View source for NOC-AE-000110, Forwards non-proprietary & Proprietary follow-up Info Related to 980226 Predecisional Enforcement Conference

{{Adams
| number = ML20217D552
| issue date = 03/12/1998
| title = Forwards non-proprietary & Proprietary follow-up Info Related to 980226 Predecisional Enforcement Conference
| author name = Cottle W
| author affiliation = HOUSTON LIGHTING &amp; POWER CO.
| addressee name = Merschoff E
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION IV)
| docket = 05000498, 05000499
| license number = 
| contact person = 
| document report number = EA-97-341, NOC-AE-000110, NOC-AE-110, NUDOCS 9803300067
| package number = ML20036E282
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 43
}}

=Text=
{{#Wiki_filter:-    _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _                                 ._
    .              eTWB Nuclear Operating Company sova r=a 5
n arartreccmas   s om ea aan umrir ramn wv.
March 12,1998 NOC-AE-000110 File No: D43 EA 97-341 Mr. Ellis W. Merschoff Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 South Texas Project Units 1 & 2 Docket Nos. STN 50-498; STN 50499 Follow-up Information Related To February 26.1998 hedecisional Enforcement Conference

==References:==
: 1.                                                       Letter from Mr. Ellis W. Merschoff, Nuclear Regulatory Commission to Mr. W. T. Cottle, STP Nuclear Operating Company dated January 8,1998 (ST-AE-NOC-000054)
: 2. letter from Mr. Ellis W. Merschoff, Nuclear Regulatory Commission to Mr. W. T. Cottle, STP Nuclear Operating Company dated February 9,1998 (ST-AE-NOC-000085)
: 3. I2tter from Mr. Ellis W. Merschoff, Nuclear Regulatory Commission to Mr. W. T. Cottle, STP Nuclear Operating Company dated February 10,1998 (ST-AE-NOC-000086)
: 4. Letter from Mr. Ellis W. Merschoff, Nuclear Regulatory Commission to Mr. W. T. Cottle, STP Nuclear Operating Company dated March 6,1998 (ST-AE-NOC-000103)

==Dear Mr. Merschoff:==

(
At the Predecisional Enforcement Conference on February 26,1998, the NRC staff requested additional information relating generally to whether (1) management conduct i     may have chilled the reporting of concems by employees in the Design Engineering Electrical / Instrumentation and Controls (E/I&C) Division, and (2) management knowingly 9803300067 980312 PDR                                      ADOCK 05000498 G                                                                      PDR
                                                                                                                                        .1'y fl BV

acquiesced in such an effect over an extended period. This letter responds to those
                                                                                                )
requests and provides additional informatioa addressing (1) available measures of the willingness of our employees to report their concerns; (2) management actions to address identified issues and encourage reporting of concerns without fear of retaliation; (3) issues raised by the attorney for the Complainants during the Conference; and (4) conclusions regarding the application of the enforcement policy.                                          1
: 1. Freedom of Employees to Report Concems In response to a concern expressed by the Commission at the Conference regarding a            4 1994 assessment of employee views in the E/I&C Division (Climate Assessment) we described the Climate Assessment and explained the context in which Company                   i management viewed its results. As you know, the Climate Assessment was conducted in response to an employee concern in early 1994 that the E/I&C Division Manager was creating a " hostile work environment." This phrase was used to describe reactions to the Manager's personality as reflected in yelling, use of profanity, etc. This concern was understood by our Employee Concerns Program (ECP) as related to the management style and personal characteristics of the Division Manager which at times made work unpleasant for employees in his division. Other allegations addressed by the same investigation included alleged favoritism in the Division Manager's dealings with a Division supervisor      i who eventually became one of the four Complainants. The ECP personnel received no              I complaint and had no reason to discern that employees were harassed for reporting safety concerns, and therefore appropriately identified the concern as non-safety related in          i I
accordance with ECP procedures. When the concern about the work environment was described to the manager of the Design Engineering Department (DED), he also understood the issue as raising questions about management style, not discrimination.
ECP decided to address the concern with a climate assessment survey of a type that was generally used at the South Texas Project for determining employee attitudes in individual work groups.
The Climate Assessment results were described in a letter to the concernee that stated that "the employee responses were approximately 75% positive and 25% negative to the question." It would be incorrect to interpret this as an indicatien that 25% of the            ,
employees indicated that the work environment was hostile; the results were much less          !
critical of the Division Manager than such a conclusion would suggest. The Climate Assessment involved interviews of 43 employees in the E/I&C Division using a standard set of 27 questions--which resulted in 1161 employee responses. The personnel who conducted the Assessment perceived approximately 25% (or 290/1161) of the responses as negative or having a negative connotation. Of these,58 (approximately five percent of the 1161) were specifically related to management or an unprofessional work environment, including describing the Division Manager as loud and unresponsive to the number of hours worked by employees. Other negative responses were not directly Ew"On

related to the Manager, including that there was a lack of teamwork and camaraderie, individuals not having job descriptions and that emergent issues were assigned that were i
not related to theirjob descriptions. The results provided to Engineering management did    !
not suggest that employees who raised concerns were subjected to harassment or that         ;
employees were reluctant to use the routine systems for reponing concerns. The DED           l Manager appropriately concluded that the remedial measures he had instituted earlier in the year also addressed these results.
l In addition to the Climate Assessment, annual surveys conducted by Behavioral Consultant Services Inc. (BCS) provide a measure of employee attitudes that can be compared to other similar groups and to results for the same group in other years. As we described at the Conference, the BCS survey was administered to the Company employees       ,
and baseline contractors annually between 1993 and 1997. When we provided a                 {
description of key results at the Conference, the NRC staff requested additional              !
information, including the number of participants and number of responses to Questions      )
59 and 60 for years 1994-97; the actual breakdown of the responses to those questions;       j comparison of the overall Station and E/I&C responses to those questions; and comparison of the overall scores and percentage of participation for the station and the E/I&C Division for those years. The requested information is provided in Attachment A, along with graphs to illustrate the trends from 1994-97. Attachment A also provides         I requested information on the total E/I&C Division staffing during that period in response to another question at the Conference. Attachment B is a copy of the letter from BCS that was discussed during the Conference.
The E/I&C results are in line with overall Station results. The data provided in Attachment  I A support the BCS conclusion stated in Attachment B that the survey results do rot          l suggest in any way the existence of a hostile work environment in the E/I&C division l
during these years.                                                                         {
The Staff also asked whether there was a survey question asking where the employee           1 would go with a nuclear-safety or quality-related concern if not satisfied with the supervisor's response to the concern. BCS survey question 60, which is discussed in Attachment A, was included to address this issue, by asking where the employee would          j bring a safety concern.                                                                       l Another strong indication that employees in the E/I&C Division felt free to raise concerns    i is the number of Condition Reports actually documented by the E/I&C Division. The total number of Conditions Adverse To Quality originated by the E/I&C Division and                 1 comparative data for the Mechanical Division, Technical Support Engineering Division and Other DED groups are presented in Attachment C. The data reflect the initiation of the new Corrective Action Program in late 1994 and the overall continuing Station effort to drive down the threshold for reporting concerns. The number of conditions and conditions adverse to quality reported to the E/I&C Division is appropriate for the size of i
npmir 4 98duc                                  3

