ML20199D457

Progress Toward Restart Readiness at Millstone Unit 2 - Nu Briefing for Nrc

ML20199D457
Person / Time
Site:	Millstone
Issue date:	01/08/1999
From:	NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20199D445	List: B17622, Forwards Progress Toward Restart Readiness at Millstone Unit 2 - Nu Briefing for Nrc. Rept Reflects Util Assessment of Readiness to Resume Safe Power Operations,Performance Measures & Activities Which Support Recovery of Mnps Units ML20199D457
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NUDOCS 9901200108
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Northeast Utilities Briefing

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! January 8,1999 9901200108 990108 PDR ADOCK 05000336 p PDR _

'\ Northeast khjjj$$ UtilitiesSystem

5 Northeast ""Pe Feny R (Route 156), WodorW 06385 9'

Nuclear Energy waletone Nudear Power station l

bortheast Nudear Energy Company P.o. Bcx 128 l Taterford, CT 06385-0128 l

(860) 447-1791 l Fax (860) 444-4277 I

• me Northeast Utihties System JAN - 6 1999 Docket No. 50-336 B17622 l

Annette Vietti-Cook, Secretary U. S. Nuclear Regulatory Commission Mail Stop 016H1 Washington, DC 20555 I Millstone Nuclear Power Station, Unit No. 2 Proaress Toward Restart Readiness at Millstone Station Enclosed is the seventh periodic report entitled " Progress Toward Restart Readiness at Millstone Station - Northeast Utilities Briefing for the U.S. Nuclear Regulatory Commission," dated January 8,1999. This report, provided in advance of the January 19, 1999 Commission Briefing, is a summary document which reflects Northeast Nuclear Energy Company's assessment of readiness to resume safe power operations, performance measures and continuing activities necessary to support the recovery of the Millstone units. As such, this report is a communication tool and does not expand the licensing bases of the units.

If you have any questions concerning this submittal, please contact [$e at (860) 440-0436.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY l Martin L. Bowling, Jr. .)

Recovery Officer - Technical Services I

(Kl422

• REV. 42 91

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/, _ U.S. Nucl:ar Regul: tory Commission l l B17622\Page 2 l

j Attachment l

l 1. " Progress Toward Restart Readiness at Millstone Station - Northeast Utilities l Briefing for the U.S. Regulatory Commission," dated January 5,1999.

cc: S. J. Collins, Director, Office of Nuclear Reactor Regulation H. J. Miller, Region i Administrator W. M. Dean, Director, Millstone Project Directorate  !

W. D. Lanning, Director, Millstone Inspections  !

. E. V. Imbro, Director, Millstone ICAVP inspections ]

l J. P. Durr, Chief, inspections Branch, Millstone Inspections I

(

P. S. Koltay, Branch Chief, Millstone ICAVP inspections l L. L. Wheeler, NRC Project Manager, Millstone Unit 1 i l S. Dembek, NRC Project Manager, Millstone Unit No. 2 l l D. G. Beaulieu, Senior Resident inspector, Millstone Unit 2 J. W. Andersen, NRC Project Manager, Millstone Unit 3 l A. C. Cerne, Senior Resident inspector, Millstone Unit 3 U.S. Nuclear Regulatory Commission l Attn: Document Control Desk Washington, DC 20555 l

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l. l l.. l l l l l Docket No. 50-336 - i B17622 l-i I

Attachment 1 l Millstone Nuclear Power Station, Unit No. 2

" Progress Toward Restart Readiness at Millstone Station - Northeast Utilities Briefing for the U.S. Nuclear Regulatory Commission" l-i i

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l January 1999 i

O Progress Toward Restart Readiness at Millstone Unit 2 O

January 8,1999 l

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P TABLE OF CONTENTS

1. E xec ut i ve S u m m a ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 II. Unit 2 Restart Readiness Milestones ......................................................15 lil. Performance on Unit 2 Key issues ........... ..............................................16

1. S e lf-As s e s s m e nt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

2. C o rre ctive Actio n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

3. Ope ration al R ea dines s .. . . . . .. . . . . . . . . . . . .. . ... .. .. . ... . .. . .. . . . . . . . . . . . . .. . . . . ... . . . . . . . . . 29

4. Wo rk Cont rol and Plan nin g ........... .... ...... ...................... . .... . .. ........ .. .. 4 5

5. Procedure Quality and Adherence ..................................................... 53

6. En gin e e rin g Q u ality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 IV. Startup and Power Ascension Program (Unit 2)..................................... 67 v Appendix - Key Performance Indicators Millstone Unit 2 Oversight Procedure Compliance and Quality Additional Work Control Indicators Safety Conscious Work Environment F

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1. EXECUTIVE

SUMMARY

Purpose of Briefing Book Since 1996, Northeast Utilities (NU) has addressed on a station level, as well as on a unit-specific level, the Key issues that were responsible for the decline in Millstone Station performance. Considerable progress has been made to address the programs and processes which are necessary to complete the recovery of the site.

Originally,16 Key issues were identified in order to restore Millotone Station program and process standards. In addition to the Key issues, eight affirmation criteria were developed to determine specific unit readiness for restart.

Prior to Unit 3 restart, station programs, processes and procedures to support each of the 16 Key issues were demonstrated as satisfactory to support

- operations. Most of the standard-raising and improvements undertaken to achieve this satisfactory status were made to station programs which are common to both Unit 2 and Unit 3. In this Briefing Book, the focus is on the status of Unit 2, and the information is presented for six of the Key issues and the eight restart readiness affirmation criteria which are specific to Unit 2. The remaining Key issues are satisfactory for both continued operation of Unit 3 and the restart of Unit 2. The current status for Unit 2-specific Key issues is summarized in Tables 1-1 and I-2. (It should be noted that the Key issue on Engineering Quality has been added since Unit 3 restart.)

Progress Toward Unit 2 Restart Millstone Unit 2 has remained shut down since February of 1996. The Unit is in Mode 6 (with core reload and mapping complete) and is continuing with recovery efforts for transition into Mode 5 (Reactor Vessel Head is placed) on schedule for late-January 1999.

An integrated Millstone Unit 2 recovery schedule has been developed and communicated to the Station. This schedule will govem the remaining work necessary to complete the recovery of the unit.

O Executive Summary

4 Table l- 1 Key issues Which are Satisfactory for both Unit 2 Recovery and Unit 3 Operations Keyissue Leadership Safety Conscious Work Environment Self-Assessment Corrective Action (Unit 3 only)

Nuclear Safety Assessment Board (NSAB)  !

Oversight

]

Configuration Management  ;

Regulatory Compliance Training Operator Readiness (Unit 3 only)

Work Control and Planning (Unit 3 only)

Procedure Quality and Adherence (Unit 3 only) l Emergency Planning l g Radiological Protection V Security l Environmental Compliance l

Table 1-2 Status on Applicable Unit 2-Specific Key issues l

Keyissue Status l Self-Assessment Satisfactory Corrective Action Tracking to Satisfactory Operational Readiness Tracking to Satisfactory Work Control and Planning Tracking to Satisfactory

, Procedure Quality and Adherence Tracking to Satisfactory Engineering Quality Tracking to Satisfactory l

4 h V

Executive Summary

5 l

fm NU is continuing to assure that a Safety Conscious Work Environment is V maintained. A December 9,1998 submittal to the NRC provides the basis that a Safety Conscious Work Environment has been established and sustained, and that the conditions which resulted in the imposition of the independent Third Party Oversight Program Order have been corrected. This submittal requests that the NRC rescind the Order.

NU is also continuing to fulfill the requirements of the Independent Corrective l Action Verification Program (ICAVP). Lessons learned from Unit 3 have been l incorporated in this effort.

Major work items which remain for Unit 2 restart readiness include: corrective actions on the ICAVP findings, physical modifications to the unit, corrective actions to close the NRC MC 0350 Significant items List, organizational and operational readiness for the NRC 40500 and OSTI inspections, and restoration of systems to an operational status. A January 4,1999 submittal to the NRC has confirmed readiness for the NRC 40500 inspection, which is now scheduled to start on January 18,1999.

l Unit 2 Restart Affirmation Criteria Millstone Unit 2 is basing its readiness for restart on eight objective readiness

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affirmation criteria. These criteria are the same criteria that were used to

• determine restart readiness for Unit 3.

The eight affirmation criteria for Unit 2 encompass both the unit-specific

application and the implementation of station programs which were initiated in l l order to support the resumption of safe power operations of Unit 3. These

! affirmation criteria collective!y define the recovery process for the site and the I

unit, and their attainment signifies Millstone's readiness to resume safe, reliable operations for Unit 2.

Criterion 1: Millstone Understands and Has Corrected the Root Cause of Performance Decline and Other Significant Issues Status l

Satisfactory. Millstone has identified leadership weaknesses as the root cause of performance decline. Sufficient progress has been made in attaining leadership goals-setting high standards, establishing clear expectations and accountabilities, and improving leadership skills to support Unit 2 restart.

(~'s V

j Executive Summary l

l 6

Summary of Progress s Millstone has identified the root cause of performance decline and has taken appropriate action. A number of management assessments (FCAT, ACR 7007) were conducted which identified leadership weaknesses as the fundamental cause of performance decline at Millstone. Since those assessments, Millstone and NU management have taken a number of clear and decisive steps to strengthen the leadership skills of its management personnel. Leadership skills training has been provided to the management team.

The NU leadership team has committed to high standards and has placed nuclear safety central to the conduct of operations at the site. The team has demonstrated a commitment to critical self-assessment, conservative decision-making and respect for the regulatory process. A commitment to high standards is embodied in the Station Success Objectives and the core values which govem l the conduct of operations at the site. Standards and expectations are routinely  !

reinforced through management assessments, employee awards and i communication publications.

Millstone action has resulted in strengthening the management team and improving leadership skills. Leadership Assessments were conducted in June and November 1998. The results of the assessments show that Millstone has maintained the gains in performance improvements seen in the past two n assessments. All categories scored above 5 on a scale of 1-8 indicating j " effective" performance. The overall change in scores from May 1998 to November 1998 was 5.76 to 5.84.

I j The overall results of the Culture Survey conducted in December 1998 was 12.75, which was a slight decrease from the June 1998 score of 12.99. The established goal is to achieve a Culture Survey Index of 13.00.

Millstone has continued its commitment to leadership training as a way to reinforce and improve the skills of its management. Supervisory personnel from the units and support organizations have attended training on Safety Conscious Work Environment, team building and leadership. A Vision and Values Workshop, designed to explain and obtain buy-in of Millstone personnel to the vision and mission of the company and help transition workers to an operational and business focus, has been provided to the majority of Millstone personnel. NU employees and long-term contractors are to attend this workshop by early 1999.

Millstone is in the process of transitioning the organization from recovery to operations. For nearly three years the station has been organized for recovery.

Significant time and resources were devoted to conducting discovery on the units and bringing the plants into conformance with the design and licensing bases.

The station's attention was also focused on addressing programmatic weaknesses in a number of areas.

Executive Summary

7 There are several initiatives which the station is undertaking to address transition issues and ensure that sufficient resources are allocated to operate Unit 3 safely and continue the recovery of Unit 2.

Reorganization / realignment process in making the transition from recovery to an operational site, a different type of organizational alignment is required to support safe and consistent operations. Management functions are being redefined. A new organizational alignment is also necessary due to the decision to decommission Unit 1. The new organization has been developed, critiqued by employee functional groups, and is in a phased implementation process. The first phase is to select leadership for the new organization and to start the transition from Recovery Officers and teams to permanent NU management. Selection and transition has started but the new organization is not expected to be fully implemented until after Unit 2 restart.

1

. Performance Plan. The Performance Plan was developed in July 1998 and implemented to define the Millstone Station path toward industry excellence.

The plan defines performance goals and standards which will build upon the gains achieved during the recovery and move the station toward top industry performance. The Plan includes the Vision for Millstone Station, the Mission, the Core Values, Performance Standards, and the Five Strategic Focus Areas. The Plan goais, performance objectives, and activities are addressed through the five sh regic focus areas:

. Safety

. Operating Excellence

. Work Environment

. Organizational Effectiveness

. Extemal Relations Millstone is continuing to assess leadership, regulatory and business performance and will continue to make adjustments and changes based on results and feedback from periodic leadership assessments, culture surveys and business needs.

Criterion 2: Millstone Has Restored Compliance with the Design and l Licensing Bases l Status Tracking to Satisfactory. Configuration management processes are in place.

Unit 2 will be substantially in compliance with the design and licensing bases prior to Mode 2.

Executive Summary

8 Summary of Progress The Configuration Management Program (CMP) which was established to restore compliance with the design and licensing bases is in place at Unit 2. The ,

scope of the CMP for Unit 2 has been extensive, and third-party oversight from the Independent Corrective Action Verification Program (ICAVP) Order has been l an integral component of the program. The CMP scope included 61 Maintenance Rule systems and 19 topical areas. More than 100 program areas received graded reviews. The Final Safety Analysis Report (FSAR)is also being revised to accurately reflect the Unit 2 design and licensing bases.

Programs, processes and procedures are in place to ensure continued compliance. Assessment results and reviews by Nuclear Oversight, as well as ICAVP findings were evaluated with NNECO expanding the scope of the original reviews in the applicable areas.

The Configuration Management Program will bring Unit 2's physical plant configuration and supporting documentation into conformance with the NRC approved design and licensing bases. The reviews have improved upon the l accuracy and usability of the Technical Specifications and the FSAR. l Programmatic improvements which will maintain the design and licensing bases over the operational life of the unit have been established and implemented. l The Nuclear Engineering Department has been assigned the lead responsibility l for the Configuration Management Program. This department has the s responsibility to define and coordinate the configuration control programs, and the design control processes, to ensure that plant configuration remains consistent with the design and licensing bases.

Unit 2 and support personnel have received training on configuration management consistent with their individual responsibilities.

A Unit Configuration Management Team has been established within the Nuclear Engineering Department to help ensure that design and licensing bases documents are consistent with each other and accurately reflect the plant configuration when making procedural or physical changes.

Unit 2 50.54(f) Response Status A final response to the NRC's April 16,1997 request pursuant to items 1,2, and 3 of 10 CFR 50.54(f) will be made at least 60 days prior to the anticipated restart date. Interim responses have been provided periodically. A final response to Item 4 of 10 CFR 50.54(f) is on schedule for January 1999 and describes how the Unit 2 design and licensing bases will be maintained going forward.

ICAVP Order

( Millstone Unit 2 has undergone a comprehensive review of programs, processes and systems by an independent third party and to the NRC. The ICAVP review Executive Summary

I l

9 i phase and closure of Discrepancy Reports (DRs) have been completed. To date, the confirmed DRs have been of low safety significance. The remaining action is

!(O) to complete corrective actions to confirmed DRs. The ICAVP results to date indicate that Unit 2 configuration management reviews have been effective in l identifying safety significant and design and licensing bases issues. l l As of December 18,1998 the ICAVP Contractor had closed all of the potential i DRs. Seventy-five of the confirmed DRs were Level 3 (lowest safety significance). There were 520 Level 4 (administrative) DRs. There were no confirmed Level 1 or Level 2 (high safety significance) DRs. As of January 5, l l 1999, approximately 78% of the Level 3 DR corrective action assignments I necessary to restore compliance with design and licensing bases have been i completed. Both the ICAVP contractor and the NRC have initiated inspections of l the completed corrective actions. )

NU is currently reviewing the Parsons Final Report and will be responding to the NRC on trends identified. The response is expected to be submitted by the end of January. j l

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i Criterion 3: Millstone Has Established a Safety Conscious l l Work Environment l l

!A

() Status i Satisfactory. Millstone has established a Safety Conscious Work Environment. 1 The station recognizes that maintaining a healthy Safety Conscious Work Environment is an on-going effort. )

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l Summary of Progress Millstone has established and sustained performance on the Safety Conscious i Work Environment success criteria.

i Continued monitoring of the Millstone Safety Conscious Work Environment

, reveals stable performance with some areas of slight decrease. Based on the I i

impacts of the realignment process, as well as the Unit 1 decommissioning efforts and forced outages on Unit 3, some decrease in employee morale was l

expected. l The overall Leadership Assessment score moved from 5.76 in May 1998 to 5.84 in November 1998. The November results showed improvement in all areas.

t The number of leaders rated as "less than effective" increased from four to nine, but only two were repeats from May 1998. This caused the percentage of leadership rated " effective" to decrease slightly from 98.7 to 96.6. l

'10 At a July 15,1998 public meeting, Little Harbor Consultants (LHC)

V acknowledged the significant improvement and organizational maturation that Executive Summary t

l 10 has occurred at Millstone in the SCWE area over the past two years. Of m particular note was the improvement in Human Resources (HR), which has

) regained employee trust to the point where many are now using HR to resolve issues rather than relying on the Employee Concerns Program or other avenues.

At the August 27,1998, November 24,1998 and December 14,1998 public meetings, LHC indicated that the progress made in the SCWE and the Employee Concems Program is being maintained. Both the LHC indicators and SCWE criteria remain positive, with no indication of any backsliding. LHC's third quarter performance report indicated that the status of Safety Conscious Work l Environment was judged to be at a level of performance supportive of continued operations. NRC inspections in August and October 1998 reached similar conclusions.

Data on employee concerns indicates a growing employee confidence in the ability of the Millstone ECP to provide a meaningful resolution of concerns. The number of allegations to the NRC has been declining. There have been no substantiated potential 10 CFR 50.7 concems since August 1997.

Criterion 4: Millstone Developed Effective Programs to identify and Resolve Problems Status g) Tracking to Satisfactory . Self-Assessment and Corrective Action programs are functioning effectively in maintaining high standards and have demonstrated that issues can be identified and resolved in a timely manner. Corrective actions backlogs for restart continue to be high but have been scoped and scheduled for completion.

Summary of Progress Millstone has established a healthy self-assessment culture. A high percentage

(>90%) of issues are self-identified. Survey results from the Employee Concems Oversight Panel (ECOP) and Little Harbor Consultants indicate that employees recognize the benefits of self-assessment. A recent INPO assessment and evaluation noted a strength in the Self-Assessment Program at Millstone.

However, some Nuclear Oversight audits and assessments continue to document a number of program implementation weaknesses and administrative l

inefficiencies.

The overall Corrective Action Program at Millstone has been upgraded. Key Performance Indicator data shows an improving trend in the quality of corrective l

action plans, the effectiveness of those plans in addressing concerns and the l timeliness for addressing Condition Reports. Challenges remain in reducing administrative burdens and the sometimes cumbersome nature of the process.

Revision 7 to RP4, the station controlling procedure for Corrective Actions, dated ns,/ September 15,1998, introduced several changes to make the Condition Report (CR) process more efficient.

l Executive Summary i

l 11 r

( Criterion 5: Unit 2 is Ready to Resume Operations Status Tracking to Satisfactory. Millstone recovery efforts have focused on retuming the plant to physical, operational, regulatory and organizational readiness.

Summary of Progress Unit 2 is making progress toward restart readiness.

Substantial progress has been made in raising the standards for safe and event-free operations. All Unit 2 departments are either satisfactory or tracking to satisfactory for restart.

During the recovery the materiel condition of the plant has been upgraded in a number of systems and components including:

. Main Steam Safety Inlet Pipes

. Service Water Coating Upgrades

. RCP Seals n . EDG Lube Oil Piping lV e Ventilation Dampers

. Rebuilt "A" HPSI pump

. Rebuilt "B" LPSI pump

. Replaced Rotating Element in "A" Auxiliary Feedwater pumps

. Turbine Building Batteries and Charger

. Control Room Air Conditioner Compressors

. Upgraded Motor Operated Valves l

. Overhauled 4160 Kv Breakers in addition, key testing and inspections will provide additional assurance that Unit 2 will meet its design and licensing bases. Completed significant testing and inspections include:

. Reactor Vessel Head Penetration inspection

• Emergency Diesel Generator 18-month inspections l

. Service Water Header Coating inspections l . Fire Protection Penetration Sealinspections

. Reactor Building Closed Cooling Water System flow testing

. High Head Safety injection flow balance testing D . Part 21 HGA relay inspection

. Loss of Normal Power testing l

Executive Summary l

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(' However, a significant number of corrective actions remain to support restart. A status summary is provided in Table 1-3.

Table 1-3 Restart-Related Work Data as of December 31,1998 Number Remaining Corrective Action 1385 Assignments NRC Commitments 105 Significant items List 23 (MC 0350) l License Amendment 2 I Requests Modifications 62 Maintenance Work Orders 690 O l l

Criterion 6: Millstone Station Support Organizations are Ready to Support Unit 2 Restart Progress Statement Tracking to Satisfactory. Millstone has made considerable progress in resolving the 16 station-wide Key issues. All sixteen issues were judged Satisfactory to support Unit 3 restart. The status of the six Key issues directly related to Unit 2 restart are shown in Table 1-2 and discussed in section til of the Briefing Book.

Summary of Progress Millstone has developed a program to sustain performance and continue

improvements. Three quarterly reports to the NRC documenting sustained

! performance on the Key issues for the station and Unit 3 have been submitted.

j The 1998-2000 Performance Plan contains the high level strategies which will govem our improvement activities over the next several years. Together they will i

Executive Summary

13 guide the improvement of the station from the current level of acceptable n performance towards industry excellence.

