IR 05000245/1998217
| ML20202J366 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/22/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20202J304 | List: |
| References | |
| 50-245-98-217, 50-336-98-217, 50-423-98-217, NUDOCS 9902090114 | |
| Download: ML20202J366 (19) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Docket No ,50-336, and 50-423 Report N t License No DPR-21, DPR 65, and NPF-49
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Licensee: Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385 Facility: Millstone Nuclear Power Station Dates: October 26-30,1998 Team Leade Helen N. Pastis, Senior Project Manager Evaluators: Robert DeFayette, NRC Consukant Steve Dembek, Project Manager for Millstone Unit 1 Richard Urban, Millstone Project Engineer, Region i Approved by: William M. Dean, Director, Project Directorate 1-2, NRR Helen N. Pastis, ECP and SCWE Oversight, Senior Project Manager 9902090114 990122 PDR ADOCK 05000245 G PM
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TABLE OF CONTENTS Page
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Ex e cutive S ummary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
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' Purpose of the Employee Concems Program Evaluation . . . . . . . . . . . . . . . . . . . . . . 1 Review Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 l
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! Composition of the Team . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Backg round . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
h Evaluation of the Employee Concems Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Employee Concems Oversight Panel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Safety-Conscious Work Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 i
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. . . . l l EXECUTIVE SUMMARY
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- On October 24,1996, the Director of the Office of Nuclear Reactor Regulation issued an Order to Northeast Nuclear Energy Company (NNECO), the licensee for Millstone, requiring establishment of (1) a comprehensive plan for resolving the Millstone Station employees'
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! safety concems, (2) an independent third party oversight organization, and (3) a plan
developed by the inde. pendent third-party organization for overseeing NNECO's
- implementation of the employee concems program (ECP) plan.
} A team was formed to evaluate whether NNECO has improved sufficiently and has i demonstrated sustained performance in maintaining a safety-conscious work environment 1 (SCWE) to allow NRC to close the Order, and whether the conditions that led to the
! requirement of the third-party oversight have been corrected at Millstone. On December 8-12, j
1997, and January 5 9,1998, the NRC conducted its first team evaluation of these programs.
On August 24-28,1998, the NRC conducted its second team evaluation. On August 24-28,
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1998, the NRC staff evaluated the Millstone ECP and the SCWE program to see if the
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improvements that had been made in support of restart of Unit 3 had been sustained. The l team found the ECP and the SCWE program had maintained the improved level of
performance; however, it concluded that it needed to conduct another evaluation to monitor j the following eight issues:
l (1) an emerging personnelissue that developed within the ECP organization during the week
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) (2) implementation of plans for, as well as the ability of, Human Resources (HR) to assume
] some of the ECP workload, as outlined in NNECO's Transition Plan
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(3) the Employee Concems Oversight Panel's (ECOP's) new role to assess ECP's effectiveness and how some of the other ECOP functions will be incorporated within the SCWE and HR function (4) the effect on the SCWE of the transition of the site from a recovery organization to an operating organization (5) the effect on the organization's effectiveness of the recent transition to a new Vice-President of Human Services (6) the pending Millstone site-wide management reorganization (7) plans for oversight of the SCWE to replace the rois of the third-party oversight organization (8) long term plans for the SCWE training program that had not yet been finalized On October 26-30,1993, the NRC conducted its third team evaluation to assess NNECO's progress in these eight areas. In this evaluation report, the staff discusses the results of the il
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October evaluation. The team attended meetings, interviewed personnel, reviewed pertinent l information, and observed various training sessions. The team members were Helen l Pastis, Team Leader; Robert DeFayette, NRC Consultant; Steve Dembok, Millstone Unit 1 :
Project Manager, and Rick Urban, Region 1 Project Engineer. Everyone on the team had also participated in the previous evaluations. The team used as guidance Inspection Procedure (IP) 40001, " Resolution of Employee Concems." Overall, the team determined that adequate progress had been made in every are The evaluation also served to support the staff's observation that NNECO continues to I improve the SCWE at Millstone. The overwhelming majority of employees are willing to raise concems and, of those who have used the ECP, only a relatively few stated they would not i use the program again. Management has shown it is willing and capable to immediately become involved in resolving problems and concems as they arise, indicating that the 1 programs in place are working. Further evidence of this is that LHC has stated that, although it l is involved in assisting NNECO in responding to and resolving concems, it is not involved nearly as much as it has been in the past and believes it has approached the time when it is not needed for third-party oversigh l l
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j EVALUATION DETAILS l
1.0 Puroose of the Emolovee Concems Proaram Evaluster, I
To evaluate whether Northeast Nuclear Energy Company (NNECO) has improved sufficient! /
and has demonstrated sustained performance in maintaining a safety-conscious work environment (SCWE) to allow the NRC to close the October 24,1996, Order, and if the conditions that led to the requirement of the third-party oversight have been corrected at .
Millstone Nuclear Power Statio .
