ML20236V754

Rev 0 to Little Harbor Consultants,Inc, Evaluation of Millstone Self-Assessment & Independent Oversight Programs

ML20236V754
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Site:	Millstone
Issue date:	07/01/1998
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i ATTACilMENT 6 To L11C Second Quaner 1998 Repon to NRC l

l l EVALUATION OF MILLSTONE SELF-ASSESSMENT AND l INDEPENDENT OVERSIGHT l l

' I PROGRAMS i Revision 0 I

l Little Harbor Consultants L

July 1,1998 j!A*AL*!!!8?!6 PDR!

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TABLE OF CONTENTS 1.0 INTRO DU CTI ON . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . 2 1.1 P urp o s e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... 2 1.2 B ack ground . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.3 Scope ............. ........ ... ............... ... ..... . .. 2 2.0 GENERAL APPROAC H . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.1 Establish Program Expectations . . . . . . . . . . . . . . ........... .......... 3 2.2 Review of Recently-Completed Independent Assessments . . . . . . . . . . . . . . . . 3 2.3 Review of Program Documents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 2.4 Interviews with Key Personnel . . . . . . . . . . . . . . . . . . ...... ......... 3 2.5 Observations of Ongoing Activities and Meetings . . . . . . . ............... 4 2.6 Review of Documentation of Previous Activities . . . . . . . . . . . ...... ... 4 3.0 EVALUATION OF NUCLEAR OVERSIGHT ACTIVITIES . . . . . . . . . ....... 5 3.1 Determination of Scope of LHC Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 3.2 Evaluation Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.3 Summary of Evaluative Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.4 Observations Regarding Nuclear Oversight ............... ........ ... 7 3.4.1 Nuclear Oversight Assessments of Self-Assessment Program . . . . . . . . 7 3.4.2 Nuclear Oversight Assessments of CAP . . . . . . . . . . . . . . . . . . . . . . . . 8 3.4.3 Review of Nuclear Oversight Restart Verification Plan (NORVP) . . . . . 8 3.5 Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...I1 4.0 EVALUATION OF NUCLEAR SAFETY ASSESSMENT BOARD . . . . . . . . . . . . . 12 4.1 Evaluation Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 4.2 Background Information on NSAB . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 4.3 Summary of Evaluative Activities . . . . . . . . . . . . . . . . ............ .. 15 4.4 LHC Observations Regarding NSAB . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 4.5 Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5.0 EVALUATION OF SELF-ASSESSMENT PROGRAM . . . . . . . . . . . . . . .... 19 5.1 LHC Expectations for Pre-Planned Self-Assessments . . . . . . . . . .. ....... 19 5.2 Summary of Evaluative Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . .... . 20 5.3 LHC Observations Regarding PPSA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 5.3.1 Performance Against Program Expectations . .............. ... 22 5.3.2 Implementation Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 5.4 Recommendations Regarding Pre-Planned Self-Assessments . . . . . ....... 27 l 5.5 LHC Expectations for Work Observation Program . . . . . . . . . . . . . . . . . . . . . 27 5.6 Summary of Evaluative Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 5.7 LHC Observations Regarding Work Observations . . . . . . . . . ............ 29 l

5.8 Recommendations Regarding Work Observat i ons . . . . . . . . . . . . . ........ 32 6.0 Summary and Conclusions . . . . ................................... .... 33 i

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs

1.0 INTRODUCTION

1.1 Purpose This report documents the evaluation that Little Harbor Consultants (LHC) has performed of the independent oversight and self-assessment programs that are currently in place at the Millstone Nuclear Power Station. The independent oversight program is implemented by the Nuclear Oversight organization and the Nuclear Safety Assessment Board (NSAB) at Millstone. The self-assessment programs are the various means used by individuals and departments to assess their own performance.

This evaluation is being performed by LHC as a part ofthe implementation of the Independent Third Party Oversight Program (ITPOP) at Millstone.

1.2 Background

The principal function of the LHC team at Millstone is to oversee Northeast Nuclear Energy Company's efforts to implement a safety conscious work environment at the site. The ITPOP Oversight Plan, Rev. 2, lists 12 attributes that LHC expects would be present at a nuclear power plant that has a strong safety conscious work environment. One of these attributes pertains to the independent oversight and self-assessment functions. It is stated as " Independent and self-assessments are performed periodically to monitor performance and correct deficiencies." Given the importance ofhaving strong independent oversight and self-assessment functions, the Oversight Plan states that "The [ITPOP] team also will evaluate the licensee's self-assessment and performance effectiveness capability." The evaluation performed by LHC to satisfy this commitment is described herein.

1.3 Scope This evaluation addressed both the independent oversight and portions of the self-assessment functions. The evaluation of the independent oversight function covered various oversight functions for both the Nuclear Oversight organization and the NSAB. More specifically, the evaluation of Nuclear Oversight's functions focused on their oversight activities that relate to the site's Corrective Action Program and Self-Assessment Program. The evaluation of the self-assessment function covered the formalized department level self-assessment activities in Units 2 and 3 as well as in non-unitized organizations.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs 2.0 GENERAL APPROACH The LHC evaluation of each function covered the three elements identified in the Oversight Plan, which are as follows:

Program design (program manual and procedure content)

. Program implementation

. Program effectiveness.

LHC completed several types ofactivities in the course ofcompleting its evaluation ofthe three areas ofinterest. These are discussed briefly below.

2.1 Establish Program Expectations The LHC team conducting the assessment ofeach program established a set of expectations for that program based on industry best practices. In creating the set of expectations, the LHC team was cognizant ofany special needs placed on the program because of the challenges that exist at Millstone in establishing a safety conscious work environment.

2.2 Review of Recently-C,mpleted Independent Assessments Assessments have been completed in the recent past at Millstone on a variety of topics by credible independent assessment teams. For example, a broadly-scoped assessment of the entire Nuclear Ovusight organization was completed by an experienced team ofoutside personnel in July 1997. The team was led by Mr. Jack Martin, who formerly served as Regional Director of both the Region Ill and Region V offices of the Nuclear Regulatory Commission. The team's report was reviewed to determine to what extent information and insights documented by that team can be used by the Little Harbor effort. Little Harbor's evaluation has drawn on the results of this and other external evaluations.

2.3 Review of Program Documents Selected program manual (s) that define program requirements and selected implementing procedures were identified and reviewed as the initial step in the evaluation.

2.4 Interviews with Key Personnel I

Interviews were conducted with the following types of personnel associated with each of the programs / organizations to be evaluated:

. Managers and supervisors in the organization (s) responsible for the program Page 3

I Evaluation of Millstone Self Assessment Revision 0, July 1,1998 and Independent Oversight Programs

. Other personnelin the organization Management and other personnel in various organizations affected by the program

. Senior management at the site.

2.5 Observations of Ongoing Activities and Meetings LHC team members observed ongoing activities such as audits and assessments being conducted by Nuclear Oversight personnel and self assessment efforts within various organizations. They also observed meetings being conducted as a part of these oversight and self-assessment efforts.

2.6 Review of Documentation of Previous Activities LHC team members reviewed the documentation of previously conducted oversight and self-assessment activities.

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i l Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs 3.0 EVALUATION OF NUCLEAR OVERSIGHT ACTIVITIES 3.1 Determination of Scope of LHC Evaluation As stated in Section 2.2, LHC began its evaluation of the Nuclear Oversight organization by reviewing reports and other information developed as products ofother independent assessments of Nuclear Oversight. The following information was reviewed:

. Independent Assessment Team Report on Nuclear Oversight Assessment, July 1997 ,

= Independent Assessment Team follow-up Letter Report, December 8,1997.

. NSAB Audits and Quality Subcommittee activities.

The Independent Assessment Team reports were reviewed first. This assessment team consisted of seven members with considerable and appropriate experience, independent of Northeast Utilities.

The Team's initial assessment, which was conducted in the summer of 1997, was extensive and addressed the appropriate areas. The Team's report effectively documented the scope of the assessment, the issues identified during the assessment, and recommendations made by the Team to address the issues. The review of the follow-up assessment report revealed that the Team had continued to interact with Nuclear Oversight management to assure that the initial report was clearly understood and that actions have been identified to address the Team's significant issues.

The LHC team concluded from its review of the documents from the Independent Assessment Team that they had performed a very extensive and thorough assessment of Nuclear Oversight. The Independent Assessment Team concluded that the Nuclear Oversight organization was making substantial progress in achieving the level ofperformance necessary to support restart ofthe Millstone .

units. They identified a number ofissues to be addressed and made a number for recommendations I regarding how to address these issues. The follow-up report noted that Nuclear Oversight continued )

to make progress. I l

l The NSAB provides a second source of independently-developed information regarding the q performance of Nuclear Oversight. The NSAB has the responsibility of monitoring the ongoing performance of the Nuclear Oversight organization. The Audits and Quality Subcommittee of the NS AB carries out this monitoring function and reports to the full NSAB on a regular basis. The LHC y team conducting this evaluation attended a meeting of the Subcommittee and discussed the  ;

Subcommittee's current perspective of Nuclear Oversight's performance with the Chairman of the j Subcommittee. l i

Through the interview, it was determined the work of the subcommittee has evolved from looking j at audit schedules and plans on to looking at audit performance and audited organization response.

