ML20216C067
| ML20216C067 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/06/1998 |
| From: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| To: | Blumenthal R CONNECTICUT, STATE OF |
| Shared Package | |
| ML20216C071 | List: |
| References | |
| NUDOCS 9805190085 | |
| Download: ML20216C067 (3) | |
Text
l So - 2 V5 f, UNITED STATES
,4 7- %,4, NUCLEAR P.EGULATORY COMMISSION Distribution:
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- WASHINGTON, D.C. 20555-0001
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/ May 6, 1998 H mpson PNorry CHAIRMAN JBlaha SCollins, NRR SDembek, NRR GCaputo, 01 KCy., 0GC HMiller, RI The Honorable Richard Blumenthal WBeecher, OPA Attorney General DRathbun, OCA State of Connecticut G980178 55 Elm Street ED0 r/f P.O. Box 120 Hartford, Connecticut 06141-0120
Dear Mr. Attorney General:
I am responding to your letter of March 16,1998, expressing your concerns about a recent document by a high-level Northeast Nuclear Energy Company (NNECO) executive that seemed to suggest continuing company efforts to isolate or silence whistleblowers. You requested that the U.S. Nuclear Regulatory Commission (NRC) thoroughly inquire into the origin of this incident and the possibility that NNECO attempted to cover up the issue.
We are also concerned about the implications of the NNECO document referenced in your letter. The NRC staff sent NNECO a letter on February 10,1998 (Enclosure 1), expressing this concern and requiring NNECO to respond in writing under oath or affirmation. NNECO sent its initial response to the staffs letter on March 12,1998 (Enclosure 2). The response made reference to the findings of an independent investigation conducted to review the circumstances surrounding the creation and distribution of the document. On March 26,1998, NNECO forwarded a Report of Investigation that was used to develop the March 12,1998, response.
(NNECO asked the NRC to withhold this report from public disclosure, pursuant to the NRC's regulations, because it contains personalinformation.) The NRC staff is currently reviewing NNECO's responses to determine the appropriate course of action to complete the inquiry.
I have asked my staff to keep you informed of significant developments. If you have any further questions on this issue, please contact Phil McKee, Deputy Director, Special Projects Office-Licensing, at (301) 415-2240.
Sincerely,
& i Shirley Ann Jackson <D6g '
Enclosures:
As stated (2) ropa p m e ~.m .
Originated by: [SDembek,NRR]
d h 5c.i M arc' N W 9805190005 980506 PDR COttMS NRCC CORRESPONDENCE PDR
Tha Honor:bla Rich rd Blum: nth:1 Attomey G:;neral Sttts of Conn:cticut
. 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120
Dear Mr. Attorney General:
I am responding to your letter of March 16,1998, expressing your concerns about a recent document by a high-level Northeast Nuclear Energy Company (NNECO) executive that seemed to suggest continuing company efforts to isolate or silence whistleblowers. You requested that the U.S. Nuclear Regulatory Commission thoroughly inquire int the origin of this incident and the possibility that NNECO attempted to cover up the issue.
We are also concerned about the implications of the ECO document referenced in your letter.
The NRC staff sent NNECO a letter on February ,1998 (Enclosure 1), expressing this concern and requiring NNECO to respond in ing under oath or affirmation. NNECO sent its initial response to the staff's letter on Marc 2,1998 (Enclosure 2). The response made reference to the findings of an indepen investigation conducted to review the circumstances surrounding the creation and distribut' of the document. On March 26,1998, NNECO forwarded a Report of Investigatio at was used to develop the March 12,1998, response.
(NNECO asked the NRC to with Id this report from public disclosure, pursuant to the NRC's regulations, because it contal personalinformation.) The NRC staffis currently reviewing NNECO's responses to det ine the appropriate course of action to complete the inquiry.
I have asked my staff t eep you informed of significant developments. If you have any further questions on this issu , please contact Phil McKee, Deputy Director, Special Projects Office-Licensing, at (301) 4 5-1455.
Sincerely, Shirley Ann Jackson
Enclosures:
As stated (2)
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NAME SDembek LBerry RSanders PMcKee WTravers DATE 04/2/98 04/2/98 03/30/98 04/6/98 04/3/98 OFFICE OI:D* OGC* NRR:D EDO), OCM NAME GCaputo MRafky SCollins N SJackson DATE 04/01/98 04/02/98 04/11/98 04//3 /98 Og/ (o /98 OFFICIAL RECORD COPY i
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DISTRIBUTION:
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$ WASHINGTON, D.C. 30seHo01
% * *'***,[ February 10, 1998 EA 98-055 Mr. Bruce D. Kenyon, President and Chief Executive Officer- Nuclear Group Northeast Utilities Service Company P.O. Box 128
- Waterford, CT 06385
SUBJECT:
POTENTIAL DISCRIMINATION j
Dear Mr. Kenyon:
On January 29,1998, the U.S. Nuclear Re Julatory Commission (NRC) t;ecame aware of a i memorandum developed by your Nuclear Oversight managers dated January 11,1998, that stated, " inability to ' isolate' cynics from group culture." The language was not consistent with encouraging a questioning attitude necessary for fostering a safety-conscious work environment (SCWE). Further, the language used in the memorandum involved a potential violation of the employee protection provisions set forth in 10 CFR 50.7(f) as it may be perceived as establishing a condition of en,ployment that would discourage employees from being engaged in protected activity. This could have a chilling effect on licensee or contractor personnel, in that these statements might deter them from identifying any nuclear safety-related concerns. We recognize that you have initiated an independent investigation into this matter to understand what occurred.
Accordingly, pursuant to Sections 161c,161o,182, and 186 of the Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR 2.204 and 10 CFR 50. 54(f)in order for the Commission to determine whether regulatory enforcement actions are appropriate, you are required 10 provide this offico, within 30 days of the date of this letter, a response in writing and under oath or affirmation that describes:
- 1. Y:,ur position regarding whether the actions described nbove violated 10 CFR 50.7 and the basis for your position, including a copy of any investigation that supports your position as well as any other investigations that addresses why this memorandum was written, distribution and release of the memorandum, and its impact on your employees, and contractor employees; 2.
Your assessment of how this incident occurred in light of your efforts to improve your '
SCWE and actions you have already taken or plan to take to assure that this matter is not having a chilling effect on the willingness of other employees to raise safety and compliance concems within your organization and, as discussed in NRC Form 3, to the NRC; and
.~
Enclosure 1
%0.3.33ON W'
e e,-
B. D. Kenyon 3. Your assessment of the need to take remedial action to prevent a recurrence of this event and if you conclude action is needed, describe such action and your schedule for achieving it.
We recognize that you may not believe that either unlawful discrimination or inappropriate conduct has occurred. Regardless of your answer to item 1 above, we request that you consider the need to address the possible chilling effect that an ongoing issue of this type may have on other employees.
Your response should not, to the extent possible, include any personal privacy, proprietary, or safeguards information, so that it can be released to the public and placed in the NRC Public' Document Room. If personal privacy information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the personal privacy-related information and a redacted copy of your response that deletes the personal privacy-related information. Identify the particular portions of the response in question which, if disclosed, would create an unwarranted invasion of personal privacy, identify the individual whose privacy would be invaded in each instance, describe the nature of the privacy invasion, and indicate why, considering the public interest in the matter, the invasion of privacy is unwarranted.- If you request withholding on any other grounds, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the basis for your claim of withholding (e.g., provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information).
After reviewing your response, the .NRC will determine whether enforcement action is necessary at this time to ensure compliance with regulatory requirements, in accordance with ;
10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and your response will be l placed in the NRC Public Document Room. j The responses directad by this letter are not subject to the clearance p;cedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L.
No.96-511.
Sincerely, W
William D. Tr ers, Director Special Projects Office Office of Nuclear Reactor Regulation Docket Nos. 50-245,50-336, and 50-423 Licerwe Nos. DPR-21, DPR-65, and NPF-49 cc: See next page
L l{, Northeast Rope Ferry Rd. (Route 156), Waterford, CT 06385 i
Nuclear Energy Mm woe Nudear Pmr Station
{- Northeast Nucicar Energy Company P.O. Box 128 Waterford, CT 06385-0128 ,
l l
(B60) 4471791 l Fax (860) 444-4277
%e Northeast Utilities System MAR I 21998 ,
Docket Nos. 50-245 !
50-336 l 50-423 B17098 U.S. Nuclear Regulatory Commission Attention: Document ControlDesk Washington, DC 20555 Millstone Nuclear Power Station Resoonse to NRC Reauest on Potentist Discrimination ,
in a letter dated February 10,1998, the NRC requested Northeast Nuclear Energy Company (NNECO) to provide a written response to three inquiries conceming a NNECO Nuclear Oversight discussion document' The document entitled " Focus 98:
DirectorNP View Of Nuclear Oversight (1/11/98)" listed seven ' Positive Qualities Of Nuclear Oversight" and seven " Areas Needing improvement." Under the " Areas l
[ Needing Improvement" was a category entitled " Current SCWE environment and
\ issues." One of the six phrases beneath this category was, " inability to ' isolate' cynics from group culture." Th's NRC has requested that NNECO describe: (a) the circumstances surrounding the creation and distribution of this document and whether ;
the events constitute a violation of 10 CFR 50.7; (b) how this document came into existence, in light of NNECO's efforts to create a safety conscious work environment, i and NNECO's assessment of the document's effect on the willingness of employees to raise concerns with the Company; and (c) any remedial actions needed to prevent !
l recurrence. NNECO's response is set forth below.
