ML20203B262

Summary of 980106-07 NRC Senior Mgt Meeting.Watch List Removal Evaluation Factors Encl

ML20203B262
Person / Time
Issue date:	02/18/1998
From:	Tracy G NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Kilgore L NRC (Affiliation Not Assigned)
References
NUDOCS 9802240239
Download: ML20203B262 (102)

Text

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O Mou y- *a UNITED STATES l

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t NUCLEAR REGULATORY COMMISSION j WASHINGTON, D.C. 20666 4001 l

%, . . . . . p' Februaif 18, 1998 MEMORANDUM TO: Linda Kilgore Public Document Room LL-6 FROM: Glenn M. Tracy, Chief Regional Operations and rogram

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Management Section, OEDO

SUBJECT:

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SUMMARY

OF THE NRC SENIOR MANAGEMENT MEETING '

JANUARY 6 AND 7,1998 l Attached for public release is information regarding the NRC Senior Management Meeting held January 6 and 7,1998. Attachment 1 is a summary of the January 1998 NRC Senior Management M.Teting. The Watch List Removal Evaluation Factors are provided in Attachment 2.

Attachments: as stated

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{ ATTACHMENT 1 NRC Senior Management Meeting (SMM) Summary January 6 and 7,1998 Region 11 O

Following the June 1985 loss of feedwater event at Davis-Besse, one resulting NRC action was that senior NRC managers periodically meet to discuss the ,Mants of greatest concem to the agency and to plan a coordinated course of action. The NRC senior managers held their twenty-fourth such meeting in Region 11 on January 6-7,1998. The previous meeting was held in Region I in June 1997. The meeting in Region 11 was structured to review the status of the Watch List plants identified at the last meeting and to review the performance of other pisnts to determine if any changes should be made to the list of facilities which require close monitoring by NRC.

In preparation for the meeting, NRR and NMSS, in conjunction with the four regional offices,

] AEOD, OE,01, and RES, prepared background documents on the plants and materials n

LJ licensees to be discussed. Inputs for each operating reactor plant included a summary of the most recent SALP and SALP history, a discussion of current operating experience, current NRC and licensee activities, and performance indicator data. Data pertaining to safety significant hardware issues at the plants were also provided. Inputs for materials licensees included a summary of recent performance and activities, including significant areas needing improvement and potential challenges to future performance. This information was distributed t", meeting attendees prior to the meeting. It provided the basis for review and discussion of each plant's or facility's performance and for senior management identification of those plants and facilities warranting increased NRC attention.

In reviewing the vactor plants that have experienced significant performance problems, the NRC managers have set the folicwing categories of performance based upon plant actions to date to correct tra problems and to achieve improved operations.

Cateaorv 1. Plants emoved from the list of problem facilities.

Plants in this categor / havt ;aken effective action to correct identified problems and to implement programs for improved performance. No further NRC special attention is necessary beyond the regional office's current level of monitoring to ensure improvement continues.

Cateaorv 2. Plants authorized to operate that the NRC will monitor closs' P' ants in this category have been identified as having weaknesses that warrant increased NRC attention from both headquarters and the regional office. A plant will remain in this category l until the licensee demonstrates a period of improved performance.

Cateaorv 3. Shutdown plants requiring NRC authorization to operate and which the NRC will monitor closely.

Plants in this category have been identified as having significant weaknessee that warrant maintaining the plant in a shutdown condition until the licensee can demonstrate to the NRC that adequate programs have been established and implemented to ensure substantial improvement. The Commission must approve restart of a plant in Category 3 status.

NRC senior management will continue to hold mee? 7s to review the status of all reactor and the major nuclear materials licensees on an approximate six-month frequency, though the ongoing review of the NRC's performance assessment process may result in a revised process in the near future. Recommendations will be made during those meetings to add or delete licensees from the list of facilities requiring increased agency-wide attention based on

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4 demonstrated performance. This program represents an effort by the NRC senior management to focus agency-wide resources on those plants and issues that need to be addressed, to communicate the concems of senior NRC managers to licensees with poor performance or adverse performance trends, and to ensure that coordinated courses of action are developed and implemented for licensees of concem before problems reveal themselves as significant events.

l The following charts list conclusions reached by the senior managers at this meeting and from the previous meeting for nuclear power plants and for materials licensees:

NUCLEAR POWER PLANTS Meetina Dates Cateoorv 3' Categorv 22 Cateaorv 1 Status JAN 6-7,1998 Millstone Clinton Indian Point 3 1,2,& 3 Crystal River 3

, Dresden 2&38 LaSalls1&2 Salem 1&2 Zion 1&2 JUN 10-11,1997 Millstone Crystal River 3 Indian Point 3 ,

1,2,&3 Dresden 2&3 LaSalle 1&2 l Maine Yankee Salem 1&2 Zion 1&2 MATERIAL LICENSEES Meeting Dates Facilities for Priority Attention JAN 6-7,1998 None JUN 10-11,1997 None (1) Because a decision regarding the restart of Browns Ferry Unit 1 has been indefinitely deferred, the senior managers concluded, in June 1996, that it should no longer be identified as a Category 3 plant unless TVA were to decide to resume operation.

(2) Because a dechion to decommission Maine Yankee has been announced, the senior managers conclude, it should be administratively removed from the Watch List.

(3) In January 1998, the senior managers concluded that Dresden 2&3 met all the watch list removal matrix items except for corporate management oversight and involvement in plant operatior.s and problem resolution.

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3 Soecific Discussion of Problem Facilities Cateoorv 1: Plants That Have Been Removed from the List of Problem Facilities None Cateoorv 2: Plants Authorized to Ooerate that the NRC Will Monitor Closelv C Backoround Information:

Clinton Power Station was first discussed during the January 1997 Senior Management Meeting due to an overall decline in plant performance during 1996. The decline was clearly demonstrated in September 1996 events associated with a reactor recirculation pump seal fai!ure which revealed significant deficiencies which included problems with procedural adequacy and adherence, lack of rigor in conducting operations, and weak engineering support to operations. The deficiencies included examples where managers and staff were not knowledgeable of their basic responsibilities and appeared to have made decisions that placed plant operations ahead of plant safety. Based on the results from the January 1997 SMM, Clinton Power Station received a trending letter The licensee's poor performance in operations continued during the next six months. For example, a number of procedural adherence violations continued to occur and inattention to detail resulted in the operators failing to respond to annunciators associated with continuous operation of the emergency core cooling system sump pump. In addition, similar poor performance was noted in plant support (especially radiation protection). Problems associated with procedural adherence, a lack of sensitivity toward radiological controls, and a lack of conservative decision-making resulted in several radiologically significant events.

While the material condition of the plant improved as a result of a concerted effort by operations, maintenance, and engineering, surveillance program weaknesses and inattention to de' ail during maintenance activities continued to contribute to equipment performance problems. Furthermore, weak engineering support for the station, incomplete and untimely root cause evaluations and corrective actions, and design errors hindered equipment performance.

A failure to take corrective actions resulted in circuit breaker deficiencies because of hardened grease. In addition, the significance of a degraded voltage problem and the degraded containrrent protective cocting were not fully evaluated or understood.

During the June 1997 SMM, NRC senior managers were most concemed that the licensee had not developed a comprehensive response the NRC's January 1997 trending letter. While the licensee had implemented a number of short-term corrective actions, it had not developed a long-term approach to address performance deficiencies. It was not clear to the senior managers that the licensee had a full understanding of the depth and scope of the reasons for the performance issues at Clinton, and until that occurred, it would be difficult to consider the performance decline described in the trending letter issued folicwing the January 1997 SMM to

' e arrested. Therefore the senior managers determined that, although performance may have improved sufficiently to support restart, conductirg a DET (or allowing the licensee to perform

4 an Independent Self Assessment) would be an appropriate approach to better understand the reasons for its performance decline and develop applica& long-term corrective actions.

Following the June 1997 SMM, the licensee conducted an independent Safety Evaluation (ISA) '

from August through October 1997 to review its performance. The NRC reviewed the effectiveness of the ISA with a Special Evaluation Team (SET) which exited on December 11, 1997. The ISA 'dentified significant weaknesses in operations, engineering, maintenance and plant support. Examples of these weaknesses occurred in management and supervision of operations, performance of system engineers, control and understanding of the design basec, 3 maintenance work scheduling and work processes, and radiation protection. The SET noted, however, that the identified weaknesses in engineering did not appear to be manifested in significant design-related hardware problems in the plant. Weak barriers to prevent safety problems were found at all levels of management and throughout the licensee's processes.

The ISA determined the root causes of these weaknesses were ineffective leadership, complacency, weaknesses in the safety culture, and poor teamwork.

The SET confirmed that the findings of the ISA accurately characterized the station's performance deficiencies and their causes. The insights provided by the ISA and SET require timely and well-focused attention to restore confidence in the licensee's ability to preclude future problems.

SMM Discussion' The senior managers considered the following facte,4 from the plant performance evaluation template, in determining the appropriate agency response to the identified pedormance

• concems:

ARGUMENTS FOR MAINTAINING CURRENT AGENCY ATTENL ;N e Effectiveness of Licensee Self-Assessment There has been recent improvement in quality assurance audits Design deficiencies have recently been identified by the licensee e Operational Performance (Frequency of Transients)

Operators responded well to minor plant transients while shutdown Improvements in procedure quality and adherence noted recently e Human Performance Several plant-wide stand downs were implemented and recently operators stopped work when activities could not be performed according to procedures There has been an acceptance of the problems identified by the ISA and SET i

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• Material Condition (Safety System Reliability / Availability)

Work process improvemerits are under ,ay Overall plant material condition is good; the significant breaker deficiencies have been addressed e Engineering and Design Independent system design and functional validation inspections initiated Tlw plant is well designed and plant modifications have not significantly affected 3 the design basis ARGUMENTS FOR INCREASING AGENCY ATTENTION

• Effectiveness of Licensee Self-Assessment Because of licensee's failures to identify and resolve significant issues such as those associated with circuit breaker and control room neon bulb failures, a Demand For Information concerning its corrective action program was issued Root cause investigations lack rigor and usually fail to identify the actual root cause(s) of problems e Operational Performance (Frequency of Transients)

Plant has not operated since September 5,1996 Operating procedures were weak and lacked guidance to complete tasks

• Human Performance Procedure compliance, self checking, work practices, and communications during operational and work activities were weak Problems are not always identified and the staff accepts and lives with problams e Material Condition (Safety System Reliability / Availability)

Work process system is very cumbersome Many preventive maintenance and surveillanx tests are overdue and a high backlog of corrective maintenance items exists

• Engineering and Design Quality of technical reviews is weak, negatively affecting safety evaluations Weak maintenance and implementation of the plant's design basis in reviewing the factors fur increasing or maintaining agency attention, the senior managers were most concemed with the lack of progress by the licensee in developing a comprehensive plan to address performance deficiencies. Despite being shutdown for a considerable length of time, there has not been substantive progress in addressing the major performance issues

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facing Cl.nton. The ISA and the SET confirmed the existence of a weak management team.

. The recent announcement that PECO Energy had been selected by Illinois Power to operate Clinton demonstrates that the licensee also considers its current management team unable to deal with the issues currently facing Clinton in a timely fashion.

Information was presented that indicated that allegations have substan'ially increased, including a number of discrimination cases. It was also noted that performance trends indicated a rise in safety system failures, procedure adherence issues, personnel performance problems, and design bases issues, supporting the observations of the region and as would be expected for a licensee undergoing a substantial integrated assessment, it was determined by the senior managers that there has been insufficient progress in addressing issues by licensee management before the ISA/ SET, and that this assessment identified management issues that exist at the site. No clear path has been identified for addressing the ISA/ SET findings and managemer t control have bon ineffective for the most prt. Though the material condition of the plant has not been adve sely degraded due to its robust design and vintage, and the relatively short period of performance decline, the managers L

determined that the scope and breadth of problems, as further highlighted by the results emerging from the ISA/ SET warrant placing Clinton on the watch list as a Category 2 plant.

CLINTON

SUMMARY

in summary, in reviewing the considerations supporting increased agency attention at Clinton,  ;

the senior managers recognized the substantial management issues facing Clinton and the challenges facing the incoming PECO Energy management team, in particular, the lack of a comprehensive plan to address previous, as well as, recently identified issues, continued procedural inadequacies, the cumbersome work process system, a tendency for operators to live with problems, and ineffective self-assessment activities. In reviewing the considerations for maintaining agency attention at Clinton, the senior managers noted some very recent  ;

observations demonstrating improved work performance, improved quality assurance audits, and initiation of system design and functional validation inspections. On bstance and considering the length of time Clinton has been shut down with minimal progress and the emerging ISA/ SET findings, the senior managers determined that the considerations for increasing agency attention, outweighed those for maintaining agency attention. Therefore, Clinton was designated as a Category 2 facility.

CRYSTAL RIVER 3 Backaround Information:

Declining performance at Crystal River 3 (CR3) was first discussed during the June 1996 Senior Management Meeting (SMM). Concems at CR3 involved Florida Power Corporation's L(FPC) handling of several design issues, their non-conservative interpretation of certain NRC regulations, and weaknesses in operator performance, corrective actions, and management

, oversight. At the January 1997 SMM, senior NRC management placed Crystal River 3 on the Watch List as a Category 2 plant, due to the enntinuing decline in overall safety performance.

These performance issues included weaknesses in the licensee's design change processes. A Confirmatory Action Letter (CAL) was issued on March 4,1997, requiring NRC concurrence for

7 the restart of CR3 prior to entering Mode 2. At the June 1997 SMM, the senior NRC -

management acknowledged that the plant was in an extensive shutdown and in the process of determining its extent-of-condition. At that point it was too early to evaluate the effect of the performance improvement plans and considerations for maintaining increased agency attention outweighed those for decreasing agency attention. Therefore, Crystal River 3 continued to be designated as a Category 2 plant.

Since the June 1997 SMM, overall performance at CR3 has improved and FPC has made substantive progress toward their planned restart. The programmatic areas of design control, 10 CFR 50.59 evaluations, and corrective actions were inspected and found adequate. Since the last SMM there has been escalated enforcement for inadequate safety evaluations for emergency operating procedure changes, and an emergency diesel generator modification that resulted in an unrecognized unreviewed safety question (USQ).

CR3 management has replaced a number of upper and middle-level managers with personnel from oe side the company. Current management used the outage as an opportunity to correct L longstanding problems and improve programs. The licensee has essendally completed the l

discovery phase and the physical modifications and is working on program changes.

The NRC developed five major areas of concern to capture broad performance pcblems which included: management oversight, engineering effectiveness, knowledge of design basis, compliance with regulations, and operator performance. These five areas are tracked by the restart restraint list. Inspections of restart related items have noted improvement in the licensee's performance in all five areas.

The NRC has applied significant resources to this plant: three resident inspectors are on-site, an Inspection Manual Chapter (IMC 0350) panel is overseeing NRC activities, the Regional Administrator is meeting with licensee management on a bimonthly basis, and there is a CAL in effect. Although FPC is still in the recovery phase, it has essentially completed efforts to discover the extent of their problems. The items on the Watch List removal matrix that remain to be completed are associated with plant restart.

SMM Discussion The senior managers considered the watch list removal matrix (Attachment 4), in determining the appropriate agency response to the identified performance conce in reviewing the watch list removal matrix, the senior managers focused on the critena that the plant had not yet achieved a period of sustained operational performance, given its current shutdown condition.

It was also noted that there are several design and licensing bases issues that still need to be resolved before the plant can begin its approach to criticality. It was noted that there is a substantial problem in understanding and reconstituting the plant's design bases due to its vintage and design and that this has led to a concem by the NRC. Forthcoming meetings were noted in which the licensee was to make its case that this situation is suitable for operating the plant. The senior managers decided that this plant will remain a watch list Category 2 facility.

8 CRYSTAL RIVER

SUMMARY

p in summary, in reviewing the considerations for removing Crystal River 3 from the watch list and designating it as a Category 1 facility, the senior managers acknowledged that the plant has yet to emerge from its extensive shutdown to demonstrate a period of sustained operational performance. The senior managers also noted that concerns in the engineering area, in particular those related to the plant's design bases, have yet to be resolved to the agency's satisfaction. Therefore, Crystal River 3 continued to be designated as a Category 2 facility.

3 SALEM

] Backaround Information:

Salem Units 1 and 2 were first discussed at the January 1990 Senior Management Meeting (SMM) and have been subsequently discussed at every SMM since June 1994. Both units were shutdown in May and June,1995, respectively to correct longstanding equipment deficiencies, poor material condition, weak management oversight, and ineffective corrective actions. As a result of the January 1997 SMM, the Salem units were designated as a Category 2 watch list facility. PSE&G has made significant progress in implementing its restart plan, including the completion of thousands of activities and the installation of hundreds of modifications. Since the most recent SMM, the licensee improved performance sufficiently to warrant modification of the 1995 Confirmatory Action Letter (CAL) to allow restart of Salem Unit 2. Senior licensee management provided effective oversight of the Unit 2 restart effort and has successfully fostered a conservative and deliberate operating ethic among the operations staff. Salem Unit 2 achieved full power on September 22,1997, and operator performance since the restart has been very good.

The licensee's self assessment programs have improved in all areas. Its operating performance has also improved and is considered to be good. No significant events occurred during the Unit 2 integrated test program, which was a substantial and thorough effort by the licensee. Human performance has improved, though some instances of failing to identify technical specification non-compliances were identified. Although licensee performance has improved significantly, the organization continues to be challenged by a very large workload.

This workload includes emerging issues from the Unit 2 startup test program and the Unit 1 steam generator replacement outage. Engineering support for plant modifications, testing, and operations has generally been good, but on occasions strained resources have impacted timely troubleshooting and repair activities. .

SMM Discussion:

W senior managers considered the watch list removal matrix (Attachment 3), in determining the appropriate agency response to the identified performance enems. In reviewing the watch list removal matrix, the senior managers noted that the t

• indicated Salem met all the criteria for removal from the watch list with the exception of de rating sustained, successful plant performance.

9 The interpretation of what is meant by sustained, succest 11 ant performance was discussed by the senior managers at length. The consensus was that _. specific definition would not be appropriate, as the root causes for a facility to be placed on the watch list may be different and the breadth and scope of its recovery efforts may vary. This would necessarily result in some facilities warranting a more extensive observation period to ensure past problems were corrected and that they will not recur.

The application of this criteria to Dresden and Salem facilities was discussed in this context.