Their scope has been specified by the NSAB, but they have provided input into what they think it j should be. They are currently seeking additional direction regarding possible expansions of scope.

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1 Evaluation of Millstone Self Assessment Revision 0, July 1,1998 and Independent Oversight Programs At present, their activities are largely focused on providing ongoing oversight of the formal audits conducted by Nuclear Oversight and not on the balance of Nuclear Oversight activities.

Based on the review of the Independent Assessment Team's efforts and the ongoing oversight provided by the NSAB, the LHC team reached the following conclusions:

. The extensive nature of the assessment conducted by the Independent Assessment Team and the ongoing interactions that have occurred between the Independent Assessment Team and Nuclear Oversight management provides confidence that any significant deficiencies in Nuclear Oversight's past performance have been identified and that Nuclear Oversight is making efforts to address these deficiencies and improve performance.

. The NSAB Audits and Quality Subcommittee's continuing reviews of selected Nuclear Oversight activities and documents provides an independent ongoing overview ofNuclear Oversight's activities as directed by the NS AB. They have been performing this effectively for the scopes they have been asked by the NSAB to review.

. These independent review and assessment efforts that have been performed are sufficient to establish the effectiveness ofNuclear Oversight performance. Therefore, there is no need for LHC to perform additional duplicate assessments of the mainstream Nuclear Oversight audit and performance essessment activities.

. Given the specific emphasis that LHC has placed on evaluating the site's Self-Assessment Program and Corrective Action Program (CAP)(because of the key roles ,

these programs play in supporting a safety conscious work environment), LHC should j conduct a more focused evaluation of the oversight effbrts of Nuclear Oversight that are directed toward these two programs.

For these reasons, the LHC evaluation of Nuclear Oversight was limited to an evaluation of Nuclear Oversight's efforts directed toward the two afore-mentioned programs.

3.2 Evaluation Criteria Because of the narrowed focus of the evaluation of Nuclear Oversight to be conducted by LHC, the LHC team established a single expectation for Nuclear Oversight performance:

Nuclear Oversight is effective in identifying and evaluating issues in the areas of the CAP and the Self-Assessment Program.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs 3.3 Summary cf Evaluative Activities The LHC team completed several activities in the course ofperforming its evaluation. These included reviews of various program documents and audit and performance assessment reports. Various ]

management personnel from Nuclear Oversight were interviewed, as well as personnel involved in the Nuclear Oversight Restart Verification Program (NORVP). Finally, team members attended a meeting of NORVP Coordinators and others at which NORVP results were discussed.

3.4 Observations Regarding Nuclear Oversight 3.4.1 Nuclear Oversight Assessments of Self-Assessment Program A Nuclear Oversight Independent Review Team (IRT) was assembled to review the Unit 3 Self-Assessment Program. This review was performed during the fall of 1997, and the report was finalized and issued in December 1997. The LHC team reviewed this effort as it represented Nuclear Oversight's most substantial review ofa group's overall implementation of the site's Self-Assessment Program. ,

The IRT review was a very detailed assessment of the Unit 3 Self-Assessment program. It included fi a very thorough scope and was well documented. The recommendations from the IRT review were documented in CR M3-97-4836. There has been considerable communication between the IRT and the line organization regarding their results and recommendations. The line organization has effectively responded to the majority of the IRT recommendations. The line organization has not implemented all of the IRT recommendations and believes that some are too prescriptive.

The LHC review of this IRT effort and the Unit 3 response, in view of LHC's independent observations, concludes that the majority of the IRT recommendations do have merit but are not necessary for an effective Self-Assessment Program. The line organization's responses to the recommendations are adequate, and improvements have occurred as a result of the IRT effort.

To gain more insight into Nuclear Oversight's efforts to assess the site's Self-Assessment Program, the LHC team selected recent nuclear oversight audits and reviewed the audit reports to determine the extent to which the auditors examined "self-assessment" as a part of their audit scope ofline organizations and the quality of these reviews. The audits selected are discussed in the following subsections:

1. MP-98-A01, Conduct of Operations- Millstone Units 2 & 3 This audit included a review of Self-Assessment and Work Observation Programs in the organizations being audited. Both the work observations and the self-assessments were found to be acceptable.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs

2. MP-97-Al1-93, Software QA The auditors who conducted this audit looked for and found a self-assessment that identified many of the same problems that this audit identified. The problems fou..d in the self-assessment were documented in CR M3-97-1945. The audit report notes that the self-assessment and CR identified many of the same problems, but the audit report makes no comn'ent on whether the actions and follow-up to the self-assessment CR were adequate. It is not clear that they are adequate. It appears that the self-assessment did not clearly identify the broad programmatic nature of the software-QA problem. The audit report is therefore somewhat deficient in not providing comments on the lack of effectiveness ofimplementation of corrective actions for the self-assessment findings back to the line organization.

3. MP-97-Al2-02, Emergency Preparedness and 10 CFR 50.54(t) Review This audit noted the review of nine self-assessments and the EP Self-Assessment procedure. The audit noted a serious disconnect between the EP Self-Assessment program and the proper initiation of CRs. The EP self-assessments were capable of identifying inues, but these issues were not documented on CRs. The audit report does properly identify the weakness of not treating self-assessment findings as CRs.

3.4.2 Nuclear Oversight Assessments of CAP The LHC team has conducted an extensive review of the site's CAP in two phases. The first phase was conducted in the late summer of 1997. LHC reported on the results of this first phase on September 24,1997. The second phase was conducted concurrently with the evaluation described in this report. In the course of this two-phase evaluation of the CAP, LHC team members interacted extensively with Nuclear Oversight staff members who had or were conducting audits and assessments of the CAP. From these interactions, it .was apparent that the Nuclear Oversight organization has been devoting substantial resources to reviewing the implementation of the CAP across the site. The LHC team has reviewed the results of these audits and assessments and found them to be of appropriate breadth and depth. The LHC team thus concludes that Nuclear Oversight i is providing a satisfactory level ofindependent oversight for the CAP.

3.4.3 Review of Nuclear Oversight Restart Verification Plan (NORVP)

The NORVP represents an effort by Nuclear Oversight to integrate the results of the various audit

and assessment activities they conduct to provide a summary perspective of the progress of the site's restart efforts. This LHC review was performed to determine the effectiveness of the NORVP in evaluating Line performance in those areas that are within the scope of Nuclear Oversight's responsibilities and that relate to attributes of a safety conscious work environment, The review was conducted in the following steps

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and independent Oversight Programs Review NORVP Procedure Nuclear Oversight Department Quality Procedure NOQP-1.08, Revision 0, Nuclear Oversight Restart Verification Plan (NORVP), describes the NORVP process. This procedure was reviewed and found

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to adequately define the process and to provide sufficient guidance for effective implementation. j Interview Kev NORVP Manacement Personnel An interview was conducted with the individual, who was responsible for the development of the procedure. This interview provided a better understanding of how the process was actually being j implemented. The descriptions were consistent with the procedure.

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l Identify the Relevant Areas of NORVP 1

The issue areas for NORVP have currently been selected consistent with " issue areas" identified in other Millstone recovery plans. This is of value in promoting consistent communication. -

The issue areas that were selected by LHC to be relevant to the safety conscious work environment include. .

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. Self-Assessment

. Corrective Action

. NSAB/ Oversight Recovery

. Safety Conscious Work Environment The last area, safety conscious work environment, is relevant by its title. In actuality, Nuclear Oversight is responsible for performing only a limited number ofactivities that relate indirectly to this area, and those activities are directly related to the first three areas noted above. It is not clear that I there is any value added by having the safety conscious work environment issue area in the NORVP.

l Interview NORVP Leads for the Relevant Areas 1 Interviews were conducted with the following Issue Leads:

. Self-Assessment ,

. Corrective Action

. NSAB/ Oversight Recovery

. Safety Conscious Work Environment The Issue Leads provided lists ofthe attributes developed as part of their assessment plans and copies of their latest evaluation reports. They discussed how they perform their responsibilities and their Page 9 l

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and independent Oversight Programs {

views on the effectiveness of the NORVP process and the effectiveness ofLine performance for their issue area.

The views of the effectiveness of the NORVP were consistent. The strengths were that the NORVP provides a good basis for collecting the results ofNuclear Oversight activities and reporting them on an integrated basis for the issue areas. The program has helped to improve communication between Nuclear Oversight and the line organizations. Individual " evaluations" are generally well done.

Some weaknesses are that scores can be based on limited data covering limited attributes and the cumulative attribute scores do not necessarily reflect current performance. It is possible to arrive at a situation where the overall current score for an issue area is " green" (acceptable) but the majority of the underlying attribute scores are " yellow" (needs improvement).

Review NORVP Attributes and Renorts for the Relevant Areas The attributes for each of the selected areas were reviewed and found to be appropriate for the area under examination. These attributes were selected from INPO good practice documents and relevant NRC inspection criteria.

Fo: mal NORVP reports for these areas were reviewed during the month of March 1998. Selected underlying attribute reports were also reviewed. The reported information for the issue areas was found to be appropriate and accurate based on the observations performed. It appears that the collective scores were appropriately determined in accordance with the program plan. The scoring, however, is quite subjective and could be challenged. Some of the vulnerabilities are as follows:

. There can be too few evaluations in a given reponing period or too few individuals making the evaluations. This can lead to too narrow a view or a lack of objectivity and scores based on limited information.

