ML15076A470

Cel 6-Month Response 1-24-14 WM14-0002

ML15076A470
Person / Time
Site:	Wolf Creek
Issue date:	01/24/2014
From:	Matthew Sunseri Wolf Creek
To:	Dapas M NRC Region 4
Proulx D
References
WM14-0002
Download: ML15076A470 (20)

Text

Matthew W. Sunseri President and Chief Executive Officer (620)364-3008 (620)364-4017 facsimile January 24, 2014 WM 14-0002 Marc L. Dapas, Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington TX 76011-4511

References:

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

Sunseri. WCNOC

2) Letter dated September 18, 2013, from M. W. Sunseri, WCNOC. to S.A.

Reynolds. USNRC

Subject:

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

Dear Mr. Dapas:

By letter dated August 19, 2013, (Letter) you notified Wolf Creek Nuclear Operating Corporation (WCNOC) of two NRC concerns with the safety conscious work environment (SCWF) at the Wolf Creek Generating Station ( WCGS) and requested WCNOC respond to certain issues identified in the letter within thirty days and within six months, respectively. By letter dated September 18. 2013, WCNOC provided the information requested within thirty days (30 Day Response). This letter provides the information requested within six months (Sir Month Response).

In order for the NRC to fully consider WCNOCs progress in addressing the referenced SCWE concerns in the context of its end-of-cycle performance review, the NRC requested WCNOC provide its Six Month Response by January 24, 2014. Therefore, this Six Month Response reflects developments as of January 23, 2014. In addition to providing this Six Month Response,

WM 14-0002 Page 2 of 2 WCNOC officials discussed their progress in addressing the work environment concerns with NRC officials in a public meeting held in the NRC Region IV offices on January 22, 2014.

The Letter requested that WCNOCs Six Month Response address three specific issues:

1) The results of WCNOCs evaluations of progress in addressing SCWE concerns at WCGS;

2) The effectiveness of actions taken to address the SCWE concerns identified in Reference 1; and

3) Any additional actions or changes in actions planned and taken to address SCWE issues at WCGS.

Enclosure 1 contains this requested information by discussing the status of the actions taken in response to the seven specific items identified in Reference 1, as well as the effectiveness of those actions or plans to determine the effectiveness of those actions. Additional planned actions are also addressed in Enclosure 1.

As described in Enclosure 1, WCNOC has identified and implemented actions designed to strengthen its SCWE. It has enhanced its ability to assess the status of its work environment, established greater contractor understanding of their obligations to cultivate a SCWE, and developed greater attentiveness of the leadership team to their role in cultivating a SCWE in their daily interactions with WCGS personnel. WCNOC will continue to evaluate the effectiveness of its improvement efforts and make adjustments as necessary to ensure it maintains a healthy SCWE at WCGS.

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, I LJ Matthew W. Sunseri MWS/djr Information Requested Within Six Months SCWE Communication Plan cc: C. F. Lyon (NRC)

N. F. OKeefe (NRC)

Document Control Desk (NRC)

Senior Resident Inspector (NRC)

Enclosure 1 of WM 14-0002 Information Requested Within Six Months 13 Pages

Enclosure 1 to WM 14-0002 Page 1 of 13 Information Requested Within Six Months Introduction In its August 19. 2013, letter (the Letter), the NRC requested WCNOC to respond to seven specific items within thirty days and provide an additional update within six months. By letter dated September 18, 2013, (the 3O Day Response), WCNOC identified actions taken or planned related to each of the seven items. Consistent with the NRCs update request in the Letter, set forth below are each of the seven items, the status of actions taken with respect to each item, and the results of any assessment of the effectiveness of such actions. Future pians to assess the effectiveness of such actions are also identified herein (Six ifonth Response).

Finally, the additional actions that WCNOC plans to strengthen its safety conscious work environment (SCWE) are addressed in the conclusion.

WCNOC identified three teams to be responsible for implementation of the Action Items relating to Quality Assurance, the supplemental workforce, and the employee concerns program (ECP)

(see Item 3). These three teams were coordinated through a fourth cross-functional team to ensure an integrated approach to implementation of the Action Items. The entire initiative was led by a project manager. In order to ensure WCNOC continued to benefit from diverse perspectives and expertise during the implementation of the Action Items, WCNOC followed the same model it had used in developing the 30 Day Response team. Specifically, it sought to ensure the implementation teams were multi-disciplinary and included individuals at a variety of levels within the organization. The composition and activities of the teams were communicated site-wide in our daily newsletter to employees, Crucial Times, and various face-to-face meetings led by senior management.

Item 1 WCNOCs 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.

