ML20217A475

Forwards Little Harbor Consultants (Lhc) Quarterly Rept for Last Three Months of 1997

ML20217A475
Person / Time
Site:	Millstone
Issue date:	03/19/1998
From:	Beck J AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ITOP-98-0014, ITOP-98-14, NUDOCS 9803250082
Download: ML20217A475 (149)

Text

'

Little Harbor Consultants, Inc.

Millstone -ITPOP Project Omce P.O. Box 0630 Niantic, Connecticut 06357-0630 Telephone 860-447-1791, est 5966 Faz 860-444-5758 March 19,1998 Docket Nos 50-245 50-336 50-423 ITPOP 98-0014 U.S. Nudear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 This letter transmits the Little Harboi Consultants (LHC) quarterly report for the last three months of 1997.

Sincerely,

.S i John W. Beck Team Leader, ITPOP President, LHC Attachments cc: Distribution 800.1 9803250082 980319 PDR ADOCK 05000245.

p PDR L

=

U.S. Nuclear Regulatory Commission Page 2, ITPOP 98-0014 Distribution:

John Streeter, NNECo Charles Brinkman, Manager Washington Nuclear Operations llarry L. Miller, NNECo ABB Combustion Engineering Nuclear Power 12300 Twinbrook Pkwy, Suite 330 William J. Temple, NNECo Rockville, MD 20852 Susan Baranski, NNECo Mr. John Buckingham Cheryl Grise, NNECo Department of Public Utility Control Electric Unit Michael Quinn, ECOP 10 Franklin Square New Britain, CT 06051 U.S. Nuclear Regulatory Commission Attn: W.D. Travers Citizens Regulatory Commission Mail Stop: 014D4 ATTN: Ms. Susan Perry Luxton Washington, DC 20555-0001 180 Great Neck Road Waterford, CT 06385 U.S. Nuclear Regulatory Commission Attn: P.F. McKee Citizens Awareness Network Mail Stop: 014D4 54 Old Turnpike Road Washington, DC 20$55-0001 liaddam, CT 06438 U.S. Nuclear Regulatory Commission The lionorable Terry Concannon Attn: li.N. Pastis Nuclear Energy Advisory Council Mail Stop: 014D4 Legislative Office Building Washington, DC 20555-0001 Hartford, CT 06106 Mr. Wayne D. Lanning Mr. Evan W. Woollacott US NRC Region I Co-Chair 475 Allendale Road Nuclear Energy Advisory Council King of Prussia, PA 19406 1415 128 Terry's Plain Road Simsbury, CT 06070 Kevin T. A. McCarthy, Director Monitoring and Radiation Division Ernest C. Hadicy, Esquire Department of Environmental Protection 1040 B Main Street 79 Elm Street P.O. Box 549 liartford, CT 06106-5127 West Wareham, MA 02576 Allan Johanson, Assistant Director Mr. Paul Choiniere Office of Policy and Management "The Day" Policy Development and Planning Division 47 Eugene O'Neill Drive 450 Capitol Avenue-MS 52ERN New London, CT 06320 P.O. Box 341441 Ilartford, CT 06134-1441 Bob DeFayette 100 King Street First Selectmen Gettysburg, PA 17325 Town of Waterford llall of Records Don Beckman 200 Boston Post Road 1071 State, Route 136 Waterford, CT 06385 Belle Vernon, PA 15012

~

E.

QUARTERLY REPORT DF LITTLE IIARBOR CONSULTANTS TO TIIE NUCLEAR REGULATORY COMMISSION Concerning Oversight of Northeast Utilities' Development of a Safety Conscious Work Environment at Millstone Nuclear Station for the Period October 1-December 3L 1997 Pursuant to an order issued by the Nuclear Regulatory Commission (NRC) on October 24, 1996 and its Oversight Plan approved by the NRC on July 14,1997, Little Ilarbor Consultants (LHC) has been overseeing the efforts of Northeast Utilities (NNECo) to develop a Safety Conscious Work Environment (SCWE) at its Millstone Nuclear Station. Under this program, LHC submits quarterly reports to the NRC on the status and progress of this process. This report

. covers the fourth quarter of 1997.

L

SUMMARY

LIIC's activities at Millstone during the quarter covered the range of activities specified in the Oversight Plan. They included monitoring of ongoing NNECo activities, presentations to the NRC Commissioners and Staff, issuance of a report on an allegation of retaliation, preparation of an assessrnent of the status of LHC recommendations to NNECo, and an interim assessment of LIIC's progress in implementing its own Oversight Plan. Principal areas of activity are listed in Part 11 below. Selected areas of endeavor, raised in some detailin presentations to the Commission and the Staff, are discussed more particularly in Part III. Because virtually all of L11C's activities are already documented in writing, this report proceeds mostly by way of reference and attachment, rather than by repetition or lengthy recapitulation of material treated in existing documents. Presentations to the NRC Staff and NNECo at formal meetings have been treated slightly differently: original slide presentations have been attached, including a summary of pertinent oral presentations at the meetings, based on transcript or videotape.

'IL PRINCIPAL AREAS OF ACTIVITY

1. Spsgjfic Areas of Aq11yity The LiiC team allocated its time among numerous areas of endeavor during the quarter.

Of these, the principal ones ofinterest included the following:

a. Continued review of files of the Employee Concerns Program (ECP), including all files alleging harassment, intimidation, retaliation or discrimination (HIR&D) 2

2 prescribed by 211 of the Energy Reorganization Act, oversight of ECP handling of these files, and interviewing employees who raised these concerns.

b. Monitoring and oversight, as needed, of concerns or HIR&D-related allegations involving Nuclear Oversight (including the Quality Control Group), Nuclear Safety and Training department personnel.

Attending and observing NNECo's development of training for all supervisors and c.

managers with respect to the NRC's HIR&D requirements in 10 CFR 50.7 and their origin in the Energy Reorganization Act 211.

d. Monitoring, development and functioning of the Executive Review Board (ERB) in the context of specific discipline issues.

Evaluation of developing negative trends in the QC Group of Oversight; meeting e.

on November 6 with NNECo management, reported in letter of November 12, 1997 (ITPOP 97-0047) [ Attachment 1].

f.

Investigation of allegations of retaliation in connection with the administration of discipline to 22 members of the Training Department at Millstone, culminating in issuance of a report dated November 14,1997 (ITPOP 97-0048) [ Attachment 2].

g. Presentation to the NRC Staff and NNECo, November 13,1997 (ITPOP 97-0049).

h. Presentation to the NRC Commissioners, December 12,1997 (ITPOP 97-0056).

i

i. Compilation of a summary of recommendations made to date by LIIC to NNECo and their status, and transmission to NNECo in a 30-page matrix, "LIIC Recommendations and Responses," dated December 19,1997 (ITPOP 97-0057)

[ Attachment 3].

j. Performance of an Interim Assessment, Status ofImplementation ofITPOP Oversight Plan, Rev.1, November 21,1997 [ Attachment 4].

k. Supporting a NRC Staff audit ofITPOP activities to date.

1.

Comprehensive review of the NNECo Corrective Action Program.

m. Preparation of an internal draft (Revision 0, Draft A) plan for evaluating Millstone Self-Assessment and Nuclear Oversight Programs, December 1997.

a

1

.1 3

2. Functional Allocation ofLHC Efforts LHC's work entails, in addition to the major efforts and initiatives summarized above, a day-to-day run of programmatic reviews, and ofinformal inquiries, investigations, correspondence and other communications with NNECo personnel at all levels, with the NRC, and with members of the public. It is not possible to itemize them all. However, a general sense of the allocation of LHC members' efforts can be gleaned from a summary of members' time sheets. The LHC team consists of 11 professionals and, during the '

calendar quarter ofinterest, one support staff person. During the quarter,10 of the professional staff spent time at the Millstone site, with full-time staff support.

Collectively, they dedicated approximately 3520 hours0.0407 days <br />0.978 hours <br />0.00582 weeks <br />0.00134 months <br /> to the project, allocated as follows by type of effort:

Time Code Time Spent Time Spent (hours)

(percent)

Investigations 445.0 12.6 %

Document Review 219.5 6.2%

ECP Reviews 994.2 28.2 %

Structured Interviews 105.5 3.0%

Public/NRC Meetings 298 8.5%

rechnical Reviews 320.4 9.1%

Intervie;vs/ Meetings / Observations 786.75 22.3 %

Management / Administration 350 9.9%

TOTALS 3519.75 100 %

IIL PRESENTATIONS TO THE NRC AND NNECo

1. LHC made two formal presentations to the NRC and NNECo during the quarter:

a. Eresentation to NRC Staff and NNECo. November 13.1997 at Millstone, including the following oral reports on six topics, five of them accompanied by slides (for original slides, see ITPOP 97-0049, attached as Attachment 5; for a summary of the presentation at the meeting, incorporating both the text of the slides and the discussion, see Attachment 6):

Independent Investigation of Allegations of Retaliation and Handling of the Training Disciplinary Action: LHC concludes that there had not been any retaliation against the former Director of Training for having engaged in protected activity. However, LHC also concludes that NNECo had neither anticipated the " chilling effect" associated with its disciplinary actions, nor adequately mitigated or investigated the incidence of" chilling efTect;" and that

4 NNECo had not fully investigated the actual allegations of retaliation. See Attachments 2,5 and 6.

Oversight of Millstone Employee Concerns Program: LIIC concludes that progress has been made in the organization and leadership of the ECP at Millstone, in the qualification and training of ECP personnel, and in ECP program defmition and implementation. It recognizes continuing difficulties in the level ofIIIR&D sensitivity among employees at large and a still-high level of dissatisfaction with the ECP expressed by emp'oyees. The presentation includes 14 separately listed recommendations.

Comprehensive Plan Effectiveness: LilC's principal expressed concern is that there are still a significant number ofIIIR&D concerns being received and substantiated by the ECP. Other issues involve coordination of activities and information among ECP, Employee Concerns Oveisight Panel (ECOP), and SCWE groups, and training at various levels. The presentation includes seven separately listed recommendations addressing these areas.

Measuring Efrorts To Implement A Safety Conscious Work Environment At Millstone: This is the first presentation of a proposed " windows" methodology for evaluating the overall SCWE program, and includes (1) a listing of SCWE attributes, (2) a scale for evaluating the quality of SCWE implementation, and (3) a means of evaluating trends in them. The discussion includes preliminary example evaluations of 3 of the 12 SCWE criteria selected by LIIC.

• LilC Asses it of SCWE Implementation Status: NNECo Performance Measure-ay Conscious Work Environment: This is a comparison of the twelve prformance measures chosen by LHC to define a Safety-Conscious Work Environment into the four Success Criteria developed by NNECo. Its purpose is to lay the groundwork for a commonly accepted set of evaluation criteria for evaluating Millstone prior to restart.

Discussion of Deteriorating Situation in the QC Group: LIIC expressed concern because facts pertinent to this issue had been known to numerous persons in NNEco management for several weeks if not months, but not communicated or responded to satisfactorily to " nip the situation in the bud."

b. Etegniation to NRC Commissioners. Dectmber 12.1997. in Whilg Flint.

involving an oral presentation, accompanied by slides, on the Status of a Safety-Conscious Work Environment at Millstone. This presentation opens with a repon on the round ofinter iews to be conducted in Febmary 1998, and on the status of investigations conducted by LilC. The principal focus of the presentation is a detailed description of the methodology (first described to the Staff on November

13) for evaluating SCWE attributes at Millstone, and a status report on these attributes. The report concludes that ten of the twelve criteria are either

5 acceptable for restart at this point or trending in that direction. The remaining two attributes are at unacceptable levels. These are (1) the continuing occurrence of lilR&D incidents and the absence of demonstrably efTective management response to them, and (2) the continuing presence of a " chilling effect" with the potential to deter employees from reporting safety issues.

IV.

PUBLIC INTERACTIONS OTIIER TIIAN FORMAL PRESENTATIONS

1. Little liarbor participated, along with the NRC Staff and NNECo personnel, in one formal meeting with the public, on the evening of December 17,1997, at the Waterford Town liall. Little liarbor personnel recapitulated the substance of their December 12 presentation to the Commission and answered questions from the audience.

2. Members of the Little Harbor team participate from time to time on local television and radio shows, at the request of the hosts. No separate record is kept of such presentations.

V.

STATUS OF RECOMMENDATIONS TO NNECo

1. As of December 31,1997, LliC had made some 73 separately enumerated written recommendations to NNECo, consisting (with subparts) of some 101 recommendations in total, set out in some 13 separate communications to NNECo.

These are recited fully in the attachment to ITPOP 97-0057, "LHC Recommendations and Responses, dated December 19,1997 (Attachment 3). A summary of their status, as of December 19,1997 was as follows:

Number of recommendations (including subparts) made by LliC: 101 Number of recommendations responded to by NNECo: 53 Number of NNECo responses evaluated by LliC: 40 Number of recommendations closed by LHC: 21 Number of recommendations open as of December 19,1997: 80 Care must be exercised in assessing the significance of these numbers: not all recommendations are created equal, either in importance or ease of resolution.

Significant further progress in evaluating NNECo responses and closing out eligible open items is expected during the first quarter.

VI.

ANTICIPATED ACTIVITIES DURING 1" OUARTER,1998

1. Conduct of second round of structured intersiews.

J

6

2. Continuation of survey of NNECo concernees re " customer satisfaction" levels with ECP.

3. Update of matrix ofITPOP recommendations and NNECo responses.

4. Continued review of specific ECP files.

5. Continued review of the functioning of the Corrective Action Program and the Employee Concerns Program.

6. Completion ofITPOP Self-Assessment.

7. NRC and NNECo Presentations, January 27 and March 3,1998

8. NRC Commissioner briefmg, February 19,1998.

9. Completion of an evaluation of the NNECo Self-Assessment and Nuclear Oversight Programs.

Vll.

CONCI,USIONS As presented in the December 12,1997 report to the Commission, LHC believes that NNECo has made strides in developing the programmatic elements of a safety-conscious work environment and in encouraging a questioning attitude among employees. Further progress is required in connection with the number of allegations of HIR&D and the responses to them. Significant work needs also to be done to ensure closure of outstanding open recommendations to NNECo prior to a request for Commission authorization of resurt of Unit 3. LHC does not know at this point of anything preventing its completion ofits own evaluations in time to address such a request, as long as NNECo is able to address the open issues it faces with respect to HIR&D issues.

[/ John W. Beck Team Leader, ITPOP President, Little Harbor Consultants, Inc.

DATE: March 18,1998

'I 7

,AT TACilM ENTS

1. ITPOP 97-0047, Letter, November 12,1997, Beck to Kenyon (NNECo), re deteriorating SCWE situation developing in QC Group of Oversight, and Nov 6 meeting with Brothers (3 PP )

2. ITPOP 97-0048, independent Investigation of Allegations of Retaliation against Michael B.

Brown and the Handling of the Training Disciplinary Action, covered by letter, November 14, 1998, Beck to Kenyon (31 pp.)

3. ITPOP 97-0057, Matrix, "LHC Recommendations and [NNECo] Responses," covered by memorandum, December 19,1997, Griffin to Brothers (31 pp.)

4. Interim Assessment, Status ofImplementation ofITPOP Oversight Plan, Rev.1, November 21,1997 (15 pp.)

5. ITPOP 97-0049, Letter, November 18,1997, Beck to Kenyon, forwarding five sets of transparencies covering LHC presentation to NRC Staff on November 13,1997:

" Independent Investigation of Allegations of Retaliation and Handling of the Training a.

Disciplinary Action"(1 page)

b. " Oversight of Millstone Employee Concerns Program" (5 pp.)

c. " Comprehensive Plan Effectiveness" (2 pp.)

d. " Measuring Efforts to Implement a Safety Conscious Work Environment at Millstone" (4 pp.)

"NNECo Performance Measures: Safety-Conscious Work Environment" (2 pp.)

e.

6. Edited summary of the meting among NRC staff, NNECo and LHC, November 13,1997 at Millstone, focusing on that portion of the meeting containing presentations by LHC (21 pp.)

7. ITPOP 97-0056, letter, December 17,1997, Beck to Brothers, forwarding transparencies used in LHC Presentation to NRC on December 12,1997 (6 pp.)

8. Transcript from NRC Commissioner meeting of December 12,1997, LHC presentation only, (14 pp.)

1

gi ATTACHMENT 1

• 'l

' Little Harbor Consultants, Inc.

Minstone-ITPOP Project Omce P.O. Box 0630 Niantic, Connecticut 06357-0630 Telephone 860-447-1791, est 5966 Faz 860 444-5758 November 12,1997 ITPOP 97-0047 Mr. Bruce Kenyon President and Chief Executive Officer Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385-0128

SUBJECT:

Nuclear Oversight, Quality Control Group in accordance with the LHC protocol governing time-sensitive ma+ters, this letter summarizes our verbal notification to you on November 6,1997, that LHC was concerned about certain circumstances within the Quality Control Group which were rapidly getting worse and needed immediate management attention.

On November 6,1997, John Beck and Billie Garde requested an appointment with Mike Brothers, the NU officer-sponsor for a safety conscious work environment, to infonn him that LHC had concluded that conditions within the Quality Control Group of Nuclear Oversight were rapidly deteriorating. Management needed to take some extraordinary measures to deal with those circumstances. The basis for the LHC concern was a combination ofinput from drop-in visits to the LHC office by numerous members of the group who had expressed various concerns, a number of

' ECP concerns which emanated from the Quality Control Group, and specific language contained in an action plan which applied to the Performance Evaluation Group. The action plan was developed to address a Problem Area which was self-identified by Nuclear Oversight management. The specific language in the action plan that was so prominent was descriptive ofoverall conditions in the Quality Control Group and was starkly similar to language used by Ms. Garde in her training courses-developed to alert managers to an incipient, organizational crisis.

. Following the LHC warning, Mr. Brothers undertook an immediate course of action that had as its initial step his face to-face meeting that morning with QC Group personnel. He was joined by other management personnel as well as Ms. Garde, who was present to observe NNECo's performance and to assure that LHC expectations were clearly understood.

A number of decisions which followed the meetings ( a second meeting with QC personnel was

- o.

ITPOP 97-0047, Page 2 November 12,1997 held in the evening of the 6* with those assigned to the evening shift ) were announced in a special edition of"To The Point" which was published on November 10,1997. This publication was r=npanied by an editorial note which reiterated management' s commitment to a Safety Conscious

. Work Environment including a pledge to communicate to all employees as frequently as possible on a wide variety ofissues.

LHC is concerned that many of the Quality Control Group issues were known to management for months and were not effectively addressed until they appeared to reach a state of crisis. We are further concerned that there are other matters that are the subject of action plans that have the potential to escalate in a similar fashion unless management takes vigorous and immediate steps to resolve them.

LHC will closely monitor the actions taken to respond to the Quality Control Group issues. We also expect NNECo to use the information available from sources such as ECP and ECOP to identify and respond to other emerging issues before they escalate to a crisis level.

Sincerely yours, h &.$=L Jdha W. Beck President, Little Harbor Consultants, Inc.

Team Leader,ITPOP cc:

Distribution

!y ITPOP 97-0047, Page 3 Novesuber 12,1997 Distribution:

D.M. Goebel, NNECo Charles BM==a Manager Washington Nuclear Operanons P, t mana. NNECo ABB Combustion #=paa-ing Nuclear Power

!=

K M. McBrien, NNECo 12300 TwinbrookPiney, Suite 330 Rockville, MD 20852 W. J. Temple, NNECo S. Barmki, NNECo Mr. John Buclungham Department of Public Utahty Control M. Quinn, ECOP Elecinc Unit -

10 Liberty Square U.S. Nuclear Regulatory Co==iaman New Britain, CT06051 Atta: Document ControlDesk

.. ashington,DC20555 CituensRegulatoryen i nn W

ATTN: Ms. Susan Perry Luxton U.S. Nuclear Regulatory Comenission 180 Great Neck Road Atta: W.D. Travers Waterford, CT 06385 Mail Stop: 014D4 Washington, DC 20555 0001 Citucas Awareness Network 54 Oid Turnpake Road U.S. Nuclear Regulatory Commission Haddam, CT 06438 J

Atta: P.F. McKee Mail Stop: 014D4 The Honorable Terry Contmanan Washington, DC 20555-0001 Nuclear Energy Advisory Council Legislative Office Building U.S. Nuclear Regulatory Comnussion Hartford, CT 06106 Atta: H.N. Pastis Mail Stop: 014D4 Mr. Evan W. Woollacott

. Washington, DC 20555 0001 Co-Chair Nuclear Energy Advisory Council Mr. Wayne D. Lanning 128 Terry's Plain Road Deputy Director ofInspections Simsbury, CT 06070 Special Projects Office 475 Allendale Road Ernest C. Hadley, Esquire King of Prussa, PA 194061415 1040 B Main Street

~ P.O. Box 549 KevinT. A.McCarthy, Director West Warchsm, MA 02576 Momtoring and Radiation Division Department of Environ =anta1 Protection Mr. Paul Chommere 79 Elm Street "ne Day" Hartford,CT 06106 5127 47 Eugene O'NeillDrive NewImedon, CT06320

' AEan Johanson, Assutant Director OtBoe of Policy and Manarama e Bob DePayette Policy Development and Planmag Division 100 Kings Street 450 Capitol Avenue-MS 52ERN Gettysburg,PA 17325

. P.O. Box 341441 Hartford, CT 061341441 Don Beckman 1071 State, Route 136 First Selectmen Belle Vernon, PA 15012 Town of Waterford Hsu ofRaciuds 200 Benon. Post Road WaeesAmt, CT06385

o e,-

l ATTACHMENT 2

.l Little Harbor Consultants,Inc.

Millstone -ITPOP Project Omce P.O. Box 0630 Niantic, Connecticut 06357-0630 Telephone 860 447-1791, cut $966 Faz 860-444-5758 November 14,1997 Docket Nos 50-245 50-336 50-423 ITPOP 97-0048 Mr. Bruce Kenyon President and Chief Executive Of5cer Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06355-0128

Subject:

Independent Investigation of Allegations of Retaliation

Dear Mr. Kenyon:

I During the November 13,1997 meeting with Little Harbor Consultants, Inc. (LHC), NR!

NNECo, LHC provided the conclusions of our investigation into the allegations ofretali connection with the Training oiscipline announced by NNECo on July 23,1997 and NNECo's handling of the disciplinary actions.

Transmitted herewith is the LHC final report documenting our investigation and conclusions. In accordance with our Oversight Plan, copies of this report are being provided to our standard f

distribution list.

Please do not hesitate to contact me at 860-444-5626 should you have any questions or need additionalinformation.

Very truly yours, (fohn W. Beck ~

Team Leader,ITPOP President, Little Harbor Consultants, Inc.

Attachments (3) cc: Distribution a

e l

l ITPOP 97-0048, Page 2 November 14,1997 1

Distribution:

D.M. Godel, NNECo Charles Brinkman, Manager Washington Nuclear Operations p, %* m ABB Cosalmesma F=pm Nuclear Power K. M. McBrien, NNECo 12300 Twinbrook Pkwy, Suite 330 2W2 W, J. Temple, NNECo S. Baranska, NNECo Mr. John Bdingk===

Department of Public Utility Control M. Quinn, ECOP Electric Unit 10 Liberty Square U.S. Nuclear Regulatory Commission New Britain, CT 06051 Atta: Document Control Desk Washington, DC 20555 Citizens Regulatory Commission ATTN: Ms. Susan Peny Luxton l

U.S.NuclearR AyCommission 180 Great Neck Road Atta: W.D. Travers Waterford,CT 06385 Mail Stop: 014D4 Washington, DC 20555-0001 Citizens Awareness Network 54 Old Turnpike Road U.S. Nuclear Regulatory Commission Haddam,CT 06438

' Atta: P.F. McKee Mail Stop:014D4 The Honorable Terry Concannon Washington, DC 20555 0001 Nuclear Energy Advisory Council legislative Office Building U.S. Nuclear Regulatory Commission Hartford, CT 06106 Atta: H.N. Pastis Mail Stop:Ol4D4 Mr. Evan W. Woollacott Washington, DC 20555-0001 Co-Chair Nuclear Energy Advisory Council Mr. Wayne D. Lanning 128 Terry's Plain Road Deputy Director ofInspections Simsbury, CT 06070 Special Projects OHice 475 AllendaleRoad Ernest C. Hadley, Esquire King of Prussia,PA 194061415 1040 B Main Street P.O. Box 549 KevinT. A.McCarthy, Director West Wareham,MA 02576 Monitoring and Radiation Division Departm:nt of Environmental Protection Mr. PaulChoiniere 79 Elm Street "The Day" Hartford, CT 06106-5127 47 Eugene O'Neill Drive New London, CT 06320

' Allan Johanson, Assistant Director 055cc of Policy and Management BobDeFayette Pohey Development and Planning Division 100 Kings Street 450 Capnol Avenue-MS 52ERN Gettysburg,PA 17325 P.O. Box 341441 Hartford, CT 06134-1441 Don Beckman 1071 State, Route 136 i First Wenen Belle Vernon,PA 15012 Town of Waterford

- Hallof Records 200 Boston Post Roso Waterford, CT 06335 -

I

?.-

a ITPOP 97-0048, Page 3 November 14,1997 INDEPENDENT INVESTIGATION OF ALLEGATIONS OF RETALIATION AGAINST MICHAEL B. BROWN AND

' THE HANDLING OF THE TRAINING DISCIPLINARY ACTION

' Little Harbor Consultants (LHC) has conducted an independent investigation into allegations that discipline taken on July 23,1997 against Michael B. Brown, by Northeast Nuclear Energy Company (NNECo) was in retaliation for his involvement in legally protected activities. Brown, Director, Analysis and Programs in the Nuclear Oversight organization, until July 23,1997, was given 90 days to fmd a new position within Northeast Utilities or leave the company. NNECo agrees tha it disciplined Brown, but asserts it was unrelated to any of Brown's activities in his Oversight role, but was based on the information developed about problems within the Training Department. Brown asserts that his inclusion in the discipline was a result of his activities in his Oversight job. Brown alleges that some of the officers at Millstone viewed Brown as being an obstacle to restart of Millstone units, that these officers were "out to get Brown," and that the Training discipline was simply a ruse. The LHC investigation was limited to NNECo's motivation in QJeg Brown and did not inquire into the appropriateness ofthe actual discipline meted out to Mr. Brown or any o other 21 NNECo employees also disciplined, nor into the appropriateness of NNECo's reconsideration of any of those disciplinary actions. In conducting the investigation, LHC has interviewed 14 people, reviewed numerous documents and re-contacted many witnesses more th once to verify information. The conclusions presented in this report are the consensus opinion those LHC team members involved.

EXECUTIVE

SUMMARY

It is the consensus of LHC that the July 23,1997, disciplinary action taken against Michael B. Brown was not in retaliation for his involvement in legally protected activities.

It is also the consensus of LHC that NNECo:

(a)

Did not effectively anticipate and plan the disciplinary actions to avoid or minimize any " chilling effect" that could have resulted from the perception that the terminatio of Brown was retaliatory; (b)

Did not conduct an adequate investigation of" chilling effect" once retaliation was alleged, or take timely action to mitigate the " chilling effect" identified by employees; and (c)

Did not respond effectively to allegations of retaliation.

3

. ITPOP 97-0048, Page 4 November 14,1997 I

FINDINGS OF INVESTIGATION The following background information was derived from a series ofinterviews, extending

- over a five-week period, with participants in the process that resulted in the discipline annam July 23,1997, and review of pertinent documents. In most cases, two persons from LHC present for each interview. Inte viewers' notes of the interviews were subsequently the interviewees for accuracy, and often resulted in an extension of the initial interview.

ATTACHMENT A is a list ofthose who were interviewed. ATTACHMENT B is a References to notes ofinterviews include the name of the interviewee and, where reviewed appropriate, the paragraph in the notes containing the pertinent information, e.g., (Smi information can be linked to specific interviews, it has been done. ATTACHMENT C is a matrix showing principal meetings leading up to the final discipline and includes those in atten L meeting based on information obtained in interviews. The principal factual findings of investigation are as follows:

Mike Brown served as Director, Nuclear Training at Millstone from December 1993 until 1.

January 1996. When Brown took over the Training organization in 1993 its perform been very poor; candidates for NRC licenses had failed examinations in 1991 and INPO had placed NNECo's accredited training programs on probation. By June 1994, B had been successful in gaining re-accreditation ofthe training programs by INPO and by 1 had established the Millstone Training Program as one of the best in the industry. This was evidenced by excellent performance on examinations for NRC licenses by Millstone operato candidates and by INPO directing utilities to Millstone to see how a successful training program should be run. During this time period Brown hosted industry meetings interest from utility trainers from U.S. and foreign utilities. (Attachment B, Reference 26)

In January 1996, Brown was asked by NNECo management to leave Training and take 2.

senior position in the Oversight organization. In September 1996, Oversight was re and Brown became Director, Surveillance. Brown reported to David Goebel, Vice President, Oversight. In January 1997, he was movcd to Director, Analysis and Programs. As a D in the Oversight organization, Brown was responsible for reviewing the performance of Millstone units with respect to compliance with rules, regulations and procedures. A specific responsibility of his position in the Oversight organization included identification of s issues.

Brown's approach to his responsibilities was frequently described as confrontatio 3.

. created friction with line management. Those interdewed also stated that this friction was

(

caused not by what Brown was saying but by the way he presented his findings. Brown was never reprimanded or disciplined for his style. Brown agrees his style was irritating to som and could have been considered offensive to others.

ITPOP 97-0048, Page 5

. November 14,1997 During his tenure in Oversight, Brown had a number of high profile "run-ins" with senior 4.

managers at Millstone. Notable confrontations referenced by Brown were: a) the Unit 1

)

50.54(f) review that resuhed in Unit 1 going from the lead plant for startup to the last in line f for restart, b) his view that the Unit 3 50.54(f) review process was seriously flawed, c) his Independent Review Team review of the June 1997 Unit 3_ operator training class record which, he claimed, contained " material false statements," and d) his monthly reports, which, he asserted, often made the Recovery Officers " livid". (Brown I, M 1, 6-9,11,13,14)

Brown also. stated that he was told by Mike Brothers on three separate occasions that he 5.

should " ease up, you have a target on your back"; by Frank Rothen in April and June 1997 that "the officers don't like you"; by Joe Solymossy (INPO) in July 1997 that "Thayer is out to get you"; and by Dave Goebel that "the officers don't like you and are out to get you."

(Brown IM 1, 6-9,11,13,14)

. In December 1996, Millstone certified seven Unit I operators as ready for licensing by 6.

NRC as either Reactor Operators (RO) or Senior Reactor Operator (SRO). Six of the seven candidates failed the license examination.

Upon notification of the failure of six of the seven candidates who took the NRC RO an 7.

SRO examinations on December 2-6,1996, NNECo began an inquiry to determine the cause of the failures. The first examination was by an Independent Review Team (IRT) which completed its report on February 13,1997. When that IRT began to develop information suggesting that problems in the Training Department extended beyond just the Unit I cla a second, broader audit, extendmg back to 1992, was undertaken for all Millstone units and Connecticut Yankee. T',is audit was performed under the direction ofMike Ross, a member of the Training organization and a former licensed Senior Reactor Operator at Millstone.

Normally, Brown would have been involved in the IRT and in any subsequent examination as part ofhis Oversight responsibilities. However, given his previousinvolvement in Train he and Jay Thayer, Vice President, Nuclear Engineering and Support, to whom the Training organization reported, agreed that Brown should recuse himself. As a result, Thayer was responsible for the IRT and the overall direction of the Ross audit. At about the same time i.e., by about mid February 1997, NNECo notified the NRC of the preliminary indications stemming from its audit. Concurrently, and in anticipation of potential regulatory consequences, NNECo commissioned a third investigation, conducted by'outside counsel, t examine NNECo's potential regulatory and criminalliability. This investigation was closely coordinated with the Ross factual audit. (Attachment B, References 1, 2,13; Ross M 2-6; Thebaud M 2,3; Thayer M 3,4)

Brown argues that the Ross audit was hollow at best and that it only identified information 8.'

that was already known and in fact "was being corrected." Brown also contends that the lawyers' investigation was biased against him.

By approximately June 10, the following preliminary conclusions had been reached by those 9.

responsible for the investigations:

a

- ITPOP 97-0048, Page 6

- November 14,1997 The difficulties in the Training Department that had been uncovered in the (a) investigation of the December 1996 examination failures were pervasive, and had existed since at least 1992-93; (b)

The problems included submission to the NRC of records containing inaccurate or

' incomplete information; The fact that inaccurate information had been submitted under oath to the NR 1

(c) implicated NNECo's management controls, and also created a potentiallegalliability for NNECo under federallaw.

In addition, a preliminary decision was also reached that disciplinary action would have to be taken because the operator license failures had occurred under the present NNECo management team. In other words, there were present effects of past misconduct and thus such misconduct was not exempted by NNECo President Bruce Kenyon's policy of not punishing " historical allegations" (Garfield, Grise, Kenyon, Ross, Thayer, Thebaud interviews)

In June 1997, a disciplinary review process began which led, about six weeks later, to a final 10.

decision on discipline, The discipline ranged from letters ofreprimand to outright dismissal for 22 NNECo employees at all levels who had been in the Training Department during the period when the events at issue occurred beginning in 1992. Ultimately the decision proc involved an ever-wider circle of officers and other high-level management personnel within NNECo. The officers were presented the conclusions ofthe investigation and the Ross audit, and participated in the development of a consensus as to an appropriate response by NN The process included at least five major meetings among NNECo personnel and outside counsel, as well as several smaller meetings. This review process resulted in a consensus a a high degree of confidence by the participants in the overall soundness of the final disciplinary action decisions. Although Kenyon was the ultimate decision maker as to Brown, the officers reached agreement on all issues. (All interviews except Solymossy, Brown; Attachment C)

Anoroximatelv June 10: A meeting was held at the offices of Day, Berry & Howard, counsel 11.

to NNECo, to inform Cheryl Grise, Senior Vice President and Chief Administrative Officer, of the status of their investigation to date. At the meeting, Chuck Thebaud, one ofNNECo's outside counsel and principal investigator for the investigation, presented a matrix of discrepancies identified by the Ross audit. A discussion was held that involved discip employees who had submitted records that turned out to be incorrect regarding the qualifications of candidates for NRC examinations. The discussion did not include s'pe proposed discipline or segregating of anyone into categories of degrees of miscondu consideration of discipline. The scope of this discussion included some training supervisors but not Brown. During the discussion, Grise asked who was in charge ofTraining during the time period covered by the events.' She stated that she felt that the " Captain of the Ship" should also receive appropriate discipline. Grise says she was concerned thm (1) the results

-_..m..a

......_m.

y

. 1

-I

.s ITPOP 97-0048, Page 7 November 14,1997 of the matrix showed a pervasive problem, (2) she could not see how Training management could or should escape some responsibility, and (3) the decisions on discipline should be made by NNECo upper management, not by lawyers (Grise 13).

12.

On or =%t June 18: A meeting was held at NNECo headquarters in Berlin, involving Bruce Kenyon, President and CEO of NNECo, other members of senior management, and outside counsel. Thebaud again presented a review of the fmdings implicit in the matrix. Again.

Brown's name did not appear in the initial present6 tion, and again Grise raised the issue of the liability of the" Captain of the Ship." Grise wanted management to focus on the matter of discipline, and for whom. At that time, Brown's name was added to the list ofthose to be considered for discipline. Discussion also took place concerning potential discipline ofpersons senior to Mike Brown during his tenure as Director ofTraining. The discussion determined that all of Brown's Millstone " chain of command" during the period in question, with the exception of Ted Feigenbaum, had already retired, been separated or otherwise disciplined for other matters. (Brothers 15; Grise 15; Thayer 112a, 2b; Thebaud (11 6,7) 13.

Garfield-Kenyon Conver==* ion: Early in the meeting process, Gerald Garfield, outside counsel to NNECo, had a conversation with Kenyon. Kenyon, who was aware that Brown had antagonized the Recovery Officers in his Oversight role, wanted to be sure that there was no consideration of these factors in the Training Department discipline. Kenyon specifically directed that the consideration of discipline for Brown was to be limited to Brown's leadership of the Training Department. Kenyon also told Garfield that he thought Brown would have to be held accountable as " Captain of the Ship." Garfield understood that Kenyon wanted this instruction communicated to those involved in the decision-making process, and he did so. (Kenyon13; Garfield 16) 14.

Julv i 5. 7 am and 10 am: The purpose of these meetings was for Jay Thayer to present and discuss his proposal for discipline to Kenyon and " Buzz" Carns, Millstone, Chief Nuclear Officer Thayer wanted to be sure that the proposed discipline was sound; that it was consistent with other discipline meted out within the nuclear organization in the past; and that it was consistent with discipline taken elsewhere in NNECo.

Thayer came into the July 15 meeting with a list of persons to be disciplined and recommendations based on relative degrees ofinvolvement. He had concluded, at least preliminarily, that the discipline should involve termination of 7 or 8 employees, including Brown. There was a discussion of Brown. Kenyon believed that Brown, as" Captain ofthe Ship" in Training. would have to be disciplined commensurately with his subordinates, on general principles of accountability. But Kenyon also wanted a better explanation of what standards had been violated and by whom. Kenyon asked a lot of questions and was troubled about the possibility of having to discipline Brown given his importance to the Oversight organization and Kenyon's previously stated policy of not disciplining persons involved in matters that were of only historical relevance. Kenyon stated that he wanted any discipline i

to be based w Brown's actions rather than simply his having been in charge; Kenyon also j

believed that Brown was generally aware of the status of the Training Department while he j

i i

ITPOP 97-0048, Page 8 -

' November 14,1997 was in charge. There was some discussion of why Brown was the most senior person slated for potential discipline. As ex'plained to Kenyon by Thayer, all persons senior to Brown at Millstone at the time of the events in question had either retired, been terminated, or been already demoted for other reasons. By the end of the meeting, Kenyon and Carns had provisionally accepted Thayer's recommendation to terminate 7 or 8 people, including Brown. (Kenyon M 2, 7; Thebaud M 9,10; Thayer M 2,3; Ross 1 14)

Jpiv 1711:30 nm ud 5:00 nm: The purpose of these meetings was to bring the Recovery 15.

Officers in on the provisional discipline decision, given its potentially widespread effe' cts. The initial presentation, which included recommendations for 7 or 8 terminations, was appa made without using names. The officers wanted to know the names of the people and Kenyon agreed that as officers of the company they should know the names When the na were revealed, it was the first time that Goebel, McElwain 'and the other Recovery Officers became aware Brown was among those recommended for termination. No one discussed Brown's current role or performance in Oversight. Goebel asked questions concerning:

retroactive fairness, i.e., is the discipline contemplated greater than would have been impose in the past? and NNECo's prospective policy, i.e., is NU willing to live up to this standa in the future? Goebel was concerned for all 22 people, not just Brown. The discussion at the meeting focused on Goebel's policy issues, and Brown was not a major issue of discussio The Recovery Officers were mainly concemed that losing the terminated people would im their ability to meet restart schedules, but ultimately accepted the recommendations. W no one voiced disagreement with the proposed actions, apparently, the rationale for the proposed actions was not totally clear and some officers did not think that the issues fully aired. Thebaud was asked to prepare a " severity ranking" of offenses and to lin individuals and appropriate levels of discipline to each. A meeting was set for the next day.

(Bowhng15; Goebel M 4,5; McElwain 13; Thebaud M i1,14; Attachment B, Reference July 18 Another officers' meeting was held. Thebaud produced a table ranking 11 types of 16.

violations. He also provided a grouping of the individual offenses under each type of Thayer started the meeting with his recommendation, which remained the violation.

termination of 7 or 8 people, including Brown. Brown was included for failing "to provide oversight, which either results in, or substantially contr%tes to, a subordinates failure to satisfy minimal expectations." After much discussion, all in attendance agreed to the recommended discipline. (Thebaud 115; Bowling 16, Goebel 15, McElwain 13; Attachment B, Reference 6)

- July 19-20: Over the weekend, Thayer, who had been responsible for making discipline 17.

recommendations, took the entire set of discipline files home with him, reviewed them, and concluded that the overall level of discipline proposed was too severe. He was particularly concerned about the possibility that some training personnel who had already been discip for their involvement in the Unit 1 failures might be subject to doublejeopardy for the same off' nsesc When he arrived at Millstone on Monday, July 21, he told Carris and Kenyon that e

he wanted to reconsider the discipline issues yet one more time. Accordingly, a final meeting was set for the next day. (Kenyon 16; Thayer g 2e,11)

i p

[

ITPOP 97-0048, Page 9 November 14,1997 '

July 22: A fmal meeting was held which lasted nearly three hours. Kenyon opened the 18.

meeting by asking Thayer to explain his change of position. Thayer explained the re-evaluation he had conducted over the weekend and his conclusion that the proposed discipline was too severe. He now recommended that the disciplines all be reduced "one notch." Thayer did not have a specific name by name recommendation and made no recommendation for discipline for Brown. The proposed relaxation of disciplines was not aempuble to Kenyon, since it would result in some of those who had committed errors receiving no discipline.

Kenyon directed Thayer to develop a specific set of recommendations for discipline. W Thayer was developing these reconunendations, the officers discussed concerns rais (1) NNECo's willingness to abide in the future by what was Goebelin previous meetings:

clearly an important precedent in terms of accountability, and (2) concern for consisten fairness for involved individuals. After some time, Thayer presented his recommendations which included reduced discipline for many individuals. His proposal did not include a recommendation for Brown. Kenyon asked each officer to provide his recommendation on whether Kenyon should accept the original, harsher discipline or the proposed reduced discipline. Thayer and Carns supported the reduced discipline and most others suppo origmal proposal. Kenyon stated, as he had in previous meetings, that he wanted th i

all officers, and hoped that they would agree with the fmal decision, but that the decision was ultimately his alone. Kenyon decided to accept the reduced discipline as recommended Thayer. Kenyon then advised the group he had decided to remove Brown from his po and issue him a 90-dayletter.

