ML20197A597

Forwards Summary of 980127 Presentation Made by Little Harbor Consultants to NRC and Nene Mgt.Slides Used in Presentation,Encl

ML20197A597
Person / Time
Site:	Millstone
Issue date:	03/04/1998
From:	Beck J AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ITPOP-98-0010, ITPOP-98-10, NUDOCS 9803090303
Download: ML20197A597 (77)

Text

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Little liarbor Consultants, Inc.

Millstone - ITPOP Project Office P.O. Box 0630 Niantic, Connecticut 06357-0630 Telephonc 860-447-1791, est 5966 Faz 860-444 5758 March 4,1998 Docket Nos. 50-245 50-336 50-423 ITPOP 98-0010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 Enclosed is a summary of the presentation made by Little Harbor Consultants to the NRC and NNECo management in a public meeting on January 27,1998. We have included a copy of the slides used in the presentation.

Sincerely,

.L /

ohn W. Beck /

President, Little Harbor Consultants, Inc.

leam Leader, ITPOP Attachments cc: Distribution /f2@[

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U.S. Nuclear Regulatory Commission Page 2, ITPOP 98-0010 1 Distribution:

J. Strecter, NNECo Charles Brinkman, Manager Washington Nuclear Operations P. leftus, NNECo AI3B Combustion Engineering Nuclect Power ,

W. J. Temple, NNECo 12300 Twinbrook Pkwy, Suite 330 l

Rockville, MD 20852 S. Baranski, NNEC Mr. John Buckingham C. Grise, NNECo Department of Public Utility Control Electric Unit M. Quinn, ECOP 10 Franklin Square New Britain, CT 06051 U.S. Nuclear Regulatory Commission Attn: W.D. Travers Citizens Regulatory Commission Mail Stop: 014D4 ATIN: Ms. Susan Perry Luxton Washington, DC 20555 0001 180 Great Neck Road Waterford, CT 06385 U.S Nuclear Regulatory Commission Attn: P.F. McKec Citizens Awareness Network Mail Stop: 014D4 54 Old Turnpike Road Washington, DC 20555 0001 Iladdam, CT 06438 U.S. Nuclear Regulatory Commission The lionorable Terry Concannon Attn: it.N. Pastis Nuclear Energy Advisory Council Mail Stop: 014D4 Legislative Office Building Washington, DC 20555-0001 liartford, CT 06106 Mr. Waync D. Lanning Mr. Evan W. Woollacott US NRC Region I Co-Chair 475 Allendale Road Nuclear Energy Advisory Council King of Prussia, PA 19406-1415 128 Terry's Plain Road Simsbury, CT 06070 Kevin T. A. McCarthy, Director Monitoring and Radiation Division Ernest C. Had!cy, Esquire Department of Environmental Protection 1040 B Main Street 79 Elm Street P.O. Box 549 ilartford, CT 06106-5127 West Wareham, MA 02576 Allan Johanson, Assistant Director Mr. Paul Choiniere OfDec of Policy and Management "The Day" Policy Development and Planning Division 47 Eugene O'Nei!! Drive 450 Capitol Avenue-MS 52ERN New London, CT 06320 P.O. Box 341441 Ilartford, CT 06134-1441 Bab DeFayette 100 King Street First Selectmen Gettysburg, PA 17325 Town of Waterford flall of Records Don Becknun 200 Boston Post Road 1071 State, Route 136 Waterford, CT 06385 Belle Vernon, PA 15012

Summary of LIIC Presentation to NRC and NNECo in a Public Meeting on January 27,1998

The subjects addressed at the January 27,1998 briefmg of NNECo and the NRC stafTincluded updates on the development of a Safety-Conscious Work Environment and the performance of the Employee Concerns Program. The focus of both subjects was the ability of NNECo to effectively address complaints of harassment, intimidation, retaliation, and discrimination

("HIRD") in potential violation of the NRC's anti-retaliation provisions set forth in 10 CFR 50.7.

LilC first summarized the expectations it has set for NNECO with respect to events t.nd incidents of potential harassment, intimidation, retaliation, and discrimination. Those expectations are as follows:

1) NNECO will be able to identify incidents of harassment, intimidation, retaliation and discrimination that are potential violations of 10 CFR 50.7 requirements;

2) NNECo will be able to respond to identified incidents in a manner that immediately considers and mitigates the potential for a " chilling effect" on other employees from the incident;

, 3) NNECo will be able to anticipate and prevent incidents of actual or perceived harassment, intimidation, retaliation or discrimination from occurring.

(See, January 27,1998, Presentation, Slide 2.)

LilC then identified the various activities and events that it observed in reaching its conclusions. As summarized in the presentation, LHC identified that it had completed the following tasks and activities:

1) Observed various training sessions given to all management and supervisors;

2) Observed the management handling of a number of high profile events that has affected de Safety Conscious Work Environment ("SCWE") environment at Millstone, including events since September 1997 within the Oversight, Maintenance, Training, Engineering, and Contracting Organizations;

3) Observed various Executive Review 130ard meetings considering proposed disciplinary actions and remedial actions in connection with various events and incidents;

4) Received regular information from the SCWE group about site events being handled by the line organization;

5) Received continual information from employees and contractors regarding the Millstone work environment and handling of certain events.

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(See, January 27,1998, Presentation, Slides 3 and 4.)

Fin:lly, LilC presented their findings on the NNECo efrons in advancing a Safety.

Conscious Work Environment at Millstone. In general LilC described the positive actions taken by NNECo is establishing a Safety Conscious Work Environment organization, headed by a Vice-i President and assisted by a second Vice President to coordinate and manage progress and activity in this area. The line organization has also dedicated substantial resources and e' Ton to providing training and guidance to its managers in implementing the expectations for the proper work environment. The line organization has been supported in a number of specific ways that have been panicularly effectise. As set forth in the presentation LilC found:

1) Substantial improvements have been made is this area that are demonstrating improved understanding and commitment to reaching the goal of an acceptable safety conscious work environment; (he, January 27,1998, Slide 5.)

As explained in the presentation, as a result of the observations made sf this area, L11C found over the preceding fou; months the NNECo line organization has, as a whole, consistently improved in their knowledge of the necessary elements of a safety conscious work environment and demonstrated their commitment to providing such an environment. Specifically discussed as examples in support of this conclusion was the training that was provided for all managers and supervisota with respect to the requirements and expectations of 10 CFR 50.7, and NNECo management, in managing employees witMn a comme cial nuclear power plant environ .ent. The trairdng was uniquely developed for the Millstone site, and presented by qualified attorneys and pofessionals farraiar with both the law and its implementation. The courses were presented to small groups, which resulted in the excellent dialogue between attendees. The training program was well received by those in a'.endance, and the material stimulated excellen'. discussions and

" Question and Answer" sessions. This training provided good reinforcemeni of the principles that had been delivered in earlier SCWE sessions to site managers and supervisors.

L11C also identified as a positive activity:

2) The use of organizational effectiveness consultants to assist in changing the Erk culture; (See, January 27,1998, Slide 6)

This finding specially refers to the decision and actions in bringing outside consultants to provide guidance and assistance from a team of consultants which has had substantial success at other troubled nuclear sites. It was L11C's observation that these efforts were providing substantial assistance in both assessing the needs of various organizations and providing Page 2

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consultant advice and assistance in efTecting cultural change. i in addition, LilC identified as e positive imprevement:

3) the positive use of surveys and assessments to gain more in depth understanding of problems areas.

(See, Janualy 27,1998, Slide 6)

L11C described the use of surveys and assessments by managementl a making personnel changes with the assistance of the leadership survey information, the measureme 2t of work 3 environmem ettitudes and opinions in reorganizing departments and functions, and the reliance on this type orinformation as one of the factors in other key organizational decisions. As LilC described in the presentation, the use of these tools had dramatically increased over the past quarter.

Finally, in this area LilC cited:

4) several strong examples of management intervention and resolution ofincidents involving potential or perceived retaliation, (See, January 27,1998, Slide 6)

The examples provided and discussed in the meeting:

1) Nuclear Engineering and Support organization LilC described an incident that was handled by Vice-President Amerine. Within the Nuclear Engineering and Support organization, a potential problem was identificd regarding a personnel action proposed by two managers. hir. Amerine was briefed on the proposed action before it occurred. hir. Amerine began analyzing the problem while on an anplane, realized the potential that the action eculd be perceived as, or may in fact be, retaliation for engagement in proiccted activity. During a stop-over in his flight, hir. Amerine got off the airplane, called the managers and halted the actions that had been proposed. Upon returning to the site, he undertook a total review of th circumstances, sought advice and assistance from others, and followed that advice. L11C identified this as an incident in which management recognized the potential for rettliation (or the perception of retaliation), became personally involved in the process, and defused a potentially diflicult situation.

2) Unit 3 Reactor Engineering Organization in this incident, SCWE staff became anare of a hallway interchange between two individuals in the Unit 3 Reactor Engineering organization. In the incident, comments were made Page 3

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in a loud conversation that could have been regarded as harassing and intimidating. When SCWE became aware of the incident, they facilitated both a direct apology between the parties, and more importantly, acted to prevent any potential" chilling effect" by facilitating an apology by the perpetrator before the incident became a rOnincant issue.

3)QA Auditorincident  :

In late October and early November,1997, an event occurred in which a QA auditor j raised a significant concern about feeling harassed. LliC noted that when the event came to the attention of SCWE management a meeting was called immediately of the entire auditing organization, during which the concern was openly addressed and the impression of harassms ,

was discussed. This event was cited as a good example of an immediate, and appropriate, reaction to an identification of alleged retaliation.

4) the Executive Review Iloard 4

LilC also discussed the establish:aent and development of the Executive Review 130ard.

The purpose of the ERB is to review proposed disciplinary actions against individuals, from written reprimand to terminations and lay offs, in an attempt to identify and avoid any potential retaliatory actions. These efforts have ocen, with several notable exceptions, efTective in identification of problem areas, problem managers, and situations requiring management attention or intervention. The ERB has prevented incidents that were not well grounded and has appeared to have a deterrent efTect as well.

LilC reported that, notwithstanding the progress of the SCWE organization, that:

2) The NNECo line organization has not yet fully developed the requisite skills to consistently prm a work atmosphere that provides a safety conscious work environment.

LilC identific . : primary basis for this finding was because a) incidents cutmue to occur and b) there has been a lack of timely responses to some of those incidents.

(January 27,1998, Presentation, Slide 7)

The incidents identified as continuing to occur include the maintenance organization personnel changes and reaction of the maintenance organization, the references to a contractor in the training department as a " problem finder," and the continuation of the Quality Control department issues. The incidents referred to as demonstrating a lack of timely rcyonses include the Manpower placements, and the failure to resolve earlier issues raised by the QC organization.

As a result of the continuation of these incidents, and given the limited amount of time in which improvements have been noted, LilC continues to observe NNECo activities in this area.

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l The fmal fmding in this area tidressed LilC's observations on the role of the 11uman Resources (" IIP.") and Legal Departments in connection with the Millstone recovery efforts.

Specifically, LilC found:

3) The support for line management from the iluman Resources and Legal Departments is currently insufficient to reliably and consistently eradicate lilRD from the Millstone work environment.

(January 27,1998, Presentation, Slide 7.)

1 While Little 11 arbor has recognized the efforts directed by the Safety Conscious Work Environment group as a positive and vital role in the recovery effort, it has also become clear that the SCWE group is being relied upon for addressing problems far beyond the focused efforts of anticipating, preventing, and mitigating conduct that could be perceived as retaliatory. This has distracted the SCWE group from its ; -imary mission, and strained its limited resources. L11C recognized that both the SCWE and eCP organizations have numerous issues that are, in reality, the types ofissues that a iluman Resources organization should be handling. In some cases, the problems of timely resolutien has actually resulted from the liR or Legal Department's untimely response to issues given to them by the organization in which time was of the essence. As a result issues that should have been resolved have unnecessarily become major challenges.

LilC observed that while the llR department has made significant strides in the right direction, there is a continuing need for both the liR and Legal departments, once an initiating event has occurred, to provide information, advice, guidance and in some cases take action in support of management. The support of these departments is needed by the SCWE organization, wl.ere a number ofissues have arisen that have liR and Legal components. The contributions from these departments needs to be held to the highest standards and those responsible held accountable for meeting management's expectations. as line management more effectively integrates llR and Legal support to more timely resolve issues or concerns, the organization as a whole can move toward a " culture of tnist". This will allow SCWE to concentrate more on any retaliation concerns and other potential problem areas.