Status of Actions Taken in Response to Item 1 The 30 Day Response explained that the facts and circumstances described in the Letter were the subject of a complaint filed under Section 211 of the Energy Reorganization Act (ERA) with the Occupational Safety and Health Administration of the U.S. Department of Labor (Section 211 complaint). It further explained why WCNOC was not able to draw a legal conclusion regarding whether the actions of Enercon might constitute a violation of 10 CFR 50.7.

Since WCNOCs submittal of the 30 Day Response, the Section 211 Complaint has been resolved to the mutual satisfaction of the parties and is pending approval before the Administrative Law Judge assigned to the case. Resolution of this matter by the parties is a

Enclosure I to WM 14-0002 Page 2 of 13 positive development with respect to the individual matter and the work environment at WCGS generally.

To enable WCNOC to provide more effective support to the work environment for supplemental personnel, certain programmatic changes have been made in connections with the Employee Concerns Program (see Item 2). WCNOC management is also taking an active role to improve its contractors awareness of their obligations to prevent discrimination and maintain a SCWE (see Item 3 and Conclusion). WCNOC is also increasing its oversight of personnel actions taken by contractors through implementation of the Personnel Action Review Board (PARB) procedure. These actions will heighten WCNOCs ability to identify potential issues of discrimination involving supplemental personnel and address any need to take action to mitigate any potential adverse impact on the sites SCWE.

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.

Status of Actions Taken in Response to Item 2 The 30 Day Response described the 051-IA Region VII Acting Regional Administrators May 15, 2013, decision regarding the Section 211 complaint (OSHA Decision) and the pending appeal of that decision. It then outlined the actions WCNOC had already taken to ensure that such decision did not have a chilling effect on the willingness of other WCGS personnel to raise safety and compliance concerns within the WCGS organization.

Ihe 30 Day Response also described additional actions it planned to assess the status of a SCWE at WCNOC following the issuance of the OSHA Decision. The results of these actions are described below.

First, WCNOC issued a survey to more formally assess the strength of the SCWE at WCGS, including whether individuals believe they can raise concerns without fear of harassment, intimidation, discrimination or retaliation, and their awareness and perception of different avenues for raising concerns (corrective action program (cAP). ECP, management and the NRC) at WCGS (the Baseline Survey). The Baseline Survey was administered to both WCNOC employees and supplemental site personnel. Site communications paved the way for broad participation by describing the confidential treatment of information collected and the identity of the individuals providing it. Alternative methods for completing the Baseline Survey were provided to enhance accessibility.

The Baseline Survey was administered between September 30, 2013 and October 15, 2013.

Throughout this period, WCNOC encouraged completion of the survey in site wide communications through Crucial Times articles, leadership verbal reminders and email by explaining the surveys role in improving the work environment. These efforts resulted in over

Enclosure Ito WM l4-0002 Page 3 of 13 1100 responses being received from both WCNOC and supplemental workers representing every work area at WCGS. The survey results indicated most respondents were comfortable reporting concerns, though improvement was needed in proper prioritization and timely and thorough resolution of issues. The Baseline Survey results did not identify any chilling effect associated with the issuance of the OSHA Decision. The Baseline Survey results are described further in Item 3, below.

Second, changes were made to the WCNOC ECP to refocus the program on, and provide greater accessibility of the WCNOC ECP to, the supplemental workforce. Programmatic changes were also made to demonstrate more clearly the ability of the WCNOC ECP to conduct investigations that not only are independent, but also are perceived to be independent. Accordingly, external resources have been relied upon to investigate certain concerns raised by supplemental workers since the issuance of the Letter. No chilling effect associated with the OSHA Decision has been identified as a result of these efforts.

Finally, following its receipt of the Letter, WCNOC heightened its infurmal efforts to encourage supplemental leaders to foster a culture where supplemental personnel feel comfortable raising issues and are encouraged to do so either within their organization or through WCNOC processes. These efforts included meeting with certain contractor management or ECP personnel to better understand their programmatic SCWE training and ECP activities. it also included more intrusive WCNOC oversight with respect to concerns raised. Although areas for improvement in work environment emerged through these efforts, no chilling effect associated with the OSHA Decision was identified.

item 3 WCNOCs 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 bow 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 WCGSs open door policy. Also include the measures that will be used to determine the action plan effectiveness.

Status of Actions Taken in Response to Item 3 Item 3 specifically focused on the Quality Assurance (QA) organization, but also led WCNOC to consider whether actions might be taken more broadly at WCGS to improve the work environment. As reflected in its 30 Day Response, WCNOCs evaluation concluded that broader actions were warranted, particularly with respect to certain existing policies, processes and practices. Based on its evaluation, WCNOC identified specific Action Items to address the work environment issues within the QA organization particularly and more broadly at WCGS.

