ML20195H740

Station/Unit 3 Third Quarter Performance Rept

ML20195H740
Person / Time
Site:	Millstone
Issue date:	11/30/1998
From:	NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20195H729	List: B17380, Forwards Millstone Power Station,Unit 3 Third Quarter Performance Rept, Which Addresses Performance of Station Key Issues & Backlog Mgt,For Period of Jul-Sept 1998.ICAVP Drs & Sargent & Lundy ICAVP Final Rept Findings,Included ML20195H740
References
NUDOCS 9811240087
Download: ML20195H740 (200)

Text

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MILLSTOXE STATION / UNIT 3 Third Quarter

>( Performance Report

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Table of Contents EXECUTIVE

SUMMARY

PERFORMANCE ON KEY JSSUES PERFORMANCE ON KEY ISSUES -KPis BACKLOG MANAGEMENT UPDATE O

BACKLOG MANAGEMENT- KPis ICAVP LEVEL 4 DR STATUS STATUS OF FINDINGS FROM SARGENT & LUNDY ICAVP FINAL REPORT O

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SUMMARY

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Executive Summary 1

Structure of the Report This pe:formance report for Unit 3 indicates the success of the Unit and supporting station programs to sustain progress on 15 Key Issues and provides a status update on the Backlog Management Plan, the status on the Independent Corrective Action Verification Program (ICAVP) Discrepancy Reports, and the status of findings from Sargent & Lundy's ICAVP final report.

I Section 2 of the report, Performance on Key Issues, provides a summary of the assessments and Key Performance Indicators (KPis) which measure progress  ;

on the defined success criteria for each issue. Copies of the KPis, which are i used to measure performance against station and unit goals, can be found in  !

Section 3.

n The next section, Backlog Management Update, outlines the progress achieved ij in dispositioning work items included in several work management categories.

Two tables summarize the end of quarter status in each work management category, and describe a recently discovered deficiency in capturing scope of some backlog items. Copies of the Backlog Management KPis can be found in Section 5.

Section 6, ICAVP Level 4 DR Status, reports on the progress toward completion of the Level 4 Discrepancy Reports from the Unit 3 ICAVP. Tatles and figures depict the anticipated work off of corrective actions associated with the Level 4 DRs.

Section 7, Status of Findings from Sargent & Lundy ICA VP Final Report, provides an update on the progress toward completion of corrective actions arising from the eleven findings and recommendations of S&L Final Report, SL 5192.

Performance on Key issues A combination of self-assessments and Key Performance Indicators (KPis) are used to gauge the health of the programs needed to support continued safe operations. These self assessments and KPis are supplemented by Nuclear Oversight and extemal assessments such as INPO evaluations and Joint Utility O, Management Assessments which provide an outside perspective on the issues.

Millstone Station / Unit 3 Third Quarter Performance Report

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2 O Each Key Issue has identified success criteria which provide a way to determine i

V the rate of performance progress toward achieving excellence goals while i

ensuring that performance necessary to support safe plant operations is being i maintained. The table below lists the 15 Key Issues.

Key lasue Leadership Safety Conscious Work Environment Self-Assessment Corrective Action Oversight Configuration Management Regulatory Compliance Training <

Operational Performance Work Control and Planning

Procedure Quality and Adherence Emergency Planning Radiological Protection Security Environmental Compliance l

The third quarte'r 1998 is the first quarter, since Unit 3 was shutdown in 1996, that the plant has operated. Accordingly many of the Key Issue areas have shifted focus from recovery to operations with Success Criteria, performance

! goals and Key Performance Indicators adjusted accordingly.

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Northeast Nuclear Energy Company (NNECO) has reviewed the information in this report and has concluded that it shows performance is being sustained at a l (k>}

! level which adequately supports the safe operation of Unit 3. All 15 Key issues have continued to meet their respective success criteria such that Unit 3 and the Millstone station can support continued safe, event-free operations. Where progress in a particular area has not attained a goal which management has set, an action plan or corrective action has been initiated.

l NNECO has observed that while Key issues attained a satisfactory level of l performance, clearly areas of some Key issues are expected to be improved l

upon. Summary on the status of the Key issues is provided in the pages that follow.

Leadership Cultural Surveys and Leadership Assessments indicate that Millstone l Station has effective leadership and that the gains made in the work culture during the recovery have been maintained. All areas in the leadership assessment except one (performance accountability,5.31) remained above the goal (5.5 out of 8). Culture survey scores remained relatively unchanged with a less than 1% change from the November l 1997 suwey.

Safety Conscious Work Environment (SCWE)

Assessments and KPis indicate steady performance and a generally

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V improving trend. A high percentage of employees indicate that they are l

Millstone Station / Unit 3 Third Quarter Performance Report

3 p willing to raise concems. The employee concerns program is viewed as V an effective means for resolving issues. Management continues to address focus areas where the attributes of a Safety Conscious Work Environment are lacking or challenged. Little Harbor Consultants has L noted that SCWE is moving in the direction of preventing problems not I just addressing issues when raised. The Employee Concems Oversight Panel has noted areas for continued improvement.

Self-Assessment Millstone Station continues to self-identify the majority of issues (>95%).

No significant programmatic issues have been identified by extemal

! oversight. The work environment reflects a critical questioning attitude.

l Corrective Action The Corrective Action program is functioning effectively. Conditions adverse to quality are identified at low threshold and the ratio of self-identified to extemally identified issues continues to increase. While the quality of corrective action plans remains high, addressing overdue corrective actions in a timely manner continues to be a challenge. Trend reports have noted the need for improvement in the areas of configuration control, tagging and adherence to administrative requirements.

i Oversight

' v The Nuclear Oversight program is functioning effectively. KPls indicate that the majority of station problems are self-identified. The timeliness of responding to Oversight generated Condition Reports improved during the quarter, however, further improvement is needed. Through the l performance of the NOVP and other regularly scheduud audits, surveillances, other assessments, Oversight is effectively assessing the

! performance of line organization.

L Configuration Management Self-assessments and KPis indicate that the Configuration Management processes are adequate. However, self-assessments and CRs continue to identify " attention to detail" problems related to implementation of these

! processes. Revised success criteria will be aligned with the maintenance I of the established design and licensing bases, and the identification and l resolution of challenges to configuration management.

Regulatory Compilance Regulatory Compliance is satisfactory to support continued safe operations. However, increased management attention is being focused on addressing commitments in a more timely fashion.

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Millstone Station / Unit 3 Third Quarter Performance Report

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i e Training

( Performance continues to improve in the training process. Line management has improved their involvement in the training process as evidenced by 100% of all unit supervisors and managers completing Management Observations during the third quarter. The processes for

, capturing and evaluating change information for training material is i l effective instructors have been assessed as knowledgeable, l l professional and effective in delivery of training. Training programs make l l a valuable contribution to meeting Station objectives.

l Operational Performance '

Assessments indicate that Unit 3 personnel have performed well during i

the restart effort. Operations KPis show satisfactory performance in diesel generator and HPSI unavailability, thermal performance fuel reliability and industrial safety accident rate. Reducing operator burdens I continues to be a challenge as the number of temporary modifications and

work arounds is above goal. Although four KPis show the unit not meeting management goals, these areas are due primarily to two major l events - the forced outage to repair an auxiliary feedwater valve, and the reactor trip in September due to high Condensate salinity.

i Work Control and Planning g The backlog of system and equipment deficiencies has shown some lQ increase in the area of on-line corrective maintenance backlogs. Overdue preventive maintenance tasks, however, remain at the goal of zero. On-l line schedule performance has attained the goal of >80% started on time.

The goal has been revised upward to >90% of work activities started on time.

l Procedure Quality and Adherence

Procedure deficiencies have been effectively addressed in a timely manner. Procedure quality for new and revised procedures is acceptable.

I instances of procedure non-compliance remain relatively low and demonstrate satisfactory performance.

l Emergency Planning i Millstone Station has an effective Station Emergency Response

Organization (SERO). Emergency Planning is maintaining and improving performance of the SERO and its associated programs. The Emergency Planning programs are continuously being upgraded based on feedback from events such as drills, self-assessments, and surveillances.

j Procedures continue to be reviewed and upgraded.

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fm Radiological Protection V Millstone Station is maintaining an effective radiological protection program commensurate with safe nuclear operations and industry standards of performance. The goal of less than one event per 20,000 entries into any RCA has been met in the third quarter. Additionally, a truck contamination monitor has been installed and is currently being l tested on-site. This device is the first of its type at a US commercial nuclear facility.

Security Assessment results show that satisfactory performance is being maintained. Key Performance Indicators show that we are tracking satisfactorily in security related events in regard to success criteria of vehicle control and control of safeguards information.

Environmental Compliance The results of performance measures and on-going program improvements and enhancements provide assurance that environmental regulations and requirements are being identified and effectively implemented.

Nuclear Oversight Verification Plan O

b During the third quarter of 1998, Nuclear Oversight transitioned from the Nuclear Oversight Restart Verification Plan (NORVP) to the Nuclear Oversight Verification Plan (NOVP). The shift in the approach better allocates Oversight resources to support the safe, event-free operation of Unit 3 and continued l recovery of Unit 2.

The NOVP assesses performance in ten (10) Unit-specific areas as well as four (4) common site programs. The ten unit evaluation areas are:

. Operations

. Work Control

. Engineering

! . Corrective Action

. Self-Assessment i

e Maintenance l . Health Physics

! . Chemistry l . Fire Protection

. Refueling Outage Preparation The four (4) common site programs areas are:

Millstone Station / Unit 3 Third Quarter Performance Report

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. Security

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. Emergency Planning

. Training

. Environmental Monitoring The assessment areas for the NOVP do not align precisely with the Key issue areas. The Oversight section and KPl C-2 summarize the results of the third quarter NOVP for Unit 3.

Backlog Management Update This section of the report provides the progress achieved in the disposition of work items that have been included in the backlog of deferred work in several work management categcries. These work management categories include Configuration Management Discovery, Engineering Backlog, Total Corrective Action Assignments, ICAVP DR Corrective Action Assignments, Corrective Maintenance AWOs, Open Operability Determinations, Operator Work Arounds, Control Room and Annunciator Deficiencies, Temporary Modifications, and NCR.

Performance is evaluated two ways - reduction of recovery deferred backlog that existed as of June 29,1998, when Unit 3 entered into Mode 2, as well as,

~N additional post-restart backlog that has accumulated.

(Y Most backlog management goals are being met. The exceptions are Operator Wor'K Arounds, Temporary Modifications and Operability Determinations. These areas are recognized by the Unit Management Team as key to ensuring an operational focus and action is being taken to improve performance, A deficiency was recently found in the methodology that was used to establish the '

number of work items included in the Engineering Backlog work management category, it introduced uncertainty in quantifying the numbers of work items in the Engineering Backlog for this report and has caused earlier accounts of the number of backlog items to be under reported. This deficiency is not expected to yield items that were inappropriately deferred, and does not impact management goals with respect to completion of backlog work items. The issue is currently tracked under the station Corrective Action Program.

ICAVP Level 4 DR Status This section reports on the progress towards completion and status of the Independent Corrective Action Verification Program (ICAVP) Level 4 Discrepancy Reports (DRs). Anticipated work off of the Level 4 DR assignments has met management expectations under the Backlog Management Plan, and appear to be on track for meeting NNECO's commitment for having the final

~/ corrective actions to address the discrepancies in the deferred Level 4 DRs Millstone Station / Unit 3 Third Quarter Performance Report

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y - dispositioned prior to the completion of the next refueling outage for Millstone Unit 3 (RFO6).

Status on Findings in the Sargent & Lundy Final Report in this section the progress towards completion of corrective actions is described for the eleven (11) Sargent and Lundy (S&L) findings that were the result of the independent Corrective Action Verification Program (ICAVP). As indicated by S&L in Section 1.7.2 of the Final Report Executive Summary, the 11 ICAVP Team findings and recommendations are based on Level 4 DR issues that had a high occurrence rate. NNECO's review of these findings indicate that they are of low safety significance and do not negatively impact the Millstone Unit 3 license bases (LB) or design bases (DB). l Some progress towards disposition of corrective actions associated with these eleven findings and recommendations has been made. In this report five of the i eleven items are described as having been addressed such that future updates regarding those five items would not be necessary. Actions have been taken to  ;

schedule and plan further review on some items. All of the Level 4 DR l assignments and disposition of the associated corrective actions will be completed prior to retum to operations from the next refueling outage (RFO6) and monitored under the Backlog Management Plan.

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A Millstone Station / Unit 3 Third Quarter Performance Report

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PERFORMAKCE ON KEY ISSUES a

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Performance on Key issues I

During the Millstone recovery, the Millstone Leadership Team identified fifteen (15) site-wide Key issues. The sixteenth recovery Key Issue, Nuclear Safety Assessment Board, is functioning satisfactorily and no longer requires classification as a site-wide Key Issue.

This quarterly performance report reflects station / Unit 3 performance for the period July 1,1998 through September 30,1998 for the following 15 Key issues:

1. Leadership

2. Safety Conscious Work Environment

3. Self-Assessment

4. Corrective Action

, A V 5. Oversight

6. Configuration Management j

7. Regulatory Compliance l

8. Training

9. Operational Performance

10. Work Control and Planning

11. Procedure Quality and Adherence

12. Emergency Planning 13.Rar.iological Protection

14. Security

15. Environmental Compliance A summary of the performance of the fifteen Key issues is provided in the Executive Summary.

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%J Key issue: Leadership l

Success Criteria The following Success Criteria are established and summarize the performance baseline for this Key issue:

. Maintain a leadership assessment average score of a least 5.5, reflecting an improvement of at least 5% (average of all categories) when compared to the November 1997 score

. Achieve a " skip level" leadership average score of acceptable or equivalent in all categories

. Complete two consecutive leadership surveys with no leaders ranked as less than effective by 12/98

. Complete a Pil Culture Survey with results which support a continuing positive trend Self-assessments 1 O' The following self-assessments are currently planned for 1998:

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. Leadership Assessment Surveys - 2nd and 4th Quarters

. Pil Site-wide Culture Survey - 3rd Quarter

. Audit of Exempt Performance Reviews

. Succession Planning (Pilot Program and Feedback)

The results will provide important input into decisions that will be made to foster further leadership improvements. The data will continue to be trended on a site-wide basis.

Performance Measures The following performance measures are being used on an on-going basis to monitor of this Key issue:

. Leadership Assessment

. Pil Culture Survey

. Skip-Level Leadership Assessment

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Third Quarter Status Leadership Assessment instruments Assessment Title Schedule Completed Revised Date (Y/N) Schedule if Not Complete Leadership Assessment 2nd Y Ouarter Pil Culture Survey 2nd Y l Quarter Audit of Exempt Performance 3rd Y l Reviews Quarter Succession Planning 3rd Y Ouaner l

Assessment Results O

v Leadership Assessment A Leadership Assessment was conducted at Millstone Station during May l 1998. Results are based on 2066 assessment forms from both l employees and contractors. Results of the survey show that employee perception of leadership effectiveness has held steady since the survey was last administered in Winter 1997. The c /erall effectiveness score was 5.71 in Summer 1998 versus 5.74 in Winter 1997. (A score between 4 and 5 is considered " effective." Scores above 6 are evaluated as "very effective to extraordinary.")

, The leadership scores improved the most from the initial survey in the i Summer of 1997 to Fall of 1997. The substantially flat results of this most recent survey may indicate that further improvements will be incremental.

! KPI G-1 shows a comparison of the Summer 1998 survey with the Winter 1997 survey in the five (5) areas evaluated.

The Leadership Assessment revealed several strengths in the ability of management to foster a supportive workplace environment and in the receptivity of managers to listen to concerns and to respect differing points of view. The survey also pointed out the need for managers to l ;neet regularly with employees and to pay attention to personal

/~T development needs.

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(-] The Summer 1998 Leadership Assessment included a " skip" level sumey V to allow employees to assess a level of management above their direct supervision. At Millstone, personnel tended to be more positive about their direct supervisor than about their skip level management. The "sk;o" level measurement resulted in an overall lower score than that obtained l for direct supervision, (5.56 vs. 5.76).

1 Culture Survey The Millstone Culture Survey was completed in June 1998. The results, as indicated in KPl G 2, show that the " Culture index" at Millstone has remained above the previously established goal of 13. (Culture Indices range from 5 to 25.) This survey included more contractor representation than previous surveys. Approximately one-third of the respondents were contractors. Millstone employees had an adjusted Culture Index of 13.17 in comparison to the adjusted Culture Index for contractors of 12.65. The composite index of both employees and contractors was 12.99 - a slight decrease from the overall index of 13.07 achieved in November 1997.

The results showed a 3.9 % increase with respect to employee perception of the Millstone Safety Conscious Work Environment.

Audit of Exempt Performance Reviews The audit of Exempt Performance Reviews is complete. Preliminary results indicate numerous examples of very positive Safety Conscious l Work Environment behaviors. Areas for improvement are currently under l review by the management team.

Successlor Planning Succession Planning for Key positions is complete. The management team has announced a site wide reorganization to ensure long-term operational excellence. The succession plan is one consideration reviewed by the Reorganization Plan Selecting Authorities as part of the reorganization process. The Succession Plan shall be revisited after the reorganization to ensure all positions are satisfactorily addressed.

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Performance Measures

. Millstone Station Leadership Assessment KPI G-1

• Millstone Station Cultural Survey KPl G-2 lO j Millstone Station / Unit 3 Third Quarter Performance Repo' t

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rm Conclusions ,

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Lea Jership Assessments and Cultural Surveys indicate that Millstone is cor.(inuing to maintain a focus on leadership and work environment issues. Results show that the gains made during the station recovery are being sustained as the station transitions from recovery to operations.

Leadership at Millstone Station is effective and continuing to improve.

Leadership assessments results show that allleadership areas are rated as " effective" or "very effective". Culture Survey results show a continuing positive trend.

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Key issue: Safety Conscious Work Environment l 1 Success Criteria The following recovery Success Criteria were previously established and summarize the performance baseline for this Key issue. These success criteria were demonstrated in letter B-17138 dated 3/31/98.  !

. Demonstrate that employees are willing to raise concems

. Demonstrcte that management is effective in evaluating, prioritizing

, and resolving employee issues

. Demonstrate that the Employee Concems Program is effective in addressing issues raised by employees that are not resolved

. satisfactorily by other means within the organization

. Demonstrate that line management is effective in identifying, investigating and resolving focus areas where the attributes of a Safety j Conscious Work Environment are challenged or lacking

. Maintain a Safety Conscious Work Environment as viewed by the Employee Concerns Oversight Panel

. Maintain a Safety Conscious Work Environment as viewed by the independent Third Party Oversight Program, established by NRC Order The operational success criteria for this Key issue are:

l- . Demonstrate that employees are willing to raise concems

. Demonstrate that management is effective in evaluating, prioritizing and resolving employee issues (See Corrective Action Key issue for performance)

. Demonstrate that the Employee Concems Program is effective in

addressing issues raised by employees that are not resolved satisfactorily by other means within the organization

. Demonstrate that line management is effective in identifying, investigating and resolving focus areas where the attributes of a Safety Conscious Work Environment are challenged or lacking Self-assessments As part of NNECO's transition to an operational focus, the overall work environment is now being monitored via the following self-assessments and performance measures.

Millstone Station / Unit 3 Third Quarter Performance Report

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• Effectiveness of Selected Employees Concems Comprehensive Plan

, Action items - 1st Quarter i . Leadership Assessment -late 2nd Quarter l . Pil Culture Survey - 3rd Quader

. Executive Review Board Effectiveness - 3rd Quarter l . HR Customer Feedback Surveys - 4th Quarter Personnel Performance Reviews - 4th Quarter -

. Continuous Monitoring by third party - Employee Concems Oversight ,

Panel  !

! Performance Measures l The SCWE infrastructure includes the dedicated SCWE group (including j the Key issue Manager), the Employee Concems Program, the Employee 1 Concems Oversight Panel, and the Human Resources organization for l NU Nuclear. i importantly, each of these four groups work closely together under the l direction of one Officer. The Independent Third Party Oversight Program '

O (Little Harbor Consultants) is continuing to function consistent with the  :

h terms of the October,1996 Order. NNECO is continuing to address LHC's recommendations. On-going performance monitoring includes:

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. Leadership Assessment (SCWE Element) l

. Culture Survey (SCWE Element)

, . NU Concems and NRC Allegations Received, Millstone Station l . Millstone Employee Concems Confidentiality Trend, Millstone Station

. Employee Concem Resolution Timeliness

. Employee Satisfaction With Employee Concerns Program

. Focus Area Action Plan Status, Millstone Station (through 3rd quarter 1998)

. Concems Alleging (HIRD), Millstone Station

. Safety Conscious Work Environment Case Status, Millstone Station (beginning 4th quarter 1998) l i

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'O Third Quarter Status Safety Conscious Work Environment l

l Assessment Instruments ,

I Three assessments were scheduled and completed in the third quarter of  ;

1998, in addition, Employee Concems Oversight Panel (ECOP) and LHC '

provided ongoing monitoring and assessment during this quarter.

I Assessment Title Schedule Completed Revised Date (Y/N) Schedule if

. Not Complete  ;

Executive Review Board 3rd Quarter Y Assessment 1998 i Culture Survey 3rd Quarter Y 1998 Common Cause Analysis 3rd Quarter Y 1998 ECOP Continuous Ongoing Y tO Monitoring Ongoing Y l LHC Ongoing Assessment Assessment Results Executive Review Board Assessment An assessment of the Executive Review Board (ERB) effectiveness was completed in August 1998. The assessment evaluated the ERB effectiveness in three areas: assuring that individuals had received due process in disciplinary actions; the timeliness of ERB reviews of proposed disciplinary and reduction in responsibility actions; and the satisfaction level with, and perception of, the ERB by involved individuals. The assessment identified no findings. Generally, the ERB was found to be effective in ensuring individuals subject to adverse employment action had received due process that was in accordance with 10CFR50.7. One weakness was noted in that a unified database for ERB cases was not established, thus limiting the efficiency in reviewing past cases. Additionally, eight enhancement recommendations were made, including development of a strategy on transitioning ERB functions to line and support organizations for eventual D reduction of the ERB role.

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l Culture Survey I jx l I Analysis of the data from the five administrations of the Millstone culture i survey that have occurred from June 1996 to June 1998 shows a significant positive trend relative to performance, attitude, and overall  ;

culture at the station as indicated by KPI G-2. Significant progress has i been made in the areas of employee concems and. safety conscious work environment. The data indicates that almost universally the largest jump in scores resulted following the November 1996 survey. This effect was 1

!. the result of the actions of the new leadership team that was established

[ in the Fall of 1996.

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Overall, continued suppon and emphasis of Millstone improvement efforts l 4 is essential to assure contin'Jed performance improvement and to avoid complacency or backsliding. The data indicates specific emphasis is appropriate to increase the simplicity and effectiveness of the station's i imork processes, and to continue to refine the corrective action process to ,

i ensure efficiency. This has been identified by Millstone leadership as one l

! of the post-startup challenges for the site and actions are underway. ]

Common Cause Analysis

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As required by the 1998-2000 Performance Plan, a Common Cause, or

,- " Common Threads" report was completed that provides a structured, collective analysis of causes of SCWE performance issues, SCWE events, and NU's actions to address the issues and events. The report .i looked at causal factors and contributing factors to ensure there are no undetected trends, to ensure that corrective actions have been effective, and to identify any additional actions that would further enhance impro /ements in the SCWE area. The collective evaluation concluded that the basic causes of SCWE performance issues have been addressed, that the 1998-2000 Performance Plan addresses the major residual causal factors, and the Millstone SCWE can be sustained, with some additional enhancements for continuous improvement. These additional enhancements include continued refinement of (1) the

' Corrective Action Process, (2) reward systerns aligned with SCWE issues, ,

and (3) rapid-response communications for mitigation of potential chilling  !

effects.

ECOP Ongoing Monitoring ECOP's ongoing monitoring continues to conclude that the ECP is an effective attemate problem resolution program, and that the number of -

HIRD concems continues to decline. Areas for continuous improvement were provided in the latest ECOP report and have been addressed as O follows:

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ECOP recommends that a higher priority be given to process improvement in the 1998-2000 Performance Plan NNECO places a great deal of emphasis on process and procedure improvement. A specific action item of the plan (A.4.b.1) requires the identification of processes which contribute to most errors or problems and development of an action plan to correct the process. In addition, based on the results of the recent Culture Survey, an in depth review of the Corrective Action Program is underway to identify ways to make it less cumbersome and more user-friendly in all areas. No process refinements to achieve efficiency will be implemented if they compromise the gains that have been achieved in process effectiveness.

. ECP needs to expand the definition and understanding of

" Customer" to include all parties involved in an in,estigation Revision 4 of the ECP Manualincorporates a new requirement to provide a form to each investigation interviewee requesting feedback on how they were treated. The overall investigation process recognizes that it is important that due process is followed and all parties feel they have been treated fairly and respectfully.

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. ECP needs to contact Concerned Individual (Cl) frequently during

{A} investigation it is a requirement of the ECP Manual that contact is attempted on a frequent basis (every two weeks). In nearly all recent cases this

contact has been attempted.

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. Concerned Individual (Cl) needs to be apprised of proposed corrective action before concern is resolved l This was a requirement of Revision 3 of the ECP Manual, and has l been strengthened in Revision 4. Revision 4 adds an administrative .I

. control that provides for a letter to the Cl when the corrective actions have been completed. Corrective actions are entered into the 3 Corrective Action Program for tracking.

Little Harbor Consultants Assessment

LHC's ongoing assessment during this quarter showed steady performance, with a generally improving trend. On August 27,1998, LHC presented the results of their latest assessment of SCWE/ECP. All of the  !

success criteria remain satisfactory, with steady or improving trends. j They commented that they continued to see a workforce that is willing to l bring issues and concerns forward, that management continues to remain focused on SCWE, and that people are being trained on SCWE. In their overall evaluation, LHC said they were impressed with the daily SCWE Millstone Station / Unit 3 Third Quarter Performance Report

j 18 i 1 meetings, the Executive Review Board, and the continuing ECP

'{' s improvements, based on user satisfaction and the quality of ECP files.

Further, they stated that the point of SCWE was not just to deal with issues but to prevent them from happening, and that they were seeing

, positive results in this area as well. It was clear that issues coming up were less severe, that great effort is taking place to train managers and leadership, and that a revision to the training curriculum is in process.

l They believe the key element to success in this area is NU's commitment '

to train on an ongoing basis and to reinforce the issues. In conclusion, LHC stated that their level of activity has dropped off, based on the overall perforrnance of NU which has been very good. l 1

Performance Measures i Leadership Assessment (SCWE Element) KPl B-1 Goal: At least 90% of supervisors and above are evaluated by their employees through the Leadership Ascessment as being an individual to whom employees are willing to raise concems.

Current Actual

98.7% This indicator most directly relates to the first success criterion and the current actual value reflects strong performance.

The schedule for the administration of the next Leadership Assessment is O fall 1998 with annual assessments thereafter.

G Culture Survey (SCWE Element) KPI B-2 Goal: At least 90% of total respondents to the Pil Culture Survey agree

. their work area supports a willingness to raise concerns.

Current Actual: This indicator relates to the firat success criterion. The June 1998 Culture Survey result was 86.6%, indicating that employees feel their work area supports a willingness to raise concems. This result falls short of the long-range goal of 90% by 3.4%, but represents an increase of 4.6% over the November 1998 results (82%). This continues to indicate that a majority of the employees surveyed rate the work environment as conducive for raising concems. When Culture Survey data is considered in conjunction with other indicators, including more recently administered Employee Concerns Oversight Panel (ECOP) surveys, progress in this area is satisfactory.

Millstone Employee Concerns Confidentiality Trend, Millstone Station KPI B-4 Goal:There is not an adverse trend in the number of concerns to ECP requesting confidentiality or anonymity.

Current Actual: This indicator most directly relates to the first success criterion. Thirty-five (35) percent of concerns have been filed

( anonymously or requesting confidentiality since the beginning of 1998.

Based on the September 1998 numbers, the trend appears to be Millstone Station / Unit 3 Third Quarter Performance Report

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/ downward. Our analysis of the concems data did not reveal any specific l\ reason why this pattent occurred. ECP monitors this closely for any adverse trena. Five of the 19 ccncems received in September 1998 were either anonymous or requested confidentiality.

NU Concerns and NRC Allegt.tions Received, Millstone Station KPl i B-3 Goal: There is not an adverse trend in the ratio of concems rece!ved by NU versus the number of allegations received by the NRC.

Current Value This indicator rebted to all four criteria. The increasing number of concems submitted to the ECP suggests growing employee confidence !:i the ability of the Mil' atone ECP to provide an effective means by which concerns can be resolved. The average number of concerns received per month in 1997, was 16. The average number for

, 1998, through September wcs 21, a 31% increase over the 1997 average.

l During the third quarter, sixty (60) c.oncems were received by NNECO l wh3e three (3) concems were received by the NRC. Through three quarters eighty-seven (87) percent of the 213 concems raised were to NNECO.

Employee Concern Resolution Timeliness KPl B-5 Goal: The average age of unresolved concems does not indicate an rN adverse trend.

V Current Actuat. This indicator relates to success criterion 3. The everage age of concems under investigation for the third quarter is 33 l days with a range from 27 to 42 days. The average age of completed l ECP investigations for September was 39 days.

Employee Satisfaction With Employee Concerns Program Goal: A substantial majority of employees who have used ECP state they would use it again.

Current Actuat. This indicator relates to success criterion 3. Feedback forms received this quarter from ECP customers continue to be largely favorable with few negative comments overall, even though a number of respondents indicate they were not satisfiv with the final outcome of their issue. A survey conducted this quarter by Human Services indicates that 83 percent would use the ECP again, and that 95% percent feel the ECP is doing an effective job. A KPI which reflects this information is under development and should be available in future reports.

! Focus Area Action Plan Status, Millstone Station KPI B-7 Goal: The number of areas where it has been determined that one or more of the attributes of a Safety Conscious Work Environment is challenged or lacking does not indicate an adverse trend.

Current Actual: This indicator relates to success criterion 4. The

~O cumulative number of focus areas from program inception to September Millstone Station / Unit 3 Third Quarter Performance Report l

I- . _ . _

t 20 l

lp 30,1998 is 33. Although the number has remained constant in the last iv quarter NNECO has had changes. One of the areas was closed in July 1998, but due to re-emerging issues, it was necessary to reopen this focus area. Of the remaining 5 areas,4 are large groups where significant improvement has occurred but issues continue to be raised and resolved.

l The last focus area is a leadership assessment where the previous leader was replaced and the initial reaction to the new leader was not positive. A new action plan in this area has been implemented.

NNECO continues to see, in many cases, evidence of proactive responses to potential focus areas. NNECO believes that management has the capability to handle many of these issues and is doing so with increased regularity. The need for trained consultants has decreased. NNECO continues with its effort to gain this type of expertise with NU personnel.

In the fourth quarter report, Focus Areas will be transitioning to Safety Conscious Work Environment cases with a corresponding transition in KPis.

Concerns Alleging HIRD, Millstone Station KPI B-8 Goal: The number of concems alleging HIRD does not show an adverse l trend. Substantiated 10 CFR 50.7 concems are infrequent and handled rs responsibly.

I Current Actual: This indicator relates to success criterion 4. A conservative classification criterion is used to categorize and investigate alleged 10 CFR 50.7 HIRD issues. Importantly, since December 1,1996, only three concerns have been substantiated as involving a potential violation of 10 CFR 50.7, and all three are related to a single event (MOVs) which occurred in August 1997. No 10 CFR 50.7 concerns have been substantiated as of the first three quarters of 1998. Open 10 CFR 50.7 concems receive the highest investigative priority. Site management continues to educate, address and when appropriate, discipline any personnel involved in such activities.

For the first three quarters of 1998 the percentage of concems alleging 10 CFR 50.7 concems has declined from 30% in the first quarter to 2% in the third quarter with a year-to-date average of 17%

O Millstone Station / Unit 3 Third Quarter Performarce Report

i 21

,] Conclusions

._NNECO's performance monitoring and third quarter assessments demonstrate steady, improving performance, with no indication of any

backsliding. The number and severity of issues continues to decline.

NNECO continually looks for areas to refine and improve, with specific initiatives being implemented in the areas of training and self and independent assessment. Our workforce is not only empowered in the area of SCWE, it is also well educated, maturing, and more capable of responding to emerging events.

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4 Millstone Station / Unit 3 Third Quarter Performance Report L

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l 22 Key issue: Self-Assessment i

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Success Criteria l

l The following Success Criteria were previously established and summarize the performance baseline for this Key issue:

. Achieve greater than 95% of self-identified issues. Note this is a revision to the previous goal of greater than 90% sell-identified issues.

No programmatic issues identified by intemal and/or external oversight Self-Assessments i

l The following self-assessments are currently planned for 1998: l

. Station Self-Assessmer.'t Program

. Quarterly Performance " Windows" Conduct of Self-Assessnient O

O i

Performance Measures The following performance measures are being used on an on-going basis to monitor this Key issue:

. Condition Report Method of Discovery - By Unit l

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V Millstone Station / Unit 3 Third Quarter Performance Report

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23 Third Quarter Status Self-Assessment Assessment Instrument Assessment Title Schedule Completed Revised I Date (Y/N) Schedule if Not Complete Quarterly Self-Assessment of September Y Performance " Windows" 30,1998 INPO Evaluation and Assessment August 14, Y l of Unit 3 and Site Programs 1998 Assessment Results The following summarizes the results of the self-assessment activities:

. Quarterly Self-Assessment. In October 1998, the Millstone Performance Windows third quarter assessment rated self-b assessment as satisfactory compared to the INPO 97-002 criteria.

. INPO Plant Evaluation, conducted on Unit 3 in August 1998, identified no self-assessment program weaknesses. INPO recognized two noteworthy self assessment strengths in the program areas of:

. Use of work observation training including mock-up scenarios to improve obsentation and coaching skills, and

. Use of management advisory board to promote self-assessment initiatives, and provide feedback on quality of self-assessment reports Performance Measures Condition Report Method of Discovery - Unit 3 KPI A-2: This indicator relates to both success criteria. Self-identified issues have demonstrated satisfactory level of performance and achieved the station goal of greater than 90% and was also greater than the Unit 3 operational goal of greater than 95%.

The number of Condition Reports (~800) initiated during the third quarter following the Unit's retum to service declined, as expected, over the first two quarters of 1998 when Unit 3 was in recovery. During the third Millstone Station / Unit 3 Third Quarter Performance Report

24 O quarter,10 CRs (~1%) each resulted from either events or extemal V oversight with about 7% being identified by intemal oversight.

While Unit 3's performance is characteristic of a plant immediately following a retum to service after an extended shutdown, challenges to the operators are higher than desired and are receiving management attention.

Conclusions An environment reflecting a questioning attitude od self-identification at Millstone is meeting management expectations. The self-assessment culture and program performance are determined to be at a satisfactory level to support the continued safe operation of Unit 3.

More than 95% of Unit 3 issues are self-identified with no programmatic issues identified by internal or extemal oversight.

O f

O Millstone Station / Unit 3 Third Quarter Performance Report

25 Key issue: Corrective Action l

Success Criteria The following Success Criteria are established and summarize the performance baseline for this Key issue:

Demonstrate that a low threshold exists for identifying conditions adverse to quality related to human performance by a high ratio of precursor errors to near misses and breakthrough events.

. The ratio of self-identified to extemally identified conditions adverse to quality continues to increase

. High quality corrective action plans are provided within 30 days of identification

. Corrective actions are completed in accordance with a schedule established in the action plan

. Corrective actions are effective in resolving the issue Adverse trends are resolved within six months of identification and do not recur Self-Assessments The following self-assessments are currently planned for 1998:

. Monthly Unit Trend Reports

. Quarterly Unit Trend Reports

. Quarterly Station-wide Integrated Trend Report

. Bi weekly Assessment of the Corrective Action Program

. Semi-Annual Nuclear Oversight Corrective Action Program Audit 3rd Quarter

. HPES Effectiveness - 2nd Quarter

. Condition Report Closure Package Quality - 3rd Quarter

. Level 1 CR Root Cause Effectiveness - 4th Quarter r

k Millstone Station / Unit 3 Third Quarter Performance Fleport

26 O Performance Measures Trend reports track corrective action system key parameters on a monthly and quarterly basis for each unit as well as for the station. The following performance measures are being used on an on-going basis to monitor this Key issue:

Timeliness of Screening CRs for Operability and Reportability

. Condition Report Evaluation Timeliness

. Condition Report Evaluation Quality Score

. Median Age of Open CRs Level 1 & 2

. Overdue Corrective Actions

. Condition Report Method of Discovery

. Recurrence of Significant Conditions Adverse to Quality

. Human Performance Third ' Quarter Status Corrective Action O

V Assessment Instruments The following assessments of Unit 3 performance in the area of Corrective Action were scheduled during the third quarter of 1998.

Assessment Title Schedule Completed ' Revised Date (Y/N).  : Schedule if Not Complete Monthly Unit Trend Reports Monthly Y Ouarterly Unit Trend Reports 9/98 Y Ouarterly Station Wide Integrated 9/98 Y Trend Report CR Clocure Package Quality 3rd ,

N Data collected, Our".. I report in progress Bi-weekly Assessment of Unit Bi-weekly Y Management Nuclear Oversight Semi-Annual 9/98 Y Corrective Action Audit

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G i Millstone Station / Unit 3 Third Quarter Performance Report i

27 j i

. r Assessment Title Schedule Completed . Revised

, '( Date (Y/N)- Schedule if Not Complete =

Joint Utility Management 6/98 Y Assessment INPO Evaluation 9/98 Y Assessment Results

! Monthly / Quarterly Trend Reports Monthly and quarterly trend reports for Unit 3 indicate that the areas of I operations configuration control, tagging, performance of safety evaluations, implementation of administrative requirennents of the action

, tracking program, and violations of administrative overtime controls L require continued management attention because the adverse trends in j these areas have not been satisfactorily resolved.

Quarterly Station-Wide Integrated Trend Report q No Unit 3 specific trends were identified in the Station Trend Report. A Q' site wide adverse trend of non-compliance with RAC 13, " Organizational i Changes" was self-identified. All corrective actions are complete. l 1 'l Bi-weekly Assessment of Unit Management i

i- Overall assessment of Unit 3 management at the end of the third quarter j

was tracking to satisfactory. Two areas, Condition Report evaluation

~

]: timeliness and age of open Condition Reports, did not meet expectations for the third quarter in a row. In addition, overdue corrective actions do i not meet management expectations. The Unit i.eadership Team reviews i these indicators on a weekly basis to provide focus for improved

performance.

i Nuclear Oversight Semi-Annual Corrective Action Audit The Nuclear Oversight Semi-annual Audit of the Corrective Action Program was completed on September 18,1998. No Findings and two i deficiencies were identified. This is a significant improvement from the previous two Audits. The two deficiencies were attributed to Unit 2 implementation of the Corrective Action program.

a Millstone Station / Unit 3 Third Quarter Performance Report

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28 l

O Joint Utility Management Assessment

'V l The Joint Utility Management Assessment (JUMA) found that significant

! improvement has occurred in the development and implementation of an effective Corrective Action Program. Additional areas for improvement were greater consistency in addressing the cause of a condition rather

than the symptom and reducing the administrative burden of the process.

CR M3-98-3163 addresses these issues. ,

1 INPO Evaluation l

There were no findings for the Corrective Action Program identified in the INPO Evaluation. Self-assessment was identified as a strength. l However, in other areas evaluated there were observations of untimely and ineffective corrective actions. These deficiencies are identified by ,

Condition Reports and will be resolved by the affected organizations.

Performance Measures A review of the Unit 3 Corrective Action Key Performance Indicators reveals the following:

i(]

. During the quarter 100 % of CRs received a screening for operability or reportability within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of initiation.

. Condition Report Method of Discovery KPI A-2. This indicator relates to success criteria 2,5 and 6. During the quarter, the perceiit of self-identified CRs continued to increase. The number of Condition Reports (-800) initiated during the third quarter following the Unit's retum to service declined, as expected, over the first two quarters of 1998 when Unit 3 was in recovery. During the third quarter,10 CRs

(-1%) each resulted from either events or extemal oversight with about 7% being identified by internal oversight.

. Condition Report Evaluation Timeliness KPI A-1. This indicator relates to success criterion 3. The average age ranged from 22-44 days with the quarter average of 36 days versus the station goal of less than 30 days at the end of the quarter.

. Condition Report Evaluation Quality Score KPI A-4 Action plan quality remained above the goal of 3 on a scale of 0 to 4.

l . Median Age of Level 1 & 2 CRs. KPI E-1. This indicator relates to

! success criterion 4. The median age at the end of September is indicated below and shown on KPI E-1. The stated goal is a declining l

g) i trend.

