ML20217M187
| ML20217M187 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/31/1998 |
| From: | Amerine D, Kenyon B NORTHEAST NUCLEAR ENERGY CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| B17138, NUDOCS 9804080031 | |
| Download: ML20217M187 (80) | |
Text
ggg Rope Ferry Rd. (Route 156), Weterford, CT 06385 Me8F b337 Millstone Nuclear Power Station Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385-0128 (860) 447 1791 Fax (860) 444-4277 The Northeast Utilities System MAR 31 1998-Docket Nos. 50-245 50-336 50-423 B17138 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-Millstone Nuclear Power Station, Unit Nos.1,2, and 3 Establishment Of A Safety Conscious Work Environment
.On October 24,1996, the NRC issued its " Order Requiring inoc'endent, Third-Party Oversight Of Northeast Nuclear Energy Company's implementatior. Of Resolution Of Millstone Station Employees' Safety Concerns" (Order). The NRC ordered that before the restart of any Millstone unit, NNECO must " develop, submit for NRC review, and begin to implement a comprehensive plan for (a) reviewing and dispositioning safety issues raised by its employees and (b) ensuring that employees who raise safety concerns are not subject to discrimination." On January 31,1997, NNECO submitted its Comprehensive Plan to the NRC for review. On December 11,1997, NNECO submitted to the NRC its Safety Conscious Work Environment (SCWE) Plan, which t
provided for a more detailed and focused plan to improve the work environment and which incorporated any remaining open items from the original Comprehensive Plan.
Consistent with the Order, on December 23,1996, Januarv 14,-1997, .and February 4, 1997, NNECO submitted for NRC approval its selection of Little Harbor Consultants (LHC) as the independent third-party to oversee NiiECO's implementation of its Comprehensive Plan. The NRC subsequently approved LHC's oversight plan and the selection of LHC on July 14,1997, and August 19,1997, respectively.
Following the selection of LHC, NNECO and LHC met publicly with the NRC on seven occasions to date, to discuss the status of Millstone's work environment. Additionally, LHC has provided NNECO with many observations and' recommendations. NNECO has responded to each recommendation and LHC is assessing the responses and the effectiveness of corrective actions. This response and assessment process is ongoing.
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U.S. Nuclear Regul tory Commission B17138\Page 2 The purpose of this submittal is to inform the NRC that NNECO has made substantial progress in implementing its original Comprehensive Plan (and the_ follow-on SCWE -
Comprehensive Plan) and to aavise the NRC that the current safety conscious work environment supports the restart of Millstone Unit 3. LHC will submit its assessment to the NRC in a separate sut;mittal or report.
This latter has six attachments which discuss the establishmer' of a SCWE at Millstone Station:
Attachment 1 Regulatory Commitments Attachment 2 Executive. Summary Attachment 3 Establishment of a SCWE Attachment 4 1998 - 2000 Performance Plan - Work Environment Focus Area Attachment 5 Requirements of the NRC Order of October 24,1996 and NNECO's Actions in Compliance Attachment 6 IP40001 issues Matrix if there are any questions on the information provided in this letter, please contact Mr.
David B. Amerine at 860-440-0437.
Very truly yours, ,
i NORTHEAST NUCLEAR ENERGY COMPANY-FOR: Bruce D. Kenyon President and Chief Executive Officer BY:
David B. Amdrine Vice President -Human Services
- Attachment 1 Attachment 2 !
Attachment 3 l Attachment 4 Attachment 5 Attachment 6-cc:- See Page 3 l
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i U.S. Nucl=r Regul tory Cummission B17138\Page 3 l
cc: H. J. Miller, Region i Administrator S. Dembek, NRC Project Manager, Millstone Unit No.1 D. G. Mcdonald, Jr., NRC Senior Project Manager, Millstone Unit No. 2 J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 T. A. Easlick, Senior Resident inspector, Millstone Unit No.1 D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 A. C. Ceme, Senior Resident inspector, Millstone Unit No. 3 W. D. Travers, Ph.D, Director, Special Projects Office ;
P. W. Eselgroth, Branch Chief, Special Projects Office i W. D. Lanning, Deputy Director of Inspection - Special Projects Office !
J. P. Durr, Branch Chief, inspections - Special Projects Office P. F. McKee, Deputy Director of Licensing - Special Projects Office ;
E. V. Imbro, Deputy Director of ICAVP - Special Projects Office ;
H. N. Pastis, ITPOP Oversight Coordinator - Special Projects Offi::e l
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Docket Nos. 50-24f5 50-336 50-423 B17138 I'
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Attachment 1 Millstone Nuclear Power Station, Unit Nos.1,2,3 Regulatory Commitments l
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m U.S. Nucirr Regul:; tory Commission B17138%ttachment 1\Page 1 l
List of Regulatory _ Commitments The following table identifies those actions committed to by NNECO in this document.
Any other actions discussed in the submittal represent intended or planned actions by ;
NNECO. They are described to the NRC for the NRC's information and are not regulatory commitments. The Director - Regulatory Affairs should be contacted if any questions regarding this document or any associated regulatory commitments arise.
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Commitment Committed Date or Outage B17138-01 NNECO will provide the Work Environment section Complete i of the 1998-2000 Performance Plan.
B17138-02 NNECO will maintain the functions of the SCWE Unit 2 entry into Team, ECP, and Human Resources organization Mode 2 - .
within the Human Services group through Unit 2 '
restart.
B17138 NNECO will implement an oversight program to Unit 2 entry into review SCWE that will include both intemal self- Mode 2 assessments and external independent assessments.
B17138-04 NNECO will provide the NRC with updates on the First update no later SCWE Key issue, including any changes to the than June 30,1998 SCWE section of the Performance Plan, as committed to in the Backlog Management Plan submitted to the NRC via NU letter B17159.
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Docket Nos. 50-245 50-336 50-423 B17138 Attachment 2 Millstone Nuclear Power Station, Unit Nos.1,2,3 .
Establishment Of A Safety Conscious Work Environment Executive Summary
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U.S. Nuclxr Regul tory Commission B17138\ Attachment 2\Page 1 Executive Summary o
- 1. Introduction 4 NNECO's conclusion that it has. achieved a safety conscious work environment finds 1
support in objective evidence and data, in September 1997, NNECO identified four
. primary success criteria, the satisfaction of which it deemed essential before requesting restart authorization. Since that time, both NNECO and LHC have gathered, evaluated, and reported the data which addressed NNECO's status in satisfying these criteria and other criteria developed and assessed by LHC. Current data supports the conclusion that NNECO has satisfied each of its criteria. Additionally, NNECO determined that restart would be dependent upon the independent assessments of LHC and NNECO's Employee Concems Oversight Panel (ECOP). On March 27,1998, ECOP reported that NNECO has satisfied the four success criteria. On March 30,1998, NNECO's Nuclear Oversight organization concluded that a Safety. Conscious Work Environment exists which supports the restart of Unit 3. Also, on March 30,1998, the Nuclear Safety Assessment Board (NSAB) concurred that NNECO has established a Safety Conscious Work Environment which supports the restart of the units. NNECO has not yet received the evaluation of LHC, which LHC will provide separately to the NRC.
The Commission's Order of October 24,1996,' came at a time when NNECO was-coming to grips with the magnitude of the challenges facing it. In May 1996, NNECO-established a Fundamental Cause. Assessment Team (FCAT) to determine whether -
management's actions- were addressing effectively the causes for' Millstone's-performance. The FCAT identified three fundamental causes in the decline in Millstone's performance:
Senior management . did not consistently exercise effective leadership and articulate and implement appropriate vision and direction; The Nuclear organization did not establish and maintain high standards and l expectations; and i i
The Nuclear organization's leadership, management, and interpersonal skills were weak.
' These same general themes were apparent in the more specific findings of the NRC's Millstone Independent Review Group (MIRG). The MIRG reached five principal conclusions about the work environment at Millstone:
The large number of concems being brought to the NRC indicated that NNECO's programs were ineffective !n resolving employees' concems; ;
Managers who were responsible for discrimination were not appropriately I disciplined; i
1 U.S. Nucl=r Regul tory Commission B17138%ttachment 2\Page 2
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Management was ineffective in implementing corrective action;
- . : Management was reluctant to admit mistakes; and
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Managers lacked the_ skills necessary to handle their employees' concems and were generally not supportive of those employees.
LThe essential message of these reports, and others, was unmistakable. NNECO must make fundamental changes in the way it conducts its business, and in particular, in the way it addresses its employees' safety concems.
The programs and events highlighted in this document must be viewed in' context. ;
First, the advancements represent NNECO's efforts to date to rebuild a healthy working environment.- These advancements are significant and reflect a fundamental change in business practices. By no means, however,'does NNECO consider the final objective reached or its goal of excellence attained. NNECO's objective is to create a healthy 0 and safe working environment which thrives in the long-run, during periods of sustained power operations, and'not only In times of intense regulatory scrutiny. Second, the
' achievements addressed here have not been easily reached. NNECO takes justifiable pride in its accomplishments, but it also recognizes that even its recent history has not
' been unblemished. But that is both the nature of the problem and, to a certain extent, a preview of the future. Despite the best efforts. of well-intended managers - and 1'
empbyees, missteps will occur. When problems arise in the future, however, they will be met by an organization that is prepared with the resources, skills, and commitment .
to resolve the problems.
. With a clear understanding of the past,~ a full appreciation for the challenges of the future, and a firm commitment to sustained excellence, NNECO reports that.it has !
achieved a safety conscious work environment at Millstone Station which will support _l the restart of Unit 3. j I
II. NNECO is Ready For Restart !
l Since the' shutdown of the Millstone units in late 1995 and early' 1996, Millstone has ;
. undergone tremendous change. .NNECO has implemented a rigorous recovery process l with unprecedented ove'rsight. In addition to the more visible changes in the Millstone leadership' team, the phpsical facilities, and in the configuration verification, the~ changes ,
in the work environment and the culture at Millstone have been equally, if not more, dramatic. The collaborative efforts of management and the workforce have produced ;
- an environment in which workers raise concems with the assurance that management .;
. supports their efforts and with the assurance that the raising of concems will not result in retaliation. Management has actively encouraged the raising of concems, rewarded ;
Lemployees for. having. raised concems, and disciplined those who failed to meet management's unbending' prohibition of retaliation.
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i U.S. Nucl=r Regulitory Commission -
B17138\ Attachment 2\Page 3 Although the changes have been pronounced and the improvement commendable, NNECO does not consider the task complete. To the contrary, the progress reported in this document is only that - progress. - NNECO realizes that much hard work lies ahead. NNECO is determined that, having'made a fundamental change in the' conduct of its business, it will not tolerate backsliding or complacency. Consequently, the efforts to enhance the work environment and to instill the attitudes and attributes of a safety -
conscious work environment will continue as part of NNECO's ongoing longer term performance plan (The 1998-2000 Performance Plan).
A. NNECO Mas Satisfied its Restart Readiness SCWE Success Criteria Attachment 3 contains a detailed discussion of the SCWE restart success criteria and
- the basis for NNECO's conclusion that it has satisfied each criterion. A summary of the bases appears below.
The First Success Criterion The first NNECO success criterion requires that the employees at Millstone be willing to raise safety concems. Many complementary indications confirm that the workforce not -
only possesses the willingness to raise concems, but it also has the confidence that the concems will be addressed, and the knowledge that the raising of concems will not be
' met with retaliation.
'Several NNECO surve[s have confirmed that employees at Millstone possess the confidence necessary to raise concems. In late 1997, a NNECO I cacership Survey
- found that. 97 percent of supervir, ors were rated as effective in- handling employee concems. Likewise, NNECC s Employee Concems Oversight . Panel . (ECOP)
- conducted. a similar survey its the fourth quarter of 1997 which concluded' that' 95 percent of these surveyed indicated a willingness to raise concems to immediate management. Most recently, in February 1998, LHC conducted a series of 298-structured interviews. In those interviews,100 percent of the employees interviewed indicated that if they became aware of a problem that could affect the safe operation of the plant, they would raise the concem through some avenue. Moreover,99 percent of those employees also indicated that. they would raise their concem with their management. The small percentage who~would not use their management, would, nevertheless, avail themselves of some other avenue to raise the concem. i These-favorable statistics are not surprising in light of the emphasis that senior management has placed on the value of employees who raise concems. Since his arrival in September 1996, Mr. Kenyon has delivered the clearest message - !
. Management expects employees to raise concems. First, Mr. Kenyon issued seven overarching success objectives for the station, one of which was the establishment of a Safety Conscious Work Environment.' Second, Mr. Kenyon's " Expectations For 1
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[L l U.S. Nucl: r Regul: tory Commission B17138\ Attachment 2\Page 4 Employee Concems at Milistone," issued in March 1997, could not be clearer. Among I
other things, "everyone" at Millstone is to:
. Maintain a questioning attitude, challenge the status quo, and make suggestions 1 for improvement. i l
f e immediately report those items that do not feel right or that are unresolved.
l l . Try to first resolve the concern through supervision.
. As an altemate to supervision, work to resolve the concern through another
- member of management, the Employee Concems Program, or the Nuclear Regulatory Commission.
Mr. Kenyon's " Expectations" make equally clear management's obligations. Among
- these are:
- Promote the new employee culture with words and actions - walk the talk.
- Foster a questioning attitude. l
- Create a non-hostile work environment. Immediately resolve any situations involving harassment, intimidation, discrimination or retribution by anyone.
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- Celebrate and recognize individuals who identify and/or help resolve significant concerns. >
l Management has reinforced the message with action. When persons have retaliated against employees (including contractors), they have been held accountable. Likewise, i when mistakes have occurred, at whatever level, management has publicly i acknowledged the shortfall and taken corrective action.
Management has not only demonstrated a lack of tolerance for offenders, it has rewarded employees who have raised concerns. Indeed, the February 1998 LHC structured interviews revealed that 78 percent of the employees interviewed had personal knowledge of employees who had received an award or praise for having raised a concem. l The Second Success Criterion The second success criterion requires that management effectively resolve issues. In !
' recognition of the importance of addressing issues, NNECO has made substantial !
reforms and progress in upgrading the quality of its Corrective Action Program. In i February 1997, NNECO established and implemented a site-wide Corrective Action Program. Although improvements in the program continue, issues are now being l l
. U.S. Nucl=r Regul: tory Commission !
B17138\ Attachment 2\Page 5 l
. addressed in a timely manner and as part of an overall approach designed to ensure ;
, the proper resolution of the concems. The Corrective Action Program has also been l separately determined to be " ready for restart" as part of NNECO's assessment of key restart issues. (See tne February 11,1998 Commission Briefing Book, submitted on February 12,1998, by NNECO letter B17034.)
9 Consistent with the desire that employees raise concems, NNECO has lowered the threshold for the - writing of Condition Reports (CR). NNECO has intentionally established this low threshold because it prefers to have an employee initiate a CR, rather than to have the employee retain an issue and permit the issue to remain unresolved. To reinforce the importance of self-reporting, NNECO has also conducted extensive training in the area of self-assessment techniques. As a result, coupled with the shutdown recovery effort, there were 10,511 CRs written in 1997 at Millstone-Station - a vast increase over the 6,455 CRs written at Millstone in 1996, or the.3,805
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i ACRs generated in 1995.
An integral part of an effective Corrective Action Program is the conduct of critical self assessments. As noted, NNECO has provided training to its management team and ;
professionals to enhance the quality of these assessments. The results of these efforts l are promising. The February 1998 LHC structured interviews showed a marked j improvement in the area of self assessments. In particular, 98 percent of the interviewees were aware of self assessments being performed within their work groups.
And 92 percent were able to provide examples of useful results which arose from the self assessments. The recognition of the value of self assessments is testimony to the efforts made thus far and a good indicator that high-quality self assessments will continue. Self Assessment is also another key restart issue, which has been recently assessed as adequate for restart.
i i Once a concem is raised, it is essential that the issues be expeditiously addressed. i
- NNECO has established a goal that the average length of time for a Level 1 and 2 CR ;
evaluation should not indicate an adverse trend, along with an intemal goal of !
completing 95 percent of all Level 1 and 2 CR evaluations within 30 days. The latest evaluation of the CR process shows that NNECO has virtually accomplished that goal
.for Unit 3. For Unit 3, the current average age of.CRs is 22 days. The effective resolution of concems also requires a high quality in their. resolution. The data which tracks the quality of CR evaluations and corrective action plans through NNECO's ;
l .. Condition Report Evaluation Score, indicates that quality of the Unit 3 CRs is good and improving. Management has established a goal of Condition Report Evaluation Scores ;
of at least 3.0. That goal is being met for Unit 3. l The Third Success Criterion ,
.The third success criterion requires that the Employee Concems Program (ECP) q l operate effectively. NNECO's ECP is operating effectively and continues to improve. ;
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, U.S. Nuclear Regulatory Commission B17158\ Attachment 2\Page 6 The current ECP bears little resemblance to its predecessor. The earlier organization 1
- had a Director and three investigators. In contrast, the current ECP has a Director,2 Managers, and 15 investigators, in addition to a 6-person support staff. This team not only investigates safety concems, it also investigates, and aids in the resolution of, i
. virtually all types of employee complaints or concems. The breadth of its charter i reflects management's belief that the re-establishment of a safety conscious work i
environment requires the effective resolution of all concems - not just those that may -
~ have safety implications. Employees who have no fear of retaliation for any reason will necessarily be more willing to raise issues having an impact on the safe operation of the plant. And the fair treatment of employees necessarily enhances employee morale and pride in the organization.