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On August 24 28,1998, the NRC staff evaluated the Millstone ECP and the SCWE progra The team found the Employee Concems Program (ECP) and the SCWE Program had maintained the improved level of performance; however, it concluded that it needed to conduct l
another evaluation to monitor the following eight issues: '
(1) an emerging personnelissue that developed within the ECP organization during the week of the NRC's evaluation (2) implementation of plans for, as well as the ability of, Human Resources (HR) to assume some of the ECP workload, as outlined in NNECO's Transition P,'an
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l (3) the Employee Concems Oversight Panel's (ECOP's) new role to assess ECP's effectiveness and how some of the other ECOP functions will be incorporated within the SCWE and HR function (4) the effect on the SCWE of the transition of the site frorn a recovery organization to an operating organization (5) the effect on the organization's effectiveness of the recent transition to a new Vice President of Human Services (6) the pending Millstone site-wide management reorganization (7) plans for oversight of the SCWE to replace the role of the third party oversight organization (B) long term plans for the SCWE training program that had not yet been finalized On October 26-30,1998, the NRC conducted its third evaluation to assess NNECO's progress in these eight area .0 Review Methodoloov The team used as guidance inspection Procedure (IP) 40001, " Resolution of Employee Concems." During the week of October 26-30,1998, the team attended meetings, interviewed people, reviewed pertinent information, and observed various training sessions.
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Page 2 of 15 The team incorporated the information that was available to it during this evaluation and considered the latest information before issuing its report. Regarding evaluations of SCWE eiements, information obtained from onsite monitoring of activities, both before and after the team's evaluation, were used to supplement the findings in this repor On November 24,1998, the team leader held a public exit interview with NNEC .0 Comoosition of the Team The teem was led by Helen N. Pastis, who is a Senior Project Manager in the Office of Nuclear Reactor Regulation (NRR). Robert DeFayette is an NRC consultant and a former Director of Enforcement and Allegation Programs in Region 111. Stephen Dembek is the Millstone Unit 1 Project Manager. Richard Urban is the Region i Millstone Project Enginee .0 Backaround On October 24,1996, the Director of NRR issued an Order to NNECO, the licensee for Millstone, requiring the development of (1) a comprehensive plan for handling the Millstone Station employees' safety concems, (2) an independent third party oversight organization, and (3) a plan prepared by the independent third-party organization for overseeing NNECO's implementation of the comprehensive pla The NRC staff has performed the following activities to ensure that NNECO's programs for handling safety concems and the independent third party organization program (ITPOP) will be effectively implemented:
Reviewed the Millstone employee safety concems comprehensive plan for reviewing and dispositioning safety issues raised by employees of NNEC *
Approved the selection of the ITPOP organization to ensure that the organization was comprised of qualified individuals who would conduct the review adequately and independently of NNECO. .The ITPOP organization would oversee the implementation of the NNECO EC *
Approved the ITPOP plan, which was used to audit the implementation of the Millstone ECP. The ITPOP review was to be comprehensive, incorporating appropriate audit and technical disciplines so the NRC could be confident that NNECO was been thorough in identifying and resolving employee safety concems at Millston During its January 1998 evaluation, the team found that NNECO had not sufficiently developed plans to address actions for maintaining and enhancing an SCWE beyond the restart of a Millstone unit. Specifically,in its planning documentation, NNECO did not address processes for maintaining the ECP and SCWE Program infrastructure, monitoring performance (including recognition of pregram degradations), and phasing out oversight orgs9zations.
I in February 1998, following the onsite team evaluation, NNECO provided the NRC with its document, " Progress Toward Restart Readiness and Long Term improvement at Millstone
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. Page 3 of 15 Station." The plan identified key perfom1ance indicators end self assessment activities that would be used to continue monitoring performance at Millstone. NNECO organized the plan into five strategic areas: safety, operating excellence, work environment, organization effectiveness, and extemal relations. SCWE is one of three subsections of work environmen However, the plan was preliminary and incomplet In a March 31,1998, letter, NNECO submitted plans, commitments, and actions for monitoring and maintaining an SCWE past the restart of Millstone Unit 3. Attached to that letter was the
"1998 2000 Performance Plan for the Work Environment Area." The SCWE portion of the work environment area identified a set of actions to implement the future transition of various functions and work groups from the current recovery organization to a future operational organization. On April 24,1998, NNECO supplemented its March 31 letter with a more detailed discussion of the organizational changes, the decision-making process, and the performance measures that NNECO planned to use to guide that transitio On April 24,1998, the staff forwarded to the Commission SECY-98-090, " Selected Issues Related to Recovery of Millstone Nuclear Power Station Unit 3." In that paper and in a May 1, 1998, meeting with the Commission, the staff concluded that NNECO had sufficiently improved its ECP and SCWE to support restart of Unit 3. The staff noted that it anticipated that