In connection with the development of a Safety Conscious Work Environment, LHC identified the following recommendations for NNECO:

1) NNECo should continue to provide training, mentoring and assistance to managers in further development of their understanding of retaliation, harassment and intimidation, rebuilding a culture of trust, and the critical nature of timely responses to employee questions and concerns;

2) The iluman Resources and Legal Support functions must provide knowledgeable and experienced professionals to assist line management in achieving its goals for the safety conscious work environment; Page 5

3) Line management must integrate these support resources in order to timely  ;

resolve issues or concerns. t (January 27,1998, Presentation, Slide 8.) '

LilC explained these recommendations, in partic iar, the need for NNECo to integrate the various responsibilities and functions being performed by IIR, SCWE, and ECP that overlap in ,

addressing employee concerns of unfair treatment.

The second subject matter presented by L11C at the January 27,1998 public meeting was  :

a review of the Employee Concerns Program ("ECP") handling of the issues of harassment,  ;

intimidation, retaliation and discrimination. LilC restated its expectations for the Millstone ECP:  ;

i The Employee Concerns Program will be able to effectively identify, promptly investigate, and timely resolve allegations of harassment, intimidation, retaliation and discrimination raised by employees or contractors with sufficient independence and competence to be relied upon by the w, *forec, ;he public, and the regulators i as an alternative to line management.

(See, January 27,1998, Slide 9.)

LilC then summarized the activities it had observed in connection with reviewing the status of the ECP:

1) LiiC reviewed 100% of the relevant ECP files (opened since January 1997 and closed through mid December,1997) containing allegations of harassment, intimidation, retaliation, and discrimination in violation of 10 CFR 50,7;

2) Resiewed summary intake and in-process investigation information on all files containing 10 CFR 50.7 allegations opened since January 1997 and still under investigation by ECP;

3) Reviewed the majority of closed lilRD files not classified as 50.7 files;

4) Interviewed allegers, witnesses, managers, and others involved with a substantial  !

number of the cases addressed in the lilRD files;

5) Observed ECP interactions with employees and managers involved in intake, investigation or the resolution stage of ECP case files.

(See, January 27,1998, Presentation, Slide 10 L11C then ptesented the following findings with respect to the ECP:.

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1) The ECP has demonstrated an ability to efTectively resolve employee concerns ofretaliation; I

2) The ECP does not always timely intervene in cases needing immediate intervention or in reaching a determination of the existence of" chilling effect,"

3) The ECP has not always displayed sensitivity to employees facing H RD i situations or m.intained sumcient communications with all concerneet during ECP investigation and resolution.

(See, January 27,1998, Slide 11)

I LilC explained these findings to include the observation that the ECP has demonstrated appropriate independence in the context of management closure panels for concerns brought to the ECP. Specific examples were given with respect to presentations made by the ECP management regarding the resolution of findings with respect to the investigation of alleged harassment of a QC inspector, the MOV incident, and other cases involving senior management cmcials. LilC also pointed to good analytical analyses in pointing out commonality ofissues and behaviois, demonstrating a willingness to reopen files, and a willingness to make necessary changes to the program as necessary.

As to the sensitivity issue, LilC reiterated its previous finding that the ECP investigators and stalTmust continue to develop and utilize the most sensitive approaches to employee concerns.

LilC made the following recommendations with respect to the ECP findings:

1) The ECP should continue to develop and demonstrate its ability to effectively resolve employee concerns of retaliation;

2) The ECP should develop, with the SCWE organization, a response protocol to lilRD allegations tha' provides management with recommendations and assistance in those situations that require immediate attention;

3) The ECP should continue to provide training to the ECP representatives and investigators on interper.,onal skills and insist on regular comm'mication with concernees (See, January 27,1998, Slide 12)

Following the formal presentation by LilC there was a ques: ion and answer period in which both NNECo and the NRC asked clarifying questions. One of the topics of discussion was the classification and handling ofissues of retaliation in potential violation of 10 CFR 50.7. The discussion was tabled, pending completion of discussions on the topic between LliC and NNECo.

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LITTLE HARBOR CONSULTANTS' REVIEW OF NNECo HANDLING OF ALLEGATIONS OF RETALIATION AT MILLSTONE Little Harbor Consultants Presentation to NRC and NNECo January 27,1998

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'anusty27,1999 Presentation to NHC and NN) Ce i N /

EXPECTATIONS

• NNECo will be able to identify incidents of harassment, intimidation, retallation, and discrimination in violation of 10 CPt 50.7,

• NNEco will be able to respond to identified incidents in a manner that immediately considers and mitigates the potential for a " chilling effect" on other employees from the incident.

• NNECo will be able to anticipate and prevent incidents of actual or perceived harassment, intimidation, retallation or discrimination from occurring.

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January 27.1998 Prewntataan to NRC and NNFCe 2 1

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OBSERVATIONS in reaching its conclusions, Little Harbor

! has completed the following tasks and activities: '

Observed the various training sessions given to all management and supervisors.

• Observed the management of a number of incidents that affected the SCWE at Millstone,includirig events since September 1997 within the Oversight,it.alntenance, Training, Engineering, and Contracting organizations.

January 21.190s l'resentation to NHC and NNI Ce J

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OBSERVATIONS, CONT.

Observed Executive Review Board meetings considering proposed disciplinary act%ns and remedial actions in connection with events . i d incidents.

Received regular information from the SCWE group about site events being handled by the line organization.

Received continualinformation from employees and contractors regarding the Millstone work environment and the handling of certain events.

/ s January 27.1998 l'resentauen to NRC and NNFro 4 2

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i FINDINGS ON NNECo SCWE EFFORTS

1) Substantial improvements have been made in this area that are demonstrating improved understanding and commitment to reaching the goal of an accepteble safety conscious ,

work environment.

• Creation of a SCWE group reporting directly to a VP;

• 10 CFR 50.7 training for all managers and supervisors;

• Management of identified " problem areas;"

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January 27,1998 Presentation to NHC and NNI Ce $

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FINDINGS ON NNECo SCWE EFFORTS, CONTE

• Use of organizational effectiveness consultants to assist in changing the work culture;

• Use of surveys and assessments to gain more in-depth understanding of identified problem areas;

• Several strong examples of management intervention and resolution of incidents involving potential or perceived retaliation.

/ 5 January 27,1998 Presentation to NHC and NNI.Ce 6 3

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CONTINUATION OF FINDINGS ON l

1 NNECo SCWE EFFORTS

2) The NNECo line organization has not yet fully developed the requisite skills to consistently promote a work atmosphere that provides a safety conscious work environment.

• Incidents continue to occur;

• Lack of timely responses to some of those incidents.

3) The support for lina management from the Hurnan Resources and Legal Departments is currently insufficient to reliably and consistently eradicate HIRD from the Millstone work environment, January 27,199u Prtientation to NRC and NNI Cs  ?

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RECOMMENDATIONS FOR NNECo e

NNECc should continue to provide training, mentoring and assistance to managers in further development of their understanding of retallation, harassment and intimidation, rebuilding a culture of trust, and the crdical nature of timely responses to employee questions and concerns.

The Human Resources and Legal support functions must provide knowledgeable and experienced professionals to assist line management in achieving its goals for the safety conscious work environment.

• Line management must integrate these support resources in order to timely resolve issues or concerns.

/ s January 27,19'MI Pres-atation to NRC and NNi ce B L ._J 4

'l i I EXPECTATIONS FOR ECP The Employee Concerns Program will be able to effectively identify, promptly investigate, and timely resolve allegations of harassment, intimidation, retallation and disc 6'mination raised by employees or contractors with sufficient Independence and competence to be relied upon by the workforce, the public, and the regulators 4

as an alternative to line management.

- N January 31,194 l'tesentataon is NHC sad NNI'Ce 9

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OBSERVATIONS OF ECP ACTIVITIES

1) Reviewed 100% of the relevant ECP files topened since January 1997 and closed through mid December 1997) containing allegations of harassment, intimidation, retaliation and discrimination in violation of 10 CFR $0.7,

2) Reviewed summary intake and in procras investigation information on al! files containing 10 CTR 60.7 allegation opened since January 1997 and still under investigation by ECP,

3) Reviewed the majority of HIRD files not classified as 10 CFR 50.7 files.

4)lnterviewed allegers, w! nesses, managers, and others involved with a substantial number of the cases addrensed in the HIRD files,

6) Observed ECP interactions with employees and tr:nagers involysi in intake, investigation or resolution stage of the ECP case file.

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< January 27,19M l'resentation ti, NRC and NNFCo le 5

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FINDINGS TThe ECP has demonstrated an ability to effectively resolve employee concerns of retallation.

2) The ECP does not always timely Intervene in cases needing immediate intervention or in reaching a determination of the existence of " chilling effect." -

3) The ECP has not always displayed sensitivity to employees facing HIRD situations or maintained sufficient communications with all concernees during ECP investigation and resolution.

e s January 27.1998 l'resentauon to NHC and NNI Ce li

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RECOMMENDATIONS

• The ECP should continue to develop and demonstrate its ability to effectively resolve employee concerns of retaliation.

• The ECP should develop, with the SCWE organization, a response protocol to HIRD allegations that provides management with recommendations and assistance in those situations that require immediate attention.

• The ECP shculd continue to provide training to the ECP representatbes and investigators on interpersonal skills and insist on regular communication with concernees.

a January 27.1998 Presentstan to NRC and NNire 12 i

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STATUS OF A SAFETY

(. ONSClOUS WORK ENVIRONMENT AT MILLSTONE Little Harbor Consultants Presentation to NRC and NNECo January 27,1998 January 27,1994 Presentauan to NRC and NNFra 13 A

STATUS INDICATORS FOR NNECo's SCWE IMPLEMENTATION EFFORT l o, n l World Class Acceptable for a Restart I**"ad b.M Not Acceptable I #*"~I u For Restart l n., l J Significant IWeaknesses Trends: " improving + Steady t Declining s

January 27,1994 Presentation to NRC and NNFCo 14 d

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STATUS OF NNECo SUCCESS CRITERIA FROM LHC ATTRIBUTES NNECo 8":, cess Criteria Statur

1. Demonstrate the w!llingness to raise concerns.

(Yellow)

N January ?",1998 Presentauen to NRC ead NNrre 15

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FACTORS CONSIDERED IN GRADING ATTRIBUTE

1. Demonstrate the willingness to raise veno 4 concerns.

Positive Factors Neoative Factors

• ERB Review

• December ECP MM Event Concerns

• Training Contractor

• MM Event Event

• RE Group Event

/ N January 27,1998 Presentation to NRC and NNFCo 16 8

/ l STATUS OF NNECo SUCCESS CRITERIA FROM LHC ATTRIBUTES NNECo Success Criteria Status

2. Demonstrate that issues are being effectively resolved by line management.

(Yellow) s January 27,1998 l'resentauon to NPC and NNtre 17 i

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STATUS OF NNECo SUCCESS CRITERIA FROM LHC ATTRIBUTES NNECo Success Criteria Status

3. Demonstrate that the ECP is effective.

(Yellow)

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January 27,199e l'reuntauen la NHC and NNI Ce 18 9

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FACTORS CONSIDERED IN GRADING ATTRIBUTE

3. Demonstrate that the ECP is effective. y ,,,1 Positive Factors Nediative Factors

• Customer Satisfaction

• Interpersonal Skills 83% .

Timely and Coordinated

• Responsive to LHC Response to Potential Recommendations " Chilling Effect"

• Demonstrated independence N

.tanuer) 27.1994 l'rewnteuem to NI4C and NN) Ce 19

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STATUS OF NNECo SUCCESS CRITERIA FROM LHC ATTRIBUTES NNECo_ Success Criteria Status

4. Demonstrate that management can recognize and effectively deal with alleged instances of HIR&D, or other circumstances which have created a chilling effect, which collectively are (Red) referred to as problem areas.

