ML20203E921

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Provides Commission W/Periodic Summary of Ongoing Activities Re Restart Assessment Plan for Millstone Nuclear Power Station,In Response to Srm,
ML20203E921
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 12/04/1997
From: Callan L
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-97-003-C, SECY-97-283, SECY-97-283-01, SECY-97-283-1, SECY-97-283-R, SECY-97-3-C, NUDOCS 9712170238
Download: ML20203E921 (36)
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POLICY ISSUE (Information)

December 4.1997 SECY-97-283 EQB: The Commissioners FROM L. Joseph Callan Executive Director for Operations

SUBJECT:

RECOVERY OF MILLSTONE NUCLEAR POWER STATION PURPOSE:

To provide the Commission with a periodic summary of ongoing activities related to the Restart Assessment Plan for the Millstone Nuclear Power Station, in response to a staff requirements ,

memorandum dated May 7,1907. The summary includes a status of the NRC's oversight of the Independent Corrective Action verification Program, an assessment of licensing issues for restart, a summary of significant inspection activities and results, and an updated project planning schedule.

BACKGROUND:

On November 4,19P5, the licensee (Northeast Utilities) shut down Millstone Unit 1 for a planned refueling outage. During an NRC investigation of licarsed activities at Millstone Unit 1 in the fall of 1995, the N RC staff identified potential violations in the refueling practices and operation of the spent fuel pool cooling systems. The violations involved inconsistencies with the Updated Final Safety Analysis Report (UFSAR). The NRC issued a letter to the licensee on December 13,1995, requiring it to inform the NRC before restarting of Millstone Unit 1 pursuant to Section 182a of the Atomic Energy Act of 1954, as amended, and Section 50.54(f) of Title 10 of the Code of Federal Reaulations (10 CFR 50.54(f)), of the actions taken to ensure that in the future it would operate that facility according to the terms and conditions of the plant's operating license, the Commission's regulations, and the plant's UFSAR.

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Contact:

NOTE: TO BE MADE PUBLICLY AVAILABLE IN William D. Travers, NRR 301-415-1200 5 WORKING DAYS FROM THE DATE OF THIS PAPER hf 9712170238 971204 PDR SECY 97-283 R PDR b]fhfff']']'

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In January 1996, the NRC designated the three units at Millstone as Category 2 plants on the NRC's watch list. Plants in this category have weaknesses that warrant increased NRC attention until the licensee demonstrates a period of improved performance. On February 20, 1996, the licensee shut down Millstone Unit 2, declaring both trains of the high-pressure safety injection (HPSI) system inoperable because of a design issue (there was a potential that the HPSI throttle valves could become plugged with debris in the sump recirculation mode). On March 30,1996, the licensee shut down Millstone Unit 3 after finding that containment isolation valves for the auxiliary feedwater turbine driven pump were Inoperable because the valves did not meet NRC requirements. in response to (1) a licensee root-cause analysis of Millstone Unit 1 UFSAR inaccuracies that identified the potential for similar configuration management conditions at Millstone Units 2 and 3, and (2) design configuration issues identified at these units, the NRC issued 10 CFR 50.54(f) letters to the licensee on March 7 and April 4,1996.

These letters required that, before restarting each unit, the licensee inform the NRC of the corrective actions taken iegarding design configuration issues at Millstone Units 2 and 3.

In June 1996, the NRC designated the three units at Millstone as Category 3 plants on the NRC's watch list. Plants in this category have significant weaknesses that warrant maintaining them in a shutdown condition until the licensee can demonstrate to the NRC that it has both established and implemented adequate programs to ensure substantialimprovement. Plants in this category require Commission authorization to resume operations.

On August 14,1996, the NRC issued a confirmatory order directing the licensee to contract with a third party to implement an Independent Corrective Action Verification Program (ICAVP) to verify the adequacy of its efforts to establish adequate design bases and design controls. The ICAVP is intended to prnvide additional assurance, before unit restart, that the licensee has identified and corrected existing problems in the design and configuration control processes.

On October 24,1996, the NRC issued an order directing that, before restarting any Millstone unit, the licensee 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 concems can do so without fear of retaliation. The order also directs the licensee to retain an independent third party to oversee implementation of its comprehensive plan.

On November 3,1996, the NRC created a new organization, the Special Projects Office (SPO),

within the Office of Nuclear Reactor Regulation (NRR), to provide a specific management focus on future NRC activities associated with the Millstone units. The SPO's responsibility for activities at Millstone includes all licensing and inspection activities required to support an NRC decision on restart of the Millstone units.

In SECY-97-003, " Millstone Restart Review Process," dated January 3,1997, the staff described to the Commission processes and approaches that the NRC staff will use to oversee

the corrective action programs at the three units of the Millstone Nuclear Power Station. The staff is applying the guidelines of NRC Manual Chapter (MC) 0350, " Staff Guidelines for Restart Approval," to the restart approvals for Millstone Units 1,2, and 3.

On January 30,1997, the staff and the licensee briefed the Commission on their respective activities at Millstone. Subsequently, on April 23,1997, and August 6,1997, the staff and the licensee provided the Commission updates on these activities.

DISCUSSION:

In a staff requirements memorandum dated May 7,1997, the Commission directed the staff to provide the Commission, prior to each quarterly meeting with the Commission, a written summary of the ongoing activities in the Restart Assessment Plan, including, but not limited to, the status of NRC oversight of the ICAVP, an assessment of licensing issues required for restart, a summary of significant inspection activities and results, and an updated project planning schedule.

The staff has identified in the Restart Assessment Plan several major elements that require resolution befoio plant restart. These elements include the corrective action program improvements, work planning and control improvements, procedure upgrade programs, employee concems program improvements, and quality assurance and management oversight improvements. The plan also includes staff activities to evaluate the completion of the ICAVP and the licensee's response to NRC's 10 CFR 50.54(f) letters regarding Millstone Units 1,2, and 3. The actions listed in the generic Manual Chapter 0350 restart checklist that are applicable to Millstone, such as those regarding management effectiveness and self-assessment capability, are also included in the plan. The plan provides for the conduct of an Operational Safety Team Inspection (OSTI), which is normally carried out to assess the overall readiness of a plant for restan after a prolonged shutdown. Other issues that will be reviewed by the NRC before restart include pending 10 CFR 2.206 petitions, enforcement actions, and allegations. Attachment 1 is a summary status of the major elements of the Restart Assessment Plan. Attachment 2 is the staffs plan for assessing NNECO's processes for handling employee safety concems. The plan provides additional details on staff actions regarding licensee handling of safety concems.

The staffs overall assessment is that the licensee is progressing in its various activities to effect needed improvements at Millstone. Led by a new senior management team since late CY 1996, the licensee has initiated a broad-scope effort to identify problem areas and to implement corrective actions. Although progress has not kept pace with the licensee's initial schedules, improvements in essentially all elements of the NRC's Restart Assessment Plans for Units 3 and 2 are being identified. This progress notwithstanding, the NRC staffs most important assossments of the licensee's readiness for restart have not yet taken place. These assessments are necessarily focused in the latter stages of the licensee's improvement program. A number of significant inspection activities (e.g., OSTI, employee safety concems, corrective actions, and oversight-effectiveness) will be initiated fohowing the licensee's own readiness determination. These inspections and the staffs remaining evaluations of the issues identified in the Millstone Restart Assessment Plans will ultimately form the bases for a staff restart recommendation to the Commission.

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The project planning schedules for Units 3 and 2 are provided in' Attachment 3. The licensee ,

continues to focus its recovery and restart efforts on Units 3 and 2 and has delayed activities at -

Unit 1. - The staffs current project planning schedules extend the previously identifed (SECY-97-166) dates for possible restart of Units 3 and 2 by approximately 3 months. These changes are directly related to slips in the licensee's schedule for accomplishing major milestones -

required for restart. The staff is continuing to plan and carry out its inspection and licensing activities based, in part, on extensive coordination with the licensee's schedules and accomplishments.