Enclosure I to WM 14-0002 Page4ofl3 Each of the Action items identified in the 30 Day Response is set forth in the first column in the table below. The status of such Action Item and, as appropriate, its effectiveness or plans to assess its effectiveness. is summarized in the second column.

Action Item Status and Effectiveness Review I. Review CAP policies and procedures to evaluate Complete. See CR 75483 The whether improvements can be made to emphasize a evaluation revealed numerous places in low threshold for writing a condition report (CR). WCNOC policies and procedures that These improvements should reinforce the need to emphasized a low threshold for writing identify issues early and at a low threshold such that condition reports. In addition.

more significant issues can be prevented and remind benchmarking revealed that WCNOCs individuals of the ability to submit anonymous CRs. goal for generation of CRs was higher than most other single unit sites, and WCNOC exceeded its goal by almost 5000. A review of the CRs indicated that many were low level issues. Although no changes to policies or procedures were warranted, the evaluation recognized that continuous communication of this expectation is appropriate.

2. Clarify the distinction between writing a CR as an See CR 7324 1-02-01. Benchmarked individual and writing a CR as a QA Audit Team with 1 6 nuclear industry peers. All Lead. Based on the results of benchmarking and respondents indicated that review is feedback from the WCNOC QA personnel, develop required prior to documenting QA appropriate processes to finalize QA audit findings in Findings in a CR. Such review is not CAP. Evaluate whether similar structural issues necessary for CRs that need to be written related to writing CRs might require clarification in for immediate action. Consistent with other site organizations (e.g. Security). benchmark results. WCNOC process requires collegial review of CRs documenting QA Findings and excludes immediate action items and CRs that do not document QA Findings from this review requirement. WCNOC, as well as the facilitator described in Action Item 5 below, have taken actions to explicitly encourage all QA Team members to write CRs. The QA personnel that participated in a recent focus group meeting acknowledged that barriers to writing CRs have been removed.

3. Implement improvement to CAP software interface Complete. See CR 75483-01-02.

to improve ease of CR initiation process. Increase Software enhancements have been made the visibility of mechanisms for initiating CRs to provide defaults to screens for through the hard copy venue. Develop and initiation of CRs and include a more implement a communications plan regarding such visible option for initiating an changes. Provide training to supervisors and anonymous CR. Hard copy CR initiation managers on the changes and managements role in options have been simplified and more supporting CAP and encouraging site personnel to visible by use of colored covered sheets identify issues at a low level in the CAP. with clear instructions on how to to \VM 14-0002 Page 5 of 13 L Action Item Status and Effectiveness Review complete and submit the CR, New kiosks that are clearly marked provide for broader distribution of such forms, as well as convenient completion.

Supervisors and managers were trained on these changes to the CAP and expectations for encouraging site personnel to identi1 issues at a low level in November-December, 2013.

4. Complete a root cause analysis to address the See CR 73241. Root cause evaluation is elements of the Letter. Identify and implement complete. Root causes included the required corrective actions. following: 1) QA management was not sensitive to the individual consequences of their actions. 2) Wolf Creek did not take action to prevent a potential chilling effect from the Enercon adverse action.

A contributing cause was also identified; specifically that current policy does not provide sufficient guidance to establish independence, or an alternate method for managing, employee concerns. The evaluation validated the corrective actions to be taken in the 30 day response. Additional corrective actions were identified and many have been implemented. An effectiveness review will be conducted in June 2014.

5. Retain third party resources to analyze the See CR 73241-02-02. An external organizational dynamics within the QA organization, facilitator/coach performed a QA Implement an action plan to improve the work organization assessment in early environment and organizational effectiveness. September, 2013, reported on her Establish criteria to measure current status and future findings and developed a six month progress, along with appropriate monitoring intervals, action plan for improvements. Facilitator implemented the action plan during the intervening months by evaluating organizational dynamics, mapping audit processes, developing strategies for organizational improvement, facilitating team interactions, providing leadership coaching, assisting in conflict resolution and supporting personnel to develop their own personal development plans.

Facilitator will conduct monthly follow-up visits starting February 3. 2013, to provide individual coaching to ensure ongoing progress. An overall evaluation will be conducted in March 2014. The new Quality Manager, in consultation with the facilitator, will review the

Enclosure I to WM 14-0002 Page 6 of 13 Action Item Status and Effectiveness Review results of such assessment and determine next steps at that time.

