ML20141E910

Summary of 970603 Meeting W/Northeast Nuclear Energy Co Re Lhc Proposed Changes to Communications & Reporting Sections of Proposed Oversight Plan & for Lhc to Present Findings from Ongoing Oversight Activities.List of Attendees Encl

ML20141E910
Person / Time
Site:	Millstone
Issue date:	06/25/1997
From:	Pastis H NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9707010206
Download: ML20141E910 (36)

Text

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1 LICENSEE: Northeast Nuclear Energy Company (NNECO) June 25, 1997

. FACILITIES: Millstone Nuclear Power Station Units 1, 2, and 3

SUMMARY

OF JUNE 3, 1997, MEETING WITH LITTLE HARBOR CONSULTANTS, INC. (LHC), AND NNECO TO DISCUSS ONG0ING LHC ACTIVITIES AND FINDINGS On June 3,1997, the Special Projects Office (SP0) staff of the Office of Nuclear Reactor Regulation (NRR) participated in a publicly observed meeting with LHC and NNECO representatives. The purpose of the meeting was to discuss LHC's proposed changes to the Communications and Reporting sections of its proposed oversight plan and for LHC to present the findings from its ongoing oversight activities of NNEC0's programs for handling employee safety concerns at the three Millstone units. During this meeting, LHC provided an update of its evaluation of the Millstone culture survey and the results of its programmatic review of NNEC0's Employee Safety Concerns Program.

Enclosure 1 is a list of the principal attendees at the meeting. Enclosure 2 is the handout provided by NNECO that responds to questions raised by the NRC in correspondence and previous meetings with NNECO. Enclosure 3 is the handout used by LHC during its presentation.

Original signed by:

Helen N. Pastis, Senior Project Manager Millstone ESCP and ITPOP Oversight Special Projects Office - Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-245, 50-336, and 50-423

Enclosures:

As stated (3) cc w/ encl: See next page liARD COPY Docket. File PUBLIC ,

SPO-L Memo ,

SP0 Reading OGC (w/o encls 2&3)

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!  %,***** ,# June 25, 1997 LICENSEE: Northeast Nuclear Energy Company (NNECO) l FACILITIES: Millstone Nuclear Power Station Units 1, 2, and 3 )

SUMMARY

OF JUNE 3, 1997, MEETING WITH LITTLE HARBOR CONSULTANTS, j l INC. (LHC), AND NNECO TO DISCUSS ONGOING LHC ACTIVITIES AND i l FINDINGS i

On June 3,1997, the Special Projects Office (SP0) staff of the Office of i Nuclear Reactor Regulation (NRR) participated in a publicly observed meeting with LHC and NNEC0 representatives. The purpose of the meeting was to discuss LHC's proposed changes to the Communications and Reporting sections of its i proposed oversight plan and for LHC to present the findings from its ongoing oversight activities of NNEC0's programs for handling employee safety concerns at the three Millstone units. During this meeting, LHC provided an update of its evaluation of the Millstone culture survey and the results of its programmatic review of NNECO's Employee Safety Concerns Program. 4 Enclosure 1 is a list of the principal attendees at the meeting. Enclosure 2 is the handout provided by NNECO that responds to questions raised by the NRC in correspondence and previous meetings with NNECO. Enclosure 3 is the handout used by LHC during its presentation.

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' ed c' Helen'N'. Pastis,ySenior Project Manager Millstone ESCP and ITPOP Oversight Special Projects Office - Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-245, 50-336, and 50-423

Enclosures:

As stated (3) cc w/ encl: See next page

7.._.

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LIST OF ATTENDEES j

June 3, 1997 I

, NAME ORGANIZATION l Phil McKee NRC Steve Reynolds NRC l

Drew Persinko NRC 4 Carl Mohrwinkle NRC l l Bruce Kenyon NNECO  !

Neil S. Carns NNEC0 l David M. Goebel NNECO Ed Morgan NNEC0 l Michael Brothers NNECO Pat Loftus NNECO John Beck LHC l John Griffin LHC James Perry LHC i

Enclosure 1

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5.1 Introduction

• 5.2 Requests ForInformation 5.3 Formal Meetings and Written Reports

• 5.4 Issuance of Observations, Conclusions l

and Recommendations  !

- 5.4.1 Obsen>ations 1

-5.4.2 Conclusions I

-5.4.3 Recommendations ,

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Communications and Reporting' m . ..

5.5 Press or Media Communication 5.6 Communication Related to NRC Oversight of LHC 1

Enclosure 2

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1 June 3,1997, Suggested Replacementfor Sections 5 and 6 of Oversight Plan, Rev. O, dated May 2,1997.

5.0 COMMUNICATIONS AND REPORTING 5.1 Introduction The oversight team considers stakeholders to be persons or organizations whose self-interest is impacted by the actions of the personnel and effectiveness of the management team at the Millstone site. This would include, but would not necessarily be limited to, the NRC, various state and local governmental entities, neighbors of the Millstone site, grass-roots organizations formed out of concern with past events or happenings at Millstone, former and current employees and the licensee management.

All of these stakeholder interests must be acknowledged as the independent oversight team proceeds with its activities. The oversight team will seek out and establish communications as early a possible with all stakeholders, particularly with those located off-site. Team members will document contacts and maintain confidentiality if requested.

5.2 Requests for Information The nature of the Oversight Program is such that there will be a continuing need to request and receive information from NNECo. LHC will use a standard information request memorandum when seeking documents from NNECo. These memoranda will be maintained in LHC files for the duration of the project. There will be occasions when information will be provided to LHC during the course of interviews or attendance at site meetings.. These transmittals will be documented in interview notes or notes summarizing meeting attendance.

5.3 Formal Meetings and Written Reports The NRC Order requires that the oversight organization report at least quarterly on their activities. LHC intends to provide a detailed, written report to the h%C (provided to all stakeholders) on a quarterly frequency. In addition to the quarterly report, there will oe pre-announced meetings on a frequency determined by the availability and significance of the results of LHC activities. LHC is of the view that the most efficient mechanism for providing such information to the stakeholders is to do so by having public meetings. This will simultaneously provide the information to the NRC, NNECo and the public. The materials presented in these meetings will be docketed by providing them in writing to the NRC and all parties on the NRC service list shortly after such meetings.

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In cases where time is of the essence in providing feedback to the stakeholders,

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LHC will make such information available to the appropriate stakeholders either verbally or in writing, and follow up with verbal or written information to all stakeholders within three working days of such verbal or written notice. This subsequent communication to the public may be at a previously scheduled public meeting ifit occurs within three working days of a time-sensitive need, or in writing by transmittal to the NRC service list. Copies of the summary will be made

available to the public at the Waterford public library. Should any member of the

public desire further elaboration regarding the material, a mutually agreeable time j and setting for a discussion with LHC personnel will be arranged.

'- The intent of the LHC team is to reach a consensus for conclusions or recommendations made as a result of the team's work. This objective creates an atmosphere in which team members must vigorously defend their individual representations to other involved team members, should there be initially differing views. The objective of consensus also tends to weed out potentially extraneous positions quickly and thus raise the level of any debate regarding an issue. Should there be an instance where a team consensus is not established, the oversight

< repon will include a clear delineation of the issue or issues and any minority views,

including the basis for the departure from consensus. The minority views will be l- prepared by the team member or members who hold such views, thus assuring a j full and fair presentation.

5.4 Issuance of Observations, Conclusions and Recommendations 1

LHC team feedback to the stakeholders will be either in writing or simultaneously i presented at public meetings. There will be three categories used:

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j 5.4.1 Observations, which will be used to describe a circumstance or emerging issue where the investigation or review has not been completed, but where enough information has been gathered to warrant bringing the subject to the attention of the stakeholders.

5.4.2 Conclusions, which will be used to describe a circumstance or issue where the facts are sufficiently clear and further review or investigation is highly unlikely to alter the facts.