The OSTI for Unit 3 is schedu'sd to begin about February 1998, provided that the licensee has implemented all necessary corrective actions to have the plant and personnel ready for power i- operations, Based on the current schedule, a Commission briefing for a Unit 3 restart decision could occur in March 1998. Licent.ee efforts at Unit 2 are approximately 2 months behind those at Unit 3. Based on the current schedule, a Commission briefing for a Unit 2 restart decision

- could occur in the second quarter of CY 1998.

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. Jggeph Callan

!. Executive Director for Ogrations Attachments:

i- 1, Major Elements of the Restart Assessment Plan

, 2. Staff Assessment Plan for ECP and SCWE

3. Project Planning Schedule DISTRIBUTION:

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Maior Elements of the Restart Assessment Plan

1. Manual Chapter 0350 and Restart Assessment Plan
2. Independent Corrective Action Verification Program
3. Handling of Safety Concems Raised by Licensee Employees
4. Licensing issues
5. 10 CFR 50.54(f) Activities
6. Corrective Action Program
7. Oversight l

l 8. Enforcement Status

9. Work Planning and Controls
10. Procedure Upgrade Program 11, inspection Activities and Results
12. Operational Safety Team inspection l

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ATTACHMENT 1

1-ISSUE: NRC Manual Chapter 0350 and Restart Assessment Plan DISCUSSION: NRC Inspection Manual Chapter (MC) 0350, " Staff Guidelines for Restart Approval," establishes the guidelines for approving the restart of a nuclear power plant after a shutdown resulting from a significant event, complex hardware problem, or one for which serious management ,

deficiencies have been identified. The primary objective of the guidelines in MC 0350 is to ensure that the NRC's restart review efforts are appropriate for the individual circumstances, are reviewed and approved by the appropriate NRC management levels, and provide objective measures of restart readiness. The NRC staff is applying the guidelines of MC 0350 to the restart approvals of Millstone Units 1,2, and 3 because of NRC concems regarding the overall effectiveness of the licensee's management. MC 0350 states that the staff should develop a plant-specific restart assessment pian for NRC oversight of each plant startup. The restart assessment plan is to include all expected NRC actions required to be taken before the NRC approves a plant for restart.

NRC ACTION: The staff has developed a Restart Assessment Plan (RAP) for each of the Millstone units to incorporate the appropriate aspects of MC 0350 and to address site-specific and unit specific issues. The RAP consists of several major elements that require resolution before plant restart and are related to the root causes for the decline in licensee performance and must be completed prior to restart. These elements include the corrective action program notification, work planning and control improvements, procedure upgrade programs, employee concems program improvements, and quauty assurance and management oversight improvements. The plan, which is periodically updated, also includes staff activities to evaluate the licensee's responses to the NRC's demand for information (10 CFR 50.54(f)) letters regarding Milletone Units 1,2, and 3, and completion of the Independent Corrective Action Verification Program. The RAP also contains a unit-specific Significant items List (SIL): items that the NRC is using to audit and evaluate licensee programs and significant safety and regulatory issues.

Additionally, the actions listed in the MC 0350 generic restart checklist that are applicable to Millstone, such as those regarding management effetiveness and self-assessment capability, are included in the plan.

STATUS: The inspection and closure of RAP ltems is continuing for Units 3 and 2.

Because of the lict:nsee's decision to focus its recovery and restart efforts on Units 3 and 2, NRC RAP activities are also being directed to these units. Tiie licensee is providing SIL closure packages for NRC review and has scheduled the Snl closure package submittab for Units 3 and 2.

There has been some slippage in the schedule for these closure package submittals. As of November 14,1997, the NRC staff has closed 30 of the 86 items for Unit 3, with an additional 34 items receiving partial review.

For Unit 2,11 of the 51 items were closed, and 1 of the 108 items for Unit 1 was closed.

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ISSUE: Independent Corrective Action Verification Program -

DISCUSSION: On' August 14,- 1996, the NRC issued a confirmatory order establishing L l an Independent Corrective Action Verificatic:; Program (ICAVP). The independer.. effort, carried out by a contractor approved by the NRC, will i verify the adequacy of Northeast Utilities' efforts to establish adequate design bases and design controls, including translation of the design -

bases into operating procedures and maintenance and testing practices, verification of system performance, and implementation of modifications '

since issuance of the initial facility operating licenses. T;e ICAVP is intent.ed to provide additional assurance, before unit restart, that the licensee has identified and corrected existing problems in the design and configuration control processes.- it includes a three-tiered approach, as described in SECY-97-003, " Millstone Restart Review Process," dated January 3,1997, for a sample evaluation of the licensee's activities. The NRC oversight of the ICAVP is one of many activities that make up the Restart Assessment Plan (RAP). The results from this program wl'l be considered as a significant part of the decision regarding recommended restart. ,

The licensee is implementing its Configuration Management Plan (CMP), j which is intended to confirm that the future operation of Millstone Units 1, j 2, and 3 will be conducted in accordance with the terms and conditions of I their applicable operating licenses, UFSARs, and NRC regulations. The CMP includes efforts to understand the licensing and design bases issues, which led to issuance of the 10 CFR 50.54(f) letters and actions to prevent recurrence of those issues. The CMP includes a review of the licensing basis requirements for the 88 Unit 3 and 63 Unit 2 systems that the licensee has categorized through the implementation of the maintenance rule as either Group 1 (safety-related and risk-significant) or Group 2 (safety-related or risk-significant). After the licensee had completed problem identification of one-half of the Group 1 systems, the ICAVP contracter began its review. The licensee completed the problem identification phase of the CMP for Unit 3 on July 16,1997, and on ,

September 15,1997, for Unit 2.

NRC ACTION: _ The staff's oversight objectives are to ensure that the review by the ICAVP contractor is independent of the licensee and its design contractors, is performed by qualified individuals, and is comprehensive,

incorporating appropriate engineering discipline and operational reviews.

In accordance with the confirmatory order, the NRC reviewed and approved the proposed ICAVP contractor for each unit and the contractor's audit plan for each review. The staff selected the specific systems to be evaluated in the ICAVP, with input from the Connecticut Nuclear Energy Advisory Council (NEAC). The NEAC selected two of the systems to be reviewed by the ICAVP contractor for Units 2 and two systems for Unit 3 from a list of systems identified by the NRC. While

, key design aspects of many of the systems being evclusted by the -

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- licensee will be assessed in the ICAVP, four systems will be examined in :

j detail by the contractor.,The scope of the ICAVP will be increased if  ;

- significant issues are identified in the assessment of the licensee's 1 corrective actions.

in addition to overseeing the activities cf the ICAVP contractor, the sta#

is performing its own independent inspechons. The staff plans to conduct ,

, independent vertical-slice inspechons of at least two systems per Unit; one within the scope of the ICAVP and one outside the scope. Also, the staff will evaluate the final results of the ICAVP contractor's audit and - o

, assessment of the licensee's corrective actions. Details of the staffs -

oversight plans are contained in SECY-97-003.  ;

STATUS: The staff approved Sargent & Lundy (S&L) for the conduct of the  :

Millstone Units 1 and 3 lCAVP on April 7,1997. The licensee completed i

.. - problem identification on one-half of the Group 1 systems for Unit 3 on

' May 27,1997. The staff approved the S&L audit plan on June 3,1997, and selected the first two systems for ICAVP review (service water i system and the quench spray /rocirculation spray system'). On July 16, i

1997, the licensee completed the problem identification phase for Unit 3.

c. The two remaining systems were selected by the NEAC from a list of

systems provided by the NRC that were grouped to provide insights into

safety system functionality. The first system group selected by NEAC  !

was the emergency diesel generator which is comprised of nine systems.

The second system group selected was the auxiliary building HVAC -

system and supplemental leakage collection and release system. '

The staff approved Parsons Power Group, Inc. (Parsons) on May 28,

1997, to conduct the Millstone Unit 2 ICAVP. The audit plan was approved by the staff on July 15,1997. The licensee completed problem identification on one-half of the Group 1 systems June 30,1997. At that time the staff selected the first two systems for review (high pressure safety injection system and the refueling water storage tank as one system and auxiliary feedwater and the condensate storage tank as the

, other system); On September 15,- 1997, the licensee completed the U

problem identification phase of CMP for Unit 2.-- In an identical process to Unit 3, NEAC selected the second two systems on September 18,1997.

