ML20196H061
| ML20196H061 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/03/1998 |
| From: | Beck J External (Affiliation Not Assigned) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ITPOP-98-0030, ITPOP-98-30, NUDOCS 9812080198 | |
| Download: ML20196H061 (51) | |
Text
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T Little Harbor Consultants,Inc.
Millstone-ITPOP Project Office P.O. Box 0630 Niantic, Connecticut 06357-0630 Telephone 860-447-1791, est 5966 Fax 860-444-5758 i
December 3,1998 Docket Nos. 50-245 50-336 50-423 ITPOP 98-0030 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Millstone Nuclear Power Station, Unit Nos.1,2, and 3
Dear Sir:
It was noted in the Little Harbor Consultant's (LHC) third quarter report on the Millstone safety conscious work environment that the LHC recommendations matrix would be provided at a later date. Enclosed please find the updated matrix.
Sincerely, k \\.
i s o % lata)
Jchm W. Beck
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Team Leader, ITPOP O
President, LHC I
Attachment cc: Distribution
[DR81208019e 981203P ADOCK 05000245 [g:-
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T U.S. Nuclear Regulatory Commission Page 2, ITPOP 98-0030 Distribution:
Ray Necci, NNECo Charles Brinkman, Manager Washington Nuclear Operations j
11arry L. Miller, NNECo ABB Combustion Engineering i
William J. Temple, NNEC 12300 Twinbrook Pkwy, Suite 330 Rockville, MD 20852
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" ^ "
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Mr. John Buckingham Cheryl Grise, NNECo Department of Public Utility Control Electric Unit Michael Quinn, ECOP 10 Liberty Square 4
New Britain, CT 06051 U.S. Nuclear Regulatory Commission Attn: W.D. Travers Citizens Regulatory Commission Mail Stop: 014D4 ATTN: Ms. Susan Perry Luxton Washington, DC 20555-0001 180 Great Neck Road Waterford, CT 06385 U.S. Nuclear Regulatory Commission Attn: W.M. Dean Citizens Awareness Network Mail Stop: 014D4 54 Old Tumpike Road Washington, DC 20555-0001 liaddam, CT 06438 U.S. Nuclear Regulatory Commission The lionorable Terry Concannon Attn: li.N. Pastis Nuclear Energy Advisory Council Mail Stop: 014D4 Legislative Office Building Washington, DC 20555-0001 11artford, CT 06106 Mr. Wayne D. Lanning Mr. Evan W. Woollacott US NRC Region I Co-Chair 475 Allendale Road Nuclear Energy Advisory Council King of Prussia, PA 19406-1415 128 Terry's Plain Road Simsbury, CT 06070 Kevin T. A. McCarthy, Director Monitoring and Radiation Division Ernest C. liadley, Esquire Department of Environmental Protection 1040 B Main Street 79 Elm Street P.O. Box 549 liartford, CT 06106-5127 West Wareham, MA 02576 Allan Johanson, Assistant Director Mr. Paul Choiniere Office of Policy and Management "The Day" Policy Development and Planning Division 47 Eugene O'Neill Drive 450 Capitol Avenue-MS 52ERN New London, CT 06320 P.O. Box 341441 liartford, CT 06134-1441 Bob DeFayette 100 King Street First Selectmen Gettysburg, PA 17325 Town of Waterford Ifall of Records Don Beckman 200 Boston Post Road 1071 State, Route 136 Waterford, CT 06385 Belle Vernon, PA 15012
4 M
i Attachement 6 To the LHC Third Quarter Report 1998 to the NF i
t LHC RECOMMENDATIONS AND RESPONSES 5 Date, Source and LHC NNECo Response LHC Evaluation LHC Effectiveness Determination.
i Recommendation S-13-97 Comprehensive Plan (CP)
- 1. Revise the CP to addreu the NNECe Istter 7/6/97 (B16529-1) The CP will be supplemented by July 22.1997, to provide a The response plus additional steps LitC evaluation is continuing regarding following:
" road map which describes the full treadth of activities in process to correct the safety-conscious NNECo has taken provide an acceptable
- .cA.~.__ effectivenest
[
t a.
Ensure all root catnes are work environment at Millstone Station.
response.
Actions taken are acceptabie-effectively addressed so that NNECe 12tter 7/22/97 (B1665I) Transmitted Supplemerit I to the CP and stated it met the LHC resultant action plans, cornhined recommendation. Attachment I provided cross reference to root causes.
with management's ducction, will correct each root cause.
- J-11-98 W-81-M CLO5ED l b-.
Place the focus on line NNECe letter 7/6/97 (B16529) No Commitment. We beheve that we have placed an appropriate Response is acceptable in that SCWE Emphasis is being placed en developmg line management's role and account emphasis on hne management's role in achievmg the desired [SCWE]. Mike Brothers' role as was created to supplement and assist the managements role in creating the desired SCWE.
abilities in achieving the desired executive sponsor of SCWE is descnbed. In addition, approximately 50% of the actic.i Items line organizations safety-conscious environment.
contained in the CP are related to improving line management's handling of employee concerns.
LHC evaluation is continuing.
Mr. Brothers has assigned additional resources to review and implement the areas of the CP that an the responsibility ofIme management.
NNECe Istter 7/22/97 (B16651) transmitted Supplement I to the CP and stated it met the LHC recommendation.
- 2-11-98
- 1-#I-N CLOSL. / MONITORING REQ'D Ic. Dnelop success enteria and NNECe Letter 7/6/97(BI6529-2) Success crneria and -------- - -z acchniques for each of the ten Response is somewhat vague; however.
KPI's and other.-..~;. are acceptable.
measurement techniques.
objectives dehneated in Appendix I of the CP will be developed by July 22,1997.
is acceptable based on NNECo's KPI's NN ECe latter 7/22/97 (Bl6651) transmined Supplement I to the CP and stated it met the LitC and additional..
4..; contained recommendation. Stated I2 techniques for evaluating and measurmg CP objectivet in the Restart Readiness Document.
H-81-98 N-88-98 CLOSED I
+
I
' legend for NNECo Column I
- Excerpts from NNECo responses are shown either as dirert quotations or as an abstract.
1 Legend for LHC Effectiveness Column
-
- Requires additional LHC evaluatiori.
- CLOSED Actions taken by NNECo era adequate No further LHC acten requwed.
- CLOSED / MONITORING REQUIRED-Accons taken by NNECo are adequata, however addihonal monstonng by LHC is wanante:t to assure antinued comptance 3 The numbenng in ttus document is sequentist for ease of tracking and does not directly conespond to recommendaten numbers in source documents s
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Date, Source and LHC NNECo Response LHC Evaluation LHC Effectiveness Detersnimation Recommendation id. Reqwre a entical review of NNECe Letter 7/6/97 (5165294) The corrective action prograrn efforts will be reflected in the Response is acceptab8e. Revisions 5 & 6 Based on review of the CAP, LHC feels acuans current corrective action
" road map' supplement to the CP by July 22.1997, to RP4 havelieen issued.
taken are effective.
programs.
NNECe Letter 7/22/97 (BI6651) transmitted Supplement I to the CP and stated it met the LitC recommendation Stated actions to improve MS's CAP.
- 1-f1-M es-15.M CLOSED le. Expand the requirement for NN ECe letter 7/6/97 (BI6529-4) The CP will be revesed to include trie self-assessment efforts by Response is adequate.
SA Prograre is adara*1y documented and formal. periodic self. assessments July 22.1997. An Executive Sponsor and issue Manager have been designated to pursue and
- y-by each organizanonal element.
ensure resolution of all aspects of the issue.
NN ECe Letter 7/22/97 (516651) transmitted Supplement I to the CP and stated it met the LifC recommendation Stated actions to improve MS's Self-Assessment Program.
- 1-JJ-M
- d.as.N CLOSED 6 3-97 Culture Servey
- 2. Defore conductmg the next survey NNECo Letter 7/6/97 (916651) On June 2L another FPI-NU Culture Survey was distributed.
Response is appropnare and adequase.
697 Survey objectives jlgt clearly dermed.
consider the following:
Pnor to the conduct of the survey, the survey objectives were clearly defined and communicated to 6/97 Culture Survey was adequately designed 2a. Objectives are clearly defined.
the workforce. The survey was designed to measure the cultural clunate. It measures abdity for self to assess and measure a nuclear safety climate.
emprovement, leadership, clear understandmg of mission goals, and quahty of processes. The All key areas of safety cuhure were addressed survey also measures the safety culture.
in the data collection.
MH B letter 2/5/98 (MHB-004) Since NNECo began admmistration of the cuhure survey in June 11/97 Survey questions were the same as the 1996, the pnmary objective of the culture survey has been a.a_.
..a tool to assess the status 6/97 Survey which were previously found to and change in the culture of the Millstone organization. As such it provides the nuclear leadership be adequately designed.
i team with a general assessment of the results of the improvement efforts bems undertaken at the 31/97 Culture Survey objectives were a
site. More specific aseessments of results are contained in the performance measures associated adequasely dermed in general statements whde with each of the mdividual critical issues, such as leadership and Safety Conscious Wort still fallmg short of clanfication of analysis Eavironment (SCWE) Within the Success Criteria for Restart, the adjusted culture indes figure and use apphcotions.
6/98 Survey questions were the same as the j
that is denved from the culture survey is used as a specific performance measure.
in additen, the department specific results of the culture survey are used as corroborating input to two previous surveys which were previously g
the assessment of problem areas. This can mclude supporting the asseruon that a work group is a found adequate.
6/98 Survey demographics were different and gwoblem area or supporting the removal of a work group from the problem area list.
Beyond these general objectives and as discussed in detail under Item 21 in this attachment, the of more valuable providag for better analysis culture survey resul s from the November 1997 administration will be forma!!y rolled out to the and less" guess work?"
t Mdistone organization and used as the basis for actions to be taken to address specific identified 6/98 Culture Survey objectives were weII I
areas of weakness (A time line for this rollout is contamed in the response to item 2i-l.)
defined and provided clarification of analysis NNECo Istter 5'84/98 (DBA-98-043) Estabhshed Administranve Guidelmes for the and use applications.
Admmistranon of the Culture Survey at Mdistone which addresses this.m...m.J4 ion.
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Date, Source and LHC NNECo Response LHC Evaluation LHC Effectiveness Determination Reconnmendation 2b. Survey objectives are NN ECe tsetee 7/687 (810451) Response included in "a", above.
Resporise is appropnate and 687 Survey obpectives33 well
=
7 commumcated MIIB Letter 2/5/98 (MHB-004) We agree that the June 1997 Survey objectives were not adequate.
- J --- ?
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1187 Survey administration process was very commumcated weit For the culture survey conducted in November 1997, two ecmmunicatens were tssued in advance of the Survey. A general bnefing sheet was issued to the Millstone well communicated.
1887 Survey objectives were stdl not well I
leadershrp team in earty November 1997,to assist in communicating to their organizations of the
=
f upcommg orgentational assessments (the Nuclear Leadersber Assessment and the culture survey).
__... _ ' --4 It was shared wA Millstone 7his brtefing sheet stated that tfac objective of the culture survey was" to determme the overall leadership in a briefmg, yet stopgel there and health of the culture within our organization. It does not aswss individuals, rather it evaluates our was not included in any other ce==mumcations overait culture and environment
- This imefing sheet further stated that,"Both the Leadership on the subject-A ssessment and the Cultural Survey (culture survey) are important indicators for us and the NRC, 6/98 Survey objectives were effectively
' and these assessments provide %portant trendmg informaten as we move toward restart
- These communicated to JLL is advance of the actual key messages were repeated is another briefing sheet issued on November 19,1997 to Millstone survey dese.
leaderslup On November 20,1997, a special eJiten of the To The Pomt (TTP) was issued at Mdtstone to inform the organiration that the culture survey would occur that day. In this TTP,it was stated that "The Nuclear Culturc Survey is an irnponant indicator for us and the NRC, and these assessments provide important trending information as we move toward restart" la addition to the special editen of TTP, on the day of the survey, posters were placed in the North Access Pomt. South Access Pmnt, Buddmg 475 lobby, and Nuctear Traming Building to inform personnel of the culture survey. These posters remamed in place for approximately four days. To provide a further means ofinforming sne personnel of the culture survey, several pr=p-up enessages were transmmed out over the site cor tputer network informing site personnet of the culture survey and t
requesteg participation.
I NNECe Letter 5/1438 (DBA-98 643) Established Administrative Guidelines for the Admmistraten of the Culture Survey at Mdistone which addresses this -.-..Jnion.
gy,yy,,g ps-JJ.98 CLOSED The 6/97 culture survey question tedesign was 2c. The scope and content of NNECo Letter 7/6/97 (BI6651) As a result of our review and validation of the survey Response is appropriate and current questions are reviewed scope and centent, new qtrestions were added to the survey tool on safety culture while adequare.
adequase and upon review validated the and vahdated.
other questions were modified. Further, additional questions tied to conservative decision 3"9ce88-making and senior management's support of a safety conscious work environment were included in the survey.
- 1-27-98 6/97 Survey was revised to include randomty 2d Questions randomly NN ECo Letter 7/6/97 (B16651) Response included in "c". above.
Response is appropiate and
=
distributed.
- adequate, distributed questions.
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Reconesnendation 1
Included in 697 survey.
2e. Add following constructs; NNECo Letter 7/6/97 (B16651) Response included in "c", above.
Response is appropnase and
" conservative decision adequate making *" senior management endorses a policy that supports the workers' right to raise safety issues =ithout fear of harassment, discrimination,or
- 141-98
- 141-M CLOSED intimidation".
All queshons convened to the existing 4 point 2f. Be consistent; use either a 4 N N ECo Letter 7/6/97 (B16651) Response inrluded in "c", above.
Response is appropnate and scale-point scale or convett to a 5 adequate.
et.21.ps
- 1-21-98 CLOSED point scale.
k All areas of cukure are now included.
2g. All areas of culture are NN ECe Letter 7/6/97 (B16651) Response included in "c", above.
Response is appropnnte and
/
included.
adequate.
01 21 00 0141-98 CIDSED l
Line management was advised of the 6/97 2h. Line managers are NNECo Letter 7/6/97 (B16651) Line managers were advised of the purpose of the Initial response (t17/06/97), as appropriately prepared and survey at a management meeting held on June 18,1997. the survey tool was distributed outlined, is Dgg appropriate and ggg Survey Isse.
involved.
by the Nuclear Officers. Collection points were located in the various departments sad at adequate Line management was advised of the 11/97
'"'Y"8'""'I"'""-
i Y
other remote locations throughout the site.
"""'8'"**"""""'d*"h**#
MHB Letter 2/5/98 (MHikUO4) As noted above, a briefing sheet was issued to line 2/5/98 Ruponse, as outlined,is management approximately 10 days prior to the conduct of November 20,1997 culture mirimally adequate and not fully 6/98 E e is more awwe and has survey. Dis communication advised them that the survey would be conducted during the appropeisse-been M advM Co enhnenns e 698 Survey schedAes we week of November 17,1997. A specific briefmg sheet was issued on November 19,1991 s
which provided the details of the administration of the culture survey, De optimum date the Imdenhip Assessment was appropriate.
3 De 698 survey has included line t
for second communication would have been earlier in the week of November 19,1997, but tased on the administration of the leadership assessment,this was no* possible. We management as alllevets in the process.
D. Amerine will hold all depenments intend to follow the recommendations of our survey consuhant (PPI) for the for anew tmming, a rdi-mn
[
administration of the next survey.
mn scheduk and Mvidual Based on the ce mmunications that preceded the November 1997 administratican of the
(
t culture survey, we believe that the line was more aware of the November 1997 survey.
g i,
The requests made ofline management were to pick up the survey material from a central
, location, distribute the blank surveys to their organizations, provide sufUcient time and a
[
comfortable envimnment for individuals to complete the survey, and return completed
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r surveys and extra survey material to a central location. Dere is no specific indication of a lack of commitment from line management during the November 20.1997 Cuhure 8843-98 CLO5ED
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Survev.
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Recoenmendation L
6/98 Survey resuhs are bemg conu sunicated j
Initial (7/fw97)responseis less 2i. Managementis committed to NN ECa Lettee 7!6/97 (816529-$) The results of the June 23,1997 culture survey =ill be translate and emplement the processed and reports will be developed by site, unit and departments. Each nuclear leader =t rp than adequese.
to significant numbers of employees.
i Acnon plans are being creased and initiated.
Responsedoes notinclude results into actens.
team omce* will assure artworriste actions are taken in a timely manner for any areas ides fied as Answer dans tabulased by an outside data
.--. a needmg ;...r..-.a.
i Sigmficant members ofline processes company was effective.
MMB letter 2/5/98 (MHB.004h Reference Ib. A 2L De d'
. of itronnation and
% ith regard to the roll out and uge of survey results, traming was provided to approximately 40 not trained in data indmduals in survey roll out and action planning De forst trasteng =as conducted in late Summer analysrs and/or action pIst instructions on Imth how to tend and interpret l
1997 and primanly focused on Millstone Umt 3 and Nuclear oveeight. Approximately 30 development.
the 6/98 survey tesults has been effectively 7 cope prescribed for action plan scheduled storms with all ananagers trainmg mdividuals muended. A second training course was held 6n October 1997 covering a more general populaten. Approximately 10 individuals received the second traming Item 26-1 below provides development is too narrow.
sessions from 7/16-7/29 up to and includmg High level broadcast of the results direct -
'= ion from D. Amerine the further information en issues regarding trainmg on use of survey resuhs and commemication of survey resuhs.
were adequese, yet not well week of 8/14/98.
2i-l Results were not commumcated to any significant number of onployees. We concur that scheduled.
No _.7M we the June 1997 results were not well commumcated to the workforce.
s with regard to the November 1997 culture survey, two editions of To The Point (December 23.
communications activity below this 1997 and December 30,1997) communicated the high levet results of the November 1997 culture level has occurred,noris survey. Specifically, the adjusted culture inden and the SCWE dnnension score were given for the scheduled.
station overall and each Vice President's%ecovery Omcer's organizaten (except flumen Resources) This is the only high level broadcast of the results that is planned. De Ime l
organizaten will take responsibihty for the communication of results to their respective organizations. Specifically, bmders of survey results are bems asscenbled by the SCWE team.
grouped by Vice PresidentRecovery Omcer. These binde'rs present the results at the Vice PresidentRecovery Officer, director, and manager levels. This information will be provided, written and verbal, to cach Vice President / Recovery Omcer or their assigned representatives. At 3
that time, instructions will be given on both how to read and interpret the survey results. To supper l
r this effort. a requen was made for each Vice President / Recovery Omcer to appoint at least one represen ative from their organization to functmn as the lead for the dissemination of the results throughout the Vice President' Recovery Omcer's organization. De SCWE team will assist the
{
represematives with the roll out of the survey data in their respective organization, and the plarming j
of actions in response to the survey. Training will be provided to the representatives and apprornate memNrs ofline management.