- J January 27,1998 l'teuntataan to NRC and NNi'Ce 20 10

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FACTORS CONSIDERED IN GRADING ATTRIBUTE

4. Demonstrate that management can

"'d H recognize and effectively deal with

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alleged instances of HlR&D ... -

Positive Factors

• $0.7 Training . Organizational

• Partnership 2000 Effectiveness Censultants

• GET Upgrade -

ERD Reviews

• ECP input to MFNS . SCWE Resources

• ECP input to Partnership . Training Contractor 2000 . RE Group Event e Jan 20 SCWE Training I

. MM End Results a / . x

.fanuary 2?,19M f*tenentation to NHC and NNI Co 11 x /

FACTORS CONSIDERED IN GRADING ATTRIBUTE

4. Demonstrate that management can

"'d 6 recognize and effectively deal with alleged instances of HIR&D ...

Neaative Factors

• Partnership 2000 Lacks SCWE MM Event

. Maintenance / Oversight Relationship DeclJan ECP (HIRD)

Concerns

• Timeliness Problems t- s January 27,19M Prewntation to NRC and NNt Ca 22

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SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

1. Senior management endorses a policy that places priority on nuclear safety, supports the workers' rights to raise safety i issues and ensures that workers will not be subjected to (Green) harassment, discrimination or intimidation if they do so.

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January 21,1998 Preuntatson to NHC and NNI.Ce 23

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SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

2. Employee perceptions of the policy and its implementation are favorable. +

(Yellow)

N Janusry 27,1999 Prewntauon to NRC and NN) Co 24 12

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SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

3. Senior management providen training to all managers and supervisors to ensure that they understand and employ good management practices when dealing with employees who (Yellow) have safety concerns and do so with understanding.

N January 27,1998 Presentauen to NRC and NNICo 28 N _

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FACTORS CONSIDERED IN GRADING ATTRIBUTE benior management provides training to all managers and supervisors to '" *h ensure that they understand ...

Positive Factors Neoative Factors 50.7 Training .

Partnership 2000 Lacks Partnership 2000 SCWE GET Upgrade ECP Input to MFNS ECP Input to Partnership 2000 Jan 20 - SCWE Training N

January 27,1998 Prewntshon to NRC and NS FCe 26 L

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SAFETY CONSClOUS WORK t ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

4. Members of the workforce have a sense of identity and are l committed to the publicly stated 4 goals and objectives of the organization, have respect for each other, communicate (Yellow) l effectively both horizontally and vertically, and feel responsible

, for their owa behavior.

January 27,1998 Presentshon to NRC and NNFro 27 l

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FACTORS CONSIDERED IN GRADING ATTRIBUTE

4. M3mbers of the workforce have a y ,n, sense of identity and are committed +

to the publicly stated goals ...

Positive Factors Neaative Factors

• MM End Results - MM Event Organi:mional

• Maintenance / Oversight Effectiveness Relationship Consultants e N January 27.1994 Presentshon to NRC and NNFro 28 l J l4

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SAFETY CONSClOUS WC 'K ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

5. People at alllevels of the organization treat each other l with mutual respect. +

(Yellow)

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, January 27,1998 Presentsuon to NHC and NNECo 29

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FACTORS CONSIDERED IN

, GRADING ATTRIBUTE

5. People at alllevels of the y,no ,

organization treat each other with ->

mutual respect, Positive Factors Neaative Factors

• Organizational .

Lack of Trust 4

Effectiveness Consultants

/ s January 27.1994 Presenteuen to NHC and NNFCo 30 15

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SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

6. Employees exhibit a " ques-tioning attitude" toward work and the, twk environment with ++

respect to nuclear safety.

Positive Factors (Yellow)

• Sludge Assessment

/ x January 27,1998 Presentsuen to NRC and NNFCe 31 s /

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS l

LHC Expectation Status

7. Positive recognition is given to employees who identify safety issues. ~+

Positive Factors

= Sludge Assessment (Yellow)

- N January 27,1994 Presenteuen to NRC and NNFCo 32 16

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/

SAFETY CONSCIOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

8. Incidents leading to allegations i of harassment, intimidation, I retallation or discrimination A rarely occur, and management is timely and effective in taking action for resolution and (Red) prevention.

N January 27,1999 Presentauen to NRC and NNFro JJ

/

FACTORS CONSIDERED IN GRADING ATTRIBUTE

8. Incidents leading to ellegations of harassment, intimidation, retallation or "du discrimination rarely occur, and management is timely and effective ...

Eositive Factors Neoative Factors ERB (10% Intervention) Dec/Je i ECP Concerns-

• SCWE Resources HtRD

• MM tssue Nucle:r Engineering and Support Activities .

Manpower s

Janusry27,1999 Presentauen to NRC and NNTCo 34 17 o

a s /

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

9. There is no evidence that an atmosphere exists that has a

" chilling offect" on the - A willingness of employees to report safety issues, gy,;;og) x January 27.1998 l'resentauen to NRC and NNI Ce )$

\ /

FACTORS CONSIDERED IN GilADING ATTRIBUTE

9. There is no evidence that an atmosphere venow exists that has a chilling effect" on the willingness of employees to report safety issues.

Positive Factors Neaative Factors

• ERB Reviews

• Dec ECP Concerns (Fear

• MM Event of Management)

• Training Contractor

• MM Event Event

• RE Group Event N

January 27,1998 l'resetitahon to NRC and NNice 36 L _j 18

i f

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

10. An effectiva and efficient corrective action program is functioning and all employees recognize the normal (and preferred method) for gy,gg3,)

addressing safety issues is through the line organization.

' N January 27,1998 l'resentshon to NHC and NNI'Ce 37

/

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS t.HC Expectation Status

11. Senior management recognizes that some concerns may not be addressed through ^

the normalline organization and has established an (y,;;ow)

(effective) Employee Concerns Program (ECP) for handling such concerns.

s January 27,1998 l'rrientshon to NRC and NNI.Ce 34 w

19

i I

s -

FACTORS CONSIDERED IN GRADING ATTRIBUTE

11. Senior management recognizes ... venog and has established an ... Employee i Concerns Program (ECP) ...

Positive Factors Nagative Factors

• Customer Satisfaction 83%

• Response to LHC Recommendations s- s.

January 27.1999 Presentsuon to NkC and NN)Ce 39 x -

SAFETY CONSClOUS WORK ENVIRONMENT ATTRIBUTE STATUS LHC Expectation Status

12. Independent and self-assessments are performed periodically to monitor

^

performance and correct identified deficiencies. (y,;;g,)

- N January 27.1994 Presentation to NHC and NNICo 40 20 1

s

u- - . -

l- l l

i LHC RECOMMENDATIONS AND RESPONSES' i

i Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Determination i 4

5/I3/97 Cosmprehensise Plan (CP) j i 1. Revise the CP to Address the NNECo Letter 7/6/97 (B16529-l) the CP will be Pending team inputs and Pending team inputs and evaluation.

j following: supplemented by July 22,1997, to provide a " road evaluation.

! la. Ensure All Root Causes map" which describes the full breadth of i Are Effectively activities in process to correct the safety-

] Addressed So That conscious work environment at Millstone Station.

I Resultant Action Plans, Combined With - NNECo Letter 7/22/97 (B 16651) Transmitted M,nate's Supplement I to the CP and Stated it Met the .

Direction, Will Correct LIIC Recamm-~'aion. Attachment 1 Provided Each Root Cause. Cross Reference to Root Causes.

i i

1

! I

) 01-2692 01-2698 l,  :

t 3' 5 I

f i

' Legend for NNECo Column

- Excefpts frorn NNECo responen are shown ether as d<ect quotates or as an abstract. [

, tegend for LHc Er.ectiveness Cow i 4 -

• Requres :wnhanat LHC fonow-up

- CLOSED No further LHC achon required.

' 3 The numbenng in trus document is sm +ntal for ease of trackmg and does not daectly correspond to recommendata numbers in source documents.

i Page 1 of 47 Rcused 126-98

• L 1

. _ . . . _ _ _ - - . . - . . _ . _ - . , ~ . . , _ . . _ _ _ _ _ . _ . , _ . . . , , . . , _ . . . _ . . . . _ . _ _ _ . , . . _ - __ - - _ . . , , , _ .-. . , - - - -

Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Determination

I b. Place the Focus on Line NNECo Letter 7/6M7 (B 16529) No Commitment Pending team inputs and Pending team inputs and evaluation.

4 hianagement's Role and We beliese that we have pixed an appropriate evaluation.

Account abilities in emphasis on line management's role in achies ing Achieving the Desied the desired [SCWE]

l Salety-Conscious hiite Brothers' role as execuri- : sponsor of Environment. SCWE is described. In addition, approximately

) 50% of the action items contained in the CP are related to improving line managen-n's fundling

! of employee concerns. hir. Brothers has assigned

additional resowces to res iew and implement the areas of the CP that are the responsibility ofline management.

i NNECo Leuer 7/22197 (B16651) transmitted

! Supplement I to the CP and stated it met the LilC recommendation. 61-26-93 01-26-93 l

I c. Develop Success Criteria NNECo Letter 7/687 (B16529-2) Pending team inputs and Pending team inputs and evahn: ion.

and Measurement Success criteria and measurement techniques for evaluation.

l Techniques. each of the ten objectives delineated in Appendix

I of the CP will be deseloped by July 22,1997.

NNECo n etter 7/22/97 (BI6651) transmitted Supplement I to the CP and stated it met the LilC recommendation. Stated 12 techniques for evaluating and measuring CP Objectives. 01-26-93 01-24-93 Id. Require a Critical NNECo Letter 7/6/97 (B16529-3) Pending team inputs and Pending term inputs and evaluation.

Review of Current The corrective action program efforts will be esaluation.

~

Correctise Action reDected in the Noad map" supplement to the CP Programs. by July 22,1997.

NNECo Letter 7/22N7 (B 1665 l } transmitted '

Supplement I to the CP and stated it met the !. llc recun-h6an. Stated actions to improve hts's CAP. 01-26-93 01-26-93 Page2 of 47 ReuscJ I.26-98

Date, Source and LIIC NNECo Resnonse LIIC Evaluation I.IIC Effectiveness Recommendation Determination I e. Expand the Rer;uirement NNECo Letter 7/6/97 (B16529-4) Pending team inputs and Pending team inputs and evaluation.

for Formal, Periodic The CP will be revised to include the self- evaluation.

Self-Assessments by assessment efforts by July 22,1997 Each Organizational An Executive Sponsor and issue Manager have Element been designated to pursue and ensure resolution of all aspects of the issue.

NNECo Letter 7/22/97 (B16651) transmitted Supplement I to the CP and stated it met the LIIC

, recommendation. Stated actions to improve MS's Self-Assessment Program. 01-26-93 01-26-93 l

6/3/97 Culture Survey -

2. Before Conducting the Next NNECo Letter 1/6/97 (B 1665 l } On June 23 Response is appropriate

• 6/97 Survey objectives nd Suney Consider the Following: another FPI-NU Culture Survey was distributi * . and adequate. clearly defined.

• 2a. Objectives are clearly Prior to the conduct of the survey, the servey

• 6/97 Culture Survey was defined. objectises were clearly defined and adequately designed te assess communicated to the workforce. The survey was and measure a m: clear safety designed to measure the cultural climate. It climate.

measures ability for scif-improvement,

• All key areas of safety culture leadership, clear understanding of mission goals, were addressed in the data and quality of processes. The survey also collection.

measures the safety culture. #I-21-93 of.2/.93 2b. Survey objectives are NNECo Letter 7/6'97 (ell 665 l} Response Response is appropriate

• 6/97 Survey objectives npl ucil communicated. included in "a", above. and ajequate. communicated.

• 01-21-93 01 2f.98

^

l l

Page 3 ot' 47 Reed 1269s f 3, -t E E

• l Date, Source and LilC NNECo Response . LilC Evaluation LilC Effectiveness Recommendation Determination 2c. . The scope and content of NNECo Letter 7/6/97 (B16651) As a result of our Response is appropriate

• The 6/97 culture suney current questions are review and validation of the survey scope and and adequate. question redesign was adequate reviewed and validated. content, new questions were added to the survey and upon review validated the tool on safety culture w hile other questions were process.

modified. Further, additional questions tied to conservati.e decision making and senior management's support of a safety conscious work environment were included in the sun'ey.