Millstone Station / Unit 3 Third Quarter Performance Report

29 1

1 (3 '

V Time in Days CR Level 1 (20/30) CR Level 2 (20/30)

All CRs 243/275 202/227 Oversight initiated 218/290 223/295 Extemally initiated 204/296 153/245 Although the number of open Condition Reports has decreased over the quarter, the median age has continued to increase. In addition, the median age of internal and extemal oversight initiated CRs has increased at a higher rate, This indicates that greater attention is being paid to the more recent CRs at the expense of those initiated in previous years. Following analysis of the reasons for the increasing age and relative disparity in resolution timeliness between self-identified by intemal and extemal oversight, a strategy to reverse the trend will be implemented.

. Overdue Corrective Actions KPl A-3. This indicator relates to success criterion 4. The average overdue corrective actions showed a slight increase to 3.4 % for the second quarter in a row and has not O

() achieved the operational goal of less than 1% overdue. The Unit Leadership Team reviews this indicator on a weekly basis to provide focus for improved performance.

1

. Human Performance KPl A-9 This indicator relates to success I criterion 1. The percentage of low significance (precursor) errors in the third quarter ranged from 90% to 97% versus the goal of 95%. This is an improvement over the first two quarters which ranged from 83% to 91%. While there were no human error related events and only one near miss in September, the small data set indicated a decrease in performance. This area will be monitored to determine if the threshold for reporting human performance issues is increasing or precursor human performance errors are not recognized by personnel analyzing l the coding data.

Conclusions The Corrective Action Program is functioning effectively; however, Unit 3 performance in this area has remained relatively unchanged subsequent to Unit restart. There has been senior management focus in the area of timely investigations and action completion and performance is slowly improving.

Millstone Station / Unit 3 Third Quarter Performance Report

30

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A high percentage of issues are self-identified (>90%). High quality action

's plans are provided within 30 days. Overdue Corrective actions remain a challenge for Unit 3.

The primary management focus has been on reducing the pre-restart ,

backlog while trying to maintain sustained good day-to-day pedormance.  !

When the backlog is under control, performance should improve in the l weak areas identified above. Ad hoc focused efforts have been  !

successfulin reducing the number of open Condition Reports, but i sustained day-to-day performance will be the key to reaching excellence.  !

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l Millstone Station / Unit 3 Third Quarter Performance Report

j 31 Key lasue: Oversight -

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Success Criteria The following Success Criteria have been established and summarize the 4

performance baseline for this Key Issue:

. Majority of station problems are self-identified

. Oversight Condition Reports are addressed by line organizations in a timely manner  !

. Oversight is effectively assessing the performance of line I organizations l

Self-Assessments l

The following self-assessments are currently planned for 1998.

First Quarter

. /N

. Audits and Evaluations: Line management feedback

. Audits and Evaluations: Achievement of Nuclear Oversight Mission Statement; and clarity on standards, expectations and goals.

. Analysis and Programs: Operating Experience Program (Vendor notification) '

. Audits and Evaluation: Station Self Assessment Program

. . Audits and Evaluation: Training

• Performance Evaluation: Implementation of recommendations of the independent Assessment Team i

. Performance Evaluation: Training l

. Analysis and Programs: Recovery Oversight - Training and Qualification Second Quarter i

. Analysis and Programs: Nuclear Safety Engineering (NSE) - Operating Experience Program (Vendor notification)

. Analysis and Programs: Issues Resolution in Analysis and Programs

. Analysis and Programs: NSE-independent Safety Engineering Evaluation (Customer Satisfaction)

. Audits and Evaluation: Training Effectiveness - Audit Program

. Performance Evaluation: Training Effectiveness - OC Inspector Program

. Performance Evaluation: Continuing Training Program Third Quarter

. Audits and Evaluation: Benchmark the number of audits / assessments p

d Performance Evaluation: Oversight Training Effectiveness Analysis and Programs: Oversight Corrective Action Effectiveness Millstone Station / Unit 3 Third Quarter Performance Report

l 32 A .

Performance Evaluation: Effectiveness of Integration Meetings k-) . Performance Evaluation: Follow-up to Self-Assessment in Work Control Process

. Analysis and Programs: NSE Customer Satisfaction ,

Performance Evaluation: Customer Satisfaction l Fourth Quarter Analysis and Programs: Self-Assessment Process in Nuclear Oversight a Analysis and Programs: Revised NOVP Process

. Audits and Evaluation: Oversight Training Effectiveness Numerous audits and surveillances as well as other assessments are also routinely conducted by Nuclear Oversight which are described in the table.

Performance Measures The following performance measures are being used for the on-going monitoring of this Key Issue:

. Condition Report Method of Discovery j

. Status of Oversight Condition Reports, Millstone Unit 3

. Nuclear Oversight Verification Plan l

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J Millstone Station / Unit 3 Third Quarter Performance Report

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!U Third Quarter Status Oversight

! Assessment Instruments Assessment Title Schedule Completed Revised

, Date (Y/N) Schedule if l Not t Complete L Self-Assessments Pedormance Evaluation: 2nd Y

Customer Satisfaction Quarter l Analysis and Programs: 2nd N Nov. 98 i Customer Satisfaction Quarter l Performance Evaluation: 3rd N Oct. 98 Oversight Training Effectiveness Quarter Audits and Evaluation:

3rd N Nov. 98 Benchmark number of Quarter 1 audits / assessments pedormed by similar plants / stations Analysis and Programs: 3rd N Nov. 98 lr]

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Oversight Corrective Action Effectiveness Performance Evaluation: Follow-Quarter 3rd N Oct. 98 up Self-Assessment in Work Quarter Control Process Effectiveness of Oversight 3rd N Dec 98 Integration Meetings Quarter Audits

! Audit MP-98-A18, " Corrective 3rd Y l Action" Quarter -

Audit MP-98-A19," Security" 3rd Y Quarter Audit MP-98-A09, " Chemistry" 3rd Y Ouader Audit MP-98-A13, " Technical 3rd Y Training Qualification" Quarter A udit MP-98-A15, " Measuring 3rd Y

_ and Test Equipment" Quarter Aud't MP-98-A16," Fire 3rd Y Prowction" Quarter Surveillances Surveillance MP3-P-98-058, September Y

" Operations" Surveillance MP3-P-98-057, " Plant

/' Support"

( Surveillance MP3-P-98-050.

Millstone Station / Unit 3 Third Quarter Performance Report

-- . . - . - . . - . . - . ~. .. . . . . . . . . - - - -. . ..

34

'Q-Assessment Title -Schedule Completed Revised V Date (Y/N) Schedule if Not l Complete

" Engineering" Surveillance MP3-P-98-053, September Y

" Maintenance" cont.

Surveillance MP3-P-98-049,.

• 1mplementation and Control of Work" Surveillance MP3-P-98-046,

)

August Y i

" Operations" j

Surveillance MP3-P-98 051, " Plant i Support" l

Surveillance MP3-P-98-043,  ;

" Engineering" Surveillance MP3-P-98-045, )

j

" Maintenance"

)

Surveillance MP3-P-98-047,

" implementation and Control of Work" ,

i Surveillance MP3-P-98-042, July Y

• Operations".

Surveillance MP3-P-98-037, " Critical Maintenance" O Surveillance MP3-P-98-036,

-Q

• Engineering" Surveillance MP3-P-98-044, " Plant Support" Surveillance MP3-P-98-041, " Plant Housekeeping" -

Other Assessments "RSS Cubicle Sump Pump (DCR 3rd Y M3-97079)" Quarter Joint Utility hdanagement 2nd Y Assessment (JUMA) Quarter 98

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Millstone Station / Unit 3 Third Quarter Performance Report

l 35 O Self-Assessments Results V l Performance Evaluation - Customer Satisfaction l

The assessment concluded that the Performance Evaluation section of Oversight is providing constructive feedback in a professional manner; however, the timeliness of feedback could be improved.

Audit Results l

Audit MP-98-A18," Corrective Action" The scope of this the Millstone Station audit was to determine the effectiveness of the Units 1,2 and 3 Corrective Action Program implementation by assessing issue evaluation, corrective action implementation, trending, and self-assessment. The audit focused primarily on correcting identified problems, specifically, whether the described problems in Condition Reports (CRs) completed and closed i within the past six months had been corrected. There were no issues identified on Unit 3.

l

(^3 Audit MP-98-A19, " Security" V

The scope of the Millstone Station audit was to determine the adequacy of the Physical Security Plan and the Contingency Plan to meet regulatory requirements and the effectiveness of the programs and procedures in '

place to implement security requirements. The audit determined that the Security Program is being effectively implemented and meets regulatory requirements.

Audit MP-98-A09, " Chemistry" The scope of the Chemistry audit included verification that the responsibilities of Chemistry and support groups at Millstone are clearly defined and documented in accordance with licensing commitments, in addition, the areas of laboratory safety, Technical Specification Surveillance Program support for Unit 3, self-assessments, Training and Corrective Action were also assessed. One Level 2 Condition Report was

, issued conceming Transient Limits which exceeded parameter limits as identified in the Final Safety Analysis Report.

Audit MP A13, " Technical Training Qualification" p The scope of the Millstone Station audit included the followlag: 1)

V Training and Qualification of Electrical Maintenance personne.3, t

Millstone Station / Unit 3 Third Quarter Performance Report

36 l

l p Mechanical Maintenance personnel, and Instrument & Control personnel; d 2) the Training Program for Maintenance Supervisor, and 3)

Implementation of the Millstone Corrective Action Procram including self-assessments and follow-up activities from the 1997 Millstu 3 Training ,

Audit. Both the training and qualification of maintenance personnel were l determined to be effective.

Audit MP-98-A15, " Measuring and Test Equipment" t

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l l The scope of the Millstone Station audit was to review the compliar ce and '

implementation of the Measuring and Test Equipment Program. Although

! there was a weakness identified with M&TE NCR dispositions, marked l improvement has been demonstrated since the previous audit performed l in August 1996.

Audit MP-98-A16, " Fire Protection" The scope of the Millstone Station audit included: Organization, Design Criteria, Fire Prevention, Testing, impairments, Training / Qualifications of the Fire Brigade, Offsite Fire Department and Engineering, Personnel, l Fire Protection, Quality Assurance Program, Appendix "R"/BTP 9.5-1, l Self-Assessments, and Corrective Action. The Millstone Fire Protection I p Program is continually improving and there is an increased level of l V Management attention and teamwork which was not evident in the audits I performed in 1996 and 1997. A lack of sufficient resources in Unit 2 could impact the time to complete open issues at Unit 3. The Unit 3 Operations Department continues to have a backlog of lapsed fire protection i surveillances which necessitates compensatory measures. j 1

Surveillances Results 1

Surveillances are the principal inputs for the NOVP unit specific areas.

These surveillances are based on multiple field observations utilizing i attributes derived from NU, INPO, and NRC documents and other sources which provide standards and guidance for the surveillances. Area performance is depicted by a " window" color code: " green" - excellent, '

" white" - satisfactory, " yellow" -needs improvement, " blue" - not assessed and " red"- significant weakness. For purposes of continuity in this quarterly report, ratings of " white" and " green" are reported as " green" or l satisfactory. Color indicators of yellow, white, and green represent l performance above the threshold for safe operations.

1 A summary of Unit 3 NOVP in areas which include the Key issues is provided below:

. Operations-Green. The rating changed from yellow to green during the quarter. Conservative decision-making, improved pre-job briefs

(

v ) and adherence to procedures minimized the challenges to safe l Millstone Station / Unit 3 Third Quarter Performance Report l

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37 i

' (' operation during power manipulations. Weekly management meetings have led to improved communication. While performance showed some improvement over the quarter, especially within the control room, some areas require continued attention including: reliability of communication equipment, identification of minor deficiencies which affect materiel condition, control room protocol of non-operations personnel and operation's ability to identify and effectively address operator burdens.

]

. Work Control / Maintenance-Yellow. Improvements have been noted in both areas during the quarter; however, some aspects are not improving as quickly as expected. Observations of work activities did not identify any significant issues. Increased supervisory presence  ;

during field activities and improved accountability for workers not in l compliance with procedures are areas requiring management focus.

Better identification of post-maintenance testing during the planning i stages of work orders could result in improved work flow.

. Engineering-Yellow. The quality of temporary modifications, and  !

technical support for safe operation of the plant, and system readiness l reports were judged satisfactory. A weakness was noted regarding the  ;

organizational ownership and operational focus of system engineering. i Ownership and proactive involvement in addressing system equipment problems is needed. Another weakness was noted regarding a lack of complete understanding of single failure assumptions related to Technical Specification Action Statements. During the third quarter, engineering management established a unit Engineering Quality Review Board which has resulted in some improvements and is expected to substantially improve the quality of engineering products over time. l

. Self-Assessment-Blue. Not assessed monthly as a separate topic area until October. The overall performance in this area for the third quarter is considered to be green. Self-assessments are critical and provide effective means for performance improvement. The Self-Assessment Advisory Board monitors implementation of the Self- 1 Assessment program, provides consistent standards, and shares lessons leamed among work groups. i i . Corrective Action--Blue. Not assessed monthly as a separate topic area until October. The overall performance in this area for the third quarter is considered to be Yellow. The threshold for reporting issues continues to be low as evidenced by the large number of Condition

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Reports being generated for Unit 3 in the first three quarters of 1998.

! Improvements are needed to achieve KPI goals, to assure consistent i

quality in root cause efforts and to improve departmental level training.

lO Millstone Station / Unit 3 Third Quarter Performance Report

1 38

/3- . Health Physics and Chemistry-Green. Health Physics and l V Chemistry continue to be pro-active in raising standards as evidenced '

by a high percentage of self-identified issues. Improvement to raise programs to top industry practice include: better HP planning for work under one rem expected exposure and tighter controls on Radiation Work Permits to decrease traffic through radiation areas.

. Common Site Programs (Security, Emergency Planning, Training and Environmenta! Protection)-Green. Reviews indicate sustained site-wide performance.

1 Other Assessment Results i JUMA - Joint Utility Management Assessment ]

As reported in the Second Quarter Performance Report, the annual Joint Utility Management Assessment (JUMA), as required by the Northeast l Utilities Quality Assurance Program (NUQAP) Topical Report, was

, performed during the week of June 22,1998. Action Assignments with due dates were entered into the Action item Tracking and Trending System (AITTS) related to the areas of corrective action effectiveness, n communications, teamwork and trust, and Oversight work product quality.

t V in addition, Oversight generated a Level 3 Condition Report to track additional actions for review that the JUMA Team identified as areas for improvement within Oversight.

"RSS Cubicle Sump Pump (DCR M3-97079)"

l The scope of the assessment was to determine whether the revision to modification DCR M3-97079 had been acceptably developed. The DCR had been revised based on issues identified by the NRC and an Event l Review Team. The assessment independently reviewed the revised design to ensure that the design package and safety evaluations were acceptable, the affected configuration management related documents were acceptably developed, and previous corrective actions were satisfactorily resolved. There were no issues identified.

Performance Measures I Indicator: Condition Report Method of Discovery - Millstone i Unit 3 KPI A-2 Status: The Station goal of less than 10% of Condition t , Reports identified by events and extemal sources g,3 . was achieved and maintained for the majority of the l

L Millstone Statiorv' Unit 3 Third Quarter Performance Report l

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l 39 reporting period. The enhanced Unit 3 goal of less i than 5% of Condition Reports identified by events and extemal sources was achieved at the end of the quarter. This indicator relates to the first success l cnterion.

Indicator: Status of Oversight Condition Reports - Millstone l

Unit 3 C-1 Status:

Performance has been tracking to satisfactory since July. However, the timeliness of evaluations for i Oversight generated Condition Reports does not j appear to be improving at the same rate as timeliness l for all Unit 3 Condition Reports as reflected in the Unit 3 KPI, Condition Report Evaluation Timeliness.

i Indicator: Nuclear Oversight Verification Plan - Millstone Unit 3 C-2 Status: Overall performance of Unit 3 needs to improve and j sustain satisfactory performance in several areas.

Conclusions I

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Nuclear Oversight programs are effective. A high percentage of Unit issues are self-identified (>95%) thereby meeting management l goals and expectations. l t 1 Oversight generated Condition Reports are given appropriate l attention by the line organizations. However, the timeliness of l evaluations does not appear to be improving at the same rate as ,

the timeliness for all Condition Reports. The reasons for this )

apparent disparity will be evaluated and any necessary remedial  ;

actions implemented.

The overall Unit 3 performance as assessed by the NOVP needs improvement to achieve excellence with some noted exceptions.

The level of performance has been essentially at a plateau since the July completion of the power ascension program.

Self-assessments continue to identify areas for improvement within Nuclear Oversight and actions are either underway or will be initiated to assure each of those opportunities are addressed.

However, Oversight management must increase attention to assuring self-assessments are completed on schedule. All self-

! assessments presently planned for 1998 will be completed by year

'g end.

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Millstone Station / Unit 3 Third Quarter Performance Report I

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Key issue: Configuration Management l l

Success Criteria The following Success Criteria were established for station recovery and  !

summarize the performance baseline for this Key Issue for the third quarter:

. The Configuration Management Program documents, verifies and validates the licensing and design bases requirements

. The Configuration Management Program provides retrievable documentation

. The Configuration Management Program provides reasonable assurance that adequate programs and processes are being implemented to maintain configuration control The above Success Criteria will be revised during the next reporting period to reflect the next evolutionary step beyond the documentation and b) validation of the existing licensing and design bases. These operational Success Criteria will be aligned with the maintenance of the established l design and licensing bases, and the identification and resolution of the loss of configuration management. The following are preliminary Success Criteria which will be utilized to assess performance for this Key issue for the next quarterly performance report.

. Programs and processes for maintaining design and licensing bases configuration requirements function satisfactorily

. Adverse conditions associated with loss of configuration management are satisfactorily identified and captured for resolution in the Corrective Action Program

. Programs and processes for maintaining design and licensing bases configuration requirements produce quality products Self-Assessments l During the third quarter of 1998, the Unit Configuration Management (CM) l Teams for Units 2 and 3 were combined into a single team in order to l ensure comrnon approaches across units.

Millstone Station / Unit 3 Third Quaster Performance Report

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' .O V The following self-assessments were planed for 1998:

First Quarter I

. FSAR Changes- Engineering Assurance Assecsment

. ESAR Corrective Actions Follow-up ,

. Setpoints PDDS

. OA Software

. Mechanical Design Setpoints - MP3 1

. Conduct of Off-Site Engineering Contracts - MP3 I

. In-Service Test Program Second Quarter l

. Follow-up Assessment from PES-97-020 (dated 4/16/98)

. MP3 Technical Specification Review (3 CMT-98-001, dated 4/29/98)

Corrective Action Effectiveness Review (CM Related) (PES-SA 002, dated 6/9/98)

. Corrective Action Effectiveness Review (Departmental) (PES-SA 017, dated 6/8/98)

(O

%)

Third Quarter

. Attention to Engineering Quality (PES-SA-98-039, dated 7/10/98 and included in previous report)

. MP3 Engineering Qualification Record Status (PES-SA-98-041, dated 7/5/98 and included in previous report)

. Calculations (PES-SA-98-009, dated 7/10/98 and included in previous report)

. PDDS Relief Valve Setpoints (PES-SA-98-003, dated 8/6/98)

Review of Minor Modifications (PES-SA-98-042 dated 9/23/98)

. Review of Material Issue and Control Processes (PES-SA-98-044, report in progress)

Fourth Quarter

. Review of Design Change Records / Minor Modifications (PES-SA 007)

. Review of Temporary Modifications (PES-SA-98-008,)

Corrective Actions Effectiveness Review (PES-SA-98-045) l Millstono Station / Unit 3 Third Quarter Performance Report

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1 Performance Measures l The following performance measures will be used for the on-going monitoring of this Key issue:

. Configuration Management Summary - CM Awareness Third Quarter Status Configuration Management Assessment instrument Assessment Title Schedule Completed Revised Date (Y/N) Schedule if Not Complete PDDS Relief Valve Setpoints 3rd Quarter Y PES-SA-98-003 98 Review of Minor Modifications 3rd Quarter Y

^(U2-CMT-98-004/3CMT-SA 98 04)

N PES-SA-98-042

! (d

\ Review of Materialissue and Control Processes (3CMT-SA-3rd Quarter 98 N November 1998 98-06)

PES-SA-98-044 i

Assessment Results PES SA-98-003,"PDDS Relief Valve Setpoints" The objective of this self-assessment was to determine the effectiveness of the MP3 Plant Design Data System (PDDS) Relief Valve Setpoint process for control of relief valve setpoints. It was determined that the l PDDS Process for control of relief valve setpoints was weak and labor

intensive to implement. The process was considered weak because other sources for the setpoints were found to contradict the information contained in PDDS. Although this did not result in a loss of configuration l control for the twenty six (26) relief valves reviewed, it was recommended i that the scope of the review should be expanded to include the remaining l safety related relief valves. Consolidation of relief valve setpoints into a j single database was recommended as a configuration neanagement i enhancement to provide further assurance that the correct relief valve

, setpoints are used on a going forward basis.

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i Millstone Station / Unit 3 Third Quarter Performance Report l

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/^g PES-SA-98-042," Review of Minor Modifications" lV The objective of this self-assessment was to determine the effectiveness I i

of the review of Minor Modifications (MMODs) by the Configuration Management Team (CMT). It was concluded that the CMT MMOD package reviews were effective in ensuring that proposed design changes maintain the Licensing Bases (LB) and the Design Bases (DB),

and that the design change process was adhered to by the Design

( Engineer. Minor improvements to the CMT review process were identified L and are being addressed.

L 1 I

l l Performance Measures I i

i indicator: Summary Configuration Management--CM Awareness.

i' KPl L-1 l Status: This KPl shows the Unit's Configuration Management awareness by identifying whether a CM related CR is i proactive (Self or Line management initiated) or reactive l (intemal/extemal oversight initiated or event related). The l KPl identified improvement in the awareness to and self-t identification of Configuration Management issues. The table

\

! below indicates the range of percent proactive Condition Reports generated for each of the four CM areas.

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l l Configuration - . % Proactive CRs - I Management Area (versus 80%_ goal). )

Range for the Quarter - i 10 20 30 Design Bases 43-55 53-86 89-100 Licensing Bases 55-67 60-65 60-83 Operations 60-93 59-79 82-86 Miscellaneous 65-71 67-86 71-87 Conclusions Self-assessments and KPls indicate that the Configuration Management processes are adequate. However, self-assessments and CRs continue to identify " attention to detail" problems related to implementation of these processes. These areas are receiving appropriate management attention.

! Performance with respect to configuration management is assessed to be at a satisfactory level to support continued safe operation.

l Millstone Station / Unit 3 Third Quarter Performance Report l

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r.

(_) As discussed above, the Success Criteria for this Key issue are being revised 1

' to reflect an operations focus. The new Success Criteria will be aligned with the maintenance of the established design and licensing bases, and the l identification and resolution of the loss of configuration management. .

Consequently, performance measures will also be revised. The new Success  !

Criteria and performance measures will be finalized and utilized to assess l performance for this Key issue for future quarterly performance reports.

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Millstone Station / Unit 3 Third Quarter Performance Report i

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V Key Issue: Regulatory Compliance l

Success Criteria The following Success Criteria are established and summarize the performance baseline for this Key issue:

. Processes for maintaining the Licensing Basis function satisfactorily

. NRC commitments and obligations are being met

. Regulatory evaluations, correspondence, and communications are complete, accurate, and timely Self- Assessments The following self-assessments were planned for 1998:

. Effectiveness of Corrective Actions Related to the Key issue of Regulatory Compliance - 1st Qtr,1998 q . Effectiveness / Compliance with RAC 08," Regulatory Communication

.'V and Docketed Correspondence" - 2nd Qtr,1998

. Effectiveness / Compliance with RAC 01, " Licensing Basis Management" - 3rd Otr,1998

. Effectiveness / compliance with RAC 06, Regulatory Commitment Management Program"- Substituted root cause evaluation for CR M3-98-2293

. Effectiveness / compliance with RAC 03," Changes and Revisions to Final Safety Analysis Reports"- Substituted and completed by PES-98-001,"MP 3 Engineering FSAR Change Requests Assessment" (complete), common cause NOV 201-06 and U2-DE-98-012," Station Procedure Consistency with MP2 FSAR"

. Effectiveness / Compliance with RAC 13, " Organizational Changes" -

Substituted root cause evaluation for CR M3-98-2119.

. Effectiveness / compliance with RAC 05,"10CFR50.72 Notification, 10CFR50.73 and 10CFR50.9(b) Reportability Determinations, and Licensee Event Reports"- Postponed to 1999

. Effectiveness / compliance with RAC 02, " Technical Specification Change Requests and Implementation of License Amendments"-

Substituted and completed by Oversight Assessment of License Amendment Request Implementation

. Department trainirig/ qualification effectiveness - 4th Otr.1998 Millstone Station / Unit 3 Third Quarter Performance Report

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Performance Measures The following performance measures are being used for the on going monitoring of this Key issue:

Comoliance Manaaement

. Licensee Event Reports

. Notices of Violation

. Inspection items i

. Pre-Restart Backlog )

License Basis Manaaement

. Docketed Correspondence

. Technical Specification Change Requests

. FSAR Change Requests l

. License Basis Condition Reports (Link to Corrective Actions Program)

. Regulatory Commitments .

l O Third Quarter Status Regulatory Compliance l

4 Assessment Results I Six (6) assessments were performed relating to the Key issue of Regulatory Compliance during the period July 1998 through September

. 1998. This brings the total to 18 assessments in this key area for the

year-to-date. The six assessments are tabulated and summarized below.

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Millstone Station / Unit 3 Third Quarter Performance Report I

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47 A

b,l ' Assessment Title Schedule Completed Revised-Date (Y/N). Schedule if Not Complete RAC01 Licensing Basis 3rd Otr. Y NA Management - Step 1.3.4, Regulatoy Performance Monitoring (3RAC-SA-98-03)

Common Cause D'etermination, Not Y NA NOV 201-06: Licensee Made previously

' Minor Changes to FSAR scheduled l'rw ings in Late 1997, But failed tn Perform Safety Evalt.stions Pursuant to RequiremenL> of 10CFR50.59(A)(l)

Stalon Procedure Cor'sistency Not Y NA with MP2 FSAR previously (U2-DE-G8-012) scheduled 50.54(f) Recovery Oversight Not Y NA Assessment Report, MP2 previously License Amendment Requests scheduled 50.54(f) Recovery Oversight Not Y NA O Assessment Report, MP2 previously Technical Requirements Manual scheduled (TRM)

Assessment of Safety Not Y NA Evaluation Screening previously Effectiveness scheduled Assessment Results RAC01 Licensing Basis Management - Step 1.3.4, Regulatory Performance Monitoring (3RAC-SA-98-03)- This assessment evaluated the effectiveness of the regulatory performance monitoring program in place to ensure overall quality, effectiveness and consistency of licensing basis management processes. The assessment concluded that the regulatory performance measures currently established are " sufficient to identify significant regulatory performance weaknesses." The assessment noted that standards have been set, goals have been established, performance is being measured, and information is being evaluated.

Although no condition adverse to quality was identified, the assessment noted that regulatory compliance management was not using the regulatory performance monitoring results and recommended that the monitoring program be reassessed to provide management with a more p'%)

Millstone Station / Unit 3 Third Quarter Performance Report

4 48 I i

useful report to assess day-to-day performance. This improvement item l . is being tracked by Condition Report M2-98-2926. )

i l Common Cause Determination, NOV201-06: Licensee Made Minor 1 Changes to FSAR Drawings in Late 1997, But Failed to Perform Safety Evaluations Pursuant to Requirements of 10CFR50.59(A)(l)-

This determination investigated a failure to meet requirements of 10CFR50.5. Changes were made to Piping and Instrumentation Drawings  !

in the FSAR without performing a safety evaluation, instead generic safety evaluation that did not bound the change was referenced. The failure was l caused by raised standards in station procedures coupled with knowledge i based human error. Thus, while the processes in place are correct, l implementation did not always meet standards. The changes to the 1

[ drawings were administrative in nature and did not rise to the level of a reportable event or of any safety significance. Corrective actions included revision to the generic safety evaluation to clearly include instrumentation i detail corrections on the drawings, and management reinforcement of

standards. l l

, Sta. ion Procedure Consistency with MP2 FSAR (U2-DE-98-012) - This L -self-assessment investigated whether statements in the MP2 FSAR were l consistent with and fully supported in applicable station procedures. The l P - results of the assessment identified discrepancies between the plant l1 procedures, FSAR, and Piping & Instrumentation Drawings. Condition L Report M2-98-1974 was issued to address these discrepancies. The effort to assure that the MP2 FSAR is accurately reflected in station procedures is an ongoing part of the MP2 recovery effort Standards in the procedure are adequate. Implementation remains a management focus item.

i l 50.54(f) Recovery Oversight Assessment Report, MP2 License Amendment Requests -The assessment focused on the effectiveness

( of processing and implementation of recent license amendments for MP2.

! A similar assessment was performed for MP3, which uses the same

! station procedure as MP2 to process and implement approved license i amendments. The MP2 assessment found that alllicense amendment L reviewed were implemented within 30 days of approval, as required by the NRC. However, deficiencies in implementation were noted and five (5)

Condition Reports were issued to address these deficiencies. Two general areas required attention. These areas are performance of all

, required personnel briefing and procedure revisions prior to L implementation. These areas were also identified as issues in the MP3 l assessment and corrective actions to enhance process used to implement

license amendments are currently underway.

LG Millstone Station / Unit 3 Third Quarter Performance Report

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I 49 p 50.54(f) Recovery Oversight Assessment Report, MP2 Technical

LI Requirements Manual (TRM)- The TRM contains information which constitutes plant operating requirernents, but which is not specified in the Technical Specifications. An assessment was conducted of the Unit 2 TRM. This assessment had two objectives. The first was to ascertain whether the information in .he TRM was consistent with other plant  ;

documents. The second objective was to determine if TRM changes were controlled in accordance with procedural requirements. The assessment concluded that changes to the TRM were being made in accordance with procedures. However, the assessment revealed several instances where the TRM was not consistent with information in other plant documents. A total of five (5) Condition Reports were issued based on deficiencies noted in the assessment. The TRM change process is currently undergoing improvements and will be re-issued as a station-level l

- procedure applicable to all three Millstone units.

Assessment of Safety Evaluation Screening Effectiveness - At the 1 request of the Nuclear Safety Assessment Board an assessment of the implementation of the 10 CFR 50.59 safety evaluation screening process was performed. A total of 121 screens we re reviewed involving MP2 and  !

MP3 engineering, procedures, and procurement activities. All 121 screens reached the proper determination. The conclusion of this I

assessment is that the quality of safety evaluation screens is improving for (q j virtually all change processes. However, there is room for improvement and recommendations were provided to enhance the process further.

Performance Measures In addition to the above assessments, monitoring of performance against the Success Criteria was conducted using Unit 3 windows and Performance Indicators. Regulatory Performance at Millstone Station is performed by Regulatory Affairs and focuses more globally on station performance. The following summarizes Regulatory Compliance Performance ind :ators for the period from July 1998 to September 1998 for Unit 3.

Success Criterion 1 Contributors Assessments Results - The assessments discussed above show that the processes for maintaining the licensing basis are functioning satisfactorily.

Management is continuing to reinforce standards and address implementation performance. However, improvements in the control of TRM changes have been identified and are being addressed. Management is increasing programmatic attention on this process.

QJ Millstone StatiorVUnit 3 Third Quarter Performance Report

50 O Success Criterion 2 Contributors V

Regulatory Commitments - An additional seven Unit 3 commitments were completed after their due date. This indicates a procedural compliance problem and a Level 1 trend Condition Report (M3-98-4232) has been written to address this. Improvement has been noted in September due to having implemented corrective actions from the trend CR.

Management focus on commitments is continuing through procedure improvements and increased implementation oversight.

Unit 3 Pre-Restart Backlog - Unit 3 pre-restart backlogs are generally being reduced consistent with management expectations. Operator Burdens are higher than desired and are receiving increased management attention.

Success Criterion 3 Contributors Technical Specification Change Requests (TSCRs)- The process for preparation of TSCRs is functioning satisfactorily. The implementation focus is now shifting to dispositioning the backlog and providing for future submittals of TSCRs. Unit 3 performance is satisfactory.

FSAR Change Requests (FSARCRs)- The FSARCR process is (pj functioning satisfactorily and FSAR changes are being properly made.

Submittal of the third quarterly update was submitted on time. Unit 3 performance is satisfactory.

Licensee Event Reports (LER's)- The process for reportability determinations and LER preparation is functioning satisfactorily. The majority of Reportability Determinations are completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Licensee Event Reports (LER's) are consistently being submitted on a schedule which meets the 30 day requirement and they are materially complete and accurate. The number of LER's associated with historical design issues is declining and performance is trending toward the industry average. Unit 3 performance is satisfactory.

Docketed Correspondence - The process for preparation of docketed correspondence if functioning satisfactorily. The standard for validation packages has been raised. Other improvements to the process have been implemented to administratively improve the handling of docketed correspondence. Overall, Unit 3 performance is satisfactory.

Notices of Viviritions (NOrs) - NOV responses for Unit 3 have generally been submitted in a timely manner. Unit 3 performance is satisfactory.

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Millstone Station / Unit 3 Third Quarter Performance Report

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51 As the corrective actions addressing past violations received during the Unit

{V 3 Configuration Management effort are completed, the focus is on continuing to improve self-identification of potential problem areas and thus minimize the number of violations in the future.

Inspection items -The number of open inspection items is declining markedly. The focus now is on submitting closure packages for those items greater than two years old, followed by those greater than 1 year old.

License Basis Condition Reports -There were only four Level 2 CR's in July, August and September addressing RAC processes. These Level 2 CRs were indicative of necessary procedure enhancements. Therefore, the processes are functioning satisfactorily.

Conclusions The Regulatory Compliance Key Issue is satisfactory to support continued safe oporations. See the indicator KPI M-1. However, increased manage. 'ent attention is being focused on completing commitments in a more timely fashion. Regulatory processes (success criterion 1) and QC/

products (success criterion 3) are satisfactory. Commitment performance (success criterion 2) requires improvement and is receiving increased management attention.

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Millstone Station / Unit 3 Third Quarter Performance Report l

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i Key lssue: Training l

l Success Criteria The following Success Criteria have been established and summarize the I performance baseline for this Key issue:

! . Training programs are recognized as contributing to meeting Station priorities and maintaining and improving operational focus

. Nuclear Training programs are upgraded and ready to support continued safe operations for Unit 3. This is confirmed by Nuclear Training Management Self-Assessment and by Nuclear Oversight.

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Self-Assessments The following self-assessments are currently planned for 1998:

. Nuclear Training Department Procedures - 1st Quarter

. Shift Manager Qualifications - 1st Quarter

. Training Effective ess 5.05/5.06 - 1st Quarter

. Systematic Approv.0h to Training Effectiveness - 1st Quarter

. Feedback / Evaluation Process - 1st Quarter

. Corrective Action Effectiveness - 1st Quarter

. TO1 Implementation - 1st Quarter

. Procedure Compliance Effectiveness Review - 2nd Quarter l . Millstone Operator Training Programs - INPO ATV - 2nd Quarter

. Non-Accredited Training Programs - 2nd Quarter and 4th Quarter

. Process Computer and Simulator - Impact of implementation of Plant Design Changes (Unit 3) - 2nd Quarter

. Review of Simulator Design Changes (Unit 2) - 2nd Quarter

. Technical /ES Programs - 4th Quarter O

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Millstone Station / Unit 3 Third Quarter Performance Report l

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53 Performance Measures The following performance measures are being used on an on-going basis to monitor this Key issue:

. Executive Training Council Meetings

. Training Advisory Committee Meetings

. Curriculum Advisory Committee Meetings

. Simulator Availability Third Quarter Status Training

. Assessment Instrument Assessment Title Schedule Completed Revised Date (Y/N) Date TO 1 Implementation (New revision 3rd Otr 1998 N 4th Otr became effective 7/10/98) 1998 Procedure Compliance Effectiveness 3rd Qtr 1998 Y Review Nuclear Training Department 3rd Otr 1998 Y Records Management Practices NTD Feedback Process 3rd Qtr 1998 Y Simulator instructor Skills 3rd Otr 1998 Y On-the-Job Training / Evaluation 3rd Otr 1998 Y Assessment Results Nuclear Training Department Records Management Practices NTDSAG-98-P01: The scope of this assessment included the review of training records from Unit 1,2, & 3 Operator Training programs, interviews with operator training personnel, and review of Nuclear Training Department record keeping processes and practices. This assessment determined that training records are being appropriately and adequately maintained. This assessment also verified that the corrective actions implemented to correct previous deficiencies have been effective.

Millstone Station / Unit 3 Third Quarter Performance Report

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NTD Feedback Process, NTDSAG-98-F12: The objectives of this self-assessment were to determine if the present feedback process meets the criteria of Objective 8, " Systematic Evaluation of Training Effectiveness",

of ACAD 91-015, identify deficiencies in the process, and provide recommendations for improvement. This assessment determined that Objective 8 is fully met and that the overall process for capturing and evaluating change information for training material impact is effective and efficient.

Simulator instructor Skills, NTDSAG-98-F15: This focused self-assessment examined simulator instructor skills and the critiquing process to ensure that the training meets Nuclear Training Department expectations. The assessment found the simulator instructors were professional, knowledgeable, and effective in their delively of simulator training. Opportunities for improvement were identified in the reinforcement of management's expectations and post exercise critiques.

On-the-Job Training / Evaluation (OJT/E), NTDSAG-98-F14: The process of On-the-Job Training / Evaluation (OJT/E) was determined to adequately address the training and qualification requirements for personnel at Millstone Station. Recommendations were made in the assessment that will enhance and improve this process. A follow-up assessment will be conducted to evaluate the effectiveness of O recommended corrective actions.

Performance Measures Indicator: Executive Training Council Meeting KPI F-1 Status: The Executive Training Council has met the specified goal of one meeting per quarter.

Indicator: Training Advisory Committee Meeting KPl F-2 Curriculum Advisory Committee Meeting KPI F-3 Status: Training oversight committees have been restructured to focus more effectively on the areas of key training interest.

Separate Training Advisory Committees (TACs) are being established for accredited, non-accredited, and engineering support programs respectively.

This realignment from unit specific organizations is an effort to move toward consistency in training expectations across Millstone Station.

O Millstone Station / Unit 3 Third Quarter Performance Report

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55 g Indicator: Simulator Availability KPI F-4 1

Status: Simulator Availability for the second quarter was 100%,

exceeding the goal of 99%

Conclusions Performance continues to improve throughout the training process. Line management has increased their involvement in observing and assessing the training of their personnel. This is evidenced by 100% of all Unit 3 supervisors and managers completing Management Observations of training during the third quarter. However, line management needs to continin to focus more on issues where their support will improve training .

implementation and effectiveness. Training performance is determined to l be at a satisfactory level and fully supporting the continued safe operation of Unit 3.

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Millstone Station / Unit 3 Third Quarter Performance Report

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U Key issue: Operational Performance l

Success Criteria i l

With Millstone Unit 3 operational, the focus for this section shifts from I

" Readiness for Operation" to " Operational Performance."

l The following Success Criteria have been established and summarize the performance baseline for this Key issue: l Pedonnance Focus l

. Operational performance is consistent with established goals for excellence

. The plant is operated within the licensing basis including Technical  !

Specifications I e Confirm, by use of performance indicators, that operator burdens are minimized b

'd Self-Assessments The following self-assessments are currently planned for 1998:

. Administration and Organization (Unit 3) -1st Quarter

. Culture Survey -2nd Quarter

. Interface effectiveness between Operations and other departments (Unit 3)- 2nd Quarter.

Conduct of Ooerations (Unit 3) - 3rd Quarter

. Configuration Control (Unit 3)-4th Quarter.

. Effectiveness of Operations Department Corrective Action Program (Unit 3)-4th Quarter.

Performance Measures l'

The following performance measures are being used on an on-going basis to monitor this Key Issue:

Millstone Station / Unit 3 Third Quarter Performance Report

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Operational Performance Success Criterion l l_

g . Emergency System Actuations l

l . Diesel Generators Unavailability l

I . Auxiliary Feedwater Unavailability

. HPSI System Unavailability i

! . Thermal Performance l

. Fuel Reliability

. Chemistry Indicator l

. Indus+ rial Safety Accident Rate I

. Unit Operating Capacity Factor / Net Generation l

Licensina Basis / Technical Specification Performance Success Criterion

. Licensee Event Reports j 1

Operator Burden Minimized Success Criterion i

. Temporary Modifications m . Operator Work-Arounds

. Control Room and Annunciator Deficiencies I

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Third Quarter Status Operational Performance Assessment instruments 1 Assessment Title Schedule Completed (Y/N) Revised Date Date Interface Effectiveness 2nd Quarter Y July 1998 between Operations and 1998 other Unit 3 Departments Conduct of Operations 3rd Quarter N In progress 1998 Nuclear Oversight Monthly Monthly Y Reports INPO Evaluation August 3 -14 Y 1998 p Assessment Results b ,

Interface effectiveness between Operations and other Unit 3 departments (Unit 3)

. In July, the results of a Unit 3 Operations Department self-assessment were released to all stations personnel.