the Division. This confirms that concerns were identified and reported regularly by personnel in the E/I&C Division, including these Complainants, throughout this time period.
Implementation of the new Corrective Action Program was reviewed by a team of NRC inspectors in early 1996. The team concluded that the Station "had a strong, well-run corrective action program" and that Station personnel had accepted and used the established corrective action program. The NRC team reviewed a sample of Condition Reports to determine the adequacy of engineering involvement and determined that significant issues were being identified and corrected in a timely fashion. The team also interviewed various engineers regarding their roles and responsibilities to determine if they were identifying problems and how they were documenting those problems. The team found that all of the engineers interviewed were aware of when and how to document an identified problem. These results are presented in Inspection Repon 50-498/96-11; 50-499/96-11, April 12,1996.
A similar result was reported in NRC Inspection Report 50-498/96-08; 50-499/96-08, December 19,1996. There the Resident Inspectors conducted a Condition Report review in which they reviewed Condition Reports 95-1360 and 96-3056, which were associated with the Fuel Handling Building damper operability concerns that were discussed at the Enforcement Conference. The inspectors also interviewed four system engineers and five design engineers regarding the condition reporting process. The Inspectors concluded that the condition reports were thorough and comprehensive, the corrective actions adequate to prevent recurrence, and the operability and reportability evaluations adequate.
Regarding the engineer interviews, the NRC Inspectors reported that:
All of the personnel interviewed understood the condition reporting process, all said they were never discouraged or put under pressure by management from writing a condition report but were encouraged by management to do so. All were adamant that they would not hesitate to write a condition report, under any circumstances (work load, management pressure, etc.) if an issue was identified.
: 2. Management Actions At the Conference, Company representatives summarized management actions taken in             !
response to the various concerns raised about behavior of the E/I&C Division Manager          ;
which included discipline in accordance with our Constructive Discipline Policy, appropriate reflection in annual performance appraisals, and peer, management and professional counseling. Engineering management efforts were directed toward assisting        ;
and otherwise encouraging this valuable employee to overcome his weaknesses in                j interpersonal skills. All these actions were consistent with Company policy and good          j management practice.                                                                          ,
repnitid498 duc                                   4                                           j

In a {{letter dated|date=March 6, 1998|text=letter dated March 6,1998}}, the Commission requested additional information regarding employee surveys and training at the South Texas Project. The requested information is provided in Attachment D, which identifies current and planned efforts to measure the safety-consciousness of the Station environment and to effect continual enhancement in that environment.
I During the Conference, the NRC Staff asked about the Company's use of the services of RHR International (RHR), particularly when used in response to an incident at the Station. l The role of RHR is described in a {{letter dated|date=May 6, 1997|text=letter dated May 6,1997}} from our legal counsel to the Office ofInvestigations Special Agent, and is further described in Attachment E, which is a letter from the RHR consultant who was consulted by Engineering management in 1996.
As these materials make clear, RHR does not act as an interrogator or investigator.
Rather, it focuses on assessing organizational effectiveness, team building, management     i processes and the abilities and interrelationships of key people.
In addition, the Company took a number of steps specifically to address concerns arising out of the tensions that arose in the E/I&C Division in 1996. These included my meetmgs      l with DED personnel, and similar meetings conducted by the Vice President, Nuclear l
Engineering and the Design Engineering Department Manager, as well as one-on-one meetings that the new Division Manager conducted with all Division personnel. In these discussions, and in Station-wide communications, we have advised employees of the settlement of Complainants' claims filed with the Department of Labor, and the fact that NRC is considering escalated enforcement. Attachment F is a copy of my prepared statements for two of these meetings, first a meeting with DED personnel in mid-July of      i 1996, and second, a meeting with E/l&C personnel in February 1997. We intend to keep        l Station personnel apprised of the results of NRC's consideration of this matter. As further  l discussed in Attachment D, we also have planned other actions that will assess the Station   j environment and enhance safety-consciousness.
: 3. Comments of Complainants' Attomey At the Conference, Complainants' attorney made several comments. Some of the issues that were discussed are addressed above. A few additional responses are in order. The attorney noted that the Complainant whose concern led to the Climate Assessment in 1994 threatened to "go to the NRC" if not satisfied with management's actions. He suggested that NRC should take that threat into consideration in assessing management's' actions.
That is not true. NRC's actual or potential involvement played no role in the handling of this matter. Our management responsibilities are not in any way diminished or increased by NRC involvement or the " threat" of such involvement.
Another comment concerned allegations of" schedule compression." It is apparently asserted that at least one of the Complainants engaged in protected activity by raising concerns about schedule compression. At the Conference, we described the only issue repen:hrM9R4s                                 5