91-21-98 01-21-98 CLOSED 2d Questions randomly NNECo Letter 7/6797 (B 16651) Response Response is appropriate

• 6/97 Suney was revised to distributed. included in"c", above. and adequate. include randomy distributed questions.

01-21-98 ' 01-21-9R CLOSED 2e. Add following NNECo Letter 7/6/97 (B16651) Response Response is appropriate

• Included in 6/97 Sun'ey constructs:" conservative included in "c" abose. and adequate decision making;"

" senior management endorses a policy that supports the wMers' right to raise safety issues without fear of harassment, discrimination,or f #1-21-98 01-21-98 CLOSED l intimidation" 2f . . Be consistent; use either NNECo Letter 7/6/97 (B1665 I) Response Response is appropriate

• All questions converted to the a 4 point scale or convert included in "c" above, and adequate. existing 4 point scale. l to a 5 point scale. 01-21-98 01-21-98 CLOSED 2g. All areas of culture are . NNECo Letter 7/6/97 (B16651) Response Response is appropriate

• All areas ofculture are now included. included in "c" above. and adequate. included.

01-21-98 01-21-98 CLOSED 1

Page 4 of 47 Rmsed I-26-98

___ m

l u- ..

Date, Source and LHC NNECo Response LilC Evaluation LIIC Effectiveness Recommendation Determination 2h. Line manaprs are NNECo Letter 7/6/97 (B1665 l } Line managers Respcase as outlined is *- Line management was advised appropriately prepared were advised of the purpose of the suney at a not appropriate and net of the 6/97 Suney late.

and involved. management meeting held on June 18,1997. adequate.

• Line managers were.nol

...the survey tool was distributed by the Nuclear involved (therefore, not Officers. Collection points were located in the committed).

various departments and at other remote locations

• 1 'ne management were not throughout the site. trained (if at all).

01-21-98 01-2f.ys

• 2i. Management is NNECo Letter 7/6/97 (B16529-5)

• Responseis less

• Results were not communicated committed to translate The results of the June 23,1997 culture survey than adequate.- to any significant number of and implement the will be processed and reports wil'. x developed

• Responsedoes not employees.

results into actions. by site, unit and departments. Each nuclear include

• No action plans were created Ier.dership team officer will assure appropriate measurements. nor initiated.

actions are taken in a timely manner for any areas

• Line management

• Answer data was tabulated by identified as needing improvement. - not trained in data an outside data processing analysis and/or company.

action plan development.

• Scope prescribed for action plan development is too narrow. '

01-21-98 gy_y7,gg

• 6/3/97 Culture Survey 6/5/97 Letter (ITPOP 97-0009)

Prosided Clarification Page 5 of 47 Reused 1-26 98

Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Determination

3. Survey Must be Properly NNECo Letter 7/24/97 {B16617 ATT.1) - Reference to

• Survey administration and Administered to Deliver Nuclear Leadership Assess.ient was administered Leadership controls have vastly improved Meaningful Results. by IIR week of June 16. IIR reps distributed and Assessraent is not and are adequate.

collected forms and were present to answer appropriate because questions. Employee access to identification it is p21 a survey.

coding was restricted.

• Survey For the Nuclear Culture Survey on June 23, administration is distributio.: was by Analysis & Programs to appropriate and Nuclear Officers, in turn to their department adequate.

heads for distribution on down in the organization; instructions were givcn to not enter names or employee ids; return completed surveys either to its source or locked drop boxes. 01-21-93 01-21 98 CLOSED Page 6 of 47 Rev?al 1-26-98

• I E

i u. . .

i -

j .

! Date, Source and LHC NNECo Response LHC Evaluation LHC Effectiveness

{ Recommendation Determination t

', 4. Must Be Committed to Act on NNECo Letter 7/24/97 (BI6617 ATr.1)

• As with #3, abose,

• 6/97 Snncy was completed and the Survey Results. Beginning in 1997 the results of the Leadership the Leadership resn' - e tabulated with Assessment are tied to the performance ' Assessment tools apprn  : printouts of scores j management process. Also in 1997, results are are not survey tools, distnb ,cu.

tied to the rewards system through the Nuclear .ather one element

• No instructions were i Performance Incentive ivogram. It is our view of an individual communicated to line j that integratirg assessmen with the performance development management (at alllevels)in j management and rewards processes demonstrates process for 10% of how to analyze this data and

{ our commitment to act on the results all management. develop action plans.

j With respect to the FPI-NU Culture Survey, the

• Ng " appropriate actions" were I results of the survey will be processed and reports

• Response with taken as a result of identified

{ will be developed by site, unit, and departments. respect to the improvement areas.

4 Each nuclear leadership team officer will ensure ' Culture Survey is

! appropriate actions are taken in a timely manner adequate and for any areas identified as needing improvement appropriate..

01-21-98

• 01-21-98 i

?

f-1 i

i i

I i

i i

i, 3 Page 7 of 47- neused i.26 98.

3 i

,-,,,,,,,,-,4 - , - - -.m, , .- . , . , , . , ,,---nam-,,-.n ,,,-y,_

~

Date, Source and LilC NNECo Response LilC Evaluation LIIC Effectiveness Recommendation l Deterntination 6/3/97 Programmatic Review of ECP 6/5/97 Letter (ITPOP 97-009)

Provided Clarification

5. NNECo Should Review and NNECo Letter 7/24/97 (B16617-1) " Joint investigation Guidelines are adequate if properly Revise the ECP Manual to Establish common standards and criteria fer Guidelines" have been implemented. There appears some Address the Following: processing concerns by all organizations hanJIing developd and issued. reluctance by the affected parties to employee concerns by September 5,1997. Acceptable. make a commitment regarding Sa. Develop Common implementation. L1IC will review Standards and Criteria implementation.

for Processing Concerns by All the Organizations llandling Employee Concerns.

01-21-98 01-21-98 5b. Develop Cle4 NNECo Le"er 7/24/97 (1116617) The standards " Joint Investigation Guidelines are adequate if properly  ;

Interfaces, Expectations and criteria described above will provide clear Guidelines" have been implemented. LilC will review '

Between These inwrfaces and expectations between all developed and issued. implementation.

Organizations. organizations that handle employee concerns. Acceptable.

01-21-98 gy_y; 9g s l

l Page 8 of 47 Reused 1-26-9s

'h O O e m

3u. ..

i t I i f Date, Source and LHC NNECo Response ' LitC Evaluation LilC Effectiveness j Recornmendation Determination

! ~

! Sc. Implement a NNECo Letter 7/24/97 (L116617-3) Implement a ECP is reviewing the Acceptable.

Management Overview formal process for management overview of the Monthly Report (MP)

of the Concern Process. concern process by Sept. 5.1997. with the Nuclear Officer j on a monthly basis' This

process started 9/30/97.

I ECP Management is i reviewing files prior to putting them in the i resolved or closed ~

category. Formal Closure -

Panels are being j conducted as needed.

Acceptable.

1 01-21-98 01-21-98 CLOSED i

5d. Provide Comprehensive NNECo Letter 7/24/97 (B:6617-2) Acceptable. Acceptable. ECP Monthly Reports l Monthly Reports to Expand the monthly report to include all active now provide adequate

! Management Addressing Millstone-related employee concerns being measurements Analysis section 1 Concerns llandled by handled by all organizations har.dling employee could be improved but is acceptable.

l All Organizations. concerns by September 5,1997. Also see item #53 on this list.

01-21-98' 01-21-98 CLOSED

6. Ensure the Elements NNECo Letter 7/24/97 (B16617-4) Adequate. Is being ' Meets requirement.

Referenced in Conclusion 4 A requirement will be documented for conducting tracked by ECP using i Are Addrersed

an annual external assessment of the ECP by AITfS.

f 6a. Manual Does Not Contain Requirement ihr Letter 7/31/97 (ECP-97-029) Established Conducting an Annual requirements and stated that the initial assessment

External Assessment of will be completed by 7/1/98.

] the ECP as Committed to t

in the CP (Action Item j 10-13.) 01-21-91, 01-21-98 CLOSED i

1. Page 9 of'47. Reused 126 98 ,

i I

n.

1

, ..,,.,u. _ - . , , , . . - , _ ._.-_._-.._..,_...,.._-..~...-; -.--.-m. , , _ _ _ ..._4-,--_,._.-_ . - - . - - --.A _ -.._.J, - - . _ , - _ .

Date, Source. and LHC NNECo Response LilC Evaluation LIIC Effectiveness Reconimendation - Determication 6b Requires All NU NNECo Letter 7/24!97(B16617-5) Unacceptable. NUP 20 NUP is not being implemented Employees to Participate Confirm ti.at the site exit process is supponing only requires an exit to be consistently to assure exits are being in an Exit Interview; these options (i.e., either participating in an exit scheduled. given to all departing NU employees llowever, Site Exit interview with the ECP or be given a letter or contractors.

Process Does Not requesting any concerns that they may have) by Assure They Will be September 12,1997.'

Directed to the ECP. 01-11-98

• 0/-21-93 6c. Manual Does Not NNECo Letter 7/24/97 (B16617-6) 'Unaccentable. The terms NNECo needs to develop plan to Address Coverage for Application of the ECP to contractors at off-site and conditions apply the check implementation.

Contractors at Off-Site locations will be defined by September 12,1997. requirements but Locations. contractor implantation Letter 9/11/97 (ECP-97-059) Application of off- has not been reviewed by.

site contractor is covered in general terms and ' N'NECo No NNECo conditions. plan exists to verify impicmentation 01-21-98

• 01-21-98 6d. Ilandling of NRC NNECo Letter 7/24/97 (B I6617) llandling of Acceptable. Process i; well defined ano is being Referred Allegations Is NRC referred a!!egations is now covered in implemented as evidenced by Lisc Not Covered.. procedwa DC 18 (Sec' ion 1.2.9), Change I, sending allegations to ECP.

which was effectise on June 30,1997 01-21-98 01-21-98 CLOSED 6e. Does Not Address NNECo Letter 7/24/97 (B16617-7) Response is adequate.

The document " Qualification of ECP Personnel Qualification Qualification and training of ECP personnel . Intake & Investigation Personnel,"

and Training. involved in handling employee concems will be Rev i dated 9'15/97 provides an described in administrative controls by August adequate set ofqualification and 22,2997 .

traimng requirements.

01-11-98 01-21-98 CLOSED

age 10 of 47 " Reusca t.26-98

~;r y . , e -

_...E_1_______.______________ . . . .

.s_.

Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Delermination

7. Implement Corrective Action NNECo Letter 7/24/97 (B16617) Manual was revised and - Weaknesses selfidentified need to for ECP Self-Assessment Actions have either been taken or are underway this resulted in process be corrected.

Identified Items: to address each of the ECP self-assessment items improvements. ECP Self-7a. De concerns resolution identified as requiring improvement, including Assessment 97-EC-4 process is flawed in the specific items highlighted by LilC. identified 3 weaknesses several key respects: and LIIC concurs.

- The Process Does NNECo Letter 7/24/97 (B16617-8) Issue Not Address liow Revision 2 of the ECP Manual by August 8, Investigative 1997, to I) ref :ct experiences gained with Findings Are implementing the manual; 2) reflect changes in Translated Into responsibilities and 3) describe interfcces with Correctise Actions. the ECOP.

- There Is No Formal NNECo Letter 7/24/97 (B16617-9) Enhance the Process for ECP corrective action process by August 29, Corrective Action 1997.

Tracking.

- There is No Process for Evaluating the Effectiveness of 01-21-93

• Corrective Actions. of.21-98 e

Page 1I of 47 nesised i.2M8

- - - - - - ~ - - - - -

- = . - - -

3 l

Date, Source and LHC ' NNECo Response LliC Evaluation LHC Effectiveness Recomsnendation Determination 7b. The ECP files are NNECo Letter 7/24/97 (316617-10) Fleview the. ECP completed review of Based on a LilC resiew of a sample deficient in several areas. pre-December 1996 files and resolve the files identified on (23) of the files and ECP Self-documentation deficiencies by October 31,1996 8/l1/97. Corrective Assessment 97-EC-3. The NNECo Letter II/3/97 (B 16842) actions for identified Corrective Actions taken appear to Letter changes commitment to reflect experience deficiencies was be adequate.

gained in review of post-December 1996 files. completed i1/24/97.