. Results confirm that Unit 3 Operations personnel have performed well as key players in the restart effort. Departments surveyed indicated that they respect Operations personnel for their contribution, have a high level of trust in the department's ability to safely operate Unit 3, and that there is a robust Safety Conscious Work Environment.

- However several issues were identified including:

- A need for improved teamwork between operations and certain other departments.

- A need to better integrate Operations functions into the Unit 3 resource-loaded work week schedule.

l l - Improved customer focus for Operations personnel.

Unit 3 management has taken the following actions to address the issues identified:

Millstone Station / Unit 3 Third Quarter Performance Report i

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o 5'9 e A process by which Operations personnel are selected, trained, and O)

(, made available to address manpower issues over the long term is currently under development.

. Additional personnel have been hired and currently enrolled in Non License Initial Training (NLIT), which should result in the addition of

nine additional Plant Equipment Operators (PEO) when the training ends in January 1999.

Six candidates for Senior Reactor Operator (SRO) License program have been selected, and are currently enrolled in the generic fundamentals portion of the licensed operator program. The next License Operator initial Training (LOIT) has been tentatively scheduled i for the Fall of 1998 or early 1999. l

. Action plans have been developed to address identified program

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weaknesses and to enhance teamwork between Operations personnel and other departments.

l l Operations Confiauration Manaaement The Operations Department corrective Action Group tracks configuration control events and their causes. Trends are developed for operations

/ management. Performance of Millstone Unit 3 Operations for the period l l (]/ July 1,1998 through September 30,1998, shows an unsatisfactory start

to the quarter with 6 configuration control events in July, followed by

significant improvement in August and September with a total of 3 events in the two month period. Overall performance was categorized as Tracking to Satisfactory, but still not consistently meeting management l expectations specifically in the area of human error.

Nuclear Oversiaht Monthly Surveillance Report

! Overall performance of Millstone 3 Operations for the period between July 11,1998 and August 71998 was categorized as Needs improvement.

None of the key attributes assessed during this time period were l characterized as Excellent Pedormance. Satisfactory Performance was i observed in the following areas: (1) Conduct of Operations, (2) Operator Knowledge and Performance, and Operations organization and Administration. Performance was rated as Needs improvementfor the following attributes: (1) Operational Status of Facilities and Equipment, (2)

Operations Procedures and Documentation, and (3) Planning and Implementation. No areas were categorized as Significant Weakness.

Operator Work-Arounds and other distractions to the operators continues

to need improvement.

Millstone Station / Unit 3 Third Quarter Performance Report

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^ Overall performance of Millstone 3 Operations for the period between August 10,1998 and September 9,1998 was categorized as Satisfactory.

None of the key attributes assessed during this time period were characterized as Excellent Performance. Satisfactory Performance was observed in most of the assessed areas, however, performance was rated as Needs Improvement for the following attributee: (1) Control Room Protocol (specifically, non-operations personnel), (2) Communication (specifically, equipment used to communicate between the field and the control room), (3) Procedure Adherence (quality and impsmentation of all procedural requirements), and (4) Materiel Condition (awareness and identification of minor deficiencies).

Satisfactory performance for Unit 3 Operations continued for the period between September 12,1998 and October 8,1998. Conservative decision making was demonstrated in reducing plant power and in tripping the unit. Reducing operator burdens continues to be a challenge.

INPO Evaluation An INPO Evaluation Team was on-site from August 3 to 14 to assess performance of Unit 3. The Team debriefed on August 24,1998.

Potentially eight (8) strengths and twenty (20) performance concems for

( the unit were identified associated with the inspection.

Performance Measures Operational Performance Focus Indicator: Emergency System Actuations (NRC Reportable) KPI K-1

_ Status: The goal is to have 0 unplanned emergency system actuations. The Reactor was manually tripped from 100%

power due to high condensate conductivity on September 15,1998. The high conductivity was caused by salt water intrusion into the main condenser via the steam generator blowdown line. As a result of the trip, Steam Generator levels went low, causing an Auxiliary Feedwater Actuation and procedure driven manual Feedwater isolation. Aux.

Feedwater Actuation and Feedwater isolation are expected responses following a trip of this kind from 100% power due to the need to prevent the transportation of salt water to the steam generators. The salt water intrusion was the result of b

Millstone Station / Unit 3 Third Quarter Performance Fleport

61 O a procedural inadequacy. Performance is not meeting management expectations.

Indicator: Diesel Generators Unavailability (MRule) KPl K-2 Status: The goalis to use less than or equal to 80% of the system's allowed Maintenance Rule unavailability limit. System performance is acceptable. SBO increase was the result of a scheduled major system outage for actual PMs, SVs, and long-standing cms. Performance is satisfactory.

l Indicator: Auxiliary Feedwater System Unavailability ( MRule) KPl i K-3 l Status: The goal is to use less than or equal to 80 % of the system's l ~ allowed Maintenance Rule unavailability limit. This system is classified as a 10 CFR 50.65 (a) (1) system due to excessive unavailability. The Action Plan was approved by l L the Maintenance Rule Expert Panel on 9/22/98. The majority of the unavailability hours can be attributed to the impact of leakage from 3FWA*MOV35D which was repaired during the last cold shutdown. Performance is not meeting  !

management expectations. j Indica _ ten HPSI System Unavailability (MRule) KPI K-4 Status: The goal is to use less than or equal to 80 % of the system's y allowed Maintenance Rule unavailability limit. System l performance is acceptable.

L Indicator: INPO Thermal Performance Inoicator KPI K-5 l

Status: The analysis of the unit is conducted on a weekly basis utilizing procedure EN31018, " Secondary Plant Performance Monitoring". From this data and data from EN31017,

" Secondary Plant Performance Test" judgments are .made conceming thermal performance. The procedures are diagnostic in nature and the actions taken range from minor l tuning of equipment to the removal of equipment from service for maintenance. Performance for the first two (2) weeks was below the goal due to condenser fouling.

Condenser thermal backwashes were performed on 9/13/98, resulting in significant improvement. As of 9/25, recirculation valves for the "B" HDL and "A" DSM pumps were open, resulting in lost efficiency. The HDL valve was N shut on 10/2. Overall, September was above goal.

!- Performance is satisfactory.

Millstone Station / Unit 3 Third Quarter Performance Report

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I (Q indicator: Fuel Reliability (INPO) KPI K-6 '

Status: The goal is to maintain the fuel reliability by indicating less l l than 0.0005 microcuries of radioactivity per gram of Reactor l l Coolant System (RCS) water. This is consistent with the l 100 point INPO goal. The equilibrium coolant activity levels indicate there is approximately 1 leaking fuel rod in the reactor. The preparation for an end of cycle fuel inspection continues to be recommended. Based on the results of this l inspection, either fuel reconstitution / repair or emergency i

core redesign may be required prior to Cycle 7 startup.

l Performance is satisfactory.

Indicator: Chemistry Performance indicator (CPI-lNPO) KPI K-7 I l

l Status: The goal is to maintain an INPO Chemistry Index less than 1.10.

The Unit took advantage of the shutdown to perform anion regeneration on all CPE beds. Time was allowed for bed soaking to remove sodium impurities and reduce sodium.

Results show that all S/G sodium values are below the l p guidelines of .8 ppb Na and are substantially lower than the

( goal. Increased condensate dissolved (CPD) oxygen continues to challenge the Unit overall, causing the CPI to be higher than the established goal. The reduced condenser vacuum has resulted in increased O2 levels.

l lhant transients (downpower and trip) along with increased l condensate oxygen have had an adverse effect on the l trend. '

Performance has decreased due to condensate oxygen levels, and is not meeting management expectations, but is ,

trending to satisfactory performance.

Indicator: Industrial Safety Accident Rate (INPO) KPl K-8 Status: The goal is to maintain an INPO accident rate less than .50 Injuries /100 employees. The Unit had one accident in July '

l. and none for the months of August and September. This is L a reduction from four for the 1st quarter and two for the l second quarter.

Performance is Satisfactory, showing significant improvement over the past several months.

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) Millstone Station / Unit 3 Third Quarter Performance Report l

63 Indicator: Unit Capability Factor / Unplanned Loss Capability Loss

!(~ Factor KPl K-9 Status: The goal is to maintain a Unit Capability Factor of greater than 88% and to have an Unplanned Capability Loss Factor less than 3%. Both the Unit Capability Factor and the Unplanned Capability Loss Factor did not meet management expectations during the month of August due to the unscheduled outage need for the repair of l

3AFW*MOV35D.

September production figures showed improvement, but failed to make the goal due to the unplanned outage caused by the chloride excursion in the condensate system.

Performance is trending to satisfactory, but currently not i meeting management expectations.  !

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Licensina Basis / Tech Spec Performance Focus I Indicator: Licensee Event Reports KPI K-10 Status: The goal to have less than or equal to the industry average ,

LERs. The industry average is approximately 1 per month.  ;

. d( m Since July 1998 Unit 3 has had 5 LERs of which 2 are i historical in nature. There were no LERs in September 1998. Performance is satisfactory.

Operator Burdens Minimized Performance Focus indicator: Temporary Modifications KPI A-6 Status: The goal is to have less than (<) 15 by 12/98, and < 10 by 12/99, with none greater than 6 months old without Unit Director approval. The number of Temporary Modifications is 22, of which 5 are scheduled to be removed in RFO 6. Of the remaining items,17 are scheduled to be removed prior to RFO 6. Of these 17, seven (7) can be removed as soon as work can be scheduled, eight (8) are waiting for design changes before field implementation, and two (2) can be removed once the final fix to hypochlorite valves is implemented. Performance is not meeting management l expectations.

i Millstone Station / Unit 3 Third Quarter Performance Report

j 64 p indicator: Operator Work-Arounds KPI A-8 1 d

Status: The goal is to have no more than ten (10) Operator Work-Arounds (OWA) by 12/98 with none greater than 1 year in age.

The Work-Around program is expanding in scope as the plant has returned to power and different Work-Arounds are

' discovered. Twenty (20) Work-Arounds were listed as of the j end of the third quarter of 1998. Further changes to the Work-Around program are under evaluation, including more specific definitions for tracking purposes. The goal may be adjusted to account for the definition changes. Action is in progress to include the OWAs into the MP312 week rolling schedule.

Performance is not meeting management expectations. The unit is currently above the goal, but scheduled to be below goal by December,1998.

Indicator: Control Room and Annunciator Deficiencies KPi A-7 -

Status: The goal is to have fewer than ten (10) control room and o annunciator deficiencies by 12/98.The number of Control V Room and Annunciator Deficiencies is fifteen (15). There are no deficiencies older than 6 months, and the total is ,

slowly trending toward the goal specified by the l Performance Plan for 1998 - 2000. Increased management I attention is being applied to this area. Performance is not I meeting management expectations.

Conclusions Performance measures evaluated for the 3rd quarter conclude the I following:

In the area of Operational Performance, KPI's indicate that performance is on an improving trend. Of the nine (9) KPI's evaluated five (5) show satisfactory performance, but four (4) in the areas of safety system actuations, safety system unavailability, chemistry performance, and unit operating capability factor / unplanned capability loss factor were not meeting management expectations. These four KPI's were driven into unsatisfactory performance areas due primarily to two (2) major events:

the forced unit outage to repair the leaking auxiliary feedwater valve 3AFW'MOV35D and the recent end of September plant trip due to high c condensate conductivity. These material condition driven events have been the focus of corrective action efforts to improve reliability and plant I Millstone Station / Unit 3 Thirr' Quarter Performance Report

65 r~- performance. Operations department performance,in safely

( . maneuvering the plant during these events, was noted to have been satisfactory.

Performance assessments performed in the 3rd quarter show an Operations Department focused on self improvement both intemally and extemally. Significant issues noted during the third quarter included effectiveness of Operations' interface with other Unit 3 departments, i adequacy of Operations Department customer service, Control Room  ;

Protocol (specifically, non-operations personnel), Communication j (specifically, equipment used to communicate between the field and the control room), Procedure Adherence (quality and implementation of all procedural requirements), Materiel Condition (awareness and identification of minor deficiencies), and Planning and Implementation. l Condition reports were written and compensatory actions are being l implemented for improving performance in these areas. These included I extensive procedural reviews, reiteration of management's expectations for procedure compliance and increased focus on Operator Work- -

Arounds, Control Room Deficiencies and Annunciator Deficiencies.

Overall Operations personnel performance shows improvement during the 3rd quarter.

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! Millstone Station / Unit 3 Third Quarter Performance Report I

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1 3

(O Key issue: Work Control and Planning l

Success Criteria The following Success Criteria have been established and summarize the performance baseline for this Key issue:

. The backlog of system and equipment deficiencies is reduced to a level consistent with industry standards l

. Preventive maintenance and surveillance activities are completed as I scheduled

. Institution of an on-line work management process utilizing schedule adherence rate consistent with industry standards Self-Assessment l The following self-assessments are currently planned for 1998:

. Work Management Training issues and Compliance - 1st Quarter

. Procedure Usage and Compliance - Refueling Schedule - 2nd Quarter  !

. Maintenance Fbnning Effectiveness - 3rd Quarter

. Schedule Adherence - Orc Quarter

. Work Management Correcue Action Program - 3rd Quarter

. INDUS Passport Automated M.-k Order (AWO) Software - 4th Quarter

. Maintenance AWO/ Procedure and Feedback Program Effectiveness -

4th Quarter

. Condition Report Process and Tracking Effectiveness - 4th Quarter

. Resource Loading Analysis -4th Quarter Performance Measures The following performance measures are being used on an on-going basis to monitor this Key issue:

('N . On-Line Corrective Maintenance Backlog Millstone Station / Unit 3 Third Quarter Performance Report

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67 O . Preventive Maintenance Tasks Overdue

. Surveillance Performance

. Schedule Performance Third Quarter Status Work Control and Planning Assessment Instruments Assessment Title - Schedule : Completed Revised .

Date (Y/N)' Date Third Quarter Condition Reports 3rd Quarter Y Ouarterly Assessment of 3rd Quarter Y Performance, " Windows" Assessment Results l

Third Quarter Condition Reports All Condition Reports from the third quarter were reviewed for adverse conditions in the Work Control process. A trend Condition Report was generated as a result of this review, highlighting the need to improve performance in utilizing Probabilistic Risk Assessment for on-line Maintenance.

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Quarterly " Windows" Self-Assessment The window for Work Control and Outage Management was rated as

" white" (meets expectations). All sub-elements were rated as either

, " green" or " white" except the sub-element of Budget Controls.

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Millstone Station / Unit 3 Third Quarter Performance Report

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, Performance Measures Indicator: On-Line Corrective Maintenance Backlog (On-Line Work i Order Status) KPl A-5 l Status: The On-Line Corrective Maintenance Backlog has increased l above the unit's established goal. An action plan has been implemented to allocate resources in the T-12 process to l

allow adequate planning and parts allocation in corrective

! maintenance work orders.

l l- Indicator: Overdue Preventive Maintenance AWOs KPI J-2 l Status: Preventive Maintenance tasks overdue remain at the established goal of zero.

Indicator: Surveillance Test Program Schedule Performance KPl I J-1 L Status: Surveillance Performance has slipped below the established )

i goal. This is due to the increase in the number of surveillance tasks required for Mode 1 operation and the l lp competition for resources in operations. I l Indicttor: On-Line Schedule Performance KPI J-3 Status: After a transition to the 12 week work management process, ,

Schedule Performance is now being monitored. Schedule i l performance goals have been attained. New goals have been redefined at a higher level to now raise the bar toward industry standards of 90%.

Conclusions An action plan has been developo to address the increase in backlogs of t corrective maintenance during the quarter. Overdue preventive maintenance tasks remain at goal and progress has been made in the c implementation and execution of on-line schedule performance. An action

. plan has been developed to further improve performance in this area.

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Millstone Station / Unit 3 Third Quarter Pedormance Report

69 O Keyissue: Procedure Quality and Adherence l

Success Criteria 4

The following Success Criteria have been established and summarize the performance baseline for this Key Issue:

. All procedure deficiencies are effectively dispositioned in a timely manner (deficiencies are promptly reported, evaluated for significance, corrected in an appropriate time frame, tracked to resolution and trended)

. Procedure quality for new and revised technical procedures are acceptada

. Instances of not adhering to procedures remain at an acceptable level Self-Assessment p The following self-assessments are currently planned for 1998:

V . Station Administrative Procedures Window - Quarterly

. Procedure Biennial Reviews - 1st Quarter

. Procedure Compliance - 2nd Quarter

. Station Qualified Reviewer - 3rd Quarter

. Master Manual - 4th Quarter Performance Measures The following performance measures will be used for the on-going monitoring of this Key issue:

. Procedure Compliance, Unit 3

. Closed CRs involving Deficient Technical Procedures, Unit 3

. Closed CRs involving Deficient Technical Procedures, Millstone Station Millstone Station / Unit 3 Third Quarter Performance Report

70 0 Third Quarter Status Procedure Quality and Adherence Assessment instrument Asamsment Title schedule Completed Revised Date (Y/N) Schedule if' Not l Complete  !

Station Qualified Reviewer 3rd Otr Y 1998 Station Administrative Procedures Y I Quarterly Group Window for Procedures Quality

, Assessment Results O st tie o ii<i e a vi - , eree< - l The Station Administrative Procedure Group completed a self-assessment

" Station Qualified Reviewer Program" for the third quarter of 1998. The assessment team reviewed other Station Department self-assessments that were required based on full SQR implementation. Specifically the assessment team reviewed " Findings" and "Other Areas Assessed and Found Acceptable" as stated in the self-assessments.

l The eight self-assessments and one surveillance reviewed show overall that the implementation of the Station Qualified Reviewer (SQR) Program is in compliance with Technical Specification 6.5.4. The overall quality of 50.59 screens is adequate and improving. Several of the assessments t found that specific departments did not have a sufficient cadre of 50.59 l screeners and the bulk of screens fell on too few individuals. The number l .of qualified 50.59 screeners has been increasing in Unit 3 over the last l month.

Station Administrative Procedures Group, Window The Station Administrative Procedure Group Annunciator Window for i Procedure Quality reported the following performance:

. Station Qualified Reviewer Program " White"(Satisfactory)

Millstone Station / Unit 3 Third Quarter Performance Report i

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,Q . Organizational Effectiveness " White" V e Administrative Procedure Process " White"

. Procedure Upgrade Project - Project Complete Performance Measures Indicator: Procedure Compliance Millstone Unit 3 KPI D-1.

Status: The total non-compliance errors /1000 hours has remained below the Station Performance Plan goal of 0.5 for Unit 3 since December of 1997 indicating satisfactory performance.

Unit 3 has recently set a new goal of 0.25. Over the last two months there has been a trend that warrants management's attention.

Indicator: Conoition Reports involving Deficient Technical Procedures KPl D-2.

Status: The quality of technical procedures for Unit 3 and the Station is acceptable. The total number of procedure-related n Condition Reports has been well below the established

() goals of less than five for the Unit and less than 25 for the site for the past eleven months.

Conclusion Overall, Unit 3 has implemented the Station Qualified Reviewer (SOR)

Program successfully. There is a need to have more qualified individuals on-shift to perform independent reviews and 50.59 procedure screens.

l The new training for 50.59 Safety Evaluations has improved the quality of 50.59 procedure screens. The procedure adherence trend warrants more attention. Recently lessons learned in procedure compliance from Unit 1 were shared with other departments.

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Millstone Station / Unit 3 Third Quarter Performance Report f

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72 O' Key issue: Emergency Planning l

Success Criteria The following Success Criteria have been established and summarize the pedormance baseline for this Key Issue: l l

. Demonstrate that Millstone Station has an effective Emergency Response Organization  !

. Complete Emergency Preparedness Maintenance program improvement actions Self-Assessment The following self-assessments are currently planned for 1998:

. Effectiveness of Root Cause and Self-Assessment Corrective Actions -

1st Quarter

. Emergency Action Level Annual Review - 2nd Quarter i

. Emergency Planning Customer Survey - 3rd Quarter

. Effectiveness of Training and Drills - 4th Quarter

. Periodic Emergency Response Drills

. Periodic Inventory of response facilities and equipment

. Weekly Station Emergency Response Organization (SERO) staffing level surveillance Performance Measures The following pedormance measures will be used for the on-going monitoring of this Key issue:

. Station Emergency Response Organization

. Off-site Emergency Response Interface / Activity

. Regulatory Compliance

. Conduct of Drills

. Station Emergency Plan & Procedures

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• Industry Benchmarking Millstone Station / Unit 3 Third Quarter Performance Report

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V Third Quarter Status Emergency Planning l

i Acsessment Instruments l

Assessment Title Schedule Completed Revised Date (Y/N) Schedule if Not Complete Emergency Action level 2nd Quarter Y Started in 2nd Annual Review 1998 quarter and

completed 3rd Quarter l Emergency Planning 3rd Quarter N To be Customer Survey completed in 4th Quarter inventory of Response 3rd Quarter Y Facilities and Equipment l Emergency Response Drills NA O ^==e=== eat ae uit-Emergency Action Levels (EAL) Self-Assessment The scope of the EAL self-assessment was tc> determine if the EALs i reflect correct classification of events and if they were reviewed as required. The results indicated that the EALs did meet the criteria.

However, there were two areas for improvement identified:

. Resolution of an inconsistency between an alarm set point and an EAL

, threshold as it applies to the Containment High Range Monitor. This was discovered during a drill. This inconsistency along with the data presentation at the drill contributed to a failure to classify a drill event.

• Clarification of which offsite authorities are required to conduct an annual review of the EALs.

l inventory of Response Facilities and Equipment Quarterly inventories for response facilities and equipment have been conducted and found satisfactory. Facilities and equipment were p maintained in a " ready" state.

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Millstone Station / Unit 3 Third Quarter Performance Report

74 O Emergency Response Drills There were no scheduled or conducted drills in the third quarter. On-going weekly SERO staffing surveillance verifies that each position is at least 2-deep. The majority of SERO positions are 3 and/or 4-deep.

Performance Measures Station Emergency Response Organization New SERO members participated in training to satisfy qualification requirements and fill vacant positions. Severe Accident Management training is complete for Unit 2 and initiated for Unit 3. Evaluated activities are scheduled for both units to complete the implementation of the program.

Off-Site Response O

V Offsite interface activities continued to be conducted. Routine monthly l meetings between Millstone Emergency Planning Services Department l (EPSD) Managentent and staff were held with State of Connecticut OEM Director and staff to dbcuss emergency planning issues. A quarterly  ;

meeting with the Emergency Management Directors (EMDs) from the  ;

Emergency Planning Zone (EPZ) municipalities has also been initiated to '

provide an opportunity for open dialogue with the State OEM and the utility. The third quarter meeting was held on September 24,1998.

FEMA representatives attended the meeting and were a positive influence '

on the discussions during the meeting.

Regulatory Compliance There were no regulatory compliance issues during the third quarter.

Conduct of Drills There were no scheduled drills during the third quarter.

Millstone Station / Unit 3 Third Quarter Performance Report

75 Emergency Response Plan Revision 24 of the Emergency Plan was implemented in July 1998. To reflect the addition of Severe Accident Management to the Plan, revision 25 has been initiated and is expected to be completed by December 15, 1998.

A project to streamline emergency planning procedures was initiated and is scheduled for completion in December,1998. Severe accident management procedures are developed for Units 3 and 2.

Industry Benchmarking Millstone EPSD was involved in one industry benchmarking activity during the third quarter. Two individuals visited Oyster Creek, Hope Creek /

Salem Station and Peach Bottom Nuclear Power Station to investigate methods for dose assessment, equipment, and emergency response facilities.

Conclusions Performance measure and self-assessments indicate that Millstone Station has an effective Emergency Response Organization. Emergency Planning is maintaining and improving performance of the SERO and its associated programs. The SERO continues to demonstrate effective emergency response. The Emergency Planning programs are continuously being upgraded based on feedback from events such as drills, self- assessments, and surveillances. Procedures continue to be reviewed and upgraded. Drills continue to sharpen response skills and identify areas for continuous improvement. Emergency planning

, performance is at a satisfactory level to support the safe operation of Unit 3.

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O Millstone Station / Unit 3 Third Quarter Performance Report

76 O Key issue: Radiological Protection Success Criteria The following Success Criteria have been previously established and summarize the performance baseline for this Key Issue:

. Demonstrate compliance and high standards

. Foster a culture of Radiation Protection Program ownership

. Achieve a going forward goal of zero incidence of High Radiation entry dosimetry events

. Achieve a goal of less than one event per 20,000 entries into any Radiologically Controlled Area Self-Assessments

/ The following self-assessments are currently planned for 1998:

. Health Physics Equipment Program Assessment - 1st Quarter

. Radioactive Matorials Shipment - 1st Quarter

. Mixed Waste - 2nd Quarter

. Radiation Protection Surveys (Unit 3) - 2nd Quarter

. Station ALARA Program Assessment - 3rd Quarter

. Tool Decontamination in the Solid Radwaste Building - Process and Techniques - 3rd Quarter

. Contaminated Laundry Services - 3rd Quarter

. HP Training and Professional Development (Unit 2) - 4th Quarter

. Free Release of Materials in Warehouse #9 - Process and Techniques

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Millstone Station / Unit 3 Third Quarter Performance Fleport

77 i l

O Performance Measures The following performance measures will be used for the on-going monitoiing of this Key Issue:

. Cumulative RCA Entry Error Rate, Millstone Station

.. Low Level Radioactive Waste Volume e Radiation Exposure i

Second Quarter Performance Radiological Protection -

Assessment instruments '

Assessment Title . Schedule Revised

Completed _

- Date - (Y/N). Schedule if Not

' Complete Radiation Protection Surveys 2nd and 3rd Y N/A l (Unit 3) Quarters Station ALARA Program Sept.1998 N October 1998 Tool Decontamination in Solid Sept.1998 N Replaced by Radwaste Building - Process " Contaminated and Techniques Laundry Services" Contaminated Laundry Sept.1998 - Y N/A Services The Radiation Protection Managers have developed a plan for joint self-assessments. The Unit RP and Site RP departments provide team members to the lead department for self-assessments. The results of these assessments, as well as Unit-specific assessments, are shared among the various RP departments.

Assessment Rt suits Radiation Protection Surveys (SA-98-02)

During the second and third quarters of 1998, an assessment was conducted as a review of the radiological surveys conducted at Millstone Station. The assessment reviewed programs that are implemented through varying methods. In general, the review identified confirmatory O monitoring, environmental surveillance and improvements in transfer of Millstone Station /Un?t 3 Third Quarter Performance Report

78 i

/ radioactive materials as program strengths. Areas for improvement V] focused mostly upon clarifications to procedures and management expectations, with some additional recommendations for improvements to air sampling and alpha surveillance.

Contaminated Laundry Services (NS-98-22)

The Waste Services department conducted an on-site and off-site assessment on contaminated laundry services 1:cm September 9 - 11, 1998. This topic was chosen in response to two personnel contamination events in the units which were attributed to laundered protective clothing.

This assessment was combined with a OA review since the laundry service had recently moved to a different facility in Royserford, PA. The results of the assessment were very positive. On-site laundered protective clothing met all contract criteria. The team observed a well maintained and V verly managed operation at the Royserford facility.

Surveys of pro %ctive clothing were performed properly on appropriate equipment. There were no findings or deficiencias observed though several minor enhancements were implemented as a result of this assessment.

Performance Measures q

V . Cumulative RCA Entry Error Rate, Millstone Station KPI H-1. A continual improvement performance has been realized in dosimetry compliance during this period. In the past 15 months Millstone Station has met or surpassed its performance goal of less than one dosimetry infraction per 20,000 RCA entries. This goal was adjusted to 25,000 RCA entries in the 2* Quarter of 1998. In a 12 month period through September 30, Millstone station is averaging less than one dosimetry infraction per 96,000 RCA entries.

. Self-Reporting Culture Chart KPI H-3. Millstone Station's expectation is that line workers will self-report dosimetry infractions by use of the CR system. However, in Se dosimetry infraction occurring inQuarter the 3"'ptember was identified1998, and the one reported by Nuclear Oversight. A Condition Report (M3-98-4097) was initiated at the time of this infraction and Corrective Actions are currently in progress.

. 1998 Rad Exposure Summary KPI H-2. The 1998 cumulative radiation exposure for Millstone Unit 3 had been set at less than 51

rem. However, effective October 1,1998, this ALARA goal has been l revised from 51 rem to 43 rem. This goal represents the level of l

r3 exposure which the Health Physics department strives to stay below in V order to maintain occupational exposures as low as reasonably Millstone Station / Unit 3 Third Quarter Performance Report

79 p achievable (ALARA). To date, the cumulative exposures are tracking 1

.V well within the ALARA goal.

Conclusions

- At the end of the second Quarter Nuclear Oversight reported an event'at Unit 2 concerning survey adequacy and monitoring for alpha activity. This resulted in an Event Review Team report with several proposed corrective actions and an NRC non-cited violation. The Corrective Action Plan for this Condition Report (M2-98-1533) is currently underway with an effectiveness review scheduled for June 1999.

A c"Iture of Radiation Protection program ownership has been achieved by the use of the CR system by line organization personnel in identifying areas of program weakness or work practice deficiency. There is an increased willingness on the part of individual workers and their peers to j.'

self report infractions. An improvement has also been realized in the Radiation Worker training program with the advent of improvement in the

practical factor facilities and HP technician involvement in radiation worker training.

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. Improved process centers for health physics functions have been

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accomplished by closing multiple entry points into the RCA and the installation of mechanical turnstiles for TLD/ electronic dosimetry RCA access. These actions have improved Millstone Station dosimetry compliance to industry benchmark levels. Also, contamination control improvement has been realized with the installation of a timed portal monitoring system at station exit points. Additionally, a truck contamination monitor has been installed and is currently being tested on-site. This device is the first of its type at a US commercial nuclear utility during 1998. Millstone Station is maintaining an effective radiological protection program commensurate with safe nuclear operations and industry standards of performance.

The goal of less than one event per 20,000 entries into any RCA has been met in the third quarter. The goal was revised in the second quarter to less one event per 25,000 entries into any RCA.

O Millstone Station / Unit 3 Third Quarter Performance Report

80 Key issue: Security l

Success Criteria The following Success Criteria have been previously established and summarize the performance baseline for this Key issue:

. Comply with all Security regulations and demonstrate continued improvement and program compliance in security vehicle control  !

. Comply with all Security regulations and demonstrate continued  !

improvement and program compliance in control of safeguards  ;

information l Self- Assessments The following self- assessments are currently planned for 1998: l

. Security Alarm Response - 1st Quarter

. SSMR Process - 1st Quarter 1 e CAS/SAS Operation - 1st Quarter O)

. Personnel PA/VA Access Control- 1st Quarter

. Security Training Program - 1st Quarter

. Station Qualified Reviewer Implementation - 1st Quarter

. Security Weapons Testing / Surveillance / Inspection - 1st Quarter

. Security Processing Center - 1st and 3rd Quarters

. Visitor Control- 1st and 4th Quarters

. Protection Security Personnel - 3rd Quarter

. Patrolling - 2nd Quarter

. Security Locks and Keys - 2nd Quarter

. I&C Training and Qualification - 2nd Quarter

. Safeguards Information - 2nd and 4th Quarters

. Vehicle PA Access Control- 2nd and 4th Quarters

, . Fitness For Duty Center - 3rd Quarter

. Security Surveillance - 3rd Quarter

. Contractor Termination - 3rd Quarter

. Application of Compensatory Measures - 3rd Quarter

'n . Performance Observation Program - 4th Quarter U . Security Lighting - 2nd and 4th Quarters I

l Millstone Station / Unit 3 Third Quarter Performance Report

81 e Security Reportrirending Analysis - 4th Quarter O' . Station Lock and Keys - 4th Quarter

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. Security Emergency Response - 4th Quarter Performance Measures The following performance measures will be used for the on-going monitoring of this Key issue:

. Control of Safeguards Information

. Vehicle Control inside the Protected Area

. Security Badge Control e Control of Visitors inside the Protected Area Third Quarter Status Security Assessment instruments O Assessment Title Schedule Completed Revised Date - -(Y/N) Schedule if Not Complete -

Protection Security Personnel 3rd Quarter Y 1998 -

Security Processing Center 3rd Quarter Y 1998 Application Of Compensatory 3rd Quarter Y Measures 1998 FFD Center / Program 3rd Quarter Y 1998 Security Surveillance Program 3rd Quarter Y 1998 Contractor Terminations 3rd Quarter Y 1998 Millstone Station / Unit 3 Third Quarter Performance Report

82 l O

Q Assessment Results Twenty one self-assessments were scheduled during the first three quarters of 1998 - eight in the first quarter; six in the second quarter, and seven in the third quarter. One of the September self-assessments was not completed and has been rescheduled for completion in October. The third quarter self- assessments covered the topics shown above and resulted in recommendations to enhance the respective programs. These self- assessments were documented within the Condition Report system, reviewed by department management, and assigned for further action if recommendations were determined to add value to the program. Overall the self-assessments indicated that the programs are effective. l Third Quarter  ;

. Protection Security Personnel - Procedures found to be clear and l concise. Recommendations made were primarily administrative in nature. l

. Security Processing Center - Millstone Processing Center noted to be in compliance with NRC requirements. Recommendations made included raising Station awareness on screening issues, and strengthening communication within the Security department. 1 f . Application of Compensatory Measures - Program of compensatory measure implementation found to be satisfactory. Recommendations made included rewording procedure for clarity.

. FFD Center / Program - Millstone Fitness For Duty program was found to be in compliance with NRC requirements. Recommendations made included communication to the Station of changes in FFD administratica, and a general reminder on confidentiality issues associated with notification of FFD testing.

. Security Surveillance Program - Surveillance program found to be satisfactory. Recommendations made were administrative in nature.

. Contractor Terminations - Termination of unescorted access is overell satisfactory with some exceptions noted. Recommendations made included increasing Station awareness of termination issues.

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Millstone Station / Unit 3 Third Quarter Performance Report

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Performance Measures Key performance indicators have been established for the following areas: l Control of Safeguards Information KPIl A goal of no more than ,

three events was established for 1998 - a reduction from the 1997 total  !

of ten actual events. Three events have occurred during 1998 ( one in the first quarter, one in the second quarter, one in the third quarter) 1 Although three events places this KPI at the annual goal, the goal of  !

three is aggressive compared to ten events in 1997. Each event )

reported during 1998 was attributed to human error. There are no '

indications of any programmatic issues. This KPI is tracking overall satisfactorily.

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. Vehicle Controlinside The Protected Area KPI l-2-- A goal of no I more than six events was established for 1998 - a reduction from the 1997 total of eight actual events. Seven events have occurred during 1998 (one in the first quarter, three in the second quarter, and three in the third quarter). Although the seven events exceed the annual goal, it is belieus ' t overall Station performance in this area is improving.

In 1997 the majority of the events were caused by inattention to detail -

(N i.e.: walking away from a vehicle with keys in the ignition. In contrast, b several of the 1998 events occurred after a good faith effort had been made to secure the vehicle. In one instance activating a tilt steering wheel allowed a locking bar to become disengaged; in another  ;

instance applying additional force to the steering wheel of a '

construction vehicle allowed a locking bar to become disengaged, and in a third instance the keys were purposely left in the vehicle to assist in towing preparation for removal from site due to a fluid leak. All of these events were discovered by a second party through the use of a healthy questioning attitude.

. Security Badge Control KPII-3 A goal of no more than 96 events was established for 1998 - a reduction from the 1997 total of 141 actual events. Forty four events have occurred during 1998 (eighteen in the first quarter, fourteen in the second quarter, and twelve in the third quarter) causing this KPI to track satisfactorily.

. Control of Visitors inside The Protected Area KPIl A goal of no more than twelve events was established for 1998 - a reduction from the 1997 total of 25 actual events. Six events have occurred in 1998 l (two in the first quarter, three in the second quarter, and one in the third quarter) causing this KPI to be overall satisfactory.

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Millstone Station / Unit 3 Third Quarter Performance Report

I 84 Conclusions Assessment results show that performance is being maintained. Security is recognized as an important aspect of the operation of Millstone Station.

Security systems are operational and functioning effectively. Personnel attention to security issues has improved.

Key Performance Indicators show that we are tracking satisfactorily in security related events in regard to success criteria of vehicle control and control of safeguards information. Security programs are satisfactory and will support the restart of Unit 2 and continued safe operations of Unit 3.

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V Millstone Station / Unit 3 Third Quarter Performance Report

85 Key issue: Environmental Compliance l

Success Criteria The fo!!owing Success Criteria have been previously established and summarize the performance baseline for this Key issue:

. The program and procedures that cover environmental requirements exist and are effective; and

. There is reasonable assurance that environmental regulations and permit requirements are being effectively implemented.

Self- Assessments The following self- assessments are currently planned for 1998:

. Assess the adequacy of Environmental Roles and Responsibilities Manual- 2nd Quarter

. Assess the effectiveness of the Air Quality Program with regard to compliance and implementing procedures - 2nd Quarter

. Assess Environmental Services process for preparing and tracking all outgoing correspondence to the DEP including embedded commitments - 2nd Quarter

. Assess the ability of Environmental Services and Millstone to inventory oil and hazardous material storage and use - 3rd Quarter

. Assess the effectiveness of the NPDES permit renewal compared to previous discharge limitations - 4th Quarter

. Assess the ability of Environmental Services and Millstone to use the CR trending information to determine if our corrective actions have been appropriate / effective - 4th Quarter Performance Measures The following performance measures are being used on an on-going basis to monitor Key issue:

. Notices of Environmental Violation

. NPDES Permit Exceedences

. Prompt Reports to the Department of Environmental Protection (DEP) q . Spills C/ . Progress Against ISO 14000 Environmental Management Standard Millstone Station / Unit 3 Third Quarter Performance Fleport

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, Third Quarter Status Environmental Compliance

, Assessment instruments j

4 Assessment Title Schedule Completed Revised 1 Date (Y/N) Schedule if 1 j- Not Complete j

Track Correspondence and July 1998 Y

] Commitments

Ability to inventory oil and Sept.1998 N Nov.1998 l hazardous material storage and i use.

) Assessment Results Track Correspondence and Commitments 1 The self-assessment indicated that while Environmental Services was tracking its correspondence and meeting its regulatory commitments, the processes in place needed to be captured in a departmental instruction ensuring that all commitments are identified in the Mi!! stone Station AITTS database as well as in the Corporate Environmental Services ENTRACK regulatory correspondence database. As a result, a departmental procedure (instruction) was developed in September 1998 for this purpose. Regulatory and non-regulatory action items are now tracked via AITTS while regulatory commitments are also tracked via the ENTRACK system to ensure that the corporate environmental database reflects those activities occurring at Millstone.

Performance Measures Performance Measure Target Third Quarter 1998 Status Notices of EnvironmentalViolations None None (two DEP audits 1998)

Number of Spill Reports TBD 11 Number of NPDES Exceedences O' 1 Millstone Station / Unit 3 Third Quarter Performance Report

i l

87 O

V ISO 140001 Progress (17)

Elements Number of Elements Complete EMS Action Plan in review; 6 elements in 1998 complete Training Programs Development Complete July 1998 All modules developed; need to j incorporate into  ;

NTD technical programs Environmental Screening in Key Complete in 1998 DCM,DC3,MP1 and i Procedures 2-WC1, NGP 5.14, l EPIP Reporting, complete Prompt Reports to DEP 27 21

• While the overall exceedence goal is 0, the KPI represents a  ;

significant step toward continuous performance improvement over  !

previous years.

The above environmental performance measures are a combination of l traditional environmental compliance indices and forward looking measures of progress toward implementation of programmatic enhancements. To date, significant progress has been made in capturing environmental decision-making in key station procedures which control design modifications and physical work. Regulatory reporting requirements have led to several Prompt Reports to the Department of Environmental Protection. These reports relate largely to the fact that the design bases of the plant discharges were not adequately described in the j prior NPDES permit application upon which the current permit is based.

Major efforts are underway to resolve this matter. Based on performance for the first half of 1998, Millstone Station has established a KPI of not more that 27 prompt reports for all of 1998. This represents a 50% ,

reduction over the first six months of the year, if achieved.  !

I Also underway are program enhancements, such as building an Environmental Management System (EMS) at Millstone based on the ISO 14000 standard, and significantly expanding training opportunities by embedding modules specific to each job class within ongoing routine training provided by the Nuclear Training Department (NTD). To date, we believe that six of the environmental management elements in place are fully ISO compliant including corrective action, emergency preparedness, audits, and monitoring and measurement. The training modules are also complete and now need to be incorporated into the NTD technical programs.

i l Millstone Station / Unit 3 Third Quarter Performance Report l

88 o Conclusions O

Millstone Station has made significant progress in identifying and implementing environmental program enhancements.

With regard to Unit 3 restart, potential air and water quality compliance issues were identified and corrective actions put in place in conjunction with the DEP to resolve the matters prior to restart. Associated design and procedural enhancements have also been put in place.

Environmental issues which arose during restart of Unit 3 are now being reviewed with the CT DEP as well. Environmental management processes have been enhanced by incorporating environmental considerations in key station procedures such as Design Control Manual, procedural modifications, emergency response, regulatory reporting and work control. Further, independent third-party experts and Nuclear Oversight now play a significant role in helping identify environmental issues and ensuring their effective resolution. Issues are being worked through the Corrective Action Program. Longer-term programmatic improvements are also underway including the development of environmental program manuals.

