim of

• blacklisting

• by some employees for the raising of issues e Determination of general insensitivity to employee b needs W 11

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Attachment XI.I Matrix of The Comprehensive Plan to Root Causes cont'd Fundamental Cause NRC MIRG Comprehensive Plan Assessment (Hannon Report) 1/22/97

.f. Team 10/96 issue Addressed By:

7/12/96 7.0 Root Causes lit, Weak leadership, 7.3 Reluctance to admit e CNO . 2,3,4,5,6,7 management, mistakes e EXEC 7 and interpersonal skills e Use of lawyers, and too e COP .10,12 e Communications and legalistc an approach, . ECPD 16,17 Interpersonal skills of particularly with respect to e HR 2,3,4,5,6,7,8.9,11,14 management did not foster Human Resources Dept. . L.1 trust, teamwork, or good e Severalcurrent and . ECPS-2 morale former employees have e EMP-4 e Management was ineffective expressed the opinion in responding to many that management has employee concems used HR Dept ta e Resource allocation, plan discredit or intimidate implementation, and concamed employees, pnorttiration did not support believe filing concems improvement, self with ECP futi'e assessments not done e A

• shoot the messengef*

• Organizational role not clearly attitude. Some employees or approprately defined feel a questioning attitude is neither encouraged or appreciated

. The above 3 items are all' chilling effects" e Use of a succession of consultants to refute NRC or I

DOL findings e Issuance of memoranda to employees and public denying or miniml->g culpability for adverse DOL, NRC findings within hours of receipt

. Some employees felt NU dismisses findings of consultants who substantate negative findings and usually does not rehire them for work g- -n ese 12

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l Attachment XI-I Matrix of The Comprehensive Plan to Root Causes cont'd Fundamental Cause NRC MIRG Comprehensive Plan Assessment (Hannon Report) 1/22/97 Team 10/96 issue Addressed By:

7/12/96 7.0 Root Causes

! 7,4 Unsupportive management e E C PS . 2,7,9

! styles and support for e S UP .1,2,3,5,6,7,8,9 concerned employees e CNO .1,2,3,5,7,8 e Condoned an arrogant e EXEC 1,2,3,4,6,8,12 management style in both e VP-1 administrative and . CDP . 5,9,12 technical functons . ECPD 2,3,4,12,13,18,32,33,34 e Percepten that e HR 4.5,6,7,B,9,10,12,17 management hes not e ECTF 4 taken disciplinary acten e COM . 3,5 against supervisors for e CNO.7 retaliatory actons against . T-9 subordinates who raise issues because the presence of retaliation is not acknowledged

. A technical conceit influences decision making, results in a lack '

of conservatism,  !

promoting an atmosphere I not conductive of the I raising of safety concems e Lack of support for concemed employees.

Including poor follow-up, no positive incentives for ra' sing safety concems, no er Auragement or recogt.ition of a questoning attitude e Current promotion process that favors technical vs. people skills e Human Resources Dept.

tendency to develop

• legalists approaches

• to contest DOL findings of d:scrimination i

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l i

l Attachment XI-I Matrix of The Comprehensive Plan to Root Causes cont'd Fundamental Cause NRC MIRG Comprehensive Plan Assessment (Hannon Report) 1/22/97

-1 Team 10/96 issue Addressed By: ,

7/12/96 7.0 Root Causes 7.8 Poor communication and a New and effective leadership brought in by teamwork Bruce Kenyon e ineffective e Newly enacted programs (i e. Bamer communications between Breakers) and among corporate . ECPS.7 managers, site e SUP . 2,9 management, and . T.1 employees e CNO . 6,7,8 e ineffective e EXEC .1,2,10 communications of the e COP 5,7,9,11 basis of performance e ECPD.

evaluations, reasons for 2,3,13,17,18,19,23,24,26,27,28,30,32,33,34 disciplinary actions . HR . 5,7,13 e ineffective e COM .1,3,4,5 communications of delays e ECTF 2,4 in resoMng concems to e EMP .1,2,3,4 involved partes e L.2 e DPO not effectivey e PEER 1 championed e Process, rneaning of confidentiality in ECP not effectively communicated to work force e Managers not aware of the magnitude of problems outside their organization e Management by memo e Misapetication of the