L Visible senior management support for the ECP has taken many forms. First, management has provided substantial manpower and logistical resources for the organization. Second, the ECP Director has direct access to the President and CEO-Nuclear, as well as to the corporation's Board of Trustees. Third, NNECO provides technical investigatory assistance to support ECP investigations. And fourth, NNECO tracks corrective actions which arise out of ECP investigations through its formal action item tracking system.
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- In addition to ECP staffing augmentation and the level of_ senior management support,
[i ECP's effectiveness has:been enhanced by the development of a comprehensive l manual. That manual formalizes the recent improvements in ECP processes and L practices and will improve consistency of performance. Notably, the. ECP' process now l requires the conduct of an immediate assessment of a concem to determine its_ safety significance, the need for an operability' or reportability determination, and the assessment of any chilling effect. The manual also provides the process'which govems the conduct of the investigation, communication with the concemee, corrective action, and feedback to the ECP from the concemee.
L The enhancements in the ECP have produced results. The latest data indicates that the average age of ECP concems under investigation is about 45 days. This'is a j
dramatic improvement from early 1997, when some concems had remained under !
l investigation for more than one year. Additionally, satisfaction among those employees
( who have used the ECP is on the rise. In June 1997, a LHC survey showed that 62 L percent of users would use ECP again, if they had a need. -in January 1998,~ an ECOP l survey indicated that 75 percent of employees would use the ECP again. Near the end i of the.first quarter of 1998, an ECOP survey indicated that 90 percent of employees j l' would use the ECP again. And in the recent LHC_ structured interviews,93 percent of i the interviewees indicated that there was no reason why they would not use the ECP. !
l The employees' satisfaction with ECP is consistent with the preliminary results of the l NRC's IP40001 inspection,'as reported in the NRC's " Quick Look" letter of February 18, j 1998. The initial feedback indicates that the ECP has'made significant improvements, l p ~ and is.well established and functioning effectively. Additionally, the preliminary report H n i
U.S. Nucimr Regul tory Commission B17138\ Attachment 2\Page 7 indicates that the ECP has the " independence, resources, and management support to conduct unbiased investigations."
Finally, the.ECP. conducted a self-assessment in November 1997 to determine the effectiveness of selected commitments and initiatives which had been taken to improve the process for addressing employee concems. The assessment identified various strengths and weaknesses, but it found no deficiencies which could adversely affect nuclear safety.
The Fourth Success Criterion The fourth success criterion requires that management demonstrate that it can recognize and successfully respond to allegations of harassment, intimidation, retaliation, and discrimination, or other circumstances creating a chilling effect. To achieve success under this criterion and, more importantly, to achieve a safety conscious work environment, NNECO has focused on steps necessary to: (a) prevent -
retaliation ~ from taking place in the first instance, and (b) take prompt, appropriate remedial action if retaliation occurs.
Preventing Retaliation. 'To prevent retaliation, NNECO has established (or enhanced) a series of four interrelated training programs. First,' NNECO has trained its management - team in the fundamentals of 10 CFR 50.7. -
Second, NNECO
. management has completed the Managing For Nuclear Safety course for the purpose of developing those skills necessary to foster a workplace in which employees are comfortable raising concems. Third, NNECO has initiated a Forum For Leadership Excellence (for Units 1 and 3) and Enlightened Leadership (for Unit 2), to establish' standards, improve skills, and provide supervisors and managers new ways of thinking, and behaving. Finally, NNECO has trained its supervisors and managers in the Civil-Treatment of Employees. Similar to the other courses, this course emphasizes the personal skills and behavior necessary to establish ari open relationship between
. supervisors and their employees.
.These four courses teach principles and skills which, together, have made substantial progress in raising the sensitivity of the management team and in preventing
' discrimination. Simply stated, a manager who: (a) treats employees with respect (Civil -
Treatment); (b) provides fresh and innovative leadership (FLE); (c) creates a workplace
' which is receptive to the raising of concems (Managing For Nuclear _ Safety); and (d) understands the requirements of the law (50.7 Training), will have the fundamental skills necessary to' establish and maintain a safety conscious work environment and, thereby, avoid any retaliation against those employees who engage in protected activity.
Training alone will.not prevent retaliation. To improve performance in this area, t NNECO has added considerable resources to support its SCWE recovery efforts. The most notable = developments in this regard are the establishment of a SCWE
' U.S. Nucl=r Regul tory Commission B17138\ Attachment 2\Page 8 organization, the May 1997 appointment of an NU Officer as SCWE Executive Sponsor, and the assignment of a SCWE' Key issue Manager. The SCWE organization's-function is to provide direct and concentrated support for management in its efforts to
. enhance the quality of the work environment. This organization also plays a critical role in the prevention of retaliation-in the site-wide disciplinary process. To ensure consistent and correct discipline, NNECO has established a formal process for disciplinary action (OA-15, " Progressive Constructive Discipline"). Further, NNECO has established an Executive Review Board which reviews all proposed discipline more
. ' serious than a verbal reprimand to (1) ensure that the discipline is based on legitimate reasons and not on any protected activity, and (2) to anticipate and counter any potential chilling effect.
Complementing the SCWE organization and the ECP is the Employee Concems Oversight Panel (ECOP). Created in April 1997, the ECOP monitors the effectiveness of the ECP _ and provides other enhancements to the safety conscious work environment. In performing its duties, ECOP provides management with valuable insight on how management actions are received - and perceived - by the workforce.
^ Finally, NNECO has substantially upgraded the Human Resources (HR) organization at Millstone. NNECO's upgrading of this organization reflects its recognition that effective HR assistance in the incipient stages of a personnel issue can often prevent the matter from developing into a more difficult problem and from causing a troubling breakdown in the employee / employer relationship.
In addition to these intemal resources, NNECO has also brought external resources to bear on the issues. In particular, NNECO retained several organizational effectiveness
. consultants beginning in December.1997, to facilitate communications, team building, y R
- and organizational effectiveness in key segments of the organization.
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To. enhance the effectiveness of the augmented resources, NNECO has adopted practices which coordinate the resources and bring to bear the necessary expertise to I solve problems. In particular, in January 1998,- NNECO consolidated its human
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. services functions under a single Vice President, David B. Amerine. .The SCWE l organization, ECP, and Millstone HR all report to Mr. Amerine. To coordinate their. j efforts, each moming at 8:00 a.m. senior representatives of these organizations, as well j as representatives of the Legal . Department, ECOP, and the organizational i effectiveness consultants meet with Mr. Amerine to discuss issues affecting the work. 'i environment.' These meetings have' proved invaluable in improving.the quality of
.g - communications among the various groups, in coordinating the resources, and in calling i senior management's attention to priority. SCWE matters. As a result, senior l management at Millstone is involved in the daily issues affecting the workforce at an ;
unprecedented level. )
i Additionally, th'e. various organizations under Mr. Amerine's leadership - have l implemented a processf for responding rapidly to any emerging matters which could i l
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U.S. Nucl=r Regul: tory Commission
. B17138\ Attachment 2\Page 9 i
have an adverse effect on the work environment. The process establishes designated '
characteristics of an issue, which if present, require the immediate notification of key persons. Those persons will then confer to determine whether the matter is urgent and, if so, they will take the necessary immediate steps to avoid any exacerbation of the !
problem. Those persons will also develop a coordinated plan to address the matter. By rapidly establishing areas of responsibility, paths of communication, and predetermined ,
actions, NNECO has significantly improved its capability to provide prompt, integrated !
solutions to priority personnel issues.
l In addition to these efforts, NNECO formulated a program to detect potential areas l where a healthy work environment is either in jeopardy or suspect. Through its '
Millstone Focus Area Plan, NNECO is able to respond to emerging issues before they l become significant issues or before they cause a degradation in the work environment. '
Simply stated, the process calls for the identification of a Focus Area, the development and implementation of a specific and detailed plan (approved by the responsible Vice President), an assessment of the results, and the identification and integration of any lessons leamed. Since the Plan's development in mid-1997, NNECO has identified 33 ;
Focus Areas. Twenty-four of the 33 designated Focus Areas have completed the l implementation of their plans and the plans are now closed. The existing nine Focus Areas have plans which are either under development or in the process of being l implemented.
Results of Enhancements The enhanced training, the additional resources, the realigned Human Services ;
organization, and the coordination of the assets have substantially improved NNECO's ability to recognize and respond to allegations of retaliation, as well as the perception of
' retaliation. Several recent examples demonstrate the seriousness with which NNECO views its obligations in this regard. In August 1997, when the ECP determined that i supervision had retaliated against several workers who had voiced concems about the adequacy of certain valve work, NNECO offered reinstatement to the displaced workers and was preparing disciplinary action against those responsible (two contractors) when they submitted resignations. When NNECO learned that a contractor had been denied access possibly because of prior protected activity, NNECO lifted the denial and fully remedied the matter within one day. When a supervisor made a remark about a contractor, which created the impression that the contractor was being terminated because of protected activity, the contractor was offered reinstatement and the supervisor apologized to the contractor, the work group, and the site. When a Vice President failed to appreciate the adverse implication of a poorly worded document, the Vice President resigned. These actions, among others, demonstrate the willingness of management to police itself and to ensure that its actions are in harmony with its words.
(Although these events are not reportable under the regulations, NNECO has advised the NRC of each of these matters).
U.S. Nucisar R:gulatory Commission B17138\ Attachment 2\Page 10 Results are not'only measured'by the remediation of mistakes, they also appear in proactive efforts to enhance the opportunities for success. Many different work groups across the site have independently formed SCWE groups, organized meetings, solicited assistance, or taken other steps to monitor their actions and to enhance the work environment. These efforts, although less visible, and at a smaller scale, are extraordinarily important. Such efforts, voluntarily initiated, confirm that the; culture has ;-
changed and that the message of a safety conscious work environment has not o' nly been received, but accepted.
Disoosition of Restart Related Actions ECP has conducted a review of open ECP concerns to ensure that any issues that have bearing on Unit 3 restart have been dispositioned (including operability, reportability, compliance with design and licensing basis, and compliance with 4 l regulations). As an added precaution, the ECP reviewed all ECP concems opened '
after 1990 which were related to Unit 3 or the site as a whole. That expanded review also found no issues which could adversely affect Unit 3 restart. Additionally, the SCWE organization has evaluated the current Focus Areas to ensure that there are no issues within those work groups which would jeopardize restart. All active Focus Areas- i are still accomplishing their. duties and responsibilities at an acceptable level. ~ Finally,
' SCWE-related restart items in the corrective action program have been addressed, and mode-restraint and post-restart items are being tracked for completion.
ECOP Concurrence l
As' noted earlier, NNECO has based its restart status on the satisfaction of the four :
su'ccess criteria as well as on the concurrence ~of the ECOP.~ On March 27, 1998,. l ECOP reported that NNECO has satisfied the four success criteria. ;
Nuclear Oversight Concurrence 3 i
f Nuclear Oversight has conclud' ed, based upon the information obtained through the ;
implementation of the Nuclear Oversight. Restart Verification Plan, that significant j progress has been made in establishing a Safety. Conscious Work Environment at
. Millstone to support restart of Unit 3. Nuclear Oversight agrees that a SCWE framework is in place, which: (a) supports the restart of Millstone 3; (b) encourages
- employees to raise concems; and (c) substantially ensures employees who raise concems are not subject to harassment, intimidation, retaliation, or discrimination.
- NSAB Concurrence i
. On March 30,1998, the Nuclear Safety Assessment Board (NSAB) concurred that the -
Safety Conscious Work Environment is satisfactory and will support the restart of the units.
U.S. Nucl=r Regul: tory Cornmission B17138\ Attachment 2\Page 11 i
B.- NNECO is Confident of Sustained Performance In the Near-Term The accomplishments which support the satisfaction of the success criteria were not easily reached. Problems with machinery are often capable of verifiable and permanent solutions. That is not the case with problems which have their roots in attitudes, habits, or behavior. But as difficult as progress has been, it will be equally difficult to sustain.
The progress to support restart of Unit 3 marks only the first milestone in NNECO's .
efforts to strengthen the work environment. Efforts from this point forward will focus on the consolidation of gains, the extraction of lessons leamed, and the institutionalization .
of the processes which will provide for continued advancement.
The key to sustaining performance in the near-term is the maintenance of the l organization, structure, and processes that are currently in place. As noted above, the various organizations which have responsibility for SCWE-related functions have been consolidated under a single executive. That organization has been successful in
)
coordinating SCWE enhancement efforts and in driving SCWE-related issues to the forefront of the site's agenda. Daily coordination efforts will continue. Issues will continue to receive real-time senior management attention. The organization will continue to respond to urgent events affecting the work environment consistent with the established rapid response protocol. Events will continue to be analyzed to extract lessons leamed and the results factored in remedial efforts. Training on SCWE-related j matters will continue, with emphasis on refresher training and training for new arrivals. j i
Finally, as part of the Backlog Management Plan, NNECO will provide periodic post- !
restart updates on the performance of the 16 Key issues, including the status of the l Safety Conscious Work Environment.
C. NNECO Will Continue To Imorove its Work Environment Over the Lona Term Long-term success requires long-term improvement in the Millstone work environment.
In recognition of this, NNECO is developing the 1998-2000 Performance Plan (Plan),
which identifies the Millstone " Work Environment" as a key strategic focus area. To ;
enhance the overall work environment, the Plan focuses attention on the interrelated areas of Leadership, Safety Conscious Work Environment, and Human Resources
' performance. The Work Environment section of the Plan is provided as Attachment 4.
(The specific target dates, performance measures and other details in the Work Environment section may change as the overall Performance Plan development nears completion and as performance and experience dictate.) NNECO will provide the NRC with updates on the SCWE Key issue as committed to in the Backlog Management Plan.
From an organizational perspective, the Plan retains the existing SCWE-related organization through at least the restart of Unit 2. After restart of Units 2 and 3, NNECO will re-examine the organizational structure and - if dictated by performance,
- U.S. Nucl:tr Regul: tory Commission 1 B17138\ Attachment 2\Page 12-not schedule - adjust the organization' to respond to existing needs. Potential organizational changes include:
. The transition to HR of most non-nuclear safety-related SCWE matters.
. - The reduction in the scope of the ECP to permit that organization to focus primarily on nuclear safety-related matters.
. The evolution of ECOP into an independent panel, similar to the Nuclear Safety Assessment ' Board, but continuing to report to the Nuclear President and CEO.
.. Consistent with regulatory consent and dependent upon solid performance, the gradual and conservative reduction in the degree of independent oversight. This reduction could include periodic (e.g. quarterly) independent evaluations until results and self-assessments demonstrate that the independent oversight presence is no longer warranted.
. Apait from these organizational efforts, each of the three key work environment components - leadership, SCWE, and HR - has established specific long-term goals and objectives, performance targets and measurements, and specific action items. And each of these components will make extensive use of self-assessments to enhance performance and to verify that performance expectations are being met. Appendix A of the Plan identifies those self-assessments scheduled for the remainder of 1998.
n Leadership Y Long-term success depends on the presence of strong and effective leaders. The Plan requires that leaders continually improve standards of performance, maintain clear accountability, and provide meaningful and constructive feedback to subordinates. To 4 achieve this goal, the Plan establishes six objectives:
e' ' The development of leadership skills of all personnel in supervisory positions.
. The personal commitment ofleaders to the establishment and nurturing of a Safety Conscious Work Environment. ,
t
. . The commitment of leaders to high standards of performance and the
, _ establishment of clear expectations for their employees.
~
.'- The adoption by' leaders of Millstone's Core Values:
+ Do what is right
+ Respect and care for the individual
- Be a team.. !
! + Be customerfocused.
.y l Vx ;
U.S. Nucirr Regulatory Commission B17138\ Attachment 2\Page 13
. The recognition that safety is the first priority for all leaders.
. The identification of succession plans and the phase-out of recovery teams.
To accomplish these objectives, the Plan has established performance measures and targets. Among the relevant targets are the absence of any SCWE Focus Areas by 1999, a five percent improvement in leadership assessment scores when compared to 9- November 1997 results, and a continuous positive trend in Pil Culture survey results.
The Plan currently contains fourteen action items to facilitate achievement of the performance targets. Several of these items will enhance the safety conscious work environment. For example, the Plan contemplates the provision of initial and follow-up training on SCWE matters, the conduct of Leadership Assessments, the conduct of Pil Culture Surveys, the establishment and communication of safety goals, the development and implementation of a SCWE Guidebook for supervisors, and the development and implementation of a management transition plan to replace recovery teams with NNECO personnel within six months after a unit's restart. The ECP has already begun the transition from a recovery mode to a more normal operational staffing level. Specifically, the ECP now has NNECO employees in the two ECP Manager positions, which were previously occupied by contractors.