The first system group selected by NEAC was the emergency diesel -

generator and support systems which for Unit 2 includes 5 systems. The 7'

second systems group selected was radiological release control systems which includes 3 systems.

1 Both Parsons and S&L have extended their projected schedules for completing the ICAVP. The extenelons have been a result of several n

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[ _ The quench spray system and the recirculation spray system are identified as two

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separate systems by the licensee but they are being considered as one system for review by

. the ICAVP.

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factors, a fuller realization of the scope and depth of review required, the -

ability to find experienced engineers to augment their staff's, and the ability of the licensee to simultaneously supply documentation in a timely manner to both ICAVP contractors and the NRC staff.

In accordance with the staff's plan to assess the effectiveness of the -

licensee's Configuration Management Plan desenbod in SECY-97-003, the staff conducted a Safety System Functional Inspection (SSFI) on a -

system that was outside the scope of the ICAVF but had been reviewed by the licensee's Configuration Management Plan (CMP), The sts#

selected the safety injection mode of the charging system for Unit 3 as the subject of this inspection. The inspection included four weeks on site in addition to two weeks of in office review. The inspection identified findings that were similar in nature to SSFis previously conducted by the sta# at other sites, including several issues that are being evaluated by the licensee that may potentially affect retem operability. The team had identified a number of findings that were not previously identifed by the licensee's CMP. Some of the findings related to FSAR information that was not consistent with the facility design. Following the inspection, the licensee reassessed their CMP for Unit 5 and concluded that it was a comprehensive program to verify conformance with the design and licensing bases. However, the licensee acknowledged that the CMP did not review system functionality in a manner similar to the SSFI conducted by the staff. Therefore, the CMP did not identify the kinds of operational issues identified by the staff. Following the conclusion of the staffs inspection, the licensee initiated a functional review of systems required to mitigate a loss of coolant accident. This review will examine the ability of these systems to perform their intended accident mitigation function ,

when called upon, considering the actual initial systems conditions anticipated during normal plant operation. The staff is evaluating the SSFI findings and the licensees corrective actions with regard to the effectiveness of the licensee's CMP.

In September, the staff completed the inspection of S&L's implementation

- of the Unit 3 ICAVP audit plan. The inspection team identified some weaknesses, which were promptly addressed by S&L. However, the team was not able to evaluate certain aspects of S&L's ICAVP implementation becauso they had not yet been started. The inspection team concluded, that for the aspects of the audit plan available for review, the ICAVP audit plan was being adequately implemented. The remaining aspects of the audit plan will be evaluated by the staff during its SSFI inspection of a system within the scope of the ICAVP.

As of November 18,1997, S&L had closed 72 discrepancy reports (DRs)

= of the 455 preliminary discrepancy reports issued. Of the 72 DRs closed, only.one DR identified a nonconformance with the design and licensing bases. This issue had not been previously identified by the CMP. The safety significance of this DR, however, was low. The majority of the issues identified by S&L did not involve nonconformances with the design

1 and licensing bases. The staff is assessing these issues to determine if they are indicative of a programmatic weakness which should be addressed by the licensee.

The staff had performed an initialinspection of Parsons' implementation of the Unit 2 ICAVP audit plan in September. Due to initial delays in getting information from the licensee, Parsons did not have enough completed work for the staff to finalize this implementation inspection.

Current plans have this inspection being completed in early December 1997.

As of November 18,1997, Parsons had closed 11 DRs of the 106 preliminary DRs issued. Of the 11 DRs closed, none identified a nonconformance with the design and licensing bases.

The staff has also begun it's inspection of the Unit 3 ICAVP Tier 2 and Tier 3 activities as described in SECY-97-003. Current plans have this inspection ending in early January 1998. Additionally, the Unit 3 ICAVP Tier 1 in-scope system review inspection is scheduled to begin by mid-December 1997 and the Unit 3 ICAVP corrective action inspection is scheduled for January 1998 Current plans for Unit 2 ICAVP inspections call for (1) the Out-of-scope Tier I system review inspection and the Tier 2 and Tier 3 inspections to begin in January 1998; (2) the In-scope Tier 1 system review inspection to begin in March 1998 (after Parsons' has completed its Tier 1 activities);

(3) arid the ICAVP corrective action inspection to begin in Apft 1998.

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ISSUE: Hand!ing of Safety Concems Raised by Licensee Employees l

DISCUSSION: In its Saptember 1996 report, " Millstone Independent Review Group Regarding Millstone Station and NRC Handling of Employee Concems I and Allegations," the NRC staff determined that, in general, an unhealthy work environment, which did not tolerate dissenting views and did not welcome or promote a questioning attitude, has existed at Millstone I plants for the past several years. This poor environment has resulted in repeated instances of discrimination and ineffective handling of employee l concems.

I On October 24,1996, the Director, Office of Nuclear Reactor Regulation, issued an order to Northeast Utilities (NU) requiring specific actions to resolve problems in the process for handling employee safety concems at the Millstone station. The order required Northeast Nuclear Energy Company (NNECO) to develop, submit for NRC review, and implement a comprehensive plan for (a) revievting and dispositioning safety issues iaised by its employees and (b) ensuring that employees who raise safety concems can do so without fear of retaliation. On January 31,1997, NNECO submitted the plan to the NRC and began implementation of elements of the plan.

The order further required NNECO to submit, for NRC approval, the name of the proposed independent, third-party oversight program (ITPOP) organization, to oversee implementation of NNECO's comprehensive plan. On April 7,1997, the NRC approved Little Harbor Consultants, Inc. (LHC), as the third-party organization. The order specified that once approved, the third-party organization was to develop and submit for NRC approvalits oversight plan. On May 2,1997, LHC submitted its third-party oversight plan to the NRC for approval. On July 15,1997, the NRC reviewed and approved the ITPOP oversight plan. As specified in the order, independent, third-party oversight will continue until NNECO demonstrates, by its performance, that the conditions which led to the requirements of the oversight have been corrected.

NRC ACTION: The NRC staff will perform the following functions regarding employee concems: (1) review and comment on the licensee's comprehensive plan; (2) review and approve the third-party organization that will oversee the comprehensive plan; (3) review ar,d approve the third-party organization oversight plan; and (4) assess the effectiveness of NNECO's implementation of its programs for handling employee safety concems.

In assessing of program effectiveness, the staff will rely substantially on the findings of ITPOP's oversight activities. The staff will direct its limited resources to evaluating a sample of NNECO's programs and activities and reviewing ITPOP oversight activities. These objectives will bo

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accomplished by reviews of NNECO programs, procedures, and data; assessment of program measures and indicators; observation and monitoring of program activiis; and a team evaluation of NNECO's,

, Employee Concems Program and safety-conscious work environment activities and ITPOP oversight of those activities.

STATUS: As discussed'above, the staff has reviewed and provided comments to the licensee on the comprehensive plan, approved the ITPOP organization, and reviewed and approved the third-party organization

, oversight plan.

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, The NRC staff is implementing its assessment plan for monitoring the licensee's implementation of the comprehensive plan and LHC oversight

. - of that implementation, An NRC team evaluation is schedcled to begin the week of December 8,1997. The staff's assessment plan for NNECO's processes for handling employee safety concems is provided .

as Attachment 2 to the Commission paper.

As of November 13,1997, the staff has observed considerable progress L in NNECO's Employee Concerns Program (ECP) efforts. LHC has found j- ,

that NNECO's response implementation have been effective in resolving l identified issues. Further, the ECP staff were proactive in their response i to several personnel action issues that occurred late in the summer.