" teamwork concept",

resulting in It's improper use to lower concemee performance reviews, to discourage a questioning attitude, inappropriate competition between units, forcing of consensus that impedes proper decision making I

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Attachment XI-I Matrix of The Comprehensive Plan to Root Causes (cont'd) l 1

Fundamental Cause NRC MIRG Comprehensive Plan Assessment (Hannon Report) 1/22/97 ,

Team 10/96 lasue Addressed By:

7/12/96 7.0 Root Causes 7.6 Lack of Accountability e 360 Assessments allowing employees to e Generallack of grade supervision accountability and e New leadership from Recovery offcers ownership e SUP 4.5,7,8  :

. Some managers lacked a e CNO - 1,3,5,7 proacthe attitude towards e EXEC - 3.5,6,7,8,9,11 aggressively resoMng e COP - 2,6,7,8,11,13 employee concerns e ECPD .15,16,24,25,26,29,31 e Abrogation of e HR 1,2,3,4,6,8,11,14,15,16 accountability by e COM.2 management in e ECTF - 1,2 inappropriate referralof e EMP 2,3 employee concems to e L.2 Legal, HR, and ECP e vp.2 Depts. . PTF 1 e Perception by some employees tnat supervisors considered responsible for i disenminating against I employees were not disciplined in an '

appropnate manner i e Management reluctant to use independent evaluation, discounts independent evaluation findings when adverse e Lack t, effective posnion descriptions for some employees left both pa ties uncertain of duties, responsibility, and authonty e More time spent justifying status quo than in addressing and resoMng issues

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N~ 15

6 Attachment XI-l Matrix of The Comprehensive Plan to Root Causes (cont'd)

Fundamental Cause NRC MIRG Comprehensive Plan Assessment (Hannon Report) 1/22/97

~

Team 10/96 issue Addressed By:

7/12/96 7.0 Root Causes 7.7 ineffective NSCP e ECPS 2,3,4,8,9,10 implementation e SUP 6,9 e Insufficient resources, e T 1,2,3,4,5,6,7,8,9 independence,and e CNO - 1,2,3,4,5,6,7,8,9 authority to fully resolve . EXEC 4,10 issues led to frustration e CDP 1,2,3,4,5,6,7,11,13

' and raising of allegations e ECPD-to the NRC 1,5,6,7,8,9,11,12,14,20,21.22,26,28,29 e Poor corrective action 31,32,33,34

• process, failure to deal e HR 1,2,4,7,9,13,15,17 with concems in a timeY e COM 1,2,3,5  !

manner e ECTF 1,2,3 '

e Lack of management e EMP 1,2 support for the program . PTF-1 i

e PEER 1,2 3 B.2 Chilling Effect e All management trained in chilling effect ,

e ECP staff to address chilling effect during  !

4 intake

. Concem Oversignt Panel to assess reported chilhng impact e ECPS 6,7,8.9 e COP 8,9,10,12 e CNO . 6,7 1

. ECPD - 16,18,25,32

. EXEC 6,7 e HR ,2,3,4,5,6,8,9,12,14 e L-1 i

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. . _ . _ _ _ _ _ - - . _ _ _ ... _ _ - _ _ . = _ . . _ _ _ _ - _ _ . . ._ . _ _ _

Attachment XI-il  :

Comprehensive Action Plan i The Comprehensive Plan identifies required actions necessary for its implementation.

l 3 in addition, the ECTF's report to the President contains recommendations and requested that certain actions be completed. For ease of execution, these action items h&ve been collated into the following tables which are grouped by the organization responsible for their implementation. Required completion dates and continuing periodicity requirements are also included. Where applicable, required actions have i been cross referenced to the root causes of the Fundamental Cause Assessment ,

Team and MIRG to indicate which root cause finding they are intended to address.

1

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l Comprehensive Action Plan S.

ECP STAFF TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS ECPS-1 7.1 On-going initiate ACRs and/or track ACRs submitted to implement corrective actions intake required or agreed to as a result of an ECP concem.

ECPS-2 7.1U.3/7.46.7 Every two- Provide feedback to Cls (or a memo to file if the Cl is unknown) on regular intake / Investigators weeks basis.

