ML20149K705
| ML20149K705 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/21/1997 |
| From: | NORTHEAST NUCLEAR ENERGY CO. |
| To: | |
| Shared Package | |
| ML20149K246 | List: |
| References | |
| PROC-970721, NUDOCS 9707300091 | |
| Download: ML20149K705 (8) | |
Text
.
1 l
4 Northeast Utilities Plan for Addressing Employee Concerns Supplement 1 July 21,1997 9707300091 970722 DR ADOCK 05000245 p
Introduction The October 24,1996, Nuclear Regulatory Commission Order to Northeast Nuclear Energy Company (NNECO), among other things, required NNECO to develop and implement a comprehensive plan for reviewing and dispositioning safety issues raised by its employees and ensuring that employees who raise safety concerns are not subject to discrimination. The Order required that the comprehensive plan shall allow for revisions based upon the experience in implementation of the plan and comments and recoramendations of the independent third-party and/or the NRC. In accordance with that provision, this supplement to the " Northeast Utilities Plan for Addressing Employee Concerns"(Comprehensive Plan) is the result of recommendations made by Little Harbor Consultants, Inc. (LHC-Independent Third Party Oversight Program) and NNECO self evaluations. The LHC recommendations were presented during meetings between LHC, NRC and NNECO on May 13 and June 3,1997, and subsequently described in LHC letters to NNECO dated May 21 and June 5,1997, respectively.
Pumose The purpose of this supplement is to expand the focus of the Comprehensive Plan issued on January 31,1997 to include the breadth of programs and processes necessary to re-establish a safety-conscious work environment at Millstone Station. This expanded focus will allow the Comprehensive Plan to become a roadmap of the efforts undenvay at Millstone Station to re-establish a safety-conscious work environment.
Backuround The Comprehensive Plan issued on January 31,1997 did not address all actions planned to correct the root causes regarding leadership, communications, teamwork, and the corrective actions program. Additionally, it did not specify success criteria and measurement techniques to detemiine the effectiveness of meeting established success criteria. Further, it did not adequately address the requirement for formal, periodic self-assessments by each organizational element.
Definition of a Safetv-Conscious Work Environme_ut A safety-conscious work environment exists when employees feel free to raise concerns both to their management and to the NRC without fear of retaliation.
Attributes of a Safety-Conscious Work Environment Employees are encouraged to raise concerns.
Concerns are promptly reviewed.
Concerns are given the proper priority based on their potential safety significance.
Concems are appropriately resolved.
Timely feedback is provided to employees.
2
Management promotes employee confidence in raising and resolving concerns.
Well-developed systems or approaches exist for prioritizing problems and directing resources accordingly.
Effective communication occurs among various departments for openly sharing information and analyzing the root causes ofidentified problems.
)
Employees and managers have an open and questioning attitude, a focus on safety, and a positive orientation toward admitting and correcting personnel errors.
Initial and periodic training is given for both employees and supervisors on options for problem identification.
Incentive programs exist which reward ideas based on their contribution to safety.
Credible self assessments are conducted to detemline whether employees believe their concems have been adequately addressed and whether employees feel free to raise concems.
Prompt corrective action is taken when problems are identified through self-assessment.
Clear identification of processes that employees may use to raise concerns exist and employees are encouraged to use them.
No method of raising potential safety concems is discouraged.
Nomial day-to-day processes are effective.
Alternate means of raising and addressing concems are accessible, credible, and effective.
1 Roadman to Success The actions specified in the Comprehensive Plan, when completed, will result in the Employee Concerns Program (ECP) becoming an effective allemate means for employees to raise and have their concems addressed adequately. In addh, many of the tools and programs necessary for line managers to carry out their responsibil' ties to establish and maintain a safety-conscious work environment are either available ar under development as a result of Comprehensive Plan action requirements. Examples of the tools and programs include:
Issuance of clear expectations from senior management.
Revision and improvement of training on dealing with employees, and resoccting differences of opinion.
Revision of programs to reward and hold personnel accountable for success iri fostering a safety-conscious work environment.
Modification of the Nuclear Leadership Assessment to include employee concerns-related questions.
Revision of the performance appraisal process for supervisors to include a specific competency on employee interaction.
Improvement of ECP processes.
The following additional actions and requirements which were being executed outside the framework of the Comprehensive Plan are appended to enable the Comprehensive Plan to become a more complete roadmap to success.
3
Leadershin. Communications. and Teamwork The root cause of the current Millstone required shutdown is ineffective leadership which set and tolerated low standards. This ineffectiveness resulted in:
Low standards in the conduct of safe operations.
Regulatory non-compliance.
Lack of effective communications.
Lack of teamwork.
Loss of credibility of management with employees, regulators, and the public.
To address the root cause ofineffective leadership, new leadership has been provided.