O Criterion 7: Management Control and Oversight-Assurance that Performance will be Maintained Progress Statement Satisfactory. Review and oversight measures are in place to ensure acceptable levels of safety and regulatory performance are established, sustained, and enhanced and that any declines in performance will be detected early and remediated. I Summary of Progress Management's expectations of high standards and continued improvement are I reinforced through management reviews which will ensure that future operations I are conducted in accordance with these principles. An interlocking set of assessments and management controls are functioning to set priorities, reinforce standards, and take appropriate corrective action. Some examples follow:

. The Self-Assessment Program is in place and functioning effectively to

{v') identify problems in the precursor stage so that early intervention can prevent performance decline. A station-wide self-assessment procedure consolidates the framework for conducting pre-planned, formal department self-  !

assessments.

. The Corrective Action Program has seen substantial improvement in quality and timeliness. Administrative compliance and implementation quality still need improvement.

. The Engineering Assurance Program Group assesses the performance of engineering functions with a focus on conformance to the Design Control l Program.

. Multi-discipline Management Review Teams provide Corrective Action Program oversight from a broad perspective not found in any one department.

. Nuclear Oversight provides independent assessment of management and technical program effectiveness. Daily field observations and feedback from audits and surveillances ensure that the station is operating in accordance with management expectations.

. The Nuclear Safety Assessment Board (NSAB) provides oversight of line activities and the intemalindependent oversight functions. NSAB has been strengthened with the involvement of senior NU management and the support of externalindustry experts.

O . The Independent Safety Engineering Group provides examination of unit V operating issues including applicability of industry operating experience.

Executive Summary

14 l . Plant and Station Operations Review Committees review and make n recommendations on matters related to nuclear safety. They provide the l() added benefit of reinforcing high standards and monitoring performance.

An Executive Review Board has been established to ensure that Safety l Conscious Work Environment factors are considered and incorporated into l significant personnel actions.

The Executive Training Council reviews major changes to and performance l of the Training Programs.

. A station Engineering Quality Review Board and a Unit 2 and Unit 3 Engineering Review Board have been established to raise standards and quality of engineering products. The boards provide feedback to engineering l supervisors and set or reinforce Millstone's commitment to high standards.

The Nuclear Committee of the NU Board of Trustees and the Nuclear Committee Advisory Team to the Nuclear Committee provide support and oversight of

l. nuclear issues. In addition to these management controls, external reviews and i assessments are on-going. Millstone had a number of INPO assist visits in l 1998. Assist visits and other independent external assessments will continue to be scheduled as needed.

Criterion 8: Millstone Station has a Rigorous Affirmation Process A

lu lU i

Progress Statement I

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l Tracking to Satisfactory Readiness restart will be affirmed using a rigorous l process. Nuclear Safety Assessment Board (NSAB) and Nuclear Oversight evaluations and approval will be required prior to entry into the appropriate mode.

Summary of Progress Millstone has established and is following a rigorous restart affirmation process for Unit 2. The process involves the direct participation by a number of intemal

, and extemal organizations. Within the affirmation process, there are checks and I

! balances to assure that all issues are resolved and all plant systems and

! organizations are ready to support operations prior to declaring the plant physically ready and prior to entry into Mode 2. A Startup and Power Ascension Plan was submitted to the NRC on December 22,1998 and provides the specific intemal reviews and approval, as well as power ascension hold points for NRC evaluation to take place. More detailed information on Startup and Power Ascension is provided in Section IV of this book.

f %.

l Executive Summary l

15 O- II. UNIT 2 RESTART READINESS

+

MILESTONES Millstone Unit 2 Restart Schedule Milestones Table 11.-1 provides key restart milestones and current NU milestone dates.

Table 11.-1 Milestone: -

Unit 2 Milestones; Dates &

Ready for ITPOP Order Closure 12/9/98 Complete initial Entry into Mode 6 12/31/98 Complete Ready for 40500 On-site inspection 1/4/99 Complete initial Entry into Mode 5 1/22/99 Physical Plant Readiness 2/99 Ready for ICAVP Order Closure 2/99 Initial Entry into Mode 4 2/99 4

Ready for OSTI On-site inspection 2/99 Request NRC approval to enter Mode 2 3/99 O

Performance on Key issues

I 16 1

111. PERFORMANCE ON UNIT 2 KEY ISSUES l

l Millstone has identified station Key issues which require management focus and l attention. These issues represent a combination of root causes and causal factors from previously conducted assessments and NRC inspection reports.

l

1. Self-Assessment

2. Corrective Action

, 1

3. Operational Performance l

4. Work Control and Planning

5. Procedure Quality and Adherence l

6. Engineering Quality l A summary of the status and progress on each Key Issue is contained in the pages .

l which follow, and a summary is provided in Table 1-2.

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O Performance on Key issues

l l 17 h SELF-ASSESSMENT l

l l ISSUE l l Ensure an effective self-assessment program exists to identify problems and support l continuous improvement using the Corrective Action Program.

l l 1

l STATUS l l 1

. Satisfactory l PROBLEM STATEMENT l l

l Self-assessment has not been a comerstone of Millstone work processes, resulting in the following cultural and programmatic weaknesses:

O G

+ A tolerance of performance inadequacies and low performance standards j . A failure to consistently self-identify significant issues and problems

. Weakness in preventing or mitigating the occurrence of events or human error l

performance failures

. An inability to consistently prevent event recurrence l SUCCESS CRITERIA l l Management assessments conclude, and Nuclear Oversight confirms, that effective l l self-assessment exists.

l . Self-identification Threshold-Satisfactory l Goal: Achieve greater than 90% of self-identified issues.

Current Actual: Unit 2 has consistently met the goal with respect to self-identification of Condition Reports in 1998 by self-identifying >95% of Condition l Reports.

. Self Identification Effectiveness-Satisfactory Goal: No breakthrough events and no programmatic issues identified by intemal

, and/or external oversight.

Self-Assessment l

l l 18 l Current Actual: Performance is satisfactory. Review of results and findings l x from the ICAVP inspections to date has prompted an assessment of the l l.

Configuration Management Program (CMP) as it relates to Millstone Unit 2. l Based partly on the overall low safety significance of the findings, it has concluded that the CMP is being effective in identifying and restoring items to i l compliance with the NRC approved design and licensing bases. However, l NNECO's self assessment has found the need for supplemental reviews in a limited number of areas which have now been completed.

i l

RECOVERY APPROACH l Two steps remain to be implemented to demonstrate effective implementation of an )

effective self-assessment process: '

1. Maintain a high percentage of problem identification by internal,(unit and support organizations, management, Nuclear Oversight and NSAB) rather than external sources.

2. Evaluate the effectiveness of the Self-Assessment and Human Performance programs.

! 1

O l COMPLETED ACTIONS l l lN )

1. Maintain a high percentage of problem identification by internal rather than external sources-Satisfactory

. The high number of Condition Reports (CRs) submitted demonstrates a low threshold for problem identification.

. A high percentage of Condition Reports are generated by the unit and support j organization, Nuclear Oversight, and Station management as a result of self-identification. Accordingly, the number of event driven and extemal oversight l

(excluding ICAVP) initiated Condition Reports is low.

. Human Performance Enhancement System (HPES)-HPES coordinators have been designated and trained to complete implementation of the Human Performance Enhancement System (HPES) program at Unit 2. The HPES program is currently being implemented. The three month rolling average for the percentage of low significance (precursor) errors to total human errors is slightly above the 95% goal.

l Self-Assessment l

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i l

19 l Progress Measurements l I

Success Criterion: Achieve greater than 90% of self-identified issues l Progress Indicator: Condition Report Method of Discovery-Unit 2,1998 l

Condition Report Method of Discovery Millstone 2 Progress: Progress is satisfactory.

20 %

y Data through 15%

$ 's

! ing , _ _ _ _ _ _

7 Goal s 10%

Good g

e 0%

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 98 98 98 98 98 98 98 93 98 98 98 98 l m % Extemal + Event ele % ICAVP -N-Goal l i

1

O l

Self-Assessment

20 l Success Criterion: Greater than 95% of Human errors are low significance 9 (precursor) events Progress Indicator: Human Performance Millstone Unit 2 Human Performance Millstone 2 Progress: Progress is satisfactory.

100 %

g _ _ _ _ ..

A t 90% -

w Goal 295% /

E 80% - l 0

70% - - Data GM o through I h 60%- 12/31/98 50 %

i g 40% <

30 %

Jan Ft.b Mar Apr llay Jun Jul Aug Sep Oct Nov Dec 98 98 98 98 98 98 98 98 98 98 98 98 l m% Low Signfl cance i (Precursor) Errors-Man. -4 *4 Low Significance Errors 3 Mon. Rolhng Avg -E-Goal l 1

i 1

9 Self-Assessment

21 ym 2. Evaluate the effectiveness of the self-assessment and Human Performance I t) program-Satisfactory Formal self-assessment activities have been established to include the following basic elements to continuously improve the quality of self-assessment deliverables:

. Performed assessments to verify the effectiveness of the Self-Assessment Program at Unit 2 and the station. Both assessments used industry peers and cross-unit peers. The assessments found the unit programs to be effectively implemented with only programmatic improvement items identified.

. The effectiveness of the Self-Assessment Program, including corrective actions resulting from each unit's assessment is being periodically evaluated using the

unit performance annunciator windows process. Line assessments of the self-assessment program on Unit 2 rate the self-assessment program as satisfactory to support restart of Unit 2.

l REMAINING ACTIONS l

1. Implement self-assessment goals and objectives contained in the 1998-2000 Performance Plan for each of the Strategic Focus Areas.

m Q l CONCLUSIONS l In summary, we have accomplished the following in the Self-Assessment program:

1. Implemented a comprehensive self-assessment program.

2. Developed feedback mechanisms to assess effectiveness of corrective actions resulting from self-assessment.

3. Demonstrated the ability to identify adverse trends to management Success criteria are being met. Management concludes that the Self-Assessment Program is satisfactory to support Unit 2 restart.

i i

(O V

l Self-Assessment

l l

22 lO 1

V CORRECTIVE ACTION PROGRAM

! l ISSUE l 1

Implement an effective Corrective Action Program for the Millstone Station.

l STATUS l Station processes are satisfactory to support station operations. Implementation is tracking to satisfactory to support Unit 2 restart.

l PROBLEM STATEMENT l The Corrective Action Program had been ineffective in ensuring comprehensive, timely, and effective corrective actions. The fundamental causal factors contributing to ineffective corrective actions include:

. Ineffective leadership that was unable to resolve identified deficiencies

. Low standards and expectations for station personnel

. Complex and conflicting processes, which created barriers to problem resolution and created reluctance at the worker level to identify deficiencies SUCCESS CRITERIA l Management self-assessments, confirmed by Nuclear Oversight, conclude that the Corrective Action Program implemented within Unit 2 is effective.

. Condition Reporting Threshold-Satisfactory Goal: Demonstrate that a low threshold exists for identifying conditions adverse to quality.

Current Actual: 3032 Condition Reports were initiated for Millstone Unit 2 during 1997 as compared with 1831 in 1996 and 1281 in 1995. As of December 31,1998, Unit 2 has written 3840 CRs for the year.

. Operability /Reportability Determinations-Satisfactory

, Goal: Demonstrate that conditions adverse to quality are evaluated for operability and reportability in a timely manner.

Corrective Actior.

23 1 Current Actual: During 1998, more than 99% of the Condition Reports initiated  !

were screened for operability and reportability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. l

. Condition Report Evaluation Age-Satisfactory Goal: The average length of time for Condition Report evaluation does not l indicate an adverse trend. l Current Actual: The average time to complete an evaluation has been 30 days )

or less during each month of 1998. Also, the average time has been decreasing during the last three months.

. Condition Report Evaluation Quality-Satisfactory Goal: The quality of Condition Report evaluations as graded by the Management Review Team is greater than 3 on a scale of 0 to 4.

Current Actual: Since June 1998 the quality of Corrective Action Plans for Unit 2 is has been greater than 3 on a scale of 0 to 4.

. Station Key Issues-Tracking to Satisfactory Goal: The station Key issues related to Unit 2 restart are satisfactory or tracking to satisfactory with action plans in place.

Current Actual: All Key issues are either satisfactory or tracking to satisfactory.

See Table 1-1.

. Restart Backlog-Tracking to Satisfactory O Goal: Allitems required for restart are on schadule or ahead of schedule.

Current Actual: Achievable work-off schedules have been established for all categories of activities required for Unit 2 restart. While current performance has not met the established goals, the net number of items required for restart is starting to decline at a rate such that future milestones can be reasonably achieved.

. Corrective Action Implementation-Satisfactory Goal: Complete corrective actions in accordance with the schedule established in the action plan.

Current Actual: The percent of corrective actions overdue is showing improvement with the past two quarters performance below the restart goal of 3%

. Corrective Action Effectiveness-Tracking to Satisfactory Goal: Corrective Actions are effective in resolving the issue. I Current Actual: There has been only one recurring significant condition adverse to quality in Unit 2 during 1998. MC 0350 Significant items List corrective actions representing long standing items are still being worked. The Nuclear Oversight NOVP continues to rate corrective action " yellow" or tracking-to-satisfactory based on backlogs, some implementation weaknesses, and the quality of effectiveness reviews. Management self assessments confirm these weaknesses.

Corrective Action

1 24

. Unit Organizational Readiness-Tracking to Satisfactory l(V3 l Goal: Monthly overall assessment of Unit readiness as determined by the Management Review Committee is Satisfactory.

Current Actual: The current assessment, from the monthly review, rates 10 of 12 Unit 2 departments as yellow or "Needs Improvement."

. Trending-Satisfactory Goal: Trending of Condition Report data is performed on a quarterly basis and adverse trends are identified.

Current Actual: Quarterly and monthly trend analyses are performed and adverse trends have been identified and are monitored for correction. In Unit 2, adverse trends have been identified in the areas of ASME Section XI repair and replacement plans, work scheduling and compliance, technical specification surveillance procedures, ARCOR application, confined space entry, and operational configuration management.

. Self-Assessment-Unsatisfactory Goal: The composite assessment of Corrective Action Program performance indicators is satisfactory.

Current Actual: The age of open Condition Reports, especially Level 1 ,

Condition Reports, Nuclear Oversight and management self-assessments i conclude the following areas need improvement: skills of root cause i

pV investigators, quality of documentation for completed actions, and trending at the departmental level.

j

. NRC Significant item List Closure Quality-Satisfactory Goal: Significant item List (SIL) packages submitted to the NRC are accepted without revision.

Current Actual: Fifty-four of 77 SIL packages have been submitted to the NRC.

SIL Package quality is satisfactory per the NRC Inspection Reports.

l RECOVERY APPROACH l The establishment of a structurally sound station Corrective Action Program was demonstrated as a prerequisite to Unit 3 restart. The following activities specific to Unit 2 implementation of the Corrective Action Program hava been established:

1. Establish clear responsibilities and expectations for implementing the

! corrective action program.

l 2. Effective utilization of Operating Experience by the Unit.

3. Verify the effectiveness of the Corrective Action Program in resolving issues.

o i Corrective Action l

l

25 COMPLETED ACTidNS l wi '

i. 1. Establish ciear responsibilities and expectations-Satisfactory

. Responsibilities for implementing the Corrective Action Program in Unit 2 l have been clearly communicated. These responsibilities are contained in procedure RP4, " Corrective Action Program" and Unit instructions.

. Expectations are contained in RP4," Corrective Action Program" and have been emphasized by senior management. Coaching is conducted when expectations are not being achieved.

2. Effective utilization of Operating Experience-Satisfactory

. A station procedure for the use of industry operating experience incorporating industry best practices has been implemented by Unit 2. An increase in the number of Condition Reports associated with Industry Operating Experience has been noted since implementation of the program and relevant OE issues are discussed at the moming Unit 2 Management Meeting. Effectiveness of implementation is monitored by the Nuclear Safety Engineering Group

3. Verify the effectiveness of the Corrective Action Program in meeting expectations-Satisfactory

. A proven methodology for evaluating the readiness of the Corrective Action Program as implemented in Unit 2 has been initiated. This process involves both line and Nuclear Oversight assessments of implernentation of the program. When the program reaches a condition acceptable for restart, notification of readiness for the NRC 40500 inspection will be issued.

. The most recent Nuclear Oversight semi-annual audit of the Corrective Action Program determined that the program effectively corrects identified problems.

. Multiple Nuclear Oversight Assessments have determined that the following areas require increased management attention:

- Quality of root cause investigations and effectiveness reviews

- Trending of the Corrective Action Program database at the department level

- Reducing the backlog of open action items

- Documentation of completed corrective actions and effectiveness reviews Action plans are in place to correct the deficiencies identified which apply not only to Unit 2, but to some extent across the station.

. The areas of Problem Identification and Problem Evaluation have been judged to be satisfactory. The area of Problem Resolution has been judged to need improvement based on unsatisfactory performance in reducing l] restart backlogs. The area of Corrective Action Effectiveness is judged to Corrective Action

i 26 l need improvement based on the current state of Unit Organizational j Readiness and Corrective Action Program performance.

i l

! Progress Measurements l i

l Success Criterion: The average length of time for Condition Report

! evaluation does not indicate an adverse trend l Progress indicator: Condition Report Evaluation Timeliness, Unit 2 1

i i

l Condition Report Evaluation Timeliness j Millstone 2 l Progress: Progress is satisfactory.

1 35 i 30 o = = = -

= = = -

. "' $f "*" =

Data 25 through 000d h 12/31/98 V 3 O

20

~

15 j i

10 j- .

5 0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 98 98 98 98 99 98 98 98 96 98 98 98 lm Average Age of CR Evaluations -in-Goal!

O . -

Correct!ve Action

i 27 J.

Progress Measurements l j Success Criterion: Complete Corrective Actions in Accordance with the j Schedule Established in the Action Plan i i

Progress Indicator

Overdue Corrective Actions -Unit 2 4

~

Overdue Corrective Actions

] Millstone 2

) Progress: Progress is satisfactory.

1 12%

d

) I 10%- I i

3 8% - '

Data

) 8 through E 6% - 12/31/98 j 4 l' t g l 4% -

Goal s 3%

o

?

- Jan W

Feb 98 Mar M

I Apr 98 May M

Jun M

Jul 98 Aug H

Sep M

Oct M

Nov 98 Dec 98 1

?

lm % Overdue Goal l 4

O Corrective Action

l 28 l

l REMAINING ACTIONS l

1. Implement Corrective Action Program goals and objectives contained in the 1998-2000 Performance Plan for the Strategic Focus Areas of Safety, l Operating Excellence and Work Environment.

l CONCLUSIONS l In summary, we have:

1. Established a low threshold for identifying conditions ac. erse to quality.

2. Demonstrated conditions adverse to quality are evaluated for operability /reportability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and consistently deve:op satisfactory action plans within 30 days of discovery.

3. Satisfactorily resolved problems in a timely manner, but have not made satisfactory progress in reducing the number of backlog restart issues or the age of open Level 1 Condition Reports.

4. Applied more management focus on trending and quality of implementation.

The program, process, and organization is in place to support timely and effective resolution of identified conditions adverse to quality, with a means to track, trend, and i assess performance. Effectiveness of corrective actions is being monitored based on l trending, self-assessment, the Nuclear Oversight Verification Plan, closure quality of NRC Significant items List items, and Independent Corrective Action Verification Program results. All success criteria are tracking to satisfactory for restart of Unit 2.

D k/

l Corrective Acti.on

29 O OPERATIONAL READINESS l ISSUE l Ensure operational readiness.

STATUS l Tracking to Satisfactory to support Unit 2 restart.

l PROBLEM STATEMENT ]  ;

Recovery from the current extended outage involves meeting several significant challenges. To ensure a safe return to power operations, continued management focus  !

is required in the following areas:

. Operator readiness for startup and power operations must be established. l

. High standards for unit operations must be instilled throughout the organization.

. Systems and equipment readiness for startup and power operations must be established.

. Maintain operational configuration of the plant with the design and licensing bases.

. Work backlogs must be reduced to support restart.

. Deficiencies must be reported and corrected to maintain plant materiel condition and to ensure human performance is not unnecessarily challenged.

. Plant procedures required for restart must meet appropriate industry standards to support safe unit operations.

. Restoration and subsequent compliance with the design and licensing bases.

SUCCESS CRITERIA l l

l . Operator Readiness-Tracking to Satisfactory Goals: Complete required training and qualifications for licensed and non-licensed operators.

O v

Current Actual: Training and simulator sessions are being conducted to maintain proficiency and providing operators with practice in preparation for Operational Readiness

i 30 power operation. Specific training is being given to operators on the newly installed design changes and procedures which have been revised or modified.

Goal: Raise. Operating Standards.

Current Actual: Operations Standards have been developed and implemented.

I Benchmarking is on-going and has resulted in the incorporation of "best

! practices"in a number of areas including work observations and pre-job briefs.