Less progress has been apparent in NNECO's activities to establish a safety-conscious work environment (SCWE). At a November 13,1997,

meeting, LHC reported that their reviews had found that ECP, SCWE, and management activities were not being adequately coordinated. LHC l.

also reported that employee tr;:ang on SCWE was not timely and that the training for managers and supervisors were lacking in instruction for the areas of protected activities, retaliation, and chilling effects. Also, while NNECO has made efforts to identify management and supervision problem areas, LHC reports that actions to address these known problem

[ areas were not being implemented in a timely manner. NNECO has I

taken action to address these findings and will address LHC recommendations at a future meeting between NRC, LHC, and NNECO.

The staff's team evaluation scheduled to begin the week of December 8, 1997, will assess the status of both the ECP and SCWE activities at Millstone station.

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ISSUE: Licensing issues .

DISCUSSION: The licensee plans to submit or has submitted licensing issues-(amendments, unresolved safety questions, relief requests, etc.) for each unit that will need to be reviewed and approved prior to restart. .

NRC ACTION: The staff will process and review licensing acti:ns as they are Nentified and submitted by the licensee. The staff will follow the normal processes for these actions.

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STATUS: UMt 3: As of November 14,1997, the licensee Ma subrnitted 29 license amendments that it has ddermined to be needed prior to restart. in  :

addition, the licensee has identified one additional license amendment, needed prior to restat (scheduled to be submitted by the end of -

Noveraber 1997). Of the 29 amendment requests submitted to the NRC, 17 have been issued,4 hav6 been withdrawn, and the other 8 are under -

NRC review. There are six other licensing issues under staff review For

five of the six issues, the staff is wwiting for additional information or the completion of the licensee's review. The staff is reviewing the remaining one.

. Unit 2: = As of November 14,1997, the licensee has identified 20 licensing actions that need to be completed prior to restart. These include 13 -

license amendments,5 other licensing actions,1 exemption, and i unreviewed safety question. Of the 20 to be submitted to the NRC,6

have been completed,9 are currently under staff review, and five have not yet been submitted.

P Unit 1: As of November 14,1997, the licent.ee has identified 14 licensing actions that need to be completed prior to restart. Only five have been submitted to the NRC. Of the five submitted, three license amendments have been issued and the others are currently under NRC review.

The amendments submitted to date end the staff's projected review

- schedule do not appear to impact the licensee's ability to restart on its current schedule. However, the staff has requested additional or clarifying information on several license amendment requests, and these requests have lengthened the review process. Late submittals or new emerging issues, which require extensive staff review, may impact the licensee's projected schedule.

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, ISSUE: 10 CFR 50.54(f) Activities DISCUSSION: On December 13,1995, the NRC issued a letter to Northeast Utilities (NU) requesting NU, pursuant to 10 CFR 50.54(f), to provide information describing actions taken to ensure that future operations of Millstone Unit 1 will be conducted in accordance with the terms and conditions of the Millstone Unit 1 operating license, the Commission's regulations, including 10 CFR 50.59, and the Millstone Unit i UFSAR. Similar letter:3 were issued to NU for Millstona Unit 2 on March 7,1996, and Unit 3 on April 4,1996 In those letters, the NRC requested that the information be submitted no later than 7 davs before restart of the respective Millstone unMs.

By letter dated May 21,1996, the NRC further requested, pursuar.t to 10 CFR 50.54(f), a comprehensive list of design and configuration deficiencies identified after the letter of December 13,1995, was sent for Millstone Unit 1, and after the Adverse Condition Report 7007 Event Response Tewm Report was issued for Millstone Units 2 and 3.

Because of the increased level of NRC overs'ght, the classification of the units at Millstone as Category 3 plants, the two previously mentioned orders, and the creation of the Spacial Projects Office, the information needed by the NRC before plant restart changed. By letter dated April 16,1997, the NRC superseded the requests contained in the previously mentioned 10 CFR 50.54(f) letters and requested the following items: (1) the significant items that need to be accomplished before restart; (2) the list of items to be deferred until after restart; (3) the process and rationale NU is using to defer items until after restart; and (4) a description of the actions taken to ensure that future operation of the unit (s) will be conductad in accordance with the license, regulations, and UFSAR. NRC requested the licensee to subrait items 1,2, and 3 within 45 days of the letter and items 1 and 2 were to be updated approximately 45 days thereafter. Item 4 was requested to be submitted 14 days prior to the Commission meeting for each individeal unit.

By letter dated May 29,1997, fhe licensee submitted the requested information (items 1,2, and 3) for Millstone Units 2 and 3. The licensee did not submit the information for Millstone Unit 1 in the first submittal because of a decision to scale back work and minimize resource l expenditures during 1997. By letter dated July 14,1997, the licensee I submitted the required information for Millstone Unit and an update for i Millstone Units 2 and 3. An inspection of the Millstone Unit 3 restart and  !

deferral list was conducted in July 1997 (see discussion below). In a  ;

letter dated August 26,1997, the licensee stated that the next update letter scheduled for August 29,1997, would be delayed due to a review of l the scope of work and the process used to develop the lists (corrective l action following inspection). By letter dated October 21,1997, the licensee submitted an update on the deferred issues (item 2) for all three 1

units. The Milstone Un!t 3 list now contains approximately 3000 items to be deferred, the Millstone Unit 2 list contains approximately 1100 items.

The licensee did not submit an update on the significant items for restart (item 1) due to continuing reviews. An inspection of the Millstone Unit 2 and 3 list was conducted in October 1997.

NRC ACTION: In July 1997, the NRC staff reviewed the licensee's May 29 and Juiy 14, 1997, submittals. As a result of the inspection, the NRC found the licensee in violation of 10 CFR 50.9, " Completeness and accuracy of information," and issued the licensee a Notice of Violation (NOV). The staff stated in the NOV that the information provided was inaccurate or incomplete in that (1) open item reports were not included in the May 29, 1997, submittal; (2) control room deficiencies and bypass jumpers were not reviewed for inclusion in the May 29,1997, submittal; (3) all exicSng items were not included in the submittals; and (4) a number of items that the licensee did not intend to defer were improperly included in the list of items to be deferred until after restart. Following the inspection, the licensee implemented several corrective actions, including defining management roles and responsibilities, developing a specific verification and validation process, and increasing management oversight.

STATUS: In October 1997, the NRC staff reviewed the licensee's October 21,1997, submittal. The staff noted improvements in the quality of the list and did not find any significant items on the deferred list that needed to be completed prior to restart.

The NRC staff plans to inspect the Millstone Unit 2 and 3 lists again closer to restart. This inspection will be limited to the additional items added to the deferred list since the October 21,1997, submittal.

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_ . _ _ _-_ ._ _-_ _._ __ _ _ _ - _ m. _ -__ , _ _ ,

f 11 #

i ISSUEi ' Corrective Actio') Program'  :

I DISCUSSION: NU's' Corrective Action Program has been weak'in ensuring comprehensive and effective corrective actions. In many instances, . j narrowly focused corrective actions have failed to_ resolve all aspects of >

the underlying problem. Additionally, the licensee has failed to follow up -i on corrective actions to ensure effectiveness.

NRC ACTION: The NRC inspection staff will concentrate on issues identified for each 4

unit by the licensee's condition report (CR) process and will audit the  :

licensee's corrective actions for completeness. The staff is periodically selecting (CRs) for review, based on the licensee's assigned level of importance, or on their risk significance, as perceived by the NRC staff.  ;

Additionally, the staff will examine other CRs to gain a broader spectrum of corrective action issues. ,

l The primary intent is to assess the Corrective Action Program while

evaluating safety-significant technical issues. Additional insights will be  ;

j gained using NRC Inspection Manual Chapter 40500, " Effectiveness of l Licensee Controls in Identifying, Resolving, and Preventing Problems,"

monitoring closure of the Significant items List issues, monitoring closure of licensee event reports, and through the normal inspection program, which routinely collects valuable insights regarding the effectiveness of l corrective actions. Additionally, the NRC staff, through oversight of the c ICAVP, will assess the licensee's corrective actions for degraded and nonconforming conditions.