5.4.3 Recommendatims, which will be made when conclusions lead the team to specify a change in how NNECo management addresses a panicular issue or circumstance, either by approaching the issue or circumstance in a different manner, or by incorporating previously unused actions. The team will not indulge in providing consulting advice to NNECo management, but will, in accordance with the requirements of the NRC Order, make 2

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recommendations as appropriate when circumstances call for them.

5.5 Press or Media Communication Press or media communication will be handled by the team leaders or by their specific direction to other team members.

5.6 Communications Related to NRC Oversight of LHC The NRC will be exercising their required oversight of the LHC team by use of telephone conference calls, site visits and meetings. These communications will not require the presence of NNECo or the public.  !

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• Employee Concerns Questions Added Questions; and to Nuclear Leadership Assessment

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I ITPOP Memorandum Date: May 30,1997 To: D. M. Goebel, Vice President, Nuclear Oversight -

t From: James K. Peny, Jr., LHC { \

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Subject:

Addendum to Survey History - Review of " Safety Cultu " Questions Added to June 1997 Survey

Reference:

Attached 29 May,1997 Letter to Michael Brown frc~n Dr. Roben R. Albright Because of the time sensitivity of this matter, I am providing my conclusions to you in writing.

Per the draft protocol, the NRC has been sent a copy of this memo and it will be reviewed at the public meeting on June 3,1997.

Conclusions-the use of Dr. Albright's " Safety Culture" constructs and their associated test items are found to be a potentially useful enhancement to your current (1996) survey instmment provided l that :

a They are randomly distributed throughout the other survey questions in the same manner as was recommended for the NU group of employee concerns questions. l' u A " conservative decision making" construct and associated test items -

is added.

m A " senior management endorses a policy that supports the workers' right to raise safety issues without fear of harassment, discrimination,

. or intimidation" construct and associated test items is also added.

m Be consistent, either use a 4 point scale for all like the one used in the i FPI survey or convert to a 5 point scale as Dr. Albright recommends.

Attachment ec: NRC-Russ Arrighi-Resident Inspector Unit 3  !

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ITPOP Memorandum t i

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Date: May 30,1997 l To: D. M. Goebel, Vice President, Nuclear Oversight NNECo-Millstone From: James K. Perry, Jr., LHC l

Subject:

Addendum to Nuclear Leadership Assessment - Summer 1997 Because of the time sensitivity of this matter, I am providing my conclusion to you in writing. Per the draft protocol, the NRC has been sent a copy of this memo and it will be reviewed at the public meeting on June 3,1997.

Conclusion-The ten (10) employee concems questions proposed for addition to the Nuclear Leadership Assessment are redundant to the anticipated culture survey.

cc: NRC-Ted Eastick SRI-Unit 1 l

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• clearly Co=c=nniated to E=ployees Regarding Scope and Responsibilities

• Concerns Addressed in Thorough and Timely Manner S N85 by Competent investigsters

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• Reviewed the ECP Manual Dated d/1487

• Management Overview of the Process

• Reviewed the ECP Consmunications Plan Dated ,

• Comprehensive Reports Providing Trending and M787 Effectiveness to Management *

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i Interviewed Seven Members of the ECP Organisation

• Site wide Consistency for Organizations Outside of a Discussed Interfaces and Other Protocol With 5 Line Whe Receive and Process Employee Concerns Managers of Organizations Outside the Line % ho

• Clearly Defined interfaces Between the Above Receive and Process Concerns Organizations a Reviewed Drafis of:

• Supenisors/Mansgers Trained in ECP

• Rev i to ECF Massal Staff Qualification $tandards Establuhed and Applied - ECP $ elf-Assesiewas

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• ECP Monthly Reports

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Co'ncinsios 2i The ECP Manual Does frogram Contains the~ Basics for an /

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[dNot Addrdithe Full' Breadth of

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• Senior Management Support is Evident

• Rehes en Human Resources, Industrial 5arety sad

• !s ladependeniFrom Line Organiastens and Reports to the VP Nuclest Oversigha With Dotted Line to the llealth, Internal Audit, System Security, and Site President sad CEO Nuclear and to the NU Board of Suurity Oganizadcas for EFectin latake, Te investigations and Closure of Conurns

• Provides for Communication of the ECP Don Not Fully Address Espectations Training and Consistencies Between These Organizations

• Describes an Adequate Approach for Receiving.

• No Currently Developed Protoni to Govern Interfaces Frierttuing. Investigating and Closing Concerns by the l

ECP Organization Between Organizations Addressing Employee

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t Conclusion 3:]DoesNot Provide for , tConclusion 4:sECP Manual Lacks hExpected Management; Overview ';

QejSome Elements ggif

• Management Review of Employee Concerns is Not

• Manual Does Not Centain Requirement for Described Conducting an Annual Enternal Assessment of the

• Data Base is Not Adequately Detailed to Contain ECP as Comanitted to is the CP (Action Item 1013) lafernation Needed to Generate Espected Trending

• Requires AH NU Employees to Participate in se Esit

• ECP Monthly Report Lacks Espected Level of Detail laterview; However, Site Enit Process Does Not Assure They Wlu be Directed to the ECP

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• Manual Does Not Addrns Coverage for Contractors at

• The ECP Concerns Resolution Process Is Off Site Locatsons Flawed in Seieral Key Respects:

Handling of NRC Referred Allegations Is Not Covered - he Procus hu Not Addras How Inm6:sdw Findings Are Translated into Corrective Actions Does het Address Personnel Qualincation and Training

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- There is No Process for Essluating the Effectiveness of Corrective Actions

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Manual to Address the Following:

• Deselop Commen Standards and Criteria for . Ensuat the Elements Referenced in Processing Concerns by AM the Organizations Conclusion 4 Are Addressed Hendling Employee Concerns

• Implement Correcthe Action for

• Develop Clear Interfaces, Espectations Bet = een These Self-Assessment identified liems Organizations

• Implement a Management Overview of the Concern Process Provide Comprehensise Monthly Reports to Management Addrenning Concerns Handled by A't Organizations

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l June 3,1997 Attached is the Northeast Nuclear Energy Company's (NNECO) supplemental response )

l to NRC letter from W. D. Travers to N. S. Carns," Questions and Comments on l NNECO's Plan for Addressing Employee Concerns," dated April 22,1997. Specifically, l Question #8 states: I l

i "The method used to link actions identified in the Plan to the Action items  !

! identified in the Employee Concerns Task Force Report and the root causes (

identified in the Millstone Independent Review Group [MIRG] Report is difficult I to follow and it is not clear that all root causes have been addressed."

NNECO concurs that the correlation of the Action Items in the Plan to the MIRG Report is difficult to follow. Therefore, we have developed a table (see attached) that clearly correlates the various Action Items to the MIRG Report.

This supplements the NNECO responses provided to the NRC at the May 21,1997 public meeting.

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Enclosure 3  ;

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CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS, MIRG REPORT ROOT

^

CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (It;ms crs listed sequentilliy by Campr;hinsivs Plin Actlin it m Number.

3,

, The listing crd:r does not imply relative significance of items.)

k i i MIRG Report MIRG Root Cause:

Root Cause No.

PROBLEM RESOLUTION AND PERF'ORMANCE MEASUBER

! "The [MIRG] team concluded that ineffective problem resolution processes have contributed to continued employee concems at Millstone, forcing reliance on the Nuclear Safety Concerns Program (NSCP) process to resolve concerns that should have been corrected by routine processes. Examples of problem areas are faulty root cause

' processes, ineffective corrective action follow-through, lack of appropriate performance I

measures (especially in the area of measuring employee trust and confidence), and cumbersome management decisionmaking processes. The team also concluded that a lack of visible progress in resolution of the concerns identified by a 1995 NSCP self-assessment team has further eroded the confidence of Millstone employees that NU

' is serious about correcting the fundamental problem described in that self. assessment.

Furthermore, several employees expressed concern that, based on experience, top management is unlikely to support the fundamental actions needed to effect change at 4

Millstone."

Como. Plan ESTE Action item No. Comorehensive Plan Action item Description Trackina No.