Commitment revised to: NNECO commits to review the pre-December 1996 Millstonc Station concern files as follows:

Review each file closed prior to December 1,1996, and categorize as follows:

A. Alleged [IllRD} or Chilling Effect.

' B. Alleged issue that could affect the safe operation or shutdown of a unit or endanger the health and welfare of the public.

C. Other (No further action will be taken for these).

NNECo Letter 11/14/97 (B 16858) changed date to 12/1/97.

01-21-98 01-11-98 CLOSED 7c. The ECP working Physical changes to the offices have been Space and equipment has Space, layout, privacy and environment is comp;ered to provide acceptable working spaces been provided. equipment are minimally adequate.

' inadequate, and private discussion areas. Adequacy is being impacted by temporary ECP personnel; no additional physical changes are anticipated. 01-21-98 01-21-93 CLOSED

. 7d. ' The ECP has an -

NNECo Letter 7/24/97 (B 16617-1 I) Complete Many improvements and ' See #17 on this list.

inadequate database the ECP database improsements by August 29, additions have been made management system emd 1997. to the database.

lacks sufficient report preparation softw2re attu -

hardware. 01-21-98 01-21 CLOSED Page 12 of 47 acused i.26-9s p -g I. g ,

't 1

4

~

f l Date, Source and LIIC NNECo Response - LHC Evaluation LIIC Effectiveness

. Recommendation Determination

+

1 7e. The ECP staff needs A new po<ition reporting to the Director will Response is adequate. Training requirements have been training in several areas oversee training and organizational development. identified and needed courses are

[ to upgrade their skills: ECP staff training has begun to support transition being provided.

from contractor based to NU based ECP As yet, there are insufficient

] organization. The goal is to make this tra.nsition numbers of NU personnel with

] by early 1998. appropriate training to support i transition from contractors in early 1998.

ll This is acceptable, provided

{ qualified individuals, either j contractor or NU are available to

meet ECP needs.

01-2I-98 01-21-98 CL() SED i

1 3 7/22/97 ECP Implementation i

i 8. ECP should complete its NNECo Letter 9/24/97 (B16685) Response is adequate. Training is being given and is

! Qualification and Training An admin control document was issued Aug.15 The requirements adequate.

j Process, w'th special emphasis describing the qualification and training ofintake contained in'the ECP l on: Intake .ncluding and investigative personnel. Seven mandatory qualifications document Qualification and Training records

!~ Reportability and Operability courses have been comptred by NU investigative may vary slightly frons are not complete or filled out in j determination criteria, and several contract individuals. what is stated here, but accordance with the stated i Investigation Training, and (B 16685-1) NNECo commits to conduct the are adequate. requirements.

! Report Writing. remaining three mandatory Employee Concerns program courses to be completed by ECP Adequate training in reportability investigative personnel by September 30,1997. and operability was provided on

_ (B16685-2) NNECo commits to familiarize ECP 10/29/97.

{. investigator?. with the ECP role in assessing i

potential reportability and operability issues by ~

The ECP Manual is still unclear on October 31,1997. .

the mechanics of transferring Also, by October 31,1997, the ECP Manual will operability and reportability issues to be revised to reflect the current ECP prac' ice of the line organization and recording

{' assuring operability and reportability reviews are the actions taken.

conducted by the line organizations for technical issues.

4

. 01-21-98 01-21-98 *

}'

Page 13 of 47 Remed I-26-98 9

1 ',

I e

, ,. . .ms,- - . - , , ,,_,,4. - - - - - , , , , - - ~.,-.mm . ~-e, . .- ,; - --, om a - , mb . . . L a- .-, ,

L_

Date, Source and LilC NNECo Response LilC Evaluation LIIC Effectiveness

. Recosninendation Determination The raentoring program NNECo Letter 9/24/971 he mentoring program ' LIIC has not received The mentoring program is not of 9.

between contract and NU employees has been 8/15/97 document to great current consequence since between contract and NU formal; zed in the administrative control [of evaluat,:. there are few NU personnel involved employees si ould be formalized and implemented. August 15) in ECP implementa ion.

_01-21-98 01-21-98

10. Program priosities should be NNECo Letter 9/24/97 On August 8,1997, the . Response is adequate. Based on LitC observations of ECP established through clear DECP issued a revised document containing the activities, priorities are now being vision, direction and agreement ECP Vision, the ECP Mission, and ECP Near adequately established and within the Department. Term Goals for 1997 implemented.

01-11-98 01-21-98 CLOSED NNECo Letter 9/24/97 The presence and Response is adequate. Director's presence has increased as

11. , increase presence and participation by both the Director, Employee verified by: I) Li(C observations; participation of Vic- President -

ofOversight and Program Concerns Program and the Vice President of 2) Level of Director signature on Nuclear Oversight (VPNO) have been increased ECP documents; and 3) Interviews Directar.

since the July 22,1997 meeting. of ECP people. VP's presence has also improved.

01-21-98 01-21-98 CLOSED

12. Finalize department NNECo Letter 9/24/97 (B16685) The ECP Response is adequate. Organizational chart has been issued orgar.ization has been finalized and a chart was . and the organization has been stable organization and program distributed to the ECP staff._ Regarding the ECP since early September.

documents and fully ,

implement. . program documen:s, Revision 2 of the ECP Manuai was issued on August 8,1997. The ECP will issue supplemental administrative controls, as appropriate, to address o"ier program enhancements.

01-21-98 01-11-98 CLOSED I-Page 14 of 47 Remed I-26 os t- ,

a, . . .

Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Determination

13. Impose discipline to NNECo Letter 9/24/97 (B 16685) ...w hen Response is adequate. LIIC Review of 24 ECP files during compliance with program Revision 2 was issued, the Director emphatically Sept and Oct of 1997 showed a vast documents. stated that the document was to be followed and improvement. Files are now meeting the ECP staff affirmed to the Director that they ECP Manual requirements.

understood and would adhere to the ECP Manual The Office Coordinator will assure file reviews i are conducted to provide increaud assurance that the documentation provisions of the Manual are satistied. 01-21-93 01-21-98 CLOSED l

l

}

w 1

Page 15 of 47 neused 126-9s iu. . a.m..---i

_ _ _ . . ~.- - -.

1 i

Date, Sonroc a.id LIIC NNECo Response LilC Evaluation LilC Effectiveness 1

Recouiniendation Determination

[ 14. Use of and reliance on other NNECo Letter 9/24/97 (B16685) We believe . Respcase is adequate for Current ECP Staffis handling IIR j organizations and lluman that the ECP staffis presently implementing the short term. investigations in an appropriate Resources investigations and prosisions of the ECP Manual for determining - ma:mer.

resolutions should be the adequacy of external reports in addressing implemented in accordance concerns. . an investigator from the iluman Approach is adequate for the short with ECP Rev.1, Sec. E.5, Resources organization and an investigator from term; however, a decision will bc j which requires o itside work to the Internal Audit Depanment have been needed regarding who investigates

be evaluated for adequacy. matrixed to the ECP. . .. They have primary llR issues brought to ErP over the j responsibility for conducting those investigations lang term..

formerly assigned by the ECP Department to the j Iluman Resources organization'.. .

j NNECo Letter 1 !/7/97 (B 16783) provides i ndditional inputs and commitments. (B16783-1) l NNECo commits to reassess the protocol j reen the ECP and IIR regarding the handling

.mployee concerns referred to llR by July 1, i 4 1998. tB16733-2) NNECo commits to reassess l l the practice of conducting periodic joint staff

{ meetings between ECP and site !IR by July 1, 1998. (B16783-3) NNECo commits to reassess the practice of ECP periodically sending a j representative to the regular site iIR site meetings a for the purpose of better understanding the issues j related to human resources that may end up as

! employee concerns by July 1,1998.

(B16782-4) NNECo commits to evaluate the g performance of the Executive Review Board in I

j. ensuring that personnel, both NNECo and contraciors, receive due process and that

[

. disciplinary decisions are consistent and not

! retaliatory by July 1,1998. Attachment I to j: B16783 provides additional details including: the i assignment of Bob Long as the iIR Recovery

• Offices and information of the Executive Review Board. 01-21-98 61-21-98 CLOEED O L t- '

t i.

Page 16 of 47 acused 126 98 i ..

I  !

.. . , - t

, , . .- . , , . . -n,,-- ,

l Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Determination

15. Files should not be classified as NNECo Letter 9/24/97 (B 16685) Concerns Response is appropriate Review of new files revealed "resolved"or " closed' without " resolved" or " closed" after June 6.1997, are and adequate. resolution and closure is now being meeting the definition in the required by the ECP manual to bas e appropriate in accordance with the hianual.

ECP manual. documentation in the Jile to support the status. .-

pre-June 6,1997 files will not be back fitted to

}

, include documentation. 0/-21-98 01-21-93 CLOSED

\

16. Employees should be kep' NNECo Letter 9/24/97 (B 16685) The ECP staff Response is adequate. File Review and contact with better informed on the status of is making a concerted effert . . to provide status concemed indis iduals (Cl s) indicate their case in accordance with reports to concernees at a minimum of esery .10 that h1anual requirements are still the manual. days until resolution . . Those contacts will be not always being met.

documented in the file. Periodic self assessments will confirm our efforts in this area.

01-21-93 01-21-98 l

17. Deselop a databr;. and NNECo Letter 9'24/97 (B16685) The ECP Database now contains Reports and information are being managemeat repens that will database now captures information on the source the information to provided to management. Special capture and provide useful and affected organization at the officer level. proside meaningful sorts are being used by ECP information to site h #1ership to .For relatis ely new concerns, the full range of reports to management. personnel and others (ex.. LliC) to enabic them to readily evahzate data has been entered into the enhanced database, Recent changes (Early assist their work.

important issues requiring Dec 97) expanded manacement attention. 8/23/97 (ECP-97-052) Pros ides additional capability to sort 50.7 Database is still not being used by information regarding the database update. The issues. ECP to m.Ae "hotspot" l

ECP database now captures information on the determinations as stated in NNECo's source and af fected organization at the Officers response bat im the capability.

Level. This information allows the ECP to make hatspot determir ations, as well as providing the capability to quickly provide a Nuclear Officer with informatien on concerns in the Officers' Organization.

9/24/97 (B 16685-3) NNECo commits that the ECP database will be updated to include the full range of data for concerns that were o n n as of December I,1996, and those concems opened thereafter, by January 10,1998.

01-21-98 01-21-98 Psge 17 of 47 Rcused 1 26-98

Date, Source and L11C NNECo Response LIIC Evaluation LilC Effectiveness Recommendation Deterraination

18. Implement the communications NNECo Letter 9/24/97 (I316685) The Manager, Response is adeqt. ate. Plan has not been implemented or plan. ECP Projects will assure the plan will be modified and there has been little to i.nplemented in a more coordinated fashion.. no communication to Millstone Subsequent priority attention will be based on personnel.

feedback from Peer R resentatives and Nuclear Communications.

j (G 16685-7) NNECo commits that ECP v ill communicate to Millstone personnel the status of the ECP and nature of concerns during the week of October 6,1997. 01-21-93 01 21 98

• 4 Page 18 of 47 Rnised 126-98 o

o. o.

Date, Source and LIIC NNECo Response LilC Evaluation LIIC Effectiveness Recommendation Determination 7/22/97 Management Support

19. All alternative management NNECa Letter 9/24/97 Common standards and Response is adequate. Concerns being received via the avenues available to employees criteria for processing concerns by all telephone are appropriately to raise concerns, outside of the organiza: ions handling emrtyce concernt were documented and included in the ECP Fmployee Concerns Program, implemented for ilR, Site Security, Internal Audit Monthly Report. Adequate should have a consistent and Security, industrial Safety and IIeal:h implementation.

mechanism to receise, process organizations and the hotlines. "The specific lists and resolve concerns. of organizations that handle employee concerns may change over time; however, any organizations added to the list will be subject to the common standards and criteria."

(B 16685-4) NNECo commits that concerns received over the telephone hotlines will be entered in the appropriate forms and captured in the ECP monthly report to of ficers.