Prerequisites for the NRC MC 40500 inspection are that the unit is i physically ready for plant restart, the Nuclear Oversight Restart Verification Plan is complete, and that there is a decreasing trend in the p number of restart issues (e.g., maintenance work orders, deficiencies, 1 significant items). The inspection will assess licensee management  ;

effectiveness in resolving problems and organizatione, effectiveness in

  • dealing with employee-identified issues, in particular, the inspection will focus on the results of the nuclear oversight restart verification process i~

for utility leadership, self-assessments, corrective actions, operating experience feedback, and the onsite and offsite safety review committees. Finally, the OSTI will audit portions of the conective action +

process, 4 STATUS: The inspections' performed to date indicate an increased management focus on the Corrective Action Program problem at Units 2 anu 3. The

. staff has noted improvements in the quality of the Significant items List

closure packages provided by the licensee. The corrective action-t planning and implementation for these RAP items are generally being
evaluated as adequate for issue closure.

l

)

4

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s The staff has requested that the licenses determine, with nuclear - .l oversight concurrence, plant readiness for an NRC MC 40500 inspection

. and communicate this to the NRC docket.' A nuclear oversight oudit _

conducted at Units 2 and 3 from August 11 through 29,1997, concluded -

that the corrective actie'1 program has not yet achieved the state of implementation required to demonstrate effectweness in resolving e identified significant concerns adverse to quality in a timely manner. In October 1997, licensee line management conducted self-assessment.

~ activities to evaluate readiness for the NRC corrective' action inspec'!on.

Based on the results of the self-assessments, the licensee first said tnat it j would be ready for the NRC MC 40500 inspection by December 1,1997 '

Subsequently, licensee management decided that the physical readiness ,

of Unit 3 for plant restart was a condition to be met before the NRC MC 40500 inspectKms. Physical plant readiness is projected for late December 1997. Therefore, the NRC MC 40500 inspection has been scheduled for January 1998, I

[ _.

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ISSUE: Oversight DISCUSSION: The licensee has identified its oversight function as deficient through self-assessments and external and intemal audits, and has identified its oversight function as a factor in its declining performance. The Yankee Atomic Electric Company (YAEC), as described in the report

" Assessment of Past ineffecilveness of Independent Oversight,"

examined the failure of Quality Assessment Services, the Independent Safety Evaluation Group, and the Nuclear Review Board to identify specific program deficiencies at Millstone. YAEC found that management did not support these oversight functions adequately.

The licensee, more recently, had an independent review of the nuclear oversight function performed by an outside consultirig firm. A July 1997 independent assessment of Nuclear Oversight stated: "The team found that the Nuclear Oversight organization has made considerable progress over the past 6 to 9 months. However, the team also found that significant additional improvement is required both from nuclear oversight and from Millstone station senior management before the oversight organization will be fully effective."

NRC ? CTION: The NRC assessment of the nuclear oversight function is addressed through insights gained from the normalinspection program. In addition, the NRC will perform a specialinspection of the oversight function using NRC Inspection Manual Chapter 40500. Additionally, the OSTI will inspect how effectively the oversight function has been integrated into the operation of the plants.

STATUS: At Units 2 and 3, the staff has observed increased Nuclear Safety and Oversight (NS&O) involvement in performance monitoring, interfacing analysis, and support of the management and line staffs. Particularly noteworthy were NS&O's assessments of training and the 50.54(f) effort.

Rotational assignments between the line organizations and Nuclear Oversight continue and appear to have had positive impact upon quality assurance credibility with other licensee organizations. Nuclear Oversight, as part of its Restart Verification Plan issued in August 1997, continues to monitor the status of approximately 21 " key issues"(e.g.,

corrective action, leadership, compliance operations, et. al.) at Units 2 and 3, thus providing line management with independsnt assessment input as to the areas that need improvement. Although the staff has ,

noted improvements, final assessnient of Nuclear Oversight performance is reserved until completion of the NRC MC 40500 and OSTI inspections.

1 i

ISSUE: Enforcement Status DISCUSSION: A predecisional enforcement conference was held with the licensee on December 5,1996, to discuss 64 apparent violatioca. Subsequent inspections have identified additional examples of similar violations these have been incorporated into the enforcemer,t package, increasing the number of violations to approximately 80 individual items. The licensee did not contest any of the violations 3t the conference, and the staff is finalizing the enforcement package.

NRC ACTION: Once enforcement actior,s have been taken, the NRC will evaluate the licensee's corrective action for those enforcement actions determined to impact the restart of each unit.

STATUS: The enforament history at Unit 3, prior to the plant shutdown in 1996, was generally good. With the significant number of configuration and deaign basis deficiencies identified during subsequent NRC followup f nspections, i as well as the licenses's own identified configuration

/ management problems, routine and escalated enforcement rose accordingly, in the last 6 months, the licensee has issued approximately 28 licensee event reports (LERs), most of which represent licensee-identified violations of regulatory requirements. Over the last three inspection periods,12 LERs involving violations of the plant Technical Specifications have been inspected and closed. Currently, there are 36 escalated enforcement items pending on Unit 3.

At Unit 2, NRC inspections conducted in 1996 resu'ted in a large number of escalated enforcement items associated with conf'guration and design basis deficiencies. Currently, there are 22 escalated enforcemen. items pending on Unit 2.

Since current violations, unresolved items, and escalated enforcenient items might actually reflect past problems just recently discovered, it is difficult to assess performance on the enforcement numbers alone.

Recent enforcement items at Units 3 and 2 are associated with procedure inadequacies, emergency preparedness, training, and failure to wear proper dosimetry.

n.

L. g ISSUE: Work Planning and Controls

, DISCUSSION: Work planning end controls are other areas in which the licensee has

'shown a weakness. The ability to plan, control, and complete work is fundamental to achieving adequate corrective actions. Effective work

. planning and controls are prerequisites for reducing and ma,1 aging

[ backlogstWeak work planning and controls were demonstrated during the Unit 2 outage, wherein tagging boundary violations resulted in an --

extensive eMort by the licensee to correct the identified weaknesses.

NRC ACTION: . The NRC staff reviewed the licensee's recently implemented site-wide

'- Automated Work Order (AWO) process. The AWO process is an integral part of the work planning and control system and is instrumental in establishing the scope of the work, providing the e,.propriate procedures, and establishing the tagging boundaries.

, The OSTI will assess engineering and maintenance backlogs during the

,. operational readiness inspection. The OSTI will determine if there are g safety significant issues that must be resolved before restart.

l- STATUU: At Unit 3, some configuration management and component lineup (e.g.,

valve position) discrepancies have contributed to operational events.

i_ While these events (e.g., a spent fuel pool heatup) were of low safety

, significance, licensee corrective measures were directed to work p'anning i

' and controls to strengthen the support to operations. Substantial

progress has been made to reduce the backlog of preventive maintenance work orders, but the corrective maintenance backlog of AWOs still represents a challenge for the licensee to keep to its work schedule for physical plant readiness. As of November 19,1997, the l AWO backlog in 2163. At startup, the goal for AWOs is less than 500 items, which includes less than 350 maintenance-rule systems items.

{ Recent progress in motor-operated valve rework and testing has allowed

, operational evolutions to proceed, but less than 50 percent of the valve work is complete.

, At Unit 2, performance associated with tagging adequacy, work scope

. definition, and procedural adherence has been good. Evaluation of the schedule from a shutdown risk perspective coritinues to be good. One of the licensee's greatest challenges continues to be a lack of adherence to schedule that limits progress in reducing backlogs and ach!aving timely corrective actions. The current AWO backlog for this outage is 1432. A great deal of work associated with engineering modifications remains.

Out of a total 151 outage modifications,105 require physical work, and only 24 have been completed. ' None of the three Significant Items List (SIL) issues associated with maintenance has yet been closed. i

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ISSUE: Procedure Upgrade Program DISCUSSION: The quality of and adherence to procedures have been chronic problems at the Millstone site. Tnis issue was an element in the " Improving Station Performance" program and the earlier " Performance Enhancement Program." In response to NRC concems, the licensee developed the Procedure Upgrade Program (PUP)in the early 1990s to improve station procedures.