The following time line applies te Miis etTort:
Assemble and distnbute mformation to Vice PresidentRecovery Omcer organizations by February 13.1998 Memo DRA-98 019 changed thts date to February 27,1998.
Provide trainmg on surv*y analysis and action plarmmg to appropriate hne management and for designated representatrves by March 20.1998 Wnrk groups hoki roll out and discussion sessions, and formulate acten plans and have acten plans approved by April i
10,I998.
Work groups implement and assess acten plans by June 30.1998.
Next admmistraten of culture survey is scheduled to be conducted August 1998.
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- 26. Management is committed to lhe overall appeach to the work place discussions and action plans will be that used for a SCWE This time line is too spread out and Significant training has occurred subsequent transla+e and implement the udeo that was distnbuted in November 1997. Specifically, folicaing roll out of the survey resul s contmacs to demonstrese so the 6/93 Survey with 39 enanagers and t
results into actmas.
at the work group level, two or three stems will be selected by the work group to be translated into management's lack of-_
supervtsers amendog 9-10 sesnons (CONTINETD) wntren action plans The action plans include specific resronsibility of action and specific to this process.
representag all but 12 departnents at performance measurement objectives. The work group is responsible for implementation of the
.. Millsenne.
action plans, assessment of results and taking any necessary follow on corrective action.
2F2 No acten plans were created nor imtiated. We concur that action plans were not created on a site-wide basis for the past culture surveys as is now plarmed for the Novembe.1997 cohure t
survey. However. as indicated previously, the results of the June 1997 survey was used m ccmnection with the determmation of"probler. areaC As such, survey results were considered in a number of problem areas in preparing the action plans for problem area resolution.
2s-3 Answer data was tabulated by an outside data processmg company.
The response mechanism for the culture survey is an optical scanning form. These forms are scanned at Millstone by NNECo personnel and the raw data is electronically transmitted to a vendor. Performance Prograrns Inc. (PPI). PPI processes the data and produces detailed reports t
presentmg the survey results in a form that caa be utilized by hWECo. NhTCo and PPI collaborete to determme the report structure and design. PPI has extensive expenence in employee culture surveye on a national wide basis. NNECo considers PPI to be a useful resource to provide i
consultmg and analysis support.
I 2i-4 Line msnsgement net tramed in data analysis anNor actica plan development.
Please refer to discussma imder item 2LI.
2n-5 Sccpe prescribed for Action Plan development is too narrow..
The acten plans discussed under item 2i-1 are intended tc function at a very local level to assist in positive changes in a specific organi.auen. They are also intended to address topics which the
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wort group has direct control over changing. such as communications, teamwork, trust and are not intended to address programmatic issues. These programmatic issues have been addressed via the issue manager concept and are bemg incorpurated in the Long Term improvement Plan.
2i-6 Response does not include measurements.
[
As dtscussed under item 2i-8, effectiveness..-..-.ns will be required for the work group acten ph Overall, the effectiveness measurement mechanism will be included in subsequent admimstratmns of the Culture Survey.
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D.lL Amerine 4-1-98 Letter DBA-98-0029 We concur that the June 1997 survey results wen not well communicated to the workforce.
2 With regard to the November 1997 culture survey.two editions of To The Pome (December 23, i
1997 and December 30,1997) communicated the high levet resuhs of the November 1997 culture survey. The adjusted culture index and the SCWE dimension score were given for the station i
overall and each Vice President's' Recovery Omcer's organization (except Human Resources).
't This is the only high level broadcast of the resuhs that is planned.
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Recentmendation 2i. Management is committed to The ime organizatmn has the responsibihty for -
' i-results to their respective t
I translate and implement the organizations. To support this, bmders of survey resuhs were assembled by the SCWE team, f
resuhs into ations grouped by VP/ Recovery Omcer, and for those duectors (Special Projects Nuclear (EUNTIN!!ED)
Communication Services, and the Nucicar Controller) who report directly. Bruce Kenyon. These bmders present t'ne resuhs at the VP/ Recovery Omcer, director, and manager levels. This e
information was provided to each VP/ Recovery OlBcer, acted directors, or their assigned i
representatives. At that tirne, guidance was provided on read ng and interpreting the survey results The SCWE team will, as requested, assist each organization with the roll out of the survey data in
)
their respective organization, and the planning of any actions in response to the survey.
l With regard to the use of the resut*s of the Nov.1997 cuhure survey, an organization-specife
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approach will be tiken. His decision was made by the Executive Training Council when the proposal of a site-wide action pohey was presented on Feb. 23,1998. This decision applied only er the rewits of the Now,1997 survey and a proposal will be made at an April 1998 Council meeting regardmg use of resub from the next cuhurt survey, which is scheduled for June 1998.
fi Since the decismo of the Executive Trairms Council group not to implement of a site-wide approach, the SCWE group has been workirg with each VP/ Recovery Omcer's organization to etermme the argvosch that will be taken. With regard to the three units, each unit's correction action /self-assessment organization has taken the lead with regard to the rese's of the culture
[
survey. For the units. the resuhs are being treated in a similar fashion to any self-assessment results That is, a Condition Report (CR) was initiated for each unit. Each CR prova$ed a summary of potential areas for
.v
..L Each emit has the responsibdaty fnr the specife action taken in response to the survey resalts from the Nov.1997 survey.
hr Nuclear Oversight, the results of the Nov.1997 enttise survey were provided to and discussed with representatives of Ndsson Associates. This is in addition to the resuhs given to the nepresentative of the then VP-Nuclear Oversight. The intention is that the survey reeks will be factored into the ongoing interventen activities underway in Nuclear Oversight.
Efforts are underway within other organizations to reHout the results and discuss them at the appropriate level. No other specific planning activities are planned for the resuhs of the Nov.1997 culture survey.
To assist management in the communication and discussion of the survey resuhs, two traming sessions are planned for Aprd 3,1998. Emh session will be four hours long and consists of approsimately two arid a half hours of mstruction conceming survey inte pretsiion, communicatieri of results, and holding effective workplace discussions. The remainirv, time in the sessiort will provide an opportunity for mdividual survey review and interaction with the instructor. The i
trainmg will be offered to...,...;inda iduals on a voluntary basis. However, the VP Nuclear Work Services (NWS) has mandated that all managers and directors in NWS will attend this l
trammg.
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r, Date, Source and LIIC NNECo Response LHC Evaluation LHC Effectiveness Deterrninstion Recommendation 2i. Management is committed to As previously mentioned, a proposal for the actum te be taken for the June 19o8 culture survey transta:e and emplement the will be presented to the Executive Traming Council fcr approval by Arnt 30.1998. Overall, the results mio actens.
mientum is to have the strategy approved and any necessary training of management personnel (CONTINITD) complete pner to the administraion of the survey in June 1998 2i-2 We concur that action plans were not created on a site-wide basis for the past culture surveys and, as discussed above, will not be required for the November 1997 culture survey-llomever, the results of the June 1997 survey was used in connection with the determination of "pn+1cm areas
- As such, survey results were considered in a number of problem areas in prepanng the action plans for problem area resolution. The planning for the results of the June 1998 were discussed imder Item 2i-l.
2i-3 The response mechanism for the cuhure survey is an optical scanning form. These forms are scanned at Millstone by NNECo personnel and the raw data is electronically transmitted to a vendor. Performance Programs Inc (PPI) PPI processes the data and produces detaled reports presentmg the survey results in a form that can be utilind by NNECo. NNEco and PPI collaborate to determine the report structure and design. PPI hss extensive expenence in employee culture surveys on a national basis. NNECo consiocrs PPI to be a useful resource to provide const:lting and analysis support.
2i-4 Please refer to discussion under item 2Lt.
2e-5 The actions discussed under item 2i-l are intended to function at a very W level to assist m positive changes in a specific organization. They are also intended to addre9%4s which the work group has direct control over such as communications, teamwork, trust, c s -se not intended to address prograrrmatic issues. Programmauc issues are being addressed vis
- m teanager concept and are tmng incorporated in the 1998-2000 Performance Plan 26-6 Please refre to drscussion under item 26-1. The proposal to be made to L. t xecutive Trammg Council en April 1998 will include the use of the efYectroeness..~ ~...~a NNECe Letter 5/l4/98 (DBA-98443) Established Admmistrate'e Guidelines for the Admmistration of the Culture Survey at M !Istone which addresses this recommendation.
8A25-98 88-1198 CLOSED 6 A97 Criture servey 6-5-97 Lettee (1TPOP 97 noe9)
Presided Clarification Sarvey administration and centrols have Reference toleadership
- 3. Survey must be properly admmistered NNECo Letter 714*97 (B16617 ATT.8) Nuclear Leadership Assessment was administered by llR
=
to detrver meanmgful results.
week of June 16. IIR reps distributed and collected forms and utre present to answer questions.
Assessment is not appropriate continued to improve and are adequate.
Employ ee access to identification cadmg was restricted.
because it is !!ala survey.
Survey admimstration is For the Nuclear Culture Survey on June 23. disenbution was by Analysis & Programs to Nuclear Officers in turn to their department heads for distnbution on down in the organization. instructions appropriate and adequate.
were given to not enter names or employee ids. return completed surveys either to its source or
- 1-21-98 88-fA98 CLOSED locked drop boxes i
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Reconen.endation i
' &97 Survey was completed and results were As with 8), above, the Leadership
- 4. Must be commmed so acs on the NNECs Letter 7/24/97 (B16617 ATT. I) Begmning in 1997 the results of the I eadership survey results.
Assessment are tied to the performance management process. Also in 1997, results are tied to the Assessment tools are not survey talmined with approprinse printouts of scores rewards system through the Nuclear Performance incentive Program. It is our view that integrating tools,rather one clernent of an destributed.
&98 instructions wete communicated to ime assessments with the performance management and rewards processes demonstrates our individual L, _a process for commitment to act en the results. With respect to the FPI-NU Culture Survey, the resuhs of the -
10% of all
. -- r management (at Eg levels)in how to analyze Response with respect to the this due and develop action plans thru the survey will be processed and reports will be developed by site, unit, and departments. Each nuclear leadershy : cam officer will ensure appropriate actions are takea in a timely manner for any areas Cniture Survey is adequate and training sessions.
As of 513-98, s'appropnete actions
- were identified as needing improvernent.
appropriate.
2/3/98 Respense, incomplete and taken as a vesuk of identified :..y.~....:.
MHB Letter 1/5/95 (Mit5404)The results of the June 1997 cahure survey were used to identify ansor corroborate the existence of problem areas in organizations. The results of the November inadequese at best areas.
No see wide..
demonstrating any I
1997 culture survey will be used, in part, to assess progress in the resolution of problem areas based on any observed change in results between the two surveys.
positive resuhs to date.
l NMECe Letter 5/14/98 (DB&98443) Established Administrative Guidelines for the LitC will continue to evaluane the implementation Admminration of the Culture Survey at Millstone which addresses this -.- 1;iort phases of the 4W98 survey action plans-03 25-90 00-13-96 i
6-3-97 Programmatic Review of ECP 6-f.97 Letter (ITPOP 974899)
Provided Claririention S. NNECo should review and revise the NNECe 1stter 7/24/97 (B16617-1) Estabbsh common standards and criteria for pecessing "Jomt Investigation Guidelines
- have tilC has verified implementatiert i
ECP Manualto address the following concems by all organizations handling employee concems by September 5,1997.
been developed and issued.
MHB Letter 2/5/98 (MHB404) All parties processing Millstone employee concems are Acceptable.
See frems M and 33.
t 5s. Ibelop common standards and commmed to implememation of the Jomt Investigation Guidelmes (J1G). In the January 21.1998, r
criteria for processing concems NNECe latter (516954) respondmg to recormnendations in the November 131997. Little by all the organizations handimg Harbor Consuhants presentatiert a _ _
^ (Bl69584) =as made to conduct an assessment in
[
employee concems.
January 31,1998 to ensure the guidelines are being implememed. That assessment was completed a
on January 30,1995, and confirmed that the organizations subject to the IIG were irnplementmg I
the J10 for investigations that fall under the J10, althungh some organizations had not yet received any concerns that were subiect to the JIG.
- 1-21-M
- d-es-98 CtX)SEp l
5b. Develop clear meerfaces, NNECe Letter 7/24/97 (B166I7) The standards and criteria desenbed above will provide clear "Jomt Investigation Guidelines
- have Guidehnes are adequate if properly implemented
}
t evpectatiores Neween these interfaces and expectations between all organizations that handle employee concems.
been developed and bsued.
LHC wift review LA.._ a.;.
MH B tetter 2899 (MHB404) See response to Sa.
Acceptable.
[
orgaruzatmns.
- 1-21-98 83-28-98 CLOSED i;
I h
I
{
Paere 9 of 49 nevised i1-23-9s
[
i i
I
I Date,Sotirce and LHC NNECo Response LHC Evaluaties LHC Effectiveness Deterusisaties Recolnniendation Sc. Implement a management NNECe Lettre 7/24/97 (BIMl7-3) Implement a formal prim.ess for ------.
-overview of the ECP is reviewing the Monthly Report Acceptable.
overview of the concern process.
concern process by Sept. 5,1997.
(MP)with ihe Nuclear OfHcer on a monthly basiss This process started 9/30/97. ECP P _ -- is reviewing files prior to putting them in the resolved or closed category. Formal Closure
[
Panels are bemg conducted as needed.
i Acceptwie.
01-21-N Cl41-N CLOSED Sd provide comprehensive vnanthly NNECe letter 7/24.97(BIMI7-2) Espand the monthly report to include all active Mitistene-Acceptable.
Acceptable ECP Monthly Repoa now provide reports to management addressing related employee concerns being handled by all organizations handhng employee concerns by adequese measurements. Analyses section could be concerns handled by all September 5.199?.
improve 1 but is acceptable, Also see itern 833 on l
organisatens.
this list.
01-21-N 01 21-90 CLQ$ED
- 6. Ensure the elements tvi renced in NNECe Istter 7/24/97 (BIMl7-4) A requnement will be documented for conducting an annual Adeque'e. Is being tracked by ECP Meets requwement.
conclusmn 4 are addressed:
estemal assessment of the ECP by August 1,1997.
usmg AfTTS, i
Letter 7131.97 (ECF-97-029) Established requirements and sisted that the initial assessment will 6a. Manual does not contain be completed by 7/1/9g.
requirement for conductmg an I
armuel estes at assenment of the I CP as commuted te % the CP laction item 10 ;3 )
- 1-21-M 83-19-N 1105ED bb Requwes all NU employees to NNECo letter 7/24/97 (BIMI7-$) Confirm that the site esit process is supportmg these options Unscceptable. NUP 20 only requires an LHC wi!I verify.
participate in an esit interview; (i c., either panicipatmg in an esit intuview with tne ECP or be given a letter requestmg any exit to be scheduled.
homever, site esit process does concems that they may have) by September 12,1997.
See drew 38.
not assure they will be directed to MilB Letter 2/5/99 (MHIMI64) On December 31,1997, NUP 20 " Termination of Employees' the ECP.
was revised to mclude a Safety-Conscious Work Environment Acknowledgment which a Process is acceptable however, it is not termmatmg NU employee is requested to sign The acknowledgment includes the following items-constseently ;...r:.._..
J.
I teve been afforded the opportunity to have an exit interview with the ECP. '
l I do notSase any knowledge of any undevnented deficiencies or concems at Millsrone Item 86 opened due to continued problem with Stat on.
implernentation.
I have been provided with a phene number and address to provide any additional information I recollect after leaving Mdistone Station.
The ECP is institurms tracking measures to ensure consistent implementation of NUP 20. These measures melude routmely obtaining montMy repris of terminarmg NU employees, determining if supervisors scheduled interviews with the ECP, determining if ECP interviews were conducted, and assurmg an informaten package was provided to employees if ECP interviews were not conducted These tracking measures will be fully in place by February 27,199g.
- 1-21-M 87-#1-M CIA) SED Page 10 of 49 Itevised 11-2348 4-4
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-n v.
~
Date, Source stJ NNECo Response LHC Evaluation LHC Effectiveness Detertaination itecommentistr 6c. Manual does ma address MCe letter 7/4%7(B16617-6) Apphcation of the ECP to contractors ar off-site locations will Unaccertabic. De terms and conditions LitC has reviewed unplementation.
coserage for contractors at of' s dermed by September 12.1997.
apply the requirements but contractor site locatens.
lpter 9/11/97 (ECP-97-059) Application of off-site contractor is covered in general terms and implantation has not been reviewed by See iten J7.
etmhom NNECo. No NNECo plan exists to Mit s letter 25/98 OfifB-004) See testanse to 6a. Efforts are in pregress to ensure compliance verify implementation.
Based on letters se:it to contract organintens and with item 17 of the general Terms and Conditions, entitled "Comractor Empiovee Protection?
2/5/98 Response is acceptable assuming plans to do annual follow-up letters, thi. item is Requests for info;mation regarding program status were sent to over 100 contractor organintions the plan to confirm implementation is considered closed.
on October 15,1997. Each contractor was requested to prende information on their 10CFR $0 7 satisfactory.
comphance pmgram Contractors were also informed of the formatma of the Millstone Executive NNECo intends to modify their response contamed Reuew Board which would be reviewmg all discipline at or ateve the level of written reprimand in MHB letter 2/5/98 (MHB-004).
prior to implementation to ensura, among other things, no discipline was in retaliation for engagmg in protected activity. Tse ensure contractors contmue to place proper emphasis in this area. NNECo mill transmit a letter to its contractor organintions on an annual basis. De letter will remind them of their responsibehties for employee protection against retaharion and for advising their employee, and subcontractors that the NNECo ECP is available to them as an attemate resolution path for raesmg safety concems in matters involving Millstone Station The first annualletter was sent to contractor organintions on January 14,1998 As a further effort to confirm contractor implementation of item 17 of the General Terms and Conditions, the ECP and Contract organintens are jeimly developing a plan to confirm implementation ofitem 17 of the General Terms and Conditions. That plan will be developed and execution ofit commenced by February 27.1998 NNI Ce letter 2/27/98 (DDA 98-021) Changed the completion date to 4/9/98. The propowd schedule change for the commitment in item 6c 1 is necessary because we need more trme to ensure proper implementation ofitem 17 of General Terms and Conditens. De proposed schedule change does not impact Unit 3 restart program-02-27 98 04-0s-98 CLOSED 6d Ilandling of NRr'--ferred NNECo letter 7/6/97 (B16529-2) flandhng of NRC referred milegatens is now covered in Acceptable.
process is well defined and is being implemented allegaemns is not w ered.
procedure DC 18 (Secten 1.2.93. Change I, which was effective on June 30,1997.
as evidenced by Licensing sendmg allegations to w
01-21-98 ECP.