According to those interviewed, no one suggested willful violations or other deliberate 19.

misfeasance on Brown's part. However there was a consensus that his failure to monitor events in the Training organization had predictably led to violations of regulatory requirements. No one raised any arguments based on Brown's conduct of his curre Oversight. Brown's anticipated negative reaction to the proposed discipline was also discussed. However, the decision made was not altered by the recognition of how Brown would react to the decision. The idea of a 90-day leter was considered appropriate. It was believed by Kenyon and the officers that demoting Brown to a non-supervisory post woul be more severe and humiliating for him than for any of the other 21 individuals. The decision to issue a 90-day letter instead of termination was seen as a recognition of 25 years of valuable work and as an opportunity to provide Brown with a fresh start in another part of the company. (It had been used before in the discipline of other senior people, including Brown's successor in Training.) At the conclusion of this meeting, all present agreed with Kenyon's decision to implement the proposed reduced discipline for all involved as recommended by Thayer. (Bowling 17; Brothers 15; Garfield j 10; Goebel 1 10; Gorski 1110,11; Kenyon M 6-9; McElwain15; Thayer121; Thebaud M 17,18; Attachment B, Reference 16)

' None ofthe discussions summarized above addressed the potential for " chilling effect" among 20.

the Oversight and Training organizations, or the perception that employees would believe

' Brown's oversight activities had led to his inclusion in the discipline.

ITPOP 97-0048, Page 10 November 14,1997

- The discipline was roblicly announced on July 23. NNECo did not take adequate time to do 21.

all the appropriato staff work before announcing the discipline. Some of those disciplined reportedly found out about their punishments in the local press or by the grapevine. Some were supposed to be advised to by superiors who had no knowledge oftheir offenses. One person with a name similar to one of those to be disciplined was apparently notified by mistake. The announcement was excessively schedule-driven in an attempt to dispel rumors that were beginning to spread at Millstone concerning the discipline. (Goebel 110, Bowling 19; Solymossy19)

Almost immediately after the announcement, many employees, including Brown, complained 22.

that their discipline was unfair. Complaints went to NNECo, to LHC, and to the NRC.

Brown also complained that his discipline had been retaliatory Employees in Brown's Oversight organization also complained that the discipline of Brown was retaliatory.

The NRC promptly summoned top NNECo officials to a public meeting in NRC headquarters 23.

in Rockville, Maryland on July 31 to discuss what actions NNECo was taking to address the

" chilling effect" that was created as a result of the discipline announcement. At the mee NNECo denied any retaliatory action in connection with the discipline and committed to undertake an independent investigation ofthe fairness ofthe discipline. Kenyon also outlined actions being taken to determine whether there was any " chilling effect" as a result of the announcement of the discipline. (Attachment B, Reference 11)

Within the week, NNECo retained Admiral Kenneth Carr, former Chairman of the NRC, to 24.

undertake the inquiry into the discipline. (Attachment B, Reference 5)

Admiral Carr and a colleague interviewed all of those disciplined who wished to speak to 25.

them, including Brown, and also talked with numerous members of NNECo management involved in the decision making process. Their report, dated August 21,1997, found that the factual assumptions underlying the discipline were well founded and that the discipline me out bore reasonable relation to the facts. Carr recommended that NNECo, should it choose to do so, might wish to re-examine the files of seven ofthose disciplined. The report did not directly address the issue of retaliation. However, a supplemental report, dated October 1 1997, concluded that no retaliation had occurred. (Kenyon j 10; Attachment B, References 17, 27)

Following Admiral Carr's initial report, NNECo re-opened the files ofthe seven persons Carr 26.

had referred to, as well as the files of two other individuals who requested that their discipline be reviewed. As a resuh ofthis review, NNECo provided total relief for three persons, partial relief for four others, and no relief for two. Brown's discipline was not reconsidered.

(Attachment B, Reference 28)

ITPOP 97-0048, Page 11 Now. 4 14,1997 H

THE DECISION MAKING PROCESS Several features ofthe discipline decision-making process followed by NNECo emerge with great consistency in the interviews and documentation. These features illustrate the contex decisions that led to Brown's allegations of retaliation.

The NNECo disciplinary process was deliberate, not precipitous. -It took, all told, seven 1.

months to gather the data and fashion decisions concerning.the Training Department discipline. The final step, reaching a decision and developing a consensus for it, involv many NNECo executives attending several signi6 cant meetings and numerous smaller o over a period of six weeks. (Attachment C)

. The process included a broad spectrum of participants, including persons considering 2.

themselves friends and admirers of Brown's (e.g., Rothen, Brothers, Gorslo) as well as those whom Brown sees as being his detractors. In the end, all of them thought the process was fair, even though some of them might have desired a different result for Brown. (Brothers Gorski115; Rothen M 8,11)

Every person interviewed, who had taken an active part in the collective decision-mak 3.

process, said that they saw no evidence of retaliation against Brown for his. Oversig

. activities. (Garfield M 4, 6; Goebel,18; Kenyon 18; McElwain 1 10; Rothen 1 11; Thayer

- 15;Thebaud124)

Bruce Kenyon made it clear that decisions concerning Brown would be based only on his 4.

as Director, Nuclear Training, not on his current position or performance. Participants in the process were aware of this instruction and all evidence gathered by LHC indicated th complied with it. (Garfield M 6, 8; Goebel 14; Grise 16; Kenyon 13)

There was no discussion in any of the meetings of Brown's current tenure in Oversight nor 5.

any suggestion that any conflicts with the Recovery organization were appropriate for

' consideration in the Training discipline decision. (Bowling 1 13; Brothers 17; Goebel 17; GorskiM7,15;McElwain110;Rothen 11) 6.

~ Goebel raised the concern that Brown's current valuable performance in Oversight and his concern about the negative effect that the proposed discipline, not just of Brown, but of the other trainers, would have on the restart effort. (Goebel M 4,7; Gorski 16; Thayer 1 13).

Grise had raised the issue early in the process, and Kenyon agreed, that Brown faced 7.

- responsibility as " Captain of the Ship." However, Kenyon also asked if there was any

' evidence of active conduct on Brown's part that would have either tended to produce compliance or noncompliance with Training requirements, and insisted that the inquiry n stop with the simple fact that Brown had been in " charge" of Training during the time question. While the inquiry did not find evidence of deliberate and wdiful violation by Brow of requirements or of instructions by him to his organization that directly contravened

~

p u,

ITPOP 97-0048, Page 12

~

November 14,1997 requirements, it did fmd that he established an attitude that led to a disregard ofrequirements and impeded implementation of a fundamental building block, the Systematic Approach to Training. (Bowling 17; Gorski M 7, 21; Grise M 3, 4; Thebaud 1 10)

It was clear that the legal liability to which the violations of regulatory requirements in 8.

Training potentially subjected NNECo meant that problems discovered in the investigation could not be ignored even ifNNECo had wanted to. However, the discipline inquiry was not intended simply to stay ahead of other investigations by the NRC and the Department of Justice; it was meant to deal with serious violations of training standards, independent of other investigations. (Brothers 18; Grise 6;Thayer1 loc)

Concerns were raised about the apparent retroactivity of discipline and the possible 9.

unfairness of holding persons acting in another era to today's standards. However, it was clear that the failure of 6 students out of 7 in an examination during the current administration at NNECo made the Training issue a current one which could not be ignored. This is consistent with Kenyon's stated exception that where there are present effects of past misconduct, the conduct can be re-visited. (Bowling 18; Garfield 19; Gorski 1 16)

Concerns were expressed about the consistency of treatment of those being disciplined.

10.

Thayer was concerned about punishing some trainers twice. Goebel was concerned that NNECo be willing to apply in the future whatever standard it established in this instance.

(Goebel16; McElwain19)

All persons in the Training chain of command at the time ofinterest, not already separate 11.

from NNECo or already disciplined by demotion, were included within the discipline. (Grise 15; Ross115;Thayer16)

The disciplinary review process concerned 22 people. Although Brown was the most 12.

prominent, his discipline did not dominate the discussions.

Thayer was concerned about faimess in the process and in the results. Thayer moderated h 13.

own proposals for discipline after examining the proposed discipline on an overall, rather t an individual, basis. (Thayer 11;Thebaud j 16; Garfield 120a)

Whilt n is true that the "90-day letter" issued to Brown removed him from further 14.

supervisory responsibility in Oversight, it lefi him free to seek other positions, including tho at a supervisory level, in other organizations within Northeast Utilities. This discipline was a last-minute change for the initially proposed, harsher discipline of termination. It also was considered that demoting him to a non-supervisory post (the discipline being given to others of his perceived level of responsibility) would have been far more severe and humiliating fo him than for any of the other 21 individuals. A 90-day letter was seen as a recognition of 25 years of valuable work and as an opportunity to get a fresh start in another part of the company. It had been used at least three times previously in the discipline of other senior people, including Brown's successor in Training. Further, it was not issued perfunctorily.

ITPOP 97-0048, Page 13 Ncm..bs 14,1997 Gorski recommended Brown for a position in Human Resources (HR), and Randell, the Director of HR, interviewed Brown for the post. To date, no response to the interview has been given to Brown. (Brothers 15; Brown 111 15; Garfield 110, Goebel110; Gorski11 10 11;McElwain15;Thayer121)

Corhian as to the Pror**= followed by NNECo. The evidence reviewed indicated that NNECo followed a lengthy and deliberate process to determine responsibility for widespread violations of training requirements which carried potentially significant legal and regulatory consequences for NNECo. While there were several meetings held to discuss the actual was to be administered to the 22 individuals, these meetings were used by Kenyon to receive inp from his management team and to develop consensus with his decisions.on the discipline. Kenyo made the final decision on the discipline for the 22 individuals, including Brown. No evidence was found that the Training Department discipline was a screen to "get" Brown, nor was there any evidence to suggest that Brown was included because of his Oversight activities.

~IU LHC EXPECTATIONS In evaluating NNECo's performance and conduct in regard to this investigation, LHC j

established the following expectations:

Disciplinary actions should not be taken in retaliation for employees' engagemen 1.

activities.

NNECo should anticipate and take appropriate action to consider and mitigate the impac 2.

potential" chilling effect" that could result when discipline is announced, particular persons disciplined have been involved in protected activities.

If retaliation is alleged as a result of the discipline, NNECo should take immediate and 3.

adequate action to specifically respond to and investigate the allegations ofretaliatio NNECo should conduct an adequate investigation of" chilling effect" which might result from 4.

the discipline and take timely and appropriate action to mitigate the " chilling effect".

BROWN'S ALLEGATIONS OF RETALIATION AND THE FINDINGS OF IV LITTLE HARBORINQUIRY Brown bases his belief that disciplinary action taken against him was retaliatory on three principal arguments. First, Brown points out that he had achieved spectacular resu during his tenure, thus the asserted bases for his discipline are not legitimate. Second, the discipline was retaliation by the Recovery Officers for his activities in Oversight an his energetic and aggressive style as a Director in the Oversight organization. Brown ass he exposed many significant problems in work in preparing the Millstone units for op he believes that Kenyon was biased against him because of Brown's close connection with N

ITPOP 97-0048,' Pags 14 November 14,1997 Brown's first contention is that the basis for the disciplinary actions were essentially flawed because the audit and investigation was not accurate and relied on incorrect and incomplete information. He points out that he was never interviewed in connection with the Ross audit, and thus the information in the Ross audit does not contain the necessary facts and explanations to support the conclusions. He provided a number of examples ofinaccuracies in the Ross audit which support position that the information was simply inaccurate, and that it was he, not Ross, that identif of the weaknesses that are now being blamed on him, and that the problems resulted from poor

)

j management above him.

i l

LHC reviewed the Ross audit for background information, but did not undertake to redo the Ross audit or challenge its conclusions. That project was undertaken by Admiral Carr, who review the specific bases for the discipline, and recommended reconsideration in certain' instanc1 individual recommended discipline, but not for Brown. However, LHC did not pursue Brown's assertion that the information in support of his inclusion in the discipline was wrong. Unless Ross was proven to be part of a major conspiracy to build a case against Brown because of hi1 activities, inaccuracies would not be relevant to the decision making process that led to Brown I

discipline. LHC found no evidence of such a conspiracy.

Second, Brown's contention that his discipline was retaliatory is based on his belief that the Recovery Officers (Thayer, Bowling and McElwain) were angry with him for his aggressive j

of his duties in Oversight. Brown's contention is that the Recovery Officers regarded him as an impediment to restart and, wanted to "get rid of him" under color of legitimacy of the Tra discipline, and used this opportunity to do so. He supports these arguments by illustratio respect to any and sometimes all of the Recovery Officers. These examples are summa Warnina from Brothers: According to Brown, Mike Brothers, a long time friend ofBrown's, 1.

warned him three times that he "had a target on his back" at which the Recovery Officers were taking aim. Brothers agrees that he suggested to Brown more than once that he case up on his confrontational style, because he (Brown) was making himselfineffective. B says that he saw no evidence of retaliation against Brown in the discipline process. B that Brown's IRT report on Unit 3 Training was "too hostile". (Brothers 1 6,9,10, Brown I,11)

Warnina from Rother! According to Brown, Rothen repeatedly told him he was going to get 2.

into trouble because he offended the Recovery Officers. According to Rothen, he never tol Brown that the Recovety Officers were "out to get him", and does not think they were. He did suggest to Brown that he ease up because Brown was " burning his bridges." (Brow 11; Rothen 1110,11)

Warnino from Goebel: According to Brown, Goebel warned him that the Recovery Officers 3.

"didn't like him" and were out to get him. Goebel denies making this or any similar statement. Goebel said that Brown had annoyed a lot of people and that he had counseled Brown because ofhis personalizing his criticism Mthe Recovery Officers. He also stated that the irritation of the Recovery Officers toward Brown may have lessened their willingness to

ITPOP 97-0048, Page 15 November 14,1997 4

leap to his defense during the discussion on discipline, but did not play a factor in the recommendation for including him in the discipline (by Grise) or the final decision by Kenyon.

-(Brown I,118,14; Goebel18) 4.

Warnina about Thaver: According to Brown, Joe Solymossy ofINPO told him, "Thayer hates your ass and is going to get you." (Brown I,11) According to Solymossy, the relationship between Brown and Thayer was sometimes difficult because of the built-in institutional conflicts between Oversight and line management and because Brown, in his reports, had occasionally blind-sided Thayer (Solymossy117,11; Garfield 119) However, Solymossy denies making the statement attributed to him by Brown. (Solymossy 18).

Solymossy says that he had suggested to Brown, in what was intended as friendly advic he be less antagonistic, and that Brown not overdraw his " interpersonal bank account"

~

(Solymossy17).

Thayer agrees readily that he and Brown had professional disagreements, but denies any animus toward Brown or any intent to "get" him, and refutes Brown's assertions with respect to critical IRT reports (Thayer 15). Goebel also dismisses the claim that Thayer was "out to get Brown", saying that Thayer had "high values" and " reached hard to do right." (Go 18)

Bowhng Bias According to Brown, Bowling, Recovery Officer for Unit 2, also was "out 5.

to get" him. As evidence of this Brown points to Bowling's denial that he had anything to do with the disciplinary decision. Brown stated that Bowling told a number of Unit 2 staffers right after the discipline was announced that he had nothing to do with Mike Brown's discipline (Brown 1,13) Bowling denies being "out to get" Brown. He stated he had little to do with Brown before the actual discipline since Brown's repons were typically directed elsewhere. (Bowling 1 4,11 )

6.

Bowlina and IRT's: According to Brown, Bowling remarked to, a contractor working for the Oversight organization, on July 22 (the eve of the disdpline announcement), that "we've found a way to control the IRT's." (Brown 112) IRT reports are a means by which Oversight points out problems. Bowling agrees that he made the remark, but states that it was ma in reference to the issue ofbringing accountability for the assignments of responsibility which should flow from IRT's. As of July 22, he had just reached agreement with Goebel and the Nuclear Safety Assessment Board (NSAB) on a means of accomplishing this task. (Bowling 112; Attachment B, Reference 21)

Recovery O&ars and IRTs: According to Brown, the Recovery Officers were " livid" when 7.

his monthly reports from Oversight were issued (Brown 1, j 8), apparently for the vigor wi' which they reported the shortcomings of the Recovery organization. McElwain and Bowling deny they were " livid" at Brown. According to McElwain, Brown's monthly reports often contained unsubstantiated information that was not useful to him. (McElwain 16)

f, ITPOP 97-0048, Page 16

- November 14,1997 l

i 8.

Garfield Bias According to Brown, Garfield, one of NNECo's outside counsel, was "out to get" him in retaliation for testimony Brown had given in 1989 that was supportive ofPaul Brown's Blanch and highly critical of NNECo and Bernard Fox, NU's former CEO.

principal allegation derives from Garfield's relationship with Bernard Fox (Fox had been the Montague Project Manager in the 1970s and Garfield the licensing lawyer for the project).

Brown states that Garfield was Fox's attorney at the time of Brown's testimony. Sim f

Garfield assisted in the development of the discipline package, he believes that Garfield u as inDuenced by Brown's 1989 testimony in reaching a decision to discipline Brown. (Brown I,

12) Garfield says that Brown is simply wrong, and that he felt positively toward Bmwn.

Garfield notes that Fox was near retirement and had absolutely nothing to do with Brown's discipline. Garfield says he was a lot closer to Bob Busch than he had ever been to Fox; anj that Busch was a great fan of Brown's. Garfield never even met Brown until Busch's going-g away party. (Garfield 118)

Grise Bias' In a later irterview Brown made essentially the same charge as he had about 9.

Garfield, this time about Grise. He pointed out that she is a lawyer even though she works on the business side ofNU, and asserts that in 1989, when he made statements critical of Fox in connection with the Paul Blanch matter, Grise was acting as counsel for NNECo on employment-related cases. He believes that Grise acquired a bias against him at that tim Grise, when asked about this, stated that she had never been involved, either as counsel for NNECo or in her other work in the HR department, in representing matters involving Fox; nor, more specifically, had she ever been involved at all in any matter involving either Pau Blanch or Mike Brown. She also stated that she had transferred from the Legal Department to the HR Department at about the time that Brown was apparently referring to in 1989. She also observed that she had never known Brown personally unti! a couple of years ago, and that she had met him only because she had made a point ofintroducing herself to him after having heard Bob Busch praising Brown's ability. (Brown II,19; Grise,111)

10. -

Cactain of the Shio theory: Brown had been advised that Grise asked, early in the NNECo deliberation process, who was in charge of the Training Department during the period when the events disclosed by the Ross audit were occurring, and that she stated her view that the

" captain of the ship" ought to be liable. Brown stated initially that he believed she was "probably not biased" and that her question was a " logical" one, which Kenyon ther proceeded to use as a convenient pretext (Brown II,13). Later in the interview, however, he stated that he believes that Grise already knew at the time she asked her question that he

- was the Director of Training at the time of the events ofinterest, and suggested that her

. question was not a straight request for information but rather a step toward ensnaring h

-(Brown II,19). Grise, when asked about this, stated that she had, of course, known that Brown was a former Director ofTraining; that she affirmatively believed, and beheves, in the concept of accountability for the " captain of the ship;" but that as of mid-June she had not,.

in fact knownjust how Brown's tenure had coincided with the events being reported; and that she had no intent to inject Brown into jeopardy by asking her question (Grise 1 12).

ITPOP 97-0048, Page 17 November 14,1997 -

11.

. AIE A hd=' ant Analiatians of Discinlina: Brown contends that the discipline imposed on him is discriminatory, and thus retaliatory, in that heads oforganizations have not typically been held accountable on the mere principle that they were "in charge." He points to two recent events, the MOV event and the Unit 3 Spent Fuel Pool heat up event, to support his argument. Other NNECo persons involved in Brown's discipline do not agree with Brown's contention First, as for historical discipline of heads of organizations (or lack thereof), it was pointed out frequently that: (1) numerous top managers at Millstone have been dismissed in the past few years, to the extent that no one senior to Brown at the time of the Training situation had not already retired, been involuntarily separated from NNECo, or been severely disciplined already; (2) other recent managers have been held responsible for their areas' problems, including Brown's successor in Training; a Unit 1 Director (for Technical Specification violations); and the Connecticut Yankee Director (for a nitrogen intrusion event). NNECo management does not regard the recent Unit 3 Spent Fuel Pool heat-up event as being in the same category of seriousness as the Training issues. Finally, Brown's citation of the MOV issue as one involving managerial misfeasance which was overlooked, is based on a misunderstanding of the facts. (Brown I,117; Brown H,11 2b, 6; Brothers 15; Kenyon113,7, Finally, Brown's contends that Kenyon's real reason for including Brown in the discipline was 12.

because Kenyon was uncomfortable with Brown's close relationship with the NRC. Brown points to a wuw, sat made by Kenyon at an officers / directors meeting several weeks before the discipline was announced, in which Kenyon stated that "There is a Director in Oversight who is closer to the NRC than he is to his own utility." When Brown questioned Kenyon if that comment was about him, Kenyon did not directly confirm that, but stated that "a lot of people believe that you are very close to the NRC." Brown concluded that Kenyon had to be talking about him, and therefore concludes that when Kenyon made his decision about disciplining Brown that Kenyon was influenced by his concern about Brown's relationship to the NRC. Kenyon denies this in total. He does not recall making the comment attributed to him by Brown and states that he believes the Oversight organization should maintain close communication with the NRC. This close communication is necessary to help develop a level of confidence in the Oversight Organization by the NRC. Kenyon states that Browns relationship with the NRC had no bearing on his decision to discipline Brown.

V.

THE BASIC LEGAL TEST The principal determination to be made in a retaliation case lies in proving that the discriminatory act or acts, in this case the discipline of Brown, occurred because the employee engaged. in protected activities. Retaliatory motives can be established by either direct or

. circumstantial evidence, or by establishing that an action'is inherently discriminatory. The most common bases are established through analysis of a variety of circumstances which either do or do

. not give rise to a reasonable inference of discriminatory motive.

ITPOP 97-0048, Page 18 -

November 14,1997 The determination ofwhether retaliation was a factor in this case begins with a collection and verification'of relevant facts. Those facts collected and verified by LHC sre set forth above. Where there is a dispute about an event or incident, LHC has attempted to set forth those disagreements.

While not every detail of the events from December 1996 failures of the RO/SRO candidates to July

- 23,1997, when the Training discipline was announced, is included, LHC has set forth the facts relevant to its determination regarding the inclusion of Brown in the discipline.

LHC has approached its determination using the same analytical structure and guidelines to review the facts'as would be used by the United States Department of Labor in reaching a

)

determination under the Employee Protection Provision of the Atomic Energy Act, as amended. 42 USC 5851. LHC has not analyzed this issue under the laws of the State of Connecticut and makes l

no representation as to viability of Brown's arguments under the new State statute or common law

' theories.

1 The first determination that LHC made was to decide whether the discipline against Brown was, or appeared to be, inherently discriminatory. That is, was the action taken so blatantly discriminatory that no further inquiry was necessary, such as might be the case ifan employer directed

- that all employees who had been in contact with the NRC shoul6 be terminated. LHC cWM that i

Brown's discipline was not inherently discriminatory conduct by NNECo. In fact, given the seventy of the problems in the Training Department, failing to take action would have been irresponsible.

Second, LHC made a determination on whether there was direct evidence of retaliatory motives by the Recovery Officers. Direct evidence includes admissions by the party engaging in the alleged retaliatory conduct. nr other forms ofindisputable proof that the adverse action was taken because the employee engaged in protected activity. In this case, everyone involved in the disciplinary review process denies that there was any retaliation, and LHC found no direct evidence ofretaliation.

1 Therefore, since the adverse action was not inherently discriminatory, nor was there any direct evidence of retaliation, the facts must be analyzed to determine whether the presence of a retahatory motive is provable by circumstantial evidence. It is important to note that proving a case of retaliation through circumstantial evidence often requires reaching a determination contrary to witnesses who perceived a lack of such improper motive. Ellis Fischel State Cancer Hospital v.

Marshall,629 F.2d 563, 566 (8* Cir.1980), cert denied,450 U.S.1040 (1981).

According to one legal treatise on the subject of proof of retaliation, the following general categories of facts or circumstances are used to establish a reasonable inference of discriminatory motive:

l'.

Employer's hostile attitude toward the matter underlying the employee's protected conduct; 2.1

. Employer's knowledge of protected conduct; L-

3A,

The nature of the protected conduct;

ITPOP 97-0048, Page 19 November 14,1997 Special conditions of employment or disparate treatment, i.e., transfers, demotions, is 4,

following protected cor. duct leading to the discharge; Previous expressions ofsatisfaction with work record, and/or failure to record dissatisfactio 5.

with work record; 6.

Termination Procedure; 7.

Timing of Discharge in connection with protected activities; Threats of retaliation against other employees for similar conduct. American Jurisprudence 8.

(2"d), Proof ofFacts, " Proof of Retaliatory Terminat'on," Section 7-1.

In this case, LHC analyzed the facts and circumstances of the termination of Brown, on the premise that those involved in the discipline review process denied having taken th retaliation.' Thus, the circumstantial evidence had to be carefully analyzed, using the three-prong approach established by federal coun in analyzing discrimination cases, in order to determination as to the question of motive. The three-prong approach was established by th courts in analyzing discrimination cases, and is used by the DOL, in reaching its determin It sets forth the following three questions, McDonnellDouglas Corp. v. Green,411 US 792 (1973).

as appropriately described for this case :

Can Brown establish a primafacie case of retaliatory termination?

1.

Can NNECo identify a legitimate, non-discriminatory reason for the termination?

2.

Can NNECo demonstrate, by clear and convincing evidence, that the terminations of 3.

Brown would have occurred but for his engagement in protected activity?

There is also a subset of" pretext" cases that carries the analysis one step further: the so-ca

" mixed motive" cases. These apply to situations where the defendant employer su=ds in show that it acted out oflegitimate, non-retaliatory motives, but the plaintiff can demonstrates that illegitimate motives also played a role in the employer's decision. In these cases, the burden yet again to the employer, which must demonstrate that, notwithstanding the admixture illegitimate motive, it would have taken the action against the plaintiff for legitimate reason Price Waterhouse v. Hopkins,490 U.S. 228 (1989). "The existence of a good and bad reason f employer's action requires further inquiry into the role played by each motive " Ashcraft v ofCincinnati,83-ERA-7, at p.10 (Under Sec'y 11/1/84)(quoting Wright Line, A Divisio Line., Inc.,1980 CCH NLRB #17, 356 (1980), aff'd sub. nom., NLRB v. Wright Line, 662 F.2d (l" Cir.1981), cert. denied, 455 U.S. 989 (1982), approved by the Supreme Coun in NLR Transportation Management Corp.,103 S.Ct. 2469 (1983)). The ultimate question in these ca is always whether the bad motive can be extricated, and conclude that NNECo would neve have acted the same way.

ITPOP 97-0048, Page 20

~

November 14,1997 VL ANALYSIS AND CONCLUSIONS Did NNECo *^- dV" = v action me=3==* B...

h=" on his involve====8 in laeany 1.

and meM:M As set forth above, LHC has analyzed the question of whether retaliation was the basis for -

the discipline of Brown using the same standards as would be applied in a Department of Labo

- context. This requires an initial determination ofwhether Brown can establish aprimafacie case o retaliatory motive for the disciplinary actions taken against him. NNECo must then be able to pres evidence that the adverse action was motivated by a legitimate, nondiscriminatory reason Assuming -

both Brown and NNECo are able to meet their initial burdens, the primafacie test drops from the analysis and Brown bears the burden ofproving, by a preponderance ofthe evidence, that the action was taken against him because of his engagement in protected activity. If Brown can make

'such a demonstration, NNECo must be able to defeat Brown's evidence with clear and convincing proof that it would have taken the same action for their asserted legitimate reason alone.

A.

Can Brown *='ahliah a Prima Facie Case of Petaliation?

Yes.

Under the statute and implementing regulations, Brown has the burden of establishing an initialprimafacie case. This consists of demonstrating that (1) he was covered by the statute engaged in protected activity; (3) his employer took action adverse to him; and (4) his par in protected activity was at least a factor in that adverse action.

As an employee of an NRC licensee, he is covered by the statute. As a Director in the Oversight organization at Millstone, engaged in review and critiquing the safety-related work pr of the Recovery organization, including potential violations of the Atomic Energy Act or NRC regulations, he was unquestionably engaged in legally protected activity. His relief from duty receipt of a 90-day letter were unquestionably an adverse action taken by his employer.

As for the fourth element of a primafacie case, establishing that the adverse action against him resulted, at least in part, from his engaging in protected activity, Brown must rely on inference created by circumstantial evidence. The gist of Brown's argument is that his criticisms of the Recovery organization, while perhaps unnecessarily acerbic, were solidly grounded. Because th were solid, they thwarted the Recovery organization's premature actions toward startup, thus st animosity _ among those who had been properly criticized. His aggressive manner only made Recovery Officers more angry and eager to get rid of him according to Brown and the Training

-matter provided the perfect pretext. In addition, he points to the dissatisfaction about his contact

- with the NRC as raised by Kenyon.

ITPOP 97-0048, Page 21 November 14,1997

_. Brown's claims have plausibility. No one has suggested that Brown's observations and

_ findings in Oversight were inaccurate orincompetent. Moreover, the concernsidentified by Oversigh censinly would tend to have had a thwarting effect on the Recovery organization. There is also

' incontrovertible evidence of conflicts between Brown and Thayer stemming from some of Brown's reports and there is incontrovertible evidence that some of the Recovery officers felt personally.

attacked by Brown's reports to the point that Brown was wamed by several persons that his actions were antagonizing the Recovery Officers.

~ lt is not necessary to have direct evidence of animus in order to infer a connection between Brown's pursuit of his' Oversight work (the protected activity) and the imposition of Training.

discipline against him (adverse action). It is permissible to infer retaliation from circumstantial evidence. The most common basis is proximity in time between the offending protected conduct and the adverse action. While Brown's training conduct occurred years ago, he was a daily " thorn in the side" of the Recovery organization, even as the discipline was being developed. On this basis, it is possible to infer a potential causal relationship between his Oversight work and the adverse ac against him.

In short, Brown can establish a primafacie case. At this point the burden shifts back to NNECo.

Can NNECo demaisiate a la hee be=== ramaan for the ar*ian==minst Brown?

B.

Yes.

NNECo can establish a legitimate business reason for disciplining Brown. NNECo's disciplinary actions against employees in the Training organization, under Brown's leadership, we based en facts supporting that Brown's department engaged in a policy over several years of giving insufficient attention to day-to-day NNECo and regulatory training requirements. The failure of 6 of 7 candidates during the December 1996 NRC examination exposed a serious problem for NNECo, extending over several years of noncompliance with its own rules, and has triggered significant potential liability for NNECo 'to the NRC. The failures also brought to the attention of current management the consequences of historical programmatic failures. In addition, as a result ofthe NRC and Department of Justice investigations of the problems, NNECo had little room to excuse misconduct or ignore accountability. The importance of reaching a sound result in their actions was clearly articulated.

In short, NNECo has compelling legitimate business reasons for having taken the actions it did against Brown'and the 21 other individuals disciplined for' the problems in the Training Department..

.... LHC does not attempt in this report to review the factual basis for the Training discipline and it is legally insignificant, because even if NNECo was wrong it is entitled to make a good faith mistake in judgment without risking a finding of wrongful discipline.

r A

.., t ITPOP 97-0048, Page 22 November 14,1997 Can NNECo ****.E:h by clear and convincine evidance that it would have take the C.

= =.2 met nn a d :: Brown in the abaance of his orotacted activities?

i Yes.

In this case there are both a legitimate explanation for the adverse action, i.e., the company's position regarding the training department failures under Brown's leadership, and an illegitimate explanation, i.e., that the true reason for Brown's inclusion in the discipline was a or scheme to get rid of him because of his aggressive protected activities in Oversight and hi connection to the NRCf Both of these hypotheses were fully explored with Brown and the deci makers, in an effort to detennine the true motive behind the adverse action complained of. LH unable to conclude that the actions against Brown were motivated by retaliation for his aggres activities in the Oversight role he was playing at the time the decision was made. Nor did L any evidence that there was any scheme by the Recovery Officers and/or executives t

in the Training discipline because of his protected activities. In other words, LHC conclude NNECo would have taken the same action against Brown even if no improper motive for his pr protected activities existed.

NNECo has consistently maintained that it disciplined Brown for his failure to "to provide oversight, which either results in, or substantially contributes to, a subordinate's failure minimal expectations." Brown does not believe this. It is true that Brown's arguments, a circumstantial evidence he offers in support of those arguments, are strong, but they are not strong enough. Without over simplifying the process that led to Brown's discipline, the facts a NNECo took months to gather and review information leading to the discipline of 22 people.

Kenyon, recognizing that an opportunity existed for the Recovery Officers to punish B present protected activities, instructed that no consideration of present conduct be reaching the final decision. Ultimately, although consensus was reached in support of decisions of the Training Department personnel, Kenyon alone made the decision on disciplini Brown. LHC interviewed Kenyon three times to probe the explanation and rationale for includin Brown in the discipline. LHC found no discrepancies or inconsistencies in Kenyon's explanatio nor any contradictory documents or testimony. LHC is not aware ofthe existence ofany docu or evidence not included in our review. Thus, LHC believes that Kenyon made a difficult decisio to discipline Brown on the basis of the Training Department information and would have same decision even if Brown was not regarded as having a close relationship with the NRC or h engaged in legally protected activities. Thus, LHC concludes that Kenyon's decision w in retaliation to or punishment of Brown, but rather was made as a legitimate business decisi would have been made anyway.

In reaching this conclusion LHClooked at the objective and subjective circumstantial ev

off'ered by Brown in support of his belief that the actions were retahatory and the object offered by NNECo.. While NNECo officials uniformly denied having any retaliatory moti attempted to collect all relevant documentary evidence of contemporaneous events as behind the general denials ofimproper motives by the decision makers. In doing so, LHC firs concludes that NNECo had no choice but to take appropriate disciplinary action of responsible

IT' POP 97-0048, Page 23 November 14,1997

'~~

individuals as a result of the findings of the NRC, its own internal reviews, and the failure of the RO/SRO candidates. This decision, while not implemented well on a variety ofievels, nonetheless -

was alegitimate action.

Having decided that some discipline was necessary, NNECo than advanced through a process

' by which it made the decisions of what action or discipline was appropriate for which individuals.

This process may be fairly criticized as cumbersome. It certainly may not have afforded "due process" to all the disciplined individuals, and was not regarded as " fair." However, Brown's complaints of retaliation do not stem from these programmatic weaknesses. He suggests a much more sinister hypothesis, i.e., the decision to include him in the discipline for alleged historical shoncomings in the Training Department was an opponunity to get rid of him in his present Oversight job because of his present protected activities.

His argument turns on whether there is evidence that would establish that the reason for his inclusion in the adverse action was his Oversight activities and/or his " closeness" to the NRC. L. C H

finds none. Instead, all of the evidence points to the opposite conclusion. The decision to include Brown in the discipline was generally regarded as an impediment to startup, and a loss to the organization. In addition, the decision to include Brown was also difficult because ofthe recognition that Brown would be likely to' publicly attack NNECo for the decision to include him.

The facts are that Brown's inclusion in the Training discipline was initiated by Cheryl Grise, and agreed to by Kenyon, on her insistence that Brown should be included as the " Captain of the Ship." Grise is not part of the Recovery organization, does not work with Brown, has not had any historic association with him, and is not in a position to have her work impeded by Brown. Her recommendation can not plausibly be attributed to Brown's work in Oversight. Thayer did not include Brown in either his initial matrix or his second matrix of proposed discipline. Grise twice insisted that would send the wrong message, and argued that Brown had to be included. Moreover, Goebel and Rothen were concerned that Brown's removal from his present responsibilities would delay recovery efforts and openly discussed this concern. Neither Bowling nor McElwain voiced any ill will toward Brown during the process. In fact, Brown had many supporters among the management team who, notwithstanding his occasional abrasive behavior, believed that he was performing an important role in the oversight arena.

Brown's evidence that 1) he was' wamed before the Training decision that he should choose a less offensive approach and style in his job, and 2) that the actions themselves are unjustified because of his previous good record in Training, do not establish a retaliatory motive. First, while there are some differences of recollection about the " threats," the facts are that these warnings were all lodged before any of the decision makers learned that Brown had been included in the disciplinary actions slated for the Training department. Brothers and Rothen considered themselves personal hiends of Brown. Their intentions were not to warn Brown that he was going to be disciplined for the Training Department problems, but rather to provide him " friendly advice" on his approach to i

delivering findings in the Oversight Department. None of the persons who are alleged to have delivered the " threats, : were involved in the decision to initiate an independent investigation of the J

ITPOP 97-0048, Page 24 Now.ser 14,1997

~

Training Dep t... eat or to evaluate Brown's role. There was no consideration ofBrown's present activities during the review process considermg the discipline.

Further, the proposed discipline for Brown was actually lowered during the process from termination to receiving a 90-day letter, offering him the opportunity to find another position within Nonheast Utilities in recognition for his 25 years of service to the company and in an attempt to keep a valued employee in Northeast Utilities.-

Additionally, Kenyon had made his expectations crystal clear on the point that Brown was to be considered for disciplinary action only. in connection with Brown's involvement in the programmatic failures of the Training depanment under his tenure. There is no evidence that his Oversight functions were considered or discussed in violation ofthis expectation. Finally, the decision to discipline Brown was ultimately made by Kenyon, who insisted that the decision about Brown be based solely on the findings of the Training investigation.

In shon, having fully reviewed all" leads" and evidence available, LHC concludes that Brown would have been terminated or disciplined even m the absence ofhis Oversight Activities.

Notwithstanding this conclusion, it should be noted that Brown's belief that the actions against him were retalistory is understandable under the circumstances These are suiroT.i !w! below because Brown's suspicions about retaliation against him and fundamental unfairness were shared by many others in the Oversight organization, and contributed to the " chilling effect" caused by his termination.

Brown, of course, did not have the benefit of the detailed information gathered by LHC and j

included in this repon. Thus, the warnings to Brown by Brothers and others, coupled with the attitude displayed to him by the Recovery Officers in response to his findings, and the departure of the Training Depanment discipline from previous practices and stated present policy at Millstone, contribute heavily to conclusions drawn by Brown and others that this was em opportunity to get rid of Brown. These perceptions and conclusions were neither anticipated, mitigated, or addressed adequately by NNECo management in preparing for or addressing this event.

2.

Did NNECo effectively elan the discieH==ry actMes to avoid or minimize any "chilline effect"?

No.

NNECo scarcely thought about " chilling effect" and did not anticipate it in its deliberations

- (Garfield 112). It was given rudimentary consideration in some of the officers' decisional meetings, when the effect of widespread discipline o3 morale within the Training Department was considered (Brothers ) 8), but it was not dealt with more systematically. The implementation of the disciplinary announcements was not carefully thought through to ensure accuracy or confidentiality. The discipline was announced on July 23, only one day after the final meeting. NNECo did not take the time to do all the necessary staffwork. Some of those disciplined apparently found out about their

~ ITPOP 97-0048, Page 25

-Nc m.la 14,1997-punishments in the local press or by the grapevine Some were supposed to be talked to by superiors who had no knowledge of their offenses (Bowling 19). One person with a name similar to one of those to be disciplined was apparently notified by mistake (Solymossy 19). The announcement was -

probably excessively schedule-driven (Goebel1 10).

The result was predictable. Almost immediately, a large number of those disciplined, including Brown, complained that their discipline was unfair, Complaints went to NNECo, to LHC, and to the NRC. Brown, in particular, complained that his discipline had been retaliatory.

3.

Did NNECo resnond effectively to allenations of r+ =!!*?

No.

NNECo stated that they would conduct an independent investigation of the allegations of retaliation; however, there is no evidence that an appropriate and effective investigation was conducted.

Following the announcement of the discipline on July 23, allegations were made to ECP, NRC and LHC that the discipline given to Brown was in retaliation for activities while a Director in the Oversight organization, not because of his role in the Training organization. Concerns were also filed with ECP and NRC that the discipline had created a substantial" chilling effect" at Millstone especially in the Training organization and in Oversight. The NRC summoned NNECo to its Rockville headquarters on July 31 to discuss what action NNECo was taking to mitigate this " chillin effect". At this meeting Bruce Kenyon stated that ECP inspectors were actively working to determine the extent of the " chilling effect" He also stated that he was going to retain an independent third party to investigate NNECo's decisions as to the appropriateness of the discipl and to investigate the allegations that retaliation was a factor in the disciplinary actions taken.

(Attachment B, Reference 11)

NNECo retained the services of retired Admiral, and former NRC Chairman, Kenneth M.

Carr to conduct the independent investigation that Kenyon had discussed in the July 31 meeting with the NRC. The protocol provided by NNECo to Carr governing his independent assessment of the Training discipline specified that he: (1) review the information and decision-making process relied upon by management in imposing the discipline and assess whether that information provided a reasonable and proper basis for the discipline imposed; and (2) review any additional information.

disciplined employees may want to provide to Carr. There is no mention of an investigation of the allegations of retaliation in the protocol provided to Carr. (Attachment B, Reference 5)

During Carr's investigation he interviewed Brown and, according to Brown, would not listen to Brown's claims that his discipline was associated with his role in Oversight. Again, according to Brown, Carr only wanted to talk about Brown's role in the Training organization. Carr_ also interviewed Cheryl Grise, Senior Vice President, who stated that Carr never asked her about retaliation against Brown or anyone else; she volunteered to Carr that she had seen no evidence of retaliatory motivation in connection with the discipline process. (Brown I 15; Grise 1 10)

. ITPOP 97-0048, Page 26 Nc u..:,er14,1997 Carr's brief report, issued on August 6,1997, made no mention of any findings regarding.

retaliation. Garfield stated that Carr told him and Kenyon that he had seen no evidence ofretaliation during his investigation. Carr was subsequently requested to supplement his report to address his findings with respect to the retaliation issue, which he did on October 13,1997, stating that he foun no evidence ofretaliation. This report, like his first one, contains no basis to support this conclusion.