Expectations for Operations Department pre-job briefs, Work Observation i

Program, and Nuclear Safety and Reactivity Management Standards have been issued. Unit 2 procedures are being upgraded to reflect plant modifications.

Goal: A low number of near miss and breakthrough events.

Current Actual: The Human Performance Indicator has been satisfactory for restart since September 1998. Initiatives have been instituted to reduce the number of tagging and mis-positioning events that occurred during the second quarter.

. Equipment / Systems-Tracking to Satisfactory Goal: Develop post-restart Backlog Management Plan.

Current Actual: A Backlog Management Plan similar to that implemented on Unit 3, which addresses the deferred items identified under 10 CFR 50.54 (f)

Question 2 (April 16,1998) including corrective actions resulting from discrepancies identified by the ICAVP process (August 24,1998 Order), was submitted on December 22,1998.

O Goal: Reduce operator workarounds, temporary modifications and control room deficiencies to less than or equal to 10 in each category.

Current Actual: The number of operator workarounds is currently 16, with control room deficiencies at 36, of which 7 are awaiting plant conditions for i retest. There are currently 18 temporary modifications of which 6 are required for outage support.

Goal: System readiness reviews are completed.

Current Actual: A total of 52 Engineered Safety Feature (ESF) and Maintenance Rule systems are proposed for detailed system readiness reviews prior to restart. Walkdowns and documentation assessments have been completed on those systems. The results will be presented to management for review as part of the Mode Change Assessment process prior to the applicable mode changes. Based on this management review, additional systems may be selected for inclusion in the readiness review population. The Mode Change Assessment receives a PORC review as part of this process. Physical plant readiness is expected by February 1999.

. Organizational Readiness-Tracking to Satisfactory Goal: Unit 2 Operations Department assessment " windows" are green indicating satisfactory for restart. Nuclear Oversight rates Operations as satisfactory.

i Operational Readiness

31 Current Actual: The third quarter windows assessment has rated Operations as O tracking to satisfactory. The latest Nuclear Oversight Verification Plan (NOVP) rates Unit 2 Operations as tracking to satisfactory.

Goal: Unit 2 leadership training is completed. ~

Cunent Actual: Managers at Unit 2 have completed Leadership training including:

. Enlightened Leadership Forum for Unit 2 first-line managers and supervisors

. Safety Conscious Work Environment courses and seminars

. Vision and Values workshops for line and staff employees Goal: Nuclear Oversight NOVP windows for Unit 2 operations are " green" indicating satisfactory for restart.

Current Actual: The most recent NOVP windows assessment, dated December l

8,1998, has rated Operations as satisfactory, and Work Control and Engineering as tracking to satisfactory.

. Regulatory Readiness-Tracking to Satisfactory l Goal: Complete NRC restart-required open items in a timely, high quality manner.

Current Actual: Regulatory product quality is generally satisfactory. Timeliness continues to be a challenge and is receiving increased management attention.

l l RECOVERY APPROACH. l 1 Six steps to achieving operational readiness at Millstone have been identified:

1. Establish and instillincreased management standards and expectations.  ;

2. Confirm operator readiness to support the conduct of safe operations.

3. Conduct necessary training.

4. Revise manuals and procedures to ensure that the plant configuration l will be maintained in accordance with the design and licensing bases.

5. Establish system readiness.

6. Maintain appropriate backlogs post-restart.

7. Restore and maintain compliance with the design and licensing bases.

l COMPLETED ACTIONS l l

l p 1. Establish and instillincreased management standards and expectations- .'

V Tracking to Satisfactory Operational Readiness

l 32 The Unit's Annunciator Windows Program was fully developed and implemented as of the second quarter of 1997. The windows are currently (V3 produced and reviewed by management on a quarterly basis.

! . The Unit's Annunciator Windows Program incorporates attributes from the l Operational Readiness Plan (ORP) associated with the upcoming OSTI inspection and the NRC MC 0350 list.

. Work stand downs have been used to reinforce management expectations.

A recent stand down consisting of three half-day sessions was attended by over 230 unit and support personnel. The stand down was produced and conducted by working level experts in such areas as safety, human performance, procedure compliance, tagging, and confined space entry.

Improved performance was noted as a result of these sessions.

. Training observation programs have been developed and implemented.

. A comprehensive se!f-assessment program has been established and implemented.

. Expectations have been established and formalized in areas necessary to support high standards of operations. Areas include pre-job briefs, alarm response, and communications.

. Reactivity management expectations, standards, and practices have been formalized.

O . Extensive benchmarking in appropriate areas has been conducted.

V . A detailed work observation program in the operations area has been developed and is being implemented to measure performance against established expectations. This process is used in conjunction with the Annunciator Windows Program.

. The Operational Readiness Plan (ORP). The revision to the ORP was docketed with the NRC on November 18,1998. The revision recognizes and drives restart performance in accordance with the Unit's Annunciator Windows Program.

2. Confirm Operator Readiness to support the conduct of safe operations-Satisfactory Unit 2 Operations committed to raising standards and improving performance.

Results are evidenced by positive feedback from various inspections, peer evaluations, and assist visits.

Operations Standards were implemented in January 1998, covering peer checking, announcing starts of electricalloads, and control board monitoring. Follow-on self l assessments will be used to demonstrate progress in these and other areas.

l . Unit 2 Operations has established expectations for the conduct of pre-job briefings. A pre-job briefing work observation form reinforces these

' expectations, and a checklist and a laminated badge are also regularly used Operational Readiness

l 33 by Operations personnel. When appropriate, multi-discipline pre-job briefings are conducted to ensure all personnel understand responsibilities.

V .

Unit 2 Operations implemented a new work observation program in December 1996, and performed greater than 100 work observations per month through the end of November 1998. This program involved the use of approximately 40 different work observation forms covering rnost activities performed by Operations. Areas where emphasis has been placed include procedure use, pre-job briefings, shift tumover briefings, tagging, self checking, and housekeeping. This program was identified as an INPO strength in September 1997.

. Human Performance trends have been positive in Unit 2 Operations for 1998.

Tagging issues and configuration control mispositioning continues to receive management focus.

. Unit 2 Operations has implemented a number of initiatives to reduce the number of tagging errors and mispositionings such as:

- Requiring observable self-checking skills.

- Training on workplace factors such as task interruption that can contribute to personnel error if not compensated by a conscious effort to focus on the activity at hand.

- Peer checking on critical activities to ensure proper performance.

- Monitoring and trending of adverse conditions. Also, trends are

(<(] discussed with crews during briefings and training.

. Reactivity Management: Millstone Station has developed and implemented two higher tier documents that provide expectations for Reactivity Management.

- Nuclear Safety Standards and Expectations Manual - implemented in May 1997, setting the corporate standed that nuclear safety is the top priority.

- Reactivity Management Program Manual - sets the standards for the relationship between reactor engineering and the operating crews, implemented in October 1997. The manual provides: 1) a standard for the controls during reactivity manipulations,2) involvement in investigations of reactivity incidents, and 3) a definition of a reactivity incident. The Reactivity Management Program Manual expands on the policy statement of the Nuclear Safety Standards and Expectations Manual to develop a programmatic approach to reactivity management.

- Additionally, Unit 2 Operations has developed 5 different work l observation forms that delineate expectations related to reactivity management for various operational modes. An Operations Standard q has been implemented which also discusses expectations. The Q

recommendations in SOER 96-01 and SOER 96-02 have been discussed extensively in requalification training.

Operational Readiness

34 l . Expectations for conservative decision making have been discussed in detail

,V n in requalification training. They are also reinforced during work activities and in training. A Work Observation form provides expectations in the following j areas: Leadership, Team Decision Making, Communication, Situational l Awareness, Conservative Decision Making and Questioning Attitude. Shift )

l Managers and the Assistant Operations Manager have been evaluating these i expectations during training sessions.

1 Benchmarking: Operations personnel have taken benchmarking trips to a number of plants in the last year including North Anna, Surry, Calvert Cliffs, Comanche Peak, Arkansas Nuclear One and San Onofre Nuclear Generating Station. A number of good practices were brought back and implemented to include: work observations, peer checking, electronic Shift Manager's Log, and pre-job briefing criteria.

. Readiness for Restart Activities: A self assessment was performed to i determine the status of restart preparation activities. The assessment covered the following topics:

- Operations ownership of the task of preparing for restart.

- Revision and preparation of restart related procedures.

- Planning and scheduling required surveillances associated with plant l restart. I

- Operator walk down of various systems to ensure system readiness.

V - Operator training needs.

. Identification of required Operations wor ~k control activities such as retests or leak mitigation teams.

3. Conduct necessary training-Tracking to Satisfactory  ;

Various training and simulator sessions have been and will be used to maintain proficiency and have provided operators with practice in preparation for power operation. A partiallist of topics is provided below.

. Shutdown operations, plant heatup, plant startup, RCS draindown/mid-loop operations, feedwater and turbine controls, controllers and instrument failures.

. Similar training for reactor startup and plant startup will be provided for the general Licensed Operator Requalification Training (LORT) population as well as for the specifically identified crews for this startup task.

. Emergency Operating Procedure (EOP) Training.

i . Loss of Electrical Abnormal Operating Procedures (AOPs) (AC and DC).

i

. Training performed for revisions to EOPs, AOPs, and significant revisions to normal Operating Procedures.

IO . Training provided on changes to Technical Specifications.

Operational Readiness

1 35

. Man-Machine Interface (MMI) introduction training.

. Specific aspects of SOER 96-01 and 96-02.

. Plant Modifications.

A " Plant Experience Review" classroom session is presented each cycle in addition to other training department presentations on other significant events.

. Administrative topics such as reportability determinations and probabilistic risk assessment in work planning.

. Systems training focused on those systems critical to plant restart and safe operation.

. Configuration Management and FSAR overview.

. The plant-referenced simulator has been maintained up to date with regard to plant modifications.

. Severe Accident Management Guideline (SAMG) training has been completed.

4. Revise manuals and procedures to ensure that the plant configuration will be maintained in accordance with the design and licensing bases-Tracking to Satisfactory All Unit 2 Departments are supporting efforts to ensure procedures accurnfely reflect the plant modifications and the design and licensing bases restoration. The following list relates to Operations-specific manuals and procedures:

. Procedure revision in support of plant modifications: Procedures are being revised as plant modifications are completed in accordance with station design control procedures.

. Restart-related orocedures: Approximately 2025 procedure revisions and changes supporting restart have been completed in 1998. A performance indicator, Restart Required Procedure Revision Backlog, is tracking progress toward completion.

. Readiness-for-restart reviews for startuo and heatuo procedures: Unit 2 Operations crews have been assigned specific procedures to review. The unit simulator is being used during these reviews. Plant heatup and cooldown and plant startup procedures are examples of where this has occurred.

. Start-uo related procedures: " Required for start-up" procedure technical deficiencies are being tracked in the Unit 2 Restart Readiness key performance indicators.

. Procedures in Do-Not-Use Status: The "Do-Not-Use" status is an administrative mechanism that is used, as committed to by NNECO in a letter

( to the NRC Staff dated October 1,1993, to place procedures in an inactive status while reviews or technical upgrades are being conducted. As of Operational Readiness

36 December 31,1998, there are 106 procedures in "Do-Not-Use."

Approximately 20 of these procedures are to be canceled. Approximately 31

~l of these procedures are not needed until the next unit refueling outage. The i

remaining 55 procedures are scheduled for revision prior to unit startup based on their functional use or mode applicability.

. Abnormal Operatino Procedures (AOPs): Twenty-eight new AOPs have been written to cover loss of vital and non-vital electrical buses or panels. Sixteen Loss of AC Electrical Bus AOPs have been completed, and 12 Loss of DC Bus procedures have been completed. Seventeen previously existing AOPs have also been revised.

. Appendix R AOPs: Twenty-four existing AOPs and four new AOPs are being revised or written to comply with Revision 3 of the Unit 2 Appendix R Compliance Report that is scheduled to be issued in early 1999. These AOPs will be effective prior to unit restart.

. In Service Test (IST) Procedures: These procedures are being upgraded to remove Operator Workarounds related to performance of IST procedures and to improve system configuration management. The majority of the Engineering Department IST procedures are being revised to become Operations Department procedures. The IST procedures will be revised to j the latest standards and requirements. Thirty-five IST Mode 6 procedures l have been identified, completed and approved.

. Emeroency Operatina Procedures (EOPs) Fifteen EOPs are being revised to incorporate data developed during a Unit 2 EOP Branching Study, FSAR Chapter 14 re-analysis, and plant design modifications. The remaining i procedure areas referenced from the EOPs have been verified accurate for EOP purposes. These EOPs have completed verification and validation. i Comments from the Operator training classes will be incorporated prior to final approval, which is scheduled for prior to Mode 4.

. Operations Department Administrative Procedures: The set of Operations Department instructions was revised to ensure that they were current and accurately reflect management expectations. Unit 2 Operations has also implemented a document set referred to as Operations Standards. In addition to the Work Observation program and the Operations Department instructions, Operations Standards provides management expectations in a number of areas such as reactivity management.

. Conduct of Operations Procedure: This procedure has been revised it now includes expectations derived from SOER 96-01 recommendations. It provides new guidance on needed training when the majority of a crew's nucleus changes. Many sections also cross reference work observations that provide real time reinforcement of management expectations, i

5. Establish system readiness-Tracking to Satisfactory 3

(V . A detailed plan for restoration of plant systems required for restart has been established Operational Readiness

._ = - - - _ _ _ _ .. - . - . . = - . --- .

37

. Modifications required to restore the design and licensing bases have been detemiined. A detailed implementation plan has been developed.

lO' l

. Plans to achieve goals for operator work arounds, control room deficiencies, and temporary modifications prior to restart have been developed.

i

6. Maintain appropriate backlogs post-restart-Tracking to Satisfactory i . The post restart Backlog Management Plan has been developed based on the  ;

Millstone 3 methodology and was submitted to the NRC on December 22,1998.

7. Restore and maintain compliance with the design and licensing bases- I Tracking to Satisfactory I i

. See discussion in the Executive Summary.

<O Operational Readiness

1

! 38 i

iO

l Progress Measurements l

1

! Success Criterion: Human Performance Indicator shows a low percentage of near miss and breakthrough events

! Progress Indicator: Unit 2, Human Performance

}

{ Human Performance j Millstone 2 i Progress: Progress is satisfactory.

I 100 % l 90%- Goal 2 95% A

! GW h 70*4 - Data i 5 through 60% - 12/31/98 50% .

1-O #

30 %

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 98 M 98 98 98 98 M 98 98 98  % 98 lM% Low Signitcance (Precursor) Enors-Mon. -ill--% Low Sigruficance Errors-3 Mon. Rolling Avg. Goal l O

Operational Readiness

i

! 39 l

1 l Success Criterion: Procedure Backlogs are reduced i

j Progress Indicator: Procedures Required for Restart Status

! Restart Required Procedure Revision Backlog l Millstone 2 i Progress: Progress is tracking to satisfactory.

1400 12 %

Data through 12/31/98 l

4 Jan 98 Feb 98 Mar D8 IfilTim' Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 (MTotal Mods and PUP Remaining --5-Month End Goal l Oct 98 Nov 98 Dec 98 O

Operational Readiness

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

40 O Progress Measurements l Success Criterion: Reduce Operator Workarounds, Temporary Modifications and Control Room Deficiencies Progress Indicator: Unit 2, Temporary Modifications Temporary Modifications Millstone 2 Progress: Progress is tracking to satisfactory.

35 o ..

O Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 98 98 98 98 98 98 98 98 98 98 98 98 lMTemp Mods 5151BOutage Suppon -e-WorkOff/ Goal  :

Goal l 1

I l

4 O

Operational Readiness

i; 41 1

i iO i

Progress Measurements l i

! Success Criterion: Reduce Operator Workarounds, Temporary i Modifications and Control Room Deficiencies 1

i j Progress Indicator: Unit 2, Operator Workarounds I

i Operator Work Arounds ,

Millstone 2  !

Progress: Progress is tracking to satisfactory. j a I 40 35 Data through )

12/28/98 l 25 GOOD i 1 20 v y l P 1 l

j Jan 98 Feb 98 Mar 98 Apr 98 May 99 HiiTfi Jun f3 Jul 98 Aug 98 Sep 98

[mW/As > 6 Mos. Old mW. As < 6 Mos. Old -m-Work Off to Goal + Goal j Oct 98 Nov 98 Dec 98 i

i i

1 i

O i Operational Readiness

42 I

j!

j l Progress Measurements l

}

q Success Criterion: Reduce Operator Workarounds and Control Room

Deficiencies i

1 1

Progress Indicator: Unit 2, Control Room and Annunciator  !

! Deficiencies 1 l Control Room and Annunciator Deficiencies l Millstone 2 i l Progress: Progress is tracking to satisfactory.

1 so l

! Data through j l 50 Goal s to at 12/28/98

. p- g Good o l l I l t l l j Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

98 98 98 98 98 98 98 98 98 98 98 98

{ lm Waiting Solution M Awaiting Retest -mH-Work Off/ Goat Goalj i

i l

i i

i i

i i

i i

O Operational Readiness

43 l

REMAINING ACTIONS l

1. Establish and instill increased management standards and expectations.

. Continue reinforcement of management expectations through developed processes. Continue management and first line supervisor meetings to ,

reinforce expectations, ensure accountabilities, and update progress towards restart.

. Corrective Action Plans to restore unsatisfactory department-level windows in the Unit Annunciator Windows Program to a restart-ready status will be reviewed more frequently as restart approaches. l

2. Confirm Operator Readiness to support the conduct of safe operations.  ;

e No remaining activities.

3. Conduct necessary training.

1

. Plans are underway to refine training for supervisors, managers, and directors. Safety Conscious Work Environment (SCWE) Refresher Training and stronger definition through a new Leadership Development Program are q part of the training programs under development.

V e Licensed operators, non-licensed operators, and shift technical advisors will continue to receive training either formally in the classroom and/or simulator ,

setting, briefings, or required reading (as appropriate) on significant plant I modifications, Technical Specifications and procedure changes as they are I completed.

4. Revise manuals and procedures to ensure that the plant configuration will be maintained in accordance with the design and licensing bases.

. Complete procedure revisions required for plant startup. Two performance indicators have been developed (Procedure Upgrade Project Status and Restart Required Procedure Revision Backlog) to track and communicate progress in this area.

5. Establish system readiness.

. Complete the remaining 59 restart modifications

. Complete review of Unit 1 System Readiness Reviews required to support Unit 2.

l . Complete remaining restart required System Readiness Reviews.

l 2

Operational Readiness

44 l 6. Maintain appropriate backlogs post-restart.

OV .

Implement Backlog Management Plan upon entry into Mode 2.

7. Restore and maintain compliance with the design and licensing bases.

. Complete remainder of the ICAVP open items required for restart, and NRC restart commitments.

l CONCLUSIONS l Overall, Unit 2 readiness for restart is tracking to satisfactory for restart, with some areas for improvement noted. Management and leadership training has improved organizational performance and contributed to an improved culture at Unit 2. Standards have been raised and management expectations have been '

communicated to the organization. Expectations for Operator readiness for restart and power operations are being met. Operations standards have been established and are being implemented. Operator classroom training, simulator training, self-checking, benchmarking, and plant experience review classroom sessions are ongoing.

Areas which are receiving continued management attention are: )

. Reinforcement of management expectations

• Restoration of areas where department performance is unsatisfactory

. Schedule adherence to achieve physical and regulatory readiness t

Operational Readiness

l l

45 O

WORK CONTROL AND PLANNING 4

llSSUE l Ensure the effectiveness of the Millstone Work Control and Planning processes.

l STATUS . l Station programs, processes and procedures are satisfactory to support operations.

Implementation is Tracking to Satisfactory to support Unit 2 restart. I l

PROBLEM STATEMENT l Significant, long standing work management weaknesses were contributing to '

unplanned reductions in defense-in-depth, removal of important safety equipment from n service that is not ready to work, ineffective use of resources, and untimely resolution of lQ problems. Contributing causal factors include: ..

. Failure of management to establish clear expectations and direction to achieve high standards in the selection, planning, scheduling and control of work.

• Failure to implement processes reflective of the industry's best practices.

. Tolerance of substandard performance and lack of accountability for work not completed on schedule.

. Ineffective methods and performance indicators were used to monitor the progress of work and to assess the overall work management process.

I SUCCESS CRITERIA l l

A direct measure of the effectiveness of work control and planning will be provided using the following criteria. The status listed is for Unit 2 l

. Reduction of the backlog of system and equipment deficiencies consistent with Industry standards-Unsatisfactory Goal: To reduce the Restart Backlog to zero and the on-line Corrective

(' Maintenance (CM) Backlog to less than 500 Work Orders , with no more than 350 being PRA risk significant.

Work Control and Planning I

46 Current Actual: Unit 2 currently has a Restart Backlog of 690 Work Orders l^-

and is near the goal of 500 total on-line CM Work Orders with less than 350 that are risk significant. Prior to restart, the on-line backlog will undergo a comprehensive review to ensure that, when viewed in the aggregate, the backlog does not compromise defense in depth or overall plant safety.