6. Evaluate the Quality Organizations reporting See CR 7324 1-02-02. The new Quality relationships and the QA organizational structure. Manager will assume his responsibilities on January 27, 2014. The facilitator and a subject matter expert assisted the team in mapping the work processes to effectively group tasks into separate work functions. On or before June 30, 2014. WCNOC will review the results of such organizational changes and determine next steps at that time.

7. Evaluate whether the current ECP policy, procedures. Evaluation is complete. This evaluation processes, resources and oversight are consistent with was supported by a self-assessment industry best practices. Such evaluation will performed November 4-7. 2013. The specifically consider whether they are adequate to 1f_cccrnnt zIf-1 i-h. X7C&t(V support heightened reinforcement of SCWE at ECPs compliance with the Attributes set WCGS, including among the supplemental forth in NECEP 08-001, as well as the workforce. This evaluation will include, but is not specific issues identified in this Action limited to the following. Item 7. The self-assessment was led by a) Consideration of a threshold screening process an external consultant with extensive for concerns to determine whether background of experience in safety culture, SCWE, and the investigator might lead to perceptions of bias. ECP. The self-assessment team included Identification of methods to ensure availability of five ECP industry peers, the WCNOC third party investigation resources when ECP Ombudsman, and a member of the personnel may be perceived to lack independence WCNOC management team. The results and effective methods to communicate the were documented in Self-Assessment availability of those alternatives. Report SA-2013-60. The Report b) Development of clearer guidance regarding concluded WCNOC ECP was effectively confidential treatment of information brought to implemented, but improvement in ECP ECP. processes and procedures was necessary c) Clarification of the distinction between the to align with ECP industry best practices.

traditional ECP and ombudsman roles and Nine performance deficiencies and evaluation of WCNOCs current practice of twenty recommendations were identified.

combining these roles within the ECP function. The performance deficiencies and Implement changes indicated by such evaluation. recommendations were included in Develop strategies to communicate changes to the WCNQCs CAP for evaluation and ECP while strengthening the view of the ECP as a development of corrective actions.

viable alternative for raising concerns among See CRs 76347-76352; 76355; WCNOC employees and supplemental workers. 76357; 76359; 76360; 76361; 76363-76366; 76369; 76370; 76372; 76373; 76507; and 76377-76383. WCNOC will evaluate the adequacy of these changes collectively to ensure key messages and processes are appropriate and consistent. WCNOC will assess the effectiveness of the changes as part of the self-assessment to WM 14-0002 Page 7 of 13 Action Item Status and Effectiveness Review process and through regular self-assessments of the ECP (CR 76370).

independent review of case files (CR 76373), and the Nuclear Safety Culture Monitoring Panel (CR 76351).

8. Provide training to WCNOC executives, managers, Complete. See CR 73241-02-04.

supervisors and project managers regarding SCWE Training was conducted to 7 groups of and strategies for managing and leading in a way that approximately 30 individuals in four strengthens a SCWE. Include application of SCWE hour sessions in November and attributes into the implementation of the WCNOC December 2013. Required participants Accountability Model. included the WCNOC leadership team, certain project managers, and on-site leadership of supplemental workforce.

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training for leaders. The class provides leaders with in-depth information about characteristics of a chilled work environment, OSHA and NRC evaluation of allegations of discrimination, and the structural and behavioral components of SCWE. Case studies are used to further reinforce the critical role leadership plays in a cultivating and sustaining a strong and healthy work environment. Feedback from employees at recent focus groups and other meetings have recognized changes in behaviors of member of the WCNOC leadership team that support a healthy SCWE.

9. Conduct benchmarking with licensees who have Complete, Benchmarked numerous substantial Contractor workforces on their sites to licensees, many of whom have or have identify best practices to encourage supplemental recently had substantial Contractor workers to raise concerns and provide work workforces on their site. Benchmarking environment oversight for supplemental workforces. supported the following corrective Identify any modifications to existing approaches actions: strengthening contract language indicated by such evaluation, prohibiting retaliation and setting expectations for maintaining a SC WE; implementation of a review procedure for significant adverse personnel actions proposed for supplemental workers; and an improved onboarding process to include a greater focus on SCWE.

10. Develop and implement a process for evaluating Complete. See CR 7324 1-02-07.

certain proposed employment actions affecting Personnel Action Review Board employees and supplemental workers to ensure such procedure Al 13C-003 was issued with actions do not constitute retaliation for engaging in an effective date of January 7, 2014. The

Enclosure Ito WM 14-0002 Page 8 of 13 4ctinn Item Status and Effectiveness Review protected activity and do not create a chilling effect PARB has reviewed certain proposed in the affected work group or elsewhere on the employment actions relating to WCGS site, J performance reviews and, as warranted.

implemented chilling effect mitigation plans. Between early November 2013 and the effective date of the PARB procedure, senior management also informally evaluated signiflcant proposed employment actions affecting employees and, where possible, supplemental workers.