01-21-98 01-21-98 Ci,OSED

20. All concerns should be NNECo Letter 9/24/97 (B16685) Response appears to Unacceptable.

evaluated for similar situations, Implementation of the common standards and focus on evaluating input generic implications and root criteria and use of the common form -.. will from alternative causes in a timely manner to enable the ECP to co!!ectively evaluate cencerns resolution organizations provide management with the received by alternative resolution organizations and does not focus on best possible insight into site and hotlines ... and enable the ECP to provide evaluation for common environment and activities. muagement with timely insight into site areas cause, etc. associated and activities needing their attention. with the items handled one at a time within ECP.

Guidelines do mt require or provide guidance on j

' evaluating similar situations or root causes.

01-21-98

• 01-21-98 Page 19 of 47 Reused 126-98

Date, Source and LIIC NNECo Response LIIC Evaluation LilC Effectiveness Recommendation Determination

21. Man gement should hase a NNECo Letter 9/24/97 (Il16685) There is a consistent process which will consistent process . . primarily consists of 1) the allow them to be informed of notification of the responsible [VPs] of the significant information existence of a concern in their area, and 2) the incidents, issues and esents. monthly ECP report to the officers... enhanced .

to include a monthly briefing of all officers on the ECP monthly report and periodic meetings on concerns activity b-tween the [SCWE[ Executive Sponsor and the [DECPj.

22. All levels of Millstone NNECo Letter 9/24/97 (1116685-5) management need to be trained NNECo commits that at the next meeting of first to develop the skills to line supervisors and abose, a presentation will be recognize and respond given to enhance the ability to recognize and appropriately to incidents that respond appropriately to incidents that could could cause or perpetuate a cause or perpetuate a " chilling effect", and that

" chilling effect" that could we will evaluate the need f or further training in prevent c.nployees from raising this area by October 21,1996.

nuclear safety concerns.

- Executive management should NNECo Letter 9/24/97 (1116685) Executis e Input from ECOP to management is kept apprized of work areas "Executis e" management be kept apprized of the existence of work areas that known or suspected to have a " chilling effect" or should M provided hostile work ensironment via the same process simult; iusly to all have been alleged or confinned as having a " chilling effect" or noted in Rec. 3. responsible officers (line)

" Additionally, the . . ECOP prosides executive as wcII as to the CEO.

hostile work environment so that they are able to better management with input on " chilling effect" and monitor and evaluate these hostile work environments as part of ECOP's situations. ongoing actisities" "The Executise Sponsor and Issue Manager for the [SCWE] hase initiated a continuing res iew of various data for indications of potential" pockets' needing management attention. . Additional management attention will be fccused on those areas having indications of problems." #1-21-93 Page 20 of 47 unua 126 9s h* D u_____

Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Determination 24 Criteria should be &veloped NNECo Letter 9/24/97 (B16685)" Management The response does not that will be consistently used to ic continually vigilant" with routine information speak to the identify or evaluate incidents or input, feedback from ECOP, Periodic Culture recommendation that allegations that a particular Surveys and Leadership Assessments. criteria be developed to working ernironment has identify erosion.

eroded to the point that employees are too demoralized to perform as expected. 01-21-93

25. Management must " walk the NNECo Letter 9/24/97 (B16635)" .. management ta!L" is evaluating available information to deal with pockets where managers and supervisors are contributing to a poor environment for addressing and resob ing employee concems"

" Management has . expressed a policy of zero tolerance for ... (IllRD) actions.. . we recognize more progress must be made to reduce the apparent distrust among our workers w hich is leading to concerns regarding lilRD aspects" 7/22/97 Case File Review

26. Increase management NNECo Letter 9'24/97 (B 16685) DECP has Response is adequate. Adequate.

expectations and ECP staff emphasized importance of adhering to ECP LIIC File Reviews in accountability to ECP Manual Manuai and has assured staff understands and is September & October requirements. committed to following the manual; staff verified improved and understands they are accountaale for complyirig. adequate implementation.

91-21-98 01-21-93 Ct.Osrn

27. Perform in-process and pre- NNECo Letter 9/24/97 (B16685) Office Response is adequate. Reviews being perforrred by ECP resolution. Coordinator will conduct pre- and post- office coordinator are nly for resolution resiews beyond that performed by the content. Implementation is investigative staff. " Periodic setf assessments w ill unacceptable, also address this area". 01-21-93 01-21-92 Page 21 of 47 ReuscJ 1-26 98

1 i

Date, Source and LIIC NNECo Resp <mse LilC Evaluation LilC Effectiveness j Reco uniendation . Determination

28. No file should be classified as NNECo Letter 9/24/97 (B 16685) No file will be 3 ECP Self-Assessments LilC review of files verified major -

resolved or closed without classified as " resolved" or " closed" without being were completed in improvements; however, some files .

. required review for reviewed for completeness and accuracy by the December. still show evidence oflack of review l j completeness and accuracy. investigative staff._ Periodic self assessments ' (Ex: 142,262,279, and 313.)

I will address this area.' 01-21-98 of-21-93

• i j 29. Establish a senior management NNECo Letter 9/24/97 (B 16685) The controls in Response is inadequate. ,See item #28 on this list.

l review panel to review resolved the revised ECP Manual are sufficient.

l files for the quality ofconcern Additional reviews are noted which assure evaluation, adequacy of effectiveness. ...we do not believe additional

disposition, and feedback to reviews are necessary.

concernees. 01-21-98 91-21-98

• J

30. Review those files resolved NNECo Letter 9/24/97 (B 16685-6) Response is adequate. Adequate.

, . since at least December 1996, NNECo commits to review ECP files classified LIIC Review of a sample

to assure allissues were as " resolved" or " closed" s;nce December I, (23 fi'es) of the files

properly resolved under current 1996 and resolse discrepancies by October 17, " redone" by ECP and 24 program definition. 1997. new files verified

Criteria for resolving discrepancies are provided compliance. ECP Self-in the res,onse. Assessment 97-EC-2 also .

NNECo Letter 10!!6/97 (B 16812) verified closure. ,

Letter advises that review is partially completed, L but will not meet committed date. Commitment

, revised to NNECo commits to resiew ECP files j classified as "resols ed" or " closed" since

December 1,1976 and resolve discrepancies by 1

November 14,190 F 1

l NNECo Letter i I/14/97 (B16853) changed the .

j 11/14/97 commitment date to 12/1/97.- 01-21-98 01-21-93 CIOSED 1TPOP 8/25/97 97-0028 ref ao I 1 8/20/97 Meeting with NNECo -

l Regarding Chilling Effect 1

i

)

i Page 22 of 47 Reuscd 126-98 t> . . -

4

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, r.,,,,- ,r wS,,,, v _-m, m-a--- . m -, , - , , -n, .- +- vwmv - - ----- ,,- ?

Date, Source and I.IIC NNECo Response LIIC Ev.duation LIIC Effectiveness Recommendation Determination

31. NNECo executi5e management NNECo Letter 12/29/97 (B1685 I) NNECo agree should take further immediate and has established an Executive Review Board action to contain the situation (ERB). Purpose of the ERB is..- ERB by assuring that the individuals membership consists of... The ERB reviews perceived as having the proposed personnel action w henever line authority to harm people who management belieses there is a need to take raise questions or have action at or above the level of written reprimand concerns cannot take action involving a company or contractors' .npioyce.

without some NNECo review Background information describing the action of those actions. The review being proposed and other appropriate information should take place outside the is to be provided by liuman Resources for NU affected management chain. employees and by the Contracts Administration Department for contractors' employees. The ERB also reviews contractor reductions in force.

i t This review will be either by reviewing the indis idual list of contractors (provided by the contracting companies) to be reduced or the methodology to be used with spot checks to ensure compliance with our requirements.

Excluded from this review are contractor releases l specifically related to pre-planned completion of I a known scope of work or managed task.

Page 23 of 47 Rmsca 1-26-(#8

4 S

Date, Source and LIIC NNECo Response LilC Evaluation LIIC Effectiveness

. Recommendation Determinatior.

32. NNECo executise management NNECo Letter 12/29/97 (B1685 I) NNECo i should take personal action to Senior Management, including the President and assure the MOV department CEO-Nuclear and Millstone Chief Nuclear j that the schedule constraints Officer, discussed these schedule changes with -

! impo^,ed on them will not be the Millstone management team (first line -

allowed to undermine the supervisors and above) at a meeting held on production of a quality product. November 5,1997. Senior Management Management also should gain emphasized durine i , meeting that concerns,

! an understanding of the depth including schedula ancerns, ned to be voiced j of the technical and schedule and raised up the m.aagement et a so the inputs

! problems within the on the schedule can be evaluated and adjusted if -

} organization. necessary.

I l- NU management is comme._ J to flexibility in the j schedule to ensure continued emphasis on i providing the required amount of time to i complete the work.

j

! 33. NNECo executive management NNECo Letter 12/27/97 (B16851) An NU j should develop and maintain a supervisor was appointed to replace the original close relationship with the supervisor (w ho was a contractor) in the MOV department in order to area, in August 1997 Also, the MOV team has counteract the chilling effect frequent meetings in which the employees are created by the series of asked to rabe any questions they may have terminations, demotions and related to the work environment. Furthermore, other actions by current - the NU supervisor has coinpleted the mandatory i management. SCWE training courses (Managing for Nuclear Safety and first two training sessions of 10 CFR 50.7)in December 1997.

ITPOP 97-0034 refIo 9/17/96 Meeting with NNECo on MOV i

}

i l

! Page 24 of 47 Resised I-2tW>s i

1

p. ...

1 1

l l

1 Date, Source and LIIC NNECo Itesponse LilC Evaluation LIIC Effectiveness llecommendation Determination

34. NNECo should immediately NNECo I ctier 12/29/97 (til 685 I) On September 26.1997, a

'*"'n8 was hclJ wath first hnc supenisors and abac.1hc develop and conduct focused purpose of the mecimg was to.1)cmphasiic senaw training for all supervisors, management's espcaatums regardmg estabhshmg a safety managers and the executive conscams weik crnironment and 2) educate the management team on SCWE related topics mcludmg recognizmg and management team on how to addremn8 chiHmg etTeasactaliatum, and contramw cm recognize EOtential retaliation cmpicyment issucs %e recogn c the trammg that uas and "c/ rilling cgcct. " how to provided during that mecting was not a!!-inciusne at =as not respond to these situations, and intendcJ to be) and theruore hase scheduled aJJitsmal t'3'ning classes These classes will be prosided tc the how to miticate the harm from

• • "*"'*'"'8'*'"'**""'h*"#*"**

events uhich confirm supenisors mcludmg contractor management NU is retaliation or " chilling effcct. " requirmg thcsc personnel to participate in a three-session trainmg program Session I classe were conductcJ in Nosember 1997, en groups of 20-30 participants. This sessum coscred the essential cicments of Jiscrimination and management actams to avoid. detect, and respmd to such claims. Session !! trainmg was conducted m groups of 20-30 participants in December 1997. T his sessam began with a diagnosue test ani fundamentals were remfaced, and idcotificJ weaknesses were remcJsated Durmg this sessum.

participants were also ponded traming m con het resolutum and cfTectnc hstenmg sk Us. Ten case studes were asailabic for discussmn One of these cases was descloped to melude issues relatcJ to MOV and trammg area issues. In additum.

lessons learncJ from the MOV issues base been conunumcated to employees through formal trammg courses NU News Releases and all-hands meetm s hnally, Sessne ill is scheduled for January 20,1993 This sessums uill take placc m a large group settmg. and site management uill aJJtess how the prmciples and attributes of a Safety Conscious Work Einironment (SCWE) will come together at Mdistonc lhe traming is desigucJ to proude the management team at Mdistonc Statum, with the necessary mformation to appropriately respond so cmployec concerns.

mimmize the potential for claims ofdncrimmatam. pres ent or mitigate a (hillmg c!Tect among others m the workforce, and to generally foster a safety conscious warL cnuronment Page 25 of 47 Reused 126-98 M

Date, Source and LIIC I NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Determination

35. NNECo should use the MOV NNECo Letter 12/29/97 (B16851) in November retaliation investigation and 1997, a case study was developed that findings as a " case study" to incorporates lessons learned from the MOV deliver" lessons learned" to the issue. The results of the actions taken to date on entire organization. this issue has e been communicated to the entire organization.

NU management believes that all the actions taken, including monitoring the effectiveness of the NU SCWE Plan and providing the required 10 CFR 50.7 training, will reduce the likelihood ofoccurrence of a similar event. As a result of these programs, NU management is acquiring the required expertise to mitigate the consequences of a similar event should it occur at Millstone.