. Completion of preventive maintenance and surveillance activities as scheduled-Satisfactory Goal: Overdue Preventative Maintenance (PM) tasks will be reduced to zero, with surveillance test completion rates at goal.

Current Actual: The goal of zero overdue PMs was achieved the week of 12/21/98. At this writing, two PMs are overdue, with the work being restrained by plant conditions. These two PMs are scheduled for completion during the week ending 1/10/99. Surveillance performance is meeting the I goal of 90% completed prior to entering their 25% grace period.

. Institution of an on-line work management process resulting in a schedule adherence rate consistent with industry standards-Tracking to Satisfactory Goal: To start more than 75% of all scheduled work on time using the on-line work control process.

Current Actual: The on-line Work Management program is the process being developed and proceduralized on Unit 2. P3 has replaced P2 as the

(]

\

primary scheduling program, positions have been staffed and Functional Equipment Group (FEG) development and integration is in progress. A transition to the on-line Work Management process will be made on March 1, 1999.

l RECOVERY APPROACH l Six (6) focus areas are identified to achieve an effective work control process:

1. Provide clear direction to the work force relative to management's expectations on work control and planning. Develop means to establish accountabilities of individuals and work groups.

2. Implement a work week management process consistent with industry leaders.

3. Establish " Work it Now" teams to respond to emergent issues and deficiencies which do not require detailed planning.

4. Revise the work control practices to upgrade standards and simplify processes. Provide training to personnel.

5. Engage in both internal and external benchmarking to achieve and retain an awareness of best practices.

6. Institute clear and simple methods of monitoring performance of the work

( management process, and raise performance to an acceptable level.

Work Control and Planning

l 47  !

COMPLETED ACTIONS l O 1. Provide clear direction to the work force relative to management's  !

)

expectations on work control and planning. Develop means to establish I accountabilities of individuals and work groups-Satisfactory

. Schedule-discipline meetings have been established at Unit 2 which focus the work force on schedule compliance and raise the level of accountability for schedule adherence while requiring job supervisors to work safely and maintain l high standards of quality.

Planning meetings nave been instituted with the workgroups to provide a forum l

for advance buy in of the work to be performed.

2. Implement a work week management process consistent with industry leaders-Tracking to Satisfactory

. The Unit Coordinator / Work Control Supervisor has been established to maintain oversight of the work control process.

Outage Coordinators / Work Week Managers have been established to manage the planning and execution of work.

. A single schedule now controls all physical work at the unit.

. A standard method for screening, prioritizing, and assigning new work has been

• developed and implemented, including a process for emergent work.

. A template 12-week rolling schedule based on work levelization and PRA risk significance will be implemented on March 1,1999.

3. Establish " Work it Now" teams to respond to emergent issues and deficiencies which do not require detailed planning-Satisfactory l Each unit now has a team in place which has dramatically improved response to emergent issues allowing the remaining work force to focus on the completion of scheduled items. Since its inception, the " Work it Now" teams have completed 9068 jobs as of December 15,1998, while demonstrating good workmanship and not causing any challenges to plant operations.

4. Revise the work control practices to upgrade standards and simplify processes. Provide training to personnel-Satisfactory

. Work package quality has improved, as determined by recently completed self assessments and evaluations conducted by Nuclear Oversight and INPO.

. Work control procedures have been upgraded, and initial training was completed f) in the second quarter of 1997.

J

. P3 interactive scheduling process has been implemented Work Control and Planning

48 The Passport work management system has been adopted for the track.ng rm and control of surveillance testing. This system streamlines the process and

'( reduces the chance of introducing human error. It's now in production on Unit 1, and is on schedule to be implemented on Unit 2 by June 1999.

5. Engage in both internal and external benchmarking to achieve and retain an awareness of best practices-Satisfactory

. Work control managers meet routinely to exchange information and plan ,

improvements, l

. A job exchange program has been instituted in which employees trade places with a counterpart in another utility for the purpose of exchanging process and cultural lessons.

. Over 100 trips have been completed by Millstone employees to other nuclear l stations, with a similar number of peers traveling to Millstone for the purpose of i leaming best practices. The units also remain active with industry groups and I associations. j

6. Institute clear and simple methods of monitoring performance of the worh management process and raise perf ormance to an acceptable level-Satisfactory

!g The following Key Performance Indicators (KPis) have been developed to monitor Q

performance in the area of surveillance testing, preventive maintenance, and backlog in accordance with our success objectives.

Additionally, reports and KPls have been developed which will monitor the evolution of work from time of scope freeze throughout to work execution.

1 Work Control and Planning

49 l

l Progress Measurements l 1

i Success Criterion: Reduction of the Backlog of System and Equipment Deficiencies Consistent with Industry i

Standards Progress indicator: Unit 2, Restart Backlog Start-up Work Order Status ,

Millstone 2 j

! Progress: Performance is unsatisfactory.

1200 - -

, Data through i 1000- 12/28/98

) 800-Good 400 - 4: If -- c. I 'l. I '

Y

, ?f

~

t.I ',; Jr. ')

200 - }g y .> .

l{. f~j: .Ir .

g, j { p:. .

Apr May Jun Jul Aug Sep Oct Nov Coc Jan Feb Mar 98 98 98 98 98 98 98 98 90 99 99 99 lBERBStart-up AWOs (Protects Subset) MStart-up AWOs + Work Ott/ Goal l l

l l

O Work Control and Planning i

l 1

i 50 i

i Success Criterion: Reduction of the Backlog of System and  !

% Equipment Deficiencies Consistent with industry

] Standards

] Progress indicator: Unit 2, On-Line Backlog i

i

1

On-Line Work Order Status

{ Millstone 2 l Progress: Progress is tracking to satisfactory.

i W

l

$ 500 - WBW_

Goal (total) s 500 Data through l 400 - 12/28/98

~

4 I

i o 300-O I I I I I i i i I I I Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 98 98 98 98 98 98 98 98 98 98 98 98 l m On-Line CM AWOs Total -e-Gehl-On-Line CM AWOs l O

Work Control and Planning

51 Success Criterion: Completion of Preventive Maintenance and 4 Surveillance Activities as Scheduled Progress Indicator: Unit 2, Overdue Preventive Maintenance Overdue Preventive Maintenance AWOs Millstone 2 Progress: Progress is satisfactory 70 61 60

1. 8 g 50 -

2 0 32 29 Good o 30 - 24 l

20 16 2

0 2 2 3 2 1

0 " " " - "

!%q

. e s a i =  ;

a  ;  ; -

9 s a

/

lmOverdue PM AWOsl l

Work Control and Planning

I l

52 l REMAINING ACTIONS l

1. Implement a work week management process consistent with industry leaders. l When the process is implemented, monitor the effectiveness of this process to ensure the goal of 75% schedule performance is met .

2. Implement sustaining performance program. j

. Implement a sustaining performance program based on the Unit 3 model since Work Control organizations will be merged following the restart of Unit 2.

l CONCLUSIONS l

1. Overall assessment of Work Control and Planning is tracking to satisfactory.

2. Progress on restart work orders is unsatisfactory.

3. Goals for on-line Corrective Maintenance backlog is tracking to satisfactory and performance of surveillances and preventive maintenance are being met.

The development of an on-line Work Management Program (12 Week Rolling Schedule) is in process and on track to support transition to this method of operation at g the Physically Ready for Restart milestone.

Restart work orders are scheduled for completion prior to startup and schedule adherence is improving steadily as evidenced by the recent completion of Facility 5 work window significantly ahead of schedule and completion of Facility 2 work window and entry into Mode 6 as originally scheduled.

O Work Control and Planning

53 O PROCEDURE QUALITY AND ADHERENCE 4

ISSUE l Effectiveness of Millstone Unit 2 Technical Procedure Quality and Adherence.

I STATUS l Station programmatic controls are satisfac'ory to support operation.

Implementation is tracking to satisfactory to support Unit 2 restart.

l PROBLEM STATEMENT l Procedure quality and adherence have been long-standing and well documented l concems.

l SUCCESS CRITERIA l

. Procedure Deficiencies Required for Restart are Resolved-Tracking to l Satisfactory l Goal: No backlogs exist for critical operational and technical procedure revisions, upgrades and reviews.

Current Actual: Progress is tracking to satisfactory.

. Procedure Backlog - 565 procedure modifications remain for restart 4 . Procedure Upgrade Program (PUP) has 11 procedures remaining for Unit 2 i . Procedure Quality for New and Revised Technical Procedures Acceptable-Satisfactory Goal: A goal of 5 or fewer Condition Reports (CRs) per month for Unit 2.

Unit 2 Current Actual: Unit 2 has had fewer than 5 CRs per month

, attributed to unacceptable procedure quality over the last 3 months.

. Instances of Not Adhering to Procedures are Reduced to an Acceptable Level-Satisfactory Goal: 0.5 total non-compliance errors per 1000 man hours.

'O Procedure Quality and Adherence

54

f-] Unit 2 Current Actual

As indicated by the Unit 2 Procedure Compliance Q KPI, Unit 2 has met its goal for the past five months. As of December 1998, total non-compliance errors /1000 hours was 0.43 for Unit 2.

l RECOVERY APPROACH l

Four (4) steps to recover the procedure quality and adherence at Millstone Station have been identified:

' 1

1. Enhance Technical Procedure Quality

2. Reinforce the Requirements for Procedure Adherence

3. Improve Procedure Adherence

4. Monitor Progress l COMPLETED ACTIONS l l

1. Enhance Technical Procedure Quality-Tracking to Satisfactory Significant enhancements to procedure development processes and the p upgrade of technical procedures have been made. Performance indicators

() have been developed and implemented. Details of completed actions are provided below:

. Verification and Validation Procedures-revised and substantially improved using industry benchmarks.

. Document Structure-has been simplified to eliminate one layer of documentation - the Nuclear Group Procedures. All Nuclear Group Procedures are now Millstone-specific and these procedures are either being eliminated or converted into Station Administrative Procedures.

Millstone is currently implementing the Master Manuals Program for common station processes.

. Technical Procedures-the majority have been upgraded, and as of December 1998 the status is as follows:

- Unit 2 has upgraded 1246 of 1257 procedures

- Support Groups have upgraded 776 of 777 procedures (the one remaining will be cancelled)

. Station Qualified Reviewer (SQR) Program- developed and implemented the SOR Program which provides departments with authority to approve new, changed or revised technical procedures or programs in f3 lieu of PORC/SORC review and approval, if a Safety Evaluation is NOT V required as allowed by Unit Technical Specifications. This reduces the Procedure Quality and Adherence

55 m administra..ve burden on PORC and SOr.0 a review large numbers of

) procedures and allows committees tc, focas on safety significant issues. A self-assessment of the SOR Program conciuded that in general the SOR i

l l

Program is being successfully implemented. As of August 1998, all SOR l Precedure Screeners were required to comp. eta new Training l O'ulification Records (TOR) for 50.50 Safety Sa!uations and Screenings. i l

• Unit 2 EOP Revision-Currently 14 EOPs are being revised to 4 ir. corporate data developed during a Unit 2 EOP Branching study. This study reviewed references to other procedures. A new EOP was developed yhich contains attachments for many of the previously i referenced areas. The remaining procedure areas referenced from the EOPs are being verified accurate for EOP purposes. It clearly identifies in each procedure that certain steps are used for EOP purposes.

• Unit 2 Abnormal Operating Procedures (AOPs). Twelve new AOPs have been written to cover loss of vital and non-vital electrical buses or panels. Eight (8) previously existing AOPs have also been revised.

2. Reinforce the Requirements for Procedure Adherence-Satisfactory DC 4, Procedural Compliance, was revised to document and communicate management's expectation for procedure adherence. A Special Procedure

] (SPROC) was approved to facilitate the communication and roll-out of DC 4 via pilot programs in a number of departments. DC 4 has been modified to include station feedback and enhancements since October 1997.

Continuous monitoring is performed by the line and oversight organizations to identify any areas that might look like they may be trending in the wrong direction. Unit 2 has implemented department specific KPis for Procedure Adherence and Lessons Learned are shared with the Units as applicable.

l t

O Procedure Quality and Adherence

56

3. Improve Procedure Adherence-Satisfactory  ;

Management has recognized the need to communicate expectations for ,

procedure adherence. Currently we are focusing on two key areas-more i supervision in the field to coach and mentor employees, and personnel accountability. Recent management attention has focused on documentation of procedural steps that are not performed because of plant conditions.

4. Monitor Progress-Satisfactory Performance indicators have been established and are frequently updated and utilized.

1 l

i LJ (3

l in iG

\ . . .

Procedure Quality and Adherence l

57 1

( Progro'ss Measurtments l Seccess Criterion: Procedure Deficiencies Required for Restart are Resolved P: ogress indicator: Procedure Upgrade Program Project Status j

I.

Procedure Upgrade Project Status Millstone 2 1

Progress

Progress is tracking to satisfactory.

t 80 30 1 I Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 98 98 98 98 98 98 98 98 98 98 98 98 lm Procedure Upgrade Project -e-PUP Work Off/ Goal l O

Procedure Quality and Adherence

58

' (,O) Success Criterion: Procedure Quality for New and Revised Technical Procedures are Acceptable Drogress Indicator: Unit 2 Closed CRs involving Deficient Technical Procedures Closed CRs involving Deficient Technical Procedures l Millstone 2 Progress: Progress is satisfactory.

to E

f e-8 Gooo ,

6- Goal s 5 per month j

4'

= = = = = = = = = =

j Data through l g 12/31/98 2- l 4

0 0

Sep Oct Nov Dec Jan Feb Mer Apr May Jun Jul Aug 96 98 98 98 99 99 M M M M M M l m Upgraded Procedures + Goal } '

4 O

Procedure Quality and Adherence

59 l l

Success Criterion: Instances of Not Adhering to Procedures are Reduced to an Acceptable Level i Progress Indicator: Procedure Compliance Millstone 2 Procedure Compliance Millstone 2 The Procedure Compliance goal has been achieved for each of the past 8 Progress: months, and shows a steady trend.

0 60

- ~ - - - - - - - - -

Goal 10.5 a'~ Data through l I '

12/31/98 E

0.00 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 98 98 98 98 98 98 98 98 98 98 98 98 lMTotal Non Comphance Enors/1000 Hrs Tot. NonComp. Enf1000 Hrs-3 Mo Rolling Avg. -e-Goal i 1

I l

l i

l O

Procedure Quality and Adherence

60 i

b V REMAINING ACTIONS l

1. Enhance Technical Procedure Quality Remaining Technical Procedures to Upgrade-Unit 2 will complete the upgrade on its required remaining technical procedures to support ready for restart. This is being measured by a Key Pedormance Indicator. As of October 1998, the procedures remaining were as follows:

- Unit 2 has 11 technical procedures to upgrade

- Service Groups have 1 technical procedure to upgrade or cancel

- Appendix R AOPs: There are 24 existing and 4 new AOPs being revised or rewritten to comply with revision 3 of the Unit 2 Appendix R Compliance Report.

l

. Station Qualified Reviewer Program-Enhance the ability of station j organizations to process procedure modifications by completing the  !

implementation of the Station Qualified Reviewer Program. (Unit 2 )

Technical Support and Health Physics has yet to fully implement the program and Unit 2 Design Engineering intends to qualify more cross-  !

discipline reviewers).

l

! ) I

2. Reinforce the Requirements for Procedure Adherence

. Management continues to routinely reinforce expectations for procedure I adherence and attention to detail in order to improve procedure i adherence and worker performance. Communication is ongoing through a variety of forums including departmental meetings, newsletters, and training.

3. Improve Procedure Adherence

. Procedure compliance will continue to be tracked through the Unit 2 Procedure Compliance Key Performance Indicator. Each department in i Unit 2 has a KPI to track procedure adherence. improved procedure l compliance will be realized as communication of DC 4 requirements to every worker via their first line supervisor is reinforced.

4. Implement sustaining performance program

. Implement goals and objectives contained in the 1998-2000 Performance Plan. Following restart of Unit 2 all procedure g development will be combined into a Central Procedure's Group.

(v)

Procedure Quality and Adherence

61 i 1

I l

x l CONCLUSIONS l )

)

in summary, Unit 2 is tracking to satisf actory in the area of Standards for j Procedure Quality and Adherence. 1 l

1. Scheduied backlog and technical procedure upgrades in support of Unit 2 restart is tracking to satisfactory.

2. Procedure Quality is satisfactory. l

3. Procedure Adherence is satisfactory.

A d -

1 l

l l

l

l Procedure Quality and Adherence

62 ENGINEERING QUALITY I

l llSSUE l Improve the quality of engineering products.

l STATUS l Tracking to Satisfactory to support Unit 2 restart.

'I l PROBLEM STATEMENT l The quality of engineered products delivered by Engineering requires improvement based on: l l

. Intemal self assessments i

( . Evidence of inadequate or unsupported technical conclusions

. Lack of attention to detail e Rework of products l SUCCESS CRITERIA l Management and extemal assessments indicate and Nuclear Oversight confirms that consistently high quality engineering products are produced.

. Quality of Engineering Products-Tracking to Satisfactory Goal: No programmatic breakdowns or breakthrough events are identified by management or extemal assessments Current Actual: There were no confirmed Level 1 or 2 safety significant (highest) ICAVP findings. Our intemally identified deficiencies and the number of Level 3 and 4 (lowest) ICAVP findings indicate that attention to detail and quality of implementation of engineering products needs improvement. Self-assessments, training, process enhancements and the Quality Review Board continue to be used by NU management to improve engineering products. The Nuclear Oversight Verification Plan (NOVP) rates Engineering as tracking to satisfactory.

q LJ Engineering Quality

63 Attention to Detail in Engineering Products-Tracking to Satisfactory Goal: Improving pedormance trends in the specific areas of " calculations" and engineering " change products" as well as improving trends in other Configuration Management (CM) areas. Engineering " change products" include design change requests, non-conformance reports and various design modifications.

Current Actual: Improvement is needed in areas such as program interfaces and assurance that safety analysis assumptions are met. The Quality Review Board and interdiscipline reviews of key systems provide on-going assurance of quality. Procedure changes are being developed j to improve processes, The coaching provided by the Quality Review Board continues to address the human performance aspects of this issue. i e Management Reinforces a Quality Culture-Tracking to Satisfactory Goal: Improving performance trends through the Unit 2 Engineering i Quality Review Board observations for rework associated with technical adequacy and procedural compliance. l Current Actual: There has been sustained improvement in the trend of rework of Engineering packages associated with the Unit 2 Engineering )

Quality Review Board findings from a high of 63% in July and since i leveled off at about 25% through December 1998. Lessons leamed are I (q

'y being communicated and training or individual coaching is conducted as appropriate. Position specific continuing training was conducted in December 1998 to identify specific rework trends and further reinforce management expectations.

l RECOVERY APPROACH l 3 Four (4) steps to improve the quality of engineering products have been 3 identified: {

l

1. Share lessons learned from Unit 3 recovery. l

2. Establish a program to ensure consistent application and control  !

of key specifications, calculations and other documents.

3. Increase engineering management involvement and review of j selected products. 1

4. Provide consistent feedback and reinforcement of quality.

n l b  !

Engineering Quality

64 O l COMPLETED ACTIONS l

1. Share lessons learned from Unit 3 recovery-Tracking to Satisfactory

. Unit 3 Engineering Self-Assessments were reviewed for Unit 2 applicability by department management.

. A joint lessons learned meeting was conducted between Unit 2 and Unit 3 leadership to discuss overall lessons leamed.

. Lessons leamed were incorporated into Unit 2's on-going activities.

2. Establish program for key documents-Tracking to Satisfactory

. Key drawings and specifications have been identified.

. Key standards for quality products have been established through the Design Engineering Standards guide.

. Key calculations are being identified as part of interdisciplinary reviews.

3. Increased management involvement in review of products-Satisfactory

. Unit 2 Engineering Quality Review Board (ORB) is in effect to provide

, in-line review of quality attributes for various change products. ORB is k an augmentation to established programmatic requirements.

Observations are tracked and trended to communicate progress.

- Engineering Assurance has assessed, and continues to assess, areas associated with engineering quality. For example, improved 1 implementation of the Quality Review Board was a topic in December 1998.

. In addition to Unit 2 ORB, a site Engineering Quality Review Board continues to ensure consistency across the three units conceming matters of quality.

4. Provide feedback and reinforcement of Quality-Tracking to Satisfactory

. Unit 2 Engineering ORB lessons learned are communicated at regular management meetings. Individual coaching is conducted as needed.

Overall progress of observed trends are provided daily and weekly as appropriate.

. Engineering Assurance and Nuclear Oversight observations and assessments are reviewed, action plans established and corrective actions are initiated to prevent recurrence of the issue.

. Position specific continuing training was conducted in December to address specific rework trends and reinforce management

) expectations for quality.

Engineering Quality

65 Progress Measurements l Success Criterion: Quality of Engineering Products Progress Indicator: Quality Review Board Results, Unit 2 I I

Quality Review Board Results 70 60 -

50 -

E g 40 - C # of Cris

' jf 30 -+--weekty vabe

--o- cunuiatue 20 l 10 <

0 m .n .- .- .-

i 3333$?%E555555558

--a a ~ iii4 ie4a EEEEEE a : aAeean+d l Date O

Engineering Quality

66 REMAINING ACTIONS l

1. Share lessons learned from Unit 3 Recovery Complete historical review of all packages identified by the screening review committee of the Engineering Quality Review Board.

