ML20210J759

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Forwards Slides,Including Textual Responses to Structured Interviews Used During 970722 & 970806 Presentation of Findings & Recommendations Developed as Result of Oversight Activities at NNECO
ML20210J759
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 08/11/1997
From: Beck J
External (Affiliation Not Assigned)
To: Goebel D
NORTHEAST UTILITIES SERVICE CO.
References
ITPOP-97-0025, ITPOP-97-25, NUDOCS 9708190045
Download: ML20210J759 (107)


Text

- ._ . .-

4 Little Harbor Consultants, Inc.

Millstone - (TPOP Project Omce P.O. Box 0630 Niantic, Connecticut 06357-0630 Telephone 860-447-1791, est (966 Fax 860-444-5758 August 11,1997 ITPOP 97-0025 David M. Goebel Vice President - Nuclear Oversight Northeast Utilities Service Company P.O. Box 128 Waterford, CT 06385-0128

SUBJECT:

July 22,1997 and August 6,1997 Little Harbor Consultants Presentations Little Harbor Consultants, Inc. (LHC) presented fmdings and recommendations, developed as a result of its oversight activities, to Northeast Nuclear Energy Company (NNECo) and the Nuclear Regulatory Commission (NRC) at a meeting on July 22,1997. The meeting was held in the Millstone simulator building and was open for observation by the public. This letter fonvards the slides, including the textual responses to our structured interviews, used during the presentation.

This letter also forwards the slides used during a LHC presentation on August 6,1997 to the NRC Commissioners at a public meeting in White Flint, Manjiand.

Very truly yours,

<).  !

Jfffn W. Beck President, LHC , g Team Leader,ITPOP Q\

100008 Attachments (4) cc: Distribution neq=nunne P

. David M. Goebel Page 2, ITPOP 97-0025 Distribution:

P. Loftus, NNECo First Selectmen Bldg 475/5 Town of Waterford Hall of Records K. M. McBrien, NNECo 200 Boston Post Road Bids 475/5 Waterford, CT 06385 W. J. Temple, NNECo Clwries Brinkman, Manager Bldg 475/2 Washington Nuclear Operations ABB Combustion Engineering Nuclear Power U.S. Nuclear Regulatory Commission 12300 Twinbrook Pkny, Suite 330 Atta: Document Control Desk Rockville, MD 20852 Washington, DC 20555 Mr. John Buckingham U.S. Nuclear Regulatory Commission Department of Public Utility Control Atta: W.D. Travers Electric Unit Mail Stop: 014D4 10 Liberty Square Washington, DC 20555-0001 New Britain, CT 06051 U.S. Nuclear Regulatory Commission Citizens Regulatory Commission Atta: P.F. McKee A1TN: Ms. Susan Perry Luxten

' Mail Stop: 014D4 180 Great Neck Road Washington, DC 20555-0001 V'aterford, CT 06385 U.S. Nuclear Regulatory Commission Deborah Katz, President Attx H.N. Pastis Citizens Awareness Network Mail Stop:014D4 P.O. Box 83 Washington, DC 20555-0001 Shelburne Falls, MA 03170 Mr. Wayne D. Lanning The Honorable Teny Concannon

. Deputy Director ofInspections Nuclear Energy Advisory Council SpecialProjects Office - Legislative Office Bailding 475 Allendale Road Hartford, CT 06106 "

King of Prussia, PA 19406-1415 Mr. Evan W. Woollacott ,

KevinT. A.McCarthy, Director Co-Chair Monitoring and Radiation Division Nuclear Energy Advisory Council Department of Emironmental Protection 128 Terry's Plain Road 79 Elm Street - Simsbury, CT 06070 Hartford, CT 06106-5127 Ernest C. Hadley, Esquire Allan Jotumson, Assistant Director 1040 B Main Street Office of Policy and Management P.O. Box 549 Policy Development and Planning Division West Wareham, MA 02576 450 Capitol Avenue-MS 52ERN P.O. Box 341441 Hartford, CT 061341441

O

i. UPDATE ONS LHC OVERSIGHT ACTIVITIES AT MIII,LSTONEj

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Presentation to Nuclear Regulatory Commission &

, NNECo July 22,1997

July 22,1997 LIIC Presentation to NRC and NNECe I h

i uw INTERVIEW QUESTION'S .

w 4 -

Attributes of a Safety Conscious Work Environment Willingness to Raise a Nuclear Safety Coneecn Willingness to Use Employee Concern

Program (ECP)

July 22,1997 LitC Presentation to NRC and NNECo 2 i

e

'SELEDTIONLDFINTERVIEWJ .

CANDIDATESJ ,y Target 250 Interviews

, => 200 NU

=> 50 Contractors Representation of all Work Groups LIIC Selected Individual to be Interviewed 5

July 23,1957 8. llc Pmentation to NRC and NNF.Ce 3 i

s :p

-CONDUCT OF INTERVIEWS w 5j Voluntary Explanation of Purpose / Process e - Ilow Feel Now/Ilow Felt ~1 Year Ago Rate Attributes 1-5 239 Interviews

=> 207 NU

=> 32 Con : ; . ors s July 22,1997 1IIC Pmentation to NRC and NNECo 4 l

t N

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F WILLINGNESS OFWORKFORCE:

TO RAISE CONCERNSi If you become aware of a problem that would affect the safe operation of the plant, would you raise a concern?

100 % Yes 0 % No Are you aware of any nuclear safety concerns that 4 have not been raised?

0 % Yes 100 % No July 22,1997 LilC Presentation to NRC and NNECo 5 WILLINGNESS OF-WORKh0RCE, Td RAISE CONCERNS What is your comfort level with respect to raising any concern?

Comfort Level for Ralsing a Concem n

50 4,3 S 40- 3.6 3.0 -

' Year Ago" June 97 July 22.1997 LilC Presentation to NRC and NNECo 6 i

3

LWILLINGNESS OFFWORKFORCE? -

TO-RAISE CONCERNS, cont'd?

Is there any condition under which you would not be comfortable in raising a concern?

=> Lack of trust in management chain o Lingering effects of previous management

=> Intimidating current management style

=> Possible career threat or loss of job

=> Discomfort with raising issues t' int impact others

= Would not like to raise issue that could go to IIR

=> Some discomfort ifit would delay restart

=> lfissue were fuzzy or not well thought out July 22,1997 l_IIC Presentation to NRC and NNEe 7 WILLINGNESS OF WORKFORCE' TO RAISE- CONCERNS, cont *d.

Ilas anyone told you that raising concerns to the NRC could delay restart?

3 % Yes 97 % No If yes, would that stop you from raising a concern to the NRC?

O % Yes 100 % No July 22,1997 LIIC Pusentation to NRC and NNECo 8 i

l

. WILLINGNESS!OItWORKFORCE1 -

w TO-RAISE CONCERNSt rost'd.

Would you take a concern to the NRC7 97 % Yes 3 % No

.: If not, why not?

3

=> Because I don't have confidence that the a 1 keep confidences; the worst violators of the entire program

=> Do not trust thern
=> Feel that I could get it resolved within NU 1 => Never again because the NRC took too long to respond and only said they were doing an investigation

, => No need to do it i

! July 22,1997 LilC Presentation to NRC and NNECo 9 CONFIDENCFiSAFETYLCONCERNS WILL BE PROPERLY. HANDLED 1 What is your confidence that if a nuclear safety concern is raised, it will be handled in an appropriate manner?

Safety Concern Handled Appropriately 43 33 4 ...

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July 22,1997 LilC Presentation to NNC and NNECo 10 i

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CONFIDENCE SAFETY CONCERNS:

WILL BN PROPERLY ANDLEDa '

What is your confidence that going this route wi!! retult in a resolution of the concern?

58 58 1.. ,,  ;-

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]4 34 lii _wE-- $ _J soir:2.i m uiC e me...io. sac.. a NtC. n l

l CONFIDENCE THAT USING:ECP:

WILL RESULT IN: RESOLUTION; Confidence that using ECP will result in resolution of Employee Consema Program 40 0 -

Year Aga" Are97 Is there any reason you would not use the ECP?

8 % Yes 92 % No July 22,1997 LilC Pmentation to NRC and NNF.Ce 13 I

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4 CONFIDENCETTH1TsDSING ECPL WILL RESULT INiRESOLUTIONS If there is a reason why you would not use the ECP, what is that reason?

=> Lack of confidentiality; lack of trust

=>No confidence in competence of staff; unprofessional

=>No clout

=>llave confidence in line management; don't need ECP

=>No different than line management July 22,1997 LilC Presentation to NRC and NNI.Co 13 CONFIDENCE THAT UsING ECP'

WILL RESULTcIN:RESOLUTIONL Are you aware of anyone who would not use the ECP?

11 % Yes 89 % No If yes, explain:

cAgent for management; "early warning system"

=> Fear of job loss / professional risk

=> Poor reputation for handling issues

=>If management doesn't handle the concern, why q expect ECP to do so

=>ECP has a chance to demonstrate success; then it may be different July 22,1997 LilC Prewatation to NRC sad NNECo 14 i

-EXISTENCE OF QUESTIONING l ATTITUDE AT MILLSTONED "Quesuoning Attitude"toward work group 4 "QuesUoning your work? Attitude *?

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How would you rate the

" Questioning Attitude" for the Site as a whole?

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av a,.- m er l July 22,1997 t ilC Presentation to NRC and NNECe 15 Efi CRITICAL SELF2 ASSESSMENT IIas "Self-Assessment" been discussed within your group?

82 % Yes 18 % No If yes,is it being done in your group?

79 % Yes 21 % No IInve you seen any useful results?

58 % Yes 42 % No July 22,1997 LitC Presentation to NRC and NNECo 16 e

.y - .- . - - _ _ _ _

i I

1 CORRECTIVE ACTION PROGRAMS I

' AT MILLSTONE o Are you avcare of Corrective Action Programs that are available to you to identify and resolve concerns?

82 % Yes 18 % No If yes, how would you rate the effectiveness of the program (s)? ,,,,,,,,,,,,,,,cm.,,,,,

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5.

1.

July 22,1997 LilC Preseadation to NRC and NNECo 17 i

CORRECTIVE ACTION PROGRAMS AT MILLSTONE, cont'dt Would you use the program (s)?

92 % Yes 8 % No IIave you ever used the program (s)?

81 % Yes 19 % No July 22,1997 LilC Presentation to SRC and NNECo 18 s

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MUTUAL TRUST?A D RESPECT,AT

- MILLSTONEL .

Do you believe that your immediate supervisor respects and trusts yourjudgment in the performance of yourjob?

96 % Yes 4 % No Rate your supervisor on a scale of1 to 5.

n. . . ...,u . .no.

88 3 4 Ia 1 .

July 22,1997 LitC Presentation to NRC and NNFCo 19 MUTUAL TR STLAND RESPECT lAT MILLSTONE, cont'd; Do you feel that you are making a contribution to the overall goals of Millstone?

93 % Yes 7 % No Do you know are are you aware of employees who have raised concerns and were rewarded or praised for it?

48 % Yes 52 % No _

July 22,1997 L IIC Presentatm to NRC and NNECe 20 i

MUTUAL TRUST'AND RESPECT AT '

MILLST'ONErcont'd.

What is the attitude toward someone who raised a concern?

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i July 22,1997 I. llc Presentation to NRC and NNECe 21

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l LACK OF CHILLING EFFEC"N

' AT MILLSTONE -

Do know of any employees who have raised concerns and suffered repercussions?

39 % Yes 61 % No Have you ever experienced a chilling effect?

26 % Yes 74 % No July 22,1997 LItC Presentation to NRC and NNECo 22 I

LACK--OF: CHILLING:EFFECT-

AT MILLSTONE, cont' dei llow do you rate the presence of a chilling effect at Millstone?

Presence of Cfillling Effect 50 i

$ 40 -

5 30-I 20 1.8 10 "Yes Ago" June 97 I

July 22,1997 1. llc Pmentation to NRC and F.NECe 23 LACK-OF CHILLING EFFECT s

=-.

AT' MILLSTONE, cont'd.

, If you are aware of a chilling effect, where is it l occurring?

l

=> Item 1

=> Item 2

=> Item 3

=> Item 4

> Item 5

. i July 22,1997 LitC Presentation to NRC and NNEco 24

TEAMWORK 4AND:COOPERATIONJ AT MILLSTONEJ Rate the level of teamwork and cooperation that exists: l 2 40-e, q.0 . . . , l 38 8 40- 38

% 80- to

% 80-to to 10 -

10 -

'v.. Ago" - ' - ' Jew s, '- aven age- awn s,

{ ase .em an.,

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% 30 n .