! 1- 1 initiate Condition Reports (CRs) and/or track CRs submitted to implement corrective actions required or agreed to as a result of an ECP concern. ECPS- 1 I 1- 2 Provide feedback to the Concerned Individual (Cl) on a regular basis (or a memo to file if the Cl is unknown).

ECPS- 2

! 1- 5 Provide accurate, real-time input to the ECP database system so that tracking and trending of activities can be completed. ECPS- 5

! 1- 6 Escalate to the ECP Director those concerns that have not been properly l dispositioned. ECPS- 6 l 1- 9 Conduct or coordinate investigations to resolve concerns within 45 days. ECPS- 9 i

i 4

2- 3 HR to conduct self assessment activities and report the results- HR- 3 4

! 2- 5 Communicate philosophy, mission, and responsibilities of HR to all j employees. HR- 5

2- 6 Review performance reviews and promotion / selection criteria for I supervisory /non supervisory positions in the Nuclear Division to inc!ude HR- 6 i competencies / goals related to handling employee concerns, thus j reducing the opportunities that result in peer pressure deterring

,i co-workers from identifying concerns.

2- 9 Review and modify HR procedures, performance review processes and HR- 9 i

supervisory selection criteria to address the attributes of addressing employee concerns and handling dissenting professional opinions as positive attributes which gain employees positive recognition. HR to identify, review and revise procedures with ECP assistance.

2-10 Implement a survey to provide all employees the opport0nity to l participate in an assessment of their supervision's performance.

HR-11 Establish a goal of 90% participation.

2-13 Develop and implement a policy in which quantified survey results HR-14 identifying poor performing supervisors are addressed and an action plan for improvement is developed. All such actions shall be documented.

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CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (It:me cre listed sequ;ntlilly by Campr:hinsiv3 Plin Actisn it:m Number.

', The listing order does not imply relative significance of items.)

l' 3- 1 Define Employee Concerns Oversight Panel goals and objectives.

include the responsibilities of Paragraph 2.6 of the Plan as a minimum. COP- 1 3- 3 Review Requests for Third Party Reviews submitted by ECP Director from Concerned Individuals. COP- 4 4- 1 Develop, implement and complete initial ECP training for all employees. T- 1 4- 3 Revise Managing For Nuclear Safety course to include ECP procedural requirements, and expected competencies. T- 3 l 4- 5 Ensure adequate resources are made available to provide support staff (i.e. HR) training for addressing employee concerns. T- 5 4- 6 Support the ECP Director by developing and implementing a new course i for supervision addressing professional dissent. T- 6 48 Ensure that courses required for ECP Intake and investigator staff are T- B readily available for personnel to complete per the ECP performance goals.

5- 1 Announce the NU Program for Addressing Employee Concerns and the new ECP. CNO-1 S- 3 Hold assigned individuals responsible for implementing corrective actions for substantiated concerns. CNO-3 5- 5 issue a statement of support for the Employee Concerns Oversight Panel to all Millstone personnel. CNO- 5 5- 6 issue an open letter to all Millstone personnel requesting identification of any new concerns. CNO-6 5- 7 Establish and post expectations to the work fo[ce regarding employee CNO- 7 concerns, 6 c) Ensure supervisors complete a course on professional dissent. SUP- 9 7- 2 All employees to cooperate in investigations. EMP- 2 9- 3 Draft a letter, signed by CEO, Nuclear, inviting Millstone personnel who ECPD- 3 have interest in the Employee Concerns Oversight Panel to cttend an orientation session.

g. 4 Conduct orientation for potential Employee Concerns Oversight Panel members. ECPD- 4 9-13 Complete training for Vice President and Director level personnel in ECPD-13 employee concerns and professional dissent.

9 15 Notify Employee Concarns Oversight Panel of action items not completed satisfactorily. ECPD-15 9-17 Attend NRC meetings and briefings at Millstone on ECP-related issues. ECPD-17 9 24 Provide to senior management, the Independent Third Party Oversight ECPD-24 Panel (ITPOP), and Employee Concerns Oversight Panel current trend

analyses of ECP activities, t

l 9-28 Assist the Training Department in review and revision of initial ECP

! ECPD-28 orientation class. Include new expectations, policies, and procedures.

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CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT j .. -

CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (Itzm3 tre listed sequintiilly by Camprrh nsiva Plan Acti n it:m Number.

j, The listing order does not imply relative significance of items.)  ;

l l 9-30 Ensure contractors cooperate with NU in the completion of required 1 investigations. ECPD-30 4

[ 9-31 Ensure all contractor supervisors on-site for more than six months have completed the Managing For Nuclear Safety and Professional Dissent ECPD-31

courses.

! 10-1 increase executive visibility in the work place " walking the talk",

EXEC-1 l promote the new culture, ECP, and welcome the identification of i

concerns. ,

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, 10-2 Direct and support the issuance of the Problem Resolution Standard for EXEC-2 l Supervisors.

l 10-5 Intervene as needed to ensure unresolved concerns are provided the EXEC- 5

! necessary attention.

4 10-7 Direct the responsible organization to revise the supervisor assessment EXEC- 7

survey to include questions which will result in corrective actions for poor supervisory performance.

i 10-8 Complete the Managing For Nuclear Safety Course or be briefed on the EXEC-8 revisions if the course has already been completed.

i 10-9 Review action items not completed as reported by the ECP Director and EXEC-9 j -

determine what additional actions are necessary to support completion.

l 10-10 Directors, Managers and first line supervisors complete or demonstrate

EXEC-10 proficiency in the following courses

Seven Habits Myers-Briggs, Labor i Relations, Principle Centered Leadership, Interpersonal Skills, Interviewing Skills, Handling Professional Dissent and Chilling Effect.

i 10-11 Ensure all employees are provided the opportunity to participate and EXEC-11

] complete an assessment of their supervision's performance. A goal of j 90% participation is set.

10-12 Ensure adequate resources are provided to execute the Plan. VP- 1 li 10-14 Promulgate the roles and responsibilities of the Legal Department. L- 1 i 10-15 Require the Legal Department to inform the ECP Director of employee L- 2 i concerns made known to them which have not been previously i documented.

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i j PAGE 3

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I CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT l . . .

CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (ltim3 tra listed sequIntl Illy by CcmprIh:nsiva Plan ActlIn itim Number.

The listing order does not imply relative significance of items.)

1 ii MIRG Report MIRG Root Cause:

i Root Cause No.

SENSITMTY TO EntPLOYEE NEEDS

"The [MIRG) team noted that some NU employees continue to perceive some managers as being insensitive to employee needs, thus creating some work environments in

which dissent is discouraged."

Como Plan EQJE l

Action item No. Comorehensive Plan Action item Description Trackina No.

1- 3 ECP staff reinforce the need for all supervisors and employees to

{ address concerns. ECPS- 3 l 1- 7 increase ECP visibility in the work place.

ECPS- 7 i 1- 9 Conduct or coordinate investigations to resolve concerns within 45 days. ECPS- 9 l

24 Change the performance management competencies listed in LINKS to HR- 4

! reflect those expectations from the new ECP Plan.

j - .

. 2- 5 Communicate philosophy, mission, and responsibilities of HR to all Hg. 5

) employees.

2- 6 Review performance reviews and promotion / selection criteria for HR- 6

supervisory / non supervisory positions in the Nuclear Division to j include competencies / goals related to handling employee concerns,

} thus reducing the opportunities that result in peer pressure deterring

co-workers from identifying concerns.

! 2-11 Reinvigorate a management led program to celebrate and reward HR-10 employees for the identification and resolution of significant concerns.

HR-12

EXEC-12 o -

i 2-16 Modify the supervisor assessment survey to ask questions that will HR-17 allow the identification of " hot spots".

46 Support the ECP Director by developing and implementing a new course T- 6 l for supervision addressing professional dissent.

! 54 Recognize employees who identify and/or help resolve significant CNO- 4

employee concerns.

l 5- 7 Establish and post expectations to the work force regarding employee CNO- 7

! concerns.