Item i NRC Request:
[ Describe] [y]our position regarding whether the actions described . . . [in the l NRC's letter of February 10,1998] violated 10 CFR 50.7 and the basis for your position, including a copy of any investigation that supports your position as well as any other investigations that addresses [ sic] why this memorandum was written, distribution and release of the memorandum, and its impact on your employees, e.nd contractor employees.
( ' Although the NRC's letter of February 10,1998, refers to the document as a " memorandum",
it was a chart for discussion purposes reflecting the perceived strengths and weaknesses of the Nuclear Oversight organization.
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- i. ' U.S. Nuclear Regulatory Commission B17098\Page 2 l
( NNECO Response:
l 1
On January 30, 1998 NNECO's Director of the Employee Concerns Program requested that Mr. Eugene T. Pawlik conduct an independent investigation into the circumstances surrounding the creation and distribution of the document. Mr. Pawlik is the former Field Office Director, NRC Office of Investigations, Region 3. Mr. Pawlik conducted his investigative field work from February 2,1998 through February 18, .
1998. On the evening of March 10,1998, NNECO received Mr. Pawlik's Report of Investigation. The report is quite lengthy (well over 100 pages) and NNECO is currently reviewing the report. NNECO anticipates completing its review, and any follow-up investigative work, by March 26, 1998. Upon completion of the review process, NNECO will forward the report to the NRC (Refer to Attachment 1, List of Regulatory Commitments).
Based on the information received to date, the facts which are relevant to the first NRC question are summarized below.
Summarv of Relevant Conclusions of the Investigation On January 11,1998, the Vice President, Nuclear Oversight, his three Directors, the Executive Assistant to the Vice President, and a Consultant to the Vice President attended a weekend meeting to explore the strengths and weaknesses of the Nuclear
( Oversight organization. Each of the six participants brought to the meeting approximately three strengths and three weaknesses for discussion. To the best of his recollection, one of the Directors submitted the following three weaknesses: " inability to isolate the adverse impact of cynics on group culture," "too much negative energy (personnel issues)," and " pockets of negativism." Although the Consultant did not recall this Director being the source of the first phrase, when the Consultant wrote the phrase on the board for discussion, he wrote " inability to ' isolate' cynics from group culture "
In accepting that phrase for inclusion, the group discussed the phrase in conjunction with other perceived organizational weaknesses. The Director intended the phrases
" pockets of negativism" and " inability to isolate the adverse impact of cynics on group culture" to convey the notiott that the organization suffers when individuals remain unable to let go of past wrongs - whether real or perceived - and those individuals seek to force the acceptance of their ill feelings towards the Company on those within the group who disagree. The other participants generally recalled this discussion as forming the basis for the phrases.
The participants did not intend to convey the notion that Nuclear Oversight management should seek to isolate individuals who have raised concerns in the past.
Nor did they intend to send a signal that management views persons who raise concerns as " cynics" or bad influences on the organization.
None of the participants recognized that the words " inability to ' isolate' cynics from group culture" - when read in isolation - could be interpreted to suggest a desire or
T.
,i, U.S. Nuclear Regulatory Commission i
B17098\Page 3
( Intent to retaliate against persons who had raised safety concems or to discourage l
l people from raising concems in the future.
Before the January 11, 1998, meeting concluded, the Consultant and the other participants placed the various strengths and weaknesses into groups of similar subject matter. After that meeting, the Consultant prepared the Focus 98 document based upon the group's efforts on January 11, 1998. On or about January 13,-1998, the Consultant distributed the Focus 98 document to the five other participants for review and comment. The Focus 98 document contained the phrase " inability to ' isolate' cynics from group culture," precisely as it had appeared on the board during the meeting on January 11,1998. The Consultant did not recall receiving any objections to the phrase from the other five participants or any substantive comments on the draft Focus 98 document. 1he Vice President of Nuclear Oversight noticed the words on the draft document and was uncomfortable with the word " cynic," but did not convey his feelings to the Consultant or dictate a change in the language. He did not consider that the words were susceptible to an interpretation which would be injurious to the raising of safety concems.
On January 21, 1998, the Nuclear Oversight management team (from first-line supervisors to the Vice President) met to conduct a team building session That session included a discussion of the matters developed on January 11,1998. Sr,on ,
after the distribution of the Focus 98 document, several managers /supervis. ors
{.
expressed their objection to the words " inability to ' isolate' cynics from group culture."
The Vice President and Directors were initially surprised by the reaction. Ultimately, j however, they agreed that the words were poorly chosen and not reflective of j management's position.
The participants agreed that the words in the document were poorly chosen and, at the suggestion of a consultant who was facilitating the meeting, the participants agreed that i the Focus 98 document should not be distributed further because of the poor word l choice. As a result, most of the participants simply left the document in the room or ,
gave the document to the consultant several hours later, at the conclusion of the ;
meeting. No one attempted to ensure the collection of all copies of the document. l There was no agreement to conceal the contents of the document, the fact of its creation, or the contents of the discussion surrounding the document. Moreover, no one directed any of the participants to refrain from discussing the meeting or the contents of the Focus 98 document.~
Assessment of 10 C.F.R 6 50.7 The events and actions, as described above, do not constitute a violation of 10 C.F.R. S 50.7. The information received to date indicates that the senior management in Nuclear Oversight did not impose, or intend to impose, any restrictions,
( constraints, or conditions of any sort on the ability of the employees to raise safety concerns with management. Additionally, they did not intend to discourage employees from raising concems or to suggest that employees who raised concerns would be
t
$. U.S. Nuclear Regulatory Commission B17098\Page 4 l viewed as " cynics" and subjected to retaliation for having raised concems. Rather, the drafters of the Focus 98 document intended to convey the notion that the Nuclear Oversight organization recognizes that there are persons who have ill feelings towards the Company and are seeking to impose their views on others who may disagree and that this imposition was affecting the organization.
The language, as it ultimately appeared in the Focus 98 document, did not accurately ,
convey the intent of the Vice President, the Directors, or the Company, if read in !
isolation, the phrase could be read to encourage discrimination against persons who i raise safety concems. Significantly, however, when several supervisors pointed out this possible interpretation during the meeting on January 21,1998, the Vice President and the Directors realized their mistake and accepted the criticism as well-founded.
Because it did not accurately reflect the views of rnanagement, the Oversight leadership team did not ratify or distribute the Focus 98 document further.
In sum, the Focus 98 document was a revoked discussion document that did not become either the policy or direction of Oversight management. The circumstances of its creation indicate that no one in management intended to encourage any form of discrimination against persons who have engaged in protected activity. No action of any sort took place because of the document's existence. Thus, no person who had engaged in protected activity suffered any adverse employment action. And, as the
( surveys described below concluded, the event did not create a chilling effect in either the Nuclear Oversight organization or the vast majority of employees . Under these circumstances there was no violation of 10 C.F.R. 50.7.
Potential Chillina Effect of the Document on Emolovees The benign intent of the Vice President and Directors neither absolves them of responsibility nor neutralizes the perception created by the inappropriate language.
Shortly after senior managc 't leamed of the Focus 98 document, NNECO initiated several independent inquiries into the possible effect of the document on the workforce.
First, the ECP Director instructed the independent investigator, Mr. Pawlik, to inquire into the possible chilling effect on management in the Oversight organization, as part of Mr. Pawlik's investigation. Second, the ECP Director directed the ECP peer representatives to conduct a survey of employees throughout the site to determine the effect of the document across the workforce. Third, NNECO directed the consulting
'There were indications of a potential chilling effect in one of the organizations polled by the ;
r ECP Peer Representatives (See Attachment 3). NNECO's SCWE organization is currently l
! taking steps to assist management in its assessment of these responses. j 8
g There is also no violation of 10 C.F.R. 9 50.7(f), in particular. @ 50.7(f) provides that:
"No agreement . . . . may contain any provision which would prohibit, restrict, or otherwise discourage any employee from participating in protected activity. . . ."
(' 10 C.F.R. Q 50.7(f) (emphasis added). Because there was no management action which constituted a prohibition, restriction, or discouragement of protected activity, and there was no agreement affecting any employee, the events do not constitute a violation of or 10 C.F.R. S 50.7(f).
(, U.S. Nuclear Regulatory Commission B17098\Page 5
( firm of Nilsson and Associates to conduct an in-depth survey of Nuclear Oversight, and those employees that interact with Oversight, to determine the possible existence of any chilling effect. The results of these surveys are attached as Attachment 2' (Nilsson 5
and Associates), and Attachment 3 (ECP Peer Representatives).
Although the scope and perspective of the surveys differed somewhat, the results are consistent. The creation and distribution of the Focus 98 document did DQ1 create a chilling effect on either the Nuclear Oversight organization or the vast majority of
' employees. ' A more thorough description of the chilling effect surveys appears in the attachments and in NNECO's response to item 2 below. Additionally, NNECO is conducting follow-up surveys to determine whether the event has had any lingering effect on the Nuclear Oversight organization or the site.