(Attachment B, Reference 17; Garfield y 11,20e)

- In short, while NNECo may have intended Carr's investigation to include the allegation of retaliation,'this investigation was not focused on the issue of retaliation and did not articulate the bases for its findings on this issue. No other investigation of the allegation of retaliation was -

conducted.

Did NNECo conduct an adesunte invwWr of"chuline effect" as a result of the

- 4.

d'r!="n ed enke t'-* and asaresr'=t* mettan to =i*iam** the ch!*!!== effect?

No.

The efforts by NNECo to determine the extent of any " chilling effect" as a result of the Training discipline were not timely and were not effective in producing sufficient information that management could use to take action to mitigate the " chilling effect" from the July 23 announcement.

Following the July 31 meeting with the NRC in Rockville, NNECo began three independent and largely uncoordinated efforts to determine if a " chilling effect" existed as a result of the Tra discipline.

The initial effort, described by Kenyon during the July 31 meeting, consisted ofdirecting ECP investigators to solicit input from the work force at Millstone, particularly in the Oversight and

- Training organizations.

The second effort, also described by Kenyon in the July 31 meeting, was that the Employee Concerns Oversight Panel (ECOP) was attempting to determine the extent of a " chilling effect" and the causes of the " chilling effect".

The third effort, which began shortly after the July 31 meeting with the NRC, was initiated by the Safety Conscious Work Environment (SCWE) group under the direction of Mike Brother This effort involved retaining the services of Performance Programs, Inc. (PPI) to conduct surveys of the Training, Oversight and Operations organizations to determine the extent of any " chilling effect".

ECP began an assessment of the presence of a " chilling effect" related to the' Training disciphne on July 29,1997. This assessment consisted of an informal effort of polling, by E-mail, the ECP Peer Representatives and interviews with six members of the Oversight organization. The E-mail sent to the peers was not specific as to the information being requested and resulted in responses from the peers that do not appear to provide meaningful information regarding the presence

=

ITPOP 97-0048, Page 27 November 14,1997 of C' chilling efect" as a result of the discipline announced on July 23. The 6 interviews conducted -

with members of Oversight indicated that all 6 individuals felt it "would be wise not to raise concerns because of what happened to Mike Brown." ECP provided this information to management in early

- August and documented their assessment in a' memorandum dated September 19,1997 that cMM that there was evidence of substantial "chdling efect" in the Oversight organization, but no evidence of" chilling effect in other parts of the Millstone organization. There is no indication of what was the basis for this conclusion. (Attachment B, Reference 8)

The ECOP efort consisted of 3 focus groups conducted with the Training organization and I focus group in Operations. These focus groups were conducted in late September and early October, at least two months after the initiating event. As ofNovember 7, ECOP has not documented any results to NNECo inanagement.

The PPI survey effort was completed on October 8. It asked questions that covered the same ground as the culture surveys conducted by NNECo earlier in 1997, rather than focusing specifically on." chilling effect". The results were not presented in a manner that was ofimmediate use to management to allow them to focus on mitigation of any lingering " chilling effect". Even with these weaknesses, the PPI survey did indicate that there was a lingering chilling efect in Training and Oversight as a result of the July 23 announcement. (Attachment B, References 9,29)

The communication to the workforce was also less than adequate. The initial announcement l

of the discipline was made before some of those to be disciplined were notified. Supervisors and Managers were not provided adequate information to answer the inevitable questions raised by the workforce. The lack of specific information resulted in the " grapevine" taking control of the event and characterizing the discipline as proof of retaliation against Brown. Following charges that the action was retaliation, the company took nine days before announcing on August I that it would even investigate those charges. This delay permitted an already negative situation to worsen. On August 5, NNECo announced to the workforce the selection of Admiral Carr to conduct the independent investigation, promising to" thoroughly communicate the results ofhis review to our employees." On August 28,1997, NNECo announced Admiral Carr's findings, including his recommendation to review the basis for discipline for some of those disciplined. This review was conducted and some of the discipline was reduced as described earlier in this report. The adjustments in discipline have never been communicated to the workforce.

In short, while ECP attempted to conduct a timely determination of" chilling effect", their effort outside of the Oversight organization was informal and not comprehensive in nature. The ECP investigation did conclude that based on 6 interviews there was a substantial" chilling effect" in the Oversight organization, but missed the presence of" chilling effect" elsewhere in the Millstone organization, specifically in Training. The ECOP effort and PPI survey did not provide a timely

determination of the presence of" chilling effect,". and NNECo's communications with the workforce were ineffective in mitigating the potential" chilling effect" associated with the Training discipline.

I

A t

E s

YE e

,BW es AMV I

E h

I c

MN 7

a R

9 t

/

E 6

tA ET 1

/

SN 0

I 1

EE YE MBW RWE I

EV MWR 79 E

/

NRT T

6 1

N

/

E I

0 S

1 YB O D MEH 7

7 7

7 7

7 7

7 7

7 7

7 9

0 9

9 M

9 9

9 9

9 9

9 EML

/

/

/

/

/

/

/

M 6

0 0

0 5

0 0

0 0

0 0

0 N

/

/

/

/

2 2

2 1

2 2

2 2

2 2

2 O

/

/

/

/

/

/

/

/

/

/

/

E 0

0 0

0 0

0 0

0 0

0 0

0 I

1 1

1 1

1 1

1 1

1 1

1 1

TN AIW YE LO BE i

AR DW d

TB O

E 7

i i

i i

i i

i i

i g

d d

d d

9 I

d d d

d d

j E

/

E V J 7

7 7

7 7

7 7

7 7

7 7

R 9

9 9

M 9

9 M

9 9

9 1

K t'

/

/

/

/

/

/

/

EI T F/6 5

6 5

0 6

4 5

5 6

6 l

1 1

1 1

1 1

1 1

1 1

1 LM T

/

/

/

/

/

/

/

/

/

/

/

/

B N

0 0

0 0

0 0

0 0

0 0

0 0

I 1

1 1

1 1

1 1

1 1

1 1

1 IF SO S

O i

OE MN d

PN EO 9

7 I

I

/

OL MS 0

I 3

TP WV

/

I 0

NC E R i

E 1

id I

i i

g i

i i

d j

7 S

d d

d g

g g

d 7

I i

YI V/

d j

j d

j E

7 7

7 7

7 7

7 M

7 7

7 9

7 7

R D R T 9

9 9

9 M

9 M

0

/

/

/

4

/

/

9 9

9

/

9 9

E A

/

/

/

/

/

1 n

3 6

7 3

3 3

0 3

3 6

0 I

E T D

/

/

/

/

/

/

3

/

/

/

/

/

U H N

0 0

0 0

0 0

/

0 0

0 0

0 0

0 I

1 1

1 1

1 1

9 1

1 1

1 1

1 1

Q T NI N CI W )s 7

E 9

H

/

I (

7 4

L VE 7

M 7

7 7

e e

1 l

7 7

7 7

RT 7

7 l

, 9 9

EA 9

9 p 9 9

M 9

p 9 6,

9 2

/

/

/

/

i

/

/

/

i

/

/

1 6

7 t

0 1

2 3

0 1

1 t

TD

/

/

u

/

/

/

3 lu

/

/

1 3

l

/

/

/

0 0

0 0

0 0

0 0

0

/

N 0

0 1

1 1

9 m m

1 1

1 1

1 1

I 1

1

)s (R

E W

n k k n n n n n n

n n i

i i i i i

i i.

E i

c c m

m m m m m

m i

m e e I

i I l V

B,B,i I.

I i i I

i n

n, n, n n

n, n R

8 T

in n n n, n i f f f f f

n f f

f f f f f in i i i i

i m

E i i i i f

f f

f f

f f

f f

f f

i f

i i i

i i i i i i i i i i

m r r 2

N r

r r r r r r r

r r r

e I

G G G G G G G G G G G G G I

g a7 P9 E

k

,9 E

y e l

e c k

o e

d k

e e

81 W

t a d c a n

J h

r k e r i y y uJ l

4 a

i e s a

, yr 04 E

M M,ki G a d r r e r y a sM

, D uh B nk F s J e

01 I

c, "

V

,C n, i i s

J awM n r

g

,d

, i

,mo 7 e R

n e nl e k e,

o r

r l

e e

9 b E

y yl s,h y a i

h nif b s s nE l

Pm T

w o v r e r t

s t

l a o o r e c o o on.n i

Oe N

o r i G G G G K M R R S

v I

B B B Po T N I

ITPOP 97-0048, Page 29 November 14,1997 ATTACHMENT B LHC INOUIRY INTO POSSIBLE RETALIATION IN THE DISCIPLINE OF MIKE BROWN DOCUMENTS REVIEWED 1.

Ross, Michael, Audit Matrices Ross, Michael," Millstone Training Program Personnel"(I double sheet), undated matrix, 2.

1 double sheet Thayer to Ross, Memorandum, " Preparation of Summary of Findings," 14 July 1997,1 3.

Page Ruth, McBeth and Ross," Nuclear Training LOIT/ LOUT Reviews,24 March 1997 Rev.

4.

2), 21 pages Protocol for Independent Assessment of Licensed Operator Training Discipline," ['Carr 5.

Protocol"),6 August 1997,2 pages 6,

Draft " Disciplinary Matrix" [ redacted),18 July 1997, 2 pages Memorandum, Garfield to Irwin, 6 October 1997 re " Request for Documents" 7.

Streeter, John to Temple, W. J., Chilling Effect - Training Disciplinary Actions - AR No.

8.

97019745/01 (4 pp., including attachments)

Meeting notes (T. Snyder) re Programs Performance, Inc. (PPI) Survey Determination o 9.

Effects of Training Discipline (8 October 1997) 10.

NRC, letter,28 July 1997, to NU re Training discipline NRC Public Meeting, 31 July 1997, Rockville, Md., " Chilling Effect", Work Order NRC-11.

1193, Transcript (31 pp.)

Millstone Point All Hands Meeting, August 4,1997, T. K. Snyder notes (2 pp.)

12.

Letter, Thayer to NRC, March 3,1997 (6 pp.), attaching Independent Review Team 13.

(IRT) Report,1996 MP1 LOUT NRC Examination Failures (Accepted 2/13/97) and 10 attachments.

)

ITPOP 97-0048, Page 30 -

Nc w..ts 14,1997 Independent Review Team (IRT) Review of 1996-97 MP-3 LOIT/ LOUT Program (Fina 14.

Report, Rev.1)(undated)(3 pp. summary plus 15 pp. report)

S. R. Crawford to M. J. Wilson, Memorant'.r.n," Assessment of MP2 Operations 15.

Training," 14 February 1997 16.

B ASIS FOR DISCIPLINE," undated, 7 pp.

Kenneth M. Carr and Warren B. Cobean, Memorandum to Bruce Kenyon, " Report in 17.

Accordance with Protocol for Independent Assessment of Licensed Operator Training Discipline of 6 August 1997," 21 August 1997 (1 page)

Training Discipline Followup," 8/26/9710:15 pm (unattributed, marginalia, I page) 18.

Documents Given to Bruce D. Kenyon..." (undated, unattributed, I page)

-19.

NU Press Release," Independent Review Concludes that Recent Millstone Employee 20.

Discipline was Reasonable and not Retaliatory," 28 August 1997 (2 pp.)

M. V. Bonaca to Bruce D. Kenyon, Minutes of NS AD Meeting 97-11, June 26,1997 (2-21.

page memo,10 pages of Minutes, 3 attachments), NS AB-97-105, July 21,1997 Mike Wiese to Bruce Kenyon," Disciplinary Action" (undated, 3 pages) 22.

Kevin M. Murphy to Jay K. Thayer," Response to Disciplinary Action," July 31,1997 (8 23.

pp. plus 3 attachments)

Trad Homer," Position Paper," July 31,1997 (4 pp. Plus 4 attachments) 24.

Adverse Conditicn Report M2-%-0657,6-1-%, re " Failure of Unit 2 NTD to consistently 25.

comply with procedures..." plus numerous similar attachments Millstone turns Problem into Big Success," New London Day, October 16,1994 26, Carr to Kenyon, October 13,1997, " Supplement to the Report of August 21,1997..." (1 27.

page) 28.

Discipline Review Summary (3 versions,9/12 through 9/25/97),3 pp 29.

PPI, NU Employee Response Survey, September 1997 e

'.k

C ede T

n c i

N 3l n 2 pu

.o E

ic o

/7 sn i

M inD A C

I H

A g

T a

x x x x x x 7 x

x x

x

)

Em T

(

ia A

rT id

,g sr n 1 ct x x x x x

x x

x 8 ei

/ ie 7f e fOm m's g pr n

)

S 5 ct x

x 7 x x

x x

7 x

x

)

ei

(

ie

(

E 7f e f

E

/Om 1

I 7

D

[

NE m

5 psd 1

0 r e i

3 em x

x x x x x

x x

c A

i r

1 f o f f 5On D

1 I

/

N 7

A

• "g g~nI S

)

G x

x x

x x

7 x

x i

(

B I

N M

I T

EEM ts o%l i

4 s

l x

x x x x

x s

1 E

a

/

N 7-i R

t I

i I

n L

i P

I l

C n n d

da l

9 o o S

2-ri e

l ic i.m s I

et f

i a

ag D

yc r

1 cg,iv 2/a a a

a N

6hV G

D T

W O

r R

on g i

)

9l n x

x x

x 7

x x

x x

B r

x x

x

(

1 eit

,Be E

8 c

K 0M 1

/ 2 6

I M

I I

x x

x s

uw yg

)

o 7 e n r

x x x x x

( ni 0 r t e

y x

oe mw 1

t e

/ t ua 6AM l

AN 1

3 eg s

a7 u

t P9 a

,9 tS 81

/e 4

t 04 o

01 N

W n

z d

r f

y s

i d e y n uy 7 e o

k g s e n w

a l

n r i r a a ad 9 b s

s n e l

r n os r

e e e o c eK nb a x l i l

k d sh v cr r

t nl h s ek n y u E wn s t a o r t

i P m n

a w or l

i w a t

ci e a

i t n b s v

v a o r a o o nh e o a a o oh u a u a uh w e r nf c

Oe e

r r o E

B B B C G G G oK L M P R R R T c G G M QT T W J

i N 1

(

ATTACHMENT 3 ci ITPOP Memorandum Date:

December 19,1997 ITPOP 97-0057 To:

Mike Brothers From:

John Griffin

Subject:

Status of LHC Recommendations Attached is a matrix providing our evaluation of NNECo's response and implementation of LHC recommendations.

The first column describes the recommendation and reference to the source of the recommendation.

Column 2 references NNECo's response to the recommendation. Column 3 is LHC's evaluation of the adequacy of the response and the final column is LHC's evaluation of the implementation effectiveness.

Where LHC is satisfied that your corrective action has resolved our initial concern, we have closed the recommendation and so indicated in the last column. Ifwe are not satisfied that our issues have been effectively resolved we have placed an

• in the final column.

We have not received your responses to our recommendations provided in connection with the MOV event or the recommendations provided during the September 24,1997 and November 13,1997 meetings.

We will issue an updated matrix on at least a monthly basis and provide status reports during scheduled public meetings.

If you have any questions, please let me know.

cc:

Ed Morgan Bill Temple Mike Gentry

4-7 9

9 1 -

2 1

ss de e n s

n o v

i ei e

vt R

ia t

n ci ef m f

r Ee ts t

n Ce e

H D muc L

od ec ruos n

is S'

re n

b E

o m

t u

i S

t c

n a

a n

N ts to r

u O

i l

b a

a a

d P

v n

ne S

E a

m sa m

E C

r o

R H

o ce s

r L

n D

io o

t N

t "w

a t

ou A

q L

E d

t

=

L H

d e

c.

i 0

S I

W TO eed ireR 3

t hi e

N T

t dt m

S i t P

ES mt e

y f

sd O

C OBSK.

i e

al o

r ERN nmp s

r a 1

E T,IRCOO I

1 en at h i 4

e T

H o

e T 7 COWT I

g ri t t

R t

SR n

9 E A

Tde ied o

a A

)9 P S s

. t, d n

P n

1 D

U T

) e m

T ma s

D o

1, N O S 1 t HI 5tah.

Ocf d

r e

NA o o

92 CSCa6 I

N p

22 6 sc sa e Fss ES dt I

s 5 YHI N 1

s Sar

.d E

e 6

T nt P f te n

LWT O BaAa id a, u

R 1

A nt M

( J "P T CL (P

.c LnL e

V Ci e BL r

I o

7 Cnt Lwo u e M

C 7 YACYn 9

o o

/ eio W10C q

9 BMA TM E

2 ht r S 'r E e

E 6D DFFT 2

/

r O

N

/E a

N L

t

/

d o neN nf 7T A OAA 7 o nt pi.oo ir C

N I S t

NOI T

r ee da w ut e r

c e s E N eI e

- cs mn dei was e E"R T ER eM DH E t

t r sv lo e

t t

t enme o

EAA T M Leoe e o r

c n e lo Cr r

L LE ET N omcf st CLl o

po Hf f

r RC O C

oP D BE ee e ed ia e

R Cl CP r r r

H E UVL RI E pC ss ar e Hrt I

s o e Len S O L P.V NpuHro Cn he N ERUON n

yn lat u t

L NDPF CE NSLc eE a nr q mN m moue f s it N

ui t

elod os i

m msCadNt i

s mo n P) n e

s, tc of os sD e

r e

s n

e c

ps sserE m

e C

C h

u a

r n ot n

preniS u

(

t a

l r

u aCr e

c t

.C aP o

Hn s

h n C e.

kEegwqO n

s o

e oNcheR L d

a e

Lo to yT o h s

xt s

t sl u C NEae* C l

r l

P d

ol uf N

i i

f i

i v

A RvS c W 'tnWC C

a o

e ot dt d

fee t

n a e

eC

- in A

v l t d d e

,t E

ad l i i

rH-no N-g s

o

.Ac t

mo o N

eL i

n n

t e

e n e n

e e e

P ef s f s n

a i, a, i R b

r t

rt r

r e

c m

h C

uEel a

c o

mfo b

r r

e r u neh e

m f

r e: sed s u

um gnrd e o ar c d

Md u

a n

n o

p h

i e inEAARCMDE Cg e

e n

So s

t g

e c

n w

e He h

,e o

s L

LL

,T eR C

iovl I

23 t

a 7

el a o

9 Rfl D

/3 1

/

5 l

0 x

=

s n

m 79-9 1 -

2 1

s d

s e

e n s

i n o v

ei e

vt R

ia t

n ci ef m f

r Ee t Ce H D L

no i

tau lav.

E C

HL e

ye d

SE or l

t r

n E D f

a e

i t a sa d

V de 0

aP s

3 r

ex L

eh e r

fmC I

e w p

t T L t

o h e e t t t

t u

f CI u

i i

i oo esovt mt EW meie o

t ih t qs rx e

gi n pt s

TJ nm N BP smn v 2

n s r h

't r e e nBr r n

hi at EOC t

e aict g

e opne r. o a c

ri MNE r

e e a

nl e

o ao paimMeh t t t

t dt s

,de s a t.

d EEH j

s n

) e

)

) e2b P

N d ;r ]enegi a s. c trPm 5t 9 S HO t

2 RTT 1 t n

a1 O e

1 e

von a

UEF.

6 sdP o

)

5t c '. E i i 9

7 t t an n u 6 s p

2 2 A Tl 9 1 na a eWui r oCe 9

6 dteC t a e g

6 d 5 E pmCedocdnmc s

5 l

s e

6 1

eea n

6 F X1 Bat g e e S[ exace nrh n Ba M OI R

1 1

S n D2 (P

ol t a (P

BD H N2 7 Cn u B

vg s"n s n

.i afm 7

c r

o

(

a an d"

(

I i

Cn a

ml en 7 NC o

9 o

E 9

o s C

7 h

e gtos e

/ ei 9 AAP Y

/

L 2 eia 9

eaeerl d. tinft an 2

t h ae t

/

AEP E

i h a 6

wmioenvl

/

U 2

i oiel 2

i t

6 RAJ t

/

d m s

dr

/

d

/ I N

e e rb o o pd a f 7 o n 7 R

/

7 o n t

EO NY r

ed 7

a i

o t

t r

hin d 's N

i r r

e rTF cpma ey eI m eI B

eI mn rt I

l erc et t edht S D t

t n amfe t

t t t a

e nh e s R E E D enmg t t t

t i enm eC e

te e vot h de ont i

l gieignb Leo L

UT E Leo i

Lmisgo sh o t

e n

P omc o61 E O omci S QA nri t t t l i s

et CmboiesiB Eoelfdisnsmn Cl r e L

Cle e

C N N E E pC lu r a av daleo

u. H ICLV p

h e E pC E

eW E m e ph i C 0%anspsp NpuH N UE EE NuHa t

i k

NoWmcMS5 le aame v

NC* ea rhhi r NSL NSTDD NSLe a

ed ir n n d

e ia t

e C

Le i

r r

ni Hn nois Ct l

es s n Lo oRsDu s

c s e si o

em i

u t ei.

c dt cri h ct c e.

l n a o = i t s n u r s b

ne ue ad F e. agom su S

n e

peiaq n

yniCn t

e e h

oleMn m

v - o c

t r m e n ueyr h

oit i cn ch e v vdc um aa cc an f

e ne oSo PMAASE DaT l

c

,e eR c

ta b

I D

l e

3

79 9

1 2

1 s

d s

e e n s

i n o v

ei e

vt R

i a t

n ci ef m f

r Ee t

Ce H D L

no i

tau la vE CHL t

t m

m r

r dep 0

r S

dep e

eh m 3

T eh m gr it e

t t

R 7.

i f

t f-a u t

t t i ns m e o o

O 9

imt o l

F "F 9 e

e t

ms 3

s an]

c t

sms Me".

F 1

n n

e E A n

n e

t e

M M2 aio h

de ai o g

t r

r t 7 e nu t di a

2 t dt

)

i t

s AD e9 u as

) ec,

P

)

) ec 4

s s

n 3 RAY 1 t a d 9 1 t a

sei a

m GOL a

9 u1 i o

ue 5t d 5t d 2l e

9 ORU 6 s a

J e

5 c2,dsh 6 s p

2 r

s 5R*

6dt n2 n rt 6 dtag a

6i a uf 1

e 6PEY nt o 1 nt 1 N HB bas oyr po bas r 1

R Bt u oos (PC n. P l

BO TP (P.

(dJ st t c

7 t

o

( I T NC 7 Cn 7 eyoende 9

o n C

7 9

o p

2 I

eie

/

E

/ei 9 sib pt s htam CwH 9

2 ht 6 v sSa a

/

ds E

/A

/

a 2

t N

/E T

2t 6

/ et n

a

/

d 7 r r s

e gl 7 o n e 7V cO 7 o n ovi l t

efi s a r

es N

rT ET r

e r

t I

ebf t eI ms udoef eI m.

L T t

e tenmA t

e C F t t t t t l t

c xEE N enmP el t t

f-i nenn Leol LeoA Lwexe RR E omc oPmEei omce o

I R

M t

e eS oO E eC C

s b u Cl r B E C C L

Cle Cs n r

s E pC l

s E

e o E p C 'S E

LP NuH' NpuH Nhe e ~A v p

S E LP s

s NHI U s

a e NSLM NTWS NSLM NTa[h r tne m

l C

e cya ribn id Hn tnn uoso la t i Lo c eo qi nt r

i t rt eee a ri i

c z

iuA RPmd dt r

n a g

C C e

.s y

l ad f e.

dms ha s

e s

t e

et v

n a ov wim r

e e e

n i

wra n oAsGe u

r c

r r m ie g

p f-hm S

aF

=3 i

s um c e e

v o

a e ur xrleal r

o i

o So RRCP EfSEE u

t c

l

,e u

eR e

a d

C t

l 7

D 9

I

/3

/6 2

t o

79 e

D D

i l

t 9

s e

t a e E

E d

S 1

w uh S

e sy r

et u

q t

s e t

a 1

ed O

ot O

2 t

u 1

t sf l

q s

p aa ut d e L

d b L

s a

n ya a C

er C

e d

t s

n s

i ao cd r

s tsd st s

e n s

wt a ye e

is de eh v

nai vi v

t i

e n o v

yel f t i

l uwa ed ei e

it t n c a

t s

v r

vt c

ngu s n c

n y

R i a sl i

e egw am e

.uin f

j.

t r

n j

ci b dSea os b d usie i

s wo a u n.

o e t

e v yd e

oe s

f m ed e l

y a ud e t

y n e

t c c er tn.

r r

f r

i Ee tf uyu r

r a

nin 7 n o.

nr s n

n et l s

ndl ea

.a o

s ueo t

ut e e yd i u u 9

Ce u

ops Sdi SlyCaumtak ee 7 m e ed o 9 c e 1

e at S m 6i ue ut c

t s

HD r7 q s

c 7l L

9 e9 ed ml 7

a rl 9

h unr

/ n u l

to i l

/

l 1 d nl

/ o 6 c6 aacAuc 6 c Tqap 6i q e

e e

e t

n t

t o

a a

a a

t i

i i

i r

r r

r i

t y

p p

p o

o o

a m

r r

r u

p p

p p

a p

p p

p l

a e.

a e.

a e.

ae.

v t

t t

s a t

s a a

i s

s a i

E u

u u

u i

i eq C

eq eq eq s

s s

n e n e n

n e s

e d

d d

d o

H o

o a

yd a

a p

p a

p sd sd L

sd e n en en en Ra Ra Ra Ra e

s, f

h d.

s l

e a

a o

g t

n 3 uy w

o t ee n yi 0

t l

l g

e u ph ak ed s

i t e

3 2b e yIt n

s s ot n afe n

f v

e.

o o o

r st rimad o

o n

ec o o

i er r v e i

nt u t

s s

r t sls p

a yd e i u

p 4

uis ua s a s

eehdnal s

m t,

Jde s

difc o

e e

i e

s vdt n sh eienmy R"

Ardo asoi R

g n

e Oat dh!cmfvc

~ u a

[ w y, n T o

[

[ s ae r, ict e

[

P s

l r

e r

a

.l e

r n

eei edo e

)

ye 1 e vde avgu rh

)h

)

o

)

ewh pw 1

r on s 1

1 r

c ur e

i 5

5 r ep t

5 t

p 5 v u

rt pd e 6

6fw s i f u m n h ]e.

vut 6

e r

n ol o s r uis n 6

s 6 u uFt 6

6]

e 6

e Sef ek ciaTs s. r as 1

1 1 nn R

d r 't m

1 u

B".

Bool t

v B

Bethdroeft

( "e.

t a sciee n n i i u r

l rel

( e

( t t ufywh ee s u v

7 o

(

eo deyfsnmi 9 o r

7 v ol t

sdsc 7

C 7t r e e r ne 9 o 9

i l

ut doe v

/

ah r o cty

/b

/l qe t

9 u c i

E 6Cul focgn 6 b et u oe 6 a

/

cosfu 6/avwamo a e

/ a N

/

rrf 7

/

d 7

ayapa 7 "a, rde e

r 7Un s

t nk t

eNord mlicoe e"

e n. n n rdar e ""c t

N e

ei efs r

r l

oee m o cee t

I-wtaoa t

t t

t r t,

w nl wi w

en t

b t

yh en e

tePe t r p, i s Li Lete o t

s Li t

h sct sso LFt eidsi l

d o n n i u "]

o d orov n eh a e o

oint no e

e r s r

e v

oo t

nur u u Cd Ce oyiiei y Cd i u Cet cet t s ce Eu h rcmgs eqs Eu Er v ss s v Et oe l

Noijmiad da Nc Nrd e ednr Nc l

r s e a e

u nu uunou n

n NaPocdml am Nin Noasqqacs Ni nrb oe e

f

g o

d n

tn e

i t

y e

et C

xwl e

r r a y

r t

l eo a

n ad a

i m

Hn Nl e s

osl l

ol e

cna o

Lo eFc v

ov d

i h

id di n

t e e t e nt d a.

dt r

ct s

n a gh a ea a e n r

ad n

s bi eu a sd t

jc e

ir e

on pqd nt n

t e v

ot e ou e e cdi4 em uit yu cnw ib c

t r m d sc r

s ee si r n ne v m eri et um o j V.

r v us o

b u o h ue o

i S o CC O Sc Tcr Qd c

eyt

,e r

eR on.

f ta eua b

c d

BS2 2

2 2

D 2

u 79 D

D D

d 9

E e

E E

e 1

h S

s S

S w

t i

t O

o O

o O

v o

2 1

d n

s L

L n

L a

.tgto r

e t

q e

d d

.C e

Cm se s

y C

e t e nt n. n t

s e n t

r a

i n

rl a

n o ul e u

v ei u

ea e

r e e

vc r

t yer t

vt S

ns u

newfo n ).

R a

el ense mla i

7 ot t

tci 9

cn u

mur n

l r

/

i e

s c

eSee et T m 6

o np f

g g h

). ga at af r

n o

o a7 n(deni IEe n9 i_

i4 sd a/adt a(

t t

d sg a

t m6 meimd e

e e Ce e

d u n rd e

vm e

H D u

qt au l

i en eheomni s

l nt nv oia l

l i c

l L

c l

l ifi n x

n r

n Ae Ai LoLicLt I

e e

e st q n

t t

t i

a o

a a

i dn i

i r

r t

p p

p ed i

r nn a

o o

o i

r r

l a u

rp p

p tue a

p p

p l

t c e.

a e.

a e.

oa t

si v

t r

s t

s a ia ap.

s a i

E u

u u

i C

eq eq eq eo e s

s sr n e n e n e npt s

a d

d o

p H

od o a ga p a

p p

p a

L sd sd sd ot a

en en en od Ra Ra Ra Rna ed ht ee e

t t nyao 0

e ub c m

3 e

e e

s h

o Jdl e f

s s

t n

n n

e r

o o

o fnt e o

o p

p p

e our r ee 5

s n edb wh e

s s

sl i e

e e

i r

t e

R R

R Loet so g

ph st a

["

"[

s r

i nt P

u gd i a ]

n

[

[

)

)

)

pn s od o

)

apn" 1

1 1

1 i

p 5

5 5

5 et s

6 6

6 6h ewnae e

t t

6 o si e

6 6

6 1fmloit s

1 1

1 R

t J

B ot oc n e B]

B]

B".

(dnt e eh

( "e.

( "e.

(

e ee yl mt o

l 7

7 v 7 smeot C

t 7

rCrao 9i v

u 9 v 9 v 9 o

/v e E

/ o

/ o

/6 b 6dgu. ph 6 b 6b

/a

/ aa sseg N

/

a a

/

7 n

rdu e "c 7 "c 7

7 e a e e N

r "c r

r r

r h cso e"

e e m t.

e i u r e "n t

t e "n t

w foh t

t t

t t

en e

a i t a 7. O r Li Li Li Lst s

d r

r a n od od o

oe 9

Cd Cd Cd C g y9 a v o e

e e

eei Eu Eu Eu Eaellch a t

l l

nv Nc Nc Nc Nar~. u c

t l

u8 no Ni Ni Ni Nms1 Nil n

n n

t e

r r v

ee e

d h v r

it e

ta 's f

t n a

r a

t C

v nh eyr c.

r ep o

io a

r e

e r

Hn e;et k e a s "g m y r f t

r e

r s r e u

a e o,

u ol e

Lo t

r n

c eioaf a

sp l

n

e c u

r g o i gl wst n

i dt n c ao e u o "n na s

c e yd t l i"k npe s ot n a

,i f

glee a

t wma ahih na o ect o

at v ad t sn nal s

t at eni n

ot mss t

s i

s w mi a snp ad aio ri t

o i

cn e do e e l

r l

v md ni e e mp n o u n s

r c

i o o5 rd oi r m s

f ri or t

s si eh m

cp au er t e i

r t e a ci a

l c n pd d si n o um l

ur o

d nc ed wi s st e4 gs ain o

Ai Laa l

ipn on sn n

So AcA

" e rihdi Bat

,c e

eR ta e

f g

h 2

2 2

2 D

79 d

D e

d E

9 t

y 1

af d

b t

S co e

s d o O

2 d g i

t 1

e nr L

nr a

tai m

C e

n ap d

s uN r

e s

s e n m m u s c

l n

s i

e o

i n o mu e

b c i ly v

r t

e a o at.

R ei on e

t vt c

w sp t at r

r s e t

i a t n s

a s

t va n

o a a

i ci nc n

wt n e u e

a a

vq f m i

i d.ad ma e

~

ef l

Ee e n s. p e f

ri t

r a e.

dh d t

a genad d y a s wieoi t

e s

t ri n yl Ce s

s yi tt a or t i yocn tr a t

HD unl aiwup ntnd l

som sap r

u on L

e mo o n no Rt eNnAac Sca o

r e

o s

n o

t a f

o t

t u.

s o

o ay o

s n

nt d

t a

n ce id

. e e

s smd s

o b

i s ev nn r

i e

.s ibr oa t

l e e t

e n/

.i t r t

o u

it e a

t s a o n gi d nc n

t e s at t

u iud e ad nnes ne pnt eieaa r a a

eqe mneaamrleam l

ch t i e e a n s p p p p p w.

nsmi l

rt s rt s es p oL yinpa v

nd ner r

umiasnl enl o ed r

v i

o o

e e oI e

ou E

oaod r

i r

q yoepoer f a psr mrpe pn pus et l

a aivoivr ee pi u d pd s

sle ce nt C

t t

e a Rimionceccea RLAaiSaaa t

n LnaadSadn h

H Rt L

t s

E n

de e

B l.

ss e x I

t t

o 0

E l.

.T A 5 pe

, o n t

e r 3

eb 3

RiSH A

UR T N

rp 2t e ol 1

npp f

esm mo o

D

)

Re o

n. N E I

T N

1 I rt nmt o

e.

o r L 5 E r

t I e uaa cd 6

T TRM nE J

F s

T

.ws pen nd e

t T a 1 d e d. J rngeh e e

g KI C OT s6 T

R r A v r AOTN Awe n cteo r e

7 P c

odt iuk a

s

)9E P M E D 7t n a a c yP i ngt c P

E r

n 5 9R i

e o E

RI erl i e e

o

- 1 9,DDA A5 1 nus e n r ;r sr&h r v 6 eJmet r

p 23 N E

we DT S A 6 mfr yeus owdo t

s 52A NP OR NF rSiods oo sofl st I e 1

e 6EhAl skedps I

c R

N

> T/T A Be elynn ne r 1

I emar ar o oeu

( s B U v

NREA A E 5 C TN T.

7 set I

9AwcEwu yo nu i

o (J

nt t

o s N

t C

7 E uU cl

/ pR l s. g luA e

l n

n ot 9 HG E,D ETRM il n i C yi inpts 4

E

/

A 2 hl o od b, tut mi 6TRTEIAO E

/s cio r s

s N

srb n eo FPI L R FV 7 r

/

yd s c a 7

5 t

i t

ae ri r N

OE RPRO r eb e

or r

T wct ne B

AOER ed dau nl is;sh n

e eS L. B ERNP c

tt a e

o u n Dd o e t i

tt T ELL DLPNM ee r d qi aNioOrt mie i

t WPlEXPAI LLee r LUI r o a a AMG ors uwifh t t e ce u t

S afiny z

s oET ONETN Ce nb sit ai b

CREL iesn r e t

E VEHRLUE D El r

nr rl da ev int i

a t c NHUEA SME Ncmts eosu agt r E RiC E

NNadtudiodFiNhe r nu SI d

oes NTSDEATN i

e t

)

C a

0 yr 9

lses Hn nh n 0

l e

Lo at io 0

ev r

srt t

i nc 7

pl i

it dt oea 9

oes t

n a nt t

n rDl mo yP o P

u ad edet t

n m

el n nOi os t

et e e e e

tt pi r a b dR a mimt u

c t

g c

i s

r m ai s e S

f r

l l

um md u eyi u

u n

ef r

Mt a

s r ra Mcar uel is g o

on e So n

C yni

,c t t e

t ein lued vma eR CLe ud r

e ta 1

d SAM 2

77 D

99 v i

// o 35 r

//66P 3

9 t

~

79 dn s

e 9

a e

n rd 1

r d

ee i

i o

n wf 2

dehc

)s a i

1 t

t s

l ei ea "s n d

s t

s wf vt ne e

l e n p

o a

d s

ee n o mds enl d s. o i i

i v

et sntcf s e

r i l_ h l ei ot u el a

lpia aoa R

vt cl o wo e

a ut i

pelt s

n t t t r

t n

ci abi n d (a e t

s z na u a e

wtarp otet yoist f m r en

.ia nl r

rt dcc eatips e ye e f

t co Ee teaeuimnar am n wi n

a pst t

t r Ce e

p pa r

u ut ugo o

s S s pb soinmat HD t

l a nt 7 upt mnwt'gkep l

r ri L

9s so a

s e pi o

oeiam 6radNcmhdft

/

i s

s s

l t e

~ n e,

on c

s v

.s oe o

i d

o ot mla pl h

c l

r j

i b%t oye u t

l t t e a

el dt an i h cdn e.

a 3

=

veinvef e wt uat u

s eim om eoSei a

l u

a nd st h

s o n p% e nt et r v

ap

- or o0 a n eu uo i

g cr t

t E

i nenle1 n n

t r

BsCQa w1 =

h av ra c

pl p

C se=

et e s u p

hAarodfeom r af e

H At L

se n

p w

s e

e i

e r e

s h

k s h

r ai e

t s

aev c

mtaa 03 y,

a l

t uu rh edde ed r

scr oe e

1 a uNo pt v n nt r e f

)d l

i o

aap af r

es s

s n u

i i st 7

T. eLnrht ert einsoe g

ceei do S d t,h nn e

e Tea I h ac es s

Ah m 7. th" rid wa r su et i a

t P

c e. d c ue t

9 gth e o t

n a a s r

7fo9 uni t rt l

a u oieee t

o 1 of1 mawdt r sl t r r

nn Cp yra a p

6 s e n r

s 6l pih gs ae Ueb t

ai e

1 u o

t ot r

nt m b

y N

dlepn R

Bse s mr t

ePeni I-l co a ehl me m r

l e

(

pesm m Pwpuo n p r "t.

rt A. r o

7 eo i

C 9 ht vs e po n sriego F yleh afe

/ t E

4 ds t

s r

2 7 e ein s ac ee vc ee m cde anr h v ea r N

/9i oic au rdEu ne t

t 79 u

nv N

r1 r p sIngmo e r o se".emp sn am n

t e

ei e e eb s

t n at e t

t s

chl t i t nicact t

pf w e i ly m l

et l e

nr na i nl Lgne e agar".

n e~

i e

t so n we o i m e. h mg mt ms e

s k t

n s s

Cnsatgor nr nt rtst wein r

oiool l r t i c

d Eie ndrft fmuh uo pi a e Ngs a e e t

ar si sp efn e

es ee e NBAmiPt pd r W e errdoin h

t no C

tc Hn A ~

Lo o

t i

dt d.

n a e s t

ad t

t l

i u

n m

s e e c

me r m oR u m Cy o

e So ev+

c Br u

,e iS eR sue ta Mh D

t 4.

a 5F il klll1l

!ll

79 D

y o

y E

9 1

l et w

S lr ems e

e O

2 r

poigv pw e

i 1

oe L

s ost ne ri d

C e

r r sair pv u

pr pdl f

i e

s n

f a rl r

n o i

edai v

i ei epegw el e

l t i R

vt t pt e

a crc aw i a

% hem..

u e

H t n ef t n qC ci faeL dH r

e ef m e

a L n.

f r

nn T.h t Ee t ioo e

.o ea d y m ii adt r

i r

t t t Ce ebmtaa ea st t

st t e

HD en eonn enn b

l ne ccee nee a

L ma amm imm n

i i

l p

l e ee e et dl c e ee dl u

l l l pp ipuk pp u mm A

i a

uml mm mii Gii t

GiI s

ri gn eh 7, o

c i

n eM e P ri T 9 n

)

t e

n6I

/ sr bw o

e h

f

. 0i oe

=

nb MOis3 i

e t

t inrhdl t

o e=

g(

s/

eM r

a o

r a9 ept e aa i

i t

a vi a vi nt ns ms a

u t

ebdms io i r v

t n

iga d t

wolpcyeel rl ga l

e l

a h d h

es mco i

t n

e l t gi erFna.

ieuh s "s a.

r f

a e

s E

e "s a.

e e

vRNt aa dl n gh o e

.Peb vedl vedl e

nts C

nneb nneb r yeo ant dy uu9 et p

a m s Mi g e s

r c

Ii pa l

I i sh h r

t wnv o l

t e o s t e o y

l i

t e

ei l H

nd e gsd t

l nd e i

n Cot PnhacPit oe l

m o

st o n

(-

ii nrCvt eaCcA L

ou v iiv e u l

o ou i

GdA E M w o pE r pr e

e J

c JGdA s

A dr r T

.r R

a a N

P 0

I s

E E

3 E

de n

l T

nc r

M S

T a

e f

t e c

E, Y

o RC sd t

l n P T B 8

i l o D

E e

v a c MNS E

h u

I E S e

N

,Y 7

E g

yne ee MC a

)

A U 0, 7

~

e

)

3 ey E O P

s 1

l S At 9

)l n

7D P9 7i wo 7G R l

wtep o

1 R Y M1 1 A P 1

6N p

6A B 6 eb m 6 A E

N 5

6 s

6DS G 1

vse 1

R e

1 N N on B

e B ME R

BA R N R (b ol E

( R C T E I,

aid

(

B t

o 7 S C D M.