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_i July 22.1997 LitC Pmentatica to NRC and NNLCe ?S COMMUNICATION OF POLICYr&S EXPECTATIONS:REGARDING7 RAISING OF CONCERNSE Are you f.imiliar with Mr. Kenyon's expectations for employee concerns?

I 94 % Yes 6 % No __.

Are you familiar with Millstone's " Success Objectives"?

85 % Yes 15 % No July 21,1997 LitC Presentatma to Ni<C and NNECo 26 t

-CDMNIONfCATIUF0FI!UEfCY/& u .

EXPECTATIONS:REGARDING RAISING OF CONCERNSrcont'd.

What does management expect you to do if you have a nuclear safety concern?

=>Take it to management: 231

-oVarious other: 6 July 22.1997 IJIC Presentation to NRC sad NNECe 27 I

CDMNIUMICATfGN GifYULICV &-

-EXPECTATIONS REGARDING: ,

RAISING OF CONCERNS, cont'd.,

Level of effectiveness of communicating policies and expectations relative to raising concerns:

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e I July 22,1997 LilC Presentation to SRC and NNECo 28

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GENERAL WORK ENVIRONMENTi AT-MI.LLSTONE?

. .. .m. e, m Ilow would you rate your , , , ,

level of understanding of (*,l your job r .sponsibilities? jn- 10- -

Ame 97 Levat of f reming an. f een Ilow do you rate the level ,u of training and tools you '" u have received to do your Job?

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July 22,1497 LitC Pmentation to NRC and NNECo 29 I

GENERAL WORKJENVIRONMENTi '

-AT MILLSTONE, cont'dc Are you given the time j $l ,, ,,

and resources to do your * "

g job right9 M re y wer

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July 22,1997 LilC Pmentation to NRC and NNECo 30 i

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O it. yin ,. , !_= .

,. '%tj iGENElML INFORMATION>- -

c.,ge.

Is there any aspect of your job that could affect nuclear safety?

87 % Yes 13 % No Itave you ever raised a concern?

50 % Yes 50 % No July 22,1997 1.IIC Prnestation to NRC and NNECe 31

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-l Employee Concernst .

('

(Program Implementsdon Rsview? _

Presentation to

Nucicar Regulatory Commission &

NNECo July 22,1997 July 22,1997 LilC Prewatation to NRC and NNECe t l

1PresentationtAreas a.

Employee Concerns Program implementation

- Leadership

- Program Effectiveness

- Information Management

+

Senior Management Support and Actions

- Alternative Paths

- Management Recognition of" Chilling Effect" Incidence

- Management Recognition ofIlostile Work Environments

  • Case File Review

- File Management

- specific Case Files

- Retaliation Cases July 22,1997 LilC Pmentation to NRC and NNECo 2

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1Expestationsi

u 1 7 The Employee Concerns Program will effectively 14andle employ ee concerns in a manner that protects those who utilize the program and assures concerns are addressed.

l

' = ECP leadership and program inanagement instills trust and confidence in the program.

. ECP is effective and reliable.

ECP will have a database to provide information on the basic issues and status of case files to provide for meaningful use of the information.

July 22,1997 LitC Presentation to NRC and NNECe 3 1 ' ..x 1 s ,. . ., . . .

- ECP Leadership: .. Evaluation 1 Process}

Reviewed quali0 cations and training of ECP personne!.

  • Interviewed entire ECP staff (including contractors) and some former ECP staff.
  • Observed ECP staff activities.

July 22,1997 LIIC Pmentation to NRC and NNECo 4 i

1

~

, ' f+^1Eeadership CobclusionW Necessary resources _ have been provided for l the program; new office accommodations, providing better privacy and more work space, private conference rooms, administrative assistance and experienced contract support.

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! July 22.1997 l IJIC Prestatation to NRC sad NNECo S T

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, TLeadership_ Conclusion'#21

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yp ECP staffis not adequately qualified or trained to provide effective ECP services.

  • Pcsition qualifications and requisite training requirements are not yet developed.

Qualification process has not been completed.

Training is not yet implemented.

Mentoring program of experienced contract ECP personnel with NU staff is not yet established or implemented.

July 22.1997 IJtC Pruentation to NRC and NNECo 6 9

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Leadership 1,ConclusionI#E --

Morale of the ECP staffis low.-

Strong belief among the staff that objectives of the program are to close concern files,i.e. " bean count" rather Qan to address concerns completely and thoroughly.

Unavailability of Director for guidance and direction because of other obligations and meetings.

Lack of visibility and support of Oversight Vice-President.

Continual department reorganization has created confusion and l-frustration among staff and contractors regarding work assignments, priorities, and overall guidance and direction.

Management has created an impression that it does not like to hear bad news.

July 2h 1997 LHC Presentation to NRC and NNI.Ce 7 l

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% Leadership;Condusion #4? 7 There is a lack of discipline and compliance with the ECP manual and program. The program has not yet converted from its previous "ad hoc"' approach to doing business to the new ECP expectations.

Only one of the files opened under the new program met all of the program requirements.

The Points of Contact System is not addressed by the new program, but continues to be utilized without documentation or be included in the ECP process.

July 22.1997 LilC Presentation to NRC and NNECo a i

C 1

Program s Effectiveness Evaluation;Procbss:

Observations of vas:cus ECP activities, including intake and exit interviews, triage session, investigative interviews, closure panel,

=

and other interactions between ECP and employees.

Reviewed 93 closed or resob ed files, and are monitoring activities connected with several open files, with regard to the ECP process.

Interviewed the ECP staff.

Interviewed concerned employees regarding their confidenceand satisfaction with the program.

July 22,1997 I LHC rresentative to NRC and NNECe 9 Effectiveness Conclusion 1:(Some Employees?

Have Lost Cdnfidence in the ECP 37% of the 27 employees contacted in follow-up, who had filed a concern, expressed dissatisfaction and would not reuse the program.

Most of the dissatisfaction stems from the fact that ECP relied too much on the investigations or resolution of other organizations, in particular iluman Relations and line management which they believe disregarded the concern in the first place.

Few employees voiced a concern over the breach of their confidentiality; however, LIIC has noted that ECP files are not secure.

July 22,1997 1.IIC rresentation to SRC and NNECe 10 i

Effe"ctiveness'Conslusioni2:3 y

The ECP intake provss is not properly prioritizing nuclear safety concerns and retaliation issues:

In stLe process properly requires that 'reportability and operability" determinations be made during intale; however, there is no indication that these determinations are made by qualified people nor is there any record in the files done under the new program that show such determinations have been made. In addition, since ECP staff are not trained to make operability or reportability determinations, the concern esists that this information is not identified duringintake.

The ECP properly requires that determinations of retallation and " chilling effect"are made w hen alleged or identified. Iloweser,the program does not require these determinations to be tende and the files done under the new program do not reveal that such determinations have been made. In addition, since the ECP staff are not trained to identify chilling elTeet or retaliation toe concern esists that these issues may be overlooked.

Triage proces* provides a " check" on intake, but still relies on the quality of the intake fn* Informarinn.

July 22.1997 LilC Presentation to hRC and NNECe !I Effectiveness Conclusion 3: Issues Are Not Consistently; Being;Addre'ssed in a Thorough and Compeient)fannerl

!with AppropriateIndhpendencel As demonstrated through File Reviews, the thoroughness and competence of ECP work is widely inconsistent, varying from unacceptable to very good.

As to independence, there remains skepticism and concern about the relationship between ECP and line management. This is based on a history of distrust that predates current program and an aggressive desire by present senior management to have concerns handled by line management.

These conflicting realities have caused some dissent among ECP staff, some of whom objected to referrals. It has also caused concern by employees who perceive that their issues are simply being referred back to the line for resolution, which they feel failed them in the first place. This has resulted in dissatisfaction and disarpointment among some concerned employees.

July 22,1997 LitC Presentation to NRC and NNECo 12 5

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-Effectiveness Conclusion 4i~ Concerns'Aren

- Not Consistenfly ~Being: Properly Re~solvedt

-or'Closedi

  • Many concerns appear to be resolved or closed without any docume'ited evidence supporting the resolution or closure, such that review of the files does not provide any indication of the closure of the file.

(The concern about the completeness of the files has been self-identified, but no adequate corrective action is identified in the self-assessment.

Management has indicated attention is belag given to this problem through the assignment of a dedicated ECP staff member.)

l July 12,1997 LilC Praestation to NRC and NNECe 13 l

Effectiveness Conciusion 5: Employees--:

Generall ;Rebeive Timely Feedback _

Employees generally receive timely feedback of the handling of their concerns; however, there were some instances in which employees were not kept advised of progress on their case and were required to re-contact the ECP for information or rejuvenate their concern.

July 22,1997 LitC Presentation to NRC and NN ECo 14 l

> s a

ECP Information Mansgement?
Expectations 1 The ECP will have an adequate database to provide -

information on the basic issues and status of case files to provide for meaningful use of the information.

+

ECP communicates information to the Millstone workforce.

I t July 22.1997 1.IIC Presentation to hRC and NNECe 15 ECE InformationfManagemedt: Evaluation; w

Processi _

  • Reviewed Computer Database.

Reviewed Monthly Reports.

Reviewed Communications Plan and Implementation.

Interviewed Management.

July 22,1997 LitC Presentation to NRC and NNECo 16

__. 1

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' LContiusions on EGP!Inf$rmitihhns -

4 -

IManagdmenti - c J[ [

Information Mananement Conclusion #1 The present computer database lacks the level of detail to provide espected i

information required to make intelligent decisions on types of concerns, degrees of significance, and cross-references.

Information Manneement Conclu lon #2 Present status reports do not contain the lesel of detallI.ecessary to be useful, i.e. do not contain treading or identify repeat areas of difeculty, levels of l significance, or areas needing attention.

1

l. Information Manneement Conclusion #3 The communication plan has not been fully implemented.

July 22,1997 LilC rrewstatina to NRC and NNECo 17 g< . 3 I

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ECP Impleme$tationiRecommendatidnst . -

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1. ECP should complete its Qualification and Training Process, with special emphasis on: Intake (including Reportability and Operability determination criteria), investigation Training,, and Report Writing.
2. The mentoring program between contract and NU empicyces should be formalized and implemented.
3. Program priorities should be established through clear vision, direction and agreement within the Department.
4. Increase presence and participation of Vice President of Oversight and Program Director.
5. Finalize department organization and program documents and fully implement.

July 22.1997 LilC Prewataten to NRC and NNECe . 18 9

l

LECP IhiplemenistionbcommendstIbnsh ConPdn* u, '

6. Impose discipline to compliance with program documents.
7. Use of and reliance on other organizations and lluman Resources investigations and rerolutions should be implemented in accordance with ECP Rev.1, Sec. E.5, which requires outside work to be e aluated for adequacy.
8. Files should not be classified as " resolved" or " closed" without meeting the definition in the LCP manual
9. Employees should be kept better informed on the status of their case in accordance with the manual.
10. Develop a database and management reports that will capture and provide usefulinformation to site leadership to enable them to readily eva'uate important issues requiring management attention.
11. Implement the communications plan.

I July 22.1997 LilC Presentation to NRC and NNECo 19

~

l LManagement Support.andiA'ctionst I ' Expectations, e Millstone management recognizes the presence of a safety conscious work environment, incidents that may cause a

" chilling effect" among employees, and hostile work environment and takes appropriate action.

July 22.1997 LilC Presentation to NRC and NNECo 20 3

. \

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-Managensent Support Evaluation! Process:

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Interviewed Senior Management.

+

interviewed lluman Resources.

+

interviewed Peer Representatives.

  • Interviewed ECP Staff, r

4

, July 21,1991 1.11C Presentsues to NRC ead NNCCe 21 1

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_ . _ - - _ .. . _ , ,_ 6 Coriclusions on Manag6 ment Support andJ 3

1 Actions: '

1-Management Support Canclusion #1 There are numerous inconsistent, alternative management methods for recclpt, processing and resolution of emplo,vec concerns outside of the Employee Concerns Program, and outside of previous identified avenues; i.e.," hot lines", peer representative program and unit points of contact.

  • The handling of concerns raised outside of the ECP varies dramatically, j but none of the asenues reviewed keep an auditable record of the handling of tiiese concerns or follow up on corrective action.
  • Concerns raised outside to the ECp program are not evaluated for similar situations, generic implications, or root causes that may result in
repeat problems, July 21,1997 1.IIC rreientation to NRC and NP Co 22 I

=

8 5

Management Support Conclusion #26 Millstone management has identified the basic tenets of a safety conscious work enironment; but has not consistently recognized and responded to incidents that could cause or perpetuate a " chilling effect".
  • Very good description of a " safety conscious work ensironment"and management espretations has bien distributed and communicated.
  • Yery good reinforcement of these principles to managers at tarlous management meetings and through site publications.