l 4
that may be the subject of this charge -- a change to the schedule for design of a modification to the Qualified Display Processing System. When this issue was presented l   to Engineering management in 1995,it was not presented as a safety-concern. At the l
Conference, we explained how the issue was addressed on its merits; there was no l   motivation for anyone to retaliate over this issue. We are not aware of any assertion that l   any of the alleged adverse actions identified by the NRC is connected with this issue.
During discovery in the Department of Labor proceeding, Complainants were asked to identify other instances in which they believed that they had raised concerns about schedules and suffered retaliation. None of the responses to those questions identified any specific concerns about compressed schedules, let alone associated retaliation.
At the Enforcement Conference, Complainants' attomey referenced the August 1995 meeting in which two of the Complainants brought a concern to the Design Engineering Department Manager concerning the Division Manager's involvement in a meeting with a contractor. He suggested that by asking these individuals to discuss their concern with their Division Manager, the Department Manager was effectively " turning a deaf ear" to the concern. The Depanment Manager, however, explained at the Conference that he wante? 'be Division Manager to get direct feedback about employee reactions to his condus He also explained that he told the two Complainants to come back to him if they were not satisfied with the Division Manager's response, and that he then told the Division Manager to pay attention to the employee concern he would be receiving. This approach dealt direcuy with the issue and was an appropriate way to foster improved communications between the employees and their division manager.
The attorney also stated that Complainants were pressured to meet with the RHR consultant and that RHR was used as a management interogator. The latter concern is addressed above. Attachment F, the letter from the RHR consultant, explains RHR's role at the South Texas Project and his specific dealings with two Complainants in 1996. These Complainants did not complain to the consultant about their sessions. Neither did they complain to Company management until after they filed monetary claims later in the year.
J Finally, the attorney suggested that the findings of the Department of Labor investigation should be ignored by the NRC because the investigator did not have sufficient background regarding the regulatory requirements and was not thorough. No basis was provided for either suggestion and we know of none. The Department of Labor investigator conducted       l numerous interviews of company employees and gave the Complainants ample                    j opportunity to expand on their co.mplaints during interviews and in writing. It cenainly    l appears that the attorney's suggestion was based on the investigation's outcome, not the investigation methods.
i
                                                                                                )

1 1
: 4. Conclusion j    We have carefully reviewed the NRC's letters and the currently available information and concluded that no violation of 10 CFR 50.7 occurred. The bases for this conclusion are l    provided in Attachment G.                                                                      !
The issues raised in the complaints and the NRC correspondence involve events that l    occurred over the course of more than two years. During the Conference we showed that l    as management learned of conduct which was not consistent with Company expectations it took appropriate corrective action. Eventually, management decided that the actions to effect improved performance would not be successful and asked the Division Manager to l     leave. These corrective actions were based on concerns identified by the Company and l     were undertaken without any NRC involvement, threatened or actual. Company
!    management has consistently been proactive in taking steps to ensure that there is a safety-conscious work environment in which employees are free to raise concerns.
Management actions throughout the events addressed in this Conference were consistent L    with the recommendations of the Commission to ensure a safety-conscious work environment which were published in the Federal Register on February 26,1997 and l   - withdrawn on February 6,1998.
In our view these considerations should compel a conclusion that escalated enforcement is
!    not justified. I would appreciate the opportunity to answer any further questions you may have about this matter.
Some of the attachments to this letter contain personal information, the disclosure of          I which would constitute an unwarranted invasion of personal privacy. Accordingly, we request that this information be withheld from public disclosure. Separate copies of the l
affected attachments are provided that identify with brackets the information that should
:    not be disclosed.
l If you have any questions please call me at (512) 972-8434.
Orw W. T. Cottle President and l
Chief Executive Officer WTC/nol Attachments:
A.        Information Requested Regarding Behavioral Consultant Service Surveys and Staffing Information wawu                                      i

i
(
B. Letter from Behavioral Consultant Services C. Design Engineering Department Condition Reports Originated Conditions Adverse to Quality                                                                    j D. Response to March 6,1998 Nuclear Regulatory Commission Request for Information                                                                   ;
E. Letter from RHR International                                                 !
l F. Statements of Mr. Cottle to Engineering Staff                                 j G. Analysis of 10CFR50.7                                                         l, i
t l
1 i
l l
1 a
l                                                                                       l l
i l
l l
wwwu

l 1
l
                                              \
j f
1 ATTACHMENT A INFORMATION REQUESTED REGARDING BEHAVIORAL CONSULTANT SERVICE SURVEYS AND STAFFING INFORMATION

e
                                          >@oy=B~ >
4 n        md2oO's.8e 5 i oC       T$a d     o0 t
t a& l
                                    /
SE
                                = X-  -
7    _
9 h       -
9    _
1 S           -
E           "
R          "                                 ,
O        "
C        ~
S       "                                       6 9
S       "
9 C       "
1 B       "
          ~
L       ~
L       ~
A        "
R        "
E        "
V                                               5
            ~
            ~
9    _
         ~
O 9    _
* 1    .
4 9
9 1
5 4                            3    2    1

Attachment A ST-NOC-AE-000110 Page 2 of 7 OVERALL .BCS SCORE zStations    fDED-ELECT /I&Ci:
:3                            ,
         ;1994         >
3.38                 3.12
         ;19951            .                 3.56                 3.53 4  ::!1996:;:                          3.64                 3.56 E19974                              3.57                 3.43 PERCENT /NUMBFsR PARTICIPATING IN SURVEY l
                                          ;Stationi g  sDED-ELECT /I&Q     J 119943                           93 % /2112            58 % /22 il995..j;              ,
93 % /1995            92 % /33
                       . . ..r, U9961!                           90 %/1668            100 % /44 V19971                           93 %/1636             79 % /31 4

Attachment A ST-NOC-AE-000110 Page 3 of 7 RESULTS QUESTION #59 "I can comfortably go to my supervisor to discuss a nuclear safety-related or quality-related concern."
sr         :3B k        e C-it        /D:    m 1E*
SAlmost::t                                       iAlmost3
((NEvid    ERh$hi     lSoAmetimesi    IDhdal::  tilWays5 ii996        Station         104       250          987           615         136 l
Elect /
I&C             0          2           10             8          0 (19952      Station         57         64          208           354        1288  ;
Elect /                                                               l I&C             0          0            3             5         25   l 1
[199d]       Station         50         43          154           301        1084 Elect /
l I&C             4          1            2            10         27   j
         ^
l 119974      Station         49         61          147           294        1066 Elect /
I&C             2          0            6             4          19 l
l Rttif 60C

Attachment A ST-NOC-AE-000110 Page 4 of 7 RESULTS QUESTION #59 "I can comfortably go to my supervisor to discuss a nuclear safety-related or quality-related concern."
                                                                                                 / 1
                                                     ~
i5tation!
LDEDi8 LECT /I&C?
s1994;          ,              4.31                             4.59
                  ,::1995;s   c                    4.40                             4.67 41996i                          4.43                             4.25 (19973
* 4.40                             4.23 i     '5T' (StUihn5         .         IDED-EL5CT/I&CI cyg                                  m E                   Response /         Percent      Response /                Percent Participants                     Participants 41994s4         >
2092/2137             98 %             22/22                100 %
l 1
(1995r              1971/1995             99 %             33/33                100 %
F19961               1640/1668            98 %             44/44                100 %
[1997)               1617/1636            99 %             31/31                100 %
i m_ar doc                                                                                          j