2. Establish program for key documents Follow on activities to ensure consistent treatment of key information across the disciplines. Ensure changes to key information sources are managed appropriately. I

4. Provide feedback and reinforcement of quality

. Clarification of detailed expectations for independent reviewers will be issued l CONCLUSIONS l In summary, Engineering Quality is tracking to satisfactory. Corrective

(' actions have been initiated to address the deficiencies, progress is being tracked, plans adjusted as necessary and appropriate feedback is being  !

provided.

l l

l l

O v

Engineering Quality i

67 a

IV. START UP AND POWER ASCENSION PROGRAM llSSUE l A

Ensure Millstone Unit 2 is returned to full power operation in a safe, defined and deliberate manner.

l PROBLEM STATEMENT l Startup from the current extended outage is complicated by the following factors:

. Systems have been out of service for an extended period of time.

. A large number of maintenance activities and modifications will have been performed during the outage.

. Changes to the Technical Specifications have resulted from modifications made to the plant.

. Operating procedures have undergone revisions and include changes resulting from modifications made to the plant during the outage.

. Some plant modifications cannot be tested until the plant is hot and/or at power.

. Plant operating crews have not operated at power for an extended period, or newly trained operators will be in an operating environment on Unit 2 for the first time.

. Operating crews have to revert from an extended outage culture to an operating mindset.

l SUCCESS CRITERIA l A successful restart and power ascension test program will have been achieved upon retum of Millstone Unit 2 to full power operation with the following criteria as goals:

. No lost time accidents or recordable injuries.

. No challenges to safety systems during startup and power ascension.

Start Up and Power Ascension

68 g . No challenges to Technical Specification requirements.

U . No reportable events per 10CFR50.72 and/or 10CFR50.73 resulting from activities performed during the unit restart.

. Satisfactory implementation and testing of those design modifications and changes to the plant configuration required for the Unit to operate safely and within its design bases at full power.

l RECOVERY APPROACH l The Millstone Unit 2 restart will be based on the following:

1. Applying lessons leamed during the restart of Millstone Unit 3.

2. Incorporation of industry experience into the Unit 2 restart program.

3. Development of a Startup and Power Ascension Program (SPAP). The SPAP will be designed to:

. Provide guidance to assure the retum to power operation is safe and deliberate.

. Outline the special administrative functions which will be in place during restart.

( . Define and detail the aggregate and sequence of activities that will be performed.

. Specify hold-points to allow periodic assessments of plant and personnel performance, test data and results, and programmatic and procedural adequacy.

. Include restart-specific commitments and/or supplemental mode-change requirements.

. Document management approvals associated with the restart program.

. Utilize existing plant operating and test procedures to the maximum extent possible.

4. Implementation of the SPAP through a special procedure [SPROC OP98-2-08, Unit 2 Restart Following 10CFR50.54(f) Outage}

constituting the sum of the administrative functions and activities required to take the unit from physically ready for restart to full power operation.

5. Implementation of those design modifications and executing those AWOs required to retum the Unit to full power operation, and satisfactorily completing the associated retesting to the extent possible prior to entry into Mode 4.

%J Start Up and Power Ascension

._. m.

i l

69 o 6. Developing special test procedures as needed to support unique  ;

Cl restart testing requirements.  !

i

7. Ensuring system performance and reliability testing will have adequately demonstrated and validated operation of plant systems )

within their design bases. l

8. Satisfactorily completing testing of components, systems, and  ;

integrated plant functions that could not be tested prior to commencement of the SPAP.

9. Providing startup and operations training to key Operations Department personnel prior to plant restart, power ascension, and at-power operations at other similar facilities and/or on the Unit 2 simulator. ,

10. implementation of revised plant operating procedures that include enhancements based on :

. Industry experiences

. Modifications made to plant equipment and configuration Lessons leamed as a result of the 10CFR50.54(f) effort

. Lessons leamed during the restart of Unit 3

-( COMPLETED ACTIONS l

1. Application of lessons learned during restart of Unit 3-Tracking to Satisfactory I l

. Meetings to discuss lessons teamed during the restart of Unit 3 have been held between Unit 2 and Unit 3 Management groups. These meetings have laid the foundation for further periodic exchanges between the two Units at the functional group level. l

. Action items to implement lessons leamed of benefit to Unit 2 were identified and ownership assigned. Applicable lessons leamed have been incorporated into the SPAP. Approximately 50% of those beneficial to Unit 2 have been addressed and incorporated. The remainder are addressed in Remaining Actions.

. The Unit 2 SPAP Procedure is based on the procedures used to direct the restart activities of Unit 3.

2. Incorporation of industry experience into the Unit 2 Restart Program-Tracking to Satisfactory

. Industry experience for development and implementation of the SPAP 4

.O is being provided by staff members with many years of initial and post- i

-d refueling plant startup experience. l t

Start Up and Power Ascension l

70

.o . Applicable industry experience has been lategrated into the SPAP .

special procedure. I

3. Development of a Startup and Power Ascension Program (SPAP)-

Tracking to Satisfactory I

. Identification of the reediness sequence of plant systems to support restart has been completed. This information supports development  !

and refinement of the SPAP Schedule. j

. The overall SPAP has been developed and defined in the SPAP I special procedure l

. The SPAP backbone schedule has been developed l

4. Implementation of the SPAP through special procedure-Tracking to j Satisfactory

. The Unit 2 SPAP Procedure [SPROC OP98-2-08, Unit 2 Restart Following 10CFR50.54(f) Outage] has been developed and approved. l l Remaining Actions l

1. Application of lessons learned during restart of Unit 3

. Complete incorporation of restart-specific lessons teamed into the O

Y overall plant operating philosophy for plant startup and power ascension consistent with the SPAP Schedule.

2. Incorporation of industry experience into the Unit 2 SPAP I

. The SPAP will be continually updated during its implementation to incorporate the most current applicable lessons teamed and industry experience inputs will be derived from Unit 3 experience, the Millstone Nuclear Safety Engineering Group, information bulletins issued by regulatory authorities, contacts in the industry, etc.

3. Development of a Startup and Power Ascension Program

. Complete development of the SPAP Schedule before entry into Mode 4 for progressing from Mode 4 through Mode 1. Incorporate into the backbone schedule the post modification tests requiring Mode 4 through Mode 1 conditions.

4. Implementation of those design modifications and executing those AWOs required to return the Unit to full power operation, and satisfactorily completing the associated retesting to the extent possible prior to entry into Mode 4.

. Complete incorporation of those major modifications required to be implemented to support return to operation.

O . A Key Performance Indicator (KPI)," Restart Modifications Awaiting V Implementation," which details and tracks the progress of the major Start Up and Power Ascension

71

.p modifications remaining to be implemented to support retum to V operation has been created.

Improve work-down rate of AWOs remaining to be completed for entry into Mode 4 and subsequent startup and power ascension to support overall restart schedule.

. A KPl, "Startup Work Order Status," which details the AWOs remaining to be completed to support entry into Mode 4 and l subsequent startup and power ascension has been created.

5. Development of special test procedures as needed to support unique restart testing requirements.

. To the extent possible, existing surveillance test procedures are being used to verify component, system, and integrated plant functions.

Where existing procedures do not exist, or are deemed inappropriate for the necessary testing, Special Procedures (SPROC) and/or in-Service Tests (IST) are being written.

. Complete identification of those test evolutions that will require a SPROC or IST, and prepare the appropriate documents consistent with the schedule for implementing the respective plant configuration l modifications. i

6. Ensure system performance and reliability testing will have adequately demonstrated and validated operation of plant systems within their i design bases. I e Post-work testing, and component, system, and integrated testing of design modifications continues to be scheduled as required to verify proper operation of equipment to the maximum extent possible in preparation for restart of the Unit.

7. Satisfactory completion of testing of components, systems, and integrated plant functions that could not be tested prior to commencement of the SPAP.

l

. Include testing that cannot be completed prior to startup in the SPAP l schedule

8. Providing startup and operations training to key Operations Department personnel Covered in the Operational Readiness Section l

9. Implementation of revised plant operating procedures that include enhancements

. Covered in the Operational Readiness and Procedure Quality and 4 Adherence Sections O

l

( Start Up and Power Ascension

72

• l Conclusions - l l

Development of the startup and Power Ascension Program which incorporates Unit 3 lessons learned and the procedure implementing the program were completed in December 1998. The Startup and Power Ascension Program was submitted to the NRC on December 22,1998.

I i .

i l

l b

i Start Up and Power Ascension

Indox Key Performance Indicators V

Millstone Unit 2 KPls Page Number KPI Title A-1........................ Task Completions Required for Restart A-2. . . . . . . . .... .. ... .... Open Level One Condition Reports A-3........................ Condition Report Evaluation Timeliness A-4. . . . . .. ... . . ... . Score Condition Report Method of Discovery A-5........ ....... ... ... Condition Report Evaluation Quality l A-6. . . . . . . . . . . . Overdue Corrective Actions i A-7................. .. Human Performance, Millstone 2 )

A-8. . . . . . . . . . . . . . Open NRC Commitments for Restart l A-9. . . . . . . . . . . . . . . . .. Significant items List l A- 1 0. . . . . . . . . . . . . . . . . . . . . . . . . 10CFR50.54(f) Significant items for Restart ,

A- 1 1. . . . . . . . . . . . .. . ....... Licensee Event Reports  !

A-12.......................... License Amendment Requests  ;

A- 1 3. . . . . . . . . . . . . . . . . .... . . Restart Modifications Awaiting implementation  ;

A-14.. . . . . . . . . . . . .. Start-up Work Order Status  !

A-15.. . .. ... ... ........ .. On-Line Work Order Status A-16.......................... Temporary Modifications i O A-17. .. . . . ......... ....... .. Control Room and Annunciator Deficiencies I A- 18. . . . . . . . . . . .. ... .. .. Operator Work Arounds A-19.......................... Procedure Upgrade Program Project Status A-20. . . . . ..... ... ... .. . ...... Procedures Required for Restart Status Oversight KPis B-1..................... Status of Oversight Condition Reports, Millstone 2 B-2. . . . . . . . ... ... . .... Nuclear Oversight Verification Plan (NOVP), Millstone 2 Additional KPls Procedure Comollance and Quality Indicators Page Number KPl Title C-1............ .......... ....

Procedure Compliance, Millstone 2 C-2. . . . . . . . . . . . ..... . ... Unit 2 Closed CRs involving Deficient Technical Procedures Additional Work Control Indicators D-1.................. .. .. Overdue Preventive Maintenance AWOs

(

C 1

1 Indox Key Performance Indicators n

U l

Safety Conscious Work Environment KPls l

I E-1.. . NU Concerns and NRC Allegations Received, Millstone Station E-2.. Millstone Employee Concems Confidentiality Trend, Millstone l E-3.. Employee Concem Resolution Timeliness E-4.. .

Focus Area Action Plan Status, Millstone Station

)

i E-5.. . . Substantiated Concerns involving Potential Violations of 10CFR50.7 l E4.. . .. Leadership Assessment (SCWE Element) l E-7.. . Culture Survey (SCWE Element)

Leadershio and Culture Indicators F-1.. . . Leadership Assessment F-2.. . . Culture Survey (a

A U

2

l i

io a

4 j

1

.I i

i

!o Millstone Unit 2 l

Indicators  !

O

i, Task Completions Requin e for Restart

! Millstone 2 a

Progress

Progress is tracking to satisfactory.

3000 ---

, 2500 i C\ta .h r '

d j # 2000- l h ~IIIE8 4

i 1

~

s i F en er.% ,j 1 1000 -

i N E E s00 i \

f 0 'N -

j Apr May Jun Jul Aug Sep Oct Nov Dec Ja Feb Mar j 98 98 98 98 98 98 98 98 98 99 99 90 M Tasks Remaining - m - WorkOft/G0al l 1 *- com . _ _

Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Od-98 Nov-90, ,; .

9 l Jan-99 Feb-99 I s.' Jr-99 1 - Created -240 387 454 423 517 308 139 257 Ji '

Completed 562 631 624 500 518 502 411 505 c'.3 4

Tasks Remairun0 2825 2581 2411 2334 2333 2139 1867 1619 1385 j WorkoR/ Goal 1887 1752 1429 1108 630 147 0 DennMen Ane&ndalAcelon i This indicator depicts tasks requiring closure pr6or to Approximately 64% of the Rest..t Ass'gnments are restart. This includes assignments associated with NRC corrective actions for CRs, and an e #tioral 9% are Open items, Significant item List issues, and Condition CMP assignments. Virtually all of ine en restart

Report corrective actions as tracked in the Action item assignments are coming from completion cf ICAVP.

I Track and Trending System (AITTS).

J Actions to improve performance inclA Restart is defined as " Ready to Emer Operational Mode improve physical work performance by imp 4,mniiting

2". P-3 Work Schedule 5

Outage Recovery Team final review for cuage scope l Not included in this indicator are Automated Work Orders Focus on System Window closure

] (AWOs) required for restart, which are tracked separately. l j '

Design Engineering. Managed Task Group, and Project

! Engineering are responsible to complete approxinvAry

}

{ 41% of the tasks remaining for restart. The Centralized j 6 Procedures Group is responsible for approximately 15%.

The remaining 46% is generalty evenly divided 9mong the remaining alert groups, i

4 Geel Canunents

The goal is to complete all non-deferrable tasks by Number of task completions includes trxle 1

restart. assignments.

NOTE: April created number appe,ars negative due to reclassification of restart asslgt ments.

g Se sce: . AITTSl Ans& sis by: S V. Heard x5600lOteveer: S V Hes;4x5600 I

A1 1

4 1

4 f

k Open Level 1 Condition Reports l Millstone 2

Progress

Progress is unsatisfactory. Level 1 CRs that are complete and awaiting 4

closure are included in the graph.

1 200 180 -

160 -  ? "

Data through 140 - y 12/31/98 120 - 1 I 10C l

E0 1 I f I t i I I i 1 Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar 98 98 98 98 90 98 98 98 o'; 99 99 99 i

lM Open Lvl 1 >120 Days -+-Open Level 1 CRs l

' Meer Opts j Apr 98 May-98 Jun-98 J498 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 j Total Open CRs 2403 2505 2635 2639 2882 2970 3009 3035 2892 Open Level 1 CRs 155 159 175 180 186 196 178 193 179

}

j Open Level 2 CRs 2248 2346 2460 2459 2696 2774 2831 2842 2713 4 CRs Open >120 Days 1831 1782 1841 1953 2090 2239 2273 2303 2317 l Open tvl 1 >120 Doys 130 130 134 143 146 153 148 150 140 j Open Lvl 2 > 120 Days 1701 1652 1707 1810 1944 2006 2125 2153 2177 j Lvl 1 CH Medan Age (Deys) 3850 379 5 360 0 361 0 2930 Lvl 2 CR Medan Age (Days) 311.0 319 0 307.0 281.0 294.0 OBRdeon AnalyeWAcGon This indicator depicts the total number of open condition reports The CR generation rate continues to exceed the rate of (CRs) and the number of Level 1 CRs open greater than 120 closure for Level 1 CRs. Approximately 25 Level 1 CRs days. Level 1 CRs identify the most significant issues. have all corrective action assignments in COMPLETE status. Ten require owner review and 15 require The 120 day criterion was selected based upon industry adm.inistrative review.

benchmarks for resolution of open items.

Since 12/1/98,27 Level 1 CRs have been closed, and R: start is defined as ' ready to enter operational rn6ce 2". 10 have been initiated. The project team expects to complete review and quality improvements on Level 1 CRs by 1/15/99.

Geef Conunents The goal is to have the number of Level 1 Condition Reports open >120 days decline.

Does Source ArrTSl Analyons by: S V. Heard x5600 l Owner: S V. Heerd x5600 A-2

Condition Report Evaluation Timeliness Millstone 2 Progress: Progress is satisfactory.

35 Goals 30 days 30 re-M 25 through Good 12/31/98  ;

- 15 10 5

0 Apr 98 l

May 98 I liilt liI Jun 98 Jul l

98 Aug 98 Sep 98 t

Oct 98 i

Nov Average Age of CR Evaluations Goal l 98 NA Dec 98 Jan 99 I

Feb 99 I

Mar 99 l

y ASIEFOstS Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec98 Jan 99 Feb 99 Mar 99 O

Average ADe of CR Evaluations Goa!

Total CR Evans Regured 24 8 30 273 30.3 30 328 26 9 30 259 21 1 30 213 27.7

kJ 303 29 8 30 286 30.0 30 1 79 26 0 30 134 NA 30 177 30 30 30 Evals Corrpleted witNn 30 Days 221 217 199 186 247 184 101 76 39

% Evals Cortp6sted wtNn 30 Days 810% 862% 76 8 % 87.3% 81.5 % 64 3 % 564% 567% NA

% Eva6s Now CorrgAete 100 0 % 100 0% 100 0% 100 0% 99 7% 98.3 % 91.1 % 82.1 % NA Dennftfort Ans& sis /Acidort l This indicator depk:t3 'he average age of Level 1 & 2 The average age of CR evaluations continue to meet {

Condition Reports :.:lis) for which evaluations are still expectations. Evaluations completed within 30 days are j open, evaluations which were completed during the month below expectation for September, October, and November.

being reviewed and the age of CRs that were originated However, evaluations completed within 40 days for the same the month under review. period have a >72% completion rate. High work load in some areas, such as Design Engineering, and focus on Loss Once issued, Condition Reports are evaluated to of Normal Power (LNP) testing and refueling activities determine the corrective actions that are necessary to resulted in low percentages of completions within 30 days.

address the issue and prevent recurrence. The 30 day clock begins on the day the assignment is rnade and ends To date there have been 3848 CRs written, approximately 3/4 when the CR is received in the Corrective Action of which are level 1 and 2. There are 21 Level 1 and 161 D partment for review. Level 2 CRs that are stil! open for investigation; 32 investigations are currently greater than 30 days old &

overdue. l The average age of 1998 condition reports that are still open for investigation is approximately 25 days.

Goat Comments g

The average time to complete CR eva' sations is s 30 NOTE: November and December data have not reached

\ days. the end of the 30 day clock.

Does source Artisl Ane& sis by: S V. Heard x5000l Owner S V. Heard x5600 A-3

j Condition Report Method of Discovery

) Millstone 2 Progress: Progress is satisfactory.

$ 25% .

Data through E 20% 12/31/98 W

l se 15% g Omls 10% G od

$ W 10% = = = -

= =

1:iI,iI"iI I lim I

Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar 98 98 98 98 98 98 98 98 98 99 99 99 f % Extemal + Event C" 3% Extemal + Event -lCAVP -e-Goal l I 4eur Osts Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 f

% Esternel + Eveal 8.4% 21.3 % 7.9% 10.1% 18.0% 18.2% SJB% 9.9% 4.0%

l

% Es1ernal + Event lCAVP 4.s% 2.s% 3.5% 1.4% 8.0% 3.3% 1.8% 2.3% 2.5% l

[s Goel 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0% 10.0 % 10.0% j

) Unit CRs 258 254 N1 239 293 265 266 221 285 l Irdernal Oversagte CRs 25 30 12 18 33 38 25 16 24 External Oversaght CRs 19 77 25 29 62 67 28 26 13 Event CRs 7 0 0 0 0 0 0 0 0 Total CRs 309 361 318 286 388 368 319 263 322 i

External + Event CRs 26 77 25 79 62 67 28 26 13 Ex1ernal + Event-ICAVP CRs 14 9 11 4 31 12 5 6 8 OsArnNilen Ane&silWAction This indicator represents the percentage of Unit 2 Condition The year-to-date (through 12/31/98) percent of Reports (CRs) identified by external sources or events extemal and event CRs to the total CRs is 3.6%.

. / Jrpared to the goal. CRs are categorized into the following j four areas: The high ICAVP identification rate will significantly Event Driven - Self-revealing, an event occurs. decrease since Parsons Power closed the remaining External Oversight - Identried by NRC, NCAT, ICAVP discrepancy reports (DRs). A three week INPO, ICAVP, etc. Corrective Action Inspection is currently underway, l Internal Oversight - identified by PORC or which is the final phase of the ICAVP order.

Nuclear Oversight: Audits, Surveillance, inspections, l IRT, NSE, and NSAB. Excluding ICAVP related CRs, the percentage of l SeN identified - Supervisor observation, document external and event CRs to the total is satisfactory.

review, Self-checking, independent / dual verification, etc.

It is desirable to have a low percentage of all CRs generated by extemal sources or events, and a high percentage generated by the line organization or intemal oversight. )

M CONINBenft r The goal is to have s 10% of issues (CRs) identified by

( Cxtemal sources or events assuming a levelized NRC inspection effort.