Before the reorganization in October 1996, there was a station-wide Procedure Upgrade Group that provided overall control of the PUP. This group developed and maintained the statior, document control (DC) procedures for control of the program, the overall status of upgraded procedures, coordinators for each Millstone unit, and the hiring of contractors, as necessary, to write the procedures. Since the licensee's reorganization in October 1996, the PUP group has been decentralized.

The station-wide group now only controls the station administrative procedures, including the PUP DC proceoures. The implementation and quality of procedure upgrades are now the responsibility of the individual technical departments within each unit.

NRC ACTION: The staff, in its inspection of selected pl ant procedures and other inspection activities, will ioentify whether the procedures have been upgraded and will evaluate the effectiveness of the PUP. NRC inspections willinclude an assessment of the PUP for each Millstone unit.

STATUS: At Unit R the effectiveness of the previous licensee PLIP initiative has not been clear. The CMP activities at Unit 3 have shown a need for individual proet dure revisions, as well as for programmatic efforts (e.g.,

integration of vv.'idor ~nformation i into unit procedures) which are still ongoing. An ;nte. grated NP,C review of procedural adequacy has determined that in conjunction with the PUP, the other licensee CMP and programmatic initiatives, if followed through to proper completion, provide reasonable assurance that adequate procedures for the safe operation of the plant will exist at the time of unit restart. Since this area continues to receive appropriate licensee management attention and will be further inspected during normal inspections and special planned team inspections the continuing assessment of procedural adequacy is an ongoing effort.

At Unit 2, the PUP has not yet been completed. The intent of the upgrade effort was to reformat the procedures.

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SSUE
Inspection Activities and Results STATUS: The most recent inspection report for the Millstone station (NRC Inspection Report Numbers 50 245/97 203; 50 336/97 203; 50-423/97-203, dated November 21,1997) identified four violations of NRC requirements. One violation at Unit 1 involved the failure to properly ensure that safety related work was correctly coded and reviewed by the Quality Control (QC) group. In May 1997, a work control procedure was revised to resolve a previously identified problem with QC involvement in the work planning process. In this case, the new requirements in that procedure were not followed. As processes and procedures continue to be changed, plant personnel need to be properly trained and new expectations must be continually reinforced. The report also describes a Unit 2 violation in which an operating procedure failed to address thermal binding concems for the Unit 2 steam admission valves for the turbine-driven auxiliary feedwater pump. Another site-wide violation involved shipping activities in which a package of radioactive material was transported from the facility to the Connecticut Yankee Atomic Power Station. Upon receipt, the package was determined to have external radiation levels above the regulatory limits. Finally, a recurring site wide violation was identified in radiological worker practices. Four examples of workers improperly entering or exiting the radiologically controlled area at each unit were identified during the period September 816,1997.

Although corrective actions taken to address previously identified violations in this area have generally reduced the rate at which such errors are occurring, they have not been fully effective.

3 At Unit 2, the licensee has been successful in addressing the longstanding problems associated with tagout adequacy, as demonstrated by good performance over an extended period. Strong self-assessments and corrective actions associated with tagging have been the driving force behind continued improvements in this area.

On September 24,1997, the licensee reported that the Unit 2 engineered safety feature actuation system (ESFAS) cabinets were inoperable because new power supplies installed in a 1994 modification conU have blown the power supply fuses if an ESFAS actuation had occurred, thereby preventing the actuation of safety equipment. The licensee event review team determined that the root cause of this event was the configuration management process was inadequately imp!omented and documented for the ESFAS power supply modification.

Substantial work remains to be done to a bleve closure of the Generic Letter (GL) 89-10 motor-operated valve (MOV) program at Units 2 and 3.

The Units 2 and 3 GL 89-10 program had recently been significantly revised. MOV design basis reviews, modifications, overhauls, and addrtional testing remained to be complated. Appropriate resources were

18-i devoted to forming a new MOV organization to support all of the Millstone units in correcting MOV program deficiencies.

For Unit 3 in this report and in the previous inspection report, improvements were noted in the programmatic control of several major technical and topical areas (e.g., environmental qualification, MOVs, electrical separation) and the SIL ltems associated with these issues appeared to be property directed toward resolution. However, in other SIL areas (corrective action; vendor programs; materials, equipment, and parts lists), which appear to represent engineering programs of a more peneral topical nature and which are applicable to all three units, prompt and sustained progress toward the disposition of NRC concems was less evident.

As the result of the emergency preparedness program inspection for restart (NRC Inspection Report Numbers 50-245/97 203; 50-336/97 203; 50-423/97-203, dated November 24,1997), several problems were identified that do not support restart. The problems included: (1) instances of failure to maintain emergency response facilities in accordance with the emergency plan; (2) inadequate dose assessment procedures; (3) effectiveness of the emergency plan was reduced without prior NRC approval; and (4) self-assessment activities did not identify these problems.

The licensee is planning to begin reloafng the core at Unit 2 on January 19,1998. The NRC staff is planning to inspect the licensee's regulatory compliance during mode change, management oversight and involvement, operator performance, and nuclear oversight involvement.

On March 7,1997, the NRC issued a confirmatory action letter (CAL) to document the licensee's commitments conceming programmatic weaknesses in the licensed operator initial and requalification training programs. On October 31,1997, the licensee provided an update response to the CAL that showed that the licensee had completed the commitments under the CAL. In addition to the corrective actions described in the CAL, the licensee is also taking a broad range of corrective actions to reinforce the overall quality of the operator training programs. The requalification training program is continuing and the initial training program is under review with an initial class schedubd to begin for Unit 1 in February 1998, and for Unit 2 in the second quarter of 1998.

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19-ISSUE: Operational Safety Team inspection DISCUSSION: As a final check before the staff can recommend restart of each individual

.Ait, the staff will conduct an inspection to verify that plant operations are being conducted safely and in conformance with regulatory requirements.

The staff will verify that the organizations that control and support plant operations are functioning effectively to ensure operational safety.

Elements of the inspection include operations, maintenance, surveillance, management oversight, technical support, safety review, quality assurance, and corrective action. Additionally, the staff will verify that the licensee has properly prepared its staff and the plant for resumption of power operations after an extended shutdown.

NRC ACTION: NRC management will designate a team leader and arrange for the appropriate technical inspectors. The team leader will develop the scope of the inspection and determine the necessary technical disciplines to inspect the plan adequately. The inspection team typically is given 1 to 2 weeks to prepare for the inspection,2 weeks (or more, if needed) on site to perform the inspection, and 2 weeks to write the report inputs. A formal exit interview with the licensee is held 1 to 2 weeks after the last day of the inspection to present the findings and receive any completed corrective actions from the licensee.

STATUS: The team leaders for Units 3 and 2 have been identified and planning has begun. A draft inspection plan has been developed and is under management review. The inspection for Unit 3 is planned to start about February 1998. The inspection for Unit 2 is scheduled to start in the second quarter of 1998.

4 Special Project Office Assessment Plan for Northeast Nuclear Energy Company's Processes for Handling Employee Safety Concerns L Background The Millstone site has had a chronic problem in dealing effectively with employee safety concems. These problems have been documented in several licensee assessments, audits, and intamal t&sk group studies, in a September 1996 report,

" Millstone Independent Review Group Regarding Millstone Station and NRC Handling of Employee Concerns and Allegations,' the NRC staff determined that, in general, an unhealthy work environment, which did not tolerate dissenting views and did not welcome nor promote a questioning attitude, has existed at the Millstone plants for the past several years. This poor environment resulted in repeated instances of discrimination and ineffective handling of employee concems.

1 On October 24,1996, the director, Office of Nuclear Reactor Regulation (NRR), issued an Order to Northeast Nuclear Energy Company (NNECO) requiring specific actions to resolve problems in tne process for handling employee safety concems at the Millstone station. The Order required NNECO to develop, submit for NRC review, and implement '

a comprehensive plan (Plan) for (a) reviewing and dispositioning safety issues raised by its employees, and (b) ensuring that employees who raise safety concems can do so without fear of retaliation. On January 31,1997, NNECO submitted the plan to the NRC and began implementation of elements of the Plan.

