WM 13-0021, Response to NRC Letter Regarding Work Environment Issues at Wolf Creek Generating Station

Response to NRC Letter Regarding Work Environment Issues at Wolf Creek Generating Station

ML13267A161
Person / Time
Site:	Wolf Creek
Issue date:	09/18/2013
From:	Matthew Sunseri Wolf Creek
To:	Reynolds S Office of Nuclear Reactor Regulation, NRC Region 4
References
WM 13-0021
Download: ML13267A161 (13)

Text

W0LF CREEK rNUCLEAR OPERATING CORPORATION Matthew W. Sunseri President and Chief Executive Officer September 18, 2013 WM 13-0021 Steven A. Reynolds, Regional Administrator U. S, Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511

Reference:

Letter dated August 19, 2013, from S. A. Reynolds, USNRC, to M.

W. Sunseri, WCNOC

Subject:

Docket No. 50-482: Response to NRC Letter Regarding Work Environment Issues at Wolf Creek Generating Station

Dear Mr. Reynolds:

By letter dated August 19, 2013, (the "Letter') you notified Wolf Creek Nuclear Operating Corporation ("WCNOC') of two NRC concerns with the safety conscious work environment

("SCWE") at Wolf Creek Generating Station ("WCGS"). The first concern related to a July 25, 2013, finding by the Regional Administrator for the U.S. Department of Labor's Occupational Safety and Health Administration ("OSHA") Region VII that Enercon Services, Inc. ("Enercon"),

a contract company ("Contractor"), performing work at WCGS had discriminated against one of its former employees for raising nuclear safety concerns at WCGS. The second concern related to the work environment in the WCNOC Quality organization.

Based on those concerns, the NRC requested specific information regarding WCNOC's assessment of its employees' willingness to raise safety concerns at WCGS and a description of remedial activity taken or planned to address any identified weaknesses as a result of the assessment. Certain information was requested within thirty days of the date of the Letter.

Additional information was requested within six months of the date of the Letter. The information requested within 30 days ("30 Day Response") is set forth in Enclosure I.

WCNOC will provide the balance of the information, as requested, within six months of the date of the Letter.

WCNOC is committed to cultivating and maintaining a strong SCWE. Following receipt of the Letter, WCNOC formed a diverse, multi-disciplinary team of employees comprised of four individual contributors, three supervisors, two managers and an executive, supported by an external SCWE expert, to consider the matters described in the Letter. The team reviewed actions taken to date to address the specific issues identified and recommended additional actions that would be effective in cultivating desired improvement. The team's effort is supporting a root cause analysis related to the issues identified in the Letter. As the executive sponsor for this team, I can say that its contribution has been instrumental in helping WCNOC P.O. Box 411 / Burlington, KS 66839 / Phone: (620) 364-8831 , .d An Equal Opportunity Employer M/F/HC/VET

Page 2 WM 13-0021 September 18, 2013 consider the specific concerns identified in the August 19, 2013, letter from different perspectives, thereby imparting a more complete awareness of the nature of the contributing factors and innovative solutions that can assist us in effectively addressing these specific NRC concerns.

More broadly, this team's work, in combination with input from employees within the Quality organization and supplemental workers, has helped WCNOC leadership gain insight regarding the strengths and weaknesses of the WCGS work environment generally. Based on these insights, site leadership recognizes the need to gain a better understanding of emerging issues in all segments of the WCNOC organization to prevent any erosion of the SCWE in those areas.

The team identified common themes between the two NRC concerns identified in the Letter and other WCNOC issues. These common themes include:

a) Weaknesses in SCWE policy, oversight and monitoring; b) Employee Concerns Program programmatic weaknesses; and c) Lack of leadership skills to recognize and address challenges to SCWE and its various attributes The team also performed benchmarking to identify industry standards and best practices in a variety of areas, including actions other NRC licensees have found effective in supporting a strong SCWE. The team considered the common themes in the context of the information gathered and its knowledge of the WCNOC history and culture to identify potential corrective actions that transcend the two specific NRC concerns.

These corrective actions, including WCNOC's plans for its leadership's dialogue with its workforce to support and sustain a SCWE, are outlined in Enclosure I. WCNOC's formal plan to communicate these corrective actions and other key messages to reinforce its commitment to a healthy SCWE is outlined in Enclosure I1.Properly implemented, these actions will lay the foundation for sustained improvement in the work environment at WCGS generally, not just within the specific areas identified in the Letter.

