ML061790693

South Texas Project - Petition Pursuant to 10 CFR 2.206

ML061790693
Person / Time
Site:	South Texas
Issue date:	06/26/2006
From:	Adler G Service Employees International Union
To:	Reyes L A NRC/EDO
References
2.206
Download: ML061790693 (31)

Text

SEIL1 Stronger Together ANDREW L STERN nternaona Presdent ANNA BURGER International Secretary-Treasuwer MARY KAY HENRY Executive Moe President GERRY HUDSON Executive Vice President EUSEO MEDINA Executie Vice PResident TOM WOODRUFF Exeactive Vice President SERVICE EMPLOYEES INTERNATIONAL UNION CLC 1313 L Street. N.W Washington, D.C. 20005 202.898.3200 TDD: 202.898.3481 www.SEIU.org June 26, 2006 Mr. Luis A. Reyes Executive Director for Operations 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

Dear Mr. Reyes:

Attached please find a memorandum providing additional information to 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 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).This information will be presented at the Petition Review Board, June 27, 2006 at the U.S. Nuclear Regulatory Commission in Rockville, Maryland.Yours truly, Glenn Adler Senior Research Analyst Ph: Fax: Email: (202) 730-7426 (202) 350-6613 adlerg@seiu.org 11104-1000 i I 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.'

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 Employees International Union 1 t 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 301-416-8200 Fax 301-415-2234 lnternet: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 Nudear 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 2 Synergy conducted confidential interviews to assess each department's and contractors 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 comFared to the composite rating for STP as a whole on the dimensions surveyed:* 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 International Union 3

.FIgure VWI2 NSC (CCI <365) GCWE (CCI <3.40) LMS (CCI Wackenhut Wackemhut Wackenhut 3.58 3.24 (22%) 3.09 (26%)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 M3%) 2-96(3o%)Unit I Opertions 3-38 p6%)Unit I Opemations 3.20 tl Unit 2 Operations Unit 2 Operations 3MY(17%) 328 (15%)ElectricxW Maintenance Electrical Mainterauce 3.37 (16%) 3.38 (15%)HealthPhysics Halth Physics 3.37(16%)

3.39(14%)Plant Design 3.39 (3%)According to the consultant, Wackenhut's scores required "further evaluation" and "remedial action in the near-term." 7 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 f Figure ViII.6 Recommendations for SIP To ed Organizations- "Industry NormnisC" Qj Organization Level NSC SCW. GCWE LM.Mechanical 2 Declined Declined 3D.0%n =.Maintmance 6.1% 9.1% Declined_________________

________ _______12.3%

..... ...... ie s .0 9 c C I Wsckenmn 3 .6% Meg-Unit I Operations 4 63%Risk& Declined.Reliablit Analysis __ _ _ __ _ _ _ _ _ __ _ _ __ 51 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 additionsl 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 V11L7) 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).11 Service Employees International Union 5 Moreover, its performance against the industry worsened from "Priority Level 3" to "Priority Level 2." According to the survey, Wackenhut's performance on these metrics was in fact declining at the time.'2 The consultant recommended that "Evaluation and remedial action is suggested in the near term." 1 3 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 , 1-.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 cmuent 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.1 5 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.1 6 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 LB -WNORMATION NOT LOCATED OR WITMELD FROM DWSLOSURE No rnods ubject to the reqet haow beow IA4I[] Certain InionaUon in the requested records is being withheld from dIsclosure pursuant to th0 e0ptione desribed in aMW for th e maons stated In Part 11. 1 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.

1 7 [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 o4 a Confirmatory Order, dated June 9, 2m05. The were problems with security, I&C, Design Engineers, and Ebasco-Rathyon.

NO SPEýCIFIC DETAILS 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 FOIANPA-2006-0052.

Your request asked for, documents related to any cultural assessment of the safety conscious work environment at t 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 FOLAPfivacy 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

-I 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 Union 10 APPENDICES Page 12: Page 14-16: Page 17-18: Page 19: Page 20: Page 21: Page 22-23: Page 24: Page 25: Page 26-29: 1998 Confirmatory Order No. 98-87 Letter from W.T. Cottle to Ellis W. Merschoff, April 17,2002 Letter from W.T. Cottle to Ellis W. Merschoff, April 7, 2003 SEWU FOIA Request 2004-0308 NRC Response to FOIA Request 2004-0308 SEIU FOIA Request 2006-0052 NRC Final Response to SEIU FOIA Request 2006-0052 SEIU Appeal of FOIA Request 2006-0052 NRC Response to SEIU Appeal of FOIA Request 2006-0052 Handwritten Notes, August 2005 Service Employees International Union 11 United States Nuclear Regulatory Commission Office of Public Affairs Washington, DC 20555 Phone 301-4154200 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, NRCs 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 overafl sustained performance in the area of employee protection has been good.Service Employees International Union 13 ulv .ýr- "msan April 17,2002 NOC-AE-2001277 10CFR50 Mr. Elis W. M=rschoff Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 ArlingtonTexas 76011-8064 South Texas Project Units I and 2 Docket Has.STN 50-498, 50499 South Texas Proiect Conmrehensive Cultural Assment Refaefes:

1. Letter, A. A- Thadani to W. T. Cottle,"Confirmatory Order Modifying Lcense (Effective Immediately) and Exercise of Discretion," (EA 97-341). June9, 1998 2. Letter, FL W. Merschoff to W. T. Cottle, "Request For Partial Relaxation Of Confirmatory Order," November 24,1999 This provides die 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 Mte groups that we plan to survey/nterview.

On March 6,2002, we received the final report from SYNERGY Consulting Services for the Comprehensive Culturml Assessment for the South Texas Project (STP).December 2001. 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 propietary to SYNERGY and are available at the station for your review.Ninety-four percent of the STP workforce responded to the assessment survey.Items conidred notable with respect to the report include: -1. STP is maintaining a strong Nuclear Safety Culture and Safety Conscious N ork Environment.

OAWN'i~nC.ItS42~iOOI21jocS~t3.29 0 Service Employees International Union 14 NOC-AE-02001277 Page 2 of 4 2. SMT' General Culture/Worik Environment and Leadership, Managerial and Supervisory scores am ranked among the highest in the nuclear industry.3. STPis initiatives in addressing localized organizational opportunities have resulted in notable improvements.

Positive trends in all the targeted organizations from the 2000 assessment resulted in their removal 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 hiform their supervisor or initiate a Condition Report 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 VrfL7) 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 Administrato 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 VIII.7 in Attachment

1. This approich is designed to provide reults that would be the most beneficial to STP, given the expected status of the respective organizational action plans. In September, thcse 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 early 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 readily allows for a second-level of questioning that is more supportive of these objectives than a written survey with a fixed set of questions.

On:?PWRC-AP0MSC.CnO}OO12",7oc Sri: 31412954 Service Employees International Union 15 NOC-AE-02001277 Page.3 of 4 STPNOC therefor requests that the Regional Administrator, authorie 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 Conulting Services Corporation will administer the proposed approach in early September 2002. SYNERGY will measure ihe 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), ft following is the status of the open cominitments:

a Annual ratings using the 'Leadership Assess ment Tool"- will complete In 2002.4 Mandatory annual training of supervisors and managers In LO R50.7 requirements

-will complete in 2002.* Mini-surveys/intervlews

-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 results 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 questionsý please contact Mark McBurnett at 361-972-7206 or me at 361-972-4434.

W. T. Cottle President

&Chief Executive Officer RDP Attachment 1: South Texas Project 2001 Comprehensive Cultural Assessment, December 2001 (without appendices)

O- Ut1 314129S4 Service Employees International Union 16 I .r 1 .An awl NW,,d , .rU April 7,2003 NOC-AE-03001501 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. SIN 50-498, 50-499 South Texas Proiect Comnrehensive Cultural Assessment

Reference:

Letter, A- A. Thadani to W. T. Cotle, "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 summiary 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 statio-r 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: 1. STP continues to maintain a strong Nuclear Safety Culture and Safety Conscious Work Environment.

2. STP's Leadership, Managerial and Supervisory scorts are ranked among the highest in the nuclear industry.3. STWs initiatives in addressing localized organizational opportunities have resulted in notable improvements in Operations and Electrical Maintenance.

4. Individuals are willing to identify their organizational affliation at a 98% rate, muck higher than typically seen in the industry and a positive indication of STP's work'environment.

5. Nimety-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, demographic variations have been noted between hourly/bargaining unit personnel and the plant staff. There were three organizations (Mechanical Maintenance, 13 STt 31582401 Service Employees International Union 17 4 V *NOC-AE-03001501 Page 2 of 3 Wackenhut Security, and I&C Maintenance) identified in the Executive Summay (Figure VHI.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.These three organizations were categorized as Priority I 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.

With 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. SIPNOC, however, believes that active management actions to assure a healthy and positive work environment, which encourages the identification and resolution of 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 environment 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 make 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 RDP Attachments:

1. Executive Summary from the South Texas Project 2003 Comprehensive Cultural Assessment, January 2003 2. Actions Taken to Satisfy License Conditions of Confirmatory Order Service Employees International Union 18 S" " t *t.~~~O P vF19111..