The chronic cyclical performance of Dresden (and cDer Comed facilities) would necessarily warrant a cautious and more extensive observation period than a facility like Salem, which has

_d substantially improved plant material condition, safety culture, and management oversight and

] effectiveness, as demonstrated by the successful startup and operation of Unit 2 during the past six months. The senior managers also acknowledged that current startup preparations and activities for Unit 1 will likely stress the organization differently than during the startup of Unit 2, as the licensee must also maintain Unit 2 operating effectively. There was also some consideration of identifying Unit 2 as a Category 1 facility in recognition of the strong startup

,g effort and current plant performance and maintaining Unit 1 as a Category 2 facility until a y successful startup could be completed. However, given the current plans that have Unit 1 d starting up in the near future, and the consensus that monitoring of the startup of Unit 1 while maintaining the safe operation of Unit 2 would meet the criteria of sustained successic!

operation for Salem, the senior managers determined that Salem would remain a Category 2 facility.

SALEM

SUMMARY

In summary, in reviewing the considerations for removing Salem from the watch list and designating it as a Category 1 facility, the senior managers acknowledged that Salem management has made substantial improvements in the plants and its operating philosophy and performance. However, the senior managers focused strongly on the watch list removal matrix item that requires the demonstration of sustained, successful plant performance. For Salem, it was determined that this would require a successful startup of Unit 1 while sustaining safe operation of Unit 2. This consideration was the overriding factor in the determination that Salem continue to be designated as a Category 2 facility.

COMMONWEALTH EDISON During the SMM, four Commonwealth Edison (Comed) facilities were discussed: Dresden, LaSalle, Zion, and Quad Cities. The senior managers recognized that the SMM process is oriented towards assessing individual plant performance. However, the senior managers were unable to separate the issues associated with Comed corporate performance, as expressed in the NRC's letter pursuant to 10 CFR 50.54(f) that was sent to Comed January 27,1997. The senior managers considered theme corporate-levelissues, in particular the cyclical performance that has marked the performance of many of the Comed facilities. This issue was the central theme of the 50.54(f) letter. The four Comed facilities that were discussed are grouped together below. In assessing the readiness of the three facilities currently on the Watch List (Dresden, LaSalle, and Zion), the senior managers noted that the watch list removal matrix has several factors associated with corporate performance. These corporate performance factors were key to the discussion of Dresden and its readiness for removal from the Watch List.

10 DRESDEN Backaround Information:

Dresden was first placed on the NRC Watch List in June 1987, removed in December 1988, and again placed on the Watch List in January 1332. Significant contributors to the decision to place Dresden on the Watch List a secono time included weaknesses in: procedure quality and adherence, communications, execution of management expectations, plant material condition, supervision and contro' of work activities, work performance, and engineering and licensing support. During the June 1996 Senior Management Meeting (SMM), senior managers

.3 concluded that an independent special team should be formed to evaluate the performance of

] Dresden station. This evaluation was conducted in the Fali of 1996 and the results were presented to the senior managers at the January 1997 SMM. Thi- team concluded that safety performance had significantly improved in plant operations while the level of improvement in g

I engineering had not yet resulted in fully effective problem identification and resolution. The team also concluded that the results of improvement initiatives in radiological protection, maintenance, and self-assessment were mixed and identified significant weaknesses in engineering, design control, and surveillance testing.

During the June 1997 SMM, improvement in the Unit 3 operational performance and material condition was noted, but senior agency managers remained concemed about continued operational challenges on Unit 2 created by equipment deficiencies, the engineering difficulties that remained to be addressed, lingering questions about work control, continued weaknesses in procedural adherence and continued maintenance issues.

Since the June 1997 SMM, operations at Dresden have demonstrated a generally high level of performance. The plant was operated safely and conservatively. Communications have been good and operational evolutions have usually been performed in a controlled manner. Although there was one event in which a feedwater pump shift evolution was not properly performed on Unit 2, resulting in the initiation of a manual scram. There have also been several power reductions and shutdowns. These have been caused by maintenance errors, material condition problems and random equipment failures.

Performance in m:' .:enance has generally been satisfactory and the material condition has continued to improve. The licensee has continued to keep material condition as a primary focus in 1997. As previously mentioned, there have been some maintenance errors, especially in the area of instrumentation, that have occasionally caused equipment problems. Overall, engineers were knowledgeable and provided good support to operations. There were certain weaknesses during surveillance testing such as the pre-conditioning of a battery during testing.

Plant support continued to improve. Radiological controls and overall performance during the recent Unit 3 refueling outage were good. Station radiation dose in 1997 was less than half what it was in 1994 aM 1995, in September, a stop work order on Unit 1 was initiated to improve overall decommissioning performance and to address recent problems with radworker performance.

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11 SMM Discussion:

The senior managers considered the watch list removal matrix (Attachment 3), in determining

- tie appropriate agency response to the identified performance concems. In reviewing the watch list removal matrix, the senior managers noted that the region indicated Dresden met all the criteria for removal and its designation as a Category 1 facility would be warranted based on individual piant performance. However, the senior managers had great difficulty in separating Dresden's performance from the overarching corporate issues identifed in the 10 CFR 50.54(f) letter. In particular, subsequent discussions regarding Quad Cities and its recent decline in performance convinced the senior managers that the cyclic performance among Comed plants had not been arrested. The senior managers focused on Part 111 of the watch list removal matrix, especially the item related to effective corporate management oversight and involvement in plant operations and problem resolution, it was determined that this item should more properly be evaluated as not yet being met, consistent with the other Comed plants discussed at this meeting. Therefore, the senior managers determined that despite the improved performance at Dresden, it should still be retained as a Category 2 facility.

DRESDEN

SUMMARY

In summary, in reviewing the considerations for removing Dresden from the watch list and designating it as a Category 1 facility, the senior managers recognized the improved, sustained performance on both Units 2 and 3, lacluding sustained dual unit operation. However, the senior managers deliberated on Dresden's improved performance in conjunction with the agency's concems over Comed corporate performance, and the recent decline in Quad Cities' performance. The senior managers concluded that this continued evidence of cyclic performance by Comed plants indicates that Dresden did not meet all of the watch list removal matrix items. Specifically, the senior managers concluded that the watch list removal matrix item pertaining to the adequacy of corporate oversight and involvement in plant operations and problem resolution was not met. As a consequence, the senior managers determined that it would be prudent to observe Dresden's performance for a longer pericd of time to ensure that cyclic performance issues do not emerge.- Therefore, Dresden continued to be designated as a Category 2 facility.

QUAD CITIES

- (Note: Quad Cities was not designated as a Category 2 Facility, but it was identified as a plant with an adverse performance trend. Its discussion is included here since its performance played a key role in determining overall Comed corporate performance.)

Backaround Information:

Qua( Oities was first discussed at the June 1991 SMM and at each SM., since June 1993 with the eueption of the June 1997 SMM. Following the January 1994 SMM, the NRC sent the licensee a Trending Letter to express concem over the continuing decline in overall performance. After the June 1994 SMM, the NRC cent the licensee a Follow-up Trending Letter expressing continuing concem. During the first half of 1995 overall performance improved. Following the June 1995 SMM, NRC managers concluded that the declining trerds at the Quad Cities Station had been arrested. During 1996, Quad Cities displayed slow

12 improvement in operations performance, material condition, procedural adherence, trending, and accountability.

Recent performance at Quad Cities has been mixed . While perfen vne was good in several areas, substantial problems were encountered in discreet techn'c,a a including: procedures for 10 CFR 50 Appendix R Fire Protection, implementation of ths - ance Rule, and hydrostatic testing of the primary system per 10 CFR 50 Appendii i the ASME Code.

. Operations generally performed well during the period, with com[ s - mutions such as startups, shutdowns, and transient responses handled well. The licensee executed a period of good dual unit operations. However, personnel errors increased slightly and equipment problems, such as a leaking reactor recirculation pump seal, low oil levels on a recirculation pump, and a leaking fuel element, burdened the operators. The improving trend which had '

been noted during the last assessment psriod stalled.

Maintenance work performance was generally adequate to good, with some examples of deficient work and need for rework. As a result there wue some equipment problems. While {

licensee self-assessment activities were effective in identifying some aspects of inadequate i implementation of the Maintenance Rule, they did not identify the broad scope of the existing problems. As a result, corrective actions were not aggressively pursued and NRC inspection -

concluded that the Maintenance Rule Program was not adequately implemented at Quad Cities. In the area of surveillance testing, problems were experienced with missed and untimely -

surveillances and with inadequate surveillance acceptance criteria.

Weaknesses surfaced in engineering involving the understanding and application of the design basis, operability and 10 CFR 50.59 evaluations, application of the parts replacement program for the emergency diesei generator (EDG) air start motors, and resolution of identified proble;ns. Recently identified inadequate safety evaluations per 10 CFR 50.59 resulted in the licensee conducting a hydrostatic test of the reactor vessel and primary system boundary after core criticality, in violation of Appendix G. Further, the licensee's implementation and evaluation of the results of the hydrostatic test were insufficient to ensure that all test points were adequately examined.

Overall performance in plant support areas, except for fire protection, were good, with radiation protection, emergency preparedness, and security performing well. However, substantial problems were encountered in the area of fire protection in that the procedures for pathways to l achieve safe shutdown in the event of a design basis fire were found to be inadequate and the resolution of the fire protection issues was poorly managed, ultimately resulting in a dual unit shutdown due to inadequate analyses.

SMM Discussion-The senior managers considered the following factors from the plant performance evaluation template, in determining the appropriate agency response to the identified performance concems:

13 ARGUMENTS FOR MAINTAINING CURRENT AGENCY ATTENTION'

• Effectiveness of Licensee Self-Assessment Assessment of Maintenance Rule implementation provided a clear set of major issues.

Good technical issues on RHRSW pump testing were identified through self-assessment -

Multiple Fire Protection safe shutdown procedure deficiencies were identifed.

All safe shutdown paths were declared inoperable and Unit 2 was shutdown early.

Audits and self-assessments in emergency preparedness and chemistry were effective.

i l e Cperational Performance (Frequency of Transients)

Good dual unit operation in 1997.

Refueling and startup were carefully planned and controlled. Operator performance during these evolutions was essentially error free.

Operator response to plant conditions remained good with complex evolutions handled well.

• Human Performance Performance by the plant staff was good overall.

Operator performance was generally good, with transient responses, startups and shutdowns handled well.

Maintenance personnel generally performed tasks safely and in accordance with procedures.

Good worker performance in Plant Support.

• Material Conditio'n (Safety System Reliability / Availability)

Material condition was generally adequate and supported 2 long periods of dual uni + operation in 1997.

Maintenance backlog has been reduced and ability to get work done has been demonstrated.

e Engineering and Design Committed to perform in-depth system design reviews.

An Engineering Assurance Group was established to review engineering products and upgrade the quality of engineering work.

Good engineering decisions were evident on selected issues.

Substantial resources were applied to the resolution of fire protection safe shutdown pathway !ssues.

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14 ARGUMENTS FOR INCREASING AGENCY ATTENTION

• Effectiveness of Licensee Self-Assessment Self-assessment findings on Maintenance Rule were largely ignored. Resolution was untimely and inadequate.

Resolution of self-assessment findings on RHRSW pump testing was not technically rigorous or comprehensive.

Even though IPEEE showed fire to be a high risk contributor and a large number E of operator actions were necessary, procedures for fire protection safe shutdown were inadequate. Resolution of fire protection issues had received low priority, requiring extensive NRC intervention. As expiration of the LCO approached, attention focused on keeping Unit 1 operating versus complete resolution of the issues.

• Operational Performance (Frequency of Transients)

Power changes were occasionally necessary to address equipment problems.

Less significant evolutions occasionally challenge.d operators.

Operating and operability decisions were weak in some cases, such as entering shutdown LCOs to perform maintenance,

• Human Performance Operator errors increased slightly and included a failure to recognize a leaking fuel element for 2 shifts.

Some maintenance errors resulted in unnecessary radiation exposure, and in one case, an intake of radioactive material.

Some isolated errors occurred in Plant Support.

Multiple weaknesses in system knowledge, understanding the design basis, and attention to detail in calculations hindered individual performance in engineering.

• Material Condition (Safety System Reliability / Availability)

Equipment problems, including a leaking fuel element just after startup from a refueling outage, affected plant operation.

Multiple, repetitive equipment problems involving rework, including a failed recirc pump seal found just after the seal had been replaced, and an RCIC valve leak caused by maintenance, occurred on both units.

u Engineering and Design Design basis weaknesses were revealed through untimely resolution of testing issues on the RHRSW and safe shutdown makeup pumps.

15 Staff change out and diversion to fire protection issues limited the effectiveness of the Engineering Assurance Group.

Engineering struggled to resolve problems in several cases, including replacement air start motors for the diesel generators and the 250vde battery I testing acceptance criteria.

l All Fire Protection safe shutdown paths were inoperable due to procedure discrepancies. Unit 2 has had to stay shutdown since September to support l operation of Unit 1 because of reliance on opposite unit equipment.

Poor safety decisions, inadequate 50.59 screening, and poor understanding of the ASME Code led to hydrostatic test of the reactor vessel at power instead of prior to criticality, in violation of 10 CFR 50 Appendix G. The quality of inspection performed for the test was also inadequate.

In reviewing the plant's performance, the senior managers acknowledged that though performance in operations and maintenanct %ve been adequate, there has been a decline in performance at Quad Cities in the engineering organization. Three icsues of note were discussed by the senior managers in assessing the performance trend of Quad Cities. Of most import was the substantial problems the licensee has experienced in trying to resolve Appendix R concems which has resulted in both units currently being shutdown. Secondly, the senior managers discussed the ramifications of a recent event in which the licensee violated requirements of 10 CFR 50, Appendix G by performing a reactor plant hydrostatic test at power.

Finally, it was noted that the licensee basically ignored findings from a recent self-assessment that was conducted on implementation of the maintenance rule. This was evinced during a recent maintenance rule baseline inspection which had very poor results. This decline in performance was viewed in the context of the overall concems about Comed's corporate performance.

f i

There were some mixed observa aons of plant performance. The senior managers acknowledged that the licensee is making continued progress in addressing rrnteria! condition concems and that operations is performing well and continuing to improve. It was also noted that at the recent Comed Commission Meeting, Quad Cities was the only unit which the NRC indicated performance may be trending downward. At this meeting it was stated that the engineering organization appeared to be stressed as a result of expending so much effort in dealing with the Appendix R issues. This performance issue was also raised as a concem by the licensee at the same meeting, indicating that corporate oversight had at least recognized that problems existed. The senior managers discussed in depth the overall concems that led to sending Comed a 50.54(f) letter last year, in particular the concems over cyclic performance.

The sense of the senior managers was that Quad Cities' performance was mixed with slow improvement in some areas, and that major issues, such as the Appendix R and Appendix G situations, reinforced the agency's view of plant performance. The senior managers noted that an enforcement conference on the Appendix G issue and an AE inspection are scheduled for the near future, and would serve to provide further insights into the performance of the engineering organization.

QUAD CITIES

SUMMARY

In summary, in reviewing the considerations for maintaining agency attention at Quad Cities, the senior managers noted that there has been good operational performance, including a

16 period of dual unit operation, and improved material condition with a deemsing maintenance and engineering backlog In reviewing the considerations for increasing agency attention at Quad Cities, the senior managers were most concemed with the level to which the NRC had to become involved before the licensee began to adequately address the Appendix R issues, the apparent violation of Appendix G, and the maintena, ice rule implementation problems. These issues revealed to the senior managers that there are still concems that need to be addressed.

Given the corporate issues that are the subject of the 10 CFR 50.54(f) letter and which have yet to be effectively addressed, the senior managers felt the recent issues at Quad Cities are another indicator that Comed has not yet been able to effectively address the concem over cyclic performance at its sites. On balance, the senior managers agreed that there are indications that the licensee's overall performance has declined, and that a trending letter was an appropriate regulatory tool to convey the agency's concems with Quad Cities' recent performance in particular, and Comed's overall corporate performance in general.

LASALLE Backaround Information:

LaSalle was given a trending letter in January 1994, due to concems about poor radiological work practices, declining material condition, declining personnel performance, and NRC staff concems about the licensee's ability to pursue and resolve root causes for these issues. By January 1995, the ;icensee's initiatives were found to be effective in arresting these adverse trends and the licensee was sent a letter informing them of this observation and urging the continuation of improvemen', initiatives, improvement in plant material condition and engineering effectiveness was limited during 1995 and the first six months of 1996. The significant amount of emergent work and difficulties in planning and executing work hindered progress in implementing the station material condition improvement plan during the last six months of 1996. In June 1996, a risk-significant event occurred involving the injection of large quantities of expandable foam sealant into the safety-related service water tunnel. The NRC issued a $650,000 civil penalty to the licensee for violations associated with this event.

Following the January 1997 SMM, LaSalle was placed on the NRC watch list as a Category 2 facility.

Both units at LaSalle have been shut down since September 1996 to address a variety of human performance deficiencies and hardware problems. In response to a number of performance issues identified by the NRC and through licensee self-assessments, the licensee developed a comprehensive restart action plan.

The licensee continues to follow the improvement program encompassed in their LaSalle Station Restart Plan. This plan focuses on seven strategies involving safe plant operation, human performance, plant material condition, effective engineering support, corrective action /self assessment, training, and process improvement. The licensee has demonstrated an improved ability to identify their own problems. For example, the licensee performed critical operator evaluations and emphasized high operator standards through the High Intensity Training evaluations and identified numerous equipment and procedure deficieacies through System Functional Performance Reviews. There have also been extensive design changes and maintenance activities to address material condition problems, establishing an Engineeria

17 Assurance Group to improve the quality of engineering work products, and implementing a Corrective Action Review Board to ensure improved root cause analysis and corrective actions.

Overall, performance at LaSalle has shown signs of improvement commensurate with the current status of the Restart Plan. While the licensee's efforts are resulting in improvemeniin several areas, this improvement is not yet consistent and continued focus is necessary to ensure the improving trend is sustained. For example, the frequency and significance of operator and maintenance personnel performance deficiencies have decreased, but the periodic occurrence of procedural adherence and work coordination problems indicates the need for continued focus on this area. The licensee has made improvements to the corrective action process. Unlike Zion, the management at LaSalle has made a substantive effort to identify its material condition problems through system reviews. It has also completed training of its supervisors and operators to address human performance errors. The licensee is now conducting the work needed to correct the noted deficiencies.