Sestral esamples of prompt and effective intervention by upper management into incidents that could cause or perpetuate a " chilling effect" at the site.

Seseral significant events where management has failed to identify or appropriately respond to incidents or areas that perpetuate " chilling effect" at the slie.

July 22.1997 t,ilC Presentauun to hRC and NNife 23 l

Management Support Conchisi6n #3 l

Millstone inanagernent does not always recognize the elements of a hostile work environtuent that could affect the I integrity of the plant operations.

Incidents or work ens tronments identified with serious employee relations problems hase not been addressed in a timely manner.

Impact of the effect of poor work ensironment not generclly considered in responding to a concern or in deselopment of corrective action plan.

  • 5till appears to be a generallack of accountability or recognition of some "old style" mant gement beharlor.

July 22,1997 Lile Pruenteuen te NRC and NNETo 24 i

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Senior Management Support Andl Actions' l Recommendations

1. All alternative management utenues available to employees to raise concerns, outside of the Employee Concerns l'rogram, should have a consistent mechanism to receive, process and resolve concerns.
2. All concerns should be evaluated for similar situations, generic implications and root car.es in a timely manner to provide management with the best possible insight into site environment and activities.
3. Management should have a consistent prpcess which will allow them to be informed of significant information incidents, issues and events.
4. Allievels of Millstone management need to be tralned to deselop the skills to recognize and respond appropriately to incidents that could cause or perpetuate a " chilling effect" that could prevent employees from raising nuclear safety concerns.

July 21.1997 tilC Prmataties to NHC and NNECs 2s Senior hianagement Support and Addions=

-Recommendationsf L 5. Executive management should be kept apprised of the existence of work areas that have been alleged or confirmed as having a

" chilling effect" or hostile work environment so that they are able to better monitor and evaluate these situations.

6. Criteria should be developed that will be consistently used to identify or evaluate incidents or allegations that a particular working environment has croded to the point that employees are too demoralized to perform as expect i,
7. Management must " walk the talk."

July 22.1997 LitC Prmstatwo to NRC and NNECe 26 t

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u Case File R'eviewiExpectation! >

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?

1g a , '

The ECP handling of employee concerns should be done in a competent manmr, resulting in appropriate restitution, ,_

and documented in accordance with the ECP Manual.

  • Concerns will be tecurately identined, and all issues fully l  ;, addressed.
  • Allissues will result in an appropriate resolution.
  • The ECP nics will be generated and maintained in compliance I

with the ECP Man.ial, and contain auditable and complete record of the handling end disposition of allissues.

July 21.1997 LilC Presentation to NRC and NNECe 27 o .

, l' I f .

?

Process for Evaluating ~CaseRie:R'eviews; i% m a

. Developed criteria for case file review.

. Selected files. .

  • Performed a comprehensive file review.

. Interviewed selected concernees.

  • Sclected specific cases for further scrutiny.

s July 22 1997 LitC Presentaties to NRC and NNrCo 28 i

\

I' m

L..

f:

y-Case File Review Conclusions Case files are not improving in the context of file content or compliance with ECP Manual.

  • New files are generally no better than old ones.

l'iles generally lack the ability to be traced to an investigator, intake, point of contact, or other ECP personnel. This lack of traceability makes meaningful follow up dimeult if not I

impossible in Instances where the file is reviewed.

l No systematic process for documenting determination of r eportability or operability.

July 22.1997 1.IIC Pmentation to NRC and NNrCo 29 i

l p

Case File' Review! Conclusions, Cont'd.

Inconsistent quality intaka and investigation of concerns.

  • Intake and investigaticn process still does not fully identify or capture all issues being raised or espressed by concerned employees.
  • The investigathe conclusions are not obilous on the face of the file, l'iles do not clearly state w hether a concern is sub:tantiated, and if so, what the corrtetite action is, or if an issue is partially substantiated but requires more analysis or Insestigation.

Cases in which retaliation has been alleged generally do not contain any investigation of whether a "chillip: effect" was investigated.

July 22.1997 LilC Pmentation to NRC and NN E Ce 30 e

+

5 m;mW G

l f

'i

.-----.%..- - . - - _ , - - a,- . -.... . em w,,____._m_,,., , , _ , , , , _ , , ,

Case File Review Conclusions, Cont'd, linsed on file review, some files shouki not have been -

classified as resolved or closed.

l July 22.1997 1IIC Presentat6on to NRC and NNI Ce 31 Case File Recommendations

1. Increase management expectations and I:CP staff accountability to ECP Manual requirements.
2. l'erform In-process and pre resolution file reviews.
3. No file should be classified as resob ed or closed without required review for completeness and accuracy.
4. Establish a senior management review panel to review resrived files for the quality of concern es aluation, adequacy of disposition, and feedback to concerners.
5. Resicw those files resolg ed since at least December 1996, to assure allissues were properly resolved under current program definition.

July 22,1997 1IIC rresentanoa to NRC and NNr.Ce 32 s

Trek listione  :.

Eweetations Renardine Workplace Environment:

Millstone will have an environment in which employees can bring forth concerns without fear of retallation or retribution, and are not subject to intimidation, harassment or discrimination for doing su.

hianagers will be provided with the tools to recognire and respond appropriately to employees engaged in legally protected activity in a manner that prevents the fear of retallation from developing among employees.

  • hinnagers will be able to demonstrate the ability to recognize and respond to incidents and es ents where fear of retallation is esprested

) by employees.

l

  • hianagement will be aware of areas in which retallation has been l

1 Idtntified as an issue and be pro-acthe in resolving it.

I July 22. le97 1.IIC rre'estsek.a to NnC sad NNrCe 34 4

3 Retaliation; Cont?dn

, c, W. a -:. g ,. ;p Process for Evaluation:

Monitoring, developing, and handling of selected retallation issues.

In depth file review (100%) including independent verification of ECP work.

  • Independent investigations.

July 22. le97 111C rre'entation le NRC and NNrce 34

' l I

i

l A'

k. L ' -

Retaliation Observations:-

,4

  • Chilling effect is still not always recognized by senior management.
  • lisues of retallation are not recching espected management attention.
  • 53% of open concerns are retallation issues.
  • No professional training has been conducted.

I July 21.1997 1.IIC Presentation to NRC sad NNire 3s

  1. w Files Open As Of.6/27/97. '

7c Total SR llR SEC IS&ll IA MISC 30 6(20) 17(57) 4(13) 2(7) 0(0) 1(3) 16(53) of tlie open files are retaliation issues.

(% Rounded)

July 13. l#97 IIIC Presentation to NRC and NNrCe 36 4

f*

" i.

Files Reviewed (Closed Oi Resolved);

llatch Revieweil Total Number With Retallatfort issues A 38 38(100) 11(29) 11 42 42(100) 12(29)

C 13 13(100) 4(31)

Total 93 93(100) 29(31)

Allof the aboge files with retallation lisues were reglewed.

(% Rounded) l July ll.1997 1.11C Presentat6en to hkC and kNI Ce 37

..w---~. a k.,,.mm-.e-=~

Files Reviewed (Closed Or Resolved); ~

llatch Reviewed SR llR SEC IS&ll IA hllSC A 38 22(58) 8(21) 0(0) 4(10) 0(0) 4(10) 11 42 13(31) 17(40) 1(2) 3(12) 1(2) 5(12)

C 13 3(23) 5(38) 1(8) 2(15) 0(0) 2(15)

SR. Safety Related SI'C . Security llR. Iluman Resources IA. internal Audit IS & il-Industri.it Safety and llealth July 22.1997 1.IIC Presgatation to hRC sad NNLCe 38 i

4

I. ..

i .

InterviewResponsestoQuestion7 w......-

Bring it up to management.

3 things in order 1) Safety Director 2)NU Supv 3)Supv's Mgr.

" Address concem with supervisor.

l Address concems as you feel appropriate l

Address it by any means. Inform supervision of what seems wrong and what should be done to conect it.

t Eing it forward right away More emphasis now than before.

Ering it out to my own group.

EnnD it out.

$nng it to management to be addressed.

! Bring it to management's attention as a concem. Nuclear safety concems should not be Capitalt2ed-It should be a concem and it should be brought to management.

1 Bring it to management's attention.

Bring it to management.

Bring it to management.

Bring it to my supervisor or manager..-_

Bring it to rny supervisor; make it visible.

Little Harbor Consultants. Inc. Page 1 of 16

I

  • p hus minigualut meist peu to 4 N yeu luss e adur aufsty emuurier" Bring it to supervisor and partcipate in resolubon of concom.

Onng it to supervisor.

'Bnng it to supervisor. Wrlie a CR.

Bring it to supervisors / managers attention.

IBring it to the attention of managernent immediately, I

l Bring it to their attention via CR Bnng it to their attention.

Bring it to your immediate supervisor, f

Bnng it to your supervisor.

I

[ Bring it up & get it resolved.

lBnng it up through Ime management.

^

Bring it up to management option to go to ECP I

Bring it up to management.

bring it up to management.

Bringit up to my supervisor, Bring it up to them--his supervisor.

j l

Littk Hart >or ConsuP. ants, Inc Page 2 ot 16

I 1

  • Wist dies ungspnuut egget yr h de N you impe e luuhr asisty numeir Bring it up to them.

Bring it up to your management.

Ering it up within the organizational chain.

Bring it up!

Bring it up, this has been restated many times.

Bring it up.

Bring it up.

~ ~

' Bring it up.

l Bring it up.

Bring it up.

^

_j Bring it up.

Bring it up.

Bring to attention of management.

Bring to Arst line supervisor and nally have it thought through.

~

Bring to immediate suscrvisor, Bring to line management.

Little Hart >or Consultants, Inc. Page 3 of 16

1 i W has genspunut WWIII Vuu 18 M yeu leue 8 Rudeer esisty sumpf

~ Bring to my boss' attention.

Bnng to my superv6sor to discuss.

Bring to the attention of management.

ilrtng to the attention of my supervisor.

bring up the issue-write a CR.

Clearly communicate problem in its entirety to line tnenagement.

Communicate concem to management.

7 Deal with it or report it.

IDo what's right. Management will support it up the line.

Document and submit to supervlsor.

Expect us to bring it to them.

Expect you to raise the 'concem.

IExpress it. If big, do it right eway.

"First, to the line management.

Erst i ne supervision and move up the chain. Can go to NRC but this is last choice.

Go after appropriate expertise to solve. Take a concem to the boss. '~d Littie Harbor Consultants, Inc. Pope 4 of 16

1 e W h W W yWlBhNyahB W hy M Go right to my supervisor, if he's not around go to another bupervisor.

Go to chain of command.

  • Go to %rst HP tech I can find.

Go to management.

Go to management.

i Go to management. I l

Go to my supervisor to get it resolved.

Go to my su'pervisor.

l l

G5 to my supervisor, Go to shift manager.

Go to supervisor Go to supervisor, but I would by-pass him and go another level up, Go to supervisor ECP and NRC.

Go to supervisor.

Go to supervisor, Go to supervisor.

LJttle Harbor Consultants. Inc. Page (, of 16

I e W h W W VWhhN m h e W W W Go to supervisor, Go to supervisor.

l l Do 10 supervisor,

~

Go to supervisor, Go to them.

10 and fix it. Tell sur Srvisor.

Identify and work to resohre.

Identify it & bring it up.

Identify it and in process take immediate steps to keep things safe until it can be evaluated.

Ide'ntify it.

Identify it.

ildentify, Ildentify.

Identify.

Immediately to management.

initiate a CR to notify management there is a problem.

Lhtle Hart >or Consuhants, Inc.

Page 6 of 16 I

I

/

WhWWmh4NpheWWW Let management know, Let someone knowin chain of command.

Une management.

Make it a pnonty functicn Bring it up Make them aware of the problem and get it resolved.

Management expects it to b6 brought up, they really do, l

My immediate mgt is very receptive to bringing up safety issues.

No question, get it out.

Notify management.

Prefer line mar.agement, but other avenues are available.

Push the rope.

Put it on the table.

Iut them on the table.

' Raise concem with supervisor.

Raise issue to supervisor.

Raisa issue. Use chain of command, Lime Harbor ConsuRants, Inc.

Page 7 of 16 i

_ _ __ ._ _. ___ ,_ . _ = . . _ _ _ _ _ _ . ___ - ..

I 1 .

e I l

W dus smugunst escut vu h de t pu has e indur selsty suusf

~

Reiseit ,

Reise it and get it into the system.

Reise it and provide info to help rssolve it.