7 dan 7ON I

9 t a 9F O N Nt

/ ec

/

C C

9 N

h 4 S a

4 b e E

4 O OA

/

ipt 2 S E

/M CH r

2 r

2

/ c xa

/ EI N

t GS 7 seh 7CI T

7 M NN r

S t

N rOI O Y ededs rO F

eR et C S t

nn O

t t

SI B t aao e

P, t

T ei N

Lr st Lt W eHE S

i LS C A eea AE Z

oicz oMV 7 oUOI R t

I ai C R R 9 CB RNE Crfn 9

EA PAC Ec r a E OE TRGN N deg NFV 1

NS ORO nt r NEF OC Naio NAO5 n

s s

s n n n

ws a r o s

i o

e e f

d r ei t

i i

C o

no e cae t

vc t

a r o ninzt

)

H ~n w

9 at t

er r oiy c

vP e

0 wlag oCCalno e

Lo 0

eu mdggp pe Cn iv ra x s s n

r i

e 7

ini mnn m

eEen ane t

v r

dtn a R

9 e aw oaiO E C m.h o

t e c n

s ad c

Po RMo Cs + egs l

Ti n

nmo ta l

e l

d nn Oi n

i

.h p

nz dPo pr o

ea mgeC t

t e e a

r a t

luCF oa i r c

l l e l f m

m c

i eae d il d c er q,

pnh a fi oEe e

l a

l r

nFAnn ve h

v i

ai um i.

t r Seh oyao DInBG mMf et d at o

s ra h

etar t

DSfbHC I

o So r

el ot ss

,c g

C Ce e t

s r e

o t

r xd Eivd eR P

I e Ned b

c t

a a

d NRA S

S S

7 7i D

9P9 v

/

/o 3C5 r

/

/

6E6P 5

=

,I l l}

fllf 1

7 9

e.

D D

gs e

9 s

E E

nt 1

l i

t b

S S

ey o

O O

b o 2

so na t

l 1

op.

dep n

t p

t et L

L eram a

d s

e i

t s

R ccs C

C n

c p

s l

e e n eci es i

l y

sa miU p

v t

n o l

s ei h

s si x

o e

i e eN len.

R vt s

h t

i l

i a n

yt t peg vo n

otel u n mr n ei tci Ma ab e

u n o

iui d a t

t st d

n gs a o n f m r

t P W, A 3

t 5 e

na p e

t f

r C

.m#

m Ee s

ie o e s.

dm E

s r

e b

t d r Ce

. enpm t

t yl o ee r

e l t el i

t ed emt u

ol a c np HD t

bvmii q

nn a

m l i e

eor oi L

aoeee r

st t t r rb e i s n

C k ppu n o Ec s

s i

Ps e c sd t

mwal o

e e us e

Un v Neh Noircgo Nc l

AnmcA M

o o

s y

e mh nb n

0 o rt oieCy o

t e

g 2

t y t

o t

a l

n i

t gi Px ep cEf i

t s

h pt ni r

i a

n Ue u

TaulavNe.

u eP N. a.

l n

i n

.sb peNv o b

r l

e not mn o oi a

sC esd s

t t a l

nieNst e

E br e v

I b.

it er e t n E

e

.y ai u t

l i

eb puqd u dmtob

. s oie lb n ect xm C

a a d s.

rh u or aoCe e e e e

H p

ue c cir nEnl c

ut p

qk n

h ys a d qns neoaNa m L

u e c nlne n

d ai chNlpi A

AtrA Uob Uar c

L E

T f-f H

A od L

TY S

f n 0

A 7

E R

9 iN R

oa 3

D O

9 nA O Y ns f

F 1

d S RTG T B om o

U E I

E% N C

L E D

e S

it r 9

E T

T s a9 S TWT Y AD ae C Y E

E hl 8 1

H I

LS ii/

E B

RE ct e

N O Y

NAU bin /

5O il g

ES TN I

l t 1 C E,V I

l a I E)

)

UE 6NF pr a

)

LL

)

e I

OP L O7 4 E NG a

7

)

P E. E Q V 7 OE pe P

s 2

i M

K. A t

- R

.R n

T MA L9 CD An U

s ey 7

E A 1

P9 7

U t

o 7T E YM1 Ehb e

1 I

6T( T Rl 6 OE

) g 1

l 1 R C

t 5

6O

m. Y p

6O DBE 6

)

d I

S N 6 TB 9

9t e 6 X N TEA B PL 0

RY 5 n s

6 P E I

1 DE B 2 at 1

1 DG i

e 1

E ET EN R h e B

OI LI E BE LP 0

( B AC 7d T T XT M (CIL

- d R

BR A l

T t p (EI 7 e

(

L DLB o

9S ON LE7.

7EW 9 r YE U E 9 em 7I P EEY o

7 LR N DM 7 L

- e 9ES7 9 L N t

/

Pv C

9/ H ANE N E Pa c 4 E

/

l I

N9 o

t E AAi9 4 I

/

WA H Cs e 2 HS T9 2 TO 9 Cc I

E 4 T EHAT 4

I N S S 7 '

Edb

/TEINN 2 N N HP 2

N 7OO G E

/ T N F

( nl 7

E T 7 FI Es 1

/

1 T

T

/

(i TH GV A O A2 7 r NA O 7

2 r

N rMSEOY eE GT 9 sw I N r

ai EAT NI H1 ENC 1 9 o l

r GI GT e

L BI D t

l t

t OOR c.

M

/

R t

t t

t i T ES E LE as t

uL T

eEI NN nt eT N A

/

eI 1

t t

1 el I S S

en L MTP DND LT 1

B r n LTMN Z N LRT E 3

A I

me AE o

/ t I

CM

/7 em oRRI R R M o

TM 9 ni oD RI R oU US C

C CIFOI O E E CI E

r ot CN EENE CQ DS r r s IS i

T C T EL

- T ecd A V CAC E PUNGN EE E

eis ENP t ue P R PNP t

P F P en NXCORO NR NS t qs NO UA COE NP F E et t

OS xes NCS PECS NAOS Lio s c NEACOC NACA I r a g

r e

eo o

f t

r t e

n fl od a

u e

p; sd r t v

a e

i i

s e oi s

t s

sy 4

n ut t i

c fS iwt At e f-C nt n n

eb en c

eio etord n

t ei e

eAm mi mn t

Hn o gf ri xt r d

s o

t oA N Pe ND NaO t

mc UavE oi h

sdlen o

i Lo et rad u

Nin s

r r

r o

+- C()

t r

e e a i

po nt sl i

t se s

s ua ot nieb e v 9

dt mpt aa t c eq l

t n

C ms n mC DRinAaC1 As So o os e n z

n n oeg s

3 P

l n a I

ad oReHi r

e o e i r, D l DCos t

l n

i t

se x e s e yE v s W P EiMl t l l sc ye n a e

ncaPe 0 o

e e r o C

a s ai g

h el n

aiunCt r m dhgr u e r t l

c 1

i r

ua d r ulpn e e yE nd n c e

r t a it a cO ntnnteEnm q

a wc e e 1+

vnn n um ooa ol rhe ad oo o

em o

a oox ei e l

h REiHPTt MACL r

t -

h h

n o

MCCEt ot h

So PMMCA

+&

t i e

c A

r

,e uu eR sf e ta 1

ner a

b c

ERA 6

6 6

D 5

6 E

7 9

D 9

g E

1 nc o

i s S

t 2

bL O

d 1

ei e

s L

e d

sy ib

.C n

e s

s e n d

P d

v i

n o ndeC e

e ei a

i vt cE f

R i a d n it eeo n

t n ci im d t e

is d

e f s n f m ee o f

i f

r dsi l

Ee t

aa e

l s

l t

Ce edg sd we e wie H D snla l

t a w i e L

" mg u

u n

ei ko A

a l

c ep e

n e

me Wb Fic 4-d E%.

C n

ns a s o

eP dcoC7 i

t e

9 -.

s a

srE k

r p

t i

u v

. a wn acu n

l en s a

ri t v

sdn o

mm e

3 c ae E

e wl t

deC lb ut C

H l

a s

i a emAiL f

i H

p u r t

n s p f-r n

L m

ed a

l emed n A

Ml iSia t

ys

,l E

8m%

E am B

f E

weg I

E 0

T o

rt n R

C 3

Y ei i

nin1 O

2 dt d L D C

NY f

g L

2 n nu oET SE AB o

EvNC e

P T

u el id dg M

S e

l D

HS 0

m c~

U n

SAI E NS 1

e n"7 P

n si s

S AL)

EE e

a e t,C E

U r

r a

C H"a e I Y OF 3 C

vh 9

)E G G

snU B

ED

)

g

)

S O

a N

U r

e oC s eL 8LE R N 9

s c

9 F

o OUNA

- R P

n

)

)1 7-a efmy 7AC) A 7 P

)

I n

7 7 w9 7

2 1 G DD Y UN;EP6 l eb 1

1 n 2 0, o

S N

1 o

1 3

6 N NE B 6

k ev 6NE L 6 O asod p

6 I

A 6

e 6 A RAITO1 D NHMS s

6 sLe 6

I t

r P ph 1MEUUCBC L

1 t

e 1 i 1

R Bs n n O

BnCmg B

PNI I

u B AN eEii (PXAB E( A e

o RI

.R

(

( niJ

(

l E7 i cn 7 TDET 7b e gh 7CE MS H9G o

7 ot I

D ED b 9

9 C

9t eo 9

/ET N T4 u.

g(

4 N VE O

/ rh ng

/

CE aSe

/

4 et ii

/

rh 4 E E

/i ous

/H EH O E

42 e v

2 LB C 2 hfi 2

2 PH/

U7

/ l 8i

/A O L V t

LT ST7E9 N

t 7

7 eh qm 7T F 7l 1 c OEINRWrR9 a

NV LI r ec rt EOR e e rFE N

r rONI eR1 edCef eI T

e v a si t

WA t

UNSt O I

t eDe t

t ae ae e2) NISCl t

t T L SR eh s t

9 E eC ter eA E 1

2 r es LC N N T L

sdf LN OE E P T Le s

i a

S M

AoCS ofru w oF N RI on e e c oO I

EN Codfe CS T, E GF r

R C EU e

I Crd CILO CI 7 Et dt s EI 7 L p

N EE G

i i

eh ECcc E AS NM 9 N ca n V 9P A E

NNpw NQPCA2 N"Aodh NR19M H TN H U R

ee NE NRrh NU oi EOD9 CINNTA t it I

.l s

n sa s

s s

n sw nm n

ee n

o n

o ch I

it i

t e

or o

ot f o i

o o

C r

oi s

u i

nso oie t

t n

a t

tcF c

Pg c

iDH l

t c

ct oi ns Hn Ci sf o

si An sd w

enAo A

oisA e

s s e rI sv t

t dt Ne d a em et p s Lo Ra eiAdANotf h's r

.Na ut ei r

r l

i g

v u

m e r

t r

e g

u eis d ast s

u g.

s c

sl i

ai gga I

s n iaiv t.

d d

o ad oar A Qn w a nl i

n a f l yrdi l

sis e

u k

i rf nl e vt u

e ePAt ne s i

ue rec n

ciket t dn uer l

=

e e

u morhrf c

u n

g e

t e oAm v

o i

na uh nmo N-n f o e e a

osa homirFTCTFCTTfEC sl o

C T-e r

cerTNI c

i r m d

mC T

l z

t t s

eI e ce d

a-S dhov um nf t e

o ae o o un

-- PleTps -

r e HRN DFa u Ci S, o f

c Et e

t n

eR moda p

r e.

ta d

e 6

6 IfI T D

7.

79 D

D D

e E

e, E

E 9

1 l

o S

S t

p

't S

a O

u O

O 2

m r

1 H

.a L

L s

s f-e L

a d

C C

s l

_p C

e ae p

s en fSea d

i n o h

nly v

ei oP n

al e

vt wC T. ke a

R y

i a eE

.a cm t

n i

3 ci vd t

ai t,

v n Kn aEo pm is ei e nCs i

i r

n r

l s

Ee Cs r

i i

,e h

He7tc t r t

9 ua t

l Ce Li A e.

ot n

f t HD ae n et yn o

a a e nh e v u I

7 L

of m

q

.m osdd t

1 s

e

+

p M2 i

e u

e

)

a s

m q

e 3 s (ACb Se S

e e

s dd f

a na o

h n

w am tn s

o en d

t n i

i oe e 7

e

- =e t

v vi 9

m e

a edif u'

ict s4 p

- b.

/

r et i e

i

.e f ena2 ud M. i. f l

- v s a

ir ewI qe

/'

a t

v. h a rd a

v n

b ois1 ed eCr y

E i

oid dv e

d

.st ce no

.n a C

od

.s7 nt ar i

H wl 9 nip cn nih e

s el ep yi e e

t i /

oc a e adt L

Pf 1 s.

i i pe Md Ce1 ce t f o

Et 8 ad w'

Sb at h/

s T

E c'

T.

e eg ES e

1 H

E S

C E

a cin TU A

0 t

3 n

T~

s. O N A

ETF B

d ae E G 3

R e

FCO pb d.

L W

E rl E

F E D

L d

s oe P U eT i

iSW TI f

s M A E

B ef T OZ EF N N L

e n gi n ta o

I E v

p I

g eeicn yl;p OY 1

V V FWA W

n x6I R

G AO a

bk a ni E L u e9M1 RO N

ei CB 1

c H

N h

r R O O c1 OMWI 9Mr S

t O G I

) S e

DD' t

O c

eou nt 1 T g

I

) S 1-L T L er ORE v wqo n e

0EY es a 1 N a

I PT n UUA T

8 h edr

)feC 6 L A

pOHE C

5 l

e M

)

a l

s R B

- E P

1 W

n e

7 2 ebO9 LD C CCSH

.A 8

o 7DS 4 r mC 9 OE s b A. p a 6E r

1 1 NE 8 oeE FS D R TR E C R 6

ea 1

p 6A I

ct sPs 6V s

6 C

6t c

R S ON O AOHLE I

1 fpaCe i

eN E 1 O 1 t A L A, HNTBH B

e 1 SN n

ee ocrEg BR R

B EE BeDNB C

]

(

T ORUT).

ca n

( P S

D LI MEE%

mt EI E P R 7

e a nya 7M

(

(I C' E 9 h

R U A NH soELL T GE U S/

t eoac 9I o

7 F I 7

rh t

ot F

i I 9 I

CI F E4 odi C

96 E

/9 m pd E FF1 HS R ATO5

/E rl 4

S 1

/9 1

is o a 2

mfeDNH S

E 4

D 3

[ I E t

v s 1 c i - RC DDPDFNT/

9

/

os 1

1 s

upc

/ A 2/ 1 N cwvEE AR: EEONO( R1 e o N

7B r cmis A

7RO 1

g s

r r se eRCEES GGE E E ROr n pi e y eT N

rEIT eeirP N W M OI LAOA H Nt aodt h vt BWF EFRR EF e eB A t

t A

t yp genEO t

t t

LS F T e'.

h ebl eD eMT e

t t

n r eHCI E L E

L7 cdt A A.H N ET L O. E EI K

9 l e ada L

I LEN

.La nmT N VC L P7 v

n oC9 CE h

Ao/

ateie WO EE O i t oEM oc 1

cl rt o C E9 DU Cr dmEI RDFABTUWCTC/

i ci C

ippai s

E t

e T

E2 1

E C%Ee nmVA N1 h onmd NT2 E

I y m d pd N H9 t

N ER O9 Nt ioET a

NPD1 N L gC R S Nto Pcaia e

d d

n n

at a r

e C

emo r

aepa s

l Hn a

g bsrew t

e n

n ayt f r

r t

Lo a e i

v k s at sno i

a i

se r

s es dt es ot adtnicn n:

n a li n wee heeio:

ad Pmta Pamf t

f e

f i

i n

Pt t r n

Cnu Cueu aa e e Ce Eoq Eeaqgsraw rn r n E i :s r e s

c eid ed nk pd ua eia v a haacera f e h

os 1 er nn r

n Timla ph So 1da Tei c

,e eR c

d ta b

D 7'

7 7

~

79-9 1

2 1

s d

s es e n iv n o e

ei R

vt i a t n ci ef m f

r Eet Ce H D L

no itau lai vE' CHL y

m E

L t

s Ue 5

U il n s

. H E

E n

0 i

l NlsT N

Z a

b o pe 3

1 oNk N

i ef N

RI D7. u at I

a gf yaTE e

l t

t a y s [o w

ntom uo b uCE O

AEN9 n r z b

f l

i o

aPoi u

n dUY S

I L A9 galo 2

m r

gd o AgedivDO ER L

MCpnea O

1 o

eet dn v e I

E P MR Y Erg nh r 1

c ai enSled NL i

t i T1,P is n e

t s s e

t b

ui nOP el sbl s a pi C M BE A PI 3Ct dr r

o o e o g

F L

n n t e c a

V CI REe ae ny P

e r aa a

srl mtcO EOI OEB E r

r s

i nh o o

)i t e TT n

eoe n

D o gt g 5 sdn o aTY S A T

A B h ut er yi mlpiv E T l

n e

8 a n n c i

c o

et rSR EG ST HR vt cl e emt i

6 wa ontnTOS p

h aia a

t zntr h "8 I

i TO

a. 7, heb h h er s e oI TR T I

I 6t n r s

S M HP n9 e e cM AU E. MTEC9 ry "Ui t

ii a r o". 9 B e i pb t

a T

s ona n 9

1 n o e

t MDOV t

R l

t eb Ni R Y1 n

eaONCNMO t c n1

( mtae I

g gf m i y

,cpd".

C WLB 7

v r nr o

7 ucv e o 9dm o

iaeCA oa v

MI 1l f e

i c )h S A l

9

/ nd C

rdt t

ot r eOM A t

PI O RITES3 h

egtcs 4

o a

a a 4d

/

o n s fr aa aie sCER C,C O NUeordu r rn ue 2

gs Q

E paPnn z

ie 2

i

/ t e ut sdEE G E3ET l

c s

9

/oqsrnN E S b t un s N

er gC o a y ah".

R OYRNA TI ods oi r

9 S

t nEigb r

e u r

.ir n

e n ev o aN HRBENI O Y ce a a

t ni N

ni G

t s cl et n t

rt n

TP t

oh o nt i oo ice)

D B) TP s

rOife c e

t v o r Lco d )5 t in n

t t

i v

GS EM2 S GT i a e apt ec gd yi 1 NN TE i

L ye ain 1

rt -

- E e

ot mhCs Ln nn a5I RET VINI sr i

g8 N E L P M N S B b r e sh oniz o

i i pept En omb at t

c el s A o, b teiwc Ce a r

a C

ai I

t 6 ACP E I S dieds6 u

eo e e Ewmg wsl odr a ne1 MNMS P ER s ci t Eacrk 6

t 1

S El l l avr Nt r u er e pe OOYB CS P eo nevps s Nnest av R C C B ( E A O "A i rwprf NbfA e o veu ai n

nBE Aodsbt NAdimi(

h n

s sa:

o s

y d.

i es i

a t

e d

t i

rl t

C gh n

l Al al a

np b

an U

e i

ik t

sim mN m

Hn t n a

as n

r g

a r

i Lo r

ie ea rd el e ei e

ea g pi n t rl gnb p i

f ve m

eTi nOen oa m

f eh a

ri dtn a ast e

i r

d 1

+d cd di a.

ga t i pt t

l i ad sne l

e r r ud c

n P id p n n plu ncTg r o e e Cga m

was ca n

n n

nt h nhnyo ni ns a r

i c

ng I

rm Eip d oiel i t

r t i t oi oo sd i t ir t c ee m

n l iwki at um eiu P

ut c =. a b n a W a

n nez ha o

r o C

o aig e e yli So Tt hi -

t mit m tloa t '

E si f nt c

t r s

l or s o

- pm Pa eI: pe vp h dmr

, e e

e eR 7

Cu nne enR T 'u e f t

t e

o a

c 9

EQFoRdI 7

/

D 2

m 7

8.

9.

2

/

~

79 D

D s

D d e D

gt s

9 el s

E P

E a

s s E

ub E

n t

1 a

n S

wa S

s a S

r v e

i Cg S

d sn 2

a m

O, st noie O

is O

u n

e el Ei O

1 d

seienc L

nn L

f e o

sd e

L a

d ob L

s leewi C_

e ee C

r t r e n C

ee s

C r

aut e bb iwou s

s w c-e n n

d nntaI e s s i

ns f o nq v

n o o

n o

r aa Ph e e e

ei in a ien) r R

t s s ae abig3 p hh.

Cs al r

vt r

a vrd h

7 a

i eCro s d 'P aob 49l n s

t n e E

ae r

9 s u t

n r

n e

ci es h m

o a hit s

e s ei cHtc;V f m b5l 21 iaF n

cae ff

.M r

oc eLes..

l Ee C o. b.

e)i ned aip oo f

zt a

s r t t

ne t P wtcn n

Delpe aS t

Hisd r 1 ieOeC Ce r e e p-mo v og H D Lp yt syoue o f

t r ly v

mE i

,l n

b cprp z

a nv n aor edeg nsee

'r l

L oet m od eoPm nhe Raoi i e i

s.

t t e vd di ue cie Ci at e Ct rt Hppe si p-eiL P Eo gd c f

ev Ba%l e

ie)C r r s

r em n

fl ni at m

c Dv2Eoa Oas LSi m ai n

e e

o e.

e t.

t i

t t

t a

a a

a u

u u

u A

u q

q q

e e

e v.

d d

d la a

a a

s s

s s

i E

i i

i e

e e

e s

s s

s C

n n

n n

H o

o o

o p

p p

p s

s s

s L

e e

e e

R R

R R

T yd e

e d

s P

l f

l h

e a

C C s, ny l

e e

j o

i El a

0 h t r rfs w

E o

c ah e

s 3

t a

dt rdn ga eo e Pt e e r i

t t

rh eh aet ueo f

7,n e yt r 9iN donc Cat hTom eh whaps n

n ssi o

s n

nl en Eh g pot Cae v 3

t ai 9iP a pd i cnf c a h

7 e r wml rEl r o 1 a l

e io 1

C emin h ad2 vg 8 toe cEee T dran9t r

".eoo l c r e

s n

. rft 9i o einp g

wi n

ap oe ch e

t n

r e re n a

s s cd e

et r, P b ".

agoI r

) t b r ei r

5 c ioodo P

ut n s o e

5) n gna et d R i 8.t s

s e 8 eoDt e

i o

u e r cevg 8

t i t i

rt av a e

vt nh 6i s er not an 6 s

.esi t e

p A m n, peMht i

6ifRumo 6Dah edpe~

r i r n s

uo ei e

l e

n ci nDe) hoe Bnt 1

s, g d s Bewtodoomd 1

h r a

s R

O" a

os u a s Nm e

(ht di et t nt aot u fstnAl r (i

dM" e

hd 9deddCdciof 7t P 7 7 nPentad 7

o 7

n' 9 9

mel e

s eCmon d C

9 esP7 9 h a69 a

4 u umuet di

/ e

/

/ t

/

oit 1 4 eEude 2 s cr o cc t

iC9 4

E 4

uea v

2 b c emo i

9idfoiwfdh 2 eE9 2 b f h

s

/s r

1

/

u g 2,

/seo N

t

/

9 ue e "s.

adOnt 9 y r i2 ahdsl e

9 e r r s e n

ot r N

t r ah o rb gs rh s pt eawhfa ec a a omipa n m e ly r

e t

ed

,f t

e h

t t nt a 1-net asui n t

t t

t l

eioPv u t

t e nls t

oidras r e e2t a

e t

r e u xu oa Lt sOJ Lt egwepm L

as

.a c I sis so a

e at o o e o ot nh l sn n Ur oprnrh oz url u r c oi a

a wa ViG as at Ci b Cid s pn puipa EieEeniuM Cie e CP u

ni c

e r s

ECPm Eicl e EarPnl t ncc N gtsCal ah Neae davse vt NECr Na oun r

n e sh uMrat NodEMisn NRst ri t h e

NDET N pC N i wae s

tn e

e C

b d

n m

m is d r e

o a

a Hn l

a r i u

r r

Lo ol d P p g

g e

i h cd e ne c or y o o t

dt shnh aci n pl pr l

t n a sgat eViF e

u e

ad e

n iuni c

d mdf nh n

n f n t

i t t ooh e

ad l i e e r ri t i

oa r

i a

n pw r m oht c

i cwt nt pna.

t c e.

i t n r oh eo st ict r

s s

um pd r pi g dit t n eidne ane dnn t

o nh i

em e a s r.

e ae So zimezem spr o eim mi, mt aiet s

,c sl i

n t

cvc l

n ea ei aaul o p u.

i, leb o ep e

eR crOr ngcp pm rt e

ai n

ct t

r om moa sige naf ir s

i a

i D

FevaD pod Fodi I c I

0 1.

2.

3 1

1 1

1 l1 lllllI L

79 D

E 9

1 t

se S

R o eteh r

O 2

He h b a 1

t s

g t,

sI igr L

l e

s ni eit v C

de h ws o s

r e n i

e p

t l

i n o d o n vP v

r ei nr oor C e

vt ap R

i fieioE s

i a hp a ch o t

n s

t ci in aewt e

f a ud t

f m q a gh f

r an e

ng f

t Ee S

d i

,iu rd o t

s a e r r Ce Pn s vegab H D Co i

Et h we em.

i s

a cor L

ah ur t grwi e o ;d s e est ts n r

uen pm dig av a pr wRn Cim At sHlo n

e ro n

f o

i ta e

u la v

s.

E iem C

sr ne H

ot pt L

so r

eh Rs e

s a

g h

w m

n e

)

w-e e t

e eh gg o

oh s

,s in 1

s s

y n

yv 3

v 0

i t

i i

og ef 1 e d a8. ed nn fr o

3 t

t t

i nm9h o

nr e at 8

,sf s

t t

le gi i n r nis ao ygt 7kf1 eR f

ns s ays a

9t ad n1 d v

o r

i i

n e6 oyats ri s

l aa t t b.t memt natse d1 o glurt J r gerh

,teont t u e

l e

ue s a1 i

aBaad nl r

a v

4 n rdugeme n

ni et h n t

.eedHieivm iBcnJ oiyoisd u

ot a e c 1

t 1

n v

oi n s yl wC miRn e

emt t b r nt o (.

l yt obtd s

r Wednh ea t

nRucuviEndt el a e nh sR e e p i a ". )p t od bsj s

e g

e r npaRicRtmdHmsHr s

e uJ evNateciH=

r n t

l l

a v veep ie r

s prit i

e s aa E

P navse e

n

) mftosmi h a o D n. 3 e eh h

8 mhe Hmitoemlytet oyoRNsit ee t

5 t sbt s st e

o 8

l ront h i

l i

t h o o es oa s e e t

b r stsehcoenAdh h t

o Pio7t ri p

6lya u pfrerdea n y gC t t

i nivt o c t

6 st ccr c n a1 m s gd c pd

.las f s

6t af nr mio i

nmRiEzBms eogn odl o e

1 nn t

r e

8 n a t P Er gsemcmcu b, e a 9 iogn e

ae o

e a ro pe R

BsMl nr t

i sirCnaCou at c en( o ad eEi r9 t

r

( e a a i

n o el a

t n o uh a gn e u 1 i e eouo 7 c erf o

7 r e a D P. d t c x niop ph c nd s d oi g9 d r aeNcC Np r

C 9 pP r t u

er oEn n

,d Lt nyr/no grNdEN Ph uoeCeoeo1 i e a

sCt est ob o

/

nat es viy abm 4i E

Cc dseI s

/gExvztiEr r n) n n)Ct pt e o

3 d yE ths s

sor 2

e ni ri l

N sRr2 cs3 Etoe e eicueBo oNf pc eJd f

9 aefind o e c1 t t

e -

e ui ht t h o a uefn l

N guepmHc3 8 o vr em) ea, yb o t d r r et a pN o e

i f n f

f ngAt r st t rd yvoi h

n8 o yi o t ePocf y a. o l l

aeximdo7 r

t n i7 t

s t

o nc6 e m6 eior e4 ch s t

i s s eCs a. s ol t

r r n f

nt r ay pe n at ci ca i

u n

b a c a 1

l 1

ss -

LEnoqse r d i yR IonoPeBtc gB tc ngea3 agto r

i t s n

a e

s i

n o

y u

8 mnci o3 mr -

oeie nc eesl t

e a C i C C o (. an( aens p7 ri a8 l

a pi 7 ned r rt xnr Ch sdeu nio t

8 pt 8. r si ri r

pret su6 o ril gcr pmmEiEEl e

f ut ca6i Et iv acoI r l

i a p9 e9 r s n uNdNem9 ee9 e p e

e. d 1 sf o t

t Na ue ns eas r st 1 f

nBenoieBaOBs h o e d

h m1 h emh mrfeoHNaNh h

e( pecd r Nh yt cRt r

t e1 t t r t

t o

t d

k r

C e

n e

r h n a c, o y.

n5 H ~n o as wc t

aE a

mn Lo n

_d eu o

r o uie

.d q i

dt eHabcesocie t

n a cst d ad cdigda ua n ntsu n1 r

l

,o n

a ia e oi v e fso e e l

vh s

c e

r m er nns4 Rid r

oi s--

ue um disn Pqta o

nt e So a a: o ---- Eha e

Cr u znt n

l c

fi

,e on uu a ol k c v eR

+ hie e

s o t

sge t

ewih s

e a

r wwb UoRri D

4 1

I o,,

79-e a

D 9

ta 1

g E

idt 1

cl n

S 2

l i

ie.

O n s bl e

d a

L i

ss dwu h) r e

e n eo n C

s a s

ti i

n a wI s v

n o l

ei esM Ct e

a t

n R

vt vi c( e e

as i a mt eeh t l t

n r r e

ut na e ci s

cdim our e

e sh T m ot ug lil i i

cw d vqn I

r f

Ee wd e adr e niei t

Ce enc nl b nan wia H D s

f n a edu y a

i cn a o o s

oa L

e w

wiw mMl t

e u R

a l

iv o e r at t

l en oh o e s i

Rri Fct n e

n t

o a

e i

t i

s a

t y

u a

v q

u ip e

a p.

d l

a v

aet s

s E

ia i

u e

eq s

C s

e n

o H

ud o

a p

L vd se en Ra R

fs0 s

e t

t a u3 n

0 ea. o t

ee 3

t rist s

a r u a yb m p'a, d Pt s

f e

s rl s n

u, t Cevis el o

r 7, r

e e9 yst Edews 5

c9 rej evfs a e

i s

1 n1 uhk ot a f"a.

o t

c h o c

g C 6, vet a Tr pmt le a

es eaorb unse P

o r

n

) nh pe

5) t mo ca 5 u ci o

8Jto pb 8

in eds ut p

6 rl s o 6.i soi s

6 ea o n 6t moih r

I r

rt e

1fut l

oa1 e n R

Banei".

B( g t 1Pi l

(

aliw ea 7"d m f s

.s o

n 7

et o

9 ds

.l r

C 9 sPe e

ei

/eenpf o

/

t hl t 4 r eo E

4 oCt ft 2 e nie e a

2l

/ c rtuh 9 "c E n 7 N

n 9

el

/

t r i

9 e n c on u N

e r

n9 m r o n si o e rh o1 e c oe t ot u

t acrdm i

t e

yta 6, c e

t L "d e r bt o

Lgolinf t

edned nt t

o ve ene ois nen Cl r mud Ckt umo oi r

c Esu uJu Ea osu Neqcec Nmpaoycl l

l N i r d d 'w e or n s e N "r r d pi s

f at o

u doe sh t ui C

ehh aw t

i t t t

f n

pt i

Hn Jwi ese c s

k e n Lo a

n c d" it eh a l

i o

dt bt d n a emi dnr ad b

n l

oo i

n t ci u

c o

e o ac f

ee n "r d h sa cm l

s in r

do ea ui l

m wf ui o

e lu h

o d" eu o n t

ns n So hega yia c

slvnm o

c am l

r

,e soi per t

eR eseP mt ee t i eeC ehh t

l a

i r D

F? mE Ebt t

5 6

1 1

79 9

1 gl o

t y

n a b

2 i

)

ie c C

d e

1 e

s b p H

e h

d s

s t

e e S P L, u

s e n r

ns i

a. C g

i a v

n o ei n nEx.

n d

t h

e i

"t et R

vt o e y (e e

i a t

t u

i n

mb s b o ab t

ci a ed r t pts s e e

mge e ot T m s s r ash.

n o a n r

onutok I

l h u

Ee f

r l

s n a gd o t

mn "e

i y

n t

i s

o u Ce inw ski d oea r i at n

HD nt bt a

a ce e m n 's y i

t L

d e-ih s

i ol i

s er ut aomCi trd a t

bt b

pi taPeEa r

ois s

pmt s

aCt Np r

e e

a r o sa DEdNc Rps n

s t

o n

ny i

er 7

l i

ma 0

a l

t t

u eE 5

a nof gg(d u

ot t

r e>

o l

cnna s

oin a

win a g a s

v ot a

n o

a ema g E

n t

mmoh Ey e

C t

r t c)l i

s oe st 7i af dt n9b s H

b nir e

a e aivo cc L

aeopeepu t

s h r e as Dt prRDci r

e e

1, r,

a LE N S

s e

e e

LI R 0

c e e rk r

R g

f Dh eah e E

a r

. nl I

T E 3

I u

o t

.oc W

cmg c 's T

t o l. e r

A B

n nd LC u

.ofonfe l

M Pseg n

MeieN a

o PEN.

o f

v n at Ot doc T T RC l

iO e

Ce i

E b h sd CNO7 e a Ehl rd nan oeP4 rf s a n ENC 9 6

S t

r e

od rDOE el ab a OF 9 pihC v aO rEFDD.

1 e nel c t

Tife T

e i

hl l

t e

uat E Docun d

S 1

s A R i

O g

rylce MT AFN9 wd b e E8 nffa d emtae e

eh s uh MA l

e nt l v iEE6 a

TOE 9 s

oo a s r h

t P

n

)i h n aont ann O D TPR R

) aal i

A i t P

S P1 5

8 pinwt S EUE l

a 5t et e sbfo sl 8 ah eaniwl ai C U D AO o

r ia a

e OE F 0

6 dnn rNTB p

6 mt s, he dt t

e s

i A O NS1 6 e r o e MO tnt vdeilowdn CB O s

EN 1 h ois s

6 rt o

EP R Y ot e M T NT zl r

e 1 oa t

R Bnfncteo r e r na sie EL GOER Bec nr a v S D C c

CA r

e p OL NO (i onn Ph ua o

NL

(

prgn s, r n t

N E NU 7 uet e CL t

I sioi 9 ea cd 2 ga oinpo NWA t

I AF o

7 o

t

)

R 9 s r aR OMPO c

REON C

/r r wr 5 nc s o t

)

dailoy

/

e 2

4 amtyr* C LWCA n

3 e

E O CK E

4 uf 0d we mta c 5AL E

/l ar i

e t nee k o

- 5 J

2l i

9 ag n

oPsN TEE 2 pant 7 a c o nin 8 BU TsY 9 iwni oNRliW r ot r N

/

E n

E N

crlye 9 gn efiun qio 6 AF A o B, r

i r mi e w oen Preefin l

r n

l es t

6 ve a

oa n1 TEi iR dpo ATE t

s t t

)

e o

Al T T a7CF miBDTS DT Ljneknfi5NOT odie".

Cn a st t t

c et r t

E eet I

t i

c -

I I

Eobdi entet e yr t

ab o a(PE N NF o e u cu8 US G anHdt L

cl n

os e e s e (i

e t

t a

z R

A or i fi7CD s

7 aa A, R CPmqam6 MUN t l 6

a Cafr E

E a

9 mdec l. obin n9 i

oaa 8 oPr epa a/EU C e eb T

b arh b

/

I EPl sdm1 M A R 6

r L N 9 E N C pb E a d F. d d 2fCuvt ph g4 E C O9 s

mu oB OT U e

an aa

/ n o eoair2 N

Nt t t t

I I

Nda 8iEsLh cwO9Dt C1 T NEiSfeC( CS D

/

I sn p

o l

i l

i i

t C

wl h a

s c

ur s

Hn t f eye ia a e l

Lo d h sdi ut u

nt u ad s n m

eas e i

a s dt eim m

el n a etrd e r t s cit ne o

ad a

yvio ag c

st t a e

n b co e e a

r omron h

a c

tat pt epa r m dndnh mm.

t t

um e not n

a maie gn e

i o

t So pe al e n o m

e c

og umbt i

l a ari e.

t

,e e a uin pn l

eR vn hr nl o

u e a

a ea pf eaqt ml t

vet Dmano I

p cit er a D

8 7

1 1

~

(

79 D

9 E

1 S

e 2

e et O

1 h

h a s

t t u L

d s

a nq C

e e n i yi e s

i vl n o ed d v

ei dt eA e

a i a v

u.

R vt eid t

t yl i

n r

ci e

e c v cn o T m e pi p i

r e

Ee ganRn.

I r

pd n

o t

ie a yi e

Ce erdh a b

l t l

H D ba et t a

set nn p

n oe L

nn emMm r o eh cpuPl e

e n

p ecCm n

ol o

Ct dei U

e t

Pe r

s u

s Ciun e

p n

n d

n i

i n

ono eEqo su omdlednee a

o e

o t

i t

t a

t g a

r c r c a

u s n z smt niht n at a

u oiat o al o i

ri u'

q a a vao t enc c chindi o

o w oimr e

e l

u i gf r s s a

d pl ui osmed gs r t

a rt v

paa oof a

s' avn ems o

.t eg E

i er n nn ci ie s

d n t

s.ol nt osot e

niin e

e C

e i e, h aivt o s

i t

l at oa t eo ai n

,s uduet ad H

o ut r

a umlodaut e i plau sh p

l L

u t

cos s

nvain r vi aecuoGoes e

or e R

Pff t s

sl nah o

S LL d

ns rn es NI n

t t

srnl yt RWD O a

ner a eoda 0

ci r ceeic n c E

N T sl nt vri e 3

ae CS A dio z oa f

l a

entnHfe j

nco i

I c e r, b NE T

r o

wcir onc OINS R a

e a e yd e y e unpovs CL e

npt 7

mo MO d

tagto s "n i

1 c

m eiasl t

e e T T RP n

pwb".A o

e ogyr mol O OE amlur e

Cinloutye opt o g

t FR sr a h

a ni a

H H pefceTehl ov nCin P

t s

s i

e;irTE EY

) nfeoEt smSa".de n

)

we TL 5

e o

e S

l 5

SNAH 8

i molnyt egt h t o

8 t

ce e s

p 6 o gi a e nmtsrirOI u

6 hi a t l r

RT 6 mmelvot s r aiicM H PN r nSin s

6 t l pi rih omiseni l

l r ed P

1 e

1 st t eh nME OO Bc ocrb yh R

B r d R, t t el i e o n u oavt aOLRM

( e ce al t (faHdhh EP o osC T PP 7h el l e t

v ne g o

7 ah rne t

et d AC

/fh ct 9

oiemn C

9i oI s gd r O E sf h

/r t

t n neaCH EE 4

adiid ofonnh t

E 4 e n

yd i a d d E T HE 2

o 2tiodt not e

/

N r at e 9 ct t r nt hdnNR TH 9 i

/ riei o ePte a a caa

.in

.w N

rdz e csiyssNENT eauCl anu z

t rt s

. t V

N a

s I

e n

a o n )4 O DI t nd E s ni en n an t t e

nimSo t

e ye t a ae gmio DRED.

Lmah et e

e neb n i

i dl mi dt L4 glpnao v

sam 5 E S t

r i

8 EE R R oe a e ogc r

t t et z

nz m6VT U E Cl o

omaifri i e v C

prl i h aa E dl t noe no6 i

I cac1 E NT C E

eb e l

N "m t acdnd na eda s i

orhBEEAm nge C EP r

a n N a y e u gt I i r nen r s Ntsb wAol cot ( RBCO N

cer ama i

s e s

eh s

nt e

s oooh e et m e

t t t yf ot i

C noo a c

t i

r o

a r rh s se t

el r

ud et oi mpegdotnp ein nunv Hn r

t ni t t

o Lo p

emir i

p getsPte,.

b sa e

at i i u

sv s r

t i

smnt c dt u

a o n

da o,s i n

eh a n a S

nt i

user l l g

uioymid a

u. n c e omi ad e

l ml s t

oec t

ee s n e e e

ear mcr n hia n

n bn cmgnaia m

m vl eo ao o s s i

t c s rl inet c

t i

nfop n

cCe r

i a

l r

a ab e e

t n

vme a

na oeasl edm um g

av mim v

i n s

o r

cehi o ce s

So n

e e nt c ie n

s ey n e' o aisd o

o s

,c s od a a

t l l h r

c u r eipr ui l

e eR M

a napu es vt i

lanuosv c d l

er mo w n

A e g c pb e t

l vo h

vear en l

a 7

lAatEs" a

9 D

m

/2 2/

9 0

7 1

2

79-9 1 -

2 1

s d

s es e n iv n o e

ei R

vt a i

t n

c i

ef m f

r Ee t

Ce H D L

t

)

n e

e n

n m

i(O l

l o

oe l

gd asE i

t r

Pa eoeC ta ndt c e u

O a i yi f h Cmv l

l f t os o a

E "e p o l r u o

v et_

E mveeb s

oib nia t

C r

as f udt nl l

cl oe l

H u euu pw tpxoms L

nEhi es I " ss r a d".

r E

o ed r

e h

e d.

s G

H R

" s v n ow s s e

s fe cm 3

u 0

s i a 'P ng N

T

, RE t

t t

h e o n U

E c e ri D "T O B u

v

. oe e el.

c "t a) t c ese c va o

ecO gr a. fl f

iefr L CF O 1

nsi fe2)

C b

E A,N U

s t

ne o

a r e[

a i

E OFEDT i

o r

p xeC ngtni t

e oh dh c eE ob r 8

e rsfn nimW MEA CF EO c age efE E C u

e t

an l p 1

Miet f

V H D T N Y xrl a n

se ut nlif e

E eki m et o a e f c C "].

d gf TO N N AG e

h s oe wo g

oi X B E o

n i

e T s ]s t

m,. i p t EB Eol s i n a, s.