This letter contains no regulatory commitments.

Please do not hesitate to contact me at (620) 364-4008 or Debbie Hendell at (620) 364-4065 if you have any questions or require further information.

Sincerely, Matthew W. Sunseri MWS/rlt Enclosures cc: C. F. Lyon (NRC), w/e N. F. O'Keefe (NRC), w/e Document Control Desk (NRC), w/e Senior Resident Inspector (NRC), w/e

Enclosure I to WM 13-0021 Page 1 of 9 Information Requested Within 30 Days Introduction In its letter dated August 19, 2013 (the "Letter"), the NRC requested a response from WCNOC on seven specific items. Each of those requests, along with WCNOC's response, is set forth below.

Item 1 WCNOC's position regarding whether the actions of Enercon Services, Inc., ("Enercon")

as described in the August 19, 2013, letter, violated 10 CFR 50.7 and the basis for that position, including the results of any investigations WCNOC may have conducted to determine whether a violation occurred.

Response to Item 1 Enercon terminated the employment of an individual performing fence erection around the essential service water ("ESW') screen house at WCGS on January 30, 2012. A Wolf Creek employee concerns program ("ECP') representative investigated the termination. The ECP representative concluded that the termination was based on the individual's performance.

WCNOC does recognize, however, that the Acting Regional Administrator for the Occupational Safety and Health Administration ("OSHA"), Region VII, issued a decision on May 15, 2013, finding that there is reasonable cause to believe that Enercon's actions in terminating the individual's employment violated Section 211 of the Energy Reorganization Act ("ERA").

Enercon's appeal of that decision is pending.

Because of the similarity of the standards of 10 CFR 50.7 and those of Section 211 of the ERA, information related to whether the actions of Enercon might constitute a violation of 10 CFR 50.7 remains under development in the OSHA proceeding. WCNOC does not have access to all of this information and is not in a position to draw a legal conclusion regarding whether the actions of Enercon violated 10 CFR 50.7. WCNOC will continue to monitor the proceeding to determine whether additional actions are necessary to address potential effects on the work environment.

Item 2 Action WCNOC has already taken or plans to take to assure that the OSHA finding of discrimination by Enercon is not having a chilling effect on the willingness of other employees to raise safety and compliance concerns within the WCGS organization and, as discussed in NRC Form 3, to the NRC.

Response to Item 2 Actions Taken To Reinforce a SCWE Following Issuance of OSHA Decision As indicated in the Response to Item 1, on May 15, 2013, the Acting Regional Administrator for OSHA Region VII issued a decision finding that there is reasonable cause to believe that Enercon's actions in terminating an individual's employment violated Section 211 of the ERA.

On May 20, 2013, a WCNOC executive contacted an Enercon executive to request information

Enclosure I to WM 13-0021 Page 2 of 9 regarding actions Enercon was taking to reinforce its SCWE. Enercon shared with WCNOC its message, sent via e-mail on May 22, 2013, to all of its employees, to emphasize the need to raise concerns and the alternative pathways available through which to do so. The WCNOC executive reinforced WCNOC's expectations that Enercon cultivate a SCWE in performing its work at the WCGS site with the Enercon's executive.

Also on May 20, 2013, WCNOC published an article in The Crucial Times, its daily on-site news publication, making site personnel aware of the OSHA decision and reinforcing its commitment to create a safe work environment where anyone can raise concerns without fear of harassment, intimidation, retaliation or discrimination ("HIRD") and thanking individuals for raising concerns. The following month, WCNOC launched a video series discussing the nuclear industry's adoption of the new Traits of a Healthy Nuclear Safety Culture. This series will feature video messages explaining each trait.

More recently, WCNOC has taken actions to reinforce a SCWE with its supplemental work force. For example, the largest concentration of Contractors currently on site are working on the ESW pipe replacement project. WCNOC's Project Director for the ESW pipe replacement project has provided copies of the WCNOC trifold entitled Our Commitment to a Safety Conscious Work Environment to contractor managers for distribution to craft workers. Similar distribution of INPO 12-012: Traits of a Healthy Nuclear Safety Culture is planned. He has worked with Contractor leadership to increase discussions of SCWE at pre-job briefs, kick-off meetings and Plan of the Day Meetings, not only to educate managers and supervisors, but also to encourage them to share the information with craft workers. Cards for raising condition reports and drop boxes have been made more widely available to supplemental workers.