1 Item 2 NRC Request:
(Describe) [y]our assessment of how this incident occurred in light of your efforts to improve your SCWE and actions you have already taken or plan to take to assure that this matter is not having a chilling effect on the willingness of other employees to raise safety and compliance concems within your organization and, as discussed in NRC Form 3, to the NRC.
{
NNECO Response:
The Effectiveness of Existing Efforts to Enhance the Work Environment NNECO was both surprised and disappointed that the events occurred - surprised because we have made significant, measurable progress in creating and sustaining a safety conscious work environment - and disappointed because, with sufficient leadership awareness, the event could have been avoided.
The information received to date indicates that the event occurred because the persons !
who were involved in the discussions and drafting of the document did not recognize or
)
1
- Attachment 2 contains personnel information, the public disclosure of which would constitute a l clearly unwarranted invasion of personal privacy. Accordingly, pursuant to 10 CFR 2.790(a)(6), the names of individuals have been redacted from pages 10 and 11 of ,
Attachment 2 to protect personal privacy. The original version of Attachment 2 is available for l NRC review on-site. l 5
Attachment 3 contains personnelinforms o, the public disclosure of which would constitute j a clearly unwarranted invasion of personal privacy. Accordingly, pursuant to 10 CFR ;
2.790(a)(6), Attachment B of Attachment 3, which identifies specific groups from which
( comments originated, has been omitted to protect personal privacy. The original version of Attachment 3 is available for NRC review on-site.
j l
1
- ' U.S. Nuclear Regulatory Commission B17098\Page 6
( appreciate the potential message.that the words in the offending phrase conveyed. In i short, they lacked the sensitivity nocessary to meet current expectations.
All of the participants in the meeting on January 11, 1998, unquestionably knew the requirements of the law and honored its prohibition against discrimination. What was t apparently lacking was the reinforcement of the notion that a safety conscious work environment can thrive only if: (1) managers place its existence at the forefront of their actions and at the forefront of their consciences; and (2) managers are sensitive to the consequences of their words and actions, regardless of the intent.
Although the sensitivity of those at the January 11,1998, meeting was lacking, the actions of the participants in the January 21,1998, meeting was commendable. Within minutes of the distribution of the Focus 98 document, several supervisors expressed their objection to the language in the phrase. What followed is an example of a healthy work environment and an endorsement of NNECO's efforts to establish a safety conscious work environment. Specifically, after the issue surfaced, the participants discussed the intent of the phrase and the Directors and Vice President recognized and acknowledged their error. There was no defense of the language and no attacking of those who questioned the language. Rather, there was listening, leaming, and respect.
And because of this, the participants corrected the problem.
Actions to Assure the Willingness of Emolovees to Continue to Raise Concems NNECO has taken decisive and effective actions to mitigate, assess, and ensure that this event and surrounding circumstances did not cause any chilling effect on the organization. Management's response to the event has occurred in four phases. In Phase 1, the senior leadership in Nuclear Oversight and at Millstone Station took immediate steps to assure the Oversight organization and the workforce, in general, that the Focus 98 document did not accurately reflect either the intent of the drafters of 1 the document, or the position of management. In Phase 2, management assessed the effect of the document on the workforce through investigations and surveys. Corrective action followed in Phase 3. Finally, in Phase 4, management is conducting additional surveys to determine the existence of any lingering effect of the event and the impact of the corrective action on the Oversight organization and site.
(A) Phase 1 On January 28,1998, it became apparent that non-supervisory employees in Nuclear Oversight, who had not attended either the January 11 or January 21,1998 meetings, had become aware of the troubling language in the Focus 98 document. The next day the Vice President, Nuclear Oversight, held an all hands meeting with members of his organization at which he apologized for the language in the document and assured the
(
(
organization that he and the Directors were not trying to discourage anyone from voicing their concerns. That same day, the President and CEO of Millstone and the Vice President, Nuclear Oversight met with the Millstone leadership team and described in detail the circumstances surrounding the document. The Vice President again
1 l
l U.S. Nuclear Regulatory Commission B17098\Page 7
( apologized for the language and stated that the implication of the words was " absolutely inappropriate" and did not reflect how management wanted people treated. The President and CEO called the phrase "a terrible choice of words" and stated that "we
[the Millstone team] want to embrace, not isolate, employees who raise concems." He also expressed his disappointment with the fact that the document had passed a l cursory management review before its distribution on January 21,1998. At the same time, the President publicly commended those who had identified the problem and brought it to light. The day after these meetings, NNECO issued a site-wide I communication discussing the two meetings in detail.
(B) Phase 2 Management has taken several specific actions to determine the effect of the document on the workforce. First, the ECP Director directed Mr. Pawlik to determine in his i
independent investigation the impact of the issue on management in the Oversight organization. The interviews revealed that none of the attendees at the January 21, 1998, meeting felt that the events surrounding the Focus 98 document had an adverse effect on their willingness to raise concems. Several persons indicated, however, that the document might cause others at Millstone to question their willingness to raise concerns.
e
((
The Pawlik investigation, of course, focused primarily on the events underlying the creation of the Focus 98 document - not the document's effect on the entire Oversight organization. For this reason, management directed a private consulting firm, Nilsson and Associates, to conduct an in-depth assessment of the document's effect on Oversight employees and on those employees who interact with Oversight. (See Attachment 2). The assessment found that no one, out of 56 Individuals interviewed, indicated that the document has caused a reluctance to raise concerns. Accordingly, the Nilsson report concluded that "there has been no chilling effect in terms of a reluctance to raise safety concems as a result of this incident." -
Management also solicited data to determine if the event had an adverse effect on the site. To obtain this information, the ECP Peer Representatives surveyed 270 people from 34 work groups. The ECP Peer Representatives concluded that the event had not created a chilling effect on the vast majority of employees. In fact, the survey noted that employees retained " strong levels of trust with their immediate supervisors" and that employees viewed management's expeditious response to the event as a positive development. (See Attachment 3)
(C) Phase 3 A key element of management's response to this event was the implementation of corrective action. Management views the event very seriously - not because the
(-
documant created an actual chilling effect - but because senior Oversight leadership did not appreciate the significance of the offending language or take appropriate corrective action.
U.S. Nucisar Regulatory Commission
- - B17098\Page 8
(
Given NNECO's commitment to th'e elim! nation of the appearance of retaliation from the site, and given the enormous emphasis placed on adherence to this commitment, management determined that the event had severely damaged the credibility and effectiveness of the Vice President, Nuclear Oversight. The Vice President agreed and, on February 26,1998, he announced his resignation.
That action was timely, strong, and public. And it sent an unmistakable message -
NNECO will not tolerate actions, however well intended, which potentially impede the l establishment and maintenance of a safety conscious work environment. To the extent
! the workforce questioned NNECO's commitment to this goal, this action should serve to i eliminate any lingering doubt.
l (D) Phase 4 As noted earlier, all indicstions are that the event did not adversely affect the willingness of employees to raise concems. Nevertheless, NNECO has continued to monitor the Oversight organization and the workforce, in general, to determine the accuracy of the initial surveys and to determine if the resignation of the Vice President created an adverse effect on the work environment. Although these assessments and surveys.have not been completed, NNECO will be carefully analyzing the results to ensure that it remains' attuned to any emerging issues or developments, item 3
( NRC Request:
i
[ Describe) [y]our assessment of the need to take remedial action to prevent a recurrence of this event and if you conclude action is needed, describe such action and your schedule for achieving it.
l l NNECO Rosponse:
NNECO has taken specific remedial action and has continued ongoing programmatic actions in response to this event.
As mentioned earlier, the Vice President, Nuclear Oversight has resigned because of this event. To ensure that the workforce understood the reasons for the resignation, the President and CEO and the former Vice President, Nuclear Oversight, met with the Oversight organization on February 26, 1998, to discuss the resignation and the importance of maintaining a safety conscious work environment. The President also spoke to several smaller groups within Oversight that same day to discuss the matter and to reinforce management's commitment to the free flow of information. Another "all
( hands" meeting on February 26, 1998, and a site-wide publication that same day discussed these same issues with the entire Millstone workforce.
-U.S. Nuclear Regulatory Commission B17098\Page 9
( Additional specific remedial action may also be forthcoming, depending upon the outcome of NNECO's review of the Pawlik Report of Investigation and the results of the continuing surveys and assessments.
In addition to the specific remedial actions already discussed in this letter, NNECO has in place a number of ongoing actions designed to enhance the environment for the raising of concems. NNECO recognizes that, despite these preventative measures, the Focus 98 event occurred. He fact that these measures were not perfect does not suggest, however, that they should be terminated. In fact, NNECO believes that, although imperfect, they have had a substantia! ed positive effect on the work environment.
Numerous briefings conducted by NNECO at of the ongoing restart and Independent Third-Party Oversight process have discussed in detail all of the ongoing i remedial and enhancement actions. Several of the key items, however, deserve emphasis here because they bear directly on the prevention of missteps similar to those found in the Focus 98 document event. .