The Order further required NNECO to submit, for NRC approval, a proposed independent, third party oversight program (ITPOP) organization, to oversee implementation of NNECO's Plan. On December 23,1996, NNECO submitted the proposed third-party organization, Little Harbor Consultants, Inc. (LHC), to the NRC.

On April 7,1997, the NRC approved LHC as the third-party organization. The Order specified that once approved, the third-party organization develops and submits for NRC approval an oversight plan for conduct of their activities. On May 2,1997, LHC submittod the third party oversight plan to the NRC for approval. On July 15,1997, the NRC reviewed and approved the ITPOP oversight plan. As specified in the Order, independent, third-party oversight will continue to be implemented until NNECO demonstrates, by its performance, that the conditions which led to the requirements of the oversight have been corrected.

1 ATTACHMENT 2

4 The NRC letter forwarding the October 24,1996, Order acknowledged that a period of time would be needed for NNECO to show sufficient improvement in its performance with regard to safety issue resolution and employee treatment as well as the continuing need for the third party oversight. The letter further acknowledged that the NRC would consider NNECO's performance in these areas within 12 to 24 months following implementation of the plan. The Order and forwarding letter did not specify pf ogram performance requirements for restart of the Millstone units. The NRC Restart Assessment Plan for Millstone station identifies NNECO's processes and programs for handling employee safety concerns as an area requiring improvement prior to the restart and operation of any of the Millstone units.

II. Objective This document presents the NRC staffs plan for assessing NNECO's actions to improve the effectiveness of their handling of employee safety concems and to improve the safety-conscious work environment (SCWE) at Millstone station. The document also presents bases for a staff determination of the adequacy of licensee programs to support restart of any of the units at Millstone station.

Ill. Scope The effectiveness of NNECO programs and program implementation associated with fostering and maintaining a SCWE and for handling employee safety concems will be assessed by NRC staff relying substantially on the findings of ITPOP's oversight activities. Staff will direct its limited resources to evaluation of a sample of NNECO programs and activities and on review of ITPOP oversight activities. This approach will provide the staff with independent assessment of the effectiveness of NNECO programs as well as establishing confidence in ITPOP's findings.

As discussed in the Background section, staff has reviewed and commented on NNECO's 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. Staff also reviewed and approved NNECO's selection of an organization to perform independent, third-party oversight of the licensee's implementation of their plan. Further, staff reviewed and approved ITPOP's plan for oversight of NNECO's programs required by the Order. Staff assessment activities are therefor focused to take advantage of the extensive oversight activities by ITPOP.

Separate from ITPOP oversight activities, NRC Special Projects Office (SPO) will conduct periodic reviews of NNECO programs, procedures, and data; will perform intermittent on-site observation and monitoring of program activities; and will conduct a team evaluation of NNECO's Employao Concern Program (ECP), SCWE, Corrective Action and related programs using the guidance of NRC Manual Chapter (MC) 0350, 2

._____-_7_._____._._

and NRC inspection Procedures 40500 and 40001, in addition, staff will evaluate ITPOP's implementation of their NRC approved oversight plan.

SPO will also evaluate the program success criteria, performance measures, and quantitative performance metrics established by the ITPOP and NNECO.

The NNECO activities subject to NRC review will include: i o Ongoing implementation of the NNECO Comprehensive Plan for Reviewing and Dispositioning Safety Concerns.

o Responses to ITPOP contractor program findings and recommendations.

o improvement in the Comprehensive Plan by better defining the actions and roles necessary to improve the SCWE .

o Ongoing resolution and closure of ECP cases.

o Review of previously resolved and closed ECP case files to identify and correct discrepancies.

o Continued development of the ECP infrastructure and organization.

o Ongoing implementation of the employee self-administered Employee Concerns Oversight Panel (ECOP).

o Responses to the Millstone Independent Review Group (MIRG) report findings.

The ITPOP activities subject to NRC review will include ITPOP evaluations of the following:

o NNECO's handling of ECP case files involving harassment, intimidation, and discrimination (Hi&D) and retaliation .

o The effectiveness of implementation and results of the NNECO Comprehensive Plan for selected critical elements, including NNECO's responses to comments and criticisms regarding the Comprehensive Plan.

o ECP and Corrective Action Program (CAP) interfaces and implementation of the CAP in its role as a closure mechanism for ECP safety issues.

o Ongoing evaluation of site working environment and culture by observing NNECO's work and meeting activities.

3

4 IV. Determining Adequate Improvement to Support Restart The adequacy of NNECO's actions to improve their programs for reviewing and dispositioning safety issues raised by employees will be assessed using the findings of ITPOP, licensee self assessments, performance indicators, and NRC evaluation findings. Performance measures and indicators include those developed by the licensee, interview results and documentation by ITPOP, and allegation information developed by 'he NRC (see Appendix for a list of indicators).

Adequate improvement in NNECO's ECP sufficient to support restart will be evaluated based on the following:

o NNECO dete5! nation that sufficient improvements have been made in ECP to support restart of one the Millstone Units.

o ECP is staffed sufficiently to handle incoming concerns and the ECP staff is appropriately qualified and trained for its tasks.

o ECP implementation is effective such that:

(1) Concems are prioritized on the basis of safety significance.

(2) Sufficient controls protect from retaliation those employees who identify safety concerns.

(3) Processes and controls are in place for receiving, evaluating, dispositioning, tracking, and documenting safety issues raised.

(4) Corrective actions appropriately address safety concems.

(5) Feedback to employees regarding the review and resolution of their concems is timely, o ECP database provides information on the receipt, review, and closure of each safety concern sufficient to understand the issue raised, actions taken to resolve the issues, and the rationale for those actions.

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. Adequate improvement in NNECO's SCWE sufficient to support restart will be evaluated based on the following:

o Management demonstrates an attitude that promotes employee involvement and confidence in raising and resolving concerns and communicates policy that safety has the utmost importance, overriding, if necessary, the demand of production and project schedules, o Line organization corrective action programs are functioning such that issues identified by employees are documented and addressed. Employees who raise issues through the line organization are notified of, or have means to easily access, the status of the issues.

o NNECO determination that sufficient improvements have been made in SCWE to support restart of one the Millstone Units.

o Oversight programs and self assessments are effective in the identification and resolution of programmatic weaknesses o Employees, in general, feel comfortable raising safety issues through line management without fear of retaliation, o Employees are informed and knowledgeable of alternative avenues for raising safety concems outside of their line organization.

o NNECO management is able to identify and deal with areas in the organization that do not support fully a SCWE.

V. Determining Completion of ITPOP Efforts As specified in the Order, the plan for independent, third-party oversight will continue to be implemented until NNECO demonstrates, by its performance, that the conditions which led to the requirements of the oversight have been corrected. Factors for determining when ITPOP can be discontinued are essentially the same as those required for restart of a Millstone unit except that sustained performance, without intervention, will need to be demonstrated. Demonstration of sustained performance will be assessod using the continued f~ndings of ITPOP, licensee self assessments, performance indicators, and NRC evaluations. It is anticipated that ITPOP will need to be in place a minimum of six months following the restart of a Millstone Unit to provide a sufficient period to assess sustained performance related to a SCWE and a capability to handle safety concerns raised by employees and contractors. Following this initial assessment period of about six months, their may me a need for periodic evaluations by ITPOP or other third-party organization to assure that programs are maintained and 5

that they are being effectively implemented.