ECPS-3 7.2/7.7 On-going ECP staff reinforce the need for all supervisors and employees to address intake / Investigators concems ECPS-4 7.7 On-going implement and support the requirements of the ECP.

Intake /InvestigPtors ECPS-5 7.1 On-going Provide accurate, real-time input to database system so that tracking and Intake / Investigators trending of activities can be completed.

ECPS-6 7.1/8.2 On-going Escalate to the ECP Director those concems that have not been properly intake / Investigators dispositioned.

ECPS-7 7.2/7.4/7.5/8.2 Weekly Increase visibility in the work place.

Intake / Investigators ECPS-8 7.7/8.2 On-going Complete the intake / triage process within 5 working days after the Cl concurs intake / Triage with the concem being accurately documented or upon receipt of anonymous concems.

ECPS-9 7.1/7.2/7.4/7.7 On-going Conduct or coordinate investigations to resolve concems within 45 days.

Investigator 8.2 ECPS-10 7.7 3/30/98 Complete all required ECP Intakellnvestigator training.

Intakelinvestigators

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18

Comprehensive Action Plan I, First Line Supervisors, Managers, and Directors TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS SUP-1 7.2R.4 3/15/97 Review, sign and post a copy of the Problem Resolution Standard for supervisors in the work areas.(initiate by 3/1/97).

SUP-2 7.2R.4/7.5 On-going Actively solicit input from employees and address all identified issues per established procedures.

SUP-3 7.2/7.4 On-going Respond jo requests for information and assist in ECP investigations to support agreed s iledules.

SUP-4 7.2R.6 On-going Complete required corrective actions per ECP investigation.

SUP-5 7.2R.4/7.6 On-going Place subordinates that are evaluated to be weak in any of the expected competencies in a documented remedial plan with specific goals to achieve in a set time period.

SUP-6 7.2/7.4/7.7 Semi- Ensure that all assigned personnel view the ECP video and discuss the ECP annually ,vocess semi-annually.

SUP-7 7.2/7.4!7.6 3115/97 include ECP performance goals in annual performance plans SUP-8 7.2/7.4/7.6 10/1/97 Complete Managing For Nuclear Safety Training by third quarter of 1997.

Personnel promoted into supervisory positions should complete course within 90 days of effective of promotion.

SUP-9 7.1/7.4/7.5/7.7 12/31/97 Ensure all managers and first line supervisors complete a course on professional dissent.

g- -.

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Comprehensive Action F;an I:

Training Department TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS T-1 7.1/7.5/7.7 3/30/98 Develop, implement and complete initial ECP training for all employees.

T-2 7.7 3/30/97 Revise Plant Access Training to include an expended ECP section.

T-3 7.1/7.7 4/1/97 Revise Managing For Nuclear Safety course to include ECP procedural requirements, and expected competencies.

T-4 7.7 12/30/97 Assist ECP Director in the identification, development, and delivery of ECP staff training.

T-5 7.1/7.7 3/30/97 Ensure adequate resources are made available to provide support staff (i.e. HR)

NU Program for Addressing Employee Concems specified training.

T-6 7.1/7.7 4/30/97 Support the ECP Director by developing and implementing a new course for supervision addressing professional dissent.

T-7 7.7 On-going Uodate Plant Access Training to include questions pertaining to the ECP.

T-8 7.1/7.7 On-going Ensure that all courses required for ECP Intake and Investigator staff are readily available for personnel to complete per the ECP performance goals.

T-9 7.4/7.7 On-going Identify a training liaison to work with the ECP Director in the overall implementation of training requirements to support the NU Program for Addressing Employee Concems.

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Comprehensive Action Plan ,'

Executive Management TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS CNO-1 7.1/7.46.66.7 1/30/97 Announce the NU Program for Addressing Employee Concems and the proposed new ECP.

CNO-2 7.3/7.4/7.7 3/30/97 Participate in a video presentation to introduce the Comprehensive Plan and the CNO/VP-Ops /VP- new ECP program.

Oversight CNO-3 7.1/7.3/7.4/7.6 On-going Hold assigned individuals responsible for implementing corrective actions for 7.7 substantiated concems.

CNO-4 7.2R.3/7.7 1/30/97 Support the Spot Recognition Awards Plan to reward employees who identify and / or help resolve significant employee concems.