I It is clear that senior Oversight management lacked the sensitivity necessary to identify the problem'with the offensive language. A lack of sensitivity can arise when people fail to understand the full extent of the issues. To remedy any lack of knowledge about the
[( rights of employees to raise safety concems, NNECO has conducted extensive training for virtually all members of the management team to ensure that the Company's leaders understand the elements of a claim of discrimination under Sectior, r. of the Ens,gy Reorganization Act. An essential part of that training included lectures and case l studies addressing the importance of employee perceptions and avoiding or mitigating potential chilling effects caused by management actions.
Supplementing this specific training, NNECO has also trained supervisors in its Forum l
For Leadership Excellence, or Enlightened Leadership (Unit 2). This training provides leaders with new ways of thinking and behaving for the purpose of enhancing the overall effectiveness of management and creating a positive work environment.
Similarly, about 97 percent of all NNECO supervisors have successfully completed the Managing For Nuclear Safety course. This course specifically provides leaders with the skills necessary to foster a work environment in which employees are comfortable raising concems.
NNECO has also heightened management's awareness and sensitivity to safety and l
retaliation issues by the establishment of a Safety Conscious Work Environment organization. This organization, which is lead by a NNECO officer, provides management with constant input and advice on a wide range of decisions and actions affecting the work environment. The SCWE organization plays en integral role in the functioning of NNECO's new site-wide disciplinary panel (the Executive Review Board) i by ensuring that any discipline recommended is not a consequence of a person's I
protected activity.
\
Q U.S. Nuclear Regulatory Commission B17098\Page 10
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Likewise; the Employee Concems Oversight Panel ("ECOP") provides employees with l direct input to management at all levels on issues affecting the work environment.
Through the use of surveys, participation in the Executive Review Board proceedings, and a wide variety of other activities, ECOP provides management with valuable insight on how management actions are received - and perceived - by the workforce.
l Finally, management's sensitivity to employee perceptions is being enhanced through the efforts of organizational effectiveness consultants. These consultants are working with various work groups on site for the purpose of improving the overall effectiveness of the groups and improving the intemal communications within the groups. The Nuclear Oversight organization is one of the groups with which an organizational effectiveness consultant has been, and continues to be, actively involved.
If there are any questions on the information provided in this letter, please contact Mr.
D. B. Amerine, Vice President - Human Services, at 860-440-0437.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY I l D. B. Amerind, Vice President- Human Services Attachment 1 .
i Attachment 2 Attachment 3 1
cc: See Page 11 1
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U.S. Nuciser Regulatory Commission B17098\Page 11
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cc: H. J. Miller, Region i Administrator S. Dembek, NRC Project Manager, Millstone Unit No.1 D. G. Mcdonald, Jr., NRC Senior Project Manager, Millstone Unit No. 2 J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 T. A. Easlick, Senior Resident inspector, Millstone Unit No.1 D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 A. C. Ceme, Senior Resident inspector, Millstone Unit No. 3 W. D. Travers, Ph.D, Director, Special Projects Office .
P. W. Eselgroth, Branch Chief, Special Projects Office W. D. Lanning, Deputy Director of Inspection - Special Projects Office J. P. Durr, Branch Chief, inspections - Special Projects Office P. F. McKee, Deputy Director of Licensing - Special Projects Office H. N. Pastis, Branch, ITPOP Oversight - Special Projects Office e
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.. l U.S. Nucl:ar Rcgulatory Commission B17098\Page 12
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i Affidavit i
i
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1, D. B. Amerine, being duly swom, depose and state that the content of this letter is )
true and accurate to the best of my knowledge, information, and belief. I Executed this _llday of March,1998
)
D. B. Am'erine l
f f
I
"!SWdrrito and subscribed before me i
I lthis' ' Q day $f OChech .1998
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ht bx bldb f46tary Pubic 4
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- h. My Commission expires t h . S O ; ELC o l l
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Docket Nos. 50-245 50-336 50-423 B17098 l
Attachment 1 l
Millstone Nuclear Power Station, Unit Nos.1,2,3 -
List of Regulatory Commitments I
L.
I
~ March 1998
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l.
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U.S. Nuclear Regulatory Commission B17098\ Attachment 1\Page 1 l l f-l List of Regulatory Commitments The following table identifies those actions committed to by NNECO in this I document. Any other actions discussed in the submittal represent intended or planned actions by NNECO. They are described to the NRC for the NRC's information and are not regulatory commitments. !
1 Commitment Committed Date NNECO will complete its review of the March 26,1998 Pawlik Report of Investigation and submit it to the NRC.
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Docket Nos. 50-245 50-336
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50-423 1 l~ B17098 l
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Attachment 2 ,
l Millstone Nuclear Power Station, Unit Nos.1,2,3 -
i Nilsson and Associates Survey Results (Redacted)
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l March 1998 wowe sw .
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i SAFETY CONSCIOUS WORK ENVIRONMENT l
(ASSESSMENT OF NUCLEAR OVERSIGHT 1/21/98 STATEMENT)
. l for Mr. Allan L. Elms :
Millstone Station I l' Safety Conscious Work Environment
P.O. Box 128 Waterford, CT 06385 i i
l by .
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Nilsson & Associates j 7278 Tascosa Drive l Flowery Branch, GA 30542 j i
l 6
1 February 17,1998 l
a o
k SAFETY CONSCIOUS WORK ENVIRONMENT '
(ASSESSMENT OF NUCLEAR OVERSIGHT 1/21/98 STATEM ENT)
INTRODUCTION Purpose Nilsson & Associates (N&A) was asked to conduct a study to determine if the events surrounding the release of a list generated by Nuclear Oversight Management containing the phrase, " Inability to ' isolate' cynics from group culture," had negatively impacted the workforce and, in particular, had in any way created a reluctance to raise safety issues at Millstone. This report details that effort which was conducted February 1,0-17,1998.
Report Overview .
This report addresses the background of the incident, details the methodology Nilsson &
Associates used in conducting the study, describes the analysis effort, and, finally, reports c
the results of the interviews and draws conclusions based on the interview results. )
I
'- BACKGROUND OFINCIDENT On Wednesday, January 21,1998, the Nuclear Oversight Leadership Team met at the Lighthouse Inn to work on a plan for moving forward as an organization. In preparation for that meeting the Vice President, Dave Goebel, the three Oversight Directors, the ;
Executive Assistant to the Vice President, and a consultant met on Sunday morning, ;
January 11, 1998 to brainstorm a list ,of Nuclear Oversight's strengths and areas for improvement. As a result of this brainstorming, the team developed a discussion paper '
entitled " FOCUS:98 DIRECTOR /VP VIEW OF NUCLEAR OVERSIGHT (1/11/98)".
This paper, designed to give the Leadership Team a sense of the VP's and Director's l thinking on Nuclear Oversight's status as an organization, was distributed at the Lighthouse Inn meeting in preparation for discussing improvement initiatives the group would address later in the day. The FOCUS:98 paper was presented as both an overhead transparency and as a one-page handout.
Upon presentation of the material, a lively discussion ensued in which several people strongly expressed concerns and sought clarification from the VP and Directors regarding three bullets listed under the following headings:
1
.. AREAS NEEDING IMPROVEMENT Current SCWE Environment and Issues l + Inability to " isolate" cynics from group culture
! + Too much negative energy (personnelissues)
+ Pockets of negativism The complete document is included at the end ofthis document as Attachment A.
l It we.s the sense of the group that these words could be misinterpreted as applying to -
people with safety concerns or those with a questioning attitude. The VP and Directors quickly made it clear that that was not what they intended. They explained they were l hoping to elicit ways to improve the culture in a way that would engage negative people and get them to be more supportive. They then thanked the group for their input.
l Several minutes of discussion followed on how to change the language to accurately '
reflect the true intent of the message. Given that the paper was intended solely to pro
- vide
, a data point for the group's work that day and never intended for publication outside the group, there was a consensus in the group to end the discussion with the acknowledgment j that the words were poorly chosen and not reflective of the group's beliefs. ,The l / suggestion was then made to collect the sheets so that no one back at the site would get l \ the wrong impression if they happened to read the paper. The group reached a quick , ;
consensus to collect the papers at the end of the day and the meeting moved on. '
1 Some days later, the paper was circulated to the site and the press, accompanied by l claims that a cover up had occurred. In response to those accosations, the Vice-President of Nuclear Oversight, Dave Goebel, held an all hands meeting on 1/29/98 at which he apologized for the language in question and said that he and the directors were not trying to discourage anyone from voicing their concems. He also took questions and listened to statements of concern from the group. -
METHODOLOGY Target Population Three groups were targeted as the most likely to have been affected by the content of the FOCUS: 98 language:
+ Management personnel in Nuclear Oversight
+ Non Management personnel in Nuclear Oversight
+ Customers of Nuclest Oversight services f
k.
2 I
k Data Gathering Method Interviewers Nilsson & Associates, retained by Northeast Utilities to build teams, develop leadership, and assist senior management in establishing a safety-conscious work environment, had arrived on site on January 12,1998 and had started working with the Nuclear Oversight organization to improve teamwork and communication. Prior to the January 21 Lighthouse Inn meeting, N&A consultants had interviewed all members of the management team to get their views about the organization's effectiveness, its strengths, and its areas for improvement and had planned to continue the interviews to include most or all of the organization.