SMM Discussion:

The senior managers considered the watch list removal matrix (Attachment 3), in determining the appropriate agency response to the identified performance concems. In reviewing the watch list removal matrix, the senior managers recognized that improvement in a wide variety of areas is being effected. However, there remains a substantial amount of work to be accomplished. TM senior managers noted that LaSalle management has identified the correct scope of work to be performed and now the effectiveness with which this work is accomplished must be observed. This places LaSalle farther along than Zion in establishing a plan for restart readiness. The senior managers determined that LaSalle would remain a Category 2 facility.

LASALLE

SUMMARY

l in summary, in reviewing the considerations for removing LaSalle from the watch list and designating it as a Category 1 facility, the senior managers acknowledged that LaSalle management has effected measurable improvement in a number of areas, and appears to have established an adequate scope of work to be accomplished before consideration can be given to restarting the facility. However, the senior managers noted that the plant is still immersed in an extensive shutdown, with a substantial amount of work to be accomplished. It was also recognized that a large portion of the wa;ch list removal matrix items have yet to be completed or assessed. Therefore, LaSalle continued to be designated as a Category 2 facility.

ZION Backaround Information:

Zion was on the NRC Watch List as a Category 2 facility from January 1991 until January 1993, when it was removed based on improved performance. This improving trend continued through August 1993. The licensee was unable to maintain a course of improvement. Efforts to improve material condition, upgrade operator performance, and effectively plan and execute work had little effect, resulting in stagnant performance. The backlog of material condition problems remained large, and operators continued to be cnallenged by workarounds and

_m

16 material condition problems. The trend of personnel errors involving operations and maintenance continued, and significant problems were identified in several technical areas and eng:neering processes. As a result, Zion Station was placed back on the NRC Watch List -

following the January 1997 SMM.

During the first half of 1997, Zion's performance was poor. Operator performance was characterized by an incussing trend in personnel errors resulting from failures to follow procedure

• inattention to detail, lack of a questioning attitude, knowledge and training deficiencies, and accoptance of abnormal plant conditions. An Augmented lospection Team investigating a rod withdrawal event identified a number of human p"formance deficiencies. Of particular concern was the breakdown in command and control by operations supervision, inadequate communications between alllevels of the operations dep rtment, the failure to pte-plan the shutdown evolution, and licensed operator knowlMge and training deficiencies.

In addition, the licensee's failure to take timely and effective corrective actions for known problems, continued to result in recurrence of events. The maintenance backlog problem was compounded by the inability of maintenance personnel to do work correctly the first time. The resultant poor material condition of safety related equipment continued to challenge operators.

These pF mance weaknesses also contributet to severai personnel safety events and the degradat ' safety related equ:pment. A decline in performance continued to be evident in the radiok 11 corttrols area.

Since the last SMM, the licensee has made some progress in improving performance at Zion l Station, but significant issues still remain which require resolution prior to plant restart. The i main performance areas which the NRC and the licensee have recognized as still needing resolution prior to restart includes the demonstration of consistently improved operations performanc6, effective corrective action program implementation, and resolution of the safety conscious work environment concerns. The licensee has been implementing extensive corrective actions to address performance problems in accordance with their Zion Station Recovery Plan.

Effective progress in resolving the issues has been difficult, although the licensee continues to make adjustments in its improvement strategies. Some indi .ations of rarformance improvement have recently become Lvident, particularly in control rcom decorum, engineering review of design issues, and problem identification. In addition, improvement is evident in the following areas: engineering identification of long standing design deficiencies, radiation (

protection efforts to decontaminate plant areas to improve access to equipment and the ability of security personnel to respond to extemal threats.

A significant increase in allegations from Zion Station ?mployees occurred during 1997 compared to previous years, with many of the concems involving alleged " chilling effect." This increase was coincident with more aggressive actions by the licensee to address operator performance deficiencies, including an Operator Assessment Process which negatively

{

impacted some opereting personnel and which some plant persennel perceived as targeting individuals who raised safety concerns. The NRC conducted a public meeting on October 2, 1997, to discuss the issue, including completed and planned licensee actions to ensure a safety  ;

conscious work environment at Zion Station. These issues, currently under investigation by the i

19 NRC, remain the subject of discrimination complaints filed who the Department of Labor and a lawsuit filed in Cook County Circuit Court in Illinois.

The ability to perform critical self assessments proved to be a problem since the last JMM.

although recent developments may be resulting in a pcsitive change. The licensee's implementation of the Operational Readiness Demenctrat:on Program cnd its assissment of operator performance improvement was deficient. ;,) addition, NRC involv', ment was necessary to get the licensee to recognize and more aggresclvely pursue widespread equipment configuration control problems and zebra mussel fouling of the service water system. Since that time, the licensee has implemented extensive organizational changes with regard to corporate and plant management and developed plans for enhanced corporate oversight of Zion Station restart activities. The licensee's characterizatien of operator performance has been consistent with the NRC's assessment.

Overall, the licensee has shown improvement in the ability to identify problems. In particular, control room operators have recently oemonstrated a more questioning attitude which has resulted in the identification of some procedure problems.

SMM Discussion:

The senior managers considered the watch list removal matrix (Attachment 3), in determining l the appropriate age'1cy respense to the identified performance concerns. In reviewing the watch list removal matrix, the senior managers recognized that improvement in a wide variety of areas is stillin its early stages. The senior managers compared Zion to LaSalle, noting that LaSalle has conducted extensive system reviews to identify the scope of work that needs to be accomplished, whereas Zion is still in the discovery phase.

The senior managers acknowledged that there has been efforts to improve material condition and engineering performance, but unlike LaSalle, the licensee has not yet approached the depth and scope of effort to identify its material condition problems. Y% senior managers also made the observation that there is no clear plan or schedule to achieve long-term plant performance improvements. The new President of Nuclear G.,neration recently pushed back the restart date for Zion in order to allow such a plan to be developed.

ZION

SUMMARY

In summary, in reviewing the considerations for removing Zion from the watch list and designating it as a Category 1 facility, the senior managers noted that there have been some recent positive indications that Zion is attempting to improve its performance and its material condition. However, the overriding concerns that captured the senior managers attention were the substantial amount of work that remains to be secomplished, the lack of a clear plan for moving towards readiness for startup, anc' the continued concems about the work environment at Zion. The great majority of the items on the watch list removal matrix were answered in the negative. Therefore, Zion continued to be designated as a Category 2 facility.

20 Cateaorv 3: Shutdown Plants Reaulrina NRC Authorization to Ooerate and which the NRC will Monhor Closelv MILLSTONE UNITS 1. 2. AND 3 l Backaround information: l Beginning in 1991, the Millstone units have been discussed at every senior management meeting. This is the thirteenth senior management meeting (SMM) that the P"' stone Station has been discussed. All three Millstone units, each of which ceased oneratir,g at some point during 1995-96, were placed on the Watch List as Category 2 facili ., as a result of the January 1996 SMM. Subsequent to the June 1996 SMM, the Comrnission identified Millstone l

as a Category 3 Watch List plant, which requires that the units individually receive Commission approval to restart.

On August 14,1996, the NRC issued a Confirmatory Order directing NNECO to establish an Independent Corrective Actions Verifiestion Program (ICAVP) to verify the adequaci of NNF.CO's efforts to establish adequate design basis and design controls. The licensee selected Sargent and Lundy as the contractor for Units 1 and 3, and Parsons Power Group as the contractor for Unit 2. The staff approved these selections. The ICAVP review has expended substantial engineering resources and diverted NU management's attention from issues such as the employee cencerns program and the corrective s,ction program. Unit i recovery efforts have been placed on hold pending completion of activities for the other two units.

On October 24,1996, the NRC issued an order directing that before the restart of any unit, NNECO must develop and submit to the NRC a comprehensive plan for reviewing and dispositioning safety issues raised by its employees, and ensuring that employees who raise safety concerns can do so without fear of retaliation. Additionally the order required the licensee to hire an independent contractor to monitor the effectiveness of the new program.

NNECO selected Little Harbor Consultants, Inc. for this independent review of the employee concems program. The employee concems program is making some progress but the number of allegations being received has not substantially subsided.

Previous NRC and licensee ossessments identified s6 - undamental problems with the licensee's performance. These underlying problems incluce. ineffective management practices, poor implementation of corrective actions, continued problems resolving employee concerns, inadequate work control practices, problems with procedural adherence and quality, ineffective quality assurance and oversight, and inadequate configuration management.

The agency accumulated enforcement issues for the Millstone site since late 1995, combining regional issues with those from the special inspection conducted in 1996. Over 80 items were identified, ranging from engineering design issues to Office of Investigation findings from wrongdoing cases. A civil penalty of $2.1 million was issued for tnese findings on December 10,1997.

l l

21 i Each unit is workirag toward response to the 10 CFR 50.54(f) letters using substantially different approaches because of the differences in the time period in which they were licensed and how much of the design and licensing bases are intact. Concurrent with the design review and reconstitution effort, the licensee is trying to deal with the issues discussed above. Although progress in all areas has been slow improvement in selected areas has been noted.

SMM Discussion:

The senior manage c reviewed Millstone's current status and noted that the licensee has a substantial amount of effort remaining to respon:"o the existing Orders and the 10 CFR 50.54(f) letters. The senior managers noted that tnere have been several briefings provided to the Commission, the most recent one occurring in December, in order Wsep the Commisslor, abreast of the current status of Millstone to support the decision the ComMssiot aust make regarding resta:: of any of the Millstone units.

The senior managers considered the watch list removal matrix (Attachment 3), in determining the appropriate agency response to the identified performance concerns, in reviewing the watch list removal matrix, the senior managers recognized that improvement in a wide variety of areas is s'ill needed to be demonstrated at Millstone, although there are indications of progress

! being made. The senior managers noted that many of the NRC's confirmatory actions remain to be executed. The staff is waiting for the licensee to inform it of its readiness for these inspections, which are expected to commence in the near future. The senior managers also expressed concern over the continued recurrence of employee concerns issues. It was noted that the licensee recently realigned the responsibilities of several senior managers in ords- to place even greater emphasis on this area throughout the organization.

MILLSTONE

SUMMARY

In summary, the senior managers did not review considerations for decreasing or maintaining the level of agency attention at Millstone. Given its current Category 3 standing, the continuing dialogue with the Commission through quarterly Commission meetings, the substantial effort required as a result of confirmatory orders necessitating the ICAVP and the independent oversight of the employeo concems program, and the fact that a Commission vote is required before any of the Millstone units can restart, it was clear to the senior managers that Millstone would continue to be designated as a Category 3 facility.

Other Plants Discussed POINT BEACH Backaround Information:

Point Beach was issued a trending letter in January 1997 dua to findings regarding inattentiveness to duty by control room operators, ineffective surveillance testing, the failure to maintain proper equipment configuration control, and inadequate operability determinations and engineering evaluations. Ineffective self assessments, narrowly-focused root cause analyses, and a weak corrective action program contributed to numerous long-standing safety issues.

22 Furthermore, management's failure to aggressively address these issues and lack of a strong safety focused questioning attitude contributed to a pervading focus on keeping the units operating without assessing or resolving long standing safety issues.

During the June 1997 SMM, senior NRC managers viewed the licensee's efforts to conduct critical self assessments, improve human performance and the conduct of operations, and review the material condition of its systems as a substantial response to the trending letter.

The senior managers acknowledged that many of the improvement initiatives have not yet matured to a level such that a determination of whether the performance decline noted in the trending letter issued following the January 1997 SMM had been arrested. This consideration was the overriding factor in the determination that the trending letter would remain in effect.

Since the last SMM, the licensee has continued its extensive improvement initiatives begun in the latter part of the previous assessment period and, as a result, performance has continued to improve. Plant and corporate management have demonstrated a strong commitment, backed by the expenditure of substantial resources, to improve performance in ali aspects of plant l

operations. The licensee implemented improved, more explicit operating standards; provided independent oversight of control room and engineering activities with experienced contract personnel; improved the nuclear safety perspective of operations, engineering, and other groups through training and the addition of experienced permanent managers and plant staff outside thn Wisconsin Electric System; and established a system engineering review board (SERB) ind an outage review committee (ORC) to systematically review open issues, work orders, and deficiencies associated with each plant system to ensure the proper identification and resolution of existing issues.

NRC has noted a marked improvement in the operational performance of day-to-day operations and the approach taken by management and staff to address difficult safety issues and operational decisions. Specifically, extensive NRC inspection coverage of the Unit 2 restart indicated substantialimprovement in the conduct of operatioris and good engineering decision-making. There were some inadequacies in operability determinations prepared in support of the Unit 2 restart, problems in fire protection and Appendix R programs and deficiencies in the control of high radiation areas. The licensee has acknowledged the need for continued improvement and has taken substantial steps to address these areas, including extensive engineering training and performing comprehensive assessments of the fire proteci;on and Appendix R programs.

The licensee has hired a number of new staff and managers to supplement the existing staff and address long-standing problems. For example, the extensive and successful efforts to lower the problem reporting threshold and the identification of many engineering issues during the comprehensive reviews by the SERB and ORC overloaded Point Beach's work order system. To address this issue, the licent,ee hired a new Work Control Manager with extensive experience and is developing a comprehensive, state-of the-art work control processing and tracking system. A similar effort was implemented in the quality assurance (QA) department, including the tripling of the QA staff. As a result, NRC has noted a marked improvement in recent QA audits.

SMM Discussion-The senior managers considered the following factors from the plant performance evaluation template in determining the appropriate ag ncy response to the identified performance concerns:

ARGUMENTS FOR MAINTAINING CURRENT AGENCY ATTENTION e Effectiveness of Licensee Self Assessment Resolving the large number of cnndition reports is, challenging staff

- Only beginning to implement new self assessment initiatives Completion of improvement initiatives will take 2 or more years e Operational performance (Frequency of Transients) l -

Dual unit operation has not yet been demonstrated Operations staff has not yet been challenged with unplanned events l -

Reviews for improvements in operations procedures and control room staffir.g are in progress

• Human Performance Health Physics program implementation and procedure adherence needs some improvement Reviews for improvements in surveillance and maintenance procedures are in-progress A large engineering backlog exists because of the number of issues being identified e Material Condition (Safety System Reliability / Availability)

A large backlog of maintenance y ark requests exists because of the number of issues being Identified Extensive reviews are in-progress to completely modify the existing work control process Maintenance staff performance is not yet always consistent with program requirements

• Engineering and Design Some system engineers are inexperienced, and contractor experience is needed to sJpplement the program A limited number of ccrporate engineers hava chosen to relocate to the site There is still a backlog of plant modifications yet to be completed, i

l

24 ARGUMENTS FOR DECREASING CURRENT AGENCY ATTENTION e Effectiveness of Licensee Self Assessment Ma kod improvement in identifying and resolving performance issues Self-assessments are thorough and comprehensive

- Numerous design issues identified and resolved e Operational Performance (Frequency of Transients)

Very good operator performance during startups, operations, and shutdowns Excellent command and control and communications Strong commitment to increasing control room staffing and upgrading procedures e Human Performance Substantial decline in personnel errors Improvement in conduct of surveillance and maintenance testing Improved engineering performance; good questioning attitude and safety focus e Material Condition (Safety System Reliability / Availability)

Improved material condition of plant as a result of problem identification program Developing a state-of-the art work control program Maintenance organization mentor program in place o Engineering and Design System engineering program fully staffed j

Moviag design engineering to the site Completed modifications have improved system safety in reviewing the plant's performance, the senior managers acknowledged that there has been a substantial effort to improve performance at Point Beach, driven by a influx of new managers and an improved capability in the area of self assessment. Though the plant has still experienced some problems, there has been a noticeable decrease in personnel errors, good control of operations, considerable attention given to identifying their own problems, and better operability evaluations. The senior minagers observed that Point Beach's improved self-critical attitude has resulted in a large backlog of work, but the licensee seems to be identifying and correcting some longstanding deficiencies.

It was noted that the NRC's performance indicators indicated a large number of design and procedure related problems, but it was determined that this is due in great part to the licensee's self-assessment efforts. The licensee has enervated its engineering department by establishing a program to hire a large number of system engineers, significantly enlarging their staff. The design engineering staff is also being increased to enable the licensee to pursue co Tection of old design issues.

1

4 l

25 PolNT BEACH

SUMMARY

in summary, in reviewing the considerations for maintaining agency attention at Point Beach, the senior manegers noted that it may be beneficial to allow its improvement initiatives to continue for a longer period of time, in reviewing the considerations for decreasing agency attention at Point Beach, the senior managers acknowledged the licensee's efforts to conduct critical self assessments, improve human performance and the conduct of operations, and improve the material condition of its systems as a substantial response to the trending letter. ,

The fact that these efforts have resulted in substantive improvements strongly convinced the senior managers that, on balance, the licensee had arrested its declining trend. The senior managers determined that Point Beach would be sent a letter acknowledging that its trend had been arrested.

INDIAN POINT 3 Bac.karound Information:

5 Indian Point 3 (IP3) was placed on the NRC Watch List in June 1993 as a result of a performance decline that was attributed to weak management processes and controls, weak independent oversight, and a growing volume of plant deficiencies and operator performance errors. The plant entered an extended shutdown in February 1993 and did not restart until June of 1995. ' Additional material condition problems emerged, necessitating an extended maintenance outage in the latter part of 1995. The plant was again restarted in April 1996, and has operated fairly consistently since that time, with a few extended outages to address some material condition deficiencies as well as a refueling outage from May to September of 1997.

Based on overall improvement in site performtece and confidence that the improvements would continue, the senior managers removed 93 from Category 2 of the Watch List in June 1997.

Since the last SMM, performance at IP3 has been mixed. Performance initiatives continue, but

- progress continues to be slow and in some areas results have been limited. The licensee extended its 1997 refueling outage to address many longstanding equipment problems, but there were challenges to the equipment during the startup at the end of the outage, including several reactor and turbine trips, and work control practices still exhibited some weaknesses in work coordination and implementation. There has been an improved self assessment capability throughout the organization along with a conservative operating philosophy. A questioning attitude among the operators has been evident. However, there have been some repetitive issues with foreign material corfol and protective tagging. ,

Engineering is an area where significant improvement still needs to be made. Progress in reducing the backlog and implementing long term improvement plans has accelerated since the outage has ended. A reorganization of the engineering department aimed at improving organizational effectiveness was recently effected. Action plans to update design-bases documents are being implemented.

__,,_,.r--,-. --,,r.-,-,,,ww+ -- - ,-.-- i.-,.---,me.-.

26 l SMM Discusalon:

The senior managers noted that IP3 performance continued to be acceptable. There have been no significant enforcement actions, it was noted that allegation levels spiked to a fairly high level during the recent outage, but have since subsided. Some recent son!or management changes have occurred, the impact of which remains to be determined. The senior managers l acknowledged that progress has been slow, but that it is continuing. It was noted that continued close monitoring of IP3 by the region will need to continue, but that agency level l attention is not warranted. The senior managers noted that IP3 will be discussed one more j time as a status plant during the June 1998 SMM.