SCWE The second part of the Plan's Work Environment focus area establishes m a goal, the ;
achievement of an environment in which all members of the NU Nucksar 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. NNECO has established, as an additional goal, that its ECP will be recognized as an industry "best practice."
The accomplishment of these goals depends on the continued satisfaction of the four restart criteria which NNECO has used to determine restart status. For example, to ensure that employees are willing to raise concems, NNECO has established a target that 90 percent of survey respondents express a willingness to raise concems. NNECO will also monitor to ensure that ECP requests for confidentiality do not create an adverse trend. To ensure that management effectively addresses issues, NNECO monitors the CR average age to ensure it continues to decline with no adverse trends.
' Additionally, NNECO has set a target of less than 3 percent of overdue corrective actions during recovery and 1 percent after restart. To ensure ECP effectiveness, NNECO will guard against an adverse trend in concem resolution timeliness, while ensuring that at least 70 percent of employees indicate that they would use the ECP again. NNECO will also monitor the ratio of ECP concems to allegations received by the NRC, to determine if the ECP receives more concerns than the NRC. NNECO will
~
also require an increase in the quality of investigations. Finally, to ensure that management effectively prevents or resolves allegations of retaliation, NNECO will
m U.S. Nucl=r Regulatory Commission B17138\ Attachment 2\Page 14 strive for, infrequent (or the absence of) substantiated cases of retaliation against
- persons who raise safety concems.
- Supporting the achievement of.the four performance olg v.ves are' twenty-two action items. For example, to ensure that employees nre willing to raise concems, NNECO will evaluate its existing reward system and develop and implement a site-wide plan to recognize and reward employees who raise concems. To~ ensure that management is effective in evaluating and resolving concems, NNECO will develop and implement
" quick ' start" training for new supervisors and managers. It will also implement integrated, one-stop supervisory training to improve training effectiveness. To enhance the ECP, NNECO will provide increased skills development training and lessons -
leamed reviews from past ECP cases. It will also design and implement an improved method for ECP case classification, analysis, and resolution.
Finally, to ensure management's increased effectiveness in resolving SCWE-related events, NNECO has identified twelve action items. Several of these items call for the evaluation of .SCWE performance measures for the purpose of considering any organizational changes. Several also focus on the use of improved' tools and methodologies for monitoring the effectiveness of SCWE functions. The Plan also includes the creation of " assessment windows" or scoring criteria which requires:
(a)the iriitiation of a Level 2 Condition Report if-a SCWE KPl _ reaches ~ a " yellow" indication in two consecutive months or any " red" indication; and (b)the initiation of a Level 1 Condition Report (which requires, a formal root cause investigation) if there are four consecutive " yellow" indications, or two consecutive " red" indicat6ns.
i
- Human Resources .
' The final element of the Plan's Work Environment focus area establishes as a goal for .
-I Human l Resources, line management's recognition and effective u'se of the' HR l organization as a source of competitive advantage.
Like the two other elements In the Work Environment focus area, HR has also j established performance objectives, performance measures, and targets. Among the 1 objectives which bear most directly on the safety conscious work environment are the-establishment.of an organization which values diversity, which develops a " deep leadership bench," and which consistently applies fair practices.
The-Plan . establishes specific targets to measure.HR performance. These targets
. 1 include: (a) escalating levels of HR customer feedback ratings by employees; (b) 90 I percent of performance ~ appraisals conducted on time; and (c) a desired level of minority and female representation in the workforce'. The action items concentrate on actions which will improve employee satisfaction, morale, and teamwork.' Among these
.are the development and implementation of a rewards and recognition strategy, re- ,
evaluation of the compensation structure, and the conduct of; visions / ' values
. workshops.
W . U.S. Nucl cr Regulitory Commission 7 B17138%ttachment 2\Page 15 y a Y
L.\.
Conclusion The collaborative and concerted efforts of management and employees have created a-
' safety: conscious work ' environment at Millstone. The achievements which-brought v about this new environment are the foundation for future growth.L The recognition of the
-need for continued efforts, however, should not mask, or detract from,' the' progress achieved.
q The stark findings of the FCAT and the MIRG are now only reflections of the past and not glimpses of the future. As the events . described in this document have-demonstrated: (1) Current senior management has exercised effective leadership and has articulated and implemented appropriate vision and direction; (2).NNECO has established and maintained high. standards and expectations; (3) . Management's leadership, managerial, and interpersonal skills are satisfactory and are improving; (4) l NNECO's programs are effective in resolving employee concems; (5) Managers j responsible for discrimination have been appropriately disciplined; (6) Management !
effectively implements correction action; (7) Management admits its mistakes; and (8)
Management has the skills necessary to handle employees' concems and has provided !
visible support to those employees who have raised concems.
The work environment at Millstone supports the restart of Unit 3.
- i'.
I,
.I ' ;
)
1 Docket Nos. 50-245 j 50-336 l 50-423 )
B17138 l l
i Attachment 3 Millstone Nuclear Power Station, Unit Nos.1,2,3 Millstone Has Established A Safety Conscious Work Environment -
Which Will Support Restart And Enhance The Safe Operation Of The Units March 1998
U.S. Nucirr Regul: tory Commission B17138\ Attachment 3\Page 1 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 '
Millstone Has Established A Safety Conscious Work Environment Which Will Support Restart And Enhance The Safe Operation Of The Units
1.0 Background
On October 24,1996, the NRC issued its " Order Requiring independent, Third-Party Oversight Of Northeast Nuclear Energy Company's Implementation Of Resolution Of Millstone Station Employees' Safety Concems." The Order described the Commission's concem "about the manner in which [NNECO] has!
treated employees who brought safety and other concerns to the attention of . . .
management." As a result, the Commission ordered NNECO to retain an independent, third-party to oversee NNECO's implementation of a comprehensive plan to improve NNECO's resolution of employees' safety concems and to ensure the fair treatment of those employees who raised concems.2 I
The Commission's Order came at a time when NNECO was coming to grips with I the magnitude of the challenges facing it. In May_1996, NNECO established a j Fundamental Cause Assessment Team (FCAT) to determine whether management's actions were addressing effectively the causes for Millstone's
. performance. The FCAT identified three fundamental causes in the decline in Millstone's performance:
Senior management did not consistently exercise effective leadership and articulate and implement appropriate vision and direction; q 1he Nuclear organization did not establish and maintain high standards and expectations; and The Nuclear organization's leadership, management, and interpersonal skills were weak. l These same general themes were apparent in the more specific findings of the NRC's Millstone Independent Review Group (M',RG). The MIRG reached five plincipal conclusions about the work environmer( at Millstone:
1 Order Requiring Independent, Third-Party Oversight Of Northeast Nuclear Energy Company's implementation Of Resolution Of Millstone Station Employees' Safety j Concerns, October 24,1996 (Order), at 1.
2 The Commission ordered the third party to: (a) obsewe and monitor NNECO activities; (b) {
perform technical reviews; (c) audit and investigate, when recessary, cases of alleged harassment; (d) audit and review, when necessary, NNEGO's handling of employee ;
safety concerns; and (e) assess and monitor NNECO's performance. J1 at 3.
.U
v:
[_ , U.S. Nucinr Regulatory Commission
. , JB17138\ Attachment 3\Page 2 The' large number of concems being brought to the NRC indicated that NNECO's programs were ineffective in resolving employees' concems;
, Managers who were responsible for discrimination were not appropriately disciplined; Management was ineffective in implementing corrective action; ;
1 Management was reluctant to admit mistakes; and
' Managers lackeci the skills necessary to handle their employees' concems and were generally not supportive of those employees.
The essential message of these reports, and others, was unmistakable. NNECO must make fundamental changes in the way it conducts its business, and in particular, in the way it addresses its emplovees' safety concems.
The simplicity of the statement of the problem, however, belies the depth of the challenge. Hardware problems can be definitively, and sometimes expeditiously, !
. fixed. But problems which are rooted in' behavior, attitude, and habit defy the forced imposition of expeditious or unwelcome solutions. Rather,-advancements
. - 'in the working" environment come about only in time and only through the f extraordinary and collaborative efforts of management and employees. NNECO understands this. As a result,.It has committed itself to the achievement and maintenance of a safety conscious work envircament.
'The programs and events highlighted in this document must be viewed in context.
First, the advancements represent _ NNECO's efforts to date to rebuild a healthy 4 working j environment. These advancements are significant~ and reflect a -
fundamental change in business practices. By no means, however, does NNECO
+ consider the objective reached or its goals attained. NNECO's objective is to M Jcreate a healthy and safe working environment which thrives in the long-run, Eduring periods of sustained power operations, and not only in times of intense regulatory scrutiny. Second, the achievements addressed here have not been
- easily reached. NNECO takes justifiable pride in its accomplishments, but it also
_ recognizes that'even its recent history has not been unblemished. But that is both the nature of the problem and, to a certain extent, a preview of the future. Despite
_.the best efforts of well-intended managers and employees, missteps will occur.
.When problems arise in the future, however, they will be met by a company that is -
prepared with the resources, skills, and commitment to resolve the problems.
. With a clear understanding of the past, a full appreciation for the challenges of the future, and a firm co;nmitment to sustained excellence, NNECO reports that it has
. . achieved a safety conscious work environment at Millstone Station.
y-m
+
U.S. Nucl2:r Regulatory Commission -
.B17138%ttachment 3\Page 3
~2.0: Millstone la Ready For Restart
- Demonstrating the presence of a safety conscious work environment is difficult, given the subjective nature of the assignment. To ensure that any finding has a s
,T_ basis'in credible, ' verifiable evidence, NNECO has established four success 4 criteria:
i: - -
Employees possess the willingness to raise concems.
- Line management effectively resolves issues.
~ . The Employee Concems Program operates effectively.
'* Management . . recognizes and effectively Laddresses allegations of discrimination. '
An analysis of each of these criteria demonstrates the significant strides that ~
'NNECO has made since the issuance of the Commission's Order and the soundness of NNECO's conclusion that it is ready for restart.
Little Harbor Consultants (LHC) has held seven meetings with NNECO and the NRC which . were open for public observation. on May 13,. l June 3, July 22,
- September 24, November 13,1997, January 27, and March 3,1998. LHC has -
made a number of recommendations during these meetings and in a number of docketed letters. NNECO has . provided ' written responses ' to the -
- i. , recommendations. LHC has provided docketed. assessments of1 the.
Improvements'and status of Millstone's Employee Concems Program and the .,
work environment, and will provide its assessment of restart readiness separately ~'
1 to the NRC.
l
-2.1 FIRST SUCCESS CRITERlON Employees Possess The Willingness To Raise Concerns
- Before requesting restart, NNECO leadership must have confidence that the employees' at Millstone are willing to raise concems.' The employees' willingness to do so provides solid assurance that safety issues, if identified, will be raised and not suppressed for fear of retaliation. Many complementary indications l
NNECO's approved third-party overseer, Little Hart >or Consultants (LHC), has developed l additional attributes of a safety conscious work environment, but has organized them into the four general criteria set forth above.
The relationship between the four NNECO success criteria, the twelve LHC success
' criteria, and the Commission's attributes, as articulated in its Policy Statement on a Safety c ~ Conscious Work Environment is set forth in the table attached as Appendix A.
l 1
L !
L l n
. U.S. Nucimr Regulitory Commission B17138%ttachment 3\Page 4 -
confirm that the Millstone workforce possesses the willingness to raise concems,
= the confidence that their concems will be addressed, and the knowledge that their raising of concems will be welcomed and not be met with retaliation.
2.1.1 Survey Results The Commission observed in its.1996 Order that "it appears some employees have been. reluctant to identify safety concems." 5 Survey and interview results indicate that this condition no longer exists at Millstone. Recent results indicate
.that nearly all NNECO employees are willing to raise issues with management for resolution. In a series of 298 structured interviews conducted by LHC in February 1998,100 percent of the employees. interviewed indicated.that if they became aware of a problem that could affect the' safe operation of the plant, they would raise the concem. Moreover, about 99 percent of those employees also indicated that they would raise the concem with line management These LHC findings are consistent with a NNECO Leadership Surveya conducted in late ?997, which found that 97 percent of supervisors were rated as effective in i
handling employee concems. Likewise, NNECO's Employee Concems Oversight Panel (ECOP) conducted a similar survey in the fourth quarter of 1997.7 That survey concluded that 95 percent of the employees agreed with the following two statements: (1)."If I had a safety concem, I would raise it using one'of the available avenues;" and (2) "If I had a safety concem, I would take it to my immediate q
supervisor." : Another. ECOP survey conducted in the first quarter. of _1998 1 confirmed these conclusions. Together, the LHC structured interview results, and the Leadership and ECOP surveys are strong evidence that the workforce not only {
possesses the willingness to raise concems, it also has the confidence to raise concems directly to supervision.
These results are generally consistent with a recent NNECO Culture Survey 8 which indicates that approximately 82 percent of the employees believe that a 5
l Order, at 1.
- The Leadership Assessment Survey, developed by the Center for Creative Leadership, is .
given periodically to provide Millstone leadership feedback on their strengths and l
weaknesses. l l
'7 I ECOP survey groups are chosen based on several factors: random draw, reported
' difficulties, specific line requests, and past history. In addition, a core group of Millstone
' employees has been established who are routinely surveyed to monitor the pulse of the j
~ workplace environment.
8 Four administrations of the culture survey have been conducted at Millstone, starting with the June 1997 survey. The survey is based on a standard survey instrument developed
U.S. Nucl=r Regul: tory Commission B17138\ Attachment 3\Page 5 safety conscious work environment exists in their work areas. Although NNECO j does not regard 82 percent as meeting its long-term standard, if 82 percent of I employees surveyed believe that their particular work area enjoys a safety conscious work environment, and if 97 to 99 percent of employees are comfortable f
j raising concems 'with line management, the surveys jointly show that even , {
employees who may work in areas which have not reached an optimum level are still comfortable raising safety concems with management. The bottom line is that, although NNECO clearly has work to do in ensuring that the employees are 4 comfortable with their work environment, virtually all employees are comfortable raising safety issues with management. That conclusion, based on multiple sources of intemal and extemal data, gives NNECO leadership confidence that, to l the extent employees have safety concems, they will raise those concems with !
management and not permit them to remain unresolved. i 2.1.2 Trends in Confidentiality and Anonymity Reauests In addition to the survey results, NNECO has also sought to assess the employees' willingness to raise concems by monitoring any trends which may appear in the percentage of ECP concemees who file anonymously or request .
confidentiality. Like oths indicators, this statistic in isolation is not conclusive. )
But, together with oth- data, it sheds additional light on the issue of the 1 employees' willingnese to raise concems.
From July 1997 through February 1998, in all months except December and '
i January, about one-third of the employees each month' either filed concems anonymously or requested confidentiality. The absence of an adverse trend in the percentage of employees who seek to shield their identity provides some additional comfort that the relatively healthy environment identified in the surveys '
remains intact. Of course, NNECO hopes to see an eventual decline in these -
percentages, which will suggest that employees are becoming increasingly more confident in their ability to raise issues.
That some employees who file ECP concems still suffer from some hesitancy to disclose their identities is not surprising. Experience teaches that a certain percentage of people will always choose anonymity, if afforded the opportunity.
~ And given the ingrained perception of Millstone's historical lack of receptivity to by Failure Prevention Intemational (FPI) with questions relating to SCWE added by NNECO.
An increase in the number of anonymous concems occurred in December and January, however no discemible pattem was detected. The increase is likely influenced by efforts to foster a SCWE, including extensive training given to the workforce. When taken as a percentage of total concems, the value has not changed significantly.
U.S. Nucirr Regul: tory Commission B17138\ Attachment 3\Page 6 concems, some people will automatically default, at least in the near term, to the ,
most secure approach.
l 2.1.3Ihe_Mumber Of Concerns Raised ,
i Perhaps the most obvious way to explore the employees' willingness to raise concerns is to examine the number of concerns actually raised. As discussed under the Second Success Criterion (Section 2.2), the greatest number of issues are being identified at Millstone through the corrective action program. NNECO Employee Concerns Program (ECP) data shows that on the average, the ECP !
receives about 20 concems of all types' each month. 2 A large number of concerns can support either of two, seemingly contradictory, conclusions. First, an increase in tha number of concems could be a positive 1 Indicator because it reflects a healthy work environment in which the employees !
raise concems because of their commitment to the Company, their desire to I enhance performance, and their acceptance of their responsibility to raise concerns. On the other hand, an increase in the quantity of concems could signal a management failure to address the issues in the normal course of business. In ,
the end, there is no way to state conclusively which message is correct. But i several indicators suggest that the number of concems raised at Millstone signals j a positive development in the establishment of a safety conscious work l environment.
l First, management has made a concerted effort to encourage employees to raise l concems. Since his arrival in September 1996, Mr. Kenyon has constantly i
. delivered the clearest of messages - Management expects employees to raise concems. Indeed, Mr. Kenyon's " Expectations For Employee Concems at j Millstone" could not be clearer. Among other things, "everyone" at Millstone is to: !