Given that Nilsson & Associates was already involved in assisting Nuclear Oversight, it was determined that they would be the logical choice to structure an instrument and conduct interviews to check for the presence of a chilling effect resulting from the Focus:98 language. ,
Interview Guide There were two interview guides-one for Nuclear Oversight and one for Customers.
r' Both are included at the end of this report as Attachment B. Each consisted of five
( questions and was stmetured to accomplish two objectives:
+ Gather the information needed for Nuclear Oversight team development
+ Check for any chilling effect that might be experienced or perceived by respondents N&A was concerned that respondents might not be inclined to answer a direct question concerning chilling effect in the affirmative ifit were posed as a stand alonc question for two reasons. One is fear that their response might be identified as coming from them or-that a "yes" response wasn't the expected or " correct" answer. The other is that they might not fully understand the ways in which a chilling effect can manifest itselfin the workplace. In an attempt to address and fully explore the var:ous " symptoms" that might signal the presence of a chilling effect, N&A asked the following five questions as a prelude to asking directly about any reluctance to raise safety concerns.
Has the recent "VP/ Director List" afectedyour:
+ Willingness to voice opinions?
+ Workperformance?
+ Work environment?
+ Trust levelin Nuclear Oversight management (Managers, Supervisors, Directors)?
( ,
+ Trustlevelin senior management?
3 l .
k The final question, not listed on the Interview Guide, addressed the chilling effect directly:
As a result ofthis list, do youfeel any reluctance to raise safety concerns?
The questions were derived from materials obtained from the Safety Conscious Work Environment (SCWE) Coordinator and Employee Concems Oversight Panel (ECOP) and approved by SCWE as likely to gain the desired information. Only the interview data gathered under Question number 5 (which contained the five separate parts listed above) was analyzed for this research. The data gathered in the other portion of the interview was. used for the Nuclear Oversight team as input to help develop improvement strategies.
Respondents The Nuclear Oversight interview respondents consisted of a 20% random sample selected from the various groups in the organization. To ensure representative coverage, the sample was " stratified," e.g., at least one representative was included from every work group. large work groups, of course, often had two or more representatives.
Management was treated as a separate group. If those selected were absent, the person whose name appears after theirs on the organizational chart was substituted.
Determining the customer population was more challenging. Since N&A was new to the station and didn't yet know the site personnel, Oversight Management Team members were asked to identify people in the customer population who interfaced regularly with Nuclear Oversight and were familiar with the way the department operates. After verifying with an independent third party that those on the list were indeed an appropriate list of customers, Nilsson & Associates then contacted those people for interviews. N&A was also prepared to conduct additional interviews in any customer areas where anyone expressed reluctance to raise safety concerns.
When an affirmative response was received in one group of non management Nuclear Oversight personnel, N&A conducted a follow up interview with that respondent to clarify the role the Focus: 98 list itself played in creating the reluctance to raise concerns.
N&A also added to the number of respondents in the group to double the sample size to 40% for that group. Another manager from the same group was added to the managers' sample.
ANALYSIS Following data collection, the interview results were analyzed by first tabulating the "Yes" and "No" responses for each item and listing the individual comments. All "Yes" responses were followed by comments as were some of the "No" responses. All the comments were included in the analysis and are listed in this report. "Yes" comments 4
l are typed in bold faced print to make them easier to identify and read. The individual comments were then analyzed for pattems.
FINDINGS AND CONCLUSIONS in this section the findings are presented for each interview question. (Since all the questions have the same lead in, the focus of each individual question is highlighted in italics.) In each case a table shows the distribution of responses for that question l followed by the respondents' comments presented under the three group headings.
l Discussion is provided for each set of data. The last question is followed by the results of l a follow-up interview conducted to clarify the intent of the respondent's comments.
l Following the question breakouts, primary and secondary finc'ings are listed. Finally a l concluding statement is presented.
Has the recent "VP/ Director List" affected your willingness to voice opinions?
NUCLEAR NUCLEAR -
CUSTOMERS OVERSIGHT OVERSIGHT NON TOTALS MANAGERS MANAGERS YES NO YES NO YES NO YES NO 1 21 0 6 2 28 3 55 l
l l CUSTOMERS COMMENTS- 1
+ Yes, to the degree that I would be watchful or mindful of saying something around someone I didn't know; Around my fellow workers no...not at all
+ No, have not seen this effect on anyone else either.
+ No, not at all l
+ No, absolutely not
+ No, because Dave is not in my food chain. I don't believe the list reflects Nuclear !
Oversight policy. -
NUCLEAR OVERSIGHT MANAGERS COMMENTS: 1
+ No comments I NUCLEAR OVERSIGHT NON MANAGERS COMMENTS:
~
+ Yes, not to managers, but would be apprehensive at the Director level and above. I
+ Yes,l'm chilled, but not by the news. I'm chilled by , a peer in the department.
+ No, not in the least
+ No, absolutely not!
+ Not at all
+ No, the group is not shy or bashf'ul.
( + No, six months ago maybe but not today; voicing our opinions is not career limiting.
5 i
. i (x + No, but if I have the chance to avoid one of these talk sessions, I do, because they're a waste of time.
+ No, but very unfortunate choice of words.
DISCUSSION:
Three of the 58 respondents said that their willingness to voice opinions had been affected by the list. One person expressed concem about speaking freely around people he didn't know for fear of having his words misinterpreted. Another complained of being " chilled" by a coworker who has been a vocal critic of management. A third said he would be apprehensive to voice his opinions to the Director level and above, although he was willing to voice his opinion to those at the manager level. No pattem was identified in the "yes" comments.
The "No's" were unequivocal in their assertion that the list had no effect and many completely dismissed the notion that their willingness to voice their opinions would be affected by anything. ,
Has the recent "VP/ Director List" affected your workperformance?
l NUCLEAR NUCLEAR CUSTOMERS OVERSIGHT OVERSIGHT NON TOTALS
(- YES NO MANAGERS YES NO MANAGERS YES NO YES NO 1 21 2 4 5 25 8 50 ,
CUSTOMER COMMENTS:
+ Yes,it's been on my mind that this incident has occurred. I'm thinking about talking with the man who raised objections at the Shirley Jackson public meeting.
NUCLEAR OVERSIGHT MANAGER COMMENTS:
+ Yes, this issue has consumed a lot of time; it has been a distraction.
+ Yes, made me as a Director concerned that everything I say will be scrutinized.
NUCLEAR OVERSIGHT NON MANAGER COMMENTS:
+ Yes, sent some resumes out afterward; gave the impression we were kind of screwed up and didn't know ifI wanted to b> Lere; felt as if Dave apologized once and that was enough; it was commendaole that he felt he owed people an apology and he kind oflost control of that Nuclear Oversight meeting; didn't say what he really meant; by not explaining, he left it open to interpretation what was really meant by those words.
+ Yes, it has been a distraction for several weeks; people are still talking about it
( (workforce)- not personally.
+ Yes, maybe temporarily. Taken aback a little.
6
$ 6
+ Yes,it affected my attitude it hit home.
+ Yes,just kept me away from my work some. Inconvenience talking about it.
+ No, it interfered with the workday (meetings).
+ No, it is embarrassing that this happened.
+ No, absolutely not! ;
+ No, not at all
+ No,it improved it
+ No, not at this point except for the time this issue has taken.
DISCUSSION:
Eight of the 58 respondents said their work performance had been affected by the hst.
Many of these felt the issue has consumed a considerable amount of time in workplace discussions and special meetings. This was the only clear pattern identified in the responses. Some noted their disappointment when they became aware of the list. One manager expressed a concern for his ability to perform his duties wh'en every word is being scrutinized. .
Has the recent "VP/ Director List" affected your work environment?
NUCLEAR NUCLEAR f CUSTOMERS OVERSIGHT OVERSIGHT NON TOTALS MANAGERS MANAGERS YES NO YES NO YES NO YES NO 9 13 1 5 10 20 20 38 CUSTOMER COMMENTS:
+ Yes, people are talking about it
+ Yes, management has made a mountain out of a molehill. People now feel they have to carefully select each word.
+ Yes, it has put a black cloud over the workforce just as things were turning around. Upset it didn't get stopped from the start. Don't believe it was motivated by bad intentions.
+ Yes, to the extent that a lot of questions were generated on how management could think that way. i
+ Yes, slightly wasting energy talking about it l
+ Yes, after Denny gave professionalism talk to control room personnel after ;
someone made a sarcastic comment.
+ Yes, only to the degree that we've been discussing it. Should be a dead issue to !
us.
+ Yes, some people still not comfortable; personally,I see it as trivial and accept the explanation. !
+ Yes. (No further comment provided)
C + No, more careful in what I say and in the words I say and write. I 7
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((. NUCLEAR OVERSIGitT MANAGER COMMENTS:
+ Yes, people are having discussions about this. This is making people focus on things other than work.
+ No, people are tired of hearing about it.
1 NUCLEAR OVERSIGHT NON MANAGER COMMENTS:
+ Yes, ambivalent; "not really" some loss of productivity; some loss of credibility
+ Yes, I understand what he was trying to say; I was disappointed in the overreaction to the whole issue; non-productive times
+ Yes, people are still talking about it. l
+ Yes, everyone is talking about it.
+ Yes, took a little bit of a hit. We keep trusting and keep getting burned. Dragged '
the whole group down. A dulling effect almost. Very sensitive now.
