ML062070008

G20060525 - Glenn Adler Ltr. Re South Texas Project Electric Generating Station - Petition Pursuant to 10 CFR 2.206 - Comprehensive Cultural Assessments

ML062070008
Person / Time
Site:	South Texas
Issue date:	06/26/2006
From:	Adler G Service Employees International Union
To:	Reyes L NRC/EDO
References
2.206, G20060525
Download: ML062070008 (31)

Text

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$£U0 June 26, 2006

% EDO DEDMRS DEDR Stronger Together DEDIA AO Mr. Luis A. Reyes Executive Director for Operations LA),

United States Nuclear Regulatory Commission Washington, D.C. 20555-0001

Subject:

South Texas Project Electric Generating Station - Petition Pursuant to 10 CFR 2.206 - Comprehensive Cultural Assessments ANDREW L. STERN

Dear Mr. Reyes:

International President ANNA BURGER Attached please find a memorandum providing additional information to International Secretary-Treasurer supplement our May 16, 2006 petition pursuant to §2.206 of Title 10 of the Code of Federal Regulations, requesting the U.S. Nuclear Regulatory.

MARY KAY HENRY CommiSsion (NRC) to take enforcement action against the South Texas Executive Vice President Project Nuclear Operating Company (STPNOC), the licensee for the South GERRY HUDSON Texas Project Electric Generating Station (STP).

Executive Vice President This information will be presented at the Petition Review Board, June 27, EUSEO MEDINA Executive Vice President 2006 at the U.S. Nuclear Regulatory Commission in Rockville, Maryland.

TOM WOODRUFF Executive Vice President Yours truly, Glenn Adler Senior Research Analyst Ph: (202) 730-7426 Fax: (202) 350-6613 Email: adlerg@seiu.org SERVICE EMPLOYEES INTERNATIONAL UNION CLC 1313 LStreet. N.W.

Washington, D.C. 20005 202.898.3200 TDD: 202.898.3481 wwv~'SEU 0rg 1 r-- 2IDS~. E-.bD-oA

South Texas Project Electric Generating Station -

Petition Pursuant to 10 CFR 2.206 - Comprehensive Cultural Assessments Pursuant to §2.206 of Title 10 of the Code of Federal Regulations, the Service Employees International Union (SEIU) petitions the Nuclear Regulatory Commission (NRC) to take enforcement action against the South Texas Project

.Nuclear Operating Company (STPNOC), the licensee for the South Texas Project Electric Generating Station (STP).

In 1998 STPNOC was required to conduct periodic independent surveys after the NRC found that the licensee had violated federal law by subjecting four employees to a "hostile work environment" after the employees raised safety concerns.1 According to the confirmatory order, STPNOC agreed to report the results to the NRC.

While improvements have been made in STP's safety conscious work environment, important problems continue to plague certain entities at the plant, which appear to be impervious to remediation. The security contractor at STP, the Wackenhut Corporation, performed poorly on comprehensive cultural assessments in 2001 and 2003. Despite apparently repeated efforts by STPNOC to evaluate its performance and take remedial action, a more recent survey revealed that such problems appeared to have continued into 2005.

According to NRC replies to FOIA requests, the Agency appears not to be in possession of important documents concerning these matters, including the 2005 cultural survey itself, STPNOC's associated final action plans and the results thereof. Absent such information, NRC can scarcely understand these persistent problems, let alone perform an effective oversight role. It is unclear whether action plans had in fact been developed by STPNOC, whether they had been implemented, or whether the results were satisfactory.

Specifically, SEIU seeks enforcement action in the form of a Demand for Information (DFI) under § 2.202 of Title 10 of the Code of Federal Regulations that would require STPNOC to provide the NRC with docketed copies of:

" Any assessments of the safety conscious work environment (SCWE) at STP conducted since January 1, 2004;

• Summaries of any associated action plans and the results of any efforts to remediate problems revealed by these surveys, including, but not limited to documents mentioned at an August 2005 meeting apparently convened to discuss the plant's SCWE:

o A SWOT analysis to assess the issues and actions required and follow-up on these actions to improve station alignment, o An outsourcing lessons learned, Service Employee, Internationa! Union I

o And an evaluation of IT, Supply Chain, Technical Training, and Wackenhut to assess the issues and recommended actions [see below];

" Summaries of any associated action plans and the results of efforts to remediate problems revealed by such surveys in 2001 and 2003;

" All correspondence between the NRC, STPNOC, and the Wackenhut Corporation concerning the 2005, 2003, and 2001 CCAs.

The documents that are in the possession of the NRC indicate persistent problems with Wackenhut's - and other STP units' - performance in respect of the safety conscious work environment. Given that the surveys - and the associated action plans - were undertaken by STPNOC in compliance with the 1998 Confirmatory Order, the absence of any documentation at the NRC as to whether the recommendations had been followed is disturbing. It is therefore necessary for the NRC to obtain and review this information from STPNOC to assure the maintenance of a safety conscious work environment, a vital condition for the safe operation of the nuclear plant.

Background

In 1998 STPNOC was required to conduct periodic surveys by an independent survey research firm after the NRC found that the licensee had violated federal law by subjecting four employees to a "hostile work environment" after the employees raised safety concerns. 2 [See Appendices, p. 12] STPNOC hired Synergy Consulting Services Corporation to conduct the surveys.