MAINE YANKEE Background Information:

Maine Yankee (MY) Nuclear Power Station was placed on the Watch List in January 1997 due to significant regulatory concems related to safety equipment operability, testing, safety evaluations, and corrective actions. These problems were uncovered principally during the independent Safety Assessment (ISA) team inspection and related follow up inspections from August 1996 to January 1997. In February 1997, MY signed a contract with Entergy Incorporated to provide management services to assist in restoring the plant to operational status. A self assessment uncovered additional root causes for the decline in MY's i performance and a new restart readiness plan was developed. The NRC staff noted signs of improvement in the licensee's safety focus and substantial outage work was identified.

However, on May 28,1997, the Board of Directors voted to reduce the level of spending while -

the future of MY as a viable asses was being determined. A final decision to cease operations and begin decommissioning activities was made by the Board on July 31,1997. On August 7

- 1997, the licensee filed its certification to the NRC of the permanent cessation of opers. tion and permanent removal of fuel from the vessel in accordance with 10 CFR 50.82(a)(1)(1) & (ii).

SMM Discussiori:

As a result of the decision of the Board of Directors to cease operation of Maine Yankee, the senior managers made the decision to administratively remove Maine Yankee from the Watch List as a Category 2 facility.

Additional Topics Discussed

1. EDO's Opening Remarks The Executive Director for Operations (EDO) welcomed the senior managers in attendance and noted that there were some vital discussions related to the SMM process that would take place during the SMM.- He emphasized that all the senior managers were " voting" members and that

~

maintaining the integrity of the process was important. He noted that the Chairman would be unable to attend but that copies of her prepared remarks would be made available and that she would address the group by phone later in the moming.

27

2. Chairman Jackson's Remarks The Chairman asked the senior managers to read through her prepared remarks and noted that since it was the beginning of the year, it was a good time for a review of the agency's accomplishments and to project wnat needs to be accomplished in the future. She noted that her presentation had four major themes: Communications, People, Planning, and Effectiveness of Regulatory Programs ar"J Assessment. Her comments in these areas are summarized below.

• Communications The Chairman noted that this was a broad subject, but that she wanted to focus on the processes that enable the Commission to have access to the information it needs to accomplish its work. She stated that those requetts of an informal and easily addressed nature should be met with minimal administrative burden on the staff. However, requests that engender a lot of work need to be handled through an orderly process, utilizing the " chain of command *, i.e., ths EDO and the Chairman.

• People The Chairman emphasized that the agency needs to recruit and retain the best people that we can. Development of individuals so that they can best help the agency is vital. She noted that severalinitiatives taxen on by the EDO, in particular succession planning and performance l appraisal, are very important. She also indicated that the recent high rate of attrition from the '

resident inspector ranks raises an important set of issues that needs to be addressed.

• Pb.nning l The Chairman noted that the Direction Setting initiatives, Strategic Plan, and Performance Plan I

have established the comerstones of the agency's planning process. She emphasized the need to look morebroadly at our planning and budgeting process and the importance of developing operating plans for each functional unit. She stressed the need for manage s to have a genuine commitment to this process. She also encouraged the senior managers to focus on outcomes and not on the number of activities that are accomplished. She acknowledged the difficulty in translating outcomes to activities, but dis has to be done before the issue of resource loading can be addressed. She strongly emphasized that programs fo#ow policy and that the budget dollars then fo#ow the programs.

She also asked the senior managers to develop the tools they need in order to determine when a program has run its course and could be 'sunsetted.' She acknowledged that the TARFIRE and ADAMS systems would provide senior managers with an effective resource mar,agement system and textual management system, respectively. She also recognized the need for further regulatory and information/ financial management training.

• Effectiveness of the Regulatory and Assessment Processes The Chairman listed a number of regulatory processes in which the agency has, or is, making improvements: plant assessment including the SMM, enforcement discretion, exemption

28 1 policy, lessons leamed out of the Millstone and Maine Yankee review efforts, FSAR, and 10 l CFR 50.59. She noted that changes in the SMM, the outfall of the Integrated Review of I Assessment (IRA), and the agency's response to the 10 CFR 50.59 related issues represent a l paradigm shift. The challenge to tnis agency is to create a new paradigm based on all the pieces that have been developed over the past several years, to implement the changes that are needed, and to continue the evolution of the regulatory process.

3. SMM Process Revisions and Initiatives Before the plant discussions commenced, the Director of the Office of Nuclear Reactor Regulation (DNRR) summarized the purposes of the SMM as outlined in MD 8.14, including identifying Wa:ch List plants, and communicating the meeting's results to the Commission, Congress, and the public. He asked that in light of the number of plants to be discussed, meeting participants attempt to stay within the time allocated for each plant discussion. He stated that the decisions for agency action would be made on th .econd day of the meeting using the SMM Nuclear Power Plant Performance Evaluation Template and Watch List Removal Matrix, as appropriate, as a guide. The DNRR also reviewed the use of the initial view sheets and how they would be used to summarize the bases for actions recommended by the senior managers and to focus the discussion on the second day. He emphasized that all the senior managers were voting members divided into two groups - those involved with day-to-day oversight of facilities and a QA group. He emphasized that all plants should go through the same process and discipline should be maintained in using the process.

The Director of NMSS (DNMSS) reviewed the se'eening process which the staff has developed to determine which fuel cycle and higher-risk mate ials facilities should be discussed at the SMM. He noted that the Commissiun directed the staff to pursue such a process in a June 30, 1997, SRM. In developing this process, the DNMSS noted that the current and evolving NRR screening process and the Arthur Andersen report of December 1996 were looked at very closely.

One of the greatest challenges in developing this process was how to incorporate risk insights.

The wide variety of facilities, the uniqueness between licensees in the same category, the generally smaller facility size and work force, and the different physical states in which nuclear material exists pose challenges to defining a process, as well. NMSS conducted a pilot process in the Fall of 1997, reviewing 8 major fuel facilities and 10 selected materials licensees. A screening meeting was held with each regional administrator to discuss performance, which included the use of performance indicators. The DNMSS noted that a Commission Paper !s being developed which will document the results of the pilot effort and make recommendations on how to enhance the process.

4. Enforcement issues The Director of OE provided information indicating that there are some apparent j inconsistencies regsrding non-escalated enforcement actions, it was noted that a reasonable ,

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29 level of consistency among the regions has been achieved relative to escalated enforcement l actions, but that one of the causes for this apparent inconsistency is that non-escalated enforcement lies medy within the purview of the regional branch chiefs and that the agency has not been proactive in s&ieving a good level of consistency. This was characterized as not only an enforceme.nt issue, but also an inspection issue, as the way inspectors treat open items and licensee-foured deficiencies is not always the same, it was determined that better guidance was needed an6 better training for inspectors and branch chiefs before this issue could be resolved, it wr.s recommended that a supplement, similar to that which exists for escalated enforcement tactions, be prepared to address lower level violations such as non-cited violations and minor violations. The Director of OE also noted that he will be increasing the staffing in both the rer,lons and headquarters, with the intent being to provide oversight in this area. This is a topic cI discussion at a meeting among the regional administrators and NRR in February, I

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ATTACHMENT 2 Senior Management Meeting Watch List Removal Evaluation Factors

- Crystal River 3

- Dresden 2 & 3

- LaSalle 1 & 2

- Millstone 1,2, & 3

- Salem 1 & 2

- Zion 1 & 2 e

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1/98 CRYSTAL RWER EVALUATION FACTORS FOR REMOVAL OF PLANTS FROM THE WATCH LIST Evaluation Factors Response Comments

1. Root Cause Identified and Corrected Weak performance areas are thoroughly a:,sessed. YES FPC has completed the efforts to discover the extent of  !

condition of their problems with inadequate: safety l evaluations (50.59), desgo control, and corrective actions.

NRC inspechons assessed the weak performance areas as adequate.

Comprehensive end clearly defined corrective action YES New program was inspected and determined to be program has been developed. adequate.

Corrective actions include sufficient measures to prevent YES Improving as management reinforces a hgher recurrence of problems. performance standard and a safety culture.

Management has allocated sufficient resources to carry YES Approximately 2000 personnel are onsite to preparing for out long-range corrective action programs. restart.

NRC is satisfied that corrective action program is YES The corrective action program has been inspected and sufficiently implemented. determined to be adequate.

Sustained, successful plant performance has been NO The licensee continues in an extended shutdown began on demonstrated. September 2,1996.

1/98 CRYSTAL RIVER Evaluaton Factors Response Comments II. Improved Self-Assessment and Problem i Resolution Evdent Program elements that monitor and evaluate YES FPC has stronger QA, Onsite (PRC) and Offsite (NGRC) ,

effectiveness of corrective achons have been instituted. Review Committees, and makes abundant use of outsde assessment groups.

Safety issues are bemg identified to appropnate YES I&miii.c4.on of safety issues has i...r c ;cd and is now management level and corrected in a timely manner. good l Quality assurance and safety oversight groups provde YES -

timely and effective self-assessments of performance to site ard corporate management.  :

Ill. Licensee Manaaement Orcanization and Oversicht Imoroved  ;

Corporate and plant management teams are fuity YES All top managers have been replaced with managers which ,

committed to achieving improved performance. are evdencing a strong safety ethic and accountability of ,

their staff. l Licensee has effective corporate management oversight YES and invo'vement in plant operations and problem resolution.

Management team provides strong direction and fosters YES a nuclear safety work ethic that is understood at all levels i in the organization. ,

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1/98 CRYSTAL RIVER Evaluation Factors Response Comments IV. NRC Assessment Com!2Leit Senior NRC management no longer considers the plant NO Plant is stillin recovery phase.

as having weaknesses that warrant increased NRC-wide attention.

I Significant NRC inspection and licensing activities are NO Inspection plan is coordinated with the licensee's restart complete and findings pu,perty resolved or understood. readiness plan and goes through the end of 1997.

1 V. Additional Considerations l Overall performance has improved as reflected in the YES SALP has been postponed during the long term shutdown most recent SALP ratings, Performance Indicators, or until six months after restart. PPR indicabs general results from the Plant Performance Review. improvement.

Enforcement history has indicated an improving trend. YES Significant enforcement has been on old issues, mostly licensee identified.

Performance has improved as demonstrated by a lack of NA Plant has not been operated.

operational problems.

Performance has improved as demonstrated by a lack of NA Plant has not been operated.

significant operator errors.

Procedure adherence problems are not evident. YES Substantive procedure adherence problems are not evident.

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1798 CRYSTAL RIVER Evaluabon Factors Response Comments Sunulatcris operabonal. YES i

Known (i.e., plant specifs or industry genenc) aging NO problems have been appropnately addressed.

t Licensee has improved its management organuation. YES All top managers have been replaced with managers which are c. A-49 a strong safety ethic and accountabihty of  ;

their staff. +

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Licensee procedures are cormidered adequate overall YES l Licensee has an effectwe root cause analysis program. YES ,

i PRA has been performed. YES PRA has been used. YES

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DRESDEN  ;

EVALUATION FACTORS FOR REIROVAL OF PLANTS FROII THE PROBLEM PLANT UST  !

Evaluabon Factors Response Comments

l. Root Cause Ident:fied and Corrected Weak performance areas are thoroughly assessed. Yes The 'Dresden Plan" was i ..,1.^,.J in 1996, and the 1997

[

Opershonal Business Plan is the tool used to monitor  ;

perbrmance and track ;.i.,,.u. c.-,4 iruhateves. The i independent Safety inspechon (ISI). conducted in the faR j of 1996, ea'w.i.C, reviewed aN performance areas and  !

identified a number of problems. The beensee has i reviewed these findings and r. ken aggresswe achons to l address them. One resulbng corrective achon was the licensee's creation of the Dresden Eruyneenng Assessment Group which has conhnued to assess the area of engineenng. Mantenance was assessed by an NRC maintenance team inspechon conducted in April 1997. Further, the Dresden specdic response to the January 27,1997,50.54f request was candid and identdied achons to te taken to conhnue ;. .,,. . c.m.45. t t

Comprehensive and clearty defined corrective achon Yes The Dresden Plan which focused attenhon on six specdic program has been dc.;;W. areas was uv .,A.",_d in 1996. The current corrective achons program is captured in several ongong efforts  ;

includmg the stahon's Opershonal Plan, the comnutments j confirmed by the NRC's CAL dated November 21,1996,  !

and the March 28,1997, Comed 50.54f response (Sechon i i

5.1). In addshon, the licensee has strengthened the process for the resolubon of problems by implemenhng a corrective achon review board to provide closer scrutmy of  ;

proposed correctrve achons.

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1798 DRESDEN l

Evaluation Factors Response Comments Correct:ve actxms mciude sumcient measures to r e ...a Yes Station performance *cr .... a plans irweM both recurrence of problems. techrwcal and superwoory trasung for the stabon's engmeenng and mantenance staff. Increased attention to the formal management review programs and the corrective schon system have improved effeceveness at identdymg and iM.;.y problems and adverse trends.

The Safety and Quakty Assurance organeshon has been merusive and idenedied pmblems and trends earty and evy Mai,, resulhng in effechve conectrve achons.

Management has allocated sufficent resources to cany Yes Long range corrective action programs have been given out long-range corrective achon programs. adequate resources. Of note was the added meresse to the 1997 budget for further improvement iruhateves. The pipxd 1998 budget also has funding for plant nipcc.i a projects.

NRC is satisfied that corrective achon program is Yes ^orrechve achon programs have been 'unplemented and sufficently implemented. ..pcxd performance by the plant and the licensee's staff have been observed. Some procedural adherence and procedural adequacy problems occur, but these are isolated, and occur at a rate on par with other piants. The licensee addresses these problems when they are Klenhfied. Plant matenal condibor; has been greatly

,,vcad as demonstrated by the work completed and

v.pund opershon of equipment. Some problems with feedwater system components remain.

2.

1/98 DRESDEN Evaluation Factors Response Comments Sustained, successful plant performance has been Yes Plant performance has improved substanhally. In 1996 demonstrated. forced outages occurred on both units. ik,w;=, between September 1996 and March 1997, both units operated concurrently for about 5 of the 7 months. Dual unit l opei t;00 smce the Unit 3 restart in June of 1997 through December 1997 has only been interrupted by a manual scram on Unit 2, and a shutdown of Unit 3 to repair a cracked weld on a primary system.

11. Imoroved Self4ssessment and Problem Resolution E' u tut Program elements that monitor and evaluate Yes The licensee has used a monthly trend status report by the effectiveness of corrective actions have been instituted. Quality and Safety Assurance orgamzaten for some time.

This report monitors issues generated as part of the integrated iepeit;ig program. The report contmues to be highly successful in identifymg repetshve problem trends in addsten to creating and trik.iuig correchve achons to resolve the problems. The station also issues a monthly performance report trackmg plant performance mdicators.

And, h response to the Comed 50.54f request, the company has insbated addsbonal performance indicators, tracked at all the Comed nuclear plants, which are takw;d monthly with wipei.ie officers and all of the site VPs.

Safety issues are being identified to appropriate Yes Significant issues are idenhfied and promptly investigated.

management level and corrected in a bmely manner. Correctrve achons are rakw;d by a plant operational 3

1/98 DRESDEN Evaluation Factors - Response Commente review committee that has become more effective.

Communications between Dresden, Quad Cities, and corporate ergir.;;.-irg have significa:;tly higcec-d.

Quality assurance and safety oversight groups provide Yes The licensee developed a plant operational review timely and effectsve self-assessments of performance to committee that has been increasingly effectrve. It has site and corporate management. been a major imgcv;.nent over the licensee's old method of on-site review. The Quality and Safety Assurance i i

(Q&SA) organization increased its effectiveness with the development of the Monthly Trend Report. Res# dent mspectors have observed that the Q&SA orgaruzation has had increased effecbveness at the site over the last year.

it has identified c: sign nt issues and trends and prorr.pted thorough corrective acbons.

Ill. Licensee Manaaement Oroanization and Oversicht imoroved Corporate and plant management teams are fully Yes Corporate and plant management have brought in outside committed to achieving improved performance. talent with sig#n.irnt experience and, in some cases, with expenence in *1uming around" an wgr.inot;on. Examples include the Site VP, Station Manager, Engmeenng Manager, Maintenan:e Manager, Radiation Protection 4

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'i 1.98 DRESDEN

• Evaluation Factors Response Comments l Manager and the Engineering Design Supt. The site vigc.n;zation has been a fairty stable orgaruzation since 1995. The result has been a consistent and strong  ;

message of performance expectahons, standards, and j accountabinty. Though corpoiew management changes

, have occurred, the changes have not impacted the Dresden isn, c...vi.c4 efforts. l Licensee has effective corporate management oversight Yes The Site Vice President has been highly effechve in i and involvement in plant vpciahons and problem focusmg plant management attenbon on problems and i resolution. iivaieng management accountabihty. This has elevated i performance throughout the plant. Comed recently ,

i unplemented extensive changes in ceipviisia management the results of which are bemg morntored by commstments  ;

in the 50.54f response.

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Management team provides strong direction and fosters Yes Management team has provided strong drechon fostenng >

l a nuclear safety work ethic that is understood at all levels a nuclear safety work ethic. A strong safety ethic has bewi l in the organization. evident in the iiripica-d performance in operabons, the ,

j implementation of self-chm.; dig pic.ctices, and dehberahons of the curiccti.e achon review board and the

! plant operahons review committee. Occr.sioni.i errors  !

occur in individual performances, but these are i

commensurate with performance at other plants i

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1f98 DRESDEN Evaluation Factors Response Comments siyi;T-d ;iiiru...i ia in Opershons and a dechne in - -

Mantenance. The most recent SALP period ended J November 22,1997. Dehbershons of the rahngs are in progress. The SALP board poted sustained u' nprovement in operstms, and general ic pc.... a in the other areas.

Performance indicators and the PPR conanued to show '

unproved performance. Performance indicators by Comed also indcate kiir c-.e.. ee.

Enforcement history has irxfhated an improvmg trend. Yes Escalated enforcement achons have declined in frequency and significance. As expected for a large in-depth inspechon, the 1996 ISI idenhfied a number of violabons in several areas. The licensee has taken correchve schons in response to the ISI inspechon, and kiirc.c.T=i45 have been noted.