Regulatory compliance and program enhancements are being tracked to assess performance and progress of improvement programs.

v Environmental compliance performance is being sustained at a level which adequately supports the safe operation of Unit 3.

The results of performance measures and on-going program improvements and enhancements provide assurance that environmental regulations and requirements are being identified and effectively implemented. Our current status is satisfactory.

\

Millstone Station / Unit 3 Third Quarter Performance Report

i) 1 i

t PERFORMANCE ON KEY ISSUES Key Performance Indicators g

l l

l Index lp Unit 3 Performance Report 1O l Key Performance Indicators Millstone Unit 3 KPls Paae Number KPI Title

A-1................................. Condition Report Evaluation Timeliness

! A-2........................ .. Condition Report Method of Discovery A-3............................... Overdue Corrective Actions l A-4............................... Condition Repoit Evaluation Quality Score A-5............................... On Line Work Order Status  !

A-6............................... Temporary Modifications A-7............................. Control Room and Annunciator Deficiencies i A-8............................... Operator Work Arounds j A-9................................ Human Performance 1

1 Safety Conscious Work Environment KPis i B-1................................ Leadership Assessment (SCWE Eternent)  !

B-2.................................

(p) B-3..............................

Culture Suntey (SCWE Element)

NU Concerns and NRC A!;egations Received, Millstone l

l l Station

'B-4............................... Millstone Employee Concerns Confidentiality Trend, Millstone B-5. . . . . . . . . . . . . . . . . . . . . . . . . . . Employee Concern Resolution Timeliness '

B-6.............................. Focus Area Action Plan Status, Millstone Station B-7................................ Substantiated Concerns involving Potential Violations of 10CFR50.7 Overslaht KPis 1

C-1.............................. Status of Oversight Condition Reports, Millstone 3 C-2.............................. Nuclear Oversight Verification Plan Results, Millstone 3 Additional KPis t

Procedure Comoliance and Quality indicators l

l Paae Number

~

KPl Title l

'D-1............................. Procedure Compliance, Millstone 3 D -2. . . . . . . . . . . . . . . . ....... Unit 3 Closed CRs involving Deficient Technical Procedures O

1

(

i

I Index

q '

Unit 3 Performance Report

'o Key Performance Indicators l Additional Corrective Action /Self Assessment Indicators E-1........................... Median Age of Open Condition Reports l

Nuclear Trainina Indicators F-1........................... Executive Training Council Meeting F-2......................... Training Advisory Committee Meeting l F-3............................. Curriculum Advisory Committee Meeting F-4. . . . . . . . . .. .. ........... . Simulator Availability Leadershio and Culture Indicators G-1.............. .............. Leadership Assessment G-2. . . . . . . . . . . . . . . . . . . . . Culture Survey Radioloalcal Protection Indicators l H-1.............................. Cumuiative RCA Entry Error Rate, Millstone Station d,o H-2............................ Rad Exposure H-3. . . . . . ............. . .... Self Reporting Culture Chart Security Indicators 1-1............................. Control of Safeguards information l l-2................................ Vehicle Control Inside the Protected Area 1-3. . . . . . . . . . . . . . . . . . . . . . . . Security Badge Control I-4.............................. Control of Visitors inside the Protected Area l Additional Work Control Indicatata J-1........................ .... Surveillance Test Program Schedule Performance l J-2........................... Overdue Preventive Maintenance AWOs J-3. . . . .. .. ........ . ... ..... On-Line Schedule Performance 1

l Additional Ooerational Performance Indicators K- 1 . . . . . . . . . . . . . . . . . . . . Emergency System Actuations K-2...................... Diesel Generator Unavailability K-3. . . . . . . . .. . . .... Aux Feedwater System Unavailability b K-4 . . . . . . . . . . . . ....... .. .. HPSI System Unavailability K-5............................ INPO Thermal Performance 2

i l

index

(~ Unit 3 Performance Report t

Key Performance Indicators Additional Operational Performance Indicators Continued K-6................................. Fuel Reliability K-7............................. Chemistry indicator K-8............................... Industrial Safety Accident Rate K-9............................. Unit Capability Factor / Unplanned Loss Capability Factor K-10.............................. Licensee Event Reports Configuration Management Indicators  ;

1 L-1................................. CM Awareness Regulatory Comoliance Indicators M-1. . . . . . . . . . . . . . . . . . . . . Regulatory Compliance 1

\

l l~ 3

I I r

0 l

l l

l i

l l

Mil stone Unit 3 o ind'cators l

1 i

I f

1 Indicators provide information reflecting performance during the third quarter. Analysis and progress statements reflect performance during the most recent reporting period.

)

Condition Report Evaluation Timeliness

Millstone 3 i

Ogress Performance is tracking to satisfactory I

45

'O '

Goal < 30 days 35 -

i' F

• sw Dets 7/8/98 7/15/98 7/22/98 7/29/98 7/8/98 11 8/5/98 8/12/98 8/19'98 M Average Age of CR Evals 7/29/98 8/5/98

&"26/98 8/12/98 Goal 9/2/98 8/19/98 8,"26/98 9/9,98 TI 9/16/98 9/23'98 9/30/98 Jf 498] 7/22/98 9/2/98 9/9/98 9/16/98 9'23'98 9/30/98

Average Age of CR Evals 33 35 't6 35 32 38 42 44 40 43 36 22 32 Total CR Evals Required 124 80 109 , 85 47 57 58 49 57 57 55 65 43

{

j  % Evals Cornpleted within 30 days 76 52 74 61 30 32 40 36 49 48 45 50 39 q  %

/ Evals Completed within 30 Days 61 % 65 % 68 % 60 % 64 % 56 % 69 % 73 % 86% 84 % 82 % 77% 91 %

i j dnition AnalyslefAction

, 'his indicator depicts the average age of Level 1 & 2 Condition Reports (CRs) for The average age of a CR evaluation over the last 12 l vhich evaluations are still open, evaluations which were completed dunng the weeks is 36 days.

i veek being reviewed and the age of CR's that were originated during the week This KPI has been showing an improving trend in the %

j inder review. of CRs evaluated within the 30 day requirement. After bottoming out @ 56% on 8/12, the subsequent reporting j )nce issued Condition Reports are evaluated to determine the corrective actions periods have shown an overall increase in the number of 1 lat are necessary to address the issue and prevent recurrence. The 30 day evaluations completed within 30 days. However, the j  : lock begins on the day the assignment is made and ends when the CR is 'At N .etili not meeting the goal.

eceived in the Corrective Action Department for review. I 1 nf the 4 overdue CRs has an approved extension.

1 1

J loel Comments

'he average time to complete a CR evaluation does not show an adverse trend, The expectation is that CR evaluations are completed nd the average time to complete a CR evaluation < 30 days. within 30 days. Due date extensions for evaluations are the exception and only granted on a case by case basis.

Efa Source: AITTSl Analysis by: G Rescek x2433 MPl Owner: G Winters x5491MP A-1

4

{ Condition Report Method of Discovery l Millstone 3 l Progress: Performance is satisfactory. ,

1 i

i g jong Goal 2 95%

j g 80 %

! 8 70%

i b Good

! 15 40%

I h 30 %

20 %

h

} 10%

l l 0% 1 1 I f I I I f f I i l 1 E s s E E S E o> d f

! l  % Unit CRs M % internal Oversight CRs Goal l 3

gg -

7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12S8 8/19/98 8/26/98 9/2/98 9/9/98 D/16/98 9/23/98 9/30/98 j  % Unit CRs 74% 93 % 90% 96 % 86 % 91 % 91 % 67% 100% 88 % 92% 91 % 98%

j  % 1nternal Oversight CRs 21 % 6% 1% 1% 14 % 4% 7% 26 % 0% 10% e% 6% 2%  !

j Goal 95 % 95 % 95 % 95% 95 % 95 % 95 % 95% 95 % 95 % 95 % 95 % 95 %

j Unit CRs 45 66 60 73 62 63 74 36 57 46 47 59 50 i Internal Oversight CRs ' 13 4 1 1 10 3 6 14 0 5 4 4 1 External Oversight CRs 0 0 1 2 0 3 0 2 0 0 0 2 0 j l

J Event CRs 3 1 5 0 0 0 1 2 0 1 0 0 0 Total CRs 61 71 67 76 72 69 81 54 57 52 51 65 51 j f

] External + Event CRs 3 1 6 2 0 3 1 4 0 1 0 2 0 l j ICAVP 0 0 0 0 0 0 0 0 0 0 0 0 0 i Dennition AnekelalAction l This indicator depicts the percentage of Unit 3 CRs identified by external Over the third quarter there has been a positive trend for I

{ sources or events compared to the goal. CRs are categorized into the self identification of issues. This is the result of a low j following four areas: threshold of issue identification and imoroved i Event Driven - Self-revealing, an event occurs performance. l

! Exurnal Oversight - Identified by the NRC, NCAT, INPO, etc.

j Intemal Oversight - Identified by PORC, Nuclear Oversight, NSAB, 1 NSE, etc.

l Self Identified Supervisor observation, document review, self-checking,

etc.

! It is desirable to have a low percentage of all CRs generated by extemal 3 sources or events, and a high percentage generated by the line organization or internal oversight.

Goal Comments The goal is to have > 95% of issues (CRs) identified by the unit or internal oversight.

Ref: INPO 97-02 SE.1.A.3 perform 8nce criteria.

Dafs Source: AITTsl Analysis by: G Rescek x2433 MPl Owner: G Weiters x5491MP A2

Overdue Corrective Actions l Millstone 3

rogress

Performance is not meeting management's expectations.

4 1

) 7.00 %

1 6.50 %

g 6.00% -

1 5 .50%

' "b 5.00 %

$ 4.50% New Goal s 1%

0.00 % l l l l l l l l l l l t j

fB o> on p B B k 3 d l M % Overdue Goal l Rtw(Mt 7/8/98 7 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 8'26/98 9/2/98 9/9/98 9/16/98 9/23/98 9/30/98

% Overdue 5.64 % 2.62% 3.15% 2.71 % 6.14% 3.20 % 3.82% 2.51 % 5.72% 2.66 % 4.47% 2.38 % 3.99%

< 'oal s 1% of Total Open C/A 3% 3% 1% 1% 1% 1% 1% 1% 1% 1% 1% 1% 1%

Open Level 1 C/A 294 294 291 301 296 300 295 280 275 294 293 292 272 j Open Level 2 C/A 2544 2640 2662 2693 2651 2668 2664 2864 2800 2790 2/75 2734 2732 Total Open C/A 2838 2934 2953 2994 2947 2968 2959 3144 3075 3084 3068 3026 3004 Total Overdue C/A 160 77 93 81 181 95 113 79 1 76 82 137 72 120 DeHnidon Analysle! Action l

This indicator depicts the percentage of the total corrective actions (C/A) Unit 3 has not met the new goal of 1% established 10

}j that are overdue. weeks ago, in general, performance indicates an

! improving trend.

j Corrective actions are developed to address issues and problems identified i by Condition Reports (CRs). Overdue corrective actions are ones that Actions needed to move the organization from current

! have not been completed by the scheduled due date. level of performance to meeting expectations are being j assessed.

i It is desirable to have a low percentage of overdue corrective actions

! relative to the total number of corrective actions that are open.

Goal Comments '

The goal is for the percentage of overdue corrective actions to be s 1% of As of 7/15/98, the goal was revised to meet the 1998 -

g 'he total open corrective actions. 2000 Performance Plan goals. The Unit has ye. ?

meet that goal.

(

Dita Source: AITTSl Analysis f>y: G. Rescek x2433 MPl Owner: G. Winters x5491MP A-3

Condition Report Evaluation Quality Score Millstono 3 l 1 '

l l 1

YOgreSS: Performance is satisfactory.

a i 3.50 -

l Goal 2 3.0 1 3 00 -

2.50 -

2 00 -

1.50 -

1.00 Good l 0 50 -

NA NA 0.00  : i i -

i e i i i i i i

a a G 2 s s .,

a G i M Average Quahty score Goal l l l

) RawOsts i 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 6/26/98 9/2/98 9/9/98 9/16/98 9/23/98 9/30/98 Average Quality Score 3.60 3.33 2.75 3.00 2.50 3 33 3.00 N/A l 4.00 3.00 NA 3.60 3.20 i Goal 3.00 3.00 3.00 3.00 3.00 3.00 3.00 3.00 3.00 3.00 3.00 3.00 3.00 i

! f'\ Total Reviewed 10 3 8 4 4 3 2 0 3 6 0 5 5

() Accepted Accepted with Comment 8 2 3 2 1 2 1 0 3 4 0 4 3 2 1 5 2 3 1 1 0 0 1 0 1 2 Rejected 0 0 0 0 0 0 0 0 0 1 0 0 0 Rejection Rate 0.00 0.00 1 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0 00

}

OsRnMion . AnslysWAction

! This indicator reflects the quality of condition report (CR) evaluations Average Quality Scores are consistently above the j presented to the Management Review Team (MRT). Each evaluation is minimum acceptable score of 2.0, with most scores j reviewed for the adequacy of the proposed plan to address the issues around the desired 3.0 quality rating.

1 identified by the CR. Point values are assigned to each evaluation as j follows: The MRT is continuing to provide constructive feedback

! Accepted - 4 points to the line departments on areas where evaluations or j Accepted with Comments - 2 points action plans need improvement.

j Rejected - O points i A weighted average Quality Score is then calculated:

{ (# Eval X 4 ooints)+ (# EvalsWC X 2 ooints) l Total # Evals Reviewed l Where:

j # Evals = The # of evaluations accepted with out comment, j # EvalsWC = The # of evaluations accepted with comments, j Total # Evals Reviewed = The total # of evaluations reviewed.

]

i

( ^ =' : Comments j he goal is to achieve an average quality score 2 3.0 on a scale of 0 - 4.0.

1 4

Dita Source: AITTsl Analysis by: G Rescek x2433 MPl Owner: G Winters x5491 MP A.4

On Lino Work Ordsr Status Millstone 3 hrogress: Performance is not meeting management expectations.

1000 800 - Goal (Total) < 500 600 -

Goal (PRA) < 350

~

MPRA Risk Sig. AWOs s a  !. s l a s 2 e M N0n-PRA Risk Sig. AWOs -+-Work Off/ Goal (Total AWOs) -u-Work Off/G0al (PRA AWOs) l w oet.

7SS8 7/16/98 7/23/98 7/30G8 8698 8/13/98 8/20/98 8/27/98 9/3/98 9/10S8 9/17S8 r)/24S8 10/198 Non-PRA Risk Sig AWOs 255 249 254 253 268 280 281 268 275 272 267 260 285 PRA Risk Sig AwOs 257 261 274 274 279 279 276 271 276 266 265 256 268

{\/

\

Work OffGoal(PRA AWOs)

Total AWO Backlog 350 512 350 510 350 528 350 527 350 547 350 559 350 557 350 539 350 350 350 350 350 551 538 532 516 553 Work Off' Goal (Total AWOs) 500 500 500 500 500 500 500 500 500 500 500 500 500 Detoltion - AnakslefAction This indicator depicts the number of on line Corrective Maintenance The goal of s 350 PRA risk Significant AWOs has been met, (CM) Automated Work Orders (AWOs), and the portion of those however, the goal of s 500 total AWO backlog has not been met.

associated with Probabilistic Risk Assessment (PRA) nsk significant systems. All work has been scheduled in its proper 12-week Equipment Outage Code (EOC) window. Resources have been added in the PRA Risk Significant systems are systems required to protect the review of T-12 through T-6 work weeks. The added focus will reactor core or mitigate the consequences of an accident. show a positive trend in reducing backlog. Maintenance resources have recently been sent to support the MP2 restart.

Work awaiting post maintenance testing or closure is not included in This change of available resources will not cause an increase in this KPl. Also excluded are AWOs for support work, such as the backlog trend, but will affect the rate of working off the insulation removal, outage work, and Preventative Maintenance or backlog.

Surveillance AWOs, as well as AWOs not associated with power block equipment.

Goal Comments The goal is to have < 500 Total On-Line Corrective Maintenance KPI Data current as of October 01,1998.

Cf WOs per unit. Of these 500,less than 350 will be PRA risk veignificant AWOs.

D:ta Source: P. O Johnson x5519MPl Analysis by: M Galtpeau x5358l owner: C Schwarr x0491MP A5

Temporary Modifications Millstone 3 li Progress: Performance is not meeting management expectations, We are currently above the goal but scheduled to be below 15 by December,1998.

l 30 j

Goal <15 by 12/98 5

R h

=

s l k s l f 8

e .

8 R

h 8

n 3

s s & B & &

l M Ternp. Mods. < 6 rnos. E Ternp. Mods. > 6 months Outage Support --5-Total Work Oft / Goal l

, Raw Date 7/8/98 7/15/98 7/22/98 7/2918 8'5/98 8/12/98 8/19/98 8/26/98 9/2/98 9/9/98 9/16/98 9/23/98 9/30/98 j Temp. Mods. < 6 mos. 14 12 12 13 14 15 13 15 5 7 7 9 9

) Outage Support 0 0 0 0 0 0 0 0 0 0 0 0 0 Temp. Mods. > 6 monthe 4 4 4 4 4 4 4 4 13 13 13 13 13 Total Installed 18 16 16 17 18 19 17 19 18 20 20 22 22 i Total Work Off/ Goal 15 15 15 15 15 15 1h 15 15 15 15 15 15 M AnekslefAc60n This indicator depicts the total number of Temporary Modifications to We are above our goal of s 15 temp mods.

permanent plant design, the portion that are " Outage Support" 5 (directly tied to physical work to plant equipment in an outage There are 22 temp mods installed of which 5 are condition), and the portion that have been in place longer than one scheduled to be removed during the refueling outage cycle, that is before 4/14/95 (mode 3 prior to RFOS). (RFO6) currently scheduled in May 1999. The remaining 17 are scheduled to be removed prior to l A temporary modification is a modification to the plant that is short. RFO6. Of these 17, seven (7) cen be removed as soon j term in nature and not part of the permanent plant design change as work can be scheduled, eight (8) are waiting for i process. design changes before field implementation and two (2) can be removed once final fix to hypochlorite valves is implemented.

l l

l Goal - Comments  !

Less than (<)15 by 12/98, <10 by 12/99, with none greater than 6 months old wRhout Unit Director approval.

Performance Plan item B.2.c.

O Data Source: 1 Cunningham x4372MP l Analysis by: S Stricker x5409MPl Owner: G. Swder x5381MP A4

A

)!

Control Room Dsficiencias Millstone 3 i Progress: Performance is tracking to satisfactory. The Performance Improvement Plan goal i

4 is to have fewer than 10 by December,1998. 1 i

y Goal: <10 deficiencies by 12/98 f

~

s 8 8 e

8 8

8 s

8 s

l le 8 8 e

8 s

9 s s B e o a l Def. > 6 Mos. Old Def. < 6 Mos. Old Goat (Total)l R09V D000 -

7/5/98 7/12 S8 7/1998 7/26/98 8/2/98 8/9S8 8/16S8 Br2398 8/30/08 9/6/98 9/1398 9,"20 S 8 977S8

) Def. 3 6 Mos. Old 1 1 0 0 0 0 0 0 0 0 0 0 0 Def. < 6 Mos. Old 7 22 23 25 25 16 22 19 19 19 16 16 15 Lit Annundators 0 0 0 0 0 0 0 0 0 10 9 9 6 Total Defidencies 8 23 23 25 25 16 22 19 19 19 16 16 15 j Goal (Total) 10 10 10 10 10 10 to 10 10 10 10 10 10 h OnRrshion AnekeWAction l This indicator depicts the number of Control Panel Deficiencies and Lit There are no deficiencies older than 6 months and the j Annunciators. total is slowly trending toward the goal specified by the

{ Performance Plan for 1998 2000. Increased Control panel and annunciator deficiencies are control room management attention is being applied to this area.

! instruments, recorders, indicators, and annunciators that functior i improperly and could challenge the ability of operators to me- ri and control plant conditions.

Gosis Cannients The goal is to have fewer than ten control room and annunciator Repairs that are complete, but await documentation O deficiencies by 12/98.

Performance Plan item B.2.c closeout or retest under specific plant conditions are not included in the total.

Data Source: Ops Shift Technicians l Analysis by: J Langan x5544l Owner: B Pinkowitz x42o3MP A-7

Oparator Work Arounds Millstone 3 YOgreSS; Progress is not meeting management expectations. Action Is In progress to Include the Operator Work Arounds into the 12 week roIIIng schedule.

1 25 -

G0al(Total): s 10 20 - - -

15 10 O I I l.. l l l l l l l l l

~

E E R S 3 5 8 8 5 5 8 R l l M W/A > 6 Mos. Old M W/A < 6 Mos. Old i iNew Criteria W/A Goal l

MewOnts 7/5/98 7/12/98 7/19/98 7/26/98 8/2/98 8/9/98 8/16/98 8/23/98 8/30/98 9/6/98 9/13/98 9/20/98 9/27/98 l Total Operator Work Arounds 15 17 17 18 18 18 18 18 17 20 20 20 20

'/A > 6 Mos. Old 8 8 9 9 9 9 9 9 8 8 8 8 8 W/A < 6 Mos Old 1 1 0 0 0 0 0 0 0 0 0 0 0 Ntw Criteria W/A 6 8 8 9 9 9 9 9 9 12 12 12 12 Goat 10 10 10 10 10 10 10 10 10 10 10 10 10 DeGr&Jon - AneWelefAction Operator Work Arounds (W/A) are ccnditions which require an operator to The procedure in effect in April of 1996 froze the work-work with equipment in a manner other than original design intended. around population. This population has 9 remaining, which met the restart goal. In accordance with the Operator Work Arounds have potential to: procedure controlling W/As, new W/As have been added e impact safe operation during a plant transient to the total and will be worked off to meet the new goal of

. impose significant burdens during normal operation less than 10 by the end of the year. Further changes to e Create nuisance conditions due to recurring equipment deficiencies the workaround program are under evaluation including

• Distract operators from noticing recurring conditions. more specific definitions for tracking purposes. The goal may be adjusted to account for the definition at that time.

It is desirable to have a small number of operator work arounds, and to limit the time such work arounds persist. Action is in progress to include the W/As into the MP312 week rolling schedule.

This indicator depicts the number of operator work arounds that exist, relative to Unit 3 goals for both number and age.

Goal Comments The goal is to have no more than ten Operator Work Arounds by 12/98 Repairs that are complete, but awaiting retest under

( ^ yith none greater than 1 year in age, specific plant conditions, and long term OWA's, are not t

( /erformance Plan item B.2.c included in the total. Age data will be revised to reflect the Performance Plan criteria.

Data Source: L. Palone x4737MP l Analysis by: K Kirkman x5090l owner: J. R. Beckrnan x5361MP A-8

1 4

Human Performanco I i

Millstone 3 '

Progress: Performance needs Improvement.

4 100%

, m Goal: ;t 95% of Total 90% -

85% -

e- '

i 1

75 %

Good S 70% -

i '

65% - ,.

60% - .

I # 55% -

50 %

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec j 98 98 98 98 98 98 98 98 98 98 M 98 l  % Low Significance (Precursor) Errors Goal l i

j MewOsas -

! Jan-98 Feb-98 Mar-98 Apr-98 May-98 Jun-98 Jul 98 Aug-98 Sep-98 Oct-98 Nov 98 Dec-98

{  % Low Significance (Precursor)

Errore 91.8% 90.7 % 93.1% 91.1 % 82.6 % 86.3 % 92.5% 97.4 % 90.0 %

Goal 95 % 95 % 95% 95% 95 % 95% 95% 95 % 95% 95 % 95 % 96%

] Human Error Precursor Events 112 107 81 102 76 69 37 37 9

Human Error Near Miss Events 8 11 6 10 16 11 3 1 1 Human Error Breakthrough Events 2 0 0 0 0 0 0 0 0 Total Human Enor CR s 122 118 87 112 92 80 40 38 10 1000 Productive Hours Worked 154 54 164 55 165 59 155.66 150.03 134 61 148.65 96.22 90.70 1 N 00Nrdilon AndysWAC60n ~

4 This indcator depicts the percentage of human errors with low MP3 has realized a reduction in total productive significance relative to the total human errors identified, and compares hours consistent with a reduction in the ratio of

the percentage to the unit goal. Human errors are identified through precursor to near miss and breakthrough events.

Condition Report evaluation, and the errors are categorized by significance level.

The reduction in productive hours is a function of the MP3 restart with the related reduction in j The most signifcant errors are called " breakthrough events", and are contractor forces. The work performed by our i

characterized by a breakdown of all barriers. Breakthough events result contractor forces was principally outside of the

, in consequential events such as plant transients, major equipment power block on tasks that rarely resulted in a damage, operation outside of the design bases, etc. "Near-miss" events human error. Therefore this is considered an involve the breakdown of multiple barriers, but have little consecuence.

area to monitor closely as a new baseline and As such, they represent a lower significance level. " Precursors" involve trend are established, the breakdown of few barriers, are caught earlier in the event chain, and generally result in no significar,' consequences. Precursor events represent the lowest significance byel.

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

G06' Commente

, The goal is for the percentage of low significance errors Data mostly reflects preliminary trend codes (precursor events) to be > 95% of the total human errors before CR investigation is performed.

identified.

Data Source: ArrTS! Analysis By: G. Rescek x2433 MPlOewner: G Wirders x5491MP A-9

t i

O 1

4 l

t L

Safety Conscious

'o 4

Work Environment

! Indicators i

l i

t j

i I

iO k

1 l

Loadorship Assossmont(SCWE Elomont)

Millstone p Progress: Progress is satisfactory. The June 1998 Leadership Assessment

& results indicate that the goal continues to be met.

1 -

0.9 -

0.8 - Goal 290%

0.7 -

g 0.6--

b 0.5 -

=

j 0.4 - A l

0.3 -

Good I 0.2 -

l 0.1 -

l 0 l l , l Jun Jul A99 Sep Oct Nov Dec Jan Feb Mar Apr May Jun  ;

97 97 97 97 97 97 97 98 98 98 98 98 98 l l  % Employees Willing to Raise issues to Mgnt. Leadership Goal l New Dets .

Jul-97 Aug-97 Sep-97 Oct-97 Nov-97 Dec-97 Jan-98 Feb-98 Mar-98 Apr.98 May-98 Jun-98 l

% Ernployees Wilhng to Raise issues to Mgnt. 97.9 % 98.7 %

Goal 90.0 % 90.0 % 000% 90.0 % 90.0 % 90.0 % 90 0 % 90.0 % 90.0 % 90.0 % 90.0 % 90.0 %

s G onunman answeacean This indicator depicts the percentage of employees The June 1998 Leadership Assessment results surveyed, by means of the Leadership Assessment indicate that the goal continues to be met.

evaluation tool, who rate their supervision as either effective, very effective, or extraordinary in their handling of The schedule for the performance of next Leadership employee concems. Assessment is fall 1998 with annual assessments there after.

This indicator is considered a valuable data point in evaluating the confidence and willingness of Millstone employees to raise issJes 10 their supervision. It is used in conjunction with other similar indicators as evidence of the presence and strength of the Millstone Safety Conscious Work Environment.

Gael Commente ,

The Goalis 2 90% of the employees surveyed to report a Data is current through June 1998.

willingness willing to raise concerns to their supervision.

p Supports SCWE Success Criterion #1 V l Data Source: Leadership Assessment l Analysis by: M. Gentry x5728MPl Owner: M. Gentry x5728MP B-1

Culturo Survoy (SCWE Elsmont) l Millstone O Progress: Performance Is considered satisfactory. Other short-term Indicators, including ECOP survey results provide additional evidence of performance quality.

1 l 0.9 -

Goal190%

[ o8- ,

E 0.7 -  !

f 06- '

0.5 - d l x * " Good I 0.3 -

h 0.2 -

0.1 -

0  ;

Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun 97 97 97 97 97 97 97 98 98 98 98 98 98 i'

lM% EmpIOyees Agree That SCWE Exists Culture Goal l MetF M - '

Jul-97 Aug-97 Sep-97 Oct-97 Nov 97 Dec-97 Jarw98 Fet>-98 Mar-98 Apr 98 May-98 Jun-98 l

% Ernployees Agree That SCWE Exists 82 0 % 86 6 %

Goal 90 0 % 90 0 % 90 0% 90 0 % 90 0 % 90 0 % 90.0 % 90.0 % 90 0 % 90 0 % 90 0 % 90 0 %

r, 00Rnnion AnakeWAcdon This indicator depicts the percentage of employees The June 1998 Culture Survey results fall short of the surveyed, by means of the Pll Culture Survey, who rate .long-range goal by 3.4%, but represents an increase of their work environment as conducive to raising and 4.6% over the November 1999 results. This continues resolving concems, to indicate that a majority of the employees surveyed rate the work environment as conducive for raising This indicator is considered a valuable data point in concems.

evaluating Millstone employees' comfort with the current concerns environment and their confidence in programs, Progress is demonstrated based on the approximate peers, supervision and upper management in supporting a six month period for data collection. Culture Surveys SCWE. It is uced in conjunction with other similar indicators are normally performed biannually, with the next survey as evidence of the presence and strength of the Millstone schedule for December 1998.

Safety Conscious Work Environment.

When Culture Survey data is considered in conjunction with other indicators, including more recently administered Employee Concems Oversight Panel (ECOP) surveys, progress in this area is satisfactory.

Goel - - Comments Data is current through June 1998.

The goal is for > 90% of the employees surveyed to report l a willingness to raise concems to their supervision.

i i Supports SCWE Success Criterion #1 Culture Survey l Analysis by: M. Gentry x5728MPl owner: M. Gentry x5728MP Data Source:

B-2

~ '

~ Scf5ty Canecicuo Wdrk Envir5nmant Empicyee2 Willingn=s to R;ies Cencarns NU Concerns and NRC Allegations Received, Millstone Station 0 Progress: Performance Is satisfactory. The number of allegations to the NRC remains at a low level while the number of concerns received by ECP is comparitively 1 high. 1 40 35 3 Data current

[ 30 through 9/30/98.

f 25 h20 ,

g_ -

15 o 10

=

0  ;

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

-*-NU Rec'd -G-NRC Rec'd l

- , _ K:' _) y[- _ [ . j_y['j_' Q'_;_f,Yy. b yj . l'j; .;.y

.}.,.: _ } i j;'T.

l Jan-98 Feb-98 Mar 98 Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov 98 Dec-98 NU Received l 27 20 l 23 l 20 l 17 18 l 19 l 22 l 19 l l l NRC Received l 4 6 l 4 l 4 l 2 S l 1 l 0 l 2 l l l NU Rec'd YTD l 27 47 l 70 l 90 l 107 125 l 144 l 166 l 185 l l l l

NRC Rec'd YTD l 4 10 l 14 l 18 l 20 25 l 26 l 26 l 28 l l l b l l l l l l l l l This indicator depicts the number of concerns received each The relatively steady number of concems submitted to the month by the Millstone Employee Concerns Program (ECP) ECP, coupled with a declining number of personnel on relative to the number of allegations associated with Millstone site, suggests growing employee confidence in the ability issues or problems which have been submitted to the NRC of the Millstone ECP to provide an effective means by during the same time period. which concems can be resolved. The average number of concerns received per month in 1997, was 16. The The Millstone Employee Concerns Program (ECP) accepts average number for 1998, through September was 21, a concerns related to a wide variety of issues, including nuclear 30% increase over the 1997 average.

safety or quahty, management, industrial safety, security and other topics. Concerns may be submitted by current or former employees and contractors. NRC allegations regarding Millstone issues may be submitted by the general public, current or former employees and contractors or members of the NRC.

Concems may also be filed concurrently with the Millstone ECP and the NRC in the same time period.

NU has not established a specific goal with respect to concerns l Data current through 9/30/98.

received. However, it is desirable to have a relatively small number of allegations submitted to the NRC as a measure of employee confidence in the various NU resolution systems.

Performance Plan C.2.c.

O kJ Supports SCWE Success Criterion #1 Dets Source C. Mihako x4541MP l Analysis by.- C. Mihako x4541MPl Owner- E. Morgan x4335MP B-3

4 4 .w- 6,._A... .dk. _ .,.-.,,L .4-.= 4 A4 ,u.+,sn #na_EeS 4 ,&~J m Millctana Empicyco Cencarna Confidontinlity Trand Millst:ina St:tian i l

(} Progress: The willingness of employees to raise concerns is satisfactory. Thirty five percent of Concerned Individuals requested confidentiality or are anonymous for 1998.

40 i 35 Data current through 9/30/98.

30

, 25

• 20 ris l 10 i

l 0 l l l Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 l -*--Total Received Anonymous and Confidentiality Requested l l Jan l Feb l Mar l Apr I May Jun l Jul l Aug l Sep l Oct l Nov l Dec Total Received by Month] 27 l 20 l 23 l 20 l 17 18 l 19 l 22 l 19 l l l Anonymous l 7 l 3 l 6 l 7 l 2 6 l 5 l 4 l 3 l l l Crmfidentiality Requested l 3 l 6 l D l 2 l 1 s l 4 l 2 l 2 l l l Confidentiality Waived l 15 l 12 l 16 l 11 l 14 10 l 8 l 16 l 14 l l l

% Anon. and Confklentiality Req l 37.o% l 40.0% l 26.1% l 45.0% l 17.6% 44.4% l 47.4% l 27.3% l 26 3% l l l This indicator depicts the number of concerns which are reported to 35 percent of concerns have been filed anonymously or the Millstone ECP anonymously, and those for which confidentiality have requested confidentiality since the beginning of is requested, relative to the total number of concerns received. 1998.

Each individual submitting a concern may request or waive Five of the 19 concerns received in Septernber were confidentiality. Anonymous concerns are also submitted. either anonymous or requested confidentiality.

Concerns requesting confidentiality or anonymity are reviewed to determine (1) if there is a significant change in either the number or percentage of concems filed anonymously or requesting confidentiality, (2) if any categories show discernible changes in make-up or source of the concerns, and (3) if any new " focus areas" are identified.

The goal is to show no adverse trends in requests for confidentiality Data current through 9/30/98.

or anonymity, based upon an analysis of the concerns and data.

Performance Plan C.2.a.

Supports SCWE Success Criterion #1 lDets Source: C. Mihako x4541MP l Analysis by: C. Mihako x4541MP l Owner

• E. Morgan x4335MP B-4

I 1

Employco Concsrns Resolution Timalinoss '

Millstone Station f~

Progress: Progress Is satisfactory. The Improved timeliness of employee concerns l resolution achieved during the past year is being sustained.

90 80 -

70 -

g 60 -

• 50 -

40- Good lil lll lill ll ll ll ll ll ll l C

m h

~

e E

t m

b R

e s

I e

l e

b 5

e 5

e m

h

=

m h

a m

b 5

e 2

m lE Average Age l uma::a w.cx _- .

_g . _

7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 8f26/98 9/2/98 9/9/98 9/16/98 9/23/98 9/30/98 Average Age 31 27 32 32 27 32 32 33 32 38 39 36 42 N._,/ Open < 45 Days 15 25 20 19 14 15 14 17 13 15 18 20 13 Open > 45 Days 3 3 6 9 6 6 6 6 8 8 9 8 9 Concerns Under Investigation 18 28 26 28 20 21 20 23 21 23 27 28 22 y&  :& % yQgy %%gf "" "" - % L .gggggQQq ;QQgp8gq This indicator depicts the average age of concerns under The average age of concerns under investigation has stayed investigation. Concems under investigation represent 'evei for the past four weeks. The average age of completed Employee Concems Program (ECP) work in progress, ECP investigations for September is 39 days.

including data gathering and analysis.

_----- c. 1 ,

Data current through 9/29/1998.

• Ng lig ) 4 ggg-gfgu gsg.gJ.B B The goal is for the average age of unresolved concems to show no adverse trend. Performance Plan item C.2.c.

('

Supports SCWE Success Criterion #3 Data Source: C. Mihalko x4541 MPl Analysis by: C. Mihalko x4541 MPl owner: E Morgan x4335MP B-5

i j Focus Arca Action Plan Status r

Millstone Station rogress: Progress is satisfactory. Resolution of all focus areas is proceeding as expected.

,s 1

2

2 t

.I'0

=

I lL 0

l IIIIIIIIIIII T

{:

I I

I m

I I I e

I o

I p>

I e

I m

I i

8 s s

8 s $ B k

B j $ 9 B

5 B

E 5

. (EOpen Focus Areas l 10w Dnk i 7/9/98 7/16/98 7/23/98 7/30/98 8/6/98 8/13'98 8/20/98 W27/98 9/3'98 9/10/98 9/17/98 9,"24'98 10/1/98 Open Focus Areas 8 7 6 6 6 6 6 6 6 6 6 6

] 6 j overdue Action Plans 0 0 0 0 0 0 (, 0 0 0 0 0 0 1

} Focus Areas 33 33 33 33 33 33 33 33 33 33 33 33 33 i Action Plans in Place 8 7 6 6 6 6 6 6 6 6 6 6 6

Vction Plans Completed 25 26 27 27 27 27 27 27 27 27 27 27 27 i

}ction Plans To Develoo 0 0 0 0 0 0 0 0 0 1 0 0 0 0

}

3

?n@& AnekslalAc6on l Thit indicator depicts the number of focus areas currently identified and the All open Focus Areas have action plans in place.

statta of action plans to correct identified weaknesses. A Focus Area is define 1 as an area of personnel interaction where a Safety Conscious Work Several focus areas have been closed out and assessment of Enviror, ment is challenged or does not exist. Others is still required before final close out.

The followng indications are used to identify the Focus Areas within the Villstone orjanization:

• Leadership Assessment score less than 4.0 (" Effective") in either the Employee Concerns area or the Overall score.

. Significant incidents

• Surveys

• Pil Culture Survey - The Safety Conscious Work Environment characteristic score is less than 3.0 (" Generally Agree") and is substantiated by a second indicator.

• Employee Concerns Program - Significant or multiple occurrences Communis within an area which are substantiated by a second indicator.

• Employee Concems Oversight Panel- Significant or multiple occurrences within an area that are substantiated by a second indicator.

• Independent Third Party Oversight - Identified areas based on investigation. Goal

• NRC - Identified areas based on investigation. The goalis to have the number of focus areas steady or declining with no overdue action plans.

Supports SCWE Success Criterion #4

\/~'k Source: A Elms x5388MPI Analysis by: A Elms x5388MPl Owner: D B Amenne XO437MP w

B-6 1

Substantictcd Conc 3rno involving PetGntici Violatiens of 10CFR50e7 Millstone Station Performance is satisfactory. There were no substantiated concerns involving O Progress: potential violations of 10CFR50.7 since August 1997.

40 88 ~

Data current 30 through 9/30/98.

25 -

g 15 -

= ^ Good 10 -

1f 5-0 a  :.

Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 JL.d 98 Aug 98 Sep 90 Oct 98 Nov 98 Dec 98 M # Substantiated Potential 10cFR50.7 Concerns --S-Total Concerns Received - 1er-# Alleged 10CFR50.7 HIRD Concems l Jan-98 l Feb-98 l Mar-98 l Apr-98 l May-98 Jtm-98 l Jul-98 l Aug-98 l Sep-98 l Oct-98 l Nov-98 l Dec-96 Total Concorr,J Received) 27 l 20 l 23 l 20 l 17 18 l 19 l 22 l 19 l l l

1. Alleged 10CFR50.7 HIRD Co 11 7 4 3 2 4 1 0 0

1. Substantiated Potentiel10CFR50.7l l l l l l l l Concemel 0 0 l 0 0 l 0 0 0 l 0 l 0 l l l Total e of HlRD Corcems Received l 18 l 11 l 11 l 10 l 4 7 l 7 l 7 l 2 l l l

% HIRD Concerns l 59% l 55% l 40% l 50% l 24% 39 % l 37% l 32% l 11% l l l

% Alegwd 10CFR50 7 HIRO Concerns l 37% l 35% l 17% l 15% l 12% 22% l 5% l 0% l 0% l l l This indicator depicts the number of concerns received by the Millstone A conservative classification criterion is used to Employee Concerns Program (ECP) alleging cases of Harassment, categorize and investigate alleged 10CFR50.7 t IIRD intimidation, Retaliation or Discrimination (HIRD), including those based issues. Importantly, since December 1,19%, only on race, sex, and national origin. It depicts the number of potential and three concerns have been substantiated as involving substantiated HIRD concerns involving alleged 10CFR50.7 violations a potential violation of 10CFR50.7, and all three are relative to the total number of concerns received. related to a single event (MOVs).

10CFR50.7 is a federal law which provides for the protection of Open 10CFR50.7 concerns receive the highest individuals engaged in protected activities. An example of a protected investigative priority. Site management continues to activity is when an individual identifies an issue that he/she believes educate, address and when appropriate, discipline impacts any aspect of activities at the Millstone Site that are regulated any personnel involved in such activities.

by the NRC, and communicates that concern to co-workers, supervisors, the Employee Concerns Program (ECP), the NRC, Congress, or the media.