Finally, together with the WCNOC Ombudsman, WCNOC's Project Director has taken a variety of measures to heighten the awareness of the availability of WCNOC's Employee Concerns Program ECP ("ECP") and Corrective Action Program ("CAP') to supplemental workers. As discussed in the Response to Item 4, these actions of the Project Director for the ESW Project will serve as a model that can be adapted for future SCWE engagement efforts with supplemental workers and employees across the WCGS site.

Actions Taken or Planned To Evaluate SCWE Following Issuance of OSHA Decision On June 7, 2013, the NRC completed a supplemental inspection pursuant to Procedure 95002.

This inspection included a limited scope safety culture assessment follow-up in accordance with Inspection Procedure 4100, "Independent Safety Culture Assessment Follow-up." Based on this assessment, the NRC concluded WCNOC's nuclear safety culture was adequate to support nuclear safety and was improving. The inspection team did, however, note a number of safety culture challenges within a few work groups. These challenges have been entered into the WCNOC CAP.

WCNOC has also initiated its own efforts to evaluate the strength of its SCWE following the issuance of the OSHA decision. First, WCNOC is providing supplemental resources to its ECP function to permit broader scope follow-up on concerns raised among the supplemental workforce regarding HIRD and to strengthen the ability to conduct investigations that not only are independent, but are also perceived by the workforce to be independent. WCNOC expects this approach will yield a more complete picture of the status of the work environment within the relevant work groups following issuance of the OSHA decision. Inputs relevant to SCWE identified from such investigations shall be considered in connection with WCNOC's response sixth months following the date of the Letter (the "Six Month Response").

Enclosure I to WM 13-0021 Page 3 of 9 In addition, in late September 2013, WCNOC will request site personnel to complete a SCWE survey. The communications regarding this survey will emphasize the confidential nature of the survey and encourage site personnel to complete the survey to support WCNOC's efforts to improve the work environment. The survey results will assist WCNOC in assessing the work environment following issuance of the OSHA decision. These results will also provide baseline data regarding the work environment against which to measure the effectiveness of WCNOC improvement efforts. A subsequent survey will be conducted to help assess the effectiveness of corrective actions, identify any need for course corrections, and for trending purposes. The survey results and trends will be addressed in the Six Month Response.

WCNOC will continue to collect data between surveys by creating a dialogue on SCWE issues within their work groups and across the WCGS site. As discussed in item 4 below, WCNOC will use engagement and skip-level meetings to create an ongoing dialogue through which to gather information about the work environment generally and the effectiveness of corrective actions specifically.

Finally, WCNOC is treating the Letter and the associated root cause analysis as an emergent safety issue in its nuclear safety culture monitoring process. Accordingly, this item will be a standing agenda item for regularly scheduled nuclear safety culture monitoring panel meetings and the panel's reports to the nuclear safety culture monitoring panel senior leadership team.

Corrective action timeliness and effectiveness will be monitored and assessed by this process.

This process also monitors other inputs that may indicate developing issues in the specific trait areas of environment for raising concerns, respectful work environment, and problem identification and resolution.

Item 3 WCNOC's action plans to address existing SCWE issues in the Quality Department to improve the environment in the department and, if appropriate, throughout WCGS. The action plans, at a minimum, should specifically address how policies can be assured of setting a low threshold for writing condition reports and how each avenue for raising concerns will be improved, including ease of use and accessibility of the corrective action program, knowledge and use of the Employee Concerns Program, availability of the NRC, and WCGS's open door policy. Also include the measures that will be used to determine the action plan effectiveness.

Response to Item 3 Many of the work environment issues in the Quality organization have emerged in the context of efforts to drive improved performance based on the results of an audit performed by the Nuclear Industry Evaluation Program ("NIEP') in 2011. NIEP identified several significant deficiencies, some of which were repeat issues from the 2009 NIEP audit. WCNOC has expended substantial effort attempting to understand and address the work environment issues within the Quality organization through use of internal and external resources, but recognizes that these efforts have not been sufficient.