Maintain a questioning attitude, challenge the status quo, and make suggestions for improvement. ,
immediately report those items you don't feel are right or that you feel are unresolved.
Try to first resolve your concem through your supervisor. I The NNECO ECP receives and resolves concems of all types - not Just concems involving nuclear safety or other matters regulated by the NRC. For instance, the ECP !
handles personnel complaints, pay problems, work condition complaints, and allegations of all forms of discrimination.
l U.S. Nuclear Regulatory Commission ' !
B17138\ Attachment 3\Page 7 1
I y *
. As an attemate to your supervisor, work to resolve your concem through )
another member of management, the' Employee Concems Program or the !
Nuclear Regulatory Commission. 'l Mr. Kenyon's " Expectations" make equally clear management's obligations. l Among these are -
i Promote the new employee culture with your words and actions - walk the talk. !
Foster a questioning attitude in the people that work for you.
Create a non-hostile work environment. Immediately resolve any situations ,
involving potential harassment, intimidation, discrimination or retribution by !
anyone. !
Celebrate and recognize individuals who identify and/or help resolve significant a concems. l I
The February 1998 LHC structured interviews showed that 99 percent of the j interviewees were aware of these expectations. ;
Second, management has reinforced the message with action. As discussed later, when persons have discriminated against employees, they have been held accountable. Likewise, when mistakes have occurred, at vvhatever. level, management has publicly acknowledged the shortfall and taken corrective action.
Third, management has rewarded employees who have raised concems. Indeed, the February 1908 LHC structured interviews revealed that 78 percent of the ;
employees had personal knowledge of employees who had received an award or 1 praise for having raised a concem. This statistic is impressive in its own right, but !
all the more impressive when compared to the' results from the June 1997 LHC !
L structured interviews, when only 48 percent of the employees knew of employees )
1 who had been rewarded for having raised a concem. ;
Fourth, given the substantial number of technical reviews, audits, and inspections !
that have occurred at Millstone since the shutdown of the units in late 1995 and :
1996, an increase in the gross number of issues and concems being raised is to l be. expected.- Were that not the case,'the quality of the reviews and assessments !
would be questionable. Accordingly, NNECO views the initial increase in the l number of concems as indicative of a workforce that has taken management's message to heart, and a work environment in which employees exhibit a healthy
. questioning attitude. '
Finally, although the number of concems being raised about Millstone with the h " NRC is large by comparison to other facilities, recent data, nevertheless, suggests l
o-U.S.' Nuclear Reguintory Commission
. B17138\ Attachment 3\Page 8 that NNECO is making steady progress. Specifically, in 1995 and 1996 the NRC received more concems than the ECP. That relationship has been reversed. In 1997, the ECP received more than twice as many concems as did the NRC. And since~ October 1997, the ECP has reccivec 105 concems, compared to 21 3 received by the NRC.
2.2 ' SECOND SUCCESS CRITERlON Line Management Effectively Resolves lasues The inability or unwillingness to resolve issues raised by employees creates a-roadblock to_ the establishment of a safety conscious work environment. If
, employees believe that the Company will not address their concems, they will be reluctant to raise issues with management. Moreover, if an employee raises a concem, but does'not see the concem addressed in a timely and respectful manner, the employee receives the message - whether intended or not - that the Company has no interest in his or her concem.' In either instance, the work environment suffers.
in recognition of the importance of addressing issues, NNECO has made substantial progress in upgrading the quality of its Corrective ~ Action Program. In February 1%7, NNECO established and implemented a site-wide Corrective
- Action Progren'. Although some improvements in the program remain to be fully ,
implemented or fully effective, issues are now being addressed in a timely manner -I and as part of an overall approach designed to ensure the proper resolution of the concems.-
2.2.1 Threshold for Reporting Adverse Conditions I l
As previously discussed, NNECO has strongly encouraged its employees to raise l co.ncems. Consistent with that overall message, NNECO .has lowered the !
threshold for the writing of Condition Reports (CR) to include questions and improvement and enhancement items. NNECO has intentionally established this low threshold because it prefers to have an employee initiate a CR and to have the matter addressed, rather than to have the employee retain an issue and permit the issue to remain unresolved. To reinforce the importance of self-reporting, NNECO
- has also conducted extensive training in the area of self-assessment techniques.
As a result, in 1997, there were 10,511 CRs written at Millstone Station - a vast -
Lincrease over the'6,455 CRs written at Millstone in 1996, and the 3,805 ACRs I written in 1995.
2.2.2Self Assessments An integral part of an effective Corrective Action Program is the conduct of critical self assessments. As noted, NNECO has provided training to its management team and professionals to enhance the quality of these assessments. The results -
. _U.S. Nucirr Regulttory Commission B17138%ttachment 3\Page 9 1
of;these efforts are promising. The February 1998 LHC structured interviews
- showed a marked improvement in the area of self assessments. In particular,98 percent of the interviewees were aware of self assessments being performed within their work groups.- And,92 percent were able to provide examples of useful results which arose from the self assessments. The recognition of the value of self
. assessments is testimony to the efforts made thus far and a good indicator that
. high quality self assessments will continue.
2.2.3 Expeditious Resolution of Condition Reports Once raised, it is incumbent upon the Company to address issues expeditiously.
To do this, NNECO has established a policy of conducting an operability and
. reportability screening for a CR during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the initiation of the CR. NNECO's tracking of its performance indicates that this goal is being consistently met. CRs are written if the expectation is not met.
Similarly, NNECO has. established a goal that the average length of time for a Level l and _Il CR evaluation should not indicate an adverse trend, along with an intemal goal of completing 95 percent of all Level I and ll CR evaiustions within 30 days. The latest evaluation of the CR process shows that NNECO has virtually accomplished that goal for Unit 3. For Unit 3, the' current average age of CR evaluations is about 22 ' days, with 94% completed within 30 days. The ~overall trend indicates that CR evaluations are being completed in a timely manner.
2.2.4 Quality of Condition Report Evaluations The effective: resolution of_ concems requires 'more than the, expeditious dispatching of the concems. It also requires a high quality in their resolution.. The data tracking quality of CR evaluations through NNECO's Condition Report Evaluation' Score, indicates that the quality of the Unit 3 CRs is good and improving. The Condition Report Evaluation Score is developed by averaging all .
CR evaluations reviewed each month by the Management Review Team. A CR receives a score 'of "4" if its evaluation is accepted without comment, a "2" if it is accepted with comment, and a "0"if it is rejected.
Management has established a goal of the average of Condition Report Evaluation
- Scores to be at least 3.0. That goal is being met, indeed,' in 1998, only two weeks had CR average quality ratings below the goal of 3.0. The other weeks were particularly good and had average quality scores of between 3.1 and a perfect 4.0.
7
- U.S. Nucisar Regulatory Commission p B17138\ Attachment 3\Page 10 -
I 2.2.5 Overdue Corrective Actions The processing and evaluation of CRs does not complete the work. Indeed, for the issue resolution process to be. effective, there must be timely management follow-through. Accordingly, management has established a restart goal of having l no more than 3% overdue action assignments which arise out of CRs. Since mid -
1997, NNECO has seen a demonstrable improvement in the reduction of overdue actions in Unit 3. Specifically, in July 1997, about 14 percent of the actions were
- overdue. There has been a steady reduction since then, and now the percentage
!. of overdue assignments is approximately 3 percent.
l L 2.3 THIRD SUCCESS CRITERlON The Emc-!cy;; Cc-s =-T.s Presse.r. Ones ' - Ei'h ":as y The NNECO Employee Concems Program (ECP) provides the Millstone workforce with an attemate means for raising concems. NNECO encourages its l employees to raise concems directly with management because experience shows that the management chain will address concems in the most effective and expeditious manner, if, for whatever reason, an employee prefers not to raise's
( concem with ' management, NNECO encourages the employee to raise the concem with the ECP.
In fulfilling its mission, ECP receives a wide variety of concems. ~ Some relate to
' 3 inuclear. safety, while most . relate to management actions,' personnel' matters, _ !
'. Company policies, industrial safety, security, or some other issue of importance to the employee. Significantly, the resources of the ECP are not only available to all NNECO employees, but also to former employees and contractors. i
- 2.3.1 j
- 1. StafRng Quality and Quantity Have Greatly improved Before the plants were shut down, the predecessor to the ECP [the Nuclear Safety Concems Program (NSCP)] had a staff of three investigators, one secretary, ' and a Director. . - None of the . Investigators had professional !
experience or formal training in handling employee concems before receiving l l his or her assignment to the NSCP. Not surprisingly, the organization lacked !
the stature, resources, and management. support to be an effective catalyst for -
the achievement of a safety conscious work environment. ~ Indeed, a NNECO !
self assessment in January.1996 concluded that'the NSCP inadequately I resolved issues, lacked executive management support, and, in general,~ had j not effectively implemented past recommendations.
'l
L U.S.' Nuclear Regulatory Commission B17138\ Attachment 3\Page 11 That organization no longer exists., The lessons of the past have been taken to heart and, more importantly, acted upon.
in the area of staffing alone, the ECP_ stands apart from its predecessor. - The ECP now has a new Director,2 Managers, and 15 investigators, in addition to a 6-person support staff. ' The Director is a retired nuclear Navy Captain with years of oversight and command responsibility. The team includes former investigatora from a variety _ of nuclear facilitien around the ' country.
Additionally, the team includes professional auditors, engineers, attomeys, e quality assurance experts, human resource professionals, private investigators, and two people who have held Reactor Operator or Senior Reactor Operator licenses.
The ECP has not been satisfied to rely on the training and experience that its staff acquired in the past. Within the past 12 months, NNECO has provided its .
ECP staff with- training in the following areas: regulatory responses; legal .
issues in employment; interviewing _ skills; effective report writing; investigation planning; time management; introduction to plant systems; interpretive skills;
, communicating with regulators: 10 CFR 50.7; and the conduct of investigations ;
involving allegations of discrimination. '!
- 2. ECP Has'the Ac*ive Saaaant of Senior h=aament I Visible senior management support for the ECP has been important in reestablishing the credibility and prestige of the organization. As previously noted, Mr. Kenyon's Expectations for Employee Concems explicitly and-publicly-record his support for the ECP organization and the process. His .~
expectations not only ' encourage employees to. use the ECP, they also i encourage management to call upon the ECP for advice, and they direct management to "[b]e responsive to concems brought to you by the ECP."
Management has matched its words with action. In particular, the substantial )
allocation of resources to the ECP sends an unmistakable signal to the site as well as 'the ECP, that the ECP enjoys the active support of senior l management.
In many respects, the relationship between the ECP and management is that .
of a cooperative partnership formed for the resolution of employee concems. '
For example, when an ECP investigation substantiates a concem, the ECP and management develop appropriate corrective actions. Those corrective actions are then placed in NNECO's action tracking system for purposes of ,
tracking the corrective action to ensure that the actions occur.' in this respect, the corrective actions which flow from the ECP are treated the same as those corrective actions which might arise from technical work or plant inspections. :
This process ensures ~ commitment and accountability.
i
l j
U.S. Nucl=r Regulatory Commission B17138\ Attachment 3\Page 12 As part of this cooperative effort, ECP has often called upon management to _,
provide the resources necessary to assist in the investigation of a concem. For instance, it is not uncommon for ECP to request, and receive,' technical or
! engineering assistance in its investigation of an employee's concem.
l Additionally,- tlke ' Director, ECP has access to the highest levels of the i
organization. Currently, the Director reports to the Vice President, Human Services, but= also has direct access to Mr. Kenyon and the NU Board of Trustees. And he has used this access. At a minimum, the Director meets monthly with all the officers to discuss the monthly ECP report and to discuss significant issues, trends, generic matters, or.any other items which the ,
Director deems important for senior management.
Finally, given its access and stature, the ECP plays a critical consulting role in most important personnel actions which could have an effect on the work environment at Millstone.
- 3. The ECP Processes Have Been Enhanced The efficiency of the ECP depends not only on the quantity and quality of the people, but also on the soundness of its processes. In this regard, the ECP has also made tremendous strides.
On April 14, 1997, the ECP issued a new ECP. manual, superseding the- 1 predecessor, which had existed for about eight years. The new manual, which has already been enhanced three: times since publication, is a vast' E improvement over the old manual and, more importantly, is a workable document that formalizes the recent program improvements.
The process now provides for a thorough' intake interview and a rapid assessment (triage) of the concem. raised. ' That triage provides for a systematic assessment of the concem by identifying the nature of t_he concem,-
the safety significance of the concem, the need for an operability / reportability determination, and the preparation of a plan of investigation. Significantly, the Director, ECP and the Manager of ECP Investigations participate in the triage, E along - with the investigator - who conducted the intake intervimv.- The-investigator then conducts the investigation' and prepares a report which is consistent with clearly established requirements and standards. Closure or resolution occurs after the investigation is complete and appropriate corrective
= actions, if necessary, have been identified by line management and the Director,- ECP. Importantly, the process also requires the investigator to
' contact the concemee at least'once every fifteen days to ensure that the -
individual is kept abreast of the investigation. And at the end the investigation,
U.S. Nucirr Regul: tory Commission B17138\ Attachment 3\Page 13 the individual is asked, and encouraged, to provide feedback to the ECP and to the Employee Concems Oversight Pariel.
The ECP has not only formalized its process, it has also established new Administrative Controls to enhance the quality and consistency of its products.
These controls complement the provisions in the ECP Manual and provide for items such as the content and organization of ECP files, monthly statistical and l trending reports, interview formats, and ECP file security. These controls have significantly upgraded the professional quality.of the ECP work product.
2.3.2 The Enhancements Have Produced Results 1.ECP Resolves Concerns In A Timely Manner i When employees call upon the ECP to address a concem, they rightly expect the ECP to look into their matter expeditiously. In their eyes, an unreasonable delay is tantamount to a denial of the importance of their concem, an indifference to the concem, or a breach of the Company's commitment to its employees to achieve a healthy work environment. In years past, the ECP, or its predecessors, did not satisfactorily deliver the desired product in a timely manner. That has changed.
Since the beginning of 1998, the average age of unresolved concems filed with the ECP has been approximately 49 days, which is consistent with the ECP's intemal goal. This result shows a favorable trend, compared to the summer j and fall of 1997, when the average age of unresolved concerns varied between '
50 and 75 days. And in eariy 1997, the ECP merely hoped to have no concerns which had been opened more than one year.
Although NNECO will continue to measure the ECP's speed of resolution as an indicator of efficiency, it does not view this statistic alone as indicative of the success or failure of the organization. Some concems will undoubtedly require more time to investigate and resolve because of their complexity and scope.
We recognize that the ECP must not feel pressured by closure statistics to truncate the investigation or reach a hasty and erroneous conclusion for the sake of achieving a desired statistic.
- 2. Most Emnioyees Are Satisfied with ECP Another important indicator of success is the willingness of employees who have used the ECP to use it again. A review of current data indicates that: (a) the ECP is meeting expectations; and (b) the percentage of satisfied employees is increasing.
U.S. Nucinr Regulatory Commission B17138\ Attachment 3\Page 14 l
In L December of 1997, the ECP began a program to enhance employee !
satisfaction. Among other things, the ECP began reviewing preliminary l investigation findings with the employee. The ECP also established a practice of meeting with the employee before resolving the concem. Additionally, the-ECP now contacts the. employee every 15 days to discuss the status of the
. investigation. Furthermore, the ECP is making a concerted effort to ensure that all letters to the employee are clear and more personal. These.
improvements appearin Revision 3 of the ECP manual.
As a result of these efforts, and others, customer satisfaction has increased. In June of 1997, about 62 percent of the employees surveyed told LHC that they would use the ECP again if they had a need. In January of 1998, the number increased to approximately 75 percent, according to one ECOP survey, and to 83 percent, according to another LHC survey. Near the end of the first quarter -
of 1998, an ECOP survey indicated that 90 percent of employees would use the ECP again. ' In the February 1998 LHC structured interviews,93 percent of -
the employees ladicated that there was no reason that they would not use the ECP. Regardiess of the precise statistic, the trend is good and the results encouraging.
Even if the true number of employees willing.to retum to the ECP stays near the current survey results, the results are not disturbing. Indeed, it might be unrealistic to expect to find statistics much higher than those already being _;
reported. Many of the concems investigated by the ECP tum out to. be
. unsubstantiated or, if substantiated, do not produce the precise outcome-desired by the concemed individual. Even though propedy investigated and properly resolved, the employee may - nevertheless feel disappointed or unsatisfied with the result. NNECO will continue to measure this statistic, but will not overreact to the emergence of a stable state at around 70 percent.