+ Yes, some embarrassment. l
+ Yes,I see people posturing on this issue. The organization is beqoming polarized ,
on the issue.
+ Yes, sick of hearing about it. *
+ Yes, don't know why it was said. What it meant wasn't clearly explained. l
+ Yes, everyone was talking about it.
+ No, it has been a distraction for several weeks; people are still talking about it in the '
r workforce, but it hasn't afTected me personally.
d + No, not at all O + No, investigation worries me. Could come out with a negative result.
+ No, can't notice any difference.
DISCUSSION:
Twenty of the 58 respondents said their work environment had been affected by the list.
The one pattern identified in the previous question carried over to this closely related question. Eight people mentioned that a great deal of time 1st been spent discussing the issue. Others mentioned having to select their words more carefully for fear of having them taken out of context. The rest of the comments expressed concern ebout what the words actually meant and how management could think this way, erosion of trust and credibility, and the effect the incident has had on peoples' outlook. Many said they were tired of the whole thing.
1 Has the recent "VP/ Director List" affected your trust levelin N.O. manageme.t?
NUCLEAR NUCLEAR CUSTOMERS OVERSIGHT OVERSIGHT NON TOTAIS MANAGERS MANAGERS YES NO YES NO YES NO~ YES NO 3 19 0 6 5 25 8 50 i
8
(( CUSTOMER COMMENTS:
+ ' Yes, a little bit; indicates a lack of trust to us
+ Yes, a slight loss of trust
+ Yes, don't know what really happened, but wondering how this was overlooked and how it ended up in the paper.
+ No, the intent was good but a poor choice of words.
+ No, don't think they have bad intent.
+ No, but I do have a deep-seated doubt about Nuclear Oversight management philosophy.
+ No, unfortunate choice of words
+ No,just think it was a goof
+ No, how did we get this careless?
+ No, by having people like Dave Goebel and Wayne Kropp in key positions we are much better ofE I have total trust in these people.
SiUCLEAR OVERSIGHT MANAGER COMMENTS: !
+ No, not one bit
- I NUCLEAR OVERSIGHT NON MANAGER COMMENTS:
+ Yes, Senior Management within Nuclear Oversight took a hit. Something was meant by that comment. Lost a little bit of my trust. Not invited to 1/29/98 apology meeting. Chipped off a little bit of trust. Willing to forgive. l f + Yes, I was impressed when I found out how the issue surfaced (Manager response). Trust in Directors has decreased due to their involvement. Try truth next time.
+ Yes, we need to raise our standards; lost trust in Dave when he responded to questions in Nuclear Oversight meeting.
+ Yes, don't have the slightest idea who said it or what was meant by it and what we're doing about it. !
+ Yes, but I'd bring up safety issues. I trust my immediate management. ,
+ No, shows that management was not sensitive to the Safety Conscious Work Environment; however, if management listens to input, then problems can be worked out.
+ No, not at all
+ No, trust level it, guardedly optimistic anyway; the comments were taken out of context.
+ No, had lower trust in Goebel to start with.
+ No, it increased tmst in Nuclear Oversight management. - never bad to start with.
+ No, already didn't trust. Didn't change anything.
+ No, poor choice of words but not a trust issue.
+ No, poor choice of words. Making a mountain out of a molehill.
+ No, but I'm disturbed that some one broke trust by maliciously promoting the
( -
distribution of the memo.
+ No,just concemed that Dave needs to get better consultants.
9
( DISCUSSION:
Eight of the 58 respondents said that the list alTected their trust level in Nuclear Oversight management.
The comments ranged from simple statements that trust had been eroded to more specific concerns over what the words meant and how the i handled. Sew al of the "No's" expressed similar concerns. Some of the "No's" sa .
they already distrusted management so the effect of the list was simply to confin doubts. Many said they regretted the poor choice of words, and one responden about the broken trust brought about by the person who distributed the iht. No patterns were identified in the responses. l Has the recent "VPIDirector List" affected your trustlevelin senior managemenl NUCLEAR NUCLEAR CUSTOMERS OVERSIGIrr OVERMGHTNON TOTALS -
- I MANAGERS MANAGERS !
YES NO YES NO j
YES NO YES NO' 1 21 1 5 3 j 27 5 53 1
CUSTOMER COMMENTS:
'( + Yes,I trust them more.
+ No, the whole event was an overreaction; it should have been a non-issue.
+ No, think Kenyon did the right thing.
NUCLEAR OVERSIGHT MANAGER COMMENTS:
+ Point" Yes,think@heDay or T .
Could have us doverplayed it. Didn't corre e more polish in talking with troops.
NUCLEAR
+ OVERSIGHT NON MANAGER COMMENTS: -
Yes, absolutely don't trust Senior Management. Myjudgement is based on their actions.
+
+ Yes, shaky today, especially because ofM issue.
Yes, made me realize there's something wrong there that they would even use the word " isolate"... that they see things as a war rather than seeing the po side of gathering in other opinions and asking why people are cynical and not trusting.
+ No, but too soon to tell; need to see what they do now.
+ No, not at all .,
+
+
No, no interaction with senior management; no effect whatsoever.
+ No, thinkgdid not handle the issue well; thinigshot from the hip.
No, still don't trust Senior Management.
+
No, Mis handling situations well.
+
No, don't lik@ to stad with; still bad trust level.
10
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+ No, if anything, it's increased it. They jumped at it.
+ No, don's know. Too early to tell based on evolving information.
+ No, I respected the fact they took quick action. Dave should have explained what was meant by the words. This is still missing.
DISCUSSION:
Five of the 58 respondents said the list affected their trust level in senior management.
Of those five, three said their trust in senior management was adversely affected by management's actions. Another indicated that his tmst in management had increased as a result of how the issue was handled. Of those who stated their trust level was '
unaffected, several said they have taken a wait and see attitude. Others said they didn't tmst management prior to this incident. No obvious patterns were identified in the responses.
As a result of this list, do you feel any reluctance to mise safety contefas? .
T- NUCLEAR NUCLEAR ,
CUSTOMERS OVERSIGHT OVERSIGHT NON TOTALS O MANAGERS MANAGERS .
< YES NO YES NO YES NO YES NO O 22 0 6 1 29 1 57 _
CUSTOMER COMMENTS:
None NUCLE h OVERSIGHT MANAGER COMMENTS:
None
~
NUCLEAR OVERSIGHT NON MANAGER COMMENTS:
+ Yes, based on 2/1138 talk with Nuclear Oversight, the message was -
there are other things to worry abotit." There's a
. lack of sincerity. The Nuclear Oversight / Maintenance issue smells terrible. The way management handled this issue says it all. Things are better than they used to be but my feeling is ifI have a pro'olem, take it to the NRC or find a new job.
Follow up Interview 2/17/98 to Further Clarify 2/11#8 "Yes" response:
+ EM should have been punished for his handling of,the HR issues and the Oversight / Maintenance issue. Oversight and Maintenance should have been together when the notification was mad did not hold his position.
and M The problem on this issue ism
[ not the list. Mis just like his predecesp;rs. I feel sorry for Dave; he seems to
( be a very nice guy. I feel that Dave is set up to fail because he's new and the Directors don't have a clue. I feel our managers are good as demonstrated by iI
(, their immediate " push back" in the meeting. I feel comfortable raising safety issues to my manager but don't think my manager would get support from above.
I question the judgment of Directors and above. I felt reluctant to raise safety issues before, but the list has made it worse. We are backing up; I'm backed up at least a year as far as reluctance to raise safety concerns. There are several
! reasons for this-the list is just one of them.
DISCUSSION Initially, one of the $8 respondents expressed a reluctance to raise safety concems. In a l follow up interview, it was determined that the respondent's reluctance to raise concerns pre-dated the appearance of the list and that the incident had simply reinforced and intensified this reluctance. It should be noted that in response to an earlier question, the j same individual expressed no reluctance to voice opinions to managers in the l department, but would definitely not voice opinions to the Directors or VP. The
- respondent repeated this statement with regard to the raising of safety concerns, stating
! clearly that there was no reluctance to raise safety concerns with managers,, but there was l an unwillingness to raise safety concems with the Directors and the VP.
The "No's" were unequivocal in their assertion that the list had no effect and many completely dismissed the notion that their willingness to raise safety concerns would be g
f affected by anything.
- t. <
Primary Finding:
+ One respondent out of 58 interviewed indicated a reluctance to bring up safety concerns but not as a result of the list.
Secondary Findings:
i
+ Most respondents believe that poorjudgment was exercised by the VP and Directors. -
+ People are disappointed, frustrated, and embarrassed that this incident ever occurred.
+ Many are concerned that the VP and Directors have still not explained what they l meant by the language they used. ,
! + People are bothered by the amount of time and atten'tion this incident has commanded.
+ Several respondents expressed concern about the need to be overly careful in choosing their words to avoid misinterpretation.
+ A division of opinion exists in the Nuclear Oversight department as to how serious the incident was, what was really meant by the language, how well the situation was ,
handled, and what should be done at this point, if anything, to help resolve the issue. )
+ Most customers and members of the Oversight Department are tired of dealing with !
I the issue.