4 Raise it to line management.

Esite it to management and go as high as necessary.

i Reese it to management.

Reise it to somebody.

R

' eise it to supervisor.

~

Reise it to the next level of management ise it to your immediate sup'v.

l ,

' Raise it, Reise it, w

Reise it.

Raise it.

~

Raise it.

' Raise it.

Little Harbor Consultants, inc- Page 8 of 16

I e i

WhWsWMhlNEMh 0MMM Raise it.

Rome it. -

l Raise it.

Raise it.

Reise it. Don't l'et job go to field.

Raise it. Use chain of command.

Reise the concem to line management, ECP or NRC.

Raise the concem, put it on the table.

Raise the concem.

~ . ,

~ Raise to immediate supervisor.

Raise to next level and then wnte a CR.

' Report immodately, would go to manager vs supervisor.

Report it and address it property.

Report it through hne management, and take further action if response is not suflicient.

Report it to supervisor.

Report it to supervisor, Utile Harbor Consultants. Inc. Page 9 of it

t 6 WhWWMDMMb5hMM Report it to supervisor.

Report it to who ever is appropriate.

Reportit up the chain of command.

Report it.

Report it.

Repcit it.

Report it.

~

' eport it.

R Report it.

IReport to kne management and resolve it.

Report to supervisor.

Repott.

Report.

l Resolve it and raise it with line management.

Resolve it to my satisfaction.

t Resolve it. People trust me and bring their problems to me.

I uttle Harbor Consultants Inc. Page 10 of 16 7 . _ . . , , . ,

e A

[

  • Wlut den .M usset you te du N yeu luso e mular sulsty sumer Re:sr/e the conoem. Concems have taken on . hfe of their own.

P;Jn it up the mg',c)ein, Elre at first W lovelif possible and handle in-hode.

t ww.,.~~--<-

Solva biltWty ly/ tt44 Ama39ement.

l - - -

l Golve it. Take p to hne and take ov,M7 hip.

l 1

STAR, then to supervisor.

I 5itodnd get it fixed, t

'Stop and seek an expert not involved with operations.

Stop work at any time.

Supervisor, management, ECP, NRC

~

'Sur 3rvisor.

~

Supervisor,

' Supervisor. Knowledge that there are other avenues avellable.

Take care of it, address it and make sure it is no longer a concern. Take it to my supervisor.

Take conservative action, bring it up to line management.

Take it to management.

utie Harbor Consultants, Inc.

Page 11 of 16

i .

"WWAhWMMitVWtehNyuhamulutyM Take it to management.

Tako it to my boss to resolve the issue (talk with him about a issuing a CR.

l Take it to someone who can do something about it.

l 1ene it to the line management.

l l

Take it to the line.

Take it to the line.

Take it to the next level of supervision, j Take it up the managedelechain if cannot resolve himself.

Take it up with immediate supervisor and work up the chain. Also can use ECP or NRC, Take to chain of command.

Take to firstline supervisor Take to sapervisor.

~

Take to supervisor.

Take to supervisor. ~

Talk to my supervisor.

Talk to your immediate supervisor.

Litte Harbor Consultants, Inc.

Page 12 of 16

_ . . __j

i .

Wh W Wmh4NmhethW M Tellline management.

Tell management.

Tell someone. l Think about it, let someone else worry about it.

! To bring it up.

To get it acted on.

To immediate supervisor.

To imvediate supervisor.

To lir.3 nanagement.

t To line management.

To management.

To my supervisor.

1 To supervision, up the chain of command, if necessary to NRC. Thinks any concem would be addressed in house.

To supervision.

To supervisor To supervisor LRtie Harbor Consuttants. Inc. Page 13 of 16

t .

l W h m W mtetNmhahtidety w To superv6sor and higher management.

To supervisor.

[

To supervisor.

To supervisor.

To supervisor.

To supervisor.

To supervisor.

'To supervisor.

To supervisor.

40 supervisor.

To supervisor.

L-To supervisor.

To supervisor.

To supervisor.

To supervisor, To supervisor.

Little Harbor Consultants. Inc. Page 14 of 16

I .

' Inst ess e meest yne is e r ysa luss a nshr asisty smuur To supervisor.

To supervisor.

To supervisor.

To supervisor.

j To supervisor.

l To supervisor.

To supervisor. Pursue other avenues, if it has not been appropriately resolved.

To your supervisor.

IUse line to resolve. Writo a CR.

Use the chain of command.

Yoice it.

Want them to issue a CR.

Work it through management.

Work through it, if cannot, go to management.

Would bring to immediate management, Write a CR and bring to management's attention.

IJttle Harbor Consultants. Inc. Page 15 of 16

1 e WhemphhKmmsemistyw Wrtte a CR.

l Little Hator Consuhants. Inc. Page 16 of 16

InterviewResponsesto Question HB u.-...

[ Person) was e' ways a pain. Nit-picked things to death. [ Person) always mumbled about management, reaented losing supervisory job and in the end had to have a settlement. Knew them both well. [ Person's) issues were not handled well.

1)ln condition where he thinks NU employees should bnng up the issue. 2) Performance of NU employees.

! Boss intimidates me.

l l

Can't raise my supervisor is trying to get rid of me because I didn't agree with something he was'trying to do.

l Continued problem with investigation- materials not identified; management doesn't want to hear about this roblem.

Depends on boss' personality. Some fear that assignments would be less challen,ng nd thus be subject tol riffs if brought up concem.

Do not trat the [6rganization) chain.

Den 1 fully trust management chain '

! Fuzzy areas where issue is not cut ano dry.

Have worked for a supervisor I wouldn1 go io and it could happen again. Not a problem today.

I am uncomfortable in raising any cory.cm. I don't want to be sent off site under unpleasant conditions.

1 I don't feel comfortable with Mike Brothers being the sponsor of the ECP process. He said be was not gracious in handhng bad news.

9 i might have a problem taking a supervisor's performance to him as a concem.

L'fo Harbor Consultants fne Page 1 of 4

1 M m m m m m M uth m h W e m W W N m W l I would not raise an HR grievance because I am not rure how it would affect my career.

l would not take it to my mgmt.

l houldn't feel right about bringing up personnel issues in my chain or w/ HR. HR blows off issues. Job postings are a joke, rm very reluctant to have my name associated w/ lasues.Not associated w/ his job in overwrtte but w/ his old job in [ Organization). '

if it had only to do with a personnel problem !! would not be raised due to past experience with non nuclear management.

lif it was in an area outside my expertise. If it molved a lot of mone/ time, or people.

If it were going to make someone else look bad, but would do it.

li it would be in conflict with Recovery organization. Would be fixed but I would be damaged (have been removed from programs due to raising issues) in area where I was not knowledgeable of all the facts. I would take time to unders*and but would definitely bring it up, r

lIn the past no one has been treated fairty. I would probably hire a lawyer to help me through the process, if jthere was a safety concem that could hurt someone I would pay the lawyer and worry about the expense 1 pater, in the past, if you rock the boat, you were not considered a team player.

Not go to general forernan: he is weak link-by-passes him (knows general foreman soon to be fired).

Not if 1 thought it would end up in HR, they just tum it over to lawyers who take a leg'alistic approach and screw the employee. {

Not in a public meeting.

Uttle Harbor Consultants, Inc. Page 2 of 4

t a I 1

l l

"k them My Ogdthi W WM4 VW M Mt b IM h f% 8_ OMEW (Yes/Nal if yes. OF NU is going to far to not challenge a regulatory position. I would be hesitant to challenge this position and be considered a maverick. Management doesn1 want to hear it.

Ordy if it involved someone's employment would I feel pricomfortable.

Personal expenence of chilling effect from an issue i raised six months ago. I should just keep my mouth shut today.

Pos)ible impact on career.

Potential conflict of interest in the CMP process.

l Potentially hesitant, may be due to that a few years ago there were lots of reasons not to bring things up.

l fut a concem into system 4 years ago tumed off by results. Thinks things have changed and would test l i syst

.I . em again.

i Ratting on a peer, but would bring it up anyway.

iSensitive, individual, confWential, organiza:ional, trust issue.

Since I have confidence that it will never get addressed, then I will just shut up.

Eome good Ideas' that have not been thought through.

Some discomfort if it would be related to delaying the restart.

Somet working environment concems I would not raiso.

The pendulum has swung too far in the direction of those who seek a " settlement" and don't really care about the issues. Lots of negative energy etill present in the person of those out for themselves.

Little Harbor Consuttants. Inc.

} Page 3 of 4

t ,,

  • k M M MuttklW Wh4 M WW41151 h M h % 3 WW'WF (YW N m 6?"

There are certain people here t*,st if I worked for them I would be concemed about raising a concem.

'There is a threat which he finds w/ new org. Which requires substantial documentation of an issue before he can feel comfortable.

IUnit Director very defensive, poor choice. Would approach Kenyon before going to [ Person).

%' hen I raise a concem it is not handled right away, I continue to raise it, and in the end I will " pay the price" Ifor not handEng it myvelf.

l With attitude of new manager 'this is bootcamp" why bother.

l Wont go 13 own supervisor, but can go easily to others.

l

! Would not consider raising a concem without ECP being involved.

Would not go to supervisor, but may go to manager, Would raise any personalissues.

Would raise but better keep eyes open to see what may happen.

Little Harbor Consultants, Inc.

Page 4 of 4

I e InterviewResponsestoQuestion121 m . . . . . ,. . ., n . . .,r

1) Mgt chain bh doesn't feel anything would get done. 2) ECP for the same reasons.

Cant imagine a circumstance where would go to NRC.

Can't use Cams hot line it got me bumed the first time.

Corporate CEO.

Do not have a lot of confidence in the NRC.

I IECP because he doesn't trust some of the people involved.

I CP, because confidence they could resolve issues is low.

I would not use the New London Day, if s >pervisor didn't handle it there is always the NL Day. ECP has a bad rep. And NRC tums names over to NU.

Local outside group.

i

! Local paper.

l Management above supervisor - don't bother I

Manager because i don't believe he w uld be supportive.

'Media Ne l dia.

My supervisor. [Name of Group]

Never need to go beyond line management.

No but not fully comfortable with the system.

Not yet, wa:t and see how they perform.

Little Harbor Consuttants. Inc. Page 1 of 3

_ _ _ l

1 e. l 1

1 i

j l

% timre my optlat lyn llMt you leve fir rehhg nummisl yeu wedd ist uut [Yes/Ilel ll yet, wlddi sd ssphet wiryr' NRC, not really their business,99.9% are resolved before getting to them.

NRC. I don't know what they would do, and whether it would solve the problem.

Peer process does not work.

Perceived lack of trust in ECP.

Prefer to go up the in-house chain.

Press press and/or attorneys Press, CRC or state regulators.

Press, they take things out of context.

' Press-doesn't think it would do any good.

P l

l ress. 1

' Press.

!Press.

' Press.

Unit director, thinks concerns would be resolved below this.

Would not go directly to the units.

Would not go to HR.

Would not go to Kenyon.

Would not go to manager because if you are a contractor, you are a 2nd class person with him.

IWould not use media.

l Uttle Harbor Consuttants, Inc. Page 2 of 3

i ..

% M Wy @lM MA M h fr % MI YE M Nt WE7 (YIS/W K M, Wikfl Ed W W Would not use NRC, do not trust. Would go to LHC if had t.n issue.

Would not use Press

~

Would not use senior rnanagement off site.

Would not use supervisor if it was a non-safety issue.

Would not use supervisor, ined and he was ineffective in responding to concem, World use NRC only as an absolute last resort.

Little Hator Consultants, Inc. Page 3 of 3

InterviewResponsestoQuestion13 EtEE'd M M M CE'fw uveAc hlPf w e. -

80% efficient and improving.

Another role of the group. Coordination of CRs. Very burdensome at this time.

Audits indicate ine*lective corrective action program.

Being abused by putting trivia in it.

Being flooded and out of control.

l l Detter than a year ago. Some CR's are too low and are distracting from important issues . C.- jrocess beats ]

people up people don't want to get involved and take the extra steps.

Detter than it was.

CA process terrible-ifs not used right & is too complicated. Has created a hostile working environment on site.

C' an't rate eflectiveness: doesn't feel knows enough about details.

CAP is overtoaded by low importance CRs.

%AP tends to eliminate normal communication between groups. Get the garba0e out of the system. Does the pssage re "wnte a CR" really make sense? The writer of a CR should not necessarily be responsible for Carried aws.y with foolish things. Not as eifective as first thought due to the volume.

Clegged with trivia. Lots of wasted time dea!ing with it. Seldom gets to root causes, usually a band-aid.