United States Nuclear Regulatory Commission Office of Public Affairs Washington, DC 20555 Phone 301-415-8200 Fax 301-415-2234 lntemet:opa@nrc.gov No. 98-87 FOR IMMEDIATE RELEASE (Tuesday, June 9, 1998)

NRC STAFF ISSUES CONFIRMATORY ORDER TO SOUTH TEXAS PROJECT REQUIRING IMPROVEMENTS TO EMPLOYEE CONCERNS PROGRAM The staff of the Nuclear Regulatory Commission has issued a Confirmatory Order to the STP Nuclear Operating Company confirming its agreement to improve the handling of safety concerns brought to management by workers. The South Texas Project nuclear generating station is located near Bay City, Texas.

Service Employees International Union

Synergy conducted confidential interviews to assess each department's and contractor's performance against the plant's overall results and against the nuclear industry as a whole. According to the confirmatory order, STPNOC agreed to report the results to the NRC.3

1) Use an independent contractor to periodically survey its employees, supervisors, management and contractors about their concerns regarding a safety-conscious work environment through 2002 and report the results of each survey to the NRC.

The Wackenhut Corporation took over security at STP in July 2001 after winning a three-year contract for security with two option years.4 In 2001 and 2003, the South Texas plant's overall scores ranked among the highest in the nuclear industry. Wackenhut's performance however, came in for repeated criticism.

In both surveys, Wackenhut scored poorly on independent surveys assessing the company's nuclear safety culture, safety conscious work environment, general culture and work environment, and leadership, management and supervisory skills and practices at STP.

2001 CCA: Wackenhut Identified as "Priority" Organization In the 2001 survey, Wackenhut was identified as a "Priority Level 1" organization

- the worst possible result - because of its "relatively low" results compared to the composite rating for STP as a whole on the dimensions surveyed:5

• Nuclear Safety Culture (NSC);

• "Relatively high negative response rates" for Safety Conscious Work Environment (SCWE);

o 31% of respondents said they knew someone "who experienced a negative reaction from [Wackenhut] supervision or management for having raised an issue or concern related to nuclear safety;"

• Among the "lowest rated organizations" for General Culture and Work Environment (GCWE);

" Among the "lowest rated organizations" for Leadership, Management and Supervisory Skills and Practices (LMS). 6 Service Employees Iuternational Union 3

Figure V11I.2 L~o est .Rated Orpanitationsss NSC (CCI <3.65) GCWE (CCI <3.40) LMS (CCI <3.40)

Wackenhut Wackenhut Wackenhut 3.58 (13%) 3.24 (22%.) 3.09 (26%K)

I & C Maintenance I& C Maintenance I & C Maintenance 3.63 (13%) 3.28 (21%) 3.29 (21%)

Mechanical Maintenance Mechanical Maintenance Mechanical Maintenance 3.64 (12%) 3.18 (23%) 2.96 (30%)

Unit I Operations Unit I Operations 3.38 (16%) 3.20 (21%)

Unit 2 Operations Unit 2 Operations 3.37 (17%) 3.28 (18%)

Electrical Maintenance Electrical Maintenance 3.37 (16%) 3.38 (15%)

Health Physics Health Physics (16%)

_3.37_3,39 .... ..... (14%)

Plant Design 3.39(13%)

Figure VIII.7 Recommendations for STP Tar eted Organizations - "Relative Norms" Criteria63 Priority NSC SCWE GCWE LMS SOrganization Level Wackenhut 3 .58 3.97 3.24 3.09 Wackenhut! _13.1% 10.0%

..... 363 4.06 3.28 3.29

-MC Maintenanco1 13.2% 9.9% 20.8% 21.3%

According to the consultant, Wackenhut's 7 scores required "further evaluation" and "remedial action in the near-term."

Wackenhut was also identified as a "Priority Level 3" organization because of its low ratings compared to industry standards.8 Service Employees International Union 4

Figure V.II.6 Recommendations for STP Targmeted Organizations - "Industry Norms" Criteria Organization Priority NSC SCNVWE GCWE LMS Level _____ _____

.2.96 CC[

Mechanical 2 Declined Declined 30.0% neg.

Maintenance 6.1% 8.1% Declined 12.3%

3 3.09 CCI Wackenhut"1 W__kcnhu ____ _25.6%3 neg.

Unit I Operations 4 Declined 6.3%

Risk & " Declined Reliability Analysis ...

. .___5.1%

According to W.T. Cottle, STPNOC's CEO, formal action plans would be prepared to address the survey results. 9 [See Appendices, pp. 14-16]

Nevertheless, the survey did identify. areas where additional improvement is needed. In reviewing the data, demographic variations have been noted between hourly/bargaining unit personnel, contractors, and plant staff. There were five organizations identified in the Executive Summary (Figure V111.7) as Priority I organizations due to their ratings relative to STP general performance and as such will have formal action plans prepared to address the survey results.

2003 CCA: Performance Deteriorates In the 2003 survey, obtained by SEIU through a Freedom of Information Act request, Wackenhut's already poor performance deteriorated further. Wackenhut was again rated as a "Priority Level 1" organization because of its "relatively low" results compared with STP's general performance:

• Once again, 31 % of its employees indicated that "during the past year, they know of someone who experienced a negative reaction from supervision or management for having raised an issue or concern related to nuclear safety," compared to an STP composite score of 12%;1°

" Among the "lowest rated organizations" for Nuclear Safety Culture (NSC);

" Among the "lowest rated organizations" for General Culture and Work Environment (GCWE);

• Among the "lowest rated organizations" for Leadership, Management and Supervisory Skills and Practices (LMS).1 Service Employees International Union

rigure VIII.2 6 Lowest Rated Organizations Mechanical Maintenanci Mechanical Maintenance Mechanical Maintenance 3.47 (16%) 2.99 (29%) 2.86 (35%)

Wackenhut Wackenhut Wackenhut 3.47 (14%) 3.17 (221/.) 3.08 (27%)

I & C Maintenance I & C Maintenance I & C Maintenance 3.56 (16%) 3.10 (2714) 3.10 (26%)

Plant Design Plant Design 3.31 (16%) 3.22 (20%)

Support Services . Support Services 3.34 (16%) 3.27 (23%)

Facilities 3.31 (19%)

Plant Mods & Des. Basis 3.36 (19%)

Electrical Maintenance 3.40 (13%)

Moreover, its performance against the industry worsened from "Priority Level 3" to "Priority Level 2." According to the survey, 12 Wackenhut's performance on these, metrics was in fact declining at the time.