01-21-98 CLOSED 6e. Does ans address personnel NN FCo latter 7/24/97 (B16617.7) Quahfication and trammg of ECP personnel involved in Response is adequate ne document " Qualification of ECP Intake &
quabfication and inmmg_
handimg emplope concerns will oc described in administrative controls by August 22,1997.
Investigation Persortnel," Rev I dated 9/l3/97 provides an adequare set of quahfication and trainmg requirements, See lien 5d 01-21-98
\\ 03-2698 CLOSED page it of 49 Revned Il-23At i
.m
.1 1
i L
1 Date, Steurce and LHC NNECo Response LHC Evalentlem LHC Efteetiveness Deteratesteen l
Recometendation
- 7. Implement corrective actn)n for ECP NNECo tseter 7/24M7 (BIMI7) Actions have either been taken or are underway to address each Manual was revised and this resulted in Weaknesses selfidenenfied need to be currected.
self-assessment identified items-of the ECP self-assessment items identined as requirmg improvement, including the specific items process improvements. ECP Self-7a. The concems resolutica process highligtsed by Litt Assessment 97-EC-4 identified 3 Corrective actions are under way by ECP and is flawed in several key respects:
NNECe Letter 7/24M7(516617-8) Issue Revision 2 of the ECP Manual by August R,1997, to I) weaknesses and LHC concurs. -
appear to be approprisse and on ecludule.
- the process does not address reflect espenences gained with implementmg the manual,2) reflect changes in responsitnheies and i
how investigative fmdmgs 3)desenbe interfaces with the ECOP.
are transisted imo corrective NNECe Letter 7/24M7 (Bl6617-9) Enhance the ECP conective action process by August 29,
(
actions.
1997.
- there is no formal prosess MHB latter 2$98 (MHB-404) The ECP self-assessment process is an ongems program.
i for corrective action -
Evidence ofits effectiveness is the number ofitems identified as needmg. 7.-..a and f
irack.ng-cormtive actions taken or scheduled. Corrective actions idenufied have been captwed in the
(
- there is no process for AITTS for tracking to completim t
evaluatmg the effectiveness t
of corrective actrtms
- 1-21-M
- 7-#1-M CLOSED 7b 1he ECP files are deficient in NNECe Letter 7/24M7 (916687-19) Review the pre-Decemher 1996 files and resolve ECP complesed review of the files Based on a LHC review of a sample (23) of the several areas.
6cumentation deficiencies by October 31,1996.
identified on 8/11/97. Conective actions files and ECP Self-Assessment 97-EC-3. The NN ECe letter ll/3M7 (B 16042) Letter changes commitment to reflect expenence gained in for identified deficienoes was completed Corrective Actions taken appear to be adequale.
review of post-December 1996 files. Commitment revised to: NNECocommits to review the pre-11/2457.
LHC will coatmue to enomear this area by December 1996 Mdistone Station concern files as follows:
reviewing selected files.
Review each file closed prior to December 1,1996, and categorize as follows:
A. Alleged [IllRDI or Chilhng Effect.
March 1998 LHC Review of 27 files shows B. Alleged issue that could affect the safe operation or shutdown of a unit or endanger the improvement; hometer, some files stiti have minor health and welfare of the publec.
problems.
C Other(No further action will be taken for thesek NNECo Letter 11/1457 (Bt6098) changed date to 12/1/97.
See asens 12,15,26. 28 & 51.
01-21-96 07-01-N CtDSED Space and ew pment has been provided..
Space, layout, privacy and equipment are
{
7c. The LCP working environment is Physical changes to the offices have been comghted to provide acceptable working spaces and s
madequare.
pnvate discussen areas. Adequacy is being impacted by temporary ECP personnel; no additional minimally adequese.
t physical changes are anticipated.
81-21-98
- 1-21-98 CLOSED j
7d. The ECP has an insdequare NN ECe Letter 7t2437 'B16617-11) Cornplete the ECP database !..
. ;by August 29 Many :..._..~.; and additions have See #17 on this list
.f datshase management system and 1997 been made to the database-lacks sufncient trport preparation software and hardware.
01-21-90 02-23-96 CLOSED I
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7e. The ECP statt tweds tromms in A rs p a.W...;te the Di== cts.=It avmn erminme and areanirarianal development.
Response is adequale.
Tramine resumenw=ms have been idenufied and several areas to upgrade their ECP staff traimng has begun to support transition from contractor based to NU based ECP needed courses are being provided.
skills.
ergamraten. The goal is to make this transition by early 1998.
As yet, there are insufrecient numbers of NU personnel with appropriate traming to support transnioni from contractors in early 1998.
This is accepaable, provided quahfied ineviduals, t
either contractor or NiI are available to meet ECP needs.
I
- 1-21-98
- 7-#1-98 CLOSED
[
7-22-97 ECF Iaiplesmestation
- 8. f CP should complete its qualification NNECo Letter 9/24/97(51%85) An admin control document was issued Aug 15 describing the Response is adequate. The requirements Traming is being given and is adequate.
and Trammg Process, with special quahfication and traming of intake and investigative personnel. Seven mandatory courses have contamed in the ECP qualifications Qualification and Training records are not emphasis on. Intake includmg Report been completed by NU investigative and several contract individuals.
document may very slightly from what is complete or filled out in accorwance with the stated stuhty and Operabihty determination (Bl%8%I) NNECo commits to conduct the remaining three mandatory Employee Concems stated here, but are adeqteLe.
requaements.
criteria. Investigarma Traming, and prograrn courses to be cornpleted by ECP invemigative persormel by Sepoember 30.1997.
Training secords have been corrected.
Report Wrnmg.
(Bl%85-2) NNECo cominns to familiarire LCP inveshgators =ith the ECP sele in assessm Adequate tramics in reportability and operabihty potential Report ability and operabdity issues by October 31,1997. Also, by October 31,1997, the was provided on 10/29/97.
ECP ILlanual will be revised to reflect the current ECP practice of assurms operability and Report
& ECP blanual is still unclear on the mechanics abihty reviews are conducted by the line organizations for technical issues.
of transfernns operabihry and reportabihty assues D.B. Anierine 4/2/98 letter DBA 9g-030 NNECo acknowledges that the commitment BIM85-1, to the line organiastion and recordeng the actions
[
reference (ak was not completed as originally stated. The commitment as stased above did not taken.
[
accurately reflect our intent at the ame. The intended NNECo response to LJiC Recommendation i simuld have been. "A!I required ECP investigative personnel will have completed the required Will be tracked order nem 54.
trainmg or equivalent by Sept. 30,1997
- 1he remaming three mandatory ECP courses applied to only one individual. This individual had previousty completed similar courses. These courses were reviewed by ECP managenent and determined to be equivalent to those required by the ECP Quahricaten Program. This review and evaluation was documented in the individuars ECP trainmg file. Based on the above, ECP management made the decision not to conduct the three rematmpg classes because the individual hsd aheady completed equivalent traming However, j
ECP management did venfy that all required or eqmvalent traming was completed by Sen 30 1997. Thus while the -.
J.-.u..; was not completed as specifically stated, the intent and sprre of the ongmal comn.nment were met, with a!! required ECP investiganve personnel hwing completed
- 1-21-98 the required c cquivalent training by Sept. 30.1997.
- d-86 98 CLOSED I
- 9. The mentorms proFram hetween NNECa 1stter 9/24/97 (91%85) The mentormg program between contract and NU employees ha<
LifC lias not received 5/15/97 document The mentoring prograrn is not of great current crmtract and NU employees should be been formahzed in the administranve centrol [of August 15).
to evalume.
consequence smce there are few NU personnel j
formahred and implemented Document is adequate involved in ECP implementaten.
Based on hmited implementahor., the process l
appears to be eftective.
t 03-20 96 07-01-98 GQg_Q l
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t Date, Source and LHC NNECo Response LHC Evaluation LHC Effectwesens Detennisaties Recommendation
- 10. Program prmntees should be NNECo Lettee 9/2497(BIM85) On August 8.1997, the DECP issued a revised document Response is adequate.
Based na LHC observations of ECP acervities, esiablished through clear vison, containmg the ECP Vision, the ECP Missen, and I CP Near Term Goals for 1997.
pnenties are now being adap% established and i
detectson and agreement within the i
depament.
01-21-N 91-21-N CLOSE.D
- 18. increase presence and panicipaten of NN ECe letter 9/24M7 (516685) ne presence and partierpation by both the Director. Employee Response is adequate.
Director's presence has increased as vermed by: 1)
~
Vice President of Oversight and Concems Program and the Vice President of Nuclear Overs ght (VPNO) have been increased since UIC observations; 2) Level of Director signature Prograrn Director.
the July 22.1997 meetmg.
on ECP docinnents; and 3) Innerviews of ECP people. VP's presence has also improved.
01-21-N 91-21-N CLO5ED
- 12. f inalire department organizaten and NNECe Letter 9/2497 (Bl6685) The ECP organization has been finalized and a chart was Response is adequate.
Organizational chart has been issued and the pogram documents ar 4 fully distnbuted to the I CP stafL. Regarding the ECP prograra documents, Revision 2 of the ECP organization has been semble since early September implement.
Manual was issued on August 8.1997 The ECP will issue supplemental administrative controls, as appropriate, to address other program enhancements.
81-21-98 87-#1-N CLOSED
- 13. Impose disciptme to comphance with NNECe Letter 9/2497 (BIM8%.when Revision 2 was issued, the Director emphatically stated Response is adequere.
LHC Review of 24 ECP files durtng Sept and 0%t program documents.
that the document was to be followed and the ECP staff affirmed to the Director that they of 1997 showed a vast improsement. Files are now undersrood and would adhere to the ECP Manual. The OfDce Coordinator will assure file reviews meetmg ECP Manual requirements.
are conducted to provide increased assurance that the documentaten provisions of the Manual are LHC will contame so inanitor this area through satrsfied.
seleceed file review.
LHC Review of 27 files in March 1998 shows continued adherence no muual.y....a, with only minor discrepancies nosed.
See careen 7b,13,26s 2K 31. 4 32.
87-21-98
- 7-ep.a8 CLOSED 4
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Date, Source and LHC -
NNECo Response.
LHC Evaluaties LHC Effectiveness Detersminaties.
i Recoinsmendation
- 14. Use of and reliance on other NNECe latere 9/24,97(B16605) We believe that the ECP staffis presently implementing the Response is adequese.
Current ECP Staff is handhng HR investigations in 1
organirauens and lluman Resce es provisions of the ECP Manual for determining the adequacy of external reports in addressing an apprepnase unanner.
mvegigahens and resolueens should concerns..an investigator from the Human Resources organization and an investigator from the l
be implemented in accordance with Internal Audit Department have been matrimed to the ECP. They have primary responsibihty for Approach is adequent far the short term.
t ECP Rev 1. Sec. E.$, which requires conducting those investigatans forme >ly assigned by the ECP Department to the Human Resources outside work to be evaluated for organization.
1.HC will continue to review this area to assure adequacy NNECa letter II/7/97 (BI6793) provides additionel inputs and ~..:..~.a (BI6753-l)
NNECo commits to reassess the protocol between the ECP and HR regarding the handling of employee concems referred to llR by July I,1998. (B16703-2) NNECo coaunits to reassess the practice of conductmg periodic joint staff meetings between ECP and site HR by July I,1998.
(BI6783-3) NNECo commits to reassess the practice of ECP periodically sendmg a repmsentative to the regular sne IIR site meetings for the purpose of better understanding the issues related to
(
IBI6753-4) NNEco commits to evaluate the performance of the Executive Review Board in.
- [
human resources that may end up as employee concems by July 1,1998.
ensunng that personnel, both NNECo and contractors, receive due process and that disciplinary l
decesions are consistent and not retaliatory by July 1,1998. Attachment I to 916783 provides '
f additional details includmg: the assignment of Bob Long as the HR Recovery Ofncer and j
information of the Executive Review Board.
NNECo tatter 4/2790 (DBA-98-038) Subsequent to the restart of Units 2 and 3, we wilt re-examine the organizational structure and adjust the organization as apprornate. One of the potential organizational changes include the reduction in the scope of the ECP to permit that i
organiraten to focus primanly on nuclear safety-related issues. The scope of the ECP will be reduced to focus pnmarily on nuclear safety significant issues, consistent with typical programs at i
other nuclear facilities. ECP would still investignie concems brought to them that may involve HR
('
ancillary issuest We expect that most non-10 CFR $0.7 SCWE functions uitwnstely will transition to the llR organization, and over time, the demands on llR would be reduced because ofincreased ime management effectiveness. In order to accomplish this successfully, wt are considenng transferring qualified ECP investigators to llR to conduct the IIR investigations.
85-N-98 87-8f-98 CID$ED
- 15. Files should not be classafied as NNECo Letter 9/24/97 (B166145) Concems resolved
- or " closed" after June 6,1997, are required Response is appropnase and adequase Review of new files revealed resolution and i
" resolved' or" closed' without by the ECP manual to have appropriate documentation in the file to support the status.. pre-June closure is now being in accordance with the 6
meetmg the defimten m the ECP 6.1997 files will not be back fitted to include documentation.
81-21-98 Manuel
.)
manual.
March 1998 file review verireed manual adherence 1
See arems 7b.13,26 28,31, & 32.
I 83-18-98 CLOSED l
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Date, Source and LIIC NNECo Response LHC Evaluation LIIC Effectiveness Determination Recommendation
- 16. I mployees should be kept better NN ECo letter 9/24M7 (BIM85) ne ECP staffis making a concerted effort _ to provide status Response is adequate. Additional ste,;s Reviews made in January show i.y a..a in informed on the status of their case in reports to concernees at a mmimum of every 30 days until resolution Those camarts wdl be desenbed in MHB404 reinforces the this area LHC will contme to tr.anitor.
accordance with the manual doc'mented in the file. Periodic self assessments will confirm our efforts in this aret enginal response.
MilB tsttee 2/$/98 (MilB-004) The ECP Director, managers and leads connnue to stress the March 1998 File Reviews and employee.:entacts necesuty of adhents to all provisions of the Manual,includmg those related to penodic contact indicates major L.mm... in this area with the Concerned Individusis (Cisk in December 1997, the ECP commenced efforts to improve satisfactmn of Cls with the ECP proc:ss. One initiative was to begin reviewing pretuninary investigation findmgs with the Cl. Specifically, the ECP has established a practice of meeting with the Cls prior to resolving their concerns whenever the Cl is physically available. Otherwise, contact mill be made bv phone when possible.
Additmnalty. the ECP goal is now to contact the CIs escry 15 days vs. 30 days Also, the ECP is espressmg greater appreciation and empathy to the Cis for their concern by assuring all letters to the Cls are more personal and clear. If a concem cannot be or was not substantiated. ECP will use more respectful language in esplaining the seasons. These improvements are expected e increase the general satisfaction level of Cls and will be reflected in Revision 3 of the ECP Manual which will be implemented by February 2 7.1998.
- 7-of-98 CLOSEF)
- 17. Deselop a database and management NN ECe 1.stter 9/24/97 (BIM85) The ECP database now car,tures information on the source and Database now contains the informanon Reports and information are being provided to reports that will capture and provide afTected organization at the oriscer level...For relatively new concerns, the fu 1 range ofdsta has to provide meaningful reports to
- c. cy.~.; Special sorts are beseg used by ECP useful information to site leadership been entered into the enhanced database, management. Recent changes (Early Dec personnel and others (ex.,l.C.) to assist their to enable them to readily evaluate 8/2197 (ECP-97-052) Provides additional information regardmg the database update. The ECF
- 97) expanded capability to sort 30.7 work.
unponant issues reqmnng database now cartures informarmn on the sourte and afTected organization at the Officers Level.
issues.
management auentmn.
This information aiows the ECP to make hotspot determmatrons, as well as providmg the 2/198 Response to use database for Database is still not being used by ECP. to make capabihty tm qmckly provide a Nuclear Officer with information on concerns in the Officers' detenninmg problem areas is acceptable.
- hotspot" determinations as stated in NNECo's Orgamration response but hgg the capabilrty.
9/2497 (B 16685-3) NNECo commits that the ECP database will be updated to include the full range of data for concerns that were open as of December 1.1996, and those concems opened UIC will verify implementation.
thereafter,by January IG.1998.
MilB istter 2/5/98 (MHB-004) The ECP database is being used by the ECP to identify areas Implementation has improved. The Director of needmg attenten. Commencing with the January 1998 monthly ECP report which wdl be issued if ECP is also mamtaming a list afissues that is Fetwuarv IME. an espiscit statement will be made regarding how the ECP. database was used to bemg used to track related issues.
determme areas naedmg anention and the results of that use of the database. The monthly ECP.
report is utthred "y the St E. team, along with mput from a vanety of sources includmg ECO to dercemme potemial new problem areas and the status of esisting problem areas.
02-27-98 87-81-98 CILOSFD Page 16 of 49 Revised 11-23-98
- o' Date, Source and LHC NNECo Response LHC Evaluation LHC Effectiveness Detennisation Recommendation
- 18. Implement the communicatens ptart NN ECe Letter 9/24/97 (BIM85) The Manager. ECP. Projects will am the plan will be Response is adequate Plan has not been '..g~,.a4 or modified and impicmemed in a more coordinated fashion Subsequent priority attention will be bred on there has been tinle to no communication to feedbacit from Peer Representatives and Nuclear Communrations.
Millstone personnet l
(B IM85-7) NNECo commns that ECP. will communicate to Millstone personnel the status of the LHC Effectiveness Determination: NNECo has not ECP. and nature of concerns during the week of October 6.1997.
unplemenced the actions indicased in their response. At this time there would be httle value in irnplementmg the original pimet An intmducten and status of the ECP has and continues to be presented to managers and supervisors in the
" Managing for Nuclear Safety
- training class. This intmduction is also now being offered in the
" Nuclear Acclimatization"(Pennership 200&, Civil Treatment for Employees) class that is being grven to,,. LHC structured inserviewsindrate that employees are adequesely aware of the ECP as i
an option for raising emplovee concemt 01-21-N 87-01-90 CtOGED t
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- 19. All alternauve managemem avenues NNECo Letter 9/2437 (BIM85) Common standards and critene fa processing concems by all Response is adequene.
Concerns being received via the telephnne are i
avadable to employees to raise organizations handling employee concerns were implemented for llR, Sne Security, Internal Audit appropriately documenaed and included in the concerns, outside of the Employee and Security,Indugnal Safety and Heahh organizations and the hotimes "The specific lists of ECP. Monthly Report. Adegante implementation.
Concerns Program, slu uld have a organizatens that handle employee concerns may change over time, however, any organizations
{
consistent mechanism to receive, added to the hst wdl be subject to the common standards and criteria."
process and resolve concernt (B IM85-4) NNECO commits that concerns received over the telephone hotlines will be entered in the appropnate forms and captured in the ECP. Monthly Report to officers.