Performance has improved as demonstrated by a lack of Yes Dresden Unit 2 has operated well smce the plant restarted operational problems. from an extended refuel outage in 1996. Although there were equipment problems on the plant restart, Unit 3 has operated well smce complete of its refuel outage in June of 1997 with a short forced outage this faR to repair a pnmary leak. Recent plant startups/ shutdowns and single loop operate, a histoncally difficult evoluhon for Dresden, have been essenhaNy error free with the majonty of equipment operahng as expected.

7

i 1798 DRESDEN Evaksetkm Factors Response Comments  ;

i Performance has improved as demonstrated by a lack of Yes Operator attenbon to detaH in the control room has signdicant opemtor errors. dramahcaNy 'unlmved since earty 1995. As a result, the  !

number and segndicance of operator errors has been reduced.

Procedure adherence problems are not evident. Yes Although some procedural a@erence problems have occurred, the number and signWicance have been reduced  !

such that the errors are in the range of normal occummce l at a dual unit site. The licensee has identdied this as an area not .T .: g management expectabons, and this has l been identdied as an issue for management attenhon. i l

Simulator is operational. Yes  !

t All identified aging problems have been addressed 6 the Yes Smlar to the core shroud repair performed on Unit 2, the  !

i NRC's satisfachon. Iscensee repawed the Unit 3 core shroud dunng the spnng 1997 outage. The staff reviewed and approved the licensee's reper technique. [

Licensee has improved its ma; agement organization. Yes The senior management team has been in place for about 2 years and includes segndicant outside expenence. t I

Licensee procedures are consioered adequate overall. Yes Overall, proceduies are adequate. When a problem is  !

noted in a procedure, it is being corrected. The most l

signdicant procedure weakness was the out-of-service  !

j procedure which has been revised and 1997 performance with out-of-services has greatly ..,c; ;1 i

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1/98 - DRESDEN Evaksation Factors Response Comments Licensee has an effective root cause analysis program. Yes Overall, the licensee's root cause analysis program has

,rpicacd and has demonstrated e#ectiveness. For example, a thorough root cause analysis was demonstrated in c=.r,-24 the contnbutors to the July 1997 Unit 2 manual scram. This resulted in several correchve achons which the bcensee has implemented.

1 PRA has been performed. Yes After several revisions to the IPE analysis, the staff concluded the IPE sutmuttal met the requwements of GL 88-20 in October 1997.

PRA has been used. Yes The hcensee has been usmg PRA in the day-to-day operation of the facility smce 1995. The licensee identifies

" protected pathways" dunng routme mantenance from a risk assessment using PRA. These risk assessments are used daily in work and surveillance scheduling.

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i 1/96 i i l l LASALLE COUNTY NUCLEAR POWER STATION f

. EVALUATION FACTORS FOR REMOVAL OF PLANTS FROM THE PROBLEM PLANT LIST t

Evaluahon Factors Response , Comments

l. Root Cause Identified and Corrected i

l Weak performance areas are thoroughly assessed. Yes issues have been identdied by NRC and from licensee

, self-assessments and a comprehensive Restart Plan has  !

- been implemented for idenhfied problems. The hcensee's  !

Restart Plan consists of five strategic areas for ;ii.,,c;;d  ;

performance. The areas are: 1) safe plant operations; 2) .l plant matenal condition and effectrve outage ani63; 3) i corrective actions, assessments and engmeenng support;  ;

4) effective work control, and 5) human interachon and - ,

pedu irwice. In addition, the licensee's 50.54(f) response  !

l was comprehensive and incle.n1 plans to review several l i processes at LaSalle that were identified as deficient.  !

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i Comprehensive and clearly defined corrective action Yes The beensee has implemented schons associated with its l program has been d;;;W revised correchve achon program defined in its Restart j

Plan such as estabhshing a Correchve Achon Review j Board. i i

Corrective achons include sufficient measures to pie. cat No The hcensee wwt ated several progra.i.mahc actions to j recurrence of problems improve the corrective achon process such as estabbshing i a Corrective Achon Review Board. These achons provide  ;

a foundation for future ;n pic.;.. .;, but its too early to tell  ;

j if these iruhateves are being .M;d,- implemented as l

- reflected in ;5e absence of recumng problems. Although some progress is apparent, conenued focus is necessary l l  ;

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1/98 LASALLE COUNTY STATION Evaluation Factors Response Cuinn,eiits to ensure consistent quality of root cause determinahons and implementation of conectrve achons.

Management has allocated sufficient resources to carry Uncertain Sufficient resources have been assigned to support plant out long-range corrective action programs. restatt. However, plans to address long-term performance ,

knprovement are not as clear and so resource needs have not yet been assessed.

NRC is satisfied that corrective action program is No Although licensee achons to improve the corrective achon sufficiently implemented. process has resulted in some progress, continued focus is necessary to ensure consistent quality of root cause ,

determinations and implementation of cuitective actions. I Although these initiatives set a firm foundahon for future improvement, corrective action problems still occur. These improvement measures have not been in place long enough to realistically expect plant peraonnel to have gained the skills and total understanding of expectations to implement an effective corrective action program.

Sustained, successful plant performance has been No Both units have remaired shut down since SemA -

demonstrated. 1996. Restart is not anticipated until April 1998.

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1/98 LASALLE COUNTY STATION Evaluation Factors Response Comments

11. imoroved Self-Assessment and Problem Resolution Evident Program elements that monitor and evaluate No The Icensee has not yet assessed the effectiveness of effectiveness of corrective actions have been instituted. many of their hTirc-.;.T,orii achons Several a sessments l whch the hcensee plans to finish before plant restart, such as those performed by Corporate and the Eite Assessment and Quality Verfication organizabons, are not w,i ,1.L. In response to the NRC's 50.54(f) letter, Comed has initisted additional performance indicators, tracked at all the Comed nuclear plants, wtuch are reviewed monthly with ceipeinte officers and all the Site Vice-Presidents SafrAy issues are being identified to appropriate Yes The licensee's atwhty to identify and implement actior's to mtnagemeM level and corrected in a timely manner. correct safety issues has been steadily improving. F80 table examples include operator performance deficiencies identified and addressed in the High Intensity Trainmg Program and plant design, material conditx,n, and surveillance procedure deficiencies identified in the Safety System Fuactional Reviews.

, Quality assurance and safety oversight groups provide No Licensee oversight groups had previously not been timely and effective self-a wssments of performance to effechve in identifymg and ensunng sufhcient section to site and corporate management. address problems. The hcensee just recently announced a isvigi--hation that would place the Quahty and Safety Assessment (Q&SA) orgeruzation and the Cviid.

Action Frey ii under the direct control of Corporate 3

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1/98 LASALLE COUNTY STATION Evaluation Factors Response Comments personnel versus the Site Vice-President. It's too early to evaluate the net effeci of this acten.

I lit. Licensee ManW Orcorhi :-i and Oversicht l Imoroved l Corporate and plant management teams are fully Yes The Site Vice-President has implemented a long-term committed to achieving improved performance. improvement strategy and is focusmg efforts on ensunng plant personnel stay on the established path. The piant management team understands and is supporting the current course of acten.

Licensee has effective corporate management oversight No The Site Vice-President has had some success in effectmg and involvement in plant operations and problem improved performance. The licensee recently resolution. implemented extensive changes in core vi.te management the results of which are bemg monitored throuoh followup of the 50.54(f) letter. It's too early to ascertain how these new managers will ulhmatelym' teract with and affect ongomg siiipic.c.ric-sit strategies.

Management team provides strong direction and fosters Yes The Site Vice-President and Plant General Manager have a nuclear safety work ethic that is understood at all levels conducted meetings for plant staff and cuisii.ctors to in the organization. address management expectahons for individuals have been communicated to everyone. The Erig;r.;;.-irig and Quahty and Safety Assessment orgamzabons have

. increased expectahons for improved currective schons and 4

,1798 LASALLE COUNTY STATION Evainfon Factors Response Comments communicated the expectatens to the plant staff. Based on interviews with plant personnel, overall iT,pic.;.Tw.i has been noted in the workers' wilhngness to work with management to ad.+?ss the plant performance  ;

deficenoes.

1 IV. NRC Assessment Complete Senior NRC management no longer considers the plant No Based upon the most recent plant performance review, the - .;

as having weaknesses that warrant increased NRC-wide licensee is making progress towards resolving some deep- j attention. seated performance problems Overall performance has shown some signs of improvement commensurate with the current status of the Restart Plan implementation and for a plant trying to implement drastic cultural and programmatic chano w Significant NRC inspection and licensing activities are No The NRC is implementmg a Manual Chapter 0350 restart complete and findings properly resolved or understood. plan for LaSalle Station. This plan, as well as the licensee's Restart Plan, concentrate on issues pertment to restart.

V. Additional Considerations Most recent set of Performance Indicators reflect oveH No The most recent (September 1997) AEOD performance improving performance. indicator report indicates little operational data available since the plant remains shut down and mainly reflects tim licensee's improved identification of pre-existing design and procedure deficences. These results also 'mdicate 5

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1/98 LASALLE COUNTY STATION Evaluation Factors Response Comments that while not high i., number, current problems consisted of poor control of plant actmbes by the operahons depoiusat, usually a result of poor personnel performance.

Overall per'ormance has improved as reflected in the N/A The October 1996 SALP noted a dechne in Operabons and  ;

most recent SALP ratings. Ergir.;;. irs from Category 2 to Category 3. Maintenance J remamed Category 3, whde impcec.T= 4 in the Plant Support area was noted and rated a Category 2. The large amount of emergent work and poor work control -

processes limited plant material condshon knpicea.re45.

Operations sa'ety focus was cc.h unsatisfactory and weaknesses in ergir.cc.irg support to operanons were noted. The current SALP assessrnert nenod has been -)

extended until ssica;reeteN 6 months after startuo of one of the reactors at LaSalls Stabon.

Enforcement history has indicated an improving trend. Yes Violations continue to be identified at LaSalle, but at a reduced rate and a lesser seventy level smce the plant shutdown began. Enforcement descrebon has been giveri for several design and wiective achon problems identified by the licensee since the event.

Performance has improved as demonstrated by a lack of No The plant has not been operate i smce bemg shut rlown in operational problems. September 1996. The licensee has implemented extensive actions such as the Operator High intensity 6

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1/98 LASALLE COUNTY STATION Evaluatioa Factors Response Comments Trainmg Previ.ni to address opershonal deficionaes.

' Although some effechve progress is apparent, conhnued focus is necessary to ensure more consistent performance improvement across the operahng organizahon.

Performance has improved as demonstrated by a lack of Yes The licensee has aggressively pursued operator significant operator errors. performance improvements in accuid.nce with their Restart Plan. In particular, a High intensity Trammg (HIT) program was implemented to address identified operator i performance weaknesses. indmdual operator and operating crews were remo;ed from shift duty as a result  ;

of heensee simulator evaluahons conducted dunng the HfT program. Some improvement has been noted and although some operator crrors have contmued, none have been significant.

Procedure adherence problems are not evident No- Some improvement in operator procedure adherence is evident However, impic.c.Tsit is not consisient and problems remain with some operahng pemonnel.

Simulatoris operational. Yes The simulator has been observed to funchon properfy.

All identified aging problems have been addressed to the Yes The licensee contmues to replace General Electnc (GE)

NRC's satisfaction. SBM (swithboard, fr.insature) control switches throughout the plant because the switches are at the end of their qualified life and GE recommended a changeout of the switches to address a manufactunng process problem.

I 7

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(

1/98 LASALLE COUNTY STATION Evaluation Factors _ Response Comments Licensee has improved its management organization. Yes Plant management, including the plant manager, contriue to emphasize clear standards of performance to plant personnel and is affecting positive change.

Licensee procedures are considered adequate overall. No A procedure upyade program has been slowly progressing. The licensee identified many procedural deficencies throtnjh its Safety System Functional Reviews.

All associated procedure changes are not yet complete.

Plant staff understand the expectations for strict procedural compliance, look for procedure problems, and correct the problems before proceeding with work.

Licensee Ns an effective root cause analysis program. No The licensee has implemented several initiatives to improve root cause anaiysis such as establishing a Corrective Action Review Board to begin re-enforcing expectations in this area. Although a foundation has been established on which to base future improvement, continued focus is necessary to achieve consistent and sustained improvement.

PRA has been performed. Yes Complete.

PRA has been used. Yes The licensee has a shutdown risk program and an on-line rit.k program for use during daily plant operations.

8

l{'. ?

MILLSTONE 1 EVALUATION FACTORS FOR RERPOVAL OF PLANTS FROM THE WATCH LIST .--

Evaluahon Factors Response Comments I. Root Cause identified and Corrected Weak performance areas are thoroughly No The current Unit 1 condshon report (CR) bodkg is 2006 (level 1 and 2 assessed. CRs), with an increasing trend. The number of level 1 and 2 CRs that j are open greater than 120 days is 978, also with an increasmg trend ]

Plant management has placed a high pnonty on completog evaluahons I within 30 days and has seen lwnsted successes. The sizable bsGkw j and limited engmeenng resources, severely impacts the licensee's .

' ability to thoroughly assess weak performance areas.

Plant management has not successfully implemented a cuiic Comprehensive and clearly defined Unknown corrective action program has developed. action program at Unit 1. In February 1997, the hcensee implemented a major revision (Rev.4) to procedure RP-4, Correchve Achon, which has not resulted in siviJicoid ;i6pic.e.Tiiisas in the corrective achon process.

This revision of the CR process was poorly implemented in that specdic guidehnes were not put in place to ensure the inehation and ppivpii.te processing of CRs for conditions adverse to quakty. The bcensee has stated that Revision 5 to RP-4 will correct many of the problems identified by the NRC. RP-4, Rev.5, will be evaluated at a later date.

Corrective actions include sufficent Unknown The use of the Multi-Discipline Management Review Team (MDMRT) measures to prevent recurrence of has improved the quality of correchve schon plans for level 1 CRs.

problems. However, repetitive CRs continue to occur. The unit has not yet attained a level of performance to demonstrate that the corrective action

. program is improving l

1/98 MILLSTONE 1 EvWM Factors Response Comments Management has allocated sufficient No The recovery vigonizahon has reduced resources to deal with the

. resources to carry out long-range corrective achon program and the CR backlog as a result of focusing corrective action programs. efforts on the support of Unit 3 and Unit 1 CMP. The reduchon in the l

.- contractor work force and a restnchon of overtime on Unit 1 has also impacted the corrective achon program. The stulity to pi;J;.it the recurrence of problems, reduce the backlog, and deal with the long-range wiiwctive schon programs has not been demonstrated.

NRC is satisfied that corrective action No As stated in NRC IR 9644 (June 6,1996): "Many of the current program is sufficiently implemented. .ppaient violabons and some of the outstandmg violshons discussed in j

~

this report, deal with inadequate corrective achons at all three units, and are associated with the current adverse condetson reportmg system. We have concluded that the corrective achon program is not currently ,

effective in correcting idenufied deficienesee " In NRC IR 97-02 (June l 24,1997) we stated that: ". . .. overall, the v Jementahon of procedure RP-4, Corrective Actions, Revision 4 has -sulted in only hmsted imprcve.T, wats in the correchve achon process. The revision of the CR process was poorfy implemented . . . Additionally, there appears to be some reluctance on the part of some Unit I staff to iruhate condshon reports."

Sustained, successful plant performance No Violations continue to be identified in NRC inspechon reports These has been demonstrated. violations illustrate that resolution of identified deficiences in a twnely manner continue to be a sivi,Eent challenge to managemerd. Little progress has been demonstrated to implenumt corrective achons for these deficiencies 2

1198 MILLSTONE 1 Evaluation Factors - Response Comments II. Improved Self-Assessment and Problem Resolution Evident Program elements that monitor and Yes Measures of effectiveness are requwed by RP-4 corrective achon evaluate effectiveness of corrective procedure (Revision 5, implemented on September 30,1997) for all actions have been instituted. level 1 CRs. "Effectrveness Reviews are conducted for all Level 1 CRs .

following the complebon of all Corrective Achons and sufficient time has transpired, normally,6 months to a year." Addshonally, quarterly trending of the AITTS database related to CRs is requwed. i Safety issues are being identified to No NRC IR 97-02: "Condehon reports are not being 'wnhated consistent with appropriate management level and the program requirement desenbed in procedure RP-4. Based on corrected in a timely manner. discussions with the icensee's staff, the number and significance of some of the examples either not reported, reported after NRC -

prompting or delayed without attemahve reasons, there appears to be -

some reluctance to initiate CRs. Several deficencies were also noted in the initial operability and reportatnhty screening for a number of the CRs reviewed."

Quality assurance and safety oversight Unknown A July 1997 independent assessment of Nuclear Overssght stated: "The groups provide timely and effective self- team found that the Nuclear Oversight organization has made assessments of performanco to site and considerable progress over the past six to nine months. Mc c.t,' the corporate management. team also found that significant additional improvement is requwed-both from Nuclear Oversight and from Millstone Station serwor management-before the Oversight orga: 'zation will be fully effective." Day to day oversight input at the plant level has u' nproved. The Operational Expenence (OE) group, part of safety oversight, has a significant backlog of 107 open evaluations, with a mean age of six months.

3

1/98 MILLSTONE 1 Evaluation Factors __

Response Comments Ill. Licensee Manaaement Ornan_igattmi and Oversicht improved Corporate and plant management teams Unknown While there is a reduction of restart activities at Unit 1, through the end ere fully committed to achieving improved of this year, configuration management progr ir6 actnnbes contmue.

performance. Followmg a major reduchon of the c6nb ctor work force for the CMP project, approximately 40 plant personnel from operations, engmeenng (all but 1 system engineer and 8 dessgn engineers), and maintenance were temporarily assigned work on the CMP. Additionally, more than one half of the maintenance dep Li. ant including mecharucs, electncians, I&C technicians, planners, and technical staff engmeers, are working at Unit 3 in support of restart efforts. Limited resources have impacted management's ability to achieve improved performance.

Licensee has effective corporate Unknown Corporate Management does not appear to have the proper management oversight and involvement in involvement in plant operations as indicated by the inability to provide plant operations and problem resolution. an accurate reliable restad schedule. Repeated schedule changes and a lack of understanding of the current workload needed for restart. -l would indicate that Corporate Management does not have sufficient involvement in plant operations. Corporate Management is also unable -

to develop and implement a plan to establish a safety conscious work environment.