. The underlying attributes are not weighted or prioritized as to importance. They may also get unequal treatment over time. This can result in a lack of coverage of important attributes and potentially distorted collective scoring for the issue area.

. The manner in which underlying attribute collective scores are calculated does not give an accurate indication of current performance and lead to what appear to be conflicting scoring between attributes and the collective score for an area.

Attend NORVP Review Meetine l -

An NORVP review meeting was attended on January 22,1998 for the issue areas ofinterest. This r meeting is where the issue leads present their collected data for the prior two week period, their summary observations, and their recommendation for the area score. The discussion and conduct of the meeting observed for the areas ofinterest was considered appropriate.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs Summary Conclusions The NORVP process is an effective means ofcollecting Nuclear Oversight observations and results and reporting them to the Line organizations in an integrated manner.

The overall collective area scores appear to be consistent with LHC's evaluations of the interest areas. However, the mechanics for developing attribute and area scores are not quantitatively defensible and could be easily challenged. Coverage of all NORVP areas and attributes is declining and may not be possible with existing Nuclear Oversight resources.

The NORVP sh'ould not attempt to cover issue areas that are outside of their organizational charter and scope of responsibility. The safety conscious work environment area is an example.

3.5 Recommendations The LHC team has developed the following recommendations for consideration by NNECo regarding the Nuclear Oversight performance of oversight of the CAP and Self-Assessment Program:

1. Given the flexibility that is permitted within the NORVP procedure for producing quantitative scores, care should be taken in preparing quantitative results to assure that results from individual observations are weighted so as to reflect both how recently the observation was made and the breadth of scope covered by the observation.

2. Because of the scarcity of relevant observations in the safety conscious work environment area, consideration should be given to dropping this area from NORVP. i i

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs 4.0 EVALUATION OF NUCLEAR SAFETY ASSESSMENT BOARD 4.1 Evaluation Criteria The LHC assessment of the NS AB developed the following expectations for safety review boards for the purpose ofestablishing expectations for evaluating the Millstone Board structure and operation.

These expectations are based on a compilation ofindustry standards and practices developed through direct experience with the off-site review function by LHC members.

Constituents Authority andCharter The NSAB has clearly-assigned authorities and responsibilities and operates under a charter that has been approved by senior management.

Balancedmembership The membership of the NSAB has the appropriate balance of internal and external members, with the internal members coming from appropriately high positions within the organization and with the collective membership having experience and qualifications that are complementary and reflective ofcurrent industry standards.

Station involvement There is a high level of participation in NSAB meetings and other NSAB activities by the station staff. The station staff who are members are proactive in taking on NSAB issues and providing the follow-through needed to assure complete resolution.

AdministrativeSupport Appropriatematerialsareregularlycompiledanddistributed to the members for review in a timely manner. A clear point of contact is designated for special requests.

Material & Information Gathering Scone ofMaterial Reviewed The scope of material provided to Board members for review is tailored for the Board structure. As a minimum, the review material conforms to the requirements of the Technical Specifications or other governing document (s). Ifcommittees are used, materials are segregated in a manner to assure all Board members receive the appropriate materials. The scope of materials is subjected to periodic reviews to assure the right information is considered by Board i members.

Development of Acenda Agendas are compiled after receiving input from all constituents. The agendas strike a balance between the breadth and depth ofissues .

based upon the station situation. Items clearly have a focus on safety. ]

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs Timeliness ofAfaterial and issues Developed Issues to be addressed by the NSAB are assigned a priority based on their significance. The NSAB demonstrates it has the capability to address individual items and, when appropriate, roll them into higher level generic issues.

Review and Analysis Processes Afectines Scheduled Consistent with Plant h eds Meetings are scheduled in accordance with plant needs, i.e., the frequency of meetings matches the operational situation of the station.

Activities Between Afectines The plant staff and the external members maintain contact with each other between meetings. Board members are involved with other oversight functions, such as audits.

Format and Conduct of Afectines Meetings are conducted in an efficient and disciplined manner. They are spirited and energetic with an open, professional atmosphere. All participants appear comfortable to challenge the status quo.

Discussions focus on the safety significance of the issues, and involve all members of the board. Board members leverage off ofeach other, and their diverse perspectives are evident. Generic implications are frequently raised, and the quality of plant performance is regularly assessed. Presentations to the Board are crisp and concise; presenters are well prepared and are able to effectively field most questions.

Devth Versus Breadth NSAB members address the issue of depth vs. breadth appropriately. The Board covers a broad range of station issues, yet addresses them in sufficient depth to provide meaningful insights. The Chair keeps the discussion on I track, and the station staffis well-prepared and able to answer most questions of detail in the meeting.

Value of Results AfethodN o/Developine Results The methods and techniques used to develop Board results are consistent and effective. Results, including recommendations, are based on key factors of the issues and should be clear and well-structured.

Feedback to Senior Plant Afanacement Results of the Board are effectively fed back to senior station management - face-to-face debriefs and written follow-up reports are preferable. The responses of the senior manager (s) to NSAB results are timely l and thorough.

Relationship to Other Action item Priorities Items developed by the Board receive priority based on a consistent ranking system. NSAB recommendations are well-distributed within the prioritization scheme and are addressed appropriately.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs Afethode for Canturine andImnlementine Board issues are captured in the site's Corrective Action Program and tracked to resolution. l Impact on the Facility Knowledee ofNSA P hv the Station Work Force Members of the work force generally understand the mission of the NSAB. In addition, there is an appreciation for the system of checks and balances used in station technical programs.

Improvements Correlated with NSAB Activities There is an effort to determine the value provided by the Board. Board members are able to provide examples ofitems that have improved overall performance of the plant. Management expectations address the fact that efforts of the Board are to add value and help improve performance, j l

Results ofNSA B Self-assessments The Board sets the standard for self-assessments. l It evaluates its effectiveness on a periodic basis, and undertakes activities to improve its performance based on these assessments. The results ofthe Board are shared with other oversight groups.

4.2 Background Information on NSAB Prior to February 1995, there were three nuclear review boards to provide oversight to the three units. In February '95 the structure was changed to have one board which covered four units - the three at Millstone and Haddam Neck. The Board structure was changed, but the modus operandi remained essentially the same - at least until December 1995. During this time frame, two external members served on the Board.

In the fall of 1996, the Board structure was reviewed, and additional external members were added l in early 1997. The new external members were selected to provide a broader range ofexperience and increase the outside industry perspective.

l The Board currently has five (5) subcommittees that augment the depth of review and cover the requirements ofvalidating unreviewed safety question determinations. The current subcommittees are:

1. Operations & Maintenance

2. Engineering Support l

l 3. Plant Support

4. Assessment and Quality

5. Safety Evaluations Page 14 I

L-_ -__-_ _ _ _--__--- ___

Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 l and Independent Oversight Prograrns Each subcommittee is chaired by an internal individual who is not a full member of the Board; however, some of the subcommittee chairs are alternates for NSAB members, including the external members. While many other boards do not have alternates for the external members, NNECo finds l l it advantageous to do this to assure a quorum in the event special meetings need to be called.

l The subcommittees do not routinely have a full Board member on their rosters; however, a liaison member from the Board is assigned to each subcommittee. This individual has the responsibility for assuring linkage exists between the Board and the subcommittee and is expected to fulfill the role of I coach and mentor.

The relationship of the NSAB to the rest of the oversight functional area is considered standard for j the industry. The reporting relationships, composition and activities parallel most other offsite review l processes.

l 4.3 Summary of Evaluative Activities l The primary evaluative activities conducted by the LHC team in its evaluation of the Board were observations of portions of three NSAB meetings, review of pertinent documents related to the conduct of the NSAB and interviews with several members of the Board.

The current conditions at the site have led to NSAB meetings being held on a monthly basis. Portions i of the January, February and March 1998 meetings were observed by LHC members. Agendas for l

the past six months were reviewed, as were minutes of those meetings. The governing procedures for the operation of the NSAB.were also reviewed. Interviews with Board members were very insightful, as was an interview with the NNECo President / CEO. The results of these reviews and observations are covered in more detail in the following section.

4.4 LHC Observations Regarding NSAB Constituency The constituency of the NSAB is consistent with other offsite review functions currently found within the industry. The internal members come from appropriate positions within the organization, and the mix of external members is similar to other review boards.

While the station has assigned appropriate personnel to the NS AB, the level of participation on the part ofsome intemal members appears to be an on-going problem. This is somewhat understandable,

! given the current situation at Millstone and the time demands placed on key managers. It is difficult for these individuals to devote a day-and-a-half every month for the purpose of NSAB meetings.

Based on observations and interviews,line managers on the Board are sometimes proactive in taking on NSAB issues voluntarily. However, the normal method for implementing Board tasks is through the assignment of action items. NSAB members do not generally participate in other oversight I activities such as audits, but with the current frequency of meetings, this is not seen as a deficiency.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Ir. dependent Oversight Programs After the units restart, the NSAB should review the "in-between" meeting activities to determine if participation in other related oversight activities would be beneficial.