A Substantiated concerns invoMng potential violatione of 10CFR50.7 are Data current through 9/30/98.

'\j infrequent and handled effectively. Performance Plan C.2.d l

Supports SCWE Success Criterion #4 Dets Source: C. Mihako x4541 MP l Analysis by: C. Mihalko x4541 MPlonner: E. Morgan x4335MP B7

--%._-m_4.. -a 42,u-A4,s- # _ A m ed .- a a ddA 4 4a m.A _4 4 h e. a.a 4.8-.6A43w -4'lk-.,4A 4 E4mm .mmeadn d ee.d a4M 6w AmEh4E Ab e %--m e-Ehpadu. mW wa meda-am-- M'-mmma--a44--ww.-

- e m.mmemaw--ww-_.

m 4

i J

lO I

l 1

i i

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i i

! l l

1 1

l l Nuc ear Overs'ght iO i

Indicators i

' 1 l

i l

i

(

iO t

i 1

Statuo of bvdrdight Condition Rcporto Milletono 3 I l

a

(} Progress: Performance is tracking to satisfactory.  ;

1 I

50 I

40 Data thru 9/29/98 Good 1

20

. E l

. l l l lEl l l l l l l

', Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep 97 97 97 98 M M

)

) 98 98 98 98  % 98 l 5 Level 1 CRs >30 days old without approved CA Plan l l 5 Level 2 CRs >30 days old without approved CA Plan l

~

l' RderDode '

Oct-97 Nov-97 Dec-97 Jan-98 Feb-98 Mar-98 Apr-98 May-98 Jun-98 Jul-96 Aug-98 Sep-98 Open 31 38 45 31 33 19 45 42 50 28 36 32 l

Total 1&2 >30 days 2 6 25 9 6 3 17 7 15 20 8 10 3

Level 1/>30 days 10 2/1 5/1 5/4 4/2 2/1 4/2 4/3 12/5 7/7 2/2 1.0 Level 2/>30 days 3o'2 36/5 40/24 26/5 29/4 17/2 41/95 33/4 38/10 21/13 34/6 31/10 Denrdian' AnelssWAction

This graph displays the status of open Condition Reports A review of the data with unit Corrective Action i (CRs) initiated by Nuclear Oversight for adverse, department identifed a discrepancy with the

. discrepant, or other conditions needing improvement. understanding of the CR status process codes in I

AITTS. The August data was adjusted on this KPl to An Open Condition Report is one for which the reflect the unit's use of the status process codes.

evabation for reportabihty and operability, failure mode i and/or root cause has not been performed, or, has been performed, but not yet approved.

4

)

i 1

0000- COR9R80nts No Level 1 or 2 CRs open > 30 days without approved extensions.

i Data Source: M BaHrii x4456l Analysis by: J Beaucharno X2113l owner: J Streeter x4300 C-1

l Nucbcr Oversight Vcrification Plan Reculto  !

l Millstona 3 3rogress: Work Control, Engineering, Maintenance, and Chemistry exhibit 1 O characteristics needing Improvement to achieve a satisfactory rating.

The remaining assessed areas show satisfactory performance.

Continued improvement is necessary In all areas to achieve excellence.

Unit Evaluation Areas l l 7/10/98 l 8/6/98 l 9/11/98 l 10/9/98 l l

)perations l Y l Y, l Y- -

l Vork Control l .Y .l Y- l Y ^ .l Y l ingineering l Y: l Y

orrective Action mm IelfAssessment M i Azintenance l ^ Y: }Y j frith Physics ma l

hemistry mme b-- _ _ _ _ ___

1:fuelOutage Preparation MM Evaluation has not yet begun.

l Common Site Programs 7/10/98 8/6/98 9/11/98 10/9/98 imergency Plan

'r:InIng invironmentalMonitoring

• " ~ gfMg5tNgy/vt@tigg!gp)lggEM?g$mMgrsR$9%%$Wyttggggft%$%fQQyPfl@$W/49Q$@$$

Each of the above listed issues are assessed based on a set of attributes derived from NU,INPO and NRC documents which provide standards, objectives and inspection guidance. Colors will normally change after two periods of consistent performance.

Satisfactory / Normal (GREEN)

I Tracking to Satisfactory /Needs improvement (YELLOW)

Not Meeting Management Expectations /Significant Weakness (RED)

Not Assessed (BLUE) i

_ a Source: AssignedLeads l Analysis by: Assigned Leads l Owner: J. Streeter C-2

0 Additional O

Indicators l

1 l

lo

lO 4

J i

b i

1 5

}

4 i Procedure Compliance ty~

and Quality Indicators 4

i i

i l

^.

i 4

i 4

o 1

i

Proccduro Complianco Millstone 3 l Progress: Performance is satisfactory, however, if the current trend continues, the goal willbe challenged.

1.00 --

0.90 -

] 0.80 -

t 5o 0.70 -

Station Performance

! O 60 ~ Plan Goal < 0.50 Good l 0.50 - l 5 0.40-y 0.30 - MP 3 Goal < 0.25 i 1

M 0.20 - l 0.10 -

0.00 l 1 l l l I l l l I I Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov 97 98 98 98 98 98 98 98 98 98 98 98 l M Total Non Compliance Errors /1000 hrs MP3 Goal --M-StatK>n Performance Plan Goal l RetF M ' '

g Jan-98 Feb-98 Mar-98 Apr.98 May-98 Jun-98 JuF98 Aug-98 Sep-98 A Total Non Compliance Errors /1000 hrs 0.48 0.32 0.25 0.40 0.29 0.37 0.12 0.24 0.43 MP3 Goal 0.25 0.25 0.25 0.25 0.25 0.25 0.25 0.25 0.25 Station Performance Plan Goal 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 Technical Procedure Non-Compliance Errors /1000 hrs 0.11 0 06 0.05 0.05 0.03 0.05 0.03 0.06 0.09 Admin Procedure Non-Compliance Errors /1000 hrs 0.37 0.26 0.20 0.35 0.27 0.32 0.09 0.18 0.34 HOURS WORKED (1000 HRS) 154.54 164.55 165.59 155.66 150.03 134.61 148.65 96.22 90.70 Technical Procedure Non-Compliance 17 10 8 8 4 7 5 6 8 Administrative Procedure Non-Compliance Errors 57 43 33 55 40 43 13 17 31 Total Non Compliance issues 74 53 41 63 44 50 18 23 39 DeNrn on A.nelystalAction This indicator depicts the procedure non-compliance errors per 1000 Increased focus on procedure compliance hours worked. Procedure non-compliances are broken down into 3 by station management has succeeded in categories: non-compliance with technical procedure-these errors reducing procedure non-compliance.

are associated with operational or maintenance procedures or work orders and are generally continuous or general level of use procedures; The unit is currently meeting the station non-compliance with administrative procedure-these errors are goals although the trend is unsatisfactory, associated with a non-compliance with an administrative or program procedure and are generally level of use procedures.

Total Non-compliance error rate is calculated based on the total of administrative and technical procedure violations per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> worked.

Goal Comments The Unit 3 goal is for procedure compliance errors (CRs) to be < 0.25 MP3 has recently set 0.25 as the new goal.

) errors per thousand man hours, with the Station Performance Plan Goal remaining < 0.50 errors per thousand man hours.

Data Source: AITTS l Analysis By: M. Finucan x3564l Owner: G. Winters x5491MP D-1

1 l

l CR0 Invciving D3ficiant Tcchnical Procodurco l Millstone 3 i

p Progress: Progress is satisfactory. A favorable performance trend which began after the l Q System Specific Assessment reviews, has continued into 1998.

l I l 45 1

40 - Data current through October 4,1998 35 -

Start of

, e 30 - monthly 25 -

trending i,. / -e E

• 15 -

l

. Goal < 5/ month

_ h,g 0 0 0 0 0 0 0 0 0 0 0 04 '96 Q1 '97 Q2 '97 Jul 97 Aug Sep Oct 97 Nov Dec Jan99 Feb Mar Apr98 May Jm 98 Jul98 Aug Sep 97 97 97 97 98 98 98 98 98 Upgraded Non Upgraded l Goal l l gg- , a+%4 Unit 3 Oct 97 Nov 97 Dec 97 Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jd 98 Aug 98 Sep 98 Upgraded 0 0 0 1 0 0 0 0 0 0 0 0 Non Upgraded 0 0 0 0 0 0 0 0 0 0 0 0 OnnnMan A~ AheknWAc60n l This indicator depicts the nurnber of condition reports (CRs) Following a peak in second quarter 1997 which t

generated as a result of procedure deficiencies. A review to resulted from SSA discovery efforts, the total number determine if procedure technical content influenced the initiation of of procedure related CRs for Unit 3 trended downward, the condition report is performed on CRs involving technical with monthly values below the goal level for the past 13

, procedures from the following departments: Operations, months, and remaining at zero for 11 of the last 12 l

Maintenance, instrument and Control, Engineering, and unit specific months.

l Chemistry and Health Physics procedures.

l CRs involving administrative procedures and failed administrative processes, such as document distribution and reproduction, are not included in the review and are not represented by the data above.

Also not included are Emergency Operating Procedures (EOPs) and Abnormal Operating Procedures (AOPs) which are not included in the Technical Procedure Upgrade Project.

! gogg .

I The goalis to have no more than 5 CRs per month initiated as a result of procedure deficiencies.

Conenener <

, Data current through Octooer 4,1998 Unit 3 Upgraded Procedures = 1244 Unit 3 Non-Upgraded Procedures = 0 Total No. of Unit 3 Level 1 CRs = 2 p)

V Total No. of Unit 3 Level 2 CRs = 76 Total No. of Unit 3 Level A CRs = 0 Total No. of Unit 3 Level B CRs = 6 Total No. of Unit 3 Level C CRs = 29 Dars Source: AITTSl Analysis by: R Bireley/T. Kulterrnan x5421MPl Owner: T. Kirkpatrick x6204MP o-2 l

1

O Additional Corrective O Action /Self AssessmentIndicators O

M;dian Ago cf Loval1 & 2 Condition Rcporto Millstone 3

n Progress: Performance is not meeting the stated goal and additional management action is being taken.

325 300 . .

275 "A  :  ;

250 225 c  :  ;

p_

- - =

" ~ "

200

• 175  !

k15o GOOD I 125 100 75 Y 50 ,

25 0 '

l l h h s ~ $ e s s G 5 8 s l-+-Level 1 CR Median Age -m-Level 2 CR Median Age l gg; '

-Y{ , ;p 9 ,

7/B/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 8/26/98 9/2/98 W9/98 9/16/98 9/23/98 9/30/98 Level 1 CR Medien Ago 249 250 245 262 265 278 286 292 293 300 273 274 275 Level 2 CR n's16en Age 210 213 222 226 227 233 231 254 244 252 217 223 227 Ext ident Lvl1 Med. Age 211 218 225 232 239 246 252 260 267 274 281 288 296 Ext. Ident. Lvl 2 Med Age 160 167 174 181 188 265 201 209 217 223 230 232 245 Y int. Ident Lyl1 Med Age 225 212 219 226 233 240 246 254 261 268 275 302 290 Int. Ident Lvl 2 Med. Age 230 237 244 252 258 265 271 277 284 289 295 294 295 Total Open CRs 3404 3403 3392 3403 3445 3481 3532 3521 3503 3495 2285 2267 2237 Open tevel1 CRs 250 254 258 257 255 254 253 254 256 255 255 197 197 Open level 2 CRs 3154 3149 3134 3146 3190 3227 3279 3267 3249 3240 2030 2070 2040 l CRs Open >120 Days 1269 1276 1295 1310 1346 1366 1379 1512 1513 1518 1522 1461 1462 l Open Level 1 >120 Days 139 140 147 145 148 156 156 161 162 162 165 164 165 l Open Level 2 >120 Days 1130 1136 1148 1165 1198 1210 1223 1351 1351 1356 1357 1297 1297 l y_ ,

, _ , _ , ~ . - l This indicator depicts the median age of open Level 1 and 2 Condition Performance during the third quarter is not meeting the Reports (CRs). stated goal. The median age of open Level 1 CRs and open Level 2 CRs is slowly increasing.

Unit 3 Corrective Actions department is focusing on closing CRs as soon as their Corrective Action Plans are complete.

Additional actions are being assessed to move performance in this area to expectations, yu -

, , n_-__._

The goalis to have the median age of Level 1 & 2 CR's decline over CR's which have no open assignments and are time. awaiting administrative closecut have been subtracted from the open level 1 and 2 CR population.

(

Dets Source: AITTSl Analysis by: G Rescek x2433 MPl Owner: G Whters x5491MP E1

1 ,

I I

i i 1

. O i.

l j

i l

i

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+

i i I

! Nuclear Training O Indicators i

4 l

l i i

4 l

l s

i 1

1 Executivo Training Council Mocting Millstone l QProgress: The Executive Training Council meeting frequency is satisfactory.

l 6

5- ETC Meeting data through 9/30/98

\

Better 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 3rd Otr 98 m Executive Training Council Meetings " Goal NSIF M 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 3rd Otr 98 Executive Training Council Meetings 2 1 4 4 1 Gml 1 1 1 1 1 DennMon - AnalveldAction This indicator depicts the Executive Training Council (ETC) No action required. ETC meeting frequency exceeds the meeting frequency. The function of the ETC is to: established goal.

Communicate management's commitment to safety, high standards, and the effective use of training to help improve worker performance.

Provide management oversight of the Millstone training programs accredrted by the National Academy for Nuclear Training, thereby demonstrating proper stewardship of the resources our company has provided.

Communicate management's commitment to high quality, performance-based training utilizing a systematic approach to training, thereby directly contributing to nuclear safety while supporting the prcper emphasis on improved achievement of agreed upon scheduit,'

Establish and monitor site training goals and performance indicators, thereby communicating the high standard necessary for safe, effective operations.

Review major changes to common site training programs.

Gant ' Comments g The goal is 1 ETC meeting per quarter. ETC Meeting data through 9/30/98 ETC was established in April 1997 Data Source: ETC Meeting Minutes l Analysis by: J. Althouse x2016MPlOwnor: J. Cantrell x2600MP F1

Training Advisory Committoo Mcoting  ;

Millstone ).

Progress: Tralning Advisory Committee meeting frequency Is not meeting management l

\ expectations.

l

{

14 -

l i

13 -

12 -

TAC Meeting data through 11 9/30/98

,, 10 - )'

,[ 9 - j 8- 0 7-o Goal 2 3 Meetings per Otr.

g

-- _=

3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 3rd Otr 98 l

mTraining Advisory Committee Meetings " Goal Raw Onte 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 3rd Otr 98 Training Advisory Committee Meetings 11 14 6 4 2 Goal 3 3 3 3 3 2

DeMnition '

AnalysWAction This indicator depicts the Training Advisory Committee (TAC) Training Advisory Committee's were realigned in July 1998.

meeting frequency. The function of the TACs is to provide Three TACs exist with the fol lowing focus areas:

senior management oversight of Nuclear Training policies and Production TAC: Accredited Programs programs and ensure the implementation of the SAT process. Site TAC: Non-Accredited Programs TACs assess training needs and accomplishments, maintaining Engineering TAC: Engineering Support Programs, a future focus on changing training needs and industry requirements, and setting the strategic direction for training TAC membership for the Site TAC and the Engineering TAC has programs, been established, it is expected that TAC meetings will meet goal for the 4th quarter, Goal - '

Comments The goal is 3 T AC meeting per quarter, which is equivalent to 1 TAC Meeting data through 9/30/98 TAC meeting per focus area per quarter.

D:ta Source: TAC Meeting Minutes l Analysis by: J. Althouse x2916MPl Owner: J. Cantrell x2600MP F. e

Curriculum Advicory Committca Meeting Millstone Progress: curriculum Advisory Committee meeting frequency is satisfactory.

j 160 140~ CAC Meeting data Goal 1 27 Meetings per Otr. through 9/30/98 i I 12o .

e \

100-j g Bo -

5 z *-

A i

l Better 20 - *l 0 * ' '

3rd Ott 97 4th Otr 97 1st Otr 98 2nd Otr 98 3rd Otr 98 r

m Curriculum Advisory Committee Meetings "" Goal MantDate! l 1 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 3rd Otr 98

. Curriculum Advisory Committee Meetings 126 143 106 32 35 l

Goal SS 55 55 55 27 l DeNnMan . AnalystelAction This indicator depicts the Curriculum Advisory Committee (CAC) The 3rd quarter performance is on track to meet the l meeting frequency. The function of the CACs is to establish established goal of 27 CAC meetings per quarter.

] effective training qualification programs and ensure the appropriate design, development, and implementation of SAT- Curriculum Advisory Committees have been realigned based training programs. CACs review, recommend, and approve and consolidated to ensure consistent oursight of their various actions related to new and existing training programs. related training programs. This also reflects CY's 1 decommissioning.

l Station Procedure TQ-1, Personnel Qualification and Training attachment 13, establishes the conduct of CAC meetings. CACs are required to meet at least quarterly. CACs are chaired by a member of station management.

4 Goel Commente l" The goal is 27 CAC meetings per quarter which is equivalent to 1 CAC Meeting data through 9/30/98 meeting per CAC per quarter.

O Dets Source: CAC Meeting Minutes l Analysis by: J Althouse x2916MPl Owner: J. Cantrell x2600MP F3

l j Simulator Availability 1 Millstone Progress: simulator avaltability is satisfactory.

l Simulator Availability data through 9/30/98 1 1000 . . .

4 Goal > 99% '

j 9...; pl s i

99.5% -

lffs I N" q.

b l B 99 0 % - M k 3 -Q 4

4 1  ? 2 l i u ,, .

Si  !

1. 98 5 % - '

BeMer i <

x2: pg

.m-.

l 98.0% - ' ' ' ' - ' ' '

3rd Otr 97 4th Ott 97 1st Otr 98 2nd Otr 98 3rd Otr 98 i

Availabdity MP1 Availability MP2 Avadability MP3 """" Goal MawDein l 3rd Otr 97 4th Otr 97 1st Otr 98 2nd Otr 98 3rd Otr 98 Availabilty MP1 100 00% 99.37 % 99 70 % 99 70 % 100 00%

Availability MP2 99 43 % 99 77 % 99 60% 99 90 % 100 00 %

3 Availabilty MP3 99 88 % 99 94 % 100 00% 99 40% 100 00 %

l l Goal 99 00% 99 00 % 99 00 % 99 00 % 99 00 %

l  %'

i DennMion AnalysWAction '

1 l This indicator depicts the simulator availability for all three No action required. Simulator availability for Units 1,2 & 3 is l Millstone Units. above goal.

5 3

i l

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i 4

\ 0000 Comments The goal is to maintain greater than 99.00% availability for each Simulator Availabikty data through 9/30/98

( Unit Simulator through Unit restart.

! )

e i

Dit3 Source: J. Cataudella x2603MP l Analysis by: J. Althouse x2916MPl Owner: J. Cantrell x2600MP i

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j Leadership and

. Culture Indicators i

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Millstone Station Leadership Ass 0ssment Progress: Performance is satisfactory; however, all categories are slightly down from the Winter 97 survey.

[

Extraordinary 8.00 7.00 -

l Very EMecthe j 6.00 - .

g _

5.00 - N k I b i EttectNo l 4.00 - j( n j f

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3.00 - W t! M D g $ Good somewhat gl b q y y y EUecthe g,gg .

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1.00 InonectNo Communicati Leadership Performance Development Employee Overall ons Concerns

• Average l 5 Winter-96 O Summer-97 0 Winter-97 5 Summer-98 l

• category added in summer 97 Af0Ir M -

Winter-96 Summer-97 Winter-97 Summer-98 Fall-1998 Communicahons 4.77 5.61 5.75 5.74 Leadersho 4.95 5.77 5.88 5.84 l {g Performance 4.42 5.29 5.34 5.31 Develonment 4.64 5.45 5.54 5.53 Employee Concems

• 6.11 6.19 6.15 Overall Average 4.70 5.65 5.74 5.71 DunsMaus DenrnMots (cont!.~M.'

The Leadership Assessment is a management tool for evaluatin9 The primary purpose of the Leadership Assessment is to the relative strengths and needs of individual management provide meaningfulinformation to Millstone management personnel at the Millstone Station, from first-line supervisor for the purpose of individual development. Although not a positions through the Nuclear Group CEO. A total of thirty nine statistically valid survey tool, the results are also evaluated questions are posed to employees regarding leadership at an organizational level to trend improvement in performance in four separate categories: Communications, management performance.

Leadership, Performance Accountability, and Development; a fifth category for evaluating performance relative to Employee Concems was added to the assessment in the Summer of 1997. Arie&sWActiers Responses are evaluated against an 8-point scale, with "1" Movement in the Leadership score is essentially negligible, representing ineffective performance, "2 3", indicating somewhat with a slight (.04) drop. All categories continue to score as effective, "4-5" rated as effective, "6 7" depicting very effective " effective" (4-5), at a minimum, with employee concerns performance, and '8" representing extraordinary performance. showing as "very effective" (6 7).

goggi -

og,,,,sersis '

j The organizational goal is to show improving trends in all categories.

! Data Source: Leadership Assessment l Analysis by: J Gorski ro462MPl owner: J Gorski x0462MP G.1

Millstone Station Cultural Survey Progress: Performance is satisfactory. Overall, the data Indicates a sustaining of the positive culturalImprovement observed over the last year. Results O~ from the June 1998 Culture Survey show a slight decrease in the Adjusted Culture Index.

25.00 1

i 20.00 -

15.00 -

Goal = 13.0 10.00 -

l 5.00 - Good 0.00  :

l Jun-96 Oct-96 Jun-97 Nov-97 Jun-98 El Adjusted Culture Index i

RGW M

• Jun-96 Oct-96 Jun-97 Nov-97 Jun-98 i

s Adjusted Culture Index 11.60 11.46 12.88 13.07 12.99 Nurnber of Participants 1026 1240 1487 1926 0 Goal 13 13 13 13 13

~

, DeRnnion AnalysiafAction j NU originally contracted Performance Improvement Despite the slight decrease (< 1%)in the Adjusted

! International, Inc. (Pil), formerly FPI, to assist in the Cultural index (Cl), the data indicates a sustaining of the assessment and improvement of nuclear organization at positive cultural improvement observed over the last j the Millstone Station. A " culture survey" was conducted year. Analysis of the decrease in the Cl indicates the to quantify employee responses on five critical factors decrease is not statistically significant. Continued that Pil has determined have high statistical correlation management attention is still required.

to future organizational performance. The five critical areas are: High Management Expectations via Strong The range of the Cl is 5 to 20. A Cl of less than 8 is

! Mission & Goals, High Knowledge & Skill Level, Strong indicative of problem or Wa*ch List plants. A Cl of I

Lateral Integration, Simple Work Processes, and Strong greater than 14 indicates a strong probably of

Self-improvement Culture & Program. The results of the continuous improvement. Scores ranging from 10 -14 is

, survey are used to construct the Pil " Culture Index." a metastable range, indicating the need for continuous

! This Culture Index (Cl) has been statistically monitoring and trending to assure sustained i demonstrated to have a strong correlation to future performance improvement. The current Adjusted i performance. Culture Index of 12.99 places Millstone Station in the metastable range and continues to indicate sustained emphasis on improvement efforts and monitoring is fully I appropriate.

Qoal Comments l NU has established a goal to achieve an Adjusted

,' Cultural Index of 13.0.

Data Source: Culture Survey Analysis by: M. Gentry x5728MP Owner: E. V. Fries x5458MP

$ G-2 4

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, Radiological Protection  !

9 Indicators 1

4 i

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4

RCA Dosimatry Daficiencies Chart Millstone Progress

Performance in this area is satisfactory.

100000-4 9000o . KPI data is cur ent as of I September 30,1998, f B 8mo -

\ A j d 70000 - Goals 1 error per 25,000 l g soooo . RCA entries

.3 s0000 A 40000 -

i i -6 .* 6 i + i

, Oct. Nov. Dec. Jan. Feb. Mar. Apr. May June July Aug Sep.

'97 '97 '97 '98 '98 '98 '98 '98 '98 '98 '98 '98 Cumulative RCA Entries per 1 Error Goat < 1 Error per 25.000 Entries 1

l MM' j Oct '97 Nov. '97 Dec '97 Jan. '98 Feb. '98 Mar '98 Apr. '98 May '98 June '98 Julv '98 Aug '98 Sep. '98

] Cumulative RCA Entries per 1 Error 26.893 29.024 32,263 44,475 43,846 47,148 49,668 71,307 77,005 74,150 70.363 96,821 l Goal: c 1 Error per 25,000 Entr6es 20,000 20.000 20,000 20,000 20.000 20,000 20.000 20,000 25,000 25,000 25.000 25.000

) \ 12 Month Cumulative FtCA Entnes 672.336 754.624 838.838 845.023 833.070 801.522 745.021 713.071 693.042 667.350 633.268 580.924

(/ 12 Month Cumulative RCA Entry Errors 25 26 26 19 19 17

] 15 10 9 9 9 6 l Dennklion '- , i AnekeWAction l This indicator depicts the number of Radiological The cumulative RCA entry rate shows a positive (improving) trend from l Controlled Area (RCA) entries per error. The October 1997 through September 1998.

Cumulative RCA Entry Error Rate is defined as the ratio of Total Error Events in the past 12 months to Total RCA The data as shown represents a rolling 12 month average. During the l Entries in the past 12 months. Error events are any past 12 months we have continually reduced the number of errors to instarce in which a radworker enters the RCA without a approximately 1 dosimetry error per 95,000 RCA entries.

Thenoluminescent Dosimeter (TLD) and/or an Electronic Dosimeter. Actions taken in June of 1997 to enhance the RCA entrance procedure through the use of mechanical, one-way " turnstiles" have resulted in a steady decline in personnel entry errors. However, one dosimetry error il event did occur on 9/8/98 when a worker entered an RCA outside of the i Protected Area without proper dosimetry. Due to the low traffic, this RCA 4 does not have a turnstile at its entry. Corrective actions have now been taken, however, to remove the radioactive source from the area when it is

! not in use. Additional corrective actions are being developed as well.

i i

l Goel C6mments j The current goalis to have s 1 error per 25,000 RCA KPI data is current as of September 30,1998.

t entries. This goal has been revised upward in view of The goal was established through a " benchmarking' process with input

{ the positive performance demonstrated since June from other utilities. As the number of errors decreases, the goal will be j 1997. evaluated to ensure the establishment of a " continual self improvement" culture.

ll h

Dats Source: P. J. Smmons x5580MP Analysis by: M Wood x5049MP! Owner: W. Nevelos x2158MP 1

i H1 i

a

Coll;ctivo Radiation Expocuro (INPO Indicstor)

Millstena 3 (U PYOgteSS; Satisfactory performance continues.

1998 Revised Year End Goals 43 Exposure data current through September 30,1998 1998 Year End Goals 51 rem Good 3 30 -

- .(

M Jan 98 l

Feb 98 Mar 98 Apr 98 MCumulative Exposure May 98 HII Jun 98 Jul 98 Aug 98 Sep 98 Oct 98

-A-YTD Goal Nov 98 Dec 98 l

gggy g E

's Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Cumulative Exposure 5.507 9.370 12.374 15.070 21.770 22.541 23.236 23.740 24.016 YTD Goal 6.400 10.455 14.509 18.564 22.618 26.673 30.727 34.782 38.837 35.033 39.012 43.000

Annual Goal 51 51 51 51 51 51 51 51 51 43 43 43 i Dentskion Ane&slalAction i This indicator depicts the cumulative radiation exposure for the Unit 3 is currently experiencing lower than anticipated year (rem year to date) vs. the year-to-date and annual radiation source term as a result of the extended shutdown.

, exposure goals for Millstone Unit 3. This reduced source term has translated directly into lower radiation exposure associated with working most These goals represent the level of exposure which we strive to primary plant systems. As a result, the Unit 3 annual

stay below consistent with the as low as reasonably achievable exposure goal has been revised from 51 to 43 rem.

1 (ALARA) philosophy.

., Qant . Consnsents The Goal for 1998 has been revised from s 51 rem to s 43 Exposure data is through September 30,1998.

rem.

Data Source: D. Evans x0080MPl Analysis by: R. J. King x6167MPl Owner: R. J. Decensi x5454MP H-2

4

Self Reporting Culturo Chart l Millstone Progress

Performance in this area is satisfactory.

4 l

1

! Goal > 75% events self-identified l KPl data is current through September 30,1998. l j 100% -

80% - .,

- 80, . k

1. GOOD 40% -

L ,

l k l 20% -

I g

os j . , , , , .

I Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep 97 97 97 98 98 98 98 98 98 98 98 98 l M% of Self-identified Events Goal > 75% Self-identified

new one.

j i

Oct 97 Nov 97 Dec 97 Jan 98 Feb 98 Mar 98 Aor 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98

% of Self-identified Events 100 % 100 % 100% 100 % 100% 100 % 100% 100 % 100 % 100% 100 % 0%

f l Gael > 75% Self 4dentrited 75% 75% 75% 75% 75 % 75% 75% 75% 75% 75% 75 % 75 %

l Self Identitled Events 1 1 0 0 0 1 2 0 0 0 0 0 i Nuclear Oversight identifed 0 0 0 0 0 0 0 0 0 0 0 1 NRC identified 0 0 0 0 0 0 0 0 0 0 0 0

Total Events 1 1 0 0 0 1 2 0 0 0 0 1 j

D.6nniers AnelpolefAc60n t

3 This indicator depicts the percentage of dosimetry events that Millstone Station's expectation is that the line worker

) are self identified by line organizational personnel relative to the organization will "self" report dosimetry deficiencies by

goal. This Self-Reporting Culture metric shows the development use of the Condition Report (CR) system. On of a culture in which personal' ownership' of the Radiation September 8,1998 a dosimetry event occurred that l

Protection Program is demonstrated through the number of self- was identified by Nuclear Oversight during a Field 1

identified deficiencies. Observation. This is the first incidence of a dosimetry infraction being reported by a group other than line The measure is considered meeting the KPl goal when the personnelin over 20 months, number of self-identified events are > 75% of the total number of events. A negative trend is indicated by Nuclear Oversight identified events > 20% of the total and/or NRC identified events

> 5% of the total.

0000 Comments O The goalis for > 75% of all dosimetry deficiencies to be self.

identified.

KPl data is current through September 30,1998.

Dets Source: C R Pairner x5256MPl Analysis by: M Wood x5049MPl Owner: W Nevolos x2158MP H-3

4 - > >. He A *-A-a k2-_=,4 a a 2 mwam---e a- --e-a3-A2m4,naas --. --.m.+A-a,e.---L AAKa.,4.,m; us %m- -+wA.4Aa-on-s--y ofma m_ w , e w--- am.sm se naas. a-eaeu,ese es 4

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Indicators 4

3 1 5

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1 Control of Safeguards Information l

Millstone Site i 1

PYOQTOSS: Control of safeguards Information Is satisfactory.

V ,

1 Data is current through

, ,, September 30,1998 1998 Goal = 3 events for the year Good w

1 2- Y 4

1 0 Jan 98 t m'I I Feb 98 Mar 98 i-Apr 98 1

May 98 I

III Jun 98 t

Jul 98 1

Aug 98 I

Sep 98

--t Oct 98 I

Nov 98

- I Dec 98 l

MCumulative Safeguards Evenis Goal i Asser Date Jan-98 Feb-98 Mar 98 Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov-98 Dec-98 Cumulative Safeguards Events 0 1 1 1 2 2 2 2 3 i

Goal 3 3 3 3 3 3 3 3 3 3 3 3

( Safeguards Events (Monthly) 0 1 0 0 1 0 0 0 1 l

, DennRion >

Ann &eWAction ~

, This indicator depicts the cumulative number of events where The 1998 goal to have no more than 3 events per year Safeguards information was found and determined to be represents a 50% reduction from the 1997 goal. In the uncontrolled. The data reflects the actual number of events based first three quarters of 1998 three events have occurred.

on information obtained from Security Reports and Condition In February a CAD drawing was found to be improperly Reports. controlled. This drawing was later declassified to non-

, s8feguards status. In May a safeguards document

] being used for training purposes was left uncontrolled.

1 In September an SI document was discovered in a non-2 Si cabinet. The document was packaged and

, addressed to a person who is no longer employed with i

the company. All three events were considered to be isolated incidents, and not the result of programatic deficiencies.

The Security Department will continue to monitor the program and investigate additional actions for 1 improvement.

Qant : Conunents I The goal is to have no more than 3 safeguards events per year. Data is current through September 30,1998

)O Data Source: Secunty and Condition Reports l Analysis by: M. Skorupski x4905l Owner: M. Skorupski x4905 l-1 l

Vohicb Control Insido tho Protcctcd Arca Millstone Site

, n Progress: Performance is satisfactory.

U 14 12 Data is current through September 30,1998 fg Good j 1998 Goal = 6 events for the year y6-4- Y 2-0 ' - ' ' '

i Jan Feb Mar Apr May Jun Jul Aug Sep

)

Oct Nov Dec 98 98 98 98 98 98 98 98 98 98 98 98 mCumulative Vehicle Events Goal l

pygy ggg - > I Jan-98 Feb-98 Mar 98 Apr-98 May-98 Jun-98 Jul-98 Aug-98 Sep-98 Oct-98 Nov 98 Dec-98 Cumulative Vehicle Events 1 1 1 3 4 4 5 6 7 g Goal 6 6 6 6 6 6 6 6 6 6 6 6 vehicle Events 1 0 0 2 1 0 1 1 1 Delkkien AnalyslalAction L This indicator depicts the cumulative number events where The station currently has 67 vehicles inside the vehicles were not controlled properly in accordance with station Protected Area identified as Designated (61) and procedures. Events involve keys left in unattended vehicles. Temporary Designated (6) Licensee Vehicles. An This data reflects the actual number of events based on average of 7 Non licensee Vehicles enter and exit on information obtained from Security Reports and Condition a daily basis. An average of 41 total vehicle l Reports. transactions occur through VAP daily.

Most 1997 events were a result of inattention to detail (ie: keys unintentionally left in vehicles), in contrast, several of the 1998 events occurred following a good faith effort to secure the vehicles. In one instance activating a tilt steering wheel device disengaged a locking bar, in another instance applying additional force to the steering wheel of a construction vehicle disengaged a locking bar, and in a third instance the keys were purposely left in the vehicle to assist in towing preparation for removal from site due to a fluid leak. All of these events were discovered by a second party through the use of a healthy questioning attitude.

Gost- Comments '

The goal is to have no more than six vehicle events per year. Data is current through September 30,1998 Data Source: Security and Condition Reports l Analysis by: M. Gelinas ext. 4258l Owner: M. Gelinas ext. 42s8 1-2

0 l Socurity Badga Control Millstone 3 f TOgYOSS Progress is satisfactory.

d i

14

1. 12 Data is current through 8

, ) September 30,1998

! 10 5 Goal s 8 0 8 Good

& I 6 Y

!  ?

O Jan 98 l

Feb 98 i

Mar 98 I

Apr 98 I

May 98 I

Jun 98 l

Jul 98 t El Aug 98 Sep 98 l

Oct 98 l

Ncv 98 l

Dec 98 1 Security Badge Controi Events Goal gg-' i. *

, i?

Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 0

curity Badge Control Events Goal 8 8 8 8 8 8 8 8 8 8 8 8 Security Badge Control Events 7 14 18 21 25 32 36 42 44 (Totah 3nnnMon AnekeWAc60n -

This indicator depicts the number events where security Most of these incidents involve key cards being broken during the badges including keycards were found uncontrolled or lost course of work.

inside the Protected Area. This indicator reflects the actual number of events. The data is obtained from Security Reports (SRs) and Condition Reports (CRs).

i I

l I

w .

The goal is to have s 8 events per month for 1998. Station population has steadily decreased from 4875 on 1/1/98 to 4010 on 10/1/98.

O kts Source: SRs/CRsl Analysis by: M. Klein x4376MPl Owner: M. Klein x4376MP l-3

Control of Vicitors Insido tho Protocted Area Millstone 3 Progress is satisfactory.

(Y10greSS; 4

Data is current through j

September 30,1998 ua 3 bc 0

Good S2 1

• l E Y j, Goal < 1 r

0 0 0 0 0 0 0 I I I I I I I l l I I Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Visitor Control Events Goal htF Oste ,

Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Visitor Control Events 0 0 2 0 0 3 1 0 0 Goal 1 1 1 1 1 1 1 1 1 1 1 1

~

Visitor Control Events Totao 0 0 2 2 2 5 6 6 6 kNnMon AneksiafAction s This indicator depicts the number of events where visitors or All six incidents involved situations where esmis and visitors escorts committed violations of the security escort exited the Protected Area turnstaes in reverse sequence - leaving requirements. This indicator reflects the actual number of the visitor unescorted in the Protected Area for a brief period in events. The data is obtained from Security Reports (SRs) each event, the escort was interviewed and their unescorted and Condition Reports (CRs), access suspended. Restoration of the escott's unescorted access occurred only after completion of refamiliarization of escort requirements via coaching / counselling / training. Additional measures have been implemented - on a trial basis - to increase the awareness of both the visitor and escort. These measures include responsibility acknowledgoment sheets signed by both escort and visitor, and a unique identifier tag reminding escorts of the proper sequence for processing out of the Protected Area.

These measures will be evaluated for effectiveness.

1ont Comments The goal is to have s 1 event per month for 1998. Data is current through September 30,1998 krta Source: SRs/CRsl Analysis by: M. Klein w4376MPl Owner: M. Klein x4376MP l-4

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O

, Ind.icators i

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Survoillance Test Program Schsdulo Performance Millstone 3 Progress: Performance is tracking to satisfactory.

100 % Goal 2 95% (New Goal)

I 90 %

) 80%

2 b 70%

] [ 60%

O s0%

d a i *o%  !

I l 30%

20*.

10% Good I

P4 , t i t l I i I t I t i i 1 3

8 f: E G 8 E

fa b C

8 B

9 5

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l M Completed Pnor to Grace Goal l

om8 7/998 7/16'98 7/23'98 7/30/98 B W98 8,1398 &'20/98 8/27/98 9/398 9/10/98 9/17S8 9'24S8 10/1/98 sV's Completed Prior to Grace (%) 81 % 78 % 89 % 86 % 91 % 87% 97% 92% 94 % 90% 88% 96 % 93%

Goat 90 % 90 % 90 % 90 % 90 % 90 % 90% 90 % 95 % 95 % 95 % 95 % 95 %

j Completed Pnor to Grace 35 39 42 82 77 67 75 80 103 65 77 71 80 Tests Completed as Scheduied 43 50 34 53 47 54 30 38 92 53 32 47 63 M .Y ",NW This indicator depicts the percentage of surveillance tests performed prior to entering The performance indicator goal was raised from 90% to the grace period. The grace period is defined as 25% of the Technical Specification 95% with the first week of the month (Tech Spec) surveillance frequency. (e g. Tech Spec surveillance frequency = 31 days, grace period is 25% of 31 days = 7 days) There were 27 surveillances performed in grace during last month. This resulted in a rnonthly rate of 92% of the The goal has been increased from 90% to 95% to reflect an increase in the standard surveillances being performed prior to grace. The dept.

of perforr1ance.

breakdown fol!ows:

Operations 20 I&C 5 Chemistry 2 Resource limitations was the reason that 25 of these surveillances were performed in the grace period. The remaining surveillances were performed in the grace period due to plant conditions.

There were 35 surveillances in grace at the end of the month, of which 19 were fire protection surveillances.

This is down from a high of 38 which occurred during the Corrarrayegy third week of the month. Operations and Site Fire The data displayed represents the previous week's sche %Ie performance. o on R are woNng tog @er to quaW W personnel to perform all fire protection surveillances.

When this is complete, the resource issue will be g diminished. As the remaining backlog of surveillances performed in the grace penod are completed, the The goalis to complete 2 95% of surveillance tests prior to entenng the 25% grace period. indicator will show the improved performance, Defa Source.- PMMSlAnalyssa by: A Rothgeb x5241MPlOwnen C Schwarr x0491MP 1

J1

Ovardua Proventiva Maintenanco AWOs Millstone 3 Progress:

4 p)

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v Perfonnance is satisfactory.

10

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2 h

S 4

l E AWOs Overdue l MM . / ... ;i; 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 l 8/12/98 8/19S8 F/26/98 9/2/98 9/9/98 9/16/98 9/23/98 9/30/98 AWOs Overdue 3 0 0 0 0 0 0 0 2 1 0 1 0 Work-oft / Goal

> \

V 1 I

am m .

m.m v. .

This indicator depicts the number of Overdue Preventive The number et overdue PM AWOs O Maintenance (PM) tasks as indicated by the number of re verdue PM Automated Work Orders (AWOs).

i 4

i l

l 1

GenV '

Cornments '

The goal is to have zero overdue PM tasks.

(Performance Plan item B.3.a) i (V

Data Source: D. A. Baanet x3062MPl Analysis by: R. M Chmietecki x6122l Owner:J R. Beckman x6361MP J-2

l l

i On Line Schedule Performance i 1

Millstone 3 l "* Ogress: Performance is satisfactory. The recent decline was due to the unit being shutdown the l week of 9/24 and the large amount of emergent unscheduled work.