The consultant recommended that "Evaluation and remedial action is suggested in the near term."13 As a result, STP's president told NRC that "formal action plans" will be prepared to address the survey results.1 4 [See Appendices, pp. 17-18]

Service Employees International Union 6

Nevertheless, the survey did identify areas where additional improvement is needed. In reviewing the data, demographic variations have been noted between hourly/bargaining unit personnel and the plant staff. There were three organizations (Mechanical Maintenance, -

Wackenhut Security, and I&C Maintenance) identified in the Executive Summary (Figure VIII.6) as Priority organizations due to their ratings as compared to the industry and as such will have formal action plans prepared to address the survey results. The action plans will be prepared after the current Unit I refueling outage and will be submitted to Senior Management for approval.

No Evidence of Efforts to Remediate Wackenhut's Performance at STP In July, 2003, following an inspection at STP, the NRC concluded that a safety conscious work environment was in place at STP; accordingly, the 1998 Confirmatory Order was closed. 15 Despite repeated commitments by STP officials that they would develop formal action plans specifically to address the results regarding Wackenhut, there is no public evidence that any concrete actions have been taken to resolve the problems revealed by the 2003 survey.

In response to a Freedom of Information Act Request filed in July 2004 by SEIU, NRC was unable to locate any documents indicating that STP's promised formal action plans had been developed for Wackenhut or that evaluation of its performance or remedial action had been taken.16 SEIU specifically requested:

Any documents (letters, notes, email, reports, memoranda) indicating that such "formal action plans" have been prepared in respect of Wackenhut's performance as assessed in the 2003 Comprehensive Cultural Assessment at STPNOC, or indicating that the evaluation or remedial action referred to has in fact been taken. [See Appendices, p. 19]

The response from NRC was "No agency records subject to this request have been located." [See Appendices, p. 20]

PART 1.8 - INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE No agency records subject to the request have been located.

Certain Information in the requested records is being withheld from disclosure pursuant to the exemptions described in and for

. the reasons stated in Part II.

2005 CCA: Wackenhut's Performance Problems Continue In December, 2005 SEIU learned that another Comprehensive Cultural Assessment had been conducted at STP during the previous year. As no Service Employees International Union 7

documents were publicly available on ADAMS, the NRC's Electronic Reading Room, SEIU requested, under FOIA, copies of:

Comprehensive Cultural Assessments or any other evaluation conducted by the STPNOC, independent contractors or by the NRC to assess the safety conscious work environment at STPNOC since January 1, 2004, as well as any correspondence, reports, presentations, or memoranda between the NRC, STPNOC, and any other entity concerning such assessments."' [See Appendices, p. 21]

A document released to SEIU under FOIA (2006-0052), "South Texas Safety Culture Survey with slides," describes a meeting of some 90 participants which appears to have taken place in August, 2005 at which the 2005 Comprehensive Cultural Assessment was discussed. According to this two-page document,

'The[re] were problems with security, I&C, Design Engineers, and Ebasco-Rathyon [sic]. NO SPECIFIC DETAILS." [See Appendices, pp. 22-23]

SOUTH TEXAS SAFETY CULTURE SURVEY

Background

The STP safety culture survey came about because of a Confirrnatory Order, dated June 9, 2005. were problems with security, I&C, Design Engineers, and Ebasco-Rathyon. NO The DETAILS SPECIFIC At least two of these four entities were singled out for further attention in previous Comprehensive Cultural Assessments. In both the 2001 and 2003 CCAs, Wackenhut and I&C were named as "Priority Organizations" for whom formal action plans would be prepared.

The NRC's final response to our December, 2005 FOIA request (2006-0052) did not include copies of the Comprehensive Cultural Assessment or any other survey on which the results were based. On March 14, 2006 SEIU appealed the NRC's response to FOIA 2006-0052 specifically asking for a copy of the 2005 Assessment itself. [See Appendices, p. 24]

In response, the NRC revealed that it is not in possession of any cultural assessments responsive to SEIU's request. [See Appendices, p. 25]

Service Employees International Union 8

On January 24 and March 9, 2006, I provided records responsive to your Freedom of Information Act (FOIA) request number FOIAIPA-2006-0052. Your request asked for documents related to any cultural assessment of the safety conscious work environment at the South Texas Project Nuclear Operating Company (STPNOC) since January 1, 2004.

This letter clarifies the fact that the Nuclear Regulatory Commission (NRC) is not in possession of any cultural assessments responsive to your request.

Sincerely, Russell A. Nichols FOIAPrivacy Act Officer Office of Information Services The Agency's reply leaves it unclear whether an action plan had in fact been developed by STPNOC, whether it had been implemented, or whether the results were satisfactory.

Evidence of Broader Safety Conscious Work Environment Problems at STP Handwritten notes, which appear to have been taken at the August, 2005 meeting, were released to SEIU under the same FOIA request (2006-0052). [See Appendices, pp. 26-29] The notes describe a number of concerns focusing on safety of the licensee's staff reductions and business concerns:

Trust of management Forced separations Outsourcing Resource [?]