81-21-M SAfs-g rLOSED
[
20 All concerns should be esaluated for NNECe latter 9/24/97 (B1M85) Implementation of the common standards and criteria and ase Response is adequate implementation will be reviewed.
similar situations, generic of the common form wat emeNe the ECP. to collectively evaluate concerns received by imphcanons and root causes in a attemauve resoluten orgamzrxes and hothnes, and enable the ECP. to provide management Limited review indrases implementation timely manner to provide with timely insight into sue areas and activities needing their attention.
improm..~.;.
management with the best possible MilB Letter 2/5/98 (MH B o04) Each concern is evaluated to determine similar situations and insight into site environment and genenc implicanons during the triage process which generally occurs within $ days of receipt of a activities.
concern. Any significant trend is immediately brought tothe anention of the responsible Vice President. The ECP Director and his senior staff hase broad awareness of past and ongoing concen acovity. Wnh their knowledge, they assess individual concems as they are neceived and processed for indications of areas needing attensio's. As areas needmg attention are identified, the appropnate level of management responsible for the area is notified. A recent example is an issue in the area c1 Unia 3 mamtenarce management. Each concem is also evaluated to determine similar situations and genenc imphcations during the closure process. Finally, ECP conceres are reviewed collectively durms compilation of the monthly report which will be issued in March, the ECP will i
conduct an integrated review ofconcem input received from all sources. To enhance timely recogmtion of preblem areas, a member of the SCWE tearn integrates problem area data from ECP]
ECOP end other sources and submits a report to the Vice Presidents for resolution. All of these g efforts are intended to provide management with accurate insight imo site environr9ent and l
activities.
- All-98
- A28-M CIASEDr' MONITORING REQ'D
- 21. Manage' ment should have a NN ECs istter 9/24/97 (BIM85) There is a consistent process pnmarily consists of I) the NNECo has identified the morning IJnder evaluation.
[
consistent process which will allow notificaimn of the revonsible [V.S l of the existence of a concern in their area, and 2) the monthly SCWE meetings as the consistent Flocess being awd is acceptable.
them to be informed of sigmficant ECP. report to the officert.. enhanced to include a monthly briefing of all officers on the ECP.
process.
mformatmn incidents, issues and monthly report enj periodic meetings on concerns activity between the SCWE Executive Sponsor evems.
and the DFCP.
- Al7-98 ed-#1-M CLOSED
[
I
- i f
f Page 18 of 49 Revned 18-23-96
[
i k
f 4
i L
m..
m.
-.m er-
~
m-
.,,,,.r
~.,
___m Date, Source and LHC NNECo Response LHC Evaluation LHC EfL A u; Deterinimation Recoinmendatiori
- 22. Alllesels of Millstone management NNECe 1stter 9/2497 (B IM85-5) NNECo commits that at the next meetmg of first line Millstone managers have been given Under evaluation.
need to N trained to develop the supervisors and above, a presentation will be given to enhance the abihty to recognize and respond good training during the past five This will be tracked under Item St.
skills to recogmre and reyond appropnately to incidents that could cause or perpetuate a " chilling etTect" and that we will months, but need more work on an apprornately to mcidents that could evaluate the need for further trainmg in this area by October 21,1996.
indsvidual department level to cause or perpetuate a " chilling effect" understand the balance between that could prevent employees from mamtaining a safety conscious work raismg nuclear safety concerns.
environment and maintaining necessary discipime and demonstratmg effective leadership. This is not bemg adequately addressed. In addition, not all senior managers are operating with the same degree of understandmg and implementation of these issues.
02-17-N N-01-N CLOSED
- 23. Executise management should be NN ECe Letter 9/2497 (BIM85) Executive management is kept apprized of work areas known er input from ECOP to" Executive" ECOP veports are being provided in a timely Legt appnied of the existence of suspected to have a"chillmg efTect"or hostile work environment via the same process noted in management should be provided
- manner, work areas that have been alleged or Retornmendaten 3.
simultaneously to a!I responsible officers SCWE daily meet ngs discuss emerging areas.
confirmed as having a"chillmg
" Add.tmnally, the _. ECOP presides esecutive management with input on "chitting effect" and (ime) as well as to the CEO.
effect" or hostile work environment hostde work environments as part of ECOP's ongoing actaities" "The Executive sponsor and This has been handled inconsistently by so that they are able to better monitor Issue Manager for the (SCWE] have ininated a contmuing review of various data for indestens of management but is improving.
and evaluate these situations-potential" pockets' needmg management attention.. Additional management attention will be focused on those areas havmg mdications of problems?
MilB letter 2-5-98 (MHB404) FCOP provides the necessary input to the"Execut ve" management on all issues related to SCWE at the daily SCWE meetmgs,includmg informaten on the ettstence of potential work areas that hase been alleged or confirmed as having a chilling effect to hostile environment ECOP also provides the same information t line management as well as the CEO 01-17-N N-13-N CLO57D 24 Cntengshould be developed that will NNECe Letter 9/2497 (88M85)" Management is continually vigilant" with routme information The response does not speak to the Rapid response process.
a he consistently used to identify or input. feedback from ECOP, Penodic Culture Surveys and Leadership Assessments.
-._ -../.aion that cnteria be SCWE Ilandbook-esaluate incidents or s".cgatons that developed to identify erosion.
Focus Area Process.
a particular working environment has croded to the pomt that employees are too denmralized to perform as exrected 01-21-90 N-15-N CLOSED D Management must " walk the talk."
NNFCe letter 9/24!97 (81M85)" management is evaluatmg available information to deal with Progress has been made, however Under evaluation.
pockets mhere managers and supervisors are contnbuting to a poor environment for addressmg and weaknesses have been identified in this resolvmg employee concerns." " Management has. expressed a policy of zero tolerance for..-
area. Management needs to do a better tillRD) actionsw._ we recognize more progress must be made to reduce the apparent distrust among job of addressing the trust / mistrust our workers which is lendmg to concerns regardmg illRD aspects?
among employees.
02-17-H 07-01-98 CLOSED
. Page 19 of 49 Re,ned I1-23-98
e, Date,hurce and LIIC NNECo Response LilC Evaluation LIIC Effectiveness Determination Recommendatioti 7-22-97 Case File Review 26 increase marragement expectations NNECe Letter 9/24/97 (Bl6685) DECP has emphasized unportance of adhering to ECP Manual Response is adequate. LHC File Adequa:e.
and FCP stalT secountabihty to FCP and hes assured statT understands and is committed to followmg the manual; staff understands they Renews in September & October LHC withentinue to monitor this area through Manual regmrements.
are accountable for complying venfied improved and adequate selected file review.
implementation.
LIIC teview of 27 files in March 1998 shows continuing L.,-~.4 however, some files still have minor problems.
See uenns 7b.13.13,26,28. 31. A 32 01-21-98 07-01-98 CLOSED
- 27. perform in-process and pre-NN ECe beter 9/2417 (B16685) OfTme CnorJmator will conduct pre-and post-resolution Response is adequate.
Implementation will be reviewed.
resolution renews beyond that perfermed by the invest ganve staff Penodic self assessmerits will also address this area'.
Two files hase had 2 ECP person renews with MilB beter 2/5/98 (MilB404) A practice will be imtiated by the ECP in February 1908 to positive results.
supplement the reviews of the Office Coordmaior. The practice will be for two or more ECP personnel to jomily conduct reviews of selected concern files pner to declanng the investigations Current practices are adequate.
complete. The renews will be for substance and will complement the OfBce Coordmator reviews for content.
02-11-98 07-01-98 CLOSED
- 28. No fue should be classified as NNECe Letter 9/2497 (B16685) No file will be classified as Wesolved" or" closed" without being 3 ECP Self-Assessments were completed LHC review of files verified major improvements.
resolved or closed without required renewed for completeness and acct racy by the investigative staff. Periodic self assessments will in December.
however. some files stdl show evidence oflack of reuew for cornpleteness and address this area review (Ex 142,262,279, and 313 )
accurnet.
MilB beter 2/5198 (MilB404) ECP files i42,262,279 and 313 w:ll be reviewed and LHC will review files 142,262. 279. and 313.
reinsestigated as necessary to resolve any noted deficiencies related to adequacy and completeness This will be completed by February 27,1998. The new practice described in the resportse to LHC Review of 27 Files in March 1998 showed Recommendation 27 wdl provide increased assurance of the adequacy of file content and continuing improvement.
substance.
NN Eco Ectter 2/27/98 (DBA 9842I) Changed the completion date to 5/1/98. The proposed See hems 76.13.15,26,28. J1. & 52 schedule change for ECP files applies only to files 142 and 262. The schedule change for ECP file 262 is necessary to espand the ECP review to ensure that the results of the investiganon are adequate and complete. The schedule change for ECP file 142 is necessary because the concerned mdmdual has been on riedical leave since January I4.1998. The renew of the other two ECP files (279 and 31 M and correction of deficiencies were completed on December 22.1997 and January 17.1998. respectively. The proposed schedule change does not impact Unit 3 restart
- A03-98
- A18-98 Q.Q_SID program MNFCo Letter 9/24?97 (B16685) The controls in the revised ECP Manual are sufficient Response is adequate.
See item # 27 & 28. LHC will re.iew 29 Estabbsh a senior management i
review panel to reuem resolved files Addinonal renews are noted which essure effectiveness....we do not beheve additional reviews arc implementation.
for the quahty of concern esaluation.
necesury.
adequacy of disposition and MilB beter 2/5/98 (MHB404) The pracuce descnbed m the updated response to Current practice is adequate.
feedback to concernees Recommendation 27 will proude assurance that files for completed invesugations are of high quality regardmg concem evaluation, disrositmn, and feedback to concernees.
01-17-98 87-#1-98 CLOSED Page 20 of 49 Revned Il-2b98
m
=
4 Date, Source and LHC NNECo Response LHC Evaluation LHC Effectiveness Detensinaties Recommendation
- 30. Review those files resolved smce at NNECe Letter 9/24/97(B 16685-6) NNECo commits to review ECP files classified as " resolved' Pesponse is adequate. LilC Review of a Adequate except for issues relaaed to IOCFR 50.7 least December 1996, to assure a!!
ce " closed" since December 1.1996 and resolve discreparmes by October 17,1997.
sample (23 files) of the files" redone" by criteria issues were property resolved under -
Cntenu for resolving discrepancies are provided in the response.
ECP and 24 new files verified
[
current program definitsen.
NNECo istter 18/16/97 (B 16812) Lccer advises that review is partially completed, but will not compliance. ECP Self-Assessment 97 meet committed date. Commitment revised to NNECo comrnits to review ECP files classified as EC-2 also verified closure.
- resolved"or" closed
- since December I,1996 and resolve discrepancies by November 14,1997.
NNECo Letter i1184/97 (Bl6858) changed the ll/l497 commament date to 12/1/97.
91-21-98 3731 93 CLOSED i
ITPOP 8-25-97 97-0828 ret to 8-20-97 Meeting with NNECe RegardiaC Chilling Effect
- 31. NNECo esecouve management NNECo Istter 12/29/97 (B16851) NNECo agree and has established an Executive Review Board This was particularly directed to the k
shoald take further immediate acten (l'RB). Purpose of the ERB is. ERB membership consists of The ERB reviews proposed MOV incident, and it has beca to contam the situation by assuring personnel action whenever line management believes there is a need to take action at or above the adequately resolved. However, the ERB that the individuals perceived as level of w,itten repnmand involving a company or contractors
- employee. Background information still has problems with imerfacing with having the authority to harm people describmg the action beir g proposed and other appropnate information is to be provided by flumer contractors and contractor reductions y
who raise questions or have concems Resources for NU employees and by the Contracts Admimstratmn Department for contractors *
(LHC has still been waiting for a i
cannot take art on without some employees. The ERB also reviews comractor reductens in force. This review wiu be either by response to its oral inquiry about the i
NNECo review of those actions. The reviewing the individual list of contractors (provided by the contracting companies) to be reduced Manpower reductions and why incorrect review should take place outside the or the methodology to be used with spot checks to ensure compliance with our requirementi information was presented to the ERB )
alTected management chain.
Excluded from this review are contractor releases specifically related to pre-planned completion of a known scope of work or managed task.
84-82-98 04 15 98 CLO$ED i
- 32. NNECo esecunve management NN ECo I etter 12/29/97 (B16851) NNECo Senior Management, including the President and MOV incident has been resolved.
should take personal action to assure CEO-Nuclear and Mi!! stone Chief Nuclear Officer, discussed these schedule changes with the i
the MOV Department that the Millstone management team (first line supervisors and above) at a meeting held on November 5.
schedule constramts imposed on 1997. Senior Management emphasized dunng this meeting that concerns, including scheduler
+
k them will not be allowed to concems need to be voiced and raised up the managemen; cham so the inputs on the schedule can undermme the production of a quality be evaluated and adjusted if necessary. NU management is committed to fkmibihty in the schedule product. Management also should to ensure contmued emphasis on providing the required amount of time to complete the work.
i gam an understanding of the depth of the techmcal and schedule problems mthin the organizaten.
- 1-f 7-98
- 1-24-98 CLOSED
- 33. NNECo esetutive management NSECo Letter 12/29/97 (B16851) An NU supervisor was appointed to replace the original MOV incident has beca resolved.
should develop and mamtain a dose supervisor (who was a contractor)in the MOV area, in August 1997. Also, the MOV tesm has relatenship with the department in frequent meetings in *hich the employees are asked to raise any nuestions they may have related to order to counteract the chilling etTect the work environment. Furthermore, the NU supervisor has completed the mandatory SCWE created by the genes of terminat ons, training courses (Managing for Nuclear Safety and first two trainmq sessmns of 10 CFR 50 7) in demotens and other actions by December 1997.
[
current management-
- 1-17-98 02-24-98 CLOSM f
I Page 2I of 49 Revned Il-23-98 r
E
+
b i
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Date, Source and LIIC NNECo Response LHC Evaluation LHC Effectiveness Deterinination Recommendation ITPOP 97-0034 ret to 9-17-96 Meeting with NNECe en MOV
- 34. NNECo should immediately develop NNECo letter 12/29M7 (B16851) On September 26,1997, a meetmg was held with first line Training has been undertaken,and LHC has evaluated NNECo's Iceg-term Training and conduct focused training for all supervisors and above. The purpose of the meeting was to-1) emphasize semor management's evaluated as having good coment Program to ensure that on-gomg training is supersisors managers and the expectations regardmg estabitshmg a safety conscious work environment and 2) educate the flowever, additional training is necessary scheduled to reinforce the infonnation provided executive mana5ement team on how management team on SCWE related topics including recognizmg and addressing chilling etTects, on a smaller scale to reinforce the habits dunng the initial training. LHC is satisfied that the to recogmze potential retahation and retahation, and contractor co empicyvnent issues. We recognite the trammg that was provided and provide assistance to managers to be NNECo program is consistent with the "chilhng etTect." how to respond to dunng that meeting was not all-inclusive (it was not intended to be) and therefore have scheduled able to lead and manage within the these situations, and how to mitteMe additional tramma classes. These claues will be provided to the executive management team dowr Millstone challenges.
the harm from events which confirm thingh the first ime supervisors inchadmg contractor management NU is re quiririg these retahatmn or chilling effect.'
personnel to participate in a three-sess6on traming program Session I classes were conducted in Neember 1997, in groups of 20-30 participants. Unis session covered the essential elements of discrimmation and management actens to avoid, detect, and respond to such claims. Session Il trammg was conducted m groups of 20-30 pamcipants in December 1997. This session began with a diagnostic test and fundamentals were reinforced. and identified weakricsses were remediated.
Dunng this session, participants were also provuled trainmg in confhet resolution and effective listenmg skills. Ten case studies were available for discussson. One of these cases was developed to include issues related to MOV and training area issucs. In addition, lessons learned from the MOV issues have been communicated to employees through formal training courses. NU News Releases, and all-hands meetmgs. Fmally, Session ill is scheduled for January 20,1998. This sessions =ill take place in a large group setting, and site management will address how the pnnciples and attnbutes of a Safety Conscious Work Environment (SCWE) will come together at Milbtone. The trainmg is designed to provide the management team at MJlstone Station, with the necessary informatmn to appropriately respond to employee concerns, minimize the potentia! for claims of discnmenation, prevent or mitigate a chilling effect among others in the workforce, and to generally foster a safety conscious wont environment.
01-11-98 IA3&98 GOSED
- 35. NNECo should use the MOV NNFCe Estter 12/29/97 (B16851) In Nmember 1997, a case study was developed that Response is acceptable, retahation investigation and findmgs incorporates lessons learned from the MOV issue. The re=ults of the actens taken to date on this as a ** case studf to deliver " lessons issue have been communicated to the ent re organization.
learned
- to the entire organizaton NU management believes that all the actions talten,includmg monitormg the effectiveness of the Nt, SCWE Plan and pro idmg the required 10 CFR 50.7 traming, will reduce the likelihood of occurrence of a samlar event As a resuh of these programs. NU management is acquiring the required enrettiw to mitigate the consequences of a similar event should it occur at Millstone.
Traming pro;: rams for NU management are en enpomg actmry.
82-17-93 1AJA98 CtJOSED Page 22 of 49 Revssed Il-23-98
.a Date, Source and LHC NNECo Response LHC Evaluation LHC Effectiveness Determilaation Recomtnendation 36 NNECo should establish expectatens NN ECo Letter 12/29/97 (916851) The Contracts Admimstranon Department (CAD), includmg Dased on recent events, there is a ERB.
and accoun'abihties for the Legal the Manager and Director-CAD, held a meeting after the identification of the MOV retalisten issa continuing concera about the Use of outside on-site legal advisor.
Department and the NNECo Contract ISeptember 19971 to discuss the lessons learned from this issue and to encourage a questioning participation of contracts and legal in the Admmistraton Department to asutude within the CAD.
management of d:fficult employment provute additional barners to in addition, on October 24.1997, the Cad issued a self-assessment report to ensure that the factors management situations.
possible future acts of retahation '
that led to the MOV termmetions are understood, and that process changes and training are implemented to preclude repetition. The self-assessment determined that communications within the Cad are effective in that problems and lessons teamed information are shared immediately and are open worked on in a team environment. Training will be provided to CAD management personnel to help them recognire and address chilling effects. retaliation, and contrador ca. -
employment issues. Initial training was provided to supervisors and above at a meeting held on September 26,1997. Additaonal training is ongoing (this is the same training program mdicated in response to Recommendation I above). With respect to the legal Department, in order to heighten their sensitivity to issues of retaliation and chilling efTect, the NU Legal Department attorneys who provute advice on nuclear employment matters have attended 10 CFR 50.7 trainmg courses. legal counsel parucipates in the ERB The Executive Review Board (ERD) will provide additional chetks and balances to ensure that future disciplinary actions are not retaliatory.