The administrative support for the NSAB appears to be adequate. Several experienced individuals are assigned to provide full-time support to the Board. The distribution of materials is considered to be timely and appropriate, although issues have been arising so quickly in the current site environment that it has been a challenge to keep Board members up-to-date with the important issues

- especially the external members. Although the sample ofmeeting minutes reviewed did not contain all of the attributes associated with excellent records, the minutes were considered adequate and appear to be distributed in a timely manner.

Material & Information Gathering The material that the Board is to review is listed in Attachment 4 of the Nuclear Safety Assessment Board Procedure, NGP 2.02. 'I he list of materials appears comprehensive and conforms to industry standards. Those items required by Technical Specifications are specifically marked, as are those areas which require review by sampling. A list of audits and related activities performed under the cognizance of the NSAB is included as Attachment 5 of the same procedure.

Agendas appear to be standardized to a significant degree, and one of the criticisms raised by a member in an interview was that they were not sufficiently customized to take into account the time-dependent, specific circumstances of the station,i.e., recent agendas have been viewed as too broad with insufficient depth. Input to the next meeting agenda is solicited at the end of each meeting; this is the only solicitation ofinput, but members feel as though they have the opportunity to provide agenda items at any time.

Review and Analysis Processes The approximate monthly frequency ofNSAB meetings appears to be meeting the needs of the site.

Once the units restart,it is expected that the frequency of meetings could be somewhat reduced to conform more with industry standards, i.e., on the order of 4 to 6 times per year.

From the sample of meetings attended, the Board meetings are being conducted in an acceptable manner. The day-and-a-half format allows the outside members time to get into the plant and meet with individuals in the organization prior to the start of the first half-day meeting. Presentations on I I

the status of restart have been a major component of recent agendas, and the Board does focus on pertinent issues that arise from the presentations. The Board members did not display as high an energy level during the course of the meetings as might be expected; however, the LHC sample from parts of meetings attended was admittedly limited. Additionally, members indicated during interviews that discussions frequently are spirited and challenging. During LHC observations,it was clear that only a few members probed and challenged to the level expected. A few members were not very active during any of the three meetings LHC attended: however, they appeared to be attentive i

to the presentations and discussions. There was a distinct effort on the part of the Board to fncus on problem areas, and notjust highlight areas of progress or success.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and independent Oversight l>rograms Presentations to the Board were of mixed quality, with most being above average. For the most part the presenters were knowledgeable and fielded Board members' questions without difficulty. Visual aides were consistently well done and handouts provided were considered very good overall.

Although the agenda items appear appropriate for the current state of the Millstone units, some NSAB members oclieve that there has been a recent imbalance between the breadth and depth of issues, i.e., the scope ofmaterial is too broad, and the Board is only able to address issues in a cursory or superficial manner. These comments could indicate an inefficient use of the subcommittees as well as the rapid pace of events associated with the approach to restart. In either event, the comments highlight the need for the Board to assess constantly the breadth vs. depth issue.

Value of Results The limited observations of the meetings by LHC did not permit LHC to de: ermine the consistency or effectiveness of the methods used to develop NSAB results and recommendt tions. There was little i evidence of group discussions that led to the uncovering of key insights or 'he extrapolation of individual items into meaningful top-level (generic) issues. Also, there were a few examples where NSAB requests were misinterpreted. On the positive side, the Board did highlight apparent discrepancies in presentations, probed areas of concern and conducted formal votes on certain areas related to the restart of Unit 3.

The NS AB Chairman debriefs the President / CEO after each meeting, and the outside members meet with him on a periodic basis. The President / CEO considers the input from the NSAB very valuable and regularly probes the Board for the key messages that need to be considered by senior management. The President / CEO relies on the NSAB as the primary mechanism to determine the effectiveness of the Nuclear Oversight organization. Since the re-organization ofthe NSAB in 1997, representatives from the advisory group to the Board of Directors (NCAT) have monitored NSAB progress. NCAT observations are documented in summary reports provided to the Chair and the President / CEO.

Impact on the Facility LHC was unable to identify situations where NSAB activities have had a significant impact on the station. While there is a clear sense that the Board is operating in a manner consistent with other such review boards in the industry, there is not much evidence of items that have led to improved

! performance that can be tied directly to the NSAB. In addition, the NS AB has not performed a self-assessment to evaluate its effectiveness.

4.5 Recommendations The LHC team has developed the following recommendations for consideration by NNECo regarding the Millstone Nuclear Safety Assessment Board:

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1. Consideration should be given to reducing the number ofsenior managers who serve on the NSAB to reduce the cumulative burden of NSAB duties on the senior management team.

2. Consideration should be given to various means ofintroducing more flexibility into meeting agendas to permit adequate focus during NSAB meetings on critical and emergent issues.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs 5.0 EVALUATION OF SELF-ASSESSMENT PROGRAM 5.1 LHC Expectations for Pre-Planned Self-Assessments The LHC team began its evaluation by establishing a set of expectations for a site-wide self-assessment program, based on INPO criteria and industry best practice. The following key elements were identified as characteristics of an effective self-assessment program:

Management Support and Involvement Management at appropriately senior levels provides support for the program and is involved in its implementation. Management has assigned adequate resources to the program.

Procram Plannine Hasis '

Plans to guide the pre-planned self-assessment (PPSA) program have been prepared and approved that cover activities for future periods of sufficient length. These plans are controlled, and progress against them is monitored. These plans are written to an adequate level of detail and provide appropriate breadth of coverage.

Denth of Program Ownership ,

f Personnel at all levels in the organization are familiar and demonstrate ownership of the PPS A process.

Evidence of Program Results Use of the PPSA process has resu~ited in (driven) changes in processes, procedures and/or performance.

Trainine Program There is an effective training program in place to support the PPSA program. l Availability of Prceram Guidanec l Sufficient guidance in the form of procedures and/or instructions is provided to support the

! program, including guidance for the following aspects of program implementation:

1. Preparing outline

2. Selectir.g topics Page 19 I

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs

3. Selecting / identifying criteria and performance objectives Evaluation of Pronram Performance There is an effective method in place for evaluating the quality of PPSAs (including providing appropriate feedback).

Sharine of Lessons Learned There is evidence oflessons leamed being shared effectively within the organization being assessed. There is also evidence of sharing of lessons leamed outside the assessed organization.  !

Participation of Outside Personnel Opportunities are taken to include outside personnel (from other units, from outside  !

Millstone, etc.) in the conduct of PPSAs.

Follow-un Processes An effective process is in place to follow up PPSAs. j

1. CRs are initiated for adverse conditions and/or improvement items.

2. Ownership is provided for CR closure for PPSA items.

3. Follow-up assessments are performed as scheduled.

4. The follow-up assessments evaluate the results (changes in process or  ;

behavior) of corrective action rather than implementation.  ;

i Performance of Self-Assessments Self assessments are being performed effectively. The results of self-assessments are being l characterized properly.

l 5.2 Summary of Evaluative Activities l

The evaluation of the program included reviews of program documents, review of existing critical I analyses of the self-assessment process, interviews with key personnel, observations of training activities and meetings, and review of a random sample of completed self-assessments. Specific review activities were conducted as follows:

1. Reviewed the site-wide procedure OA-11 and previous unit versions of OA-11 that were operative during the 1997 self assessment period; I

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs

2. Reviewed existing critical evaluations of the self assessment process:

. IRT Report 002-IRT-98 of January 6,1998 covering the Unit 3 Self Assessment Program.

. Unit 3 "Self-Assessment of Self Assessment Program Effectiveness" 3 CAD-SA-97-04 performed 5/12-16/97 and follow-up reviews of August 1997 and November 1997.

3. Conducted interviews with the self assessment coordinators for Units 2 and 3, for the design engineering group, Nuclear Work Services and Nuclear Oversight.

4. Observed meetings of the Unit 3 Self Assessment Advisory Board (SAAB) and reviewed selected minutes of SAAB meetings. '

5. Observed a formal training class conducted by Nuclear Training Department (NTD) covering performance of self-assessments and follow up reviews.

6. Reviewed a sample ofself-assessment reports completed during 1997 by Units 2 and 3, design engineering, Nuclear Work Services and Nuclear oversight (approximately 80 self-assessment repcrts).

Self-assessments selected randomly from the self-assessments completed during 1997 were evaluated using the following checklist:

1. Does the report contain an effective outline?

a. Are specific performance objectives and assessment criteria specified?

b. Are expected tasks / scope and methods detailed?

2. Does the report provide evidence of application of the outline? Are there notable deviations from the outline?

l 3. Is there participation in the PPSA from outside the assessed organization?

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4. Does the report assess observations against criteria?

5. Does the report identify strengths, weaknesses or both?

6. Does the evaluation appear consistent with and supported by the evidence presented?

7. Are findings / recommendations clearly and unambiguously stated?

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs

8. Does the report consider findings in light of broader issues (applicability to other organizations, root causes, etc.) ? If not, should it?

9. Does the report consider the significance of findings?

10. Does the report indicate that CRs are initiated for conditions adverse to quality /

improvement items / both?

11. Is follow up review scheduled or attemate method identified? Is appropriate -

justification provided?