Adding VPs but cutting staff Focus on profit with questionable regard for employees Not appear to affect safety, Not yet.

Safety still seen as priority, however question commitment to staff Reduction: although staff decreased, workload not adjusted to compensate Many comments regarding supervisor lack of commitment to employees.

Again strong [?] of more commitment to profit than to workers Question whether time will bring more commitment to money than to safety. Does not seem to be case currently but have how far will profit drive station?

These notes describe a potential problem in which the licensee's business concerns may trump safety.

Service Employees International Union 9

Given that STPNOC's action plans arising from previous CCAs apparently were not successful in respect of Wackenhut and other entities, such as I&C, it is important for the NRC to scrutinize the steps taken by STPNOC to rectify problems identified in the 2005, 2003, and 2001 cultural surveys. Some of these steps are mentioned in the "South Texas Safety Culture Survey" document from the August 2005 meeting:

• A SWOT analysis to assess the issues and actions required and follow-up on these actions to improve station alignment;

• An outsourcing lessons learned;

" An evaluation of IT, Supply Chain, Technical Training, and Wackenhut to assess the issues and recommended actions.

By obtaining this information from STPNOC, the NRC will be better informed about the licensee's progress towards improving the plant's SCWE. In addition, the NRC will be able to assess the effectiveness of steps taken in the past to redress problems with Wackenhut and I&C for whom problems persist despite STPNOC's apparently repeated remediation efforts.

SEIU further requests that the NRC:

• Provide SEIU with copies of all correspondence sent to STPNOC regarding this petition and the subject of the safety conscious work environment at STP;

• Provide SEIU with advance notice of all public meetings conducted by the agency with STPNOC regarding this petition and the subject of the safety conscious work environment at STP;

• Provide SEIU with an opportunity to participate in all relevant calls between NRC staff and STPNOC regarding this petition and the subject of the safety conscious work environment; and

• Provide SEIU with copies of all correspondence sent to Members of Congress, contractors, and/or industry organizations (e.g., the Nuclear Energy Institute) regarding this petition and the subject of the safety conscious work environment at STP.

Service Employees international Unimoln0 lo

APPENDICES Page 12: 1998 Confirmatory Order No. 98-87 Page 14-16: Letter from W.T. Cottle to Ellis W. Merschoff, April 17, 2002 Page 17-18: Letter from W.T. Cottle to Ellis W. Merschoff, April 7, 2003 Page 19: SEIU FOIA Request 2004-0308 Page 20: NRC Response to FOIA Request 2004-0308 Page 21: SEIU FOIA Request 2006-0052 Page 22-23: NRC Final Response to SEIU FOIA Request 2006-0052 Page 24: SEIU Appeal of FOIA Request 2006-0052 Page 25: NRC Response to SEIU Appeal of FOIA Request 2006-0052 Page 26-29: Handwritten Notes, August 2005 Service Employees International Union 11

United States Nuclear Regulatory Commission Office of Public Affairs Washington, DC 20555 Phone 301-415-8200 Fax 301-415-2234 Intemet:opa@nrc.gov No. 98-87 FOR IMMEDIATE RELEASE (Tuesday, June 9, 1998)

NRC STAFF ISSUES CONFIRMATORY ORDER TO SOUTH TEXAS PROJECT REQUIRING IMPROVEMENTS TO EMPLOYEE CONCERNS PROGRAM The staff of the Nuclear Regulatory Commission has issued a Confirmatory Order to the STP Nuclear Operating Company confirming its agreement to improve the handling of safety concerns brought to management by workers. The South Texas Project nuclear generating station is located near Bay City, Texas.

The order, signed by Ashok A.Thadani, NRC's Deputy Executive Director for Regulatory Effectiveness, confirms the licensee's agreement to:

1) Use an independent contractor to periodically survey its employees, supervisors, management and contractors about their concerns regarding a safety-conscious work environment through 2002 and report the results of each survey to the NRC.

2) Conduct annual ratings of supervisors and managers by employees.

3) Establish a mandatory training program for all supervisors and managers designed to reinforce the importance of maintaining a safety-conscious work environment and of assisting managers and supervisors in dealing with conflicts in the work place regarding these issues.

4) Notify all of its employees and project contractors in writing of the details of the NRC confirmatory order and inform them of their rights to raise safety concerns to the NRC and their management without fear of retaliation.

The order was issued following findings by the NRC Office of Investigations that the company had violated federal law by subjecting four employees to a hostile work environment created by a former manager after the employees raised safety concerns.

The manager involved left the company in mid-1996.

Enforcement action by the NRC is being waived because the licensee settled the employees' complaint prior to an evidentiary hearing before, and prior to a finding by the U.S. Department of Labor that the four employees had suffered discrimination.

Service Employees International Union 12

NRC also waived enforcement action because STP Nuclear Operating Company took what NRC regarded as particularly good corrective actions and designed a comprehensive program for promoting a safety-conscious work environment. NRC also believes the licensee's overall sustained performance in the area of employee protection has been good.

Scrvic Employces International Union 13

April 17, 2002 NOC-AE-02001277 IOCFR50 Mr. Ellis W. Merschoff Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 South Texas Project Units I and 2 Docket Nos. STN 50-498, 50-499 South Texas Project Comprehenrsive Cultural Assessment

References:

1. Letter, A. A. Thadani to W. T. Cottle, "Confirmatory Order Modifying License (Effective Immediately) and Exercise of Discretion," (EA 97-341). June 9, 1998

2. Letter, E. W. Mcrscholf to W. T. Cottle, "Request For Partial Relaxation Of Confirmatory Order," November 24, 1999 This letter provides the results of the recent Comprehensive Cultural Assessment and actions planned, and requests that the Regional Administrator authorize revision, in writing, the requirement for the conduct of the 2002 mini-survey (References I and 2).