Training programs for NU management are an ongoing activity.

Page 26 of 47 Rcused 126-98 S* ,  %

__ =

Date, Source and LIIC NNECo Response LilC Evaluation LIIC Effectiveness Recommendation Determination

36. NNECo should establish NNECo Letter 12/29r,1(B16851) The Contracts expectations and Administntion Department (CAD), including the accountabilities far the Legal Manager and Director-CAD, held a meeting after Department and the NNEC o the identification of the MOV retaliation issue Contract Administration (September 1997) to discuss the lessons learned Department to provide from this issue and to encourage a questioning additional barriers to possible attitude within the CAD.

future acts of retaliation. In addition, on October 24,1997, the Cad issued a self-assessment report to ensure that the factors that led to the MOV terminations are understood, and that process changes and training are implemented to preclude repetition. The self-assessment determined that communications within the Cad are effective in that problems and lessons learned information are shared immediately and are often worked on in a team environment.

Training will be provided to CAD management personnel to help them recognize and address chilling effects, retaliation, and contractor co-employment issues. Initial training was provided to supervisors and above at a meeting held on September 26,1997. Additional training is ongoing (this is the same training program indicated in response to Recommendation I above).

With respect to the Legal Department, in order to heighten their sensitisity to issues of retaliation and chilling effect, the NU Legal Department attorneys uho provide adsice on nuclear employment matters hase attended 10 CFR 50.7 training courses.

Legal counsel participates in the ERB. The Executise Review Board (ERB) will provide additional checks and balances to ensure that future disciplinary actions are not retaliatory.

Page 27 of 47 Remed I-26 98

(

Y

Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Determination

37. NNECo should cor.tinue to take NNECo latter 12/29/97 (B16851) The MOV actions to ensure that the group is being supervised by NU management.

employees in the MOV Group This change in leadership has changed th are willing to raise concerns environment in the group. For example, frequent and approach their positions all-hands meetings are held to fr ilitate group with a " questioning attitude." communications. In addition, executive level oversight is provided throughout the program.

38. NNECo should critically NNECo letter 12/27/97 (B16851) please see NU review the ability of the response to Recommendation 1 in Attachment I pronosed disciplinary review on the Executise Review Board (ERB) Charter panel's capability to provide the and responsibilities.

protection anticipated, formally Also, training was provided t execu'.ive institute the resiew panel, and management on October 3 I and December 17, ensure that persons on the panel 1997. The purpose of the training was to educate have the skills and the executive staff on what constitutes qualifications necessary to harassment, intimidation, retaliation, and make critical evaluations and discrimination (IllR&D) and the basic premise of judgements about proposed protected activities. T.aining for the ERB disciplinary actions to ensure members is ongoing and expected to be l that future esents such as the completed by January 31,1998. Until all ERB MOV terminations do not members are trained, an attomey w ho possesses r occur. the requisite skills and qualifications will participate in ERB meetings te help ensure that all relevant information is appropriately considered.

page 28 of 47 Reused t.h98 W , e

- __~__-_--_ - - _ _ - .

,,e ...

Date, Source and LHC NNECo Response LilC Evaluation LIIC Effectiveness Recommendation Determination

39. NNECo should ensure that the NNECo letter 12/29/97 (B16851) On September retaliatory actions taken against 25,1997, the manager of the Contracts the contract engineers are Administration Department (CAD) requested that obliterated, including assuring a review of the records of the two subject that the termination letters are individuals be conducted t ensure that the NU rescinded, that the security Not6ification of Termination does not indicate access records are restored and unfavorable terminations. A review of the do not reflect terminations"for security records was conducted between cause " September 25,1997 and October 5,1997, w hich indicated that the termination records did not t- show an unfworable termination status. On October 7,1997, the manager of the Cad, in two .

separate letters to the MOV contractors, retracted NU's letter WRC-97-022, dated August 7,1997.

The October 7,1997 letters stated that the services of the two contractors have been extended at Millstone and a revised purchase order to that effect had been issued.'

9/24/97 Corrective Action Program -

F Establish Priorities fo- Level I ' NNECo Letter 12/29/97 (BI6851) ,

This will be acceptable IF CR Actions That Reflect the Recommendation I response; RP4, Rev. 6, timely and effective Urgency of Avoiding Corrective Action Program, to be implemented by actions are taken for

. Recurrence and Ensure Jan 31,1998, stipulates higher levels of significant Level I Adequate Interim Actions. management approval for Level I corrective events. LilC's actions with longer term completion dates. All observation was that there Lesel 1 action plans require compensatory were few Level I actions to be in place until corrective actions are corrective actions to implemented, These expectations are monitored prevent recurrence by the approving Director and the Management implemented for events Review Team (MRT). that continued to occur.

01-22-98 L Page 29 of 47 Revned 126-98

Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Determination

41. Provide an Accountable "CR NNECo Letter 12/29/97 (Ill6851) Acceptable.

Owner" for the Implementation Recommendation 2 response; RP4, Rev. 5, Phase of Each Level I CR; implemented 9/30/97, establishes CR owners for Establish and Communicate CRs, accountable for action plan development Expectations for"CR Owners." through implementation . Expectations are spelled out in the procedure and training.

e 01-12-98

12. Proside Increased hianagement NNECo Letter 12/29/97 (Il16851) This may be acceptable Attention to implementation of Recommendation 3 response; RP4. Rev. 5 directs depending on Corrective Actions for Level I that the h1RT evaluate, approve, and approve implementation. LilC's CRs; Improve hionitoring of changes to Level I CR action plan actions and recommendation was Implementation Efforts and of due dates. The MRT is apprized of overdue focused on the need to Corrective Action actions. Upon action plan completion , CR provide increased Effectisene,s. owners report on effectiveness to the h1RT. management attention to getting corrective actions for Level I CRs impicmented.

01-22-98

43. Coordinate Actions on CRs NNECo Letter 12/29/97 (1116851) This may be acceptable That flave Common Causes Recommendation 4 response; Common causes depending on (And Provide Improved are identified in the trending process implementation Analytical Capability for implemented on o/30'97. Organization Trend demonstreing the ability Identifying Such Causes). Coordinators hase the anal)tical tools fbr to w rap existing and new identifying the causes. Appropriate management CRs into this trend will receive results through trend reports for evaluation.

action. For Station lesel common causes, the Site h1RT will propose an issue manager to coordinate response to the identified cause.

01-22-93 Page 30 of 47 Rcused 1-N-98 9 y e

i l

1 Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Cffectiveness Recornmendation Determination

44. Increase Managersent Attention NNECo Le? e 12/29 97(B16351) It is acceptable to handle to Resolution of Oversight and Recommenhn 5 response; Osersight and self- Oversight and Self-

Self-aeunent Findings. assessment fmdings are reported using CRs and assessment findi..gs

u resulting action follows the nomul CR prccess. CRs. L1IC's point was j Action plans developed to address the Oversight that the fmdings uere CRs are not dunged w ithout Oversight's accurate and, if acted con urrence. upon, could presear

adserse conditions from

occurring. Increased management attention should be prosided to assure that appropriate priorities are applied to correctise actions.

0 93

45. Pros ide Adequate CR Context NNFCo Letter !2/2997 (B16851) Tnis does not appear to Information to Personnel Who Recommendation 6 response; CR Owners are acceptably address the Are Given Corrective Action assigned to develop complete action plans for recommendation. The Assignments. CRs and are knowledgeable of CR context. response does not ensure Cos dise Action Coordinators are available to that an mdisidual i assist each manager in getting iiformation from assigned to implement an the CR Tracking Database. action receives any information other than the single action statenwnt.

01-22-93 ,

$ 46. Moci5 Program Guidance Yo: NNECo Letter 12/29 97 (B1685I) Guidance contained in 462. t.imit the Number of Reconunendation 7.1 response; CR caners use referenced .nemorandum C wrectise Actions for their judgement of value' resources in descloping is acceptable. Ilowever, Lesel 2 CRs (Aw.J a action plans. MP3-CAD-97-064, I I/13/97, this informa ioa aceds to

-Fis' for Esery C ause). prosi&s guidance for Lesel 2 CR imestigations be controllea m such a to identify specific issues, correct and trend them manner that it is directly referenced in the

procedure.

01-22-93 Page 3! of * , Reused 1-26-98

Date,Soure:and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Reconnu.endation Determination 46b. L.imit the Numbei of NNECo Letter 12/29N7 (f!I6351) Acceptable pending Correctise Actions for Recommendation 7.2 response; CR owners use resiew of RP4 Rev. 6.

Lesel I CRs to theirjudgement of value' resources in developing Significant Causal action plans. Guidance will be provided in RP4, Factors. Rev 6., to focus correctise actions on root c:.use and related causal factors. Other causal factors should be addressed by writing separate CRs.

Directors and MRT provide osersight to ensure appropriate correctise action scope <

O!-22-93 46c. Justify Waivers of Root NNECo Letter 12/29,97 (1316851) Acceptable.

Cause Evaluations. Recommendation 7.3 response; RP4, Rev. 5, 9'30.97, prosides guidance that requires justification for waivers of Level I root cause evaluations.

-i 01-12-93 46d. Do Not Permit 30 Day NNECo Letter 12/29 97 (Il16351) Acceptable, de~ wiing on tmestigation Recommendation 7.4 response; The process practice. tlc process Requirement to impact allows extensions ofinsestigan a time, with allows extensions. but the Quality of satisfactoryjustification to MRT. does not emphasize the Significant management expectation Imes-igations. to put quality before schedule.

l 01-22-93 1

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48. Increase Con * : With NNECO Leuer 1/21/98 (B16958) ECP Response is adequate. Recent customer inputs regarding Empleces Throughout the recognized the need for improved contact with satisfaction has improved from 50% t Process, Panw ntvly at the Concerned Individuals (Cis) and began an to 83% Will continue to monitor j] Pr olution;Obtam Employee improsement program in U cember 1997. An this area. }

} Feedback at Resolution. initiatise at that time was to ; gin s esiewing 2

preliminary investigation find.%s with the Cl. l The ECP has established a practics. of meeting with the CIs prior to resolving thei concerns wheneser the CI is physically available. ,

j Otherwise, contact will be made by phone when j possible. Additionally, the ECP goal is now to

{ contact the Cis every 15 days vs. 30 days. ,

j Furthermore, the ECP is expressing greater i appreciation and empathy to the CIs for their  ;

! concern by assurmg all letters to the Cis are more l

! personal and clear. If a concern cannot be or wm not substantiated, ECP wi!! use more respec;ful language in explaining the rm These j impros ements are expected to increase the general satisfaction lesel of CIs and will be -

reflected in Revision 3 of the ECP Manual which j will be implemented by February 27,1998. el-22-9a 01-26-98

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Date, Source and LIIC NNECo Response LHC Evaluation LIIC Effectiveness Recommendation Determination

54. Require Concerns With NNECC Letter I/21/98 (B16958) A CR will be Response is adequate.

Operability or Reportability initiated per RP-4,-Corrective Action Program "

Potential to Be Documented on for concerns hasing an operability / reportability CRs, potential. This will either be accomplished by the line or ECP and the CK number will be reflected in the ECP concern file. This practice will be reflected in the ECP Manual Resision 3 to be implemented by Febmary 27,1998. 01-22-93

55. Ensure That Common NNECO Letter !!21/98 (B16958) The common Response is adequate.

Guidelines Are Used by All guidelines (Joint Investigation Guidelines) w ere Organizr. tion- Processing appros ed for use by NU investigation bodies.

Concerns The Executise Sponsor of the NU Compliance

, Group will conduct an assessment by January 31, 1998 to ensure the guidelines are being

., implemen:ed by organizations processing concerns. 01-22-93

56. Classify, Count and Track NNECO Letter 1/21/98 (B16958) The ECP will Response is adequate. ECP Monthly Report now tracks individual issues From Multi- modify its process to commence tracking and individual issues.

faceted Concerns As Indisidus! counting indis idual isst.es as they are received.