12. Is the assessment a follow up? If so:

a. Did follow up take place as planned?

b. Does follow-up evaluate the completion (implementation status) ofcorrective actions? Does it include statusing of CRs (and/or ARs) from underlying assessment?

c. Does follow-up evaluate the results of corrective actions (changes in process or behavior) ?

5.3 LHC Observations Regarding PPSA The Pre-Planned Self-assessment program at Millstone is generally sound. It gives promise of continuing to grow and improve as it matures further. LHC observations are presented below in the context of the program expectations and implementation adequacy.

5.3.1 Performance Against Pror, ram Expectations Management Sunnort and Involvement

1. Substantial evidence exists that demonstrates higher management support for and involvement in the Self-assessment Program. This evidence includes the specific mention of the program in the Millstone success objectives, the Nuclear Group Policy l on the Self-assessment Program, and reference to tile program in the Nuclear Safety Standards and Expectations. Evidence of senior management direction and participation include a memo from the Vice-President of Nuclear Work Services, a i

directive to his organization from a Recovery Officer, the Vice-President of Nuclear l Engineering and Support presenting a training kickoffspeech, and participation of the Unit 3 Director in the Unit 3 SAAB. A number of the self-assessment coordinators made specific mention of the support they had received in various ways from senior management.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs

2. Department management involvement is evident in the preparation, review and approval of self-assessment plans for 1997 and 1998 and participation on the Unit 3 Self-assessment Advisory Board (SAAB).

3. There is sor.e evidence that there is a scarcity of resources available to implement planned sent-assessments. A nmnber ofinterviewees mentioned during the February 1998 LHC structured interviews that they had concerns about adequacy ofresources to implement their parts of the 1998 self-assessment plan.

Proeram Plannine Basis

1. Program procedures require that each group and department prepare an annual plan for the PPSAs that the organization proposes to perform that year. These annual plans were prepared and approved by the end ofJanuary 1998 for the year 1998. The plans are controlled and a process exists to modify them as needs dictate during the remainder of the year.

2. The LHC review of the various annual plans prepared for 1998 revealed that efforts had been made in the various groups and departments to select appropriate topics for self-assessments in 1998.

Depth of Proeram Ownership

1. The results of the February 1998 LHC structured interviews indicate that 94% of those interviewed were aware of the topic ofself-assessments having been discussed in their work group and 92% of those interviewed reported seeing useful results from self-assessments that had been conducted.

2. The " nit 3 SAAB established a requirement for all Unit 3 departments to establish and wamunicate self-assessment performance expectations for all First Line Supervisors and workers. This action has been reported as complete.

Evidence of Pronram Results

1. Many of the self-assessments completed since July 1997 have resulted in Condition Reports and other action documents. By definition, these documents results in various actions being taken to correct problems and enhance performance.

2. The February 1998 structured interviews indicated that 92% of the interviewees have seen improvements as a result of the self-assessment process.

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Evaluation of Millstone Self Assessment Revision 0, July 1,1998 and Independent Oversight Programs Trainine Proeram

1. Initially, employees attending the training course on how to perform self-assessments frequently had the attitude of "what am I doing here". In contrast, the course is now frequently oversubscribed. This provides evidence that worker enthusiasm for and interest in the program are increasing.

2. The degree of integration between the Nuclear Training Department and Self-assessment Program management has improved. At present, for example, Unit 3 SAAB minutes are being provided to training, and training it'structors are participating in the Unit 3 SAAB.

3. The content of the training course provided by Nuclear Training is good. It addresses current issues and places emphasis on the importance and nature of follow up reviews for effectiveness and the use of pre-planned checklists.

Availability of Procram Guidance

1. As oflate 1997, each group on the Millstone site had a group-wide administrative procedure that governed the conduct of self-assessment activities. In early 1998, a single site-wide procedure, OA 11, "Self-Assessment", was adopted for use across the site. This procedure provides adequate guidance for conducting effective self-assessment activities.. The revised procedure incorporates improvements recommended in self-assessment and IRT reviews of the earlier self-assessment processes.

2. The new procedure provides effective guidance for preparation of an outline for a PPSA and for the selection of topics for PPSAs.

3. The procedure does not provide effective guidance for selecting and identifying applicable performance criteria for use in the PPSA.

Evaluation of Proeram Performance

1. The site procedure for PPS A provides a checklist for eveluation ofthe self-assessment report, and requires review of the checklists prepared during the self-assessment by the lead assessor as a tool to assist in preparation of the report.

l 2. Unit expectations include having an independent evaluation of a sample of self-assessment reports using the checklist from the procedure.

3. Unit 3 management provided feedback on approximately 30% of the PPSAs completed during 1997. Currently, feedback includes reviews for self-assessments by the Self-assessment Advisory Board, post-report review by the SA Coordinator, Page 24

Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs

" coaching" review of draft reports by the SA Coordinator, and forwarding of scored checklists completed by Nuclear Oversight. This represents a more effective process 4 that existed in 1997.

4. A comparison ofaverage scores by Nuclear Oversight on PPS A completed before and I

after November 1,1997 shows significant improvement in recent evaluation scores.

Sharine of L>essons Learned

1. There are expectations in the site self-assessment procedure that department results and lessons learned be shared with department personnel and reports be distributed to other Station groups and units.

2. Discussion by Unit 3 managers at SAAB meeting indicate each Department has a program for intemal feedback that is being followed.

3. Transmittal memos are used by the Unit 3 S/A Coordinator to distribute self-assessment reports across the site.

4. Within Nuclear Oversight, the sharing of results appears somewhat limited but the

. trend is improving.

5. The structured interviews showed that more than 92% of those interviewed feel that self-assessment is being discussed in the work groups and that they have seen useful results.

Participation of Outside Personnel

1. Review of a sample of self-assessments done in 1997 indicates a small percentage have relied on outside or " peer" reviewers.

I

2. The 1998 Unit 3 plan indicates approximately 25% ofPPSAs are targeted for outside reviewers. In addition, Health Physics reviews for each unit are being coordinated as site-wide reviews.

Follow-un Processes

1. Are CRs initiated for adverse conditions and/or improvement items?

. A sample of self-assessments indicates that CRs were developed for deficiencies and/or improvement items for Unit 3 assessments in 26 of 30 reports, and for Nuclear Work Services assessments in 6 of 12 reports.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs Within Nuclear Oversight, many self-assessments have generated no CRs; when there are CRs, the tendency was to classify issues as items for improvement rather than as deficiencies.

2. Is there evidence of" ownership" of CR closure for PPba items?

A review of Unit 3 self-assessment generated CRs done by the Unit 3 S/A coordinator showed that essentially all action items generated by self-assessments in 1997 scheduled for completion in 1997 were closed on schedule. Approximately half the actions were scheduled for completion in 1998 or later.

An IRT review of Unit 3 S/A conducted in the fall of 1997 indicated a number of actions improperly closed without evidence, or by transfer to other actions (This may be a deficiency of the CR system in general, rather than a S/A issue).

3. Is follow-up rigorously performed as scheduled?

Follow-up reviews on Unit 3 were generally completed as scheduled, with 7 of 11 that were scheduled to be complete by the end of 1997 completed by year end.

1

4. Does follow-up evaluate the results (changes in process or behavior) of corrective action rather than implementation?

e The samples of Unit 3 follow-up reviews indicates that they are not effective in evaluating the results of corrective actions.

Follow-up reviews appear to have been schedule driven for early performance rt ther than based on sufficient time for corrective action to have taken place.

5.3.2 Impicmentation Issues Performance of Self-Assessments

1. Performance: Based on a review of self-assessment reports, most self-assessments j appear to have been thorough evaluations. Several appeared to be extensive reviews j of areas that appear to be oflimited value to the mainstream performance ofcritical l processes. More recent self-assessments appear to involve areas more essential to the organization's success.

2. Characterization of Results  ;

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Evaluation of Millstone Self-Assessrnent Revision 0, July 1,1998 and Independent Oversight Programs Items characterized as strengths would frequently be more appropriately characterized as management expectations.

There is a tendency to downplay weaknesses (adverse conditions) as areas for improvement. This could lead to less than appropriate action being taken to improve performance. In general, however, CRs are being written for both characterizations.

Adeauncy of Plannine

1. Outlines for recent self-assessments are clear and complete in detailing expected tasks and methods.

2. Outlines are frequently weak in detailing assessment criteria, thereby providing little or no basis for objective evaluation of observations.

Effectiveness of Nuclear Oversieht

1. The Nuclear Oversight NORVP evaluation of the self-assessment process provides a meaningful assessment.

2. The IRT assessment performed in August thru October 1997 was an effective review.

3. Key Performance Indicators (KPIs contained in the Restart Readiness Report) are less than adequate in their ability to measure the success ofthe Self-Assessment Program.

5.4 Recommendations Regarding Pre-Planned Self-Assessments The LHC team has developed the following recommendations for consideration by NNECo relative to Pre-Planned Self-Assessments:

1. Consideration should be given to strengthening the guidance that is provided in program procedures for how to develop acceptance criteria for use in self-assessments.

2. The conduct of follow-up reviews should be strengthened to improve their focus on establishing the degree ofeffectiveness ofcorrective actions implemented as a result of self-assessments.