3.ECP is independent and Credible A key component in judging the effectiveness of the ECP is the ability of the ECP to act with independence. This 'means that the organization must objectively investigate concems and reach conclusions supported by. the investigation.' The organization cannot become either a rubber stamp for I management or an advocate for each concemed individual. Moreover,- I success in this area will not be found in a statistical comparison of findings "for" or '"against" the concemed individual. Rather, independence ~ can be determined by examining a variety of measures. ,
1 Clearly, the employees' willingness to use the organization again is a positive sign of independence. If the ECP were viewed as having a management bias, the level of satisfaction would not be at the current levels. Additionally, the most recent evaluation of the ECP performed by the NRC confirmed that "the
U.S. Nucl::r Regulatory Commission B17138\ Attachment 3\Page 15 ECP organization' ha[s] independence, resources, and management support to perform unbiased investigations." " In reaching these conclusions, the NRC reviewed eighteen ECP. case files and noted that the ECP conclusions were
' supported; by the investigations and that- the corrective actions were appropriate. To assure the continued independence and quality of the ECP, the organization conducts self-assessments. Again, the NRC found that the self-assessments were " adequately self-critical" and the results " appropriately disseminated to plant management and staff."
A review of several specific matters. confirms the independence of the ECP.
For example, the ECP conducted an investigation of allegations surrounding the removal and/or discipline of three persons who had raised concems in' the course of their work in the Motor Operated Valve Group. The ECP concluded that the employees' protected activity.had played a role in the adverse action.
Although senior management initially did not act on the ECP's recommendations, the ECP Director persisted in his view, revisited the issue, and ultimately prevailed. As a result, NNECO offered the_ employees re--
employment and began the process of removing the responsible managers from their positions. Those managers (who were contractors) voluntarily resigned. Unquestionably, the preferred result would have _been the outright prevention of the -adverse action in the first instance; but having already occurred, the ECP performed the next best service - the identification of the error and the facilitation of remediation. ECP did not hesitate to make the call against the Company or to challenge senior management's initial assessment.
Significantly, the ECP suffered no adverse reaction from management because of its position or a:tions. In fact, the resolution of the case enhanced the ECP's stature.
Finally, the ECP conducted a self assessment in November and December 1997 to determine the effectiveness of selected commitments and initiatives which had been taken to improve the process for addressing employee-concems. The assessment was probing and critical. It identified various strengths and weaknesses, but it found no deficiencies which could adversely ,
affect nucler.r safety. l L2.4 EQUBIHEllCCEBR_CBlIERlON Management Can Recognize and Effectively Deal With Allegations of Discrimination The fourth success criterion requires that management demonstrate that it can l recognize and successfully deal with allegations of harassment, intimidation,
]
Letter from Philip F. McKee, Deputy Director for Licensing, Special Projects Office, to Martin L Bowling, Jr., Recovery Officer Unit 2, February 18,1998, at 1.
. I i
j
U.S. Nucl=r Regul tory Commission .
B17138\ Attachment 3\Page 16 retaliation, and discrimination, or other-circumstances which create a chilling
{
effect. Not surprisingly, success under this criterion was-the most difficult to achieve. NNECO is confident, howevar, that it has satisfied this criterion. It also recognizes that the prevention of retaliation is the most difficult challenge that the NNECO faces in establishing and maintaining a safety conscious work environment.
To eradicate d' iscrimination from the workplace, NNECO has established (or enhanced) a series of interrelated training programs and developed various organizations and processes to detect and prevent discrimination from occurring i in the first instance. If these multiple defenses fail, NNECO has demonstrated the
, capability and the will to remediate the effects of any discrimination.
2.4.1 Prevention Of Discrimination
- 1. Pree:ation of Disc..:... nation Through Training To be able to prevent discrimination, management at all levels must have the necessary skills and knowledge. The starting point for the development of these tools lies in the establishment of an integrated training program. In constructing this program, NNECO has recognized that many matters which ultimately result in confrontation and turmoil have their roots in ineffective leadership. As a result, the enhancement of management's leadership skills is essential in the creation of a safety conscious work environment and in the avoidance of discrimination.
Formal management. training has occurred in four separate, but related, j courses. First, about 90 percent of all members of the NNECO management ;
team have participated in training to leam the fundamentals of 10 CFR 50.7. i The purpose of that training was not to have managers become legal or~ i licensing experts, but, through lecture and case studies, to recognize prohibited conduct for the purpose of avoiding it in the first instance. That training not i only emphasized the importance of preventing discrimination against l individuals, it also focused on the importance of taking the necessary action to prevent the. creation of a chilling effect, regardless of the outcome of the specific case. !
The second component of the training program requires that management successfully complete the Managing For Nuclear Safety course. The purpose ,
' of this course is to develop in management the skills necessary to foster a.
workplace environment in which employees are comfortable raising concems. l In April 1997, NNECO revised the program to include a training module on the 4 function = and ' operation of the ECP. To date, almost 97 percent of all !
supervisors and above have successfully completed this course.
~
. U.S. NucLer Regulatory Commission B17138\ Attachment 3\Page 17 Third; NNECO has hired a consulting firm, Xcaliber Consulting Group, to -
conduct a Forum For Leadership Excellence (FLE). This course does not focus on the raising of safety concems, but it establishes standards and.
expectations, and provides supervisors and managers with new ways. of
~
thinking and behaving in their positions, in other words, it seeks to provide the -
management team with positive and creative ways of accomplishing the work group's objectives. In this way, the course, will assist in ~ eliminating past leadership styles and techniques which may have contributed to an unhealthy environment. To date, about 72 percent of the_ supervisors and managers of Units 1 and 3 (and those whose support organizations interface.with these units) have completed this course._ Unit 2 supervision is completing a similar course titled " Enlightened Leadership." By mid-1998, NNECO expects that - <
over 95 percent of supervisors and managers will have attended one of these courses.
Fourth, NNEOO has trained almost 94 percent of its leadership in the Civil' Treatment For Managers. Similar to the courses discussed above, this course seeks to teach. supervision the personal skills and behavior necessary to enhance the work environment. Through classroom instruction,' case studies, -
and role playing, the paiticipants leam to avoid disruptive _ behavior which could inhibit workplace professionalism or create friction.
These four courses teach ' principles and skills which, together, have. made substantial progress in raising the sensitivity of the management team and in preventing discrimination. Simply stated, a manager who: (a) treats employees '
with respect (Civil Treatment); (b) provides fresh and innovative leadership (FLE);~(c) creates a workplace which is receptive to the raising of concems-(Managing For Nuclear Safety); and (d) understands the requirements and .
proscriptions of the law (50.7 Training), will have the fundamental skills necessary to establish and maintain a safety conscious work environment and, thereby, avoid the discrimination of those employees who engage in protected activity.
In addition to these formal courses, NNECO has conducted two "all hands" management meetings (one in September 1997, one in January 1998) to address issues affecting the maintenance of - a safety conscious work )
environment. Each of these sessions was held off-site and attended by over j 400 members of the management team. Although specific topics varied at each meeting, the central theme was that senior nuclear management was placing the highest priority on the continued improvement in the quality of the work environment at Millstone. The discussions at these meetings were far more than the mere recitation of lofty corporate goals. They included frank acknowledgments by both senior and junior members of management of past
- errors as well as public commitments to progress.
l
U.S. Nucl=r Regul: tory Commission B17138\ Attachment 3\Page 18 The establishment of a safety conscious work environment is not solely a function of management. The employees also bear some responsibility for.its maintenance, in recognition of this, NNECO requires that its employees participate in its "Partne'rship Beyond 2000" course for the purpose of making the employees aware of their role in maintaining a healthy environment. In April-1997, NNECO added a new training module to address the role and operation of the ECP. To date, over 1400 employees and seconded contractors have attended the. Partnership _ course. An ECP training module.has also been included in the annual Plant Access Training requalification program.
- 2. Additional Resources To Prevent Discrimination
. Focused training, heightened awareness, and management leadership are all important parts of the overall solution. But the best trained and best led workforce ~ cannot achieve. the desired results if it lacks the necessary resources. As a result, management has taken the steps necessary to provide additional support to strengthen its SCWE recovery efforts. The additional resources include intemal as well as extemal resources .
-(A) Internal Resources The SCWE Organization The most notable realignment'of intemal resources is visible in the creation of -
the SCWE organization. The organization-was established in May of 1997, with the appointment of an' NU Officer as SCWE Executive Sponsor and the
' assignment of a SCWE Key issue Manager. Currently, the SCWE.
organization; consists of one Manager, one supervisor, and nine other
. employees. The Organization's Manager reports directly to the Millstone Vice-President, Human Services. 'The SCWE organization's function is to provide
, direct and concentrated support for management in its efforts to_ enhance the
- quality of the work environment. This organization also plays a critical role in the. prevention of retaliation in the site-wide disciplinary process.
Despite the group's responsibilities, the SCWE organization has not usurped management's overall responsibility for the maintenance of a safety conscious work environment.' indeed, that responsibility remains with management. But management recognized the importance of the expeditious achievement and maintenance of a safety conscious work environment, and concluded that it must have reliable resources that are devoted on a full-time basis to the pursuit of the goal. The SCWE_ organization provides that immediate and continual coverage.
n
l U.S. Nuclur Regul: tory Commission i B17138\ Attachment 3\Page 19 '
i The SCWE organization has become an integral part of NNECO's work '
environment improvements. For example, the number of groups or leaders who have requested review or assistance has increased steadily. Areas that have sought SCWE ~ assistance -include all unit directors,- managers from
)
j maintenance, operations, unit engineering, program engineers,' procurement, .!
document services, and work services. The type of requests range from requests for a review of performance appraisal information . to formal interventions to improve employee interactions. SCWE is also an integral part of the Executive Review Board (ERB). The SCWE organization, in concert with l the ERB, reviews- every significant disciplinary action, whether for an- NU ' l employee or a contractor, and most contractor workforce reductions, to ensure that protected activity is not a part of the reason for any adverse personnel-action.
l ECE A second notable increase in the allocation of resources has been the radical l enhancement of the ECP. The specific enhancements to this organization j have already been discussed in this letter. Through the massive infusion of
~
experienced personnel, the change of leadership, the creation of _new !
processes and practices, the enhanced stature of the organization, and the :
direct access to senior management, the ECP has become a vital component of the maintenance of a safety. conscious work environment. Essentially,-the I ECP provides an attemative problem reporting and resolution path. Given this function, ECP serves not only as a means for the prevention of discrimination,
.it also serves as an additional means of remediating adverse action in the event tnat discrimination has already occurred. i ECOP 1
in addition to the overhaul and refurbishment of the ECP, NNECO has also established the Employee Concems Oversight Panel (ECOPj. ECOP came i into existence in April 1997, as part of the NNECO's compliance with its i Employee Concems Comprehensive Plan. Its primary purpose is to monitor !
the effectiveness of the ECP and to facilitate the enhancemen' of a safety conscious work environment. In these functions, ECOP provides ranagerront with valuable insight on how management actions and policies are received - !
and perceived - by the workforce. ECOP performs these responsibilities by, ;
among other things, monitoring the workplace for potential chilling effects, l reviewing cases of discipline for ' persons involved in protected activities, i
i
l
~ U.S. Nuclur Regulatory Commission B17138\ Attachment 3\Page 20 conducting empigee surveys on relevant issues, assisting in the identification of" Focus Areas" , and assessing Human Relations issues.
- In performing these responsibilities, ECOP has been successful in several potentially counterproductive situations. By intervening at an early stage and by. facilitating discussions ~ within the affected work group, ECOP was instrumental in' resolving incipient issues and restoring work place stability.
~ ECOP has also identified various areas of improvement for the ECP, which, when acted upon, enhanced employee satisfaction with the ECP.
q Executive Review Board ]
Discrimination against persons who raise concems can take many forms and occur at various levels of an organization. One of the most fertile areas for discrimination, however, is in the imposition of employee discipline. ideally, discipline should be handled at the lowest reasonable management level after
~
consideration of the circumstances of the offense and the history of the offender.
But in an organization which has employee equanimity, workplace stability, and the elimination of retaliation as uncompromising goals, the diffusion of.
responsibility for discipline carries unnecessary risk. Accordingly, in October 1997, NNECO established the Executive Review Board (ERB), to provide a I further, higher level of review of disciplinary actions. [NNECO has also established a formal process for the review and implementation of discipline,- to ensure faimess and consistency (OA-15 " Progressive Constructive Discipline")]. The ERB reviews all proposed written reprimands, suspensions, demotions, removals from duties, and terminations, regardless of whether the employee recommended for discipline is a NNECO employee or a contractor.
The ERB's composition- ensures that it is.particularly attuned to possible discriminatory motives. Sitting as permanent members of the ERB ara the Vice President of Human Services who chairs the meeting [the Vice President- I Operations (who also bears Executive responsibility for SCWE matters) is the l attemate chair], the Director of Human Resources, the SCWE Issue Manager, and the Director of Contracts. Additionally, sitting as ex officio members are the Chair of the Employee Concems Oversight Panel, another member of the SCWE organization, and a legal representative.
The ERB's procedures ensure an anti-discrimination focus. When a matter is ready for ERB review the SCWE-Issue Manager performs a review to 12 fFocus Areas" are certain work groups at Millstone in which evidence suggests that a less
. than adequate environment for the raising of safety concems may exist. See Section
- 2.4.1.4 for a more substantial discussion of " Focus Areas."
i U.S. Nucidr Regulttory Commission B17138\ Attachment 3\Page 21 determine whether the employee had engaged in any protected activity, and if j so, whether any retaliatory. motive lies beneath the recommended discipline.
.The SCWE lssue Manager also checks for consistency and appropriateness of ;
the recommended discipline. Finally, the SCWE lssue Manager determines j whether the proposed action has already created, or will create, a chilling effect !
on the affected work group or the site'as a whole. At the ERB meeting to _
consider the case, the SCWE lssue Manager reports on these matters and the i Board then determines whether, in light of these considerations, to approve or l disapprove the proposed discipline. .j
. 1 The ERB has not been a rubber stamp. Indeed, the ERB has disapproved or altered recommendations in about 10 percent of the matters brought before it.
The ERB is by no means a perfect creation or a foolproof safeguard against ;
discrimination. It is, however, another defense to actions which could. be !
retaliatory. At'a minimum, it serves to direct attention to the relevant questions, while slowing down the natural rush to judgment and permitting the disciplinary decision to be made in an objective, rational, and unbiased process.
'Given the expertise that the ERB has developed, managers are now seeking
. advice from the ERB conceming issues and problems before they culminate in a need for discipline. This counseling function is particularly valuable because it permits management to take preventative or proactive measures, rather than reactive discipline.
Human Resources Before the shutdown of the units in late 1995 and early 1996, NNECO's Human Resources functions were performed by a relatively small group at Millstone. In fact, that group had only three HR professionals providing service to the entire site. Heroic efforts notwithstanding, that group was incapable of providing the support needed. During the succeeding months, the Millstone HR organization has undergone a wholesale transformation. l l
To head the HR recovery effort, NNECO temporarily retained Robert Long, the -
. former Senior Vice President for GPU and a seasoned nuclear executive experienced with successful recovery efforts. ' NNECO further buttressed HR leadership by the'on-site presence of Cheryl Grise, the corporate Senior Vice
~ President and Chief Administrative Officer. Under this leadership team, the HR ;
staff has been increased to roughly twenty-five; about half of whom are NU !
employees and half contractors. HR has also assigned full-service HR
" business partners" to support each unit and site services functions.
'8 - . Mr. Long completed his assignment March 6,1998.
i
l U.S. Nucirr Regulatory Commission B17138\ Attachment 3\Page 22 i
These changes have proved effective. A recent ECOP survey" revealed that 76 percent of those surveyed rated HR overall service as acceptable. Although further improvements are needed and are ongoing, the progress to date is I significant.
.The importance of these changes and HR's role in the maintenance of a safety conscious work environment should not' be overlooked. Experience at !
Millstone and other facilities -teaches that many of the p'oblems r which ' i ultimately. blossom as significant employee concems first surface as issues,.
which, if. effectively addressed when raised, would not have become the exacerbated' situations they became over time. Effective HR assistance in the. )
incipient stages of problem development is essential to the satisfactory resolution of the employees' problems and the overall maintenance of good !
morale.
In addition to the added resources, HR participates in the Executive' Review Board and works closely with ECP, ECOP, and the SCWE group. HR also participated with ECP in a self. assessment of the Employee Concems .
Comprehensive Plan. HR administers the Leadership Assessment (discussed under First Success Criterion) and developed a process to address the bottom .
10 percent of the assessment. Also, HR participated in development of the :
Joint investigative System to standardize the investigative intake process for ;
the various intake groups.