1 1. Develop provisions that outline a Contractors Complete. See CR 73241-02-04. These obligations to prohibit retaliation for engaging in provisions have been included in protected activity, cultivate a SCWE, and cooperate WCNOCs standard terms and conditions with WCNOC in monitoring the work environment and will be included in a substantially and investigating concerns, provide access to an ECP, similar form in future material contracts and participate in WCNOCs process for evaluating between WCNOC and nuclear materials certain proposed employment actions. Incorporate and services suppliers. Certain existing this provision in WCNOCs standard terms and contracts with large outage services conditions for inclusion in new contracts with major providers having a significant site Contractors performing work at WCGS. Consider presence will be amended to include contract amendments with existing Contractors as these provisions prior to the Spring 2014 appropriate, mid-cycle outage.

WCNOC conducted focus group meetings with members of different work groups in January 2014. The specific work groups included Quality Assurance, Maintenance. Information Services, Performance Improvement/Organizational Effectiveness and Health Physics (Security will be scheduled for February 2014). Work groups were selected based on results from the Baseline Survey. The interviews were intended to assess the effectiveness of certain corrective actions taken, identify any need for course corrections and to collect data for trending purposes.

Certain themes emerged. In the QA organization, the participants acknowledged that barriers to raising concerns have been removed, that they understand the alternative avenues for raising concerns and they are willing to report concerns through these avenues. Moreover, they reported organizational dynamics are improving. Other teams had similar views and reported that the cascading message on Baseline Survey results was effective. One participant from the QA organization did express residual concerns during the focus group about using ECP but was unaware of actions taken to address their specific concern. It was also too early to assess the effectiveness of the recent changes to ECP as well as certain other corrective actions. Proper prioritization and timely and thorough resolution of issues in CRs also is perceived to be an area for improvement (see Item 2).

WCNOC plans to conduct additional focus group meetings during 2014 to help assess the effectiveness of the corrective actions discussed herein. WCNOC also plans to conduct a mid year safety culture assessment (developed by the Utility Services Alliance), a follow-up SCWE survey later in 2014, and additional SCWE surveys thereafter. The Baseline Survey will provide the baseline data regarding the work environment that WCNOC will use to measure the

Enclosure I to WM 14-0002 Page9ofl3 effectiveness of WCNOC work environment improvement efforts. WCNOC will make adjustments to its improvement efforts as dictated by the information gathered though these efforts.

Item 4 WCNOCs 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.

Status of Actions Taken in Response to Item 4 The 30 Day Response described WCNOCs integrated communications strategy and how it had updated the SCWE component of that strategy to incorporate communications related to the Letter. A current version of the SCWE communication plan is attached as Enclosure 2. Recent communications under this plan are described in greater detail in Item 7 below. In addition WCNOC has updated its Corporate Policies regarding both SCWE and ECP to reinforce the expectation that employees raise concerns and the alternative avenues for doing so.

The results of the Baseline Survey indicate that site personnel understand their obligation to raise nuclear safety and other concerns and are comfortable doing so. Site personnel were also aware of different avenues for raising concerns. An area for improvement included prioritization.

rigorous evaluation, and timely resolution of concerns. In December 2013, a cascading message was delivered to all WCGS site personnel regarding these survey results and key corrective actions. Management engaged their direct reports in discussions on the Baseline Survey results and used this as an additional opportunity to reinforce the availability of alternative avenues for raising concerns.

More recently. the effectiveness of these messages has been reflected in the comments provided in the Focus Group meetings described in Item 3 above, In addition, beginning in April 2014, part of each WCNOC Divisions Excellence Plan will include actions the work group has identified to improve a SC WE. These actions will be developed based on each division managers dialogue with the work group on the Baseline Survey results for their group. This will provide an opportunity for dialogue on the effectiveness of the actions taken to date, but will also allow each division to tailor additional actions based on its unique needs. Finally, the surveys and additional focus group meetings during 2014 will help assess the effectiveness of these corrective actions and communications (see Item 3). WCNOC will make adjustments to its improvement efforts as dictated by: the information gathered though these efforts.

Item 5 WCNOCs 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.