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3. Consideration should be given to developing KPIs that collectively provide a better tool for measuring the effectiveness of the Self-Assessment Program.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 l and Independent Oversight Programs 5.5 LHC Expectations for Work Observation Program Expectations for the work observation program were dermed based on a review ofINPO criteria and "Best Practice" experience of the reviewers. The following expectations were e.pplied to determine the effectiveness cf the program and its implementation on Unit 3:

Procram Definition The program is well defmed.

Assienment of Responsibilities Responsibilities are properly identified and assigned.

Communication of Management Expectations Management's expectations are well-dermed and effectively communicated. Evidence of management support is evident.

Availability of Trainine and Guidance Appropriate training and guidance is available to support execution of the program consistent with expectations placed on it.

Meets Industry Standards The program meets industry standards cf good practice (INPO/ Benchmarked utilities).

Freauent Management Participation Managers frequently monitor and iruluence personnel perfom1ance improvement by observing work activities and training.

Use of Performance Evaluations j Performance evaluations are used to determine the effectiveness of processes and work activities and to identify improvement actions.

Self-Evaluations are Integrated Self-evaluations are integral to daily activities, such as identifying lessons leamed during post-job critiques, and are used to evaluate work areas or processes in depth for improvements.

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l Evaluation of Millstone Self-Assessment Revision 0, July 1,1998

and Independent Oversight Programs Trackine of Action Items Action items from self evaluations are tracked to completion and are periodically reviewed for timeliness and effectiveness.

Manaeement Initiates Self-Evaluations Managers initiate self-evaluations to identify adverse cultural symptoms, such as complacency.

Ouality of Reports Self-evaluation reports are clear and concise and provide relevant information on strengths and areas ofimprovement to other managers.

Effectiveness ofImplementation The program is effectively implemented. Evidence exists to show that the program results in improvement. The program is effectively linked to the corrective action process. The program, as implemented, gives evidence that the criteria listed abc'.e are being pu.

Available Performance Indicators Effective performance indicators have been defined for the program to allow management to assess the effectiveness ofimplementation.

5.6 Summary of Evaluative Activities t review was conducted to determine whether Unit 3 had a reasonable work observation A limi ed progr.un in place, as one element of the self-assessment process. Discussion was held with the Unit Self assessment Coordinator, and a review was made of Millstone procedure OA 5, " Work Ob',ervation Program", Rev.2 and Unit 3 Procedure U3 OA 5, " Management Observation Program",

Rc v.0 and 1. A sample of reports generated from the work observation program during the first querter of 1998 was reviewed. In addition, a self-assessment of the work observation program (3 CAD-SA-97-10,11/12-21/97) was reviewed. Minutes of the Unit 3 Self-assessment Advisory l Board were reviewed to determine whether there was a record of attention being paid to l implementation of the work observation process.

l l 5.7 LHC Observations Regarding Work Observations The following observations are limited in extent and conclusions to be drawn from the observations must be considered preliminary. The observations made tend to confirm the conclusions reached in the self-assessment report conducted in late 1997 by Unit 3 Corrective Action Department (3 CAD-SA-97-10).

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l Evaluation of Millstone Self-Assessmeet Revision 0, July 1,1998 l and Independent Oversight Programs l '

Program Definition The program is well defined. There is a Unit 3 procedure (OA 5) which defines the program.

In addition, there is a site procedure (OA 5) applicable to non-unit organizations whose work supports Unit 3 activity.

Assienment of Responsibilities Responsibilities for the work observation program are assigned at Unit and department level.

The responsibilities of observation performers and of the coordinator are also covered.

Responsibility for interpretation and evaluation of results, and evaluation of program performance are not explicitly assigned.

Communication of Manacement Expectations Examples included in the procedure provide a measure of management expectations. In addition, discussions among responsible department management representatives have taken place during SAAB meetings. There is evidence ofparticipation in these discussions at the Unit Manager level. There is some indication that management may not be providing a high priority to work observation activity, based on survey returns described in the self-assessment report on Management Observation Program Effectiveness,3 CAD-SA-97-10, dated 11/12-21/97.

Availability of Trainine and Guidance Training is available in work observation. Operations has utilized this training as part of the licensed operator re-qualification training process, but it has not yet been fully utilized by managers or non-management personnel on a unit wide basis.

Frequent Management Participation Based on survey responses described in the self-assessment of the work observation program, it appears that direct feedback (coaching and correction) is provided to improve performance.

A review of the schedule and performance of work observations indicates a wide range of work activity and training are covered.

Use of Per formance Evaluations Reports sampled frequently contain recommendations, and there is indicatien that CRs are generated from work observations to provide tracking for corrective actions.

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Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 and Independent Oversight Programs Self-Evaluations are Inteerated The work observation process has been made an integral part of the work practice in Maintenance. Observations are carried out at aillevels ofthe organization, including first line supervisors. Extensive records are maintained of the extent and type of observation, the results, and actions taken to improve performance. There appears to be effective distribution ofthe results to all maintenance personnel. Topics covered include pre and postjob briefmgs, as well as the conduct of the work tasks.

In other areas, the focus is on pre-scheduled four hour long observations, with less involvement of the first line supervisor. These observations are more widely distributed in time, and are less evidently a part of the day-to-day operation of the unit.

Tracking of Action Items Action items (corrective actions) are incorporated into existing problem resolution processes (TR, CR) for tracking and evaluation. In addition, Maintenance provides a summary report of noted problems (including those which may not rise to the level of the formal control systems) as part of their feedback process.

Management Initiates Self-Evaluations The emphasis of the reports reviewed and subjects scheduled appears to be en procedural compliance and physical condition. There is no indication in the work observat.on procedure that adverse cultural symptoms are an appropriate subject for work observation. The general overview in the procedure focuses on observation and evaluation ofthe quality ofwork being performed. Instructions to observers direct that emphasis be placed on " detail, procedural compliance, meeting of specific performance standards, and management expectations".

Ouality of Renorts Reports reviewed exhibit a wide range of effectiveness in clarity and conveyance of information on strengths and areas ofimprovement. Those reports which include the sections containing recommendations and the observation log (which are optional parts of the report according to OA 5) appear to provide a more effective means of communication.

Effectiveness ofImnlementation l Implementation of the work observation program appears to be fairly effective. The implementation in Maintenance, where it is carried more deeply into the organization and is more fully integrated with day to day operations, is noted as a strength. The incorporation of corrective actions into dermed action management programs gives confidence that issues identified will receive attention, but it is too early in the program to determine whether it is having an overall bereficial effect. In the past, there has been a tendency to identify as Page 31

! Evaluation of Millstone Self-Assessment Revision 0, July 1,1998 l and Independent Oversight Programs strengths activities that should be expected as effective performance. A recent revision to OA 5 adds the characterization of an observation as " Positive Performance," which should aid in distinguishing the difference between expected performance and a strength. In general, the program implementation meets most of the criteria as noted above.

Available Performance Indicators Appropriate performance indicators for the program are not evident. 'l racking of scheduled versus performed work observations provides a measure ofthe work observations performed, but not the quality or effectiveness. There were no Key Performance Indicators observed which are directly tied to the work observation program.

Review of SAAB minutes indicates that there is management attention given to the conduct and effectiveness ofthe program. The procedure provides no measures ofperformance, nor any guidance on expectation of effectiveness or its evaluation.

5.8 Recommendations Regarding Work Observations The LHC team has developed the following recommendations regarding the work observation program in Unit 3 for consideration by NNECo:

1. Completion of training in work observation is recommended for all personnel who are expected to carry out work observations.  !

2. The " working level" approach utilized by Maintenance should be extended to other areas of the organization (particularly operations). A program structured like Maintenance has structured theirs would probably provide more management involvement and real time benefit (especially in terms o fmanagement involvement in the work place on a day to day basis) than the "four hour block" process described in OA5.

3. It is suggested that the responsibility of Unit level management in assessing the effectiveness of the work observation process be explicitly addressed in the procedure.

4. Management should assure that work priorities and resources are consistent with the importance placed on the work observation portion of the self-assessment process. )

5. The direction to observers in OA 5 should address issues other than direct work performance, by incorporation of guidance with regard to attributes of a safety conscious work environment that should also be observed.

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6.0 Summary and Conclusions

! As reported in the previous three sections, LHC has co.mpleted an evaluation of NNECo's l

independent oversight and Self-Assessment Programs. The various programs reviewed have been determined to be adequate to support a safety conscious work environment at the Millstone site.

- Recommendations for strengthening various aspects ofthe programs reviewed have been offered by

- LHC. Overall, LHC concludes that the site's independent oversight programs and Self-Assessment Program are adequate to support the' safe restart of Millstone Unit 3.

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' ATTACllMENT 7 To LIIC Second Quarter 1998 Report to NRC Little Harbor Consultants, Inc.