I

% Work Activities Started on Time */o Work Activities Completed on Time 100 % l 100%

90g . Goal 2 80% 90% . Goal 2 75 %

j 80% - E_Em n 8*-

70% - 70% -

60% - k 60% -

I l 50 % . 50 %

COOd 40% -

40% .

l 30% -

30% .

20% - 20%

10%- 10% -

0% 0%

E

!R 8 $ z$

0 8 ,s !!5

$ $ $ E fE081-8 E E fE e D $

E E fE E$

a m ,g _ g .e ?. n. 5 R ,= - ~ . -

m - ~ m M Percent Started Goal M Percent Cornpleted Goal l l l e,wom,

) 7/9S8 7/16/98 7/23S8 7/30/98 8/6'98 8/13/98 8/20/98 8/27'98 9398 9/10/98 9/17/98 9/24'98 10/1/98 j

Percent Started 74 % 82% 77 % 83 % 80 % 85 % 80% 60% 80 % 86 % 83 % 70% 91 %

Goel 75 % 75% 75% 75% 75% 75% 75% 75% 80 % 80 % 80 % 80% 80%

Total Scheduled Starts 161 256 220 246 233 254 241 291 282 288 258 256 288

} 194 176 226 248 213 180 262 Total Actual Starts 119 209 169 203 186 215 j

Percent Completed 68 % 77 % 71 % 78% 69% 80% 67% 50 % 71 % 76 % 79 % 66 % 81 %

j Goal 70% 70% 70% 70 % 70% 70% 70% 70% 75 % 75% 75% 75% 75 %

Total Scheduled Cornpletions 138 289 230 272 234 253 246 280 328 286 240 298 251

! Total Actual Completions 94 222 164 212 162 203 164 141 233 217 189 197 203

$ 3efinition Analysle/ Action 1 This graph illustrates the performance of scheduled starts and During the week of 9/24/98 the unit was shut down, therefore l completions of work activities detailed in the on-line 12 week rolling greatly affecting the work release and completion rates for the l PMMS AWO (automated work order) work plan. week. Now that the unit is back on line the work start and l completion rates again achieved the goals. l l This is tracked on a weekly basic and is captured Fnday before the l subject work week and analyzed the Monday following the work week.

l

- l

}

3081 COntnterlis The goals are 80% of work activities to start on time and 75% of work Date idcates the end of the work week.

activities to complete on time (within work week).

O Cdm Source: P3 Schedule l Analysis by: M Galtpeau X5358 MPl Owner: C Schwarr x0491MP l J3

4

1 1

4 4

O i

5 i

i t

4 4

! Additional Operational

~O i

4 Performance Indicators 9 -

I-l l

A I

4 i

k i l

\

O ,

1

i Emcrgancy Syst m ActuOti na(NRC R portebb) l Millstone 3 l

,< m Progress: Performance is not meeting management expectations. There were 3

(). unplanned safety system actuations durin,q the month of September.

10 8

KPI data current through September 28,1998.

I 3 Good 36 N

2 2

• f 1

h 2

0 0 0 0 E I 0

l 0

i 0

I 0

I I t i I Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan 98 98 98 98 98 98 98 98 98 98 98 98 99 E Actuations I hM Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 oct 98 Nov 98 Dec 98 j

ECCS Actdation 0 0 0 0 0 0 0 0 0 l

Ctmt Spray Actuation 0 0 0 0 0 0 0 0 0 Ctmt Isolation 0 0 0 0 0 0 0 0 0 l Main Steam Isolation 0 0 0 0 0 0 0 0 0 I

[N Control Bldg Isolation 0 0 0 0 0 0 0 0 0 Feedwater Isolation 0 0 0 0 0 0 0 0 1 Aur Feedwater Actuation 0 0 0 1 0 0 0 0 1 Service Water Actuation 0 0 0 0 0 0 0 0 0 Toul EsFAs: 0 0 0 1 0 0 0 0 2 RPs 0 0 0 0 0 0 0 0 1 LOP - EDo start 0 0 0 0 0 0 0 0 0 Total 0 0 0 1 0 0 0 0 3 DennMon AnekeWAcilon This indicator depicts the number of NRC Reportable The Reactor was manually tnpped f rom 100% power due to high Emergency System Actuations as required by Tech Spec condensate conductivity on September 15,1998. As a result of 3.3.1 and 3.3.2. the inp, Steam Generator levels went Low, causing an Auxlalary Emergency Systems are: Feedwater Actuation in addition, a Feedwater Isolation resulted

1) RPS - Reactor Protection System Actuation, f rom the Reactor trip coincident with Tavg less than 564 degrees

2) Emergency Core Cooling Systems (ECCS) Fahrenheit. The Aux. Feedwater Actuation and Feedwater actuations. (includes Low Pressure Safety injection, Isolation are expected responses following a trip from 100%

High Pressure Safety injection, and Residual Heat power.

Removal System Activation),

3) EDG - Emergency Diesel Generators (start on Loss of Power),

4) ESFAS - Engineered Safeguard Features Actuations System (includes cctuations of Emergency Core Cooling Systems (ECCS), Containment (Ctmt) Spray, l Aux Feedwater (For Automatic initiation only), and Service Water, as well as isolation of Ctmt, Main Steam. Control Buildino. and FjedwaterL Gosi '

1 Commende O Goalis to have 0 Unplanned Emergency System Actuations.

O Data Source: J Langan x5544MPl Analysis by: J Langan x5544Mo! Owner: B Pinkowiti x4203 MP l K1 I

Diocci Goncretora Uncvailability (MRulo)

Millstone 3 pProgress: The performance is satisfactory.

U 1 00 %

a

l Goals 80%

80% - = = = = = = = = = = = =

KPl data current through l gn% _

SeVembeQO, M8.

/

q

.240% - Good 5 l S

$ 20% -

Y I g! I E

$ E. -

o 0% l

1. Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Jan 99 Feb 99 Mar 99 Apr 99 May 99 l l

Emergency Diesel Generator A Emergency Diesel Generator B A

Blackout Diesel Generator (SBO) -m- Goal

, r y ;y (w 93 , l Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Jan 99 Feb 99 Mar 99 Apr 99 May 99 Emergency DieselGenerator A 12.23 % 12.23 % 32.24 % 39.74 %

Emergency Diesel Generator B 5.40% 5.40% 10.56 % 12.76%

Blackout Diesel Generator (SBO) 24.56 % 50.02 % 50.02 % 50.02 %

Goal 80% 80% 80 % 80*/. 80 % 80 % 80% 80 % 80 % 80 % 80 % 80 %

l 6 M2 '

W@

The indicator is the percentege of the allowed Maintenance System performance is acceptable. The Station Black Out (SBO) i Rule (10CFR50.65) unavailablity limits over a 24 month Diesel unavailability increase was the result of a scheduled major l rolling period. The values are based on Maintenance system outage for annual Preventive Maintenance (PMs),

Effectiveness. The values are then analyzed by the PRA to Surveillance Testing (SVs), and longstanding Corrective ensure the individual Core Damage Frequency is within Maintenance (cms).

industry guidance.

l y . ,

w m The goal is to use s 80% of the system's allowed 2

{ lMiintenance Rule unavailablity limit.

Data Source: 50.65 Monitoring Requirements l Analysis by: Tim Ryan x0700MPl Owner: Gary Swider x538 t MP

! K-2

Auxiliary Foodwater System Unavailability (MRula) l Millstone 3 YOgreSS; Performance is not meeting management expectations, an action plan is monitoring progress.

E

• 3 160%

E'#0%

j .

KPI data current through l120% September 30,1998.

m j 100% .

80% -

Ggg Good j 60% -

l 2

a 2 40% <

f I 5  ;

20 %

h 0% -

f 1 1 1- l-- - - l- - -

1 - 1 --l-- --l -- - - --

1. Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Jan 99 Feb 99 Mar 99 Apr 99 May 99 mTubine Driven AUX Feedwater Pump MD AUX Feedwater Purnp A 4

MD AUX Feedwater Pump B -*- Goal

^

bM ~ '

a Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Jan 99 Feb 99 Mar 99 Apr 99 May 99

Tubine Dnven AUX Feedwater j Pump 165.48 % 163.41 % 166.13% 153.63 %

j MD AUX Feedwater Pump A 82.83 % 82.30 % 90.37% 89.83%

MD AUX Feedwater Pump B 94.80 % 156.10 % 107.07% 100.93 %

j Goal 80 % 80 % 80% 80% 80 % 80 % 80% 80% 80 % 80% 80% 80%

i M AnaknWAc60n

The indicator is the percentage of the allowed Maintenance This is a 10CFR50.65(a)(1) system due to excessive unavailability.

Rule (10CFR50.65) unavailablity limits over a 24 month The Action Plan was approved by the Maintenance Rule Expert

! rolling period. The values are based on Maintenance Panel on 9/22/98. The majority of the unavailability hours can be i Effzctiveness. The values are then analyzed by the PRA to attributed to the impact of the leakage from 3FWA*MOV35D which 4

ensure the individual Core Damage Frequency is within was repaired during the last cold shutdown. The Containment l industry guidance, penetrations are generally remaining cool (check valves holding),

and system performance is expected to improve over the coming months.

l 1

1 a

~

Mi Conennents Tha goal is to use s 80% of the system's allowed

{ f aintenance Rule unavailablity limit.

l Deb Source: 50.65 Monitoring Requirements l Analysis by: Tim Ryan x0700 MPl Owner: Gary Swider x5381 MP K-3

! HPSI System Unavailability (MRulo)

Millstone 3

ogress; Performance is satisfactory.

j 100 %

j Goal s 80%

j 3 80 %  :  :  :  :  :  :  :  :  :  :  :

Good 4 E KPl data current through September 30,1998.

i 2

l $20%

2 j0% l I I I I l I I I I I

[ Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Jan 99 Feb 99 Mar 99 Apr 99 May 99

. o l # - High Press injection Pump A High Press injection Pump B --M- Goal 4

1 gm . '<

Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Jan 99 Feb 99 Mar 99 Apr 99 May 99

^

. High Press injection Pump A 45.76 % 55.70 % 43.70 % 47.30 %

i High Press injection Pump B 53.49 % 53.49 % 48.05 % 59.11 %

Goal 80 % 80 % 80 % 80% 80 % 80% 80 % 80 % 80 % 80 % 80 % 80 %

1

~ '

b 2nhMan Annironn/AcNon >

1

The indicator is the percentage of the allowed Maintenance System performance is acceptable.

Rule (10CFR50.65) unavailablity limits over a 24 month rolling period. The values are based on Maintenance l Effectiveness. The values are then analyzed by the PRA to ensure the individual Core Damage Frequency is within j industry guidance.

1 4

i i

Basi s Comments

e goal is to use s 80% of the system's allowed

intenance Rule unavailablity limit.

Ms Source: 50.65 Monitoring Requirements l Analysis by: Tim Ryan x0700 MPl Owner: Gary Swider x5381 MP 4

K-4

INPO Thormal PGrformanca Indicator Millstone 3 rogress: Performance is satisfactory.

100.5 %

100.0 %

Goal a 99.5%

g 99 5%

99.0 %

!;ii 98.5% A l

l if 98.0 %

97.5%

97.0% l i l l l l l 1 l I I Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Thermal Performance Goal MayM L >

Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 Therrnal Perforrnance NA NA NA NA NA NA 99.2 % 99.8 % 99.7 % 0.0% 0.0% 0.0%

Goal 99.5 % 99.5% 99.5 % 99.5 % 99.5 % 99.5 % 99.5 % 99.5 % 99.5 % 99.5 % 99 5 % 99.5 %

Dennition AnalvelefAction The purpose of the Thermal Performance Indicator (TPI)is The analysis of the unit is conducted on a weekly basis utilizing to monitor and maintain efficient thermal operation. procedure EN31018, " Secondary Plant Performance Monitoring".

Operating at or near the best achievable value for thermal From this data and data from EN31017, " Secondary Plant performance reflects emphasis on thermal efficiency and Performance Test' judgements are made concerning thermal attention to detailin maintenance of balance-of-plant performance. The procedures are diagnostic in nature and the systems. The thermal performance indicator is defined as actions taken range from minor tuning of equipment to the removal the ratio of the best achievable gross heat rate to the of equipment from service for maintenance.

average adjusted actual gross heat rate expressed as a Weekly Data was as follows: (Week Ending, TPI): 9/5,99.3; percentage. 9/12,99.4;9/19,99.6; 9/26,97.7;10/3,99.6 Performance for the first two weeks was below the goal due Note: The thermal performance indicator data is taken condenser fouling. Condenser thermal backwashes were during power operation when the plant is operated greater performed on 9/13/98, resulting in significant improvement. As of than 80% power, following any single 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period of 9/25, recirc valves for the 'B' Low Pressure Heater Drains (HDL) stable operation at the same power level, and 'A' Moisture Separater Drains and Venst (DSM) pumps were open, resulting in lost efficiency. The HDL valve was shut on 10/2.

Overall, September was above goal.

Gost . Comments The goal is to maintain a to 99.5%. This is consistent with f Ihe INPO goal Dats Source: K.M.Doroski x5284MPl Analysis by: K.M.Doroski x5284MPl Owner: G L.Swder x5381MP K-5

Fual Rolirbility (INPO)

Millstone 3 n Progress: Performance is satisfactory, the tuet rettability Index is below the goat.

U 1.00E-01 KPl data current through 1.00E-02 September 30,1998.

1.00E-03 Goal < 0.0005 Good 1.00ti 04 1.00E-05 1.00E-06 l l l l 1 1 I i 1 l l Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 98 98 98 98 98 98 98 98 98 98 98 98 E Fuel Reliability MewOEMi Jan 96 Feb 96 Mar 96 Apr 96 May 96 Jun 96 Jul 96 Aug 96 Sep 96 Oct 96 Nov96 Dec 96 Fuel Reliability NA NA NA NA NA NA 9 67E-05 1.15E-04 6 53E-05 h Goal 5.00E-04 5 00E 04 5.00E-04 5 00E 04 5.00E-04 5 00E-04 5 00E-04 5 00E-o4 5.00E-04 5.00E-04 5 00E-04 5.00E 04 D

.x- >

The Fuel Reliability index (FRI) is a measure of the integrity of Analysis of the equilibrium fuel reliability data indicates no the fuel rods in the core. A failed fuel rod will release significant change in fuel status from the last report for August radioactive materialinto the Reactor Coolant System (RCS). 1998 operation. The equilibrium coolant activity levels indicate The amount of certain radioactive isotopes in the RCS is there is approximately 1 leaking fuel rod in the reactor. The unit measured, and the measured value is adjusted for meets its 100 point FRl goal for the month of September 1998, differences among individual plants. This adjusted value is The non-equilibrium data from the September 15th shutdown the Fuel Reliability Index (FRI), which can be used to directly display no evidence that a new failure event occurred during this compare the fuel integrity at different plants. operation. The transient Cesium data from this shutdown do not provide a clear and unambiguous estimate of the bumup of the The fuel reliability indicator for Millstone 3 is defined as the leaking fuel, and it is therefore possible that the leaker may be in radioactivity levels of iodine-131 corrected for both the system any of the batches resident in-core. For this reason, the background radioactivity and for the reactor power level, and preparation for an end of cycle fuel inspection continues to be then normalized to the power generated in a standard fuel rod recommended. Based on the results of this inspection, either fuel and to a standard purification rate, reconstitution / repair or emergency core redesign may be required prior to Cycle 7 startup, aang - r Commente The NU goal is to have this fuel reliability index indicate less The fuel reliability index is calculated in accordance with INPO 98-

, (q)

V than 0.0005 microcuries of radiation per gram of RCS water. 005, dated August 1998.

This is consistent with the 100 point INPO goal.

Dsta Source: Nuclear Fuel Eng. New Britain l Analysis by: M Baldwin NB x4747l Owner: D McDaniel NB x4764 K6

Chomictry Porformanca Indicator (CPI-INPO) i Millstone 3 Ocgress: Performance is not meeting management expectations. Efforts are under way to identify the sources of condenser air inieakage.

2.0 I

! 1.o Begin monthly tracking KPI data is current through September 30,1998.

a 1.5 1.3 4 1.0

. Good 0.8 Unit Goal = 1.10

0.5

, 0.3 -

i 0.0  : . . ~l l l l k h h h h k h *

!! = - s G G - s s H s *s s H s 1

1 Chemistry Indicator (INPO) Unit Chemistry Goal

Raw Dets 7/25/98 8/1/98 8/8/98 8/15/98 8/22/98 8/29/98 9/5/98 9/12/98 9/19/98 Sep-98 Oct-98 Nov-98

{

Chemistry Indicator (INPO) 1.33 1.28 1.30 1.25 0,0* 1.15 1.33 1.13 1.15 1.27 4 Unit Chemistry Goal 1.10 1.10 1.10 1.10 1.10 1.10 1.10 1.10 1.10 1.10 1.10 1.10 Definition Analysis / Action The CPI calculation is based on the concentration of The Unit took advantage of the shutdown to perform anion impurities which will cause deterioration of PWR steam regeneration on all Condensate Polishing Equipment beds. Time generators, allowed for bed soaking to remove sodium impurities, and reduce sodium throw.

Th3 CPI combines several parameters into a single indicator of the effectiveness of Secondary System Results: All S/G sodium levels are below the guidelines of 0.8 ppb Chemistry Control. Na, and a substantially lower sodium value, at or below goal.

Increased Condensate Dissolved (CPD) Oxygen continues to The CPI compares the concentration of selected impurities challenge the Unit overall goal. Reduced condenser vacuum has to th3 limiting value for those impurities, by use of the resulted in increased O2 levels.

following formula.

Condensate (CPD) oxygen continues to be a problem, causing the (S/G CU1.60 + SG SO4/1.70 + S/G Na/0.80 + FW Fe/5.00 CPI to be higher than the established goal.

+ FW Cu/0.20 + CPD O2/3.30) divided by 6. Plant transients (downpower and trip) along with increased Condensate O2 has had an adverse effort on the trend.

S/G = Steam Generator, FW = Feed Water.

Goal Comments Th3 goalis to have an INPO Chemistry Index of < 1.1.

• Week of 08/22/98 the Unit was shutdown, no CPI value was generated.

Dets Source F. Y. Mueller x8121 l Analysis by: S.R.Matthess x4343MPl Owner: s.R.Matthess x4343MP K-7

1 Induttrici Scfaty Accidant Rcta (INPO) sarety performance is satisfactory, showing significant improvement over the past several p) Progress:

t months.

l Q./

J 1.5 to l L

KPt data current through i; September 30,1998. 8 to i  ;  ;  ; ^

6 k Good 4 .

N  :  :  :  :  :  :  : $ 5

{ 0.5  ;^.

g =

g = = = = = = = = = ., j 0.0 m IE EB B e a a a e 0 c g g a a s s s a s a s s s g$

!*$ !"$ $ k $

$ b $ b $ k A $ $

5 ,

e 1

l ' Monthly Accidenis -*-MP Total Ste lSAR lSAR Goal -lSAR industry Median l l

gg > -(= 4 s

-7 12 Month Aolkng Average 1995 1996 1997 Oct-97 Nov-97 oec-9 7 Jan-98 Feb-98 Mar-98 Apr 98 May-98 Jun-98 Jul-98 seo.98 '

Aut98

! MP11 san 1.13 0.20 1 75 1 78 1 76 1 75 1 78 1 78 1 81 1 89 1 18 0 82 0 00 0 00 0 00 J

MP2 ISAA 0 50 0.55 0 60 0 32 0.31 0 60 0 58 0.56 0 53 0 26 0 25 0 25 0.24 0.23 0.23 t MP3 isAR 0 31 1 25 0 71 1.27 0 73 0 71 0 45 0 63 0 59 0 76 0 73 0 53 0 61 0 50 0 48 .

MP Total SMe ISAR 0.62 0.78 0.96 0.99 0.97 0.96 0.95 0.94 0.93 0.82 0.78 0.65 0.54 0.54 0.51 tsar Goal NA WA MA 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 0.50 1.

ISAR Industry Med6an 0.44 0.43 0.35 0.15 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 Monthly Accidente MA NA MA 1 2 1 2 1 1 1 1 0 1 0 0

' l-( ) OsSmWes M_ _ 1 ^^_ '4 V INPO Industrial Safety Accident Rate (ISAR) = OSHA Form 200 Fatalities (Column Unit 3 has experienced 29% of Millstone Station's injuries that ,

1) and injuries With Restriction of Work / Motion or Lost Workdays (Column 2) meet the ISAR criteria in 1998 (2 injuries out of 7). The other five i expressec' as the number of injuries per 100 full-time workers. injuries involved non-unit specific employees included in the MP f Total Site category. l The indicator is defined as the number of injuries per 200,000 man-hours worked for all utility personnel permanently assigned to the station that result in any of the {

i following: one or more days of restricted work (excluding the day of the accident); }

one or more days away from work (excluding the day of the accident); or fatalities. Management focus needs to:

Millstone Site Total includes Unit 1,2 and 3 employees and non-unit specific

• ensure effective pre-fob safety briefings j employees.  ;

• Include observations for unsafe actions of people in work observations l l

Gosf - Commeses 1 Millstone Station's 1998 INPO Goal = 0.50 injuries /100 employees Millstone Station has experienced 7 injuries to date that meet the j INPO ISAR critena. l l

l l

t Date Source: NUSCo safety l Ana4sJe by.- A Bovendge MP Ext 5369lownee M Biron x6838Mo O

~.

K-8

Unit Ccpability and Unplcnn::d Capability Loac Factor Millstone Unit 3 p Progress: Tracking to satisfactory.

%.) j Unit Capability Factor Unplanned Capability Loss Factor 100%

100 %

- = - = = =

80 %

6W Good 4 o=a ,o

} l 1

2a 2a 0% =:=:= n:= u 8 8 8 8 8 8 8 8 8 8 8 8 0% .- - - - -

I =.=.=

8 8 8 8 8 8 8 88 8 8 8 5$EE$kE$$5$? k$5E$k?$$5$?

m Monthly Capability Factor m Monthly Unplanned Capability Loss Factor

-e-Monthly Capability Factor Goal -e-Monthly Unplanned Capabihty Loss Factor Goal MM '

l Jan 98 Feb-98 Mar-98 Apr-98 May-98 Jun-98 Jul-98 Aug-98 Seo-98 Oct-98 Nov-98 Dec-98 l MontNy Gapabdity Factor 00% 00%

)

00% 00% 00% 00*4 55 6 % 63 3% 87 8% 00*4 00% 00*4  !

MontNy Gapabdsty l

Factor Goal 00% 00% 00% 00% 00% 00% 88 0 % 880% 88 0% 88 0% 88 0*4 88 0%

r% MontNy Unplanned

( 4 Capabihty Loss

(/ Factor 100 0% 100 0% 100 0% 100 0% 100 0% 100 0% 44 4 % 37 7 % 12 2% 00% 00% 00%

MontNy Unplanned Capabihty Loss Factor Goal 30% 30*4 30% 30% 30% 30% 30% 30% 30% 30% 30% 30%

DeRMen .* -.". _ Aeden The Unit Capability Factor (UCF)is defined as the ratio of Unit Capability Factor and the Unplanned Capability Factor the available energy generation over a given period of time Loss factor did not meet the goal during the month of to the reference energy generation of the same period of August due to the unscheduled outage needed for the time, expressed as a percentage. This indicator is to repair of aux. feedwater valve (3AFW'MOV35D) repairs.

monitor the reliability of the unit and is an indicator that reflects the effectiveness of plant programs and practices in The September production figures show improvement but maximizing available electrical generation. This indicator failed to make the goal due to the unplanned outage provieds an overall Indication of how well the plant is caused by a chloride excursion in the condensate system operated and maintained. and subsequent manual trip of the unit.

The Unplanned Capability Loss Factor (UCLF) is defined as the ratio of unplanned energy losses during a given period of time to the reference energy generation, expressed as a percentage. This indicator monitors progress in minimizing outage time and power reductions that result from unplanned equipment failures or other conditions. Energy losses are considered planned if they are scheduled at least 4 weeks in advance.

Gent Commenk

(^

(

z 88% for Unit Capability Factor, and s 3% for Unplanned Capability Loss Factor Note: Capability factors are based on data for entire year Omfa Source: M P Hills x5598 MP l AnsIysis by: M P Hills x5598 MP l Owner: G L Sweder x5381 MP K-9

Licaneco Evont Rapsrts Millstone 3 c Progress: Performance is satisfactory. The number of LERs associated with

& historical design issues has declined, and performance is currently below the Industry standard.

12 10 - LER data current through September 30,1998.

8 Industry Standard = 1 per month

@6 g - Good

~

I 4 - -

Y 2

0 l

. O' . . .

Jan Feb Mar Apr May Jun Jul Aug sep Oct Nov Dec 98 98 98 98 98 98 98 98 98 98 98 98 l LERs-Recent i i LERs-Historical industry Standard l MpnVC9tt' Jan-98 Feb-98 Mar-98 Apr-98 l May 98 Jun-98 Jul-98 Aug-98 sep-98 Oct-98 Nov-98 Dec-98 LERs-Recent 1 0 1 1 a 0 3 0 0 LERs-Historical 4 6 9 3 2 4 1 1 0

( LERs YTD 5 11 21 25 30 34 38 39 39

( Industry standard 1 1 1 1  ? 1 1 1 1 1 1 1 OnRnMon a/ W AnalysletAcNen This indicator depicts the number of LERs submitted to There have been no LERs submitted to date during the the NRC, relative to the current industry standard. LERs Month of September.

are reflected in the month in which they are submitted.

Licensee Event Reports (LERs) are reports made to the NRC pursuant to 10CFR50.73.

Recent LERs document current emerging issues and events. Historical LERs document events or issues that did not occur in the previous twelve months.

The 1997 industry average LER generation annually is

14. or approximately 1 per month.

Geef -

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

Cornmente r, <

LER data current through September 00,1998.

J Data Sov",e R. Flanagan x5817MPl Analysis by: R Flanagan x5817MPl Owner: D. Smith x5840MP K-10

C l

l Configuration O Management Indicators O

Configuration Managamant Summary - CM Awarencss Millstone 3

n Progress

cu awareness in Design eases, operations, and Miscettaneous items are i Q satisfactory. CM awareness in Licensing Bases needs improvement.

i j 100.0 %

90.0 % F

g =

, Goal 2 80 %

80 0% 2-------IIF B----)IF M---416----- ,, q H m lll ll: :K m

a i 1 70 0 % U 3 d [

]L go og , 1 L 0 GOOD s

j  %

50.0 % g f 40.0% d i g ,

J

1. 30.0 %

j 20.0 % 3 10 0%

00% b W d d El 5 f l I i I si =1 *I l l

! Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jtri 98 Jul 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 I

MDesign Bases: % Proactive M Licensing Bases: % Pr0 active CMiscellaneous: % Proactive

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Operations: % Proactive -)lF-G0al I

bM ~

Jan 98 Feb 98 Mar 98 Apr 98 May 98 Jun 98 Jd 98 Aug 98 Sep 98 Oct 98 Nov 98 Dec 98 a Design Bases % P oactive 45% 43 % 55% 53 % 69 % 86% 89% 100% 90 %

j Licensing Bases % Proactive 65% 55% 67% 60 % 61 % 65% 83% 75 % 60*/.

j Misceilaneous % Proactive 65 % 69% 71 % 68 % 67% 86 % 87% 71 % 85%

] 'Q Operations: % Prt ective Gs.,M 60% 82 % 93% 59 % 79*<. 76*4, 86 % 82% B3%

80 0 % 80 0 % 80 0 % 800% 800% 80 0 % 80 0% 80 0% 80 0 % 800% 80 0 % 80 0 %

k DenrMon Aml@eWAction ,

} This KPI reflects the culture of Millstone Unit 3 on awareness The CM awareness in Unit 3 was satisfactory for Design Bases,

! to and self-identification of Configuration Management (CM) Miscellaneous items, and Operations.

$ issues by tracking and trending CM related Condition Reports

?

(CRs). Licensing Bases did not reach the goal for CM awareness. There was a limited sample size of 15 Licensing Bases CM related CRs Proactive CRs are those that are issued prior to a loss of CM for September, six (6) of which were categorized ' reactive" by this event. In order for the CR to be proactive, it must be CM KPI's definition. Two (2) of the ' reactive

• CRs dealt with differing related CR at level 2 or 3 and either Self Identified (SELF), interpretation of Regulatory Compliance positions.

Program Identified (PROG), or Line Management identified (LINE). There was one (1) Level 1 CR regarding missed NRC commitments by Unit 3 over the past seven (7,1 months. Although it was Reactive CRs are those that are issued after a loss of CM. discovered by Regulatory Affairs (which would be considered to be Such CM related CR's criteria are: any level 1 CR, any CR 'proactive" in normal circumstances), it was listed as a ' reactive' identified by Nuclear Oversight (INOV), Extemal Oversight CR due to its impact to Unit 3 CM.

such as NRC (EXOV), or a result of an Event (EVEN).

The data is shown in percentage. The precentage indicates -

the fraction of proactive CRs in the group. The goalis to have the total number of proactive Configuration Management related CRs in each group for each reporting period 2.

Note: (1): " PROG" has been taken out of SI-100.2 after 80%.

6/1/98. This criterion is kept to categorize historical data only. g-The definition of "SELF" now covers " PROG".

This KPI summarizes historical data from AITTS and the Unit 3 Tracking and Trending Database. Number of CRs for each month can vary slight due to the difference between the Discovery Date and the CR Wntten Date.

sta source: ArTTS. CR Tracking and Trending Database l Analysis by: J H Rein x3543MP l Owner: 8 J Willkens x6635MP L1

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Regulat ry compliance 4

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Indicators 9

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i Regulatory Complianco i

orogress: Third quarter performance Is considered satisfactory (green) to support operations.

Commitment Performance requires Improvement and is receiving increased

<O management attention.

PRE-RESTART OPREAT;ON l 6/30/98 9/30/98 l 12/31/98 l l l l l IEGULATORY PERFORMANCE INDICATORS IUCCESS CRITERION 1 e j ielf Assessment Results -

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! IUCCESS CRITERION 2 l Y.l Y- l 4

ommitment Performance l' Y- l Y l Init 3 Pre-Restart Backlog -

IUCCESS CRITERION 3 -----

'echnical ification Cha es -----

SAR Cha ests

.ictnsee Event R s -

i .le:nse Basis Condition Re ris - ---

l )ocketed Corres ondence l tices of Violations

! C Inspection items a

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! I I I i l l l i l I I i

l leNrnien AnekeWAction:

Each of the above listed issues is assessed in the Performance Commitment performance needs improvement. Third quarter

donitoring Report. The colors correspond to the following performance revealed multiple incidences of regulatory ggend. Colors will normally change after two periods of commitments being completed after their due date. Regulatory l

ensistent performance. NOTE: Regulatory Compliance Affairs has issued an adverse trend Condition Report (CR M3 l

} nanagement may determine that a diffvent color is more 4232).

ippropriate based on its best judgment.

Satisfactory (GREEN)

I improvement needed (YELLOW)

Significant weakness (RED)

An issue which has not been assessed (BLUE) st) Source: AssignedLands Analysis by: Assigned Leads M-1

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BACKLOG MAGEMENT UPDATE i

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Backlog Management Update Page 1 of 6 O BACKLOG MANAGEMENT UPDATE Third Quarter 1998 l

The purpose of this Backlog Management Update is to provide the progress achieved l in the disposition of work items that have been included in the backlog of deferred work l in several work management categories. These work management categories include Configuration Management Discovery, Engineering Backlog, Total Corrective Action Assignments, ICAVP DR Corrective Action Assignments, Corrective Maintenance

! AWOs, Open Operability Determinations, Operator Work Arounds, Control Room and Annunciator Deficiencies, Temporary Modifications, and NCRs. This Backlog l Management Update reflects the status of the deferred recovery backlog, the accumulation of post recovery new backlog, and adjustments to performance targets and the Backlog Management methodology functional requirements.

l l Background

" Backlog Management Plan, Millstone 3 - Post Mode 2 Restart (Deferrable items),"

Rev. 0 was approved by the Unit 3 Plant Operations Review Committee on June 24, 1998. A subsequent revision was approved on 9/3/98 with additional clarifying details.

p The plan provides a structured approach to successfully manage and disposition the

() deferred backlog population while maintaining a management focus on safe, event free operation of Unit 3.

The functional requirement for dispositioning the Backlog of Deferred Work was i

described in the " Backlog Management Performance Update - Second Quarter", issued on June 30,1998. That functional requirement reads as follows: Backlog of Deferred Work will be dispositioned prior to entry into Mode 2 following RFO6 plus 6 months except for DR corrective actions and corrective actions related to previous UIRs and OIRs.

The functional requirement regarding the utilization of existing Unit and Station work control and prioritization processes to disposition work items, as well as the use of an Operational Expert Panel for line oversight reviews of items dispositioned for cancellation, has been enhanced to add the following:

A multi-discipline Unit Deferred items Committee and a Management Review Team have both been used to augment the Engineering Backlog (Engineering Modifications) prioritization/ disposition process. These reviews were in addition i

to existing prioritization processes.

No additional changes to the remaining original functional requirements have been made.

V Millstone Station / Unit 3 Third Quarter Performance Report

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! Backhg Managsment Update Page 2 of 6 l Line Self-Assessment i The functional requirement for conducting periodic self-assessments that was described I

in'our Backlog Management Update for the second quarter has been modified. In place 1 of quarterly Management self-assessments, that were originally described as part of the backlog management strategy to assess deferred backlog work-off performance, the following will now apply. Routine review of Key Performance Indicators by Unit Management assesses performance against goals. Appropriate action plans are established if performance is not meeting management expectations. '

A Unit 3 formal self-assessment of the effectiveness of the Deferred Backlog Management Plan implementation has been scheduled to be performed in the first quarter of 1999. (3 CAD-SA-99-01 " Deferred Backlog Reduction Effectiveness")

Nuclear Oversight Assessment l Nuclear Oversight will periodically assess the deferred backlog work-off process and overall post-restart plant performance in these areas.

O eerrormeace Table 1 represents the Deferred items Baseline and the Deferred items Quarterly Status as of September 30,1998. Table 2 represents the Performance Status and Targets by Work Management Category. Also attached are the Key Performance Indicators for backlog management.

Most backlog management goals are being met. Overall reduction of the frozen l recovery backlog is greater than 25% for the first quarter. The exceptions include l Operator Workarounds, Temporary Modifications, and Operability Determinations.

These areas are recognized by the Unit Management Team as key to ensuring an operational focus and action is being taken to improve performance.

l Much effort in the first quarter following unit recovery restart has been in the disposition l and scheduling of unit engineering backlog items. The review and issuance of a j resource loaded plan for engineering backlog will be completed by December 31,1998.

l The RFO6 and cycle 6 modifications list has been issued.

l l Backlog Management performance is evaluated two ways - reduction of recovery l deferred backlog that existed as of June 29,1998, as Unit 3 entered into Mode 2, as well as, additional post restart backlog that has accumulated. Both perspectives are presented in the attached Key Performance Indicators for each work management category, where appropriate.

Millstone Station / Unit 3 Third Quarter Performance Report

Backlog Managsment Update Page 3 of 6 Table 1 Deferred items Baseline and Quarterly Status Work Management Category Bins As of: 6/29/98 As of: 9/30/98 Corrective Action Assignments (non DR) 3915 2735 4

Corrective Maintenance Work Orders 583 445 Configuration Management Discovery 864 640 Non-Conformance Reports 57 40 Operator Work Arounds 15 14 Control Room Deficiencies 5 1 Temporary Modifications 15 14 Engineering Backlog 587 608*

O- DR Corrective Action Assignments 838 620 Operability Determinations 28 24 includes 7 USQs includes 6 USQs Total Deferrable items 6907 5141 Number of Engineering Backlog items has increased due to incorrect initial counting at the time of mode 2 entry, (i.e., an additional 80 items). The Engineering Backlog is being evaluated to verify significant engineering issues have been previously reviewed for deferability. This Engineering Backlog quantity does not include the 69 items noted in the comment section of the associated KPI chart.

O Millstone Station / Unit 3 Third Quarter Performance Report

Backlog Management Update Page 4 of 6 l

n Table 2:

('u) ist Quarter Post Restart Performance Status and Targets by Work Management Category Work Deferred Category Status RFO6 RESTART Management Recovery (including Near Term Targets) TARGETS Category Backlog Status (as of 9/30/98)

Corrective Action 1180/ 3915 3862 outstanding assignments (total new Continued reduction Assignments (30.1%) work and recovery backlog) - total open was in total open CR completed expected to remain steady 1" quarter AITTS following restart.

Near term target has been met.

. Subsequent quarters expect gradual reduction in total open.

Corrective 138/583 551 outstanding total non-outage corrective 1500 Power Block Maintenance (23.7%) maintenance backlog (new work and 5 350 On PRA Work Orders completed recovery backlog). Total was expected to Risk Significant (AWOs) - rise for the first quarter following restart. Systems Actual progress has improved upon the near term target. Total is expected to hold steady in the second quarter following restart and be reduced in subsequent quarters.

O U Temporary 1/15 completed 22 total temporary modifications existing. < 10 by 12/99 with Modifications Target is the end of 1998 510 Temp. Mods. none > 6 months old that can be removed at power and < 15 without Unit Director Temp. Mods. by 12/98. Efforts are in approval progress to attain this target. 4 are scheduled for RFO6 Operator Work 1/15 20 total existing, target is < 10 by 11/98 with < 10 with none > 1 Arounds (OWAs) completed none > 1 year in age. Although efforts are year in age in progress near term goal will not be met.

Revised goal is to be at 10 by February 1999.

Control Room 4/5 completed 15 total existing. Target is < 10 by 12/98. 5 5 CRDs at Deficiencies Efforts are in progress and on track to attain Restart.

(CRDs) this target. . No CRDs open > 1 l cycle without Unit Director approval (at Restart after each planned refueling outage).

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l Millstone Station / Unit 3 Third Quarter Performance Report l

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Backlog Managemsnt Update Page 5 of 6 Table 2:

V 1st Quarter Post Restart Performance Status and Targets by Work Management Category i l

Work Deferred Category Status RFO6 RESTART Management Recovery (including Near Term Targets) TARGETS Category Backlog Status I (as of 9/30/98)

Non-Conformance 17 / 57 Target is no overdue NCR corrective . Switch to Use of Reports (NCRs) (30%) actions. Performance was not satisfactory CRs in place of l completed upon close of quarter due to three overdue NCRs.

i NCR actions, however reduction efforts are . Use CR goals on track. thereafter.

1 Configuration 224 /864 Near term target of a 25% reduction in the All assignments Management (25.9%) number of corrective actions related to dispositioned Discovery completed previous UIRs and OIRs by the end of 1998 t (corrective actions has been met. l l

related to previous UIRs and OIRs) l

! Engineering 59/667 Near term target for restart mode 2 plus 1 month prior to I

Backlog (8.8%) 90 days: RFO6 (revision to 3 I completed . Organizational Req Jirements months prior)

(includes: EWA, Determined Engineering EWR, MMOD, . Resource Loaded Plan Finalized Packages issued for

(

DCN, DCR, . Issue List of RFO6 and Cycle 6 Mods all RFO6 PDCE, MSEE, Modifications l PDCR, PMR, Status:

l RIE) . The RFO6 and Cycle 6 mods list has RFO6 Restart been issued. Complete RFO6 l

l . Organizational requirements and a Modifications resource loaded schedule for RFO6/ Cycle 6 mods will be issued by 6 months prior to l 12/31/98. Organizational requirements RFO7 and a resource loaded schedule for Engineering l

i items beyond RFO6 will be issued by Packages issued for 9/30/99. all RFO7 Modifications Some additional assignments have been included in the total as a result of incorrect initial counting. Also see comments section of the associated KPl chart.

ICAVP DR 284 /904 Near term target of 25% reduction in open AllICAVP DR ARs Corrective (31.4%) DR assignments by 12/98 has been met. dispositioned.

Actions completed Some new assignments have been created to manage closure of original issues.

s 4

hiillstone Station / Unit 3 Third Quarter Performance Report i

1 Backlog Management Update l Page 6 of 6 l

, Table 2:

s v) ist Quarter Post Restart Performance Status and Targets by Work Management Category Work Deferred Category Status RFO6 RESTART Management Recovery (including Near Term Targets) TARGETS Category Backlog Status (as of 9/30/98)

Operability 4/28 closed Near term target of a gradual reduction in . ODs assessed Determinations the number of open ODs has not been met. for age with none Currently there are 37 open Operability greater than two Determinations. Efforts are in progress to years attain this target. . No open ODs without a safety evaluation or ,

corrective action plan approved by PORC prior to Restart l %Q

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Millstone Station / Unit 3 Third Quarter Performance Report l

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BACKLOG MANAGEMENT UPDATE i

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Index

" " "' S " * " " S * * * " ' ' " d ' "'

O Millstone Unit 3 Backloo Manaaement KPls B L K- 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Configuration Management Discovery B L K-2. . . . . . . . . . . . . . . . . . . . . . . . . . . . Engineering

.. Backlog B L K-3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Total Corrective Action Assignments B L K -4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . D

. R Corrective Action Assignments B L K- 5 . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Corrective

. Maintenance AWOs B L K- 6. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Open Operability Determinations B LK-7. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Operator Work Arounds B L K- 8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Control Room and Annunciator Deficiencies B L K- 9. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Temporary Modifications B L K- 1 0. . . . . . . . . . . . . . . . . . . . . . . . . . . . Non Conformance Reports O

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Millstone Unit 3 O Backlog Management Indicators l

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I Backlog Management Configuration Management Discovery l Orogress: Performance is satisfactory.