Dess source ArTTSl Ans& sis by- S. V. Heard x 5600lOsmer- S V.Heerd x5600 A.4

a l I

Condition Report Evaluation Quality Score

. Millstone 2

. Progress: Progress is satisfactory l 4 00

{

350-Goal 23.0 \

3 00 -

1 I l 2.50 - Good 1 2.00 -

l j 1.50 -

1 1.00 -

0.5o -

4 j 0.00

} Jan Feb Mer Apr May Jun Jul Aug Sep Oct Nov Dec 98 98 98 90 98 98 98 98 98 98 98 98 lm Average Quality Score Goal l 5

) Notr M 3 Jarv98 Feb-98 Mar-98 Apr-9e May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 l Aversee Quality Score 3.s7 3.a3 3.79 3.se 3.83 3.20 3.2e 3.18 3.28 3.32 3.21 3.34 Goal 3.00 3.00 3.00 3.00 3.00 3.00 3.00 3.00 3.00 3.00 3.00 3.00 l l

i Toie; Rev6ewed til 47 28 19 24 40 51 49 65 47 73 94 Aa:epted 90 43 26 17 15 28 40 35 52 36 57 73 Accepted W/Corntnant 18 4 1 0 4 8 4 8 2 6 3 11

, Rejected 3 0 1 2 5 4 7 6 11 5 13 10 i l'sjechon Rate 0 03 0 00 0 04 0 11 0 21 0 10 0 14 0 12 0 17 0 11 0 18 0 11 l* DeRnNiion AnakeWAction This indicator reflects the quality of Condition Report (CR) The 4 week rolling average quality score is 3.21.

evaluations presented to the Management Review Team CR investigation quality continues to excen. J the goal.

(MRT). Each evaluation is reviewed for the adequacy of the The MRT is maintaining high standards for CR proposed plan to address the issues identified by the CR. investigation quality.

Point values are assigned to each evaluation as follows:

Accepted - 4 points Accepted with Comments - 2 points Rejected - O points A weighted average QualMy Score is then calculated:

(# Eva! X 4 ooints)+ (# EvalsWC X 2 ooints)

Total # Evals Reviewed Where:

1. Evals = The # of evaluations accepted without comment,

1. Evals WC = The # of evaluatons accepted with comments, Total # Evals Reviewed = The total # of evaluations reviewed.

Gent Comments The goalis to achieve an average quakty score 23.0 on a The number of CR evaluations plotted as

• total #

scale of 0 - 4.0. accepter includes the evaluations accepted with and without comments.

two source s v. Heard x5e00l Anstrels by- s v Heard x5800l0wner: S V. Heard x5600 A-5

J Overdue Corrective Actions Millstone 2 1

Progress: Progress is satisfactory.

12 %

10% -

O 8% . Data through 6% -

4%- Good Goels3%

a Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec M 99 M M 98 M 98 M M 98 M M l m% Overdue Goal l bb Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98

% Overdue 11.2 % 9.0% 0.0% 3.1% 6.4% 4.0% 4.0% 1.0% 1.0% 1.0% 2.3% 2.0%

O Geel 3.0% 3.0% 10% 3.0% 3.0% 3.0% 3.0% 3.0% 3.e% 3.0% 10% 3.0%

Open Level 1 CA 480 407 389 394 406 425 395 395 384 397 373 Open level 2 CA 2759 2836 2888 2817 2877 2803 2005 2834 2865 2702 2657 Total Open CA 3371 3219 3243 3277 3211 3283 3228 3200 3229 3249 3099 3030 Overdue Level 1 CA 32 21 to 26 28 21 4 12 16 15 19 Overdue Level 2 CA 283 272 90 179 119 108 29 39 36 55 41 Total Overdue CA 377 315 293 100 205 147 129 33 51 52 70 60 Dennihon AnefyelefAc6an This indicator depicts the percentage of the total corrective increased line management attention and enhanced CR cctions that are overdue. review and work scheduling are starting to improve this trend, but we are still challenged to prevent the peak Corrective actions are developed to address issues and that occurs at the beginning of each month.

problems identified by Condition Reports (CRs). Overdue corrective actions are ones that have not been completed Having more activities schedule driven has had a by the scheduled due date. positive impact on this indicator.

It is desirable to have a low percentage of overdue Corrective Actions (CA) relative to the total number of corrective actions that are open.

Geef Comments The goalis for the percentage of overdue corrective actions to be s 3% of the total open corrective actions.

sees source: AITTSl AmefyeAs ty: S V Heard x5600 l owner: S V Heerd x5600 A4

i 1

4 l Human Performance

!, Millstone 2 Progress: Progress is satisfactory.

100 % -

E l 90%< Goal a 95%

O  !

e0%-

70% - Data through I

g 60% -

l 12/31/98 50% . l j 40%< j j #

1 30% i i t t t i i t i i t -

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec i M M M M M M M M M M M M

%% Low Segrdcance (Precursor) Errors-Mon. % Low Segrdcance Errors-3 Mon. Roihng Avg -Goal l 5

Asw anas Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98

% Low Significance (Precursor)

Errore-Men. 77% 94 % 97 % 96 % 92 % 90% $7% 97 % 96 % 98 % 99 %

% Low 86gninconce Errore-3 Mon.llioNhng Avg. 75 % 94 % 91 % 96 % 96 % 92% 90 % 93 % 94 % 99 % 97 %

l Goel (16% 95 % 96 % 95 % 96 % 96% 95 % 95 % 95 % 90 % 95 % l Hornan Enor Precursor Events 58 121 94 41 54 46 27 63 58 52 77 Hurnan Error Near Mira Events 16 7 1 2 3 4 4 2 3 2 1 Human Error Breakthrough Events 1 1 2 o 2 1 0 0 0 0 o Tcdal Human Error CRs 75 129 97 43 59 51 31 65 61 54 78 1000 Productive Hrs Worked 128 972 179 425 189.229 211.113 172 958 199 691 177.268 189 128 201.113 204 720 245 670 M AnOfy9WACYett This indicator depicts the percentage of human errors with The three month rolling average for the percentage of low significance relative to the total human errors identifed. low significance (precursor) errors to total human Human errors are identified through CR evaluation and the errors is above the 95% goal.

errors are categorized by significance level.

The unit is identifying and taking effective corrective The most significant errors are called breakthrough events actions for human errors at a low threshold which is and are characterized by a breakdown of all barriers. reducing the error rate for more significant errors.

Breakdown events result in consequential events such as plant transients, major equipment damage, operation outside The increase in precursor events dunng the month of design basis, etc. Near miss events involve the breakdown December is due to a change in the basis for selecting of multiple barriers but resulted in little consequence. As a human error precursor events trend code. It is not such, they represent a lower significance level. Precursor indicative of an increase in personnel errors.

events invofve the breakdown of few barriers, are caught early in the event chain, and result in no significant consequences.

It is desirable to have a higher percentage of low significance human errors (precursor events) to total errors to allow for the implementation of corrective actions at a lower threshold, thereby preventing more significant errors.

Geet Commente The goalis for the percentage of low significance errors Contractor hours are included as of January 1998.

(precursor events) to be > 95% of the total human errors identified Dese Spurse ArTTS l Ana&oAs Sy: S V. Heard x5600l Owner- S V Heard x5600 A-7

4 I

h' Open NRC Commitments for Restart Millstone 2 l Progress: Progress is tracking to satisfactory.

3 150 l

l Data through 125 12/31/98 100

)

y 0 1 I I I I I t i I I I e j Apr May Jun Jul Aug tiep Oct Nov Dec Jan Feb Mar 98 98 98 98 98 98 90 98 98 99 99 99 l

j j MOpen items Overdue items -e- WorkOft/G0al l 1 l l NWIIf M Apr-98 Ma y-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Jarv99 Feb-99 Mar-99 j Open items 95 101 103 100 88 122 110 105 i Overdue items (, 0 0 0 0 0 0 0 0 Iterns Closed 14 7 7 6 5 18 10 23 31 j ttems Added 3 23 13 8 2 6 44 11 26 WorkOff/ Goal 88 112 81 94 51 12 0 M Anoly90WAC0eN This indicator depicts the number of Nuclear Regulatory The work off curve has been adjusted to incorporate the Commission (NRC) commitments that require final increase in commitments as of 12/25/98. While the year closure with the NRC prior to restart of t'1e unit. end data appears to exceed the goal, a review of the NRC commitments in the Action item Tracking and Trending An NRC commitment is defined as: System (AITTS) database indicates 9 commitments are in

. a written statement that is docketed progress. i

. a verbal statement to take a specific action, agreed to by an officer New commitments are added based on Licensee Event

. a requirement to take an action imposed by the NRC Report (LER) submittals and receipt / submittal of docketed correspondence. Unit 2 Mode 6 related activities are being Restart is defined as ' Ready to Enter Operational Mode completed. Most NRC commitments are tied to Mode 4, it 2". is anticipated this indicator will show significant improvement as Mode 4 activities progress.

Goat Comments The goalis to have no overdue NRC commitments, and Source of commitments:

complete all commitments prior to restart. LERs: 49 Other Docketed Correspondence: 56 Dets Source: E. Annino x4604 l AnalyeAs by: E. Annmo x4604l Owner R JosN x2000 A4

1

O significant it.m. ti.t '

Millstone 2 l Progress: Progress is unsatisfactory.

? l

'J 50 h Data through g 12/31/98 30

$ Good

20 to j 0 I I I I I t I I t - 1 j Apr May Jun Jul Aug Sep Od Nov Dec Jan Feb Mar i 98 98 98 98 98 98 98 98 98 99 99 99 l

j l Closure Packages Remaining Packages Workoft/ Goal l Monv Ones

, Apr 98 May-98 JurF98 Jul-98 Aug-98 Sep 98 Oct-96 Nov 98 Dec-98 Jan 99 Feb 99 Mar-99

! Ch>sure Packages Remaining 43 39 38 38 38 32 29 28 23 jg Closure Pkgs Submitted-NRC 32 38 37 39 38 43 48 49 54

+

Total Closure Pkg Required 75 75 75 75 78 75 75 77 77 77 77 Packages Workott/ Goal 32 27 23 13 3 0

. DentnMon Ann &eWAction The MP2 Significant items List (SIL) includes those For the 77 closure packages which are required to address items (54) chosen by the NRC that require closure the 46 SIL ltems, 54 have been submitted to the NRC prior to start up. In May 1997, the NRC determined through 12/31/98 and 23 remain. Some closure package that 8 SIL ltems (2,3,4,11,13,15,17,50), based on completions are dependent upon factors such as plant the scope of the issue, do not require a closure operating mode, scheduling, and resources, package. The 46 remaining SIL ltems require a closure package to be submitted to the NRC. DBDP Closure (SIL 27) will be closed during the ICAVP Corrective Actions inspection.

The work off/ goal line in the graph above has been revised reflect tracking of the 77 individual closure Eighteen of the 23 remaining SIL deliverab%s require packages required to address the 46 Sils. completion of physical work.

Restart is defined as " ready to enter operational The NRC indicates the quality of SIL packages is meeting mode 2". the expectation for providing " objective evidence" that the corrective action plan has been implemented. Physical work completion is a significant barrier to closing the remaining SIL packages.

M N -_.

The goal is to submit all items prior to restart.

Does Source C. Clement x5590l Analysis by: C Clement x5590l owner- R. Joshi x2000 A-9

Q J

i 10CFR50.54(f) Significant items for Restart Millstone 2

Progress

Progress is tracking to satisfactory.

1800 l 1400 l 1200

! 1000 Data through j 12/31/98

c 000 Good E

l g e00 400 0 1 i f I i l l I t i N Ap.- May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar j 98 98 98 98 98 98 98 98 90 99 99 99 l-Open Significant items --sH Work Oft / Goal l h Ogde Jan 98 Mar 98 Apr 98 May 98 Jun 98 JLA98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 O Open Sognrhcant items cioned segnkant nems Total Sign 4 cant items 1380 1811 3191 1350 2218 3568 1318 2169 3487 1437 2241 3678 1483 2403 3866 1518 2474 3992 724 3673 4397 690 3884 4574 644 4138 4782 694 4274 4968 616 4489 5105 Work Oft /Goa! 684 609 DennWon ,p Ane&eWAction Significant items for Rw. 11:e those ~e ns being The increased Significant items for Restart are due to the reported to the NRC in accordance with the the number of new items continuing to be generated 10 CFR 50.54(f) request of April 13.1997, exceeding the number closed.

The increase in November is due to previously closed Restart is defined as ' ready to enter operational mode Significant items for Restart being reopened. Good 2". progress is being made reducing the number of Significant items.

Genf Conwnents I Sgnificant items for restart closed no later than 14 days prior to the Commission meeting for unit restart.

Dois Source J. Z. LaPlarde a 3269lW by: J. Z. LaPlanto x 3269l Owner: J. Z. LaPlanta x 3269 l

A io

I l

! l l,,

il p

N Licensee Event Reports Millstone 2 Performance is satisfactory, LER generation for current Issues remains ProgTOSS; at the Indust;y average. 1 5 ,

4 -

Industry average = 1 per month i

f3 J

Data through I g l 12/31/98 g2 - -

1r 1 - -----

I O I --+---6---4---+- --4---

Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar 98 98 98 98 98 9e 98 98 98 99 99 99 l LERs-Recent LERs-Historical industry Standard l lf) MM l Apr-98 May 96 Jun-98 Jul-98 Au9 98 Sep-98 Oct-98 Nov 98 Dec-98 Jan-99 Feb99 Mar-99 LERs-Recent 1 0 0 0 0 0 0 0 0 0 0 0 LERs-Historical 3 3 4 2 1 3 3 2 0 0 0 0 LERs-YTD 6 9 13 15 18 19 22 24 24 Industry Standard 1 1 1 1 1 1 1 1 1 1 1 1 Donnhien Analyse!Acelan This indicator depicts the number of Licensee Event Twenty-four LERs have been submitted to the NRC Reports (LERs) submitted to the Nuclear Regulatory through 12/25/98.

Commission (NRC), relative to the industry standard.

LERs are reflected in the month in which they are The following LERs were submitted during November: l submitted.

LER 96-023-00: Failure to Adequately Test Containment Licensee Event Reports (LERs) are reports made to Air Recirculation Fans in Accordance with Technical the NRC pursuant to 10 CFR 50.73. Specification Surveillance Requirements (historical).

Recent LERs document current emerging issues and LER 96-024-00: Potential Leakage Path through events. Historical LERs document events or issues Containment Pressure instruments identiled (historical).

that did not occur in the previous twelve months.

I l

Goal Conwnenes

!(fx)

U The goalis for performance to be less than or equal to the industry average. For 1997, the industry average was 1 per month.

Deep Seuree J Winzenreid x2073 l Analyede by- R. Joshi x2080lOumer: R Joshi x2000 A-11

License Amendment Requests i

Millstone 2 Progress: Progress is tracking to satisfactory.

12 1

4 10 1

8 Data through l'

E 12/31/98 Good

$e z v b

0 l I I I I I l l l l l j Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar 98 98 98 98 98 98 98 98 98 99 99 99

l LARs Remaining -gF-Work-Off/ Goal l l

e bb Apr-98 May-98 Jun-98 Jul 98 Aug-98 Sep-98 Oct-98 Nov-98 Dec 98 Jan-99 Feb-99 Mar 99 f LARs SubmMted 2 2 0 3 1 3 2 1 2 LARs Created 3 4 0 0 1 3 0 1 1

-. LARs Remameng 8 10 10 7 7 7 5 5 3 Work-Oft / Goal 7 5 5 4 0 i DenMalon AnalyeWAsnan i License Amendment Requests (LARs) are Twenty-eight LARs have been identified as being required for changes to Technical Specifications or other restart. Eleven were submitted in 1997 and an additional 13 have

{' license changes that are needed for restart that been submitted through December 31,1998. The NRC has gre to be submitted to the NRC for approval. approved 13 amendments and 12 have been implemented.

Emergent issues continue to increase required numbers of license Restart is defined as ' Ready to Enter amendments for restart. An additional amendment request related Operational Mode 2", which is the point at which to the EBFS Bypass Leakage (Tech Spec) has been identified. It Commission approvalis required. has been determined that the LAR related to the cable tray separation issue is not required.

Continuous management attention is being directed to expedite the License Amendment Requests.

l LARs remaining and approximate submittal dates:

- Hydrogen Purge - TS - 1/8/99 IST Flow-ECCS Pump-T.S. - 1/4/99

- EBFS Bypass - T. S. - 1/25/99 Genf Comunener

)

i The goal is to submit all LARs to the NRC prior U to restart.

Dois Sowce R. JosN x2000l AnsApteds by: R. Joshi x2080l Dimer- R. JosN x2080 A-12

43 p Restart Modifications Awaiting implementation Millstone 2 Progress: Progress is trucl:!:q to satisfactory. Currently Engineering is Bi% complete

, and Construction is 69% complete. l l

1 go l i'

80 - -

2 WW 12/31/98

70 -

d 80 -

4 50

$ 40 < t 30-a 20 -

10 -

. 0 1 1 1 i 1 1 1 I t t Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Jan 99 r ob-@ Mar 99 lmMods Released to Fleid C""l2 Mods Aweeng Engineenng -e-Work Oft / Goal l O

Mew Dein Apr-96 May-98 Jun 99 i Jul-98 Aug 98 Sep-98 Oct-98 Nov-98 Feb-99 Mar-99 Oc-et ( Jan-09 Mods Released to F6 eld 45 39 39 39 32 33 34 40 26 , y Mods Amalten0 Engmeenng 34 41 39 34 49 46 50 34 34 __

Total Mods Romaming 79 80 78 73 81 79 84 74 60 Work Ott/ Goal 81 73 84 72 52 28 0 Onhnnion An.MyndelAction This indicator depicts the total number of design As of 12/31/98, the total number of Des 6 Jn Modifications modifications, classified by completion status, which required for start-up is 229. Of these, it 8 require field must be implemented by restart. implementation and 61 are Engineering (Wy. Engineering has issued 195 Rev 0 Design Packages and Construction has Restart is defined as " Ready to enter Operational Mode completed 116 of 168 modifications.

2".

This month: (12/1 through 12/31/98)

This Indicator excludes Testing and Close-out

• 19 Modifications were completed

• 9 Modifications were added

+ 7 Modifications were released to the field

• 22 Modificatons work in progress Geel Commente All start up related design modifications completed prior Discovery is not complete with respect to engineering programs to restart. and Parsons. As a result, additional projects continue to be added.

Dets Sowse- ez x4930l A@ by: S Doubet x-5644loemer s Bnnkrnan x5321 A 13

Start-up Work Order Status

] Millstone 2 Progress: Performance is unsatisfactory.

1200 Data through 1000 -

12/28/98 n / Good 600-400- N 200-0 -

l Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar 98 98 98 98 98 98 98 98 98 99 99 99 lC Start-up AWOs (Pro}ects Subset) Start-up AWOs -m-Work Off/ Goal l l

hM Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 Stirimp AWOs Total 963 1016 993 992 994 827 886 840 690 Start up AWOs (Protecta l

Subset) 446 454 457 543 $10 513 567 502 337 l e Start-up AWOs 517 562 536 449 484 314 319 338 353 Work Oft / Goal 608 328 104 0

• U '^': -- AnetroinfAction This indicator depicts non-recurring and non-support The outage schedule has a Mode 4 date of February (scaffolding, shielding, and other 'OT' type) Automated Work 18,1999. This is roughly 9 weeks from December 28, Orders (AWOs) which the Unit has identified for completion 1998.

prior to Restart. The projects subset is provided only to Between 12/7/98 and 12/28/98,374 AWOs in the non-gauge the portion of the backlog which is attributable to recurring population were completed. The net for the design projects from the CMP effort. It is a subset of the same period was a backlog decrease of 149 AWOs.

trended Start-up AWOs. Progress is improving but is still unsatisfactory. The Unit must achieve a net decrease of 130 non-recurring This KPt does not include AWOs awaiting Post Maintenance AWOs/ week (completed minus new) to meet the February Testing (PMT) or closure. 18 (Mode 4) goal of zero.

Actions put into place to ensure the work-off rate is met Restart is defined as ' Ready to enter Operational Mode 2'. include: 4 week look-ahead of the schedule to get AWOs ready to work; schedule review and buy-in by all groups NOTE: Date is updated on Mondeys supporting the outage; addition of parts support personnel; and addition of a multi-discipline team to work Turbine Building restart AWOs. Other actions in progress to ensure the work-off rate is met include addition of significant resources to handle the MEPL/PMMS ID backlog, and moving some Rapid Response MEPUPMMS ID and Procurement Engineering adjacent to planning.

The backshift is staffed as required to support increased production.

All AWOs within the start-up backlog will be completed prior to restart, or approved for deferral as on-line work or future 9 eutage work. The startup backlog will be assessed prior to cach mode change to ensure all required AWOs are implomonted in the appropriate mode.