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continuation of the third party oversight would be required for 6 months beyond restart to allow for evaluation of the licensee's continuing performance in the ECP and SCWE Program area .0 Evaluation of the Emolovee Concems Procram
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Two of the eight followup issues were associated with the EC Issue No.1: Personnel issues that developed within the ECP oraanization in the August 1998 evaluation, the team noted that it was going to continue to monitor personnel issues that had developed within the ECP organization during the week of its evaluation and any other issues that may emerge in the near term. During the October 1998 evaluation, the team noted that the ECP handled these issues well, including not only the issues that emerged within the ECP organization itself but also another site-wide issue involving NNECO managemen In addition to the issue that emerged in August, another issue emerged later involving the Vice-President of Engineering Services and the "Audix" issue. Concems were raised regarding the pending reorganization selection process and the potential that it may be used to benefit an Individual the Vice-President knew through his previous employer. NRC staff monitored NNECO's activities and relied on LHC's oversight to follow the resolution of this issue. When the team retumed in October, it discussed with the ECP investigators the course l
taken by the ECP to investigate this issue. NNECO assigned the investigation to the Director of the ECP and to the ECP Manager. This created a potential conflict of interest because the
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Director of ECP previously reported to the Vice-President of Human Services. In addition, the '
ECP Director's current vice-president also was involved with the issue under investigatio The ECP Director told the NRC team that he recommended an outside investigator be hired for this issue because of the apparent conflict of interest. However, NNECO determined that it
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needed a more timely response to the concem and instead instituted compensatory measures (mainly additional levels of review) to address the potential conflict of interes The team interviewed all of the available investigators as part ofits assessment of the licensee's handling of the investigation. Most of the investigators believed that the investigation should have been performed by either an outside investigator or by one of the contract investigators currently working for ECP. Some ECP investigators were skeptical of the rationale provided by their management regarding assigning the investigation to the ECP managers, and some investigators felt it suggested that they were not good enough to handle it themselves. Additionally, while some of the investigators disagreed with some of the conclusions reached by the ECP managers, most of investigators did agree with the overall .
conclusions. Although some negative aspects were voiced by some investigators, the team, l
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as well as LHC, believes that NNECO conducted a fair and professional investigatio The team also followed up on an issue regarding a disagreement between an ECP investigator l and his management. The team found that the licensee is addressing this issue through i mediation. The team found the mediation process to be an acceptable resolution metho l During the evaluation, the ECP Director announced to his staff that he would be leaving Northeast Utilities (NU) at the end of the year for personal reasons. Additionally, the two ECP manager positions will be rebid as part of the licensee's site-wide reorganization. Because of I the planned and potentialleadership tumover, the continued success of the ECP will depend ,
on the continued support of senior licensee managemen '
Issue No. 2: Human Resources to assume some of the ECP workload in August 1998, the NRC staff noted that the ECP and the HR organizations continued to work '
together closely and effectively, and shared information to the benefit of both organization The team stated that it will continue to monitor the plans for, and the ability of, HR to assume some of the ECP workloa During its evaluation, the team interviewed all the ECP investigators, ECP managers, and the HR Director, and observed HR and ECP staff meeting The NRC team found the plan to have HR assume responsibility for investigating all HR-related concems stillin the early stages of development. A draft plan was developed and management reviewed it, but the transfer of most of the pertinent responsibilities was not planned to take place until after the restart of Millstone Unit 2. Because the licensee has not significantly progressed in this araa since the last evaluation, the team was unable to conclusively assess this are Conceming the sharing of information, the team found some inconsistency in the level of cooperation between the HR and ECP staffs since the previous evaluation. The ECP and the HR directors stated that they would meet to discuss the issue and to work on a long-term solution that would include developing written guidance on the type of information to be shared between the staffs. During a subsequent meeting with the HR Director, the team found the HR Director willing to work with the ECP Director to resolve the recent conflicts between the ECP and HR staffs. Because the transfer of responsibilities is not imminent and the ECP and the
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. I Page 5 of 15 HR directors are working together to address the issue, the team believed that the licensee's actions were appropriat In addition to the interview questions discussed above, the team asked the investigators other questions to assess the overall ECP. Most of the investigators stated that they continue to receive adequate support from the ECP management and the organizations under investigation. Also, the team reviewed severalinvestigation reports and found the reports to be well written and the conclusions to be well supporte .