)

d S[ P 5E A O HN H wh vl r s

a i

.l t

nfan n P

t n

i l

ope raieC 5

DTS TLT A 5 f "c e o

- N OP s

I

)

ol a ot o cVr s o nio n

)

efehE 8E N ESL ER 8 o t

r E

h ri a c ph p i c s 5

t i y [e i f g d n [

o nenta rio pt D 6

NRTI c s I

8 6 DA E N HTA 6da a P"

a daomt p

e l

6il c

6 e ei CA e o n e

1 T SV D E i

s 6

rb v

Ons adtagad et i S

1 s e

1 ai h UI Bivrat Cot rt cat n N D "A LH st ei n e e RI e

fawh BA O G R

Bmnnh AI

( ph n n

e oainni C

AT e

Et e t

( TS E E E V N

( i t it t u

sidaeg r oi r r ed 7 AI B ZIN T EI 9 pom pm 7

o 7 ppntob ob n 9H RLINO pd m t

at ninnimmi V

n s r p

C 9

/

A

/ t n

n n o

/

e et yetya r "s S e f n a h ev o

pi rogga E

4. r c oh ri r 2 S P I GT U LO 4

rl 4 T EL ei e

L 2 et hhi TI N

/

2 s e n v o

/

e v

i TUWO S

C Y EWN 9 k c v. t t 9 eh optnlyis 9I

y. i n i v h tvieaad n N

/ s I

i t

P se n3 s

e t

w evi e a a c

c r oh cn rM N E L t

I ri pe N

emfaPmt ao eM ECR E REA e

t it a e me

.l r

t s cl u]dnl o

n NI T EWR nuk ankt t

sp t

r t

cE epnfCao nS eOI TOA T.

Lmr e

r c t

t P

e e sr ne a a t

Eemre LC LA TI R T oRom oa eWs*

o us ne o

wgx ot os Ltnie d Pci oO TT R O AR 6 oe o w nie ev nECie S N YP H E 9 t

t cyuCnt CCRE T OE T H9 Cgnl oe a eiige Srki o d d alioe[ acih nl l t

i t

Csc u

J R S T1 Enawi Eiieh cEo c EEI S ed nt gh v odt t

UD R ost Aa T

t sfti s n n c e F EI P t

s h f "p d e

n NNF RDP ANU1 Na noo" oox oh oE NNOP AACAF2 Nmkh n mhon" Nnt i

i o e n x o

t o

Ao Ncnemt t

d g

d r d

eo e

t n

l m

o l f n

a is uo a r "t t

h ia h

hf ct r s s

e l

i aio s

a t

C wd ad i

t r

e n

t sel r s

t nfenee Hn t

u t

s of et h t

e t

vh e

e naoms acmn v et ebod euco n neac embe Lo hi ndt r r ehe o e r

r gn hoid t

n o t

oietcpaf t r i

e mf a onotoa t

ot s dt d

wf c

ir u

nan t

l pnrh n a se n eo l

g k dl s

l usima idk i el i si et eo adr ei vl a l

ad l

os e

o p "t yc n e o gh nb v l

e r s sr n

heboe Mr ed yoel aiwleceae t

e e s c r coy s

f u t h nl T pe mrf a "a rked oo ns f nt aeelemfa ep c

t l

r m np t

r t r

t s o a n.

po i s o epeau ngwyr e

m i,

um as t

smozia ges vae t

n o

m ne s

c n n

c ei e

l S o e eh at eel ir nt r t n vvlehtoio i

cn vge npc t

na u p e "e na c

gt t i

t i e ea vgodl ee l

c et ai t i s

l

,e ai wid l

e rl i vl t t eR ano gc a

cpuh e c eksivh s aotu ns ni nd o exasohmi Mcasi Amtoepocr u x

l t

l l

a ol r ac" pn Eb ehaht s

n i

D 1

2 3

2 2

2

79 D

9 E

1 S

P O

C 2

1 L

Er s

o s

C yf de b

e n y

s i

n o dl ei e n ve vt mo R

i a r e n

or tc f a i

r e

r f n e o n

pt fEe gan ni t

Ce b o ide r

H D e

t so.

L a

wct u

n q

eee ict e

si n d

ef o f

A Roc

.no i

n o

rdt enenta e

t t

o o

t t

t n

ad aib an a

i t

h e uso de u

a s

t p qwtcem q

u o

nlo.

e e

eeOve d

d oen di ol l

p a

vo a\\

a i

e& rpm t

e ei v

s ses s

s iRr mi d o i

E nh er ee eie e

ut C

po wbe nFmdt n

sl b s

i a

y e

H mk uiaf o

el u u

t f q p

i urt pct s

pi e eHeed b

L e ao en r

t hecie RLS va I

perd Ts r ci s

s e

g r

i t n e

e mz d

n h

i t

no g

ei s "s s

0 n

y yt 3

ei e a

t n

i l

n spa p

b t

ma ru n

fg h c a

e f

oece hCs m

dm o

eml ar o

t gr mog d

s P Enfo et s

chi u

on yet h p

- e aoC nf e e pi cr ewa Cotatac cs ms 9

l v

ior e 1

an b ea o owurD Dgelr;f ec s E

s sr i

r l

l Ofpfr t

s "M i c o s e

o i s.

a d

a g

edt l h o s p. der nd ae e

no n i

a a wt e

) n ef

.ekI

)i s

r a

r oH 5 e unb r

rn ul 5 a pl P

ie

)

i n

) t r m 5 v s gd e

5 u e s 8

at n dso 8h a

8 t s o

ei n ent wg 6dfatmn 6 rh c.

- a mPs 6 gk t a 8

6 e p

6 so n

6 aa u

1 e

6 nc u sier pt d "a i

s i

e 6 h P. s dud 1ft e o Bt do ob g e c t

1 t s

1 i s

aor Bo h c cnie t

r R

BwOA B a pi n pa mga i

ri

(

dt c uo ea

(

r r t

s

( uh n s Cp x

ng 7

eega

(

e D) b cr 7d l t o

7 "t Ei 7 aioe y

e e

ePs ob" o r 9 nuie 9

n h

9 v w c r"s n

C 9

.R ms as wr 4

/

/

n s

/

i d

amr 4

el e h

1

.I t 4

t s c

2 sard sHsan 2 r ao E

4 csft l oe 2

aan a(

t u

r

/ o l

w s

2i

/

/grd y

l

/ i e N

r 9ifa 9t ds reh ms e 9 psl o e 9l ietas uc mhafh e

n r o sr n e

wis r N

vk e r

r r

eo ofct.

r v

t e

eycL e

nn r st o t

i o

t r eed mt a

t dt s t

st oe ois c d

eo rvd t l ed t

t l b d t

nin cmf ud o Lz a n

La nt a i

e nd ee ead n o v e t

i Lu ea L gi r oa o at e mee e ot t e a onigs egc n

oisl t

ne s o n apnyan yeg Ca ais Cdut t t o i f, e it il Ct y

Camuoona r n umr Erl s a Ehpn md nt r s rl i

e E m. f n n m M* l.odvpareadopa Nm Nooel Eou v i

e r os vl a

N Ncpu r

pe on omal NeMcu NCrieniw N".n aee*

sn NiiS t

i r

o o d

l t

e a

dd z

e u

s t

h f n e

C ee n r

i a

l t

f r

ps el s a

a a p

o ud ua r

k Hn sM t

Lo el cicht o.

l d

l yi a

amd w

w PP n

t vt nt t

n a

nh et e

eCC eni r i

dt de a

t e

e d p s

mEE epmtno n a t

t i

s s

v est e

ad bsu aa u

e edo c

i nio a

dnl a op c

m R

gnt o

ot n

t e e o a r

e aay.

r r m ucvhier s t

e n

t s p

l c

a sit et vh aa n

l nlin n.

o e snt e

iF mob um e

n hsbro ne sm m

i ogt wr e

et am mi o

i o

o So al yi l

o e

satne t

s n d c,f g

a aGui r

r c

i i f t u

siaieie a".

C e

ol r

r

,e e

n r wou f o tn gkerd p p ak c

ycq r

eR t t s

t i ael oomo Mt l

7 nnce e e a

r hdliaweet a

9 I ear Pr r

'D Ct

/

4.

5.

2 7

/

6 2

2 2

7 2

2

79 e

v 9

. sn 1

r e

ol 2

i i s jf 1

a e

merm f ).

d s

e s

o3 s

e n d o 1

i e sk e

n o v

r,c 3 i

ei f

t i

ad s

R vt r el i

i a e

n l

vf n

v eo a s

tci sw i

9 h

oa7 e

e f m t

l f

ih n

s k 2, r

f Ee f

o t

ot i2 8

Ce wee 2 nv6 2

HD emw2 i

m L

s e e4 e

e v h1 r

t o s i

C pl r

x e

l HmiE e

Lis(

S t

s t

e n

ta o

u i

q ta a n e

i d

u

- d a

l n

a i

v A

E f-A.

s i

C Sw M.

le u e

sn H

P op Ce s

L EeM r

e 3 w R

e s

b l

0 y

l c

o l

l r

a 3

n". e o it a

t n

f wu r o

o u o

t.

ri eh c cnui 0

t l t cf e sd 2

i i fwol eisd e

o h ca a e

N"ds".

Ti g

" dnc "fh e

e a

e ada uc v P

i s

)

i n

) s s o e 5 sh e i

5 osir o

8l era 8 ewl r

6 e

p 6 "c epi 6

6 ne s adb s

t et 1

e 1 rt

.h ct o e

t Bu o R

Bol pgs n n n s

(

o-7 d"

(

mae 7 ae o

9 rdy

/Ma C

9 eotsd r

r

/ v c 4

ea ed 2Psws E

4l r 2 o va

/Cw.e s

s o N

efi

/

e.

t l 9 Ei".n c

9 al e "r d g i N

v e

r r

eiw ede s

t t s wt s s t er s e teaeet esl e r i

Ldv v n Lv ana i

e ene een o rov s oirim C

iiw Cf es et t gh s i

Ehdece i

Es i

s nt e Nai s

Nt dfev eys n

NiAer Nlcbb a t d ntn s

eher a

mo o

C d

y es n k

c t

t c

ge e u a

Hn of c i

a r f o r

c Lo sh u

nwf o a i

i si c

a b

t eoidwf wra mi dt a

c e

vy l

n a c

e o

r ei t dfd orl ad e e n

nud io a n

bs wa nt u n

e e dlo e

e a

q a,i s c

c n ;-

sl m

u l

e r

e ore anhn um ie s

o hor hat o e

So sdd spri s

n i

iwfot nr c

eee*-

a r

lbe u u e vi l

,e i

c f o u as sl l

eR pn vet t

s t

osq-el vio s

a Nreew Erf edc i

D r

8 9

2 2

r L

7 9-D 9

1 E

S 2

O 1

s L

de s

C s

en iv n o e

ei R

vt a it n ci ef m f

r Eet Ce H D

.e L

a t

uqe dA o

e 4

s l

l

. p 2

T-a n

l o

em d

e2 i

t a sn S

t a s ea C-a u

P li u

qaf PdeC-E.

ef eCiE7 e

l ohEi 9 u f

r d

a a

t r

wf y et o v

s eobwc+l s

E i

iv) s n c

WI e s "e e a C

" d e

l i Rl nil

~

e H

~

i i of p f

Cf d wmwi L

r 3 e e o e

RIJ 2 "r ncAv

(

d E

e d,

"D e

0 C

d et h

3 t

n i

N v

e ePE t

l I

o pmCS d

f S

p mi E O e

o r

t S "D o m W"L g

1 CE7 n

.e cyoV R L9 h 7.

2 E E r

mE V9 a

LS 7 a e

I HO 9

9 ACE O O1 c/

g l

9 s l

e

)

L e

)

a S,

)1 6P 1

E 4 8/

P s

. R "D R 5 C "C E

,ic t e 2i 5 2 1

n 1

V7 n 8

rt O

R 8

1 o

8E RL1 a 6 aaT E D pd V

E 6 o 6

p 6 WOO Rp 1

SL N B 1 t S E e

sd TO A M Be s

E "D e

1 r

Bi eI E

B c I

t E

(

MS%V R

wt R

BV a

(

VDwd E

s t

E 7d

( E eiMR9 i

79 v m O

9 t o

7 R LN A

i O"

1

/ n C

9OOACg 6

/

mCS N

4 e

e

/

n r o A1 Y

/

1 E

4 TS cO m

1 2 S E 6Y v

/ t i

9 Bl 0 a CD RB 1 t N

/ T "R t

i e

E E 1

9I 9

o h

S m

s e.1 eEI B E r

1 S t

N r MS

,E e s e s mNFMI em r

eMA1 Cr ot st NS E C I

r nt e I

t t

t o t

S C N e c e O D R N o pL v ei o LCEE Afs dntoAEA L

7 L

P oODBP ae oal dC DE o9 CCS MEi r C/

l r

Crie ER I

E Re e 4

wsSiECC E1 EES CCt h Eet vLNS N/

A NN ESi Nt t

t L

r eu eI I

I 1

NNCDDCiNLb rF S D N1 I

n t

s t

n e na o

w wh.

l n

et e

aou e

miid h

ne n

6 r

w oiet 9

r edt C

d 9

.u oo ge ui e

t e i

i vi ve a a v i

r1 c

t C amt delpea ri c i

cr ed h Hn hr er f

n eEt ams nh ov o et t s

Lo oer e c

ea eCh un i t sbed rNe mi e eg i

k e

- wn 8Nf rh n a u n.

2 f

eet hn ph a E T o e dt r

s em edo 0hE vhnt v mctiN. ce ti s

ad e nuet 0tig t r oNs ag r

i it iaa n

l Dslvi 7 wn uut hhas n nl a

s i

h n a

e e n

cf nt s o n eopn f

et iof 9 gl e eogaoi ami ea c

i r m i

l t

s sl s e 7 ni xk ck m uviwco t

cnd oal e

y s s a a um h e a rd 9ih e a oi o

r et nt et d teC ot t

/

t l eym 5

So wtaur a 2 eg Cdnsir qr usde rl Euo seo eool t

c l

echh uc spg

/Mn e

r

,e Noiach ie e

8 eR vc s nt t of s

t rt i i

a o

P7d hcyeuaoifhf t

en Nsabparcwosa a

Rioirpp O/a 9 r st D

P 0 g 0.

T/R 2 e 1

I 8 3

3 Ifft

79

-9 1

2 1

d s

e s

s e n iv n o e

ei R

vt i a t

n ci ef m f

r Ee t

Ce H D L

no i

tau lavE CHL 0

3 fo 22 eg e

a s

P nop seR oC ENN d

t t

na n

nm t

t.

ne o cnh e

oo oao a

e n

V lyd

,et i c

uit e n

t d

t r

C mtnnt b d a pl mi c

t se e

t

,f e

t u ot olio nm f

vwa ws e s s e o e n oge u et e r

a 6O ri i t er d d gnh s u o

e t

9 ia Hn gi maoh pd e

c ai t e

s

/M d foichahi r

t t

t a g

at r nt eh nah ogooef n n l

7 Lo n ct t yuh c vene",ah mi n

r 1

e a

sl et ot s ami t t n i r

/

n r

u r x o t

a a

mtce e l

dt ml pninihf i

rl l

md wel eo u ri st r 9 o ci eil t

l e

n a e owias odnh e n pd irh a

up a esh fi l

mc oo md u emife nd c mu t nh i

t r

ad v sVlemr qsoga e o vai nshat C

i e n e o "c t

eey nl n ph o c s d,b eE t

est c f

d ol t e ea n

i i

e l

i t

aaiah ued t r s nee cl d e e ueOd h nf t l

u o a nt o gh gh r t

d ct.

cl nihhs st rN u

c od r a n pint co r m c pM e u on ni n

eeot t t t

nnn 4N hno e

i i

anwo xvintcyo im 0h t i e e h

n n et oihn o e l

u m xk eeoo iomrsh 3

s af smel r

zi m wi i

t t

o t

cst eeae abi e

t t o

a ce 0t op geeihd ah d dt eeemz o dl a

emrd t

S o ot t e r t e n ag i

C o n g g n "c n o s a t

e c gd ei Cd e

c Cd eh =

eir a 7 w Een l iaag et t i uanel n l

r t nno nl wdnuhb

,e l

r t viaacd ywet a

Eu e antamen 9 g Ne eR Euut n a

s pu erh a po

=

oa t og No o ove a

n t, h e r Nosa t

Pn Ndt mmr r

e hl eor etom Nshsh ml l

r nf r r a pM a o p o Ns cd cct a

ai i

Ot at D

i e

Pe 2

3 T M 4

3 3

3 I

79-9 1 -

2 1

s d

s e

e n is n o v

ei e

vt R

i a tc n i

ef m f

r Ee t

Ce HD L

no i

tau lav' E

CHL 0

3 fo 32eg e

a s

P nop seR oC ENN e

d sn e

k p

na d

ee h

e a

s "e.

we wo l o l

t u s V

n r h t

do a

b o nn adut s

ed

,e sl o C

Ont o gC i

o r

od s

t rl ii mn so r

emdie pk yn e an t

s t

eE eGeiu y

v v ei t s Hn M a "y "d s.

e cii e

h L

n t t l

r sr o r oh o l

e No on uh Vnst ahr part t

ad s

Lo hioue hNiepo e

t t

o ot ot cd n

i e

i aOcp a ct y pe ae t

l t d i

i t n b

t aiot a r u

hh lups ss i

oih if r t t t

dt a sr a

er vt a g

t o at c

nhMer t t n

n t

rht e

a n t

n a i

i nyt i

in r

sge e a s

ot s usl e ee t

ot s

r v auiot o s

nsd neie rh ah n ctyi r a ceeiei nt ad ut a ed is f

l t i

l pi a u u a v ot ni et i

n s

l t

eni r

d ut rt o dl ii t sh eb cea c s :

d d e "a n 2 e e aiamtor r l

i l i s

nin sl a avn s

o sit dt bo o nintoht u b c t. otsel na syei l

l v

oD u

c af u

s u n r m c s oai e

t l

e pi n oct em s s h ninAn s

h sg

.e hed

.tcidn oi r

u ii e

obe a

at soen u u t t nar m

hnal l

r shdceyapcna aienue q

s s

o c

t p

r o

iamtct o

= n a o

ei ot e t

So o i s "r v

ot cml u C s yl p "a C w s 's o l it t i

l l

stnt at n

i t g

, ef e e p f V r.

,c Canee C

noi ol r al i

r ri d Eol wa h Eepepmehi u a i

u adMtaOc e

yce+Daf k g l

i i vr E

eR El nt a Nipcmedt Nvo op pd u

i n er Ntadii N

t anu uihMco t

r ni er ah o t

ed u

nlen i

poqmjdt a

NscDC a

Naeaaw Nr ppt f Neirfd e D

5 6

7 8.

3 3

3 3

79-9 1 -

2 1

d s

e s

s e n v

i n o e

ei R

vt i a t

n ci ef m fEre t

Ce H D L

no itau lavE CHL 03 fo 42eg e

a s

P nop seR oC ENN t

i "s.

n. f no oi f

1 f o e

r n

s Rt e

r ni s

h r

ne te Cta;t e i

otod s e v,i n g n t

e oh h

Rs n

C nRacw nt t

e it rt n a Cu r )s t

s et "c eCinO nnr r a

n gat t

a ado e n

r c a a e "e.

at Ii s Hn h

f i

ic e o im t

nCt s

ngnn t eniihsf l

s n

of guc al l r e rt t e i

1 u aeotor o nmia Lo yu mR Mmfif e

l rked mt.d e o

t r u o

f i

s e n s u

r sRinA umvmC pe o m pi C t

n orl snf dt uatl rd ot c t

a i

n e

e o "r dl n3En n a st cctee co c

e mbah dEm ad nsan d

enr A

amiMni epo o

i i t oi LCo mI pc i

enri enr o

t a odi s

t r

ce i

t ot c

n diot

,hi of rhvne chh ds eI ceic.

Ao e a u f

n s d "s e

e e l t t c oTAat At c oAvtaAs CdC S od s

s v

s c

r ir n

ra nn ct uc ct ae e

t r m oa ed ot e

e i

g i

PsfoaI noEao n

c n

t n

nvpn nn awo an er t

vl un h

e ahr c n o c

e af ht I

e ie nar ci i

yh ert e a ai e

ho f

oim oi s

i y sif mt wi m wi iv e

oi a

ei r

s r

t r

iHPt f d "e e b m

in t

g a yd a So otot t

a r

ic-t i

r l

dt d

yi i

c-u t

t l n t en e

l c

rt dl t

,c Ca sbi siri o

bA e q

l ve usp ue oan an i

r r r vns a y

ot e

n o ueutom Cm i

El a

e at ohAned oRmof eR Ntaa est cs r 7 a sRg-d owh i

s a

r t

t f

Nr aaal s r t 9 r ECUFA POPEE PACCI CE CT(AI t

t r

r egr s e eee aD

/ g 2

3 4 o 1

2 r

0 9P 4

4 4

4 9

/

3

79

-9 1 -

2 1

s d

s e

e n s

i n o v

ei e

vt R

a i

t n

ci ef m f

r Ee t

Ce H D L

no i

tau lav f

E CH L

0 3

fo 52e e

g s

a n

P op seR oC ENN t

t o o:

t t

e n

)

n xh n T

oa s f o o

a a

ui s

y r

e r

o y

c s o

)

t e

enWi eo d u o

R.

D p

aa

(

t t

o f

C m

f f

m Ct e

i f

t c

si a s

l f s s

n s

c Hn o s ol c n r r

e e noC e

s o n 0

n a

i I

t e u

CmA ab ov bo u

si o

oe Cic o

3 os ahi f

n e Lo os' Rre imtiAry s

t d

i o a rt t f s

t mt t

nia C wi u

e i

ct ea Wp i

uAsv uAsC vu mnt o n

RrP t

v c( e dt et n a mlu f-il r o n o

d d od oe e uc G N eRE N eRt aa eieytni o

S t

l ad e, s S aPr mevCr evCa.

Wv Paml aa v n Rtee t

e n

t t

t e

i n

r e t

c E

geacg o a aa e e a

uo r ahi o

hi t

t 2f t c f r t I is et u c

nRd qt o.

gt el i

oir uf i r n r t c ye t i t

NequQis po rS q r m ao a d

n oi s

n e nCt t el io f

s u

e "x ir ent is ne mi r

s e e t u um Mt mr vi nr o

n h s.

Aione vgc s

egv t

a ov e I a enrd t

r PioeT ioeia LCL LCLSF JC DInRthi n u

t e SI egcEAA avm So eogg e

n y

dit a si in f

mGg c

at n

d

,e e n is sd.

i i

i i

veia r

r eR d

eed v

i ct v n ofoes oa.

b c

d r

ovu7 t

r s 6

6 6

4 4

4 4

PING 4 r

nAOF PInAA M6 t

a i

r D

I 4.

5 6.

7.

4 4

4 4

r 79-9 1 -

2 1

s d

s es e n iv n o e

ei R

vt ia t

n c

i ef m f

r Eet Ce H D L

no i

tau l

a

+

vE CHL 0

3 fo 62eg e

a s

P nopseR oCENN C

e h.

l s Hn t l ae o e uu Lo t v d s e

i s nL i

dt o

-vI se n a i e et t ad sa a i-l n

u n i.

ai s :

e e Cm s

c a e i r

r r

r o

ut he st y.

d f o n d

u u e Se PDA AP

,ce eR b

c t

N' a

7 7

D 4

4

T 79-9 1 -

2 1

s de s -

s en iv n o e

ei R

vt i a t

n ci ef nn fEe t

Ce H D L

no itau la vE CHL 03 fo 72eg e

a s

P nopseR oC ENN e

g n

o o

r n

o A

t t

i t

s g

mn yd a,

n e

n a n

h t

t e om C

r e

t n

d r

i t n

e n

ed Ce o

h v

r n i

l n i

i i

ei idW Hn f

an sl f

sns e=

hbe t

a ce t

p.

c am l

s t t n

dn a r ag sA o y, e o s A==

s t

t Lo n

hu am i

r r

i t

o eo e T

n u

e

=

a Woc r u eisCr p

i o

t o i

ih yEi aCr Di n

t t

dt t

r d

o sM*

spo n a a

Wgr nlu r

A aRla Cf n

u R

nReD l

t l

o cl saI ad e

l uaio gl nI e ad d

t A m r.

oH D e s a ul hA a

e l

t s e r

t n

n colun s

iQlAi d Ii c oB s ny e

e s

r e

nf ee i

l r

r e e e

a hct R oe gnt Wn y L. h t

n olb nn c

s nTtiO t

I n

i e

n k oi.

Mo Vihed m

i i

t r

d h

n oyo oa a

s r

et o r

e o

a;t hnr a ys t t n a r

Ci ai m

Cs WsovM ebi f

t e

o EPM Af e

a P s.

e P.i *r wmy l l t

t aie n

naTt e o m om i a i g ai vy ee So ca e

aieif tP et uw r

sy-t sf y dst a iat i

r a o u a c

e r

ns uot oCe ur n.

r t t r ci r

l i

l l h osi

,e Rg t e i

il u sw ie h

qees n

pet eptoR vPsa ep ol r e sa ps nm eR 7 o o

nn qos ss r

e ms rCe el a av ss e

e rcmr ea t

MIAAI Rton ROPC n

d r

IAIdi P E S E' RCC 9

a ~

/P n

T i

IEPRF D'

3 gg 1F 1.

2 3

4.

/C 8

9 0

1E 4

4 5

5 5

5 5

1

- g

~

_s f

+

3

7 9

9 1 -

2 1

s d

s e

e n s

i n o v

ei e

vt R

a i

t n

c i

ef m f

r Ee t

Ce H D L

no i

tau lavE C

UL 0

3 fo 8

2 e

e ga s

P nop seR oC ENN l

e n

c e

t a

v s

n t

u i

i g e

i d

e i

n f

t r y t

l c

y e

e o s rl l

C l

ui r

oe

)

n u

d m D L a

oe k

s Ag t

cMi o

t e

R i

MCm I

r ne yaeg d

t l

l I n yn a

wt c

s u

ar cea P

n Lo nb s mI a

i i

r oT r

c f

i l

t ri yi e

nt Tos r

wu o

e f

r i

s a g o T, t

dt od e v

epa S

a eq a

e ol drA c e n a msec c

t ie mh n i

nF l

p s

r i

ad mUr as s Cr Pa w.

e S vR Cl o

o m '#

s n

e si r

l Pe t

i n

e gr en eA P

t t

n o e s.

xoi C Rn d

ne F

o E,R s

i aM a

a e e Cr s n ur h

l o

ur t

An u se n

e s c st d ECr P

Eni oh s

e c

i r m a

o oI n f-ne e

C ot r

r a

h C gC p

t ML A et el t t i um het.

C, l si o.

Ome hl n E.

e ce t

f n

ntan S d (e ms oemr a

s S o Tn as AI e2 zn yuCn e

o t

s uieM Cn l e mf m ar s o e Cd e c

el ir fdd r erem yei v

e t

i i

x n

f r x o e eiu r ene e e i i il wie r

e Evb n n ui

,e u d ac s vt c i

t ul d

u r

l l sE pn pac aqt n 7 v Nooa eR gn sien

. em qp s i adco o s n n

uo e no 9i t

EGOC CInaC FRI MAa mA mQD MREC NPPM r r a

n ur o l

/ t f

I I

3 c D

/ f 1 e 5.

6.

7 8

9 0.

1 1 f 2

5 5

5 5

5 6

6 1E 6

=a 79-9 1

2 1

s d

s es e n i

n o e

ei vt R

i a t

n ci eT m I

r Ee t

Ce H D L

no i

tau lavE C

HL 0

3 fo 92 eg e

a s

P nop seR oC ENN t

s nd t

s c

m en a

s c

s g

r g

A n

e A

go i ah n

e s

yea n

C n

etwp o

i ah ns n

i l

i n

i i d n t,

a t

n d nt a

nns g

n a

veu sEo n

Hn opec o

opec aer in h

t i

Br i

i iWi FsCny e

i r pt FsCny c

c t

Lo e

enG t

a n

n l

dt M,EtiE ~

iCz PoEie Tum,i P oEie i

f o v

i l

sh Oio Lh n a g

iSn Oio Lh S

f CcC Cat dT l

t Aersg Cat dT nd t

t a

n aW ad 4id ct a i

d s n o m

t d sn o o n yi d Enia S rC

.r E niaS aein ee apt.

t n n

a l v s

t f

e e apt.

i s

s c a oS.

PaOne e e 0,i g n P, t Oe en amBunl d r s

t t

t is ac a t

t amBunl c n t

t L=i nO =-

CGha cmeroe u d e u A n, cmero esu r

r nI u

Agqaedo nomG eR um s

i ie o

a oC EnfM nomGme t

t i

i uci eR e nd et uci So p r-n woo y 4

eTEg e d aAt a.

mReTEg e gE o

m d+ dn c

cit a

i sl R

a i Mtat ae md aWnh os el c C. d a W n h

,e ude l

CroiP r.

n l

mrhot eR er ocC t

t c em

=

eCa n t

ef o neCa n f

t a o ei aRSMo Pf" PRE CaRSMo n

r r

o' a

CfCAEM NFNT o

D 7

3 4

5 6

6 6

6 6

6

+

w

r

~

79-9 1 -

2 1

s d

s e

e n s

i n o v

ei e

vt R

ia t

n ci ef m f

r Ee t

Ce H D L

no i

tau lavE CHL 03 fo 03e e

ga sn P

op seR oC ENN f

Pseo o e

n n e

n t

f a o.

aRh s

o Cestinal o st s t

t e i

t n r

go g

P E h sih p nnian aCota "t Fr C

ns g

n C

Ta st m oil o h

c.

ud n

i e.bn n o i

/

Hn aai t

ae g

ia

)

n Es i

eo t t t t 0d hfd u

s n

t T wv r

e a 3 a

r n

e r

5 u g1 hioc e

anea d1 nt f

Lo e

ia a

s i

t at n k a norlo ef a et r

e i

t i l

s ai a eicl n oPegc l

r i

dt So sh Tic T

5s t 3 nl i

s n gi

,i u

tni m niav r

i r

r n 0I edoilao iur rtn7 n a mnCuid la cec Pdu a.

0 t

7 vn st ad nd e

r o n

n yi d CeN yP 7 0 i

i n ad eee Pqt e eiEslnio t

l n

o e e c e0 t

v d

evrt al Crd nto5 e a eihc ein Eu r eC t

e e t

t t a a

9(5 r2 e

,s nf u Eo o pR d ot i

l o

ht c l

oio c

is a c ecf pE g

6l s

l m

d r o "e n r

q i

2 cRse et yc si r

A g q A n, 7

d d eu ing

= d 9 n n

fF vtsf r

ua i

nd heaaoC t i n F

n

/ s a,eHoa f t i

l s o

a edo aica t

os t r nrt

s. e i

a 0 s 2 r i

l i w

a "y.

1 e n4 eri n y uien0 eixE i

So end et g

xC l t E

/r e1 woai fd a

a.

t mh e1 r

,c d aAtcit t e u

n u

e 7. W 2

ieit nt e

nMt W

d p ssPge dcl em, e

nl el c eR o rhaeH ae a e 1

eleeCl e ooeh e.

ht d

o ad t er ia f

S RS FA RfiiEaw Mppwl e.

Wo0Cg t

.S"M a l

r r r v l

a r

f ei p5Si e o

D PfTPRE Os I

?le 8

9.

0 li 1

2 3

6 6

7 FF 7

7 7

o

T ATTACHMENT 4 f -

Interim Assessment Status ofImplementation of ITPOP Oversight Plan, Rev.1 Introduction Revision 1 of the Oversight Plan (the Plan) for the Independent Third Party Oversight Program (ITPOP) was published on June 12,1997 and approved by the Nuclear Regulatory Commission on July 14,1997. Since the Plan was published, the Little Harbor Consultants (LHC) team has completed a number of activities identified in the Plan. Additional activities documented in the Plan are being readied for implementation over the next few months. Given that some four months have passed since the Plan was submitted for approval, the LHC team is conducting a review ofthe current status ofimplementation of the Plan and the extent to which commitments made in Rev.1 ofthe Plan have been met or remain to be met. This brief report documents the results of this review of Plan implementation.

Activities and Commitments in the Plan Section 2.0 cf the Plan lists four major activities that LHC is committed to conduct. These major activities are discussed in more detailin Sections 3.0 and 4.0. Specific actions and commitments from these three sections are listed below.

Section 2.0 Activities and Commitments 1.

Benchmark the existing conditions at Millstone with respect to the prevailing safety culture.

1.a Perform an assessment to determine the prevailing attitudes of the site population regarding all aspects of the handling of employee concerns.

1.b Conduct a detailed review of existing documentation, including internal and external evaluations and inspections, program descriptions and procedures, to identify programmatic issues that have contributed to the current problems.

2.

Evaluate all programs and processes that are associated with the identification and resolution of employee concerns.

2.a To aid in determining the adequacy of programs and processes currently in place, conduct independent technical reviews and audits to validate the results of past evaluations and the status of ongoing evaluations.

2.b Evaluate the Comprehensive Plan to determine its adequacy.

3..

Monitor and evaluate the implementation of the various programs and processes associated with employee concerns.

3.a Evaluate plans developed to implement corrective action.

3.b Determine the effectiveneas of corrective actions.

Page1

A' 11/21/97 Status of Implemamarian of 1170P Owrsight Plan, Rev. 0 3.c.

Determine the effectiveness and compliance with programs and procedures that fall within the framework of the employee concerns program.

4.

Monitor the effectiveness of all activities at Millstone intended to improve the safety culture.

4.s Identify and quantify changes in the environment at Millstone.

4.b Evaluate the licensee's self-assessment and performance effectiveness capability.

Section 3.0 Activities and Commitments 1.

Perform an evaluation to characterize the current Millstone safety culture.

1.a Review applicable reference material, including the results of internal and external assessments previously performed, inspections performed by the NRC, the results of employee surveys conducted by the licensee, and other relevantinformation.

1.b Based on insights gathered, design and conduct structured interviews with a representative sample of the work force.

l.c Using information Sained from 1.a and 1.b, characterize the attributes of the existing Millstone culture.

l.d Compare the attributes of the current Millstone culture with those ofkn l

" ideal" environment.

l.e Using this comparison as a template, develop methods to monitor progress toward achieving an environment closer to the " ideal" state.

2.

Conduct structured interviews to establish a baseline against and to measure subsequent changes in the safety culture.

[ lots of commitments regarding how the interviews will be conducted, how 2.a interviewees will be selected, how the questions will be formulated, etc.]

2.b Following completion of the interviews, the LHC team will analyze the information and characterize the predominant cultural elements at the site.

This analysis will be done in accordance with an internal instruction.

Review employee survey results with the primary objective of determining how the 3.

employee perceived the site safety culture.

4.

Observe and monitor daily activities across the site, including, but not limited to, the following:

Daily planning meetings where problems are identified to management Meetings where identified problems are categorized and prioritized a

Page 2

g 11/21/97 Status dI--,'-

W= ofITPOP Oversight Plan, Rev. 0 Meetings where corrective actions to identified problems are discussed Maintenance activities a

Safety meetings Shift turnover rnectings Controlroom observations

~ ECP activities

=

Training, lasses for supervisors on handling employee concerns a

Meetings where the root causes ofidentified problems are discussed Inspection and audit meetings 4.a Conduct observations during normal working hours and on back shifts and weekends.

4.b Document information gained from such observations.

1 4.c Provide results ofobservations, along with conclusions, to stakeholders in the J

quarterly reports.

l Stetion 4.0 Activities and Co. u -/^rinta Conduct a thorough programmatic evaluation of the Comprehensive Plan, including 1.

subsequent revisions. Conduct oversight of the licensee's implementation of the j

Comprehensive Plan.

Conduct a programmatic evaluation of the ECP to assure that the program has been 2.

designed with the appropriate attributes to achieve effective performar.x.

Conduct an assessment of implementation of the full range of ECP activities.

3.

Examples of activities to be assessed include:

Audit and review the handling of specific concerns Evaluate the timeliness and thoroughness ofinvestigations Determine how employees are kept informed of the results ofreviews a

Examine how confidentiality is maintained Observe ECP interactions with concerned individuals

=

Review the training and qualifications ofinvestigators a

Evaluate reponing and communications with management Review how anonymous concerns are handled Measure the effectiveness of the overallimplementation of the ECP.

j

=

=

, 4.

Perform some independent investigations ofconcerns and cases ofalleged harassment, intimidation, and discrimination, independent technical reviews, and make recommendations to address specific concerns.

1 Page 3

s 11/21/97 Status d Is '

^=L= dITPOP Oversight Plan, Rev. 0 5.

Conduct programmatic and implementation evaluations of corrective action program (s) that provide for day-to-day identification and resolution ofproblems and issues.

5.a Identify the objectives for the program being evaluated.

5.b Establish an objective set of attributes, based on industry best practices, that the program, once implemented, would be expected to meet.

5.c Compare program documentation (program manuals, procedures, etc.) with the attributes identified above to identify strengths and weaknesses.

5.d Evaluate implementation of the program in the field through interviews of program management and users and by reviewing representative sets ofin-process and completed problemidentification documents against the attributes identified above.

5.c Conduct more detailed evaluations ofany less-than-adequate program outputs to determine causes of poor performance.

5.f Document any program waak=m, report overall conclusions, and provide feedback to thelicensee.

5.g If necessary, conduct funher evaluations of the program or specific elements until the data gathered clearly demonstrate successful implementation of the program.

6.

Conduct a programmatic and implementation evaluation of the licensee's root cause evaluation program using the approach described in 5.a through 5.g above.

7.

Conduct a programmatic and implementation evaluation of other licensee programs that are used to conduct technical evaluations to support the resolution ofproblems and technical issues using the approach described in 5.a through 5.g above.

Analysis of Status of Implementation The table that stans on the following page documents this interim assessment of the extent to which the LHC team has completed the actions and/or satisfied the commitments that are listed above. The first two columns of the table restate the actions / commitments listed above. The third colu indicates the status of completion and provides brief comments on the means by which each action / commitment has been panially or completely satisfied. The founh column provides a description of the documentation that exists for each completed action / commitment.

l I

Page 4

4 7

e 2

e 9

't eh e

bft aCr h

v

/

e d

st r

d. R w e

e 1

h iac e

2 oo 2

e t

ca 2

Bt o Nd n

f Lie w

t t

/

r wic e

nt Pcl sm

.e a ron 1

e gd y

e o

e t e mvds 1

r sdmh nim Ciumm eu Chaph er e

a e e

i a a t

doe ENJ u t ve wtut f at n uds h in oe s

nrap r

nape n se et s o

e p== i e n epna u nn hd e

Ro=

h a el ee t

n m er s

i d

va s

r t t a

a

.r e

et l s df a.

f a7 c atx=

fm o t

e r

nd oU 9ee e=

omgslsspw s v t

sa en ef t

od",

n uUh e a

a nt 9r r

ns npu ea r

gn nN1 pen a oei i

s e

m dN Tt

=

i r ee eh o

had t

e a

i d

,et t

e so an13hf dp apeh rbt e

.h aiu L.

t t

e t ee s u

rd 7t Pl e

l g e.

ua opu utmfh v n un9 r

l s yf co e a9s.

k.