6- 1 Review, sign and post a copy of the Problem Resolution Standard for gyp.1 j Supervisors in their work areas.

l 6- 2 Actively solicit input from employees and address all identified issues

! per established procedures. SUP- 2 i 6- 3 Respond to requests for information and assist in ECP investigations to SUP- 3 j support agreed schedules.

4 j 6- 4 Complete required corrective actions per ECP investigation. SUP- 4 i 6- 5 Subordinates that are weak in any of the expected competencies will be SUP- 5

] evaluated and remedial action taken, i

l PAGE 4 1

f' CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (It;ms cre liited sequentlilly by Campr;hin lv3 Pirn Acti:n it:m Number.

The listing order does not imply relative significance of items.)

6- 6 Ensure that Millstone Station personnel view the ECP video and discuss the ECP process semi-annually. SUP- 6 6- 7 include ECP performance goals in annual performance plans. SUP- 7

~

6- 8 Complete Managing For Nucleariafety Training by third quarter of 1997. gyp g Personnel promoted into supervisory positions should complete course within 90 days of effective promotion date.

6- 9 Ensure supervisors complete a course on professional dissent. SUP- 9 8- 3 Assist the Nuclear Training Department in producing a management COM- 3 l video to introduce the new ECP with emphasis on new culture, personnel i

and line managements resolution.

8- 8 Facilitate the ECTF's issue of a thank you letter to all Millstone personnel. ECTF- 4 9- 6 Assist in placing the permanent Employee Concerns Oversight Panel CNO-9 Administrator.

l 9-10 Maintain safeguards to protect the confidentiality of Concerned ECPD-10 Individuals who request confidentiality.

l r

l 9 12 Ensure PEER procedure is updated to reflect ECP revisions. Integrate ECPD-12 PEER program into overall ECP communications plans.

9-13 Complete training for Vice President and Director level personnel in ECPD-13 l employee concerns and professional dissent.

9-15 Notify Employee Concerns Oversight Panel of action items not completed satisfactorily. ECPD-15 9-23 Develop a newly formatted ECP monthly report which will provide more ECPD-23 insightful information to those reading it.

g.31 Ensure all contractor supervisors on site for more than six months have completed the Managing For Nuclear Safety and Professional Dissent ECPD-31 courses.

9-32 Establish and implement in collaboration with ECP personnel ECPD-32 l appropriate monitoring measures to evaluate the work place environment being conducive for workers to raise concerns without fear of retallation.

9-33 Ensure an adequate ECP knowledge base is present in the contractor ECPD-33 work force demonstrated by completion of ECP training, and spot surveys.

9-35 Draft a letter, signed by CEO, Nuclear, to former Millstone personnel rlCPD-35 seeking their input of potential technical concerns.

l l

1 PAGE 5 l

h

l. ,

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

CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS

., (Items cra listed sequentlilly by C:mpr: hen:lva PI:n Acti:n it:m Number.

The listing order does not imply relative significance of items.)

E' , ,eDort MlRG Root Cause:

Root cause No.

RELUCTANCE TO ADMITMISTAKES "The [MIRG) team concluded that management's reluctance to admit its mistakes has significantly impeded efforts to improve the corporate attitude toward M;llstone employees who raise concerns. Among the significant examples of this tendency are a legalistic approach to dealing with employees and their concerns, prr; acted study of probleins, continued denial of discrimination findings, the prevalenc( ' a " shoot the messenger" attitude, and a failure to recognize the need for credible, I, e,' pendent assessment of discrimination concerns at Millstone."

Como. Plan QGIE Action item No. Comorehensive Plan Action item Description Trackino No.

1- 2 Provide feedback to the Concerned Individual (Cl) on a regular basis (or ECPS- 2 a memo to file if the Clis unknown).

2- 2 Establish protocol, expectations and goals for HR-ECP interfaces.

Define and clarify the expectations of the on-site HR' representatives in HR- 2 the handling of issues brought to their attedon.

2- 3 HR to conduct self assessment activities and report the results. HR- 3 24 Change the performance management competencies listed in L!NKS to HR- 4 reflect those expectations from the new ECP Plan.

2- 5 Communicate philosophy, mission, and responsibilities of HR to all HR- 5 employees.

2- 6 Review perfonnance reviews and promotion / selection criteria for supervisory / non-supervisory positions in the Nuclear Division to HR- 6 include competencies / goals related to handling employee concerns, thus reducing the opportunities that result in peer pressure deterring co workers from identifying concerns.

2- 7 Support the ECP through timely responses to investigation requests in HR- 7 accordance with set schedules.

2- 8 Develop and implement, with the assistance of the ECP, a plan for a Hg. g Non-Union Peer Review Process to supersede the existing NU grievance proc.3s.

2- 9 Review and modify HR procedures, performance review processes and HR- 9

) supervisory selection criteria to address the attributes of addressing l employee concerns and handling dissenting professional opinions as positive attributes which gain e.nployees positive recognition. HR to identify, review and revise procedures with ECP assistance.

2-10 Implement a survey to provide all employees the opportunity to HR-11 participate in an assessment of their supervision's performnce.

Establish a goal of 90% participation.

2-13 Develop and implement a policy in which quantified survey results HR-14 identifying poor performing supervisors are addressed and an action i plan for improvement is developed. All such actions shall be [

documented. l l

PAGE 6 '

_ _ _ _ _ _ - _ - - i

I i CORRELATION OF COMPREHENSIVE FLAN ACTION ITEMS. MIRG REPORT ROO )

• CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS i (It;ms tre listed sequentitily by Comprehensive Plan Action item Number. 1 The listing order does not imply relative significance of items.)

i t.

(

3- 9 Develop a protocol for the panel to be notified of terminations and review '

terminations and planned reductions in the permanent work force to COP-10

]

determine if there is evidence that ernployees involved in a protected

_ activity are being singled out. Provide recommendations as appropriate.

$_i $ Review for potential " chilling effect" and determine if work place intervention is required by management. COP-12 l 4- 6 Support the ECP Director by developing and implementing a new course for supervision addressing professional dissent. T- 6 5- 2 CEO participate in a video presentation to introduce the Comprehensive Plan and the new ECP, CNO- 2 4

5- 3 Hold assigned individuals responsible for implementing corrective  !

actions for substantiated concerns. CNO- 3 '

i l 5- 4 Recognize employees who identify and/or help reso!ve significant employee concerns. CNO- 4 s -

4 5- 5 issue a statement of support for the Employee Concerns Oversight Panel i

to all Millstone personnel. CNO- 5 i 1

5- 6 issue an open letter to all Millstone personnel requesting identification of

, any new concerns. CNO- 6

~

l- 5- 7 Establish and post expectations to the work force regiding employee

. concerns. CNO- 7 ,

i 6- 9 Ensure supervisors complete a course on professional dissent.

SUP- 9 I 74 Maintain a questioning attitude and make suggestions for improvement, EMP- 4 q question the status quo, and raise concerns as appropriate.

!' 9-13 Complete training for vice President and Director level personnel in

) employee concerns and professional dissent, ECPD-13 j 9-16 Notify Employee Concerns Oversight Panel of alleged harassment, intimidation, discrimination & retaliation instances. ECPD-16 9-17 Attend NRC meetings and briefings at Millstone on ECP-related issues.

ECPD-17 I 9-31 Ensure all contractor supervisors on site for more than six months have i completed the Managing For Nuclear Safety and Professional Dissent ECPD-31

j. courses.

l 10 Direct the responsiblehanization to revise the supervisor assessment survey to include questions which will result in corrective actions for EXEC-7 j poor supervisory performance.

I 10-14 Promulgate the roles and responsibilities of the Legal Department. L- 1 i

i 4

)

l l PAGE 7

3. - , _, _

- CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT

• CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (items tre llIted sequ:nttilly by CtmprehInsivs Pl:n Actlin it:m Number.