82-17-98 klJ.98 CLOSElWMONITORING REQ'D
- 37. NNECo should continue to take NNECe Estter 12/29/97 (516851) ne Mov group is bems superviwd by NU mansgement. This NU did a goodjob in replacing the MOV actions to ensure that the employees change in leadership has changed the environment in the group. For example, frequent all-hands department managers and the deps 1 ment in the MOV Group are willmg to meetings are held to facilitate group comenunicatioris. In addition, execunve level oversight is appears to have returned to stability.
raise concems and approach their provnied throughout the program.
posanons with a'questenir g 82-17-98 statude?
82-17-98 CLOSED 35 NNE Co should cntically review the.
NNECe letter 12/29/97 (B16851) Please see NU response to R--Mion I in Attachment I The ERB has demonstrated the authority ERB performance is acceptable.
abihty of the proposed disciphna y on the Executive Review Board (ERB) Charter and responsibilities. Also, treining was provided to and ability to mentam the status que of review panel's capabdity to provide esecutive management on October 31 and December 17,1997. De purpose of the traming was to employees whose proposed discipline is the proted.on anticipated, formally educate the executive staff on what constitutes harassment, intimidation, retaliation, and questionable, and thus provide a mstitute the review panel, and ensure discrimination (HIR&D) and the basic premise of protected activities. Training for the ERB deterrent to retahmtory action, and a that persons on the panel have the members is ongomg and expected to be completed by January 31,199g. Until all ERB members forum to anticipate and prevent incidents skills and quahfica' ions necessary to are tramed, an attorney who possesses the requisite skills and quahncations will participate in ERB for occumng.
make crincal evaluauoris and meetmgs to help ensure that all relevant information is appropnately considered.
judgements about proposed disciphnary actions to ensure that future events such as the MOV termmatmns do not occur.
82-17-98
- J-98 CLOSED Page 23 of 49 Revned18-23-98
. c.
4 Date, Source and LHC NNECo Response LHC Evaluation LHC Effectweness Detersmination Recotntmendation
- 39. NNECo should ensure that the NNECe letter I2/29/97 (BI68SI) On September 25,1997, the manager of the Contracts Evaluation took too long but has been retaharcry actens taken agamst the Admimstration Derstment (CAD) requested that a review of the records of the two subject ressived..
'y contract engmeers are obhrerared.
mdivuluals be conducted to ensure that the NU Notifu:ation of Termination does not indicare includmg assurmg that the unfavorable terminations. A review of the security records was conducted between September 25.
termu ation letters are rescinded, that 1997 and October 5,1997, which indicated that the termination records did not show an the secunty access recwds are unfavorable termination status. On October 7,1997, the manager of the Cad,in two separate lettera reered and do not reficct to the MOV contracters, retracted Nlrs letter WRC-97-822, dated Angust 7,1997. De October terminations "or cause."
7.1997 letters stated that the services of the two contracters have been extended at Mdistone and a revised purchase order to that effect had been issued.
82-IT-M
- 2-17-98 CLOSED 9-24-97 Corrective Acties Prwgram
- 40. Estabhsh pnontics for level I CR NNECe istter12/19/97 (B16851) Recommendation I respc=ise: RP4. Rev,6, Corrective Action This will be acceptable if timely and RP 4 Rev. 6 provides for upper management and i
actions that refect the urgency of Program, to be implemented by Jan 31,1998, stipulates higher levels of management approval for effective actions are taken for significant MRT involvement in setting, approving and avoidmg recurrence and ensure Level I corrective actions with longer term completion dates. All Level I action plans require level I events. LHC's observation was revising due dates for level I CR corrective actions' adequate mterirn actions.
compensatory actions to be in place untd corrective actions are implemented. Dese expectations that there were few Level I corrective and sequires that necessary compensatory actions are monitored by the approving Director and the Management Review Team (MRT).
actions to prevent reciatence be in place until corrective actions are NNECs Letter 1127/98 (Bl7016) changed date for RP4, Rev 6 tc 2/27/98.
implemented for events that continued to accomplished. Unit 3 MRT meetmas display occur.
appropriate priority for level I actions and NNECe Letter 2127/98 (Bf 7087) changes the implementation dan for RP44 to 4/6/93 This schedule change is necessary to ensure that personnel are adequaten trained prior to sensitivity to dase extensiera Review of recent implementation.
Unit 3 level I CRs indicates that compensatory actions are identified and seflected in the analysis, prior to full implementation of longer term conective actions.
Recurring items are identified througli quarterly trend analysts. On Unit 3 these key issues are addressed rnanthly, with a status of action and any noted change to the trend identified in a report to (Effec'tiveness has not been assessed for other unrts.)
01-22-98 04-2 & 96 M
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- 41. Provide an accountable "CR owner NNECa Letter I2/29/97 (816851) Recommendshon 2 response; RP4, Rev. 5, implemented Acceptable.
CR owners are assigned for all CRs. Expectauens for the unplementation phase of each 9/30/97, establishes CR owners for CRs, accountable for acten plan development through are adequately stated in the procedure and Level I CR, estabitsh and implementation. Expectations are spelled out in the procedure and trainmg.
procedure rollout traming. U4C has not made commumcate espectations for"CR sufficient observanons to determee the owners?
effectiveness of CR owners. Based on interviews, it appears that effectiveness is mixed, varying with the desire of the " owner" to exercise comrol over the corrective action process Some individuals take a proactive role in the development of the action plan and its implernentation, having a positive effect. The process as implemented on Una 3 provides the owner with completed work products as they are completed, a!!owing a venficar;on that the activity meets expectations without waiting for completion of all of the activities associated with the CR.
(The process has not been assessed for other units.)
01-12-98 04-2 & 98 CLOSED
- 42. Provide mcreased management NNECe Letter 12/29a97 (Bt6851) Recommendauon 3 response; RP4, Rev. 5 directs that the This may be acceptable depending on levet I CRs continue.. define actions to evaluate attent:on to ur:plementation of MRT evaluate, approve, and approve changes to Level I CR action plan actions and due dates.
implementation. DiC's effectiveness. RP 4 Rev. 6 requires owners of CRs corrective actions for Level I CRs.
The MRT is appnred of overdue actions. Upon acten plan completion, CR owners report on
-....dion was focused on the to review and report to the MRT on effectiveness improve monitonrg of effectiveness to the MRT.
need to provide increased management of the corrective actions tAen. (Li1C has not yet implemenestion efforts and of attention to getting corrective actions for reviewed the effectiveness of this pmcess).
corrective action etTectiveness, Level I CRs implemented.
Management is now better able to view status of assignments to implement corrective actions. Unit 3 Daily Status Report provides visibility for open and overdue action requests (ARs) supporting the corrective action programfor Unit 3 snd non ur.it organizations with ARs supporting Unit 3. This "emortunity matrif oisplays all alert groups and meagers with their AR stants, as well as any overdue CR evaluations. This Unit 3 pmcess appears to provide effective visibihry to management.
01-22-98 08-26-98 QJ> SED
. Page 25 of 49 Revised Il-2348
e" Date, Source and LHC NNECo Response LHC Evaluation LHC Effectiveness Deteranisation Recommendation
- 43. Coordmate actions on CRs that have NN ECo letter 12/29/97 (B16851) Recommendation 4 response; Common causes are identifed ir This may be -W depending on The CAD Manager and the Unit MRT provide an common cauws (and provide the trendmg process implemented on 9/30/97. Organuation Trend Coordmators have the analytice implementaten L.._. ;.4 the ability institutional mernary to identify relased CRs and improved analytial capabihty for tools for identifymg the causet Appropriate management will receive results through tread reports to wrap existing and new CRs into this relate CR activities when they view it as identifying such cases).
for action. For Station level common causes, the Sete MRT will propose an issue manager to trend evaluationL approprisse. Assigned CR owners coordmate coordmate response ta the identified cause.
common activines within their funcuenal areas De Corrective Action Departrnent does a trend code assignment foreach CIL The Unit 3 CAD has developed a dann base which assigns existing lesel ICRs to 45 7ssue Bens *, allowing a spick check to be made among CRs related to common issues. For level 2 CRs, the trend reports identify groupmss of events and trigger initiation of a Level I CR if an adverse trend has developed.
(Effectiveness has not been assessed for other unitt) 01-22-N N-WN CLQ$ Lit
- 44. Increase management anention to NNECa letter I2/29/97 (B16851) Recommendation 5 response; Oversight and self-assessment It is acceptable to handle Oversight and CRs are routinely initiated by Nuclear Oversight resolution of Oversight and self-fmdmgs are reported using CRs and resulting acsion foHows the normal CR process. Action Plans Self-assessment findings as CRs LilC's and Self Assessment activity. These CRs and the assessment fmdmgs developed to address the Oversight CRs are not changed without Ovarsight's concurrence.
point was that the fmdings were accurate associated reports containing tite fedmgs or and, if acted upon, could prevent adverse L.wa.;.;;ivmg rise to them are reviewed by conditions from occurring. Increased appropriate liut management The CR process maragement anennon should be provides for a determmation of action and the provided to assure that appropruse priority appropnate for ARs. On Unit 3, the CAD priormes are applied to corrective Manager conducts a weekly review with actions.
management of all CRs over 21 deys in the review eycle, and all overdue CRs, highlightmg those arising froen Nuclear Oversight activity.
Interviews with Nuclear Oversight personnel and the Unit 3 Self Assessment Coordinator indicate that line management attenten to Oversight and Self Assessment f;ndings has increased and is adequate. Review of ARs generated through 1997 by Unit 3 self assessments showed excellent ceriformance to schedule for closure.
(Effectiveness has not been assessed for other unitt) of-22-98
. W-N 98 CLOSED Page 26 of 49 kevised Il-23-98
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Date, Source and LIIC NNECo Response LHC Evaluntion LHC EITectiveness Deterniination Recommendation 41 Provide adequac CR context NNECe letter 12/2997 (Bl6851) Recommendation 6 response; CR Owners are assigned to nis does not appear no acceptably Dtscussion with Unit 3 CAD manager indicates information to personnel who are develop compicte actmn plans for CRs and are knowledgeable of CR context. Correcove Action address the,~... J ; ion. De this issue may be abating based on irnproved given corrective action asugnments Coordmators are available to assist each manager in gettmg information from the CR Tracking response does not ensure that an dermition of CR action items. Guidance (510031 Database.
individual assigned to implement an training and feedback to investigators, through the action receives any infor nation other CR evalunion process is resultmg in mere than the single action statement.
definitive and complete statements of corrective action. On Unit 3, MRT review of corrective action plans includes scrutrny of correctrve action wording. These statements are transferred in soro to the ATTTS. An individualin doubt as to the AITIS assignment can review the CR package in the CAD. (Effectiveness has not been assessed for other unitt) 01-22-98 04-2 S 98 CLOSM 46 Modify program guidance to' NNECe letter 11/29/97 (B16851) Recommendation 71 response; CR owners use their Guidance contained in referenced he guidance of the referenced memo has been 46a.
Limit the number m Judgemant of value/ resources in developing acten plans. MP3-CAD-97-064,11/1g!97, provides m.ac J s. is acceptable. However.
incorporated into general guidance of SI-100 3.
correctne actmns for Level 2 guidance for Level 2 CR investigermns to identify specific 6ssues, correct and trend thent this information needs to be cwitrolled in Rev.0(Millstone Station Corrective Action CRs (avoid a "fic for every such a manner that it is ducctly Review). Traming and implementaten causel referenced in the procedure.
.mpovements are taking place. RP 4 Rev.6 no longer requires a fix for every apparent cause.
Review within CAD (Unit 3) by CAD engmeers identifies CRs where this guidance is violated, and these CRs are selected for MRT review. His process is providing additional :. r....;. A review of a sample of current Uma 3 level 2 corrective action plans shows impovement.
(Effectiveness has not been assessed for other unrts) 01-22-98 04-20 98 CLOSED 4hh Lemit the numt er of NNECa letter 12/29/97(Bl685I) Recommendation 7.2 response; CR owners use their Acceptable pending review of RP4 Rev.
Neither RP 4 Rev.6 nor root cause procedure RP 6 correctne actons for 1.csel I judgement of valedrewurces in developing action plans. Guidance will be provided in RP4. Rev 6.
Rev.R guidance has been changed to hmit the CRs to sigmficant causal 6., to focus correctne actens on root cause and related causal factors. Other causal factors should number oflevel I corrective actions. However, a factors.
be addressed by writmg separate CRt Directors and MRT provide oversight to ensure appropriate review of a selection of recent Unit 3 level I CRs correctne action scopes shows that root cause evaluations are now more focused and corrective actsons rnere hmited in number. His is attributed to improved experience with root cause process and potentially MRT review. (Effectiveness has not been assessto for other unitt) 01-12-98 04-20-98 CLOSED Page 27 of 49 Revned Il-23-98
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LHC Evaluation LHC Effectiveness Detersminaties l
Recontinendation 46c. Justify maivers of root cause NN ECe Letter 12/29M7 (816851) R -------- -- : ion 7.3 response. RP4, Rev. 5,9/3097, provide, Acceptable.
RP 4 Rev.6 requires documentedjustificahon for j
evaluations.
guidance that requires justification for waivers of Level I root cause evaluations.
the werver of a level I root raiser A follow up review of recent Unit 3 icvel I CRs demonstruses hat the guidance of RP4 is being effectively emplemensed.
(Effectiveness has not been assessed for other units.)
01-22-98 ed-JS-98 CLOSED 46d.
Do not permit 30 day NNECe Letter 12/29M7(516851) Recommendation 7.4 response; The process allows extensions Acceptable, depending on practice. The Observation of Unit 3 MRT nieetings has shown investigation requurment to of inveshgahon tune, with satisfactory justification to MRT.
process allows extensions, but does not that inveshganon duc dates are considered and impact the quahty of emphasize the management expectation allowed when apprepnene. Interview with the significant invesugations.
to put quality before schedule.
MRT chair indscases that this has occurred on a number of ar==au A review of a selected set of level I CRs for Unit 3 subcases that the quality of investigations is acceptable and is not bemg impacted by the way in which the 30 day hmn is being controlled.
(Effectiveness has not been assessed for other units.)
81-22-M Sd-28-98 CLOSED
- 47. Provide improved root cause NNECe letter 12/29M7(816851) Recommendation 8 I response; RP4, Rev.5,9/30/97 provides Acceptable pending review of RP6 The noted changes to RP4 Rev 5 and RP6 Rev i inveshgation er1 presentation espectations on the type ofinformation to be contamed in a root cause evaluanon. RP6, Root revision.
have not provided improved guidance that would guidance Cause Analysis, to be implemceted li3 !!98, will provide more specific guidance on content and address this recommendonon. However, a review 47a.
Ensure root cause(s) are format of mot cause evaluations.
of a tunited number of recent Unit 3 level I CR stated with adequare NNECo Letter Ir31M81817016) Changes the implementation date for RP6 to 2/27/98-root cause evaluations has shown that root cause specificity.
NNECe Letter 2/27MS (B17087) changes the implementation date to 4/6/98. This schedule spectficity has improved, and is as an mi:ceptable ch mge is necessary to ensure that personnel are adequately trained prior to imp!cmentation.
level This appears to be the result ofimproved experience of root cause in.-
., and the review process given to root cause evaluations on Unit 3.
(Effectiveness has not been assessed for other units.)
l 81-22-98 84-28-98 CLOWD P
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Date, Source and LilC NNECo Response LHC Evaluation LHC Effectiveness Deteratination Recommendation 47b. Push cause dercrmination to NNECe Letter 4/17/98 (DBA-98-035) RP6, Revision I, Root Cause Analysis Procedure, which kesponse is adequate.
The noted changes to RP4 Rev 5 and RP6 Rev I the apprornate level.
was unplemented on February 23,1998 provides clear guidance on the information so be included have not provided improved guidance that would b a root cause investigation report The introduction of each root cause report includes a address this.-
However, a review description of the issue, event. program or organization failure which is being investigated and the of a limited nurnber of recent Unit 3 level I CR scope of the investigation. RP4, Revision 6, Corrective Action Program, which became effective root cause evaluations has shown that root cause on Apnl 6,1998 specifies that the investigator for a vuot cause investigation shall be trained in root specificity has improved, and is at an acceptsNe cause analysis to improve the hkelihood that the cause will be determined. The Management level This appears to be the result ofimproved Review Teams review the results of root cause investigations and the ensuing action plans. Ifit is experience of rcot cause investigators and the identified that personal performance was the cause or contributed to the event, the Management review process given to root cause evaluations on Review Teams are not reticent to ensure that corrective actmns are taken to address the personal Unit 3.
performance issues. When it is clear that human performance has not met expectations, appropriate (Effectiveness has not been assessed for other conective measures are espected to be taken u hich hold those indniduals accountable for their units.)
performance.
5 84-98 5 04-98 CfASED 47c.
Address mdividual NNECa Letter 12/29/97 (B16851) Recommendation 8 2 response; Each Unit has established a This does not appear to fully address the The noted changes to RP4 R: y 5 and RP6 Rev i performance issues.
Performance Enhancement System Coordmaior to monitor response to human errors and provide recommendation. LHC's have not provided improved guidance that would coaching on methods to in prove human performance recommendation was to clearly identify address this -.~./ ; ion. However, a review and address specific personnel of a limited number of recent Unit 3 CRs has performance errors and problems. It is shown a willingness to identify cause and not evident that the actme taken will corrective action at an individual perfonnarce address the need to improve level.
identification of specific personnel (Effediveness has not been assessed for other performance errors during the CR cause units.)
evaluation.
01-22-98 04-2M8 CLOSED 11-8597 Recommendations for ECP Pretram 48 Increase contact with employees NNECO Letter 1/21/95 (BI6953) ECP recognized the need for improved contact with the Response is adequate.
Recent customer inputs regarding satisfaction has throughout the process, particularly Concemed Individuals (Cis) and began an tmprovement program in December 1997. An initiative improved from 50% to 83% Well continue to at resolution, obtam en. ploy ee at that time was to begin resiewing prelimmary mvestigation findmgs with the CL lhe ECP has '
monitor this area.
feedback at resolution.
estabhshed a practice of meetmg with the Cls prior to resolving their concerns whenever the Cl is physically avadable. Otherwise, contact will be made by phone when possible. Additionally, t'ic March LHC contacts show that 93% cf those using FCP goal rs now to contact the Cis every 15 days vs. 30 days. Furthermore, the ECP is expressing ECP would reuse.
greater appreciation and empathy to the Cis for their concem by assuring all letters to *he Cls are more personal and clear. If a concern cannot be or was not substantiated ECP will use more respectful language in espiaining the reasons. These improvements are espected to increase the general satisfaction level of CIs and will be reflected in Revision 3 of the ECP Manual which will be implemented by February 27.1998.