During the course of its review of the work environment concerns in the Quality organization and the other issues identified in the Letter, WCNOC identified areas for improvement in existing policies, processes and practices. Improvement in these areas is expected to improve the overall work environment at WCGS on a sustained basis. Among these enhancements are those designed to ensure condition reports are written at a low level and heighten the visibility,

Enclosure I to WM 13-0021 Page 4 of 9 ease of use, and accessibility of alternative pathways for raising concerns. Set forth below are the action items that have been initiated or are planned to address the work environment issues within the Quality organization particularly and more broadly at WCGS. These actions will be supplemented by those actions identified in the responses to Items 2, 4, 5 and 6. The effectiveness of these actions will be assessed as described in the Response to Item 2.

Action Item Status and Schedule

1. Review CAP policies and procedures to evaluate whether The August 27, 2013 improvements can be made to emphasize a low threshold issue of The Crucial for writing a condition report ("CR'). These improvements Times described to site should reinforce the need to identify issues early and at a personnel the process by low threshold such that more significant issues can be which CRs can be prevented and remind individuals of the ability to submit initiated and the process anonymous CRs. by which to submit anonymous CRs.

Scheduled completion of other action items by Six Month Response.

2. Clarify the distinction between writing a CR as an individual The August 27, 2013, and writing a CR as a Quality Assurance ("QA") Audit Team issue of The Crucial Lead. Based on the results of benchmarking and feedback Times reaffirmed that no from the WCNOC QA personnel, develop appropriate prior approval or processes to finalize QA audit findings in CAP. Evaluate permission from another whether similar structural issues related to writing CRs might is required to initiate a require clarification in other site organizations (e.g. CR. Benchmarking Security). completed. Scheduled completion of other action items by October 18, 2013.

3. Implement improvement to CAP software interface to Enhancement to the CAP improve ease of CR initiation process. Increase the visibility software to reduce CR of mechanisms for initiating CRs through the hard copy initiation burden have venue. Develop and implement a communications plan been identified and are regarding such changes. Provide training to supervisors scheduled to be and managers on the changes and management's role in implemented at the next supporting CAP and encouraging site personnel to identify software update planned issues at a low level in the CAP. in 2013.Scheduled completion of other action items by Six Month Response.

4. Complete a root cause analysis to address the elements of A root cause analysis is the Letter. Identify and implement required corrective in progress. Information actions. gathered to support this 30 Day Response will be considered. Upon identification of action items, the schedule for implementing any additional corrective actions shall be set forth in CR 73241. The status

Enclosure I to WM 13-0021 Page 5 of 9 of any such corrective actions shall be addressed in the Six Month ResDonse.

5. Retain third party resources to analyze the organizational Third party consultant dynamics within the QA organization. Implement an action performed assessment:

plan to enhance organizational effectiveness and to coach September 2-6, 2013.

manager and supervisor on how to improve the work Preliminary results were environment. Establish criteria to measure current status presented to WCNOC and future progress, along with appropriate monitoring executives on September intervals. 6, 2013. Report of assessment results and strategy for improvement under development. The strategy and status of any corrective actions shall be addressed in the Six Month Response.

6. Evaluate the Quality organization's reporting relationships Evaluation underway.

and the QA organizational structure. Executive Team will consider recommendations. The status of implementation of any changes shall be addressed in the Six Month Response.

7. Evaluate whether the current ECP policy, procedures, The evaluation shall be processes, resources and oversight are consistent with completed by the Six industry best practices. Such evaluation will specifically Month Response. The consider whether they are adequate to support heightened status of the reinforcement of SCWE at WCGS, including among the implementation of any supplemental workforce. This evaluation will include, but is changes to the ECP not limited to the following. program shall be a) Consideration of a threshold screening process for addressed in the Six concerns to determine whether background of the Month Response.

investigator might lead to perceptions of bias.

Identification of methods to ensure availability of third party investigation resources when ECP personnel may be perceived to lack independence and effective methods to communicate the availability of those alternatives.

b) Development of clearer guidance regarding confidential treatment of information brought to ECP.

c) Clarification of the distinction between the traditional ECP and ombudsman roles and evaluation of WCNOC's current practice of combining these roles within the ECP function.