The listing order does not imply relative significance of itsms.)

i* MlRG Rooort MIRG Root Cause:

Root Cause No.

hfANAGEMENT STYLE AND SUPPORT FOR CONCERNED EMPLOYEES 7'4 "Several individuals at various organizatic.nal levels expressed the view that top l leadership at NU has condoned an arrogant management style, for both technica? and i

administrative functions, and has not been supportive of concerned employees. They l felt that this deficit had been particularly noticeable in the human resources area, where

! the tendency to develop a legalistic approach to contest DOL findings of discrimination j was evident. The [MIRG) team concluded that this perceived style had the potential to

stifle dissenting views."

Como. Plan PSIE l Action item No. Comorehensive Plan Action item Description "rackina No.

i 1- 2 Provide feedback to the Concerned Individual (Cl) on a regular basis (or i ECPS- 2 a memo to file if the Clis unknown).

! 1- 7 increase ECP visibility in the work place.

i ECPS- 7 l 1- 9 Conduct or coordinate investigations to resolve concerns within 45 days. ECPS- 9

! 24 Change the perf7rmance management competencies listed in LINKS to reflect those expectations from the new ECP Plan. HR- 4 2- 5 Communicate philosophy, mission, and responsibilities of HR to all j employees. HR- 5

2- 6 Review performance reviews and promotion / selection criteria for

! supervisory / non-supervisory positions in the Nuclear Division to HR- 6

! include competencies / goals rela *.ed to handling employee concerns,

! thus reducing the opportunities that result in peer pressure deterring

l. co-workers from identifying concerns.

! 2- 7 Support the ECP through timely responses to investigation requests in HR- 7 j accordance with set schedules.

t j 2- 8 Develop and implement, with the assistance of the ECP, a plan for a HR- 8 3 Non-Union Peer Review Process to supersede the existing NU grievance process.

I Review and modify HR procedures, performance review processes and 2- 9 HR- 9

} supervisory selection criteria to address the attributes of addressing i employee concerns and handling dissenting professional opinions as l positive attributes which gain employees positive recognition. HR to

identify, review and revise procedures with ECP assistance.

{ .

. 2-11 Reinvigorate a management led program to celebrate and reward HR-10 j employees for the identification and resolution of significant concerns.

HR-12

EXEC-12 i 2-16 Modify the supervisor assessment survey to ask questions that will HR-17 l allow the identification of " hot spots".

34 Provide assistance in dispute resolution for those case files as COP- 5

!. requested by the ECP Director.

1 3- 8 Provide constructive recommendation where " protected conduct"is COP- 9

} being viewed as poor performance in order to avoid issues of i harassment, intimidation, discrimination or retaliation.

i i

PAGE 8 4

CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT

} ,, . CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (ltims tre listed sequ:ntlilly by Ccmpreh:n:lva Plin Acti:n it:m Number. -

The listing order does not imply relative significance of items.)

2 (I

i 3-11 Review for potential " chilling effect" and determine if work place COP-12 intervention is required by management.

l- 4- 6 Support the ECP Director by developing and implementing a new course l for supervisic n addressing professional dissent. T- 6

' )

i l 4. g Identify a training liaison to work with the ECP Director in the overall implementation of training requirements to support the NU Program for T- 9 i l

Addressing Employee Concerns. '

l 5- 1 Announce the NU Program for Addressing Employee Concerns and the

! new ECP. CNO- 1 i

5- 2 CEO participate in a video presentation to introduce the Comprehensive j Plan and the new ECP. CNO- 2 f 5- 3 Hold assigned individuals responsible for implementing corrective CNO- 3

]- actions for substantiated concerns.

5- 5 issue a statement of support for the Employee Concerns Oversight Panel CNO-5 j to all Millstone personnel.

i 5- 7 Establish and post expectations to the work force regarding employee CNO- 7 a concerns.

5- 8 CEO announce approved recommendations contained in ECTF Report. CNO- 0 Respond by letter to the ECTF to explain rationale for those items not approved.

6- 1 Review, sign and post a copy of the Problem Resolu'lon Standard for gyp. 5 Supervisors in their work areas.

4 6- 2 Actively solicit input from employees and address all identified issues per established procedures. SUP- 2 6- 3 Respond to requests for information and assist in ECP investigations to gyp.3 support agreed schedules.

6- 5 Subordinates that are weak in any of the expected competencies will be SUP- 5 evaluated and remedial action taken.

' 6- 6 Ensure that Millstone Station personnel view the ECP video and discuss the ECP process semi-annually.

SUP- 6 6- 7 include ECP performance goals in annual performance plans. SUP- 7 6- 8 Complete Managing For Nuclear Safety Training by third quarter of 1997. gyp. g Personnel promoted into supervisory positions should complete course within 90 days of effective promotion date.

6- 9 Ensure supervisors complete a course on professional dissent. SUP- 9 83 Assist the Nuclear Training Department in producing a management COM- 3 video to introduce the new ECP with emphasis on new culture, personnel and line managements resolution.

8- 5 invigorate the PEER program by reintroducing the Peer Representatives COM- 5 7

to the work force.

8- 8 Facilitate the ECTF's issue of a thank you letter to all Millstone personnel. ECTF- 4 PAGE 9

CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT

• - CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (It:ms tra listed sequenttilly by Csmprah nriva Pl:n Actirn it:m Number.

The listing order does not imply relative significance of items.)

i 92 Develop and implement a comprehensive communication plan to promote the changes occurring at NU. Address training, employee ECPD- 2 recognition, community outreach, executive management involvement, and long-term plans. Targct audiences include all employees, NRC and general public.

9- 3 Draft a letter, signed by CEO, Nuclear, inviting Millstone personnel who have interest in the Employee Concerns Oversight Panel to attend an ECPD- 3 orientation session.

g. 4 Conduct orientation for potential Employee Concerns Oversight Panel members. ECPD- 4 9-12 Ensure PEER procedure is updated to reflect ECP revisions. Integrate PEER program into overall ECP communications plans, ECPD-12 9-13 Complete training for Vice President and Director level personnel in employee concerns and professional dissent. ECPD-13 9-18 Develop a specific Community Outreach Plan as part of the overall communication plan to update Concerned Individuals and Groups on the ECPD-1B ECP progress.

9-31 Ensure all contractor supervisors on-site for more than six months have completed the Managing For Nuclear Safety and Professional Dissent ECPD-31 courses.

32 Establish and implement in collaboration with ECP personnel appropriate monitoring measures to evaluate the work place ECPD-32

( environment being conducive for workers to raise concerns without fear of retaliation.

9-33 Ensure an adequate ECP knowledge base is present in the contractor work force demonstrated by completion of ECP training, and spot ECPD-33 surveys.

9-34 Evaluate PEER fiepresentatives augmentation of ECP staff for functions ECPD-34 such as information gathering, looking for/at " hot spots", and promoting the new program.

10-1 increase executive visibility in the work place . " walking the talk", EXEC-1 promote the new culture, ECP, and welcome the identification of concerns.

10-2 Direct and support the issuance of the Problem Resolution Standard for EXEC-2 Supervisors.

10-3 Direct line supervision and support organizations to include ECP EXEC-3 accountability goals and competencies in each supervisor's and employee's performance review plan.

10-4 Introduce the Managing For Nuclear Safety course (on a rotat!ng basis). EXEC-4 10-6 Support the goals of the ECP by effectively dealing with negative trends EXEC-6 and poor supervisor, performance as identified by the ECP Director and/or Employee Concerns Oversight Panel.

10-8 Complete the Managing For Nuclear Safety Course or be briefed on the EXEC- 8 revisions if the course has already been completed.

10-12 Ensure adequate resources are provided to execute the Plan, yp.1 PAGE 10

i- CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT CAUJES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (ltims cre listed requintitlly by Ccmprihin:lv3 PI:n Acti n it:m Number.

l The listing order does not imply relative significance of items.)

. i MIRO Report MIRG Root Cause:

Root Cause No.