1000 800

$ 600 Good 5 '

8 I li 400 200 0 I i l l I l l t l l l l l 6/29/98 7 8'98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 8'26/98 9/2/98 9'9/98 9/16/98 9/23/98 9/30S 8 Configuration Management Discovery (Recovery Backlog) Target of 25% reduction by end of the year

%$t1rOnt#

7/8/98 ,.* 5/98 7/22/98 7/29/98 8 5'98 8/12/98 8/19'98 8'26/98 9'2/98 9/9'98 9/16/98 9723/98 9/30/98 Configuration Management Discovey (Recovery Backk>g) 864 850 842 839 839 838 825 817 809 796 721 660 640 Orget of 25% reduction the year 856 by end847 of 839 831 822 814 806 798 789 781 773 764 756 Onhnklen AnalyelWAction This indicator depicts the number of Open item Report (OIRs) and Engineering and other departments are continuing to work off Unresolved item Reports (UIRs) for which the corrective actions are items in parallel with resource loading efforts.

not yet complete. These items are being transferred into the Corrective Action Program for tracking and close-out purposes. The goal to reduce the number of UIRs/OIRs by 25% was met on 9/30/98 from the initial Count of 864.

3001 Csmmente The Configuration Management backlog will be dispositioned by entry into mode 2 following completion of Refueling Outage 06.

I a Source: G Rescek x2433MPl Analysis by: G Rescak x2433MPl Owner: G Winters MP BKL1

Backlog Managsmont Engineering Backlog brogress: perrormance is not meeting management expectations.

1000 900 A 800 R*w Data O Illlllllllllll 6/29/98 I

7/8/98 Engmeanng Backlog (Recovery t

7/tk98 t

7/15/98 t

7/15/98 7/22/98 7/29/98 7/22/98 I

8/5/98 E Engineering Backlog (Recovery Backlog) 7/29/98 I

8/5/98 I

8/12/98 8/19/98 8/2698 8/12/98 i

tut 9/98 i

9/2/98 8/28/98 I

9/9/98 9/2/9e I I i 9/16/98 9/23/98 9/30/96 5 Engineering Backlog (New Work) 9/9/98 9/16/98 l

9/23/98 9/30/98 Backlog) 587 587 587 587 687 687 667 631 621 814 812 608 808 Engmeenng Backlog (New work) 145 145 150 Definition AnalysisfAction This indicator depicts the number of open engineering work products, Review and issuance of a resource loaded plan will be completed by both deferred and new. These include Engineering Work Assignments 12/31/98. The Refueling Outage (RFO6)/ cycle 6 modifications list i (EWAs), Engineering Work Requests (EWRs), Minor Modifications was issued on 11/13/98.  !

(MMODs), Desigrt Change Notices (DCNs), Design Change Records (DCRs), Plant D9 sign Change Evaluations (PDCEs), Plant Design Engineering will issue RFO6 modification packages 1 month prior to Change Record s (PDCRs), Material Substitution Engineering RFO6 as determined by the resources loaded schedule. RFO7 Evaluation (MSIEs), Plant Material Requests (PMRs), and Replace modification packages will be issued 6 months prior to RFO7.

Item Evaluatiors (RIES). l Goal Comments The Engineering backlog will be dispositioned by entry into mode 2 During the Unit Deferred item Committea (UDIC) Review Process following completion of Refueling Outage 06 plus six months. At it was determine that 69 additional EWR's that were code normal Rtcovery Restart Mode 2 plus 90 days (9/30/98) organizational work should have been Deferred items. These items have been requirements will be determined, resource loaded plan finalized, and added to the review process and are now coded as deferred. This RFO6/ cycle 6 modification list issued. change will be shown in the next quarteriy report.

Datz source: W stairs r5917MAl Ans!ysis by: W Stairs x5917MPl Owner: P Grossman x0488MP BKL 2

Backlog Managemant  !

Total Corrective Action Assignments l Ov Og(OSS: Performance is satisfactory.

8000 7500 7000 Number of Non-DR assignments at restart m

, j5500 Good 2bUUU 4500 I 4000 g g

!!IllilillIIIIII 6"29/98 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 8/26/98 9/2/98 l E Non-DR Corrective Action Assignments (Recovery Backlog) 1.' W-9/9/98 9/16/98 9/2398 9/30/98 E Open Non-DR Corrective Action Assignments (New Work) l 7/22/98 7/29/98 8'5/98 8/12/98 8/19/98 6/26/98 9/2/98 9/9/98 9/1 &98 9/23/98 9/30/98 7/&98 7/15/98 Non DR Corrective Action A

f issignments (Recovery Backlog) 3691 3582 3522 3449 3355 3272 3220 3153 3077 3017 2942 2863 2735 Open Non-DR Corrective Actiori 557 641 884 891 981 1014 1060 1127 Assigiments (New Work)

Completed Non-DR Correctnie 570 Action Assignments (New Work)

Denrution AnalyelelAction The Corrective Action backlog was frozen with the unit's entry into This indicator depicts the total number of open AITTS assignments mode 2. The data from the past three weeks indicates that the linked to Condition Reports (CRs). Deficiency Reports (DRs), which are tracked within the Corrective Action Program, are not included in current backlog of recovery + new work is approximately the same this indicator. These are broken down into two categories, deferred as the backlog frozen at mode 2, which reflects the near term target for the first quarter following post recovery restart.

and new. DRs are tracked by a separate indicator.

Goal Comments The Corrective Action backlog will be dispositioned by entry into mode 2 following completion of Refueling Outage 06 plus six months.

Gradual reductions in total open assignments.

G Rescek x2433MP! Analysis by: G Rescek x2433MPl Owner: G Winters MP Jats Source:

BKL-3

, l l Backlog Management l DR Corrective Action Assignments TOgreSS; Performance is satisfactory.

i 1

l 1000

• 00 l

.P 800

! E 700 ,

600 GOOD i

500 l i Y j 400 4

) E j ] 200  !

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H

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i 0 1 I l- 1 I I I I I I I I l 6/29/98 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 8"26/98 9/2/98 9/9/98 9/16/98 9.23/98 9/30/98

! l MICAVP DR Assignments -Target of 25% reduction by end of the year l '

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i 9ewone I

! 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 &"26/98 9"2/98 9/9/98 9/16/98 9/23/98 9/30/98 j ICAVP DA Assignrnents 838 904 902 900 890 886 857 855 793 680 643 605 620 1 Target of 25% reducton by end of l I the year 904 895 885 876 866 857 848 838 829 819 810 800 5

Ond%iden AnakeWAction i This indicator depicts the total number of open AITTS assignments The DR Corrective Action backlog was frozen with the unit's entry j linked to Deficiency Reports (DRs) resulting from ICAVP Condition into mode 2. The number of assignments increased due to I J Reports (CRs) . incomplete counting when the backlog was frozen. The backlog j as of 9/30/98 reflects the new DR assignments which have been created to manage closure of originalissues.

The near term target of a 25% reduction in open DR assignments by 12/98 has been met.

pool Comments The DR Corrective Action backlog will be dispositioned by entry into mode 2 following completion of Refueling Outage.

%2 Source: J Fougere x5526MPl Analysis by: B Stairs MP! Owner: P Grossman MP BKL 4

Bccklog Managsmant Corrective Maintenance AWOs OProgress: Performance is tracking to satisfactory. The organization is currently scheduling the A WOs into the 12 week rolling window schedule and the next refueling outage.

800 yon . AWo Backlog Goals 500 600 500  %  %  %  % T T i

< 400 15 Y

• 300 200 100 g 0

6/29/98 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 8/26,98 9/2/98 9/9/98 9/16/98 9/23/98 9/30/98 m Recovery Conective Maint. Backlog (Non Outage) E--]New Work Corrective Maint. Backlog (non outage)

-m--Non PRA Risk Significant AWO Backlog Goal R'w Data 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 8/26/98 9/2/98 9/9/98 9/16/98 9/23/98 9/30/98 Totst AWO Recovery Backlog (On Line. Future Outage) 570 557 548 536 536 521 515 503 491 480 467 460 445 Recovery Backlog future outage 120 120 120 120 120 120 120 120 120 120 120 120 ;35 Recovery Conective Mamt Backlog (Non Outagei 450 437 428 416 416 401 395 383 371 360 347 340 310 New Work conectwo Maint Backlog (non outage) 155 166 153 175 185 174 180 241 Non Outage Conectwo Maint Backlog (Recovery & New Work) 512 510 528 527 547 556 561 536 546 545 521 520 551 PRA Risk signdeant Awos 257 261 274 274 279 279 276 271 276 266 265 256 268 PRA Risk S#gndcant AWO Backlog Goal (s350) 350 350 350 350 350 350 350 350 350 350 350 350 350 Non Outage Conective Maint.

Backlog Goal (s 500) 500 500 500 500 500 500 500 500 500 500 500 500 500 Definition Analysis / Action This indicator depicts the number of on line Corrective Maintenance The AWO backlog was frozen with the unit's entry into mode 2. The (CM) Automated Work Orders (AWOs), the portion of those Organization is currently scheduling the AWOs into the 12 week associated with Probabilistic Risk Assessment (PRA) risk significant rolling window schedule and the next refueling outage.

systems, and Corrective Maintenance (CM) work schedule in future outage (s). PRA Risk Significant systems are systems required to A 23.7% reduction of the frozen recovery backlog has been protect the reactor core or mitigate the consequences of an accident. completed, and an additional 23.1% is scheduled for future outages.

Work awaiting post maintenance testing or closure is not included in this KPl. Also excluded are AWOs for support work, such as insulation removal, outage work, and Preventative Maintenance or Surveillance AWOs, as well as AWOs not associated with power Goal block equipment. All Corrective Maintenance (CM) work schedule in The Recovery AWO backlog will be dispositioned following future outage (s), does not ir'clude support Automated Work Orders completion of Refueling Outage 06 mode 2 plus six months. The (insulation removal etc.), Preventative Maintenance (PM) or goalis < 500 Total On Line Corrective Maintenance AWOs per unit.

Surveillances (SV) Automated Work orders (AWOs). Of these 500,less than 350 will be PRA risk significant AWOs.

-) Comments o., s_., , O __55 t 9Mel.n.,,e,. e, me,., m9, M,lo_ c s~am.9,M.

BKL-5

Backlog Management Open Operability Determinations 00gress: performance is not meeting management expectations.

I 40

%l ll Il ll ll lll ll 0

6/29/98 f

1 7/& 98 l

7/15/98 7/22/98 7/29/98 8/5/98 E Total Open ODs (Recovery Backlog) 1 8/12/98 8/19/98 W26/98 9/2/98 9'9/98 E ODs New Work 9/16/98 9/23/98 9/30/98 980er OSIA 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 8/26/98 9/2/98 9/9/98 9/16/98 9/23/98 9/30/98 Total Open ODs (Recovery C,\/ Backlog)

USOs (Recovery Backk>gi 28 7

27 7

27 7

27 7

27 7

26 7

26 7

25 7

24 6

24 6

24 6

24 6

24 6

ODs New Work 3 4 5 8 10 11 11 11 11 12 12 13 DeRnstlen Ane&slWAction This indicator depicts the number of open Operability Determinations Review and issuance of a resource loaded plan is approximately (ODs), and Unreviewed Safety Questions (USOs). Open ODs tied to 30 days behind schedule. The goal is, however, expected to be USOs remain open until approved by the NRC. met with in 120 days of entering Mode 2 after Refueling Outage 06 (RFO6).

A USO is an activity or condition that may be outside the licensing basis of the plant and therefore requires NRC review and approval.

An OD is an evaluation performed on a degraded Structure System or Component (SSC) to determine that the SSC is able to perform its safety functions. New ODs on degraded conditions are closed when the condition is restored to fully quahfied requirements.

l 30el - Comments The Open OD backlog will be dispositioned by entry into mode 2 following completion of RFO6 plus six months. No OD age > 2 years l prior to RFO6 mode 2.

) Source: Operatms OD Log & CR/AR Status l Analysis by: R McGumess x6855MPl owner: G Swider x5381MP i BKL4

Backlog Managomant Operator Work Arounds

&rogress: Performance is not meeting management expectations.

25 20 ;ia W W bk e 3 3 g ,

= &  ; aoed 3

B I

'10 0

6/29/98 l

7/8.98 l I I 7/15/98 7/22/98 7/29/98 l 1l 11111111 8/5/98 I I 8/12/98 8/19/98 W26/98 I

9/2/98 I

9/9/98 I

9/16<98 t t 9/23/98 9/30/98 l

WW Operator Work Arounds (Recovery Backlog) ll=l3 Operator Work Arounds New Work -Goal < 10 l R *w Data 7/8'98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 & 19/98 8'26/98 9/2'98 9/9/98 9/16/98 9/23/98 9/30/98 Operator work Arounds l (Recovery Backlog) 14 14 14 14 14 14 14 14 14 14 14 14 14 Operator Work Arounds New 6 6 6 9 7 3 3 3 3 3 6 6 6 Work Operator Work Arounde >1 Year in

,9 39 3, 39 9, 39 ,, j9 99 9j 39 q, 39 Age Definition Analysis / Action This indicator depicts the number of Operator Work Arounds (W/A). The Operator Work Around backlog was frozen with the unit's These are broken down into two categories, deferred and new. entry into mode 2.

W/As are conditions which require an operator to work with equipment Management expectations are not being met. Review and in a manner other than original design intended. Issuance of a resource loaded plan is approximately 30 days behind schedule. The goalis, however, expected to be met with in Operator Work Arounds have potential to: 120 days of entering Mode 2 after Refueling Outage 06 (RFO6).

+ Impact safe operation during a plant transient,

+ Impose significant burdens during normal operation,

+ Create nuisance conditions due to recurring equipment deficiencies,

+ Distract operators from noticing recurring conditions.

Gos! Comments The Operator Work Around backlog will be dispositioned by entry into mode 2 following completion of RO6 plus six months. The Goal is to have < 10 by 11/98 with none > one year in age.

osts source: L Paene mo37MP l Analys/s by: K Knman x5090MPl Owner: B Pinkowit2 x5361MP O

BKL 7

Backlog Management Control Room and Annunciator Deficiencies (Ogress: Performance is tracking to satisfactory. Deficiencies are expec4ad to be cleared in the 12 week work planning process or the next refueling outags. an appropriate.

26 24 2 22 20 18 p 12 oop 10 38 6 I El El El 3o i m f I l l l l l l l

• 6/29/98 7/8/98 7/15/98 7/22/98 7/29'98 8/5/98 8/12/98 8/19/98 8'26/98 9/2/98 9/9/98 9/16/98 9/23/98 9/30/98 MControl Room and Annunciator Deficiencies New Work m Control Room and Annunciator Deficiencies (Recovery Backlog)

Goal <= 10 819W Dets '

7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 8/26/98 9/2/98 9/9/98 9/16/98 9/23/98 9/30/98 Control Room and Annunciator CDeficiencies (Recovery 4 Backlog) 4 4 2 2 2 1 1 1 1 1 1 1 Cont c w nir nir nir nir 23 14 21 18 18 18 15 15 14 3entnion AnekelalAction This indicator depicts the number of Control Room and Annunciator The Control Room and Annunciator Deficiency backlog was frozen deficiencies. laese are broken down into two categories, deferred with the unit's entry into mode 2.

and new.

Deficiencies are expected to be cleared in the 12 week work Control room and annunciator deficiencies are control room planning process or the next refueling outage, as appropriate.

instruments, recorders, indicators, and annunciators that function improperly and could challenge the ability of operators to monitor and control plant conditions.

Seal Commerits The Control Room and Annunciator Deficiency backlog will be dispositioned by entry into mode 2 following completion of Refueling Outage 06 plus six months. The Goal is to have < 10 by 11/98 with

_none > one year in age.

_ rs Source: L Palone x4737MPlAnm4 sis Dy L Palone x4737MPl Owner: B Pinkowitz MP BKL-8

l Backlog Management l Temporary Modifications 1

i 'OgYOSS; Performance not meeting management's expectations.

1 j 25 i

l k .h * '

! It 15 -

Good f g j l

{ 10 -

) 1 Y i *

} 5-l 0 j s s s h

E j d h

h h

5 k

fe M Ternporary Moddications (Recovery Backlog) Temporary Mods New Work -Goal for All Open Mods 4

i 9sw Dets 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 8/26/98 9/2/98 9/9/98 9/1 &98 9/23/98 9'30/98 f

j Ternporary Modifications j mecovery Backlog) 15 15 15 15 15 15 14 14 14 14 14 14 14 jg/ Temporary Mods New Work 3 1 1 2 3 4 3 5 4 6 6 8 8 i

Definition AnelveWAction l

i This indicator depicts the total number of Temporary Modifications The Temporary Modification backlog was frozen at 15 with the

(TMs) to permanent plant design. These are broken down into two unit's entry into mode 2.

4 categories, deferred and new.

j Temp mods are not being removed per the original workdown rate.

4 A temporary modification is a modification to the plant that is short- Design changes are not being approved as scheduled. The major

! term in nature and not part of the permanent plant design change delay in issuing design changes is the rework required for outside j process. vendor supplied design packages.

1

There are 20 temp mods installed of which 5 are scheduled to be removed in RFO6. The remaining 15 are scheduled to be removed prior to RFO6. Of these 15, seven (7)) can be removed as soon as E work can be scheduled, and eight (8) are waiting for design changes before field implementation.

TM's 3-97 052 & 3 98-046 are scheduled to be removed this week.

i i 3001' TM 3-98-046 has been scheduled to be removed for the last two

} The Temporary Modification backlog will be dispositioned by entry into weeks by Maintenance.

) mode 2 following completion of Refueling Outage 06 plus six months.

i Goal of < 15 open i

E

--tm Source: J Cunnrigham x4372MP l Anatysis by: S Stncker x5409MPl Owner: G Swider x5381MP 1

1 i

BKL 9

I l Backlog Management i

P NCRs Qgress: Performance is satisfactory. l 1

1 l 1

! 60 1,n 7/8/98 7/15/98 7/22/98 7/29/98

. l..,.l.l,l,l.ll?

8/5S8 8'12/98 8/1998 E'26/98 9/2/98 9/9/98 9/16/98 923/98 9/30/98 l M Deferred NCRs (Recovery Backlog) MOpen NCRs (New Work) l Waw Dets l 7/8/98 7/15/98 7/22/98 7/29/98 8/5/98 8/12/98 8/19/98 a'26/98 9/2/98 9/9/98 9/16/98 9/23/98 9/30/98 l l

l Deferred NCRs (Recovery l Backlog) 57 57 57 57 51 48 48 47 45 44 42 42 40 (New Worki 4 4 2 2 2 13 13 10 10 10 15 16 14

(' %/ Overdue OpenNCR NCRs Assignrnents 3 Mion AnalyslefAction l Current NCR owners are:

This indicator depicts the number of open dispositioned l Owner #NCRs Nonconformance Reports (NCRs) that have been determined by

, Engineering to be deferrable as well as new NCRs. 3MGRDESENG 9 l

3MGRICE 1 3MGRMECH 7 l

3MGROPS 2 I 3MGROUTAGE 4 3MGRPLAN 22 3MGRPT3 1 MGROVRINSP 8 in for final administrative closure There are 3 NCR assignments currently overdue.

i i

l i Goal Comments

! The NCR backlog will be dispositioned by entry into mode 2 following On 9/15/98 Revision 7 of RP4 (Corrective Action Program) j  ::ompletion of Refueling Outage 06 plus six months. enveloped the NCR process so that no new NCR will be generated i on field conditions as they will be handled under the CR Process.

1 G OBnen x5298 MPl Analysis by: G OBnen x5298 MPl Owner: R Andren x5727MP I$ource:

i I

BKL 10

J

}

4' i

i i

ICAVP LEVEL 4 DR STATUS i REPORT 2

1 l

4 i

l l

i I

i i

i I

4 I. 4 >

l O ICAVP LEVEL 4 DR STATUS Third Quarter 1998 The purpose of this section is to report on the progress towards completion and status of the Independent Corrective Action Verification Prc am (ICAVP) Level 4 Discrepancy l Reports (DRs).

Background

Northeast Nuclear Energy Company (NNECO) has committed to provide this update to the NRC on the completion and status of corrective actions to the ICAVP Level 4 Discrepancy Reports. The update has been described in a letter dated April 20,1998, from the NRC where NNECO's proposed process regarding disposition of Confirmed Level 4 DRs was found consistent with the NRC's expectations. In previously docketed correspondence, NNECO committed to having the final corrective actions to address the discrepancies in the deferred Level 4 DRs dispositioned prior to the completion of the next refueling outage for Millstone Unit 3 (RFO6).

The action plan for ICAVP Level 4 DRs that were deferred and not completed prior to a restart, are being controlled by the Millstone Station Corrective Action Program. These deferred tasks are tracked in the Action item Tracking and Trending System (AITTS),

()

and performance is trended using the Backlog Management Performance Indicators.

The process for closing these deferred items is consistent with the closure of other corrective actions taken at Millstone Station.

The ICAVP resulted in Unit 3 receiving a total number of 599 confirmed Level 4 DRs.

Significance Level 4 DRs involve discrepancies that identify that a system meets its licensing and design bases, however, there exists minor errors such as minor arithmetic errors that do not significantly affect the results of a calculation or inconsistencies between documents of an editorial nature.

Methodology in the letter from the NRC, dated April 20,1998, the NRC established the expectation that NNECO would format the quarterly reporting on the status of the Level 4 DRs to provide the schedule for implementing corrective actions to address each DR, a list of the DRs for which all corrective actions that have been completed since the last submittal, and references to specific closeout documentation and the dates associated l with document changes that were made. As a practical matter, based upon AITTS and l Millstone Station / Unit 3 Third Quarter Performance Report

i i

Backlog Management capabilities, the actual contents of this status report are provided l in the following format: l l 1) Figure 1, Anticipated Work Off of ICAVP Level 4 DRs:

1 The figure shows the number of open working assignments in AITTS by quarter up until restart from RFO6, when remaining ICAVP DR related assignments are scheduled to be completed.

2) Table 1, Discrepancy Report Corrective Action Dispositions:  ;

I The table lists the closed ICAVP Level 4 DRs and the cross reference to the Corrective Action Department Condition Report (CR) number. It also lists the documents that have been changed, the effective dates or revision level, as a result of disposition of each CR used to track the i

ICAVP Level 4 DRs.

Third Quarter Status Update The backlog of corrective actions on ICAVP Level 4 DRs were established with the unit's entry into mode 2, on June 29, 1998. The completion of corrective action assignments associated with the Level 4 DRs will continue until all assignments are completed, during the end of second quarter of 1999. i A '

O.

Figure 1: Anticipated Work Off of ICAVP Level 4 DR Assignments 900 - 866 800-

$ 700 E 577 f T All assignments completed y by end of second quarter in

< 1999.

f 400 - 348

.8 E 300 -

j 200 200 -

0 2nd Quarter 3rd Quarter 4th Quarter 1st Quarter 2nd Quarter 1999 1999 a

Millstone Station / Unit 3 Third Quarter Performance Report

4 7 Table 1 (V Discrepancy Report Corrective Action Dispositions 13-Nov-98 1 DR Significance Level: 004 1 M3-DRT-00007 M3-DRT-00007 ICAVP DISCREPANCY REPORT USE OF " UNVERIFIED INFORMATION" CR #: M3-97-2316 ICAVP DEFICIENCY REPORT DETAILS (DR MP3-0007) REF. MATERIAL AVAILABILITY Closure Document: None Not a discrepancy, no action requir:d 8/1/97 2 M3-DRT-00009 M3-DRT-00009 ICAVP DISCREPANCY REPORT ATWS 50.59 DOESNT ADDRESS

INCREASED FW FLOW 4

CR #: M3-97-2888 50.59 SAFETY EVAL. NEEDS ADDITIONAL IMPACT EVAL. FOR ATWS MOD (ICAVP DR-MP3-0009)

Closure Document: Nonc reviewed safty eval for PDCR MP3-88-008 and found no 9/30/97 discrepant conditions. No actions required 3 M3-DRT-00012 M3-DRT-00012 ICAVP DISCREPANCY REPORT INCONSISTENCIES WITEI FSAR, TS, &

WEST ANALYSIS CR #: M3-97-2823 INCONSISTANCY IN FSAR BETWEEN CHAPTER 15. TABLE 15.0-6 AND CHAPTER 7, FIG. 7.2-

I(ICAVP DR-MP3-0012)

Closure Document: FSARCR 97-MP3 583-P N2t;8 5 4 M3-DRT-00018 M3-DRT 00S12 ICAVP DISCREPANCY REPORT SP 3606.1 USES INCORRECT PUMP ID CR #: M3-97-2822 ICAVP DISCREPANCY REPORT: COMPONENT ID DISCRtPANCYIN STEP 4.4.12.1 OF SP iO 3606.1, REV.10 CilG 1 Closure Document: Procedure SP 3606.1 Rev.11 2/2M8 5 M3-DRT-00025 M3-DRT 00025 ICAVP DISCREPANCY REPORT UFSAR/P&lD ATWS DISCREPANCIES CR #: M3-97-2889 UFSAR DISCREPANCY REGARDING ATWS TURBINE IMPULSE SIGNAL (ICAVP DR MP3 0025)

Closure Document: FSARCR 97-MP3 490 P 12/5/97 6 M3-DRT-00032 M3-DRT-00032 ICAVP DISCREPANCY REPORT WATERlLAMMER ANALYSIS CALC ERRORS CR #: M3 97 3058 ERRORS NOTED IN CALCULATION 12179-NP(B)-163-FA, REV.2 (ICAVP DR-MP3 0032)

Closure Document: None Review of Cale 12179-NP(B)-257-FA did not find problem 6/2/98 7 M3-DRT 00034 M3-DRT-00034 ICAVP DISCREPANCY REPORT PIPING DATA PACKAGE REFERENCE ERROR CR#: M3 97 2911 INCORRECT CALCULATION REFERENCED IN QSS STRESS DATA PAC.* AGE (ICAVP DR-MP3-0034)

Closure Document: CALC SDP-QSS-01358M3 Rev.6 Change 1 9/15/97 8 M3-DRT-00038 M3-DRT 00038 ICAVP DISCREPANCY REPORT INCOMPLETE C.A. IN ACR M3 034I CR#: M3 97-3023 CAUSAL FACTOR CORR ACTION PLAN FOR CR M3-96-0341 FAILS TO ADDRESS TWO ISSUES !!CAVP DR MP3-0038[

Closure Document: DCN DM3 00-1334-97 9/24/97

I Table 1 i

Discrepancy Report Corrective Action Dispositions 13-Nov-98 2 9 M3-DRT-00045 M3 DRT 00045 ICAVP DISCREPANCY REPORT. PIPE SUPPORT CALC DISCREPANCY CR #: M3-97-2944 CALC 12179-NP(F) Z79B-148, REV3 NO2, PRESCRIBES ALLOWABLE BOLT LOAD >AISC ALLOWS (ICAVP DR MP3 0045)

Closure Document: CALC 12179-NP(F).Z79B 148 Rev.3 Change 4 9/25/97 10 M3-DRT-00053 M3-DRT-00053 1CAVP DISCREPANCY REPORT DISCREPANCY IN SW PIPE SUPPORT CALCULATION CR #: M3-97 3210 DISCREPANCIES NOTED IN PIPE SUPPORT CALC. NO.12179-NP(F)-Z019B-405 !!CAVP DR.

MP3-0053[

Closure Document: CALC 12179-NP(F)-Z019B-405 Rev. 7 Change 1 10/1767 11 M3-DRT-00055 M3-DRT 00055 ICAVP DISCREPANCY REPORT INCOMPLETE ACR M3 0087 CR #: M3-97-2910 ACR CLOSED & REFERENCED DRAWING NOT UPDATED TO RE-FLECT FIELD CONDITIONS (ICAVP) DR-MP3-0055)

Closure Document: Form Revised section 2A of M3-o6-0087 9/11/97 12 M3-DRT-00060 M3-DRT-00060 ICAVP DISCREPANCY REPORT USE OF UNAPPROVED CODE CASE CR #: M3-97 2849 WRONG CODE CASE REF. IN CA AND MISSING INFO. AND ORIGINAL SIGNATURES !!CAVP DR MP3-0060[

Closure Document: Form Processed RP4-2 for 97007257-06 9/18/97 13 M3-DRT-00069 M3-DRT 00069 ICAVP DISCREPANCY REPORT TRAY SUPPORT NOT INSTALLED PER DWG CR#: M3 97-3176 SUPPORTS NOT INSTALLED IAW DRAWINGS (ICAVP DR-MP3-0%9)

Closure Document: AWO M3-97-21163 1/9S8 Closure Document: DCN DM3-00-1635-97 11/687 14 M3-DRT-00070 M3-DRT 00070 ICAVP DISCREPANCY REPORT CABLE TRAY ID BETWEEN DRWG & j FIELD INCONSISTENT CR #: M3-97-2926 ID OF TRAY ON TRAY LOC. DRAWINNG IS INCORRECT & EXTRANEOUS CONDUIT NO.

ON DRAWING (ICAVP DR-MP3- l Closure Document: DCN DM3 00-1274-97 9/12S7 15 M3-DRT 00071 M3-DRT-0007I ICAVP DISCREPANCY REPORT EXTRANEOUS CONDUIT NUMBER ON DRWG CR #: M3-97 2926 ID OF TRAY ON TRAY LOC, DRAWINNG IS INCORRECT & EXTRANEOUS CONDUIT NO.

ON DRAWING (ICAVP DR-MP3 Closure Document: DCN DM3-00-1274 97 9/12/97 16 M3-DRT 00089 M3-DRT-00089 ICAVP DISCREPANCY REPORT PIPE SUPPORT CALC DISCREPANCY CR #: M3-97-3524 DISCREPANCY IN PIPE SUPPORT CALC. !!CAVP DR-MP3-0089(

Closure Document: CALC 12179-NP(F)-Z079C-127 Rev. 2 Change 2 10/27/97

, V

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

L

( Table 1 l\ Discrepancy Report Corrective Action Dispositions

! 13-Nov-98 3 1

17 M3-DRT 00093 M3-DRT-00093 ICAVP DISCREPANCY REPORT PIPE SUPPORT CALC DISCREPANCY CR #: M3-97 3490 DISCREPANCY FOUND WIT 11 ALLOWABLE STRESS USED FOR SilEAR LUG IN CALC 12179

!ICAVP DR-MP3-0093[

Closure Document: CALC 12179-NP(F)-279B-161 Rev.3 Change 2 10/27/97 18 M3-DRT 00094 M3-DRT-00094 !CAVP DISCREPANCY REPORT DISCREPANCY IN SW rLv SUPPORT CALCULATION -

CR #: M3-97-3208 DISCREPANCIES NOTED IN PIPE SUPPORT CALC. NO. 12179-NP(F)-Z019A 135 !!CAVP DR-l' MP3-0094[

Closure Document: CALC 12179-NP(F)-Z019A-135 Rev.4 Change 1 10/16/97 19 M3-DRT-00101 M3 DRT-00101 ICAVP DISCREPANCY REPORT QSS/RSS PUMP ROOM VENTILATION  ;

CALCULATION DISC CRs: M3-97 3241 DISCREPANCIES FOUND WlilLE REVIEWING CALC.P(D)-1001REV.0 AND CCN I !!CAVP DR-MP3-0482[

Closure Document: CALC P(B)-1001 Rev.O Change 2 10/7/97 j

20 M3-DRT 00106 M3-DRT-00106 ICAVP DISCREPANCY REPORT LOGIC AND SCHEMATIC DWG DISCREP. FOR QSS MOV'S CR #: M3-97 3246 CONFLICT INFO BETWEEN LOGIC DIAGRAMS & SCHEMATIC DIAGS (ICAVP DR-MP3 0106.0118,0119,0120,0121,0126) ,

Closure Document: DCN DM3-00-1567-97 10/21/97 y 21 M3-DRT 00ll7 M3-DRT-00ll7 ICAVP DISCREPANCY REPORT NOTIFICATION OF FAILED SURV TEST FOR 3 MSS'RV26C CR #: M3-97 3117 MISSING SIGNATURE ON SURVEILLANCE COVER SHEET FOR COMPLETED PROCEDURE

!!CAVP DR-MP3-Oll7[

Closure Document: None Maintenance personnel briefed 9/29/97 22 M3-DRT-00118 M3-DRT-00118 ICAVP DISCREPANCY REPORT SCHEMATIC & LOGIC DISCREP FOR RSS PUMP MOTORS CR #: M3-97 3246 CONFLICT INFO BETWEEN LOGIC DIAGRAMS & SCHEMATIC DIAGS (ICAVP DR MP3-0106,0118,0119,0120,0121,0126)

Closure Document: DCN DM3-00-1567-97 10/21/97 23 M3-DRT 00119 M3-DRT-00119 ICAVP DISCREPANCY REPORT SCilEMATIC & LOGIC DISCREP FOR RSS MOV'S CR#: M3-97-3246 CONFLICT INFO BETWEEN LOGIC DIAGRAMS & SCHEMATIC DIAGS (ICAVP DR-MP3-0106.0118.0119,0120,0121,0126)

Closure Document: DCN DM3-00-1567-97 10/21/97 24 M3-DRT-00120 M3-DRT-00120 ICAVP DISCREPANCY REPORT ESK-6ALG AND LSK-9-10E DISCREPANCY CR #: M3 97 3246 CONFLICT INFO BETWEEN LOGIC DIAGRAMS & SCHEMATIC DIAGS (ICAVP DR-MP3 0106,0118,0119,0120,0121,0126)

Closure Document: DCN DM3-00-1567-97 10/21/97 l

m Table 1 U

Discrepancy Report Corrective Action Dispositions 13-Nov-98 4 25 M3-DRT-00121 M3-DRT-00121 ICAVP DISCREPANCY REPORT SCHEMATIC & LOGIC DISCREP FOR SWP MOV'S CR #: M3-97-3246 CONFLICT INFO BETWEEN LOGIC DIAGRAMS & SCHEMATIC DIAGS (ICAVP DR-MP3-01 %,0118.0119,0120.0121,0126)

Closure Document: DCN DM3-00-1567-97 10/2167 26 M3-DRT-00122 M3 DRT-00122 ICAVP DISCREPANCY REPORT SCHEMATIC AND WIRING DWG DISCREPANCIES AT MCC'S CR #: M3-97-3711 MOV WIRING AND SCHEMATIC DIAGRAM DISCREPANCIES !!CAVP DR-MP3-0122[

Closure Document: DCN DM3-00-1765-97 11/1987 CR #: M3 98-2085 ICAVP DR-MP3-0122 IDENTIFIED DISCPIPANCIES/W WIRING DIAGRAM 25212-39245 SH 691 Closure Document: DCN DM3-00-0371-98 4/28/98 Closure Document: DCN DM3-01 1765-97 4/24 S 8 27 M3-DRT-00126 M3-DRT-00126 ICAVP DISCREPANCY REPORT Cil & LGIC DISCRP RESET MTR IJO SWP' PIA &C

CR #

M3 97-3246 CONFLICT INFO BETWEEN LOGIC DIAGRAMS & SCHEMATIC DIAGS (ICAVP DR-MP3-01 %,0118,0119,0120,0121,0126)

Closure Document: DCN DM3-00-1567-97 10/21/97 28 M3-DRT-00129 M3-DRT-00129 ICAVP DISCREPANCY REPORT ACR M3-96-0272 USED TO UPGRADE VS CGD CR #: M3-97-3183 CR FORM NOT FILLED OUT CORRECTLY Closure Document: None Human Error in using form 9/26/97 29 M3-DRT-00137 M3 DRT 00137 ICAVP DISCREPANCY REPORT FSAR ACCIDENT ANALYSIS ASSUMPTIONS INCONSISTENT WITH OPERATING PROCS EOP 35E-0 AND EOP 35ES-l.1 CR #: M3-97 4412 DISCREPANCY; FSAR CHAPTER 15 AND EOPS DO NOT AGREE !!CAVP DR MP3-0137[

Closure Document: FSARCR 97-MP3-583-P 2/2/98 30 M3-DRT-00179 M3-DRT-00179 ICAVP DISCREPANCY REPORT VENT / DRAIN CALC DONT REFLECT ,

LATEST HDR MOVEMENTS l CR #: M3 97-3865 ICAVP DR MP3-0179 VENT / DRAIN CALCS NOT REVISED Closure Document: CALC 12179-NP(FFSWP-95-V222 Rev.2 9/30/97 Closure Document: CALC 12179-NP(FFSWP-95-V223 Rev.2 9/30S 7 Closure Document: CALC 12179-NP(FFSWP-97 V224 Rev.2 9/3067 Closure Document: CALC 12179-NP(FFSWP-97-V225 Rev.2 9/30/97 31 M3-DRT-00181 M3-DRT-00181 ICAVP DISCREPANCY REPORT CONFIG DISCREPANCIES BETWEEN FSAR & P&lD j CR #: M3-97-3362 DISCREPANCIES FOUND WITH FSAR SECTION 15.6.2  !!CAVP-MP3-0181[ I Closure Document: FSARCR 97-MP3-583-P 2/2/98 I f%

i

ip- Table l

'V Discrepancy Report Corrective Action Dispositions 13-Nov-98 ' S 32 NU-DRT 00183 M3-DRT-00183 ICAVP DISCREPANCY REPORT DISPERSION PARAMETER FOR Fila IS l NOT CURRENT CR #: M3-97-3672 DISCREPANCY; NDS MISSING CALCULATION  !!CAVP DR-MP#-

0173[

Closure Document: CALC ENVR W166 Rev.0 Change 0 3/13/98 Closure Document: CALC UR(BF227 Rev.3 3/13/98

- Closure Document: CALC UR(BF228 Rev.4 3/13/98 Closure Document: CALC UR(B)-270 Rev. I 3/13/98 Closure Document: CALC UR(BF272 Rev. I 3/13/98 33 AD-DRT-00201 M3-DRT-00201 ICAVP DISCREPANCY REPORT INAPPROPRIATE COMMERCIAL GRADE PROCUREMENT CR #: M3-97-3587 INAPPROPRIATE USE OF COMMERCIAL DEDICATION DISCOVERED BY ICAVP !!CAVP DR.

MP3-020l[

Closure Document: PO 00066526 revised 12/19/97 Closure Document: PO 00066526 revised 12/19/97 Closure Document: PO 00056538 closed 12/19/97 Closure Document: PO 00956633 closed 12/19/97 Closure Document: PO 00957790 closed 12/19/97

- Closure Document: PO 02014472 revised 12/19/97 34 M3-DRT-00205 M3-DRT-00205 ICAVP DISCREPANCY REPORT DRAWING DISCREPANCY LSK 27-O 12B CR #: M3 97-3517 DEFICIENCY IDENTIFIED, PlWSICAL PLANT AND DRAWING DO NOT MATCH Closure Document: DCN DM3-00-1663-97 11/5/97 35 M3 DRT-00207 M3-DRT-00207 ICAVP DISCREPANCY REPORT DRAWING DISCREPANCY LSK 27-12D CR #: M3-97-3517 DEFICIENCY IDENTIFIED, PHYSICAL PLANT AND DRAWING DO NOT MATCH Closure Document: DCN DM3-00-1663-97 11/5/97 36 M3-DRT-00212 M3-DRT@212 ICAVP DISCREPANCY REPORT DWG DISCREPANCY-SCHEMATICS QSS 440A,B CR#: M3-97-3517 DEFICIENCY IDENTIFIED, PlIYSICAL PLANT AND DRA%1NG DO NOT MATCil Closure Dncument: DCN DM3 00-1663-97 11/5/97 37 M3-DRT-00214 M3-DRT-00214 ICAVP DISCREPANCY REPORT DRAWING DISCREPANCY.