CNO-5 7.1/7.3/7.4/7.6 1/30/97 Issue a statement of support for the Concems Oversight Panel to all Millstone CNO/VP-Oversight 7.7 personnel.

CNO-6 7.1/7.3/r.5/7.'" 3/15/97 :ssue open letter to all Millstone personnel requesting identification of any new 8.2 concems.

CNO-7 7.1/7.2/7.3/7.4 2/15/97 Establish and post expectations to the work fome regarding employee concems.

7.5/7.6/7.7/8.2 CNO-8 7.4/7.5/7.7 3/31/97 Review recommendations contained in ECTF Report CNO-9 7.2/7.7 3/31/97 Assign the Concems Oversight Panel administrator.

1 EXEC-1 7.1/7.4/7.5 On-going increase executive visibility in the work place ' walking the talk", promote the Executive new culture, ECP, and welcome the identification of concems.

Management EXEC-2 7.1/7.4/7.5 3/1/97 Direct and support the issuance of the Problein Resolution Standard For Executive Supervisors.(initiate by 2/15/97)

Management EXEC-3 7.4/7.6 3/15/97 Direct line supervision and support organizations to include ECP accountability Executive goals and competencies in each st,pervisor's and employees' performance Management review plan.(initiate by 3/1/97)

EXEC-4 7.4/7.7 On-going Introduce the Managing for Nuclear Safety course.

Executive Management

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Comprehensive Action Plan .-

Executive Management cont'd TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS EXEC-5 7.16.6 On-going Intervene as needed to ensure unresolved concems are provided the necessary Executive attention.

Management EXEC-6 7.4/7.6/8.2 On-going Support the goals of the ECP by effectively dealing with negative trends and Executive poor supervisory performance as identified by the ECP Director and/or Concems Management Oversight Panel.

EXEC-7 7.16.3/7.6/8.2 3/15/97 Direct the responsible organization to revise the supervisor assessment survey i Executive to include questions which will result in corrective actions for poor supervisory Management performance.

• EXEC-8 7.19.4/7.6 5/1/97 Complete the Managing For Nuclear Safety Course or be briefed on the Executive .evisions if the course has already been completed.

Management EXEC-9 7.16.6 Monthly - Review action items not completed as reported by the ECP Director and Executive minimum determine what additional actions are necessary to support completion.  ;

Management EXEC-10 7.1/7.5U.7 12/30/97 All managers and first line supervisors complete or demonstrate proficiency in Executive the following courses: Seven Habits, Myers-Briggs, Labor Relations, Principle Management Centered Leadership, Interpersonal Skills, Interviewing Skills, Handling Professional Dissent and Chilling Effect. '

EXEC-11 7.16.6 5/15/97 Ensure all employees are provided the opportunity to participate and complete Executive an assessment of their supervision's performance. A goal of 90% participation is Management set.

EXEC-12 7.2U.4 4/15/97 Support the " Spot Recognition Awards Plan" and/or other types of instant Executive rewards to be given to individuals for nuclear safety and other appropriate non-Management technical enhancements.

VP-1 7.1a.4 On-going Ensure adequate resources are provided to execute the ECP plan.

VP - Oversight VP-2 7.6 Annually Commission an assessment of the ECP by an extemal evaluator.

g- Oversight

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-_-_ _______- ______________ _ _ _ - _ - _ - - _ - ____- I

1 Comprehensive Action Plan 1 Concerns Oversight Panel l TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS

! COP-1 7.1/7.7 5/15/97 Define Concems Oversight Panel goals and objectives.

l COP -2 7.6/7.7 5/30/97 Develop and implement an operating procedure for the Concems Oversight Panel's activities.

COP -3 7.7 6/1/97 Develop a protocol for the Concems Oversight Panel to be notified of terminations involving individuals involved in protected activities.

COP -4 7.1/7.7 On-going Review Requests For Third Party Reviews submitted by ECP Director from Cis.

COP -5 7.4/7.5/7.7 On-going Provide assistance in dispute resolution for those case files as requested by the ECP director.

COP -6 7.6/7.7 On-going Oversee the performance and effectiveness of the ECP.

COP -7 7.5/7.6/7.7 Quarterly Report assessment findings with recommendations to the CEO and Board of

~

Trustees.