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From: uld no body abody@nrc.gov>

D I d To: 4ola@nrm.gov> "O..C!.E Date: Wed, Ju 21, 2004 4:34 PM Subject WWW Form Submission Below is ft result of your feedback form, It was submitted by 0 on Wednesday, july 21. 2004 at 16:33&18 FiatName: Lasthanie:

Oompeny/Affliation:

Address1:

1313 L Street, N.W.Address2: City WashVton State: DC Zip: 20W14 Country. LUltedStates CoutMry-Olher:

Email: Phone: Desw. Through FOIA I obtained a Comprehensive Cultural Assessment conducted at the South Texas Project in 2003. This Is now posted in ADAMS: Letter from W. T. Cottle to Ellis Merschoff re: Final Report 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 Vprority organization' and the South Texas Project Nuclear Operating Company President stated that Wackenhut and two other organizations

• ril have formal action plans prepared to address the survey results.'

Later in the attached Comprehensive Cultural Assessment (p. 74). It Is noted that 'Evaluation and remedal action Is suggested In the Immedate fiture.*Please provide any documents (letters.

notes, email. reports, memoranda)

Widcating that such "lormal action plans" have been prepared In respect of Wackenhurs performance as assessed In the 2003 Comprehmnive Cultural Assessment at STPNOC, or indicating that the evaluation or remedial action referred to has In fact been taken.FeeCategory.

PrivaleCorporetion MediaType:

Service Employees International Union 19 NRC "ORM 44 Purt I u.s. UCLE.AR IGLATORy COMuMS FOIAfPA IN WPOiN UMBE 2004430 RESPONSE TO FREEDOM OF INFORMATION ACT (FOIA) I PRIVACY TPsE ACT (PA) REQUEST TP! E FINAL 3 PARTAL

"' ' 'OA'T!JUL 3 0 W34 PART L -INFORMATION RELEASED[E No additiona agency records m8e4t 0o the request have been located.El Requested records am availlable tfough another public program. Se0 Comments secuon.Aency Elor)s su to #h mqueg *W amentified In Me Wed appendice am ahady available fr public Inspection and 00Pylng a t NeI RC PNibc Document Room-Agency ~ ~ ~ ~ ~~ta arod ubett te o e idntaIod in the listed appendices are being matde available lor EpublrIsectio and copying =t NRC Public Doc n t Roome El s Is information on how you may obtain access to and the charges for copying records located at the NRC Pubic Document Room, 2120 L Street, NW. Wash'ngton, DO.E-l Z ] Agenoy records subject to the request are enclosed.[3 Records sub=ecl0 the request owat contain Information orignated by or o Interest to anoth Federal agency be been ency (see section) for a dacsur deternai and direct response 10 you.[ w We ar continuing to process yom request[] See Comments.PART LA"- FEES II. You wil be blled by NAC forthe amount isted. gi None. "ninmum tee thrfshold not met.You wAl, rceive arefund for heamount le0d. [] Fees waived.PART I1 -INFORMATION NOT LOCATED OR WiTIIHELD FROM DISCLOSURE No agencmy ecords sbject to the request ham beew located.[ C Certain inormaion in the requested records i being withtiold from disclosure pursuant 1t th OImnplions deacribed in and Ice ftm reaos stated in Part II.Thi o.determnatin be appealed within 30 days by writing to the FOIA/PA Officer, U.S. Nucear Regulatory Comnesion, Wassingon, DC 2055-0. Clearly state on the envelope and in the letr Vhat It IW a "FOIAJPA A4pelat.PART LC COMMENTS (Use attached Comments conturmatkon We If MreIOred'Carol Ann Reed WC FCM 484 Ponl 1 (6.19M) PAIKt!O CH REcYOLE PAPER irb WFA V" ige f awwto' iFemis Service Employees International Union 20 t ¶ r 1

Subject:

WWW Form Submission Bebow is the result of your feedback forn, It was subimltta by o on Tuesday, Oecemnber 13, 2005 at 13:440t3 FRstt~are:

Glenn LastNam: ,Pde r CoFpany/NfTwtlon:

Sev Employees Intenationl Union A~ddissI:

1313 L St. NW Address2: 40M WashIogton State: DCdo1 Count)' Unite&_StatUs counbs-othe Emmal: Adlergseku.org Phone: 202.730-7402I reques m s cop or the fodbwbiv docxuments be provied tome Com P h .a s alsvmea-WOU n Ieat N Janua 1¶ 2004, as we" as any concerning such S~sessnrenr fts o mekg es o hol nwthtIln In order to help you deterffine my status for ihe purpose of assessing tees, you should know that I am an employee of a ab unim. I amwilIUng to pay fees for ths request up tos maxlmum of S50. It you esumate t the tees will exceed Ofu omit, plase Worm me fist.tO MedaTe: FeeCetegory.DesVPlo r Exped1temmlnlenfTbrea!Text Service Employees International Union 21 SOUTH TEXAS SAFETY CULTURE SURVEY Background The STP safety culture survey came about because of a Confirmatory Order, dated June 9, 200& The were problems with security, I&C, Design Engineers, and EbasCo-Rathyon.