Implement changes indicated by such evaluation. Develop strategies to communicate changes to the ECP while strengthening the view of the ECP as a viable alternative for raising concerns among WCNOC employees and

Enclosure I to WM 13-0021 Page 6 of 9 supplemental workers.

8. Provide training to Quality manager and supervisors, as well A training needs analysis as other WCNOC executives, managers, supervisors and has been initiated and project managers, regarding SCWE and strategies for approved, trainers have managing and leading in a way that strengthens a SCWE. been identified and Include application of SCWE attributes into the training materials are implementation of the WCNOC Accountability Model. under development.

Scheduled completion by the Six Month Response.

9. Conduct benchmarking with licensees who have substantial Benchmarking of Contractor workforces on their sites to identify best practices licensees has been to encourage supplemental workers to raise concerns and undertaken and is largely provide work environment oversight for supplemental complete. Evaluation workforces. Identify any modifications to existing completed by the Six approaches indicated by such evaluation. Month Response. The status of any modifications will be addressed in the Six Month Response.

10. Develop and implement a process for evaluating certain Development of the proposed employment actions affecting employees and process shall be supplemental workers s to ensure such actions do not completed by the Six constitute retaliation for engaging in protected activity and Month Response. The do not create a chilling effect in the affected work group or status of implementation elsewhere on the WCGS site. of such processes will be addressed in the Six Month Response.

11. Develop provisions that outline a Contractor's obligations to Draft provisions have prohibit retaliation for engaging in protected activity, cultivate been prepared and will a SCWE, and cooperate with WCNOC in monitoring the be adjusted as necessary work environment and investigating concerns, provide to address other access to an ECP, and participate in WCNOC's process for programmatic changes evaluating certain proposed employment actions, discussed herein.

Incorporate this provision in WCNOC's standard terms and Implementation of the conditions for inclusion in new contracts with major provision into WCNOC's Contractors performing work at WCGS. Consider contract standard terms and amendments with existing Contractors as appropriate, conditions will be completed by the Six Month Response. The status of any completed amendments will be addressed in the Six Month Response.

Enclosure I to WM 13-0021 Page 7 of 9 Item 4 WCNOC's plan to communicate expectations and policies concerning SCWE at WCGS, and methods used to verify that all WCGS and contractor personnel have received the message and clearly understand it.

Response

WCNOC has built an integrated communication strategy for WCGS. Communication plans are developed for specific initiatives that include key topics, key messages, communication tools and a summary of communication activities related to that area. These individual plans are integrated into the overall station strategy to provide an overview of the multiple pathways through which site personnel hear key messages.

To ensure the information communicated is reinforced and retained by site personnel, consistent messages are developed. A core team of subject matter experts help Corporate Communications to determine the key messages to communicate for a specific initiative. A Corporate Communications representative meets with the President and Chief Executive Officer weekly to discuss key communication items and any associated emerging issues to determine whether adjustments to the communication plan is necessary, thus allowing a timely response to developing information. The station communication plan is updated with this information and is shared weekly with the Executive Team for awareness and input. This ensures the leadership team is aligned to the messages and priorities for station communication.

WCNOC has incorporated its expectations and policies concerning SCWE, refined to incorporate its receipt of the NRC's Letter, into this communication strategy. Enclosure II includes the SCWE communication plan excerpt from this communication strategy.

WCNOC realizes, however, that its leadership must reinforce these formal communications by creating a dialogue on SCWE issues within their work groups and across the WCGS site. As discussed in the Response to Item 2, the Project Director for the ESW project has provided a useful model. WCNOC will adapt and implement this model site-wide. Adaptations may include engagement meetings and skip-level meetings to create an ongoing dialogue within and among the WCNOC workforce on these issues.

Item 5 WCNOC's plan to ensure that individuals who are not satisfied with the resolution of a problem can pursue the concern further through additional avenues (such as WCGS management, the corrective action program, the Employee Concerns Program or the NRC) without fear of retaliation.

As a threshold matter, WCNOC will evaluate its SCWE policy to ensure it appropriately encourages the use of additional avenues when individuals are not satisfied with the resolution of a particular problem. It will communicate any changes to the workforce, along with a reminder of the available alternatives for raising concerns and that retaliation for raising concerns is prohibited. Completion is scheduled by October 31, 2013.