"a w k aCa otsok a ec ot ao t

l i

i l c v

it shs n

wl c s D

mC1 v

ea e

l eRMr=s vb eonsu s

^-

ut u

r e

s a e

,m w t+ rbb eNnd sR 2 e

t el e n de a e e e ha p c

w eN2 v

l

,e ym heo rd d t a nmf n i

i A. b e

=

t n esi f r o

o heyr eaupc e

h da mk v

a r ha i

f t o gh h c t

e hlud t H

ft h tho.

t o u e n

o l

st hesrp.

smt edct e e oe r

k h o

J n

e-mhm o

i t Pah st n 2

d t

l dshtnit u

e t

l l at do1 d 2

smf a u e gT e e a -

s sUT ab t

l r

^

e e

y a a ot st nh enN nf o ueg^

en n.mb r

en n u

u hehe r o 7 e op st l

r i

t i

t t

et7 ugs et d9at p i

t r et c

J Ctich ese9 c e

o nl hcn9 eu ese u

c f ah hee 9 r

o Jhwo lpm 1dEf r TAa1 mss t

r i

f hrem Tps rs S

t I t o

o 7

s d

t e

h a n 9

a n

~

r y

o s

w edad 9

e wd a l

nt l

e y

es d su ep d

m heh n 1

s e

ha ias nwJ hxf u a

f ea sl T ns t, ou wn a yh t

u aed t eotim t c hng i

e oimt ev n gogt a t

ven au

,i u t

s yd nr a nt e

nag C

nene wJ or mt elago muA r

e ut e ndi ro H

x s

du nr agf l

n

?. h e

J nn ee di r t e ce il e

r r o r

i n eP L

ar o e thi ank m ge a

niu dn ri r

oFs idJ gah pG a r u t s e e a ad h m=

h den dih hpnengt f, A e M o r

n h

n Pnt ee a m gr nf w

t o n er i l

t t u k r oio efi sd ene f f msJ o

s D, n cC a

hic r

s oll o opi o

et swdsinh n

i t

t v(C puH etdn e

l t

s g ia i

sbr e o

srdu o i r e r en exi Ph gyk mtL r

ne l

t e u ed Ctn dw o

y

= wa cC r

e i a qf doo ct h s

aP p u

At bv n

nr l t

=

Eo s w i,e mren

~

eo ceb t

u e

emrPed aC g W

o awo=u t

sh n

m.

n wt sy e

uH atd

• p e

el et

=

h e

i7 e

ue no mh Pie rt

4. l wht qis rl vs en eiCe n Ar9 5

t p s, gc u

s u u erd ep e

er ede rheEh a, ve t

9 yd c

m hnve vnr ot m

m. Y e

i c

ur Fniet n

.b 1

g hrod hteu n i i t n

1nioE T

snrs t

u ighJi Cd 1,b o

r dninnc T

ho d

i t ednt e

P t c d

t c e cN d e e J_ h t

e esh eaf d

e E J. k. i.

hrSe a

e J. 's a,h a

i t

o ct z

en

.m e7 e epr epo t

e t

t ieb t 9 r e

e a

r os plpo p a. e @d.

n l

l 9 e t o l

pcp pl e s as f mtp mt m cmvu mmB L p1 w7 m

.lp i

es r r ege oeie myt 9 r

o oy stnrl

.o a

o oa o oea oluh 9 CAe u

C pC w c d c Ccbiiof F pT S i

p st CJ 1

t e

g h

a t

f n

t o

i c

h d

e t

e sef umm w

i l

d o ca=

u d

t g nr =

i g e

r i n

,ok t

ta t i h

al nr

^

t d

op-cs i

i,-

on w

gn t

s s r na a n se h

e i

t O.

n l

no ac

i. he ei

.c e n t

o t

s v

ut mc o

om r

e n

s t

e ac up r a, rfo c s e

l R,

m M

es t e li o

b a e difnyo h y n

t h i.

r t o a

i t

gdtip el l

t P

m a

e r nnnt r p t

n iaen

= m s

t h

m n

de i

s sir e e o

ml g

o i

o r nf i

x n u

C t

rl u

oo o t, r

d e a e

s r

i c

pn t

f t

n eg e

/

o a e. he o

v y

o e dn u

di O

i c u od wl t

r i

a-t nt a

u o

al t

t r e v P

v gl i

a i

t so s

ve O

t nu P

c ic ng el s

d me t

e e r a e

ar s y nr A

s d n rtu rd I

ixt un n e

T e

r g n f

ef mar l

edib o a t

o e a e a e axnr i

s t

r

=

h n ac t ea n pn t

t g mlu o ddso n

e l o k-kn npc nnc at l i

^

i rl a

ai a o a aeie e c e

pe ma mey tcl v

t drWh i

a a

af v

u n ui e

r t o

t hr oi l l

t a n cp f sp ne a

v e n

ot h

Ei r e ehm n

d e

e Ci h

t Bt Pt e fo a.

b.

N 1

1 1

2 s

o u

2 2

2 2'

ss es c

ItIlllrllf l

f 7

r 9

o e

ee C

s o

1 y

h ghb u

R7 n n

t

.t

/

t nt d

N 9 e o

m o

M.Mm t

a i

2 f

oo 9 i d

e n

h e

/

r n 's eheh ee1 n

o gt t 1

nin nspaaCcbt vh u s un s a

1

,cn l

i t 3 o *= o oieeih l o a

r t

o o aig Sme Hel l

o coa t

h vni Lrif et di vt n i

ei

, g *=

t y

ci t

r a+su eat 1

sws nt

,n=a t o s!

u t i l

s e

nnsr t

oa c

t ei eiel ncaga* eoeo c = M '^-

e t

r e a a s

i n

vn r v o

nt e

i t f f = n o

f sia7 ms af epe e

i w

uhsd e o=o' c

ot c me nt 9

e9ccpg.

ne ci t

e e

ar s el n ch h d e et g Hd r

nb t

a1 n

onunm opn oit n

l t

pcnad u

u

,dori n

il f f a

s op r a m eit e

t b p3 u ociu1 o o a u eca or r e s

eCt cl ndi i g u eese r

upt l

t t

e n s

s l

ut l

ebdrouneinmno wiii a

eh e a aol t ir nhit r

v v

t v ht u e

t aioP ePc et d us f

ypob a si t

q s a e o cmt s n n eCl ni e

an i

t t

e e

s arP hl ae el net r c nv s e

ia eo hEbo a eob v

hiUhee t pt s et v si h hi t

ur o

Neh dma ao evt t

s r t c f e pf w eps u b

t v

e eUdNrptc=- nA oh f

t i a

i' t

odDd pmt t au e r

s teoNn n eae e

t nf o

s rt ov i

2 n

n i a s

2 t a e e a

oad e

.ll os

~

v uf l

gew=wt nrditom

.t s

m uC7 nh ewd 7 l

i sUasewsa n9 s

s 9 ee r

h nt e-c e

e e

eR 9 mp pia 9 nNh' h t r r

i i

v-e reideCcCoo o

r g v

rN1 um crc 1 emr t

t s

n i

ei o

htcnhHaHf e

3 o o HveR

, c

, eov r

e e

r e

f Dh dC LoN2 nf oI pC TaaTLrLeP 4

i t

e r

1 S

t y

s n

e ag Pob e

t h

e wn b

CR h

i rh d

d t

i e

o l

t t at ww vCB le r o n

en

.r eet e

r I rfob t

e a

iHy i

o d

t uf e

1,f vvheLb h et l

h i i ac ede4 i

li r s pb t

r at

.t eet r ed oBy

. h A

f

.o n ohe t, cs v.

o r

/d mo ye p

Go r

r r r

r e mrfoiR b e. S t ef Sf

)

l

? *e cy ayaCye ap w

t f

i e ibl dt r

n.

l l me l

rP

.bi r e o=

sb sn eimo m

t a

i g

i

/r w7drif da Ba Tn ne;Pde g h 'e i N d il i

a v

9i pT n e e de dr r

i i -.Cer ot et i

c r

s u o

t ea 2 a, p n t i

f c

s a s9 rd o e

t e

pC a o nto m.

hn ni v

Ef y Po ef n

e e h

i 1 i

l il aia t, ig e na n5 ct i

,d p a a m mH r 's nog Pn? h el o

t r Y(C t, lyr n

nC r

i u a Pu a anl i v. ledH e

oL iU ou o CE

- t e

i d

r soa t

oim cehiL d w CJGas vg e

s s c e m N f. u Eb t si art s r

o sh eo iregarP o

eiue E

ingrP l

s s

r em e y e

at t

g1 sb eH ei l nr a wy gosrl s h B

- d e 6i l

n ein t

n t t l

hrl yC a l e

s eelFin b

ni iFno rberbe i

ed i

pBt p

t o

s mi i7 EnP t

- nn 6

s rA e ni t i i o

ob Aia nst me of d h os c oCo c

Fdhgr H7 ka bmED aA et p pe.

e i h oY Fo wee ae g

nt 9

oBoe g

d hf u v

ia afDaA rar v v 1

a Cf ds ro e

y h r n e eisodoheCe ws P

d rde t

n I

eh e s t l t ef v

i t

e v i

t a

aet ei sc esisse m d r s epas ene r et i t

s i

t et e M nuf t s c nwnhiHrl lpmpe t

et ei c

l i

nour omb ulpe a

oi l

oeit m mot pnimCmr o

r igr d e ms g

=

y nt aCf ocadt vno a

.d h i

i r

r n n el o

l r

Casch daarceEFt 4 at e

o enel o a

or e

o a

Ct EmAcC Ce O c a A pC h

w fo md s

nu y

s at c

n s

a st a

r n

s u

se o

we e q

uc i

pih e

o n t

d vt d

n o c

n ed a

c a

a e

r a

n s

ve v

l t

c sa a i

i e y t

O.

mcs e

h c

e, v

t amn n

t e

o i

f r

e n

rhi m

o o

r e

gct R,

m oe a r

n s

c u

e r t v

d

-oh t

n pt l

t i

a i

f n a e

t t

e i

lP m

oe e o

w d

h m

ynt d

1 t

t s

r e a n

- e 3-

=-

g o

- p p a

a t

s C

,df P

)i pe l

c i

r i n o e

/

n

.o o

4 v

y wis

.s t

O is t

t t i

ec u e a f-l P

v h u s hs i

t d e t e O

t i.

s P

c gnr 3

e s noe s a e t

T A

ich n c

I n

t u o A

o l

n *-

f i

ei ar o

t t vp s

nt aa C

ed n

W+

e:du l

a e

d n a

c i l l

e na v h

na p

di v e as e

t m

n e

r

4. tog ta t

n a

o a u

i d

t sr u

mrg a

~io l

i t

l a

d g a

oo v

f o

un v

r T

ao E

Mp E

1 fo s

o a.

b.

a.

N 2

2 3

3 u

2 2

2 2

ta tS

?

7 s

9 t

a c

U

/

lu 1

e 2

h

,7. en ti N

e. s s

l r

/

t 29 ha ob w

4.d e enhhr 1

e t m f u c

1 nh 29 ei f r f p

c. aT shvb t eil 1

oa e

ot o !y e

t u3 wr ga r u t

.tnTep

4. C e t n

et J1 ep t

rC R7 e

.n i

f v

N9 msie 9

i anr ie cs oe rb oH r

w=s b el iL 4

uwd u t

e1 eet n

f h c

u gmvl oy ot 2 o vuf

, i r i

e=

i e ne o w ib vr ivg ny d o2 dr t n eci r pt o nm l

nt ynt u e

gl udl on rt ev nicNia.

icna oe uii t ur s e

rt J s v oend ngg oi aJf -

t Cbcnion gd n nt t

t n

- o anri nio se s-i r so e

- d Helvb7 opt or i

e egs-La u9 cse e

f n r r

e--

ip epn e h p9 enm s

r --

u i

het p ioe t 1 ho h

he M

t e eMrb c

t i

t a

t r

t e e

,f cl b.

f f

t i

wmhede fodaU4 oAb 3

i o

o w-t h ns 2

son s

f t oi s

u s

t sc of c w s.

c, p 2

t t

t l

i uwl l

l t

_l d

t oeeg u

uPn u ie n

s g

s eb u sk n eCa" wt s

s u

e e e eiu s

r ot el i i

e v pd l 1

r t

rb^

t eean uhl e r

REC f-r I

u l

e

.f e

el t l e e

s i

h t

e hi htnt heRN E_ hTCa S

T w ;_

Tiahr o

a efowm Tt h

t e

t c

s t

a g

ue u

d a

hde a

n shgm e

d h t nr o

f n

mr nt t

ut i

eo g

onst o

a a:

e s s hmc air a

se-i i l

t e-ne r

e ef

=-

,h ah:

a dn 5 t i v

e gk s

/d oi bn ct eme t

t t

h e

ssisf u --

r

) e et mi ee o--

t r

e e h

uJ c

vhhl

?t he r

s t

u o 1 i q H :+_

t 5

uC e

cn-ot Ti e l

i oe t

t r a

rL

.e rdfyst. wc ntc sv

.s ui o

l r

Np n o e

s n

C afai i

i t

a rdsi r

/m t

e o

=h b.

gs ea n. u

.c stei e ec t

.o f cnr otews s

t e

ni s a3 aiced r

.p oua r

=t 3

Y(C

= dC 2

ooe o yi

- a a.

o uypume i t n ec i

d s

t r r d

d r

d d c

n nqedne-ih e n n n u

t sf okoot o

dw mnH m

mfel t eicie hU f ct n

eo o aL e

o ef t

_ns n t

r me a

sCd mChoer t

eH cPy t

r ail _aml sHt opredr s

I t

e eew nCb s

Ht otssPaP rLps l

e l

l eEm r ve s

t a

a, s c h r iLa af r e f

p wuai i

mn ee' s

s e

c. o t e a e "i t

v 7

gh m

Cehib rU me t

ea i

c i t g a

H ht rd o N '

sh r oY wut e e

pn hht r

T "p a t t

t r at g

t e

T a

.etshn a

hf S

L Cf Tom ng i

i s

c i

.a e on-v t

.d gw7 rf f

P I

zwP z

gsMl pii' r

e l

9 h n d =n yeo o

sr i

nc9 i e l

ne s n

gi i ns o f

l t dw-it r.-+-,t e e yd ueua u

om1 ---

i d

n i

t i

i i o

o o

giva omi gi n n

a ni m

gi ot c

n n

n et n

nt a

r o e

nt l

OoA O

QcRheepmCtod nua oh oh o

c v

o OiJhr t r cr a"

t b i

dn d

e e

n a

d o

s n

ts ma e

l t

l a

r n

i y

M g *--

i o

en t

r a

p o

h t

t s

n s

t e l

0 n

l e

ih m

i e

wt M

v t

ef n

e n

t o

t o

e c

c a

r R,

a nk m.

i s

v e

a i

n e

n v.

i a

v l

i i

t e

l it p

P m

i c

m-~

v e

t e

i h

h m

r o-t r

c e c

t g

o o

a n

i c

df i

i C

f n e l

s l

e

/

o ah a.

s r

e s

st f e g

v y

r O

o u n

t s

s n i

e ei st a

P v

n nh s

l O

t e

et e u h

i v

n c c

i

?

c v

iw ey fy i

t A

c cl vt i

t f

s e t

f e

el t f n

f f

f am ca f

f f a

o e

et a es r

f u

e e ag f

e q

+-

h h

h eh t

t t o et d

r

^

e eap h e n

t v

a n

n s

r u

y i

i

- n f

m m"

o r r

r r

e i

i t

e e

c n

t n

n oi e

t t

/

e e

o o

d D

Dpc Mt I

I fos o

b.

c.

a.

u N

3 3

4 4,

t 2

2 2

2 a

tS 1

I if ll lllll t

y 79 s

dy y

U a

nes r

t f

2 mri tnA a

U l

s a e e==

si e n ni nl n o ai I

n c = a t ue pr ms s

ceNm ae ealcb N

r a

r s d

edn e

ne e nl c

l e

e aww=Cw oi t

h i

t a.

a.

a.

ngn=e n

a.

t s

n ar mrh 7 ng 1

1 1

1 e

s a aa

.t e

2 2

2 a

kgs gt9 en 2

b.

/

/

/

e n oeoa9ne 1

1 1

1 1

4 i

/

i m=

2 2

2 2

2 2

r t r c

e pd P p1 a

r g

o m

m m

m t

erd na4 r

t D

e =

n n

aaniU2 m c e

e e

e e

e o

e r

e h

t r

i t

t t

t t

s oasAnicNeCb n

l i

i i

i i

w e t d b o

o o

o o

o o

t t

t t

t t

nHu mc aeLp e

e e

e e

e s

H n

a = d AC pe a r

t s

s s

s s

s i= o c=

m n

n n

n n

n e

ud o

o o

o o

o n f-r ol h

. Rest e p

p p

p p

p t

sg

.N us s

s s

s s

s e

s i

o df s e

e e

e e

e c

r r

r r

'C h r C e naie e

e e

e e

e es e

r r

h n s 2 e e

e e

e e

e ev et p

S S

S S

S S

t HfOho2f r

r Lo t t d

r n

g i

e n

df e

o a.

a.

ha.

i n o t

oh a.

r C7 o

t t

aU eNe sn g

1 1

1 t

t h

foR9 s

2 2

9 n

l i i

2 b.

tN1 s

/

/

i

=

vf o

s

/

r o

c t n r f-e 1

1 1

1

= bt o f-og yi e

r ae i

cl v 2

2 2

2 ph2 m

/,

= de6l t 2 n e

) _

e t

n m

m s

e

== e r s sv aa iso

?.

aoy h

n r

r g h a er e

e e

e t l t

mo ;m, i d. b e

o m

t t

dnJ g

u nf ha t

t N._

m rC I

i e

t t e i

i e

ao ahc f

f f

f t o n.

s c

/

l sm f-fd o

o o

o ehn e n m e ::-

i r

u-t

.tt u t

ptao d4 l

h l

W e o o

t t

gP n b N a

a a

e epa mng e2 Y(C s

r Pe e uAo e

e e

en f

Chw~nCcfdt c si sm o

p p

p o

ds d

nn e

e e

t t

ei dw ndEt ssye nt ae r

r ee ie r

t sr t i u

nt eh a eia a

a a

a ape n

n eo i

r cic tf en as s

s s

s we m on eH matsa ohht r

t nt f

a i

i i

i it u shc f

C@ff e

o aa so2 nr n i

i l

x s

s s

s t i ed p s, 8

i i

i l

miagu z

s e n

hfb nade-awom h

h h

i i

h me o u ib e

s iannl a a b

ge pc T

T T

i o

r i

g e

oY H ae np l r r rgg o

o t s d

d d

d do I c a

r n t

t t hh

'a e P

cni e

e e

e e

e CN Lv por8o=rp l ieh t

s OaPr s r e

l t e

e est nd i ant e

t a

l l

l r t s

e= y =

i wnay p

o p

p pea nt r

l l

n=u nh=fn -- Ctesf r

ot s

m n

m m

mp ao a

r c*ntoier n ei na ch= e Hsst o

o o

o o eU mf n

ar O N v A w== diiLsms C

C C

C C pN Ofe r

a

=

ye a o

f t

o e

h r

h t

e e

s e

d. c.

t i

s n

t e

w o

e t o l

o u

y l

r z

e sc t

s W "g-

+

s i

o e

i. f r

r d

ll t

e u

on r

tn mk i

t t

c l

h e M

e h

.- a or a

u tem v

m o r

c t

t ff e w

a e

mn n

ge ol t

r o

e c

h n

pr O

e npsr ue e

n r

u d yl r dh c,

o ui v.

t n

i t

J. vn t

ue nt s

ssh of

b. e c

ul l

e d

i,;shed d*:-

dt M

e. e l

l R,

m n

e c uet c o 1 r i

u d

h nor o n

a n

t n

nlu t

t

,t a

a c n

e.a a

i tn e

n l

lP m

a z

e g

n,,a n

a. e e

=

e i

n e s C e, g

1 n r

a i.

n r

r t

h m

m t

e Re o

ut t

l t i

=

s6 nt c n

= k g

o a

c an s

meNn e

i s e

r a

u C

l e

n ee d, ;^

el hm aM a

r r

m a

ri a

h enhc e

/

i d

fM t n v

y f-c c etl d

f o s

r e

O n=ye t

e=bh e

eg or ad i

l r

r e

o i

r n n sv' na P

h s

t r

t h

e=d iai en ow O

t sy n

t T

c

'e l o

dl ey a

t t

gs u e s

t o

i a nb g

nx b*

nt i

r h

n A

=b s

er nt s a o e r a pse i

1 il es f

n e oe l

f

= a u

bn f i h h he t e t

t o

ep a

av r r gt ah ad mret l

a wa v

ce eu ii nt e

ogt i

s pt sw nf h "n s p l" M

c e e i co t

r n

o t

lpd ~s n n r

r e ss nu n noo is o

f s e a i

h e al pa ocn nw ne rf h r ea t

a t

n iu l i s a oe i t ao od t

e e nc wat ym dv gb pc' i

u g i "e t

n i

en o ^y enr r

nn e er er ni ma mt irve=vo p

s e i r is o l c f

rf at st o o v5 P

Riisi Bn Ua Ct Unh r

ae e'-

t h

et nnur a t Ec I

f l

a.

b.

c.

d.

e.

os o

b.

1 1

1 1

1. '

1 n

3 3

3 3

3 3

N 4

em 2

aS

^

1

{f gg 8

A l.l!

1 ol j

s e

m l

,I,i i a.vif.

1 1

i.

l_ii, li,I sh a a

15 4

a 9

4 4

4 5'$hh b,

g !

b i 3 al p1 i

1 gPllP bj

!lir}!

i l i I

h"i i i

i

!! 11i!Ililll!

1 I 1

i a 9

1, y

1

!,1 j i

o a p!nl.

Il i{il.

MI Il 1

1 }j{i 5

j l

.i1, ti jlf h ij 1111l>j!!!

1 3

1 lI l!I!Il !!OI!I]lldi!I I!

f li lli Illl il 11...........

j

,,1 3

7 t

9 o

f

/

t d

s t

edl n f

c uo i

1 i

d h nt e oel t

os 2

e bb n

dt

/

caae t

t l

n aCthb hl u eenu 1

t gi p mh as l

I e e t

s t

h s aRda nswe s

he a

t t e eh ar r

st r

n p s. h N r i r cenu eae t

s he i e at i v ot sU Tt iotiu h

oegwhpaeh f

W dl c et f

n aN s

fbn r

t g 's a t c

.t s

r t i

t opn n a id7 n l t n

iCeU n

e e

t S

an9 e eiet eo v

h wnteebt d

i HmN ma9 m m

e o

c u

Le mC u

1 e

a t

b ad l t l b

a a

enicfii m t l d

c l

r al onwr npn aR3 o h

a e

e oma gN e d 4

4 s

brs o r.

r 3

3 n nu mfdnC sf ri n

ent n

e pb a r ine oe u o

hJ o t

e i r o r

t r

m m

mb a nt pea ael aR pt i

t eUm nehu b.hPN eo nt e

e u

u a

h t

t oha N a, b leyeh 2 a e e ht ot l

r t q c

n i

i v

e c

t g e n.

h f"

o o

n 4t z

e ns t

t ri c 2 r eio o-e e

csd yeer a i

o t

vt a e ms t n nl r t s

s s

e r

n- "t lt

- epa n

n no alaa am e o?-

e u i C n h u m "-

t s

u o

o at

,- mh I i g

s l

p p

c a

s aRio

- n e

ict v sQu eu s

s i

v e

e f

t neNir. s el i

r t

i erbme el ir t

d o

=

S c r

r c

e e

gs e d pU d n

-.e Dew pf u o e

.o o

r h e

n b h acC n

e e

i ArNa t

S S

Sot u

y b

a M

b. s i

d e

e e

2. h bn v

v v

t o

o o

h 2t a

o b

b b

amt Bi l

c a

a a

m e u r

r t d yp 4

4 4

ein b A 3

3 3

v so d

m m

m Oac en t i e

e e

.e o e e bmt pd h

i I

l t

t o

o o

d a 4 ma r

s oG t

t t

e h-t e e

e e

eh c

s s

s l

e n

n n

pt si s

al mib wl o

o o

i p

p p

os sB s

s s

c e

e e

Ci 0

g id nH.i f"y r

r r

hn 1

n e

e e

a e

o e

e e

e g

iab d r a

S S

S t

g a

ee P

u a

r ua e.

t i r

ce l

u ainay im.

i u

t o

p a

o vosi n

mi7g9 v

a m

n Eani n

.nat on9 u

l c s

Q O

O aOPa CE1 o

k t

^

c s

a tae b

^-

h u t

n b

t o

o ei C

t r r d

n s

s ut t

n s

s a s

a n

o en ae s

o i

t r

i s

h o oa t i u

t u

i t

a f se r

o l

Pp oihvt O.

h v

c e

nef Cro r

n v

t g

o s

o o

Ep r

e n

n R

e b

c it nn ep i

t m

k o

h au eo h a t

r h

ui t e i

n i

a t

o c

w aqt fh l

a w

u i

vet ot lP m

s g.

es n a

ns be nh l

h s

n m

ot c

t u

oi t

i sm r

i w

i l

o t

g o

n o

t a, ep a gle a

r i

o f

s mnp ud.

C n

d n

s ee l

r r

v y

g e

oy mdm anc e

/

i vgn t

n n

l aui eia O

i i

t r rl s s

i i

P v

u g

vt o n 'e 4em r

a ae gc i

r a ri e dr r

O t

d n

e o

s nf T

c s

o s u p nnn.

er b q ha ea e

A n s.

e i

I t

od a

oe gl cl b p T

f t n m

fh uPl P i

i se yav o

ae ot o

eeW r

vk o

sn r

.hi vh t

=

r e f

hi hoit c

e e n

us t

s 2

bw nf

,mfe s

i s r o

aaf t

e e ae od a

rd re ht tcg c ceh t

t n l

c 6

eo r g u o u a n

dh u pis d pL r

t v e d

t s u

i

'n f nmr n

e o e h c

ok oo i

o v

h c a

oh Cs D

Ps CCoC Ct a r

t I

fos o

a.

b.

~c.

N 4

4 4

1 2

u t

3 3

3 4

4 a

tS

=

79 n

o U

s se t

e t e d

r e

r 2

e ob e

s e

t nw U

y pe n oeue t n l

o ev e

1 l

r h s et p

a sgt eb h a

m nh e nf et r

i r

e ge oe vs pit gim m et h an n

r e eut ho d

a e

nn.f e nos r

o i

t vae w adt ss i i neu l r m d cn n

el oTm e

nl a i l i

m nemt obhmf c

e v

n c

upo ih a a bu e c u u

,td d n ph o k c e

sdnr heTdce c

e ah ah o

sn e n.c vt

.labt aae ui D

A l

et 7if t c pb r b a9 r r

e e

s e oo v

v e

ueo u iU9 w

t t p o

o v

o vdp h

1 aep b

b o

fa e N

o b

9 Cht e f

t

,ms u

a a

H a

4 a ch od es 2 nv 5

5 o

,at n

2 wVtndo s

or o 4

4 t auCL.ist Oeet nd' 2

t l

e e *"

m m

t rMmr a

ts d

n s

. tnt a" t ne eR r

e e

r x

t t

e i

ri s f e he4ene" rN e

i I

e s ep a

,a t

I h pt e e

e et e al e

e hnDt e

Tt pA rpP S

S h

r I

h e e

Ti r

S ed r

mn e

t oa t e uh s s e

Ct 7 ds g9 2

ea l

yd Ai1n9 tc c e

2 r

t uh.

b d yu e

n dc t

L.

t.

l nud e

t os e d

p e

t e

.m cf n m"

I vo e

n so a

, i, eo b

b i

a s r r

mC r

o a

a d

h n a fS o

r S

5 5

e miw emd r

w t

atas pi 4

4 eo m

ega sTn m

m t

a a

t i

eH o

s wdt e

e Cts r t

t s

ns i

i i.

ee Hvh sau i

i g

e e

1 s

s Lnt hn u S

S

m. Y e

e 1

e ih eio I o htnc d' sA e

t I

uf d

d g

cf d'

Teu zdd ego e

e a

t t

P I

t e

r e

e n nn e es l

l h

l ieo pFh p

p opc mel mnn m

m t

sdl oo o o

o i

Oiw CDm C

C n

C s

s e

o sr t

s l o t

s f :

e ua c

s e

oe at a

s n

f b

e d.

n h

dg d

o o

ye g

r t

y mi n

d a n,u s a rb l

e f

t n k s

o a nl d

t a

n c

o sd n

d eh v

e sb d o<

e ul ri of d

n o

t i

s a

d u t

l n a n t

l v co e

di ni d

l i e

at e u

n o r

ur m

ed w

n i

a cim u y-en w

f e cs s

l i

e. fos hl c

i s r

n t

nm as a

l oim ad s v

n o

0 er f

e f

a i

.s n l

v i

e od i

o a

h =

c n

t ni e r c cc od g

v p4 i n

r o er e

v.

t t =

z-e r

l t

e n

f =

ia a e f se nf n n

r n ot i

v s

a t

oc c

so oidr o e a i

e e p

m:t e

R, ai i

e a

i nb f

e m

cn n

s e

t d s b

aim h, l o

i r e nd k k

n n

ao v.

shf u eh ona e

t v t

ht g

nf b a, m noe m

s p i

r.

a i

m ct t i l

as nl l

yi er l a

e t

P m

a m

a t wum ooP gnd m pb u

s t e i

t d

i r

ni l

o g

i t

d n s

l e

as qo csC uon et r h

m nm t

e b

ap o

n a i n c

s eE st a e

s i

l nc r

a e

t d

g o

l c hs o

et an o ne ea ph r

et s

y i, o nd u

f p

t n

i v d s, nt i

t C

pa ee s

o a o, eh niw i )s e

n mvt r

l v

y mf hn p

dc a

e

/

u n

h f

i ag i

f yt f ine d (m i om m

n e. n g mco nt v s aat o

e r o

t i

o t

t ii O

n r

t a l

i t

i n i

f s we e s os e

en e n r

wewc n ni xf n P

v oe em u

f sg at d i,l rf r

O glo s

eo a

i l

i s o i w P r. r r

i i o

aei O

t nt e

t p vt enac os e

vr n

p?

v t

weW em eenh P

c rhoierho C e :c -

r e v

ip c

e h

pein pr A

ma dt ot dmno sd M

f-e I

i e

Eh T

x t

h nf e t e shc nn dtam ht f

sE nea e

gio n e e

n s

aimsivwtaswr t

o e

at i a e 'c.

sc

. oa e

u d

s.

meileuaes

.it n iut r

M t

r t ert s s s

ae d a eteluas va nia a

i

. c nh l

m h P +s, v

aio e

o e

uv v es xb ev a o

pet h

a t, i

c AEiDeEOREmRMi nit t

n sd a

t h sd av r

t v c y

se m g cai f

i i

c :e t t c c r e s

u ci i

f l

i t

bt ua ol e

d et n

ac d

r nr n fla d

nP r

r e e

t a ef d

o s r od d

oC Cci Ep-CE P oia i

I fo a.

b.

s o

t N

3 4

5 5

5 4

4 4

4 a

4 eS

[

I

d 7

e b

M g

l 1

l l 2

n aie c

cwh

/

i i

u t

c net eao 1

d 1

i hu hct tnt p ca n e s one a o t

c s cor r es u

sst edi r u h

v t

t i

se f of t

i r oh of t f a et g se t r n nm a oi t

l uf m u oa l

sbr aso e mg vic r

s u o e ap el r

hap e

ob u e

e e

e t v n m

oha.

en t

t v

t e m

m m

o n

o t

b edi t

n n n a

a a

a snc a

di a t

t i

t nndP l

eaA 5

5 5

5 5

oae rpg 4

ms e t e

nh 4

4 4

4 n v.

m cm=g l

i t

l i a

m n

ir ig ea u

t t

wtocn e

n s

d r e

e e

e eg=

t r

ei I

t t

t t

i e

t Cnr e e

e or v I

I I

I r

Hoo e e

1 r a e

e e

e S

S S

S LmCm S

1 pd O e

e e

e t

t ss a

o e

et n

d h

n h

o e

s r

dse e

t m

t i

a na aC v

f a dt p

r a

i s

H t

or eiee om4L e

t t c

r t g cabrp r o ape f

ar uh o f

t

/d

) e n gR h e

pp.

dt t g s

r sn e nssn

?t o oo t

nr t f e=

a v

oeni e

N*

e e

t

. oo cv o

Ps o h=

o eib a

i b

nit t

o nst rr s

n ou e a

.ca el ai

. a e e u s m e

e o

/

e o m

m m

m gi s c b m

.e b bl n g

o bi.

ewvho a o nt i fl d v5 n

i t

ic v l

Y(C t

t a

a a

a uAecia 4

voe n

ri w pt s

c anht m dw 5

5 5

5 fi d

e-nAt h

i t

i c ni t

ncnn eo 4

4 4

4 o

e e o a s.

sr5 snu e ce ao 4 nnsmd t

m n

c uphf n t

cH a

qs soio wc oe yu s e

m n

d e

e e

e a

e n t,

h 'F. n c i t

t s

..eAh 2

s i

t h

t I

I i

ih s

aoh a ;-

o s c

g s i

1 a

htd u

u e e

e e

e C

JrDt b

n S

S S

S H Cude e

e e

e

.v f e l

o e

e s e

Tot aIf oY g

n v

e v

L hdt g-dne eeye~

P d

a Cf d

d d

d i

e t n n n t

om h hr e

e e

e ei c

t I

t t

t a ea e

chu cTac e

e e

e nt mu t

t a

s u r

imu c u. ed l

l e a5 n

r s

i l

s e

p p

ou ei o

s e t

o o

o o

o n a vpn ic slad otaeoh

. l t m

m el cna a

n o vs v emo

=f C

C C

C OeRicio Cei Ndnct e

l

,s a

g e

h c e.

n n

t hw m

h f

m i

o e

f ahm e

s t

c ol i

s s

ra o a g

y u e a

a=

h t

ct a

or no n c a

i u

o e

f os d

eme q

c mn or s

p hmt g i

r i

e n

ao bp shd 5 tn h r a

t ef d

o r n a

ax k bbt e

c gs u

ucn

,e yl i si i

eah l e l

l o n i

oe ah at sg nL l

rd vt ed r e a

p vt u o r

y eg ecmu ct E n pd a

w u

o h

O.

i e

e er a e e ad s.dl h h

nn t

vt s

f h m.

m h se e sr on t

oi t nbt t

e n

m v

s t r t t

e h u oo t

e e s o t

sdr nm.

-- cr a.

e ni nsl u e

m o

a R,

o r

p5 m

a a i u pb p

o e l

t a

of n

a rd md mi r

y pg e

neg ea e on t

nf t

ge anot t

r, a heo mgm

=- end r a c a a o n

- d i

or r

a i

mf i

l e

f s r

eo so e P

m (p t o nnh i

g de o e s a sh p prtpa d ui l

t s

em ua t

t n

t b h

m s

l e

r t

nu s e age m ng

= eun pea ni t

aa e e vat o5 a oe g

o on mss hc ns et di d

s s rl h

i i

u C

e sn c

e

=s h gei ne kn af t e e r

rdo nta4 nard e

t ca un ae e

/

s t v

y au f a og l i e

au ah ec hen t a #- tashc t eh onr a am wl tho O

t

=b-l i

i

= aps v

i t a mt e r r

i P

v v

o ut r

mt fl a e

=

e t

mt o n n dt t

0 i

O t

t r r a

i t G-i e

mf a

a op rk t

a o==

gc n n e

r ed P

c r

a gp p s

l e e e

A i

u e

u m a a.

opa r

ao oi n hk f

i t a s

t t r u gt r

e rt s

f n

sd d=

ps t c c5

. ps e o

ahe oe a r

ni t

h r

ye ep

- o4

. eot rtiw p

e=

nf

,mm ron pet g gwd f_fMn r t ss m

n o

o om ae ye a nnin i

ri p )s a i s

- n m n=

asd eos l

t n

l i ens ew-a n u

= ein c 'e e cit u t ci t

e v

=

t i f

c cn o

=

m u eb ul a s

a. -

eh s e i

adt si d

ua mr

=

r r

d sn drue up r

ne nel u pe g av t

d r n es eh v s

.n ng cd

=

a mc n l r s

~

oc e

., d o o e ae e

o o o n f

,r t

Chd Coei r

vt r

Cp Da n

r t Cps Ei I

.i f

l s

o c..

d.

e.

f.

g o

6 7

N 5

5 5

5 5

n 4

4 4

4 4

4 4

em as

[f j

llllI i

.s.-

Status ofI,'

^-S= ofITPOP Oversight Plan, Rev.0 11/21/97 Actions Regnised to Complete Implementation of Plan The table below summarizes the actions that remain to be completed to assure satisfaction of the actions and commitments identi6ed in the 11 POP Oversight Plan. Preliminary assignments have been made for most of the identified actions.

Action Items from ITPOP Commitment Review Item Action Item Assignee 2.1.b.

Formalm the Required Randmg List" of h=neate containing key Don Ferguson (with background information that the WC team maahers who helped create the support from John B.

Structured Intemew questionnaire and then conducted the interviews and John G. in originally read. Get appropnate people to sign of on the list.

constructing the list) 2.2 Work with Bob h=3=-iar to verify that the working files that document the Don Ferguson & Bob review of the ECP are adequately orgamand to arvive an audit.

Eagimeier 2.3 Ensme that the ECP review Ales and CAP ovemew files reflect the ongoing Bob Ensimeier & Tim overview efforts by WC for each.

Snyder 2.4 Fonnalw the list of all of the activities that NU is pursmng that are John / John to make intended to improve the safety culture. Detenmac how many of these are assignment already being monitored by WC, Assign people to monitor the one not already being monitored. Establish means to document that we are monitoring these activities to demonstrale amtiaraction of this commitment.

2.4.a Conduct the second round and any necessaiy additional rounds of.ir ; J John / John interviews to satisfy this commitment.

2.4.b Develop and i=a1*=*at a systematic approach to evaluating NU's self-John / John to make assessment program and Nuclear Oversight performance Document assignment evidence gathered and results of evaluation.

3.4 Identsfy those activities that WC should monitor on an ongoing basis.

John / John to make Develop an appmach for momtonng the selected activities, along with assignment to develop documentation requirements. Make assignments for monitoring and plan.

proceed to do so. Report on results of monitonag efforts as appropnate at future public meetings.

4.1 Develop Guidelines for documentation of ongoing effort to oversee the Al Cutter / Don i=al-ntation of the Comprehensive Plan.

Ferguson 4.4 Prepare and maintain case files for each of these cases that we lnvestigate.

Don Irwin/ Billie Garde 4.53 Continue to monitor the performance of the Corrective Action Program.

Don Ferguson/ Tim Document the activities that are being conducted to monitor the progress Snyder/Al Cutter being made in the Corrective Action program 4.7 Document our reasons for not evaluating the other licensee programs used to Don FergusonfTim E=4=' technical evaluations in a Muent revision to the Oversight Plan.

Snyder/Al Cutter F

Page 13 -

s.

11/21/97 status d hapla-*=han d ITPOP Oversigk Plan, Rev. 0 Discussion of Required Actions Each of the action items listed in the table above is briefly discussed in this section.

It= 21.b - Develon R= dred R==dino List A number ofdocuments were circulated among LHC team a,wA,ers to read at the baainnine of LHC's tenure at the Millstone site. These documents cwalaad essential background information with which team members needed to be familiar. We will prepare a list of the most significant of thest documents and have each team member certify which dac=nants they reviewed.

-Jimm 2 2 - Review Structure of ECP Review Files The purpose of this review is to assure that the files are complete and are organized so that they can be easily audited by outside reviewers.

Itam 2.3 - Kaan ECP Review Files and CAP Overview Files Current This will be done by Bob -

Engimeier and Tim Snyder as a part of the ongoing overview of these programs.

Itam 2.4 - Manitarine of Site Activitian intendad to Imorove Safety Cuhure LHC has already been monitoring a number of these activities. The list of all such activities that LHC should monitor will be formalized and assignments made to team c 0,ers to undertake appropriate monitoring efforts, with an attendant requirement to document the monitoring efforts.

Itam 2.4.a - Conduct Additional Rannd(s) of Structured Interviews LHC is already planning the second round ofinterviews. The data from this round will be anrj zed as for the first round and y

reported in a public meeting as before. LHC will continue to monitor the situation to determine if additional rounds of structured intitviews will be required, item 2.4 b - Evaln=te NU's Self-A====mant and Nuclame Overaioht Pronrams This effort should be

' initiated soon by assigning responsible individuals and requiring that evaluation plans be prepared and approved prior to beginning the evaluation.

Item 3.4 - Monitor Daily Activities Like Item 2.4.b, this effort should be initiated soon by assigning responsible individuals and requiring that briefmonitoring plans and documentation requirements be prepared prior to beginning monitoring efforts.

Item 4.1 - Devalan Guidalinas for Documentation ofOvernicht ofComorehensive Platl Development and application of these documentation guidelines will assure that an auditable basis exists for any conclusions that LHC reaches regarding the licensee's effoits to complete implementation of the Comprehensive Plan.

Itam 4 L4 - Prannte and Maintain Case Files As with Item 4.1, the files will provide an auditable basis to the conclusions that LHC reaches in these potentially contentious situations.

Item 4 5 a. Cantinue Monitorine Performance of Corrective Action Pronram ' A plan is being prepared to guide this activity, which will continue until LHC determines that the program is performing satisfactorily. <

Page 14 o

Jin r

t, 11/21/97

[

Status of I =F- = =tation d ITPOP Oversight Plan, Rev. 0 Item 4.7 - Document Ba=is for not Evaluatinn Other Programs This documentation will demonstrate that independent reviews ofthese other programs being conducted by other outside organizations will provide theinformation that LHC wil I need to achieve its objectives.

Page 15

ATTACHMENT 5 4

Little Harbor Consultants, Inc.

Millstone-ITPOP Project Office P.O. Box 0630 Niantic, Connecticut 06357-0630 Telephone 860-447-1791, est 5966 Fax 860-f f f 5758 November 18,1997 ITPOP 97-0049 Bruce D. Kenyon President and CEO Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385-0128

SUBJECT:

November 13,1997 Little Harbor Consultants Presentation Little Harbor Consultants, Inc. (LHC) presented findings and recommendations, developed as a result of our oversight activities, to Northeast Nuclear Energy Company (NNECo) and the Nuclear Regulatory Commission (NRC) at a meeting on November 13,1997. The meeting was held in the Millstone simulator building and was open for observation by the public. This letter forwards the slides used during the presentation.

If you have any questions or require further explanation on any of our findings or recommendations please do not hesitate to contact me.

Very truly yours, l

'12 N John M. Griffin ([/~.. >

Deputy Team Leader, OP Little Harbor Consultants, Inc.

Attaclunent cc: Distribution

A-ITPOP 97-00049, Page 2

. November 18,1997 Distribution:

D.M. Goebel, NNECo CharlesBrinkman Manager Washington Nuclear Operations Ph' NNECo ABB Combustion Engineenng Nucicar Power K. M. McBrien, NNECo 12300 Twinbrook Pimy, Suite 330 Roclaille,MD 20852 W. J. Temple, NNECo S. Baransid, NNECo Mr. John Buckingham Department of Public Utility Control M. Quina' ECOP Electric Unit U.S. Nuclear Regulatory Commission 10 Liberty Square Atta: Document Control Desk New Britain, CT 06051

.Waalungton, DC 20555 Citizens Regulatory Commission U.S. Nuclear Regulatory Commission ATTN: Ms. Susan Perry Luxton Atta: W.D. Travers 180 Great Neck Road Mail Stop:014D4 Waterford, CT 06385 Washington, DC 20555-0001 Citizens Awareness Network.