NO SPECIFIC DETAILS Objective The objectIve was to accurately measure woridorce perception end Improvement priorities for the following areas of the culture:* bStrategy and goals* Work ernvronment

• Nuclear safety and safety consious work envinent* Employee concerns program effectiveness S .Leadershp effectiveness

• Program and process effectiveness, and* Organbzatlonal interface effectiveness.

Purpose This survey would provide the Senior Management Team with concise recomended leadership actions with the greatest likelihood of sustaining progress to date and moin organizational performance to higher levels.Methodology The methodology was to customized a study for STPe specific infoamayton needs. Seniors nmanagern.managers were terviewed to identify and understand key Issues and desired scope of the study. Past survey data and pest Interviews were conducted by a Contractor (Management Insight).Ouestlonnalres were created oove,,ng various areastorganizatIons:

General population, Engineering and Technical Support, Operations, Outage end Work Control, end Security (Wac*enhut).

The questionnaires were design to focus toward soliciting detailed-perceptions and desired Improvement priorities from the STP community.

Implementation and Response* Show Chart/data 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 tie organization, the majority of workers agree that the strategy is needed and most appear willing to support It.* Trust and people-related Issues are the top work environment improvement priorities

• Work commitment to SWP, 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)have had a negative cultural Impact, Including an Impact on perceptions of Senior Management Team credibllty The workforce is eager for substantial process Improvernets, espeHally In te areas of work planning and execution, end desire an active role in the planning and hnplemnentatmon of the Improverents.

One item that the Senior Management Team noted from the survey was that 1 Ine supervisors were more aligned with thi workforce than with management.

1" HIe supervisors were not part of th6 decision making process but had to Implement the decisions.

Notes* In~volunv layouts have ceased. -* Management Is working on a voluntary package that Is not complete yet* 2005 DRAFT Cultur Assessment Action Plan Service Employees International Union 23

' .* r S~EIU.Stronger Together ANDREW L STERN-uaoa Pmkr ANNA 9LIRGER MARY KRV HENRY teane Vie roe*Wt GESRY 1-UOSCIN EXO We ftý'TOM WOOORLO 6=%We V 610Cfs SERVIC~E IEWL0YE A11ORNWWL IJNKON AFL-CI. C1C 1313 L SaMe N.W.Vtaslntxcn 04C. 20005 202M9.3200 TDD0 202.98%-3481 W.%vSEKJ"9r March 14,2006 RE: FOIA/PA APPEAL Mr. Russell A- Nichols FOLA/Privacy Act Officer Office of Information Services United States Nuclear Regulatory Commission Fax no: (301) 415-5130

Dear Mr. Nichols:

On December 13,20051 made a request for various documents relatedato Comprehensive Cultural Assessments conducted at the South Texas NMI=e Operating Company in Texas (FOIA)PA 2006.)052, see Attached).

Today. I received a final response fom the NRC, which included the last of four shert documents released under the request, related to the implementation of the Assessment.

and/or slides of meetings at which the Assessment was prmsented.

Unfortunately the release did not include copies of the 2005 Assessment itselL which I specifically requested in my December 13,2005 FOIA submission.

This 2005 Assessment clearly must exist, since it is the subject of and s clearly 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 not exist. Nor does the response I received today explain why this document has been withheld.I hereby appeal the NRC's response to my IOIA submission and request that the NRC release a copy of the 2005 Comprehensive Cultural Assessment I requested on December 13, 2005.Yours

, Glenn Adler Senior Research Analyst Ph: (202) 730-7426 Fax: (202) 350-6613 Email: adlerg@seiu.orm Service Employees International Union 24

,- ¶ r UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINOTON.

D.C. 25,M-Co0 lIAR W 1 Mr. Glenn Adler Senior Research Analyst Service Employees International Union 1313 L Street, NW Washington, DC 20005 IN RESPONSE REFER TO FOIA/PA-2006-0052

Dear Mr. Adler On January 24 and March 9,

2006, 1 provided records responsive to your Freedom of Information Act (FOIA) request number FOINIPA-2006-0052.

Your request asked for documents related to any cultural assessment of the safety conscious work environment gt dth 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, r6aA AýIg Russell A. Nichols FOIA/Privacy Act Officer Office of Information Services Service Employees International Union 25

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• U E S l I' i .l l/412~i; -:.. .. .. ..-: ..* .. ... .. .... ..: ,: ...: -..: .. ., ..: ... , i Service Employees International Union 2!9 NOTES 1 "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 1, South Texas Project, 2001 Comprehensive Cultural Assessment.

"'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, 59.9 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 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. 66.11 "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. 74.14 Letter 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."5 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, FOLA/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