However,just changing leadership will not in itself correct the organizational issues created by past ineffective leadership. The Chief Nuclear Officer has been assigned the responsibility to lead the new management team to correct organizational issues created by past ineffective leadership. He has been directed to take the following actions:
Establish organizational ownership and accountability.
Set clear standards and expectations.
Re-establish a safety-conscious work environment.
Carry out necessary actions to realize the seven Millstone Station success objectives.
Self-Assessment Prouram The ability to self-identify issues in a timely manner and to assess the effectiveness of previous corrective actions is an essential element of a safety-conscious work environment. Actions to improve Millstone Station's self-assessment program include, but are not limited to, the following:
Conduct periodic formal comprehensive assessments of each unit and major support organization. The assessments shall consist of an in-depth review ofimportant line and staff activities, and be conducted by teams of knowledgeable individuals.
Develop and implement a station-wide schedule for planned self-assessments.
Develop and implement a management work observation program to ensure adherence to fundamental work practices.
Develop and implement formal ties to the corrective action program.
Implement peer self-assessments of work related activities.
4
Corrective Actions Program An effective corrective actions program is an essential element of a safety-conscious work environment. Actions to improve the Millstone Station corrective action program include, but are not limited to, the following:
Clearly communicate management expectations for the corrective actions program from all levels of management to all levels of station personnel.
Assign a Director level persan the responsibility to establish consistency of vision and process for the corrective action 3 program.
Develop station-wide processes to trend and validate that corrective action performance expectations are being met.
Success Criteria and Measurement and Evaluation Techniaues Success criteria and measurement and evaluation techniques for each of the ten objectives delineated in Appendix I of the Comprehensive Plan are provided as Attachment I to this supplement. The following measurement and evaluation techniques are available to determine progress in meeting Comprehensive Plan objectives:
Self-assessments.
Nuclear Oversight Audits, Evaluations, and Assessments.
Commissioned assessments by independent external organizations.
Regulatory agency assessments.
FPI Culture Survey.
Safety-Conscious Work Environment Surveys.
Nuclear Leadership Assessments.
- Performance indicators.
Independent Third Party Oversight Program (ITPOP).
Employee Concerns Oversight Panel (ECOP).
Department of Labor responses.
Employee feedback.
The principal measurement and evaluation techniques for each objective are in bold type in Attachment 1. Periodic assessments using the specified measurement and evaluation techniques will be used to determine progress in meeting the success criteria.
Attachment 5
3
- of Supplement I to NNECO Comprehensive Plan for Reviewing and Dispositioning Safety Concerns EMPLOYEE CONCERNS COMPREllENSIVE PLAN OBJECTIVES Measurement And AND SUCCESS CRITERIA Evaluation Techniques Dblective I: Exercise effective leadership FPI Culture Surveys e
Safety Conscious Work e
Success Criteria:
Environment Surveys Vision aad direction are consistent with the fundamental needs of a well-e Nuclear Leadership performing nuclear organiz non Assessments Management responds without defensiveness to problems, issues and concerns e
Nuclear Performance Emphasis on resolving problems rather than justifying status quo Indicators 1
e Effective response to problems is consistently evident ITPOP Input Regulatory Agency Assessments ECOP Input e
Emph,yee Feedback Oblective II: Establish and maintain high standards FPI Culture Surveys e
Safety Conscious Work a
Success Criteria:
Environment Surveys Management and personnel standards consistently ensure conservative decision e
Nuclear Leadership e
making Assessments Deficient conditions are consistently found, accurately investigated, and corrected e
Nuclear Performance in a thorough and timely manner Indicators Prevailing attitude toward regulatory standards are consistently appropriate for e
ITPOP Input e
nuclear excellence Regulatory Agency e
Assessments ECOP Input Employee Feedback Ohlective III: Strengthen leadership, management, and interpersonal skills FPI Culture Surveys e
Safety Conscious Work e
Success Criteria:
Environment Surveys Communications and interpersonal skills of management foster trust, teamwork, e
Nuclear Leadership e
and good morale Assessments Management is effective in responding to employee concerns e
Nuclear Performance Resource allocation, action implementation, and prioritization support Indicators e
improvement efforts, including increased self-discovery and effective corrective ITPOP Input actions Regulatory Agency e
Organizational roles are clearly and appropriately defined Assessments ECOP Input e
Employee Feedback e
Oblective IV: Establish effective problem resolution and performance measures FPI Culture Surveys e
Safety Conscious Work e
Success Criteria:
Environment Surveys Decision-making process is efficient e
Nuclear Leadership Results ofindependent assessments of performance are used as the basis for Assessments e
appropriate improvement actions Nuclear Performance e
Top management are the visible champions of fundamental actions necessary to Indicators effect change ITPOP Input e