Enclosure 1 to WM 140002 Page 10 of 13 Status of Actions Taken in Response to Item 5 The Baseline Surve responses referred to above suggest that individuals are aware of alternate avenues for pursuing concerns, however improvements are necessary in both the ECP and CAP to more broadly encourage individuals to use these avenues as alternatives for individuals to use when they are not satisfied with the initial resolution of a problem. WCNOC is implementing corrective actions to drive these improvements.

First, as indicated in the 30 Day Response, WCNOC has evaluated its SCWE policy to determine whether it appropriately encourages the use of additional avenues when individuals are not satisfied with the resolution of a concern. WCNOC also considered comments contained in the ECP Self-Assessment described in Item 3 above regarding this issue. Based on its evaluation, WCNOC has revised its policies regarding safety culture, SCWE, and ECP to acknowledge the opportunity employees have to pursue resolution of issues through additional avenues.

Second, WCNOC has also revised its ECP procedure (AP 18A-001) to clearly identify each of the alternative methods for reporting concerns. The revised procedure includes contact information for both WCNOC and NRC reporting alternatives. AP I 8A-00l explicitly identifies management as responsible for establishing and maintaining an atmosphere that encourages employees and supplemental workers to raise concerns through station processes or to the NRC.

Management responsibility for supporting the use of alternate avenues to pursue resolution of concerns was reinforced in the SCWE training provided to WCGS leadership.

Third, the lowest scores in the Baseline Survey brought our attention to the proper prioritization and timely and thorough resolution of issues placed in CAP. WCGS has engaged in a successful reduction in the backlog that existed in the corrective action program since the survey was conducted reaching its end of year 2013 reduction goal to be below 450 open items. Further efforts to maintain a low inventory of open CAP items continues in 2014.

As reflected in the response to Item 3 above, WCNOC has very recently instituted several improvements to strengthen its ECP function and enhance the ECPs credibility as an alternative through which to pursue resolution of concerns. The ECP Assessment suggested that the Ombudsmans many roles and responsibilities, which extended beyond ECP, could be impairing individuals confidence in the ECP. The role of Ombudsman was renamed ECP Coordinator and referrals by the ECP Coordinator to other departments for non-ECP matters were more clearly defined. This also allowed the ECP Coordinator to refocus the program on, and provide greater accessibility of the WCNOC ECP to, the supplemental workforce as well as WCNOC employees. Improvements to confidentiality protocols, and additional options for ensuring the independence of investigations, were also designed to increase transparency and reinforce to WCGS personnel that the WCNOC ECP is a viable and safe alternative for seeking resolution of concerns.

The ECP changes described above are included in the WCNOC CAP system, and have been communicated to all site personnel in a Crucial Times article dated January 22, 2014.

Enclosure 1 to WM 14-0002 Page 11 of 13 The surveys and additional focus group meetings during 2014 will help assess the effectiveness of these corrective actions and communications. WCNOC will make adjustments to its improvement efforts as dictated by the information gathered though these efforts.

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, Status of Actions Taken in Response to Item 6 A key aspect of the SCWE Training for WCGS leadership included clarification of the term chilling effect. examples of actions that can have a chilling effect. and guidance on how to avoid or mitigate a potential chilling effect. This training also provided practical approaches for managing in a way that not only avoids a chilling effect, but actively strengthens a SCWE.

In addition, as discussed in Item 3 above, WCNOC has implemented the PARB process for evaluating certain proposed employment actions affecting employees and supplemental workers to ensure such actions do not create a chilling effect. (See Personnel Action Review Board, Al 13C-003). The procedure applies to WCNOC employees and supplemental workers.

Implementation of this procedure is specifically intended to prevent retaliation and mitigate potential chilling effects associated with the covered employment actions. But over time it is also expected to enhance the ability of managers site-wide to identify potential perceptions of retaliation in other contexts and take actions to avoid or mitigate associated chilling effects.

The application of Al 1 3C-003 to certain proposed employment actions affecting supplemental workers is one of two actions directly focused on avoiding a chilling effect among the ranks of the WCNOC supplemental workforce. The second included development of a SCWE contract provision, and inclusion of such provision in new contracts and in amendments to some existing contracts (see Item 1). These new contract obligations will provide a means through which to ensure WCNOC is promptly informed of all claims of discrimination involving WCGS supplemental personnel such that it can be involved in assessing any associated chilling effect.

These contract provisions will also actively reinforce WCNOCs expectations that its contractors maintain a healthy SCWE.

With respect to the QA organization. the intensive involvement of the external consultant has helped improve communication within the QA organization. This communication has heightened management attention to actions that could be perceived to have a chilling effect and allowed prompt intervention.