4 l _ .___- _____ _

1/98 MILLSTONE 1 EvMustian Factors Response Comments Management team provides strong Unknown The management from PECO Energy is now begenmg to replace direction and fosters a nuclear safety work members of the origi" i recovery team. The directors of engmeenng ethic that is understood at all levels in the and maintenance, ar. the design manager have been replaced. The organization. ope.~ations manager and the assistant operahons manager have been replaced, after the previous opershons manager left the company. The supervisor of heense tirJrarg, tre manager of regulatory comphance, and the ergirs.-irs tech. support manager, have also left the company and were replaced with a mix of NU and PECO people. While the management team attempts to pr' *! strong direchon and foster a good nuclear safety work ethic, tte frequent management changes do ,

not contribute to the stability the orginiizabon needs to provide  !

continuity and leadership.

IV. NRC As===sment Complete Senior NRC management no longer No With significant improvement yet to be demonstrated and continued considers the plant as having weaknesses weaknesses being identified, NRC-wide attention is warranted. CMP that warrant increased NRC-wide discovery continues, which provides some uncertainty as to the attention. magnitude of the design deficiencies at Unit 1.

5 l

1/98 MILLSTONE 1 Evaluation Factors Resoore. Comments Significant NRC inspection and licensing No The development of the 11RC's significant items list (SIL) was activities are complete and findings completed with 108 items being identified. To date, we have received properly resolved or understood. one completed package, and an accurate schedule for completion of these issues has not been developed. There are approximately 220 NRC open items at Unit 1. The licensee intends to provide a corrective y

action closure package for each of these items. To date, we have received 11 completed packages. An extensive inspection effort will be required to resolve both the hardware and programmatic issues at the site. Since the CMP is stillin the discovery phase with no scheduled date for " ready for ICAVP," the extent of future licensing activitie , are not known at this time. The licensee is also developing their SIL in an effort to docket that information.

V. Additional Considerations Overall performance has improved as No Overall performance has not improved, as reflected in the current PPR.

reflected in the most recent SALP ra'ings. Continued management changes (additional PECO personnel) and l Performance indicators, or results from ongoing program development (work control process, corrective action the Plant Performance Review. program, and project management concepts for plant modifications) continue to challenge the stability of the organization. Additional time and effort will be required before substantial improvement can be demonstrated.

)

6

r 1/98 MILLSTONE 1

- Evaluation Factors Response Comments Enforcement history has indicated an No Enforcement history for Unit 1 smce January 1995 is as follows improving trend. l 1995 - 15 violahons and 13 Eels -

1996 -7 volabons and 17 Eels 1997 - 3 violatons and 11 Eels i

The currernt viforcement history for the unit doec iot indecate an improving trend. Violatens continue to be kjent6vd in our inspecten reports. ,

i Performance has improved as Unknown Based on current plant conditions and the low level of plant actmty, the demonstrated by a lack of operationst operations staff has not been significantly challenged Therefore, problems. petformance whole operatmg at power has yet to be demonstrated.

Performance has improved as Unknown Same as abem.

demonstrated by a lack of significant operator errors.

Procedure adherence problems are not Unknown Site management has emphasized the importance of procedural 1

evident. adherence. However, the current low level of actmty in the plant does not provide enough information to ~mdecate or trend a procedural adherence problem A recent violation of a work control procedure would indicate a problem still exists.

i 7

1/98 MILLSTONE 1 Evaluation Factors . Response Comments Simulator is operational. Yes Hcwa=, recent problems identded by the NRC and the licensee witis respect to the trammg depart nent have raised questions about the effectiveness of the operator travung program. While the requalificahon program is bemg implemented with a reduced traming staff, the inshal ,

facense training is on hold until the SAT program can be evaluated. An initial class is scheduled for February 1998.

Known (i.e., plant specific or industry Unknown The plant staff is addressing material condition and equipment issues.

generic) aging problems have been However, we are not aware of any specific efforte on the part of the appropriately addressed. licensee to address the issue of plant agog Licensee has improved its management Unknown Although significant changes have occurred in the management g organization. organization as stated abnve, the overall effechveness of these changes has yet to be demonstrated. Smce October 1996, when the  ;

^

PECO recovery organization amved, there have been chenges in 15 of 16 key management positions at Unit 1. ,

Licensee procedures are considered No. Even after the licensee implemented a mulh-phase procedure upgrade adequate overall. program that lasted for a number of years, procedural problems continue to be identified. Problems with off-normal, general operating, and emergency operating procedure have been noted. For example, the service water normal operating procedure does not cc7tain appropriate guidance for determining normal system operahng

. parameters for,cw:.ig system restoration. An independent assessment conducted by nine Peach Bottom operators and traming personnel in April 1997, identified that "The station operating procedures (ops, ONPs, and ARPs) were found to have mulhpie challenges due to a general lack of direction and control of plant equipment."

8

1/98 MILLSTONE 1 Evaluation Factors Resoonse Comments Licensee ;ias an effective root cause No The licensee has made a number of attempts to correct problems with analysis program. the root cause analysis program, which to date have not been effective.

The most recent attempt has included the use of human performance evaluation system (HPES) personnel. One HPES coordinator has been assigned to each unit to assist in the root cause analysis process.

PRA has been performed. Yes The Millstone Unit 1 IPE is completed, and was evaluated by the NRC as having lets detcil than the average. Inspection issues resulting from the IPE evaluation (spc,,ificis*1y for Unit 1) included: the need for review of the adequacy of improvements to the loss of 120VAC diagnosis / response procedures, and inspection of the ADS system reliability, maintenance, and testing.

PRA has been used. Unknown The Licensee had planned to implement a risk-based maintenance schedule during the next cycle. Additionalinspection is needed to j determine the status of that plan.  !

9

1I98 MILLSTONE 2 EVALUATION FACTORS FOR REMOVAL OF PLANTS FROM THE WATCH LIST

^

Evaluation Factors C O. . .. ,s, . ui,

_Resconse I. Root Cause identified and Corrected Weak performance areas are thoroughly Yes The licensee's leti.v- dated July 27,1997, " Progress Toward Restart assessed. Readiness at Millstone Station," addresses the broader management performance issues by providing their assessment of what the site-vdde restart issues are, their plan to address EACH of the issues, progress in implementing the plan, and measures to evaluate effectiveness of these corrective actions. For site-specific issues at Unit 2, assessments and corrective actions to add ess technical issues and programs are ongoing. Since the implementation of corrective actions often results in the generation of new condition reports and a resulting eximnsion of outage scope, and therefore, assessment of weak performance areas is ongoing. For example, aKhough the Electrical Equipment Qualification (EEQ) Program is a known programmatic concem, specific EEQ l deficiencies continue to be identified. l 10 E _

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

1/98 MILLSTONE 2 I

Evaluatior Factors Response Comments Comprehensive and clearly defined Unknown The Corrective Action Program itselfis generally acceptable, corrective action program has developed. implementation of the program has been a concem, particularly regarding completion of identified coma:tive actions in a twnely manner which is reflected by the large backlog of Condehon Reports. For severa! years the licensee has touted revisions to procedure RP-4,

" Corrective Action", as tf 3 soluhon to the correchve action problem

However, these " quick and easy" program changes did not affect needed performance improvements because the real problem is that ,

there was insufficient pnonty and resources provided to disposition idantified issues. Although the licensee is currently providing these  !

resources, dispositioning the Condition Report backlog is a tremendous task, particularly because many require resolubon by the already taxed Engineering Department. ,

i Corrective actions include sufficient Unknown Millstone is characterized by the pervasiveness of problems much more measures to prevent recurrence of than by the occurrence of significant events. The culture of low problems. standards has created many areas where due to the inattention has resulted in substandard and often inadequate performancc. Although the NRC can review the current condition of any specifw technical issue and programs, a key element in prne,niig recurrence involves cultural changes. The recovery managers clearly are expecting higher standards, in addressing these widespread performance issues.

However, ttrre has been limited opportunity for the new management team to raise standards and provide a sense of assurance that changes will be lasting.

i  !

s 1

11

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1/98 MILLSTONE 2 Eyguallon Factors ResDOnse Comments Management has allocated sufficient Unknown Although the licensee has defined many of the corrective actions that resources to carry out long-range they plan to complete after restart, the resources needed to complete corrective action prograhis. these tasks is still largely undefined. Based on the licensee *s well-established history where promised performance improvements were not realized, licensee assurances conceming their post-restart activities should be treated with great skepticism. This will be a consideration in the upcoming inspection of the items the licensee plans to defer until after restart.

NRC is satisfied that the corrective action No Corrective action program implementation has not yet been reviewed by program is sufficiently implemented. comprehensive NRC inspection activities. The licensee has delayed declaration of readiness for an NRC MC 40500 inspection in order to further assess implementation and effectiveness of the corrective action program.

Sustained, successful plant performance No Although there are some signs of progress, overall plant performance has been demonstrated. has not reached a point that can be described as successful, let alone sustained.

II. Imoroved Self-Assessment and Problem Resolution Evident Program elements that monitor and Yes Although the elements have been instituted by procedure RP-4, evaluate effectiveness of corrective " Corrective Actions," the effectiveness of these program elements has actions have been instituted. yet to be established. A recent QA Audit of the corrective action program identified trending as an area of concem. Revision 5 to RP-4 was issued to provide addition guidance regarding corrective action trending.

12 1

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if98 MILLSTONE 2 Evaluation Factors Response Con ==nts Safety issues are being identified to Yes/No Corxhten Reports provide an effective nyens of commumcahng appropriate managementlevel and idenhfied concems to plant management in a twnely manner. However, corrected in a timely manner. tunehness associated with completen of corrective schons remams to be a significant concem. The condshon report 'vedk,g conhnues to grow.

i Quality assurance and safety oversight Unknown The NRC 40500 inspection of this area has not yet been performed, groups provide timely and effective self- but, is tentatively scheduled for somehme in December,1997. An assessmerits of performance to sik and endependent assessment of Nuclear.Overssght in July 1997 found that corporate management. although there has been considerable progress in the last six to nine months, significant additional imgc.;.,we is,requwed by both Oversight and senior line management before the Oversight organization will be fully effective.

Ill. L!censee Marmaament Ornas*=*L3n and Oversiaht Imoroved  :

Corporate and plant managerrent teams Yes The management team from Virginia Power brought in for Unit 2 has are fully committed to achieving improved demonstrated a commitment for lasting imgc.;;,wds in performance performance. through raising of standards and expectahons. The chiage at this time is the tremendous work load involved in addressing past performance deficencies Licensee has effective corporate Unknown The new recovery organization has provided a much greater level of management oversight and invcivement involvement in daily plant achvities.

in plant operations and problem resolution.

13

1/98 MILLSTONE 2 Evaluation Factors Response Comments Management team provides strong Unknown An improved nuclear safety work ethic (by the Unit 2 management 2) direction and fosters a nuclear safety has been demonstrated by conserva'.ive deosen making The work ethic that is understood at all levels effectiveness of the above management communicahon and in the organization. conservative decision making in improved employee performance has .

not yet been demonstrated. However, NRC evaluation cf whether workers have universally embraced the improved nuclear ethic message that is being delivered is still ongomg IV. NRC Assessment Complete Senior NRC management no longer No Although the Virginia Power recovery team has instituted new program ,

considers the plant as having initiatives and raised performance standards, their overall effectiveness .l weaknesses that warrantincreased has not yet been demonstrated. Continued NRC-wide aMention is NRC-wide attention. warranted.

Significant NRC inspection and licensing No The Unit 2 Significant items List (SIL) has been developed that activities are complete arid findings describes the programmatic and technical issues that requre NRC properly resolved or understood. inspection prior to startup. Only 11 of the 51 SIL items have been closed. Ten of thirteen technical specification changes neeoed for startup have been submitted, one of which has been approved.

14 1

1798 MILLSTONE 2 Evaluation Factors Response _ Comments

' V. Additional Considerations Overall perfomiance has improved as No The SALP process is suspended at Millstone. For Unit 2, whee reflected in the most recent SALP impc.e.T nts in the plant and programs are clearly in evidence, overall ratings. Performance it.thcators, or performance imgc.e.T ui trends have not yet been estabbshed A results from the Piant Performance tremendous amount of design engmeenng and physical work remains Review. some of wtuch is needed to address NRC restart issues While an improving trend is peiG;ved, addshonal time and effort by the new management team will be required before substanhal ;. .,,c.;.. ni can be demonstrated.

Enforcement history has indicated an No The enforcement history smce January 1995 i.s as follows-improving trend.

1995 - 10 violabons and 5 Escalated Enforcement items (Eels) 1996 - 7 violations and 29 Eels 1997 -4 violations and 5 Eels The NRC inspections (in particular the engmeenng team inspechon) conducted in 1996 resulted in a large number of escalated enforcement items associated with configuration and design basis deficiencies.

Recent enforcement items are associated with procedure inadequacies, traming, and failure to wear proper dosimetry.

Performance has improved as Unknown Overall performance of on-shift operators has beeil good with self-assessments providing a mechanism for contmued impic.e.6.nl Major demonstrated by a lack of operational problems. evolubons such as a core off-load and swappmg the protected facihty to support maintenance have been well controlled with only one noteworthy event (loss of 4160 Vac vital bus) in the last six months.

15

1/98 MILLSTONE 2 Evaluation Factors Respons1, Comments Performance has improved as Unknown Same as above. Although operator performance has been good, demonstrated by a lack of significant operators will become more challenged during future mode changes.

operator errors. Due to the extended shutdown, the NRC must ccatinue to monitor this area closely.

Procedura adherence problems are not Yes During the extended refueling outage (11/94-8/95) performance issues evident. such as procedural adherence was a key area evaluated as part of the MC 0350 restart process. Performance improvements in this area that were made at that time, to a large extent, have been maintained.

Simulator is operational. Yes The simulatoris operational.

Known (i.e., plant specific or industry Unknown The plant staff is addressing material condition and equipment issues.

generic) aging problems have been However, the NRC is not aware of any specific efforts on the part of the appropriately addressed. licensee to address the issue of plant aging.

Licensee has improved its management Yes The new Unit 2 management team was established using a organization. combination of Virginia Power and NU personnel. Although some directors have been assigned additional responsibilities at Units 1 and 3, this management team has remained relatively stable.

Licensee procedures are considered No The Procedure Upgrade Program, which began in the early 1990's, has adequate overall. not yet been completed and the quality of the upgrade effort was often insufficient because many procedures were simply reformatted.

Numerous examples of inadequate surveillance procedures have been identified. Although the focus has been on design discrepancies, there are a number of examples of systems being operated in a manner inconsistent with the FSAR. An evaluation of whether sufficient progress has been made regarding EOP upgrades and the acceptability of completing AOP upgrades after restart are considered startup issues.

16 L____

1198 MILLSTONE 2 Evaluation Factors Response Comments Licensee has an effective root cause Yes Recent inspection reports provide examples of quality root cause analysis program. analyses performed by the licensee.

PRA has been performed Yes TLe Unit 2 IPE has been completed and evaluated by the NRC.

PRA has been used. Yes PRA is utilized to evaluate the collective risk of para 3el mantenance activities to allow scheduler adj".astments to min %ize risk.

17

1/98 MILLSTONE 3 EVALUATION FACTORS FOR REMOVAL OF PLANTS FROM THE WATCH LIST Evaluation Factors Egttagnpi ' Comments I. Root Cause identified and Corrected Weak performance areas are thoroughly Yes The licensee has identified the programmatic areas of weak assessed. performance at Unit 3 and these areas have been substantiated by NRC inspection to be problem areas. The licensee assessment process appears to be broad based and has resulted in the initiation of corrective actions for the weak performance areas. While progress has been made, the licensee appears to have had more success in fostering improving in the technical areas versus those representing programmatic controls. The licensee appears cognizant of the performance areas that require management attention and recent management emphasis has been directed to those programmatic areas y

where progress lags and concerns still exist.

I 18 l

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1/98 MILLSTONE 3 Evaluation Factors Response Comments Comprehensive and clearty defined Unknown The corrective action program for the entre station has been revised , I corrective action program has developed. several times over the last year. The new program appears capable of fostering good problem identificahon and root cause analysis, but has j not yet proven itself either in effechng lastmg corrective measures or in j efficiently dwecting resources to a pnonhzed respense to problems The hcensee has been successful in reducmg the backlog of condshon reports (CRs) requong analysis; k ;.r, due to both the number of CRs and multiple correchve achons for each, a backlog remains for corrective action closure. While this pesents an unknown factor in the ultimate determination of corrective achon effectiveness, as ytit to be 3 venfied by future NRC ' msg echons, the hcensee does appear to have made progress in the " definition" and " der.;4. >t" of its correchve action program and goals, Corrective actions include sufficient Unknown As stated above, corrective action effechveness has not yet been measures to prevent recurrence of demonstrated. Over the recent performance history, problems have problems. recurred (e.g., work control / configuration management), but this may relate to the recently instituted corrective measures not yet talung hold.

Performance indicator data has not established a trend iridk i g that the licensee has ha~.ed problem recurrence. With the discovery of configuration management problems still ongoing at a somewhat surprising rate, it may be too eady to assess whether the licensee is tracking on a clear success path in this area.

1 19

1198 MILLSTONE 3 -

Evaluation Factors Response Comments Management has allocated sufficient Unknown The sufficency of resources is in question based upon the achon item resources to carry out long-range backlog, the performance indicator trends, and the fact that problem corrective action programs. " discovery" has no'shown signs of atmis.g. Addshonally, NRC '

inspection findings nave indecated that the large corrective achon

' workload has created situahons where the responsible staff personnel have erred in deodmg when sampling versus comprehensive reviews adequately address the problems S;y-Jcien resources, primarily in the area of engineenng, are still dedicated to the responsaveness to ICAVP and continued problem " discovery". The licensee has not yet demonstrated the effectiveness of corrective achon solubons. Thus, the j resources needed for both problem resolubon and contmued problem

" discovery" response raise doubts whether the hcensee has sufficently

. gauged the required resource needs.

The Corrective Action program effectiveness has not yet been I NRC is satisfied that corrective action No program is sufficently implemented. demonstrated. " Discovery" continues to identify repetitive problems.

The Corrective Action Program was just recently again revised, partly in response to a Nuclear Oversight audit that indicated that the program implementation is not yet providing evidence of satisfactory results The licensee has delayed dec!aration of readiness for an NRC MC 40500 inspection in order to further assess the corrective actinon program implementation and effectiveness. While the NRC can project that the licensee has provided direction toward iiv,i i cx.r, a in this area, the verifiable results and evidence of a clear success path are not yet available.