Attachment A ST-NOC-AE-000110 Page 5 of 7 Number of People Responding To Question #60 O'
55idiihnsi                  5 Net /Iddj      -
j        Response /          Percent  Response /       Percent Participants                 Participants 51994)       2020/2112             96 %     22/22            100 %
riip95?      1963/1995             98 %     33/33            100 %
           -?1996i!     1636/1668             98 %     44/44            100 %
fl99h -      1615/1636             99 %     31/31            100 %
1
      - .a u

  .                                                                                         l 1
Attachment A
{
ST-NOC-AE-000110      l Page 6 of 7
{
RESULTS QUESTION #60                                 I l
                    "IfI had a nuclear safety-related or quality-related concern, I wouldfirst express that concern to:"                   j l
l l
l A:           To my Supervisor                                                          {
l    B:           To other Management.                                                      {
C:           By writing a Condition Report ("CR").                                     l D:          Employee Concerns Program ("ECP")(Nuclear Safety or Quality Concern)
E:          NRC l                                         W           ;BJ     ,
R           a:D:!      sEn l
:Othert Sspervidor;  $NsAtli     $CR$       $ECp3     $Nkd?
          *1994J           Station       87.9 %      2.1%       2.9%         4.3%      2.8%
DED-Elect /I&C     90.9 %        0%       4.5%          0%       4.5%
:(1995;         Station       87.9 %       1.7%      4.6%         3.2%      2.6%
DED-Elect /I&C      94 %         3%        3%           0%        0%  I s1996;     ,
Station       88.3 %       1.8%      5.2%         2.1%      2.6% l DED-Elect /I&C     88.6 %      2.3%        0%           0%       9.1%
p 619974               Station       85.9 %        2%       6.9%         2.2%       3%
DED-Elect /I&C     80.6 %        0%       9.7%          0%       9.7%
are,enf doc

0                     r 1
1               t e oct 0              is ra                          1                   3                              3 0              T-    t 0    0000             2    0008           1   0    2     0       0   0   2 0-             f n
A E              Oo t
C nA7 e - f mCo hO7         6           r 9      et o aNe c
t T- g 9
1 t
is a
                        - r c
0    0000             1 000290                   1    0       0   0   2 t
a            nt                           1                                                  1 ASP              Oon C                                                                                                    _
P                                                                                                         _
                     &        7 9
871         1 7
2    060        452           4    7       4   0 9
6 L
I 323              1               641           2    1 2
I r
tet o
* c is ar    I    001 0            4    7207           8   0     2    0       0   0   7             s T-    t                        3                   1 3             p I
n                                                                                         u Oo                                                                                              o T             C                                                                                          r g
N                                                                                                        r e
E               r o                                                                                      ht 5      et o
_           M   9 9
t is c
                        - ra 6                                          0                                            o
_           T   1 nt n 6000 1
1    0001           1    0    0    2       0   0   9 1            t n
R        Oo                                                                                            i AT            C                                                                                        d e
PR                                                                                                       v EO l
o s
P DP       &        9    1 1 2            7    8                        8    6               7 id s
GE       L        0 1    433         5    3 1    2   60 472 531           2    3       7   0   1 3             e NR       I I                                                                                               r e
-           I T                                                                                                      w R
E N             r y
e E U       tet o c                                                                                      R NO       i ar s                            8        0                                         1 6    21 1 2                8       0550             0    3       0   4 I C      T-f t
n 4        3                                         6            t s
-           GD       Oo C
n e       _
-           NA                                                                                                       m EEI                                                                                                      t r
a p
RI              r o                                                                                        e       _
A   4    it et c                                                                                      d E   9 9      s- ra  8    8000             8    8 00     1 5      4    0    1       0   2   9      t  . e n s           -
L   1      nt n                         4    1          1 1                                5       u h   e       -
C        Oo                                                                                        ot dc g U             C                                                                                           n ai N
et
_                                                                                                             h c a
p      _
                                                                                                              "l P                                                                                         a ui m
                     &        5    0500             8 0    04 0       67I           6    4       7   6   %       t L        9    2331             1    21         3 2i          2    3           2   2       c5 l
f a9 "r
a/
19
-                                                                                                              e4
_                                                                                                              y9 f 9             _
_                                                                                        e                     o1             _
i v                     gn  i t                       n a
r id ne g        t                       nr n       i s
i r gu n
i t                r n
e                e       i e c b c e         m                            o m                n                                n g                        e              ig        d                l a    on i
n                        g a s             n s A                s t
o po ut i
r                                       E s /ti a
e s e
nt c a e             t     y   r          m T       dei z g       d
* r   l a o            a     g g t Mji                 o l
n iuni o  v         p n p r     n     s a n  a n ro /                                       g r gl      C                      riCp t             i                                                                        i n             e nF                      pmP      C              A pu             o     r   b g r e             or i
u             e El/&n t     r e   par na/gl/
                                                                         &u                        P e          e r
o             n       a/l e         e u gi cl l l S             &    S                 n     e e   r c           ig   tycl m             n                           l     g      r g     i g     w d
n l    i ae         ig S or ri   e aanc             e    n     a n n           s D i
a tn e
i nc E b ai gr a n g             nP e ai ic nh    r t n      F u  i r     e ri E       eE        c o
H em                                                                    e s lc e          e          r iah   c   t c   n   F idi     ogc        ch                                    uN       d nec Nu en ra s                         s                         r m e ee a n e           n e e c                                   :  gn        f.
l l
e a                                       n a tr          e RMEM                   DMEMlET l
u a  p       t ig s                           lc e  i gi n vr igl n c e EiFA T             e_
t               s                                                             P..
c    e        y                     e                             u Ee           E u     O . .         c r
A D           S     * * *
* D e * * * .
* N
* S       V
* N   N1 2          n

4 m
h i
l 1
i l
ATTACHMENT B LETTER FROM BEHAVIORAL CONSULTANT SERVICES

ATTACHMENT C NOC-AE-000110 Page 1 of 2-a c            )
ew v
stMAvionAt CONSULTANT SUMCLS. INC.
February 24, 1998 W.T. Cottle, President and Chief Executive officer STP Nuclear operating Company P. O. Box 289 Wadsworth, Texas 77483