Ownership frequently in wrong place.

' Comp!icated.

Constant state of change. It should be simple. Its just a tracking program. l l

Constantly changing.

CR - confusion on when to writes.

{

l Little Harbor Consultants. Inc. Page 1 of 8

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M airIEEEutBM k M M M ICR is punishment bec T,erang. Process is overwhelming. Swamping the system. Backlog was worked off but fach one created 4 AR's that now have to be worked off. -

CR rd etncient b*.t. effective.

CR process is a mystery. Sees 50.54f screening as duplicating CR process.

CR process is tedious.

CR's are being written for absurd things, a real abuse of the system.

'CR's are too detailed, volume too great., thinks will go back to ACR's.

ICR's are witfien for everything minor (ie parking lot probs) & the system is abused. We never use the Trouble l Report System.

CR's need to be reviewed carefully, many are ridiculous. People are wnting them to pass the buck.

l CR's you do today you don't get feedback on or buy-in for the renoltdon.

(

Created a lot more paper work, system is driven by numbers rather than results.

CRs are well used. There is no supervisor who would discourage entering a CR.

! Cumbersome and overturdened.

Cumbersome and overionded. Constantly changing process.

Cumbersome and time consuming, many spurious CR's.

Cumbersome but much better.

Cuiiterscrne to use. Could be improved. Over-reaction to past problems.

Cumber.ome.

Cumbersome.

Uttle Harbor Consultants, inc-Page 2 of B l

a

i ,..

asard namest rieres as amsese asem pnym.

Numbersome.

l Cumbersome. Also, Concem that corrective actions add training commitments without first coordinating with training, or making training aware.

Cumbersome, Don't do good root cause evals. Training and procedure for root cause evals is poor,

! Cumbersome. Has improved significantly. Actions are tracked to completion.

Cumbersome. Wrote a CR in Jan that training had no systemabc approach to training and ntthing was done.

l fow we have a training shut down because NRC found the same thing.

l l Currently pretty new, too hard to judge effectiveness at this time.

'Didn't use to have adequate tracking system.

i Does not service the work services organization very well.

Don't ag7ee with the type of CR's being wntten, just DO IT, Dramatic improvement in the backlog. Better quality. Faster resolution.

'Duphcition o' input.

Effective. Rapid tumaround and updating of info.

Effectiveness not there yet.

eedback is near zero. Many times CRs are routed back to the person who generated it for resolution. Other imes, the CR seems to disappear into a black hole.

Feedback to initiator of final result would improve progtam. Current feedback is 03 assignment of corrective fction.

Flooded with low threshold I: ems. Too cumbersome to fa things in a timely manner.

Forced into using. Sometimes being abused but intent is good.

Gone overboard. Volume too great. Problems are often vague. Everything is a "1" or "2*???

L!ttle Harbor Consultants, Inc.

Page 3 of 8 r

i .. 1 MMMMMhh Gone too for and is not very offdsnt, constantly changing, resolve everything in 30 days is too much given everything else that needs to be do.w.

Good at ID of problems, still not good at solving them. Oversight will be looking at CAP in late July or early August.

Good for identifying and tracking. Very d4 cult and cumbersome to use.

Good intentions, but process toc cumbersome. I Has heard of them; but it doesn't get to the fire watch.

Have gone overboard, too much work.

High volume.

Huge backlog, behind and can't catch up. Does seem to be working better, if a CR is written on a hardware problem it is more time-comsuming than just replacing the hardware itself.

Multiple CR's on a design package with no flexibility whatsoever, j implementation inefficiencies, cumbersome process, causes lots of frustration. Maybe not used because of burden. Lots of room for improvement.

Improving, disconnect between identifying and fLxing.

It is too cumbersome, too complicated. Too many people raising concems for own personal gain.

It's a do everything program.

It's an administrative monster, it's broke and is choking us, it's too complicated & they keep changing it so no one understands it. Lack of tng. Em forced to use it.

Kenyon prom; sed new efficient work processes, where are they?

Lacking in implementation of Corrective Actions and follow-through. Attention to timeliness. Interim CIAs are hnd-aids.

Litue Harbor Consuttants, Inc.

Page 4 of 8

i .,

i-M M % h M AstleFmp1m Lessons aren't being loamed. New item on source of supply of elect. Rotors (Maint. Unit 1) is a repeat..

ILot tr. ore emphasis placed on it but it is too early to rate effecoveness. In past CRs go to responsible work grp but nothing was done. New grp was established to work down backlog. Potential to retum to the old way.

Mgt not able to recognize the proper root causes, CR's should not go to people who don't know t.w technical detail.

~

Move effective with the unit focus toowy Still cumbersome and clogged, Training may be the answer.

1 Much better today, worked off backlog. But not sure if we are fixing things right the first tirne. '

'NCR is asking engineering for a resolution. i (Need a better handle on closure. Many are repeats.

L Need to purge backlog.

Never see results.

'Never sees results of CAs from CRs written for self assm'ts.

'No--his group normally doesn't use CRs.

!Not a consistent threshold.,

~

Not a whole lot of confidence. Would use nt the direction of supervisor and system engineer.

Not as effect*e dealing with ' soft" issues as with hardware.

Not there yet! It used to t,e a lot easier to get work done right. T'oday it is too complex and complicated.

Productivity has suffered and very little value has been added.

eeople play games with system, stay in

  • notify" and wait to last minute to transfer.

Process way too cumbersome. Some people won't fill out because its just too hard and it will boomerang back to them.

Program is good, problem is in implementation. What is the role of the Director of Corrective Actions?

LRtle Harbor Consultsnts, Inc. Page 5 of 8

\ .s

, +

MmphMh>

8tessonable effective ty*/ because of the tremendous emphasis being placed on it. Peope kooping own data-bases in order to keep up.

Room for improvement.

iSeen as punitive by some detractors,

' low. Threshold too low, Aooding the systeni So cumbersome and burdensome, almost never gets implemented. Tough issues dont get resolved. Had a CR go through MRT and still didn1 work out.

po many written it gets diluted. No sense of priority. Need better screening. Fire extinguisher and RCP have yme priority.

' ome people think the CAP has too much paperwork. Have a large number right now. Too time consuming and nnexible.

%ometimes issues are input when somethings broke and should just be fixed. Too complicated for the end i

fesult. Should be more toward generic issues. Understand trending is better, but root causes still weak.

' Sound program, but tco complex and not user friendly, Step down from a year ago, if you write CR lt ends up back in y'our lap, if note it can work off when you have fime.

' System is working and is on track.

'Taken to the extreme!

Takes too long . Question if things are getting looked ct close enough.

trhe processes are cumbersome, especially to timeliner r3ver burdening.

1 The whole system needs to be stream-lined.

The working level at site continue to do their jobs well, in spite of very complex procedures.

r There are " tons and tons" of CR's.

There are ton many CR's in the system, but it is improving.

Lit:e Harbor Consuttants, Inc.

Page 6 of 8 7 - . _ . i

t ..

M M M h h '11N M @ _

Throwing CR's at everything. Not seeing any maults from L6nding and analysis of CR's. Need better training CR s a,e ,oo,iy weien. l Tied up in p19erwork.

foo complex & is used for items that shouldn1 be addressed as a CR. A lot of this is due to lack of tmg. This

takes away resources. Threshold of use is too low.

Too complicated, too much paperwork.

Too complicated. Being implemented diffe enUy at each unit Too cumbersome. Procedures hard to follow. Lots of forms. Makes a mountain out of a mole-hill. Assignments are difficult.

Too limiting because it punishes the user by focusing resolution on initiator. Work load is chilling effect in itself.

! foo many CRs without significance dilute the system. lli need to fix something i do it without CR-too much

! trouble to use it.

i l Too many issues to be handled effectively.

l Too new to tell.

l Too time consuming and cumbersome.

Tries to resolve problems through experienced peers rather than via the CR.

Tries to use peers to resolve first. On.[i ,,, confidence issue would be resolved via CR.

Very cumbersome.

Very effective not very efficient.

Very inefficient.

Volume way too high.

We are over-doing at raising concems and writing CR's. The threshold is too low.

Little Harbor Consultants, Inc.

Page 7 of 6

1 MMMMMMM We put a lot inore on paper than we need to, ho*s pretty good.

?

[

Wrong assignments reso;ution, almost impossible to change, who wants it?

1 mut +4 l

(.

Uttle Harbor Consunants, Inc.

Page 8 of 6

InterviewResponsesto Question 17a

% M ulyMyMMMtM yEWP N yu,wW s's tiew

[ Weak staff).

t) Ineffective based on personal perspective. 2) Chose DOP b/c of experience. Not real high on probability list.

As a contractor I'm not sure it applies to me.

Because it would not be effective.

Concemed about by-passing his own management.

Concems not processed in timely and offective .mnner; incompetent.

'Doesn1 know who ECP is, poesn't trust some of the people.

l Don 1 see any advantage to taking to ECP. No drfference than taking to hne managerrout.

Don't think they have enough voice or can do anything more then the line.

IECP has no clout, raised a concem 7 months ago, still open.

ECP is not nocessary.

Has confidence in other re:nedies.

I have a hard problem that NU hired [ Person)- perception vs substance.

I think it's a joke.

l I would go to hne management first. I would be comfortable with ECP after that.

If confidentiality were an issue would not use ECP. They have let identity become known too many times.

Little Harbor Consultants, Inc.

Page 1 of 2

'~

. o --"-

% tW9WyMVWMWtW h_EFF Kyu.wWn k6 i 11 the issue required immediate attention. ~

ineffective, organizationally poor, [ Expletive) cast of players. _

tt's had a bad reputation and talking to at least 2 peer reps.

before you go to ECP. TheyVe told rne you might want to think twice Line can resolve a concem, and have no reason to use ECP. '

Mentioned d5culty of maintaining conficentiality if used ECP. _

Might get back to management. If not nuclear lasue they won 1 preserve anonytnity Prefer the direct approach. -

Rumors that the staff is weak, poor people in organization. Would probably use in a pinch, Seems OK today, but in the past there were totalty unprofessional peop'e involved.

Would not use ECP for non-nuclear and don't trust HR. ~

Litus Harbor ConsuRants, liic.

Page 2 of 2

InterviewResponestoQuestion17b

w. . . . . . . - e A lady (NU employee) works w/ talked to him about an issue & he tried to get her to go to ECP & she refused b/c she was afraid.

A lot of peop8e I know would not use it. Lots of people are waiting to see before using IL An individual raised a cutcem and his supervisor was aware before he got back to his office. Once bumed, twice shy Now that person has a severely challed attitude as a result.

An obstinate individual who may have retired. I l

C had discussions witn ,sople T who were not getting resolution but did not want to tak6 it outside managernent.

l Hear negative comments about personnel involved in ECP, Heard that ECP poorly handled issue a couple of months ago.

It might draw a lot of attention and then you might have to move on.

'Knows

a number of people who woulo not go to anyone with "sufi' issues. ECP has a chance to demonstrate l l success, then it may be different.

%ess aggressive people who don 1 wont to expose themselves-a new person. None of the old timers would be reluctant.

Let's of people are still afraid.

Most employees just don't trust them.

No reason in particular.

Ndt by name but by sight. Still think there is retaliation.

Others have said that they Jon't cee the need for 1 if managen,ent doesni care in the evaluation, what good is ECP?

People would rather deal with lone management.

t Some feel that i 4 an agent for management, "the early waming system" People who think that way should be !

made to go to the shrink.

l Little Harbe' Consultants, Inc. Page 1 of 2

_ _ _ _ _ _ _ - _ _ _ _ - _ - - - - - - - - - - - - -~~- ~

w -n . ...rmn w Some in our group would go directly to NRC, rather than use ECP, due to their personalitie

~

Some of the older employees. '

I Some people complain about everything. "They have their reasons".

Some people in area would not use the ECP b/c of past history.

^

Some pesonality cor flicts, past experience implies concems won 1 be deatt with app Some recalcitrant who didn1 trust anyont.

I Still a feeling that the minute you go to this kind of group, you discredited. ,

are exposed to risk giving a on on how to IStut,bom people will not use it. ._.

[.

The one individual felt he would be labeled s' troublemaker if he went to the ECP T5ere are a lot who are below me who would fear their jobs and just wo ld u not use ECP.

Uttle Harbor Consultants. Inc.

Page 2 of 2

InterviewResponsestoQuestion18b w . ,. . - . . - m r A last resort.

After exhausting Une Managemeist attematives.

J

'After lin) and ECP.

All else has been exhausted, feel strongly the issue was still a concem.

'All other attema*.ives failed.

All other avenues have been exhausted w/ undesirable results.

I fs a final result to get the issue resolved.