20

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1/98 MILLSTONE 3 Evaluatignf_afdgry _Runonse. comments Sustained, successful plant performance No in the area of corrective acbon, performance indicators continue to has been demonstrated, illustrate a backlog of work, although problem analysis and evaluabons have improved in timeliness. Also, no fully-developed evidence of corrective action effectiveness has yet been demonshted. The corrective action program has undergone multiple revisions recently, therefore, neither success, nor sustained performance have been verified by the licensee or examined by comprehensive NRC inspection activities.

II. ImDroved Self-Assassment and Problem Resolution Evident Program that monitor and evaluate Yes Corrective action tracking and performance indicator programs have effectiveness of corrective actions have been instituted. Additionally, Nuclear Oversight appears to have been instituted. established defined criteria and a means of monotonng effectiveness in .

this area. While the results currently remain ira.oriciusive, hcensee management has emphasized the importance of this area and j continues to evaluate progress, trends, and results.

Safety issues are being identified to Unknown The management review team concept for safety concems (e.g., CRs) appropriate management level and appears to be working by providing direction, emphasis, and corrected in a timely manner. appropriate management involvement in corrective action implementation. The timeliness of corrective measure initiation has improved. However, as noted previously, the workload has stramed the capability of the responsible personnel to accomplish all designated assignments. Furthermore, as indicated, neither the trended data, nor the Nuclear Oversight reviews have validated the " effectiveness" of the corrective measures. Thus," timeliness"is also in question.

21

1/98 MILLSTONE 3 Evaluation Factors _;tesponse Comments Quality assurance and safety oversight Yes The Nuclear Oversight organization has shown not only increased groups provide timely and effective self- involvement in the audits and assessments of ongomg activities, but assessments of performance to site and also additional strength in effectog line management response to corporate thanagement. perceived problem areas. Rotational assignments between the Unit 3 line organizations and Nuclear Oversar'n t contmue and appear to have had positive impact upon QA creditniity and an increased understandmg of organizational roles. Nuclear Oversight, as part of its Restart Verification Plan issued in August,1997, continues to monitor the status of approximately 21 *tey issues" (e.g., Gniective achon, leadership, compliance operations, et. al.); thus, proveng line management with independent assessment input as to the areas that need improvement.

Ill. Licensee Manegament Oraanization and Oversiaht improved Corporate and plant management teams Yes The NU team that has taken over from the loaned Carolina Power &

are fully committed to achieving improved Light personnel in directing the recovery of Unit 3 continues to provide a performance. positive, fully involved approach toward raising Unit 3 standards. One possible outlier in this regard has been upper NU management's continued emphasis upon schedular goals for its lead plant Unit 3.

While management has stressed " safety" over " schedule", optimistic schedular expectations have appeared to burden the Unit 3 work force with compromising the comprehensiveness of work efforts with the need to efficiently get them done. Only recently, with the announcement of schedule slippage, have management actions demonstrated what was heretofore preached; i.e., the importance of getting things done right, even if more time is necessary.

22

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179 8 RNLLSTONE 3

' Evr - ~-- ; Factors Reeponse Co e Licensee has effective wipui.ie Unknown Lire management decisions and Nuclear C..; g4 'wwolvement in daily management c.;;s;via and invch.;.T a plant operations and recovery activibes are evident However, problem in plant opershons and problem resolubon at the m< idle management and worker level has been ,

resclubon. affected by the previously noted, "rrwxed message" from upper .!

management on schedular goals. The work 'W, performance )

indicator data, and evidence of some recurent prthlems (e..g., work control, design review nwsses) do not provide a current indicator of comprehensive problem resolubon. While lic3nsee management has orthned the right w verh to problems, effechve correchve achon compfehon has not yet been derconstrated.

Management team provides strong Unknown While problems with the communicahon of expectabons to the craft direction and fosters a nuclear safety k n ansen, parbcularfy with respect to schedule, overaR a strong work ethic that is understood W all levels salty ethic is in evidence. The Unit Dwector and the Operahons Staff in the vigordzation. have parbcularly demonstrated conservahve decision malang and goed c,via gern;y planning for ongoing outaga and shutdown plant evolubons The NU Unit 3 reanagement team has provided strong dwection down to the supervisory /wortung levels on matters wwolving personal and nuclear safety. Upper NU management has impleme-*ed recent iruhateves (e.g., off-site retreats, enhanced trainmg) to further promote strong ide* wxf goals to lowerlevels of the orgaruzation.

• k, ;.n, some interpersonal conflicts and work control problems have r

illustrated that the workers have not ursM embraced the improvt.4 I nuclear ethic message being delivered. "I'ne effectivenets of the above r inagement irubatives has not yet been derronstrated.

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f i 1798 RI6LLSTONE 3 i i

i-Ewf - ^'=- Factors Response Comments i

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. IV. NRC Assessment Complete i

Semor NRC management no longer No Management changes (VP - Eny;.~;.-;..v) and program changes i

considers the plant as havmg (cutiwCJ; achons) conhnue to occur at MiRstone; and intemal  ;

I wealmesses that wammtincreased reorgamzabon (e.g., PECO and VEPCO support to Unit 3 restart) have  !

NRC-wide attenhon. created some confusion over the consistency of NU managements

, apprcach to recovery. Overall e5ectmeness and significant '!

...p c.c..wa have yet to be established. As of October 24,1997, there i

i were about 2660 condshon reports requong correctwe schon with an

increasmg trend. About 1200 were more than 120 days old.

Configurahon management problem C; scc;;.f conhnues at a surpnsingly high rate, with ICAVP and NRC inspechon actwees  ;

indicahng that NU may not yet have sc.;W the fu2 spedum of such  !

issues. While substanhal progress is bemg made in plant  ;

i. p c.e..was, design modific&Trnplementahon, and pror, ram

! enhancemerWs, the presently enjoeng status of such work does not ment a decrease in NRC attenhon to Millstone or its managements

, wvedi to recovery.

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t 1198 RBILLSTONE 3 i

Ev :- ^':=. Factors Response _ Comments j Sividinwd NRC inspection and licensmg No Of the d6 issues on the Unit 3 Signdicant items List,29 items have l actmhes are complete and findogs been closed and another 34 items inspected and updated. NRC l property reschecd or understood. resident and team inspechons have raised new inspechon osues  !

requong licensee attenbon. Several MC 0350 program areas requwe addibcnal msoechon review, not the least of which are an MC 40500 f

! inspechon and the OSTI, for which the licensee has not yet indicated  !

recommended readmess dates. The ICAVP has commenced, but has already twice slipped its schedular cu. ,1.3. In licensing, all the technical .,mdric. .v6 changes requred for unit restart hree not yet

been submitted to the Office of NRR. Configurahon management l discrepancies and design-basis r===hans are still being rased, at a

[

lower but still somewhat surpnsmg rate, as disccaciy conhnues at the t plant (e.g. condehon reports in the last six months have been issued in  !

excess of 10 per day). As a resbit of the decovery process,28 LERs j have been issued in the last six months. NRC inspechon and license amendment review actmhes appear as if they will contmue for the next few months at a necessary, heightened level.

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1/98 RAILLSTONE 3 Evr'~ ^*si Factors Respogas. Comments V. AdditionalConsiderathms ,

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! Overall performance has improved as No The SALP process is suspended at Millstone. For Ur.it 3, while reflected in the most recent SALP

ivipicm.iim as in the plant and programs are clearly in evidence, overaN rahngs.' Performance wdcators, or performance wnprovement trends have not yet been established. AN results from the Plant P=fvimiswi areas reviewed wdcate mixed results, with "desegn engmeenng"in i Review. particular represenhng an area of organizahonal and topical concem.

i Even in areas where a conservative safety approach has been i i

i demonstrated (e.g., operahons), events like the spent fuel pool heat-up i'

and some valve nusalignments have demonstrated that configurabon  ;

management errors have not been fuNy and ~~~;" J J;t i addressed. The status of"conechve achon", where the licensee conhnues to assess i whether previous program 'wwhatrve have achieved effechve results, is representative overall of the plant's"perfo.mma" status. The conhnuing burden of configurabon management discovery and ICAVP ,

findogs, along with difficulty in demonstratmg effective fixes for past

, problems, have created a situohon where plant performance, while i improvng, cannot tu concrmed to be where it needs to be before the l l NRC approves restart i

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1/98 MILLSTONE 3 Evaluation Fas_ tors Response Coraments Enforcement histery has indicated an No The enforcement history at Unit 3, prior to the plant shutdown in 1996, improving trend. was generally good. Since January 1995 the enforcement history is as follows:

1995 - 7 violations and 0 Escalated Enforcement Iterc.s (Eels) 1996 - 5 violations and 29 Eels (Many Eels due to the Engineering Team inspection conducted in April-June,1996) 1997 - 5 violations and 5 Eels (October 31,1997)

With the significant number of configuration and design-basis deficiencies identified during subsequent NRC fi low-up inspections, as well as the license 's own identified configuration management problems, routine and escalated enforcement rose accordingly. In the last six months, the licensee has issued approximately 28 LERs, most of which represent licensee-xlentified violations of regulatory requirements. /Jthough a high number of violations have not been in evidence in routine resident reports, the identification of a several unresolved items, along with the continued documentation of escalated enforcement items (Eels), indicate that configuration mar.agement concems have not abated. Over the last three inspection periods, twelve LERs involving violations of the plant technical specifications, have been inspected and closed. Since current violations, unresolved items, and Eels might actually reflect past problems, just recently discovered, it is difficult to assess performance on the enforcement numbers alone. However, it is clear that an improving trend in the Unit -

3 enforcement data is not currently evident 27

1/98 RAILLSTONE 3

)

Ev_ ' r^':-s Factors Response C-. ^

l Performance has improved as Unknown While the number of operatonal problems in mode 5 conditions have demonstrated by a lack of operabonal '

been few, there have been events (e.g., spent fuel pool heat-up, RCS problems. leakage through misaligned valves) that have a root cause based in configuration control concems. On a proporbonal bases to the number of systems that are required to be operable, it could be argued that the number of events and/or system shgnment enors i% ,,..-4 a sipsficant concem for the current conduct of operabons. However, several of the identified concems have basis in hestoncal causes. Also, shutdown risk controls and conhngency plannmg for the individual system outages dunng this shutdown penod have been good. Efforts to ,

reduce operatmg burdens (e.g., temporary modificahons) and to re-assess the status of operator" work-arounds" and control board deficiences prior to the retum power opershons reflect a good management perspective on the goal of reducing operahng burdens to a minimum. Nevertheless, the current mode 5 activihes are not a good indicator or predictor of the lack of fu'ure opershonal problems in a higher mode. Hot performance prior to actual start-up (mode 2) will be monitored by the NRC (e.g., OSTI) and will provide for a better assessment of this area.

Performance has improved as Unknown Same as above comment. Operator errors (as highlig%xt above) demonstrated by a lack of signiGcierd dunng mode 5 evolutions have occurred, but piar? volubons and post-operator errors. modificahon and surveillance teshng activihes have generally reflected conservative operahons controls and good conhngency plannmg The number of operational cn-m wie crease m with plant heat-up, which presents a better time to further assess opershonal performance.

28

i 1/98 MILLSTONE 3 Evaluation Factors Response Comn @

Procedure adherence problems are not No Problems with adherence to regulatory and procedural requirements -

evident. has been k$entified to be a problem from a histoncal perspectrve at Millstone Unit 3. De licensee's con 5gurabon management prey.ni (CMP) has found several reportable events .'LERs) related to such issues. While most of the tediac.al spm.ifn Gen violations represent

" verbatim compliance"deviabons of a mostly menor 5;y-nTn nc.e. the overall number of CMP deficiences and operator ' Work-arounds"is likely reflective of a past cultural problem witri ngorous compliance. A recent NRC inspection of the procedure upyede program (PUP) revealed its intent was not to correct all procedural deficiences.

However, this same inspection noted that current licensee initiatives ,

provide reasonable assurance of adequate procedures prior to the plent restart. Based tryon this past history and given that procedure and t performance adherence ch;" ..njes will increase with plant heat-up, testing, and opei Gen in higher modes, this is an area that will ment i continued managemont attenSon and heightened NRC inspection ,

review. i i

Simulatoris operational. Yes The Unit 3 simulator is Opei Genal and being utilized for testing of contiinjencies, planned plant design changes (e.g., RHR flow control modifications), and operator training, both of a routine nature and to "

check out infrequently performed tests or evolutions.

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1/98 RAILLSTONE 3 E,_M"_"=i Factors Response Comments Known (i.e., plant spec;Tc or industry Yes Aging problems are not a major concem at Unit 3, imensed in 1985. l I

genenc) agmg problems have been K ;.r, the Icensee has implemented feedwater replacement of appropriately addressed. piping subject to erosson/ corrosion problems. Addii.onally, the licensee has demonstrated appropnate considershon of industry operahng expenence and has been senssteve to ;.. ,,c.;d matenal plant conditions, as well as equipment and replacement pirt concems.

Problems with the review of generic mdushy and NRC gudence for component problems in the past have resulted in escalsted enforcement (e.g., Target-Rock valves) and engmeenng program evaluahons (e.g., MEPL) that are conhnumg to be assessed by licensee personnel for corrective achon. Recent NRC inspechons have found that hcensee performance in this area has improved and the known problem areas are bemg further inveshgated for ai% resoluhon.

Licensee has improved its management Yes Currently led by an NU VP, the cummt safety ethic and .p,,vwJi to organization. fixing pivy i-iiatic Sioblems are strong. However, it should be noted that each of the many past organizabonal management changes has appeared to create some 'mstabihhes in the undorm direchon toward problem resolubon. As an example, the strong emphasis by upper NU management on attammg planned milestones and adhenng to unreesonable schedule goals appear to have had an adverse effd upon plant staff performance in certain areas (e.g., MOVs, comprehensive SIL corrective measures). Overall, the management vig nik t;On has iiiipic?;d compared to the sstuabon prior to the shutdown. However, the cummt management must stay focused on unit recovery, versus when it11 be back on line, if it is to avoid a " mixed message"to its work force.

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1798 MIt.LSTONE 3 Evahution Factors Response C _ - 1 Lcensee procedures are considered Unknown As noted prenously, the effectmeness of the previous licenses PUP l adequate overN!. irwhatwe has not been clearty endent. The CMP actmhes at Unit 3 have indicated a need for individual procedure remssons, as well as .

guyi . 4c efforts (e.g., mtegrahon of vendor informahon into unit procedures) that are still ongoing. An integrated NRC review of procedural adequacy has determmed that in conjunchon with PUP, the other heensee CMP and guy .s Gc iruhatwes, if followed through to proper cu...G.;,i, provide reasonable assurance that adequate procedures for the safe operation of the plant will exist at the time of unit restart. Sece this area conhnues to recewe appropnate scensee management attenhon and will be further inspected dunng rouhne and special planned NRC team inspechon (i.e. ICAVP; IP 40500 "Correctwe Achons"; and IP 93802, "Operahonal Safety Team Inspection [osTl)) efforts, the final assessment on procedural adequacy (other than for current plant safety, as deemed acceptable) need not be made at the present time.

Lcensee has an effectue root cause Unknown See correctwe action factors evaluated under sechon I above. Several analyses program. revisions to hcensee's correctwe acbon process have appeared to strengthen the quahty of requred root cause analyses. However, past attempts to assess the adequacy of conectwe measures for Level 1 CRs (which requre a root cause analyses) have been unsuccessful because these problems lacked sufficient closure files. The licensee is currently assessmg both the Level 1 CR results and the attendant root cause analysis process to determine in it is ready for an NRC MC 40500 inspection. Until the licensee is able to evaluate the effectweness of the achons taken to address the root causes of problems, and NRC validt.tes that the progrwn is wortung, the effectweness of the bcensee's root c=maa analysis, as with its entre correctwe achon progra:n, is stiN subgect to w .T . 4vi7.

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I 1/98 MILLSTONS 3 Evaluation Factors . Response Comments i

PRA has been performed. Yes The Millstone Unit 3 iPE has been submitted in Levels 1. 2, and 3 detail (including consideration of intemal events). The NRC review has determined that the IPE submittal package was comparable to the mdustry everage and that the Unit 3 IPE meets the intent of GL 88-20.

Yes The PRA has been used in cuiinection with the Mamtenance Rule PRA has been used.

implementation, in the evaluabon of the need for plant modificabons, and in the conduct of CMP actmbes. The IPE is considered a "livmg  !

PRA" document at Millstone Unit 3. Shutdown risk has been eGocit.-df cuia.Cd dunng this extended outage.

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1/98 SALEM 1 & 2 EVALUATION FACTORS FOR REMOVAL OF PLANTS FROM THE WATCH UST Evaluation Facict:: Response Comments

1. Root Cause identified and Corrected Weak performance areas are thoroughly assessed. Yes PSE&G conducted an extensive review to identify fundamental issues wnich resulted in overall performanT decline. This review also identified common causes for decline across organization. In addition, PSE&G conducted an extensive FSAR versus plant review.

Comprehensive and clearly defined corrective action Yes A comprehensive corrective action plan has been program has been developed. developed to address each of the fundamental causes of performance decline. This plan was sent to the NRC in a letter, dated November 24,1995, and contained detailed actions in each area, as well as the management process to be used to determine if the corrective actions are effective.

Corrective actions include sufficient measures to prevent Yes Overali, licensee performance improved sufficiently to recurrence of problems. warrant modification of the 1995 Comirmatory Action Lettes (CAU to allow Salem Unit 2 startup. The licensee corrected all significant workarounds, along with known design and material deficiencies that threatened safety functions. The licensee also substantially reduced the backlog of equipment deficiencies with a resultant reduction in operator burden and increr.se in the margins of safety.

1/98 SALEM 1 & 2 Evaluation Factors Response Comments Mcnagement has allocated sumcient resources to cany Yes Segn6 cant resources have been dedicated to address the out long-range corrective achon programs. numerous hardware and program issues dunng the extended outage.

NRC is satisfied that corrective action program is Yes The NRC star has reviewed the licensee's conectwo sumaently ~w nplemented. action progra:n and has determmed that it has ; ,,rc .;d signdcantly. The program has a low threshold for entry l ,

and, by ussng it, the Salem stat has rouhnely ident6ed j

plant problems. Root cause analyses and corrective schon

' implementation conhnued to improve. The correctwe

action c^.;.%jd groups provided very effectwe feehack

, on the quahty of actmhes. Quahty Assurance audits provided comprehenswe assessment of the program with well-supported cer'_.ussons. Performance indicators

) provided an eMectwe way for managers to monitor i departmental performance. Some problems remam, but are considered minor relatwe to the overaN ; ..r c a in i ...

the program.