==Dear Mr. Cottle:==

You asked me to review the data that we have collected at the South Texas Project over the years to ascertain whether there are indications of the sort one would expect to see if there had been a hostile environment in the Electrical /I&C Division of the Design Engineering Department during the 1994 -
1996 time frame.          Based on my review of the empirical data, which I have attached in the form of two charts, I cannot find any such indicators. In fact, the data demonstrates just the opposite.
As you will recall, the data is grouped into the nine (9) areas that focus on specific management practices. As you can tell from the attachment, the overall results for the Electrical /I&C Division from 1994 through 1996 show steady improvement in management practices.
Three questions from the survey warrant particular attention because they reflect the willingness of employees to raise safety concerns and to have open discussions with their supervision. These are listed on the second figure.      Question 33 states, "When it is necessary to correct an employee, my supervisor is objective and constructive," and the responses show improvement through 1996. Questions 49 states, "I observe embarrassment and humiliation being used as methods of control on the job," and also indicates improvement over the years. Question 59 states, 'I can comfortably go to my supervisor to discuss a nuclear-related or quality-related concern," and the score shows improvement in 1994 and 1995. While the data for Question 59 shows some decline in 1996, the score is very positive, as it indicates a score between "often" and 'almost always." Also, you will recall that the 1996 survey was conducted in the summer in 1996, after the outage.
I also reviewed the responses to the question: 'If I had a nuclear safety-related or quality-related concern, I would first express that concern to: my supervisor; other management; by writing a condition Report; to Employee Concerns Program; or to the NRC." The responses for the Electrical /
I4C Division indicated that the number who would report the concern to their supervisor or tr.anager in 1994 - 1996 was 90.9, 97. 0, and 90.99 percent,                                   ,
respectively.       I noted that the slight drop in 1996 reflects that four l
employees answered that they would report their concerns to the Nuclear                                      !
Regulatory Commission (NRC) .
P.O. DRAWER 7556. BEAUMONT. TEXAS 77726 7586 SS25 PHELAN SufrE lot. SEAUMONT. 77.XAS 77706. TELEPHONE do9-566 6900
                                                                                                                         )
i

ATTACHMENT C NOC-AE-000110 Page 2 of 2 i
My overall assessment of the data is that there was continuous improvement in the appropriate management practices in the Electrical /I&C Division throughout the period in question. In our opinion, we would not see such positive responses and overall scores if there were a hostile work environment, or if harassment and intimidation had been practiced routinely by the management of this division.
Please let me know if you have any other questions about our survey results.
Sincerely, Wanda Myers, Ezeeutive Director Behavioral Consultant Services, Inc.
WM/jlb l
l l
l I
C/C 3Dvd             CISe+SC8+60b'CI              INOWnv38 40 IMOd'HOMd WC'41 96-95-834

i! l                 .
6 .
4              .
.                   9        9 _.
           ~
9        9 _   _
1        1     _
5        5 _-
I!                    L N
O                                                     L8e' I
S I                                            t V
I              -
D              -                                      8586 L              --
O               -
R               -
T               -
8W9g6 N               -
O               -
C t
  &                                                     8aE3" T
N                                            1 E                                                   -
M                                                     $o5 U                                                         sSgs t
R T
                       -                       1                     _
S N
I                                                     8sRg' i-D N
1 A
L                                                    ig A
C I
t R
T                                                    t2.s*
C                                                            i 8
E                                                 -
9
                                                                  /
L                                             +   -
3 2
E                                                              /
2 E=82      S L
X.
F 0 0 0       0    0   0    0     0   0   0 0                  N 0 5 0       5    0   5    0     5   0   5 0                  E 5 4 4       3    3   2    2     1   1   0 0                  C I
L m$4 Eo*

l
         -6                                                  r e
4          1          5         ht
         .9               7          6          2            o 9        3          3          4            o 1                                          t
         .                                                d e
r a
5        5          6          7 p
9        5          3          6            m o
9        3          3          4 c
e L            1                                        b                  s y
O    .
         .4 d
l u               a R            9        8          4          9            o c             l A
w T    .9 1
1 5            m          E   t N    .1 3          3          4         i t
e               s o
m O                                                      ht e             l A
C                                                       t o
d
    &                            e s          a d
e s
r T                 y          u          s e
ve NS                m g
n s
u r
Dt n
e EM                                                         s
                       ,       i            c                  a o
f s
ME    .
e e        b e        i d                9 w
UT    _.          y o e        n          o n
                                                     . 4 RI              l            o         t      r e
m e
TY                p v      i t
t           r c            i a          o                  r S E               mi   t   i s n   o        f o
s NV                e c      l i          i                    e              e n u        m.         v     c            r I                       r                                  o              m R                                    r N    at s       ub         ed p et c
s        C i
t e
D- U         O   t c n      h o ua e              m NS           I    e o   c  dj           s ht
                                                                   ,        S o
A                            n e l              s T    r r          aht        yr e           i s
a L            S    od c n                   m ty-          b n n t
A            .E         a                                t n
o     e    e o        oi              i o
C            U   t v    ml t    l a            p              y s o        gq u o                               l I
R    -Q           yi r
a t
c    s t r
5 t
o        B e
r a
r n R
T                 s e        a          y r             1 s j              o  l       o            a C                 eb c o r
a c      b ad e               n o
E                 e s      bf          t L
E ni s r mo e s      f r t o   l a
d e
o r
S:
N e            c     O i
t i i o
s    e do vh mr o r-s a
e r
I T
P r
e v
e r t                                        N n v                   c     a                             8 e e   r    e s     e nl    e s
m    OA      t s
o 9
                                                                                /
3 2
h       p  b       m    a     c            e t     R        m
                                                                                /
2 o s        c     u i
E      l S
L A
l Wsu        I      a   I      n    E:
T A l
W S
X.
F N
E 3          9          9         O             N          C U
3          4          5         N             A

9 O
                                              )
1 !
ATTACHMENT C DESIGN ENGINEERING DEPARTMENT CONDITION REPORTS ORIGINATED CONDITIONS ADVERSE TO QUALITY
                                              )
l l