Millstone -ITPOP Project Office P.O. Box 0630 Niantic, Connecticut 06357-0630 Telephone 860-447-1791, ext 5966 Fax 860-444-5758 May 27,1998 Docket Nos. 50-245 50-336 50-423 ITPOP 98-0023 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Millstone Nuclear Power Station, Unit Nos.1,2, and 3

Dear Sir:

Early in April, Little Harbor Consultants, Inc. (LHC) became aware that Mr. David Brown who had reached a settlement during the winter of 1997-98 with Northeast Utilities (NU or the Company) to resolve allegations of harassment, intimidation and discrimination at Millstone Point had sought to reopen the settlement negotiations and alleged that the earlier settlement discussions had been tainted by coercion and duress. He also alleged that one of LHC's members had acted improperly in connection with the negotiations or settlement. On April 7, LHC retained an outside law firm to conduct an independent investigation of those allegations. That investigation is now complete. It not only found no evidentiary basis for the allegations but found that the available evidence, consisting ofcontemporaneous documents and interviews, substantially rebuts them. This letter summarizes those allegations and the results of the independent investigation.

I The investigators had unfettered access to NU and LHC personnel and records, and are

! believed to have interviewed everyone connected with the allegations except Mr. Brown. The reason for that gap is simple: Mr. Brown's attorney would not permit it. The investigators telephoned Mr. .

Brown's attorney during the week ofApril 13, and requested him to provide concrete allegations and l

underlying facts to assist in framing the issues to be addressed in the investigation, and also requested an in-person meeting with Mr. Brown to discuss his issues and concems. Mr. Brown's at:arney declined both requests, but asked the attorneys conducting the investigation to put them in writing. The attorneys conducting the investigation did so in a letter dated April 17 to Mr. Brown's counsel. That letter reads in part:

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c-U.S. Nuclear Regulatory Commission Page 2, ITPOP 98-0023

[We] called to ask you to provide us with concrete allegations and underlying facts to assist us in framing the issues to be addressed in our investigation. We also asked if you would arrange an in-person meeting with Mr. Brown to discuss his issues and concerns.

In response to our request, you stated that you could not discuss Mr. Brown's concerns because they were privileged. You also stated that you doubted that it was in Mr. Brown's interest to discuss his allegations with us. You asked, however, that we put our requests in writing so that you could discuss them further with Mr.

Brown. This letter complies with that request.

As we stated in our conversation, we believe that a frank airing of the issues raised by Mr. Brown is to the mutual benefit of LHC and Mr. Brown. Accordingly, we urge you to reconsider your decision not to discuss this matter with us.

No response has ever been received to this letter. Nor has counsel for Mr. Brown subsequently contacted LHC or the outside firm which conducted this investigation in any other fashion.

The allegations set forth below were identified on the basis of allegations made by Mr. Brown to an officer of the Company:

Allegation 1: LHC acted improperly by conspiring with the Company to force Mr. Brown out of the Millstone facility.

Findings: No evidence supports the allegation that the Company and LHC conspired to drive Mr.

Brown out of the Millstone facility. To the contrary, the evidence overwhelmingly shows that it was Mr. Brown's idea and desire to leave the Millstone facility for a non-nuclearjob and that he changed his mind only when the newjob he requested and was given did not meet his expectations.

Allegation 2: Mr. Brown's settlement agreement was the product of duress and coercion.

Findings: The investigators were unable to find any evidence supporting Mr. Brown's claim that the settlement agreement was the product of duress and coercion. Exhibits attached to the report, moreover, support the opposite conclusion, as do various witness interviews.

Allegation 3: Billie Garde acted unethically by interfering with Mr. Brown's attorney-client relationship with a named attorney.

Findings: The investigators were unable to find any evidence to substantiate this claim. To the 7

L contrary, there was evidence that Mr. Brown either clearly represented himself at various stages of the negotiations or had retained the services of an attorney for review and comment on the proposed agreement.

J 1

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U.S. Nuclear Regulatory Commission Page 3,ITPOP 98-0023 Allegation 4: Billie Garde acted as Mr. Brown's attorney in connection with the settlement l

negotiations. .

l l Findings: No evidence was found that Billie Garde functioned as Mr. Brown's attomey. Ms. Garde l was cognizant that Mr. Brown was represented by named counsel in other potential litigation against j the Company, and insisted that the named counsel be kept apprised of Mr. Brown's settlement i negotiations, up to the point that Mr. Brown withdrew from the potential lawsuit. Both Ms. Garde l and the senior Company official negotiating with Mr. Brown understood that no settlement of the

other potential litigation could be discussed with Mr. Brown while he was represented by counsel and Mr. Brown was repeatedly informed of this fact. The Company official witnessed Ms. Garde telling Mr. Brown repeatedly that she was not his lawyer, and could not act as his lawyer. Ms. Garde also provided Mr. Brown, at his request, with the name of another attomey so that his settlement agreement could be reviewed by counsel on his behalf. The other attomey confirmed that Ms. Garde had stated to her that Ms. Garde could not review or negotiate Mr. Brown's settlement agreement because that would not be consistent with her oversight role, and that Ms. Garde had also so stated

. to Mr. Brown.

l.

Other witnesses confirm that Mr. Brown initiated contact with Ms. Garde and that he was eager to discuss resolution of the other potential litigation with her. Mr. Brown was told by a Company ECP investigator, who was investigating earlier issues involving Mr. Brown, that it was appropriate for Mr. Brown to contact Ms. Garde. Mr. Brown often called and visited Ms. Garde during the negotiation period, but the impetus for the calls and visits came from Mr. Brown. Not a single witness.who observed Ms. Garde's conduct throughout the entire ECP investigation and the settlement negotiations believed that she was acting as Mr. Brown's attomey.

The report concludes that Mr. Brown's " allegations regarding LHC and Billie Garde lack credibility and are not supported by the facts. Accordingly, we believe that these allegations should have no impact on the NRC's deliberations regarding LHC's conclusion that the Millstone site has achieved a sufficient state ofreadiness vis-a-vis a Safety Conscious Work Environment to support resumption of Unit 3 operation."

Sincerely, cJ. /Y ~

John W. Beck I President, LHC Team Leader,ITPOP cc: Distribution l

l L ___n_____.________ _ _ _ _ _ _ _ _ _ _

a, U.S. Nuclear Regulatory Commission Page 4, ITPOP 98-0023 Distribution:

John Streeter, NNECo Charles Brinkman, Manager Harry L. Miller, NNECo Washington Nuclear Operations William J. Temple, NNEC ABB Combustion Engineering Nuclear Power 12300 'I winbrook Pkwy, Suite 330 Rockville, MD 20852 Susan Baranski, NNECo Cheryl Grise, NNECo Mr. John Buckingham Department of Public Utility Control Michael Quinn, ECOP Electric Unit 10 Franklin Square U.S. Nuclear Regulatory Commission New Britain, CT 06051 Attn: W.D. Travers Mail Stop: 014D4 Citizens Regulatory Commission Washington, DC 20555-0001 ATTN: Ms. Susan Perry Luxton 180 Great Neck Road U.S. Nuclear Regulatory Commission Waterford, CT 06385 Attn: P.F. McKee Mail Stop: 014D4 Citizens Awareness Network Washington, DC 20555-0001 54 Old Turnpike Road Haddam, CT 06438 U.S. Nuclear Regulatory Commission Attn: H.N. Pastis The Honorable Terry Concannon i Mail Stop: 014D4 Nuclear Energy Advisory Council Washington, DC 20555-0001 Legislative Office Building Hartford, CT 06106 Mr. Wayne D. Lanning US NRC Region I Mr. Evan W. Woollacott 475 Allendale Road Co-Chair l King of Prussia, PA 19406-1415 Nuclear Energy Advisory Council 128 Terry's Plain Road Kevin T. A. McCarthy, Director Simsbury, CT 06070 ,

Monitoring and Radiation Division  !

Department of Environmental Protection Emest C. Hadley, Esquire 1 79 Elm Street 1040 B Main Street l Hartford, CT 06106-5127 P.O. Box 549 West Wareham, MA 02576 Allan Johanson, Assistant Director Office of Policy and Management Mr. Paul Choiniere P The Day" olicy Development and Planning Division 4 47 Eugene O'Neill Drive 50 Capitol Avenue-MS 52ERN P.O. Box 34144i New London, CT 06320 Hartford, CT 06134-144i l

Bob DeFayette t

First Selectmen 100 King Street Town of Waterford Gettysburg, PA 17325 Hall of Records

';00 Boston Post Road Don Beckman Waterford, CT 06385 1071 State, Route 136 Belle Vernon, PA 15012 u_____________------------------

THE DAY, SUNDAY. M AY 24,1900 l R' estart, no matter what? = u Delaware. This is akin to a Connecticut motorist ATTACIIMENT 8 l Thes e is a sense of inevitability regarding the restart of Millstone Unit 3 as June 2 Jacking up a car to fix a flat, only to find that his approaches. That's the date that the Nu- sparc tire was somcwhere in Maine.

To LilC Second Quarter 1998 Report to NRC clear Regulatory Commission 1s scheduled to This serics of eventa shouldn't have hap-  !

I decide whether or not to mstart the plant that pened, especially not at this plant, and at this has been shut down for two years. This sense of late date, tha inevitable would be a cause for rejoicing u Several peopic alleged last month that Little tre it based solcly upon solid results from the liarbor Consultants, the independent consul.