COP -8 7.6/8.2 6/1/97 Review instances of past and present activities where evidence of " chilling effect* is apparent as identified by supervisor assessment surveys.

Conclusions and recommendations shall be documented.(initiate by 4/1/97)

COP -9 7.4/7.5/8.2 Annual Provide constructive recommendation where " protected conduct

• is being viewed as poor performance in order to avoid issues of harassment, intimidation, discrimination or retaliation.

COP -10 7.3/3.2 On-going Review terminations and planned reductions in the permanent work force to determine if there is evidence that employees involved in a protected activity are being singled out . Provide recommendations as appropriate.

COP -11 7.5/7.6/7.7 On-going Review ECP trend data.

COP -12 7.3/7.4/8.2 On-going Review for potential

• chilling effect* and determine if work place intervention is required by management.

COP -13 7.6/7.7 Six months Ensure audits and assessments of ECP's performance are completed on a minimum. periodic basis.

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_ . _ . _ . - - _ . . _ _ - - - _ _ . _ _ _ _ _ _ _ _ - _ - _ _ _ - _ - - _ - _ _ - - - -- A

q Comprehensive Action Plan .

ECP Director TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS ECPD-1 7.7 1/30/97 Retain temporary experienced investigator assistance to reduce the backlog and provide mentoring to staff.

ECPD-2 7.4/7.5 2/30/97 Develop and implement a comprehensive communication plan to promote the changes occurring at NU. Address training, employee recognition, community outreach, executive management involvement, and long-term plans. Target audiences include all employees, NRC and general public.

ECPD-3 7.1/7.4/7.5 1/30/97 Draft a letter, signed by CEO, Nuclear, inviting Millstone personnel who have interest in the Concems Oversight Panel to attend an orientation session.

ECPD-4 7.1/7.4 2/15/97 Conduct orientation for potential Concems Oversight Panel members.

ECPD-5 7.7 3/30/97 Format, implement, and maintain new ECP procedures and guidelines specified by the Plan. (i.e. Employee Concems Resolution Form)

ECPD-6 7.7 3/15/97 Assist in placing the permanent Concems Oversight Panel administrative position.

ECPD-7 7.7 4/15/97 Complete interviews for Concems Oversight Panel.

ECPD-8 7.7 5/1/97 Attend first Concems Oversight Panel meeting to facilitate start-up.

ECPD-9 7.7 4/15/97 Establish and publish intemal performance goals and objectives for inclusion in ECP staff's performance reviews.(initiate by 3/1/97)

ECPD-10 7.2 3/15/97 Maintain safeguards to protect the confidentiality of Concemed Individuals who request confidentiality.

ECPD-11 -* /

. 3/30/97 Implement new ECP procedure to address concems.

ECPD-12 7.2/7.4/7.7 3/30/97 Ensure PEER procedure is updated to .=flect ECP program revisions. Integrate PEER program into overall ECP communication plans.

ECPD-13 7.1/7.4/7.5 5/30/97 Complete training for Vice-President and Director level personnel in Employee Concems and Professional Dissent.

ECPD-14 7.7 4/30/97 ECP brochure is updated and distributed.

ECPD-15 7.1/7.2/7.6 As-needed Notify Concems Oversight Panel of action items not completed satisfactorily.

ECPD-16 7.3/7.6/8.2 As-needed Notify Concems Oversight Panel of alleged H,1,D&R instances.

ECPD-17 7.1/7.3/7.5 On-going Attend NRC meetings and briefings at Millstone on ECP related issues.

ga g ~n-

Comprehensive Action Plan 'l ECP Director cont'd TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS ECPD-18 7.4U.5/8.2 On-going Develop a specific Community Outreach Plan as part of the overall communication plan to update Concemed Individuals and Groups on the ECP Program progress.

ECPD-19 7.5 6/1/97 Develop an Intranet NU ECP Web page.

ECPD-20 7.7 3/30/97 Develop job descriptions for intake and Investigative personnel.

ECPD-21 7.7 5/1/97 Identify and select appropriate permanent staff to support the new ECP program.

ECPD-22 7.7 5/30/97 Develop and publish an ECP Organization chart.

ECPD-23 7.2/7.5 3/1/97; Develop a newly formatted ECP monthly report which will provide more monthly i'isightful information to those reading it.

thereafter.