I As a last resort if all other paths failed, but that is not likely.

As a last resort, if not getting any action from other avenues.

{As a last resort.

l A3 a last resort.

As a last resort.

As a last resort.

As a last resort.

{

l

%s a last resort.

I As a last resort.

As a matter of last resort if NU management would not address the concem.

Utile Harbor Consultants. Inc. Page 1 of 13 I.. .. .

._________.----j

s ..

4 f

"!Wudd yes tes a suusm te es E?l B yes. uitar WWit sesseus?"

Behof that this is an important issue and that company has not apprepriately responded to it.

' Cant get it resolved intomally last resort.

Can16magine having to use.

bepends on the issue. If the system failed.

Failure of pmper resch. tion of concem.

If all earlier efforts to work within NU had failed.

If tilelse didntwork 11 all else failed or timeliness became an issue if all else failed to work If all else failed.

If all else failed.

If all else fails.

If all other avenues failed.

if all other options fall, i if a!! other routes failed.

If blew off by management and ECP.

If chain of command did not respond, if chain of command failed.

Uttle Harbor Consultants. Inc. Page 2 of 13

x --_--. _ _ _

m._ z - _-

\ .s M VW W 8 M lB h EST}Nyu, W m M If couldn't get it resolved otherwise.

'If didn1 get proper resoluten elsewhere.

1 if didn't get resolved within NU.

If disappointed with station management action and if convinced it was high safety significance.

if everything else didn1 work.

If exhaust all other options.

l If felt that concem being raised could have a negative consequence on career.

If forced due to management's actions.

ilf getting nowhere with other avenues.

I If he felt is was important enough.

If he honestly believed inat issue was a nuclear safety concem not being handled by management.

If I felt I was being lenored.

If I felt strong enough about it.

If I had to because direct management wouldn't handle it.

If I had to get it resolved.

If I had to get resolved.

l1f l Wasn't getting the problem resolved, k

If ignored by channels.

Litte Harbor Consultants, Inc.

Page 3 c' 13

\ . au M V W taks s e to h M 1 W y m.

  • M M Ifin-house failed.

If it didn1 get prorr<pt and satisfactory response within company, if it was a nuclear safety contem and it was necessary, if it was an immedials safety issue, if it wasn1 being addressed.

~ ~

l if it wasn1 being resolved to my satisfaction.

1 Tit wasn1 getting addressed.

If it wasn1 resolved anywhere else and felt strongly about it.

If it wasn1 resolved by other means.

If it were a serious problem and no one in NU would address it.

Ett were a significant issue and was not being addressed if it were an immediate threat to the public.

If it were big enough, as a last resort, and I were ready to retire.

If it were serious enough and not dealt with by line management.

If it would be necessary to get the concem resolved if line management fai;ed.

If management and ECP did nothing if management failed to handle substantive issues.

Uttie Harbor Consultante, Inc. Page 4 of 13

\

  • M yWW 5m ts h MI Nyu,emM If management fa' led.

If management refused to support resolution of my concem.

If management was ineffective.

If management was not addressing the issue.

~

If management was not responsive.

If necessary. If the management system failed.

l If necessary. No other avenue which would provide required attention.

~

If needed to. If concem in their ares.

if no one was taking my con'cem senuusly and didn't get back to me in a timely manner, f not addressed by management.

If not addressed properly before that.

If not getting addressed through the proper channels, if not getting proper resolution.

if not satisiied by the other processes. Does not think it would be necessary today.

flinot satisfied through normal chain.

lif not Msfied with NU handling.

If not satisfied with NU resolution if nothing else worked.

1.ittle Harbor Consultants,Inc.

Page 5 of 13

t ..

MVWheetshMI Nyu,mmN If nothing else worked. Not employee concems.

If NU didn1 act and was a safety problem.

if NU was not resolving issue through the chain.

If NU watn1 responding quickly enough.

If other avenues fail.

If other evenues failed, l

l if probbms with line management and ECP route fails.

I If resolution couldn't be gotten thru ths normal chain of command.

If significant and other avenues failed, i ~

lf sVuck out on management and ECP, If superp.sor and manager did nothing.

If system failed.

If that was the next step in the process.

If that were the only way to get a response, if the company chain of command was unresponsive.

if the issue req'd immediate attention.

If the other avenues didn1 work.

if thare were no resolution by raanagement. Last ditch effort.

Uttk Hartwor Consuxants. Inc Page 6 of 13

\ ..

,M VW h a m b h W1 N yu,e enaamissaat-If unhappy with other options.

li~ depends on how important it is,

~

it would have to be a very bad concom.

Last dstch effort.

Last resort Last resort Last resort and we owe it to the public if management cannot resolve a concem.

Last resort for nuclear safety questions.

'Last resort if unable to get an answer.

l Last resort only.

l Last resort.

Last resort.

Last resort. i Last resort.

l l

Last resort.

Last resort.

Last resort.

Last resort.

Lltue Harbor Consultants. inc. Page 7 of 13

.\. ,e MyumsetshM Eyu.emm Last resort.

~

Last resort.

Last resort.

Last resort.

Last resort.

Last resort.

Last resort.

l Last resort.

l- Last resort.

I Last resort.

Last resort.

Last resort.

Last resort.

Last resort.

Last resort.

{

l Last resort.

Last resort.

Last resort.

Little Harbor Consultants, Inc.

Page 8 of 13

1' 'n, 4

N Wttes e tsh Mitm e m m Last resort.

Last resort.

Last resort.

Last resort.

Last resort.-

last resort.

Last resort. l Last resort.

m-Last resort.

~

last resort.

Last resort.

Last resort..

Last resort.

Last resort.

~

Last resort.

l

~

Last resort.

Last resort.

Last resort.

Little Harbor Consultents, Inc. Page 9 of 12

. u

s ,i M ym m a e t h MINyn e m M Last resort.

Last resort.

Last resort.

Last resort.

Last resort.

Last resort.

Last resort lLast resort.

m tasi ,eso,t.

Last resort.

'Last resort.

!Last resort.

Last resort.

'Last resort.

Last resort.

I i

Last resort.

Last resort.

Last step but would never have to go that far.

Litus Harbor Consultants, Inc. Page 10 cf 13

t .-. <

o M VW W e m t h M Nym m m 6 Last stop to get it resolved.

Last step, doubt would ever get there.

Last stop.

Last r, lop.

Last stop.

Line would have to fau.

l

)

Management and others had not fixed the problem.

No resolution from management.

No satisfaction achieved with other options.

Nuclear concem and not getting response within NU.

Only as a last resort.

'Only as a last resort.

~

Only as a last resort.

Only as a tast resort.

Only as last resort.

Only for a major conum that NU did not deal with.

Only go to the very top (Commrssion) no confidence in bureaucrats.

Only if a nuclear safety issue could not be resolved by management.

Little Harbor Consultants, Inc. ' Page 11 of 13

F ,i e

M V W W 8 M 1B h E Cf} N y a, e e M IOny if an else fails.

-~

/

Only if an else fails.

Only if Ct.aldn1 get it resolved otherwise.

Only if couldn't get it resolved otherwise.

Only if I couldn't resolve the issue thru normal channels.

Only if I had to....

Only if intemal mechanisms failed.

Only if it wasn't resolved by line management and was legitimate.

Only if line management and the ECP didn't show any results.

Only if other avenues failed.

Requirement from other options.

Serious problem and last resort.

Significant issue and no results from management, can't imagine that happening today.

Under extreme conditions.

Very last step, can't imagine using it.

When got no or unsat response from NU.

When hasn't received satisfactory resolution within company.

With a lawyer, if supervisor doesn1 work, and I don't believe it would.

Uttle Harbor Consultants, Inc. Page 12 of 13

l l

W M bS M hh RQM W M M ,

Works w/NRC personnel, would seek their opirwons informally, a collegial approach i

Would be the last choice.

i, Would go W stone-walled by management and had a legitimate luue.

J l

i l

I i

I 4

3 Uttle Harbor Cons Aants,Inc Page 13 of 13

InterviewResponsestoQuestion18o

,. . .. - . n...r Because I don 1 have vofedence that they will keep in Confdence; the worst violators of the entire program.

Do not trust them.

I I feel that I could get it resolved within NU.

Never again b/c the NRC did not do anything at all t4 9/96 & in 4/97 the NRC called bar.A & said they were doing an investigation.

No need to do it.

No need to.

l Uttle Harbor Consultants, Inc.

Page i of i

4 InterviewResponsesto Question 18d l

= - = . = % __ u. . ..

Based on what it takes to resolve. Will raise legitimate issue.

iBecause if an USQ must be resolved.

Could by virtue of time to resolve, i

l know just from working here that every concein is tied to restart issues can take time tu resolve.

i 11 has been brought up.

it means management has failed.

No but it is on people's mind.

~

Option is available, no need so far.

'Possibly, depending on concem.

! Read it in report on CR threshold; lowering threshold might delay restart.

!Sure. tiature of problem would take time to resolve. Could impact others' willingness to talk.

Time it takes to deal with them.

Little Harbor Consultants,Inc. Page 1 of 1

InterviewResponsesto Question 18d m bsess.ihet.si s ,sesmises===is ,fset w.,s uis, -

Iffut Emmment whhh sakes s.Wra ntetant to raha a samarr beamse of red r ps1.W sethns r huhnbre by smusement r paars towsN sthers who hss tens saJ If you re swers of a *ct.g effect",whars k it scomiter"

[ Group in Area). tesidual effects. l

[ Group, Group, and Group)in unit 2.

t

[ Group) across site.

[ Group) and [ Group) across all units.

[ Group) and rumored in the [ Group).

[ Group) as a whole.

[ Group).

{

[ Group).

[ Management) level and above.

l ,

[ Organizational Elements)

[ People in Group) 4

[ Person's) orgentration.

l [Two Organizational Elements).

l I All the way from Manager to the VP. (Supervisor is chilled)[ Person) gave interviewee a bad review because he was siding with employees who raised safety concems.

'At the ' sponsorship" level, i

At the supervisor and mid-manbgement level.

i

< LRtle Harbor Consuttma's, Inc. Page i of 3

l

'lh h se tW h am W bem meneted to a *m effect" wlDi W to rdsbe esiseu. m Effect: Envhisasut widah askas asleysus ruhetat to ruhe a oman huomme of md r putWnd acthns r behesirs try smuguset r paars towsil suurs who have ihm mJ If you re own sf a 'eless effset", wlum k it snartte?"

before there was a lot of finger pointing. It's much better now. Yes--over promotions in [ Group)(all units) and

[ Group).

First line supervision, on our floor.

From the press, from the outside. 7 I was accused of creating a chilling effect by talking to other group leaders and sharing confidential information that really wasn't confidential.

In [ Group): don't trust anyone. [ Group): problem iyr ago, probably not now.

In[ Person's) area, in [ Person's) area. It's their style, fMdie management site wide. Not intentional, e g.: not assigning a job to someone who is likely to raise a potential problem.

Middle management.

No, except [ Person) incident.

'Not for safety issues but still is for management and administrative issues.

lNot for safety issues, losing confidence in management they don't talk about problems just about the good stuff l Organizational Elements).

Pockets.

IRumored te exist in [ Organization), from upper unit mgmt.

Senses in own department, some ridicule, non-sequitor answers.

Some temporary occurrences but management seeks them out.

IStill exir's 'in the plant".

Still reluctant to take it those who treated you bad!y in the past Little Harbor Consultants. Inc Page 2 of 3

"Ik h M M mtsu 6 h h 6 te s *m effet" with W te e m m Effut. Enhuant whhh muka saghysse rakstat to mbs a sueurs baness of rul r pnelved othes y bdestre by W r M M sthW h h m.] N ymi re swn el e 'm effet', e h it sw There is an overall chilling effect because of our current uncertalnty to the future.

Thinks it exists at [ Management Level), old habits spilhng out, apologies being made.

l l

IUnh 1 has a chilling effect due to economic pressure alone.

I Unit 2 [Spedfic Elementl) project management.

Unit 2 [Spedfic Element).

Unit supervisor may say things in jest, but can have a chilling effect. [ Organizational Element).

Very possible et my VP's level [ Organizational Element).

i' Wherever [ Person) or [ Person) may be.

Would not ral6e en issue to [ Person).

Yes, but not on 6afety issues. l 2

j Yes-in [ Organizational Element) People in this group fear retaliation from their Dept. Head.

i I

Little Harbor Consultants. Inc. Page 3 of 3

1 InterviewResponsesto Question 22 I

'is llure anyputts 'let l GWt uk tint i sludd limW" teural tammets.