Conclusions The team found that the ECP organization contin: es to possess the independence, resources, and management support neesstary tc perform thorough, unbiased investigation The conclusions of the ECP cases reviewed by the team were properly supported by the licensee's investigations, corrective actions were appropriate to resolve the issues, and communications with the concemed individuals were adequate. The ECP was adequately defining the concemed individuals' issues. The ECP was properly protecting the identities of those individuals bringing concems to the ECP. An extemal assessment of the ECP organization conducted by GPU Nuclear personnelwas very positive. The employee survey results continue to rate the ECP highly. Therefore, the team concludes that the ECP continues to function well. This finding was based on the small backlog of cases, the high quality of the case files, and the interviews of the ECP staff. Since the team's last evaluation, NNECO has made additional modifications in the ECP to improve the efficacy of the progra .0 Emotovee Concems Oversicht Panet issue No. 3: ECOP's new role During the August 1998 evaluation, the team determined that the ECOP wasn't functioning effectively, and appeared overtaxed in its ability to perform allits activities. The team also noted some documentation weaknesses. Since that evaluation, NNECO decided to restructure the ECOP to better serve the needs of the future Millstone organizatio ECOP is in a state of flux and will be reorganized soon. In a memorandum dated August 17, 1998, the President /CEO-Nuclear announced thst, in the future, the ECOP shovid focus on
.nscessing the climate of the site organization and that some of the other ECOP functions woud amain with the new ECOP (SCWE oversight, review of harassment esses, and focus group reports). The ECOP focus group reports and the quarterfy reports are useful products for management. The focus group reports are a real-time summary of the health within an organization and allow management to handle problems before they escalate; this promotes an SCWE. Also, by virtue of providing site employees with an attemate method for resolving their concems, the ECOP promotes an SCWE. As of August 1998, specific duties for the new ECOP were not yet determined, but NNECO intended the new ECOP to be operational by
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November 1,1998. However, NNECO was slow to develop the new ECOP Charter. The new ECOP Charter was not signed until November 17,1998. Those aspects of ECOP that are a valuable tool for an SCWE are being maintained in the new charter. Also, the selection of the new ECOP Chairman was announced on November 24,1998. It appears that the initial role of ECOP was too broadly based to serve the site effectively. The team noted that one of the more valuable aspects of the ECOP (employee surveys) will be moved to the SCWE organizatio In late August 1998, the ECOP presented a list of people to the President and CEO Nuclear who they believed should be considered for the new position of ECOP Chairman. The President /CEO-Nuclear appointed a three person panel of vice-presidents to review this !!st, as well as any other potential candidates, and to recommend an individual to serve as the new ECOP Chairman. The plan is for the new ECOP Chairman, along with the former ECOP Administrator and a third person yet to be named, to select four ECOP members from a list of volunteers. The new ECOP may not be fully in place until early 1999. The new ECOP should provide site employees with an altemate method to resolve their concems. The ECOP Chairman and the four ECOP members will serve for a term of 18 month l The team reviewed the new ECOP Charter, in draft form. The mission of the new ECOP is to
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monitor the workplace environment at Millstone and to provide its insights and
- recommendations to the President /CEO Nuclear. The new charter is a very short, revised
) version of the previous charter. The new charter was developed by the original ECOP and 3 describes attributes of the new panel, such as its responsibilities, composition and terms, self-
assessments, reports, etc. One major difference noted by the team was that the panel would j
no longer provide independent oversight and assessment of the ECP. When questioned by i
the team, the ECOP Administrator stated that the ECP would be independently assessed by i
the new ECOP when it reviews a sampling of unsubstantiated harassment, intimidation, i retaliation, and discrimination (HIRD) cases, and all substantiated HIRD cases. These
{ responsibilities were listed in the new charter.
i 4 j The August evaluation stated that current ECOP members would be moved into various j
organizations, with some maintaining their former duties. Only one individual and that person's i current function (employee surveys) will be moved from the ECOP into the SCWE j organization. The team previously stated that employee surveys were one of the more
valuable attributes of the ECOP. This function should continue to be effective within the SCWE organization.
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i Another issue discussed in the /,ugust evaluation was the ECOP's second-quarter report.
Comments in the second-quarter report increased tensions between the ECOP and the ECP.
! The team reviewed the licensee's draft response to the second quarter report, which was
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before the Board of Trustees for approval at the time of the October evaluation. The draft i response states that additional discussions between both organizations have determined that
- the ECOP continues to conclude that the ECP is an effective sitemate problem resolution j program. The comments made in the report were intended to convey recommendations for l improvement in several areas, and were not meant as an overall comment on the program, its j methods, or any of its staff, in response to the criticisms, the ECP staff has revised portions of l its manual and has instituted additiona: training for its investigators.