ECPD-24 7.1/7.5/7.6 4/1/97; Provide to senior management, IOT and Concems Oversight Panel current minimum trend analyses of ECP activities.

monthly thereafter or as-needed.

ECPD-25 7.6/8.2 6/1/97 Implement a database to identify and trend work place environment issues i.e.,

• chilling effect".

ECPD-26 7.5/7.6/7.7 3/31/97 Develop protocol with the licensing department to investigate concems referred by the NRC.

ECPD-27 7.5 On-going Inform seniorline management of concems ECPD-28 7.1/7.5/7.7 3/15/97 Assist the Training Department in review and revision of initial ECP orientation class. Include new expectations policies, and procedures.

ECPD-29 7.6/7.7 2/28/97 Solicit personnel to become members of the Concems Oversigt!t Panel.

ECPD-30 7.1/7.5 On-going Ensure contractors cooperate with NU in the completion of required investigations.

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25

Comprehensive Action Plan '*

ECP Director cont'd TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS ECPD-31 7.1/7.6/7.7 10/1/97 Ensure all contractor supervisors have completed Managing For Nuclear Safety Course and any new eppucaNe course (i.e. professional).

ECPD-32 7.2/7.4/7.5 6/1/97 Establish and implement in co@horation with ECP personnel appropriate 7.7/8.2 monitoring measures to evaluate the workplace environment being conducive for workers to raise concems without fear of retaliation.

ECPD-33 7.2/7.4/7.5/7.7 6/1/97 Ensure an adequate ECP knowledge base is present in the contractor work force

'1emonstrated by completion of ECP training, and spot surveys.

ECPD-34 7.4/7.5/7.7 On-going Evaluate PEER Representatives augmentation of ECP staff for functions such as information gathering, looking for/at " hot spots", and promoting the new program.

ECPD-35 7.2 4/30/97 Draft a letter, signed by CEO, Nuclear, to former Mi;istone personnel seeking their input of potential technical concems.

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Comprehensive Action Plan .-

Human Resources TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS HR-1 7.66.7 3/1/97 Matrix the site HR organization to the President and CEO of Nuclear Operations for a minimum of two years.

HR-2 7.3/7.6/7.7/8.2 3/15/97 Establish protocol, expectations and goals for HR-ECP interfaces. Define and clarify the expectations of the on-site HR representatives in the handling of issues brought to their attention.(initiate by 3/1/97)

HR-3 7.16.3/7.6/8.2 3/30/97 Review and respond to all elements contained in the NRC order's specified assessment as to what additional actions HR will implement to support changing the culture at Millstone.

HR-4 7.2/7.3/7.4U.6 3/30/97 Change the performance management competencies listed in LINKS to reflect 7.7/8.2 those expectations from the new ECP.

HR-5 7.1U.2/7.3/7.4 3/30/97 Communicate philosophy, mission, and responsibilities of HR to all employees.

7.5/8.2 HR-6 7.1R.2/7.3 3/31/97 Review performance reviews and promotion / selection criteria for 7.46.6/8.2 supervisory /non-supervisory positions in the nuclear division to include competencies / goals related to handling employee concems, reducing the opportunities that result in peer pressure detening co-workers from identifying concems.

HR-7 7.3/7.4/7.5/7.7 On-going Support the ECP through timely responses to investigation requests in accordance with set schedules.

HR-8 7.3R.4/7.6/8.2 7/01/97 Develop and implement, with the assistance of the ECP, a plan for a Non-Union Peer Review Process as an addendum to the existing NU grievance process (develop by 3/30/97).

HR-9 7.1/7.3/7.4 3/31/97 Review and modify HR procedures, performance review processes and 7.7/8.2 supervisory selection criteria to address the attributes of addressing employee concems and handling dissenting professional opinion as positive attributes which gain employees positive recognition. HR to identify, review and revise procedures with ECP assistance.(initiate by 2/15/97) ,

HR-10 7.2/7.4 4/15/97 Support the

• Spot Recognition Awards" and/or other types of instant rewards to be given to individuals for nuclear safety and other appropriate non-technical enhancements.