"We , 3 no worse off than many others in the industry *,

  1. CRs increase-folks comfortable. Effective training Resources-too many contractors to build group.

Concem would be addressed-outcome not satisfactory. Raised concem-no action from super /mgr; went w/ parallel mgr io ECP-happy w/ close-out.

[Org Element) is like a black hole. Supervision doesn't have the guts to make hard people decisionsIor the last 3 weeks I have been paid to do nothing, asked to be laid nff, to no avail. Bruce Kenyon and hlw direct reports are credible and believable.

l l Organization) manager

  • consider this bootcamp. I'm going to shave your heads, tear )ou down and build ou back up again' Has chilled the grcup. (100 people).

[ Person) sometimes shoots men,enger and retaliates against employees who bring up concems. Chilling as not changed in the last year. [ Person) does not know what is going on.

A mos. In current job. Given enough time but not resources. High confidence in supervisor but things get idropped if goes higher (even CRs). Raised concem-had to bring up 3 X b/c nothing done-typical NU-things ptarted; not followed thru to completion.

'A great desire to see plant restart. Rejects the idea that nuclear safety would ever be compromised for job isecunty. Management should find out what the workers really think, walk the talk. Get out into the plant.

(A lot of personal agendas have had a huge impact on Millstone. DPO's are OK if they are legitimate. Many are not.1

^

i]A ear ago would not have said a word if had an issue. No problem today. Management won't turn their back lon us. ECP need better communication, don't know who they are and jury is still out on them.

l_

' dm. Tmg avg; tech tmg bad. Raised concem: frustrating but fixed. Site making headway treating people;still

, ong way. Schedule still driving force. No results from self-assm'ts. Top mgmt's prionty production. Upper yngmt needs mingle w/ troops.

Analyze the concem to make sure it is valid & needs resolution. Concem about

  • hiring practices
  • In Unit 1.

No evidence of presence of chilling effect.

At times our employees can develop a " crusade syndrome" that in tum causes an emotional response from supervision and manrgement.

Barriers still exist to open discussion of issues. There are still some supervisors / managers who discourage a questioning attitude.

Uttle Harbor Consultants, Inc. Page 1 of 12

e 1MgpMlWidMIMW MM ,_,

Beteeves new mgmt. Raised concom-no results from previous unit director; resolved w/ new unit director.

Con 6 dent things tuming around. Pressures going to increase b/c of everything coming together for restart.

Berlin management was horrible. People here are trying to do the right thing.

, Bruce Kenyon has brought hope although we are not there yet. Pressure in the job made him list production its top priority.

l Bush my way or hwy Encourage good comm in Myrock. N. Safety mgt priortty since Kenyon. Raised concem-good resolution.12% CE playing game to conoems (protecting selves). [ Group) isn1 acctble-supv not people persons. Common sense not used on site.

ICancel.ation of ' Power of Five' created more mess.

jCEs inM vocal now. Mgt listens more now. Comm giod U1/ 2 b' turiot 3-[ Person) prob. Not as bad as ail pkes sound. Wonders how concem issue such big deal never had prob. Knows 2 have raised concems; i

are not happy w/ outcome;not agree troublemakers.

f ICES more willing to ask quos than before. Top mgt priority-n. safety but cost pressures;mpt pushed envelope before. Some mgt only saying right-good show. Mid mgt not loomed empower. Units competing affects

[earnwork.NU affected by outside influence-PSC pomfort level w/ raising concem has improved. One of the rnost notable changes. Effectiveness of

icommunication becomes less effective at higher levels oue to nature of beast. Presence of chilling effect

%ay be in' pockets; not in general.

pomfort raising concem dropped b/c CEs womed about jobs. They are rea9y/ honestly trying. Millstone above avg in doing right thing compared to other sites. Comm worse lower in org. Thinks there are CEs who houldni use ECP-doesni know personally, pomm question-wresthng w/ dartty of wntten comm. A few yrs ago, there were individuais who got ,

"squashof. Prepares through study ofissue before raising.

Concem over coop. Between units and non-unitized staff. Sees new doc. control as lack of confidence in staff. Confidence in Cams (coffees) and Kenyon.

~

Concemed that there isn1 enough tr+Justry inte acIt 5Iand benchmarking going on.

Configuration mgt la finally paying attention to the materials being used. Seems to be getting better. You cannot get material without specifying where it will t,e used. First time!

IContractors are treated like 2nd dass citizens. A lot of talk about self assessment but no results.

Utue Harbor Consultants, Inc. Page 2 of 12 U

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

i

%MWy@MlElNMlMM MM _

Contrac'oca are treated like noo'nd class cuens Cams event an example of the double standard at Millstone Unit 3 technical arrogance prevents issues from being identrfied.

Corporate cdEllenge at Northreeld Mountain a good exponence and overcame some history of favorttism and unequal treatment.

k:R not for personnelissue; where do these go? Paths for technical issues, not personnel. Questions from ECP on concems too general to get a good answes without *20 Questions' Curreint management team is getting tneir message across.

Dramatic improvement in his department in last 6 months. Middle managers see startup as an end goal.

[ Person)is non existent. Kenyon and Brothers are good communicators.

Employees are not as comfortable yet as they could be. Dave Goebel being put in charge of ECP is very good, he will get it done.

Everybody seems to be pulling together,

!Everything is right up front.

iEverything we do is a fire drill, Onty in job 2 mos. CEO/ exec say a lot but don 1 mesn. Would go to the NRC iand never up mgt chain or ECP 'or handling a safety concem. Other people in his area would not use the lECP.

Executive management's priority a year ago was cost and stillis.We have to get through this by year's and of we run out of money.

Executive management's top priority is cost. I'm seeking employment elsewhere because this place doesn1 have a prayer, Only company I have been ashamed to work for, Feels good about his work exper6ence at Millstone (four year employee).

Frequently feels really alone in dealing with problems. Needs a "Who does What' guide to tell him who is responsible for problem solving.

From Sept, '96, has felt that the commitment to ECP has gotten stronger and that finally it may work.

Little Harbor Consultants, Inc, Page 3 of 12

4

%%RQhWlWt6 MlHW WM Get the job done. Snng up concems and see thet they get resolved.

Good old boy network st6ll exists in torne places, getting better Vo;y positive about work group Rothen is proat.

Orp for 3 mos. [ Persons)-cost; [PersonFprod; [PersonFsays rt things. Raised conoem-poor response-supv-nut support @ ist. [Porson) jumped all over lead auditor at audit exit appror 3 wks ago.

Has a safety concem has been struggling with for last 24 hrs conoemed about possible impact on career, Has always felt that those he knew at Millstone would make a conservative decision. Felt the the U1 spent fuel issue was because of not knowing that the FSAR was a goveming document also, in addition to the toch l specs.

l Have seen major movement in the last three mcnths. Self assessment is becoming a contenutrig part of daily life. Ezec. Management. led by Bruce Kenyon, is very accessible and communicative.

ll s till arrogant.do believe that some employees would raise a concem for the sole purpose of protecting l

ll feel more confident with the change of command than i did a year spo. Chilling effect is virtually non-existent today.

l l have more confidence in supervision and management that things will be acted upon.

ll think that the fact that many employees r?ly or' their jobs is a possible inhibition to filing concems. Why does it take mgt so long to hear what people say? They have lost their people skills and become work a-holics.

I would raise any concem, but would feel bad about any serious one that may delay startup.

li LHC doesn't know how effectrve our plans are then you did not do your job.

If we don't have a unit running soon, we won't have a job. Feels that this is a motivated, safety conscious work force. Why doesni the NRC come take a good look? Including Chairman Jackson?

In all meetings they say safety first, quality second and schedule third, yet they are clearly schedule driven.

Executive management is too schedule driven.

Little Harbor Consultants, Inc. Page 4 of 12

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

% tium my gesumi nut 1 AWt at not i statilewr" teorid tumustr.

~

In his group safety is #1, period, no doubt whatocever.

\

in the past he was bltter because he was let down by his leadership and it was not his fault or his co-workers. Angry at past managemer1 for screwing him up and he had no control.

inadequate resources. Management is just not hearing us.

Z interviewee has + attitude. Knows how use cha.,i nf command effectively. NU disentninetes against contrar: tors. Likes Kenyon's periodic explanation of events.

Interviewee likes her situation today, quite the opposite with the previous administration.

Interviewees director never gets out in the plant and meets his people.

It is a totally different site today Difference is unbelievable.

fenyon always talks about respect for the indMdual s.7d doing the right thing, and I believe him. Most iemployees are still not ready to trust management. On the other hand, management is intent on building trust. i l

Ker. yon has done a lot to make everyone aware that it is unacceptable to not bring something up We are making progress.

Kenyon is invisible; don't see his presence. Cams has made inappropriate. Comments on Unit i l&C tech.

Procedure change not integrated. No in-process training (MIMS)

Knows and understands Kenyon's Expectations & Success Obj; but, has never seen posters. Tmg deteriorated past yr. Mgmt focus from production (2 yrs ago) to safety. U2 will be physically ready for restart before U3.

Knows people suspicious of ECP. Mgt saying right thir$gs.

Lack of teamwork across site is biggest issue.

Last leadership survey discussed only the supervisors, not others up the line . seen as a real negative.

Uttle Harbor Consultants, Inc. Page 6 of 12

. -4 .~ . . -

1 k t X @ M l E t W Esill M W M M Line mgmt has said *you san 1 pet that in report will make me look bad; you doni know what you are talking about? Some mgmt with omamental ears.

Little tmg on specific job. Supys promote nog towards concem (taxe too personal). Deterioration btween supy & workers. Discussed recent leadership assm1-just another survey that won't result in action. Supv needs to listen more to people in workgroup.

Lots of management changes, NU to Seabrook to PECO, and PECO doesn1 seem any better than those they replaced.

4 Lots of nice policies + not being used on site; not policed or consistent.

, Low confidence in current Director and supervisor, Shortcut 6 being taken to recover from stand-down in training (talk do it right, walk-get back in operation.)

-)

Management and supv. Training is lacking. There is a growing inertia to 'not rock the boat" f.anagement is Deginning to take an interest in the employees. Once the units are up and running, will it tevert back to where it used to be??? Until a year ego ECP wasn1 worth the paper it was written on because

%nagement didn't want to hear, Managemeot is nr>t walking the talk when it comes to bringing up concems and dealing with them bppropriately.

, l Management needs to listen. Used to not listen now they pretend to listen.

Management seems to be bending over backwards today to get concems on the table. Hope that someday we don 1 need an ECP, l' %anagement s$ould be held accountable consistently by an objective, outside third party, I am sure while we late in the spotlight that any nuclear safety c.ancem will be appropfiately handled, but not so sure after the

)ights go out.

Mgmt priority from cost to safety. Comm prob-Issues diluted up chain. Discard /re-do procedures vs band-sids. Boss critical to proposed chng. Morale-very poor. Top mgmt expectations not thru mgmt chain. Non-exempt EE not treated well. Not people co. any more Mnmgt/ supervisors good pointing out directions; prior, executives good but was wrong direction. ECP is good program. Presence of chilling effect doesni exist. No problem w/ safety concems program; problem w/

Individuals, More emphasis on communications, cooperation and teamwork. Needs to be more sense of accountability and responsibility.

. Little Harbor Consultants, Inc. Page 6 of 12

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% nere surymstun not i ert ut est i emm isest" taurg a,masan, Most of the problems come in the middle tr.anagement ranks out in the field. Mind-set that all contractors (esp. union) att trying to stretch out the job. There is an absence of 'co.1structability" of the procedures.

"Much better sense ofi:or:sistency and predictability than pre-Kenyon days of extreme fluctuation.

%uch variation in people skills of various foreman. Much info to Millstone's transttion never reaches fire etch. New unior, contract is unfav, but not ECP issue.Knows little to ECP Mgmt now much more focused han before on dealing w/ chilling effect.

Myrock doesn1 get the recognition we deserve.

N. Safety not always top mgt prioetty-ex of U2 vatve tried 32 X to be sealed. Raised concom-didn1 fully agree but accepted ok. Q22: No-Most of my answers are upbeat b/c IVe always been able to talk to my mgt.

Need better face to facs communications. Need more training. ECTF will *get the bad guys" who are still out there. Communication breaks dowr* at the Director level gets mushy below & Supervisor deesn1 have a clue.

I Need better human resources at NU. 'i his is the first time he has had a personal interview in over 16 year at NU.

Need to purge nordperfcrmers. A realissue. We have hog tied ourserves. A handful who had real poor treatment and many more who are non-performers and bitching.

New management is great. A stronger sense of being a team today. We have to gain the public's trust again.

That really hurts.