COMMUNICATIONS AND TEAMWORK

{ 7.5

" Communications appeared to be a continuing problem area, characterized by poor j

inter departmental interaction, general failure to encourage questioning attitudes, and a

tendency to manage by memorandum. Ineffectivt implementation of the concept of 1

_ teamwork also appears to have contributed to employee concerns at Millstone."

l Como. Plan ggIg i

Action item No. Comprehensive Plan Action item Descriotion Trackina No.

l 1 Increase ECP visibility in the work place.

ECPS- 7 j 2- 5 Communicate philosophy, mission, and responsibilities of HR to all

employees. HR- 5 2- 7 support the ECP through timely responses to investigation requests in l accordance with set schedules. HR- 7 l 2-12 Assign HR Reps to padicipate in ECP Intakelinvestigator training. HR-13 34 Provide assistance in dispute resolution for those case files as COP- 5 l requested by the ECP Director.

! 3- 6 Repnrt assessment finding j ith recommendations to the CEO and to the COP- 7 Nuclear Committee of the Board of Trustees. (NCAT) 3- 8 Provide constuctive recommendation where " protected conduct"is

being viewed as poor performance in order to avoid issues of COP- 9 j harassment, intimidation, discrimination or retaliation.

j 3-10 Review ECP trend data. COP-11 l 4- 1 Develop, implement and complete initial ECP training for all employees. T- 1 4- 6 Support the ECP Director by developing and implementing a new course T- 6 l for supervision addressing professional dissent.

i

5- 6 issue an open letter to all Millstone personnel requesting identification of CNO-6

any new concerns.

1 i 5- 7 Establish and post expectations to the work force regarding employee CNO- 7 concems.

i

! 5- 8 CEO announce approved recommendations contained in ECTF Report. CNO- 8

, Respond by letter to the ECTF to explain rationale for those items not approved.

6- 2 Actively solicit input from employees and address all identified issues SUP- 2 per established procedures.

l 6- 9 Ensure suporvisors complete a course on professional dissent. SUP- 9

. ~

j 7- 1 Report unresolved issues and concerns. EMP- 1 7- 2 All employees to cooperate in investigations. EMP- 2 1

7- 3 Participate in supervisory assessments and company surveys. EMP- 3

+

PAGE 11

i i

CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT

!. + CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS

~(ItIms tre it:ted requintillly by Ccmpr:hrnilva Plin Actirn it:m Number.

l The listing order does not imply relative significance of items.)

/

7- 4 Maintain a questioning attitude and make suggestions for improvement, i

question the status quo, and raise concerns as appropriate. EMP- 4

~

t 81 Assist in the advertisement of the new ECP and other elements of the l

i communication plan developed by the ECP Director. COM- 1

! 8- 3 Assist the Nuclear Training Department in producing a management video to introduce the new ECP with emphasis on new culture, personnel COM- 3

and line managements resolution.

84 Determine if a " Rumor Control Hotline" to address rumors and general i questions is warranted and implement per a set schedule. COM- 4

8. S Invigorate the PEER program by reintroducing the Peer Representatives to the work force. COM- S .

8- 6 Facilitate the ECTF attendance at a public meeting to explain and promote the Comprehensive Plan. ECTF- 2 92 Develop and implement a comprehensive communication plan to ECPD- 2 promote the changes occurring at NU. Address training, employee recognition, community outreach, executive mana2ement involvement, and long-term plans. Target audiences include all employees, NRC and general public.

9- 3 Draft a letter, signed by CEO, Nuclear, inviting Millstone personnel who have interest in the Employee Concerns Oversight Panel to attend an ECPD- 3 orientation session.

9-12 Ensure PEER procedure is updated to reflect ECP revisions. Integrate PEER program into overall ECP communications plans. PEER- 1 9-13 Complete training for Vice President and Director level personnelin ECPD-13 employee concerns and professional dissent.

9-17 Attend NRC meetings and briefings at Millstone on ECP related is' sues.

ECib$1[

9-18 Develop a specific Community Outreach Plan as part of the overall ECPD-18 communication plan to update Concerned Individuals and Groups on the ECP progress.

9-19 Develop an Intranet NU ECP Web page.

ECPD-19 9-23 Develop a newly formatted ECP monthly report which will provide more ECPD-23 insightful information to those reading it.

9 24 Provide to senior management, the Independent Third Party Oversight ECPD-24 Panel (ITPOP), and Employee Concerns Oversight Panel current trend analyses of ECP activities.

9-26 Develop protocol with the licensing department to investigate concerns ECPD-26 referred by the NRC.

9-27 Inform senior line management of concerns. ECPD-27 9-28 Assist the Training Department in review and revision of initial ECP ECPD-28 orientation class, include new expectations, policies, and procedures.

9 30 Ensure contractors cooperate with NU in the completion of required ECPD-30 investigations.

PAGE 12

CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS, MIRG REPORT ROOT

' CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS

(!t:ms tre llated sequ:ntirlly by Crmpr;hinsive Plan Action item Number, j The listing order cioes not imply relative significance of items.)

9 31 Ensure all contractor supervisors on site for more than six months have completed the Managing For Nuclear Safety and Professional Dissent ECPD-31 courses, j g.32 Establish and implement in collaboration with ECP personnel appropriate monitoring measures to evaluate the work place ECPD-32 environment being conducive for workers to raise concerns without fear of retaliation.

g.33 Ensure an adequate ECP knowledge base is present in the contractor work force demonstrated by completion of ECP training, and spot ECPD-33 surveys.

g.34 Evaluate PEER Representatives augmentation of ECP staff for functions such as information gathering, looking for/at " hot spots", and promoting ECPD-34 the new program.

10-1 increase executive visibility in the work place " walking the talk",

promote the new culture, ECP, and welcome the identification of EXEC-1 concerns.

10-2 Direct and support the issuance of the Problem Resolution Standard fcr EXEC-2 Supervisors.

10-10 Directors, Managers and first line supervisors complete or demonstrate proficiency in the following courses: Seven Habits, Myers-Briggs, Labor EXEC-10 Relations, Principle Centered Leadership, Interpersonal Skills, Interviewing Skills, Handling Professional Dissent and Chilling Effect.

10-15 Require the Legal Department to inform the ECP Director of employee concerns made known to them which have not been previously L- 2 documented.

PAGE 13

,f i

[,, CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT

-

• CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF1 ACTION ITEMS (It:ms are listed sequentially by Comprehensive Plan Action item Number.

{ The listing order does not imply relative significance of items.)

i i!

MIRG Report MIRG Root Cause

Root Cause No.

MANAGEMENTACCOUNTABILITY O '

i "A general lack of management accountability and sense of ownership appeared to have contributed to current problems at Millstone. Managers were perceived as

! i providing more emphasis on justifying the status quo, than on aggressively addressing '

i and resolving employee-identified problems. Also, employees considered that e

J supervisors responsible for discriminating against employees were not routinely '

i disciplined in an appropriate manner."

i Como. Plan E91E l Action item No. Comorehensive Plan Action item Description Trackina No.

l 2- 1 Matrix the site HR organintion to the President and CEO for a minimum of two years. HR- 1 j -

2- 2 Establish protocol, expectations and goals for HR ECP interfaces.

} Define and clarify the expectations of the on-site HR representatives in HR- 2 l the handling of issues brought to their attention.

! 2- 3 HR to conduct self assessment activities and report the results. HR- 3 l ' 2- 4 Change the perfonnance management competencies listed in LINKS to

reflect those expectations from the new ECP Plan. HR- 4 I 2- 6 Review performance reviews and promotion / selection criteria for i supervisory / non-supervisory positions in the Nuclear Division to HR- 6 l, include competencies / goals related to handling employee concerns, thus reducing the opportunities that result in peer pressure deterring

co-workers from identifying concems.

i .

l 2- 8 Develop and implement, with the assistance of the ECP, a plan for a HR- B i Non-Union Peer Review Process to supersede ine existing NU grievance l process, i

2 Implement a survey to provide all employees the opportunity to HR-11 i

participate in an assessment of their supervision's performance.

j Establish a goal of 90% participation.

l 2-13 Develop and implement a policy in which quantified survey results HR-14

identifying poor performing supervisors are addressed and an action j plan for improvement is developed. All such actions shall be i documenteJ.