'(
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- g. Conclusions While there have been a number of undesirable consequences rising out of the appearance of the VP/ Director list, there has been no chilling effect in terms of a reluctance to raise safety concerns as a result of this incident. i l
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ATTACHMENT B l l
NEEDS ASSESSMENT FORM AND CUSTOMER FEEDBACK FORM e
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NEEDS ASSESSMENT
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-(NO !?(TERVIEW GUIDQ l
- 1. How would you rate the overall effectiveness of your Work Group?
1 2 3 4 5 Ineffective OK Very Effective 1
- 2. What are your Work Group's greatest strengths? I
( 3. What are your work group's greatest areas for improvement? -
- 4. If you had a magic wand and could use it to improve Nuclear Oversight, how would you use it?
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( 5. IIas (lic recent VI'/ Director List" affected your :
I l Arca Yes No Comments i
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+ Willingness to voice opinions?
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+ Work performance?
l' + Work environment?
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+ Trust levelin NO Mgt.? ;
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+ Trust levelin Senior Mgt.?
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CUSTOMER FEEDBACK l( (wrr.nviavcuion
- 1. How would you rate the overall effectiveness of the support you receive from Nuclear Oversight?
I 2 3 4 5 Ineffective OK Very Effective
- 2. What do you like best about Nuclear Oversight's support?
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- 3. How can Nuclear Oversight improve its support?
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- 4. If you had a magle wand and could use it to improve Nuclear Oversight, how would you use it?
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- 5. IIas (lic recent "VP/ Director List" affected your :
Area Yes No Comments l
l l + Willingness to voice opinions?
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+ Work performance?
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[ + Work environment?
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+ Trust levelin NO Mgt.?
+ Trust levelin Senior Mgt.?
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I Docket Nos. 50-245 )
50-336
(- 50-423 B17098 l
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Attachment 3 Millstone Nuclear Power Station, Unit Nos.1,2,3 -
ECP Peer Representatives Survey (Redacted)
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l March 1998 i
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d we c Safety Conscious Work Environment Assessment of Nuclear Oversight 1/21/98 Statement Revision 0 Employee Concerns Peer Representative and y' Safety Conscious Work Environment t Organization Poll NOTE: Based on ECP Peer Representative request, Appendix B, Detailed Responsesfor Each Question, is considered CDEEIDENIIAL since the section lists the group from which the comments originated.
March 6th, gggg
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g we ce Collection of Organizational Reactions
\ to the Nuclear Oversight Focus'98 Draft Paper Table of Contents EXECUTIVE
SUMMARY
_- - . . 't PURPOSE: -: . . . . . . . . ..........3 OVERVIEW : . . . . . . . . . . . . . . . :3 INTRODUCTION - . . ..................................3 POSITIVE THEMES..... .... .. - - . . ~ . - . ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . -4 NEGATIVE THEMES . ..: - . .... . ..................................4 DATA GATHERING PROCESS. - 4 QUESTIONS = . . . . . . . . - . . . . . . . . . . . . . . . . . 4 DATA SOURCES .... .... . ..... .... . . . . . . . . . . . . . - . . . . . . . . . . . . . . ~ . . . . . ~ . . . . , . . ..........4 SAMPLE SIZE ., . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .............4 THEMES 11Y QUESTION. < 5 Q1: WHAT IMPACT, IF ANY, HAS THIS EVENT HAD ON YOUR WORK ENVIRONMENT 7.. . . .. ..............$
Q2: WHAT IMPACT HAS THIS EVENT HAD ON YOUR WILLINONESS TO VOICE OPINIONS ON ISSUES 7.. .. ........ ...... ........$
Q3: WHAT IMPACT HAS THIS EVENT HAD ON YOUR WORK PERFORMANCE 7. . .... . ....... . .~.. ... .. ... 6 l Q4: WHAT IMPACT HAS T1(IS EVENT HAD ON THE TRUST LEVEL BETWEEN YOUR BOSS AND YOU7...... . .. -6 Q$: WHAT IMPACT HAS DUS EVENT HAD ON THE TRUST LEVEL BETWEEN SENIOR M ANAGEMENT AND YOU7..... .. ... 7 ATTACIBIENT A: DEMOGRAPHICS AND DATA GATHERING - - 8 ATTACIBIENT B: DETAILED RESPONSES FOR EACH QUESTION 11 l
Q1: WHAT IMPACT, IF ANY, HAS THIS EVENT HAD ON YOUR WORK ENVIRONMEN17.: . I1 Q2: WHAT IMPACT HAS THIS EVENT HAD ON YOUR WILLINONESS TO VOICE OPINIONS ON ISSUES 7.... .. . .... .15 Q3: WHAT IMPACT HAS THIS EVENT HAD ON YOUR WORK PERFORMANCE 7 : . ................17 Q4: WHAT IMPACT HAS THIS EVENT HAD ON THE TRUST LEVEL BETWEEN YOUR BOSS AND YOU7 - . ..... .. 20 QS: WHAT IMPACT HAS THIS EVENT HAD ON THE TRUST LEVEL BETWEEN SENIOR MANAGEMENT AND YOU7 .22 Q6: DO YOU HAVE ANY COMMENTS 7.. . ... .. . . . . . . . . . ..... .... 2 8 i
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I March 6*,1998 Revision 0 Page 2 of 40
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rn.nt wa c== Collection of Organizational Reactions
( to the Nuclear Oversight Focus'98 Draft Paper I
Executive Summary Purpose This report assesses the Organizational chilling effect of a dran working paper generated by Oversight management. The draR paper contained the phrase, " inability to isolate cynics from 1 the group culture." This report details the p*olling and results of the information that was collected from February 2 to Febmary 18 ,1998.
Overview This report provides a brief description of the event, summarizes positive and negative theme and the data sources, identifies themes for each question, details the demographics, and categorizes for each question the responses by polled group. Although individuals are not identified, a polled group requested that their comments not be publicly identified. For this reason, Appendix B of this report is considered confidential and is not to be publicly distributed.
Introduction On Sunday, January 11*,1998, the Nuclear Oversight Vice President, the three Oversight Directors, the Executive Assistant to the Vice President, and a consultant met to brainstorm a list of Nuclear Oversight's strengths and areas for improvement. The group developed a draft list (k. titled Focus:98 Director / YP View ofNuclear Oversight (1/11/98).
The draft paper was distributed to the Nuclear Oversight leadership team at an off site meeting on Wednesday, January 21",1998. The paper contained the following information:
Current SCWE Environment and Issues
- Inability to " isolate" cynics from group culture l
- Too much negative energy (personnel issues) e Pockets ofnegativism Members of the group quickly noticed these words. The group discussed these ideas, noting that the words could be misinterpreted as the desire to isolate individuals from the group. The leadership team agreed that the draft paper did not represent their thoughts and should be corrected.
The draft paper was distributed to the site and the press. The draft paper had the potential of causing anxiety throughout the orgamzation. The Safety Conscious Work Environment (SCWE)
Group asked the Employee Concerns Program (ECP) peer representatives to poll the organization to determine any chilling effect as a result of this draft paper. The SCWE Group also polled parts of the organization that was not represented by ECP peer representatives. This report summarizes the positive and negative themes as determined by the polling. This report also summarites themes by yestion, and details the polling demographics.
March 6*,1998 Revision 0 Page 3 of 40
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g we coa. Collection of Organizational Reactions l ( to the Nuclear Oversight Focus'98 Draft Paper 1
Positive Themes
- No apparent chilling effect in the majority of the organization
. People want to be able to concentrate on their work, especially restart efforts l
- Trust was not impaired with immediate supervision
- Speed of response time was judged as positive Negative Themes
- Three comments from one polled group indicated a chilling effect
. One anonymous comment indicated a lack of willingness to voice opinions
+ Unintended perceptions always need to be considered, especially at Senior Management levels
- Comments indicated that some loss of trust with Senior Management occurred e People need help learning to distinguish between cynicism and constructive criticism
. The faster the investigation can be completed and follow-up actions communicated, the less negative impact on trust will result
- Data Gathering Process Questions (s 1. What impact has this event had on your work environment?
- 2. What impact has this event had on your willingness to voice opinions on issues?
- 3. What impact has this event had on your work performance?
- 4. What impact has this event had on the trust level between your boss and you?
- 5. What impact has this event had on the trust level between c:nior management and you?
- 6. Do you have any comments?
Data Sources
- All peer representatives were asked to gather data from their work groups (and other work groups)
Additional individuals were queried in departments not represented by peer representatives e Data gathering included one on one interviews, questionnaires, group meetings, and informal conversations !
- Responses reflect overall impacts, not only chilling effect impacts l
l Sample Size
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. Number of work groups sampled: 34
- Number of employees sampled: 270 March 6*,1998 Revision 0 Page 4 of 40 i
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I wec== Collection of Organizational Reactions k to the Nuclear Oversight Focus'98 Draft Paper I 1
Themes by Question Q1: What impact, if any, has this event had on your work environment?
Summary regarding chilling effect: "None" Summary regarding other impacts: Concern about how Senior Management could have come to use this inflammatory language.
Representative Comments of Concern:
- Incident has been costly in terms oflost time on-the-job e Was initial disappointment in management's poor choice of words; "how could this have happened in light of current problems?"