No follow-up or action on results of critiques ~ b/c budget / schedule? Performance appraissis very late.

Continuity /standardslexpectations suffer b/c mgmt are contractors. Stability, confidence in upper mgmt lacking. Kenyon not good

  • break point'.

No ownership in procedures grp. Comes together in mid-mgt; they're the problem. Pressure on mid mgt for production.No consistent mgt. Open concem. Repercussion-peer verbal abuse. Big issues pushed aside/not resolved (tng); little issues fixed.

No perception of animosity in mgmt. Potential chilkng w/ next lay-offs, ineffective corrective actions; poor trending. Lack of cooperation-competition cost a yearl Resource reduction causing problems. Mgmt changes were not solution to problem.

Not very aware of ECP. Layoffs disproportionate to minoritiws.

Noted + change began 4 yrs age. Raised concem '92-93-poorty handled-should have taken further up chain. Maybe chilling in outlying orgs, not in units Q22: 1) Headed right direction? 2) Making major corrections to do right way-If do, should work on own.

Little Harbor Consultants, Inc. Page 7 of 12

is are my passu nut l awt se not t emN hsWF tumW t=-$

NU builds instructions and procedu.es too confusing. The procedure to write procedures is thicker than 19 procedures together. Cannot keep and hire good people because pay scales are too low Good ones are trying to leave.

OK to raise concems as long as it doesn't question something management has done, then it can truncate

your career, We are in a cris;s mode, too many changes.

4 Qn safety comm.ttee; now, ltttle mgmt participation / support of ' safety"; focus on nuclear safety. Q#22: 1) 1 Effectiveness of direction of org; 2) Been improvement in terms of r6ght course?

One thing Millstone really needs to work on is ' keep it simple, stupW. Get it done and go on. Don't make a big deal out of everythliig. Priorttire efforts.

IOutside managers are detrimental to long term success and don't have NU employees interests at heart.

Need some people who have gotten a troubled plant off the list.

Overall the atmosphere for raising concems is pretty good, fast mgt sh'd self assessed. Not happy job; people not respected. Current mgt creditable; past mgt not lead example Called complainer front 0; .:o-worker by mgt when mentioned prob. Chilling worse since push get unit up. Going r'ght direction under Kenyon.

People are not willing to admit mistakes a lot of people are still rationalizing. Status quo.

Positive info being derived from 50.54(f) proc est. Company doesn't support toch proficiency. Mixed msg. re mgmt priortties.

Positive on Cams. Cites meeting with his work group, reaction to coworker who took a set of issues to Cams (with supvst OK). Very positive on work group and their impact.

Positive reaction to the M Brothers incident. Things are a lot better today and is frustrated that no one recognizes it.. Kenyon and Brothers are good communicators, supervision is excellent, the in between needs fixing.

Previous managers who gr ve him a hard time have been moved out of his chain into Nuclear Oversight.

Department training flows. own for flexibility but is not meeting requirements.

4 .

Q18D: No. Just the opposite. Q22: Chng in Leadership Assessment-ie only goes up one level. Wasn't explained effectively; should not been changed. Still need resource loaded schedule. Peer of Paul Blanch &

Goo Galadis & felt they were not treated right.

paised conoem-initial result poor; but finally resolved-after threatened to call site safety omce. Overall lattitude towards doing things right is much better today.

l Little Harbor Consultants, Inc. Page 6 of 12

  • ls est ery gustlei nut l et(t ask list l ehmed luur toursl eammasta_

Rated production as highest priority because not involved with nucioar safety matters.

Re: mgt, message has gotten out. More evidence of follow thru. Thinks it's 6lnoere.More pain w/

timehosources b/c of startup. 3 yrs ago priority was production; msg was safety. Moving Chemistry under Ops was good move re efficiency and moral.

$chedule pressure from top down. Set schedules with no realisyc idea of what it takes to complete. Was narnSd that NU management selected the names for LHC to interview. Management says safety is #1, alt and see i month before startup if still true.

SEE FILE. [A long series of very negative

  • feeling statements' w/o specificity.)

Seemed genuinely comfortable with his work environment and the way things are going.

jSees improvement in management accepting iss aes. Example-has advised mgmt that core load date on Unit 2 needs to be changed to be done with key worir first. Getting positive consideration.

Self assessment is identifying issues, but NU is not taking full advantage to effect ch'anges. Still motivisted to corrective actions driven by outside organizations.

Self assessment not as strong as it should be. The ECP is more accessible now that Kenyon is here.

Self assessment programs have identified areas for improvement, but have not been implemented yet.

Self-assessments have improved communication and feedback te fellow workers.

Service groups are not treated as part of the team. Took an issue to Cams got no answer. Service gro.:ps have to deal with 3 different companies.

Should have some fun at the same time we are focussing on the re-start.

Supervision stn'ggles with empowerment. We should trust management to change the ECP without acronyms and buzz-words.

Supervisory assessment center has made a contribution to the transition of management. Bruce has promoted it.

Little Hart or Consultants,Inc. Page 9 of 12

'k tra my gustles list 1 $$rt at Out I shun hsWl' tauruHummuta.

Supervisory survey questions good but what results?

I The attitude towards raising concems at alllevels has e.5anged. They went to see 6ssues raised and ,

resolved. There has been improvement. l

! *The feeling is that if you raise a concem you can assure your job security or yet a buy-out or cash for personal gain.

The supervisors say what Bruce wants them to say and not necessarily what they believe, so l often don't listen and do what I feelis right.

There are pockets of people who don 1 communicate at all, just play games wtth others.

i i

There is no difference between what Kenyon and Busch say, the big differenc,t is in the actions being taken

today.

IThere should be more training available in how to do your job properly. People want to do the right thing today.

Things are much, much better today than with the previous management. Past :wnagement practices of E know better than anyone" will not happen again.

4 Thinks [ Person) went overterd in past. Thinks some have own spenda, seeking notariety, want attention

!_ and big settlement.

This is a good job and people want to keep them, but interviewee honestly thinks that pobple will not compromise safety fur theirjobs.

1 Thought ECP was a part of the CR process; top mgmt priority is a little light on safety maybe not irtentionally, i

Today's senior management has made it avlte clear that nuclear and personnel safety are #1.

i Too much paperwork for his area (Bldg Maint-HVAC). Too many problem mgrs still here. [ Person)(went to HS w/) good intentions but misinformed. Site is so big it can't be managed. [ Person) has been jerk for yrs (sues overyone he deals w/).

Total grid lock before. Perception is of a small margin for error. Not a gold pot fueling us. Kept on the steep part of leaming curve. Management is trying harder. Some positive changes. Morale still in pits.

Little Harbor Consuttants, Inc. Page 10 of 12

e 4 are any seems as'. l art se not l emm isver' teural emumsta Training poor, liow a mnre questioning attitude, Turnever rate influencing job. W of concoms & time needed affecting quality of eval,some disappear & lor parked. DYNst in new mgmt. Stili ' good ole boy" network. Losing some of best people. Many things being done rather than fewer things well.

)

Unit 3 denlaL we're here because other people let us down Up mgt saying right, not sure mean. Chemistry under Ops right. Knew [ Persons)-[Pwson) backstabber.HR handle promotions badly My level, only 1 chance; engrs moved other job. Job posting joke;HR not know doing. Too heavy Oversite. + feeling to site Ur.ually concems are based on lack of f/l knerwiedge of the situation. The people I work wtth are conservative and all want to do the right thing.

VEPCO management is no different than the others we had before. May become an arrogant nuclear island again.

Very positive outlook. Attributes improvement in attitude toward concem raisers to actions of senior management.

Wanted t_

to know if NU selected him tor interview, lHas not seen any results from self casessment process fenyon gets good marks, Cams and others wei end see.

We are getting better at a questioning attitude. The company went out and paid people off vs solving the issues.

We are still schedule driven. Unit 3 work lacking in quality. Raising technical issues are ok HR issues are not ok. [ Person) is a cancer. Clear distinction between treating technical vs personal issues. We are doing what

,we have to do to get paid.

We have come a long way in the last year, yet still have pockets of resistance.

I We must avoid bean-counting and measure those things entical to our success. Training is never validated and it should have been, fe must quickly fix the CAP administrative burden. The shoot the messenger nature of having the writer fesponsible for resolution is frequently orttemely drfficult to accomplish. Takes entirety too much time for the any conceivable benefit.

We're all here for the same reason, but management needs to give more recognition to those who do what's right the first tinus, Little Harbor Consultants,Inc. Page 11 of 12 l

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l 1s Bure astgestul Out 1 $$(t ask gut I sluiN iever" teural Rummula.

Mat is really holding this place back is that most are still in denial. Just wait for the media storm tJ d63 down. Kenyon never has a visible presence in the work place. hierviewee gave up after Kanyon did nothing effective. Doesn1 think it will work.

Who is the ECP? They are never out in the plant! It is more important with my management that you get along with everybody, not did you get your job done.

1 Whole problem was a lack of trust. Personally never had a problem, but management mis-handled past personnel issues. Seems to be trying very hard to recover today.

1 Wehet there were an all-knowing body of technical expertise to render solid judgments.

W

' ork processes are very cumbersome.

l Work week managers are totally schedule driven, I

Worrles about priortty of

  • training
  • supervisors, should spend money elsewhere and just get rid of the supervisors who don't measure up.

lWould go to NRC before ECP, doesn1 know who ECP is Fett very good about the M Brothers apology femmwork has decreased in last year on Unit 3 and Millstone.

Yellow badge is a detriment to getting things done.

I Little Harbor Consultants, Inc.

Page 12 of 12 o

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i OVERSIGHT OF MILLSTONE WORK ENVIRONMENT i

Little Harbor Consultants i Presentation to l j Nuclear Regu!atory Commission '

i August 6,1997 ll

August 6,1997 Preiesist6en to NHC Commhs6coers I i

i i

i s

ENVIRONMENT FOR RAISING l CONCERNS HAS IMPROVED l -

Management expectations have been j communicated effectively j Yes 94% No 6%

i -

Workforce is willing to raise safety concerns i Yes 100% No 0%

1 j A. its,i,97 rrmouti.. i. Nuc c...tini..ers 2 l

)

j .

1 i

4 ENVIRONMENT FOR RAISING CONCERNS HAS IMPROVED

+ Workforce has greater confidence that concerns will be resolved ndled A p op y 4.8 l

f1 80' 3.8 o< i

  • VeerAge" June 97 August 6,1997 Presentauen to NRC Commissionns 3 SAFETY CONSClOUS WORK ENVIRONMENT Existence of ,, ' ""~"'"'^~"~

Questioning ja "

Attitude: j"

,. , m .,

impact of "Self-Assessment" on 48 % Yes 52 % No workplace:

August 6, l997 Presentshen la NMC Commissiseere 4 i

__J

d SAFETY CONSClOUS WORK ENVIRONMENT Presence of Chilling Effect presence of a 1 .o .

chilling effect i 24 at Mlllstone: j 2,. u ir - i

" Year Ago" June 97 Augwat 6,1997 PresentaUen to NRC Canuniasioners 8 l

l CONI2lDENCE IN EMPLOYEE l CONCERNS PROGRAM GROWING Confidence in Employee Confidence that concom erogram using ECP will  ;*. u result in i...

resolution: j

10 - S v..,A..- un. .,

Any reason you would not use the 8 % Yes 92 % No ECP? .

August 6.1997 Presentauen te NRC Commlasleners 6

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.. ....w

IMPROVEMENTS IN EMPLOYEE CONCERNS PROGRAM Necessary resources have been provided for the program l -

Enhanced program is documented in new ECP Manual Experienced contractors brought in to support program implementation August 6,1997 PresentaSen to NRC CesanMoners  ?

DEFICIENCIES REMAIN IN ECP IMPLEMENTATION Staff qualification process has not been I completed l Staff training is not yet implemented 1 Lack of discipline and compliance with the ECP Manual requirements  !

37% of 27 employees who had filed a concern expressed dissatisfaction and would not use the arogram again August 6.1997 Prnentauen to NRC Commissioners 8 l

i

DEFICIENCIES REMAIN IN ECP IMPLEMENTATION, cont'd

. ECP intake process is not properly prioritizing nuclear safety concerns and retallation issues

. ECP database lacks data required to provide meaningfulinformation to management Management does not always recognize presence of a hostile work environment a s,m e. .. . .. ne c...u ,

DEFICIENCIES REMAIN IN ECP IMPLEMENTATION, cont'd Documentation in many case files is inadequate and not improving Intake and investigation of concerns often performed inconsistentiy Based on file review, some cases improperly classified as resolved or closed 53% of open concerns centain retallation issues 4 .. im r, ..... ne c...w .. i.

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