U- 27

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Comprehensive Action Plan '.'-

Human Resources (cont'd)

TRACKING NO MATRIX NO DUE DATE PERFORMANCE ACTION ITEMS HR-11 7.1/7.3/7.6 5/15/97 Implement a survey to provide all employees the opportunity to participate in an assessment of their supervision's performance. Establish a goal of 90%

participation.

HR-12 7.2/7.4/8.2 6/1/97 Reinvigorate a management led program to celebrate and reward employees for the identification and resolution of significant concems.

HR-13 7.5/7.7 12/30/97 Assign HR Reps participate in ECP Intake / Investigator training.

HR-14 7.1/7.3/7.6/8.2 7/1/97 Develop and implement a policy in which quantified survey results identifying poor performing supervisors are addressed with redemption and/or any other discipline up to and including termination. All such actions shall be documented.

(initiate by 5/15/97)

HR-15 7.6/7.7 12/30/97 Revise supervisor and employee position descriptions to address problem identification and resolution.

HR-16 7.6 2/1/98 Establish a leadership assessment which permits 360 degree reviews of site-wide supervision.

HR-17 7.2/7.4/7.7 6/30/97 Modify the supervisor assessment process to ask questions that will allow the identification of *hotspots."

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Comprehensive Action Plan .'

Misc. Organizations TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS COM-1 7.5/7.7 3/3/31 Assist in the advertisement of the new ECP and other elements of the Communication and On- comrnunication plan developed by the ECP Director.

Dept. going COM-2 7.6/7.7 1/30/97 Assist ECP Director in holding initial orientation meeting with employees.

Commum :ation Dept.

COM-3 7.2/7.4/7.5/7.7 2/28/97 Produce a management video to introduce the new ECP with emphasis on new Communication culture and personnel.

Dept.

COM-4 7.5 6/1/97 Determine if a " Rumor Control Hotline' to address rumors and general questions Communication is warranted and implement per a set schedule.

Dept.

COM-5 7.4/7.5/7.7 3/30/97 Reintroduce the PEER program and the PEER reps to the work force.

Communication ECTF-1 7.6/7.7 2/15/96 Support the Concems Oversight Panel selection.

Employee Concems Task Force ECTF-2 7.5/7.6/7.7 3/1/97 ECTF attend a public meeting to explain and promote the Comprehensive Plan.

Employee Concems Task Force ECTF-3 7.7 1/23/97 ECTF post program recommendations, concept diagram, timelines and flow Employee charts.

Concems Task Force TJ' ~"~

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Comprehensive Action Plan '. ,'

Misc. Organizations TRACKING NO MATRIX NO. DUE DATE PERFORMANCE ACTION ITEMS ECTF-4 7.2/7.4/7.7 1/24/97 lssue a thank-you letter to all Millstone personnel.

Employee Concems Task Force EMP-1 7.5/7.7 On-going Report unresolved issues and concems.

Employees EMP-2 7.1/7.5/7.6/7.7 On-going Cooperate in investigations as appropriate.

Employees EMP-3 7.5/7.6 On-going Employees Participate in supervisory assessments and company surveys.

EMP-4 7.3/7.5 On-going Employees Maintain questioning attitude and make suggestions for improvement, question the status quo, and raise concems as ai440priate.

L-1 7.1/7.3/8.2 3/30/97 Legal Communicate to all employees the responsibilities, mission and philosophy of the Legal Department.

L-2 7.1/7.5/7.6 On-going Legal When safety concems are raised in the course of depositions which have not been previously known by the company, forward them to the ECP Director.

PEER-1 7.5/7.7 On-going implement requirements of PEER program procedure.

PEER Representatives PEER-2 7.7 3/30/98 PEER Complete all ECP specified training. (initiate by 2/15/97)

Representatives PTF-1 7.6/7.7 7/15/97 Procedure Task Review NGPs, other select piecedures, and departmental policies as required, Force to include appropriate elements of the new ECP in the documents and subsequent training requirements. (initiate by 2/15/97) rJ~ ~ " ' "

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- - _ _ . _ _ - _ _ - - _ _ _ - _ _ _ - - _ _ _ _ _ _ - _ _ - _ - _ __ - -________ --_ _______ _ _-___-_ - - - _ _-_-__ _ - __- _-__-_- _ _ _ _--_____ __ :