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i NNECO has been slow to develop and implement the new ECOP. The new panel, originally scheduled to be functional on November 1,1998, may not be fully in place until 199 l j
However, many of the key roles filled by ECOP are being retained, though some are being j transferred to other parts of the organization. The new ECOP should provide site employees '
with en attemate method to resolve their concems and, therefore, promote an SCWE. '
7.0 Safetv-Conscious Work Environment An SCWE applies to all the site activities to foster an environment in which employees feel comfortable raising any issues important to them without fear of retaliation or discriminatio NNECO formed an official SCWE organization with a full-time staf The remaining five follow up issues are associated with SCWE-related activitie Issue No. 4: SCWE lona-rance olan The fourth issue involved the SCWE long range plan, in August, the team stated that it would continue to monitor the implementation of the long-range plan and the transition to an operating organizatio The long-range plan states that Millstone will maintain the current structure of the SCWE organization until the units have been restarted. Subsequently, all changes to the SCWE-related organizations and processes will be based on demonstrated performance and results achieved, and will not be schedule-driven. Self assessment will be used to verify that performance expectations are being met. The objectives, measures, and targets to assess performances are stated in the SCWE segment of the plan, along with specific action items to support each objecSve. These action plans are assigned to specific individuals and are given specific target dates for completion. Each action item is also tracked in the Action item Trar.ining and Trending System (AITTS). Management has made samest efforts to track elements of the plan, although the whole plan won't be implemented until after the restart of Millstone Unit 2. Although NNECO has made slow progress in the implementation of the long-range plan, NNECO's deliberate transition continues to foster an SCW Issue No. 5: The new Vice President of Human Services in August 1996, the team noted that the Vice-President of Human Services was reassigned to the position of Vice-President of Engineering Services, the position he was originally hired for in 1997. The team believes that he was effective and instrumentalin ensuring that the SCWE staff remained focused on improving the safety culture at Millstone. In August 1998, the NRC noted that it was going to continue to monitor the SCWE Program for any signs of degradatio In October 1998, the staff noted little, if any, change. The team interviewed his replacement and noted that this individual has extensive experience in the nuclear industry and has an excellent attitude regarding maintaining an SCWE. He noted that be intends to devote much time walking around the site to miset the staff and to loam their concems firsthand. He believes one of hir highest prioritios is to unify the site in those areas than can be unified and to minimize the " silo" effect resulting from each of the three units operating as independent
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Page 8 of 15 entities rather than as a unified site. He believes that this willimprove the SCWE. He also noted that the site must strive for organizational stability as soon as possible because the current instability and uncertainties are not healthy or conducive to good employee morale, which raises the potential for SCWE problems. On the basis of its observations, the team believes the new vice-president is a positive addition to the SCWE organization at Millston Issue No. 6: The pendino Millstone site-wide manaoement reoraanization in August 1998, the team became aware of the pending management reorganization. At that time, the team noted that a lot of planning and effort had been given to the pending reorganization and that NNECO had consulted with experts in formulating its reorganization i
plan. The team noted that the potential for substantial organizational stress existed and that it '
would continue to monitor the reorganization activities. As part of the proposed reorganization process, NNECO solicited comments from its employees on the proposed reorganization and
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has made some substantive changes to minimize potential problems and to apply lessons l
leamed from previous reorganization efforts. Currently, the reorganization has been !
completed through the manager's leve Also, in August, the team commented that employees had not been told about the pending reorganization. Subsequent to the team's observations, NNECO made substantial efforts to communicate the reorganization to the employees through various means, including a web page. Although the Audix issue raised a potential concem about the faimess of the selection process, the team notes that the licensee has been thorough and deliberate in its efforts to ensure that each vacancy is filled by the best-qualified candidat Issue No. 7: Plans for the oversicht of SCWE to reolace the role of the third-party oversicht oroanization One long term issue directly related to an SCWE that had not yet been resolved during the team's August evaluation was oversight of the SCWE organization after LHC departs. During the team's August and October evaluations, NNECO had not completed its planning on how that would be accomplished. The Recovery Officer for Nuclear Oversight told the team that this issue had priority, and that he intended to resolve it as soon as possible. Following its October site visit, NNECO gave the team its SCWE assessment plan, which described what oversight and self-assessment activities will occur by organizations both intamal and extemal to NNECO. In addition to a number of intemat oversight and assessment activities, NNECO is planning periodic third party assessments. The team reviewed this plan and found it adequate. The plan is comprehensive and broad in scope. However, the plan could be improved in describing areas of responsibility and methods of assessmen Issue No. 8: Lono-term olans for the SCWE trainino orocram
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During the August evaluation of NNECO's SCWE training program, the team found that long- -
term plans (such as SCWE refresher training for supervisors and managers, SCWE continuing training, and enhancements to current SCWE training courses based on lessons leamed) were lacking. Since that evaluation, the licensee introduced a ' quick start" process, which ensures that new supervisors and new managers receive initial SCWE training soon after being selected for the new position. In October 1998, the staff found that long term plans for the
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SCWE training program had been developed. An SCWE refresher training class was l l
scheduled to begin at the end of the first quarter of Calendar Year 1998 NNECO was already l tracking recommendations to approve current training and to develop continuing training. The t j , SCWE training program continues to be a key element in fostering an SCWE.