                                                                                                  $>ai$ o 59>jj l
a                                              s                               I1 ca           .
t o                                            R s                                                                       _
T         C            R                       C l
                           &            C                       l a
c      /
l s    l                         a                                               _
i l
aR           a                     t o
n t                                                                 y cC a       i r
o                     T                                       i t
h                      T                         r                                     l c s t
c l
a    E                         e                                       a us t              eR        et o                               h                                         qn S                       t n          MC l
E T          T                       O                                         oi o
e         g         B I
j j
j t
e s
t a
c  _
t m *s t
                                                ,                [
r g e
vi n r   r                                                                                             dk a
p   o p                                       -                      -
a c s
nt ra e e
                                                  .i :
                                                  .!:!:ii+
                                                       !:!:ii
                                                  .!:!:ii~                                                os       _
ia t
D R i
7 9       dh n c g                                ]                                   1
                                                                                             ," 9         o  u n
                                                                                     ,l c s 1
i n o                                                                -                   ,
h y t    t r i
                                                                !:!i<                                     oi l t
e d i                                                       !:!l~
                                                                !:!i
                                                                !:!f=
b a s
e qu e n                                                                                       6 9       dut o n o i
                                                                                 ,? l''       ~ 9       l c e i                                                                                           1 g C                                                                                               i nsr e
n l 3:!!
ts v E ta                                                               :
3:!!~ :    !     !
5 rd oa pt n o                           p x          ~
r:                 9 9
e r o n
n g T                                                            L i
1 o nso s                                                                                                 i i
t e
                                                                                             '               i l-l d    i t
                                                                                       .l=                 nd o
c n i
D                                                                                   i 4              o a c l
                                                                                 !i=            9 9         t d 1
Ta on
_}       _[             _:                  - : -                  - -
0        0         0              0                       0                      0 5        0         5              0                       5 2        2         1              1

  .                                                                                          >1>OCamH O 28 >1aoOwHo T
t s                                                                     ,am N om a L
s   Q Q     A A     C C     C l
                     &                    s a   l s         Q c   /
l Q          A i
n     a      A a     c                 C h
i r      C           r t          c t
c      E           e ny       e   l e      S h
t M     E        T          O eit    a     O        B          D mla r u t                                       -
                              !!!!i!* !!:* $!!!!!
                              !!!!!!*      !!::$!!!!! i aQ
                              !!!!!!* !!:* i!!!!!                  !!!!!!."
p 7
e To l                                                                           9 9
1 D
gse nr                                                              ! ! ! i !."
                                                                        ! 5 !l!! i !."
                                                                        !,5!i!.  ;
                                                                                           ?
6 ier ev                  l q.iS! :,             .p2 9
9 ed                                       '
I                                1 i
nA gs                                                                           !!
                                                                                     !!.E nn                                                                           i!."
t!
s!.
i! . "
5
-     Eo   i 9
t                                            < 3'                                        9 ni                                                                 -
1 gd in s o                                                                                   .'
eC D
4
                                                                               .                    9
                                                          ; Tb h a '
                                                                         ~
1
                                                                               .                    9 1
: _ -          : ~ -                _ - - -
l                   _
0            0                 0                        0                          0 4            3                 2                        1

.              !f
               !E
               ![
7 9
y           9 t             1 is l
at u n  a Qn t oa i l
6 9
ep          9 smo 1
r e
vC d      y Ab            5 9
sd n
9 e
1 ot ia t
i di     n ng oi r        4 CO            9 9
1 5

ATTACHMENT D RESPONSE TO MARCH 6,1998 NUCLEAR REGULATORY COMMISSION REQUEST FOR INFORMATION

l o
Attachment D NOC-AE-000110
.                                                                                 Page 1 of 3 1
Response To March 61998 Nuclear Regulatory Commission Request for Information I
i As discussed in the Enforcement Conference, the new management team recognized in 1993 that successful restart and sustained opcrational excellence was predicated on changing the atmosphere and the perception of the atmosphere at the South Texas Project.
Efforts continue to maintain and improve station culture to ensure that the environment is open and there is a positive relationship between employees and supervision that promotes the willingness and ability of employees to bring forth safety concerns. Numerous actions in 1993 were begun towards this end, including the use of the Behavioral Consultant Services to perform site-wide assessments of the working relationships between employees and supervision. This tool has been a key to assessment of the station environment and was used each year through 1997. However, prior to the survey in 1997 executive management and the contractor recognized that employees had seen the same questionnaire for 5 years in a row and that the instrument was likely growing stale. Focus group sessions were added to the 1997 survey to help determine how to better assess climate in the future, and an effort was initiated to find an improved instrument that would better suit station needs considering where the station culture had evolved to by 1997.
Beginning in 1998, the station will integrate into its overall program for enhancing the work environment a tool developed by Synergy. Synergy provides a Comprehensive Cultural Assessment which includes both a written survey of employees (including supervision and management) and baseline contractors, and confidential interviews of selected individuals. This will be an independent chara terization and rebaselining of the   I nuclear safety and general culture at the South Texas Project and will include an            )
evaluation of cultural values, behaviors, and practices; leadership characteristics; and     l identification of areas for future cultural development. This activity is scheduled for the  l second quarter of 1998 and expected to be performed on 18 to 24 month intervals.
Synergy has utilized this tool at a number of other nuclear power stations and facilities, and has developed a proprietary database which provides insights on areas for improvement, etc. This tool is a natural follow-on to the assessments previously conducted by BCS. The tool also fits with other metrics used by STP, such as the Leadership Assessment Tool (LAT), which is discussed below. As part of the overall cycle, other diagnostic tools and intermediate " mini" surveys will be conducted, as needed, l in selected areas between uses of the comprehensive tool to assess progress in specific areas and provide specific feedback.
l I

Attachment D NOC-AE-000110
.                                                                                   Page 2 of 3
    -In 1994 the station began to use the LAT to provide feedback to supervisors and managers on their personal management attributes. Employees rate their immediate               j supervisor / manager in various aspects of management and the overall results are provided     j to the supervisor / manager. It is expected that this or a similar instrument will continue to be used on an annual basis. Results from this tool are used to identify areas for individual improvement and are expected to be factored into the individual supervisor's or manager's appraisal and development assessment plan. Specifically, in 1997 and 1998, results of the LAT were reviewed not only from an individual supervisor's development viewpoint, but also to assure that intervention, where necessary, was occurring. Specific criteria were utilized to identify supervisors who were not meeting site expectations, either in the current assessment, or the previous two assessments. Human Resources worked with, and continue to work with, the management of these individuals to assure that specific action plans are in ptace to address the issues raised by these assessments.
To provide continual reinforcement of management and supervisors responsibility for creation of a culture in which employees feel free to raise safety concerns, a continuing training program is provided for supervisors and managers. Participation is mandatory.         I This program is under the auspices of the Supervisory Skills Technical Assessment Committee (TAC). As oflate 1997, the TAC evaluated the key issues facing station supervisors and managers and determined that continuing training should focus on maintaining and improving the skills that promote a safety conscious work environment.
The TAC made this determination based on a number ofinputs including review cf the operational experiences at the Clinton Power Station related to the failure of a Recirculation Pump seal, review of departmental self-assessments against INPO performance criteria, and a station-wide review against INPO performance criteria related to Safety Culture. The TAC considered this relationship between supervision and employees as an essential component of accomplishing and sustaining world class operations at the South Texas Project. As a result of this determination, the TAC scheduled supervisory training on Building Positive Relationships to be conducted in the first half of 1998. This training was planned to include specific feedback on the behaviors that were discussed in the enforcement conference. This training will reinforce the imponance of maintaining a safety conscious work environment and help managers and supervisors understand options and strategies to deal with conflicts in the work place within the context of maintaining a safety conscious work environment. A specific course entitled " Safely Speaking" which is offered by Employment Learning Innovations, Inc.