As reflected in the Response to Item 3, WCNOC also intends to provide training to the WCNOC leadership team that reinforces their obligations to cultivate a SCWE and practical strategies for

Enclosure I to WM 13-0021 Page 8 of 9 doing so. This training not only will provide an overall foundation for understanding SCWE, but also will address particular cultural issues at WCNOC that may present barriers to a strong, sustainable SCWE. In particular, the training will be designed to assist WCNOC leadership to cultivate awareness among site personnel of the alternative pathways that are available for raising concerns and to encourage their use.

WCNOC also recognizes that the availability of viable alternative avenues through which to raise concerns will give individuals confidence in using them. Therefore, as reflected in the Response to Item 3, WCNOC plans to strengthen the ECP function. WCNOC plans to undertake a review of all of its ECP policies, processes and procedures to determine whether they are consistent with industry best practices. Issues that warrant particular attention include the need to strengthen confidentiality protocols and enhance the alternatives WCNOC ECP can provide to ensure independence in investigating issues. A communication strategy regarding these changes will be implemented to ensure the changes provide meaningful benefit.

Finally, on January 1, 2013, WCNOC implemented a Differing Professional Opinion Resolution Process, procedure AP 17B-001. This process outlines an alternative way to formally review these differences of opinion and incorporates the opportunity for an independent, impartial review by individuals who are knowledgeable about the underlying technical issues. The process is available to all employees. The availability of this new alternative process was most recently communicated to site personnel on September 3, 2013 in The Crucial Times, the WCNOC daily on-site news publication.

Item 6 What actions WCNOC has taken or plans to take to ensure that actions taken against individuals are not perceived as retaliatory to avoid a further chilling of the environment at WCGS.

Response

Many of the actions identified in the Response to Item 2 were designed to communicate WCNOC's prohibition on retaliation against individuals for raising safety concerns. This message will be reinforced by certain action items identified in the Response to Item 3. These action items include a) leadership training regarding strategies for managing and leading in a way that strengthens a SCWE, particularly with respect to performance improvement and Contractor oversight, and b) the development and implementation of a process for evaluating significant employment actions taken with employees and supplemental workers to ensure such actions do not constitute retaliation for engaging in protected activity and do not create a chilling effect. Both of these actions, effectively implemented, will help ensure that actions taken against individuals are not perceived as retaliatory, thus helping to avoid any chilling effect associated with such actions.

The enhancements to the ECP function and the action plan developed to improve the work environment within the QA organization also contain elements that will assist in identifying potential perceptions of retaliation and taking effective actions to prevent any associated chilling effect.

Enclosure I to WM 13-0021 Page 9 of 9 Item 7 Your plans to inform the WCGS workforce including contractors, of: (0)the issuance and content of this chilling effect letter; (ii) the current status of SCWE at WCGS; and (iii) your action plan to address the SCWE issues.

Response

WCNOC informed site personnel of the receipt of the Letter through an e-mail from the CEO published on August 21, 2013. A copy of the Letter was attached to the e-mail. In this e-mail, the CEO explained that certain prompt actions had been taken to address some of the identified issues and described planned actions, including plans to give leaders the tools to cultivate a strong safety conscious work environment. He also summarized the path forward, stating that additional corrective actions would be identified during the course of developing the response to the Letter and a plan to ensure certain corrective actions are deployed broadly. He reinforced the practice of notifying the NRC when individuals do not feel comfortable raising concerns internally, recognized the licensee's responsibility to create an environment where individuals feel encouraged to raise concerns internally, and requested individuals to inform any member of WCNOC leadership or the WCNOC Ombudsman of any examples of requirements or actions they believed could have the effect of discouraging individuals from raising concerns to help them ensure those issues are addressed. Finally, the CEO reaffirmed his commitment to achieving the goal of creating an environment where each individual feels comfortable raising concerns.

On August 29, 2013, WCNOC published an article in The Crucial Times informing site personnel of the formation of a team to assist in developing WCNOC's response to Letter, identified each team member, and encouraged input from site personnel to support the effort.