1 i Sustamed, succes:,ful plant performance has been No Although Salem Ur.d 2 startup occurred in August 1997, 4monstratod. some addshonal plant problems should be expected gwen the magnstude of the outage. The hcensee's at2ty to 4 sustain Salem Unit 2 ;,i ru.... a while resolving Salem

) Unit 1 restart issues and startmg up Salem Unit i remams to be demonstrated. Thus, it would be premature to take

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j any addihonal achon at this time.

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f 1f98 SALEM 1 & 2 l i Evaluation Factors Response Comments l

11. Imoroved Self-Assessment and Problem l

Resoluton Evident i

Program elements that monitor and evaluate Yes The new corrective achon program includes a prinuary effectiveness of corrective actens have been mstituted. tiement that monitors and evaluates the effectiveness of corrective actens. [

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Safety issues are bemg identified to appropnate Yes PSE&G consistently demonstrated a very low threshold for

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management level and corrected in a timely manner. identifymg issues to the appropnate management level.  :

I The timelmess of the corrective actons was commensurate with the large volurre of ongoing actrvities.

Quality assurance and safety oversight groups provide Yes improved contnbubons were noted from the QA and other j c.c.ya groups. Site management has routmely utilized

timely and effective self-assessments of performance to

' expertise from outssde PSE&G to benchmark performance.

site and ceipviele management.

The impact of contmung management changes within  :

+ oversight groups remams to be seen. I lit. Licensee Manaaement G serazistieri and Oversioht Imoroved The current PSE&G management team has routmely I Corporate and plant management teams are fully Yes committed to achievmg irnproved performance. demonstrated a commitment to achieving ni.pic;;d [

performance. Ex.mples include managerrent intervenhons toip;d at improving the 1a6 and skit l levels of operators and mantenance technicians.  !

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1798 SALEM 18. 2 I

l . Evaluation Factors , Response Comments i

i The licensee has effective ceipui te management Yes Corporate management is substanhally involved in plant l oversight and involvement in plant operations and oversight and uhkzes an offsde Nuc%er Review Board to -

problem resoluhon provide obpective assessment. ,

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Management teams provide strong drechon and foster a Yes Management decision malang is conservative and l l ' nuclear safety work ethic that is understood at all levels management fosters a good nuclear safety work ettuc. j in the vig.fiation. New management is now in place in wwtually all key l cvipui.ie and plant-level posshorn, many of whom came  !

from outsede PSE&G with significant industry expenence at solvmg longstandmg performance problems. The impact  !

! of contmung management cher.ges remains to be seen.

! IV. NRC Assessmer:t Complete  !

l l l Senior NRC management no longer considers the plant No Although improved performance has been noted in all key l l as having weaknesses that warrant increased NRC-wide areas, there remains some performance uncertainty given t l attention. the magndude of the effort and the absence of sustamed  !

' power operabon of both units. i Significant NRC inspection and licensing actwihes are No All of the specific technical and pivvi t;c issues l

l complete and findings properly resolved or understood. needed for Salem Unit 2 restart have been resolved. t Additionally, certain tests and restwt actwihes, includmg  ;

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power operahons, were mondored by staff and found to j have been conducted in an +x::4+W manner. Salem ,

Unit 1 restart issues and the startup test program reman to be cuiisp,.;cd prior to restart. i i

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1798 SALEM 1 & 2 Evaluation Factors Response (4mments

'j V. Additional Considerabons Overall performance has improved as reflected in the Yes Tlw SALP process has been suspended until retum to most recent SALP ratings, Performance Indicators, or 'A is achieved. The NRC has formed a Salem results from the Plant Performance Review. Assessment Panel to more closely morutor the progress of

- the corrective actions. Although the most recent Plant Perfonumce Review indicated improvmg performance, there is some uncertamty that this level of performance wF. ,

be sustamed given the absence of integruend opershonal perfo:mance and coef.inumg management changes.

Enforcement history has irdcated an improvmg trend. Yes Signdicant enforcement achon was taken for those performance issues that preceded the curnmt shutdown.

Sece the shutdown anti implementahon of subsequent corrective actions, includmg substanhal management changes, descrebon has been applied to enfcrcement schons for issues stemmmg from the problems that caused and preceded the shutdown. Enforcement achons evolvmg recent performance ir* shutdown operations have generally been less sogneficant, but have contmued to occur. Recently, the NRC issued a signdicant enforcement achon due to problems with fire protechon and the switch over methodology for the emergen::y core coohng system (ECCS).

Performance has ;.ry ce d as demonstrated by a lack of Yes While operahonal problems have conhnued to occur, they operahonal problems. appear to be less frequent and signdicant. Prolonged 5

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1/98 SALE';i&1 Evaluahon Factors Response Comments performance wv .,,.

c w-t while operahng has not yet been demonstrated.

Performance has improved as demonstrated by a lack of Yes The number and segrdficance of operator errors have been 5;gri. cent operator errors. reduced, and the schon taken to address these errors has bed comprehensive. Operators did an excellentjob coordinabng large scale plant evolutions during the startup and power ascensson teshng. While improved, occasional lapses and human performance problems conhnue to be noted. However, they are less prevalent and signdicant Procedure adherence problems are not evident. Yes Site management has emphasized the importance of procedural adherence, and the number of errors has been reduced.

The simulator is operational. Yes The swnulator is opershonal with good fidehty as demonstrated by a recent NRC SSFI effort.

Known (i.e., plant WT.c or industry generic) agmg Yes PSE&G is completmg an extenssve outage to address problems have been appropriately addressed. matenal condshonfequipment issues throughoct the plant For issues with agog or parts avadabiles. such as with the .

RPS com.ol modules, PSE&G implemented extensive refurtnshment and repar actrvehes.

Licensee has improved its managemerit organization. Yes Site manag 'wmt has been replaced with expenenced managers from other plants. This management team has been in place now for most of the outage, and has 6

1/98 SALEM 1 & 2 i Evaluabon Factors Response Comments i

demonstrated a conservabwe safety ethic through the insistence of reporting and addressing problems.

l Licensee procer :msidered adequate overall. Yes The NRC SSFI considered the operahng procedures assooated with the component cooling system as good. In ,

addebon, a co cs . upgrade of the Atmormal and Emergency Operahng Procedures has been completed.

Licensee has an effective root cause analysis program. Yes Root cause analyses are considered generally thorough W comprehensrve.

PRA has been performed Yes The Salem IPE is coin @% and evaluated by the NRC as relatively detailed.

PRA has been used. Yes PRA is being used with the Maintenance Rule unplementation. In addibon, the PRA has been updated to r plant modificahons from this outage.

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1/96 ZION NUCLEAR POWER STATION EVALUATION FACTORS FOR REMOVAL OF PLANTS FROM YHE PROBLEM PLANT LIST Evaluation Factors Response Comments I. Root Cause identdied and Corrected Weak performance areas are thoroughly assessed. Yes The hcensee &.;:W and issued a comprehensive Recovery Plan to address pvy .stic and performance problems that were demonstrated dunng the reactivity management and reactor s*ssel voidmg events in j i

February and March 1997. These weaknesses etwefly involve operational performance and corrective action program implementation problems. The hcensee is  ;

implementog some achons to address other weaknesses in engmeenng, mantenance, and radiahon putoctivn, identified by the NRC and from heensee self-assessments, although these are considere<f longer-term issues and not necessanly required for restart. In adchhon, the hcensee's 50.54(f) response was comprehensive and included plans to review several processes at Zion Stahon that were idenhfied as deficient.

Comprehensive and clearly defined correchve action No Licensee plant, ~A achons have concerstrated on issues program has been developed critical to restart. As a result, the licertsee has implemented extensive achons to improve operabonal performance and the corrective actxm program. Although the licensee has been implementmg some achons to address other wealmesses, a comprehensive and clearly defined plan to achieve long-term plant performance improvement has not yet beet 1 c.;:wi

1/98- ZION STAT 90N Evalusten Factors Response Comments

)

' Correctwe actions include sufficent measures to r e.c.-a No Extensive actens to address operahonal performance recurrence of probier.w. problems have recently resulted in some shght in.r c-...ir=,-a. However, the sduabon is tenuous at best  ;

and its not yet clear whether this in.r v...iwe can be l expected to conhnue. The licensee also irubated several actens to improve the correctwe achon process such as estabirshmg a Correctwe Achon Review Board. These achons provide a foundshon for future Mir c ...rse, but its too early to tellif these initishves are being m4.;ij implemented as reflected in the absence of recumng problems. The beensee has taken actions, such as estabhshmg an Engmeenng Assurance Group, to improve in other areas. As a reFult, some Irubal Eipc.c.Tmd is aoparent in areas such as operability evaluahons.

Mc ;m, some deh are sull being nMed in thest areas and contmued hcensee focus is necessary to ensure long-term ;.ivc.c.noin.

Management has allocated sufficent resources to carry Ur>certain Sufficent resources have been assigned to support plant out long-range currective acten r vvianis.

restart. However, plans to address long-term performance improvement are not as clear and so resource needs have -

not yet been assessed. The licensee has reached agreement with their unen to address operator staffing concems with management e.,,;o,;; e (sener reactor operators) filhng in for reactor operators until a sufficent number of heensed reactor operators are available.

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1/98 ZION STATION Evaluation Factors Response Comments i

f j NRC is satisfied that correctwe achon program is No The licensee *s knpiuse. Ten for the correctwe achon sufficiently implemented. program, such as establishmg a Correctwe Achon Review i Board, are still in the early implementahon stages.  !

Although they set a firm foundehon for future kipc.,,.ise, corrective achon pidMis still occur. These Lipc.,..n e i

neasures have not beeri in place long enough to reakshcally expect plant personnel to have gamed the skills I and total understandmg of expectahons to implement an j effectwe conectwe achon program. l i Sustamed, successful plant performanca has been No The bcensee decided to mantain both units shut down in demonstrated. February 1997. Restart is not anhcipated until February ,

1998 at the earliest. l'

11. Imoroved Self-Assessment and Problem l Resolution Evident i i Program elements that monitor and evaluate No The hcensee has not yet assessed the effectweness of l effectiveness of ccirwctive actions have been instituted. many of their imprc.c.cewnt actions. The Operahonal l Readiness Performance Demonstrabon, although  !

complete, did not sufficiently assess some important i operabonal performance attnbutes, such as off-shift j management cvursida and LCO tr&,ivis. Several other assessments which the hcensee plans to firush before plant restart, such as those pevformed by Corporate and i the Site Assessment and Quahty Verficahon organizahons, l are not complete. In response to the NRC's 50.54(f) letter,

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1/98 ZION STATION Evaluation Factors Response Comments Comed has initiated additional performance indicators, - ,

tracked at all the Comed nuclear plants, which are ,

revewed monthly with corporate officers and all the Site Vice-Presidents.

i Safety issues are being identified to appropriate No improvement has been noted in the licensee staffs ability management level and corrected in a timely manner. to identify problems. I-icwcecr, periodic involvemert by the ['

NRC staff has been necessary to ensure appropriate licensee actions are implemented to address problems.

Examples include zebra mussel fouling of the sennce water system and configuration control problems. In addition, the licensee is currently implementing x:tions to address a " chilling effect" at Zion Station.

Quality assurance and safety oversight groups provide Yes Licensee oversight groups had previor ,.. w timely and effective self-assessments of performance to effective in identifying and cnsuring wrficier lion to site and corporate managemer:t. address problems. The licensee just recently announced a reorganization that would place the Quality and Safety Assessment (Q&SA) organization and the Corrective Action Program under the direct control of Corporate personnel versus the Site Vice-President. Recently the ,

Q&SA organization has been more aggressive in identifying problems.

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1/98 ZION STATION Evaluation Factors Response Comments Ill. Licensee Manaoement Oveerielion and Oversicht imoroved Corporate and plant management teams are fully Uncertain The licenset ch to make frequent and substantial committed to achievmg '.mproved performance. changes in te corpei.te and plant management wfuch has resulted in inconsistencses and lack of contmusty in management approach and focus. Although licensee management states the intention to improve, the individual managers tend to change before their commitment to improvement can be clearly substantiated through their actual achons and long-term followup. l Licensee has effective corporate management oversight No The Site Vce-Presidents have been ineffective in fostermg and involvement in plant reperations and problem a work environment conducive to sustammg performance resolution. improvement initiatives. Instablity in that position has hampered the abilty of site personnel to properly focus on consistent long-term goals. Frequent wpviele management ch&ges have hodered that organization's ability to provide consistent c.ccskjd. Th wree plans corpoiete involvement in restait evalue'xms and eviews.

Management team provides strong direction and fosters No Instability in plant management, includog N Sif 3 Vce-a nuclear safety work ethic that is understood at all levels President and many second-tier managers, i.cm,ws the in the organization. ability of station personnel to remam focused on performance improvement $s a result, strategies and direction tend to be unclean , and overall accountability for performance impic'.c.Twd tends to be ambiguous.

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-1/98 ZIO*4 STATION Evaluation Factors Response Comments IV. NRC Assessment Comticia Senior NRC management no longer considers the plant No Previously identrfied weaknesses, for the most part, are as having weaknesses that warrant increased NRC-wide still apparent. For example, mcidents involvmg procedure attention. adherence problems still frequently occur, corrective actions in some instances remain untimely and ineffective, the ability of operators and plant staff to consistently plan and execute operating evolutions withcA perturbahons has .

yet to be demonstrated, and configuration control continues to be an waisonal challenge. Some recent minor improvement is apparent in control room operations and some aspects of engineenng performance. Mcase ,

the situation is tenuous at best and its not yet clear whether improvement can be expected to contmue.

Significant NRC inspection and licensing activities are No The NRC is implementing a Manual Chapter 0350 restart complete and findings properly resolved or understood. plan for Zion Station. This plan, as well as the licensee's Recovery Plan, concentrate on issues pertment to restart.

chiefly operational performance and the corrective action program.

V. AdditionalConsidei tions Most recent set of Performance Indicators reflect overall No The most recent (September 1997) AEOD performmce improving performance. indicator report shows operational and personnel performance deficiencies. This includes concems j regarding poor control of plant activshes, licensed operators 6

1/98 ZION STATION l Evalushon Factors Response Comments j l

faihng to exercise appropnate command and control of plant actmhes, poor regarements for implementmg c.c. v.c.r.d structure, and failures to adhere to station poices and procedures. This informahon reflects the reactivity management and reactor vessel voidmg events of Fetwuary and March 1997.

Overall performance has improved as reflected in the i4/A The most recent SALP penod ended in December 1995.

most recent SALP ratings. Zion Station received SALP 2 rahngs in Mantenance, Engmeenng, and Plant Support and a SALP 3 rahng in Operahons. Dechnsng performance has smce been roted in all SALP areas and Zion Station was placed on the NRC watch list in January 1997. The current SALP assessment penod has been extended unbl accroximately 6 months after startuo of one of the reactors at Zion Stabon.

Enforcement history has irxhcated an i nprovmg trend No Enforcement acbons. .." ^ s r@;;t on i hcensee performance, occur sg a higher rate than wo'sid be expected from a plant that is currently shut ouwn and is focusmg on improvmg performance.

Escalated enforcement is cummtly being considered for a programmatic breakdown in the fitness-for-duty area.

In September 1997, a $330,000 Civil Penalty was issued for the reactmty management and reactor vessel voidmg events that occurred in February and March 1997. These 7

1/98 ZION STATION Evalushon Factors Response Comments event reflected opershonal performance and conectwo achon program weaknesses.

In September 1997, a S;...ity Level 111 NOV with no civil penalty was issued for removal of a block wall in l November 1996 wtuch allowed flow to bypass the normal fuel buedmg ventnahon system.

In June 1997, a $50,000 Civil Penalty was issued for a programmatic breakdown regarding radioactive waste is Wust;cn that was idenhfied in January 1997.

Recent Seventy Level IV NOVs indicate conhnued problems with personnel pe**wmance.

Performance has improved as demonstrated by a lack of No The bcensee suspended a July 1997 atlempt at conduchng operational problems. an Operahonal Readmess Demonstrahon Program due to operational performance and work planning deficiencies.

The licensee re-irwhated the Program in November 1997,~

but commenced a slowdown of work actmhet, after several occurences of problems with the control and planning of evolutions. Overall, with both units shut down, there have been few challengmg operahonal actmhes to truly measure the effectweness of heensee operator performance impic.;.T=nt iruhatwes.

Performance has improved as demonstrated by a lack of Yes The licensee hasve yrddi pursued operator significant operator errors. performance impic.;.w.te in accordance with their 8

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1!98 Z ON STATION Evaluation Factors Response Comments Recovery Plan. Most notable act'ons included an Operator Assessment Program and supplemental trammg, termed

" Phoenix Trammg* by the licensee. No siy-JTe4 operator errors have occurred smce the reactivity management and reactor vessel voedmg events of February and March 1997. l However, inspedors have contmued to kjenhfy many l violation examples involvmg less sagrwficant failures to follow procedure dunng routme inspections. Recently inspectors have noted some signs of improvement in control room decorum and operator response to events.

Procedure adherence problems are not evident. No The hcensee and NRC contmue to idenhfy procedure adherence issues with mulhpie example violabons bemg issued with routme mspechon reports.

Simulatoris operational. Yes The simulator has been observed to funchon property.

All identified aging problems have been addressed to the Yes No sigrwficant age-related issues have been identified NRC's satisfaction. recently. However, the licensee recently idenhfied extensive problems in implementation of the Maintenance Rule and is pursumg ccirectie achon.

Licensee has improved its management organization. No instability within the ranks of plant Ime-management has impeded site impic.c.Te4 initiative. A lack of senior management visibility and impact, inclJding that attributable to the plant manager, is spp.ierd.

No The licensee is taking achon to address the previously 9

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i Evaluation Factors Response Comments Licensee procedures are considered adequate overall. noted problems with regard to procedure adequacy.

Operators have recently become more aggressive at j

idenbfymg procedure problems. Reviews of procedures  !

prior to usmg them for evoluhons are resultog in the i idenhficahon and correchon of numemus procedural l

deficiencies.  !

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! Licensee has an effective root cause analysis program. No The bcensee has implemented several iruhahves to

improve root cause analysis such as estabbshog a

! Corrective Achon Review Board to begn re-enforcing j expectahons in this area. Although a foundshon has been estabbshed on which to base future ;iipc;;.T a, i l conhnued focus is necessary to achieve consistent and sustained iiipc;;.T= 4.  !

PRA has been performed. Yes Co i@ c l

PRA has been osed. Yes The licensee has a shutdown risk program and an on-hne  !

risk program for use dunng dah plant opershons.

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