f 7.1 SCWE Staffino and Oraanizational Suonort
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The SCWE organization continues to be involved in the daily meetings of the Human Services organization, and continues to meet twice weekly to discuss and coordinate issues. Other parts of the Millstone organization continue to give full support to SCWE acuvities. For several months the SCWE staff was augmented by contractor support, but when the contract recently expired the contractors were not replaced. This reduction of staff has the potential to overburden the SCWE organization, given the ongoing site-wide realignment of Millston .2 ,Recent Chance in the Position of the Vice President of Human Services in Evaluation Report Nos. 50 245/98 215,50-336/98-215, and 50-423/98-215, the NRC noted that the Vice-President of Human Services, a key position in the SCWE organization, had recently been replaced, but that based on a brief interview with the new vice-president, it appeared he would be a positive addition to the progam. The report stated that the NRC would continue to monitor the SCWE program for any signs of degradation. As noted under issue No. 5 on the previous page, the team continued its monitoring and has noticed no degradation. This was also confirmed by NNECO, as noted in Section 7.4 of this report, in its third-quarter performance report to the NRC. Furthermore, in discussions with various employees ranging from directors, managers, and supervisors to workers, it was noted that the Vice President of Human Services has thus far been an effective leader and has been a positive addition to the SCWE Progra The vice president had stated during the previous evaluation that he intended to spend time in the plant talking to workers. During this present evaluation, the NRC confirmed that he has done that. For example, he has visited the control rooms for all three units and the maintenance shops for Units 2 and 3. He has been a proactive and effective member of the SCWE organization and holds people accountable for their assigned actions. He regularly participates in the daily meetings of the " people team"(this is the informal name used to identify leaders from Human Resources, ECP, ECOP, SCWE, and the legal group who meet at 8:00 a.m. every day to discuss issues involving SCWE ectivities and problems). He is sensitive to the organizationalinstability at the site and wants to stabilize the organization as quickly as possible. He continued to be sensitive to employee concems and the EC .3 Effect of Pendino Reoraanization At the time of the August evaluation, NNECO had not planned to implement a realignment of the staff from a recovery organization to an operational organization, with certain exceptions, until after Unit 2 restarted. Since then, on the basis of business and organizational needs, as well as being responsive to work force needs, the company decideo to make the changes more quickly and initiated the realignment process. Initially, NNECO published a draft new organization in September 1998 and requested feedback from all employee groups through a
" bottoms up' process The contractor hir ed t io mplement the changes met with about 70 work
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groups to solicit comments, and these comments were then evaluated by management in j
considering whether to make changes to the proposed organization. On the basis of these comments, significant changes were made. One of these resulted in the lend position of the i ECP being upgraded from a manager to a director, and in upgrading the two supervisors to j
managers. Also, the company established a position of Vice-President for Nuclear Oversight and Regulatory Affairs, a position that did not exist previously. Many other changes were also
- made in the proposed organization.
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i Recognizing that this realignment could be traumatic for many employees, because it will
- reduce by about 50% the number of managers and supervisors, the company instituted a
program to keep the staff informed of the status of actions, it routinely publishes information ( about the reorganization in the "To the Point" site publication, and has established a web page, j which is routinely updated for those who want more information j (www.mp sta ge.nneco.nu.com/reorg/).
j As noted in the previous evaluation report, under the realignment process, a!! site leaders from i the director level down to the supervisor level will be required to bid forjobs. This includes the i
incumbents. The realignment was started in October when a Director Jobs Book was issued j
along with bidding instructions, key dates and milestones, bidding forms, and a listing of the 16 l director positions that will be available in the new organization. The subsequent process, 3 which will be used for all positions, calls for the next higher level (s) of management to review j the bid packages and select no more than four candidates for interviews. A director will then j be selected from those interviewed. For the director positions, the successful candidates were
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named on November 9,1998. Next, the manager positions were to be posted and filled, which j will be followed by the supervisor positions. This means that the realignment should be completed a few months earlier than planne The NRC stated in the previous report that it is unlikely that any changes in the leadership would negatively impact the SCWE at Millstone because the selected person must meet the minimum qualifications noted on the position description and must be evaluated as technically qualified for the position. One of the highest weighted selection criteria that is locluded in each of the 16 director positions relates to safety consciousness and requires, among other things,
"an ardent supporter of the safety conscious work environment, sensitive to employee concems." Involving the Vice President of Human Services, whose responsibility includes an SCWE, in the selection of each director, should preclude anyone who does not meet that criterion from being selecte .4 SCWE Lono Rance (Transition) Plan The SCWE transition plan describes the process of how Human Services wn! transition to the new organization. It is a subset (the Work Environment section) of the "1998 2000 Performance Plan" that is the Millstone plan for the long-term realignment of the entire site . In Evaluation Report Nos. 50 245/98-215,50-336/98 215, and 50-423/98-215, the NRC noted that Millstone had made progress in developing plans for transitioning the SCWE functions to the new organization in order to enhance and ma,intain an SCWE. This progress has continue .
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Page 11 of 15 The Work Environment section, among other things, focuses on the following:
- Leadership is strong and continually improvin *
Clear standards of performance and accountabilities are establishe *
A healthy SCWE exists if all employees feel comfortable that any issues they raise will be addressed with commitment, respect, and timelines *
The ECP is effective, continuously improving, and held in high regard by employee *
The work force is motivated, respectful, and has pride in personal, team, and I organizational accomplishrnsnt !