With the added HR resources on-site, the integration of those resources into the management structure, and the increased senior management emphasis :
on the timely resolution of HR problems, management's ability to deliver- J '
effective and timely HR assistance has been dramatically increased. These .
improvcirants serve as an essential complement to the other organizational changes and resources being devoted to the maintenarice of a safety l conscious work environment. -j (B). External Resources Organizational Effectiveness Consultants As noted above, employee concems may arise originally as HR problems. So l too, poorly handled employee concems often arise in dysfunctional i organizations ~or organizations that are burdened with difficult histories or long- i standing intemal tension. Providing the supervisors and managers of those organizations with the special resources needed to deal with difficult issues is Survey results are from a third quarter 1997 ECOP survey involving some 250 randomly chosen Millstone employees i
, U.S. Nucl*cr Regul: tory Commission -
B17138\ Attachment 3\Page 23 essential to the success of these organizations and the re-establishment of a safety con:cieus work environment.
To provde exrM advice to.those organizations and to supplement existing intemal: qq.ca; NNECO has retained the services of Nilsson & Associates (N&A) end ti,e ; #iber Consulting Group (XCG). These consultants have played an inipci'am Me in facilitating the discussions and problem resolution efforts in severe o. w NNECO's current " focus areas."'5 For example, N&A has helped facilitate a series of Cily meetings between two .
NNECO departments wh!ch were experiencing problems with communications and trust. Those meetings have produced considerable reconciliation and the resumption of effective communications.
In another matter, N&A intervened in a dispute between two groups which appeared to arise from interpersonal issues. The intervention uncovered process issues, which permitted the groups to make substantial progress'in resolving the friction points.
N&A has also helped one organization initiate " Executive In Touch" sessions,' ;
at which randomly selected participants offer the Vice President in charge of j
the organization their thoughts on what-is working well and what needs improvement in a facilitated meeting that protects the contributors' confidentiality. ' N&A anticipates conducting " Executive in Touch" sessions site-- !
wide in the future, j b XCG has also been involved in numerous preventative measures. In one case, l 3
XCG conducted with a series of diagnostic interviews and planning meetings !
with the managers of two g'roups. A series of joint working meetings.were then held with all of the groups' membership. The structured facilitation yielded both the pinpoint identification of the core issues and interpersonal problems. This l approach promoted an ongoing process of collaborative problem solving.and I has produced enhanced work performance.
In another example, XCG has been involved in structuring and conducting team interventions through the use of a feedback instrument which allows employees to assess the leedership of their direct supervisors. The use of this '
data has promoted' both a better understanding of those specific leadership behaviors needing attention and their impacts on the members of the group.
These interventions - have produced a working partnership between 'the "5
As' discussed in the next section, during the past 12 months, NNECO has identified 33
- focus areas." These are departments or work groups in which management is devoting :
special resources and attention to improve the work environment.
2
I
' U.S. Nuclear Reguintory Commission B17138\ Attachment 3\Page 24 supervisors and the employees. In addition, the open and candid exchanges have established greater trust and a climate where open changes can occur more frequently.
3.The Organization of SCWE and Human Services Assets Supports The Work Environment To enhance the effectiveness of the augmented resources, NNECO has developed an organization and adopted practices which coordinate the resources and bring to bear the necessary expertise to solve problems. In particular, in January 1998, NNECO consolidated its Human Services functions under a single Vice President, David B. Amerine. The SCWE organization, ECP, and HR offices all report to Mr. Amerine.
. To coordinate their efforts, each moming at 8:00 a.m. senior representatives of these' organizations, as well as representatives of the Legal Department, ECOP, and the organizational . effectiveness consultants, meet with Mr.-
Amerine to discuss issues affecting the work environment. These meetings have proved invaluable in improving the quality of communications among the various groups, in coordinating , the resources, ' and in calling senior management's attention to priority SCWE matters. As a result, senior management at Millstone is involved in the daily issues affecting the workforce at an unprecedented level.
Additionally, the various organizations under Mr. Amerine have developed a process for. responding rapidly to emerging matters,.which could have an adverse effect on the work environment. The process establishes designated characteristics of an issue, which if present, require the immediate notification j of key, designated persons. Those persons will then confer to determine {
whether the matter is urgent and, if so, they will take the necessary steps to' !
avoid an exacerbation of the problem.' Those persons will also develop a !
. coordinated plan to address the matter. By rapidly establishing areas of !
l responsibility, paths of communication, and predetermined actions,' NNECO j has improved its capability to provide prompt, integrated solutions to priority 1 personnel issues. i 1
- 4. Prevention of Discrimination'By Early Detection of Potential Problems v By providing the management team with integrated training and by providing q that team with coordinated and upgraded resources,' NNECO has substantially improved its ability to eradicate discrimination. Although the marshaling of l
, resources to' respond to emerging issues is essential, the eradication of I
. discrimination can best be achieved NNECO detects potential " hot spots" at the 1 earliest possible stage. To do this, NNECO'has developed, formalized, and I implemented the Millstone Focus Area Plan.
- U.S. Nucirr Regulttory Commission -
B17138\ Attachment 3\Page 25 The purpose of this Plan is to identify those work areas in wiiich the
- environment may. not be conducive to the raising and resolution of safety concems. The Plan envisions four phases: (1) identification and prioritization of the Focus Area; (2) development and implementation of a. detailed Focus Area Plan for the particular work group; (3) assessment of the results; and (4) identification and integration of any lessons leamed. A particular Focus Area can be identified by a variety of sources. For instance, if Leadership
. Assessments or Culture Surveys reveal troubling results, the work group may
. be designated as'a Focus Group. Similar1y,.if the ECP or ECOP find significant or multiple problems in a group, that group will become a Focus Area. Finally, if management, the NRC, or an independent oversight organization identify problems within an organization, that group will become a Focus Area. Once identified, the Focus' Area, with the assistance of the SCWE organization and with the approval of the responsible Vice President, must develop the specific plan for the resolution of the problems. The success or failure of the plan will n be monitored and assessed by persons outside of the Focus Area to ensure objectivity in the evaluation of the results.
NNECO has embraced the Millstone Focus Area. Plan. Since the Plan's-development in mid-1997, NNECO has identified 33 Focus Areas. Twenty-four of the 33 designated Focus Areas have completed the implementation of their plans and the plans are now closed..The remaining nine Focus Areas have plans which are either under development or in the process of being implemented. Not all of the 33 Focus Areas were designated as such because the work environment was necessarily poor. In fact, of the 33 Focus Areas ,
. identified to date,10 were created because individual leaders scored relatively low on in the Leadership Assessments.
2.4.2The Steps Taken To Data Have Produced Favorable Results The training, resources, and processes discussed above have produced favorable and encouraging results. They have not yet produced results, however, which permit NNECO to conclude that its goals have been achieved or that the Commission should discharge the third-party overseer (LHC). That time is l coming, but it is not here yet. But candidly acknowledging that work remains does not imply that progress has been minimal or that the record does not support I restart. The record categorically supports restart.
To determine the extent of retaliation, the ECP conducted a review of the 228 ECP concems closed after December 1,1996, and before March 10,1998. Using an l e exceptionally broad, conservative definition, the ECP determined which of those j
- concems, either explicitly or _ implicitly, alleged that: (a) someone had suffered !
some form of discrimination for having raised safety concems; (b) someone was reluctant to raise a safety concem for fear of retaliation; or (c)a chilling effect l
l
' U.S. Nucirr Regulatory Commission B17138\ Attachment 3\Page 26 existed. Sixty-four cases fell into the broad category, which NNECO has labeled )
as " Alleged 50.7" concems. j l
The ECP has reviewed the results of those cases to determine whether a potential violation of 10CFR50.7 has occurred or whether a chilling effect existed. In determining whether a potential violation of 10CFR50.7 occurred, NNECO has again been conservative in its classification protocol. Specifically, NNECO has labeled as " Potential 50.7" concems, those cases in which the ECP report I substantiated the elements of a cause of action under Section 211 of the ERA, as l well as those cases which reached an " Indeterminate" conclusion because of the inability of the ECP to determine to any reasonable degree of certainty the presence or absence of one or more of the required elements. Using this classification process, the ECP has pre!iminarily determined that there were 11
" Potential 50.7" concems - 3 of which arose from one " Substantiated" event (the Motor Operated Valve event, the results of which NNECO previously provided to the NRC), and 8 of which arose from " Indeterminate" cases. Of these eight
" Indeterminate" cases, seven arose out of events which occurred at least one year ago. Moreover, these seven cases received " Indeterminate" classifications for one or more of the following reasons: (a) a key witness was not interviewed or left Millstone; (b)the concemed individual asked to have the investigation cease because of a satisfactory resolution; (c) management resolved the concem, but the ECP report does not reflect the basis; or (d) the ECP report does not address a key issue with sufficient clarity to reach a finding.
Whether a case receives a " Substantiated" or " Indeterminate" label is of little significance. NNECO will regard both as " Potential 50.7" cases and will inform the NRC of all such " Potential 50.7" cases.
In addition to examining the ECP files to determine the presence of the elements of a cause of action under Section 211, the ECP has also reviewed the files to determine whether the facts substantiate the presence of a chilling effect.
NNECO has required this separate determination because a chilling effect can exist even in cases in which no violation of the regulations arguably occurred.
NNECO's preliminary review of these 64 ECP cases indicates that there were 16 ,
cases of " Substantiated" chilling effect, 5 " Indeterminate" cases, and 43
" Unsubstantiated" cases.
The classification of these cases, although instructive for monitoring purposes, does not conclude NNECO's work on the cases. For all " Potential 50.7" concems, !
'8 The number of concems reported in the various categories are currently being reviewed by ECP and LHC and may change. The precise determination of the outcome of a case requires the subjective assessment of sometimes conflict %g evidence.
U.S. Nucirr Regul: tory Commission B17138\ Attachment 3\Page 27 and all " Substantiated" or " Indeterminate" chilling effect cases, NNECO has (or will j have) identified and implemented appropriate corrective action. As noted earlier, ECP enters the corrective action items in its site-wide tracking system to ensure follow-through 'and accountability. !
I As noted, the mitigation of potential chilling effects has not been limited to those I circumstances in which discrimination has occurred. Management has also acted l
in circumstances in which it may appear to the workforce that retaliation may have occurred. For instance, a supervisor in one department made an improper remark to a contractor and, later, declined to extend the contractor's contract. Although the denial of the contract extension had a basis in matters unrelated to protected activity, the perception created by an insensitive remark called into question the propriety of the action. Upon leaming of the event, the responsible Vice President expeditiously remedied the circumstance with the contractor, counseled the- :
supervisor, and conducted personal interviews of the affected work group to 1 determine whether a chilling effect existed. Additionally, the supervisor voluntarily )
shared his experience and thoughts on the event with the entire management team so that all could leam from his mistake. Surely, the avoidance of the problem in the first instance would have been preferable, but this event j demonstrates that management knows how to respond to potential problems and i how to resolve them.
)
Another prominent example of management's sensitivity to the perception of retaliation occurred when a manager was transferred from his position in an effort to introduce new standards and leadership into his organization.- The organization, however, reacted adversely to the change and widely viewed the I change as indicative of a lack of support for the manager, whom the workforce recognized as being receptive to the raising of concems. The legitimacy of )
management's motive notwithstanding, management determined that the proposed move might send the unintended signal that it did not support the raising of concems. As a result, management reinstated the-manager to avoid the j creation of a potential chilling effect. Most recently, NNECO took the painful step of accepting the resignation of a Vice President who. did not recognize 'or appreciate the negative message conveyed by an inaccurately recorded phrase.
Specifically, the Nuclear Oversight Vice President and Directors constructed a working document that included, as an organizational weakness, the phrase
" inability to ' isolate' cynics from group culture." Although the document did not reflect the intent of the drafters, the document sent the wrong message to the workforce and created at least a perception that management did not value the contributions of dissenters. The resignation of the Vice President left no doubt ;
about the. seriousness with which senior management views the maintenance of a safety conscious work environment. 4 Management is not only doing the right thing when problems or issues arise, it is soliciting help and engaging the issues proactively. For example, the following
U.S. Nucle:r Regulatory Commission
'. B17138\ Attachment 3\Page 28 work groups have contacted the S'CWE organization within the past eight months
-to request the group's assistance in improving the work environment: Waste Services / Site Health Physics; Unit 3 Chemistry; Site Security; Contracts; Unit 1 Work Planning -Unit 3 Design Group; Unit 2 Health Physics; managers from
. Operations, Maintenance and Unit Engineering; and all Unit Directors.
Many organizations, large and small, have, on their own. taken independent steps to ensure or enhance the work environment. For example, Unit 1 has adopted a <
format for the daily moming meeting that places " safety issues" as the first item on the agenda to be discussed. Likewise, each moming representatives from site management, HR, legal,- the SCWE organization, ECP, and ECOP assemble to
' discuss any issues affecting the work environment. Because of these efforts, more potential problems are being addressed when the symptoms surface, not
- when the symptoms manifest themselves as work place disruptions. Additionally, ,
the _ Officer agenda.for weekly meetings is prioritized based on (1) Safety,:(2)
SCWE, and (3) Unit 3. Also, the NSSS Group has established its own.SCWE )
. group to address the environment within that organization. The Unit 2 I&C Department has_ established an informal process for the calling of aftime out" if anyone within the group witnesses or believes that an issue has not been properly received. The Unit 3 Chemistry Technical Support Staff conducts weekly staff' meetings to review safety issues and to address concems.
Although illustrative, these few examples do not capture the ' magnitude of the change that has swept through Millstone. Some.'will undoubtedly question the validity of the surveys, the value of training, or efficacy of the resources, but no one can, in good faith, challenge the sincerity of the effort or the depth of the commitment. Management and workers together have _ made great strides in -
improving the work environment and in eliminating both the fact of, and the fear of,-
. retaliation. Still, vestiges of the past remain. And they will probably remain for the foreseeable future. But with the long road back to full recovery clearly marked, the resources and skills firmly in hand, and the commitment to excellence restored, restart is justified.
3.0, ECOP. Nuclear Overslaht. and the N#- Safety A======nent Baard Have
~
Concluded That The Work Environnient Supports Restart j
_ ~ ;
On March 27,1998, ECOP reported that NNECO has satisfied the four success l criteria. On March 30,1998, NNECO's Nuclear Oversight organization concluded '!
that a Safety Conscious Work Environment exists which supports the restart of Unit 3. Also, on March 30,1998, the Nuclear Safety Assessment Board (NSAB) concurred.that NNECO has established a Safety Conscious Work Environment which supports the restart of the units. 1 i
l
i U.S. Nucirr Regulatory Commission
.l B17138\ Attachment 3\Page 29 l 4.0 Millstone's Progress Will Continue After Restart At the beginning of this document, NNECO indicated that it does not view the !
progress reported here as having reached NNECO's ultimate goal. While i justifiably 'proud of the progress, we recognize that success in a period of - 1 operations ' depends upon-vigilance against backsliding and concentration on i improvement. - If we have leamed nothing else from the past, we have teamed that' complacency and indifference are indistinguishable and both willlead inevitably to failure. Our future success, therefore, depends epon our commitment to sustained progress. And our continued progress depends upon our daily adherence to the principles which create and sustain a safety conscious work environment. l l
Progress sufficient to support the restart of Unit 3 marks'only the first milestone in .j NNECO's efforts to strengthen the work environment. Efforts from this point forward will focus on the consolidation of gains,- the extraction of lessons leamed, and the institutionalization of the prccesses to provide for continued advancement.
The key to sustaining performance is the maintenance of the organization and I
structure that is. currently in place. As noted above, the various organizations !
which have responsibility for . SCWE-related functions have been consolidated i under a single executive. That organization has been successful in coordinating - i SCWE enhancement efforts and in driving SCWE-related issues to the_ forefront of
' the site's agenda. Daily coordination efforts will continue. Issues will continue to receive real-time senior management attention. . Events will continue to be analyzed to extract lessons leamed and the results factored in remedial efforts.
Training on SCWE-related matters will continue, with emphasis on refresher-training and trtining for new arrivals.
As NNECO gains experience with the organization, it will continue to monitor the effectiveness of the organization. As performance and needs dictate, NNECO will adjust or realign the organization to address the circumstances. For example, if circumstances warrant, it may be appropriate to have organizations such as SCWE become part of the HR organization.
NNECO will contirue ,to perform self-assessments and monitor progress. If performance remains ~ satisfactory, it may be appropriate for LHC to conduct.
quarterly or semi-annual assessments, as opposed to the current daily monitoring of site activities. But performance - not time - will determine the level of LHC involvement and the ultimate structure of NNECO's SCWE related assets.
1 1
' U.S. Nucirr Regul:. tory Commission B17138\ Attachment 3\Page 30
- 5. Conclusion
.The work environment at Millstone has made great s+ ride'; and continues to improve; The employees are raising issues and the Company is resolving them fairly and appropriately. For those who choose, NNECO has created an Employee Concems Program that .is staffed with skilled, unbiased investigators and professionals. For its part, management has its eyes fim1)y fixed on the continual .
Improvement in the environment, so that the recent galos form the foundation for-future progress.
Going forward, NNECO has the infrastructure, the processes, and the dedicated
. oversight to ensure that it will continue to improve. As discussed in the 1998-2000-Performance Plan, NNECO will continue its work place enhancement efforts while carefully monitoring performance to validate the health of the work environment.