U.S. Nuclear Regulatory Comnussion

' 54 Old Turnpike Road Atta: P.F. McKee Haddam, CT 06438 Mail Stop: 014D4 Waslunston, DC 20555 0001 The Honorable Teny Concannon Nuclear Energy Adsisory Council U.S. Nuclear Regulatory Commission Legislative Office Building Attn: H.N. Pastis Hartford, CT 06106 Mail Stop: 014D4 Mr. Evan W. Woollacott Washington, DC 20555-0001 Co-Chair Mr. Wayne D. Lanning Nuclear Energy Adsisory Council Deputy Director ofInspections 128 Terry's Plain Road Special Prq!ects Office Simsbury, CT 06070 475 AllendaleRoad King of Prussia, PA 19406-1415 Ernest C. Hadley, Esquire 1040 B Main Street KevinT, A.McCarthy, Director P.O. Box 549 Monitoring and Radiation Division West Wareham, MA 02576 Department of Emironmental Protection 79 Elm Street Mr. Paul Choiniere Hartford, CT 06106-5127 "The Day" 47 Eugene O'Neill Drive

Allan Johanson, Assistant Director -

- New London, CT 06320 Office of Policy and Management -

Pohey C,

^ and Planning Division -

Bob DeFayette 450 Capitol Avenue-MS 52ERN 100 Kings Street

- P.O. Box 341441 Gettysburg, PA 17325 Hartford, CT 06134-1441 Don Beckman First Enlarenen 1071 State, Route 136 Town of Waterford

- Belle Vernon, PA 15012 Hall of Records

~200 Rama= Post Road :

. Walesford, CT 06385 -

e C NECTATIONS INDEPENDENTINVESTIGATION OF ALLEGATIONS OF ltETALIATlON AND HANDLING OF THE TRAINING Y, "f,'"*"

DISCIPLINARY ACTION Praected Ac Mues.

NNeCo should Anticipate and Take a

N W CMM Appropriate Act.on to Consider and Mitigate Present Wonto the impact and Potential "Chuling Effect" That INLC & NNECo Could Result When Discipline le Announced.

Novemisor13,1997 Par #culerty where Persons 06ecipilnod Have Been involved in Protected ActMWee.

.~,.y

- 3. y.

LHC EXPECTATIONS EXECUTIVE

SUMMARY

• If Retellationle AEeged, NNEco Should Take Inunediate end Adequate Action to SpecificeNy it is the Consensus of LNC That the July 13, Roepend to and investigste the Allegations of 1997,Dieciplinary Action Was Not in Retellation Retellemon.

for Employee involvement in LegeNy Protected

• NNECo should Conduct en Adequate Activities.

Investigation of "ChilNng Effect Which thght Resun Prom the piecipune and Tone Timely and Appropriate Action to telligste the

-Chang erseet.-

.c. y.

-.y.

EXECUTIVE

SUMMARY

OVERSIGHT OF MILLSTONE EMPLOYEE CONCERNS n to Aamo the Cone.neue er ueC That NNECo:

PROGRAM

- ou Ne enaeuveer Anmeipote end Plea **

DioelpIInery Ascens to Avoid er tegnendes Any

• channe w, uttle Harbor Consultants

- Did itse conduet en Adeguate envestigesen et Present donto

% SAset" Once flotellegen Was Alinged.

er Thha Thnet Acean to OHugees See "Ohgeng NRC & NNEco Olseet" lessened by Esapioyees; and Nevesnber 13, ige 7 6 Old test Puer bweeligste Anagogens et metenemen.

m.,mme.

nee anse. -

1-7

a:

ACTIVITIES COMPLETED DURING ACTIVITIES COMPLETED DURING LHC CONTINUING REVIEW OF ECP LHC CONTINUING REVIEW OF ECP R**"88'

. gritorylewed, -

. as anser pas.

- 12 BCP Staff Membere

. rs earposenwww neum.hereroc,

- ser amener eoene sem en en newtwem 11 Eniployees Prom Wie *New" Pilee n

~8

'N'" "

te sw eec p4.or. r,t:47,7.as.or te4s.

- 4 NNEco Officere pr st sett

. = o,es. sees. - nos e

. ecc.

an.naisissi.ec,

. ee, um. a e t di$"*

ESE ACTIVITIES COMPLETED DURING CONCLUSION LHC CONTINUING REVIEW OF ECP AREAS ADDRESSED

• ENeerves AceWee Aeneeseene WenIne Gensere

. Orgenlantion and Leadership pvessee:

• Ouellfication and Training

. enessee

. ecop osseesent erecP

-owenesumesecesw

. pes e e, e enesene

. Program Definition e'*

• Pre 9temimplementation 7,c7 meesteselere Prus

. Intehe

. Analysie &Trenchng

. Danes

. lausteer osereseht M

. inteospetten

.Decumentesen

' Cleeure

. Reporeng

. cteews Pepose -

tes.a. Ilessne

= acmewnen Rosessee

. Employee seawacoon

. Adminiserseen

. Ess.edvsmodseerscP me. er n.en

= nosena

=

5g=.

yg-.

CONCLUSIONS:

CONCLUSIONS:

ORGANIZATION & LEADERSHIP QUALIFICATION AND TRAINING

. Accepteste ECP stoft Gualthastion Suleeknee Neve gCP Resources Have inctoseed.

Seen Ertenhohee, But euelencemen Receres Are Not e

De6ng Reviewed one Documentes Per the Sulessnes.

W hade h improd.

, y,,,ning for Intekt one invoettgatione Hoe Isoproves.

4

)

+ Managensent Presence andlavo4vesnevnt Has

. Asequate Training en leonesying Potentie o,eroes, an..e,.rt.os.ue n

Provisee to the ECP steft.

. ECP Management's Sig P6ctwo" W Of Collective ECP leeues

. Ageltlenel Treining in left0 ene Sensitively in Dealing Needs To Imptove.

wHh ampieveen is gensees.

5g-.

e

.q;-.

1 j~

2

e CONCLUSIONS:

CONCLUSIONS:

PROGRAM DEFINITION PROGRAM IMPLEMENTATION Alternseye teenagement teethods for Receiving and Processing Concerne Are Now improved and includes Vehdemon WMh Employee.

e Seing Conducted in a Conodotont Atenner The meesen for Employee Coming to ECP vs. Lane Acceptende Common Guidelines for Dealln9 teenagement le Acknowledged but NonneMy test With Concerns Have Seen Established; Acted upon.

seeves of recenses operswissy and neportewany

' -- ""lon le Yet to Be Evolunted.

Amto to Am %n w Are k umm Contractere Are Not Required to Have Emit er Concound.

~

CONCLUSIONS:

CONCLUSIONS:

PROGRAM IMPLEMENTATION, cont.

PROGRAM IMPLEMENTATION, cont.

InvestiSation Ehti.93 1

closure Panele Are EWective in Derining Correcsve a

power neferrete and Addleon er Nn Ges# to ECP is Actone and Communicating With teenagement.

en improvement, At Concerne Are Not neceiving Consletent Quehty of Investagettens le im proving.

"'**w Ciesure new,semm.e noeun g in:

aCP noview and Centrei et neverred inveengemens

- tseeing iseuse neve hnproved.

- inapprenneen meessutenceews

= teseing Trende u

a

,,,y g=e*

,,,,,,=,,;a==*

CONCLUSIONS:

CONCLUSIONS:

PROGRAM IMPLEMENTATION, cont.

PROGRAM IMPLEMENTATION, cont.

EmSlovee Satisfa9 tion Analysis a Trendina

• The SCP Data Sees ites been improved.

• ge% Of the Eiepeevese Centested Empressed D6esesefecean and Would feet use the ECP Again.

• *Sig Pkture* Analyste end Trending of Collective Concerne le Not Seeng Performed and neported in e

• Communicamen Wuh Employees leineWective:

I"N

- Not Enough Dteing in Procese er et nosolueen to answe empesy e unseresandens and Swy.in.

i

. Ctesureimmers to Empesyees Are oman hapersonal and Winer.

es= *===*

.,,,u, museese 40,ase' U#

3 i

_ _j

e' CONCLUSIONS:

- CONCLUSIONS:

PROGRAM IMPLEMENTATION, cont.

PROGRAM IMPLEMENTATION, cont.

Documentation Resortine

• Compuence With De ECP Itenuel le heproving-

• The ECP Monthly Report Has improved.

. The Use of Concem Pee %48ste* Helpe PNe

• ECP le Presenting Summary information to Esecutive Orpealeotten.

IAenegement on e Monthly Deele.

• ECP Pee Chaseetogasel Lag Entrice are inconsistent.

. Wenceveness of These 7

le Sull Going Evolusand anc smace se wac*

m CONCLUSIONS:

LHC RECOMMENDATIONS FOR ECP PROGRAM IMPLEMENTATION, cont.

PROGRAM Adninistration inemese Centact Witn Empierees Throughout the Procwas, Particulerty at Resolut6en; Obtain Employse Itste Pecoted Concems Are Itot Casseined, Counted Pecebeck et Receiution.

and Tracted As IndMauel Concerne.

. soprove theintegrated Assessment of AN Conceme Secunty of ensin Files Mee leproved, but secunty for te idensfy Problem Areas in e Timely basener.

Working Pltes in Annes 2 is Net Adequate.

Provide Addataenel Treening to ECP staff en IGRO There le Me teenstering of off-ane Centracter and Senaltvity in Desting With Empieyees.

Employee Concem Requirements.

. Require a RAero Coneestent Closure Process for An Conceme.

m r

_.5.,.,.,--.

_.g r.

LHC RECOMMENDATIONS FOR ECP LHC RECOMMENDATIONS FOR ECP

{

PROGRAM PROGRAM

• Heintain Vigilance of inveettgegen QueNty,and

• Closelfy, Count and Track indMdual leaves Prem Aeouro That Au leeves Associated With e Concern ghstudeceted Concerne As Individual Conceme.

Are identined and Addressed.

. gneuve Offete Centractor Requiremente Are

• Report Why Insees Are Coming to ECP vs.Line implemented.

00nnagement in the Monthly RW RAndWy the Exit Process to Assure AN Centracters e

. Requero Conceme Wish Operonisty or Reportabelny Receive en Exit Interwow.

Potental to be Documensed on CRe.

• Ensure That Commen Guidelines Are Weed by AB Orgenteettone Procemeing Cenoems.

m

- _.3.y.

3

.u.

1 i

i 4

1

LHC RECOMMENDATIONS FOR ECP PROGRAM COMPREHENSIVE PLAN EFFECTIVENESS

. improve EcP nie s.curny in annes s.

• imPh.mont SCP sesff Guelencemen Review and oecumenieren neguirements.

. eminuet snevie cieerty penne nequired Little Harbor Consultants Chronningical Log satries (e.g Employee Contacts, Present49an to em p's.Tnese.l NRC & NNECo November 13,1997 m =.= mac.

m a

se g= ace AREAS EXAMINED BY LHC CONCLUSIONS:

. Safety Cons;lous Work Environment A Signifit. ant Number of HIRD Concerns (SCWE) Results.

Are Current'y Being Received and Substantiated by ECP.

Employee Concems Oversight Panel.

a

• Actions to Address Known Problems Site Training.

and Problem Areas Are Not Being 1

implemented in a Timely Manner.

g= g==c.

.c g= c.

r 1

)

CONCLUSIONS:

CONCLUSIONS:

• ECOP's Charter is Eroader Than the CP ECP,ECOP SCWF.Gecup,and Requirements and Duplicates some sCwE Management Activillen Are Not Ac*Mues.

Adequa'ely Coordinatod.

• ECOP Findings andinformation Are Not Communicated to ECP, sCWE, and Line teenagement in a Timely teenner.

= g c.

5 3

1

9 e_

e CONCLUSIONS:

CONCLUSIONS:

The ECP Presentation in " Managing for Cuttent Training Cou ses for Managers a

and Supervisors Are Not SufRcient for Nuclest Safety"is Not Being Managing Concerne in the Current Consistently DeHvered to Comenunicate:

Envivenment:

- Management E 4+ ^ ^' : for ECP;

- LacNeg in #w Arses of Protected Activenee,

- How ECP Conducts Business; Rotallation, and ChMung Effects.

- How Employees Should Interfe:e WRh ECP, a

q; e.

47;-=

CONCLUSIONS:

LHC RECOMMENDATIONS

. poiEco Managenwnt Must Provide Leadership EtnploMs Are Not Being Trained on to Correct Problem Areas in a Timesy Menner.

SCWE and ECP:

. DevelopImproved Mechanisme for

- A key Employee Course,"Portnership Communicating, Coordinating and Effectively Beyond 2000", Hee Been on Hold Since the Acting on information Between ECP, ECOP, Treening Department Shutdown.

SCWE Group and Management.

• Narrow ECOP Activitsee to Focus on Greatest SCWE Needs of the OrganizaWon in a Timely j

Menner.

j a,,,,,,5, %=-

q

=c.

=

I LHC RECOMMEP:0ATIONS LHC RECOMMENDATIONS Communicate ECOP Pindinge and

• Improve the ECP Training Segment Recommendelions on a Real Time cases to included in " Managing for Nuclear ECP,the SCwt ereup and une Management Safety".

Se They can Act on the Resuna.

• Resume Employee Training on SCWE Provhie AddMlonel Training for Managers and '

and ECP, Supervleere That Adequately Covere Protected Activities, Rotenation, and ChNiing Effect.

gg==e.

~

,,,,,,5, %""**

i t'

'6

e a

CONCLUSIONS:

MEASURING EFFORTS TO IMPLEMENT A SAFETY CONSClOUS WORK

• A Significant Number of HIRD Concerns Are Curfontly Being Received and ENVIRONMENT AT MILLSTONE Substantiated by ECP.

Little Harbor Consultants

• Actions to Addfoss Known Problems p,,,,,,,,,,,

and PfoMem Areas Are Not Being NRc& NNECo implemented in a Timely Manner.

,.,,,7%="*'

ggi se.

t O

LHC's OVERALL MISSION: OVER.

NNECo IS CASED ON OVERSIGHT SEE IMPLEMENTATION OF SCWE PLAN

• From Overs 6ght Plan; ". evers6ght will continue until such time that the NRC deter.

• Oversight Planidentifles 11 Attributes Usually mines that lNU) has demonstrated by its per.

Present When strong safety Culture Exists.

formance that the conditions.have been

• Additional Attributes May Se Added sased on corrected and that safety issues raised by LHC Oburvadons.

employees are being evaluated and tesolved in a timely manner

• LHC is Continuounty Monitoring for Presence a

• LHC's Oversight Activit6es Pocus on Ag of These Attributes Through interviews, Aspects of NNECo's Efforts to " improve the Program Reviews, and/or Observations.

safety.ceurc1Lmeiement a sCwEt

,,,,, ;;%='*

. ;g-c.

=

STATUS INDICATORS FOR SCWE STATUS REPORT IS PRELIMINARY IMPLEMENTATION EFFORTS AND PARTIALLY COMPLETED eseets aspectat6 mis F"'~~")

• LHC Has Completed Some Key Activities

,~

~

approecwne

- structured Interviews E8P'C1'uons

- ECP and CAP initsal Reviews tdmo)

L.J

. Other oversight Activities Still ongoing (ditto)

W "g*,'IP

- Compeehensive Plan Effectiveness Review h segnmcent

- AdditionalstructuredInterviews weakness

- Closure of ECP and CAP Reviews none.

T empremas -+ emer 4Dul#*9

- C9DtlfHilng QblerVStlon 3djelt3CtlVides

=me.

• "**g7 %"".

I 7

i 1

+

e'

)

LHC ASSESSMENT OF SCWE LHC ASSESSMENT OF SCWE IMPLEMENTATION STATUS IMPLEMENTATION STATUS mamammen

ac. w

man m,

m, m

J.e." T

• l," " "

• 1, ""

...e

.. w e, u m. u 4 tI c,u.se

,=,--i.-

c, *n OC'"

• Z'T.' T.

,=,,=,rja,,-.,ll;a,,,, ; =

P. a*

e in, s.-e g-.

7;-.

LHC ASSESSMENT OF SCWE NNECo PERFORMANCE IMPLEMENTATION STATUS MEASURES

=--

'a==^=.

maa SAFETY CONSClOUS WORK l

ENVIRONMENT c',';*Z."rla'"i!. 9!

;,L'"*,*.,'=,,,';;*.;".,,', 'l' am.n er we ne ee a

Little Harbor Consultants g. g 7.u..t**

Presentation to

.se ne imy NRC & NNECo November 13,1997 Exavvele

, g-c.

g=.

LHC ATTRIBIITES AD6IiE5 SED BY LHC SCWE ATTRIBUTES NOT MILLSTONE PERFORMANCE INCLUDED IN NNEco ATTRIBUTES MEASURES

• Employee Percept.one of SCWE Policy.

. Employee Perceptions of SCWE Policy.

. Mutual Respect for People at All Levels.

. Work Force Has sense of identity.

. No Evlstence of an Atmosphere Causing a

. Mutual Mespect for People at All Levels.

W6ng N"

, HIR&D Events are Rare; Management Reaction Timely.

e.

- - -sc.

8

e

' e'

IRCTITRIBUTEFK5bRESSED BY LHC ATTRIBUTES NOT 1

MILLSTONE PERFORMANCE ADDRESSED BY MILLSTONE MEASURES PERFORMANCE MEASURES

• No Evidence of an Atmosphere Causing a

• Senior Management Endorsement of SCWE

• Chilling Wrect."

Pol 6cy.

• WWettive and Emelent Corrective Action

• Senior Management Provides Adequate Prveram.

Training.

• ECP Program ie Vigorous and Effective.

• Employees ExhitWt a Questioning Atutude.

• Self Aseesoments Are Effective.

• Positive Recognitionto Employees Who identify Safety issues.

,,,;5, ;--

P 9

ATTACHMENT 6 EDITED

SUMMARY

OF THE MEETING AMONG NRC STAFF, NNECo and LHC, NOVEMBER 13,1997 AT MILLSTONE, FOCUSING ON THAT PORTION OF THE MEETING CONTAINING PRESENTATIONS HY LHC Ete: This sununary se based on a combination of(l) the IJIC PowerPoint presentatwns made at the meeting, converted to a word processing format, and (2) the videotape taken of the meeting {there is no official transcript of the meeting). Since the purpose orthis sununary is to capture the substance of the rindings and recommendations being m..de by LilC rather than a transcript of the entire meeting, it does not cover those gxstions imching presentations or comments by others, except as they involve questions or rewponses to IJIC-sponsored material.

. ERELIMINARY MATTERS INTRODUCTION BY NNECo (Buzz Carns): Our progress toward SCWE needs to get into a more anticipative mode. In the recent Quality Control (QC) situation we took adequate action once we focused on it, but we should have acted on the information that was available to us sooner. (Carns also discusses the initial proceedings of the ERB.)

LHC (Griflin) [ responding to Carns]: We have stated several times previously that we think that the ERB is a necessary stopgap at Millstone at present. Out overall observations are positive.

The ERB is taking a very disciplined approach. They have encountered some bumps in the road but overall the results are good. LHC will continue to monitor progress.

LHC (Deck): We will make 6 presentations today:

1. QC Group Situation, discussed in LHC letter of November 12,1997 [ITPOP 97-0047]

2. Independent Investigation Of Allegations Of Retaliation And Handling Of The Training Disciplinary Action

3. Oversight Of Millstone Employee Concerns Program

4. Comprehensive Plan Effectiveness

5. Measuring Efforts To Implement A Safety Conscious Work Environment At Millstone

6. NNECo Performance Measures: Safety Conscious Work Environment

1. OC GROUP SITUATION IITPOP 97-0047. November 12.19971

[ Presented by John Beck]

Our protocol requires us to bring time-sensitive issues to the attention of NNECo management, then to send written information promptly to the service list, thus getting it to

- affected groups. The letter is self-explanatory except for the last 2 paragraphs. As Mr. Carns said, the matter was dealt with straightforwardly and quickly once it was brought to Mr.

Brothers' attention, and we commend NNECo for that. But we're still concerned that these

)

i'ssues were known to management for months and were not effectively addressed until they

2 appeared to reach a state of crisis (Carns concedes this.) We're also concerned about certain other " problem areas" in NNECo that could also become crises, and encourage NNECo to put laser focus on them to preclude their becoming ciises. We will watch resolution of QC Group questions and will be monitoring action taken in other problem areas.

NNECo (Goebel): QC is in my area. I agree that most of the QC Group issues were known to some degree to someone in NNECo management. We are addressing why they weren't addressed earlier. Some of the issues were valid, and we're speeding up our review of them.

We're also looking at what we can address.

NRC Q/A: As a matter of process, are there other areas that raise the same kind of concern and need to be targeted now?

NNECo (Goebel): There is one, I told you about before the meeting, that we're looking at

[does not mention it by name here]. Not all of them are within my purview. We need a more site-wide attack on them.

NNECo (Brothers): This is area 3 of my intended presentation. We think we're not meeting our goals there yet. We have found and omcially identified 33 " Problem Areas" (former so-called " hot spots"]; we have action plans for 10 of them; 4 are considered resolved. The QC situation reveals a lack of understanding by management of the importance of dealing with these issues. Finally, the incidence of HIR&D complaints remains too high. We will review this with management tomorrow. We are also getting status of all 33 problem areas for omccrs tomorrow. We are also collecting information from ECP on HIR&D complaints for omccrs. Evaluations to date have been "in silos," not integrated across site or areas; we need to start the coordination process. Tomorrow's meeting with the omcers is their first exposure to it in detail. We look at these areas from 5 standpoints, and many of the areas have problems with all five.

NRC Q/A: How does an area become a " problem area?"

NNECo (Brothers): We have various criteria, involving consultation with LHC, ECOP, Leadership Surveys, Oversight, Pil surveys, etc. We don't like to designate an area from just one standpoint; many of these have indications from all 5. We have a small group doing the analysis. " Problem Areas" can be an individual or a group; dermition of the group " rolls to the smallest group" that includes all of the complaints: a group of people, a first-line supervisor, a manager, etc.

NNECo (Carns): Ofindividuals, supervisors or managers getting Leadership Survey results,3 have lef1 NNECo; 6 have voluntarily " stepped out of supervisory roles" to individual contributors; thus they're no longer in management. Iluman Resources (HR) is helping with aggressive intervention plans. I'm encouraged. NNECo will monitor the results of HR's intervention. We don't close an area until we have done this monitoring and review.

NNECo (Brothers): Assessments are done after plan implementation.

3 NRC Q/A: What process are you using for assessing success?

NNECo (Brothers): We do the evaluations, but there's no specified deadline because of the disparate aspects of these situations. We may re-evaluate these as we go forward.

NRC Q/A: What are your plans for post-closure monitoring?

NNECo (Brothers): We plan to do it, but we don't yet have a procedure for doing it.

2. INDEPENDENT INVESTIGATION OF ALLEGATIONS OF RETALIATION AND HANDLING OF THE TRAINING DISCIPLINARY ACTION

[ Presented by John Griflin]

GRIFFIN INTRODUCTION re TRAINING INVESTIGATION Our investigation grew out of the 7/23/97 training discipline, involving complaints that the discipline was unfair and, in one case, involved retaliation for protected activity. The NNECo investigation (by Admiral Carr) focused on the fairness of the discipline; we focused on the retaliation allegation. We found no retaliation. LHC have completed our investigation and will issue a report in several days; we can give you our expectations and conclusions today.

LHC EXPECTATIONS

1. Disciplinary actions should not be taken in retaliation for employees' engagement in protected activities.

2. NNECo should anticipate and take appropriate action to consider and mitigate the impact and potential " chilling effect" that could result when discipline is announced, particularly where persons disciplined have been involved in protected activities.

3. If retaliation is alleged, NNECo should take immediate and adequate action to specifically respond to and investigate the allegations of retaliation.

4. NNECo should conduct an adequate investigation of" chilling effect" which might result from the discipline and take timely and appropriate action to mitigate the

" chilling effect."

EXECUTIVE

SUMMARY

LHC (Griflin): This was a lengthy and diflicult investigation. As in many such investigations, we had to rely on circumstantial evidence. Here is what we found, in summary:

4

1. The July 23,1997 disciplinary action was not in retaliation or employee involvement in legally protected activities, using tests used by DOL and the courts.

- 2. However, NNECo did not effectively anticipate and plan the disciplinary actions to

. avoid or minimize any " chilling effect."

3. NNECo did not conduct an adequate investigation of" chilling effect" once retaliation was alleged, or take timely action to mitigate the " chilling effect" identified by employees.

' 4. ' NNECo did not fully investigate allegations of retaliation.

LIIC (Griffm): The report will be out within the next two days.

- NRC Q/A: Where did NNECo's investigation of retaliation fall short? Who in NNECo was expected to do an internal investigation into retaliation?

LIIC (Griffm): No one, though it appears that they expected Admiral Carr to conduct one.

Carr's initial report made no mention of the subject. In a supplemental report, Carr mentions it, but provides no basis for his conclusion that he found no retaliation.

NRC to NNECo: Where would you expect this kind ofinvestigation to take place within NNECo?

NNECo (Brothers): ERB is the location, now that it's in place. We put it in place Aug 13, but ERB didn't exist when these events occurred on July 22. Ifit occurred now, ERB would investigate before any discipline took place.

LHC (Griflin): In the MOV event, ECP organization did investigate the retaliation allegations in great detail.

NRC Q/A: What does the LHC report recommend?

LHC (Griflin): This report does not contain any recommendations. The report includes conclusions and the backup information supporting the conclusions.

NRC Q/A: Why was there no ECP involvement in the Training matter?

NNECo (Streeter): No complaint went to ECP. These types of allegations don't automatically go to ECP: it's a safety valve. If concerns go to the line organization and it resolves them, that's fine.

5 LilC (Beck): Just to make the record clear, there were visits to LHC, from more than one source, alleging retaliation in the training matter; this is what triggered our interest.

NRC Q/A: When this happens, what do you do?

LiiC (Griffm): We encourage them to take the issue to ECP or line management first. Our role is not to mount separate efTort, or be a separate ECP. Then we watch what NNECo does with the issue put before it.

NRC Q/A: In some of your reports, you have dived deep into issues. What kind of expectation are you creating for the future?

LIIC (Griffm): We hope that in the future our role will come to be perceived as superfluous and that we can fade away. In the interim, our Oversight Plan has various facets that will get us involved. One of them is to do an independent evaluation of an issue in which NNECo is itselfinvolved. That was the impetus for MOV investigation, since NNECo was already evaluating it itself. Normally, we don't get into these types of things and we hope everyone understands that.

NRC Q/A: Do you think that everyone understands that?

LIIC (Beck): I hope so: Let me say again, normally we don't do this type ofin-depth inquiry.

I think NNECo understands that, and I hope that the Commission doesn't expect us to: it would be a misallocation of resources. But from time to time we will do so.

NRC Q/A: You mentioned that several people affected by training discipline had come to see you. What kind of reaction did you get when you suggested that they go to management or ECP7 LHC (Beck): I hesitate because of confidentiality: usually when they come to see us they feel uneasy about going to NNECo or perhaps to the Commission. In this situation we understand that information went promptly to the Commission, though not to NNECo. But we did encourage them to go there.

NRC Q/A: In MOV case, ECP was right on top ofit and did a good job. IIere, it's distressing that no one out of about 20 went to ECP.

NNECO (Streeter): L11C has referred at least 20 cases to us and then backed off to let us handle them. They then continue to observe our performance on them.

LIIC (Griffm): In the Training situation, the individuals decided to go to NRC rather than to

)

ECP.

=

6

3. OVERSIGilT 0F MILLSTONE EMPLOYEE CONCERNS PROGRAM

[ Presented by John Griflin]

l LHC (GrifSn): Our initial presentation on July 22 was a " pretty stiff wire brushing of the ECP program." Since then, we've continued our review, focusing on the etTectiveness of the corrective actions taken in response to our fmdings. Our expectations have not changed.

ACTIVITIES COMPLETED DURING LHC CONTINUING REVIEW OF ECP

1. Reviewed:

24 "New" Files 23 "Old" Files That Were " reworked" by ECP since reworking of ECP manual e

ECP Monthly Reports done in the new format e

ECP Database NNECo's Letters to the NRC (7-6-97,7-22-97,7-24 97,10-16-97,11-3-97)

Joint Investigations Guidelines, Rev 0 e

ECOP Reports related to ECP ECP Manual, Rev 1 e

2. Interviewed:

12 ECP staff members e

11 employees from the "new" files e

9 Employees from the "old" files e

e 4 NNECo oflicers

3. Observed the following activities associated with the concern review process:

Intakes Staff meetings, ECP and Nuclear Oversight Training of ECP investigators Triage Closure Panels e

Executive review of ECP Monthly Report e

ECOP debriefing of ECP e

Focus group meetings e

Nuclear Oversight Readiness Verification Panel Nuclear Oversight All Hands Meeting e

ECP-HR Joint Meeting

7 CONCLUSIONS

1. ORGANIZATION & LEADERSHIP ECP resources have increased.

e ECP organizational structure has stabilized.

ECP staff morale has improved.

Management (Morgan and Goebel) presence and involvement has improved.

ECP management's " big picture" understanding of collective ECP issues needs to improve on the part of all. We are concerned that management does not yet appear to be stepping back and taking a big-picture look at trends rather than single cases.

2. QUALIFICATION AND TRAINING Here, we also see improvements.

Acceptable ECP Staff Qualification Guidelines have been established. This is a correction since July. But it is not clear how they are being implemented. We believe they are, but can't document it. Qualification Records are not being reviewed and documented per the guidelines.

Training for intake and investigations has improved, with corresponding improvement in implementation.

Adequate training on identifying potential operability and reportability issues has now been provided to the ECP staff, also with improvement in implementation.

Additional training in HIR&D and sensitivity in dealing with employees is needed.

3. PROGRAM DEFINITION Alternative management methods for receiving and processing concerns -

various hotlines and informal processes for receiving information -- are now being implemented in a consistent manner. Information from them is available for analysis.

Acceptable common guidelines for dealing with organizations receiving concerns - ECP, Security, etc. - have been established recently, implementation is yet to be evaluated. We will be looking at them soon.

Contractors are not required to have exit interviews. We think this is a gap in

+

the program and should be re-evaluated

4. PROGRAM IMPLEMENTATION Intake Overall, has improved significantly and now includes validation ofissues with employee; a marked improvement since July.

The reason for employee coming to ECP vs. line management: information on this issue is being collected by ECP, but is not being fed back to line management for action.

M Issues of potential operability and reportability appear to be acted upon, but

=

are not being documented or controlled to verify that they've been put through the formal system.

~NRC Q/A: What kind of action would you expect them to take?

A (Griffm): It would not involve dealing with individual cases, but rather organizational issues or recurrent problems - recognize the barrier and break it down.

NRC Q/A (to Streeter): What are you doing with this information?

A (Streeter): As Griffin said, we're collecting and evaluating, but haven't been feeding back to line. Streeter corroborates a recent ECOP suggestion that ECP start feeding this information back to line about " hot spots" or " problem areas." Typically, people come to ECP because they have been unsuccessful in dealing with line management. This is an opportunity to help line resolve issues.

Investigations are also improving:

We are seeing fewer referrals from ECP to other organizations; and addition of HR and Internal Auditing Staff to ECP is an improvement.

Quality ofinvestigations is improving. Perceptions of their quality are improving.

Quality of ECP review and control ofinvestigations referred to other organizations (HR, Security, etc.) have improved.

Closure Closure Panels are effective in defining corrective actions and communicating e

with management. Not all concerns are receiving resolution / closure review; thus there are inconsistent results. Sometimes this results in missing issues, inappropriate resolution / closure and missing trends.

Emolovce Satisfaction: This is the most significant issue / challenge for ECP.

July interviews review showed 37% of employees dissatisfied with ECP and would not use ECP again. Current file reviews of old and new files showed that 50% of the employees contacted expressed dissatisfaction and would not use the ECP again.

We believe that this problem is very closely tied to ineffective communication

.with employees, particularly at closure of concerns:

- Not enough dialogue in process or at resolution to ensure employee understanding and buy-in. We believe that this problem stems from lack of communication and dialogue with employees about ECP's conclusions and process.

- Closure letters to employees are often the first and sometimes the only communication. They can be impersonal and unclear. Often the

9 i

employce's only commuisication has been an impersonal closure letter, which begins " Dear Concernee."

NRC Q/A: Did the employees who are dissatisfied tend not to have gotten the relief they wanted?

A (Griffm): Yes, predominantly. But the key is less whether the concernee gets the relief he wants, than in giving employees the sense that their issues have been looked at carefully.

NRC Q/A: Is 37% to 50% an adverse change despite additional resources and good press from MOV incident?

A (Griffm): No; the change isn't great; the point is that the situation has not gotten better.

NRC Q/A: llow about the Manual's goal of resolution of concerns within 30 days?

A (Streeter): Our own information is that we need to improve on getting information back to individuals: (a) give more weight to getting through in 30 days; (b) improve our " standard" letter to deal with " dear concernee" issue (confidentiality] or recognize the risk and fear that concernees often feel. Confidence is key to us, and we feel that confidentiality is key to that is a lot of cases. We are re-evaluating what to do here.

4 NRC Q/A: llow do you think that " Dear Concernee" protects confidentiality?

l A (Streeter): We try to avoid putting names on paper any more frequently than we have to.

We're working on the problem.

i Anal sis & Trending y

The ECP Database has been improved.

13ut " big picture" analysis and trending of collective concerns is not being performed and reported in a timely manner.

Dagumentalinn Compliance with the ECP Manual is improving.

The use of concern file " booklets" helps file organization.

ECP file chronological log entries are still inconsistent.

Renoning The ECP Monthly Report to management has improved significantly.

ECP is presenting summary information to executive management on a monthly basis. We have witnessed two of those presentations so far.

Effectiveness of these presentations is still being evaluated.

10 b_dministration Frequently, multi-faceted concerns are not classified, counted and tracked e

individually, with the result that some concerns may not be focused on and addressed (some may have nuclear safety components and HIR&D components; present system doesn't permit this breakdown).

Security of main files has improved, but security for working files in Annex 2 is not adequate.

There is no monitoring of existing NNECo standard-contract requirements that an equivalent of the ECP be put into place for off-site contractor employees (e.g., the contract requires GE-San Jose to have an adequate ECP, though not necessarily the one used by NNECo; contractors on site use NNECo ECP).

Brothers notes that NNECo's implementation of 50.7 is more aggressive than those of most other firms. Streeter says he's looking into it.

RECOMMENDATIONS FOR ECP PROGRAM

1. Increase contact with employees throughout the process, particularly at resolution; obtain employee feedback at resolution.

2. Improve the integrated assessment of all concerns as " big picture" to identify problem areas in a timely manner.

- 3. Provide additional training to ECP staff on HIR&D and sensitivity in dealing with employees.

4. Require a more consistent closure process for all concerns.

5. Maintain vigilance ofinvestigation quality, and assure that all issues associated with a concern are identified and addressed.

6. Inquire further and understand why issues are coming to ECP vs. line management and discuss in the Monthly Report.

- 7. Require concerns with operability or reponability potential to be documented on CRs.

8. Ensure that common guidelines are used by all organizations processing concerns.

9. Classify, count and track individual issues from multi-faceted concerns as individual concerns.

10. Ensure off-site contractor requirements are implemented.

I1. Modify the exit process to assure all contractors receive an exit interview.

1

1 11-

' NRC Q/A: How is this to be'done?

' A (Griflin): It doesn't necessarily require individual inte views; it does require at least group-interviews with opponunity for individuals to raise issues there or to have an individual interview.

4 RECOMMENDATIONS FOR ECP PROGRAM (Continued)

12. Improve ECP file security in Annex 2.

13. Implement ECP staff qualification review and documentation requirements.

14. Manual should clearly define required chronological log entries (e.g., employee contacts, CR #'!s, triage.)

I LIkC (Griffin) Summary: Keep pushing for excellence. This report shows pretty significant progress, but also shows you have a long way to go, particularly with respect to " customer satisfaction."

NRC Q/A: Do you have a formal tracking system for your recommendations?

A (Griffin): Yes. LIIC and NNECo cooperate on this; we will continue to track issues for closure and effectiveness, and document the ones that are tracked and closed out in quarterly reports.

NRC Q/A: This is imponant to NRC, too.

NNECo (Streeter) re security in Annex 2: Is the problem with locking of file cabinets or locking ordoors?

LHC (Griflin): Locking of doors, particularly during lunch hour, when the entire space is accessible and not closely watched.

4. COMPREHENSIVE PLAN EFFECTIVENESS

[ Presented by John Griflin] -

AREAS EXAMINED BY LHC A. Safety Conscious Work Environment (SCWE) results.

B. Employee Concerns Oversight Panel.

j-g

' C. Site training

' I

.1-

. f..f-A s

12 CONCLUSIONS

1. A significant number of HIR&D concerns are currently being received and substantiated by ECP: over the last 3 months, 52% of all concerns had an HIR&D component; in October,71% of them did. Over 60% of these allegations are still being substantiated.

2. Actions to address known problems and problem areas are not being implemented in a timely manner. This is true in QC and other areas.

3. ECP, ECOP, SCWE Group, and management activities are not adequately coordinated. We have seen a lot of activity but there does not seem to be timely communication to permit effective response. The QC Group event last week was an example of a situation where there was information available that should have raised the flag for all concerned that it was an issue getting ready to go to a crisis stage.

4. ECOP's charter is broader than the Comprehensive Plan (CP) requirements and duplicates some ongoing SCWE activities.

5. ECOP findings and information are not being communicated to ECP, SCWE, and line management in a timely manner. They are finding some very good information but it is not being communicated in a timely way.

6. Current training courses for managers and supervisors are not suflicient for managing concerns in the current environment. They are lacking in the areas of protected activities, retaliation, and chilling effects. This is a deficiency that we have mentioned at least one time before now.

7. The ECP presentation, which is part of the " Managing for Nuclear Safety" course is not being consistently delivered to communicate these three elements:

Management expectations for ECP; How ECP conducts business; How employees should interface with ECP.

8. It is an important part of that presentation and this is the only means for it to be presented to the work force. It needs to be tightened up and presented in a consistent and straightforward manner.

9. Employees are not being trained on SCWE and ECP, despite commitment in CP:

A key employee course, " Partnership Beyond 2000", has been on hold since the training department shutdown Nothing else has taken its place.

NRC Q/A: What about training a couple of weeks ago in Norwich?

o

13

)

1 I

A (Griflin): That was good, but, it was for managers and supervisors only. The cunmitment in the CP is for the entire work force.

I J

LiiC RECOMMENDATIONS NNECo management needs to:

1. Provide Icadership to correct problem areas in a timely manner.

2. Develop improved mechanisms for communicating, coordinating and effectively acting on information between ECP, ECOP, SCWE group and management.

3. Narrow ECOP activities to focus on greatest SCWE needs to ensure that information is provided to the organization in a timely manner.

4. Comm'micate ECOP fmdings and recommendations on a real time basis to ECP, the SCWE group and line management so they can act on the results.

5. Provide additional training for managers and supervisors that adequately covers protected activities, retaliation, and chilling effect. We understand that that training has been approved and should begin next week. Ifimplemented, it should address this concern totally.

6.

Improve the ECP training segment included in " Managing for Nuclear Safety" and ensure that it's being provided in consistent manner.

7. Resume employee training on SCWE and ECP.

LHC (Griflin) In summary: Your biggest challenge is that actions taken to date have not been effective in reducing either the number of ECP concerns received or the percentage of them that are substantiated. Further, actions to address known problem have not been effective. This inefTectiveness is being perceived by both your employees and your overseers as a lack of resolve on the part of management to address these very important issues. They both have to be fixed.

NRC Q/A: What are the kinds of things that people are coming with to ECP (being downgraded, pay being cut, bad performance appraisals, etc.)?

A (Beck): Everything you've mentioned, plus more. There are some indications that ECP is over-classifying files by now, and that ECP is not making any preliminary screening of their validity.

NNECo (Streeter): We're being even more conservative: we look through the words and try to hear what they're saying.

NRC Q/A: Are you "over-substantiating" too [re the 60% reported as substantiated]?

m 14 A (Streeter): Yes.

NRC Q/A: How do you view the fact that 60% of HIR&D complaints are being substantiated?

Does it stem from the way you're classifying these things?

A (Streeter): Could be. ECP could have been giving ofTicers better information on trends in the areas. Brothers wants a meeting tomorrow with ofIicers to develop " decisive and dramatic" reactions.

NRC Q/A: You really have to understand what your numbers represent, or it's the blind leading the blind.

A (Streeter): I agree.

LHC (Griflin): Just the large number of concerns is itself a problem. If those issues are out there, management has to focus on them. We will be watching them. The problem is that the steps taken to date to get people to bring concerns forward haven't been effective in heading them off.

The other item to remember re ECP training for the work force: the Comprehensive Plan action item for that training we.s crossed off when the training lesson plan was developed. But the training has never taken place. This was not the intent of the action item. We will need to go back and see of there are other such premature signoffs.

NRC Q/A: We're concerned about a number of such potential situations. We're concerned about how these are being pulled together.

5. MEASUPING EFFORTS TO IMPLEMENT A SAFETY CONSCIOUS WORK ENVIRONMENT AT MILLSTONE

[ Presented by Don Ferguson)

LHC INTRODUCTION (Beck): We've been putting a lot of effon into putting together a methodology for evaluating Millstone performance against SCWE goals. We've got some preliminary thoughts. We're not finished, but want you to see our work to date today and give us any comments you may have bec0use this is a very important bottom-line area for us. We will give some specific examples of how things will look when things are finished.