Based on the ECP Self-Assessment described in the response to Item 3 above. WCNOC is enhancing the ECP to help ensure individuals are more likely to identify concerns regarding discrimination. This should assist in early assessment of potential chilling effects and timely mitigation efforts.

Enclosure 1 to WM 14-0002 Page 12 of 13 Another key change to WCNOCs ECP is the plan to reinvigorate focus groups conducted by the ECP Coordinator. These focus groups can help identify chilling effects, but can also be targeted to help WCNOC assess the effectiveness of its efforts to mitigate any potential chilling effects associated with actions taken with individuals. In addition. the effectiveness of these actions will be evaluated through the 2014 SCWE survey and focus group meetings.

Item 7 Your plans to inform the WCGS workforce including contractors, of: (i) 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.

Status of Actions Taken in Response to Item 7 As described in the 30 Day Response, WCNOC broadly communicated to the WCGS workforce regarding the issuance of the chilling effect letter and its action plan to address the SCWE issues.

In addition, WCNOC has communicated broadly to the WCGS workforce the results of the Baseline Survey, and improvements to the WCNOC ECP.

WCNOC is continuing its frequent and transparent communication approach by sharing this Six Month Response site wide. WCNOC will continue to communicate key SCWE messages and updates through the SCWE Communication Plan component of its integrated communications strategy.

Additional Actions Planned In addition to the actions identified in the 30 Day Response, WCNOC has identified other enhancements that will help strengthen its SCWE. These actions are outlined below.

First, WCNOC has updated its new employee onboarding session to include instructions on alternative avenues for raising concerns. These changes will become effective in February 2014.

Importantly. the sessions will now be scheduled to occur within weeks of the new employe&s arrival and will be taught by an independent contributor.

Second. WCNOC is updating its process for onboarding supplemental workers. This new process will include a session facilitated by a senior WCNOC leader to communicate expectations regarding five basic elements:

1. Traits of a healthy nuclear safety culture

2. Site wide fundamental behaviors and WCNOCs accountability model

3. Industrial safety and human performance

4. Avenues for reporting concerns

5. Training as core business.

Third, the Nuclear Safety Culture Monitoring Panel (NSCMP) is reviewing the timeliness and effectiveness of the corrective actions identified in the root cause analysis performed in response

Enclosure 1 to WM i400O2 Page 13 of 13 to the Letter. The NSCMP has also monitored other inputs, including the Baseline Survey results, that may indicate developing issues related to the WCNOC work environment.

The NSCMP is increasing the number of inputs it considers to evaluate work environment (e.g.

engagement/focus group meeting results, exit interview results. etc.), as well as its methodology for evaluating and reporting on those inputs to the senior leadership team. This revised approach is designed to support the senior leadership teams efforts to take a more proactive approach to cultivating a strong SCWE. The NSCMP is piloting methodologies for reporting such information in the first quarter of 2014 and plans to implement this revised approach in the second quarter of 2014 In September 2013, Mr. Matthew Sunseri. President and Chief Executive Officer of WCNOC.

announced his retirement. On January 17, 2014, WCNOC announced that Mr. Adam Helm will succeed Mr. Sunseri as President and Chief Executive Officer. This transition will occur on January 31, 2014. During this transition, Mr. Helm will be briefed on the Letter and the actions taken by WCNOC to improve its work environment. Mr. Helms views and perspectives, along with those of the senior leadership team collectively, as informed by the various inputs outlined herein, will help guide WCNOC in its development of any additional plans to strengthen its SCWE.

of WM 14-0002 SCWE Communication Plan 3 Pages

Enclosure 2 to WM 14-0002 Page 1 of 3 Communication Plan for Chilling Effects Letter Response Topic/issue:

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

. The letter describes two NRC concerns about Wolf Creeks safety-conscious work environment (SCWE)

. An initial response is due within 30 days of the letter date. A second response is due January 24, 2014.

Key messages:

V It is important that we have a strong SCWE.

V We encourage anyone working at Wolf Creek to raise issues without fear of retaliation.

V We encourage initiation of Condition Reports by anyone working Wolf at Creek.

V We communicate issues with our supervision and management team first.