In the present organization, the SCWE work group reports to the Vice-President of Human I
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Services and has responsibility for focus area management, culture surveys, identification of !
chilling effects, and conducting interventions to alleviate problem areas. In the new organization which will be finalized after the site staff is realigned into an operating organization, the staff functions reporting to the Vice-President for Human Services change, and a new group, called Human Performance and Development,is added. This group will encompass nearly a!! human performance functions and willinclude, among other things, an SCWE group. The SCWE group will be responsible for conducting all non-10 CFR 5 investigations; developing action plans to resolve focus area problems; Ennutive Review Board (ERB) coordination to ensure that proposed disciplinary actions are proper and prudent and not the results of harassment, intimidation, retaliation, or discrimination (HIRD); and " issue intake." This latter item may eventually involve establishing an ombudsman for the sit The objectives, measures, and targets to assess performance are stated in the SCWE segment of the long term plan along with specific action items and schedules to support each objective. The goal, as stated in the plan, is to reach the point at which "a safety conscious work environment (SCWE) exists whereby all members of the NU Nuclear team feel comfortable with, and accept responsibility for, raising any issue important to them with high confidence that the issue will be addressed with commitment, respect and timeliness. Our Employee Concems Program should set the standard to which others in the industry aspire."
This goalis generally being met. The third-quarter performance report, which is docketed and sent to the NRC, indicates no comp'acency or backsliding; the SCWE success criteria continue to be met; and key performance indicators (KPls) continue to indicate satisfactory progres With respect to the specific action items that were developed to implement the transition, only eight remain to be completed and they are on schedule with completion dates ranging from late 1998 to early 1999. Some examples of remaining items are (1) develop and implement 10 CFR 50.7-related requalification/ refresher training for managers and supervisors; (2) develop and implement an improved set of performance measures for measurement of continuous improvement; and (3) conduct periodic benchmarking and implement methods for sharing lessons leamed from highly rated plants (ongoing). Two actions are related to the new 4 realignment (evaluate and irnplement a phased plan for realignment of SCWE functions and realignment of ECOP).
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The transition plan seeks to shift emphasis from mitigative to more effective preventive actions.
One component of this focuses on leadership as follows:
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i Skill development: Ensuring management attendance in requisite training, measuring leadership effectiveness, and adjusting training as appropriate. To help meet this goal, the site is developing a leadership program curriculum that includes a continuous leaming
) approach and uses industry best practices. It is scheduled to be complete by March 1999.
in addition, all but 6 of 430 managers and supervisors have completed initial SCWE l training. A " quick start" training session has also been developed for new managers / supervisors, which is provided to them shortly after they assume their new
- position .
Standards and expectations: Establishing, communicating, and reinforcing consistent standards and management expectations. As part of this goal, the SCWE group published an SCWE Guidebook, which presents the process for addressing leadership inadequacie .
Succession plannino: Establishing plans to ensure that qualified candidates are identified to fill vacated positions on short notice. All managers and their supervisors were to have this completed by the end of 1998. However, this schedule will change because of the i
pending site-wide reorganizatio .
Self assessment: Using mentoring to improve leadership effectiveness and to ensure continuous improvement. One part of the action plan for this goalinvolves assembling a <
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team of current leaders, who are considered and rated as excellent, to be available to help mentor those leaders who may need to improve their leadership skills. An SCWE Assessment Plan was also published (see Section 7.5 following).
7.5 Plans for Oversicht of SCWE As discussed earlier under Issue No. 7 on Page 8, an issue of concem to the NRC is independent oversight of the SCWE after the departure of the independent third party (Little Harbor Consultants). In the previous evaluation reports, the NRC noted that NNECO had not decided how that would be done. Since then, however, NNECO has developed and issued an
"SCWE Assessment Plan" that describes the means by which Millstone will, with extemal support, continue to monitor and assess the SCWE and overall culture at the Millstone Statio The plan states that the Human Services team will monitor and oversee the efforts to maintain, foster, and mature the SCWE at Millstone, and groups extemal to Human Services will provide additional independent oversight. This oversight is intended to ensure that there is early identification of any negative precursors that could potentially lead to backsliding. The oversight willinclude monitoring of performance and self assessments. The monitoring and l self-assessment results, combined with input from other organizations such as Nuclear '
Oversight, Nuclear Safety Advisory Board, and ECOP, will be evaluated on a quarteriy basis to ensure that any program degradation or backsliding is correcte ' l The oversight plan willinclude use of the following assessment tools: key performance ;
indicators (KPis), Human Services self assessments, site culture surveys, leadership assessments, review of SCWE-related condition reports, employee feedback, ECP reports, ERB screenings, and peer review. Overview of the assessment activities will be provided by the following extemal (that is, extemal to Human Services) oversight: nuclear oversight, peer
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utility assessments, NU officers, Corporate Center, Nuclear Safety Assessment Board (NSA Nuclear Committee Advisory Team (NCAT), non NU third-party personnel, and ECO Examples of self-assessments,that are planned are
e effectiveness of selected employees concems comprehensive plan action items culture surveys
ERB effectiveness I e *
human relations customer feedback surveys
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personnelperformance reviews
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-. ' leadership assessments leadership training
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e common threads (lessons laamed)
contractor downsizing
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work force discipline cases e
unit restart readiness The success criteria / attributes and performance indicators that were used to determine that an SCWE had been established at Millstone will continue to be used as fundamental measurements of the SCWE. These willinclude the following:
Demonstrate that employees are willing to raise concem *
Demonstrate that management is effective in evaluating, prioritizing, and resolving employee issue .