Dets sowoe S. Tnpp x5923l Anafreds by: S. Tnpp x5923l Owner- J. W. Riley x4337 A-14

4 i

On-Line Work Order Status Millstone 2 j Progress: Progress is tracking to satisfactory.

i 80

) = = = =

" E 500 - = l = =

Goal (total)s 500 Data through 400 12/28/98 i

i I1 i lI ll lI 111 O

Jan 98 Feb 98 l

Mar 98 Apr 98 May 98 Jun 98 t

Jul 98 i

Aug 98 t

Sep 98 i

Oct 98 I

Nov 98 I

Dec 98 l On-Line CM AWOs Total -e--Goal-On-Line CM AWOs l l Meer Ones Jan-98 Feb-98l Mar 98l Apr.98 l May-98] Jun-98 l Juk98 l Aug-98] Sep-98l Oct-98 l Nov-98 Dec-98

^

Data will be provided when P-3 schedule is implemented O l On4_lne CM AWOs Total 117 203 217 169 237 269 254 325 578 556 532 534 l'

Goal-On-Une CM AWOs 500 500 500 500 500 500 500 500 Soc 500 500 500 l Goal-PRA Risk Segneficant AWOs 350 350 350 35o 350 350 350 350 350 1 350 350 350 l

1 Denninen Anakele!Aeden This indicator depicts the number of Non-Recurring Automated The following actions will be taken to achieve the Work Orders (AWOs) which have been deferred until after 500 limit for this indicator:

Restart with the unit On-Line. The portion of these AWOs I associated with Probabilistic Risk Assessment (PRA) risk 1) The WIN Team will continue to work off a significant systems or components is also id8ntified. portion of these deferred items.

PRA Risk Significant systems are systems required to protect 2) AWOs will be identified and echeduled in the 12 the reactor core or mitigate the consequences of an accident. week rolling schedule for completion prior to restart.

Recurring AWOs (Surveillances and Preventive Maintenance) are not included.

Restart is defined as ' Ready to enter Operational Mode 2'.

Geef Cessments The goal is to have s 500 total on-line AWOs at restart. Of NOTE: Data is updated on Mondays these, no more than 350 will be PRA risk significant AWOs.

%./

Date Sounor S. Trtpp K5923l AneWes by: S. Trtpp E5923l Owner: J W Riley x4337 A-15

l 4

'b Temporary Modifications Millstone 2

Progress

Progress is tracking to satisfactory.

j l 35 Data through 30 -

12/28/98

1. 5' Gc ad 20- Y 15- Goals 10 at $ i eta 4 l 10 - - - -

3

5-0 i i l i l I i i 1 i I j Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar 98 98 98 98 98 98 98 98 98 99 99 99 l Temp Mods Outage Support -e-WorkOff/ Goal -hGoall

]

MM j Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 90 Oct 98 Nov 98 Dec 98 Jan 99 Feb99 Mar 99

} , Temp Mods 17 17 16 16 16 14 12 12 10

4 OutsDe Support 9 15 9 10 10 8 7 7 6 Total insta4ed 28 32 25 26 26 22 19 19 16 f WorkOff/ Goal 25 27 23 25 20 23 19 19 15 9 8 8 4

Goal 10 to 10 to 10 10 10 10 10 to 10 10 DeNndalen AnalyeWAcdon j This indicator depicts the total number of Temporary There are 16 TMs installed on the plant, all have been Modifications (TMs) to permanent plant design, and the installed greater than 6 months. The 6 ' Outage Support *

- portion that are ' Outage Support' (directly tied to physical Temp Mods will be removed prior to restart.

work to plant equipment in an outage condition).

The Unit 2 Recovery Team has captured the Temp Mods in the work schedule to track their successful resolution. The A temporary modification is a modification to the plant that is short-term in nature and not part of the permanent latest work-off curve has the Temp Mods being resolved plant design change process. with eight remaining post start-up.

Restart is defined as ' Ready to Enter Operational Mode Actions to improve performance indicator 2*, - Improve physical work performance (schedule adherence).

- Outage Recovery Team assistance.

Geel Canunents Unit 2 has a goal of s 10 installed temporary modifications at Restart and none > 6 months old.

t

%J Os8s Sounce W. Woolery x0698l Anstyeds by- W Woolery x0698lOsmer: M J Wilson x2081 A-16

1 O Control Room and Annunciator Deficiencies Millstone 2 Progress: Progress is tracking to satisfactory.

50 _

Data through 12/28/98 40

.E Good N* l I lz 20 t 1

\

h Goals 10 at rest &rt 0 t i I 1 1 I i i t i I l

Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar  !

98 98 98 98 98 98 98 98 98 99 99 99 l lMWaiting Solution C"] Awalong Retest - e-Work Oft / Goal -*-Goal l newDan Apr-98 May-98 Jun-98 Jul-98 Aug -98 Sep-98 Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Ma -99 O Closed New Awaiting Retest 11 5

2 7

12 7

15 16 8

11 11 11 14 14 11 17 5

10 11 14 6

8 7

9 13 9

5 Warhng Solution 39 39 39 37 37 26 33 29 29 Total Dehciencies 41 46 47 48 48 36 39 38 34 Worit Off! Goal 37 41 39 40 43 37 37 33 34 17 12 10 Goal 10 10 10 10 10 10 10 10 10 10 10 10 Do6nition AnalysiafActiers This indicator depicts the number of Control Room and Nine CRP Deficiencies were generated and thirteen were Annunciator Panel (CAP) deficiencies that exist. resolved during the month of December. Fourteen of the CRP deficiencies are greater than six months old. Five of CRP deficiencies are control room instruments, the items being tracked are awaiting Retest and will be recorders, indicators, and annunciators that function removed upon successful completion of the retest or when improperty and could affect the ability of the operators plant conditions permit the retest. Eight CRP Deficiencies to monitor and control plant conditions. either have EWRs resolving the discrepancy or are awatting Engineering direction.

Restart is defined as ' Ready to enter Operational Mode 2* The number of deficiencies scheduled to be worked will allow us to meet our goal at start-up.

Actions to improve performance indicator:

- Improve physical work performance (schedule adherence),

- Outage Recovery Team assistance.

Geels Commente O Operations has a goal of < 10 CRP Deficiencies prior to restart and none > 6 months old.

Dess source W Woolery x0698l AnstysJe by: W Woolery10698l Owner: M J. Wilson x2081 A 17

n d Operator Work Arounds Mllistone 2 Progress: Progress is tracking to satisfactory.

25 Data through 12/28/98 N Good 1 - _ _ _ _ _ _

0 t i I i l i t t I t t Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar M 96 M 98 98 M 98 98 98 W 99 W l - W/As > 6 Mos. Old M W/As < 6 MOs. Old -e-Work Off to Goal + Goal l Row Date Apr-98 May 98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Jan-99 Feb-99 Mar-99 W/As > 6 Moe Old 16 16 12 16 16 16 17 16 16

% W/As < 6 Mos Old 5 5 5 1 1 1 0 0 0 Total Operator W/As 21 21 17 17 17 17 17 16 16 Work Off to Goal 21 21 17 17 17 17 15 15 14 12 10 10 Goat 10 10 10 to 10 10 to 10 10 to 10 10 Definition AnalyelalActka i Operator Work Arounds are conditions which require an All 16 of the open operator burdens identified have been operator to work with equipment in a manner other than on the list for greater than 6 months.

original design intended.

Plans are in place to resolve Operator Burdens such that Operator Work Arounds can: the start-up goalis achieved.

1. Potentially impact safe operation during a plant transient

2. Potentially impose significant burden during normal Management will continue to analyze the aggregate of all operation the items on the Operator Burden List and their effed on

3. Create nuisance condition due to recurring equipment the safe operation of the plant.

deficiency

4. Distract an operator from noticing a recurring condition Actions to improve performance indicator:

- Improve physical work performance (schedule it is desirable to have a small number of operator work adherence),

crounds, and to limit the time such work arounds persist. Outage Recovery Team assistance.

Restart is defined as " Ready to enter Operational Mode 2",

which is the point at which Commission approval is required.

Gon! Commente The goalis to have no more than 10 Operator Work Arounds prior to Mode 2.

Data Soures: W Woolery x0698l AnalysJs by: W Woolery x0698l owner M J Wilson x2081 A-18

a 4

i

Procedure Upgrade Project Status 4

Millstone 2 l Progress: Progress is tracking to satisfactory.

! 80

$ 70 12 j o l l l i I I i 1 i l l i Jan Feb Mar Apr May Jun Jul Aug Sep Oct ibv Dec j 98 98 98 98 98 98 98 98 98 98 98 98 l Procedure Upgrade Project -e-PUP Work Oft / Goal l Aleer Osts Jan-98 Feb-98 Mar-98 Apr98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 O

Dec-98 Procedure Upgrade Pro 4eci 78 69 64 83 62 53 42 27 19 13 11 11 PUP Work Off/ Goal 75 89 63 57 So 43 36 29 22 15 11 11 N AnstedWAcidon This indicator depicts the number of technical procedure The Unit 2 PUP initially identified 1258 technical revisions that must be completed prior to restart, in procedures which needed to be upgraded. At the accordance with the Millstone Procedure Upgrade Project beginning of 1998,1172 procedures were completed and (PUP). 86 remained in process. As of December 31,1998, 1247 (99.1%) procedures were complete and 11 The goal of the Millstone PUP is to improve the technical remained in the revision process. The Unit 2 Centralized quality and usability (human factors) of procedures to Procedures Group (CPG) have all of the remaining reduce human error and enhance plant reliability. procedures drafted and in the process of technical reviews, verification, writer's guide review, validation, or Restart is defined as " Ready to Enter Operational Mode 2". safety and environmental screening and are scheduled for completion.

_Goel Commende The goal is to complete all PUP revisions to technical procedures prior to Unit 2 restart.

OsasSeeroe W.J Challant uS416 l Analysis by: W.R. Watson u6245l owner- W. R. Watson x6245 A 19

Restart Required Procedure Revision Backlog Millstone 2 l Progress: Progress Is tracking to satisfactory.

1000 l l

Data through 800 12/31/98 ,

700 e00 y Good 500 Y

300 200 100 0 t I l I I I I I f I I Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar 98 98 98 98 98 98 98 98 98 99 99 99 l Total Mods and PUP Remaining -se--Month End Goal l b Chts Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 oec-98 Jarw99 FotF99 Mar-99 Procedure Mods Compkte 133 276 210 91 122 259 223 221 204 Emergent Promdure Mode 50 104 125 85 211 173 12 315 151 Total Mods and PUP Remaining 995 873 738 732 821 735 524 618 565 Month End Goal 823 738 732 821 716 531 565 445 298 151 0 C ^:.2':; + ;.,aa'Achon This indicator depicts the technical procedures which have in June,1997,711 procedures were identifed as been identified to have deficiencies and are scheduled to needing modification prior to restart. As of December be completed prior to Unit 2 restart. The Unit 2 31,1998 the total identified has increased to 3.260.

Centralized Procedures Group (CPG) has completed documentation and scheduling of the identified procedure These procedure modifications are scheduled for modifications. The Unit 2 Configuration Management completion based on the neec' for the procedure (e g.,

Project (CMP) discovery phase has documented a large plant physical work, surveillances, or unit mode quantity of procedural deficiencies in addition to those requirements).

deficiencies identified by other Millstone 2 departments and the Centralized Proceduras Group (CPG). Additional Additional management attention is being applied. A requirements are still being identified due to procedure thorough review for scope control in accorderce with 2-usage and the continuing intensive procedure reviews by U1-1.04, 'AITTS Assignment Screening Process' these departments. Attachment 2. "Deferabliity Screening

• is on-going. The placement of procedure modifications into the unit's Restart is defined as " Ready to Enter Operational Mode

• Plan of the Day' schedule willincrease management's 2*. focus on procedure modifications. The Procedures Steering Committee was formed in early August,1998 to provide additional assessment and is recommending additional streamlining and prioritization of procedure modifications.

Gesi Contenants l The goalis to complete all Unit 2 Restart Required The November 1998 increase is due to changing the Technical Procedure Revisions prior to restart. schedule completion date from 12/31/98 to 2/12/99, resulting in an increase in scope (i.e.,18 month murveillancet)

Dude Source W J Chaffant x6416 lA @ by: W R Watson x6245lOernor- W R Watson x6245 A-20 l

I o

l l

/

l l  :

i i i i

l o Nuclear Oversight ,

Indicators

Status of Oversight Condition Reports Millstone 2 - December 1998 Progress: Progress is satisfactory.

50 40 g Data thru 12/27/98 to I

Good 10 0 l I "! I t i I i I l i Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 98 98 98 98 98 98 98 98 98 98 98 98 WLevel 1 CRs >30 days old without approved CA Plan Elevel 2 CRs >30 days old without approved CA Plan Meer Oste Jan-98 Fe498 Mar-98 Apr48 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov 98 Dec-98 Total 1&2 >30 days 18 4 2 21 9 5 3 13 9 3 9 5 Open 23 20 21 44 22 18 15 31 29 19 19 14 L1/>30 days 1/1 0/0 2/0 3/1 1/0 2/1 1/1 3/1 Or0 1/0 0/0 1/0 L2/>30 days 24/17 20r4 19/2 41/20 21/9 12/4 14/2 2&S 299 18r3 16/9 13/5 Dn6nhion AnelveiefAction This graph displays the status of open Condrhon Reports Performance is satisfactory.

(CRs) initiated by Nuclear Oversight for adverse, discrepant, or other condmons needing improvernent .

An Open Condition Report is one for which the evaluation for reportabihty and operabildy. failure mode and/or root cause has not been performed, or, has been performed, but not yet approved.

Gent Commente No Level 1 or 2 CRs open > 30 days without approved extensions.

f

\ Does Source: M Baldant s4456lAnalyske by: J Beaucherno X2113lOsmer/ R NocciX5739 B-1

Nuclear Oversight Verification Plan Results lO Millstone 2 Restart Readiness Progress

Engineering processes have improved. However, engineering product quality improvement is still necessary. 40500 Readiness is satisfactory. However, weakness continues to be noted in the area of corrective action effectiveness. Continued improvement in Engineering,

Corrective Action, Procedural Quality / Adherence and Fire Protection is necessary to l demonstrate restart readiness.

l Keyissues 7dO48 8 4/98 $N1M 104/98 11 4/98 12M98 1mte i

I Work Control Y Y Y Y

! noen Y Y Y Y Y

~

Corrective Action i Y Y Y Y

~

SelfAssessment l Procedural Quality / Adherence Y Y Y Y Y l Otherissues 7h048 84/08 $N148 19448 114/98 12MOS 1/7/98 __

Meineenance Health Physics Y Y

~

l' ire Protection Y- Y Y Y Y Y ll Inspection Readiness Y Y 08T1 Readiness Evolustion has not begun.

Power AscensforVMode Change' Y Y Y Y Y Common Site Programs ent/te 104/08 11 4/98 12Ab/OS 1/7/98 _ _

Security M84/B0 I2"L"e-----------_. __

En@onmengMonito@g___ __

OrganizationalRealignment Evolustion has not begun.

l DonnNien Each of the above listed issues are essessed beood on a set of attributes derived from NU,INPO and NMC documents which Provide standards, otgectives and inspec#on guidance in generel, the color corresponde to following scores. Colors will normally change sher two periods of consistent performance

'All 84 ode Change issues must be addroceed to be rated above Yellow.

? -- " A y (GREEN) l l Tracking to Satisfactory (YELLOW)

S';te a Weekness (RED)

Not Assessed (SLUE)

Onee Sowee: Asesened Leedo l Anolyele by: Asebened Leade lOenner: R. Nocci B2

i, iO i

i l

l l

1 i

l lO Additional l

i ndicators i

O

l l

O i

4 i

i l

a

< j i,

l O Procedure Compliance  !

1 and Quality Indicators l 1 I i l t \

\

i l

i .

t ,

)

i O

1 l

l 1

Procedure Compliance l Millstone 2 1 The Procedure Compilance goal has been achieved for each of the past 8 Progress: months, and shows a steady trend.

0 60 5  :  :  :

Goals 0 $ I

" #0~

08ta through 12/31/98 I

C 00 l I f f f f I f I t 1 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 98 98 98 98 98 98 98 98 98 98 98 98 l Total Non-Comphance Errors /1000 Hrs -el-Tot Non-Comp Err /1000 Hrs-3 Mo. Rolkng Avg -G-Goal l ASSIf M Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov98 oec 98 Total Non % -

l Enora/1000 Hrs 0.567 0.419 0.500 0.423 0.237 0.370 0.200 0.322 0.230 0.214 0.225 0.305 l Tot. Non. Comp. Eart1000 Hrs-3 Mo. Rollhg Avg. 0.412 0.438 0.528 0.478 0.404 0.338 0.364 0.293 0.251 0.295 0 225 0.252 Goed 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 Techncal Procedure Non-Comphance/1000 Hrs 0 064 0 047 0 078 0 053 0 062 0 087 0 075 0 056 0 079 0 070 0 078 0 208 Admm Procedure Non-Comphance/1000 Hrs 0503 0 372 0 502 0 370 0 175 0 283 0 125 0 265 0 159 0.144 0 147 0 098 Hours Worked (1000 hrs) 125 320 128 972 179 425 189 229 211 113 172 958 199 691 177 268 189 128 201 113 204 720 245 670 Techncal Procedure Non.

Compliance Errorn 8 6 14 10 13 15 15 10 15 14 16 51 Adminstratrve Procedure Non-Compliance Errors 63 48 90 70 37 49 25 47 30 29 30 24 Total Non-Comphance lsauen 71 54 104 80 50 64 40 57 45 43 46 75 CJ: , Anetyele!Achon This indicator represents the procedure non-compliance rate per Progress is good in this area and continues to 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> worked. Procedure non-compliances are segregated improve. Current human performance initiatives are into 2 categories: non-compliance with technical procedure- expected to sustain this trend.

these errors are associated with operational or maintenance procedures or work orders and are gener8 tly continuous or general The increase in technical procedure non-compliance tvel of use procedures; non-compliance with administrative errors during the month of December is due to a procedure-these errors are associated with a non-compliance with change in the basis for selecting a procedure non-s.n administrative or program procedure and are generalty level of compliance trend code. It is not indicative of an use procedures. increase in personnel errors.

Total Non-compliance error rate is calculated based on the total of tdministrative and technical procedure violations per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> worked.

Goel Comments f The goal is for procedure compliance errors as identif wxi in condition reports (CRs) to be s 0.5 errors per thousand hours Contractor hours are included as of Janaary 1998.

worked, usen sowee: ATTTS l Analysis ey: S V Heard E5600lownen S V Heard x5600 C-1

O V Closed CRs involving Deficient Technical Procedures Millstone 2 Progress: Progress is satisfactory.

10 8-Good y 6- Goals 5 per month d* Data thrcugh 12/31/98 2-V o i I I I I i I I i i i Sep 98 Oct 98 Nov 98 Dec 98 Jan 99 Feb 99 Mar 99 Apr 99 May 99 Jun 99 Jul 99 Aug 99 l Upgraded Procedures -in--Goal l Aser Osde Sep-98 Oct-98 Nov-98 Dec-98 Jan-99 Feb Mar 99 Apr 99 Mey-99 Jur>99 Jul-99 Aug-99 j' Upgraded Procedures 3 1 1 o gj Goal 5 5 5 5 5 5 5 5 5 5 5 5 Cf ^^^ ; _

Ane&nde/ Action This indicator depicts the number of conddion reports (CRs) For the months of Septernber through December 1998, the that resulted in procedure deficiencies. A review to total number of procedure related CRs for Unit 2 was determine N procedure technical content influenced the below the goal of no more than 5 s. CRs per month initiation of the condition report is performed on CRs involving initiated as a result of procedure deficiencies. In technical procedures from the following departments: September 1998, three CRs were a result of procedural Operations, Maintenance, Instrument and Control, deficiencies, whereas only one procedure deficiency Engineering, and unit specific Chemistry and Hea4h Physics related CR occurred in both October and November 1998.

procedures.

CRs involving administrative procedures and failed administrative processes, such as docurnent distribution and reproduction, are not included in the review and are not represented by the above data. Also not included are Emergency Operating Procedures (EOPs) and Abnormal Operating Procedures (AOPs), which are not included in the Technical Procedure Upgrade Project.

Goat Comments The goalis to have s 5 CRs per month initiated as a result of

! procedure deficiencies.

Does soune ArrislAns&ede by: B. Luce x 2094l Owner- T. Kirkpatrth x 62o4 C-2

i 1

i IO i

1 i

)

i a

4 i

i.

3 i

i i

i i

O d

Additional Work Control i Indicators i

)

O

l i

y Overdue Preventive Maintenance AWOs Millstone 2 l Progress: Progress is satisfactory '

70 --.

60<

a i 40- I i

M

' l l

< ,0 t '

E I 10 .

• d 0 ^ * " " B " - "

g s* l k

$ e n

g

- e lm Overdue PM AWOs l l

j MM '

l 10/92/98 10/1fF98 10/26/98 11/2/98 11/9/98 11/16/98 11/22/98 11/30/98 12/7/98 12/14/98 12/21/98 12/28/98 Overdue PM AWOs 29 32 29 24 16 2 2 5 3 1 0 2 4 Osaneion Anafree/Acelos This indicator depicts the number of preventive maintenance WPOM focus on Overdue PMs, with the support provided (PM) automated work orders (AWOs) which are NOT by l&C, CBM and MNTC, has resulted in excellent gains con'pleted PRIOR to the PMMS Required Completion Date, on this KPl. Unit focus on overdue PMs will continue to

These AWOs include 1-Page ' routine" PMs. drive and maintain this KPl at Zero.