V We give nuclear safety Milestones: Date:

CEL team charter developed Weekly CEL Meetings Aug. 28, 2013 (scheduled, complete)

Final date for collection of requested information for 30-day response Sept. 4, 2013 Sept. 13, 2013 Submit 30-day response to NRC Sept. 18, 2013 Submit six-month response to NRC January 24, 2014 (formerly Feb. 19, 013)

Communication type Communication vehicle Outage handbooks include SCWE information Distributed to all personnel prior to an outage Station-wide Fundamental Behaviors include SCWE Distribited to all personnel working at Wolf Creek Face-to-face commu nications to align the,,,

LeaderinrriAlinment Meetings and All-Hands Meetings Tracks 81-weekly/every six week presentations Visual reminders on SCWE Marquee messages, posters, presentations Surveys used to pulse the organization on p Monkey Activity/Key Messages/Delivery Method Contact/person Delivery Date(s) Completed Date responsible Crucial Times:

Wolf Creek supports a strong SCWE C.Bailey -

May 20, 2013 May 20,2013 i-ide e-mail:

M. Sunseri June 17, 2013 - June 12013 Chilling Effects Letter communication plan, REV. 1, page 1

Enclosure 2 to WM 14OOO2 Page2of3 Site-wide e-mail:

Site-wide message to the station about receipt of CEL with letter attached M. Sunseri g201 Crucial Times:

Message about how to initiate a Condition Report C.Bailey Aug. 27, 2013 Aug. 27,2013 Crucial Times:

and introducing Lisa Vaughn y201 29, 2013 Marquee Messages:

jsonthemfquees SCWE Cly_ Began Aug. 27,2013 Crucial Times:

Differing professional opinion procedure released J. Bronaugh Sept.

3013 3, 3013Sept. 3, 2013 Crucial Times:

Cly Spt1t2013 Crucial Times:

Maintainjpj strong safety cu Iture is key to avoiding wIfulrisconduct C. Bailey pLi1,2013 Crucial Times:

Team members insights valuable to NRC response C. Bailey Sept. 13, 3013 pt.13, 2013 Site-wide e-mail:

the station about initial response M. Sunseri Site-wide e-mail: Sept. 19, 2013 Spt. 19, 2013 Request to complete SCWE survey M. Sunseri October 2013 October2013 Crucial Times:

Personnel encouraged to complete SCWE survey J. Bronaugh Oct. 2,2013 Oct. 2, 2013 Crucial Times:

CEL implementation teams formed Oct. 8, 2013 Pc 8, 2013 Crucial Times:

C. Baiy Oct. 8, 2013 Oct. 8, 2013 Crucial Times:

Update on ECP implementation team C. Bailey Oct.24, 2013 OcL 24, 2013 Crucial Times:

reviewed Oct. 30, 2013 ._

Crucial Times:

ECP self-assessment team shines light on program health ona_ Nov. 14,2013 Nov 14, 2013 Crucial Times:

CARB approves CEL root cause .

C. Bailey Nov.20, 2013 Nov. 20, 2013 Crucial Times:

LCT kiç artiçi ants increas erstanding of SCWE ________

C,y Nov. 21, 2013 No 21, 2013 Site-wide e-mail:

tsfromrecentSçsurv Dec. 9, 2013 Dec.9, 2013 Site-wide e-mail:

communication about issuance of survey and results C. Bailey Dec. 9, 2013 Dec. 9, 2013 Chilling Effects Letter communication plan, REV. 1, page 2

Enclosure 2 to WM 14-0002 Page 3 of 3 Site-wide e-mail:

Leadership Team e-mail about ESW incident Leadership Team Training: Dec. 18, 2013 Dec. 18, 2013 Training conducted with all Leadership Team members during faIl 2013 Leadership Continuing Training D. Hendell/L. Vaughn October 2013 December2013 Focused Teambuilding:

External Facilitators p23 Site Artifacts:

Replace current safety cuitureposters witpcificinformatio_

Dec. 2013 Face to Face Communications: Week of Jan. 1, 2014 and Conduct focused group interviews to assess effectiveness of SCWE corrective actions Jan. 20, 2014. Security to S. Koenig/E. Peterson be scheduled Cascade message:

Cascade SCWE survey results through all site organizations C.j__ Dec. 9, 2013 Dec 27, 2013 Leadership Action:

Action: Review PARB procedure and affirm by January 28 ly_______ Jan. 14, 2014 Jan. 14, 2014 Crucial Times:

New P procedufe issued C. Bailey Jan. 15, 2014 Jan.15, 2014 Crucial Times:

[Ombudsman title chan Crucial Times: Jan. 21, 2014 Jan.21 2014 Wolf Creek representatives to meet with the NRC in Arlington Jan. 21, 2014 Crucial Times: Jan. 21 2014 Employee Concerns Pro provements ______

J. Bronaugh Jan. 22. 2014 Jan. 2 2014 Site-wide e-mail:

Site-wide message to the station about Six Month Response to CEL with letter attached M. Sunseri Jan. 27, 2014 Chilling Effects Letter communication plan, REV. 1, page 3