81-22-98
- 7-01-98 Q.OSED Page 29 of 49 Revned Ii-23-96
g Date, Source and LHC NNECo Response LHC Evaluation LHC Effectiveness Determination Recommendation 49 Improve the integrated assessment of NNECO letter 1128!98 (816958)The ECP Director and his senior stafThave broad awareness of Good progres has been made, but the Adequale presgress has been made. Will be tracked all concerns to identify problem areas past and ongomg concern activity and problem areas. With their knowledge,they assess individual integ*stion 1:ast become part of the under item 63.
in a timely manner.
concerns as they are received and processed for indications of problem areas. As problem areas are mermal approach to issues across the site identified, the apprornate level of management responsible for the area is notified. A recent in order so anticipare and prevent example is an ongoing concern related to a change in Unit 3 mamienance -
The ECP additional incidents or crosions to occur.
also routmely conducts integrated reviews of concems to identify common issues and organizations durmg compdation of the monthly report an reflects sigm6 cant problems in the report. To enhance timely recogninon of problem areas, a member of the SCWE team integrates problem area data from ECP, ECOP and other sources and submits a report to the Vice Presidents for resolution.
81-17-98 88-#3-98 CLOSED
- 50. Proiide additional traming to ECP NNECO 11tter 112199 (516958) The ECP has made lilRAD training a high pnority since the Responseplusadditional Effectiveness of traising will be evaluated by staff on lilRD and sensdivity in begmmng of the current training prograrn (April 1997.) Courses which directly or indirectly are adequase. Additional training is enonitoring ECP's handimg of HIRD issues and the dealmg enh employees.
address this topic were conducted in Aptd, May, fur e, August. October and December 1997.
planned for the 1* week of March.
training to be coeducted during the l' week of Additional trumms was conducted on December 17,1997 for the ECP staff on HIR&D issues.
March.
Funhermore, the Director of ECP and selected staff will attend the SCWE Session Ill training es See dren de.
desenbed in the response to R-~~tmion 5 in Section 11 of this Attachment Training conducted on 3/19/98 and 4/1/98 is adequate.
82-28 98 87-81-98 CLOSED
- 51. Require a more consstent closure NNECO Letter 1/21/98 (B16958) The consistency of the ECP concern closure process is under Responseis adequate.
Changes to the manuel and its implementation mill process for all cr,cems.
review. Process enhancements resulting from this review will be reficcted in ECP Manual Revissor be evalueled 3, which will be implemented by February 27.1998.
See deems 7A 13, f5,26. 2& & 52.
Manual changes are adequese. March LHC Review of 27 files shows improvement.
- 1-22-98
- 7-81-98 CLOSED
- 52. Maintam vigdance of mvestigation NN ECO letter 1/2 I!98 (816958) Durmg the triage process, pnor to commencement of an Response plus additanal information Under.
quahty, and assure that all issues investigation, potential issues associated with a concem are identified. At the conclusion of an from conversations with ECP March LHC review of 27 files shows improvement.
associated with a concern are investigation, concerns are reviewed by the investigators for thoroughnessL Additional reviews are management imhcating that ECP intends ECP-98-028 verifies that an" internal closure identified and addressed conducted dunng the normal review and approval process by ECP management. This process to conduct "intemal closure panels" on paner' and review was conducted on 2 files.
includes an issue-by-issue verification that each item has been investigated and an appropnate selected cases is adequate.
Seeitems 7A /3,15,26 28, & jf.
conclusmn has been drawn These practices will be reflected in ECP Manual Revision 3 which will be implemented by February 27,1998 81-23-98
- d-81-98 CLOSED @lONITORING REQ'D 51 Report why issues are coming to ECP NNECO lettre 1/21/98 (B16958)13cginning with the December 1997 ECP monthly report issued Response is adequate.
Indicator and desa contained in the ECP Monthly vs. hne management in the monthly en January 1998, information was included as to why Cls did not use line management Guidance Report now provides a-W with appropriate report uill be issued and controlled, equivalent to ECP Manual. reflecting this ECP monthly practice by information.
February 27,1998.
81-21-98
- 1-22-98 CLOSED Page 30 cf 49 Revised 18-23-9s
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$4. Require concerns *nh operability or NNECO Letter I!21/98 (B16958) A CR will be imtiated per RP-4," Corrective Action Program "
Response is adequate.
l llc has reviewed Rev 3 to the manual.
reportabihty potential to be for concerns having an operabihty i Repnrt abihty potential. This will either be accomplished by Rev 3 is still unclear en the mechanics of documented on CRs.
the hne or ECP and the CR number will be reflected in the ECP concern file. This practme will be transferrms operabihty and reportability issues to I
reflected m the ECP Manual Revision 3 to be implemented by February 27.1998.
the ime organization and reconhng the actens t
taken. Rev 3 to the inanual still does not require a CR to be generased when there is a pttentied i
reportaintity or opersinhty issue.
Rev 4 to the ECP Manual requires the aw of a CR for transferrmg Operability and Reportability j
issues to line organizations. CR's are being used for this purpose.
01-22-N OM2H CLOSED
- 55. Ensure that common guidelmes are NNECO Letter 1/21/98 (816958) The common guidelmes (Joint lavestigation Guidelines) were Response is adequate.
Regulatory -
-- = B169984 se conduct an used by all orgamrations proce.smg approved for uw by NU investigation boires. The Executive Sponsor of the NU Compliance ~
assessment to enswe the J1G's are being concerns.
Group will conduct an assessrneset by January 31,1908 to ensure the guidelines are being 1..-./J was performed and documented in a
[
..3 implemented t,y organizations pocessing concems.
memo dated I/30/98 from R.V. Ahlstrand to W.
t Temple.
Guidelines have been irnplemented. Templiance Group" will track usage and discuss potential i
modifications around 3-31-98.
See trees Sa & Sb.
01-22-N 07-01-N CLQ$ED
- 56. Class #fy, count and track individual NNECO letter 1/21/98 (Bl6938) The ECP will modify its process to commence tracking and Response is adequate.
ECP Monthly Report now tracks individual issues.
issues from multi-faceted concems as countmg indindual issues as they are received. This practice will be reflected in Revision 3 of the individnl concems.
ECP Manual which will be implemented by February 27.1998.
81-22-N 07-22-98 Of.OSED i
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Date.Scurce and LHC NNECo Response LHC Evaluation LHC Effectiveness Detersmination Recotumendation
- 57. Ensure off-sitecontractor NNFCO Letter 1/21/98 (B16958) Current NU Nuclear contracts include general terms and Response is adequate.
Undu evaluation.
sequirements are implemented.
conditions which detail contractor responsibilities beyond the specific scope of work to be i
performed. liem 17 of the General Terms and Conditions. entitled Tontractor Employee laatial and fonow-up la'ters have been sent.
Protection," provides detailed requirements regarding contractor employee protections which must be assured by contractors and subcontractors. Effo.ts to ensure compliance with these contract See isem de.
provinons are in progres Requests for information regardmg pmgram status were sent to over 100 contractor organizations on October 15.1997. Each contractor m requessed to provide infonnarmn on their 10CFR *0.7 comphance program. Contractors wwe also informed of the forrnation of the Millstone Executive Review Boced which would be reviewing all discipline at or ahnve the level of wrmen reprirrand pnor to implementation to ensure, among other things, no disciphne was in retaharton for engaging in protected activity. To ersure contractors continue to place proper emphasis in this area, NNECo will transenit a letter to its corttractor organizations on an annual basis. The letter wdl remind them of their responsibihties for employee protection against retaliation and for iA
- a tter employees and subcontractors that ce NNECo ECP is avadable to them as an ahe~
' own path for raising safety concerns in maners involving Millstone Starmn. The irrst ar
- edt be sent to cohtmetor cagenizations by January 31, 1998 ff-22-M
- 3-18-M CLOSED 58 Modify the exit process to assure all NNECO Letter 1/21/98 (B16958) All contractors will continue to be given the opportunity to Response is adequate.
O A-13 was changed; howevcs, the exit process is contractors receive an exet interview.
have an exit interview with the ECP. Rather than requirmg contractors to receive an exit interview, not being consistently implemented.
the contractors will be asked by their employers to sign an NU form (ContractorNendor Out-processing Checklist) statmg that they:
See imm 66.
6 have been afforded the opportunity to have an exit interview with the ECP, I
do not have any knowledge of any undocumented deficiencies or concerns at Millstone Station, Imple.nentation of the Exit Process is now I
and consistent.
have been provided with a phone number and address to provide any additional information they may recollect after leaving Millgone Station.
This NU form is retamed by Millstone secunty. This process is currently being implemented and the above NU form will be incorporated into a revisen to procedure
- Procurement and Admimstration of Contratter Services"(OA-13) by February 6,1998.
61-22-98 99-82-98 CLO5ED i
- 59. Improve LCP file security m Annex NN ECO tstter 1121/981886o58) To improve file secunty, effective November 13,1997, the Re ponse is adequate.
Response has been L.,b.C as verified by 2.
Annes I and 2 doors are kept locked at all times. Signs have been placed on both sides of the observations of annex's being locked.
Annex doors to ensure the doors remain ticked for file secunty purposes. Guidance will be issued.
e,d controlled equivalent to ECP manual, reflecting these ECP file secunty practices by February 27,1998.
81-22-98
- 3-28-M CLOSED j
6
- 60. Implement ECP stafTquahfication NNECO letter 1121/98 (B16958) ECP staff qualification and documentation were reviewed Response is adequese.
Director of ECP has wrinen a.a! signed reuew and documentaten durmg a foerth quarter self-assessment Deficiencies regardmg the Director's approval of qualificaten records. -
t requirements.
contractor investigator quahfications have been corrected. To ensure that the ECP is in compliance t
with ECP staff goahfication review and documentation, all other deficiencies will be cormted by February 27.1998.
81-22-98 03-f9-98 CLOSED
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(
Mecominiendation
{
- 68. Manual si.ould clearly derme NNECO letter 1121/98 (516958) The ECP has heightened the awareness of their investiptors; Response is adequese.
Under evaluation.
required chronologicallog entries however, the ECP will provide guidance in Revision 3 of the ECP Manual to be implemented by Rev 3 to the monumi delinesses C 4# log (e g, employee contacts, CR 8's, February 27, I 998, regarding chronological log entries.
reqdrements. LHC Review of 27 recent files tnage )
verified vast imprevements of the logs.
81-22-M 01-22-N CLOSED y
,L 11-l3-97 Comprehengive Plas
[
Effntiveness
- 62. NNECo management must prnvide NN ECO Letter 1/21/98 (816958) NNECU management recognizes the need to provide leadership Commitment is appropnate..
leadership to correct problem areas in to currect publem areas in a timely manner. To accomphsh this, the Protlem Area (PA) Plan will l
e timely manner.
be formalized, and controlled, by February 19,1998, so ensure a consistent and thorough approach in resolving the pas snd will include the following elements:
Recerve senior management review to ensure that ewh issue is bemg appropriately addressed a
Ensure that each PA is prioritired. and that Action Plans are mor.itored and effectiveness a
reviews are performed.
Speci$ that the PA Action Plans are nightly controiled to ensure confidentiahty.
82-l7-M 88-26-M CLOSED 61 Develop improved mechamsms for NN ECO letter 1/21/98 (816958) Effective December I.1997, an organizananal change was Response is adequale.
LHC Effectiveness Determination: The meetmgs communicatmg. coordmating and made, which among others, changed ECP to report from the Oversight Organization to M lt referenced in the NNE' response have improved i
effectively artmg on information Brothers.Vice President-Operations and Execuuve Sponsor of the SCWE. M 10 Brothers has communication and coordmance ofinformatmn t
between ECP, EWP, SCWE group included ECOP in daily meetmgs with the SCWE and ECP senior staff to discuss issues related to between these group Coordination of actmns and and managemem.
SCWE and problem areas resolut on. Typecal attendees at the daily meetings are the Executive effectiveness of actions still needs :.,-. ~
+
Sponsor-SCWE, SCWE lssue Manager, liuman Resources representative, Director-ECP, ECOP See farm 49 A 32.
Chairman, and various personnel frorn the represented groups. These act ons have facihtated the Will be tracked under hem 82.
communicatens among SCWE, ECOP, and ECP stafE 8142-M
- d-86-98 Q,93E_D1 l
- 64. Narrow ECOP activines to focus on NNECO letter 1/21/98 (816958) Based on meetings held with Bruce Kenyon on November 4 Response is adequate.
LHC has reviewed the revised scope of ECOP's greatest SCWE needs of the 1997 and Little Harbor Consultants on November 21.1997. ECOP is focusing its efforts on IIIRD oversight activities and finds that it is consistent organization in a timely marmer.
issues and reporting or a real time basis.
with the recommendation.
p Additionally, the Executive Sponsor of the SCWE has included ECOP in the daily SCWE i
meetings, fuethenne the coordmaten of the ECP.SCWE team, and ECOP activities. During these meetings, the Executive Sponsor-SCWE has requested ECOP to investigate areasrissues that need immediate attention te g, ECP satisfaction inden).
81-22-98 1848-98 Q&iED
- 65. Communicate ECOP findmgs and NN ECO Letter 1/28/98 (B16958) ECOP is communicatmg its findmgs (predominantly) with the Response is adequere.
LifC has reviewed ECOP*s protocols and found recommendauons on a real time basis SCWE team as they are discosered. Similarly, information is shared with Human Resources on them to be acceptahic.
to ECP.the SCWl group and hne is1ues relatmg to their functions, while information such as cost control center specific survey data management so they can act on the are shared with respective Ime officers soon after survey completion.
results.
The dailv SCWE meetings have provided a forum for timely exchange ofinformation among the l
ECP. SCWE team, HR and the ECOP representarrves.
81-22-M 18J8-M CLOSED 1
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- 66. Provufe additmnal training for NNECO Istter 1121/98 (B16958) NU is requiring first line supervisors and above to participate in Actens taken to date have been good Imt LitC Effectiveness Determinatierr The trammg managers and supervisors that a three-session traming program on SCWE-related topics including recogniang and addressing are not enough. Additional trainmg and provided to date has been good. There is a need to adequately covers protected protected activmes, chilling effect, and retalisten issues. Session I classes were conducted in support for managers to manage ar.J lead provide the same trainmg for any new supervisors actmises, retahatmn, and "chillms November 1997. This sessmn covered the essential elements of discnmmation and management is necessary.
and managers is a timely manner. There is also a effect" actions to avoid, detect, and respond to such claims. Session 11 training was conducted in need for continumg training for manalters and December 1997. This session began with a diagnostic test and fundamentals were temforced, and supervisors ident:Ged weaknesacs were remediated. During this session, participants were also provided See frems 75 d 81, trammg in confhet resolution and effective listening skills. Ten case studies were available for Will be tracked under item gl.
discussion. One of these cases was developed to include issues minted to MOV and traming area issues. In additen, lessons learned from the MOV issues have been commumcated to employees through formal training courses, NU News Releases, and all-hands meetings. Finally, session III is scheduled for January 20,199g. This sessma will take place in a large group setting. and site management will address how the pnnciples and attnbutes of a SCWE are bemg enhanced and maintamed at Millstone.
Collecuvely, the traming package ts designed to provide the tnanagement team at Millstone Station mith the necessary information te: appropriately respond to employee concerns, minimize the potential for discrimination, prevent or mmgate chillmg efTect within tl* wo force, and to 82-17-98 84-86-98 CLOSED improve the safety conscious work environment.
- 67. Improve the ECP traming segment NNECO 1 tier 1/21/98 (B16958) The number of persons presenting the ECP segment in the Response is adequate LilC Effectiveness Review: The ECP tmming mctuded in *wanagmg for nuclear MFNS has been reduced to improve the consistency of delivery of the lesson plan message.
segment included in the *Managmg for Nuclear safety."
Whenever possible, the ECP Director or his senior staff will conduct the training. Additionally, the Safety" training course has becn improved. There lesson plan (FS 0004/I'S 0034) will be improved by February 27.199g. This will be accomplished is a new lesson plan and the consistency of by mcorperstmg lessons learned and other developments dunng t%c past year.
presentation has improved. This same segment is NNECe 1stter 2/27/98 (Bl7087) changed the commitment date to 4/9/98. This schedule change also included in the " Nuclear Acclimatization" is wcessary to allow cornpletion of the review process by the recently reorganized Nuclear course that is given to employees.
l
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[
Traumg Department-
- 68. Resume employce training on SCWE NNECO letter 1/21/98 (B16958) The Nuclear Acchmatization trammg course restarted on This training includes an ECP training LIIC Effectiveness Review: ne ECP trainmg and LCP.
November 24,1997, and is being presented to facility perscemet as a complement to Managmg for segment which is appropnare. It does segment is included in this course and has been Nuclear Safety and Civil Treatment for Managers received by line management. De Nuclear not, but should contam training on improved. Some references and ties to SCWE Archmateatmn training course consists of two parts:
SCWE expectations for employees.
have been added by the training personnel. This l
Parmership P yond 2000 content should be reviewed by SCWE personnel ta Ciul Treatment for Employees determme ifit adequa4 conveys the desired SCWE expectations for employees.
o 81-22-98 g4.ogn Page 34 of 49 Revned I t-23-98
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ITPOP 12-10-97 (97-0055) ECF Files 4
i Addressing 50.7 Issues 69 Reopen and remvestigate ECP files NN ECe letter 19938 (Bl6949) Files I42,262 & 313 will be rev:'-ed and reinvestigated as Response is adequate.
1.HC wHl review these files when avadable.
142,262, and 313. These files were necessary. To resolve any noted deficiencies related to adequec) < -mh will be t
closed on the basis of ECP or HR compiered by 2/27/98 investigatmns into allegatores of NNECe Letser 2/2738 (817987) changed commitment dase to 5/188. The proposed schedule retalisten that were inadequate or change applies only to ECP files 142 and 262. The schedule change for ECP file 262 6s neceswy incomplete.
to expand the ECP review to ensure that the results of the mvestigation are adequate and complete.
The schedule change for ECP file 142 is necessary because the concened indivuhrd has been on medwat leave since January 14. I A98 The review of ECP fHe 313 and cirrectwn of deficiencies was comp;eted on De-ember 22,1997.
- A2AN JJ.2A9g CLOSM
- 70. Madify the ECP intake procedure to NNECe 1;rttee 14938 (B16949) A preliminmy determmation of whether a concern contams an Under evaluation.
(Jnder evaluation.
require a preliminary determinsten element of potential retaliation (i.e.10CFR50 7 violation) is now being made in the Triage process Rev 3 to the manual requires determmation to be of whether a concern contams an This practice will be reflected in Rev.3 to the ECP Manual mhich will be implernented following made at Triage and documented on form ECG4.
element of potential retaliation,i c.,
the Triage of the ECP staff by 2/27M8.
10 CFR 50.7 violations.
92-7 7-M
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- 71. Where it is determined that a NNECe letter 199/98 (B16949)The ECP has instituted the procuce ofinitiating a chilling effect Process dermed is adequete.
(Jnder evahsation.