VI Staff Assessment Activities Qblervations and Monitorino Staff will conduct periodic on site observation of NNECO's ECP, SCWE, and ECOP activities and ITPOP efforts. Activities to be monitored include:

NNECO:

o ECP Concern Processing Activities (1) Intakes (2) Investigation Activities (3) Internal Working Meetings o ECOP (1) Working Meetings (2) Assessment Activities o Training Activities (1) General Staff Training (2) ECP Staff Training, Qualification, and Certification o Data Base Management and Data ITPOP:

o Hi&D and Retaliation Case File Review Activities o Comprehensive Plan Effectiveness Review Activities o Corrective Action Plan Evaluation o NNECO's Line Organization Performance Monitoring o ECP Program Development Completion and implementation o Confirmation of Completion and Effectiveness of ITPOP Reviews of NNECO Documentation and Data Review Staff will review ITPOP and NNECO program work products as they are produced.

Documentation to be reviewed wili include:

NNECO:

e "CP-(1) Program and Procedure Reviews (2) Review a sample of ECP Packages 6

._. . _. _ _ = .

e (3) Performance Measure Data (4) Schedules and Schedule Performance Data (5) Handling of ITPOP Recommendations and Related Follow up Actions I o ECP(Cont)

(6) NNECO Oversight & Self Assessment Results (7) Review of NNECO Tracking (8) Interfe") with Condition Report Process o SCWE 1 (1) Action Plans for dealing with management ' hot spots' (2) Management and Supervisor training l oSCOP (1) Program Documents .

(2) Work Outputs (3) ITPOP and NNECO Response to ECOP lssues ITPOP:

o Program and Procedure Reviews o Handling of ITPOP Survey, Interview, and Assessment of Adverse Results o Handling of NNECO Responses to ITPOP Recommendations ,

o Effectiveness Reviews of NNECO Response Actions o Schedules and Schedule Performance Data Evaluation and Insoection in addition to onsite observations and documentation reviews described above, the SPO staff will evaluate NNECO's processes for resolving safety concerns reported by NNECO's or contractor employees. This evaluation will primarily be accomplished through two specific on-site evaluation and inspection activities. One activity will be a team evaluation focusing on NNECO's processes for handling employee safety concerns and issues that are handled outside of the normal line organization. The second activity will involve an inspection of NNECO's processes for identification and resolution of issues raised in the normal course of business.

The team evaluation of NNECO's process for resolving safety concerns will be conducted using the guidance in NRC Inspection Manual, inspection Procedure 40001,

" Resolution of Employee Concerns". The emphasis of this evaluation will be on NNECO's implementation of the ECP and activities to improve the SCWE.

The inspection activity directed at NNECO's processes for identification and resolution of issues will be conducted by participation in the scheduled NRC inspection of the 7

licensee's processes for identification and resolution of issues using the guidance in NRC Inspection Manual, inspection Procedure 40500. This inspection focuses on the licensee's corrective action and oversight programs. An inspector will be assigned to this inspection to assess these problem resolution processes from the perspective of resolution of issues identified by individual employees.

Documentation of Findinos and Conclusions Findings and conclusions of the evaluations and inspections described above will be documented in separate reports prepared specifically for IP 40001 and IP 40500.

The SPO staff will use information from each of these activities, as well as information obtained from other in-office reviews and site activities, to develop assessments and recommendations regarding the condition of the NNECO SCWE and ECP relative to readiness for plant startup. This information will be completed in advance of the Commission meeting on plant restart.

8

4 Aopendix Performance Measures and Indicators Employeo Concern Program (ECP) Data

1. Number and trend of concerns brought to ECP
2. Number and trend of concoms brought to ECP alleging Hal and Retaliation
3. Number and trend of significant issues brought to ECP
4. Number and trend of concems on Maintenance Rule Group 1 and 2 Systems brought to ECP
5. Number and trend of concems brought to ECP compared to number of allegations brought to NRC
6. Number and trend of requests for confidentiality to number of concems received
7. Number and trend of backlog of employee concorrs not resolved
8. Timeliness of employee concern resolution
9. Training completion status for ECP staff Safety-Conscious Work Environment Data
1. Results and trend of licensee Leadership Assessments
2. Results and trend of licensee Culture Surveys
3. Completion status of general employee training on concepts of SCWE
4. Licensee Condition Report (CR) Information and trends (per Millstone unit)

(a) Number of CRs compared to the number of LERs (b) CR evaluation quality (c) CR evaluation acceptance rate

I (d) CR evaluation timeliness completed withing 30 days (e) CR corrective action status I

7. Licensee Oversight organization effectiveness (a) Product quality measurement  !

P (b) Audit schedule adherence [

, t (c) Evaluation of unit self assessment

8. Organizational problem area action plan status Third-Par 1y Organization Data ,
1. Results of structured interviews ,
2. Assessment of program status with respect to ITPOP developed 11 attributes of an ' Ideal' Safety Culture NRC Data

. 1. Number and trend of NRC allegations

2. Number and trend of NRC silegations concerning Hal and discrimination d

i d

)

I h

2

- . __ _. _ . . . . . .,..a . . . - , . . _ . __- ______. . .-

s PROJECT PLANNING SCHEDULE MPdSTONE UNIT 3 11/26/97 i .i I

j Otr 2.1997 Otr 3,1997 Qtr4,1997 ID Took Name Otr 1.1998 Otr 2.12 '

Start FMoh Apr l May l Jun Jul lAug!Sep 1 CMP UNIT 3 fMPLEMENTATION

  • 6/3/96 7/16/97 .

Oct l Nov l Dec Jan l Feb l Mar Apr l Mey 1 i

i

,g i 1

2 BCAVP UNIT 3 IMPLEMENTATION " i 5/27/97 1f23f96

) I i a NRC iCAvP wesPECTsOrtS M t197 2,W96 i 4 ,

NRC ICAVP INOFFICE REVIEWT DOCUMENT 2/9/96 3/20/98 5 INSPECDON PROGRAM g

i 2/1M7 1/30/96 i 6 FEMA NODRCADON i  ;

j 3/2S6 3696 ' -

I 7

i I g '

EMPLOYEE CONCERNS PROGRAM f2/837 1/3096 '

! INSPECTM

. uCENSe AMENDuENTS xs/97 37679e -

s OPERADONAL SAFETY TEAM Mm,r rON t 2/9/98 2/20/96 l to RESTART ASSESSMENT PANEL REVIEW g j 2/1 M 8 2r2M6 l 11 EDO/DIR NRR BRIEF g

i 3598 3696 12 COMMrSSION BRIEFING 3/13/96 I

3/13/99 i g

13 Kr31-RESTART INSPECDON PROGRAM 3f16/90 GS98 i

l Configurction Management Program (CMP) carried out by the licensee.

ICAVP carried out by Sargent & Lundy contractor.

i t

  • ATTI,CHMENT 3

4 j

PROJECT PLANNING SCHEDULE MILLSTONE UNfT2 11/2W97 Qtr 3.1997 Otr 4.1997 Qtr 1.1996 Otr 2.1998 o T kN.m. St.<t rwen u I Aug l Sep Q 1

Oct l Nov j Dec Jan l Feb l Mar Apr l May l Jun M l CMP UNIT 2 SAPLEMENTADON

  • NT96 9/1997 ,

.g 2 ICAVP UNIT 2 IMPLEMENTATION " 7/1/97 4/7/98 3 NRC ICAVP INSPECTIONS 8!2997 i 5/1/98 4 NRC CAVP DMgFu REVEVW DOCUMENT 5/4/98 6/1L W .

s i l mSPECDON PROGRAM 3/T97 3G7/96 s FEMA NOURCADON 5/18/98 922S8 i g

7 EJPLOYEE CONCERNS PROGRAd 12 %97 1/30/98 WSPECTON lg i s UCENSE AMENDMENTS i N21/97 S 22/98 9 OPERATIONAL SAFETY TEAM INSPECTION 5/4/98  !

5/29/96 10 RESTART ASSESSMENT PANEL REVIEW 5/25/96 6/5/96 11 g

EDO/DfR NRR BREF 6/12/98 6/12/96 l g' 12 COMMSSION BRIERNG 6/19/96 6/19/96 I .

g 13 POST-RESTART WSPECDON PROGRAM 6/2196 8CS/96 l  ;

t l

Configuration Management Program (CMP) carried out by the licensee. .

ICAVP carried out by Parsons Power Group, Inc. contractor. (

.

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