Many individuals responded to this request, providing input either directly or indirectly. On September 13, 2013, WCNOC published another article in The Crucial Times updating site personnel on the work of the team to date, its future role in the site's SCWE efforts, and plans to share the WCNOC response with site personnel.

The Response to Item 4 outlines the approach taken by WCNOC for important communication initiatives. WCNOC will rely on this approach to communicate at appropriate intervals the current status of SCWE at WCGS and its action plans to address the SCWE issues. The communication plan set forth in Enclosure II will be updated to plan and track these communications.

Enclosure II to WM 13-0021 Page 1 of 2 Communication Plan for Chilling Effects Letter Response Topic/issue:

• Wolf Creek received a Chilling Effects Letter from the NRC on Aug. 19 (Letter).

• The letter describes NRC concerns about Wolf Creek's safety-conscious work environment (SCWE).

• An initial response is due within 30 days of the letter date. A second response is due six months from the letter date.

Key messages:

-V To be developed specific to each action item (ifappropriate) set forth inthe 30 Day Response.

Milestones: Date:

Response team charter developed Aug. 28, 2013 (complete)

Kickoff response team meeting Aug. 28, 2013 (complete)

Target date for collection of requested information for 30-day response Sept. 4, 2013 (complete)

Submit 30-day response to corporate sponsor Sept. 13, 2013 (complete)

Submit 30-day response to NRC Sept. 18, 2013 (complete)

Submit six-month response to NRC Feb. 19, 2014 Communication type Communication vehicle Outage handbooks include SCWE information Distributedto all personnel priorto an outage Station-wide Fundamental Behaviors include SCWE Distributedto all personnel working at Wolf Creek Face-to-face communications Pro-job briefs, kick-off meetings, plan of the day meetings, engagementmeetings, skip-level meetings and All Hands Meetings Written communications LeadershipTeam initiated e-mails/CrucialTimes/Wolf Tracks Leadership Team meetings Bi-weeklylevery six week presentations Visual reminders on SCWE, ECP and CAP Marquee messages, posters,presentations Surveys Electronic,paper Activity/Key Messages/Delivery Method Targeted Delivery Date(s) Completed Date CrucialTimes:

Wolf Creek supports a strong SCWE May 20, 2013 May 20, 2013 Site-wide e-mail:

Site-wide message to the station about receipt of Letter with Letter attached Aug.21, 2013 Aug.21,2013 Leadership Team meeting (MRM):

Message about response team initiative and key SCWE messages Aug. 23, 2013 Aug. 23, 2013 CrucialTimes:

Message about how to initiate a Condition Report and anonymous CRs Aug. 27, 2013 Aug. 27, 2013 ChillingEffects Letter communication plan, REV. 0, page 1

Enclosure II to WM 13-0021 Page 2 of 2 Crucial Times:

Message about team formation and introducing external SCWE advisor Aug. 29, 2013 Aug. 29, 2013 Marquee Messages:

Weekly messages on the marquees about SCWE Began Aug. 27, 2013 Underway Crucial Times:

Differing professional opinion procedure Sept. 3, 3013 Sept. 3, 2013 CrucialTimes:

__NIEP provides preliminary results Sept. 11, 2013 Sept. 11, 2013 Leadership Alignment Meeting:

Meeting discussed SCWE purpose and progress on preparing our 30 Day Response Sept. 16, 2013 Sept. 16, 2013 Site-wide e-mail:

Site-wide message to the station about 30 Day Response Sept. 18, 2013 Station-wide Survey:

Station communication about issuance of survey and results September and October 2013 All-Hands Meeting:

Discuss 30 Day Response action items, implementation plan and key SCWE messages Oct. 1, 2013 Crucial Times:

Communicate any changes to the SCWE policy and alternate methods to report concerns Oct. 31, 2013 Crucial Times:

Communicate root cause for issues raised in Letter October 2013 Crucial Times:

Training provided to Leadership Team during fall 2013 Leadership Continuing Training October 2013 Crucial Times and Leadership Team Meetings:

Communicate changes with CAP software and management's role to encourage low October 2013 threshold for initiation Site Artifacts:

Replace current safety culture posters with site specific information October 2013 CrucialTimes:

Communicate updated ECP policies and processes TBD Othercommunications as directed by implementation teams (to be updated)

ChillingEffects Letter communication plan, REV. 0, page 2