L f
potential eiolation of10 CFR Sf evaluation at any point in the process where it is determined that a concern could involve a Rev 3 to the manud reflects requirements to k
exists the ECP anser the SCWE potential violaren of 10CFR50 7. This practice will ha reflected in Rev. 3 of the ECP Manua!
perform a chilling effect evaluation.
I effort insures that an immediate which wdl be implemented following Triage of the ECP staff by 2/27/98.
j Nhilling effect' evateauon is conduoed.
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- 72. Vice President of Osmight NNECo Letter 12/29S7 (B1685I) EKective December I 1997, the ECP began reporting to Mike Response is adequate. Recent EITective, No further evaluation required.
contmues to demonstrate less than brothers. Vice President of Operations. Mr. Brothers has demonstrated and will continue to organizational changes also impact the espected vmbihty and support of demonstrate his support for the ECP through interactions with the ECP staff. The following relative importance of the issue.
ECP Program.
information relates to the support of the ECP by the Vice President of Nuclear Oversight (VPNO) when the VPNO had responsibility for the ECP. LHC mm... m..Ad in its futy 22,1997 presentation that NNECO increase the presence and partierpation of the VPNO in the Ernployee Concerns Program Regardmg the VPNO support of the ECP, the NU response described the acten by the VPNO in eclievmg the Director. ECP (DECP) of the requirement to ottend several permdic statimeetmgs not directly retsimg to the E CP. That had a encar and significant impact on mcreasmg the day-to-day s etailed involvement of the DECP in ECP activities. The VPNO 6
i promptly and favorably responden 4 all requests for additmnal ECP resources and frequently inquered if there were additional needs or other ways he could support the ECP. Furthermore, the VPNO mas :he initiator of actions to formulate improved performance indicators and was intamately involved m their development. In summary, the VPNG involvement in and support of the ECP =as clearly demonstrated by these examples. The NU response also desenbed the personal mteraction between the VPNO and the ECP staff and the inclusion of the ECP staffin the VPNO monthly Nuclear Oversight all-hands meeting. Those measures contmued and the WNO periodically attended ECP meetings in addition to the WNO monthly all-hands meesmg. Those were part of the overall VPNO effort to get m the field to keep abreast of thmgs important to his statT. to demonstrate support, and to strengthen trust in senior management.
- 1-26-98
- 1-26-98 CLOSED
- 73. LitC preltmmary review of closed NNECo Letter I2/29/97 (BIG 851) The closure actions related to the 155 Comprehensive Plan Response is adequate.
actmn etems does not demonstrate acten items were taken based on the determmation that the stated actions had been accomphshed.
adequate effectiveness measures.
Implementation etTectiveness assessments will be as described in the response to Observation 3.
De effectiveness of many of the actions related to improvement of the ECP have been assessed by LilC durms its review of the ECP. LilC made m....
. 3.: ions when shortcomings were identified and these recommendations have been or are being addressed by NNECo.
NN ECo Letter $(I4/98 (DBA-98443) Effectiveness of selected elements of Employee Concems CP addreswd in Self-Assessment 98-SCWE-l of March I3,1998."
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Recoinniendation 74 No scheduled self-assessment on NNF.Ce 1sttee 12/29/97 (Bl60SI) The initial self-assessment of the Comprehensive Plan Response is adequate, Self-Asses.:nent 98-SCWE-I of 3-13-98.
[
Comprehensive Plan effectiveness..
implementation effectiveness commenced on November 3.1997, and was completed on November 22,1997. This was a joint effort netween lluman Resources and ECP and assessed seventeen Self Assessment (SA) scheduled for selected Comprehensive Plan action itens. The report was issued on December 5,1997 and 3/13/98 has been performed but not,
r revealed that corrective actions may be a tessary for several of the items to assure implementation teleased.
effectiveness. The resuhs of the self asseunt witi be reviewed collectively by ECP,ifR, and SCWE staff by January 5.1998 and assignments made for any actions deemed necessary. The overall responsibility for the Comprehensive Plan was trarsferred from the ECP to the Safety Conscious Work Favinmment staffin November 1997. The issue Manager for the Safety j
Conscious Work Environment will conduct a self-assessment of the hne :
- portion of t!w 4
Comprehensive Plan by January 31,1998.
NNECo Exteer 1/27/98 (817916) Conduct self-assessment of the line management portion of the CP action items by 1/31/98.
p NN ECa treter 2/27/98 (Bl7087) changed the -_-
^ date for con 6 cts self-assessments to p
3/13/98. This schedule change is necessary to allow the results of the Fe wry f E 1998 SCWE opimon survey to be factomd into the ongoing self-assessment of the hnc stenagrAicnt portion of the Comprehensive Plan Action Itemt 8d-86-98 87-81-98 ROSED 127-98 SCWE i
- 73. NNECo should continue to provide NNECo lettee 2/27m8 (DB498-822) NU is committed to provide training, mentoring, and Response is adequate Will be tracked under item 81.
trainmg. mentoring and assistance to assistance to first ime supervisors and above in the area of harassment, intimidation, retahation, managers in further development of and discrimmation lillR&D). These traming programs are ongoing activities. NU first hne 4
their understandmg of retahation, supervisors and above at Millstone Station were required to participate in a three-session training harassment and trtimidation, program en SCWE-related topics includmg recognizirig and addressing protected activities, rebuildmg a cuhure of trust, and the chillmg effect, and lilRAD issues. Furthermore, ECP has made IliR&D training a high priority r
cntical nature of timely responses to since Apnl 1997. Courses which dsrectly or inducctly address this topic were conducted in April, I
cmployee questens and concerns.
May, June, August, October, and December 1997. Additional training was conducted on
?
December 17,1997 for the ECP staff on IllR&D issues [please see the response to Recommendation 3 in Section I in our letter to you Bl6958, dated January 21,1998) In addition f
to these trammg courses, NU intends to: 1. Modify the Plant Access Training (PAT) r: incorporate t
the sahent points from 10 CI'R 50.7 topics. and SCWE expectations. All new employees and
[
contractors must take this course and pass the required examination before being badged for site access. In addition. all employees and contractors are required to take this course on an annual basis. This will be implemented by March 10,1998 2. Communicate lessons semmed to site population on an ongoing basis in the areas of SCWE. Executive Review Board, and resolution of
[
problem areas. 3. Incorporate elements of 10 CFR 50.7 traming into new leadership and ongoing traming programs for new first Ime supervisors and above to complement the existmg Civil Treatment for Managers and Managing for Nuclear Safety courses. This will be implemented by
{
April 24,1998. NU beheves that the above training will provide the management team at Millstone with a thorough understanding ofIflR&D issues. These courses will be conducted, as needed. during 199R.
4-57-98 d-81-98 CLOSED
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- 76. The lluman Resources and Legal NNECs letter 2/27M8 (DBA98422) The llaman Resources (llR) and Legal support functions Response is adequate.
support functions must provide have added several, senior-level professionais to assist Millstone Station ime management. With knemledgeable and esperienced respect to the area of flR, Ms. C W. Gnse, Senior Vice Presulent and Chief Admmistrative professionals to assist ime Officer, has been on-site full time smce January 26,1998. Ms. Grise has broad corporate management in achiesmg it's goals emperience, mcludmg IIR and legal. She is currently concentrating on expediting resolutions to for the safety conwious work outst mdmg employee relations issues and on redeploying support resources from corporate HR to envmmment.
Millstone llR to assnt the MiLtone flR functmn in addressing jobrade, policy and pay issues.
The Legal funcien has designated two senior attorneys to support line management at Millstone Station. Mr. G L Edgar is a senior partner in the law firm, Morgan, Lewis & Bockius, who heads the firm's energy practice. Mr. Edgar has extensive expenence working in the nuclear industry and has amsted numerous other licensees who had performance issues. Mr. G. Garfield is a partner in the law firm Day, Berry & 54eward, who has acted as Special Nuclear Genera! Counsel for NU siene March 1996. In that capacity, Mr Garfield has been responsible for management and coordmation of NVs nuclear legal matters. Mr. Garfield has worked on Millstone-selated issues for over 25 years Together, Mr. Edgar and Mr Garfield will provide full-time support to Millstone Staten ime management. IIR and Legal have taken several additional steps to ensure an integrated approach to solving employee relations issues. For example, HR and Legal participate dat in the 8 00 a m. SCWE meeting with representatives from SCWE, ECOP, and I CP to coordmate activmes to address emerging employee issues. Legal and IIR participate in the ERB Also, the first of two off-site ilumen Resources workshops was held on February 6,1998. These workshops are intended to address integration. staffmg needs, and roles and responsibilities. A joir a llR/ECP stafY meeting was held on February 18,1998 to begm discussion on the transfer of filR&D and other IIR related investigstens in en effective manner A furtherjomt dTort is the
. sr. formation sharmg initiative undertaken by ECP41R/ Internal Audit / Security and Environmental Safety and 14calth. Fmally, consistent with these specific actmns and as a longer term solution to inteFratmg work on people issues, the reponmg relationship of the Employee Concerns,iluman Resources, Safety Conscious Work Environment. and Tramms have been consohdated under Mr.
D. R Amerme, VP-Iluman Services, who represents an officer-level resource being brought to beni on os crati people issues.
441-98 10JS9e CLOSED
- 77. Lme management must meegrate NNECs istter 2127/98 (DBA98-012) As discussed in our response to Recommendation 2, semor Response is adequate, these support resources in order to representatnes frorn the Lepal and ilR Departments have been attendmg the daily SCWE meetmgs timely resols e issues or concems.
to improve coordu aten.
4-01-98 d-#198 CLOSED l-27-98 Employee Concerns Program 78 The ICP should contmue to develop NNECs Letter 2/27/98 (DBA98422) In additmn to the IllR&D training that has already been Response is adequate Training provided was very good. Subsequent and demonstrate Ws abiltty to prouded to ECP personnel, arother training session will be provided by March 5,1998. The monitonng by 1J1C has determmed that ECP is effectively resolve employee purpose of this trammg session is to enhance the uniformity and thoroughness of ECP now performing acceptably well in this area concerns of retahaten mvestigations into concerns levolving alleged harassment, meimidation, retahation, and discnmmatmn
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- 79. The LCP should develop with the NNECs letter 2/27/98 IDBA98-022) The ECP should develop, with the SC%E organization, a Emergency response protocol has been LitC willevatusse implementation.
ECOP organizatien, a response response protocol to tilRD allegehens that provides management with
,m..
a.i.: ions and developed.
protocoltoIIIRD allegations that assistance in those situations that require immediate attenitori.
provides management with Response is adequate.
recommendations and assistance in those setuation
- d-86-N
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- 80. De ECP should coiwave to provide NNECs Letter 2/27/98 (DBA98-022) The ECP has made significant strides over the past three Re ponse is adequare.
Based on LHC contact with individuals who have i
traming to the ECP en mterpersonal months in emproung its -......_.%.; with concerned individuals. We have described steps we used the ECP, this area contmues to improve.
I skills and esist on regular have taken in recent ev....w.J;..;; with Little Harbor Consultants (NNECO letter B16958,
[
commumcations with concemees_
Section I, response to R-...
./ ; ion I. dated January 21.19981 One of those steps was more frequent and regular communications with concerned individuals. The Director of ECP is continuing to emphatically express to the ECP statT his expectation for frequent and regular commonwatens with concerned indiv6dusis. Although we see improvement in the level of l
satisfacten of concemed individuals with the services provided by ECP. we recognize the need to be vigilant m this area and further improve our interpersonal skills. To that end, a presentation on enhancing interpersonal skills is presently planned to be conducted for ECP invesugation personnel by March 5.1998.
4-8f-N 87-d!-N CLOSED 3-20-98 ITPOP 98-0815 t
Bl. SC%I training must be provided to NN ECs Letter 4/28 /98 (DBA 98-036) NU First Line Supervisors (F1.Ss) and above have been Response is adequate.
LIIC has rnonitored irnplementation of the SCWE i
all supervisors and managers. This required to enend the mandatory SCWE trainirrg programs. About 95% of these personnel have training andof the subsequent performance of I
mcludes t ainmg for all new taken the required courses. NU has established a special training program for the new managertal and supervision. LHC is satisfied that
^
management Personnel. The pmgress personnel, employees and contractoes The new FLSs and above int required to:
the current traming program,if maintamed,is t
made withm the management force is
- Take the new Plant AccessTrainmg (PAT) course and pass the required exammation. The a;tequate.
too tenuous to rely upon for new PAT course has incorporated the salient points from 10 CFR 50.7 sopics and SCWE continued improvement or to avoid espectations. This new PAT training course sta ted on March 10,1998, setbacks that are inevitable with new
- Go through the Quick Start video'on SCWE and read the SCWE Handbook; and management personnel trained in the
- Take the required SCWE courses within 90 davs of the date of their promotion or being spec:fac sensitivitees of the Millstone hired as a new FLS and above.
unrk enuronment.
Furthermore, matenal frorn the previous SCWE courses has been incorporated into the Managing for Nuclear Safety (MfhS), Civil Treatment for Managers (CTMk and Emplovce Relatsons h
Trammg(ERT) courses. While performing the modifications to these courses. the new ERT t
matenal received the bulk of the change. All new FLSs and above are required to take these courses as part of their teminmg. FinaHy. a memor tan espe tenced member of NNECo management team) will be assigned to each new FLS and above for guidance until they have completed their traming programs successfully.
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- 82. NNECo must establish a formal NNECa Letter 4/2 tMS (DBA 984M) NNECo has established a protocol for govemance of Response is adequese.
Protocol is established and :;4...i.;
j protocol for governance of the interactmns among ECP. HR. and StWE to respond to rent time events at the Millstone Station.-
interactens between ECP. IIR and.
The NNECo Raprd Response Protocol SCWE to respond to rent see events
- Provides guidance on maners requinns immediate response as opposed to normal in the workplace. The development business; is driven by enggermg considerations wtdch address immediate poeential for 10 CFR 50.7
)
of a protocol, which is a repeat 2
recommendation, will be of chilling efTect; I
Clearly defines the nsignments and responsibilities for line management. SCWE. IIR.
sigmficant value in respondmg to a
allegations of retahahon, as well as ECP, and ECOP; and Provedes the mechanism for promulgation oflessons learned as well as impa-mentation of mitigating any adverse cucun Ances to incidents requirmg intervention.
corrective actions.
4-24-N 4-24-N CLOSED
- 83. NNECo management must assure NNECa Letter 4/21/98 (DBA 984M) NNECo agrees that the departure and transfer of several Response is adequate.
LHC wdl monitorimplenwntation.
that recent ECP stafrmg key people must be addressed promptly. On March 22.1998, we filled the position of ECP requirements, resultmg from the Investigations Manager with an NU cmployee. This mdividual has considerable experience in the departure of several key contract area of mvestigatens. lie has seven years experience in directmg and pc-forming special investigators and the transfer of John investigations for Ntrs Intemal Audit Departrnent. Since September 8,1997, he has been Streeter. must be addressed pro nrtly.
reassignedo the Mdistone ECP to conduct investigations and has been cualified as an ECP
[
Investigator. %e have also created another management position within the ECP. This second t
management position. ECP Mar ager of Protects, has recently been posted to have the position filled with a permanent employee. This is the position that Mr. Streeter had been fillmg. Unt I a
[
candidate is selected to fill the position permanently, a qualified NU employee is temporarity fitting
[
the position.
4-24-N 97.#1.M C1OSED 44 98 Employee Canceras Program
- 84. Requere concerns with operabihty NNECo Letter 4/28/98 (DRA-98439) Revision 3 to the Employee Concerns Processing Manual Response is adequate, The lasest revision of the ECP Manual provides for and reportabihty potential to be currently contams General Note 2, which states:*'If at any time durms the ECP process an appropname mechanisms to assure that CRs are cxumented on CR's.
operabihty#eportabihtv (OR) issue is suspected. the ECPR [ Employee Concerns Program written when appropriate.
i Representativel shall assure a determinsten is made, a Condition Report (CR) is written (etther by
[
the Ime or ECP) if necessary, and the OR results rettected in the database."
j This General Nots will be revised and strerigthened to state:"If at any time during the ECP process en operability /repnetabihty (OR) issue is suspected, the ECP shall initiate a CR in acenrdance with RP-4 Torrective Actens Program " to insure that the appropriate operabihty/reportability screenings are performed. A copy of the CR and any operabihty/reportability screens shall be retained by the LCP and placed in the Concern File."
Additenally, the intake Form. ECF-I; the Triage Form ECF-5-2; and the Investigation Form ECF-6 wit! be revised to mclude the line items requesting the CR Number and the results of the operabitetyr portability screens. if applicable.
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- 85. Managementand SCWE should.
NNECe 14tter 4/2s/98 (DSA-98439) Since December 1997, the Employee Concems Program Response is adequate.
incorporate the information almi (ECP; has been collecting data why employees choose the ECP instead ofline management for i
why employees chose ECP mstead of concern resolution. The results are induded in the ECP reports w hch are presented to the Officers kne managernent and take on monthly basis.
apprornate corrective actmns.
There are five categones why employees choose ECP instead ofline management. These are:
- Fear of retalisten; this reflects a concerned indrviduars belief that he'she would be retaliated agamst either by management or by co-worker if a concem was openly raised This has been the i
area where we have spent most of our focus smce this is the issue that we feel most impacts the
}
SCWE.
i
- Management incapabic; this reflects the concernee's opinion that either hiWher line management staff is unable to resolve a concerns or the management system is incapable of successfully addressing a concern.
- Management s the concern: this means that the actions of the tme management cause the i
concem.
Management refusal to act: thes refkcts the concemee's percepten that management is awate of the concem issue and has decided not to take action.
- Others Concems whkh can not be placed into any of these rive categories are documented as "others" This has constituted about 50% of the issues.
l The ECP March 1998 analysis has indicated that for the rwst time in many months no concemee stated that they failed to use management because of a fear of retaliation. This shows that an improvement in our SCWE culture. The same analysis shows a downward trend in the nember of 6
concemees mim chose to take their concems to ECP instead of their line management. The SCWE team miti contmue to analyze the data related to the use of ECP instead ofline management t
throughout 1998. The goal is that by sustaining a SCWE at Millstone empicyees feel free to raise their concems with their ame management instead of ECP.
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Reconimendation g6. Implement the exet process NN ECo Letter 4/28/98 (dea-98439) 7-8 Exit Process for Terminating Contractors. Security Response is adequate.
Montering by LHC has determined that NNECo's effectively to assure all termmatmg Department implemented a process in November 1997 to ensure that a!! contractce personnel who exit processes are adequase and are being employees and con:ractors are leave the company have completed the necessary forms associated with the"out process." All irnplernented acceptably processed in accordance with personnel must relmquish thcir badges upon termination of their employment at Milistone. In procedural requirement *.
addition, contractor companies rnust furnish Security with a termination form and a completed outprocessing checklist (Attachment 7 of OA 13. Rev. I) for their employees. If Secunty does not receive a badge or receives a badge without supportmg documentation, i e., checklist or termmatior form, a phone call is made to the company for the information. If documentation is not received in day's end, a request is sent via fax to the company to furnish the information If the company does
[
not respond within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, secunty agam contacts the company by phone to request the informaten Past expenence has shown that most companies respond after the initial phone call.