Restart is defined as ' Ready to enter Operational Mode 2".

J l

Geef C_- - -. _ . .Z The goal is to have zero overdue PM AWOs prior to restart. NOTE: Data is updated on Mondeys Does Sowre D. Knopf x6174l Anedrede by: D Knopt x5174lOsmer- J W. Riley x4337l D-1

i

!O l

i i

i i

~

l l Safety Conscious to l

4 i

Work Environment Indicators l

l 4

i i

10 i

i i

1 Safety Conscious Work Environment l O

O Employees Willingness to Raise Concems l NU Concerns and NRC Allegations Received, Millstone Station i Progress: Performance is satisfactory. The number of allegations to the NRC remains at j l a low level while the number of concerns received by ECP is high.

4o . _ _ .

36 Data current 30 through 12/31/98.

25 4' 8 80 -

15 l

l 10 0 2  ;-

l Jan 98 Feb 98 Mar 98 Apr 98 Mey 98 Jun 98 .M 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 l NU Rec'd -e-NRC Rec'd l l

l ^ ~" v}ik:: Qik Q:::biQfQQQ[?QQ@T,$@fQ @dQ W%ffQpWFkdQ;%Q%ffyQ,QQ:AQ} ".

l Jan-ge Fet> 98 Mar-98 Apr-SS May-98 Jun-98 Jul-OS Aug-98 Sep-e8 Oct-98 Nov-98 Dec 98 up eet.es rr se as as 17 1s to as to 17 to as o.

(j

.c e,.e.

NU Rec'd YTD 27 s

47 70 to 107

. s 125 144 106 1a5 o

2o2 22o 246 NHC Rec'd YTD 4 1o 14 18 2o 25 26 26 as 28 3o 32 l

7 """"5jQyg;{ w r-

@)T'TU""*5Df(@,7 f This indicator depicts the number of concems received sedi The increasing number of concoms submitted to the ECP )

month by the Millstone Emp6oyee Concoms Program (ECP) suggests growmg empioyee conf 6dence in the abHity of j relative to the number of milegations associated with Millstone the Mikstone ECP to provios an effective means by which lesues or problems which have been submitted to the NRC concems can be resolved The average number of during the same time period. concems received per month in 1997, was 16. The I average number for 1998 was 21, a 31% increase over l The Millstone Employee Concems Program (ECP) accepts the 1997 average.

I concems related to a wide variety of issues, including nuclear j safety or quality, management, industrial safety, security and Twenty six concems were rewived by NU during other topics. Concems may be submitted by current or former December. Nine of the 26 new concoms received were employoos and contractors. NRC allegations reportsng reisted to the MiRetone Reakement Process. Two Millstone issues may be submitted by the general publ6c, Millstone ."qn-is were received by the NRC in that current or former employees and contractors or members of the same month.

NRC. Concems may also be filed concurrently with the j Muistone ECP and the NRC in the same time period, bqggi:6 ,6:3e g: " r QwU9 m W , fx , , pg siy " - ' w 4 M 4 NU has not octabhehod a epoc2c goal wHh roepect to concems M* e ; rent through 12/31/98.

received However, it is desirable to have a relatively sman I

number of aNegat6ons submitted to the NRC as a measure of employee confidence in the various NU resolution systems.

Performance Plan C.2.c.

Supports SCWE Success Criterion #1

a. _ __ iae.b o__. 7 a__

l E1

l l

l l

l Millstone Employee Concerns Confidentiality Trend

/3 Millstone Station lN/

Progress: The wittingness or employees to raise concerns is satisfactory. Approximatly 37% of ConcernedIndividuals requested confidentiality or filed anonymously for 1998.

I 40 35 Data current through 12/31/98. j l25  ;

o,.a

, . 4 0

v/ 5 Jan 98 Feb98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 l -*-Total Received --e- Anonymous and Confidentiality Requested l m 21 y 1 - o ,

, Jan Feb Mar Apr May Jun Jul Aug Oct Nov Dec

/ Total Received by thenIh 27 20 23 Se 17 1s is 22 15 17 1s as

, Anonymoue 7 3 s 7 2 s s 4 3 2 s s C 1. - - 2, " , 3 s e 2 1 3 s 2 3 3 3 s Conhdenhahty WeNed 17 12 17 11 14 10 8 16 13 12 10 16

% Anon and Conhdoreshty Req 37 o% 40.0 % 28 1 % 45 0% 17 6 % 44 4 % 579% 27.3% 31 8 % 29 4 % 44 4 % 38 5 % i This indicator depicts the number of concems which are reported to Approximatty 37% of concems have been filed the Millstone ECP anonymously, and those for which confidentiality anonymously or filed requesting confidentiality since the b requested, relative to the total number of concems received. beginning of 1998. Based on the Decernber 1998 numbers, the percent trend appears to be level. ECP l Each indtvidual submitting a concem may request or waive monitors this closety for any adverse trend. l confidentiality. Anonymon concems are also submitted.

Ten of the 26 concems received in December were Concems requesting confidentiality or anonymity are reviewed to either anonymous or requested confidentiality. Nine of determine (1) if there is a significant change in either the number or the 26 new concems received were related to the percentage of concems filed anonymously or requesting Miastore Renfignment Process.

confidentiality, (2) If any categories show discemible ctianges in make-up or source of the concems, and (3) If any new " locus areas" are identified.

3;e( y;g ,;~ ,

The goal is to show no adverse trends in requests for confidentiality Data current through 12/31/98.

or anonymity, based upon an anstysis of the concems and data.

Performance Plan C.2,a.

/g 4 J Supports SCWE Success Criterion #1 I nees soww C uinamo a4541up l Analyede by: C f#eko a4541MP l owner: T. Burns a4335M l

u l

l

4 l

Employee Concerns Resolution Timeliness Q:

l Millstone Station 4

?

, Progress: Progress is satisfactory. The improved timeliness of employee concerns resolution achieved during the past year is being sustained.

s0 1

1 1 60 '

Data current through 12/31/1998.

40 -

30 - -

20 - lf 10 -

l 0

Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec ,

97 98 98 98 98 98 98 98 98 98 98 98 98 l l E Avera9e ADe l i Dec 97 Jan 98 Feb 98 Mar 98 Apr 98 May 98 JunOn Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Averego Age 41 42 40 54 47 45 23 27 32 28 SS 25 32 Open < 45 Days 32 30 24 21 19 13 15 12 13 17 16 15 27 Open > 45 Days 13 20 24 20 12 7 3 5 8 5 1 3 9 concems Under invesugation 45 50 48 41 31 20 18 17 21 22 17 18 36 m<

i y a, .

This indicator depicts the average age of concems under The average age of concems under investigation has stayed investgation. Concems under investigation represent below 45 days since May. The average age of completed Employee Concems Program (ECP) work in progress, ECP investigations for December is 32 days.

including data gathering and analysis.

m 1.is Data current through 12/31/1998.

^ '

4 e The goalis for the average age of unresolved concems to show no adverse trend. Performance Plan item C.C.c.

Supports SCWE Success Criterion #3 Data Source C. Mahoto n4541 MPl A@ by- C Mihalko x4541 MPl Owner- T Bunu m4335MP E-3

Q Focus Area Action Plan Status Millstone Station Progress: Progress is satisfactory. Resolution of all focus areas is proceeding as expected.

15 10

[I,1,1,1,I.I,II,I,I,Ie

~ '

t g g e e e e e e e e e g

e e  ! l

6 e

e e

l l-6 e

E e

3 B

3 S

lEOpen Focus Areas l JIIHe Oste 10/15/98 10/22/98 10/29/98 11/5/98 11/12/98 11/19/98 11/26/98 12/3/98 12/10/98 12/17/98 12/24/98 12/31/98 open Foous Areen 5 5 5 5 5 5 5 5 5 5 5 3 Overdue Assion Mene 0 0 0 0 0 0 0 0 0 0 0 0 Focus Areas 33 33 33 33 33 33 33 33 33 33 33 33 Action Plans in Place 5 5 5 5 5 5 5 5 5 5 5 3 Action Plans Completed 28 28 28 28 28 28 28 28 28 28 28 30 )

Actzn Plans To Develop 0 0 0 0 0 0 o 0 0 o 0 0 DeNnnien Anakede/Acelon This indicator depicts the number of focus areas currentty identified Review of the November 1998 Leadership Assessment and and the status of action plans to correct identified weaknesses. A December 1998 Culture Survey resutted in satisfactory Focus Area is defined as an area of personnel interaction where a assessment of two Focus Areas. These Focus Areas are closed.

Safety Conscious Work Environment is challenged or does not exist. Three Focus Areas remain open and plans are underway to deve,op actions to address the remaining issues.

The following indications are used to identify the Focus Areas within the Millstone organization:

• Lcadership Assessment score less than 4.0 (" Effective') in either the Employee Concems area or the Overall score.

• Significant incidents e Surveys e Pil Cutture Survey - The Safety Conscious Work Environment characteristic score is less than 3.0 ("Generalty Agree *) and l

is substantiated by a second indicator, o Employee Concems Program - Significant or multiple Canunones '

occurrences within an area which are substantiated by a l second indicator.

• Employee Concems Ovemight Panel - Significant or multiple occurrences within an area that are substantiated ty a ,

second indicator. Geef

• Independent Third Party Oversight - ,dentrfied areas based on The goal is to have the number of problem areas steady or l

{ l Investigation. declining with no overdue action plans.

' NRC - identified areas based on investigation.

Supports SCWE Success Criterion #4 Does seurwe: A Dms x5388MPl AWAe by: A Dms x5388MPl Owner: D B Amenne XO437MP i

E-4 t

Substantiated Concerns involving C Potential Violations of 10CFR50e7 Mllistone Station i Progress: Performance is satisfactory. There were no substantiated concerns involving

, potential violations of 10CFR50.7 since August 1997.

l l 40 Data current 30 through 12/31/98. 1 25 -

I

_ good

),.. l 10 y I S-0  ;  ;  ;-

Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep98 Oct 98 Nov 98 Dec 98 8 Subelantated Potental 10CFR50.7 Concerns -G-TotalConcems Received - ilr-# AAsged 10cFR50.7 HIRD Concems w* ,,y p 99e ,

,~ n y, ,

y,;;- s 1

,g , p.4 , ,

, a Jerv98 Feb-98 Mar.98 Apr.98 May-98 Jurw98 Jul-98 AuD-98 Sep-98 'Oct-98 Nov.98 Dec-98 3 .._

8 aReasd 1.CFHg. 7 HNto concerne 8 substanthead Patential 1.CFR8. 7

1. 7 4 3 2

1.

4 1 .

1.

,7 1

18

.8 2

- . . . . e . . . . . . .

i Total s of HIRD Concems Recewed 18 11 11 to 4 7 7 7 2 9 8 11 l

% HIRO Concems 59 % 55% 48 % 50 % 24% 39% 37% 32 % 11% 53% 33% 42 %

% Alleged 10CFR50 7 HIRD Concoms 37% 35% 17% 1L% 12% 22% 5% 0% 0% 8% 0% 8%

j

- ^ - -

, y .p 'gir , ' - - - - , s , $

i This indicator depicts the number of concoms received by the Millstone A conservative classification criterion is used to Employee Concems Program (ECP) alleging cases of Harassment, categorize and lavestigate alleged 10CFR50.7 HIRD Intimidation, Retaliation or Discrimination (HIRD), including those based issues. Importantly, since December 1,1996, only l on race, sex, and national origin. It depicts the nurreer of potential and three concems have been substantiated as involving a substantiated HIRD concems invoMng alleged 10CFR50.7 violations potential violation of 10CFR50.7, and all three are relative to the total number of concems received. related to a single event (MOVs). Two alleged 10CFR50.7 concems were received in December 10CFR50.7 ts a federal law which provides for the protection of 1996.

l individuals engaged in protected activities. An example of a protected actMty is when an individual identifies an issue that he/she believes Open 10CFR50.7 concems receive the highest impacts any aspect of actMties at the Millstone Site that are regulated investigative priority. Site rnanagement continues to by the NRC, and communicates that concem to co-workers, educate, address and when appropnate, discipline any l supervisors, the Employee Concems Program (ECP), the NRC, personnel involved in such actMties.

l Congress, or the media.

Nine of the 26 new concoms received in December were related to the Millstone Realignment Process.

"% _ iM M w <

, , y y Substantiated concems invoMng potential violations of 10CFR50.7 are Data current through 12/31/96.

~ infrequent and handled effectively. Performance Plan C.2.d Supports SCWE Success Criterion #4

( Dass asense C. nahalko n4541 WP l Anakeds br- C ue. koi4s41 uplainier- T sums s433sMP t

E-6

Q Leadership Assessment (SCWE Element)

Millstone Progress: Progress is sa."sfactory. The November 1998 Leadership Assessment {

results indicatt. that the goal continues to be met.

d 1

0.9 -

0.8 Goal290%

f0.7-06-

=05-r A 0.4 -

l 0.3 - Good j 1 0.2 -

0.1 -

0 Jun Jul Aw; Sep Oct Nov Dec Jan Feb Mw Apr May Jun Jul Aug Sep Oct Nov Dec 97 97 97 97 97 97 97 98 98 98 98 98 98 90 98 98 98 98 98

(  % Employees Willing to Raise issues to Mgnt. Leadership Goal l newone Jun 97 Nov 97 Jun 96 Nov 98 e % Employees Wilhng to Rasse lasues to Mgnt 97.8 % 97.9 % 967% 96 6 %

Goal 90 0 % 90.0 % 90.0 % 90 0 %

DnRn6l ion AnalyelelAc60n This indicator depicts the percentage of supervisors who The November 1998 Leadership Assessment results werw rated as either effective, very effective, or indicate that the goal continues to be met, although extraordinary in their handling of employee concems. there was a slight decrease. This is being evaluated in light of the leadtership re-alignment process.

This indicator is considered a valuable data point in evaluating the confidence and willingness of Millstone The schedule for the performance of next Leadership employees to raise issues to their supervision. It is used in Assessment is fall 1998 with annual assessments conjunction with other similar indicators as evidence of the there after, presence and strength of the Millstone Safety Conscious Work Environment.

Gael Conwnents The Goalis z 90% of the employees surveyed to report a Data is current through November 1998.

willingness willing to raise concems to their supervision.

Supports SCWE Success Criterion #1 OstsSowee: L eadership Assessment l Analysk by- M Gentry xb728MPlOwrier: M Gentry x5728MP E4

.(^) Culture Survey (SCWE Element)

Millstone i Progress: A slight decline in the Indicator was observed in the December 1998 Culture Survey. Performance is stili considered satisfactory.

1 0.9 -

Goal290%

{ 0.8

., 4 0.7<

f06< j 0.5 -

l

, 0.4 '

Good 0.3 -

, p 0.2 -

l 0.1 -

. 0<

l Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jtd Aug Sep Oct Nov Dec 97 97 97 97 97 97 97 98 98 90 98 98 98 98 98 98 98 98 98 lM% Employees Agree That SCWE Exists Culture G0all MM Jun-97 Nov-97 Jun-98 Dec-98

% Employees Agree b That SCWE Exists 82.0% 82.0 % 88 8 % 84.7 %

Goal 90.0 % 90.0 % 90.0 % 90 0 %

Dennnlion AnekoielAenen This indicator depicts the percerMge of employees The December 1998 survey value of the indicator falls surveyed, by means of the Pil Cutture Survey, who rate short of the 90% goal by 5.3% and has declined from their work environment as conducive to raising and the June 1998 survey value (86.6%) by 2 A% The I resolving concerns, trend over the last 18 rnonths is posithre. Overall I performance is considered satisfactory. This is l This indicator is considered a valuable data point in corroborated by the performance in the employee evaluating Millstone employees' comfort with the current concerns area of the Winter 1998 Leadership concerns environment and their confidence in programs, Assessment.

peers, supervision and upper management in supporting a SCWE. It is used in conjunction with other similar The results indicate continued emphasis and close j indicators as evidence of the presence and strength of the monitoring of this indicator is appropriate to assure Millstone Safety Conscious Work Environment. continued good performance and progress toward the established goalof 90%

Ossi CommerWs The goalis for > 90% of the employees surveyed to report Data is current through December 1998, s a willingness to raise concerns to their supervision.

Supports SCWE Success Criterlon #1 Dode Sowse Culture Survey l Ansfysis by: E. Fries x 5458 MPlOsmer- A. Elms x 6388 MP E7

O j

O Leadership and l

Culture Indicators li

.I O l 1

i

Millstone Station Leadership Assessment Progress: AII categories are slightly up from the Winter 97 survey.

smenerenery 8.00 7.00 -

Mary unsettw 8.00 - -

nflM-f I:-l fF onenooton 1.00 -

no I

Communice6o Leadership Performance Development E Winter-96 O Summer 97 D Winter-97 E Summer-SS EWinter-se Employee Concerne*

OvereN Averego "

7 D

W W er96 Summer 97 Winter-97 Summer-9e Wwiter 98 O Communications Leaderstup Performance 4.77 4 95 4.42 5 61 5.77 5.29 5.75 5.88 6.34 5.74 5.84 5.31 5 82 5 92 5.42 Development 4.64 5.45 5 54 5.53 5 61 Employee Concems 6.11 6 19 6.15 6.18 OvereN Average " 4.70 5.70 5.80 5.78 5.84 De6nNon OpRnMen 'L '.. _- 3 The Leadership Assessment hs a management tool for evaluatinD The primary purpose of the Leadership Assessment is to the relative strengths and needs of indvidual management provide meaningful information to Millstone management j personnel at the Millstone Station, from first-line supervisor for the purpose of individual development. Although not a positions through the Nuclear Group CEO. A total of thirty-nine statistically valid survey tool, the results are also questions are posed to employees regarding leadership evaluated at an organizational level to trend improvement performance in four separate categories: Communications, in management performance.

Leadership, Performance Accountability, and Development; a fifth category for evaluating performance relative to Employee Concems Was added to the assesstrient in the Summer of 1997. Anebode/Acelen l Response are evaluated against an 8-point scale, with *1' Movement in the Leadership score is slightty positive. All representing ineffective performance, *2-3', indicating somentiaf categories continue to score as ' effective * (4-5), at a effective, '4-5* rated as effective, '6-7' depicting very effective minimum, with employee concems showing as 'very performance, and '8' representing extraordnary performance. effective" (6-7).  ;

Gent Commen.s The organizational goal is to show improving trends in all " This value is the numerical average of the individual categories. assessment questions not the average of the catego.y scores.

._ c.--. a. . .,, -, _w - . - -

F-1

h Millstone Station Cultural Survey

.\

^

Progress: Progress is satisfactory. Results from the December 1998 Culture Survey show a slight decrease in the Adjusted Culture Index. OveraII, the data indicates a sustaining of the positive culturalimprovement observed over the past 18 months. l i 25.00

}

) 20.00-i l

'5 ~

l Goal = 13.0 0.00 '

Jun-96 Oct-96 Jun 97 Nov-97 Jun-90 Dec 98 4 -

l 5 Adjusted Culture index

O 1

Jun-96 Oct-96 Jun-97 Nov-97 Jun-98 Dec-98 Adjusted Culture Inder 11.60 11.46 12.80 13.07 12.99 12.75

! Number of Participants 1026 1240 1487 1926 2104 1757 j Goal 13 13 13 13 13 13 Dennition AnalysinfAction _

NU originally contracted Performance improvement Despite the slight decrease (< 2%) in the Adjusted Intemational, Inc. (Pil), formerly FPl, to assist in the Culture index (Cl), analysis indicates a sustaining of the tssessment and improvement of nuclear organization at cultural improvement observed over the last 18 months.

the Millstone Station. A ' culture survey' was conducted Continued management attention is still required, to quantify employee responses on five critical factors especially in efforts to improve processes (predominately that Pil has determined have high statistical correlation the corrective action process and procedures). These to future organizational performance. The five critical areas showed significant declines in the December 1998 treas are: High Management Expectations via Strong survey.

Mission & Goals, High Knowledge & Skill Level, Strong The range of the Cl is 5 to 20. A Cl of less than 8 is  !

Lateral Integration, Simple Wort Processes, and Strong indicative of problem plants. A Cl of greater than 14 Self-improvement Culture & Program. The results of the indicates a strong probably of continuous improvement. j survey are used to construct the Pil " Culture index." Scores ranging from 10 14 are in a metastable range, This Culture Index (Cl) has been statistically indicating the need for continuous monitoring to assure demonstrated to have a strong correlation to future sustained performance improvement. The current j performance. Adjusted Culture Index of 12.75 places Milistone Station in the metastable range and continues to indicate sustained emphasis on improvement efforts and monitoring is fully appropriate.

Gent Conunents NU has established a goal to achieve an Adjusted CulturalIndex of 13.0.

o s. sown. cumure survey l Anseynis by: E. Fnes x 5158 MPl owner: A. Elms x 5388 MP F2