LHC's OVERALL MISSION: OVERSEE IMPLEMENTATION OF SCWE

' LHC (Ferguson): Our hope is to measure NNECo's progress toward SCWE in response to the

)

NRC order requiring them to do so and setting LHC's charter. We will present our final methodology and initial conclusions next month. Here's what they would look like today:

-15 Our efrorts derive from the NRC's guidance:

1. From ITPOP Oversight Plan: ".. oversight will continue until such time that the NRC deter-mines that [NNECo] has demonstrated by its performance that the conditions.

have been corrected and that safety issues raised by employees are being evaluated and resolved in a timely manner."

2.

LHC's oversight activities focus on all aspects of NNECo's efforts to " Improve the Safety Culture" (Implement a SCWE).

LHC APPROACH TO MEASURING NNECo IS BASED ON ITPOP OVERSIGHT PLAN

1. Our approach derives from the ITPOP Oversight Plan, which identifies 11 attributes usually present when strong safety culture exists (or an SCWE exists).

2. Additional attributes may be added based on LHC observations. We've added one (HIR&D).

3 LHC is continuously monitoring for presence of these attributes through interviews, program reviews, and/or observations.

STATUS INDICATORS FOR SCWE IMPLEMENTATION EFFORTS Here are LIIC's proposed indicators and scaling for SCWE:

STATUS INDICATORS FOR SCWE IMPLEMENTATION EFFORTS Meets Expectations Approaching Requires Management Action

+ ven=

Expectations Y'""

(ditto)

Marginally (ditto) l - v.u-Exhibits significant g,,

Weakness A

Trends i Improving

-* Steady Declining

16 STATUS REPORT IS PRELIMINARY AND PARTIALLY COMPLETED L11C Has Completed Some Key Activities:

1. Structured Interviews i

2. ECP and CAP Initial Reviews

3. Oversight Activities

4. Comprehensive Plan Effectiveness Review

5. Observation of Site Activities We have a lot of bases for continuing to judge site activities to give us a basis for judgment.

These all help us to judge presence or absence of SCWE. We're ready to present three areas today 'where we have some views.

NRC Q/A: How do you measure and grade each attribute?

A (Ferguson): In scientific terms, the Delphi process: we get all the knowledgeable people in a room, and develop our consensus. It's very subjective, but we intend it to be as stmetured and as consistent as we can in dealing with these subjective attributes.

LHC ASSESSMENT OF SCWE IMPLEMENTATION STATUS LHC Expectation NNECo Antions Status

1. Senior management CP 5-1 thru 5-8 endorses a policy that CP 6-1,6-2 places priority on nuclear CP 9-32

+i safety, suppons the CP 10-1 tinu 10-4 workers' rights to raise CP Supp.1 Item on safety issues and ensures Leadership, that workers will not be Communications & Trust subjected to harassment, discrimination or intimidation if they do so.

LHC (Ferguson): We've searched NNECo documents - Comprehensive Plan, supplement to it, policy statements, and so forth - in the "NNECo Actions" column to implement our expectations.

We believe that this area is yellow +, trending up, which is about a B+. Their actions are consistent with policy statements but we need to see that it is effectively achieving desired end results into the future before it gets a " green" The only thing really missing from policy

j 17 statements is an explicit statement that nuclear safety takes precedence over all other considerations.

1 By contrast, here is an area where things are not going so well:

LHC Expectation NNECo Actions Eta. tus

9. There is no evidence that an CP 3-7, 3-8, 3-9, 3-11 l

atmosphere exists that has a 4

W

" chilling effect" on the willingness of employees to report safety issues.

There are some actions in CP intended to achieve absence of" chilling effect." But there have been and continue to be substantiated instances of HIR&D and other actions that have a " chilling effect" on employees. We base our concern that not allis going well here on the simple large number of substantiated incidents that still occur. There is no substantial sign ofimprovement at this point. We have begun to examine specific actions called for in the CP but this is based more on continuing events.

NRC Q/A: Do your interviews substantiate this result? In June-July 1997, we heard of a large enough number of employees who thought they were or had been " chilled." The situation was better than a year previously, but we're aware of a lot of other sources ofinformation.

LHC (Beck): You raise a good point - there are conflicting sources of conflicting information, and we seek your help in developing a defensible system for evaluating inherently subjective attributes. We debated not even bringing this out until we'd finished the methodology but wanted j

input.

j i

NRC Q/A: We agree with this early exposure and the " attributes" methodology seems sensible.

LHC (Griffm): We're also going to add KPIs to the NNECo action expectations.

NNECo (Goebel, when asked for his thoughts): We will get to you as soon as we've been able to think about it and seen the whole program rolled out.

LHC Expectation NNECo Actions Status

10. An effective and eflicient CP Supp.1 Items on corrective action program is Correction Action Program t

functioning and all recognize the normal (and preferred method) for addressing safety issues is through the line organization.

y e

i

18 We reported on this general issue before, on September 24. Our problem then had been that though a lot of concerns had been processed, we didn't have a long enough period to understand whether the processing was valid. With more time to evaluate outcomes, we'd expect continued up-rating.

NRC Q/A: What was the attribute that you added?

A (Beck): IllR&D. We expect few allegations of HIR&D, and swift and effective management action when they do arise.

NRC Q/A: Is effectiveness of QA programs one of your attributes?

A (Beck): No. They all deal directly with SCWE.

NRC Q/A: A lot of the time we speak of HIR&D items, we're talking at a lower threshold than s 50.7.

6. NNIiCo PERFOR_h1ANCE MEASURES: SAFETY CONSCIOUS WORK ENVIRONMENT

[ Presented by John Beck]

LHC (Beck): Our final item this morning is an attempt to compare our list of attributes of a safety-conscious work environment against those of NNEco, which were independently derived.

NNECo had 18 attributes for SCWE; we had 11, now 12. We mr.pped our attributes against their success criteria and found one hundred percent correlation. Reversing the process, we found that LliC had a couple that isn't in NNECo's. This is not a criticism, just an effort to ensure that we're looking at the same things.

THREE LHC SCWE ATTRIBUTES NOT SPECIFICALLY INCLUDED IN NNECo ATTRIBUTES Employee perceptions of SCWE policy.

Mutual respect for people at all levels.

No evidence of an atmosphere causing a " chilling effect."

LHC ATTRIBUTES THAT ARE ADDRESSED ONE WAY OR ANOTHER BY MILLSTONE PERFORMANCE MEASURES Employee perceptions of SCWE policy. [This may reflect a lack of coordination with NNECo " attributes", which do not directly reflect this matter.]

Work force has sense ofidentity.

Mutual respect for people at all levels.

HIR&D events are rare; management reaction timely.

No evidence of an atmosphere causing a " chilling effect."

I f

19 EITective and eflicient corrective action program, ECP program is vigorous and effective.

e Self-assessments are effective.

FOUR LHC ATTRIBUTES NOT ADDRESSED BY MILLSTONE PERFORMANCE MEASURES 1

Senior management endorsement of SCWE policy - NNECo may know e

werything it wants, but documenting it would be good.-

Senior management provides adequate training.

Employees exhibit a questioning attitude: want a positive recognition toward employees on this issue, and the next one. We're not suggesting that it isn't 4

happening, only that we can't find a basis where NNECo is trying to measure it. We're trying to capture this in our structured interviews.

Positive recognition to employees who identify safety issues. We're looking

' for this in structured interviews, too.

LIIC (Beck): We are willing to meet with NNECo at any point on these issues to talk about how to measure things we think are important. We want to talk with NNECo about this. Comments and questions today are welcome.

NRC Q/A: Is there a NNECo performance measure that tracks the number of corrective actions tracked by the line organization? If so, wouldn't this relate to presence of a questioning attitude?

A (Beck). Could be. As we developed our presentation today, it was a question-mark on our white board.

NRC Q/A: The numbers are fairly dramatic.

NRC Q/A: Some indicators lend themselves to plot over time; others, not. Don't try to force everything into a time plot.

NRC Q/A: NRC is extremely interested in getting confidence before restart that problems have been addressed, given the history of problems at Millstone. A list of agreed-upon performance indicators is important, and we need agreement on the means of coming to conclusions, recognizing that every indicator has pitfalls. So we need to come to common understanding of this subjective area. Example; Recalls Billie Garde's relating how in the early stages of an improvement in the area, there may actually be a rise in the number of concerns expressed as confidence rises.

It's important that LHC and NNECo try to get a common understanding of common indicators and of an evaluation system. NRC is not expert in this area and thus will rely heavily on LHC and

-will solicit NNEco's views on this methodology ASAP; doesn't want debate before Commission on the validity of the methodology.

20 LIIC (Griffin): We'd also like input from NRC as to what it thinks are good indicators or valid methodology.

.' NRC Q/A: Despite what Billie says, he thinks that the apparent rise in customer dissatisfaction -

with ECP is a disturbing piece of data.

LIIC (Beck): A final caution: There's always a tendency to try to manage indicators'or

" windows" whenever you use them, rather than focus on the real issues. It's an occupational hazard, but we need to avoid it at all costs. It's one of the reasons we hesitated about ever using

. this methodology in the first place. If we see evidence that this is occurring, we will try to stop it.

NNECo (Goebel): This is different from agreeing on a common list of attributes.

' LIIC (Beck): Definitely.

Tills IS TI1E END OF TIIE LIIC PRESENTATION

'l I

I y

i 4

m

s ATTACHMENT 7 Little Harbor Consultants, Inc.

Millstone -ITPOP Project Office P.O. Box 0630 Niantic, Connecticut 06357-0630 Telephone 860-447-1791, est 5966 Far 860444-5758 December 17,1997 ITPOP 97-0056 Michael H. Brothers Vice President - Operations, Millstone Station Northeast Utilities Service Company P.O. Box 128 Waterford, CT 06385-0128

SUBJECT:

December 12,1997 Little Harbor consultants Presentation Little Harbor Consultants, Inc. (LHC) presented fmdings, developed as a result ofits oversight activities, to the NRC Commissioners on December 12,1997. The meeting was held in White Flint, Maryland and was open for observation by the public. This letter forwards the slides used during the presentation. We stated in the presentation that LHC has concluded that each of the NU Success Criteria must be rated neutral yellow (with a horizontal arrow) or better to be considered ready for restart of a unit at Millstone.

We summarized our presentation by stating that we have seen improvement at Millstone in the last few months with respect to a safety conscious work emironment. The Employee Concerns Program has made'idgnificant strides'bGt_ requires additional effort to improve the perception ofits users. The most difficult task fa' ding NU is clearly the need to improve its performance with respect to harassment. intimidation, retaliation and discrimination issues in the workplace. We.will continue to monitor those areas.

Very imly yours,

?-

Jolm W. Beck President, LHC Team Leader, ITPOP Attachment cc: Distribution

'4

4 w,

9 Michael H. Brothers Page 2, ITPOP 97-0056 Distribution:

D. M. Goebel, NNECo Mr. John Buckingham Department of Public Utility Control P. Loftus, NNECo Electric Unit 10 Franklin Square W. J. Temple, NNECo New Britain, CT 06051 S. Baranski, NNECo Citizens Regulatory Commission ATTN: Ms. Susan Perry Luxton C. Grise, NNECo 180 Great Neck Road Waterford, CT 06385 M. Quinn, ECOP Citizens Awareness Network U.S. Nuclear Regulatory Commission 54 Old Turnpike Road Attn: Document Control Desk Haddam, CT 06438

. Washington, DC 20555 The Honorable Terry Concannon U.S. Nuclear Regulatory Commission Nuclear Energy Advisory Council Attn: W.D. Travers I.egislative Office Buildmg Mail Stop: 014D4 Hartford, CT 06106 Washington, DC 20555-0001 Mr. Evan W. Woollacott U.S. Nuclear Regulatory Commission Co-Chair Attn: P.F. McKee Nuclear Energy _ Advisory Council Mail Stop: 014D4 128 Terry's pia' m' Road Washington, DC 20555-0001 Simsbury, CT 06070 U.S. Nuclear Regulatory Commission Ernest C. Hadley, Esquire 4

Attst H.N. Pastis 1040 B Main Street Mail Stop: 014D4 P.O. Box 549 Washington, DC 20555-0001 West Wareham, MA 02576 Mr. Wayne D. Lanning Mr. Paul Choiniere US NRC Region !

"The Day" O'Neill Drive 475 AllendaTeRoad 47 Eugene King of Prussia, PA 19406-1415 New London, CT 06320 Kevin T. A. McCarthy, Director BobDeFa ette Monitoring and Radiation Division.

100 King Street Department of Environmental Protectiort-

'Gettysbmg, PA 17325.

79 Elm Street w-Hartford CT06106 5127 Don brMan e

1071 State, Route 136 Allan Johanson, Assistant Director Delle Vernon, PA 15012 Office of Policy and Management Policy Development and Planning Division 450 capitol Avenue-MS 52ERN P.O. Box 341441 Hartford, Cr 061341441 First Selectmen Town of Waterford Hall of Records -

200 Boston Post Road 9-Waterford, CT 06385 Charles Brinkman, Manager Washington Nuclear Operations ABB Combustion Engmeering Nuclear Power 12300 Twinbrook Pkwy, Smte 330 Rockville, MD 20852

=

=

\\

/

STATUS OF A SAFETY CONSClOUS WORK ENVIRONMENT AT MILLSTONE Little Harbor Consultants Presentation to NRC Commissioners December 12,1997

/

\\

J o

ri2.i m rr.s..

. uac c..ndssi.e.r.

i LITTLE HARBOR CONSULTANTS OVERSIGHT ACTIVITIES Structured Interviews of Workforce Second Round of Interviews Sc. 3duled for February Review of:

Program Design (e.g., NU Comprehensive 1

J Plan, ECP, CAP)

Program implementation Program Effectiveness

/

s December l',1991 Presentauon to NRC Comadssioners 2

1

• ^

\\

/

LITTLE HARBOR CONSULTANTS OVERSIGHT ACTIVITIES, Cont'd.

Specialinvestigations MOV Dept. Event involv!ng Allegation of Retaliation Against Contractors Allegation of Retaliation in Discipline of Training Dept. Staff

/

\\

December 12,1997 Presentaties to NRC Commissioners 3

(~

i l

l N

/

LHC APPROACH TO EVALUATION Oversight Plan identifies 11 Attributes Usually Present When Strong Safety Culture Exists l

One Additional Attribute Added Based on LHC Observations LHC is Continuously Monitoring These Attributes Through Interviews, Program Reviews, and/or Observations L

\\

Ikceenbar12.1997 Presentat6es to NRC Commoisalemers 4

2-

~-

\\

/

LHC APPROACH TO EVALUATION, cont'd LHC Team Meets Periodically to Discuss information Gathered That Provides insights into Each Attribute Consensus Regarding Status of Each Attribute is Reached Through Group Analysis of Data and Information Updated Status Will Be Periodically Communicated to NU and the NRC Staff

/

\\

December 12.1997 Presentaties to NRC Commissioners 5

\\

/

STATUS INDICATORS FOR NU'S SCWE IMPLEMENTATION EFFORT Meets Expectations lm*l p,l Approaching Requires Management l

Action jf,j Marginally Acceptable Exhibits Significant Weakness lmeel Trends: k Improving -> Steady y Declining

/

\\

December 11,1997 Presentauen to NRC Commissioners 6

3

I

\\

/

STATUS REPORT IS PRELIMINARY BASED ON PROGRESS TO DATE Key Activities Completed

- Initial Structured Interviews

- ECP and CAP initial Reviews Ongoing Oversight Activities

- CompreheraGive Plan Effectiveness Review

- Additional Structured Interviews

- Closure of ECP and CAP Reviews

- Continuina Observation of Site Activities December 12,1997 Presentauen to NRC Comsdasioners 7

N

/

STATUS OF NU SUCCESS CRITERIA BASED ON LHC ATTRIBUTES NU Success Criteria Status

1. Demonstrate the willingness to raise concerns.

(Yellow)

/

s December 12.1997 Presentauen to NRC Commissioners S

4

s.

\\

/

STATUS OF NU SUCCESS CRITERIA BASED ON LHC ATTRIBUTES NU Success Criteria Status

2. Demonstrate that issues are being effectively resolved by 3

line management.

(Yellow)

/

\\

December 12,1997 Presentauen to h1tC Commissioners 9

m

\\

STATUS OF NU SUCCESS CRITERIA BASED ON LHC ATTRIBUTES NU Success Criteria Status

3. Demonstrate that the ECP is effective.

A I

(Yellow)

/

\\

December 11,1997 Presentanen la bltC Commissioners 10 5

N

/

STATUS OF NU SUCCESS CRITERIA BASED ON LHC ATTRIBUTES

{

NU Success Criteria Status

4. Demonstrate that management can recognize and offectively deal with alleged instances of HlR&D, or other circumstances which have created a chilling (Red) effect, which collectively are referred to as problem areas

/

\\

Deceanber 15. t997 Presenteuen to NRC Comunissionare it l

N

/

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

1. Senior management endorses a policy that places priority on nuclear safety, supports the workers'. rights to raise safety issues and ensures that (Green) workers will not be subjected to

. harassment,- discrimination or

)

intimidation if they do so.

s Deceanber 12,1997 Presentmoem to NRC Canuntasioners 12 4.

6

)

1 SAFETY CONSCIOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

2. Employen perceptions of the policy and its implementation Y

are favorable.

(Yellow)

{

/

\\

December 12.1997 Presentaties to NRC Commissioners 13

)

)

)

\\

SAFETY CONSClOUS WOR.K ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

3. Senior management provides training to all managers and supervisors to ensure that they understand and employ good management practices when (y,ggo,)

dealing with employees who have safety concerns and do so with understanding.

/

\\

December 12.1997 Presenteuse to NRC Commissioners 14 7

i

N

/

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

4. Members of the workforce have a sense ofidentity and are committed to the publicly stated 4

goals and objectives of the organization, have respect for j

each other, communicate (Yellow) effectively both horizontally and vertically, and feel responsible for their own behavior.

December 12,1991 Presentages to NRC Comunissioners 15 N

/

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

5. People at alllevels of the organization treat each other

+

with mutual respect.

(Yellow)

/

\\

Deceanber 11,1997 Presentstka to NRC Commissioners 16 8

\\

/

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

6. Employees exhibit a " ques-tioning attitude" toward work and the work environment with Y+

respect to nuclear safety.

(Yellow)

/

\\

Documber 12,1997 Presentetles to NRC Commissioners 17 y

/

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC ExDectation Status

7. Positive recognition is given to employees who identify safety

-+

issues.

(Yellow) -

/

\\

December 12,1997 Presentation to NRC Commissioners IS 9

s

/

s SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS l

LHC Expectation Status

8. Incidents leading to allegations of harassment, intimidation, retaliation or discrimination rarely occur, and management is timely and effective in taking (Red) action for resolution and prevention.

/

\\

Deceanber II,1997 Presentation to NRC Ceaunimeners 19 s

/

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

9. There is no evidence that an atmosphere exists that has a

" chilling effect" on the willingness of employees to report safety issues.

(Red)

/

\\

Deceanber 12,1977 Presentation to NRC Conunissioners 20 l

10

N

/

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

10. An effective and efficient corrective action program is 3

functioning and all employees recognize the the normal (and preferred method) for gy,;;,,)

addressing safety issues is through the line organization.

/

\\

Deceenber 12,1997 Presentauen to NRC Commissiseers 21

/

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

11. Senior management recognizes that some concerns O

may not be addressed through the normalline organization and has established an gy,ggo,)

[ effective) Employee Concerns Program (ECP) for handling such concerns.

/

\\

December 12,1997 Fresentauen to NRC Commisdeners 22 11

1 e

'e,.

i N

/

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

12. Independent and self-assessments are performed

^

periodically to monitor performance and correct identified deficiencies.

gy,,,,,)

/

\\

December 12,1997 Presentaties to NRC Commissioners 23 i

L, m--

12 L

<<A.

1 ATTACliMENT 8 STATUS OF A SAFETY CONSCIOUS WORK ENVIRONMENT AT MILLSTONE:

TRANSCRIPT, FOCUSING ON TIIE LIIC PRESENTATION ON DECEMBER 19,1997 TO TIIE NRC COMMISSIONERS Little Harbor Consultants Presentation to NRC Commissioners December 12,1997 1

i

l 3-

~

122 1 - their responses from level fours.

2 We do now presently have about 118 in progress, 3 - 132 have been posted on the web and, much as Sargent &

4 Lundy, we are working through that process.

5

_ CHAIRMAN JACKSON: Any other questions?

6

_ Okay, thank you very much.

7 We will now hear from Little Harbor Consultants.

8 Mr. Beck, you are leading the discussion?

9 MR. BECK: Thank you, Chairman Jackson. Good

)

10 morning, Commissioners.

-Qg 11 I am John Beck, President of Little Harbor T5 12 Consultants and team leader for the Independent Third Party 13 Oversight Program at the Millstone site. With me this 14 morning is John Griflin, who is my co-team leader, and 15 Ms. Billie Gard, who is a principal on our team.

16 As you are aware, Little Harbor has the 17 responsibility to oversee Northeast's etTorts to establish a 18 safety-conscious work environment at Millstone. We have 19 been acting in this capacity since approximately March of 20 this year. During this time, we have reported our findings 21 to Northeast and your staff at eight public meetings.

22 Little Harbor has maintained essentially a full-time 23 presence at Millstone, typically with five or six team 24 members at the site, depending on the requirements of the 25 particular oversight activities that were being conducted.

ANN RlLEY & ASSOCIATES, LTD.

Court Reporters 12501 Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 NTATils Ol? A SAFETY CONSClot!N WORK ENVIRONMENT AT MILIETONE: TRANMCRIPT FOCUSING ON Tile 1,IIC PRESENT ATION ON llECEM HER 19,1997 TO TIIE NRC COMMISSIONERS

!)ttle llartmr Consultants Prenantation to NRC Conunisakmers ikcember 12.1997 Page 1 of 14 s

4

.Q 123 l

Our next major activity will be to conduct a 2 second round of structured interviews with the work force at 3 the Millstone site. This will add a set of data points to 4 those which we gathered last June. The purpose of the 5 interviews is to determine how people at Millstone feel 6 about all facets of a safety-conscious work environment.

7 Those to be interviewed will be chosen by Little Harbor to 8 be representative of the work force and will be a different 9 ' set of people from those interviewed in June. The results 10 will be available prior to the anticipated Commission vote 11 and we will also continue our oversight of the various 12 Northeast programs supporting a safety-conscious work 13 environment with a penicular emphasis on the effectiveness 14 of these programs.

15 CIIAIRMAN JACKSON: Let me ask you some overarching 16 questions. And if you are going to get into them with your 17 specific slides later, please say so.

18 The first is, have you sensed or detected an 19 improvement in leadership on site as the leadership 20 assessment that the licensee spoke about indicates? And, if 21 so, or if not, you know, what specifics support your 22 conclusion?

23 MR. BECK: We are going to have some specific 24 comments that will directly address that question about 25 leadership, particularly with respect to the criteria ANN BILiiY & ASSOCIATES, LTD.

Court Reportea 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 i

8TATUS OF A SAFETY CONSClOUS WORK EN 'IRoNMENT AT MILLSTONE: TRANSCRIPT, FOCUSING ON TIIE LIIC FRESENTATION ON DECEMilER 19,1997 TO TIIE NRC COMMISSIONERS little llartxw Consultants Presentation to NRC Commissioners December 12,1997 Page 2 of 14

.=

124 1

1. relating to retaliation and so forth.

2 But, in general, I would say that there has 3 clearly been an improved understanding by the management 4 team at Millstone, vis-a'-vis a safety-conscious work

~

5 environment, particularly over the last three months. And 6 we can perhaps illustrate that better in a few minutes.

7 John, would you like to add?

8 MR. GRIFFIN: No, I agree.

9 CHAIRMAN JACKSON: Do you find that employee 10 - concerns rise as Millstone nears its deadline with the steep

11. work-off rates? Is there any detectable change?

12 MR. BECK: There has been a slight inc, ease in 13 December over the month of November. But I wouldn't 14 particularly associate that with approaching a deadline.

15 That is always a question. What do the numbers, in and of 16 themselves, mean. Frankly, we are far more interested in

17. looking at the issues that are involved and looking at the 18 quality of those concerns. And, in particular, with respect 19. to any questions of retaliation or 50.7 issues.

20-One of the questions you raised earlier, and 21 perhaps I can respond to it now, was with regard to the 22 correlation between the corrective action program and 23 employee concerns issues. IfI heard you correctly, we have 24 not, for example, none of us can recall a technical issue 25 that went to ECP that had not already been a CR and the ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

t-

,: r -

! STATUS OF A SAFETY CONSCIOUS WORK ENVIRONMENT AT MILLSTONE: TRANSCIUPT, FOCUSING ON THE LilC

^

' ~

PRESENTATION ON DECEMBER 19,1997 TO Tile NRC COMMISSIONERS Little liarbor Comultads Ibsentation to NRC commissioners December 12,1997

. Page 3 of I4

{

4

.a.

W_,

1 b

125 I 1 ' concern was either unsatisfactory resolution of the CR by

2 the management team or untimely resolution of the CR and 3-that's not a -

4 CHAIRMAN JACKSON: Not that it wasn't addressed?

5

- MR. BECK: Not that it was not addressed.

6

~ CHAIRMAN JACKSON: Do you have a way ofmeasuring 7 or of detecting the overall stress on the managers and the 8 employees? Do you have experience with other sites to make 9_ a comparison?

' 10.-

MR. BECKf Being on site essentially full time, we 11 cannot help but have our fmger on the pulse of the 12 organization. The stress levels we have seen ebb and fall 13 or rise and fall depending on particularly what's going on 14 = and who's affected by it. It is certainly not an unexpected

15 phenomenon to see people, when they are working as hard as 16 they are, show some signs of stress. I have seen on the 17 part of management a recognition that this is a fact oflife 18 and some pretty careful attention being paid to stress in

-19 general.

20

- For example, if you go back to the MOV incident, 21-there was a lot of stress in that organization prior to the 22 retaliatory action that was taken. The stress level, in our 23 opinion, subsequent to that change in management, in the 24 group, although they are working very hard, appears to have 25 diminished somewhat.

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 L

'N.

1 t

b

' Je MTATU5 OF A SAFETY CONSCIOUS WORK ENVIRONMENT AT MillSTONEt TRANSCRIPT, FOCUEING ON Tile LIIC.

FRESENTATK'N ON 1)ECEMHER 19,1997 TO THE NRC COMMISSIONERS -

!ittle liarbor c msultants Presentation to NRC Conunissioners December 12.1997 Page 4 or 14 5

_g.

14 e.

4 126-1 CHAIRMAN JACKSON: Okay, why don't you go on.

2-COMMISSIONER DICUS: IfI may ask a quick 3. question?

4 CHAIRMAN JACKSON: I'm sorry. Go ahead.

5 COMMISSIONER DICUS: This round ofinterviews that 6 ' you have scheduled for February. What is the sampling size?

'7-MR. BECK: we are going to sample'approximately 8 280 to 300 individuals and they will be chosen across the 9 organization and up and down, excluding directors and above 10 ' in this particular case.

I1-COMMISSIONER DICUS: Is that about the same 12 sampling size?

13.

. MR. BECK: Yes, it will be.

14 CHAIRMAN JACKSON: Okay.

15 MR. BECK: There have been - slide number 16. ' 3 - two events at Millstone since our last meeting for 17.which we performed an independent investigation per the 18 provisions of our oversight program. The first involved 19 potential retaliation against contractors in the MOV 20 ' department by their immediate management who also happened 21 to be contractors. The second incident involved an 22 allegation of retaliation claimed by one of the individuals 23 disciplined by Northeast as a result of the training 24 department investigation.

25 In the first instance, we verified and agreed with ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005

-(202) 842-0034-STATUS OF A IMFETY CONSClOUS WORK ENVIRONMENT AT MILIETONE: TRANSCRIPT. l'OCOslNG ON Tile 1,IIC PRESENTATION ON DECEMBER 19,1997 TO Tile NRC CUMMISSIONERS

. Ijttle llarbor Canaltants Presenta6on to NRC C -

'=-, December 12,1997 Page 5 of 14

[

4 127 1 the conclusions reached by the company investigation of the 2 ECP investigators of the MOV issue that retaliation was, in 3 fact, a factor in the termination of two contract engineers.

4 In the second case, we concluded that there was no evidence 5 of retaliation by Northeast management in the disciplinary 6 actions that they took.

7 Moving on to our evaluation of Northeast's 8 progress, with respect to establishing a safety conscious 9 work environment, our oversight plan contains 11 attributes 10 which we think are critical to an ideal safety-conscious 11 work environment. Since the plan was published in June, we 12 have added another attribute to cover incidents related to 13. harassment, intimidation, retaliation or discrimination.

14 Little Harbor continuously monitors these 15 attributes through interviews, reviews, investigations and 16 observations. As information dictates, the Little Harbor 17 team members working in a particular area meet to discuss 18 data and reach consensus for relative attributes. As 19 changes occur in the future, we will communicate these 20 changes to the NRC staff, Northeast Utilities and the 21 public.

22 CIIAIRMAN JACKSON: What was the additional 23 attribute that you --

24 MR. BECK: It relates to the question of 25 harassment, intimidation, retaliation and/or discrimination, ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 ST ATUS OF A SAFETY CON 5CIOUS WORK ENVIRONMENT AT MILLSTONE: T RANSCRIPT, FOCUSING ON TIIE LilC PRESENTATION ON DECEMilER 19.1997 TO TIIE NRC COMMISSIONERS Little !!arter Consultants Presentation to NRC Commissioners ikccmber 12.1997 Page 6 or 14

128 1. specifically.

'2 CHAIRMAN JACKSON: And how do you weight the -- do 3 a relative weighting? You talk about doing program reviews, 4 interviews and then you have these attributes. How do -

5 you -- is it you have a weighting system or you do one to j

6 kind of check the other?

7 MR. BECK: Some of them are relatively 8 straightforward and simple and it is easy to make the 9. evaluation. Others involve a lot of subjective evaluation, 10 discussion by the team members who are involved in various 11 ' reviews or investigations and that consensus reaching demand 12 which we place on ourselves results in the weighting taking 13 place.

14 As we -- and I will go into later -- roll up our 15 12 attributes, if you will, to be consistent with the four 16 that you heard from the company on earlier this morning, you 17 will see how they --

18 CHAIRMAN JACKSON: Stack up?

.19 MR. BECK: Yes.

20 This next slide shows our approach to evaluating 21 the status of Northeast's safety-conscious work environment 22 implementation efforts. And I will relate that to your 23 desire for satisfactory approaching expectations and not 24 meeting them in a moment. We have chosen to use five 25 gradations for evaluation of each Little Harbor attribute or ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

STATUS OF A SAFETY CONSCIOUM WORK ENVIRONMENT AT Mll.lETONE: TRANSCRIPT. FOCUSING ON Ti!E Llic PRFEENTATION ON DECEMBER 19,1997 TO Tile NRC (UMMISSIONERS little liarixw Consultants Presentation to NRC Conunissioners December 12,1997 Page 7 of 14 1

F

d 129 1

roll-up to end use success criteria.

2 Green meets all expectations. Red, on the other 3 hand, requires significant improvement. And we use three 4 levels within the yellow band, as indicated on the slide.

5 We also evaluate our view of the current 6 performance trend for each attribute as indicated by an 7 arrow in the box. It is the consensus of the Little Harbor 8 team that each of the four Northeast success criteria, which 9 you heard discussed by the Company this morning, must be 10 rated neutral yellow or better to be considered ready for 1I restart of the unit at Millstone. Therefore, ifyou drew a 12 line below neutral yellow, a horizontal arrow, above that 13 line, you would have to be at that point or above to be 14 satisfactory.

15 The next slide, the status reports which we will 16. be sharing in a moment are based on our evaluation of 17 progress to date. Little Harbor opinions are based on our 18 initial structured interview results, initial reviews of the 19 employee concerns program and corrective action program and 20 ' other activities. We are continuing our review of the 21 comprehensive plant effectiveness, another round of 22 structured interviews, closure of our employee concerns 23 program and corrective action program reviews and continued 24 observations of site activities.

25 I am not going, due to the limited time available, ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 STATUS OF A SAFETY CONSCIOl'S WORK ENVIRONMENT AT MILLSTONE: TRANSCRIPT, FOCUSING ON TIIE I,lic PRESENTATION ON DECEMBER 19,1997 TO TIIE NRC COMMISSIONERS Little liarbor Consultants Presentation to NRC Commissioners December 12,1997 Page 8 cf 14

130 1l to go through each of our 12 attributes but rather focus on -

2 the four end use success critelia this morning. We did '

3 include those other evaluations in our advance package, 4-however, if you have any questions about any of these, we 5 would be pleased to respond.

6 Going to the first end use success criteria, 7 willingness to raise safety concerns, we rate this 8 satisfactory today, a neutral yellow with a holding steady.

9 It is based on a roll-up of our attributes 2,6,7,9 and 10 12, which were in ~your advanced package.

11 While there continue to be some problem areas at 12 Millstone, we believe that this attribute has improved and 13 workers at Millstone are willing to raise safety concerns 14 via one of the available mechanisms. Resolution of the 15 ' existing problem areas' coupled with the ongoing training of 16 the work force should provide further improvement in this 17 criteria in the future.

18-The next criteria, issues are effectively resolved 19 by line management, which is really the corrective action 20 program, is also evaluated as neutral yellow but with an

-21 improving trend. It is based on'our attribute number 10 and 22 the evaluation ofit, the corrective action program which we 23 reported on in September. ' We performed a comprehensive 24 review of the program and completed it as I said in 25 September.

ANN RILEY & ASSOCIATES, LTD.

Court Reporters j

1250 I Street, N.W., Suite 300

. Washington, D.C. 20005 (202) 842-0034

^

' STATUN OF A SAFETY CONK'IOUS WORK ENVIRONMENT AT Mll,1, STONE: TRANSCRII"r, H)CUSING ON Tile I,IIC

.. PRESENTATION ON DECEMBER 19,1997 To Tile NRC COMMISSIONERS 1,ittle !! arbor Consultants Pre,.entation to NRC Canmissiomrs December 12.1997 Page 9 er 14 L

r

\\

1 131 1

We concluded that Northeast has established an 2 excellent corrective action program which is being 3 aggressively implemented. Our continuing review in this 4-area will focus on the effective t esolution of problems 5 addressed by the program.

6 The next area, effectiveness of the ECP, we do not 7 consider to be satisfactory today. It is a minus yellow 8 with an up arrow. And it is identical to our attribute 9 number 11. Northeast, however, has rnade significant strides 10 in improving the employee concerns program. We feel that 11 this rating would be up at least one notch to neutral 12 yellow, improving or satisfactory, but for the apparent high 13 percentage ofpersons who have used the program and who 14 indicate that they wouldn't use it again.

15 We are not satisfied today that we totally 16 understand why users of the employee concerns program feel 17 this way and will develop that understanding over the next 18 few weeks. Thus, our conservative rating at this time, 19 Overall, we feel that NU management and the 20 employees and contractors in the employee concerns program 21 have made significant strides over the nert few months and 22 the program is continuing to improve but for that one 23 - aspect.

24 And, finally, the last NU success criteria, 25 recognizing and dealing with harassment, retaliation, ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 STATils OF A MAFETY CONSCIOUS WORK ENVIRONMENT AT MILLSTONE: TRANSCRIPr. FOCUSING ON TiiE LllC PRESENTATION ON DECEMBER 19,1997 TO TIIE NRC COMMISSIONERS 1

4 Little liarixt Consultants 14esentation to NRC Commissioners December 12,1997 Page 10 of 14 4 -;

LA

A 132 1

intimidation or discrimination we rate as red today. This 2 is a roll-up ofour attributes 3,4,5,8 and 9. The 3 sources ofinput were the Little liarbor reviews of end 4 process training, observations in the work place, specific 5 investigation of Millstone incidents, employee concern 6 follow up interviews, validation of comprehensive action 7 plan action items and walk-in intelviews.

8 1 should add that we have observed positive 9 movement by Northeast management in this area very recently.

10 Some examples include the 10 CFR 50.7 training efrort which 11 you saw as in progress. We were involved in communicating 12 our expectations of such a program while it was being 13 developed. We have monitored the training sessions as they 14 are under way and we think it has significant potential to 15 raise the level of awareness from first line supervisors up 16 within the Northeast management chain.

17 We also have witnessed some behavior on the part 18 of management responses to recent issues involving potential 19 retaliatory behavior and it has been very positive and 20 significantly better than it had been in the past. The 21 consolidation and addition ofinanagement resources under 22 Mr. Brothers regarding all matters assoc!ated with a 23 safety-conscious work environment at Millstone we think is a 24 very positive step and is beginning to show positive 25 results.

ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 FrATUA "W A NAFETv CONSCIOUS WORK ENVIRONMENT AT MILISTONE: TRANSCRIPT. FOCUSING ON Tile 1, llc PHENENTATION ON DECEMl!EH 19.199710 Tile NHC COMMISSIONERS Little llarter Consultants Prmntatmn to NRC Conuniasioneen Decender 12.1997 Page !I of 14

l 4

133 1

That concludes our prepared remarks.

2 In summaly, we have seen improvement in the last 3 few months with respect to the safety-conscious work 4 environment. The employee concerns program in particular 5 has made significant strides but requires some efrort to 6 improve the perception ofits users. The most diflicult 7 task facing Northeast management is clearly the need to 8 improve its performance with respect to harassment or 9 potential retaliatory actions in the work place. We are 10 going to in particular monitor very closely these areas.

1I We would be pleased to respond to any questions 12 you may have.

13 CHAIRMAN JACKSON: The first one is an 14 informational one. I didn't take down the roll-up. Ifyou 15 go back through the 1,2,3,4, tell me how your criteria 16 roll up into the different ones.

17 You're saying that NU's Criteria 1 is a 18 combination ofwhich ones ofyours?

19 MR. BECK: Their Criteria 1 involves our Criterion 20 2, which is employee perceptions of the policy that NU has 21 established for a safety-conscious work environment.

22 CHAIRMAN JACKSON: You can just give me the 23 numbers.

24 MR. BECK: Okay, I'm sorry -- 2, 6, 7, 9, and 12.

25 CIIAIRMAN JACKSON: Okay, and number 27 ANN RILEY & ASSOCIATES, LTD.

Court Reporters 12501 Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 STATUS OF A SAFETY CX)N5CIOUS WORK ENVIRONMENT AT MILLSTONE: TRANSCRIPT, FOCUSING ON TIIE LilC PRESENTATION ON DECEMBER 19,1997 TO TIIE NRC (X)MMISSIONERS Lidle liarbor Consultants Presentation to NRC Commissioners Ikccmber 12,1997 Page 12 of 14

134 1

MR. BECK: Number 2 is number 10.

2-CHAIRMAN JACKSON: Okay.

3' MR. BECK: Number 3 is number 11.

4' Number four is three, four, five, eight, and nine

.5 again.

6 CH AIRMAN JACKSON: No, I appreciate your doing 7 that grouping, but essentially what you are saying is that 8 the ability to grapple with alleged instances of harassment,-

9 intimidation, retaliation or discrimination -- they really 10 have a long way to go yet, and then the very thing that is 11 the subject of your existence, namely the Employee Concerns 12 Program and its effectiveness they have some improvements to 13 make.

14 MR. DECK: That's correct.

15 CHAIRMAN JACKSON: Okay. All right. Are there 16 any additional questions? Yes?

17 COMMISSIONER DICUS: In the presentation that 18 Northeast Utilities made on their program they analyzed 19 themselves and they indicated, as you are well aware, that 20 you concurred with where they felt they stood in the issues 21 that they were dealing with~ with the program.

22 Do you concur completely or is there an area, a 23 significant area not a minor area, a significant area where 24 maybe you don't concur with their own analysis?

25 MR. BECK: IfI may, Commissioner, I interpreted ANN RILEY & ASSOCIATES, LTD.

Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 i STATUS OF A SAFETY CONkCIOUS WORK ENVIRONMENT AT MILIETONE: TRANSCRIPT. FOCUSING ON TIIE LIIC PRESENTATION ON DECEMBER 19.1997 TO THE NRC COMMISSIONERS Little liarbor Consultants Prencntation to NRC Commissioners December 12,1997 Page 13 or 14 7

4

?.

1 135 1 that " LAC concurs" as another criteria they are setting for 2 themselves.

3 Today we do agree on those four elements, namely 4 the first two are satisfactory, the last two are not today, 5 so we are in synch at this point in time.

6 CHAIRMAN JACKSON: Okay. Thank you very much.

7 Now we will hear from the NRC Staff--last but 8 not least.

9 MR. THOMPSON: Good afternoon.

10 CHAIRMAN JACKSON: Yes, I guess it is. Good 11 afternoon. You sure it is not tomorrow?

12 MR. THOMPSON: Chairman Jackson, Commissioners, as 13 you know, this is an effort that the NRC Staff has put a 14 major focus on. This is our fourth presentation and I think 15 you know the gentlemen at the table with me.

16 Before I turn it over to Bill though, I would like 17 to indicate that we are recognizing the importance of where 18 we are in this program -- I'm sorry --

19 CHAIRMAN JACKSON: We know who you are.

20 MR. THOMPSON: We have our tent cards here.

21 Before we get to having. Bill go through and 22 summarize what we believe are the important elements of our 23 0350 process, and that is our restalt assessment program, I 24 would like to indicate that this is a time we recognize that 25 there are lots of activities that are ongoing at the site.

ANN RILEY & ASSOCIATES, LTD.

j Coult Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 NTATUS OF A SAFETY CUNSCIOUS WORK ENVIRONMENT AT MILI. STONE: TRANSCRIPT. l'OCUSING ON TIIE 1 IIC PRESENTATION ON DECEMBER 19,1997 TO TIIE NRC COMMISSIONERS little Ilarbor Consultants Presentation to NRC Commissioners Ikccmber 12,1997 Page 14 of I4 L_