STP Nuclear Operating Company (STPNOC) requests the option of conducting the 2002 mini-survey In the form of interviews and focus groups in lieu of a survey. By this letter,

• we are also informing you of the groups that we plan to surveylinterview..

On March 6,2002, we received the final report from SYNERGY Consulting Services for the Comprehensive Cultural Assessment for the South Texas Project (STP).

December2001. As required by the confirmatory order dated June 9. 1998 (Reference 1), the executive summary of the report is attached. The appendices to the report are considered proprietary to SYNERGY and are available at the station for your review.

Ninety-four percent of the STP workforce responded to the assessment survey.

Items considered notable with respect to the report include:

1. STP is maintaining a strong Nuclear Safety Culture and Safety Conscious Work Environment.

0%WI*N L'RC-At'tIISC-O2*rCOO1277.doc STn 31412954 Service Employees International Union 14

NOC-AE-02001277 Page 2 of 4

2. STPs' General CulturelWork Environment and Leadership, Managerial and Supervisory scores arc ranked among the highest in the nuclear industry.

3. STP's initiatives in addressing localized organizitional opportunities have resulted in notable improvements. Positive trends in all the targeted organizations from the 2000 assessment resulted in theirremoval or lowered absolute priority as compared to the industry.

4.. Individuals are willing to identify their organizational affiliation at a 98% rate, a positive indication of STP's work environment compared with the industry average of 86% - 87%.

5. Ninety-nine percent of the respondents indicated that if they had a Nuclear Safety concern, they would inform their supervisor or initiate a Condition Report.

Nevertheless, the survey did identify areas where additional improvement is needed. 1n reviewing the data, demographic variations have been noted between hourly/bargaining unit personnel, contractors, and plant staff. There were five organizations identified in the Executive Summary (Figure VIII.) as Priority I organizations due to their ratings relative to STP general performance and as such will have formal action plans prepared to address the survey results.

We are in the process of sharing and disseminating the results of the survey with our site organizations.

The confirmatory order (Reference 1) requires that the Regional Administrator'be informed of the groups to be surveyed during the 2002 mini-survey currently scheduled for early September 2002. By this letter we are informing you of our plans for meeting this commitment.

STPNOC proposes to conduct interviews or focus groups in lieu of a mini-survey for the organizations listed as Priority I in Figure VII.7 in Attachment 1. This approach is designed to provide results that would be the most beneficial to STP, given the expected status of the respective organizational action plans. In September, these organizations will be in the process of implementing their action plans for approximately three months. Any measurable affects as a result of these plans would be expected some six to twelve months later. Accordingly, in the earl, stages of implementation, we would find it more beneficial to acquire inputs that would assist us in determining whether the current courses of action are appropriate or need adjustment. The nature of interviews and focus groups reaWily allows for a second-level of questioning that is moresupportive of these objectives than a written survey with a fixed set of questions.

2 O0 1I2

• ,' NL* RC.Ar~ iC. 02*O STI: 31412954 Service Employees International Union1 15

NOC-AE-02001277 Page.3 of 4 STPNOC therefore requests that the Regional Administrator, authorize the revision of the requirement for the conduct of the 2002 mini-survey to allow the proposed approach. STPNOC believes this proposal meets the intent of the original License Condition. Following written approval from the Regional Administrator, SYNERGY Consulting Services Corporation will administer the proposed approach in early September 2002. SYNERGY will measure the effectiveness of the completed actions in the next Comprehensive Cultural Assessment scheduled for 2003.

Consistent with the committed schedule documented by the NRC in the confirmatory order (References I and 2), the following is the status of the open commitments:

• Annual ratihgs using the 'Leadership Assessment Tool" - will complete in 2002.

• Mandatory annual training of supervisors and managers in 10CFRS0.7 requirements -

will complete in 2002.

• Mini-surveys/interviews - will complete in 2002, as noted above.

• The final Comprehensive Cultural Assessment - will complete in 2003.

All of the requirements from the confirmatory order will be satisfied when the iesults of the 2003 Comprehensive Cultural Assessment are transmitted to the NRC Regional Administrator within 60 days of receipt of the survey results.

If you have any questions, please contact Mark McBumett at 361-972-7206 or me at 361-972-8434.

W. T. Cottle President &

Chief Executive Officer RDP Attachment I: South Texas Project 2001 Comprehensive Cultural Assessment, December 2001 (without appendices)

O.\WI1LNRC-API ISC-02'3O. 1277.do STi. 31412954 Service Employees International Union 16

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sowo~ o IMdim-t. Ton 77?4SI April 7,2003 NOC-AE-03 001501 Wr. Ellis W. Merschoff Regional Administrator, Region AV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 South Texas Project Units I and 2 Docket Nos. STN 50-498, 50-499 South Texas Project Comprehensive Cultural Assessment

Reference:

Letter, A. A. Thadani to W. T. Cottle, "Confirmatory Order Modifying License (Effective Immediately) and Exercise of Discretion,"

(EA 97-341), June 9, 1998 On March 31,2003, STP Nuclear Operating Company (STPNOC) received the final report from SYNERGY Consulting Services for the Comprehensive Cultural Assessment for the South Texas Project (STP), January 2003. The executive stnithary of the report is attached (Attachment 1) to meet the requirement of the Confirmatory Order to provide the summary results and conclusions of the assessments. The appendices to the report are considered proprietary to SYNERGY and are available at the station for your review.