That Millstone once suffered through a difficult period is a fact the employees and -
management cannot afford to forget. Indeed, the scars from those experiences remain with the organization and many of its employees. To all, they serve as a reminder of the fate that awaits the organization if our vigilance slackens or if our commitment to excellence waivers.
Our progress - incomplete though it may be - provides us with the sure knowledge that our course is correct and that our daily efforts to enhance the work environment will bring rewards for NNECO, its employees, and the public.
l I
a 1
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Docket tlos. 50-245 60-336 50-423 B17138 Attachment 4 Millstone Nuclear Power Station, Unit Nos.1,2,3 1998 - 2000 Performance Plan - Work Environment Focus Area
\
March 1998
U.S. Nucl::ar Regulatory Commission B17138\ Attachment 4\Page 1 i WORK. ENVIRONMENT l l
i The Long-Term Vision for the WORK ENVIRONMENT Strategic Focus Area includes the following overarching accomplishments: ;
e Leadership is strong;
. Clear standards of performance and accountabilities are established; i
. A healthy safety conscious work environment exists; e The employee concems program is effective; 1
. The workforce is motivated;
. Compensation is competitive and based on performance; and
. Hours worked are reasonable. '
The strategic focus area of Work Environment encompasses:
. Leadership
. Safety Conscious Work Environment
. Human Resource Performance This section summarizes initiatives specifically targeted at improving the work environment at Millstone Station. While only the areas of Leadership, Safety Conscious Work Environment (SCWE), and HR Performance are specifically included in this Strategic Focus Area, other topics discussed in the 1998 - 2000 Performance Plan (Plan) affect our SCWE in some fashion, and contribute to improvements on this front. In particular, our actions in the areas of safety and operating excellence will fundamentally influence and determine our success in sustaining improved performance in regard to SCWE.
Significant progress has been made since issuance of the NRC Order in October of 1996. At least through restart of the units, we will maintain the current structure and rapid response capability that has been successful in achieving our results to date.
The Work Environment initiatives will be carried out by the responsible organizational units that are presently reporting to the Vice President, Human Services. These functions are coordinated through meetings among the leaders of the responsible functions (HR, ECOP, SCWE, Legal, ECP, etc.) and more recently, through a rapid n
U.S. Nuclur Reguir. tory Commission B17138\ Attachment 4\Page 2 response protocol developed for urgent events. After restart of the units these organizational relationships will be re-examined and adjusted as follows:
- e. All changes to the Safety Conscious Work Environment (SCWE) I organizations and processes will occur based on performance demonstrated and results achieved, and not based on schedule; e Independent of performance, we do not envision any SCWE organizational changes before Unit 2 startup; e Most non-10CFR50.7 SCWE functions ultimately will transition to the Human Resources organization, and over time, the demands on HR would be. reduced because of increased line management effectiveness; i e The scope of the Employee Concems Program (ECP) will be reduced to focus primarily on nuclear safety significant issues, consistent with typical programs at other nuclear facilities;
- The Employee Concems Oversight Panel (ECOP) will evolve to an independent panal, similar to Nuclear Safety Assessment Board, continuing to report to our Nuclear President and CEO; 'j Consistent with regulatory consent and dependent upon solid
~
e performance, the gradual and conservative reduction in the degree of independent oversight. This reduction could include periodic (e.g.
quarteriy) Independent evaluations until results and self-assessments demonstrate that the independent oversight presence is no longer warranted; and
. Self-assessment will be used to verify that performance expectations are being wt. Self-assessment will be considered effective when intemal oversight er extemal evaluations have limited value because they simply validate self-identified issues. Appendix A provides the self-assessments scheduled for the balance of 1998. The measures to assess performance are stated in the SCWE segment of this Plan. These self-assessments are l' designed to assure that the progress realized to date is sustained, any backsliding is promptly detected, and corrective actions are promptly taken'.
_' l While this plan maintains our present organizational strengths, it also seeko to shift -)
our emphasis from mitigative to.more effective preventive actions. As we have !
identified and addressed the major causes of past SCWE performance issuas, we l
~i have used these insights to refocus and retarget our actions, accelerating toward our performance improvements. Our plan does that with three interrelated components:
e Leadership e Safety Conscious Work Environment
. . Human Resources Performance
j U.S. Nucle:r Regulatory Commission B17138\ Attachment 4\Page 3L in the area of Leadership our initiatives fccus on:
. Skill Development - Ensure management attendance at requisite training, measure leadership effer tivanesr, and adjust training as appropriate
. Standards and Expecta'. ions - Establishing, communicating and reinforcing -
consistent standards end management expectations
. Succession Planning - Establish plans to prepare for.the transition from recovery organizations and ensure qualified candidates are identified to fill vacated positions on short notice ,
in the area of SCWE our initiatives focus on:
. Lessons Leamed - Systematically evaluate SCWE events and experiences, identify important lessons leamed and adjust / augment our actions accordingly-e nTraining - Conduct an integrated assessment of SCWE-related employee, j supervisory and management training and implement more efficient and effective SCWE-related training
. ~ Organizational Structure - Based on assessments of SCWE performance J objectives and measures, deliberately transition into the organizational .I realignments needed to maintain effective and efficient management of -
SCWE activities
. Monitoring and Methodology / Tools -Improved monitoring of SCWE.
performance and develop methodology / tools to improve the effectiveness and efficiency of SCWE activities in the area of Human Resources Performance our initiatives focus on:
- Organizational Diversity
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- Personnel Management l
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i U.S.. Nuclear Reguistory Commission B17138%ttachment 4\Page 4 l
C.1 Leadershio Goal Leadership throughout the Millstone organization is strong and continually l
improving. Standards ofperformance and accountability are clear. l Supervisors are providing meaningful and constructive feedback- both oral j and written - and the organization is weII coached by the leadership team. '
The leadership provided by the management team is perceived as a strength l by the employees, INPO, the NRC and the generalpublic. !
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Objectives, Performance Measures and Targets zitems . ObMotive gPerformance Meesure - PerformanceJargets ; !
may 8
, 4 ,
gg s. se w , ,.
C.1.a Leadership skill development has been Requisite Management 90% by 10/99 i provided to all personnelin Training Attendance !
supervisory positions i Requisite Management 90% by 10/99 ;
Requalification Training Attendance ,
Leadership Assessment > 5.5 (Reflecting an improvement of at least 5% ,
average of all categories) '
No Leaders are ranked "less than effective"in two consecutive assessments (Complete by 11/98)
" Skip Level" Leadership TBD t'ollowing baseline Surveys survey C.1.b Leaders are personally committed to Leadership Survey and 90% of respondents would the establishment and nuturing of a Pil Culture Survey bring concems to their Safety Conscious Work Environment (Employees Willing to immediate supervisor (SCWE) Bring Concems to immediate Supervisors)
Millstone Employee No adverse trends in Concems Confidentiality requests for confidentiality Trend (anonymous or or anonymity, based on confidential employee analysis of concems and concems filed) data.
Focus Area Action Plan Zero by 1/99 Status (SCWE Focus Areas)
Pil Culture Survey Continuing positive trend C.1.c Leaders are committed to high Assessment index (self- Line Self-Assessments are standards of performance and assessments results vs. more critical, indicated by a establishing clear expectations for nuclear oversight results) + Index value
- their employees
U.S. Nucirr Regul: tory Commission B17138\ Attachment 4\Page 5 8t 3mayem) , Objechve, ~ -
- Performorpe Measure? lPerfonnance Targep s e ,e > + so C.1.d Leaders embrace Millstone's Core " Skip Level" Leadership TBD l Values
- Do what is right; Respect and Surveys care for the individual; Be a team, Be customer focused i C.1.e Safety is the first priority for all in a " Skip Level" Leadership TBD leadership position and is sponsored - Surveys as such to their employees C.1.f Leaders have planned for succession Plans to transition from All plans in place by i and phase out of recovery teams recovery to operating 12/1/98 for key positions !
organizations developed and in place l Actions required by Recovery Teams are I Transition Plans phased out and replaced i completed on schedule by NU line management I within 6 months following unit restart Action items ,
i I
. Item Action : Respons-. Target Supprtng i
. No.- ibilityi Date Plan Ref.
C.1.a.1 Develop the metric for " skip level" leadership HR 5/98 assessments and conduct the assessments at least i annually in 1998,1999, and 2000 C.1.a.2 Develop and implement a nuclear leadership development Training 8/98 i program that builds on the accomplishments of 1997 (See C.3.8)
C.1.a.3 Supervisors provide meaningful and constructive Line Mgmt TBD feedback, both oral and written, and good coaching as measured annually by leadership surveys and the LINKS process C.1.a.4 Revise the management development program to include Training 12/98 a " continuous leaming" approach to leadership ,
development, incorporating best practices (See C.3.8)
C.1.a'.5 Conduct Leadership Training - Training will be provided to Training TBD l
all incoming / promoted management personnel.
Commitments for continual upgrade and refresher training ir:clude all management personnel (See C.3.8)
C.1.a.6 Conduct Leadership Assessments HR 6/98 12/98 l C.1.b.1 All managers and supervisors complete initial SCWE Line Mgmt 9/98 i training (See C.2.2)
C.1.b.2 Complete the evaluation of the need for additional SCWE 6/98 leadership training, particularly with respect to SCWE issues and all the related ramifications and schedule periodic reevaluations (See C.2.2)
C.1.b.3 Conduct Pl! Culture Survey SCWE 9/98 l
I
4 U.S. Nucl=r Regulatory Commission B17138\ Attachment 4\Page 6 .
Item . Action . Respons- . Target - Suppring
. No. Ibility Date Plan Ref. ;
C.1.b.4 Complete development and implement the SCWE SCWE 4/98 j Guidebook which provides the process for addressing leadership inadequacies (See C.2.3.4)
C.1.c.1 Develop departmental business plans with measurable Line Mgmt TBD J goals that are in alignment with the Plan. Status and update plans periodically C.1.e.1 Managers and supervisors communicate to their staff that Line Mgmt 4/98 the 199 Octety Goals are achieved in pursuit of"Zero defects and injuries, one day at a time" C.1.e.2 Develop and implement management transition plan to Officers TBD replace recovery teams with NU line management within six months following each unit restart C.1.f.1 All managers and above wi have developed a Line Mgmt 12/98 succession plars(s w C 0.5) l l
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U.S. Nuclear Regul:. tory Commtsion B17138\ Attachment 4\Page 7 m .
3 C.2 Safety Conscious Work Environment Goal 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 standant to which others in the industry aspire.
Objectives, Performance Measures and Targets W) g ' %nk$ $ W ce na ,
m
~
MM
>g , ,;g
?8V99lSW C.2.a Establish and maintain high Leadership and Pil 90 %
confidence that employees are willing . Culture Survey -
to raise concerns (Willingness to Raise Concems)
Millstone Employee No adverse trends in Concems Confidentiality requests for confidentiality Trend or anonymity, based on analysis of concems and i
~
data j l
C.2.b Establish and maintain high Condition Report No Adverse Trend l confidence that management is Evaluation Timeliness l effecthee in evaluating, prioritizing, and (Time for Condition j resolving employee issues Report (CR) Evaluation)
Condition Report Quality Condition Report Quality <
Score (condition report Score is 23.0 on a scale of quality) 0.0 to 4.0 Overdue Covective Overdue corrective actions Actions (overdue are < 3% during recovery corrective actions from and 1% after restart level 1 or 2 CRs)
C.2.c Establish and maintain high Employee Concem No Adverse Trend confidence that the Employee Resolution Timeliness Concems Program (ECP)is (average age of continuously improving and effective in unresolved concems) addressing issues raised by employees that are not resolved satisfactority by other means within the organization Employee Satisfaction A substantial maiority With ECP (Employees (90%) of employees using ECP would use it indicate they would use the again, ECOP survey data) pror/am again f
U.S. Nucl=r Regul: tory Commission B17138\ Attachment 4\Page 8 i ltemy 4 Objectwo d, Performance Measure; PerformanceTa.rgetsj
. . . = .
NU Concems and NRC No quantative Goal. It is Allegations Received desirable to have a relatively small number of allegations submitted to the NRC as a measure of employee confidence in the various NU resolution systems investigation Quality Positive Trends C.2.d Establish and maintain high Substantiated Concems infrequent and Handled confidence that line management is involving Potential Effectively effective in identifying, investigating, Violations of 10CFR50.7 and resolving focus areas and 50.7-related events, where the attributes of a SCWE are challenged or lacking Supervisory and 100% of requisite training Management Training completed and Attendance Requalification maintained ;
I l
Action items 1
. Item Action . . Respons- - Target Supprtng l No. :ibility '- Date' Plan Ref. !
C.2.a.1 Evaluate existing reward systems and develop and Line Mgmt. TBD implement a systematic plan for reward and recognition of employees that raise concerns C.2.a.2 Develop and implement 50.7 module for incorporation in Training 5/98
- Partnership 2000" employee training C.2.b.1 Develop and implement " quick start" training for new Training 4/98 managers and supervisors, and enforce 90 day window for new training C.2.b.2 Develop and implement integrated, one-stop supervisory Training 5/98 training from current training courses C.2.b.3 Develop and implement 50.7-related Requalification / Training 5/98 refresher training for managers and supervisors C.2.b.4 Implement a peer review process by year-end 1998 Line Mgmt 12/98 including selection of a design committee C.2.c.1 Conduct lessons teamed reviews of completed ECP ECP 6/98 cases C.2.c.2 Provide increased staff training on investigation ECP 6/98 consistency and process, and interpersonal skills.
Enhance the ECP continuing training program
U.S. Nuclxr Regul; tory Commission i B17138\ Attachment 4\Page 9 l l
l item Action - Respons- Target . Supprtng ;
No. ibility . Date Plan Ref.
C.2.c.3 Transition ECP from contractor-staffed to NU-staffed ECP 12/98 organization and develop succession plan for ECP staff C.2.c.4 Develop and implement improved methodology for 50.7 ECP 4/98 )
case classification, elements of proof for 50,7 and HIRD l investigations, investigation lessons leamed C.2.c.5 Deve'op metric to measure investigation quality ECP TBD C.2.d.1 Based on assessment of SCWE performance objectives SCWE Ongoing l and measures, evaluate and transition into the organizational structure necessary to maintain effective / l efficient management of SCWE activities ;
C.2.d.2 Evaluate and implement phased plan for ECOP ECOP 12/98 realignment, if dictated by perforr=.ce C.2.d.3 Evaluate and implement phased plan for realignment of All TBD SCWE functions, including transfer of non-50.7 HIRD functions from ECP and SCWE to HR, and incorporation i of SCWE into the line organization C.2.d.4 Evaluate and implement phased plan for realignment of All TBD SCWE oversight in response to sustained, positive performance trends, including rampdown of LHC oversight; develop and implement phased plan for l complementary, enhanced oversight from Nuclear l Oversight, ECOP, NSAB, and self-assessment, and potentially third party assessments C.2.d.5 Address all Focus Areas effectively, continuing use of SCWE/ 12/98 organization effectiveness consultants, and factoring Line Mgmt leaming process from those activities into the permanent organization C.2.d.6 Complete the development of and implement the SCWE SCWE 6/98 '
Guidelines, which provide the process for addressing Focus Area definition, action plan development, monitoring and close out C.2.d.7 Develop and implement an improved set of performance SCWE 9/98 measures for measurement of continuous improvement C.2.d.8 Systematically evaluate SCWE events and experience SCWE 6/98 and identify causal factors and important lessons teamed. Perform comparative analysis and baseline causal factors and current conditions against the MIRG Report. Implement enhancements, as appropriate.
C.2.d.9 Evaluate current SCWE Plan actions and adjust and SCWE 6/98 augment as necessary to address causal factors and lessons leamed C.2.d.10 Develop and implement process for ongoing systematic SCWE 6/98 evaluations and assessments of lessons leamed C.2.d.11 Conduct periodic benchmarking and implement methods All Ongoing for sharing lessons teamed from highly rated plants
U.S. Nucirr Regul: toy Commission B17138\ Attachment 4\Page 10
-item Action 7 . Respons- - Target:- -
Supprtng No. -ibility Date -: Plan Ref..
C.2.d.12 Enhance SCWE monitoring to include assessment SCWE 8/98 Windows scoring criteria which requires: a) a Level 2 Condition Report to be initiated if a SCWE KPl reaches a
' yellow' indication in 2 consecutive months or if any SCWE KPI reaches ' red *, and b) a Level 1 Condition Report, requiring formal root cause investigation, to be issued in the event of 4 consecutive Yellows' or 2 consecutive ' red' windows
i U.S. Nucir"r Regul tory Commission i B17138\ Attachment 4\Page 11 i C.3 Human Resources Performance Goal l Millstone recognizes that a strong site team is fundamental to sustaining full recovery and makes effective use ofits human resources as a source of competitive advantage. It furtheracknowledges that achieving a high quality of work life balanced with strong workerproductivity is the best way to meet 1 the needs of aIIits stakeholders. !