SCHEMATIC 3QSS-060 CR #: M3-97-3803 DISCREPANCY; DRAWING ERROR ON W1 RING DIAGRAM !!CAVP DR-MP3-02141 Closure Document: DCN DM3 001816-97 11/26/97 38 M3-DRT-00229 M3-DRT 00229 ICAVP DISCREPANCY REPORT MISSING EQUlPMENT ID TAGS i

CR#: M3-97-3455 MISSING COMPONENT LABELS ON QS AND RSS SYS. flCAVP DR MP3-0229 AND 0230[

Closure Document: Nonc Installed labels using minor maintenance i

] <

12/23/97

)

n)

(

Table 1 Discrepancy Report Corrective Action Dispositions

!3-Nov-98 6 39 M3-DRT 00233 M3-DRT-00233 ICAVP DISCREPANCY REPORT DRAWING DISCREPANCY-LSK 9-10C,K CR #: M3-97-3842 DISCREPANCY; DRAWING INCONSISTENCIES !!CAVP DR-MP3-0233[

Closure Docament: DCN DM3-00 !803 97 1I/21/97 40 M3-DRT-00240 M3-DRT-00240 ICAVP DISCREPANCY REPORT DRAWING DISCREPANCY 3SWP-152A.B CR #: M3-97 3462 WIRING DRAWING DISCREPANCY DISCOVERED BY ICAVP Closure Document: DCN DM3-00-1579-97 10/18 S 7 CR#: M3-97-3463 DOCUMENT CONTROL DISCREPANCY DISCOVERED BY ICAVP Closure Document: None Reviewed aperture cards for correct drawing revisions 11/6/97

^

41 M3 DRT-00253 M3-DRT-00253 ICAVP DISCREPANCY REPORT INACCURATE DATA IN CORRECTIVE ACTION M3-96-0268 CR #: Mk97 3529 DISCREPANCY WITH 160 HR RATING IN FSAR FIGURE (ICAVP DR-MP3 0253)

, Closure Docament: DCN DM3 01-0149-97 11/5S 7 42 M3-DRT 00255 M3-DRT-00255 ICAVP DISCREPANCY REPORT RCP UNDERSPEED CAL DATA CONVERSION DISCREPANCY C R #: M3-97-3453 SETPOINT REFERRECNCE DISCREPANCY FOR RCP UNDER- SPEED - CAL DATA COV.

!!CAVP DR MP3-0255[

Closure Document: Procedure 3442H01 1 Rev. 7 Change 2 10/20/97 43 M3-DRT-00259 M3-DRT-00259 ICAVP DISCREPANCY REPORT LOAD COMB. DISCREPANCY IN NORMA 1/ UPSET STRESSES CR #: M3-98-0175 ICAVP IDENTIFIED CALC 12179-NP(B)-53900 DISCREPANCIES

Closure Document

CALC 12179-NP(B)-X53900 Rev. 5 Change 1 1/28/98 Closure Document: None Review of others Cales OK 1/28/98 44 M3-DRT-00264 M3-DRT-00264 ICAVP DISCREPANCY REPORT VOIDED UIR'S CONSIDERED TO BE IN SCOPE CMP CR #: M3-97-3804 DISCREPANCY; THREE UIR'S VOIDED IN ERROR fICAVP DR-MP3-0264[

Closure Document: None No actions required 11/11/97 45 M3-DRT-00269 M3 DRT-00269 ICAVP DISCREPANCY REPORT CHEMISTRY ACTION LIMITS NOT SPECIFIED FOR RWST CR#: M3-97-3551 RWST BORON I IMIT NOT TIED TO PH IN FSAR (ICAVP DR-MP3-0269)

Closure Document: Procedure CP 3802C Rev. 3 Change 2 11/29/97 CR #: M3-97-4361 DISCREPANCY DISCOVERED WITH PROGRAM USED TO CORRELATE PH TO BORAN CONC. !!CAVP DR-MP3-0269[

Closure Document: Procedure CP3802C Rev.3 Change 2 11/29/97 h

G

(~] Table 1 V Discrepancy Report Corrective Action Dispositions 13-Nov-98 7 46 M3 DRT-00300 M3-DRT-00300 ICAVP DISCREPANCY REPORT PDDS IDENTIFIES DISCREPANT COMPONENT SPEC NUMBERS CR #: M3-97 3995 DISCRPEANCY; DOCUMENTATION ERRORS !!CAVP DR-MP3-0300[

Cosure Document: PDDS PDDS-97-0341 12/8/97 47 M3-DRT-00333 M3-DRT-00333 ICAVP DISCREPANCY REPORT SCHEMATIC AND WIRING DRAWING DISCREPANCIES FOR SWP,RSS,& QSS SWOR PUMP BREAKERS CR #: M3-98-0570 ICAVP IDENTIFIED DISCREPANCIES W/ SCHEMATIC DIAGRAMESK-05CK REV.

16 Closure Document: DCN DM3-00-0122-98 2/16/98 48 M3 DRT-00344 M3-DRT-00344 ICAVP DISCREPANCY REPORT 3HVR*ACUl A/B FAN BRAKE HORSEPOWER DISCREPANCY CR #: M3-97-3908 DISCREPANCY; FAN BRAKE HORSEPOWER FOR 3HVR*ACUI A/B !!CAVP DR-MP3-0344[

Closure Document: DCN DM3 00-1617-97 11/20/97 49 M3-DRT 00352 M3 DRT-00352 ICAVP DISCREPANCY REPORT CSL DRAWING DISCREPANCIES CR #: M3-97 3887 DISCREPANCY; ERROR IDENTIFYING CONDUlT NUMBER flCAVP DR-MP3-0352[

Closure Document: DCN DM3 00-1806-97 11/25/97 h 50 M3-DRT-00373 M3-DRT 00373 ICAVP DISCREPANCY REPORT 295 CALCULATION US(B).

CR#: M3-98-2066 ICAVP IDENTIFIED DISCREPANCIES W/ MINIMUM RWST DRAWDOWN LEVELS AND DRAWDOWN TIMES Closure Document: CALC US(B)-295 Rev. 7 5/28/98 51 M3-DRT-00409 M3-DRT-00409 ICAVP DISCREPANCY REPORT INCOMPLETE EVALUATION PACKAGE FOR MATERIAL CONDITION CR #: M3-96-0301 RUST NOTED ON STAINLESS STEEL PIPE WELD Closure Document: None Add links to DRs and CRs in passport 5/8/98 CR#: M3-98-1916 ICAVPIDENTIFIED DISCREPANCIES W/ACRS M3-96-0301 &

13789 Closure Document: None Add links to DRs and CRs in passport 5/7/98 52 M3-DRT-00436 M3-DRT-00436 ICAVP DISCREPANCY REPORT INCONSISTENCY BETWEEN PDDS &

P&ID EM-112C WITH RESPECT TO LINE NUMBER IDENTIFICATION CR#: M3-97-4063 DISCREPANCY; DRAWING INCONSISTENCIES WITH PLANT COMPUTER DATABASE

!!CAVP DR-MP3-0436[

Closure Document: PDDS PDDS-97-0333 11/26/97 53 M3-DRT-00458 M3-DRT-00458 ICAVP DISCREPANCY REPORT ELBOW WAS COMPARED TO UNVERIFIED /INCOR ACCEPTCRIT CR#: M3-98-0303 ICAVP IDENTIFIED DISCREPANCIES W/ PIPE STRESS CALCULATIONS Closure Document: CALC NCR 3-91-406-116-EM Rev. O Change 1 1/20/98 N

i

(] Table 1 v Discrepancy Report Corrective Action Dispositions )

13-Nov-98 8 54 M3-DRT 00467 M3-DRT-00467 ICAVP DISCREPANCY REivni CALCULATION DISCREPANCIES l INVOLVING SWP NON-REVER-SING MOTORS l CR #: M3-97-4061 DISCREPANCY; INCONSISTENCIES IN CALCULATION SF-M3-EE-342 (REV.1) !!CAVP DR l l MP3-0467[

Closure Document: DCN DM3-001769-97 11/18S 7 I $5 M3-DRT 00504 M3-DRT-005N ICAVP DISCREPANCY REPORT VENDOR DATA NOTIN AGREEMENT I W/ NAMEPLATE CR #: M3-97-3899 DISCREPANCY; MOTOR NAME PLATE DATA DOES NOT MATCll DRAWING l

SPECIFICATIONS !!CAVP DR MP3-0504[ l Closure Document: CALC NL-025 Rev.3 Change 21 12/187 Cosure Document: CALC NL-033 Rev.3 Change B 12/1/97 Closure Document: CALC NL-038 Rev.2 Change 12 12/1/97 Conure Document: DCN DM3401818-97 12/2/97 56 .M3-DRT 00550 M3-DRT-00550 ICAVP DISCREPANCY REPORT DRAWINGS NOT IN AGREEMENT CR #: M3-97-4403 DISCREPANCY; VENTED TRAY COVERS INSTALLED WHERE FLAT COVERS ARE CALLED FOR llCAVP DR-MP3-0559}

Closure Document: DCN DM3-00-1995-97 l/3SS CR #: M3-98 !458 ICAVP IDENTIFIED DISCREPANCIES W/ CABLE TRAY WIDTH DIMENSIONS l Closure Document: DCN DM3-00-0290-98 3/24/98 j V 57 M3-DRT-00$$9 M3-DRT-00559 ICAVP DISCREPANCY REPORT TRAY COVERS NOTIN ACCORDANCE  !

l WITil DESIGN DOCUMENT I CR #: M3-97-4404 DISCREPANCY; CABLE RACEWAY PROGRAM AND COVER LOCATION AND IDENTIFICATION DRAWING DO NOT AGREE (ICAVI-Closure Document: DCN DM3-00-1995-97 1/3/98 58 M3-DRT-00575 M3 DRT-00575 ICAVP DISCREPANCY REPORT AUXILIARY BUILDING FILTER UNIT CHARCOAL ADSORBER FACE VELOCITY CR #: M3 98-0923 ICAVP IDENTIFIED DISCREPANCIES W/FECH SPEC & FSAR TABLE I.8-1 Cosure Dochment: FSARCR 98-MP3-79-P 5/8/98 59 M3-DRT 00591 M3 DRT-00591 ICAVP DISCREPANCY REPORT TECHNICAL ERRORS IN PAST PROCEDURE CHANGES CR #: M3-98-0169 1CAVP DISCREPANCY REPORT

!. IDENTIFIED Gosure Document: Form 3646A.151 1/28/98 Closure Document: Form 3646A.16-1 1/24/98 Closure Document: Form 3646A.17-1 2/2/98 Closure Document: Form 3646A.181 1/28/98 Cosure Document: Procedure SP 360lF.5 5/28/97 CR#: M3-98-0492 ICAVP IDENTIFIED DISCREPANCIES W/ TECHNICAL ERRORS IN PAST PROCEDURE CHANGES Closure Document: None Closed to CR M3 98-0169 2/2/98

?

V o

i

1 p

d Table 1 ,

Discrepancy Report Corrective Action Dispositions '

13-Nov-98 9 l i

60 M3-DRT-00623 M3-DRT-00623 ICAVP DISCREPANCY REPORT CRITERIA DETERMINING WHICH l VENDOR TECHNICAL MANUALNEED UPGRADING BY STARTUP j CR #: M3 981206 ICAVP IDENTIFIED DISCREPANCIES W/ CRITERIA FOR DETERMINING WHEN VENDOR TECH MANUALS ARE UPDATED Closure Document: EVAL M3-EV-97-0326 Rev.1 (on Key Safty Related Equip List) 3/3/98 61 M3-DRT-00638 M3-DRT-00638 ICAVP DISCREPANCY REPORT SURVEILLANCE PROGRAM DOES NOT ASSURE THAT ALL SWI"S ARE TESTED FOR ALL OPERATING REQUIREMENTS CR .t: M3 98-0169 ICAVP DISCREPANCY REPORT IDENTIFIED 1 Closure Document: Form 3646A.151 1/28/98 l Closure Document: Form 3646A.16-1 1/24/98 Closure Document: Form 3646A.17-1 2/2/98 Gosure Document: Form 3646A.18-1 1/28/98 Cosure Document: Procedurc SP 3601F.5 5/28/97 i 62 M3 DRT-00657 M3-DRT-00657 ICAVP DISCREPANCY REPORT DISCREPANCY BETWEEN REG GUIDE 1.9, DESIGN BASIS

SUMMARY

DOCUMENT & DIFFERENTIAL TRIP OF GENERATOR l

1 CR#: M3 97-4463 DISCREPANCY W/ EMERGENCY DIESEL GEN DESIGN BASIS j

SUMMARY

l Closure Document: [X:N DM3-S-00-1901-97 12/13/97 j 63 M3-DRT-00745 M3-DRT-00745 ICAVP DISCREPANCY REPORT INCOMPLETE CLOSE-OUT ON b LICENSEE EVENT REPORT (LER) COMMITMENTS U CR#: M3-981968 ICAVP IDENTIFIED DISCREPANCIES W/ CORRECTIVE ACTIONS TO LER 92-020-00 Closure Document: None No adverse condition, info was submitted. ref commitment 5/6/98 17389 64 M3-DRT-00759 M3-DRT-00759 ICAVP DISCREPANCY REPORT DEFICIENCIES IN QSS PROCEDURES SP3609.1 AND SP 3609.2 CR #: M3-98 0941 ICAVP IDENTIFIED DISCREPANCIES W/SP3609.1 & SP 3609.2 TYPO Gosure Document: Procedure SP3609 Rev. 8 Change 4 2/l M 8 65 M3 DRT-00764 M3-DRT-00764 ICAVP DISCREPANCY REPORT I&C'S MEASUREMENT & TEST EQUIPMENT USED FOR SURVEILLANCE TESTING NOT PROPERLY DOCUMENTED CR #: M3-98-0562 ICAVP IDENTIFIES DISCREPANCIES W/ OPS FORMS Closure Document: None Error in documenting equipment on forms 2/19/98 66 M3 DRT-00772 M3-DRT-00772 ICAVP DISCREPANCY REPORT CLOSURE OF DESIGN DEFICIENCY REPORT (DDR 1027)

CR #: M3-97-3161 CHANGE TO FSAR SECTION 9.4.3 AUX BLDG VENTILATION NEEDED

, Oosure Document: FSARCR 97-MP3-590-P 1/23/98 l

l 67 M3-DRT-00791 M3-DRT-00791 ICAVP DISCREPANCY REPORT CABLE LENGTHS USED ASSUME ONE WAY VOLTAGE DROP (CALCULATION 122E)

CR#: M3 98-0371 ICAVP IDENTIFIED DISCREPANCIES W/ CALCULATION 122E " SIZES THE PT LEADS" d

C Gosure Document: CALC 122E Rev.0 Change 1 9/28/98 I

l

?

l Table 1 Discrepancy Report Corrective Action Dispositions 13-Nov-98 10 68 M3-DRT-00855 M3 DRT-00855 ICAVP DISCREPANCY REPORT INCORRECT DYNAMIC DISPLACEMENTS USED IN PIPE STRESS ANALYSIS CR #: M3-98-0505 ICAVP IDENTIFIED DISCREPANCIES W/ CALCULATION FOR CODING OF SEISMIC MOVEMEMS FOR PIPING STRESS Closure Document: CALC 12179-NP(F)-728 Rev.0 Change 3 1/3168 69 M3-DRT-00907 M3-DRT-00907 ICAVP DISCREPANCY REPORT INSTRUMENT INSTALLATIONS NOT IN ACCORDANCE W/ DESIGN DOCUMENTS AND STANDARDS CR#: M3-98-0551 ICAVP IDENTIFIED DISCREPANCIES W/ DRAWINGS AND INSTRUMENT i INSTALLATION l Closure Document: AWO M3-98-02739 3/30/98 Closure Document: AWO M3-98-02856 2/24/98 Closure Document: DCN DM3-00-0113-98 2/12/98 Closure DNument: DCN DM340-0304-98 4/7/98 70 M3-DRT-00909 M3-DRT-00909 ICAVP DISCREPANCY REPORT CLOSURE OF UNRESOLVED ITEM REPORT (UIR 36)

CR #: M3-98-0460 ICAVP IDENTIFIED DISCREPANCIES W/ UNRESOLVED ITEM REPORT (UIR) 36 CLOSURE  ;

DOCUMENTATION i Closure Document: FSARCR 97-MP3-543-P 4/6/98 l 71 M3-DRT-00919 M3-DRT-00919 ICAVP DISCREPANCY REPORT RECORD RETENTION FOR A TEC}iNICAL SPEC TEST PROC NOT MAINTAINED CR #: M3-98 0656 ICAVP IDENTIFIED DISCREPANCIES W/ RECORD RETENTION FOR T.S. TEST PROCEDURE Closure Document: Procedure Records Retention and Turnover Schedule lland Book was 7/27/98 revised Rev. I 72 M3-DRT 00926 M3-DRT-00926 ICAVP DISCREPANCY REPORT ELECTRICAL INSTALLATION NOT IN ACCORDANCE W/ DESIGN DOCUMENTS CH #: M3 98-0497 ICAVP IDENTIFIED DISCREPANCIES W/ ELECTRICAL INSTALLATION NOT AS PER DESIGN DOCUMENTS Closure Document: AWO M3-98-04447 3/5/98 Closure Document: AWO M3-98-07072 5/1/98 Closure Document: DCN DM3-00-0114-98 5/1/93 Closure Document: DCN DM3-00-0122-98 2/16/97 CR #: M3-98-0591 ICAVP IDENTIFIED DISCREPANCIES W/ ELECTRICAL INSTALLATION COVER LEIT OFF Closure Document: AWO M3 98-03915 5/21/98 Closure Document: AWO M3-98-07721 5/21/98 73 M3-DRT-00936 M3-DRT-00936 ICAVP DISCREPANCY REPORT INSUFFICIENT DOCUMENTATION TO VERIFY CLOSURE OF UlR 639 CR#: M3-98-2210 ICAVP DR MP3-0330 IDENTIFIED DISCREPANCIES W/RSS SPRAY NOZZLES Closure Document: None info verified by field walkdown 4/29/98 Closure Document: Report editorial correction to the BTP Apppendix R Compliant Report 4G9/98 l

l (O-)

(

l I

i i

Table 1 l Discrepancy Report Corrective Action Dispositions 13-Nov-98 ))

74 M3 DRT 00959 M3-DRT-00959 ICAVP DISCREPANCY REPORT DUCT SUPPORT CALCULATION DISCREPANCY CR #: M3-98-0728 ICAVPIDENTIFIED DISCREPANCIES W/ CALCULATION FOR PIPE SUPPORTS Closure Document: CALC 12179-NP(F)-Z5451-1235 Rev.2 Change 1 9/10/98 75 M3-DRT-00983 M3 DRT-00983 ICAVP DISCREPANCY REPORT MOUNTING DETAll QUALIFICATION FOR DUCTMOUNTED RAD-MONITOR CAN NOT BE VERIFIED CR #: M3 98-0666 1CAVP IDENTIFIED DISCREPANCIES W/ CALCULATION FOR QUALIFICATION FOR PIPE LINES Oosure Document: CALC 12179-NM(S)-767 CZC (found) 11/7/85 CR#: M3-98-2271 ICAVP M3-DRT-00983 IDENTIFIED DISCREPANCIES W/ CALCULATION FOR QUALIFING NOZZLES Cosure Document: CALC 12179-NM(S)-767-CZC Rev.0 Change 1 10/7/98 76 M3-DRT-00994 hG-DRT-00994 ICAVP DISCREPANCY REPORT SCHEMATIC DIAGRAMS DO NOT MATCH THE WIRING DIAGRAM CR #: M3-98-0621 ICAVP IDENTIFIED DISCREPANCIES W/SCitEMATIC DIAGRAMESK-7L REV 24 Gosure Document: DCN DM3-00-0112-98 2/9S8 77 M3-DRT-01001 M3-DRT 01001 ICAVP DISCREPANCY REPORT UIR 970 IS NOT IMPLEMENTED AS STATED IN THE DISCREPANCY CLOSURE REQUEST CRN: M3-98-0976 ICAVP IDENTIFIED DISCREPANCIES W/ CHANGES TO FSAR TABLE 6.2-62 THAT WERE NOT IMPLEMENTED Closure Document: DICP for UIR 970 3/1!!98 Closure Document: FSARCR 98-MP3 29-P 3/8/98 78 M3-DRT-01043 M3-DRT-01043 ICAVP DISCREPANCY REPORT INCOMPLETE CLOSURE PACKAGE FOR CR M3-97-0733 CR #: M3-98-1739 ICAVP IDENTIFIED DISCREPANCIES W/ INCOMPLETE CLOSURE PACKAGE FOR CR M3-98-0733 Gosure Document: None include additional documentation in CR package 4/29/98 79 M3-DRT-01054 NO DRT-01054 ICAVP DISCREPANCY REPORT INCONSISTENT VALUES IN FSAR TABLE 15.6-6 CRN: M3-981935 ICAVP IDENTIFIED DISCREPANCIES W/ CALCULATION FOR STEAM GENERATOR TUBE RUPTURE Gosure Document: FSARCR 98-MP3-20-P 2/27/98 80 M3-DRT-01070 M3 DRT-01070 ICAVP DISCREPANCY REPORT SER SEC 7.3.2.8 INCONSISTENT W/

ISOLATION OF NON SAFETY RELATED SERVICE WATER PIPING CR #: M3 98-1614 1CAVP IDENTIFIED DISCREPANCIES W/NONSAFETY RELATEDPIPING ISOLATION VALVES FSAR VS SER Closure Document: COTRAP B17246 5/9/98 Closure Document: Memo MP3-DE-0166 4/28/98 81 M3-DRT-01077 M3-DRT-01077 ICAVP DISCREPANCY REPORT ACR M3-96-0335 CORRECT 1VE l ACTION ITEM 2 IS A PRE STARTUP ISSUE BUT IS SCliEDULED FOR POST STARTUP CR#: M3 98-1790 ICAVP IDENTIFIED DISCREPANCIES W/ ENGINEERING EVALUATION PER EDi#30010 OF MP3 SYSTEMS k Oosure Document: EVAL M3-EV-98-0079 4/3/98

(' Table 1 d Discrepancy Report Corrective Action Dispositions 13-Nov-98 12 82 M3-DRT-01082 M3-DRT 01082 ICAVP DISCREPANCY REPORT INSUFFICIENT DOCUMENTATION TO VERIFY CORRECTIVE ACTION FOR CR M3-97 0729 CR #: M3 97-0729 ADMINISTRATIVE ISSUES RELATED TO EDG INCONSIST ANCIES (SPECS VS DRAWINGS)

Closure Document: FSARCR 97-MP3-150-P 8/1/97 CR #: M3-98-1952 ICAVP IDENTIFIED DISCREPANCIES W/CR M3 97-0729 IMPLEMENTATION Closure Document: Form Revised RP44 closcout form with incorrect DCN reference. 4/14/98 Updated AITTS closure notes 97005927-01,02 83 M3-DRT-01086 M3-DRT-01036 ICAVP DISCREPANCY REPORT CLOSURE OF UIR 1144 CR #: M3-97 2789 EQUIP. & SUPPORT IN AUX. BLDG. & MCC ROD CONTROL AREA 24'6", NOT EVALUATED FOR EFFECTS OF LOW Closure Document: Memo . MP3-DE-97-1415 10/8/97 CR #: M3-98-0224 ICAVP IDENTIFIED DISCREPANCIES WITH CALS 3-92-103-191 M3-CNN Closure Document: CALC 3-92-103-191M3 Rev.1 Change 8 5/26/98 Closure Document: None Review found that FSARCR not required 5/26/98 84 M3-DRT-01087 M3-DRT 01087 ICAVP DISCREPANCY REPORT CR M3-96-1222 CORRECTIVE ACTION IMPLEMENTATION 4

O CR #: M3-98-1690 ICAVP IDENTIFIED DISCREPANCIES W/CR M3-96-1222 CORRECTIVE ACTION PLAN IMPLEMENTATION Closure Document: CALC 97-SCS-01471 M3 Rev. I 5/1/98 Closure Document: OD. MP3-042-98 Rev. I restored full operability 5/10/98 85 M3-DRT-01089 M3-DRT-01089 ICAVP DISCREPANCY REPORT INCORRECT CALCULATION REVS REFERENCED IN DCR'S CR #: M3-98-2294 ICAVP M3-DRT-1089 tDENTIFIED DISCREPANCIES W/ RSS MODIFICATION DCRS Closure Document: DCN DM3-00-0163-98 2/23/98 Closure Document: DCR M3-97045 Rev.1 4/4/98 86 M3-DRT-01094 M3-DRT-01094 ICAVP DISCREPANCY REPORT MODELING OF AIR CONDITIONING UNITS IN CALCULATION T 01528-53 CR#: M3-98-1851 ICAVP IDENTIFIED DISCREPANCIES W/ CALCULATION FOR ECCS PASSIVE FAILURE IN RSS PUMP CUBICAL Closure Document: CALC T-01528-S3 Rev. I 5/9/98 m

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m sum-em%e m m- nm-mAawvm mmEmemAm- m.m,mmem, 4'

STATUS OF FINDINGS FROM SARGENT & LUNDY ICAVP FINAL REPORT h

O Status on S&L Findings From ICAVP Third Quarter 1998 The purpose of this section is to report on progress towards compIstion of corrective actions to the eleven (11) Sargent and Lundy (S&L) findings resulting from the Independent Corrective Action Verification Program (ICAVP).

Background

Northeast Nuclear Energy Company (NNECO) reviewed the Sargent and Lundy Millstone Unit 3 ICAVP Final Report Executive Summary, SL-5192, dated June 1,1998.

As had been required by the NRC's August 14, 1996, Confirmatory Order, NNECO provided a written reply', dated June 13,1998, to address the eleven (11) ICAVP Team findings and recommendations contained in the Final Report. NNECO issued on June 2

13,1998, the Backlog Management Performance Update for the Second Quarter , and committed to providing quarterly the status of progress towards the final disposition of the eleven S&L findings from the ICAVP.

As indicated by Sargent and Lundy in Section 1.7.2 of the Final Report Executive

-, Summary, the 11 ICAVP Team findings and recommendations are based on Level 4 Discrepancy Report (DR) issues that have a high occurrence rate. NNECO's review of these Level 4 DRs, both individually and collectively, indicate that they are of low safety significance and do not impact the Millstone Unit 3 license bases (LB) or design bases (DB). These areas continue to be under review to determine where improvements could enhance NNECO's configuration control going foiward.

Status Report There are eleven ICAVP Team findings and recommendations from the S&L Final Report, SL-5192. In this section a states is provided below on the progress towards completion of corrective actions associated with each of the eleven findings and recommendations. The information is intended to supplement NNECO's earlier correspondence', dated June 13,1998, in which a written reply to address each of the items in the Final Report was initially provided.

p M. L. Bowling letter to U.S. Nuclear Regulatory Commission, ' Independent Corrective Action

(' Verification Program Final Report Executive Summary Comments," dated June 13,1998.(B17297) 8 M. L. Bowling letter to U.S. Nuclear Regulatory Commission, " Backlog Management Performance update - Second Quarter 1998,* dated June 30,1998 (B17287)

Millstone Station / Unit 3 Third Quarter Performance Report

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

l 3

Status on Findings in the S&L Final Riport Page 2 of 9

. Ry.atem Review (S&L Final Report. SL-5192. Section 1.7.2.1) i

1. "The PMMS and PDDS databases contain sufficient number of errors and

. omissions so as to render the data suspect for design input."

NNECO Response:

a) The PMMS and PDDS data issues are to be resolved as part of the Master ,

Equipment List portion of the Indus Passport (Passport) implementation project. The Passport planning event was conducted August 18-27, 1998.

The missius of the planning event was to carefully and objectively evaluate the Passport suite of applications as a viable opportunity to establish 'best practice' business processes and to provide the Project Management Team  !

with sufficient information to develop a preliminary work scope, schedule, and cost estimate. In this regard the following objectives were met:

. Established a baseline understanding of the Passport Project Plan j

. Developed a preliminary Project Scope & Schedule with work scope &  !

resource information l

. Presented preliminary project plan to Senior Management on September  :

8,1998 i i

O V The formal project plan is undergoing the final review and approval process.

The next phase of the project, detailed planning sessions, i.e., Business Process Integration (BPI), is scheduled to be conducted in the fourth quarter

.of 1998 and complete early in the first quarter of 1999. The Master Equipment List BPI session is tentatively scheduled to commence during December of 1998 and complete early in 1999.

b) An Engineering Assuranco Group assessment of PDDS Relief Valve Setpoints was completed in the third quarter of 1998. The objective of this assessment was to determine the effectiveness of the Unit 3 Plant Design Data System (PDDS) Relief Valve Setpoint process for control of relief valve I

setpoints. It was determined that the PDDS Process for control of relief L valve setpoints was weak and labor intensive to implement. The process  !

i was considered weak because other sources for the setpoints (e.g., PMMS) were found to contradict the information contained in PDDS. Although this i did not result in a loss of configuration control for the twenty six relief valves  ;

l reviewed, it was recommended that the scope of the review should be l expanded to include the remaining safety related relief valves. Consolidation

,. of relief valve setpoints into a single database was recommended as a l configuration management enhancement to provide further assurance that i

the correct relief valve setpoints are used on a going forward basis. These

.l recommendations were accepted and are being tracked through the 4 corrective action process.

Millstone Station / Unit 3 Third Quarter Performance Report

4 Status on Findings in the S&L Final Report Page 3 of 9  !

1 O

2. "The component procurement specifications and vendor drawings have not been consistently kept up-to-date."

NNECO Response:  !

As noted in our initial response, NNECO recognizes the importance of up-to-date )

procurement specifications and vendor drawings. While our processes covering I these activities did not always achieve the desired result, there are controls in

place to ensure that component data and vendar drawings are verified for accuracy prior to their use 'as design inputs. This allows time for an orderly  ;

transition to our Passport Information Management strategy which will serve to I

improve links between associated components and applicable documentation, including vendor specifications and drawings with associated revision status.

The following actions have been initiated to address these issues:  !

• An engineering department instruction was issued for Millstone Unit 3 to ,

provide specification categorizations and guidance for use. Many l procurement specifications are designated " historical" as they are not being actively used (reference only) and will not be updated.

. An engineering department instruction was issued for the Station to provide drawing categorizations and updue requirements in order to apply consistent I

' levels of drawing update requirernents based on current drawing use and importance to plant operation and design.

I NNECO considers this item of the Final Report to have been fully addressed by the completion of the actions described above.

l I 3. "The number of instances where incorrect design inputs were used indicate a calculation control problem. The concem is limited to mechanical system sizing calculations and electrical system calculations.

l This condition appears to be due to the fact that volded or superseded calculations are not adequately controlled (i.e., kept as active) and

therefore can e.nd are inadvertently used when new work is being

\ performed."

l-During the third quarter Engineering Assurance completed an assessment titled

" Attention to Engineering Quality." The purpose of this assessment was to evaluate how strictly procedure requirements were being adhered to by Urut 3 Engineenng when preparing Design and Technical Support Engineering products. Three Design Change Records, two Technical Evaluations and one

~( Special Procedure were reviewed. The assessment identified three cases where independent reviews or inter-discipline reviews were not documented as required asillstone Station / Unit 3 Third Quarter Performance Report

Status on Findings in the S&L Final Report Page 4 of 9

}

by the procedures. Further investigation determined that the reviews had been i

[ performed . however the documentation was not included in the package.

i- Although these deficiencies did not result in a loss of configuration management in the physical plant they represent further evidence of problems with attention to i~ detail relative to compliance with engineering procedures. The results of this l . assessment were presented to the Engineering Quality Review Board who

j. reinforced management's expectations concerning these attention to engineering quality issues to the line management responsible.

1 i Within Unit 3, the Design Engineering Manager commissioned an independent

. review of recent calculation essessments. This review was performed as part of l the continuing effort to improve calculations. As a result of this review specFic

corrective actions and plans to further improve il 4 quality of new or revised

calculations were identified. These corrective actions Mcluded such items as the

use of an Accountability Review Form by Design Engineering supervisors, i j

development of a listing of acceptable inputs for each of the Passport /CTP fields

, for use by Unit 3 design engineers, and recommendations to the Design Control Manual Committee for consideration of additional changes to the DCM.

l a-L in addition to the site wide Quality Review Board (QRB) discussed in NNECO's original response, the Unit 3 QRB was formed in August,1998. The charter for

this new board, as identified by the Uriit Engineering Director, is to review engineering' documents prior to their release. Board membership consists of engineering supervisors within the unit having the capability to review the quality of the documents from both technical and administrative perspectives.  !

1 To date, the Unit 3 QRB has reviewed a total of 46 calculations that have undergone revision. Of the 46, three were identified as requiring rework, meaning that the Safety Screen / Evaluation fell short of NNECO's expectations.

The Unit 3 Qi4D will continue to monitor and trend calculations as part of the NNECO's continuing effort to improve the quality and control of calculations.

1

4. "A high number of minor discrepancies were identified in both old and recently revised mechanical system sizing calculations. While none of these discrepancies affected the calculation results or impacted compilance with the licensing and design basis, overall quality could be improved."

NNECO has recognized that the calculation control process has had historical weaknesses. The discussion and initiatives identified in the response to item (3) above, and in NNECO's original response, to the calculation control process are equally applicable to this issue.

Minstone Station / Unit 3 Third Quarter Performance Report

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Status on Findings in the S&L Final R port Page S of 9 l

S. "FSAR sections regarding filtration system compilance to RG 1.52, Revision 2, are incomplete and should be revised to more clearly define the systems DB/LB."

NNECO Response:

NNECO had focused on this area of ICAVP findings prior to the issuance of either of the Sargent and Lundy reports, and fully recognized that it represented the area at greatest deviation from the unit's FSAR. NNECO understards the regulatory requirements in the filtration system area and has an adequate process in place to control future changes such that continued compliance is l ensured. Our actions to review and, as appropriate, correct any and all discrepant descriptions of filtration system features contained in FSAR Table 1.8-1 and Section 6.5, are currently being formulated and scheduled. This includes a search for compliance issues relating to the Regulatory Guide and related ANSI Standards N509 and N510. Confirmed Level 3 DRs have been addressed and corrected, as appropriate.

6. "DBSDs for the HVAC systems should be revised to more clearly define the O

systems DB/LB, particularly exceptions to minor requirements of RG 1.52 and ANSIN509 and N510 standards."

4 NNECO Response:

NNECO has recognized the need for improvement within the HVAC-related DBSDs. As in the case of the filtration systems discussed above, we are formulating a plan and schedule for completion of this review.

O Millstone Station / Unit 3 T!iM Quarter Performance Report

Status on Findings in ths S&L Final Report Page 6 of 9 f~ 7. " Inconsistencies between the cable and raceway database (TSO2) and electrical design documents related to cable tray cover data and conduit support data (greater than 200 occurrences were identified). The high number of discrepancies indicate the data containedin the databases may rot be accurate and as such, the data should not be used as approved design input without prior verifications." i l

l NNECO Response:

As noted in our response to the ICAVP Final Report, sample audits of electrical design documents have provided reasonable assurance that design requirements contained in the plant drawing system match or are less conservative than the actual raceway installation in the field.

. The level 4 DR's addressing discrepancies between the Cable Raceway Database and electrical design documents have been included in the " binned" l status. These level 4 DR's are being dispositioned in accordance with the

commitments in the Backlog Management Plan. As these items are l dispositioned, any trends that are confirmed will be subject to additional l

corrective actions in accordance with the NNECO Corrective Action Program.

A G 8. " Undocumented attachments to supports (approximately 42 occurrences).

l Although, none of the undocumented attachments affected the structural l adequacy of the support and many resulted from original design and construction, the findings indicate NU should review their control mechanism to prevent recurrence."

l l NNECO Response:

l NNECO agreed in our response to the ICAVP Final Report that the high number of findings in this area is indicative of the need for a better control of l documentation to prevent recurrence.

During the construction of the, olant, attachments to supports were controlled by the design process. As a res it, a large number (in the thousands) of change documents were produced tc document changes such as these. NNECO revievd a namber of DRn where Sargent and Lundy had identified undocumented a:tachments. M informal review of 42 identified undocumented

! attachments was conducted. This review revealed that 37 instances had adequate documerJation to justify the attachment. Based on this review, NNECO expects that a number of the DRs which identify undocumented attachments will, upor formalization of this work, be resolved using existing documentation. Any remaining attachments with missing documentation and

~

Millstone Station / Unit 3 Third Quarter Performance Report

L Status on Findings in ths S&L Final Report Page 7 of 9 other discrepant issues will be addressed and corrected as necessary to support future work activities.

NNECO has reviewed the present design control process included in the Design Control Manual and has determined that the existing process contains sufficient guidance to minimize the potential for incorporation of uncontrolled attachments to supports on a going fonvard basis. The existing design control process also includes the requirement for a detailed walkdowns in accordance with the Design Control Manual in advance of the incorporation of changes to affected supports.

This will serve to ensure a proper starting point is established for future changes.

NNECO will review the DRs related to this issue and disposition these items in accordance with the Corrective Action Program, as part of the Backlog Management Plan, and the current commitment to address all Level 4 DRs.

NNECO thus considers this item of the Final Report to have been addressed, negating the need for future quarterly status report.

9. " Component tagging / labeling issues (approximately 160 occurrences).

Additional controls to prevent mislabeling / tagging should be considered."

NNECO Response:

O in our response to the ICAVP Final Report, NNECO agreed that improvements in the controls necessary to prevent mislabeling and/or tagging are appropriate.

Upon further review for improvement potential, it has become apparent that the March,1998, revision to the applicable procedure, Operations Procedure OA9, entitled System and Component Labeling, has accomplished the objectives identified by Sargent and Lundy, Foremost among these changes are the incorporation of INPO recommendations for in-Plant Posting of Protected Equipment and the requirement to " Ensure component identifications being used for a new label request, nr changes to component identifications, are the same as indicated on approved drawings, procedures, specifications, and Material Equipment and Parts List (MEPL)." The timing of this revision is such as to have not had any impact on past performance that was the subject of Sargent and Lundy's review which supported this recommendation. On a going forward basis, however, we have a high level of confidence that tagging and labeling will improve in fidelity with time. Thus, we have concluded that there are now suitable and effective methods specified for accomplishing and maintaining an accurate, complete and effective component labeling program. This program ensures that the unit minimizes human error relating to the identification of plant components, systems and facilities. NNECO thus considers this item of the Final Report to have been addressed, negating the need for any future status reporting.

Millstone Station / Unit 3 Third Quarter Performance Report

< s

l Status on Findings in th.s S&L Final Report Pago 8 of 9 O

O Operations & Maintenance and Testina Review (S&L Final Report. SL-5192. l Section 1.7.2.3.1)

10. "NU has reported that they believe that their current program for Heat Exchanger Testing meets the intent of the generic letter. S&L agrees with NU's assessenent, provided the agreed to enhancements are incorporated into the currentprogram." l NNECO Response:

NNECO is taking actions to enhance the program to address the items identified by Sargent and Lundy. Two discrepancy reports are involved in the issue of adequacy of testing of service water cooled heat exchangers.

The first discrepancy report (DR-MP3-0035) questioned the inspection criteria l required to be performed on the RSS heat exchangers. NNECO concurred with Sargent and Lundy and updated the related procedures and their bases document.

l The second discrepancy report (DR-MP3-1074) questioned NNECO's position

, on the baseline testing of all heat exchangers (excluding RSS). Sargent and Lundy reviewed a recent NNECO submittal to the NRC on Generic Letter 89-13 to clarify this requirement. This discrepancy was closed by Sargent and Lundy as a Level 4 discrepancy report.

Enhancements to the program are being tracked via the corrective action

program. NNECO will review the DRs related to this issue and disposition these l items in accordance with the Corrective Action Program, as part of the Backlog Management Plan, and the current commitment to address all Level 4 DP,s.

Therefore, NNECO considers this item of the Final Report to have been addressed.

l l

d Millstone Station / Unit 3 Third Quarter Performance Report

Status on Findings in the S&L Final Report l Page 9 of 9 l

General Conclusions (S&L Report Section 1.7.2.3.2)

11. "An overall observation regarding maintenance, surveillance / calibration, and testing and operations is that some of the processes in use place a l very high reliance on skIII and performance of individuals... While this 1 approach in and of itself does not take the plant outside the Design or l Licensing Basis, it does not provide some of the safeguards that a more procedure orprocess-driven approach would provide."

l NNECO Response:

The Master Manual effort at Millstone station is underway with eight (8) Master Manuals currently under development. Senior Management has endorsed this Action Plan for the Master Manuals. All Administrative Processes at Millstone will be revised and incorporated into the Master Manuals over the next two years.

l The Site Procedures and Process Steering Committee (SPPSC) has been meeting on a regular basis for over six months. This group reviews the processes and issues that Master Manual Program Owners have under their responsibility. The Program Owners are required to develop a Scoping Document that will capture all requirements for their particular program and then break these into " Key Elements."

From this, they will develop the Station and functional administrative procedures.

' The Site Procedures and Process Steering Committee has replaced the Process

! -Improvement Team because Senior Management recognized the duplication of duties between these two groups. The Site Procedures and Process Steering Committee facilitates and coordinates the Master Manual effort, provides coaching ,

l and support relative to its implementation and monitors overall progress.

l Each Master Manual has a responsible Executive Sponsor. The Executive Sponsors ensure that barriers in which the Program Owner has in the development and l implementation of their Master Manuals will be resolved and corrected. The Program Owner is also responsible in assembling a Functional Team. These Functional Teams consist of Subject Matter Experts within the different Units and departments who will help develop the procedures, guidelines and appropriate reference materials with the assistance of the Station Administrative Procedures Group.

Since the Master Manual effort at Millstone Station is well underway with eight (8) l Master Manuals currently under development, and Senior Management has endorsed this concept, NNECO considers, item 11 of the S&L Final Report Findings and Recommendations adequately addressed and as such subsequent updates are no longer necessary.

l Millstone Station / Unit 3 Third Quarter Performance Report l