Ninety-one percent of the STP workforce responded to the assessment survey, a participation rate among the highest encountered by SYNERGY. The following items are considered notable with respect to the report:

I. STP continues to maintain a strong Nuclear Safety Culture and Safety Conscious Work Environment.

2. STP's Leadership, Managerial and Supervisory scores are ranked among the highest in the nuclear industry.

3, STP's initiatives in addressing localized organizational opportunities have resulted in notable improvements in Operations and Electrical Maintenance.

4. Individuals are willing to identify their organfzational affiliation at a 98% rate, much higher than typically seen in the industry and a positive indication of ST?'s work environment-

5. Ninety-nine percent of the respondents indicated that if they had a Nuclear Safety concern, they would inform their supervisor or initiate a Condition Report.

Nevertheless, the survey did identify areas where additional improvement is needed. In reviewing the data, demoraphic variations have been noted between hourly/bargaining unit personnel and the plant staff. There were three organizations (Mechanical Maintenance, O;WN.tpJLAIRC.APMISC-O3\33001501 .d zo STI: 315E2-01 Service Employees International Union 17

NOC-AE-03001501 Page 2 of 3 Wackenhut Security, and I&C Maintenance) identified in the Executive Summary (Figure VIII.6) as Priority organizations due to their ratings as compared to the industry and as such will have formal actio n*plans prepared to address the survey results. The action plans will be prepared after the current Unit I refueling outage and will be submitted to Senior Management for approval.

These three organizations were categorized as Priority 1 in the last survey in 2001 due to their ratings relative to STP general performance and as such were the focus of the 2002 mini-survey. STPNOC has had success in resolving the issues in other organizations onsite, and we will use the lessons learned from these experiences as we prepare the action plans for these organizations.

STPNOC is in the process of sharing and disseminating the results of the survey with the site organizations.

Witlh the completion of the 2003 survey and the documentation presented in Attachment 2, it is our position that STPNOC has met all of the requirements of the Confirmatory Order. STPNOC, however, believes that active management actions to assure a healthy and positive work environment, which encourages the identification and resolution bf work place issues, are an integral part of our business and a key to our future success.

Therefore, actions to periodically assess,manage, and improve the STP work envir6nment and culture will continue.

STPNOC requests a management meeting with the NRC to discuss the results of the 2003 survey more completely and to describe the actions we intend to take to miake further improvements in the culture at STP.

If there are any questions regarding the survey or to schedule the management meeting, please contact Mr. Mark McBurnett at (361) 972-7206 or Mr. Joe Sheppard at (361) 972-8757.

W. T. Cottle President &

Chief Executive Officer R1DP Attachments: 1. Executive Summary from the South Texas Project 2003 Comprehensive Cultural Assessment, January 2003

2. Actions Taken to Satisfy License Conditions of ConfLrmatory Order Service Employees International Union I8

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Email:

Phone:

Texas Desc: Through FOIA I obtained a Comprehensive Cultural Assessment conducted at the South Report Project In 2003. This Is now posted In ADAMS: Letter from W. T. Cottle to Ellis Merschoff re: Final from Synergy Consulting Services for Comprehensive Cultural Assessment for South Texas Project January 2003. ML041380347 In the assessment the Wackenhut Corporation was Identified as a 'priority organization' and the South Texas Project Nuclear Operating Company President stated that Wackenhut and two other organizations

'will have formal action plans prepared to address the survey results.* Later In the attached suggested Comprehensive Cultural Assessment (p. 74), It is noted that 'Evaluation and remedial action Is in the immediate future.*

'formal Please provide any documents (letters, notes, email, reports, memoranda) Indicating that such action plans, have been prepared in respect of Wackenhut's performance as assessed In the 2003 action Comprehensive Cultural Assessment at STPNOC, or indicating that the evaluation or remedial referred to has In fact been taken.

FeeCategory. PrivateCorporation MediaType:

I Service Employees International Unionz 19

NRC FORM 464 Part I U.S. NUCLEAR REGULATORY COmmIssiOn FOIN/PA RESPONSE NUMBER OF 204-0308 RESPONSE TO FREEDOM INFORMATION ACT (FOIA) I PRIVACY RESPONSE ACT (PA) REQUEST TYPE RECUESTER DATE JUL 3 0 2004 PART I. - INFORMATION RELEASED

] No additional agency records subject to the request have been located.

] Requested roeords are available through another public distnbutton program. Seo Comments section.

] iloiCEs IAgency records subject to the request that are Idontified In the listed appendices are already available for public Inspection and copying at the NRC Public Document Room.

[] , S IAgency records subject to the request that are Identified In the listed appendices are being made available for

" public Inspection and copying at the NRC Public Document Room.

D Enclosed Is Information on how you may obtain access to anid the charges lor copying records located at the NRC Public Document Room, 2120 L Street, NW, Washington, DC.

El II Agency records subject to the request are enclosed.

[3 Records subject to the request thal contain information originated by or of Interest to another Federal agency have been referred to that agency (sea comments section) for a disclosure determination and direct response to you.

] We are continuing to process your request.

[ See Comments.

PART I.A - FEES lI14CXP~r" j j Youwll bebllledby NROfortheemountlistld. None. 1,nimum fee thlrsholdnot met.

[$ ,. , [. You will receive a refund for the amount listed. [] Fees waived.

• See orP~evne, PART 1.B - INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE No agency records subject to the request have been located.

[ Certain informatIon In the requested records is being withheld fromdisclosure pursuant to the exemptions described in and for the reasons staled in Part II.

may be appealed state30 ondays to the by wrttingand FOINIPA Officer, it Is aU.S. Regulatory Commission, NuclearAppeal."