Concerns. This practice will be reflected in Revision 3 of the ECP Man ol w hich will be implemented by February 27,1998. 01-22-93 #1-22-93 Ct.OSED Page 37 of 47 Remed I.26 98

Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Recorntnendation Deterinination

57. EnsureOff-siteContractor b'NECO Letter Ie2I/98 (R16958) Current NU Response is adequate.

Requirements Are Nuclear contracts include general terms and Implenaented. conditions u hich detail contractor responsibilities beyond the specific scope of work to be performed Item 17 of the General Terms and Conditions, entitled -Contractor Employee Protection " provides detailed requiresnents  ;

regarding contractor employee protections uhich must be assured by contractors and j subcontractors. Efforts to ensure compliance with these contract prosisions are in progress.

' Requests for information regarding program status were sent to over 100 contract.-

organizations on October 15.1997. Each contractor was requested to proside information on their 10CFR 50.7 compliance program.

Contractors were also informed of the formation of the Millstone Executive Resiew Board which would be review ing all discipline at or above the level of written reprimand prior to implementation to ensure, among other .hings, no discip'he was in retaliation for engaging in I protected activity. To ensure contrr.ctors l

continue to place proper emphasis in this area, 1 NNECo will transmit a tener to its contractor organizations on an annual basis. The letter will remind them of t!.eir responsibihties for employee protection against retaliation and for advising their employees and subcontractors that the NNECo ECP is available to them as an ahemate resolution path for raising safety concerns in matters invohing tiilistone Station The first annual letter will be sent to coatractor organizations by January 31,1998. 01-22-93 Page 38 of 47 acusca 126-93

o. .

Date, Source and LilC NNECo Response LIIC Evaluation LilC Effectiveness Recommendation Determination

58. hhwiify the Exit Process to NNECO Letter 1/21/93 (B16958) All contractors Response is adequate Assure All Contractors Receive will continue to be given the opportunity to has e an Exit Intenicw. an exit inteniew with the ECP. Rather than requiring contractors to receive an exit interview, the contractors will be asked by their employ ers to sign an NU forr' (Contractor / Vendor Out-processing Checklist) stating that they;

- have been afforded the opportunity to have an exit mteniew wnh the ECP,

- do not h.ne any knowledge of any undocumented deficiencies or concems at htillstone Station, and

- hase been provided with a phone number and addre<s to provide any additional information they may recollect after leasing hiillstone Station.

This NU form is retaincd by hiillstone security.

This process is currently being implemented and the above NU form will be incorporated into a res ision to procedure -Procurement and Administration of Contractor Services"(OA-13) by February 6,1998. #1-12-93 59 Improse ECP File Security in NNt!CO Letter I/21/98 (B16958) To improse file Res;onse is adequate. Respo.2 has been implemented as Annx2. security, effectis e Nosember 13,1997,the Annex serified by observations of annex's I and 2 doors are kept locked at all times. Signs being labeled.

hase been placed on both sides of the Annex doors to ensure the doors remain licked for file securitv purposes. Guidance will be issued, and controlled equivalent to ECP manual, reflecting these ECP file security practices by February 27, 1998 #1-22-93 01-22-93 Cl.OSED Page 39 of 47 Rn rwd 1-26-93

i i

l 1 Dase, Source and LHC NNECo Response LHC Evaluatian LIIC Effectiveness

' Determination

"-- mmendation i i

60. Implement ECP Staff NNECO Letter 1/21/98 (B16958) ECP staff Response is adequate.

j Qualification Review and qualitication and documentation were reviewed

] Dv m at=' ion Requirements. during a fourth quarter self-assessment.

Deficiencies regarding the Director's approval of 4 contractor ir.vestigator qualifications have been I

corrected. To ensure that the ECP is m t f compliance wit'n ECP staff qualification review j and documentation, all other deficiencies will be

! correctal by February 27,1998. 01-22-98

61. hianual Should Clearly Define NNECO Letter I/21/93 (B16958) The ECP tias Response is adequate.

Required Chronological Log heightened the awareness of their investigators; Entries (e.g., Employee however, the ECP will provide guidance in ,

Contacts, CR #'s, Triage.) Revision 3 of the ECP hianual to be implemented by February 27,1998, regarding chronological log entries. 01-22-98 l I1/13/97 Coasprehensise Plan i ElTectis emess

}

i 62. NNECo hianagement hiust NNECO Letter I/21/93 (B16958) NNECO ,

j Provideleadership to Correct management recognizes the need to provide '

1 Problem Areas in a Timely leadership to correct problem areas in a timely i Atanner manner To accomplish this, the Problem Area (PA) Phn will be formalized, and controlled, by l 4 February 19,1998, to ensure a consistent and ,

i thorough approach in resolving the pas and will i i include the following clenwnts: '

- Receive senior management review to ensure that each issue is being appropriately addressed.

) - Ensure that each PA is prioritized, and that i Action Plans are monitored and  !

} cffectiseness re,iews are performed.

l - Specify that the PA Action Plans are tightly

{ controlled to ensure confidentiality.

2

{

}  ;

f Page40 of 47 ' Remed I-26-98 l ' . j l

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Date, Source and LIIC NNECo Respon.;e LIIC Evaluation LIIC Effectiveness Recommendation Detertnination

63. Deselop Improsed h1echanisms NNECO 1.etter 1/21/98 (B 16958) Effective Response is adequate.

for Communicating, Decenhr I,1997, an organizational change was Coordinating and Effectisely made, which among others, changed ECP to Acting on Information Betw een repon from the Oversight Organization to ht.II.

ECP, ECOP, SCWE Group and Broth rs, Vice President-Operations and hianagement. Executive Sponsor of the SCWE. Al.II. Broth rs has included ECOP in daily meetings with the SCWE and ECP senior staff to discuss issues related to SCWE and problem areas resolution.

Typical anendees at the daily meetings are the Executis e Sponsor-SCWE, SCWE Issue hianager, liuman Resources representarise, Director-ECP, ECOP Chairman, and various personnel from the represented groups. These actions has e facilitated the communications among SCWE, ECOP, and ECP staff. 01-02-93 M. Narrow ECOP Activities to NNECO Letter I/21/98 (b16953) Based on Response is adequate.

Focus on Greatest SCWE meetings held with Bruce Kenyon on Nosember Needs of the Organization in a 4,1997 and Little !! arbor Consultants on l Timely h!anner. November 21,1997, ECOP is focusing its effons on IllRD issues and reponing on a real time basis.

AJJitionally, the Executise Sponsor of the SCWE has included ECOP in the daily SCWE meetings, funhering the coordination of the ECP, SCWE team, and ECOP actisitiet. During tiese l

meetings, the Executive Sponsor-SCWE has requested ECOP to investigate areas / issues that need immediate at ention (e g., ECP satisfaction index). #1-22-93 Page 4I of 47 acusca t.h9s

n.

Date, Source aad LilC NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Determination

65. Communicate ECGP Findings NNECO . - ter 1/21/93 (B16958) ECOP is Response is adequate.

and Rec =mmbrions on a communica. ng its findings (predominantly) with Real Time Basis to ECP, the the SCWE team as they are discoscred.

SCWE Group and Line Similarly, information is shared w ith Iluman Management So They Can Act Resources on issues relating to their functions, on the Results. while information such as cost control center specific survey data are shared with respective i

line officers soon after suney comple: ion.

f The daily SCWE meetings hase provi. fed a forum for timely exchange of information among the f ECP, SCWE team, IIR, and the ECOP representarises. 01-22 93 l

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Date, Source and I.HC NNECo Response LHC Evaluation LHC Effectiveness Determination Recominicadation

67. Improse ther PTraining NNECO Letter I/21/98 (B16958) He number el Response is adequate.

SegmentIncia. ?n persons presenting the ECP segment in the Atanaging for N. 's Safety." h1FNS has been reduced to improve the consistency of delisery of the lesson plan message. Whenever possible, the ECP Director or his senior staff will conduct the training.

Additionally, the lesson plan (FS 0004/FS 0034) will be improved by February 27,1998. This will be accomplished by inca.rporating lessons leamed and other des elopments during the past year. 01-22-93

68. Resume Employee Training on NNECO Letter 1/21M8 (B16958) Re Nt. clear This training includes an Acclimatiution training course restarted on ECP training segment SCWE and ECP.

Nos ember 24,1997, and is being presented to which is approp :ste. It facility personnel as a complement to hianaging does not, but should for Nuclear Safety and Civil Treatment for cor.tain training on hianagers receised by line management. He SCWE expectations for Nuclean Acclimatization training course consists employees.

of two parts:

- IWip Beyond 2000

- Civil Treatment for Employees #1-22-93 ITPOP 12/10M7 (97-0055) ECP Files Addressang 50.7 Issues

69. Reopen and reinwstigate ECP NNECo Ictter I/09N8 (B16949) Files 142,262 &

files 142,262, and 313. Rese 313 will be resiewed and reinvestigated as files uere closed on the basis of neem To resolve any noted deficiencies EC. r I1R invest.gations into related to adequacy or completeness will be allegatior.s ofretaliation that completed by 2/27M8.

! were inadequate or Lwomplete.

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• Date, Source and LIIC NNECo Response LIIC Evaluaiian LIIC Effectiveness Recommendation Determination

, 70. Modify the ECP intake NNECo letter I/09.93 (B16949) A preliminary

. procedure to require a determination of whether a concern contains an preliminary determination of element of potential retaliation (ie 10CFR50.7 whether a concern contains an violation) is now being made in the Triage element of potential retaliation, process. His practice will be reflected in Rev.3 i.e.,10 CFR 50.7 violations. to the ECP Manual w hich will be implemented following the Triage of the ECP staff by 2/27/93

71. Where it is determined that a NNECo letter 1/09/93 (B16949) ne ECP has potential violation of 10 CFR instituted the practice ofinitiating a chilling i 50.7 exists the ECP and or the effect evaluation at any point in the p.ocess

) SCWE effort insures that an uhere it is determined that a concern could

immediate chilling effect" invohe a potential violation of 10CFR50.7. This evaluation is conducted. practice will be reDected in Rev. 3 of the ECP Manual which will be implemented following Triage of the ECP staff by 2/27/98.

9/24/97 'Observatioru" l

Page 45 of 47 Rcusca t.259:

n Date, Source and LIIC NNECo Response LIIC Evaluation LIIC Effectiveness Recommendation Determination

72. Vice President ofOversight NNECo letter 12/2987 (1116s51) EtTectae occcmber I, Response is adequate. Effective. No further evaluation 1 the EEP an repatm i e brother \ Recent organizational required.

continues to demonstrate less ,

than expected visibility and ,,t amtuu c to Jenunurate his suppwt fin the ECP through changes also impact the mteractsans with the ECP sta!T. The faloming mfismatmun r, ,e importance of Ele support of ECP progrant relates to the suppwt of the ECP by the Vice Prc adent of y ,

Nuclear Oversight (VPNO) when sie VPNG had icsponsibitsty for the ECP.

f IIC recorns-a.* -J m its July 22,1997 presentaram that NNECO anerc:be the presence and participatam of the VPNO in the Employee Conecrus Program Regardag the VPNO supows of the ECP, the NU respmse Jescnbcd the actam by the VPNO m rebesang the Ducctar, ECP(DECP) of the segmrement to atterd sescrat perkxhc statT mectmgs not Jacctly retarm; to the ECP. That had a cicar and segmficant unpact on accasung the day-to-Jay Jctuled mwAcnwns of the DELP m i CP actsutss The VPNG promph and favorably resemded so all requests f.w aJJammal ECP resources and frequently inquircJ if there ucre aJJaumal accJs av other ways he could supswt the ECP. Furtlwrnswe, the VPNO mas the instaat.w of actants to firmulate impraed pcismance andacators and was m.unately inwiscJ m thew Jewtopment. In summary, the VPNG inmisement m and sag gwt of the ECP was clear 13 dermuwtrated by these exampics The NU response also Jescribed the perstmal inscractum between the VPNO and the ECP statf and the mctusam of the ECP staff a the VPNO nuvahlv Nuclear Oscrsight a!!-hands sectag Ttuvsc measures contmurd and the VPNG permwhcally atacaded ECP mectmgs m addsrum to the VPNO simmthly all-hands meetsng T?uwe were part of the mcrrl!

VPNO ctTivt to get in the field to Lecp abreast of thmgs unpetant to tus staff, to Jenamstrate support. and to CI,041 0/-26-93 014/#-93 j strwthen trw a senaw weiswn:

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