Attachment D NOC-AE-000110
  .                                                                              Page 3 of 3 (ELI) will be incorporated into this training The ELI course has been successfully utilized at several other nuclear power stations.
It should be noted that all the actions discussed above are part of the ongoing efforts at STP to assure a quality work environment. It is only in such an environment that the overall goals, mission and vision of the Company can be realized.

4 ATTACHMENT F STATEMENTS OF MR. COTTLE TO ENGINEERING STAFF

July 11,1996    i INTRODUCTION                                                                         I l
Ladies and Gentlemen:
I I want to take just a few minutes with you this morning to really try to            i dispel what I perceive as some suspicion and uncertainty with respect to an ongoing issue in the Design Engineering Department.
All of you are aware, at the South Texas Project we deal with complex issues both from a technical and a human standpoint. From time to time, we have legitimate disagreements in both those areas. That's true today and, I think in spite of everyone's best efforts and intentions, will be true to some extent for as long as the South Texas Project exists.
Now I don't think these circumstances are an indictment either of the technology that we all work in or of an indictment of the Team we are all trying to build at South Texas. Rather, I believe that it is realistic to expect that any organization that deals in a demanding technology and has a highly skilled and dedicated work I
force will have issues which lead to disagreements. I don't believe that we would    '
want it to be otherwise. The alternative to me would appear to be an organization of "yes" people - an organization where diverse views and new approaches aren't solicited or considered. I don't want to work in such an organization and I don't believe that you do either.
1

BACKGROUND This Team has worked awfully hard over the past three years. Your contributions to the restart of both of the units, the safe & reliable operation of the units, and the new world standard you have established for the planning and execution of refueling outages have been nothing short of incredible. This Team has taken on tough issues in a straightforward and open manner and your performance in addressing these issues has indeed been World Class.
Nothing we have accomplished in these past three years has been more important than our efforts in trying to shape a work environment where issues are addressed in an atmosphere of openness and with personal and professional respect.           We aren't perfect in this regard, and probably never will be, but we have made substantial progress. We have significantly improved:                                 l
: 1)    The Employee Concerns Program
: 2)    Supervisory and Management Training
: 3)    Our formal & informal communications processes
: 4)    Call out methods to solicit individual employee input such as the BCS Survey, the Leadership Assessment Tool, and the Business Planning and Budgeting process.
2

We know that additional improvements are still possible and we are pledged to continue our efforts in this regard.
CURRENTISSUE At the present time, we are attempting to address a situation in DED which relates to an outwardly successful manager that some employees felt to be overbearing          3 and was perceived to be allowed by senior management to create a hostile work l
l   environment within his division.
It is not my intention this morning to make any remarks with respect to these l
!   circumstances that would reflect negatively on that manager, who is no longer with the organization, or would reflect negatively on any of the individuals who feel that they have been harmed. I respect the personal privacy of all of the individuals in this situation.
l But this situation is being talked about in the organization and I believe that all of 1 you deserve to know how we are attempting to address it. We can't afford to let this group be distracted by personal confrontations or professional disputes - your contribution to the continued safe operation of this facility are too important.
My personal desire would be to put this issue behind us as quickly as possible.
However, with the potential for litigation, my experience has been that a speedy resolution isn't always possible and so these issues may be with us for some time 3
l l

to come. And that is ok. We are professionals and we will deal with this matter in a professional manner, respecting every emplcyee't right to seek redress of the courts if they believe they have been wronged.
I have initiated an independent investigation to get all the facts but I can share some preliminary observations with you based on an internal review.
i)       First, there were clearly some personality clashes among good people.
Some of the behavior was certainly not up to our expectations and was probably unprofessional.
I ii)      Secondly, some of the people involved had worked together for a        '
number of years before coming to STP. One of the individuals had expressed an interest in leaving. This individual and one other were offered separation packages if they desired to leave. They have declined and we are happy to have them continue to contribute to STP.
iii)     Thirdly, some individuals feel that they have been treated unfairly. I have asked them to begin a dialogue about their concerns. We must work through their attorneys. That is their right and we respect it. l We will try in every way to respond to their concerns. I sincerely hope that they will respond favorably to my request for discussions; 4

and we have no pre-conditions for such discussions.
There has been some speculation about why senior managers permitted actions which were viewed by some individuals as unacceptable. I am withholding final judgement until we complete the independent review that I mentioned, but I have known Steve Thomas and Ted Cloninger for many years and I can tell you that neither one would tolerate harassment or intimidation; both are true professionals who share my management philosophy concerning the importance of the "open site." If the actions they took or failed to take are perceived as intentionally 1
improper i believe that is a mistaken impression. We will address that issue after I our investigation is complete and all the facts are on the table.
I have reported these matters to the NRC personally, including the independent investigation that we have initiated. We are elso continuing our investigation of any technical aspects of the control room envelope damper issue.
We will share the summary conclusions of these investigations with you to the full extent that sharing the results does not in itself cause harm or damage or embarrass any of the individuals involved.