This determination Washington, DC 20555-0001. Clearlywithin the envelopo In the letter that 'FOIAJPA PART I.C COMMENTS (Use attached Comments continuation paqe If reultred)

SCNA1UP.E.FR544f*A.PINTE R EAow , i Carol Ann Reed C.6Ae, .- ,~~

UnC i'1.1cAre &~tu l (6-1999) PRINTED ONREC'rCLED PAPER using InFomis This "cnwasaosignmez Service Employees International Union 20

t I

A-'WWW Form Sbiso ae From:

To:

uid no body <nobody@www.nrc.gov>

<fola@nrc.gov> D RK FowlU-Que8 Wit I

Date: Tue, Dec 13, 2005 1:44 PM 6 1dlS .

Subject; WWW Form Submission FIed Ct.: .*

Below Is the result of your feedbacd form. It vis submitted by on Tuesday, December 13, 2005 at 13:44:03 FirstName: Glenn LestName: Adler Company/Affliation: Service Employees Intemational Union Addressl: 1313 L St. NW Address2:.

City. Washington State: DC Zip; 20005 Country:. UnitedStates Country-Other Email; adlerg@seiu.org Phone: 202-730-742.6 Desc: I request thata copy of the following documents be provided to me: *Compreh.n'lw Cultural

~ssessments* or any other evaluation conducted by the 5 1 NU U.-ndeoendent 2 aontrctors toassess the-saely conscious work environment at STPNOC since January 1.2004, or by the NRC s well as any correspondence, reports, presentations, or memoranda between me i'IR, STPNOC, and any other entity concerning such assessments.

In order to help you determine my status for the purpose of assessing fees, you should know that I am an employee of a labor union. I am willing to pay fees for this request up to a maximum of $50. If you estimate that the fees will exceed this limit, please Inform me first.

FeeCategory. Prlvate.Corporation MediaType:

FeeCalegory

Description:

ExpedlteJmminentThreatText.:

Expedite.UrgencyTofnform TexL" Service Employees International Union

'71

SOUTH TEXAS SAFETY CULTURE SURVEY"

Background

The STP safety culture survey Came about because of a Confirmatory Order, dated June 9, 2005. The were problems with security, I&C, Design Engineers, and Ebasco-Rathyon. NO SPECIFICDETAILS Objective The objective was to accurately measure workforce perception and Improvement priorities for tho following areas of the STP culture:

• Strategy and goals

• Work environment

• Nuclear safety and safety conscious work environment

• ° Efinployee concerns program effectiveness

• Leadership effectiveneis

• Program and process effectiveness, and

• Organizational Interface effectiveness.

Purpose This survey would provide the Senior Management Teamn with concisie recommended leadership actions with the greatest likelihood of sustaining progress to date and moving organizational performance to higher levels.

Methodology The methodology was to customized a study for STP's specific information needs. Seniors managers/managers were interviewed to identify and understand key Issues and desired scope of the study. Past survey data and past interviews were conducted by a Contractor (Management Insight).

Questionnaires were created covering various areasforganizations: General population, Engineering and Technical Support, Operations, Outage and Work Control, and Security (Wackenhut). The'questionnaires were design to focus toward soliciting detailed perceptions and desired improvement priorities from the STP community.

Implementation and Response

• Show Chart/data

+1..

Service Employees International Union 22

Insights STP continues to maintain an effective Safety Conscious Work Environment and effective Nuclear Safety Culture Although the station strategy of Operational Excellence and Financial Excellence is not strongly Ingrained In the day to day culture of the organization, the majority of workers agree that the strategy is needed and inost appear willing to suppbrt It.

• Trust and people-related Issues are the top work environment improvement priorities

• Work commitment to STP, job satisfaction; and overall perception of the work environment remain an organizational asset

" The recent work force management activities (e.g:, reductions and outsourcing reviews) havehad a negative cultural impact, Including an Impact on perceptions of Senior Management Team credibility

" The workforce is eager for substantial process improvements, especially In the areas of work planning and execution, and desire an active role In the planning and Implementation of the Improvements.

One hem that the Senior Management Team noted from the survey was that 1 line

• supervisors were.more aligned with the workforce than with management. 16t lihe Ssupervisors were not part of th6 decision making process but had to Implement the decisions.

Notes 0 Involuntary layouts have ceased.

0 Management is working on a voluntary package that Is not complete yet.

0 2005 DRAFT Cult'ure Assessment Action Plan Service Employees International Union 23

March 14.2006 50 EMEU, RE: FOIA/PA APPEAL Stronger Together Mr. Russell A. Nichols FOIA/Privacy Act Officer Office of Information Services United States Nuclear Regulatory Commission Fax no: (301) 415-5130 ANDREW L STERN

Dear Mr. Nichols:

W~weeaf% PMUE*r".

ANNA BURGER On December 13,2005 I made a request for various documents related to Comprehensive Cultural Assessments conducted at the South Texas Nuclear Operating Company in Texas (FOIA/PA 2006-0052, see Attached). Today, I MARY KAY -ENW7Y Exctre Vke Premdent received a final response from the NRC, which included the last of four short documents released under die request, related to the implementation of the GERRY HUDSON Assessment, and/or slides of mneetings at which the Assessment was presented.

EUSEO MEDINAf Unfortunately the release did not include copies of the 2005 Assessment itself,

• AKUo.,e Vice Preide-t which I specifically requested in my December 13, 2005 FOIA submission. This

' TOM WOODRUPF 2005 Assessment clearly must exist, since it is the subject of and is clearly EcciI"m Vice Pmridcrt referenced in the presentations described in documents that were released to me, Indeed, the response I received today does not indicate that such a document does nor exist. Nor does the response I received today explain why this document has been withheld.