Work that thousands of Northeast Utilities em- tants NU hind to assess how well the plant was ployees have donc - the 70-hour weeks, the un- handling employee concerns, was acting both as wanted overtime, the personal sacrifices many umpire and outfleider for the NU team. Such a workers have made to help start the stalled clahn,1f it had any factual basis, would bring plant. into scrious question the work Little Harbor has Dut the restart decision, if it comes, may not done. The allegations were that consultant Bil.

be solely based upon the readiness of the com- lie Gardo improperly intervened to help negoti.

pany. The road to restart has been, at least in ate a settlement for Dave Brm n, a quality-con-part, schedulc driven, not motivated by a desire trolinspector at the Millstone site, leaving his to begin the plent only when its many problems attorney, Robert W. Heagney, in the dark. In re- .

l are solved, but to keep NU from going into bank- sponse to these allegations Littic Harbor hircd ruptcy The colnpany's financial difficulty has a Washhlgton, D.C., law firm to investigate and f added enormously to the pressure to start the claimed that the report completely exonerated l plant. Ms. Garde, even though the investigators never i So it is worth repeating U.S. Sen. Christopher talked to Mr. Brown and never talked to anyone  ;

J. Dodd's admonition: It would be a disaster for who made the allegations. j the NRC to start Millstone 8 before it's read.y. But the investigation was good enough for the l Given that, and given several recent events, it is NRC. Should it have been? Three investigators  !

I difficult to understand recent NRC reactions from the NRC Office of Inspector General will which have minimized obvious problems at the be in the area Tuesday to try to answer that company Those comments have made observers question.

here believe that the plant will be restarted no u One of the most important questions re-matter what. Restart, no matter what, would be garding the plant was whether management a mistake. could successfully establish a healthy Safety Recent occurrences have made many ob. Conscious Work Enviromnent, a questionhlg at-servers question whether the plant is ready to titude that's vitalin the safe operation of nu- ,

restart; clear plants. Recently the NRC concluded that j O On May 15, Millstone 3 announced that, NU had established such an environment, giv- I while making repairs to a critical valve which ing the company a big boost toward restart. l regulates water carried from the reactor core, But has the company accomplished this? I Corkers found they did not have the part they An editorial in January discussed the Nuclear i needed to fix the valvo. If such a valve leaks, it Safety Oversight group at the Millstone site, a cannot be isolated, making repairs difficult. group whose independence and critical attitude 1

The parts needed, called freeze seals, were not are crucial to rumling the company successfully in the plant and not even in the state. They were Workers from that department met in December )

in Delawam at the Ramada Inn in Norwich to discuss the en-When asked about this incident, Dr. Shirley vironment in which they worked. During the Ann Jackson, chairwoman of the NRC, said that meeting, workers agreed that their department the company's reaction was "a strong response " had only two of lu characteristics deemed vital because NU leaders replaced a manager and for a Safety Conscious Work Environment. l c lled for an investigation of the incident. Dr. Two outof 181  !

Jackson's reaction is bizarre. She praised a per- Management promised the workers that the  !

formance by NU that was unacceptable. entire group would participate in drafting a In fact, the problem never should have oc- corrective action plan. That wasn't done. But '

curred. workersgotadraftof theplanonMay19-after The valve started to leak on April 13, a full 32 the NRC approved the company's efforts at es-  ;

days before workers began to attempt a repair. tablishing a Safety Conscious Work Environ-When a valvo leaks for a month, there is plenty ment - and the group wasn't consulted at all. ,

of time to plan the most conservative possible Indeed,despite thelack of consultation,many l steps to make repairs. There was ample time not items listed as needing attention were marked only to have freeze seals available. but also to " completed." That sounds Imt a way to sweep is-have them in place. They could have been af- sucs under CA rug, and keep them from inter-fixed to the pipe before workers attempted the feringwith ceset.

I repair, so the pipe wouldn't ler*; at all when the Many ques 0cns renatn regarding the readi.

faulty valve was removed. Br.t that didn't hap- ness to restart of Millstone Unit 3.The NRC pen. When workers, in the middic of the repairs' must ask those questions, because it would lose asked for the freeze seals in order to attach them what little credibility it has if the commission t3 the pipes, they were told the seals were in approved mstarting n phmt that wasn't ready

. ATrACitMENT 9 :

To LilC Second Quarter 1993 ;

Report to NRC

,n Little Harbor Consultants, Inc.

Millstone -ITPOP Project Office P.O. Box 0630 Niastic, Connecticut 06357-0630 Telephone 860-447-1791, ext 5966 Fax 860-444-5758 i May 27,1998 ITPOP 98-0024 Editor The Day PO Box 1231 New London, CT 06320 To the Editor of The Dav:

Your May 24 editorial on Millstone (" Restart, rr, matter what?") raises a number ofquestions as to whether the NRC should permit Unit 3 to start oack up at this time. One of them involves a

, complaint by a former Millstone employee that his settlement with Northeast Utilities was tainted by duress, and that a member of Little Harbor Consultants acted improperly in connection with it.

LHC took this allegation very seriously. Your editorial observes, accurately, that a prompt but thorough independent investigation commissioned by LHC reached the conclusion that there was no basis for the criticism of the LHC team member. But it then immediately dismisses the investigation with the statement that the investigators had "never talked to Mr. Brown and never talked to anyone who made the allegations."

LHC has kept its investigation report confidential, out of concern for the privacy of individuals actually or potentially involved. However, one aspect of your editorial - its implication

! that the results of the LHC investigation should somehow be discounted because the individual I himselfdid not participate in it - casts stones in the wrong direction. The independent investigators d

were given unfettered access to all personnel who had direct knowledge about the allegations, ar 1 to their papers, with one exception - Mr. Brown himself. Why? Because, having made t j allegation publicly, ifindirectly (through third parties), he wouldn't cooperate. The investig*

attempted on multiple occasions both to obtain a specific statenent of Mr. Brown's allegations ana their basis, and a face to face interview with him. They were enable to gain either. Mr. Brown's attomey wouldn't discuss the allegations himself, contending that they involved attorney-client -

privilege. Nor would he allow his client to meet with the investigators, saying that he " doubted it was in Mr. Brown's interest." Why wouldn't they cooperate? Draw your own conclusions.

The editorial's related suggestions that the investigators somehow missed the mark by having "never talked to anyone who made the allegations" adds nothing: the only person who made the  ;

l

Editor ofIhe day Page 2, ITPOP 98-0024 allegations is the individual himself. Whatever other sources your editorial writer relied on were

! merely repeating those allegations - passing along hearsay, nothing rnore.

In short, LHC has concluded, after a thorough investigation, that the allegations are not only l

- unproven but baseless.

Sincerely,

=!

l l

John W. Beck President, Little Harbor Consultants, Inc.

ATTACllMENT 11

• • To LilC Second Quaner 1998 Report to NRC IHC DAY, FRIDAY. JtJNE.12,199D a

ew i a a.

Relay a restart of Millstone' OPEIOE ny day now, perhaps even today, the Nu' And he adds that the valve m question is not clear Regulatory Commission is likely to part of the plant's operating system. The valve ow Northeast Utilities to restart Mill- is a factor when the plant is undergoing mainte-stone Unit 3. That's a mistake because of NU's nance.

continuing failums to respond appropriately af. The valve also is used when engineers want to ter engineers and managers point out major isolate the reactor coolant system loop or when problems.

they wanttoadacepressun, Chairwoman Shirley Jackson and her col-leagues on the NRC should read the most recent .The new mport says that, faced wi0ga pn>l>-

lem valve in the reactor coolant system as early' report on a major problem at Millstone 3 befort as 1995, NU personnel failed to heed an engi-they vote. Ms. Jackson and other commissioners neer's warning that the valve m40t have suf-could hardly nad the just-released report by the. fered a separation of its valve stem and disc. A ,

Independent Review Team at Millstone and con-wott order to address the situation was written, clude that Northeast managers have serious is-but then the order was canceled, apparently sues under cont d withoutexplanalion. '

g g 3 c g o,, The valve was repacked in 1996, but NU em-The report makes clear that the company's ployees noticed in April 1998 that the packing engineers and managers continue to make the was leaking. The effort to repack the valve same kind of substantial mistakes that led to failed and the valve continued to leak. The sys-thetwo-yearshutdownof thispla'at.Thereport tem engineer for NU recogmzed the potential also demonstrates that NU did not give pmper that the disc stem had seliarated on May 13.1998.

cadence to warnings f!Dm its oversight employ- lie raised the issue but the maintenance super-ees, failed to follow its own wmpany procedures vis r failed to follow the maintenance manag.

and did not take the proper corrective actions. cr's order to fix the problem, Mr. Kenyon says.

Retnember, this is a report written by NU's The repott also says that NU cmployees failed own employees.

Indeed, the Independent Review Team said that mistakes made in handling the incident were akin to those made when NU employees at-tempted in 1993 to make temporary repairs to a damagod 442 valvo in the reactor <oolant system at Millstone 2. They did so while the plant was still operating. A follow-up review determined that this was the worst incident ha the plant's history and a very serious safety problem.

l Bruce Kenyon, CEO of Northeast's nuclear operation, says that this most recent valve inci-dent does not compare with the 442 pmbicm.

"This was tiot unsafe. The 442 valve was un-safe," Mc Kenyon said. "I'he plant was put on a safe condition to do thbjob." ,

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