==SUMMARY==

I came here in 1993. I pledged to myself and to every employee on this site that 5
1 j

we would work to have an "open site" where everyone could freely state his concems and best professional opinions. Our surveys and various inspections indicate that we have made tremendous gains in the last three years and that people generally feel that their concerns and observations are welcomed and l   encouraged.
l We have come too far to let things to slip away. We also know that complacency i   is the enemy and we're not going to slip into that mode -- we need the continued support and confidence of everyone on site. If you have problems or concerns, let us know about them.
The problem we are dealing with here is not unusual. We have highly motivated, hard driving people who are pushing to solve problems. These traits have served to make STP a stand-out performer but they can have a downside when l
l   personalities clash. We can solve that problem without sacrificing the benefits if we reason and talk together. If there was harassment, we'll get to the bottom of it and correct the situation. In the meantime, let's not lose sight of our shared goal of making STP a "World-Class Performer."
My door is open to each and every one of you. If there are questions or concerns that you feel have not been appropriately addressed, I would welcome a personal visit and an opportunity to discuss them with you. Thank you very much. That's really all I have this morning. Have a nice day.
6

t.
February 12, 1997 Good morning -
l I know that you are all extremely busy - you have an outage, and other activities, to support - and that's important.
I want to take a few minutes of your time this morning to update you on an issue that is as important to me, and I believe to this organization, as your support of the on-going outage and other    )
l    activities.
l l
l Last July, I' met with the entire design engineering organization l    and shared my thoughts on an issue that was developing in the Design Engineering Department. This morning, I would like to review the comments I made at that meeting and then give you an l
update of where I believe we are today on that issue. If you will bear with me, let me read the comments I made in our July meeting.
l
     " July 11, 1996 meeting comments" Alot has occurred since July and I believe it is important to keep you abreast of where we are today. So where are we today?
1
: 1. In July I told you that I had initiated an independent investigation of this issue. I commissioned Ms. Kathleen Shea, a retired attorney, to perform this investigation. I selected Ms. Shea for a number of reasons:
First, Ms. Shea is an excellent attorney with a great deal of experience in intimidation and discrimination cases.
Secondly, Ms. Shea was familiar with the South Texas Project l      and with my personal expectations of maintaining an open l
l      work environment where individuals could freely state their concerns and best professional opinions.                      ,
l Thirdly, Ms. Shea is retired. She doesn't depend on the South Texas Project, or on Bill Cottle, for any future business or income.
Lastly, and most important, I trust Ms. Shea to tell me exactly what she believes, because she always has.
l Ms. Shea interviewed some 29 individuals, both HL&P and       !
consultants, in the course of the investigation. The bottom line of her report, as made to me on August 29, 1996, was:
1 l                                  2

i
         ... complainants are all adult male professionals who have worked at nuclear power plants for lengthy periods (each for ten years or more), not in ivory towers. This investigator believes that each must necessarily have been accustomed to pressure and to conversation which would not be appropriate for a " tea party."  Let us assume that (the manager's)
L      behavior could be termed abrasive. This investigator has not found any suggestions before May 1996 that any of (the manager's) behavior was undertaken for a discriminatory or
!      retaliatory purpose or resulted in discrimination or           1 i
retaliation. The present allegations are not supported by i
!      facts established during this investigation."    Ms. Shea goes on to say that, "Nothing suggests that there was a hidden      I i
motive of retaliation against these employees if, indeed, the offer of additional compensation to a person who chooses to leave his employment can be regarded as retaliation.
l
: 2. The Occupational Safety and Health Administration of the l      U.S. Department of Labor investigated the complaints that      !
l l      were made in this issue. Their findings were transmitted in l      a {{letter dated|date=November 5, 1996|text=letter dated November 5, 1996}} which stated that:
        "This letter is to notify you of the results of the investigation in the above noted case, in which the above i
named complainants alleged violations of Section 211 of the Energy Reorganization Act, as amended. Our initial efforts 3

a to conciliate these matters did not result in mutually agreeable settlements. Fact finding investigations were then conducted. Based upon our investigations, the weight of the evidence to date indicates that complainants alleged themselves to be protected employees engaging in protected activities within the scope of the Act, and that discrimination as defined and prohibited by the statute was a factor in the actions which comprise their charges. The evidence did not verify that discrimination was a factor in any of the charges. Consequently, it is determined that complainant's allegations can not be substantiated."
: 3. In November 1996, the Nuclear Regulatory Commission conducted an inspection which included, among other things, the design change packages for modifications to the heating, ventilation and air conditioning systems for the control room and fuel handling building. They also reviewed the condition reports associated with the 125 Vdc power supply from the station batteries to these systems and the failure of the Train B fuel handling building exhaust system to operate in automatic mode. The findings of this inspection are documented in an NRC inspection report dated December 19, 1996. The findings of the inspection included:
4

a "The modification package and review for the replacement of control room and fuel handling building heating, ventilation and air conditioning damper power supplies, from battery i
!   packs to the station batteries did not thoroughly consider all relevant design input information and confirm all design inputs. This was an isolated situation not representative 1
of the state of other design changes reviewed."
    "The inspectors found that the condition reports were thorough and comprehensive. Condition Report 95-1360 addressed the concerns and the weaknesses of the new modification process. Because there were no actual equipment failures, most of the investigations and corrective actions revolved around programs and processes.
The inspectors found that the corrective actions taken in response to the condition reports were adequate to prevent recurrence. The condition reports reviewed also generated operability and reportability evaluations which were reviewed by the inspectors and found to be adequate.
The inspectors interviewed four system engineers and five design engineers regarding the condition reporting process.
All of the personnel interviewed understood the condition    j reporting process, all said they were never discouraged or   l put under pressure by management from writing a condition 5

c o
f report but were actually encouraged by management to do so.
All were adamant that they would not hesitate to write a condition report, under any circumstances (work load, management pressure, etc.) if an issue was identified."
Where do we go from here?
First, the reviews and investigation activities will l
l          continue. The initial Department of Labor finding has been appealed and will be heard by an Administrative Law Judge.
The NRC has an on-going investigation of the non-technical aspects of the issue. We will cooperate and actively participate in these on-going proceedings - and let the l          facts determine the outcome. From a personal standpoint, I have not seen anything which causes me to doubt the honesty i
j          and integrity of this organization or its management. I l
continue to have the utmost confidence in Steve Thomas and Ted Cloninger - I believe that they share my beliefs and l
convictions that an open site environment is essential to l
l the continued safe operation of this facility. That's my l
reason for requesting this meeting with you this morning.
We need every individual to feel that their concerns and best professional opinions are valued as contributing to the l
safe operation of the South Texas Project. If there is anything arising out of this issue that is troublesome to you or would cause you to hesitate to share any concerns 6
L_  _

k that you might have, I would welcome the opportunity to discuss that with you. I continue to believe that the only issues that can jeopardize our goal of making STP a "World Class Performer" are those that are not expressed and therefore not addressed.
Thank you for your time and your attention this morning.
And thank you for your continued contributions to the South Texas Project.                                               ,
I 1
1 l
l l
I l
l 7}}