As a result, Secenty has only had to send two requests smce the beginning of January 1998.
Secenty files the completed forms upon receipt and forwards a copy of the outprocessing checklist j
to Contracts as well as to Computer Services, who deletes the employce's computer access.
7 2 Exit Process for Employees. As part of the protocol established for outprocessing employees l
who terminate from the Company or who transfer from the nuclear organization to another part of the Company, the Employee Concems Program (ECP) department has been provided on a monthly bases a report directly from the NU personneltpsyroll system (NUCHRIS)of the terminations and j
transfers fror i the Millstone nuc! car organization. As defined in NUP 20. Termination of i
Employment,Ime managers are required either te schedule an interview with ECP or ask the t
employee to complete the SCWE fum. Similar requirements are now being intented into NUP 12, Employment, that will address transfers from the nuclear organization.. The supervisor forwards the completed forms to Central Records in Berlin. Once a month,the copies of the forms are batched and sect to the ECP department who matches the forms received to the termination / transfer report. Berlin Records files the completed forms in the personneljacket.
Individuals without completed forms are sent SCWE packages directly to their horne address by the ECP department. This pmcess has been communicated in To The Pomt as well as emphasized by the Vice President ofIluman Services in his presentation on SCWE to Millstone management and supervision and by the HR Business Parmers mhe attend local staff meetings.
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- 87. Assure consistency m use of jig's NN ECo tetter 4/28/98 (DB4-98439) The primary means for assurmg consistency in the use of Response is adequare.
through funher guidehne dermition the Jomt investigation Guidelines (IlGs) is the oversight provided by the Cornpliance Committee.
and trammg.
This Commmec meets approximately twice monthly to 6:scuss, among cdct matters, common mvestigstens and implementation of the JIG and the associated systeri Each department identified in the J1G as having responsibihty forjoint/ shared investigstions b represented ca the Committee whwh is chaired by the Vice President. Environmental, SafePj, and Ethics. Since the J1G and the Joint investigattve System (JIS) are relatively xw, we have and will continue to update and modifs them as we gam expenence or identify the need to chmge/ enhance portions of the investigative process. In fact, such changes are presently bemg snade imed on the expenence we have gained sece December 19,1997 and we illy expect %ose ;hanges will be completed on or before the July 1,1998 deadline. Supplemental traming ;s bemg planned and will be offered to JIG and JIS M4-98 p?.#J-98 CLOSED uwrs 88 Continue trainmg of FCP NN ECo Lettee 4/28M9 (DBA-98-039) Trammg will continue to be provided to the ECP Response is adequate.
investigators through use of critical investigators. Cnucal case analysis is conducted on a monthly basis, as previously committed to analysis.
LIIC, and the results/ lessons learned art bemg communicated to the ECP investigstors. For example, the results of March monthly review of case files were dscused during an ECP staff meetmg held on Apnl 9,1998. During this mectag, the ECP management commumcated their espectatwns regarding the need to provide a basis for each conclusma reached and that all conclusens need to be addressed. Specincally, the March case file review noted that mvestigators were stating that. "do chillms effect was reported and none was observed." Ahlumgh it was apparent that the subject concern under investigation would not lead one to beheve that a potential chillmg effect exists, there is no basis in the report for such a conclusion that"none [chdlmg efTect]
was observed." nis statement appears to be a standard (t%erplate) statement in the ECP case files. Therefore, the investigators were advised to modify the statement to accurately reflect what was observed or not obserted. ECP will continue this practice of entically reviewing case files and sharmg the lessons learned with the ECP investigators. In addition, a summary of the lessons learned from the iniual renew of sixty-four " Alleged 50.7* case files will be developed by May 30, 1998, and will be shared with the investigators.
M4-98 p?-dJ.98 CLOSED 89 Reexamme 15 clo=ed fiscs 6dentined NNECe Letter 4/28/98 (DBA-98 439) NNECo will re-examme and conduct additional by LilC.
investigatmns, as appropnate, for the subject case files. We have conducted an initial review of the subject case files and have determined that addituni actions are not required. E'ach case file will be re-truewed in accordance with the ECP prionty process and the ECP wd! utthre its normal 50.7 evaluation process to determi'e their classificauon (e g., substantiated, indetenninate or r
- ? 8J-98 CLOSED unsubstanuated) and will rmufy LilC of the results.
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Recommendation
- 90. Conduct vigomus self-assessments NNECe 1stter 4/28/98 (DBA-98439) An independent assessment will be conducted on the Response is adequate, on new mvestigations into retahation
" Alleged 50 7" case files that are closed or resolved. His independent assessment will be allegations utetuii g revised 50.7 conducted on a lu-monthly basis (i c., every two months) through the end of the year (1998). In 7
analysis addition, effective April 2,1998, the ECP added a new form to the ECP Processing Manual This i
ne forrn, ECF-9." Potential 10 CFR 50.7 Violation Esaluat on," requires the ECP investigator to i
conduct an evaluation to deiermine if the " Alleged 50.7" issue is either substantiated, indeterminate or unsubstantiated. Subsequent to the investigators evaluation, ECP Manager of Projects is
[
required to conduct a critical teview of the investigator's evaluation for concurrence 5-0d-98
- 7-#1-98 CLOSED
- 91. Develop a process to assure that NNECe tatter 4/29/98 (DhA-98439) De Employee Concerns Program will develop an Response is adequase.
i lilRD issues surfacing outside the Admmistrative Control to establish a formahred process for the capture ofilIRD issues surfacing ECP, the exit process or other from outsule the normal ECP, exit processes or other estabhshed mechanisms. Concerns ident2fied estabbshed mechanisms, are captured through this process will be handled via the normal Triege and Investigation processes. This new and dealt with.
Admmistrative Control will be developed by May 15,1998.
87-#f-98 1143 98 CLOSED i
44-98 Corrective Action Prograan
- 92. Senior management should NN ECo letter 4/2&98 (DBA-98-839) All the Unit MRTs are chaired by the Manager of Response is adequate.
participate in and maintain oversight Corrective Actions. De Unit 3 Umt Director rcuttnely participates in the Unit 3 MRT. The j
of the activities of the MRT to assure majority of the members of the Site MRT are Directors. His recommendatmo will be provided to i
it meets management expectat ons.
Unitsi and 2 Unit Directors who are responsible for designating nvembers of the Unit MRTs (RP4, i
Attachmerit 9) by May 30,1998.
5-06-98, 5-86-98 CLOSED
- 93. Management should take increased NN ECa Letter 4/28/98 (DRA-98-839) While it is clear in RP4 that CR owners are responsible for Response is adequate _
f action to assure that the acceptance of the timely and acceptable re alution of conditions that " hey own, twcause okhe wwk load in the CR ownership responsibihties by certam areas during the outage this responsibehty has in.ca delegated to the 14anager of the CR owners es umformly high.
Corrective Department Upon completion of the cutage,the expectation is that the CR owners will take personal responsibilrty for their CRs. RP4 is clear on the expeciation ofissue ownership (Section I.2 and Dermitions).
5 86-98 5 46-98 CLOSED f
44-98 Site 4 Oversight Pregrams (Self-Assessments)
- 94. Strengthen guidance for identification N%FCo letter 4/28/98 (DBA-98-039) OA II, Revision 0,"Self-Assessment" was approved on Response is adequate.
[
of acceptance cntena for March 13.1998. Step I.4 4 of this new Station level"Self-Assessment Program" procedure assessrnents.
provides guidance for the preparation of *Self-Assessment Outime" and reouires hsting of
- aplicable specific performance objectives and assessment critena, such as INPO 97-002,
" Performance Objectives and Criteria," NRC Inspection Modules, and other industry entena. OA
[
h
]I, Revision 0 is applicable to all Station Groups and will strengthen our common approach to clearly idenufy the acceptance cntena for assessment. S'ep l.5.1 also reinforces assessment and
[
exammation of collected information and data agamst management expectations and appropnate l
standards. Das is also stressed in the Nuclear Training Department Self-Assessment training module.
5-06-98 5-06-98 CLOSED I
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- 95. Sirengthen the conduct of follow up NNECe Letter 4/28/98 IDBA-98439) OA II, Revision 0,"Se f-Assessment" was approved on Response is adequate.
reviews to focus on effectiveness of March 13,1998. Steps t 8.2-1.8.4 provides enhanced guidance to perform follow-up revicws.
correctne actions.
I his includes," Consider evaluating actual corrective acten performance results, use of interviews, surveys, benchmarking or Geld obsenation to assess elTectivene=s.* Also, Step I.S.4 requires the evaluator to "Reuew for evidence of sustamed irnproved performance in areas in which adverse conditions or areas for improvement were identified and corrective actions taken." These provisions for improvement were identified and corrective actons taken." These provisions in the OA i1. Revismn 0 procedure strengthen the conduct of follow-up review to focus on elTectiveness This is also stressed in the Nuclear Trainmg Department Self-assessment training module.
5 06-98 5-06-98 CLOSED 4-6-98 Site's Oversight Programs (Nuclear Oversight) 96 Enhance quantitative results NNECe txtrer 4/28/98 (DBA-98439) Under the current procedure, only observations performed Response is ad @ * -
produced by NORYP by m the two week gradmg period are included in the latest score. In this way, old data does not unplementing a scheme for time and mfluence the performanct scoring. With respect to the relative significance of observations, the significance weighmg ot'obscrtation NORVP issue lead is given discretion in determining the importance of the various observatens sheMe recenes, the relevance of the observations to the review attributes, the appropriateness of scores.
the scoring, and the relative weighting provided observations that may cover longer periods of observation or more hne products (such as AWOs) In addition, our procedure allows us to ovemde the numcrical score and assign a lower (or higher) color to reflect significant events or findmgs which occur. This is another method of"weighmg" more significant observations.
Because our current procedure already allows us the flexibthty to weigh significance, we do not intend to make any changes in this area.
5-06 98 5-06-98 Cl0$ED
- 97. Ehmmate NORVP obsersations and NNECe I mer 4/28/98 (DBA-98439) The site is moving from an entirely recovery mode to a Response is adequate.
reportmg m the SCWE area.
situation or an operatmg plant (Unit 3) and a plant in recovery mode (Unit 2). Consecuently, Nuclear Oversight is in the process of assessing the NORVP to ensure that it continues to meet the station's needs for monitoring performance. We are considering revismg NORVP review annbutes. consohdating issue areas to better reflect an operstmg mode, and shifting emphasis away from areas that have demonstrated satisfactory performance for a long period of turne and therefore can be reuewed on a less periodic basis. In addition, several areas such as SCWE may no longer need to be assessed by Nuclear Oversight. Pnor to any changes being made, Nuclear Oversight will obtam concurrence from senior management.
5 4 98 5 4 98 Cl OSED 44-98 NS4B 98 Consider reducmg number of senior NNECe 12tter 4/28/98 (DBA-98-039) Alternatives to the current membership are being evaluated Response is adequate.
managers on NSAB to reduce with the objectne of reducing the number of OfTicers currently on the Board. The timing and cumulative burden on senior extent of the changes are being carefully assessed in order not to degrade NSAB performance and management team.
to allow current membership to complete its process of affirmation of Millstone 3 readiness for restart Based on current progress, membersh p changes are expected to take place prmr to the scheduled June 25 NSAB meeting 5-06-98 5-06-98 Page 45 cf 49 Reved II-2F98
p Date, Source and LHC NNECo Response LHC Evatustion LHC Effectiveness Determination Recommendation 99 Consider means to introduce NN ECe Letter 4/28.98 (DBA-98-039) Sigmficant efforts have been made to introduce flexibility Response is adequate.
flexibility in meetmg ag-ndas to in meetmg agendas, in order to focus the NSAB on emerging issues. With the excepten of permit more NSAB focus on entical presentauons by the subcommittee chairmen and by the Unit Directors, which focus the Board on and emergent issuem most recent events and safety performance, the agenda items for the next meetmg are selected by the Board at the end of each scheduled meetmg and are modified as necessary to address.
5 06-98 5-86-98 CLOSED 44-98 Focus Areas 100_ Reevaluate SCWE " cases" as focus NN ECo letter 4/28/98 (DBA-98-039) The SCWE group has discussed the current SCWE csses Response is adequate.
- As of 8/10/98 three of the eight were closed v.ith respect to Focus Area determination. One case as currently under consideration and awaiting utiliang the Culture Survey, Leadersfinp areas Vice Presalent decision. The additional cases do not meet the Focus Area cntena. The Focus Area Assessment ECOP Survey and ECP inputs for Program is bemg moddied to include focus area cnteria and require formal documentation fo' closure.
Five (5) remain open and will be assessed for focus area determinanon. Formal documentation for the cases is being performed on the eight oper cases This documentauon will be complete by Apnl 30,1998.
closure by plan by year end.
The revised SCWE Group Process is being
=
applied consistently and is working 5-04-98 11-23-98 CLOSED Of the 33 Focus Areas:
101. Resicw 33 focus area files:
NNECo latter 4/2&98 (DBA-98-039) A revsew of the focus area files has been performed to Response is adequate.
- Problem Definihon determine the effectiveness evaluation As a result of this revicw, two focus areas (97-001 and 97-
- 25 are closed
- Adequacy of Action Plan 009) have been reopened for action plan implementation. Two other focus areas (97-020 and 97-
- 3 of the 5 Focus Areas with ininally
- Effccuveness Evaluation 003) has been reopened pending the next leadership assessment scheduled to begin May 18,1998.
compicted Action Plans awaitmg Focus From this point forward, all focus areas whose assessments have not been performed will be Area effectiveness reviews remam open considered open and tracked as such. A review of the focus area files to ensure problem definition
- Ref. Recommendation f100 above; the and adequacy of action plan will be performed on a priority basis as follows:
following is a break down of the 5 open Workmg focus areas without current accon plans signed by the Vice President cases: 4 are okay and are swaning a
Workmg focus areas with action plans signed by the Vice President assessment; 3 need a new plan; and 1
=
Focus areas with completed action plans awaiting assessment appears to have been ignored and needs This review will not be done on focus areas whose assessments indicate that the corrective actions significant work.
were effective. Addinonally, this review will not be performed on currently act!ve focus areas w hose future assessments will indicate that the correcove actions were efTective.
5-04-98 g.gf pg Of the four (4) referenced in NNECo's 102. Review effccuveness evaluanons of NNECe Letter 4/28/98 (DBA-98-039) As stated above, a review of the focus area files has been Response is adequate the 20 closoJ focus areas.
performed to determme the effectiveness esatuanon. As a result of this review, two focus areas response, one remams open; 2 were closed; and (97-001 and 97-009) have been reopened for accon plan implementauon. Two other focus areas one is still under review indicating that it was (97-020 and 97-003) has been reopened pendmg the next leadership aswssment scheduled to begin never re-opened, reviewed, etc.
May 18,1998.
5-84-98 g.yg pg Page 46 of 49 Re,med i123-98
f Date, Source and LitC NNECo Response LHC Evaluation LHC Effectiveness Determination Recommendation Review of the $ Focus Areas
- Actmn Plans 103. Determine elTectiveness of 5 focus NNECe lettee 4/28/98 (DBA-98439) An elTectiveness review is scheduled for the five areas that Response is adequate.
areas =ith templete action plans.
indicate completed action plans. Smce the LilC review, seven areas currently have action plans indicates that one was well done; one was complete and are wanmg assessment An assessment will be performed on each of these areas. A incomplete, poorly documented, yet closed; review of the non-assessed action plans will be done on a priority basis as cuttmed in our re ponse two need new Acton Plans to be efTect've; to recommendation 9.
and the last has no Action Plan, no further development and is poorly assessed, if at all.
6 5-04-98 g-g g.pg 44-98 Safety Conscious % ork Environsment 104. Management must include measures NNECe Letter 4/2fL98 (DBA-98439) The long term vision for the work environment strategic Response is adequate.
in their "1998-2000 Performance focus area The strategic focus area ecludes the fellowing overreaching accomplishments:
Plan-Work Enseronment Focus Leadership is strong; a
Clear standards of performance and accountabihties are established, Area"(Performance Plan) which a
A healthy SCWE esists, will assure the contmued The workforce is motivated; and deveiorment and demonstration of llours worked are reasonable, the custence of a self-sustainmg a
safety conscious work env ronment The strategic focus area of work environment encompasses three elements:
Leadership, at Millstone.
SCWE; and a
lluman Resources Performance.
a Each element identifies objectives, measures and targets, and actions to ensure a SCWE is mamtnined, fostered, arid improved as it becomes entrenched in the daily operation of Millstone station. NNECo has submitted a more detailed explanation of the organizational changes, the decision makmg process, and the performance measures that NNECo will use to transition from the recovery of shutdown umts to sustained power operations, while mamtaining a stabic, effective work environment. Progress to date will not bejeopardized by a rush to realign and stream!me the organ zation. The existmg extra resources and capabilities present in the organization are prudent investments that ensure SCWE improvements become entrenched and permanent. NNECo will make no organizational changes before the restart of Units 2 and 3.
19902000 Performance Ptse foe Millstone (7/24/93) contains four pages which address this recommendation, especially pages 46 and 47 titled ' Objectives. Performance Measures and Targets?
8-12-98 g-12-yg CLOSED Page 47 of 45 Revued I t-23-9s
-r Date, Source and LHC NNECo Response LHC Evaluation LHC Efsutiveness Desernaamaties Recosamendation ITFOP 11-13-98 (98-0928) ECF Files Addressing St.7 Issues 105 Impreve the quahty of ECPillRD investigaten reports, eliminatmg estraneous personal comrnentary and opineras of the inves.igators, and clarifying the basis for the ECP conclusmns.
106. Improvequality ofintemalself-assessment file reviews to provide greater depth in evaluating mvestigations of 50.7111RD issues.
107. Implement the new investigative guidelmesin conducting interviews with employees accused of wrongdoms and witnesses, including measurmg performance of investigators in conducting i
investigation interviews through use of customer feedback forms.
108. Contmue to provide training to ECP investigators on understandmg the elements of a 50.7 II?RD concern,in order to properly invcstigate tilRD complaints, analyre ti.e evidence collected, and provide logical conclu'sions in the basis for ECP tindings.
109. Develop a consistent definiten and 1
understandmg among all ECP i
investigators and staff, as well as other Millstone entities involved in ECP acuvines, of relevana terms and concepts, such as " chilling effect,"
" adverse actens" and
" blacklisting "
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r-Date, Source and LitC NNECo Response LIIC Evaluation LIIC Effectiveness Deteratination Recommendation i10. Continue self-assessment and extemal assessment activities of 50.7 It!RD files and follow through on all observatuwis and recommendaticos fwn such movities.
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