. Silence on the issue raises even more question
- Confusion and rumors have been byproducts -
- Questions / concern by workers that we're not making progress
- More cynicism
. Caused unrest / disappointment with Senior Management e Concem about whether the incident will impact start up (r' e "The response... has been one of wonder. In their right-minded, seemingly well-intentioned attempts to apologize and explain, they may have said more than they needed."
1 Representative Positive Comments:
- 9 work groups reported no negative impacts e Management's intention wasn't to isolate and identify specific people e " ...
in our branch, there has always been an open channel to voice one's opinions related to safety issues and that quality of... communication has never been threatened."
e "this event has actually had a positive effect. Yes, someone made a mistake, but as soon as that mistake was realized, action was taken immediately to correct it; apology was made."
Q2: What impact has this event had on your willingness to voice opinions on issues?
Summary regarding chilling effect: A total of three comments noted a chilling effect. (See comments in bold below.) i Summary regarding other impacts: One negative comment was noted regarding lack of !
willingness to voice opinions. (See comment in bold below.)
l Reprer.entative Comments of Concern:
. It further allenates me from my management because I consider myself a skeptic. Note:
(- skeptic originates from skeptikos (thoughtful) and skeptesthal(to look, consider).
March 6*,1998 Revision 0 Page 5 of 40
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t we em Collection of Organizational Reactions k to the Nuclear Oversight Focus'98 Draft Paper o "wouldn't ...ever, ever consider voicing any kind of opinion to upper management.
They still don't get the messages of how to treat, address, think of, or value input from their employees."
- Decreased willingness e Presents a chilling effect l
- "For now, some hesitation, but not at the expense of safety or lowering our standards."
l Representative Positive Comments: l
- 16 work groups noted no negative impacts e " ...
the comments that I hear from peers and some supervisors have made me more aware of what I say to whom." l
- "I saw the original remark as a way to help the general workforce and to foster a positive working environment. I saw the response as an over-reaction which was then promulgated by the media." :
- "Somewhat positive since this issue was promptly discovered and addressed. This would not have happened several months ago".
Q3: What Impact has this event had on your work performance?
f l Summary regarding chilling effect: None k
Summary regarding other imps cts: None, except the time lost in discussing the incident.
Representative Comments of Concern:
- Diverted time from productive work.
"None...other than I wonder how much longer it will take to get past these types issues and get on with ' normal' living/ working."
Representative Positive Comments:
e 17 workgroups noted no negative impacts e "I've tried not to use double meaning words and to insure the person I speak with walks away knowing what I had in mind."
e "I was pleased to see how strong and how quick the management response was to get this information out to everyone."
Q4: What impact has this event had on the trust level between your boss and you?
Summary regarding chilling effect: None (100% of respondents)
Summary regarding other impacts: None March 6*.1998 Revision 0 Page 6 of 40 .
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d we c, a. Collection of Organizational Reactions to the Nuclear Oversight Focus'98 Draft Paper l
l Representative Comments of Concern:
e "It takes time, but I do believe we're seeing genuine changes. The jury...still remains out l
about whether or not these positive attitudes will remain when things retum to normal. That is the biggest test."
Representative Positive Comments:
"I have complete tmst in my supervisor, manager and director to keep me informed ofissues l and to listen and respond ifI have an issue..."
. Trust level remains high.
"None, other than ar. increased sensitivity on our supervisor's part to look at how 'what they say' could be misperceived".
05: What impact has this event had on the trust level between senior management and you?
Summary regarding chilling effect: None .
Summary regarding other impacts: "No impact" to " definite negative impacts" trusting Senior Management to lead effectively.
, Representative Comments of Concern:
( e Less respect may result if more explanation about the event isn't forthcoming.
" Negatively impacts trust regarding Senior Management. I feel the current problems were brought on by Senior Management and they still haven't changed their attitudes at certain levels. I trust Mr. Kenyon and feel he is trying hard to tum the situation around. However, it seems additional changes and/or replacements in some areas are still necessary."
. Makes some employees question theirjudgments.
Representative Positive Comments:
e 10 workgroups reported no negative impacts.
. "None. Absolute tmst!!"
e "If anything, the trust has increased. It is noble to admit a mistake and confront it head on."
- Employees appreciated the apology.
"I do believe that they could have meant something else, but didn't see the full meaning of the words."
e "It's a shame management has to waste time and money responding to crap like this. Let's realize this is a business and allow management to focus on the real issues."
. Several supportive comments were made about Mr. Kenyon's leadership I
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March 6*,1998 Revision 0 Page 7 of 40
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l we'c# Collection of Organizational Reactions j to the Nuclear Oversight Focus'98 Draft Paper 1
1 1 Attachment A: Demographics and Data Gathering i 1
l UNIT ONE: l \
Guy Mtadenhail .- Ennerience Assessment. part of Supnort Services; j Demographics:
N=10= most of his people,1/2 exempt Process:
j one-on-one with some, later met with all (including original 3-4) on second day i l
Walter Liss - Maintenance Demographics:
N= 17 Process:
distributed individual questionnaires, verbatim responses captured anonymously Dwnvne Basler - Unit 1. FIN Demographics: .
l N=10= 100% of his group, varying levels: I sup. for ops.,2 operators, engineer, electrician, maintenance, HP,2 j I&C specs., planner l
Process: i at his regular AM meeting; he read the questions to the group and told them they could also come to him individually .
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William Loweth - Enaineering:
Demographics:
N=1 Process: own opinion Fred Altvatar- Unit L HP:
Demographics:
N=4, HP group Process:
informal, break room l UNIT TWO: l E Walnlo - Design Engineering:
Demographics:
N=20 Process:
Distributed questionnaires to individuals; verbatim comments captured anonymously.
l March 6*,1998 Revision 0 Page 8 of 40 -
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e wecm Collection of Organizational Reactions
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to the Nuclear Oversight Focus'98 Draft Paper l UNIT THREE.
Randy Jacobson - Unit 3. Maintenance:
j Demographics:
N=6 Process:
random talks with individuals Mike Kennedv - Operations:
Demos / process:
N=4, casual conversations N-12, at a shift turnover meeting a few others in casualconversations l NUCLEAR ENGINEERING AND SUPPOR T O VER VIEW l LuAnn Cataudella - Professional Devel. Groun. Nucl. Tr.!
Demographics: her own personal opinions John Doroski - Technical Chemical Supnort!
Demographics:
N=4 in his group = almost all of his group: 1 tech, I scientist, I sr. engineer, I sr. chemist.
Grec D' Aurla - Chemistry Technical Sunnort: ~
Demos-two groups surveyed:
[( l . h.is direct reports, N=8 (2 non-exempt), e.g. sr. engineer, sr. chemist, other engineers
- 2. Nucl. Water Chem, N=10 = all exempt engineers Process:
unofricial group meetings Jeff Tavlor - Nuclear Traintny:
Demographics:
N=7 in Nuclear Training Group Process:
informal discussions Jim Bennett - Nuclear Training Demographics:
N=7 Process:
casualconversations in workgroup Jack Barnett/ Rich Badon - Nuclear Engineerine. New Britain Demographics:
N=40 Process:
questionnaires distributed, verbatim comments captured anonymously Barbara Tarallo - Emergency Planning Servlees r Demographics:
I N-2
\ Process:
March 6*,1993 Rev:. .sion 0 Page 9 of 40
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wac# Collection of Organizational Reactions to the Nuclear Oversight Focus'98 Draft Paper aformal comments in workgroup l NUCLEAR WORKSERVICES OVERVIEW: l Josenh Hockdorfer -- Maintenance Services Demos - two groups:
- 1. Joe's group, N=4, exempt aad non-exempt
- 2. Group of Millstane employees who report to Joe's boss, N=6-7, I secretary, I constmetion rep., I work order preparer, I construction rep.
N=6-7, don't repcrt to Joe; orie Process: informal one-on-one Rich Rocozinsk't - Unit 3. Procurement:
Demographics:
N-15, an:ludes 2 exempt Proces:
group meeting 'At start of two days, revisited on two diff. days talked one-on-one Art Flath - Nuclear 1" Demographics: N=7 Process: group meeting led by his supenisor r IN ADDITION TO PEER REPRESENTATIVES.TIIE FOLLOWTNG DEPARTMENTS ALSO PROVIDED DATA:
Licensing: (N= 5), questions ast.ed randomly to individuals -
Waste Man agement: (N= 9), informal lunchtime conver;ations; qvutions not asked directly Documentation and Services:(N=5)
Unit 2, questionnaires distributed to individuals:
Eng;ineer (N=l)
Miscellanious (N=4)
Chemistry (N=4)
Msintenance (N=5)
I&C (N=6)
Englocering (N=5)
Opera tions (N=7)
Radiological Engineering (N= 1)
IIP (N=7)
Unit 2 MOV's: (N=2), questions asked randomly to individuals Communications (N=6), informal poll by manager Unit 1 Maintenance (N=17), questionnai es di ,tributed to individuals s
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! svkonmord l we c== Collection of Organizational CONFIDENTIAL Reactions to the Nuclear Oversight Focus'98 Draft Paper Attachment B: Detailed Responses for Each Question I
Attachment B contains personnel information, the public disclosure of which would constitute a clearly unwarranted invasion of personal privacy. Accordingly, pursuant to 10 CFR 2.790(a)(6),
Attachment B which identifies specific groups from which comments originated, has been !
omitted to protect personal privacy.
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