I hereby appeal the NRC's response to my FOIA submission and request thlat the NRC release a copy of the 2005 Comprehensive Cultural Assessment I requested on December 13, 2005.

Yours truly,.

SERVICE EMPLOYEES INTERNAQO*AL UN..N

,AFL-CIO. CIC Glenn Adler Senior Research Analyst 313 LSireeL N.W.

V"-,ngta-. D.C. 20005 Ph: (202) 730-7426 202.698.3200 Fax: (202) 350-6613 TM. 202.898.3481 Email: adlcreQ@seiu.orm V,*,vSEaU.otg I

Service Employees International Union 24

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINOTON. D.C. 20555-t001 WAR17 200 Mr. Glenn Adler IN RESPONSE REFER Senior Research Analyst TO FOIA/PA-20060052 Service Employees International Union 1313 L. Street, NW Washington, DC 20005

Dear Mr. Adler:

On January 24 and March 9, 2006, I provided records responsive to your Freedom of Information Act (FOIA) request number FOINPA-2006-0052. Your request asked for documents related to any cultural assessment of the safety conscious work environment at the South Texas Project Nuclear Operating Company (STPNOC) since January 1, 2004.

This letter clarifies the fact that the Nuclear Regulatory Commission (NRC) Is not In possession of any cultural assessments responsive to your request.

Sincerely, Russell A. Nichols FOIAPrivacy Act Officer Office of Information Services Service Employees International Union 25

01.06,2066 10 :47 Aiw Uniled 3Sttes Nucl~earRaitt.atery Ca,~lss 381072553 $17

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Service Employees International Union 29

NOTES

'"NRC Staff Issues Confirmatory Order to South Texas Project Requiring Improvements to Employee Concerns Program," United States Nuclear Regulatory Commission, Office of Public Affairs, Washington, DC, No. 98-87 (Tuesday, June 9, 1998).

2 "NRC Staff Issues Confirmatory Order to South Texas Project Requiring Improvements to Employee Concerns Program," United States Nuclear Regulatory Commission, Office of Public Affairs, Washington, DC, No. 98-87 (Tuesday, June 9, 1998).

3 "NRC Staff Issues Confirmatory Order to South Texas Project Requiring Improvements to Employee Concerns Program," United States Nuclear Regulatory Commission, Office of Public Affairs, Washington, DC, No. 98-87 (Tuesday, June 9, 1998).

4 "Wackenhut Corporation Awarded Contract for Security Services at Nuclear Power Plant in Texas," The Wackenhut Corporation, Palm Beach Gardens, FL, Press release, July 9, 2001.

5 Letter from W.T. Cottle, President and Chief Executive Officer, South Texas Project Nuclear Operating Company, to Mr. Ellis W. Merschoff, Regional Administrator, Region IV, U.S. Nuclear Regulatory Commission, April 17, 2002, Attachment I, South Texas Project, 2001 Comprehensive Cultural Assessment.

6 "South Texas Project 2001 Comprehensive Cultural Assessment, December 2001," Synergy Consulting Services Corporation, pp. 9-10; p. 59.

7 "South Texas Project 2001 Comprehensive Cultural Assessment, December 2001," Synergy Consulting Services Corporation, p. 57, pp. 9-10.

8 "South Texas Project 2001 Comprehensive Cultural Assessment, December 2001," Synergy Consulting Services Corporation, p. 57, pp. 9-10, 57, 59.

9Letter from W.T. Cottle, President and Chief Executive Officer, South Texas Project Nuclear Operating Company, to Mr. Ellis W. Merschoff, Regional Administrator, Region IV, U.S. Nuclear Regulatory Commission, April 17, 2002, Attachment 1, South Texas Project, 2001 Comprehensive Cultural Assessment, p. 2.

10"South Texas Project 2001 Comprehensive Cultural Assessment, December 2001," Synergy Consulting Services Corporation, p. 63; "South Texas Project 2003 Comprehensive Cultural Assessment, January 2003," Synergy Consulting Services Corporation, p. 66.

""South Texas Project 2003 Comprehensive Cultural Assessment, January 2003," Synergy Consulting Services Corporation, p. 53.

12 "South Texas Project 2003 Comprehensive Cultural Assessment, January 2003," Synergy Consulting Services Corporation, p. 58.

13 "South Texas Project 2003 Comprehensive Cultural Assessment, January 2003," Synergy Consulting Services Corporation, p. 74.

14Letter from W.T. Cottle, President and Chief Executive Officer, STP Nuclear Operating Company to Ellis W. Merschoff, Regional Administrator, Region IV, United States Nuclear Regulatory Commission, "South Texas Project Units I and 2 Docket Nos. STN 50-498, 50-499 South Texas Project Comprehensive Cultural Assessment," April 7, 2003.

15 Letter from Thomas P. Gwynn, Acting Regional Administrator, Region IV, U.S. Nuclear Regulatory Commission to James J. Sheppard, President and Chief Executive Officer, STP Nuclear Operating Company,

Subject:

South Texas Project Electric Generating Station - NRC Inspection Report 50-498/03-09 and 50-499/03-09, July 11, 2003.

16 United States Nuclear Regulatory Commission, Response to Freedom of Information Act Request, FOIA/Privacy Act (PA), 2004-0308, July 30, 2004.

"7 United States Nuclear Regulatory Commission, Freedom of Information Act Request, FOIA/PA-2006-0052, December 13, 2005.

Service Employees International Union 30