Objectives, Performance Measures and Targets Attem; s Performance Measure PerformanceTargets q
gjp. Objective., .
C.3.a Employees view the Human HR Customer Feedback " Satisfactory" by 12/98 j Resources (HR) organization as " Good" by 12/99 l vigorously championing their issues to " Excellent" by 12/00 i management O.3.b Management seeks HR as a resource HR Customer Feedback " Satisfactory" by 12/98 for counsel and guidance " Good" by 12/99
" Excellent" by 12/00 C.3.c Diversity is valued and regarded as an Organizational Minority Desired Levels by 12/98 integral component of the and Female Staffing organization's ability to compete I successfully Diversity Events > 2 annually C.3.d A culture exists that holds dear Human Resources Culture demonstrating respect for one another, Survey celebrating successes, embracing worthwhile work, maintaining Overtime Time Levels reasonable work hours, fostering pride in personal, team, and organizational Nuclear Performance I accomplishment, and engaging all Incentive Plan workers, including shift workers Achievement Minimum of one event targeted at shift workers C.3.e The workforce plan is in p%ce that Succession Plan At least one candidate for takes into consideration bench strength each identified key position and employee development C.3.f Performance management is owned by Performance Appraisal > 90% are performed as line management, and along with Schedule Adherence scheduled coaching,is viewed as an important part of setting expectations and holding Audits of Performance Overall audit rating of at one another accountable Reviews least " Satisfactory" with regard to quality, including a development plan Leadership Assessment, Positive trend in year-to-Performance year assessment results Development Section C.3.g HR policies are viewed as consistent HR Customer Feedback " Satisfactory" by 12/98 Ratings " Good" by 12/99
- Excellent" by 12/00 h
U.S. Nucbar Regul: tory Commission B17138%ttachment 4\Page 12 iltem,i ev Objective.3:--
>' ; Portormance Measure ggPerformanceJargcl+g gj gg g .,3 4 --
g., .
, 3e C.3.h Compensation strategy is aligned with Competitiveness of At Market by end of 1999 industry benchmarks and with the Compensation organization's desired culture and business objectives Senior Management Evaluation i
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i U.S. Nuclair Regulatory Commission 1
- B17138\ Attachment 4\Page 13 - !
J
. Action items 1
-1 Item; . Action Respons-4 i TargetJ Supporting i No? J -ibintyi ' Datai e Plan Ref.
C.3.c.1 Continue to implement diversity initiatives in concert with HR 10/98 line management and successfully implement and
'l' complete the Summer Hire Diversity Program C.3.d.1 Conduct at minimum the following self assessment HR 12/98-activities: investigation record-keeping; 1997 exempt performance reviews; and implementation of a customer satisfaction methodology C.3.d.2 Conduct vision and values workshop and development of Officers TBD teambuilding concept; introduce the "We" concept C.3.d.3 Implement " Working Backshift" module for affected HR TBD-workers (focus groups) -
C.3.e.1 Develop and present a workforce plan that includes a HR 1/99 methodology for implementing succession planning and -
workforce demographics analysis C.3.f.1 Conduct an audit of the 1997 performance reviews for HR 6/98 quality and timelines. . Present results to Millstone line-management for action j C.3.g.1 Implement Unit i redeployment, including development Officers 4/98 and publication of an officer-approved process C.3.g.2 in concert with Corporate HR, review HR Northeast HR 1/99 Utilities Policies (NUPs) to assure applicability to - Line Mgmt -
Millstone, competitiveness with benchmaric companies,.
clarity. and consistency with practice ,
C.3.h.1 Develop, present and gain approval of an approach for HR 3/99 j implementing broad banding at Millstone in 1999 C.3.h.2 - Develop and obtain approval of an articulated rewards HR -- 1/99 .
and recognition strategy for Millstone including: defining i the pay philosophy, competitive market, mix of pay, '
paylines and overtime practices in the context of nuclear business objectives; in concert with Financial Control, -
revamp NPIP and establish more timely and effective '
communications in support of the program; and reevaluate nuclear exempt compensation levels for j market competitiveness j C.3.h.3 Develop criteria forjustifying senior level positions at HR 4/98 l Millstone Station, including the establishment of a multi- 6/98 i discipline task force by 4/98 .
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1 U.S. Nucinar Regulatory Commission B17138%ttachment 4\Page 14 i
APPENDIX A PERFORMANCE MONITORING l
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U.S. Nucirr Regulatory Commission B17138\ Attachment 4\Page 15 PERFORMANCE MONITORING 1
The successful efforts throughout the station which are raising performance for each !
of the sixteen Key issues to a standard supporting restart authorization must be maintained in the future. For each Key Issue, significant accomplishments were .
achieved through extensive, dedicated efforts. This level of performance will be 1 sustained by carefully tracking the designated key performance indicator (KPI) data, ,
supplementing the on-going efforts with directed self assessments, and taking !
appropriate action if a decline in performance occurs.
(
For each Key issue: previously established Success Criteria for recovery are restated; related self assessments planned for 1998 are listed; and the corresponding performance measures, including Key Performance Indicators (KPis),
are identified.
4 Success Criteria, developed for each Key Issue as part of the recovery process, are included to reiterate the baseline for future performance. KPis provide an important indication of performance. The key concept is that KPls are a tool to: i
. Identify areas requiring focus or additional management attention; ,
I e Identify barriers to success; and
. Identify improvement strategies.
Management uses the KPis in developing a picture of the general health or state of affairs, and the need for remedial action. Reviews of the indicators are regularly performed. When performance is not meeting established standards or goals, the ,
responsible individual provides ar, analysis as to why performance is deficient and takes action to bring performance back to the specified standard.
Assessments will also be conducted routinely to verify acceptable performance and validate the information presented in the KPis. These self assessments include, but are not limited to, those currently planned during 1998. Assessment topics may be added, substituted, deleted, or rescheduled as circumstances dictate during the course of the year. For some Key issues, the list of self assessments includes a combination of traditional self assessments and oversight organization monitoring activities such as, Nuclear Oversight Restart Verification Process (NORVP), Nuclear Safety Assessment Board, Training Advisory Council, etc.
i U.S. Nucirr Regul: tory Commission l B17138\ Attachment 4\Page 16 As part of the Plan, as 'a minimum, each of the 16 Key Issues will be explicitly ;
monitored through the remainder of 1998. '
- 1. Leadershio Success Criteria !
The following Success Criteria are established and summarize the -
{
performance baseline for this Key issue: :
. Achieve a leadership assessment score of a least 5.5, reflecting an improvement of at least 5% (average of all categories) when compared to I the November 1997 score e Achieve a " skip level" leadership average score of acceptable or equivalent in all categories !
. Complete two consecutive leadership surveys with no leaders ranked as less than effective by 12/98
. Complete a Pil Culture Survey with results which support a continuing !
positive trend Self Assessment The following self assessments are currently planned for 1998:
. Leadership Assessment Surveys - 2nd and 4th Quarters ,
. Pil Site-wide Culture Survey - 3rd Quarter l
- Audit of Exempt Performance Reviews i e- Succession Planning (Pilot Program and Feedback)- '
l The results will be an important input to decision-making actions that will be ;
taken to foster further leadership improvements. The data will continue to be trended on a site-wide basis.
Performance Measures ;
The following performance measures will be used for the on-going monitoring of this Key issue:
. Leadership Assessment j e Pil Culture Survey i e Skip-Level Leadership Assessment )
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i U.S. Nucl=r Regul tory Commission
- B17138\ Attachment 4\Page 17 l
, 2. Safety Conscious Work Environment (SCWE)
Success Criteria The following . Success Criteria were previously established and summarize the performance baseline for this Key issue:
- Demonstrate that employees are willing to raise concems e- Demonstrate that management is effective in evaluating, prioritizing and resolving employee issues e Demonstrate that the Employee Concems Program is effective in addressing issues raised by employees that are not resolved ' satisfactorily by other means within the organization
. . Demonstrate that line management is effective in identifying, investigating and resolving' problem areas where the attributes of a safety conscious J work environment are challenged or lacking e Maintain a Safety Conscious Work Environment as viewed by the Employee Concems Oversight Panel-
'
- Maintain a Safety Conscious Work Environment as viewed by the Independent Third Party Oversight Program,' established by NRC Order Self Assessment The following self assessments are currently planned for 1998:
. Effectiveness of Selected Employees Concems Comprehensive Plan Action items - 1st Quarter
. Pil Culture Survey- 3rd Quarter
. Executive Review Board Effectiveness - 3rd Quarter 4
. HR Customer Feedback Surveys - 4th Quarter l e Personnel Performance Reviews - 4th Quarter
. Continuous Monitoring by third party - Employee Concems Oversight Panel
- Performance Measures '
The SCWE infrastructure includes the dedicated SCWE group (including the Key _ issue Manager), the Employee Concems Program, the Employee i Concems Oversight Panel, and the Human Resources organization for Nuclear. ' Importantly, each of these four groups work closely together under !
the direction of one Officer. The Independent Third Party Oversight Panel l
' (Little Harbor Consultants) will continue to function consistent with the terms'of ;
the October,1996 Order, and their recommendations and NU's responses are .i
- routinely updated. On-going pedormance monitoring includes:
i e Leadership Assessment (SCWE Element)
. _ Culture Element (SCWE Element) i i
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- U.S. Nucl=r Regulatory Commission B17138\ Attachment 4\Page 18
. NU Concems and NRC Allegations Received, Millstone Station
. Millstone Employee Concems Confidentiality Trend, Millstone Station e Employee Concem Resolution Timeliness
. Employee Satisfaction With Employee Concems Program e Focus Area Action Plan Status, Millstone Station i e Concems Alleging HIRD, Millstone Station
- 3. Self Assessment Success Criteria l The following Success Criteria were previously established and summarize the performance baseline for this Key issue:
. Achieve greater than 90% of self-identified issues
. No significant events and no programmatic issues identified by intemal and/or extemal oversight Self Assessment The following self assessments are currently planned for 1998:
1 e Station Self Improvement Culture and Self Assessment Program I e Quarterly Performance " Windows" Conduct of Self Assessment
. Oversight Audits (which include self assessment discussion)
Performance Measures The following performance measures wiil be used for the on-going monitoring of this Key issue:~ i e Millstone Oversight Evaluation of Unit Self Assessment (NORVP)
. . Condition Report Method 'of Discovery - By Unit
- 4. Cmetive Action <
Success Criteria ;
- The following Success Criteria are established and summarize the !
. performance baseline for this Key issue: l 1
Demonstrate that a low threshold exists for identifying conditions adverse l to quality by an increasing ratio of Level 2 and 3 CRs to Level 1 CRs' 1 e The ratio of self-identified to extemally identified conditions adverse to j quality continues to increase e' Provide high quality corrective action plans within 30 days of identification e Complete corrective actions in accordance with a schedule established in l
- the action plan l2 j
U.S. Nucl=r Regulatory Commission B17138\ Attachment 4\Page 19
. Corrective actions are effective in resolving the issue
. Adverse trends are resolved in six months after identification and do not recur Self Assessment The following self assessments are currently planned for 1998:
. Monthly Unit Trend Reports
. Quarterly Unit Trend Reports
. Quarterly Station-wide Integrated Trend Report
. Quarterly Self Assessment of each unit Corrective Action Program
. Annual Assessments of each department corrective action performance
. Semi-Annual Nuclear Oversight Corrective Action Program Audit
. Nuclear Oversight Restart Verification Plan (Monthly)
. Station Self-improvement Culture and Self-Assessment Program Effectiveness - 2nd Quarter
. HPES Effectiveness - 2nd Quarter
. Operating Experience Program Effectiveness - 3rd Quarter
. Station Corrective Action Program Effectiveness - 3rd Quarter Performance Measures Trend reports track corrective actions system key parameters on a monthly i and quarterly basis for each unit as well as for the station. The following j performance measures will be used for the on-going monitoring of this Key !
Issue: ;
e CR Method of Discovery :
. Human Performance (as measured by the number of precursor, near miss !
and breakthrough event Condition Reports (CRs) per 1,000 man-hours worked) i
. Timeliness of Screening CRs for Operability and Reportability 1
. Action Plan Development Time for Level 1 and Level 2 CRs
. Action Plan Quality
. Median Age of Open CRs
. Overdue Corrective Actions
. Recurrence of Significant Conditions Adverse to Quality
Docket Nos. 50-245 50-336 50-423 B17138 Attachment 5 Millstone Nuclear Power Station, Unit Nos.1,2,3 Requirements of the NRC Order, dated October 24,1996 and NNECO's Actions in Compliance 1
March 1998
L U.S. Nucl:ar Regul tory Commission B17138\ Attachment 5\Page 1 Order: Independent Third-Party Oversight Program (ITPOP)
The information below indicates progress in satisfying the requirements of the Order.
Requirement of Order Within 60 days from the date of the Order, the Licensee shall develop, submit for NRC review, and begin to implement a comprehensive plan for'(a) reviewing and dispositioning safety issues raised by its employees and (b) ensuring that employees who raise safety concems are not subjected to discrimination.
Status NNECO's comprehensive plan was submitted to the NRC and implemented on January 31,1997. The remaining open items have been rolled into the Safety Conscious Work Environment Comprehensive Plan which was submitted on the docket on December 11,1997. The remaining open items are being tracked as restart or post-restart, as appropriate.
Requirement of Order Within 30 days from the date of the Order, the Licensee shall submit, for NRC 1 approval, a proposed independent _ third-party organization to - oversee implementation of the comprehensive plan.
Status !
I The independent third-party organization was proposed to'the. NRC in letters - I dated December 23,1996, January 14,1997, and February 4,1997. j Based on NRC !etters dated July 14,1997, and August 19, 1997, LHC was !
approved as the ITPOP Contractor. i
.i Requirement of Order l 1
Within 30 days of the NRC's approval of the third-party, an oversight plan for conduct of this third-party oversight shall be developed by the third-party and ,
- forwarded for NRC review.
Status !
l LHC's Oversight Plan and Revision 1 of the Oversight Plan were submitted to the NRC on May 2,1997, and June 13,1997, respectively. l l
U.S. Nucinr Regulatory Commission
- B17138\ Attachment 5\Page 2 Requirement of Order NRC approval of the ITPOP Oversight Plan is required prior to its implementation. i The~ NRC requires the plan to specify procedures for concurrent reporting of {
oversight activities, findings, and recommendations to the NRC and the Licensee.
Status The NRC approved the ITPOP Plan on July 14,1997.
Requirements of Order Reports on oversight activities, findings, and recommendations shall be provided to both _the licensee and the NRC at least quarterly following NRC approval of the oversight plan.
Status LHC has held seven meetings with NNECO and the NRC which were open for -
public observation on May 13, June 3, July 22, September 24,~ November .13, .]
1997, January 27, 1998,~ and March 3,1998. LHC has made a number of j recommendations duringl these . meetings. LHC~ has also made additional-1
- recommendations in a number of docketed letters. NNECO has provided written responses to the recommendations.
Requirements of Order The plan' for. Independent third-party oversight will continue to be implemented
-until the Licensee demonstrates, by its performance,' that the conditions which lead to the requirement of that oversight have been corrected to the satisfaction Lof the NRC.
, Status As discussed in ' Attachment 3 of this letter, NNECO has demonstrated substantial
~ progress in improving the SCWE at Millstone Station. The fundamental causes of - j the decline in Millstone's performance, as identified by NNECO's FCAT, and the j
_ findings of the NRC's MIRG, have been successfully addressed by.the changes :
and improvements' implemented at Millstone. The successful fulfillment of the four restart success criteria and the formal establishment of the infrastructure and j c programs to sustain performance, confirm that the work environment at Millstone !
, " Station is safety conscious,' accountable, and improving. !
Docket Nos. 50-245 5D:13fi 50-423 B17138 Attachment 6 Millstone Nuclear Power Station, Unit Nos.1,2,3 IP40001 issues Matrix March 1998 l
1 I -.
U.S. Nucl:rr Regulatory Commission B17138\ Attachment 6\Page 1 The following table lists the issues identified by the NRC IP40001 team in the February 18,1998 " Quick Look" letter, and the location in this letter where the issues are addressed.
IP40001: Issue t ~ '
.NNECO' Status / Letter Soctione a Timely communication to Concemed Individual Attachment 3 - Section 2.3.2-2 ECP Case Classification Attachment 3 - Section 2.3.1, 2.4.2 ECP Case Closure Basis Attachment 3 - Section 2.3.1,2.4.2 LHC Recommendation Tracking Attachment 5 Problem Area (Focus Area) Action Plan Adequacy Attachment 3 - Section 2.4.1-4 Long-range Action Plan / Performance Monitoring Attachment 4
/ SCWE Infrastructure / Oversight Phase-out Deviations from ECP Training Procedures / These deviations are z
Manuals administrative in nature and have been corrected or are being tracked in the corrective action program Metrics / Trend ng - Consistency of Analysis / Attachment 4 Format i
e s