Accurate root cause analysis, timely and thorough corrective action, and consistent Regulatory Acency Page1
. of Supplement I to NNECO Comprehensive Plan for Reviewing and Dispositioning Safety Concerns 4
EMPLOYEE CONCERNS COMPREllENSIVE PLAN OBJECTIVES Measurement And AND SUCCESS CRITERIA Evaluation Techniques verification of corrective action effectiveness ensure problems are resolved Assessments There are meaningful performance measures in the organization, especiMiy for ECOP Input e
measuring employee trust and confidence, and training effectiveness Responses to independent e
assessments Employee Feedback e
Oblective V: Increase sensitivity to employee needs FPI Culture Surveys e
e Safety Conscious Work Success Criteria:
Environment Surveys Aggressive efforts are performed to locate and eliminate workplace " chilling Nuclear Leadership e
effects" Assessments Management consistently works to achieve workplace environments that are open Nuclear Performance and conducive to differing opinions and viewpoints Indicators There is a zero tolerance for harassment and intimidation, or " blacklisting" by any e
ITPOP Input individual in the organization Regulatory Agency e
Management demonstrates sensitivity to employee needs Assessments e
}
ECOP Input j
=
Employee Feedback e
Ohlective VI: Freely admit mistakes FPI Culture Surveys j
Safety Conscious Work e
Success Criteria:
Environment Surveys i
Management freely ad.mits mistakes and takes corrective action to prevent e
Nuclear Leadership e
recurrence Assessments Management uses Legal and IIR as resources to fairly and objectively to assist in e
Nuclear Performance e
problem resolution Indicators A questioning attitude is encouraged and appreciated e
ITPOP Input e
NRC and DOL findings are responded to in an objective manner e
Regulatory Agency e
Management is considerate of the findings of consultants that substantiate negative Assessments e
findings. These findings are appropriately used as the basis for corrective action ECOP Input e
Responses to NRC and DOL Employee Feedback e
Oblective VII: Develop supportive management styles and support for concerned FPI Culture Surveys e
employees Safety Conscious Work e
Environment Surveys Success Criteria:
Nuclear Leadership An arrogant management style in both administrative and technical functions is Assessments e
clearly unacceptable and is never rewarded
. Nuclear Performance Employees perceive that members of management are held accountable for their Indicators e
handhng of employee concerns and treatment ofindividuals who raise concerns ITPOP Input Technical conceit never influences decision making Regulatory Agency Conservative decision making is consistently practiced Assessments Visible support for concerned employees - including timely follow-up, positive e
ECOP Input incentives for raising safety concerns, encouragement or recognition of a Responses to DOL questioning attitude Employee Feedbacli e
Promotion process has a balanced emphasis oa technical and pc9ple skills e
DOL findings are responded to in an objective manner e
Page 2
Attachment i of Supplement I to NNECO Comprehensive Plan for Reviewing and Dispositioning Safety Concerns EMPLOYEE CONCERNS COMPREllENSIVE PLAN OBJECTIVES Measurement And AND SUCCESS CRITERIA Evaluation Techniques Obiective VIII: Develop effective communication and teamwork FPI Culture Surveys e
Safety Conscious Work e
Success Criteria:
Environment Surveys Effective conununications between and among corporate managers, site Nuclear Leadership e
management, and employees Assessments Effective communications of the basis of performance evaluations and reasons for e
Nuclear Performance e
disciplinary actions Indicators Effective communications of delays in resolving concerns to involved parties e
ITPOP Input The DPO process is effectively championed Regulatory Agency Process and meaning of confidentiality protection in ECP is communicated to Assessments e
work force ECOP Input e
Managers are aware of the magnitude of problems outside their organization a
Employee Feedback Management by memo is not practiced e
Appropriate application of the " teamwork" performance appraisal competency e
Obiective IX: Establish accountability FPI Culture Surveys e
Safety Conscious Work e
Success Criteria:
Environment Surveys There is an obvious presence of accountability and ownership at all levels of the e
Nuclear Leadership e
organization Assessments I
Managers consistently demonstrate a proactive attitude towards resolving e
Nuclear Perfom1ance employee concerns Indicators Critical actions and decision making in resolving concerns is never abrogated to e
ITPOP Input e
Legal, HR or ECP Regulatory Agency e
Perception by employees is that members of management are held accountable for Assessments l
e their handling of employee concerns and for their treatment ofindividuals who ECOP Input raise concerns Corrective action in Management consistently demonstrates willingness to use independent evaluations response to ECP findings e
to investigate concerns and willingness to aggressively pursue corrective actions Employee Feedback determined necessary by the independent evaluation findings There are effective position descriptions for all Nuclear positions e
Qblective X: Establish an effective ECP ECP Self-Assessment
=
Safety Conselous Work e
Success Criteria:
Environment Surveys The ECP has sufficient resources, independence, and authority to fully resolve e
Independent ECP e
issues Assessment A timely and effective corrective action process results in concems being resolved
. Nuclear Performance and closed in a timely manner Indicators There is obvicus management support for the program e
ITPOP Input Regulation Agency e
Assessments ECOP Input e
Employee Feedback e
Page 3