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e Demonstrate that the ECP is effective in addressing issues raised by employees that are not resolved satisfactorily by other means within the organizatio *
Demonstrate that line management is effective in identifying, investigating, and resolving
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focus areas in which the attributes of an SCWE are challenged or lackin .6 Lono-Term Plans for SCWE Trainina i
The team evaluated the licensee's long-term plans for the SCWE training program, which includes refresher training for supervisors and managers, continuing training, and enhancements to current trainin Observations and Findinos
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The team reviewed a draft outline for the proposed SCWE refresher training class for
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supervisors and managers. The class is already budgeted for 1999, and is scheduled to begin
- in March. The class will last for 2% hours, and will begin with a short test to assess the retention of the fundamental principles previously leamed. Following a review of the test results and a brief lecture on key principles, the remainder of tne class will be spent discussing contemporary case studie With respect to continuing training and enhancements to current training, the licenses will rely on self assessments of its SCWE training program, feedback from SCWE training classes, surveys, and industry initiatives. The licensee's self assessments are done on a routine basi The team reviewed self assessment 98 SCWE 5, dated October 22,1998. The self-
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assessment made seven recommendations, and several of the recommendations concemed continuing training and enhancements to current training. These recommendations were being tracked for completion by two condition report Conclusions Long-term plans for the SCWE training program have been developed. An SCWE refresher training class is scheduled to begin at the end of the first quarter of Calendar Year 1999. The licensee is already tracking recommendations to improve current training and to develop continuing trainin !
- 7.7 Little Harbor Consultants Oversicht !
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' Since its inception in an oversight role at Millstone, Little Hart >or Consultants (LHC) has made 104 recommendations to NNECO to improve the SCWE. In the August evaluation, the NRC noted that LHC had closed 81 of those recommendations as acceptable and another 6 as acceptable but with continued monitoring of the corrective actions. LHC had considered the remaining 17 responses as adequate, but kept the recommendations open untilit completed its evaluations of the corrective actions. As of the end of this evaluation all but 7 of the l recommendations have been closed and LHC was in the process of evaluating those for closure. LHC and NNECO continue to work in this are On August 27, LHC presented the results of its most current assessment of SCWE/ECP and noted that all of the success criteria remained satisfactory, with steadily improving trends. It commented that it continued to see a work force that was willing to take issues and concems forward, that management continued to remain focused on SCWE, and that people were being trained on SCWE. LHC stated that it was impressed with the daily SCWE meetings, the ERB,
- and the continuing ECP improvements, based on user satisfaction and the quality of ECP files.-
LHC also stated that the point of SCWE was not just to deal with issues but to prevent them from happening, and that it was seeing positive results in this area as well. Finally, LHC stated that its level of activity had dropped off based on the overall performance of NNEC .8 Conclusions On the basis of the team's observations, supported by Little Harbor Consultants observations and reviews, and by on site assessments performed about once a month by NRC representatives, the team concludes that an SCWE continues to exist at Millstone. The current NNECO staff members have gained valuable experience in the last year, are comfortable in l
theirjobs, and have become proactive in responding to potential SCWE issues. The team ;
notes, however, as it did in the August evaluation report, that the site must be vigilant because of pending organizational and personnel change On the basis of its review of documentation and on the evaluations, the team concludes that NNECO has sustained and, in some instances, improved the ECP and SCWE at Millston Employee surveys and interviews indicate that the overwhelming majority of employees are willing to raise concems, and of those who have used the ECP, a strong majority stated they would use the program again. This was verified not only by NNECO through the various surveys and questionnaires at its disposal, but also by LH _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _
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- i Page 15 of 15 The team concludes that NNECO's ECP and SCWE are established and functioning effectively at Millstone. Employee concems are prioritized based on safety significance, identities are protected, case resolution is timely, and there is appropriate follow-up on corrective action adequacy. Further, significant improvements have been made in the training provided to employees and contractors regarding SCWE and the ECP. In addition, NNECO has established effective supplemental measures (e.g., the ERB, focus area plans, and leadership surveys) that provide enhanced assurance of providing and maintaining an SCW The team also concludes that NNECO has developed adequate plans for monitoring the site's safety environment, addressing problems as they may arise, and applying necessary resources to support the ECP and the SCWE Progra It should be noted that there is still some fragility in the various programs that make up an SCWE. Management has shown it is willing and capable of immediately becoming involved to resolve problems and concems as they arise. There continue to be issues raised through the ECP; however, relatively few allegations are made to the NRC. These issues are typically of little or no safety import and support the observation that the programs in place are workin The team urges caution in going forward as potential problems that could arise from any number of areas, such as the impending reorganization and recent managerial changes. The team notes that the licensee has in place the plans, processes, and resources to sustain the
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improvement it has made in fostering an SCWE and in providing an effective ECP. Clearly, l the potential for issues to emerge continues to exist as Millstone Unit 2 approaches restart and as the management reorganization process continues. As Millstone proceeds through its transition to an operating organization, continued vigilance and involvement will be necessar l l
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