! 2-14 Review and revise supervisor and employee position descriptions to HR-15 i address problem identification and resolution.

! 2-15 Establish a leadership assessment which permits 360 degree reviews of HR-16 L site-wide supervision.

3- 2 Develop and implement an operating procedure for the Employee COP- 2

! Concerns Ov.ersight Panel's activities.

.i 3- 5 Oversee the performance and effectiveness of the ECP. COP- 6 4

i 3- 6 Report assessment findings with recommendations to the CEO and to the COP- 7 i - Nuclear Committee of the Board of Trustees. (NCAT) i a

4 PAGE 14 4

CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROCT

• - CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS

^ (It ms gra Ilited sequ:ntirlly by Ccmprehensive Plan Action item Number. -

The IIsting order does not imply relative significance of items.)

3- 7 Review instances of past and present activities where evidence of

" chilling effect"is apparent as defined by supervisor assessment COP- 8 surveys. Conclusions and recommendations shall be documented.

3-10 Review ECP trend data.

COP-11 3-12 Ensure audits and assessments of HR's and ECP's performance are completed on a periodic basis. COP-13 4- 6 support the ECP Director by developing and implementing a new course for supervision addressing professional dissent. T- 6 5- 1 Announce the NU Program for Addressing Employee Concerns and the new ECP. CNO- 1 5- 3 Hold assigned individuals responsible for implementing corrective actions for substantiated concerns. CNO-3 5- 5 issue a statement of support for the Employee Concerns Oversight Panel to all Millstone personnel. CNO- 5 5- 7 Establish and post expectations to the work force regarding employee concerns. CNO- 7 6- 4 Complete required corrective actions per ECP Investigation.

SUP- 4 6- 5 subordinates that are weak in any of the expected competencies will be evaluated and remedial action taken. SUP- 5 6- 7 include ECP performance goals in annual performance plans. SUP- 7 6- 8 Complete Managing For Nuclear Safety Training by third quarter of 1997. gyp. g Personnel promoted into supervisory positions should complete course within 90 days of effective promotion date.

6- 9 Ensure supervisors complete a course on professional dissent. SUP- 9 6-10 Review NGP's, other select procedures, and departmental policies as required, to include appropriate elements of the new ECP in the PTF- 1 documents and subsequent training requirements.

7- 2 All employees to cooperate in investigations.

EMP- 2 7- 3 Participate in supervisory assessments and company surveys. EMP- 3

~

8- 2 Assist ECP Director in holding initial orientation meeting with employees. COM- 2 8- 6 Facilitate the ECTF attendance at a public meeting to explain and promote the Comprehensive Plan. ECTF- 2 9-13 Complete training for Vice President and Director level personnel in ECPD-13 employee concerns and professional dissent.

9-15 Notify Employee Concerns Oversight Panel of$ction items not completed satisfactorily. ECPD-15 9-16 Notify Employee Concerns Oversight Panel of alleged harassment, ECPD-16 intimidation, discrimination & retallation instances.

PAGE 15

. .. - .~. - -.

l CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT i

'f CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (It:ma cr3 listed sequ:ntlilly by Ctmprsh:nsive Plin Actisn itsm Number.

The listing order does. not imply relative significance of items.)

{

9 24 Provide to senior management, the independent Third Party Oversight i

Panel (ITPOP), and Employee Concerns Oversight Panel current trend ' ECPD-24 i analyses of ECP activities.

g.25 - Implement a database to identify and trend work place environment 1 issues i.e.," chilling effect". ECPD-25

g.26 Develop protocol with the licensing department to investigate concerns i referred by the NRC. ECPD-26 j g.29 Solicit personnel to become members of the Employee Concerns j Oversight Panel. ECPD-29 i 9-31 Ensure all contractor supervisors on-site for more than six months have i completed the Managing For Nuclear Safety and Professional Dissent ECPD-31 l courses.

! g.36 include members of ECTF in follow on meetings to brief them on the i status of the implementation of this plan and to obtain their assistance in ECTR 1 plan implementation.

10-3 Direct line supervision and support organizations to include ECP accountability goals and competencies in each supervisor's and EXEC- 3 employee's performance review plan.

10-5 Intervene as needed to ensure unresolved concerns are provided the EXEC- 5 necessary attention.

10-6 Support the goals of the ECP by effectively dealing with negative trends EXEC- 6 and poor supervisory performance as identified by the ECP Director and/or Employee Concerns Oversight Panel.

10-7 Direct the responsible organization to revise the supervisor assessment EXEC-7 survey to include questions which will result in corrective actions for poor supervisory performance.

10-8 Complete the Managing For Nuclear safety Course or be briefed on the EXEC- 8 revisions if the course has already been completed.

10-9 Review action items not completed as reported by the ECP Director and EXEC- 9 determine what additional actions are necessary to support completion.

10-11 Ensure all employees are provided the opportunity to participate and EXEC-11 complete an assessment of their supervision's performance. A goal of 90% participation is set.

0-13 Commission an assessment of the ECP by an external evaluator (e.g- \/P- 2 annually).

10-15 Require the Legal Department to inform the ECP Director of employee L- 2 concerns made known to them which have not been previously documented.

t PAGE 16

CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS. MIRG REPORT ROOT e - CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (ftems are listed sequentially by Comprehensive Plan Action item Number.

The listing order does not imply relative significance of items.)

MIRG Report MIRG Root Cause:

Loot cause No. NSCPIMPLEMENTATION "On the basis of the large number of allegations received by the NRC, the [MIRG) team concluded that the NSCP has not been an effective vehicle for resolving employee concems at Millstone. The team noted some indication of management support deficiencies, including inadequate NSCP resources, and insufficient independence and authority for NSCP to fully resolve issues."

Como Plan ECTF Action item No. Comprehensive Plan Action item Description Trackina No.

1- 2 Provide feedback to the Concemed Individual (Cl) on a regular basis (or ECPS- 2 a memo to file if the Clis unknown).

1- 3 ECP staff reinforce the need for all supervisors and employees to address concerns. ECPS- 3 1- 4 Implement and rupport the requirements of the ECP.

ECPS- 4 1- 8 Complete the intake / triage process within 5 working days after the Concemed Individual concurs with the concern being accurately ECPS- 8 documented or upon receipt of anonymous concems.

1- 9 Conduct or coordinate investigations to resolve concerns within 45 days. ECPS- 9 1-10 Complete required ECP Intakellnvestigator training. ECPS-10 2- 1 Matrix the site HR organization to the President and CEO for a minimum of two years. HR- 1 2- 2 Establish protocol, expectations and goals for HR-ECP interfaces.

Define and clarify the expectations of the on-site HR representatives in HR- 2 the handling of issues brought to their attention.

24 Change the performance management competencies listed in LINKS to HR- 4 reflect those expectations from the new ECP Plan.

2- 7 Support the ECP through timely responses to investigation requests in HR- 7 accordance with set schedules.

2- 9 Review and modify HR procedures, performance review processes and HR- 9 supervisory selection criteria to address the attributes of addressing employee concerns and handling dissenting professional opinions as positive attributes which gain employees positive recognition. HR to identify, review and revise procedures with ECP assistance.

2-12 Assign HR Reps to participate in ECP Intake / Investigator training. HR-13

'2-14 Review and revise supervisor and employee position descriptions to HR-15 address problem identification and resolution.

2-16 Modify the supervisor assessment survey to ask quastions that will allow the identification cf " hot spots". HR-17

> 2-17 Provide for tracking and feedback to Concerned Individuals of the status of their concerns. Not in ECTF PAGE 17

CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS <MIRG REPORT ROOT  !

A CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (EC,TF) ACTION ITEMS l (It m3 cre II:ted sequ:ntirlly by C:mpr:hrn:lva Plan Acti:n it:m Number.

l' The listing order does not imply relative significance of items.)

3- 1 Define Etaployee Concerns Oversight Panel goals and objectives.

include the responsibilities of Paragraph 2.6 of the Plan as a minimum. COP- 1

-2 Develop and implement an operating procedure for the Employee Concerns Oversight Panel's activities. COP- 2 3- 3 Review Requests for Third Party Reviews submitted by ECP Director from Concemed Individuals. COP- 4 3- 4 Provide assistance in dispute resolution for those case files as requested by the ECP Director. COP- 5 3- 5 Oversee the performance and effectiveness of the ECP.

COP- 6 3- 6 Report assessment findings with recommendations to the CEO and to the COP- 7 Nuclear Committee of the Board of Trustees. (NCAT) 3- 9 Develop a protocol for the panel to be notified of terminations and review terminations and planned reductions in the permanent work force to COP- 3 determine if there is evidence that employees involved in a protected activity are being singled out. Provide recommendations as appropriate.

3-10 Review ECP trend data.

COP-11 3-12 Ensure audits and assessments of HR's and ECP's performance are completed en a periodic basis. COP-13 3-13 Define the role and reporting relationship of the Employee Concern Oversight Panel Administrator and Chairman, Not in ECTF 4- 1 Develop. Implement and complete initial ECP training for all employees. T- 1 4- 2 Revise Plant Access Training to include an expanded ECP section.

T- 2 4- 3 Revise Managing For Nuclear Safety course to include ECP procedural requirements, and expected competencies. 73 -

44 Assist ECP Director in the identification, development, and delivery of T- 4 ECP staff training.

4- 5 Ensure adequate resources are made available to provide support staff T- 5 (i.e. HR) training for addressing Employee Concerns.

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

4- 7 Update Plant Access Training to include questions pertaining to the ECP. T- 7 4- 8 Ensure that courses required for ECP Intake and Investigator staff are T- 8 readily available for personnel to complete per the ECP performance goals.

4. g Identify a training liaison to work with the ECP Director in the overall T- 9 implementation of training requirements to support the NU Program for Addressing Employee Concerns.

4-10 Provide for training of " Peer Representatives."

PEER- 2 5- 1 Announce the NU Program for Addressing Employee Concerns and the new ECP. CNO- 1 PAGE 18

CAUSES, AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (It:ms cro li ted sequ:ntisily by C mpr;h nsivo Pitn Action it:m Number.

The listing order does not imply relative significance of items.)

5- 2 CEO participate in a video presentation to introduce the Comprehensive Plan and the new ECP. CNO- 2 5- 3 Hold assigned individuals responsible for implementing corrective actions for substantiated concerns. CNO- 3 5- 4 Recognize employees who identify and/or help resolve significant employee concerns. CNO- 4 5- 6 issue an open letter to all Millstone personnel requesting identification of any new concerns. CNO- 6 5- 7 Establish and post expectations to the work force regarding employee Concerns. CNO-7 5- 8 CEO announce approved recommendations contained in ECTF Report.

Respond by letter to the ECTF to explain rationale for those items not CNC-8 approved.

6- 6 Ensure that Millstone Station personnel view the ECP video and discuss the ECP process semi-annually. SUP- 6 6- 9 Ensure supervisors complete a course on profeWonal dissent. SUP- 9 6-10 Review NGP's, other select procedures, and departmental policies as required, to include appropriate elements of the new ECP in the PTF- 1 documents and subsequent training requirements.

7- 1 Report unresolved issuas and concerns.

EMP- 1 7- 2 Ali employees to cooperate in investigations.

EMP- 2 8- 1 Assist in the advertisement of the new ECP and other elements of the communic'ation plan developed by the ECP Director. COM- 1 8- 2 Assist ECP Director in holding initial orientation meeting with employees. COM- 2 8- 3 Assist the Nuclear Training Department in producing a management video to introduce the new ECP with emphasis on new culture, personnel COM- 3 and ilne managements resolution.

8- 5 Invigorate the PEER program by reintroducing the Peer Representatives COM- 5 to the work force.

8- 6 Facilitate the ECTF attendance at a public meeting to explain and ECTF- 2 promote the Comprehensive Plan.

8- 7 Help produce ECTF program recommendations, concept diagram, ECTF- 3 timelines and flow charts.

8- 8 Facilitate the ECTF's issue of a thank you letter to all Millstone personnel. ECTF- 4 9- 1 Retain temporary experienced investigator assistance to reduce the backlog and provide mentoring to staff. ECPD- 1 9- 5 Format, implement, and maintain new ECP procedures and guidelines ECPD- 5 specified by the Plan. (i.e. Employee Concerns Resolution Form) i PAGE 19

CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS, MIRG REPORT ROOT f

• CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (It:ms cra listed requ:ntially by CamprIh:nsivs Pl:n Acti:n it:m Number.

The listing order does not imply relative significance of items.)

9- 6 Assist in placing the permanent Employee Concerns Oversight Panel administrator. CNO- 9 ECPD-9 9- 7 Facilitate interviews for Employee Concerns Oversight Panel applicants.

ECPD 7 93 Attend first Employee Concerns Oversight Panel meeting to facilitate start up. ECPD- 8 99 Establish and publish internal performance goals and objectives for inclusion in ECP staff's performance reviews. ECPD- 9 9-11 implement new ECP procedure to address concerns.

ECPD-11 g.12 Ensure PEER procedure is updated to reflect ECP revisions, integrate PEER program into overall ECP communications plans. ECPD-12 pggg, j 9-13 Complete training for Vice President and Director level personnel in empicyee concerns and professional dissent. ECPD-13 9-14 Update and distribute a revised ECP brochure.

ECPD-14 9-20 Develop job descriptions for intake and investigative personnel.

ECPD-20 9-21 Identify and select appropriate permanent staff to support the new ECP.

ECPD-21 9-22 Develop and publish an ECP organization chart.

ECPD-22 9-26 Develop protocol with the licensing department to investigate concerns referred by the NRC. ECPD-26 g.28 Assist the Training Department in review and revision of initial ECP orientation class. Include new expectations, policies, and procedures. ECPD-28 9-29 Solicit personnel to become members of the Employee Concerns Oversight Panel. ECPD-29 g.31 Ensure all contractor supervisors on site for more than six months have completed the Managing For Nuclear Safety and Professional Dissent ECPD-31 Courses.

9-32 Estab!!sh and implement in collaboration with ECP personnel appropriate monitoring measures to evaluate the work place ECPD-32 environment being conducive for workers to raise concerns without fear of retaliation.

9-33 Ensure an adequate ECP knowledge base is present in the contractor work force demonstrated by completion of ECP training, and spot ECPD-33 surveys.

g.34 Evaluate PEER Representatives augmentation of ECP staff for functions such as information gathering, looking for/at " hot spots", and promoting ECPD-34 the new program.

9-36 include members of ECTF in follow on meetings to brief them on the status of the implementation of this plan and to obtain their assistance in ECTF- 1 plan implementation.

9-37 Provide Peer Representatives with necessary training. PEER- 2 l PAGE 20

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

i CORRELATION OF COMPREHENSIVE PLAN ACTION ITEMS, MIRG REPORT ROOT

j. CAUSES. AND EMPLOYEE CONCERNS TASK FORCE (ECTF) ACTION ITEMS (It:ms gra listed coqu nti;lly by Csmprshinilv3 Pirn Actirn it:m Number.

The listing order does not imply relative significance of items.)

I 10-4 Introduce the Managing For Nuclear Safety course (on a roteting basis).

i - EXEC-4

. 10-10 Directors, Managers and first line supervisors complete or demonstrate e

proficiency in the following courses

Seven Habits, Myers-Briggs, Labor EXEC-10 Relations, Principle Centered Leadership, Interpersonal Skills, [

i~

interviewing Skills, Handling Professional Dissent and Chilling Effect. t t j a

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